AQUILA STEEL (S AFRICA) (PTY) LTD: MELETSE IRON ORE PROJECT Environmental Management Programme under the MPRDA, 2002

Locality: Remainder of the farm Donkerpoort 448KQ and Remainder of the farm Randstephne 455KQ, Thabazimbi; Limpopo Ref: 30/5/1/2/2/10071MR Date: 26 March 2014

Shangoni Management Services (Pty) Ltd

ENVIRONMENTAL MANAGEMENT PROGRAMME

AQUILA STEEL (S AFRICA) (PTY) LTD: MELETSE IRON ORE PROJECT

Locality: Remainder of the farm Donkerpoort 448KQ and Remainder of the farm Randstephne 455KQ, Thabazimbi; Limpopo

Departmental Ref No: 0/5/1/2/2/10071MR

DATE: Date: 26 March 2014 Unit C8, Block @ Nature 472 Botterklapper Street Pretoria

Office: + 27 (0)12 807 7036 Fax: +27 (0)12 807 1014

ENVIRONMENTAL IMPACT ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PROGRAMME

SUBMITTED FOR AN APPLICATION FOR A MINING RIGHT IN TERMS OF SECTION 39 AND OF REGULATIONS 50 AND 51 OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002, (ACT NO. 28 OF 2002) (the Act)

Shangoni Management Services (Pty) Ltd

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STANDARD DIRECTIVE

All applicants for mining rights are herewith, in terms of the provisions of Section 29 (a) and in terms of section 39 (5) of the Mineral and Petroleum Resources Development Act, directed to submit an environmental Impact Assessment, and an Environmental Management Programme strictly in accordance with the subject headings herein, and to compile the content according to all the sub items to the said subject headings referred to in the guideline published on the Departments website, within 30 days of notification by the Regional Manager of the acceptance of such application.

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PROJECT DETAILS

Department of Mineral Resources (DMR)

Reference No 0/5/1/2/2/10071MR

Project Title: Meletse Iron Ore Project

Project Number: AQU-TH-11-03-01

Compiled by: Shangoni Management Services

Date: 25 March 2014

Location: Remainder of the farm Donkerpoort 448KQ and Remainder of the farm Randstephne 455KQ, Thabazimbi; Limpopo

Technical Reviewer: Brian Hayes

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TABLE OF CONTENTS

PROJECT DETAILS ...... 5 TABLE OF CONTENTS ...... 6 LIST OF FIGURES ...... 10 LIST OF TABLES ...... 12 LIST OF APPENDICES ...... 14 REFERENCES ...... 16 DEFINITIONS ...... 18 ABBREVIATIONS ...... 20 EXECUTIVE SUMMARY ...... 21 SECTION 1 – ENVIRONMENTAL IMPACT ASSESSMENT ...... 26 Regulation 50 (a) ...... 26 1 .... Description of the baseline environment ...... 26 1.1 ...... Concise description of the environment on site relative to the environment in the surrounding area ...... 26 1.2 ...... Concise description of each of the existing environmental aspects both on the site applied for and in the surrounding area which may require protection or remediation ...... 100 1.3 ...... Concise description of the specific land uses, cultural and heritage aspects and infrastructure on the site and neighbouring properties/farms in respect of which the potential exists for the socio- economic conditions of other parties to be affected by the proposed mining operation ...... 101 1.4 ...... Annotated map showing the spatial locality and aerial extent of all environmental, cultural/heritage, infrastructure and land use features identified on site and on the neighbouring properties and farms ...... 113 1.5 ...... Confirmation that supporting documents in the form of specialist studies are attached as appendices ...... 115 2 .... The proposed mining operation ...... 116 2.1 ...... The mineral to be mined ...... 116 2.2 ...... The mining method to be employed ...... 116 2.3 ...... List of the main mining actions, activities, or processes...... 118 2.4 ...... Plan showing the location and aerial extent of the aforesaid main mining actions, activities, or processes as required to calculate the financial provision ...... 157 2.5 ...... Listed activities (in terms of the NEMA EIA Regulations) which will be occurring within the proposed project ...... 157 2.6 ...... Indication of the phases and estimated time frames in relation to the implementation of these actions, activities or processes and infrastructure ...... 161 2.7 ...... Confirmation if any other relevant information is attached as appendices ...... 163 3 .... The Potential Impacts ...... 164

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3.1 ...... List of the potential impacts, on environmental aspects separately in respect of each of the aforesaid main mining actions, activities, processes, and activities listed in the NEMA EIA Regulations ...... 164 3.2...... List of all potential cumulative environmental impacts ...... 165 3.3 ...... State specifically whether or not there is a risk of acid mine drainage or potential groundwater contamination associated with the mineral to be mined ...... 169 Regulation 50 (b) ...... 171 4 .... The alternative land use or developments that may be affected ...... 171 4.1 ...... Concise description of the alternative land use of the area in which the mine is proposed to operate . 171 4.2 ...... List and description of all the main features and infrastructure related to the alternative land uses or developments ...... 173 4.3 ...... Plan showing the location and aerial extent of the aforesaid main features of the alternative land use and infrastructure related to alternative land developments identified during scoping ...... 173 5 .... The Potential Impacts of the Alternative Land Use or Development ...... 175 5.1 ...... List of the potential impacts of each of the aforesaid main features and infrastructure related to the alternative land use or development and related listed activities ...... 175 5.2 ...... Description of all potential cumulative impacts of the main features and infrastructure related to the identified alternative land uses or developments ...... 175 Regulation 50 (c) ...... 177 6 .... Identification of potential social and cultural impacts ...... 177 6.1 ...... List of potential impacts of the proposed mining operation on the socio-economic conditions of other parties’ land use activities ...... 177 6.2 ...... Description of the cultural aspect that will potentially be affected, and describe the potential impact on such cultural aspect ...... 177 6.3 ...... Description of heritage features and the potential impact on such heritage feature ...... 177 6.4 ...... Quantification of the impact on the socio-economic conditions of directly affected persons, as determined by the findings and recommendations of a specialist report in that regard ...... 177 7 .... Assessment and evaluation of potential impacts ...... 182 7.1 ...... List of each potential impact identified in paragraphs 3 and 6 above ...... 182 7.2 ...... Concomitant impact rating for each potential impact listed in paragraph 7.1 above in terms of its nature, extent, duration, probability and significance ...... 208 7.3 ...... Indication of the phases and estimated time frames in relation to the potential impacts rated ...... 213 Regulation 50 (d) ...... 214 8 .... Identification of the alternative land uses which will be impacted upon ...... 214 9 .... Listed results of a specialist comparative land use assessment ...... 217 Regulation 50 (e) ...... 218 10 .. List of all the significant impacts as identified in the assessment conducted in terms of Regulation 50 (c) ...... 218

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Regulation 50 (f) ...... 220 11 .. Identification of interested and affected parties ...... 220 11.1 ...... Introduction ...... 220 11.2 ...... Objectives of the public participation process ...... 220 11.3 ...... The guidelines followed for the public participation process ...... 220 11.4 ...... Interested and affected parties database ...... 221 12 .. The Details of the Engagement Process ...... 226 12.1 ...... Advertisement ...... 226 12.2 ...... Site Notices ...... 229 12.3 ...... Written Notices ...... 234 12.4 ...... Public Meeting ...... 234 13 .. Details regarding the manner in which the issues raised were addressed ...... 256 An e-mail received from Patrick Benson on the 11th of February 2014...... 272 Regulation 50 (g) ...... 277 14 .. The appropriate mitigatory measures for each significant impact of the proposed mining operation277 14.1 ...... Adequacy of predictive methods utilised ...... 277 14.2 ...... Adequacy of underlying assumptions ...... 277 14.3 ...... Uncertainties in the information provided ...... 278 REGULATION 50 (h) ...... 283 15 .. Arrangements for monitoring and management of environmental impacts ...... 283 Regulation 50 (i) ...... 286 16 .. Technical and supporting information ...... 286 SECTION 2 – ENVIRONMENTAL MANAGEMENT PROGRAMME ...... 287 Regulation 51 (a) ...... 287 1 .... Description of environmental objectives and specific goals for mine closure ...... 287 1.1 ...... Environmental aspects that describe the pre-mining environment ...... 287 1.2 ...... Measures required to contain or remedy any causes of pollution or degradation or the migration of pollutants, both for closure of the mine and post-closure ...... 287 2 .... Description of environmental objectives and specific goals for the management of identified environmental impacts emanating from the proposed mining operation ...... 298 2.1 ...... List of identified impacts which will require monitoring programmes ...... 298 2.2 ...... List of the source activities that are the cause of the impacts which require to be managed . 298 2.3 ...... Management activities which, where applicable, will be conducted daily, weekly, monthly, quarterly, annually or periodically as the case may be in order to control any action, activity or process which causes pollution or environmental degradation ...... 298 2.4 ...... The roles and responsibilities for the execution of the monitoring and management programmes ...... 298 3 .... Description of environmental objectives and specific goals for the socio-economic conditions as identified in the social and labour plan ...... 299 3.1 ...... Human resources development plan ...... 299

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3.2 ...... Employment equity plan ...... 299 3.3 ...... Mine community development ...... 300 3.4 ...... Measures to address housing and living conditions ...... 300 3.5 ...... Processes pertaining to management of downscaling and retrenchment...... 301 4 .... Description of environmental objectives and specific goals for historical and cultural aspects ..... 304 4.1 ...... Environmental objectives and goals in respect of historical and cultural aspects identified in specialist studies conducted during the EIA phase ...... 304 Regulation 51 (b) ...... 305 5 .... Appropriate technical and management options chosen for each environmental impact, socio- economic condition and historical and cultural aspect in each phase of the mining operation ...... 305 5.1 ...... Actions, activities or processes, including any NEMA EIA regulation listed activities, which cause pollution or environmental degradation ...... 305 5.2 ...... Concomitant list of appropriate technical or management options chosen to modify, remedy, control or stop any action, activity, or process which will cause significant impacts on the environment, socio-economic conditions and historical and cultural aspects as identified ...... 305 6 .... Action plans to achieve the objectives and specific goals contemplated in Regulation 50 (a) ...... 306 7 .... Procedures for environmentally related emergencies and remediation ...... 317 7.1 ...... Fire management ...... 317 7.2 ...... Spillages removal ...... 317 8 .... Planned monitoring and environmental management programme performance assessment ...... 318 8.1 ...... Description of planned monitoring of the aspects of the environment which may be impacted upon ..... 318 8.2 ...... Provide a description as to how the implementation of the action plans contemplated in Regulation 51 (b) (ii) as described will be monitored as described in paragraph 6 of the EMP will be monitored ...... 318 8.3 ...... Frequency of proposed reporting for assessment purposes ...... 318 9 .... Financial provision in relation to the execution of the environmental management programme ... 319 9.1 ...... Plan showing the location and aerial extent of the aforesaid main mining actions, activities, or processes anticipated ...... 319 9.2 ...... Annual forecasted financial provision calculation ...... 319 9.3 ...... Confirmation of the amount that will be provided should the right be granted ...... 322 9.4...... The method of providing financial provision contemplated in Regulation 53 ...... 322 10 .. Environmental awareness plan (section 39 (3) (c)) ...... 323 11 .. Attachment of specialist reports, technical and supporting information ...... 324 12 .. Section 39 (4) (a) (iii), capacity to manage and rehabilitate the environment ...... 325 13 .. Undertaking ...... 327 14 .. Identification of the report ...... 328

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LIST OF FIGURES

FIGURE 1: REGIONAL LOCALITY MAP ...... 29 FIGURE 2: MAP INDICATING THE FARM PORTIONS DIRECTLY ADJACENT TO THE PROPOSED SITE ...... 30 FIGURE 3: SIMPLIFIED GEOLOGICAL MAP OF THE THABAZIMBI AREA ...... 31 FIGURE 4: TWO STRUCTURAL REGIONS OF THE LARGER THABAZIMBI AREA IN THE VICINITY OF THE ...... 34 FIGURE 5: PROFILE INDICATING THE SPACIAL RELATIONSHIP OF THE FOOTWALL ROCKS ...... 36 FIGURE 6: LITHOSTRATIGRAPHICAL PROFILE OF THE MIXED ZONE ...... 37 FIGURE 7: REGIONAL MAP IDENTIFYING THE PROJECT AREA STRUCTURALLY EVALUATED ...... 39 FIGURE 8: IDENTIFIED IRON ORE LODES INCLUDED IN THE RESOURCE STATEMENT AS WELL AS PROFILE (LINES AND THE RESOURCE DIMENSIONS INDICATED IN BLUE)...... 41 FIGURE 9: AVERAGE RAINFALL FROM 1935 - 2010 ...... 43 FIGURE 10: ANNUAL WIND SPEED DIRECTION ...... 51 FIGURE 11: TOPOGRAPHICAL LOCALITY MAP ...... 53 FIGURE 12: MAP ILLUSTRATING THE SOIL TYPES AT THE PROPOSED SITE ...... 55 FIGURE 13: VEGETATION UNITS OF THE PROPOSED SITE ...... 58 FIGURE 14: SENSITIVITY MAP ...... 60 FIGURE 15: QUATERNARY CATCHMENT ...... 79 FIGURE 16: THE LOCATION OF ALL THE SITES VISITED AND / OR SAMPLED. THE BLACK ARROWS INDICATE THE MAIN NON-PERENNIAL DRAINAGE LINES ...... 81 FIGURE 17: WATER LEVEL ELEVATION AND TOPOGRAPHY CORRELATION ...... 86 FIGURE 18: BAYESIAN INTERPOLATED GROUNDWATER LEVEL CONTOURS ...... 87 FIGURE 19: LOCALITIES RECORDED DURING THE MELETSE USER SURVEYS ...... 92 FIGURE 20: RESULTS OF GROUNDWATER USER SURVEY ...... 93 FIGURE 21: ENVIRONMENTAL FEATURES EXISTING AT THE PROPOSED SITE ...... 114 FIGURE 22: MINING PRODUCTION (*** SOURCE: AQUILA STEEL MINING WORKS PROGRAMME) ...... 117 FIGURE 23: STARTER PIT – PIT SHELL 29 (GREEN) WITH ORE BLOCKS (RED AND BLUE) ...... 120 FIGURE 24: PUSHBACK 2 – PIT SHELL 34 ...... 121 FIGURE 25: PUSHBACK 3 – PIT SHELL 45 ...... 122 FIGURE 26: FINAL PIT – PIT SHELL 61 ...... 123 FIGURE 27: MINE LAYOUT PLAN ...... 124 FIGURE 28: TYPICAL EFFLUENT TREATMENT PLANT LAYOUT ...... 131 FIGURE 29: CROCODILE RIVER SOUTHERN PIPE ROUTE (OPTION A) ...... 134 FIGURE 30: CROCODILE RIVER NORTHERN PIPE ROUTE (OPTION B) ...... 135 FIGURE 31: GENERAL RUNOFF ...... 138 FIGURE 32: RIVER WATER TREATMENT PROCESS ...... 140 FIGURE 33: BOREHOLE WATER TREATMENT PROCESS ...... 141 FIGURE 34: WATER BALANCE DIAGRAM FOR AQUILA (MONTHLY AVERAGE)...... 146 FIGURE 35: WATER BALANCE DIAGRAM FOR AQUILA (WET SEASON) ...... 147

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FIGURE 36: WATER BALANCE DIAGRAM FOR AQUILA (DRY SEASON) ...... 148 FIGURE 37: PROPOSED TRAFFIC ROUTE OPTIONS (***SOURCE: TRAFFIC IMPACT ASSESSMENT) ...... 153 FIGURE 38: PLAN SHOWING CURRENT INFRASTRUCTURE RELATED TO ALTERNATIVE LAND DEVELOPMENTS ... 174 FIGURE 39: IMPACT PREDICTION MODEL ...... 208 FIGURE 40: ADVERTISEMENT IN THE KWEVOEL ...... 227 FIGURE 41: ADVERTISMENT IN DIE POS ...... 228 FIGURE 42: SITE NOTICE IN THABAZIMBI TOWN ABSA BANK PARKING LOT ...... 229 FIGURE 43: SITE NOTICE ALMA/THABAZIMBI CROSSING ...... 230 FIGURE 44: SITE NOTICE AT THE CORNER OF ELAND STREET IN NORTHAM ...... 230 FIGURE 45: SITE NOTICE AT THE MODIMOLLE AND ROOIBERG ROAD ...... 231 FIGURE 46: SITE NOTICE AT THABAZIMBI LOCAL MUNICIPALITY OFFICES ...... 231 FIGURE 47: SITE NOTICE AT THE THABAZIMBI NG CHURCH ...... 232 FIGURE 48: SITE NOTICE AT THE THABAZIMBI POST OFFICE ...... 232 FIGURE 49: SITE NOTICE IN ROOIBERG TOWN ...... 233 FIGURE 50: SITE NOTICE AT AQUILA STEEL ENTRANCE GATE ...... 233 FIGURE 51: SITE NOTICE AT THABAZIMBI GYM ...... 234

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LIST OF TABLES

TABLE 1: LANDHOLDINGS UPON WHICH THE PROJECT WILL BE IMPLEMENTED ...... 26 TABLE 2: ADMINISTRATIVE AND WATER MANAGEMENT BOUNDARIES ...... 26 TABLE 3: DIRECTION & DISTANCE TO THE NEAREST TOWN(S) ...... 27 TABLE 4: SURFACE RIGHTS HOLDERS OF PROPERTIES ADJACENT TO THE PROPOSED SITE ...... 27 TABLE 5: GENERAL STRATIGRAPHY OF THE THABAZIMBI PROJECT AREA (MODIFIED AFTER SACS, 1980) ..... 32 TABLE 6: MAXIMUM RAINFALL IN 24 HOUR PERIOD IN 2010 ...... 42 TABLE 7: RAINFALL DATA FROM 1935-2010 ...... 44 TABLE 8: MEAN MONTHLY MAXIMUM AND MINIMUM TEMPERATURES ...... 48 TABLE 9: AVERAGE ANNUAL PRECIPITATION AND EVAPORATION ...... 48 TABLE 10: A LIST OF PLANT SPECIES CHARACTERISTIC OF THE WATERBERG MOUNTAIN BUSHVELD, CENTRAL AND WESTERN SANDY BUSHVELD VEGETATION TYPES...... 61 TABLE 11: THE SURFACE AREA (HA) OF EACH DEFINED VEGETATION UNIT IN RELATION TO THE PROPOSED STUDY SITE ...... 62 TABLE 12: RED DATA AND ORANGE LISTED PLANT SPECIES LIKELY TO OCCUR ON THE STUDY SITE BASED ON THE OCCURRENCE OF SUITABLE HABITAT ...... 63 TABLE 13: A LIST OF WEEDS AND INVADER PLANT SPECIES IDENTIFIED ON THE STUDY SITE...... 65 TABLE 14: RED DATA SPECIES FOUND IN THE AREA ...... 66 TABLE 15: VULNERABLE BIRD SPECIES IN THE AREA ...... 66 TABLE 16: EXPECTED AND OBSERVED HERPETOFAUNA DURING THE SITE SURVEY ...... 73 TABLE 17: FLOOD PEAKS AND VOLUMES ...... 80 TABLE 18: PRESENT ECOLOGICAL STATUS CLASSES ...... 81 TABLE 19: SITES MONITORED DURING THE STUDY ...... 82 TABLE 20: CONCENTRATIONS OF INDICATOR CHEMICAL PARAMETERS OF THE REGIONAL SAMPLING LOCALITIES FOR MELETSE (MG/L) ...... 84 TABLE 21: SUMMARY OF HYDROCENSUS AND GROUNDWATER USER SURVEY ...... 88 TABLE 22: ATMOSPHERIC DEPOSITION RESULTS (MG/M²/DAY) AT AQUILA IRON SITE: JUNE 2011 TO JULY 2012

TAKEN FROM THE ATMOSPHERIC DEPOSITION MONITORING REPORT COMPILED BY AIRSHED PLANNING PROFESSIONALS...... 94 TABLE 23: TYPICAL RATING LEVELS FOR AMBIENT NOISE IN DISTRICTS ...... 96 TABLE 24: TYPICAL RATING LEVELS FOR AMBIENT NOISE IN DISTRICTS ...... 97 TABLE 25: THABAZIMBI MUNICIPALITY POPULATION STATISTICS (CENSUS 2011) ...... 105 TABLE 26: AGE DISTRIBUTION ...... 105 TABLE 27: EDUCATION LEVEL FOR THABAZIMBI MUNICIPALITY ...... 106 TABLE 28: ECONOMIC STATUS OF THABAZIMBI LABOUR FORCE POPULATION (CENSUS 2011) ...... 110 TABLE 29: HOUSING AVAILABLE IN THE THABAZIMBI URBAN NODE ...... 111 TABLE 30: MELETSE IRON ORE RESOURCE ...... 116 TABLE 31: MELETSE IRON ORE RESERVE AND SALEABLE PRODUCT @62%FE ...... 117

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TABLE 32: ACTIVITIES APPLIED FOR...... 129 TABLE 33: SUB CATCHMENT AREAS ...... 133 TABLE 34: DAILY DOMESTIC WATER DEMAND...... 139 TABLE 35: WATER DEMAND FOR INFRASTRUCTURE AND FIRE PROTECTION ...... 141 TABLE 36: WATER BALANCE INFORMATION AND ASSUMPTIONS...... 144 TABLE 37: ESTIMATED BUILDING REQUIREMENTS ...... 155 TABLE 38: EIA LISTED ACTIVITIES TRIGGERED ...... 158 TABLE 39: CUMULATIVE IMPACTS ...... 165 TABLE 40: POTENTIAL IMPACTS OF MAIN FEATURES AND INFRASTRUCUTE RELATED TO THE ALTERNATIVE LANDUSE ...... 175 TABLE 41: POTENTAIL CUMULATIVE IMPACTS ON MAIN FEATURES AND INFRASTRUCTURE ...... 175 TABLE 42: ALTERNATIVE LAND-USE ANALYSIS 18 YEARS (2013 RAND VALUES) ...... 178 TABLE 43: GDP ADDITION UNDER DIFFERENT LAND-STERILISATION SCENARIOS ...... 178 TABLE 44: POTENTIAL JOBS CREATED OR LOST ...... 179 TABLE 45: DETERMINATION OF PROBABILITY OF IMPACT ...... 209 TABLE 46: DETERMINATION OF MAGNITUDE OF IMPACT ...... 210 TABLE 47: DETERMINATION OF SEVERITY OF IMPACT ...... 213 TABLE 48: IMPACT ASSESSMENT SCENARIO ...... 214 TABLE 49: ALTERNATIVE LAND-USE ANALYSIS 18 YEARS (2013 RAND VALUES) ...... 215 TABLE 50: GDP NET DIFFERENCE BETWEEN THE PROPOSED MINE AND ECO-AGRICULTURE ALTERNATIVE LAND- USES ...... 217 TABLE 51: INTERESTED AND AFFECTED PARTIES (INCLUDING ADJACENT LANDOWNERS)...... 221 TABLE 52: STAKEHOLDER DETAILS ...... 224 TABLE 53: PUBLIC MEETING MINUTES ...... 234 TABLE 54: COMMENTS AND RESPONSES REPORT ...... 256 TABLE 55: ANNUAL FORECAST FINANCIAL PROVISION ...... 320 TABLE 56: REHABILITATION COST ESTIMATE ...... 325 TABLE 57: FINANCIAL PROVISION CALCULATIONS AS PER DMR REQUIREMENTS ...... 325

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LIST OF APPENDICES

APPENDIX A: PROJECT TEAM PROFILES

APPENDIX B - SITE PLANS Appendix B1 - Locality Map Appendix B2 – Mine layout Map

APPENDIX C - GOVERNMENT CORRESPONDENCE Appendix C1 – Acknowledgment letter from DMR

APPENDIX D - PUBLIC PARTICIPATION Appendix D1 - Public participation process Appendix D2 - IAP Register Appendix D3 - IAP notification letter Appendix D4 - Newspaper advert Appendix D5 - Site notice Appendix D6 - Invitation to public meeting Appendix D7 – Minutes, attendance register and presentation of the public meeting Appendix D8 - Comments received from IAPs Appendix D9 – Guidelines to conducting PPP

APPENDIX E – SPECIALIST STUDIES Appendix E1 - An ecological evaluation for the Aquila Steel project, Thabazimbi Appendix E2 - Aquila Steel Meletse Iron Ore Project: Report on geohydrological investigation as part of the EIA and EMP. Appendix E3 - Paleontological Assessment: Site Visit Report. Gatkop cave on farm Randstephne 415 KQ near Thabazimbi, Limpopo province Appendix E4 - Cultural heritage resources essay for the farms Donkerpoort 448 KQ, Randstephne 455KQ and Waterval 443KQ, Limpopo province Appendix E5 - Assessment of the bats at Gatkop Cave, and possible mitigation measures. Appendix E6 – Storm water management plan Appendix E7 – Air Quality impact specialist study Appendix E8 - Noise study Appendix E9 - Visual impact assessment report Appendix E10 - The Ecological Integrity of the aquatic habitat at the proposed Aquila Steel mine on the Farms Donkerpoort 448KQ and Randstephne 455KQ, Thabazimbi district, Limpopo Province, South Africa.

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Appendix E11 - Environmental Impact Assessment: Ground Vibration and Air Blast Study Aquila Steel (Pty) Ltd. Meletse Project Appendix E12 - Traffic impact study Appendix E13 - Economic impact study

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REFERENCES

AGIS - Comprehensive Atlas, Agricultural Geo-Referenced Information System, www.agis.agric.za/agisweb/agis.html.

Constitution of South Africa, 1996 (Act No. 108 of 1996).

National Environmental Management Act, 1998 (Act 107 of 1998).

Aquila Meletse. 2012. Social and Labour Plan.

Aucamp, S. 2011. Ptersa. Social Scoping Report.

Almond, J 2012. Paleontological Assessment: Site Visit Report. Gatkop cave on farm Randstephne 415 KQ near Thabazimbi, Limpopo Province

Du Plessis, W., 2014 Groundwater complete Aquila Steel Meletse Iron Ore Project: Report on geohydrological investigation as part of the EIA and EMP,

Friedmann, Y. & Daly, B. 2004. Red Data Book of the Mammals of South Africa: A Conservation Assessment. CBSG South Africa, Conservation Breeding Specialist Group (SSC/IUCN), Endangered Wildlife Trust, South Africa.

Henning, G.A., Terblanche, R.F. & Ball, J.B. (eds.) 2009.South African Red Data Book: butterflies. SANBI Biodiversity Series 13.South African National Biodiversity Institute, Pretoria.

Kearney, T. & Seamark, E. 2012. Africanbats.org. Assessment of the bats at Gatkop Cave, and possible mitigation measures.

Kornelius, G. 2012. Airshed Planning Professionals Pty Ltd Atmospheric deposition monitoring at the Aquila iron site, Thabazimbi Report: Jun 2011 to July 2012.

Meletse Iron Ore Project Conceptual Revision Study 2013 done for Aquila Steel.

Meyer C. F. 2011. Varicon CC. Environmental Noise Survey Report. April 2011 – February 2012.

Miller, S. 2011. Cultural Heritage Resources Assay for the farms Donkerpoort 448 KQ, Randstephne 455 KQ and Waterval 443 KQ, Thabazimbi, Limpopo Province

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Muller, G. 2012. Strategy for Good: Aquila Meletse Alternative land-use initial economic impact assessment

Oberholzer, B. 2005. Guideline for involving visual & aesthetic specialists in EIA processes: Edition 1. CSIR Report No ENV-S-C 2005 053 F. Republic of South Africa, Provincial Government of the Western Cape, Department of Environmental Affairs & Development Planning, Cape Town

Pachnoda Consulting CC. 2011. An Ecological Evaluation for the Aquila Steel Project Thabazimbi.

Resource Estimation Update of the Meletse Iron Ore Deposit – December 2012.

Seamark, E.C.J., Correction and update of distribution data for Cloeotis percivali Thomas, 1901 (Chiropters: Rhinolophidae: Hipposidernae) in southern Africa. African Bat conservation News 4: 3-5. Steenkamp G. 2012.

Wiesel, I., Maude, G., Scott, D. & Mills, G. 2008. Hyaena brunnea. In: IUCN 2010. IUCN Red List of Threatened Species. Version 2010.4.http://www.iucnredlist.org/

Zeeman, J D. 2012. Blasting management and consulting. The Ecological Integrity of the aquatic habitat at the proposed Aquila Steel mine on the Farms Donkerpoort 448KQ and Randstephne 455KQ, Thabazimbi district, Limpopo Province, South Africa

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DEFINITIONS

Environment: The surroundings (biophysical, social and economic) within which humans exist and that are made up of:  The land, water and atmosphere of the earth;  Micro organisms, plant and animal life;  Any part or combination of (i) and (ii) and the interrelationships among and between them; and  The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and wellbeing.

Environmental aspects: Environmental aspects are elements of an organisation’s activities, products or services that can interact with the environment.

Environmental degradation: Refers to pollution, disturbance, resource depletion, loss of biodiversity, and other kinds of environmental damage; usually refers to damage occurring accidentally or intentionally as a result of human activities.

Environmental impacts: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s activities, products or services.

Environmental impact assessment: An EIA is a study of the environmental consequences of a proposed course of action.

Environmental impact report: A report assessing the potential significant impacts as identified during the environmental impact assessment.

Environmental impact: An environmental change caused by some human act.

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Land use: Land use is the various ways in which land may be employed or occupied. Planners compile, classify, study and analyse land use data for many purposes, including the identification of trends, the forecasting of space and infrastructure requirements, the provision of adequate land area for necessary types of land use, and the development or revision of comprehensive plans and land use regulations.

Pollution prevention: This is any activity that reduces or eliminates pollutants prior to recycling, treatment, control or disposal.

Public participation process: A process of involving the public in order to identify needs, address concerns, in order to contribute to more informed decision making relating to a proposed project, programme or development.

Topography: Topography is a term in geography, referring to the "lay of the land” or the physio-geographic characteristics of land in terms of elevation, slope and orientation.

Vegetation: Vegetation is all of the plants growing in and characterising a specific area or region; the combination of different plant communities found there.

Waste: Waste is unwanted or undesired material left over after the completion of a process. "Waste" is a human concept: in natural processes there is no waste, only inert end products.

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ABBREVIATIONS

AADD Average Annual Daily Demand BID Background Information document

DARDLA Department of Agriculture, Rural Development and Land Administration

DMR Department of Mineral Resources

EIA Environmental impact assessment EMP Environmental management programme ESR Environmental scoping report

HIA Heritage impact assessment

IWULA Integrated water use licence

IAPs Interested and affected parties

LoM Life of Mine MPRDA Minerals and Petroleum Resources Development Act no 28 of 2002 LEDET Limpopo Economic Development, Environment and Tourism MWP Mining works programme MPDWA Mpumalanga Department of Water Affairs NEMA National Environmental Management Act no 107 of 1998 NEMBA National Environmental Management: Biodiversity Act no 10 of 2004 NEMWA National Environmental Management: Waste Act no 59 of 2008 NWA National Water Act no 36 of 1998

WDM Waterberg District Municipality

PPP Public participation process

PCD Pollution control dam

RoM Run-of-mine

SIA Social impact assessment

SLP Social and labour plan

SAHRA South African Heritage Resource Agency

TLM Thabazimbi Local Municipality

WRD Waste rock dump

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EXECUTIVE SUMMARY

The Applicant Aquila Steel (S Africa) (Proprietary) Limited (Aquila), a wholly owned subsidiary of Aquila Resources Limited, a company listed on the Australian Stock Exchange, holds a 74 per cent interest in the Meletse Iron Ore Project in the Limpopo Province of South Africa (“the Project”). The Project covers 2 adjacent farms, which are covered in two separate prospecting right areas granted to Aquila by the Department of Mineral Resources. Since the grant to Aquila of the prospecting right, Aquila has prospected extensively and has completed a prospecting drilling programme that has delineated an extensive high grade hematite (iron ore) resource that has been upgraded to a code compliant resource of 80.8Mt at 61.1%Fe. The project is located approximately 30km east of the town of Thabazimbi in the Limpopo Province and in the proximity of the existing Thabazimbi Iron Ore mine and approximately 10km south of the Marakele National Park.

Background description Aquila holds the prospecting rights to the Meletse iron ore deposit located near the town of Thabazimbi in the Limpopo Province of South Africa. Prospecting of iron ore was conducted at the Klipgat LP613 and Donkerpoort LP1301 tenement, and this project is referred to as the Meletse Iron Ore Project. An opencast iron ore mine with an estimated Life of Mine (LoM) of 18 years is proposed on the remainder of the farm Donkerpoort 448KQ and the remainder of the farm Randstephne 455KQ. In addition to the opencast mining operation it is proposed that a beneficiation plant also be constructed and operated. Aquila owns the surface rights of the said farm portions. Currently there are no mining activities taking place on the site.

This environmental management plan (EMP) is compiled to fulfil the requirements as set out in Section 37 and 38 of the Minerals and Petroleum Resources Development Act no 28 of 2002 (MPRDA) and regulations 48 and 49 of the Mineral and Petroleum Resources Development Regulations, GNR 527 of 2004 (MPRDR) in terms of the MPRDA. This EMP shall be submitted to the Limpopo Department of Mineral Resources (DMR).

Aquila engaged with the public through four pre-consultation information sessions. The information sessions were held on the 30th of July 2011, 2nd of December 2011, 10th of March 2012 and on the 1st of February 2014. The purpose of these information sessions was:  to provide the adjacent landowners with available project information, i.e. the proposed activities at the time and the process to be undertaken;  to establish a platform for future engagement between Aquila and the adjacent landowners;  to inform the adjacent landowners of the specialist studies to be conducted;  to identify needs for both the Aquila and the adjacent land owners, during the initial project phase; and

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 Allow the public, stakeholders and organs of state the opportunity to ask questions on the project.

Identified impacts The activities associated with the project are described in full in Sub-section 2 and the anticipated and /or actual impacts of the project are described in Sub-section 7. In this report, only the impacts related to the activities applied for in this application will be dealt with. These impacts are summarised as follow:  Disturbance of fauna and flora species;  Disturbance of Sensitive landscapes;  Visual impacts of proposed infrastructures as well as the proposed waste rock overburden and discard dumps;  Soils erosion;  Siltation of watercourses(drainage lines);  Dust generation  Loss of land use and land capability and;  Establishment of invader plants.

In addition to the mining right application, an environmental impact assessment (EIA) in terms of the National Environmental Management Act no 107 of 1998 (NEMA) will be conducted and submitted to Limpopo Economic Development, Environment and Tourism (LEDET) and an integrated water use license (IWULA) in terms of the National Water Act no 36 of 1998 (NWA) will be compiled and submitted to the Limpopo Department of Water Affairs (DWA). These three processes run parallel and one integrated Public Participation Process (PPP) is conducted. The PPP officially commenced on 1 February 2014. This EMP will be made available to all stakeholders and registered interested and affected parties (IAPs) during the course of the PPP.

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MPRDA Environmental Process and timeline

Schedule Process Steps

Mining Rights

application Phase:

 Mining Works  Submission of Mining Rights Application July 2013 Programme (MWP)  Acknowledgement letter from DMR and go-ahead  Mining Rights received Application

Scoping Phase:

 Compile ESR  Information gathering and consultation with applicant  Submit ESR to DMR October  Compile ESR 2013  Submit ESR to DMR (as per due dates provided in letter) (26 October 2013)

EMP Phase:  Further investigations as indicated in ESR

 Further Investigations  Conducting of EIA

 EIA  Notification of I&AP’s and Stakeholders of the October  Consultation with process and application 2013 to I&APs and  Compilation of EMP in terms of MPRDA Februar Stakeholders  Submission of EMP to DMR (26 March 2014) y 2014  EMP

Current Status

Layout of this document This document comprises of an Environmental Impact Assessment (EIA) section and an Environmental Management Plan (EMP) section. Section 1 (EIA) is divided into sixteen (16) paragraphs in accordance with Regulation 50(a) to Regulation 50(i) of the MPRDA. Section 2 (EMP) is divided into fourteen (14) paragraphs in accordance with Regulation 51(a), Regulation 51(b) and Section 39 of the MPRDA.

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Sub-section 1 of Section 1 (EIA) is a description of the present environmental background. Sub- section 2 is a description of all proposed mining operations. Sub-section 3 is a list of all potential impacts including cumulative impacts. These three sub-sections are in accordance with Regulation 50(a) of the MPRDA. Sub-section 4 considers alternative land uses or developments that may be affected and sub-section 5 lists the potential impacts in the case of alternative land use or developments taking place. This sub-section also includes the cumulative impacts of such land use or development. These two sub-sections are in accordance with Regulation 50(b) of the MPRDA.

Sub-section 6 is an identification of potential social and cultural impacts. This sub-section includes the quantification of the impacts on the socio-economic conditions. Sub-section 7 is a combination of sub- section 3 and 6 with the significance rating included, and also describes the method for significance rating as well as the impact phases associated with the mine. These two sub-sections are in accordance with Regulation 50(c) of the MPRDA. Sub-section 8 is an identification of alternative land uses that will be impacted upon and sub-section 9 indicates any results from a specialist on comparative land use assessment. These two sub-sections are in accordance with Regulation 50(d) of the MPRDA. Sub-section 10 is a list of all significant impacts identified in sub-section 7, which is in accordance with Regulation 50(e) of the MPRDA.

Sub-section 11, 12 and 13 is a detailed discussion of public participation that has taken place. These three sub-sections are in accordance with Regulation 50(f). Sub-section 14 is a description of the appropriateness of the assessment. This includes the adequacy of the predictive methods, underlying assumptions and any uncertainties in the information. This sub-section is in accordance with Regulation 50(g) of the MPRDA. Sub-section 15 is a detailed description of monitoring and in accordance with Regulation 50(h). Sub-section 16 is a list of additional information relevant to Section 1 (EIA) attached to this document.

Sub-sections 1 to 4 of Section 2 (EMP) are descriptions of environmental objectives and specific goals for mine closure, management of identified impacts, socio-economic conditions and historical and cultural aspect. These four sub-sections are in accordance with Regulation 51(a) of the MPRDA. Sub-section 5 is a complete description of the mitigation and management measures, sub-section 6 lists all action plans to achieve the objectives and specific goals, sub-section 7 lists all emergency procedures, sub-section 8 is a description of monitoring and environmental performance assessment, and sub-section 9 gives detail on the financial provision related to the impacts and mitigations assessment. These five sub-sections are in accordance with Regulation 51(b).

Sub-section 10 is a description of the environmental awareness plan, and sub-section 12 is the capacity of the mine to manage and rehabilitate. These two sub-sections are in accordance with Section 39 of the MPRDA. Sub-section 11 is a list of additional information relevant to Section 2 (EMP) attached to this document, sub-section 13 is the undertaking and sub-section 14 is an identification of the report.

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Applicant

Applicant Aquila Steel (S Africa) (Proprietary) Limited

Postnet Suite 317 Private Bag X 75 Postal Address Bryanston 2021

Responsible Person Mr. Michael Halliday

Telephone Number 011 463 1340

Facsimile Number 011 514 0441

Cell Phone Number 27 82 655 3401

E-Mail Address [email protected]

Company Registration No. 2005/021254/07

Appointed Environmental Assessment Practitioner

Name of firm Shangoni Management Services

PO Box 74726 Postal address Lynnwood Ridge 0040

Telephone No. 27 (0)12 807 7036

Fax 27 (0)12 807 1014

E-mail [email protected]

Team of Environmental Assessment Practitioners on project

Name Qualifications Responsibility

BSc Hons Environmental Nomkhosi Mohlahlo EAP Management

Leeanne Fellows B-Tech Nature Conservation Project manager

Jan Nel MSc Environmental Management Technical reviewer

B Eng (Chemical), MSc Brian Hayes Quality reviewer Environmental Engineering,

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SECTION 1 – ENVIRONMENTAL IMPACT ASSESSMENT

Regulation 50 (a)

1 Description of the baseline environment

1.1 Concise description of the environment on site relative to the environment in the surrounding area

1.1.1 Regional background An opencast iron ore mine is proposed on the remainder of the farms Donkerpoort 448KQ and Randstephne 455KQ located within the Thabazimbi local municipal area of Waterberg district, in the Limpopo province. Refer to Figure 1 for a regional locality map of the proposed mine. The property sizes and title deeds are given in Table 1 below.

Table 1: Landholdings upon which the project will be implemented FARM NO. EXTENT TITLE DEED Remainder of the Farm Donkerpoort No. 448 KQ - T28163/1986 Remainder of the Farm Randstephne No. 455 KQ - T14383/2011 TOTAL 1563,4310ha

Table 2 below provides information on water management boundaries while Table 3 gives a list of towns closest to the proposed site.

Table 2: Administrative and water management boundaries Province Limpopo District Municipality Waterberg District Municipality Local Municipality Thabazimbi Local Municipality Department of Mineral Resources (DMR) Local Office Limpopo Region Department of Water Affairs (DWA) Local Office Limpopo Region Department of Economic Development, Limpopo Region Environmental Affairs and Tourism Catchment Zone Limpopo River Catchment area Water Management Area A24H quaternary catchment area.

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Table 3: Direction & distance to the nearest town(s)

Distance Direction from site Closest town

±27 West Thabazimbi

±76 East Modimolle

±70 South east Bela-Bela

1.1.1.1 Land tenure and use of immediately adjacent land Immediate adjacent land is utilised for agricultural activities. Agricultural activities in the area can be divided into three broad categories, namely irrigation farming, dry land crop production and cattle and game farming. Crops produced in the area include wheat, soya, maize, cotton, sunflower, sorghum, red pepper and a variety of fruit and vegetables. Livestock include cattle, goats, pigs and game.

The surface owners of the farm portions immediately adjacent to the proposed site are listed in Table 4 below and the neighbouring farms are illustrated in Figure 2.

Table 4: Surface rights holders of properties adjacent to the proposed site Portion Farm name Owner 5 Rookpoort 450 MJ Raath 4 Buffelshoek 446 E.B Nieuwoudt 16 Buffelshoek 446 E.B Nieuwoudt 17 Buffelshoek 446 E.B Nieuwoudt 18 Buffelshoek 446 E.B Nieuwoudt 19 Buffelshoek 446 E.B Nieuwoudt 21 Buffelshoek 446 E.B Nieuwoudt 22 Buffelshoek 446 E.B Nieuwoudt 23 Buffelshoek 446 E.B Nieuwoudt 28 Buffelshoek 446 E.B Nieuwoudt

0 Rebelsig E B Shelf Inv No 166 Pty Ltd 5 Zandrivierspoort 442 Chris van Rooyen 6 Zandrivierspoort 442 Dr A Martin 6 Rookpoort 450 MJ Raath 10 Donkerpoort 448 Jan Coetzer 3 Buffelshoek 446 Alwyn Hefer Trust 15 Buffelshoek 446 Calshelf Inv 173 Pty Ltd 2 Buffelshoek 446 E.B Nieuwoudt 20 Buffelshoek 446 Calshelf Inv 173 Pty Ltd 0 Donkerpoort 448 Aquila Steel 2 Meletse 697 Louis van der Walt 11 Meletse 697 Louis van der Walt 1 Meletse 699 Jonker Family Trust

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Portion Farm name Owner 3 Donkerpoort 448 Dr Andre van Coller 11 Donkerpoort Tony Visser Buffelskloof 452 Staat verdrag 10 Waterval 443 Mr Piet Venter

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Figure 1: Regional locality map

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Figure 2: Map indicating the farm portions directly adjacent to the proposed site

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1.1.2 Geology The following section was compiled using: “Resource Estimation Update of the Meletse Iron Ore Deposit – December 2012.

1.1.2.1 Regional geology The proposed mining sites fall in the Transvaal sub-basin of the Limpopo Province. The principal commodity being sought is iron ore (Fe). Structural deformation on the Thabazimbi area has caused the Chuniespoort Group sediments to dip south at 50⁰ to 60⁰ and thrust repeat the BIF sequences. Refer to Figure 3 for the geology of the area and site.

The Meletse iron ore deposit is developed in Banded Iron Formation (BIF) of the Transvaal Supergroup. The Transvaal Supergroup rocks were deposited in an open marine sedimentary basin developed on the Kaapvaal Craton in depositional environments which varied from fluvial, through deltaic to marine. Figure 3 depicts the regional geology and of the major thrust faults in the Thabazimbi area, defining mountain ranges that strike approximately east – west.

Figure 3: Simplified geological map of the Thabazimbi area

These rocks unconformably overlie an Archean Basement of granite-gneiss and are intruded by rocks of the Proterozoic Bushveld Complex. The Transvaal Supergroup is thought to attain a thickness in excess of 12 kilometres in the Transvaal sub-basin, although true thickness is affected by over- thrusting that has repeated the stratigraphy in the Thabazimbi area. The Transvaal Supergroup in the Thabazimbi region is subdivided into six major units:

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 Loskop Formation,  Rooiberg Group,  Pretoria Group,  Chuniespoort Group,  Black Reef Quartzite,  Buffalo Springs Group.

Refer to Table 5 below for the Transvaal Supergroup’s major stratigraphic units.

Table 5: General Stratigraphy of the Thabazimbi Project Area (Modified after SACS, 1980) AGE SUPERGROUP/ LITHOLOGY FORMATION GROUP/SUBGROUP (Ga) COMPLEX Clastic Waterberg Group Sediments Mafic Bushveld 2.06 Lithologies - Complex dominant

Mokolian Clastic 2.224 Pretoria Group Sediments Banded Iron Penge 2.43 Formation Formation Chuniespoort Transvaal Malmani Group Supergroup 2.58 Dolomite Subgroup Black Reef

Quartzite Formation Wolkberg Group

Vaalian

Granite - Makoppa 3.1+ Gneiss Dome

Swazian

1.1.2.1.1 Buffalo Springs Group Comprises of fluvial sandstones and quartzites unconformably overly the Archaean greenstone belts and form the basal unit of the Transvaal Supergroup. Mafic and felsic volcanic rocks along with interflow cherts represent the top of this stratigraphic unit.

1.1.2.1.2 Black Reef Quartzite Consist of quartzite and quartz sandstone. The conglomerate is developed at the base of this unit, where it rests on older basement, can be gold (Au) bearing.

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1.1.2.1.3 Chuniespoort Group The Black Reef Quartzite grades up through a transition zone of iron and manganese-rich dolomite, carbonaceous shale and quartzite into Malmani Subgroup. The Malmani subgroup comprises formation of dolomites and limestone with distinct chert-rich and chert-poor units. The uppermost unit is the Frisco Formation, which grades upwards from chert breccia, shale, chert-poor dolomite and limestone with shale and BIFs increasing towards the gradational contact with the overlying Penge Iron Formation. The Penge iron Formation is composed of BIF and carbonaceous shale.

1.1.2.1.4 Pretoria Group The Pretoria group consists of clastic sediments and volcanics that unconformably cut across the chemical sedimentary sequences of the chuniespoort group. Chert breccia and conglomerate occur at the base passing up into a marine sedimentary assemblage of quartzite, shale, sandstone and carbonate. Mafic-intermediate volcanic occurs at various intervals in the stratigraphic sequence.

1.1.2.1.5 Rooiberg Group Composed mainly of rhyolitic volcanics up to 3000m thick with minor sedimentary interbeds.

1.1.2.1.6 Loskop formation Consist of clastic red bed sediments, sandstone and shale. It also includes rhyolite flows and basalt. The regional linear trends of the larger Thabazimbi area were evaluated and a distinct difference was identified between areas where known iron ore deposits are developed and sterile areas. In the Kumba Mining area as well as in vicinity of the Meletse Range two weakly defined linear trends dominate; while only a single trend dominates in the remaining areas (Figure 4).

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Figure 4: Two structural regions of the larger Thabazimbi area in the vicinity of the Northern rim of the Transvaal Basin based on regional linear trends.

Precambrian banded iron formations (BIF’s) are host to the majority of the world’s high- grade iron resources. The formation of high- grade iron ores from a BIF protolith requires essentially the effective enrichment of iron, at the expense of SiO₂. This process is typically associated with the transformation of all iron bearing minerals of the BIF into hematite and martite, accompanied by minor amounts of magnetite, keno magnetite and goethite.

A number of recent studies investigating the origin of high – grade iron ore deposits, yielded evidence in favour of epigenetic fluid – rock interaction processes, both of hydrothermal and of supergene nature. These genetic models share similar structural controls, such as faults, thrusts, and synclines. The structures act as traps for either hydrothermal and/or supergene fluids that transformed BIF to high grade iron ore. The known iron ore deposits of the Kumba Mining area occur as localized high- grade ore-bodies of hematite rock (iron content > 60%) within the lower Penge Formation of the Chuniespoort Group. These high-grade ore bodies are considered to be the result of local chemical modification of a thick zone of BIF initially accumulated at the top of the Chuniespoort Group. Local chemical modification occurred as a result of magmatic to metasomatic-hydrothermal activities with a later supergene overprint.

With depth, the hematite rock grades into talc-hematite rock and calcite-hematite rock. Goethite and limonite are also present within the ore and low-grade ores at Thabazimbi Mine. The main iron ore

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 35 of 328 Management Programme under the MPRDA, 2002 deposits mined by Kumba are hosted within the Northern Range and cover a total strike length of approximately 11 kilometres. Within the Southern Range, iron ore mineralization is more sporadically distributed compared to that of the Northern Range and are only present over a strike length of approximately 5 kilometres.

Iron ore has been mined from Thabazimbi Iron ore mine since 1931 and the deposits are now almost mined out. It is of premium quality, especially low in phosphorous and silica. Structural deformation has caused the iron bearing sequence to be repeated by over-thrusting. The ore at Thabazimbi Iron mines is mined from underground and open cut operations at a rate of 2.4Mt per year. It occurs within the basal portion of a BIF unit of the Penge Formation that is underlain by chert-poor dolomite. There are four separate ore bodies within a 12 kilometres strike. None of the other documented occurrences have been mined.

1.1.2.2 Site specific geology According to a study conducted by Aquila Steel “Resource Estimation Update of the Meletse Iron Ore Deposit – December 2012” conducted on the remainder of the farm Donkerpoort 448KQ and remainder of the farm Randstephne 455KQ, banded iron ore formations (BIF’s) are developed in the Transvaal Supergroup within the Transvaal sub-basin of the Limpopo Province. The iron ore deposits occur within the Penge Formation of the Chuniespoort Group. Generally the iron content of the BIF’s varies between 25% and 35% Fe and it is only where significant enrichment has taken place (upgrading the iron content to >60% FE) that the iron formation constitutes ore. The mechanism of the enrichment process is still not fully resolved. Supergene enrichment through replacement by iron minerals is a major factor, but the controls on that enrichment can be viable. Hydrothermal fluid flow, structural channelling / plumbing and paleo-weathering, leading to supergene upgrading at unconformities, play important roles in the enrichment process.

The Meletse Deposit is mainly underlain by clastic sedimentary rocks of the Waterberg Group, granite of the Bushveld Complex, BIF of the Penge Formation and dolomite of the Malmani Subgroup (Figure 5). In the south-western portion of the mapped area, the BIF of the Penge Formation is underlain by dolomite of the Malmani Subgroup, whilst to the north-east the BIF rests non-conformably on the granite of the Bushveld Complex and un-conformably on the sandstone of the Waterberg Group. Being a strata bound deposit, it is important to define the hanging- and footwall rocks associated with the deposit.

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Figure 5: Profile indicating the spacial relationship of the footwall rocks

Lithostratigraphic data gathered from mapping and borehole logs of the sediments of the Chunniespoort Group were used to reconstruct a stratigraphical profile of the upper Malmani Subgroup and basal Penge Formation (Figure 6). Chert poor dolomites of the Frisco Formation are overlain by a transitional zone (locally referred to as the mixed zone). This zone comprises of an alteration of shale and chert macrobands and has an average thickness of 15-20 m. Nodular pyrite is present in the carbonaceous rich shale macrobands while contorted microbands of ankerite are developed in the chert macrobands.

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Figure 6: Lithostratigraphical profile of the mixed zone

Brecciation and metamorphism deformed the rocks of the mixed zone in close contact with the intrusive granite of the Bushveld Complex. Rock samples of the contact zone were analysed by MINTEK and they concluded that the samples represent a fine grained hornfels with quartz, chlorite, mica and pyrite. The rock samples can be described as a dark hornfels which lacks definite sedimentary structures. These fine-grained rocks are composed of a mosaic of equi-dimensional grains without preferred orientation and typically formed by contact metamorphism (MINTEK, May 2010).

The mixed zone is conformably overlain by metamorphosed iron oxide facies BIF. The basal BIF can be defined as a femicrite composed of macrocycles. In their complete form the macrocycles are composed of stilpnomelane lutite overlain by siderite microbanded chert, magnetite – siderite, and hematite-magnetite banded micritic iron formation. Well defined alteration of micro- and mesobands of iron oxides and chert is visible in outcrops and core. The iron oxides have a dark appearance while the chert is light grey in colour. The bedding character of the chert mesobands does vary from even,

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 38 of 328 Management Programme under the MPRDA, 2002 wavy to podded forms. The high grade iron ore lodes are developed in the basal iron oxide facies BIF protolith and underlain by BIF and or granite in the proximity of the outcrops and by the mixed zone in the dip extent of the deposit.

Boreholes drilled on the SW dip extent of the sequence penetrated a magnetite bearing BIF. Mesoscopically the BIF is grey to light grey in colour and fine grained with dark iron oxide bands alternating with grey laminae composed of chert and iron silicates. The contacts between the laminae are often sharp but mostly poorly defined. The magnetite bearing BIF can be defined as a femicrite. The macrocycles composed of stilpnomelane lutite overlain by microbanded chert, iron oxide – iron silicates micritic iron formation are not as well defined as in the iron oxide facies BIF. The mineralogy also differs and this can be a result of a facies change and/or the submergence of the carbonate shelf.

1.1.2.2.1 Structural setting Field observations and drill hole results (undertaken and analysed between 2008 and 2013 by the Aquila Exporation team) reveal a hydrothermal – supergene origin for the formation of the high grade Meletse deposit. The Meletse Deposit is spatially associated with thrust faults that offset and duplicate the stratigraphy. These faults and associated splays provided critical pathways during their extensional episodes allowing movement of basinal brines and /or deeply circulating meteoric water into the BIF and the transformation of BIF to high-grade hematite ore.

Most high – grade iron deposits in Hamersley province is associated with normal faults that usually caused down-throw of the mineralized zones and burial by younger sediments. This was particular favorable to the preservation of ore deposits. Compressional structures such as thrusts as indentified at Meletse were far less favorable for the preservation of ore deposits, due to the uplift caused and subsequent erosion of the ore bodies. This might be one of the main reasons why there is such a major size difference between the Hamersley metalliferous deposits and deposits in the Thabazimbi iron ore province.

It is evident that the geometry and geological setting of the Meletse deposit is complex. Defining the structural controls in context with simplified deformation periods enabled the Aquila exploration team to do a lateral and down dip interpretation of the geometry and extent of the iron ore lodes. The proposed structural model defined as different episodes is discussed. Refer to Figure 7 for a regional map identifying the project area structurally evaluated.

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Figure 7: Regional map identifying the project area structurally evaluated

According to McCourt (1994) the craton scale Thabazimbi-Murchison Lineament developed during the 3100 Ma accretion event and continued its influence throughout Waterberg times and had a major influence on the development and setting of the Meletse Deposit. The structural deformation that influenced the Meletse Range started with the two major fault systems namely the Bobbejaanwater and the Belt-of-Hills fault systems that duplicated and in some instances triplicated the rocks of the Transvaal Supergroup and the Bushveld complex. This period of deformation is defined as the end of the first episode.

Sediments of the Waterberg Group were deposited post the first episode and pre the second episode of deformation. The second period can be defined as the episode when the Gatkop over-thrust thrusted the chemical sediments of the Chuniespoort group over the clastic sediments of the Waterberg group. This changed the southerly dip orientation of the rocks to SSE.

The third episode is identified as the north directed stress field gave rise to the formation of several synthetic thrusts all slaying of the Gatkop thrust plane, which served as a floor thrust, creating the Meletse Thrust and the Northern Thrust. The Meletse thrust was intersected in two diamond boreholes (DT033 & DT075). Folding was initiated during the compressional phase, followed by a period of relaxation leading to extensional structures.

Rotation of the regional stress field marks the beginning of the fourth episode. On a local scale the rotated stress field gave rise to the developing of open folding with NW – SE trending axes. Smaller

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 40 of 328 Management Programme under the MPRDA, 2002 synthetic thrust faults all verging to the north-east developed and changed the orientation of the BIF block, hosting the Meletse iron ore body. These thrust faults probably resulted in the staggered appearance of the Meletse Iron Ore Body.

The accumulated effect of the different deformation events are reflected in the present outcrop patterns of ore lodes as determined by the current topography of the area. A structural analysis of the present BIF orientation was evaluated “Resource Estimation Update of the Meletse Iron Ore Deposit – December 2012” Indications are that the total sample of poles to bedding planes lies in a girdle field with a centre of gravity (C) at 152°/12° and a significant concentration of poles, also lying in a girdle field, representing bedding planes dipping at 50° to 60° in a SSW through a southerly to a SSE and a less prominent concentration dipping at approximately 60° in a NNE direction.

1.1.2.2.2 Orebody geology Ore genesis commenced during the early stages of the tectonic events that developed into the Belt of Hills thrust system with subsequent hydrothermal remobilization associated with the Gatkop, Meletse and Donkerpoort thrusts. Indications are that fold hinges, fault splays and the impervious shales of the mixed zone acted as aquitards. The Donkerpoort thrust resulted in the upliftment of a deep seated micro banded magnetite – chert - rich BIF that was transformed at the base of the sequence to a low to medium grade kenomagnetite -martite rich ore. Thus the first, hypogene, stage of ore formation presently identified at Meletse transformed magnetite – chert – rich BIF into a kenomagnetite -martite rich low to medium grade ore. This proto – ore was at a later deep meteoric stage oxidized to a hematite assemblage with the magnetite converted to martite. The inherently lower phosphorous content of the hematite rich high grade ore could be an indication of meteoric descending waters resulting in a supergene alteration of the hematite – martite ores of the Penge Formation.

The Meletse orebody is composed of numerous irregular shaped, hard, lumpy, high-grade hematite rich iron ore lodes outcropping along a lateral extent of 600m as illustrated in Figure 8. Six hematite rich ore lodes defined in alphabetical order from west to east were identified during the detailed mapping exercise. Additional drilling information gathered during this campaign indicates that two of the lodes namely C and D coalesce at close proximity down dip of the outcrop. These lodes were modelled as one lode and reported as lode C/D

The iron ore lodes are defined as having an average a >50% Fe content. These lodes forms irregular shaped bodies dipping of 40° on average to the SW and flatten to 20° at the dip extent of the lodes. Rafts of sterile protolith BIF and/or iron enriched BIF are developed within the ore envelopes and vary in thickness from one to three metres with a lateral extent of a few metres. The iron ore lodes bifurcate and coalesce in profile and are gently folded along strike. During the deformation episodes, synclinal structures were developed in two directions: NE-SW and SE-NW. Mineralization occurred in

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 41 of 328 Management Programme under the MPRDA, 2002 the hinges of these synclinal structures causing the ore to locally thicken in the synclinal hinges. The relaxation episodes of the main compression stress fields resulted in the development of boudin structures.

Figure 8: Identified iron ore lodes included in the resource statement as well as profile (Lines and the Resource dimensions indicated in blue).

1.1.3 Climate This section was compiled using information from the South African Weather Services – Climate Analysis of the proposed Mine at Thabazimbi.www.weathersa.co.za, 2012.

1.1.3.1 Brief description of the climate The Thabazimbi area lies in the summer rainfall region of the Bushveld. The Thabazimbi area is known for its relatively high temperatures, with day temperatures that may rise above 40°C in summer and to a few degrees below zero in winter.

January to March is the peak rainfall months with hail being prevalent. Frontal climatic systems bring soft soaking rains on occasion. Mean Annual Precipitation (MAP) is generally higher in the southern and eastern parts of the catchment where this value averages out at around 800mm per annum. The northern and western lower lying areas tend to have a MAP of between 500-600mm. MAPs fluctuate in dry/wet cycles of between 7 and 10 years (variations from 300mm in dry years to 1000mm in good

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 42 of 328 Management Programme under the MPRDA, 2002 rainfall years). During certain years large-scale flooding occurs in this catchment which wreak tremendous damage on irrigation farming operations (mainly north of Magaliesberg). This irrigation farming tends to be located on the broad floodplains associated with the middle and lower Crocodile River System.

1.1.3.2 Mean monthly and annual rainfall The Thabazimbi area has a mean annual precipitation (MAP) of 645 mm, of which 90% falls in the period October to April. The highest rainfall in a single day measured since 1981 was 223.5 mm on the 15th of February 2010. Table 6 below shows the maximum rainfall per 24 hours recorded for each month in the year 2010. The MAP is reflected in Figure 9 below.

Table 6: Maximum Rainfall in 24 Hour Period in 2010 MIN RAINFALL AVG RAINFALL MONTH MAX RAINFALL (mm) (mm) (mm) January 2.8 222.5 115.0 February 4.3 223.5 71.2 March 6.3 198.4 71.1 April 0.8 95.5 23.4 May 0.0 31.8 7.8 June 0.0 55.1 12.0 July 0.0 10.2 2.6 August 0.0 7.1 1.2 September 0.0 68.3 12.5 October 0.0 81.3 32.9 November 1.8 129.0 71.0 December 1.0 164.8 87.3 Total 431.8 770.6 541.8

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Figure 9: Average Rainfall from 1935 - 2010

1.1.3.2.1. Maximum rainfall intensities Thabazimbi normally receives about 529mm of rain per year, with most rainfall occurring mainly during midsummer. Thabazimbi receives the lowest rainfall (0mm) in June and the highest (106mm) in January. Refer to Table 7 for rainfall data from 1935 to 2010.

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Table 7: Rainfall Data from 1935-2010 YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC TOTAL 1935 0.00 0.00 0.00 0.00 5.10 102.10 107.20 1936 65.50 169.20 135.90 0.00 68.80 0.00 0.00 0.00 0.00 74.40 111.80 0.00 625.60 1937 245.10 159.80 68.60 29.70 0.00 0.00 0.00 0.00 17.80 72.60 20.60 175.80 790.00 1938 147.10 70.40 22.60 98.60 0.00 6.40 0.00 0.00 0.00 22.60 21.10 138.20 527.00 1939 45.50 269.20 158.00 0.00 44.50 0.00 30.00 4.80 11.70 58.70 185.40 74.20 882.00 1940 123.70 70.90 132.10 38.60 29.00 88.90 0.00 3.60 76.20 32.00 54.40 231.90 881.30 1941 83.10 48.80 14.70 78.50 0.00 0.00 0.00 0.00 9.10 13.00 16.50 139.70 403.40 1942 81.00 108.50 143.30 0.00 8.90 0.00 0.00 10.90 37.80 109.50 52.80 97.80 650.50 1943 102.10 49.00 104.60 140.20 40.10 1.00 3.30 13.20 29.50 125.70 29.50 38.10 676.30 1944 170.20 220.50 58.40 2.30 14.70 55.60 0.00 0.00 4.10 114.80 125.50 18.80 784.90 1945 74.70 78.50 116.80 34.80 3.30 0.00 3.30 0.00 0.00 55.40 63.20 34.80 464.80 1946 287.00 158.80 76.50 19.80 0.00 0.00 0.00 0.00 0.00 13.20 39.10 37.80 632.20 1947 106.20 109.00 159.00 30.20 0.00 0.00 2.30 0.00 6.90 39.90 203.50 108.00 765.00 1948 75.40 37.30 152.10 44.50 15.50 0.00 0.00 0.00 10.20 67.80 151.60 2.50 556.90 1949 179.80 49.50 53.30 13.70 8.40 25.90 1.80 0.00 0.00 30.70 69.60 237.20 669.90 1950 68.10 40.40 53.60 61.00 37.10 0.00 0.00 0.00 4.80 6.10 59.40 247.90 578.40 1951 69.10 82.30 61.70 50.30 37.10 5.10 16.00 16.30 3.30 105.90 24.10 56.40 527.60 1952 120.90 141.70 32.30 29.70 33.50 1.00 0.00 0.00 0.30 23.10 142.20 178.10 702.80 1953 70.60 179.60 153.70 112.00 6.60 0.00 0.00 0.00 0.00 23.60 125.50 89.90 761.50 1954 213.40 82.00 27.90 67.10 4.80 0.00 0.00 0.00 3.00 20.80 96.50 119.40 634.90 1955 165.10 358.10 50.80 27.40 10.20 13.00 0.00 0.00 0.00 47.80 71.60 344.40 1088.40 1956 43.70 189.50 153.40 15.20 38.10 0.00 0.00 0.00 30.50 20.60 71.10 96.00 658.10 1957 88.40 93.00 44.70 32.50 17.50 64.30 63.00 41.90 38.90 48.00 36.60 32.80 601.60 1958 133.60 65.00 33.00 57.20 1.80 0.00 0.00 0.00 30.00 55.10 106.20 175.00 656.90 1959 179.60 123.20 92.50 40.60 25.70 0.00 2.00 8.10 0.00 15.00 117.60 165.90 770.20

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YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC TOTAL 1960 35.80 98.30 79.50 74.40 14.00 0.00 1.00 18.00 1.50 37.60 199.10 127.50 686.70 1961 50.60 79.80 47.50 76.00 32.50 10.50 0.00 0.00 0.00 19.80 124.00 102.00 542.70 1962 86.50 30.50 23.00 77.50 0.00 3.60 0.00 2.50 0.00 21.00 97.50 76.20 418.30 1963 75.50 35.60 0.50 56.40 9.00 51.00 0.00 0.00 0.00 57.50 87.00 67.60 440.10 1964 143.00 39.60 4.00 42.00 0.00 1.00 0.00 0.00 5.60 151.00 68.00 103.60 557.80 1965 60.00 46.60 11.00 64.00 0.00 0.00 0.00 0.00 0.00 0.00 91.00 35.50 308.10 1966 90.50 67.00 9.00 24.00 2.50 32.00 0.00 0.00 63.50 53.50 41.00 111.00 494.00 1967 326.70 198.60 100.50 158.00 16.00 0.00 0.00 16.50 0.00 20.00 89.50 35.30 961.10 1968 147.60 50.50 88.00 78.50 38.00 0.00 0.00 0.00 0.00 9.00 103.00 84.60 599.20 1969 38.00 83.60 138.20 21.60 27.00 0.00 0.00 1.50 1.00 52.60 57.00 233.60 654.10 1970 144.00 36.00 35.60 10.50 11.00 8.00 7.60 0.00 13.50 55.00 89.50 109.00 519.70 1971 202.20 120.20 47.00 38.60 20.00 0.00 0.00 0.00 20.00 46.00 152.20 68.10 714.30 1972 227.00 50.60 143.00 16.00 6.10 0.00 0.00 0.00 4.00 12.50 92.00 66.00 617.20 1973 62.50 166.60 57.40 40.00 0.00 0.00 0.00 0.00 15.00 94.50 83.00 169.00 688.00 1974 98.50 54.50 120.50 32.00 0.00 0.00 0.00 6.50 18.00 20.50 92.00 165.50 608.00 1975 205.00 144.00 30.00 131.50 41.50 5.00 0.00 0.00 0.00 10.00 46.50 189.50 803.00 1976 127.00 122.50 108.50 30.00 32.50 0.00 0.00 0.00 14.50 60.00 107.00 148.50 750.50 1977 192.00 55.00 100.50 79.00 0.00 0.00 0.00 18.50 98.00 48.00 45.50 204.00 840.50 1978 325.00 108.00 98.00 41.00 0.00 0.00 0.00 0.00 20.00 54.00 58.50 57.50 762.00 1979 59.50 95.50 108.00 22.00 40.00 0.00 2.00 23.00 11.00 76.00 174.00 55.00 666.00 1980 151.50 103.50 53.00 23.50 0.00 0.00 0.00 0.00 29.50 30.50 113.50 157.50 662.50 1981 141.00 46.00 85.00 18.00 0.00 9.00 0.00 22.00 16.50 8.00 124.50 58.50 528.50 1982 152.00 54.50 120.50 13.00 0.00 0.00 10.00 0.00 0.00 77.00 53.50 158.90 639.40 1983 65.00 16.00 90.00 44.00 2.00 9.00 0.00 20.00 15.00 27.50 130.00 135.20 553.70 1984 14.50 24.00 126.00 0.00 0.00 41.00 29.00 0.00 5.00 92.00 96.00 172.40 599.90 1985 133.60 63.00 53.00 0.00 2.00 0.00 0.00 10.00 6.00 58.50 26.50 152.60 505.20

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YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC TOTAL 1986 68.50 78.50 80.50 56.00 0.00 0.00 0.00 4.00 29.50 88.00 130.00 102.50 637.50 1987 68.50 87.50 104.50 14.00 0.00 0.00 0.00 18.00 8.50 27.00 151.00 98.50 577.50 1988 103.00 163.50 140.50 54.50 0.00 1.00 0.00 2.00 27.00 92.50 32.00 144.00 760.00 1989 54.50 240.50 43.50 42.50 0.00 7.80 0.00 6.50 0.00 36.20 93.20 134.80 659.50 1990 86.90 111.20 94.00 57.00 31.70 0.00 0.00 0.00 10.30 22.10 18.00 69.20 500.40 1991 268.30 141.30 206.90 0.00 0.00 0.00 0.00 0.00 4.00 34.00 115.00 148.00 917.50 1992 34.50 46.70 82.60 34.60 0.00 0.00 0.00 0.00 0.00 38.00 131.70 80.50 448.60 1993 53.90 143.20 159.70 43.40 0.00 0.00 0.50 0.00 18.00 74.40 76.30 137.70 707.10 1994 115.90 107.50 12.70 3.80 0.00 0.00 0.00 0.00 0.80 50.30 30.10 119.10 440.20 1995 76.80 46.80 110.50 19.10 19.00 0.00 0.00 5.50 1.00 52.00 123.40 144.60 598.70 1996 127.80 324.40 52.50 42.00 7.30 0.00 1.90 0.00 0.40 47.80 77.40 148.70 830.20 1997 261.10 20.60 133.40 11.00 49.30 1.00 1.10 0.30 42.70 22.00 76.60 96.80 715.90 1998 115.10 55.20 17.70 8.50 0.00 0.00 0.00 2.00 2.90 29.70 99.60 251.20 581.90 1999 95.10 18.90 24.70 26.80 71.50 0.50 0.00 0.00 2.70 42.40 24.00 265.30 571.90 2000 308.00 230.80 119.90 27.00 23.00 15.90 1.30 0.00 0.00 74.80 48.30 81.50 930.50 2001 11.10 151.20 49.30 72.30 35.80 2.30 0.00 0.00 19.10 129.30 176.10 66.00 712.50 2002 26.10 0.00 35.60 36.40 0.50 44.30 0.00 2.00 11.00 60.70 0.70 207.80 425.10 2003 111.30 75.10 6.00 0.00 0.00 17.30 0.00 0.00 0.00 42.20 134.30 122.50 508.70 2004 130.20 159.80 203.10 63.90 0.00 0.70 13.70 0.00 0.00 2.10 67.30 176.30 817.10 2005 84.30 18.70 77.00 35.30 0.00 0.00 0.00 0.00 0.00 0.00 156.90 110.50 491.70 2006 256.20 326.80 138.90 0.00 4.00 0.00 0.00 6.90 0.00 76.50 56.70 116.80 982.80 2007 73.90 10.80 0.50 33.80 0.00 19.60 4.30 0.00 52.00 92.50 21.80 203.00 512.20 2008 259.02 37.60 101.40 0.00 14.00 3.00 3.40 0.00 0.00 1.20 122.70 67.30 609.62 2009 169.80 100.40 62.40 0.00 11.70 64.20 0.10 0.60 35.00 87.40 47.60 49.60 628.70 2010 146.10 57.10 106.50 159.70 73.00 0.00 0.00 0.00 0.00 542.40 Monthly 125.32 102.64 81.88 41.03 14.41 8.12 2.60 3.75 12.32 48.15 86.15 121.72 648.09

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YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC TOTAL average *Source: Department of Water Affairs

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1.1.3.3 Mean monthly maximum and minimum temperatures The Thabazimbi area lies in the summer rainfall region of the Bushveld. The Thabazimbi area is known for its relatively high temperatures, with day temperatures that may rise above 40°C in summer. The mean maximum summer temperature is approximately 30°C.

In summer, the mean temperature at 14h00 is 30°C, and in winter 21°C. At 08h00, the mean temperature is 23°C in summer and 8°C in winter. The mean monthly maximum and minimum temperatures are shown in the Table 8 below.

Table 8: Mean monthly maximum and minimum temperatures

MONTH MAX. TEMP. (° C) MIN. TEMP. (°C)

January 33,4 20,7 February 32,3 21,1 March 31,9 19,0 April 29,3 16,6 May 27,3 12,8 June 25,1 10,1 July 25,1 11,1 August 27,9 14,4 September 29,8 17,6 October 31,9 19,9 November 32,0 20,4 December 31,6 20,7

1.1.3.4 Mean monthly evaporation Refer to Table 9 below for the monthly evaporation measured at station A4E001 for an S class pan located approximately 56 km north-east of the proposed site.

Table 9: Average annual precipitation and evaporation Date Evaporation (mm) January 170.1 February 147.5 March 140.1 April 112.0 May 93.8 June 76.9 July 86.7 August 114.1 September 149.5 October 180.4

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Date Evaporation (mm) November 169.7 December 170.1 Annual 1630.2

The mean annual evaporation is 1630.2mm with monthly extreme values of 170.1mm (maximum) in December and January and 76.9mm (minimum) in June.

1.1.3.5 Extreme weather conditions The area experiences hot temperatures and high rainfall events leading to flash floods.

1.1.3.6 Mean monthly wind direction and speed Figure 10 below presents wind roses indicating the mean wind direction. From the wind roses it is evident that the mean wind direction North-east to South-east. During the winter months April, May, June and July the wind roses indicate that the wind direction sometimes changes slightly to South- west. The mean monthly wind direction and speed are shown in the Figure below. Statistics based on observations taken between 12/2011 - 6/2013 daily from 7am to 7pm local time. The prevailing wind direction is north-east, at a speed averaging 2.5m/s. Gale force winds occur very rarely.

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Figure 10: Annual wind speed direction

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1.1.4 Topography

1.1.4.1 Regional Description The topography of the region is characterised by a valley rising from west to east and bound on the northern and southern sides by two prominent mountain ranges. The non-perennial Crocodile River crosses a flood plain that forms the western part of the valley. An intermittent creek (which flows only after a heavy shower), the Rooikuilspruit, separates the mining areas of the northern range into two separate mountain sections. The Rooikuilspruit flows into the Crocodile River.

In the immediate mining area, thrusting, faulting and weathering have caused the BIF, Shales, quartzite's and dolomites of the Transvaal sequence to form prominent ranges of relative steep hills (30-45° from horizontal). These hills rise up to 500 m from the valleys below, to a maximum of about 1650 mamsl in the Rossouw’s kop area to the west of Thabazimbi. The hills usually comprise the BIS formations or quartzites while the valleys are the remembrance of the less erosion-resistant dolomite, shale and lava.

To the north of the area, the hills taps out to flat bushveld topography, until the rise of the escarpment of the Kransberg formed by the sandstones, shales and conglomerates of the Waterberg succession is reached.

1.1.4.2 Site specific description The topography of the proposed mining area is very rugged. The Meletse deposit is situated in Meletse mountain ridge, which is a northeast-southwest trending extension of the Northern range, to the east of Thabazimbi town. Refer to Figure 11 for the topographical map of the proposed mining site.

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Figure 11: Topographical locality map

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1.1.5 Soil The Memoirs on the Agricultural Natural Resources of South Africa, No.10, were used to determine the different types of soil that exist at the proposed site. The proposed site reaches over three land units namely Ae (Red apedal, freely drained soils), Ib (Diverse soils) and Fa (Glenrosa- and/or Mispah soil forms). The dominant land type is the Fa category. The Fa unit is intended to accommodate pedologically young landscapes. The soil forms, which epitomise these processes, are Glenrosa and Mispah. Fa refers to land in which no lime in the soil is encountered. These soils are usually shallow with a low cropping potential but can be used for grazing.

Soil in the north-western parts of the site has loamy sands present and is moderately susceptible to wind erosion. Soil in the north-eastern part of the site has sands strongly dominant and is susceptible to wind erosion. Soil in the southern part of the site is not susceptible to wind erosion. Soils where slopes are steeper are more susceptible to water erosion. The clay content of the soil of this vegetation type is less than 15% with a swell-shrink potential being low in the southern part of the site.

Soils do not have poor or impeded drainage. Topsoil depth is less than 450mm. The water-holding capacity is low in the northern part of the site and moderate in the southern part of the site. Soils are not saline or sodic. Soils on the southern part of the site have structurally favourable properties for arable farming. Soils do not have beneficial water-retaining layers below the rooting zone

Organic carbon percentage is moderate and pH is between 5.5 and 6.4. Soils on the southern part of the proposed site are somewhat susceptible to acidification and are eutrophic. Refer to Figure 12 below for a map illustrating soils on site.

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Figure 12: Map illustrating the soil types at the proposed site

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1.1.6 Land capability The land capability of the proposed site where mining activities will take place can be defined as game farming, which offers hunting, eco-tourism, accommodation and game-breeding.

1.1.7 Vegetation

1.1.7.1 General The proposed mining site corresponds to the Savanna Biome and more particularly to the Central Bushveld Bioregion as defined by Mucina & Rutherford (2006). It incorporates three ecological types known as the (1) Waterberg Mountain Bushveld, (2) Central Sandy Bushveld and (3) Western Sandy Bushveld (Mucina & Rutherford, 2006). The following information was extracted from an ecological evaluation conducted for the Aquila Steel project, Thabazimbi by Pachnoda Consulting CC. For comprehensive details on this study refer to Appendix E1.

Waterberg Mountain Bushveld The vegetation & landscape features of this vegetation type is rugged mountains with vegetation grading from Faurea saligna - Protea caffra bushveld on higher slopes through broad leaved deciduous bushveld (Diplorhynchus condylocarpon) on rocky mid - and foot slopes to Burkea africana - Terminalia sericea savanna in the lower-lying valleys as well as on deeper sands of the plateaus. The grass layer is moderately developed or well developed.

This vegetation type is predominantly confined to the northern half of the site, and is restricted to the Waterberg Mountains including a number of outlier hills and ridges of the Vlieëpoortberge and Boshofsberge near Thabazimbi. The conservation status of this vegetation type is least threatened, but poorly protected. About 9% is statutorily conserved mainly in the Marakele National Park and Moepel Nature Reserve. More than 3% is transformed, mainly by cultivation. Erosion is generally very low to low. The clay content of the soil of this vegetation type is less than 15 percent; with a topsoil depth of less than 450 mm. Soils are not suitable for arable agriculture. Soils are mainly suitable for forestry or grazing where climate permits (ENPAT 2001).

Central Sandy Bushveld This vegetation type is confined to a small area on the eastern extremity of the site. It extends in a broad arc south of the Springbokvlakte from the Pilanesberg region in the west, through Hammanskraal and Groblersdal to GaMasemola in the east. It is located on low undulating areas dominated by tall, deciduous woodland on deep sandy soils (typified by Terminalia sericea and Burkea africana). On shallow, gravel soils the floristic composition consists of Combretum apiculatum while Acacia, Ziziphus and Euclea are prominent on areas consisting of eutrophic soils. The Central Sandy Bushveld is “Vulnerable” with less than 3 % conserved in a number of scattered nature reserves. It is transformed by cultivation and urbanisation.

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Western Sandy Bushveld This vegetation type is dominant on the low-lying areas of the study site, and is typical of the sandy flats and undulating plains west of the Waterberg Mountains and north towards Steenbokpan. The vegetation structure varies from a tall, open canopy to low woodland dominated by broad-leaved and microphyllous species on soils underlain by arenite and sandstone. Noteworthy species include Acacia erubescens and Combretum apiculatum, with Terminalia sericea on areas comprising of deep sandy soils.

The Western Sandy Bushveld is also Least Threatened with about 6 % statutorily conserved in the Marakele National Park (Mucina & Rutherford, 2006). Refer to Figure 13 for a map illustrating the vegetation units of the proposed site.

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Figure 13: Vegetation units of the proposed site

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1.1.7.2 Ecological sensitivity The proposed site consists of a number of habitat types with high ecological value (refer to Figure 14 below for a map illustrating sensitive areas). The areas of avifaunal importance include the following:

 The Sand River tributary provides ideal habitat for the “near-threatened” Half-collared Kingfisher (Alcedo semitorquata) and is a critical important daily flight/dispersal route for water bird taxa. The Sand River tributary forms a vital corridor with other foraging habitat (impoundments) and roosting sites in a region where surface water is naturally scarce.  The Loudetia flavida – Monocymbium ceresiiforme crest grassland and Protea savanna sustain a relict grassland community with affinities to the Drakensberg Highlands. In addition, the presence of P. roupelliae highlights the possibility for the occurrence of an isolated population of Gurney’s Sugarbirds (Promerops gurneyi) – a small population exists on the nearby Marakele National Park.  The Mimusops zeyheri – Calodendron capense Afromontane forest and tall woodland along the various drainage lines support a bird composition of local interest that is commonly associated with forested habitat types.  The ridges and vertical cliffs (part of the Loudetia flavida – Monocymbium ceresiiforme crest grassland) are the ideal nesting platform for Falconiiform taxa and foraging habitat for charismatic birds of prey species (Verreaux’s Eagle Aquila verreauxii);  The large dead trees pertaining to the Acacia erioloba – Panicum maximum woodland provide roosting and breeding habitat for cavity nesters including the Red-billed Oxpecker (Buphagus erythrorhynchus) and the presence of free-roaming game is responsible for the establishment of a local population of “near-threatened” Red-billed Oxpeckers (Buphagus erythrorhynchus).

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Figure 14: Sensitivity map

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Table 10 summarises a list of plant species characteristic of the Waterberg Mountain Bushveld, Central and Western Sandy Bushveld vegetation types.

Table 10: A list of plant species characteristic of the Waterberg Mountain Bushveld, Central and Western Sandy Bushveld vegetation types. Waterberg Mountain Bushveld Grassy Layer Forb Layer Woody Layer Loudetia simplex, Herbs: Xerophyta retinervis, Tall trees: Acacia robusta Trachypogon spicatus, Berkheya insignis, Hibiscus meyeri Small trees: Acacia caffra, Burkea Themeda triandra, africana, Croton gratissimus, Enneapogon pretoriensis, Combretum apiculatum, C. zeyheri, C. Heteropogon contortus, molle, Faurea saligna, Heteropyxis Tristachya leucothrix natalensis, Protea caffra, Englerophytum magalismontanum, Ochna pretoriensis Tall shrubs: Diplorhynchus condylocarpon, Elephantorrhiza burkei, Dichrostachys cinerea, Vitex rehmannii Low shrubs: Barleria affinis, Searsia rigida subsp. dentata Woody climbers: Ancylobothrys capensis Central Sandy Bushveld Grassy Layer Forb Layer Woody Layer Brachiaria nigropedata, Herbs: Indigofera daleoides, Justicia Tall trees: Acacia burkei, Sclerocarya Eragrostis pallens, Panicum anagalloides, Kyphocarpa birrea subsp. cafra maximum, Loudetia simplex angustifolia Small trees: Burkea africana, Combretum apiculatum, C. zeyheri, Terminalia sericea, Peltophorum africanum Tall shrubs: Grewia bicolour, G. monticola Low shrubs: Agathisanthemum bojeri, Indigofera filipes

Western Sandy Bushveld Grassy Layer Forb Layer Woody Layer Anthephora pubescens, Blepharis integrifolia, Chamaecrista Trees: Acacia erioloba, Acacia Digitaria eriantha subsp. absus, Evolvulus alsinoides, nigrescens, Sclerocarya birrea subsp. eriantha, Eragrostis pallens, Geigeria burkei, Kyphocarpha caffra, Acacia erubescens, Acacia Eragrostis rigidior, Schmidtia angustifolia, Limeum fenestratum, mellifera subsp. detinens, Acacia pappophoroides, Aristida Limeum viscosum, Lophiocarpus nilotica, Acacia tortilis subsp. congesta, Aristida diffusa, tenuissimus, Monsonia angustifolia, heteracantha, Combretum apiculatum,

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Aristida stipitata subsp. Clerodendrum ternatum, Indigofera Combretum imberbe, Terminalia graciliflora, Eragrostis filipes, Justicia flava. sericea, Combretum zeyheri, Lannea superba, Panicum maximum, discolor, Ochna pulchra, Peltophorum Perotis patens. africanum. Tall shrubs: Combretum hereroense, Euclea undulate, Coptosperma supra – axillare, Dichrostachys cinerea, Grewia bicolor, Grewia flava, Grewia monicola.

1.1.7.3 Protected tree species from vegetation unit Three tree species namely Acacia erioloba (Mimosaceae) – Camel Thorn; Combretum imberbe (Combretaceae) – Leadwood; Sclerocarya birrea subsp. caffra (Anacardiaceae) –Marula were found on the proposed mining site. These species appear on the national list of protected tree species as promulgated by the National Forests Act, 1998 (No 84 of 1998). The main reasons for this list are to provide strict protection to certain species while others require control over harvesting and utilisation.

These species occur widely throughout the study site and is by no means restricted in range nor localised. In addition, these species are not threatened (not Red Data listed), but should be considered during the development phase of the project based on their legal status.

1.1.7.4 Site specific The dominant vegetation composition and structure on the study site comprises of five major communities simulated by environmental drivers such as rock cover and soil depth, altitude, slope and prominent geology (Table 11).

Table 11: The surface area (ha) of each defined vegetation unit in relation to the proposed study site Vegetation Community and sub-communities Environmental Area % drivers (ha) 1 Open Protea caffra – Loudetia flavida savannoid Mountain 350.51 16.44% grassland plateaus 1a Open Loudetia flavida – Monocymbium ceresiiforme Upper slopes 66.18 3.10% crest grassland 1b. Open Protea caffra – Bewsia biflora savannoid Upper slopes 284.34 13.33% grassland 2 Steep rocky Open Acacia caffra – Combretum molle – 737.50 34.59% Diheteropogon amplectens woodland slopes;

3 Dense Combretum apiculatum – Dichrostachys cinerea Gradual slopes 953.26 44.70% – Panicum maximum woodland and pediments

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Vegetation Community and sub-communities Environmental Area % drivers (ha) 3a. Open Dichrostachys cinerea–Nidorella resedifolia Sandy soils 181.33 8.50% shrubland

3b Combretum apiculatum – Panicum maximum woodland Rocky soils 559.28 26.23% 3c Tall Spirostachys africana – Dicliptera eenii woodland Drainage lines 87.91 4.12% 3d. Deep sandy Open Acacia erioloba-Panicum maximum woodland 124.73 5.85% soils 4. Mimusops zeyheri – Calodendron capense Dolomite hills 36.91 1.73% Afromontane forest 5. Croton gratissimus – Kirkia acuminata woodland on Dolomite hills 54.20 2.54% dolomite hills 100.00 Total 2132.38 %

1.1.7.5 Rare or endangered species

1.1.7.5.1 Red and orange listed data species Refer to Table 12 below for Red Data and Orange listed species likely to occur on proposed sites.

Table 12: Red Data and Orange Listed plant species likely to occur on the study site based on the occurrence of suitable habitat Species Flowering Habitat Probability of Conservation Season occurrence Status Red Data Listed (threatened taxa) Cyphostemma October - In shade of trees among Possible, however not Vulnerable hardyi December boulders and outcrops. encountered. Cheilanthes Northern aspects of rock Confirmed from the Vulnerable deltoidea crevices (phonolithic lava of open Loudetia flavida subsp. the Waterberg Group). Also – Monocymbium silicicola on chert outcrops. ceresiiforme crest grassland. Orange Listed Adromischus November- Rock crevices. Confirmed from the Taxonomically umbraticola December Loudetia flavida – Uncertain (DDT) subsp. Monocymbium ramosus ceresiiforme crest grassland. Boophone October- Grassland and bushveld. A widespread species Declining disticha January on rocky substrates. Freylinia July - June Riverbanks and streams (at Absent, not likely to Rare tropica 1 800 m). occur.

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Species Flowering Habitat Probability of Conservation Season occurrence Status Myrothamnus November - On sandstone or granite High, suitable habitat Taxonomically flabellifolius May outcrops with shallow soils. observed from Uncertain (DDT) sheetrock (confined to the Acacia caffra – Combretum molle – Diheteropogon amplectens woodland on steep rocky slopes.

Red Listed Species The threatened pteridophyte Cheilanthes deltoidea subsp. silicicola was confirmed from the Loudetia flavida – Monocymbium ceresiiforme grassland of the mountain summit. This species is restricted to the rock crevices and sheltered soil pockets of the large boulders that are located in open grassland. Given its small size and the habit of shrivelling during dry periods, it is often overlooked. It is currently known from only nine localities with an area of occupancy of 2-5 km2. The estimated total population size is between 600 – 800 individuals (Raimondo et al., 2009).

Orange Listed Species Boophone disticha is a “declining” geophyte that was recorded from the grassland and woodland communities. It is declining as a result of its medicinal properties; large quantities are being harvested and sold nationwide. Although this species is Orange listed, all populations should be managed within the footprint areas through prior marking and identification, and removed if threatened by destruction.

The dwarf succulent Adromischus umbraticola subsp. ramosus is another species of conservation concern. The taxonomic status of A. umbraticola subsp. ramosus is currently uncertain since it is easily confused with the similar A. u. subsp. umbraticola. If further research suggests that it deserves to be treated as a full species, it could justify placement in the “near-threatened” category. It was observed from rock crevices on the Loudetia flavida – Monocymbium ceresiiforme grassland.

1.1.7.6 Invader species Invaders and weed species are plants that invade natural or semi-natural habitats; especially areas disturbed by humans, and are commonly known as environmental weeds. Weeds that invade severely disturbed areas are known as ruderal and agrestal weeds. Most of these weeds are annuals colonising waste sites and cultivated fields. These weeds only persist on recently disturbed areas and seldom invade established areas (Henderson, 2001).

Declared weeds and invaders have the tendency to dominate or replace the canopy or herbaceous layer of natural ecosystems, thereby transforming the structure, composition and function of natural

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 65 of 328 Management Programme under the MPRDA, 2002 ecosystems. Table 13 below provides a list of declared weed and invasive plant species recorded during the flora study.

Table 13: A list of weeds and invader plant species identified on the study site. Control Species Vernacular Name Type Category Measure Achyranthes aspera Burrweed Weed Control 1 Jacaranda mimosifolia Jacaranda Invader Control 3

According to Table 13, it appears that the natural vegetation units on the study site were relatively clear of alien and invasive plant taxa. However, minor ruderal weeds observed include species such as Conyza canadensis, C. albida, Tagetes minuta, Bidens pilosa, Schkuhria pinnata and Zinnia peruviana. These species are all annuals (they completely die off during the dry season), and are of temporary nature.

1.1.8 Animal life The following information was extracted from the report “Aquila Steel Herpetofauna Survey; compiled by Luke Verburgt, dated July 2012”. A Herpetofauna survey was conducted by Enviro Insight. For comprehensive details of this survey refer to Appendix E1.

The proposed site falls within the extensive Waterberg bushveld region with a unique but widespread geology. The Waterberg mountain range provides habitat for several reptile species found almost exclusively on the mountain e.g. Waterberg crag lizard (Smaug breyeri), Waterberg Dwarf Gecko (Lygodactylus waterbergensis) and Waterberg quill-snouted snake (Xenocalamus bicolor australis) (Branch 1998). However, despite the geographic distribution restriction of these species to the mountain range, they are not listed as species of conservation concern due to the large extent of the Waterberg mountain range (~14500 km2). Furthermore, the herpetofauna of this mountain range enjoy a good degree of protection due to the fairly large portion of this area which is managed as game farms, private reserves, conservancy or national parks.

The herpetofauna species observed are all common and typical of the bushveld complex. The three species of conservation concern that can potentially be found on the study site have relatively large geographic distributions in relation to the project property. According to the herpetofauna survey, it is unlikely that Giant bullfrogs (Pyxicephalus adspersus) will be found here. Consequently, only species protected by NEMBA (2004) due to the risk of exploitation or over-utilization by humans are likely to occur on the property.

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1.1.8.1 Vertebrates

1.1.8.1.1 Mammals Refer to Table 14 for Red data species that might occur at the proposed site and to Table 15 for vulnerable bird species found in the area.

Table 14: Red Data Species found in the area Scientific Name Common Name Status Damaliscus lumatus lunatus Tsessebe Endangered Diceros bicornis minor Black Rhinoceros Vulnerable Hippotragus equines Roan Antelope Vulnerable Hippotragus niger niger Sable Antelope Vulnerable Acinonyx jubatus Cheetah Vulnerable Crocuta crocuta Spotted Hyena Near threatened Hyaena brunnea Brown hyena Near threatened Leptailurus serval Serval Near threatened Lycaon pictus African wild dog Endangered Mellivora capensis Honey badger Near threatened Cloeotis percivali Short-eared trident bat Critically endangered Myotis tricolor Tamminck’s hairy bat Near threatened Pipistrellus rusticus Rusty bat Near threatened Rhinolophus clivosus Geoffroy’s horseshoe Bat Near threatened Rhinolophus darlingi Darling’s horseshoe bat Near threatened Rhinolophus hildebrandtii Hildebrandt’s horseshoe bat Near threatened Atelerix frontalis South African Hedge Near threatened Dasymys incomius Water rat Near threatened Manis temminckii Pangolin Vulnerable

Table 15: Vulnerable bird species in the area Scientific Name Common Name Status

Gorsachius leuconotus Whitebacked night heron Vulnerable

Gyps coprothercs Cape vulture Vulnerable

Gyps africanus African whitebacked vulture Vulnerable

Torgos tracheliotos Lappetfaced vulture Vulnerable

Aquila rapax Tawny eagle Vulnerable

Polemaetus bellicosus Martial eagle Vulnerable

Terathopius ecaudatus Bateleur Vulnerable

Falco naumanni Lesser kestrel Vulnerable

Podica senegalensis African finfoot Vulnerable

Ardeotis kori Kori bustard Vulnerable

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Scientific Name Common Name Status

Pterocles gutturalis Yellowthroated sandgrouse Near threatened

Certhilauda chuana Shortclawed lark Near threatened

Buphagus erthrorhynchus Redbilled oxpecker Near threatened

1.1.8.1.2 Cape Vulture (Gyps coprotheres) Conservation Status and Breeding Localities The Cape Vulture is a southern African near-endemic species, and classified as “vulnerable” due to its small population size which is estimated at approximately 8 000 to 10 000 individuals in 2006 (Dickmann in litt., 2006). It has declined by 60-70 % in eastern South Africa during the past 15 years (BirdLife International, 2008). Its core distribution consists of two distinct population nodes confined to the North West Province and the Limpopo Province, and another occurring in the Lesotho highlands, the uplands of KZN-Natal and the Eastern Cape (Barnes, 2000; Tarboton et al., 1987). The largest breeding colonies occur in the Limpopo Province at Kransberg, Manoutsa and Blouberg (Piper, 1994). A small outlying population also persists at Potberg in the Overberg, Western Cape (Barnes, 2000).

The nearest breeding colony to the study site is located at Kransberg approximately 10 km north of the study site. The Kransberg colony is also the largest Cape Vulture breeding colony in the world with an estimated c. 900 breeding pairs (as estimated in the late 1990s; Barnes, 1998). The number of breeding pairs observed during 1984/1995 (c. 961pairs) have declined by 58 % during 2003/2004 (Monadjem et. al., 2004).

The Cape Vulture is currently threatened by loss of habitat (affecting food availability), poisoning (especially unintentional treatment of cattle with the anti-inflammatory drug Diclofenac), the “muthi trade”, power line collisions as well as osteodystrophy (a calcium deficiency causing metabolic bone disease) due to a lack of sufficient food supplies (Barnes, 2000). Locally it appears that tourism and mining operations in the area are critical disturbance factors that threaten the breeding success of the Kransberg colony (Barnes, 1998).

Breeding and roosting habitat Cape Vultures are mainly resident and does not venture far from their breeding grounds (Piper, 2005). However, some individuals are known to wander widely (ca. > 750 km) from their breeding colonies during the non-breeding season. Similarly, young adults have shown a high frequency of nomadism when attempting to breed for the first time, and will often cover large areas in search of a suitable breeding partner (Piper, 2005).

Breeding normally takes place on steep ledges (ca. 15-150 m), usually the highest point in a landscape with a preference for south and east-facing cliffs (Wolter et al., unpubl. data). Therefore,

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 68 of 328 Management Programme under the MPRDA, 2002 mountain ranges composed of weathered sedimentary rock (e.g. quartzite and sandstone) provide ideal breeding platforms for this species.

Roosting generally takes place at the breeding colonies, although individuals will also temporarily make use of powerline pylons (high-voltage lines) as well as large, flat-topped trees (Piper, 2005).

Foraging habitat Foraging habitat is not specific but depends on the availability of food. Cape Vultures appear to favour rural game farms and grazing areas within extensive systems managed as communal land (Huntley et al., 1989). These areas are earmarked by a high loss of livestock, although more areas are becoming unavailable to foraging vultures due to improved husbandry practices. Cape Vultures are therefore highly opportunistic, and will travel widely in search for food, which is generally located by “tracking” mammalian scavenger taxa (Piper, 2005).

However, Cape Vultures have undoubtedly benefited from the establishment of vulture restaurants, which is probably their most reliable source of food (Barnes, 1998). The nearest known restaurant to the study site, and probably one of few reliably food supplies for the Kransberg colony is located at the Kumba iron ore mine near Thabazimbi.

The occurrence of the Cape Vulture (Gyps coprotheres) on the study site The Cape Vulture is regarded as an occasional foraging visitor on the study site, and was regularly seen soaring overhead. Their occurrence on the study site is discussed in more detail below:

 Breeding & roosting habitat: The study site is located within the Waterberg region and in close proximity to the existing Kransberg breeding colony. However, the exposed outcrops and ridges on the study site, and their associated cliffs are not optimal for breeding. They are regarded as low (not remote enough) and generally accessible to a variety of predators which will discourage birds from breeding or roosting.

 Foraging habitat: The Cape Vulture is opportunistic and could utilise the study site if an opportunity prevails (e.g. a carcass). However, approximately 34.6 % of the study site is covered in dense woodland, which makes it difficult for these birds to find access and landing sites. The only suitable foraging habitat is provided by the Protea savannoid grassland on the summit areas, the open Dichrostachys cinerea–Nidorella resedifolia shrubland and the Acacia erioloba-Panicum maximum woodland. Foraging individuals are therefore referred to as opportunistic visitors.

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1.1.8.1.3 Bats The following information was extracted from the “Assessment of the bats at Gatkop Cave, and possible mitigation measures” report compiled by Kearney and Ernest, (2012). Refer to Appendix E5 for comprehensive details of this study.

The Gatkop cave is located 24.61799°S, and 27.65235°E on the farm Randstephne 455KQ. The Gatkop cave is 436m north of the Sandspruit River and is situated approximately 4km from the potential mining site. The Gatkop cave is at the foot slope of the mountainous area and is not situated at the higher altitudes where prospecting takes place. The Gatkop Cave (15-18 December 2011) serves as a habitat for seven species of bats (C. percivali, H.caffer, R.blasii, R. simulator, N. thebaica, M. tricolor, and M.natalensis), which were recorded with verifiable voucher specimens and one species that was recorded by echolocation call only (R. hildebrantii). The detectors placed further away from the cave also recorded about five other species that cannot be reliably identified from their call only. These species were unlikely, however, to be roosting in the cave, given their call parameters were not like those of cave roosting species, and that they were not recorded on the detector at the entrance to the cave.

Given the large numbers of female M.natalensisrelative to the other species, it appeared M.natalensis is still using the cave as a maternity roost. Based on the capture of volant sub-adults, post-lactating and lactating females the following species may also have used the cave as a maternity roost: R. blasii, R. simulator, N. thebaica, and M. tricolor. However, given the absence of any sub-adult M.natalensisin the captures, it was assumed the young of M. natalensiswere non-volant, and, or still being born. Since only males were caught of C. Percivali and H. caffer, and no individuals of R.hildebrantii were captured, it is not known if these species also used the cave as a maternity roost. It was not possible to determine if some of the species were using the roost as a day or a night roost (DEWHA 2010), and not all species were recorded directly at the cave entrance. Berry and Brown (1997) reported ‘two-way traffic’ in mines in the USA, where Little Brown Bats and Pallid Bats entered mines to utilize them as a night roost, even before Townsend’s Big-eared Bats had exited the mine they were using as a day roost. There is also a possibility levels of activity at the roost entrance may have been over-estimated given the observation of bats ‘swarming’ above the flat area just before the decline leading into the cave entrance, after dark around 20h30, once the main emergence appeared to have ended. Furthermore, the Anabat system has an additional constraint that only the call with the loudest intensity is recorded at a point in time, which in the context of a variety of different species occurring together in an area at a similar time, means species with lower intensity calls would be under-sampled in relation to those with louder intensity calls.

Although the capture technique of the bat traps appears not to catch all species with equal probability, i.e. C. percivali appears better able to avoid capture than most other species (Seamark, 2005); the numbers of each species captured may give some indication of the relative size of the populations of each species utilizing Gatkop Cave. The species for which the most number of individuals were

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 70 of 328 Management Programme under the MPRDA, 2002 caught, listed in order from highest to lowest, were: M.natalensis, R.simulator, N.thebaica, R.blasii, H. caffer, M. tricolor, C.percivali, and R.hildebrantii. The numbers of individuals of each of the species from the lowest to the highest increased exponentially, with there being 690 times more M. natalensis caught than individuals of H. caffer, M. tricolor, and R. hildebrantii, and 31 times more M.natalensis than the second most captured species, R. simulator. The activity levels calculated from the passively recorded echolocation calls for the different species may reflect differences in behaviour, i.e. a single individual commuting straight past the detector would record less activity than a single individual foraging within the recording range of the detector. However, comparing the mean of the highest activity recorded over three days at the entrance to the cave for each species, the species listed in order of highest to lowest activity were: M. natalensis, R.simulator, R.blasii, R.hildebrantii and M. tricolor. The different levels of activity for each species, from the lowest to the highest activity also increased exponentially, with M.natalensis being 114 times more active than M.tricolor, and twice as active as R. simulator.

Subsequent to the site visit Prof Mac van der Merwe confirmed Gatkop Cave is the same cave he previously reported as Sandspruit Cave No. 1. This means Gatkop Cave has a considerable history of prior evidence regarding bat records at the site, albeit listed under the name Sandspruit Cave No. 1. Interestingly though, in contrast to the eight species we recorded from 15 to 18 December 2011, throughout the work by Prof Mac van der Merwe at Gatkop Cave between 1967 and 1984 during the M. natalensis maternity period, i.e. from the end of October to the beginning of March, M. natalensis was usually the only bat species recorded at the cave. The exception being during a visit on 17 December 1984 when a small colony of 200-300 juvenile M.tricolor was also observed in the cave (van der Merwe, 1987). No M.tricolor was observed during a subsequent visit on 26 January 1985 when the cave was still occupied by M.natalensis females and juveniles (van der Merwe, 1987).

A maternity roost of some of the bat species we identified at Gatkop Cave had been recorded in 1967 at another cave 9 kilometres northwest of Sandspruit Cave No 1. Four small clusters of R.simulator, N.thebaica, M, tricolor, and C.percivali with their young were observed at Rookpoort Guano Cave on 10 December 1967 (van der Merwe, 1987). With the exception of C.percivali, which was never recorded as Gatkop during the work between 1967 and 1984, the other species had been recorded at Gatkop Cave, but only at times of the year outside the M.natalensis maternity period, i.e. In June and August (van der Merwe, 1987). It is interesting that C.percivali was not recorded at Gatkop Cave during the period of Prof Mac van der Merwe’s work between 1967 and 1984, given the species was identifiable at the nearby Rookpoort Guano Cave. The absence of C.percivali from Gatkop Cave during the work of Prof Mac van der Merwe, may have been the result of it being overlooked, since it appears this species can be overlooked during visual inspection and is apparently under-sampled by many capture techniques (Seamark, 2005). However, if it was absent and the use of Gatkop Cave as a roost for C.percivali is relatively recent, it may suggest C.percivali is not as faithful to a particular roost, and that over the course of some years they will move between different roosts, or they have

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 71 of 328 Management Programme under the MPRDA, 2002 been disturbed at Rookpoort Guano Cave and have moved from Rookpoort Guano Cave to Gatkop Cave, or this may represent an expansion of the population into Gatkop Cave.

Work on M.natalensis by van der Merwe (1973a, 1978) at Gatkop from November 1967 to March 1968, and October 1974 to February 1975 indicated the females had given birth to their single young from the end of October, with the peak in births occurring from the end of November to the beginning of December, and this species had left the cave by 3 March in 1968. Gatkop Cave is used as a maternity roost for M. natalensis, although far fewer non-pregnant females and males have also been observed along with the pregnant / lactating females in this roost. As indicated by banding results this species migrates to and from Gatkop to other caves on the Highveld where it hibernates for the winter (van der Merwe, 1973a, 1975).

There have been several visits to the cave by the Gauteng and Northern Area Bat Interest. During visits on 13 September 2005 and 4 February 2006, the following species were observed: M.schreibersii, C.percivali, R.simulator, R.blasii (Dean Peinke, pers. comm.), with R.simulator and R.blasii being verified by voucher specimens, and during a visit in September 2011, six species were observed: C.percivali, N.thebaica, M. tricolor, R.blasii, R.simulator and M.natalensis (Stan Rodgers, pers. comm.).

According to the IUCN Red List assessment categories of the last regional assessment (Friedmann and Daly, 2004), of the species we recorded one was listed as Data Deficient (H. caffer), two were listed as Least Concern (R.simulator, N.thebaica), two were listed as near threatened (R.hildebranti, M.natalensis, M.tricolor), and one each were listed as Vulnerable (R.blasii) and Critically Endangered (C.percivali). Even though M.natalensis is not the species with the most threatened conservation status, in the context of the conservation of the bat populations roosting at Gatkop Cave, it is the specialist’s opinion that M.natalensis is the species most at risk to any potential damage to this roost. Gatkop Cave has been documented as a maternity roost for M.natalensis species since 1967, at which time it was noted the roost must have been in use for some time before that given the deposition of guano (van der Merwe, 1973a). It is also one of only two maternity roosts for this species known in the bushveld region and of those was recorded as supporting the larger population. Van der Merwe (1973a) recorded Gatkop Cave (Sandspruit Cave No.1) as having more individuals (estimated 158 900 juvenile M.natalensis in 1967 and 110 000 in 1974) than Peppercorn’s Cave at Makapans (estimated 49 000 juvenile M. natalensis in 1967 and 59 000 in 1974). As evidenced by the results of our site survey, the high level of fidelity shown in the continued use of Gatkop Cave as a maternity roost by M.natalensis indicates the preservation and conservation of this cave is significant for the long-term stability / security of the population of this species.

1.1.8.1.4 Reptiles

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The following information was extracted from a report titled “Ecological evaluation conducted for the Aquila Steel project, Thabazimbi compiled by Pachnoda Consulting CC. For comprehensive details on this study refer to Appendix E1.

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Table 16: Expected and observed herpetofauna during the site survey

Funnel Additional trap drift sampling: fence Frogging & night- arrays General- and active sampling drive combinations

Red list Atlas region Random 17- 18- 19- Species Family Species Common name 2427DA Unlikely category endemic 1 2 sampling ASP1 ASP2 ASP3 ASP4 ASP5 Nov Nov Nov totals Agamidae Acanthocercus atricollis Southern Tree Agama Not Evaluated 3 3 Agamidae Agama aculeata distanti Distant's Ground Agama x Not Evaluated x 1 1 Amphisbaenidae Monopeltis capensis Cape Worm Lizard x Not Evaluated Amphisbaenidae Monopeltis infuscata Dusky Worm Lizard Not Evaluated Kalahari Dwarf Worm Amphisbaenidae Zygaspis quadrifrons Lizard x Not Evaluated Common Purple-glossed Atractaspididae Amblyodipsas polylepis Snake Not Evaluated Black-headed Centipede- Atractaspididae Aparallactus capensis eater Not Evaluated Atractaspididae Atractaspis bibronii Bibron's Stiletto Snake Not Evaluated 1 1 Xenocalamus bicolor Waterberg Quill-snouted Atractaspididae australis Snake Not Evaluated x Bicoloured Quill-snouted Atractaspididae Xenocalamus bicolor bicolor Snake x Not Evaluated Boidae Python natalensis Southern African Python Not Evaluated Common Flap-neck Chamaeleonidae Chamaeleo dilepis Chameleon Not Evaluated 1 1 Colubridae Boaedon capensis Brown House Snake x Not Evaluated Colubridae Crotaphopeltis hotamboeia Red-lipped Snake Not Evaluated Colubridae Dasypeltis scabra Rhombic Egg-eater Not Evaluated Colubridae Dispholidus typus Boomslang x Not Evaluated Colubridae Gonionotophis capensis Common File Snake Not Evaluated Colubridae Gonionotophis nyassae Black File Snake Not Evaluated Colubridae Hemirhagerrhis nototaenia Eastern Bark Snake x Not Evaluated Colubridae Lycophidion capense Cape Wolf Snake Not Evaluated

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Funnel Additional trap drift sampling: fence Frogging & night- arrays General- and active sampling drive combinations

Red list Atlas region Random 17- 18- 19- Species Family Species Common name 2427DA Unlikely category endemic 1 2 sampling ASP1 ASP2 ASP3 ASP4 ASP5 Nov Nov Nov totals South Eastern Green Colubridae Philothamnus hoplogaster Snake Not Evaluated Colubridae Philothamnus semivariegatus Spotted Bush Snake Not Evaluated Colubridae Prosymna bivittata Two-striped Shovel-snout Not Evaluated Colubridae Psammophis angolensis Dwarf Sand Snake x Not Evaluated Colubridae Psammophis brevirostris Short-snouted Grass Snake Not Evaluated Western Yellow-bellied Colubridae Psammophis subtaeniatus Sand Snake Not Evaluated 1 1 Colubridae Psammophylax tritaeniatus Striped Grass Snake Not Evaluated Colubridae Pseudaspis cana Mole Snake Not Evaluated Colubridae Telescopus semiannulatus Eastern Tiger Snake Not Evaluated 1 1 Colubridae Thelotornis capensis Southern Twig Snake Not Evaluated Cordylidae Cordylus jonesii Jones' Girdled Lizard Not Evaluated Cordylidae Cordylus vittifer Common Girdled Lizard x Not Evaluated Cordylidae Platysaurus guttatus Dwarf Flat Lizard Not Evaluated x Cordylidae Platysaurus minor Waterberg Flat Lizard x Not Evaluated x 7 7 Pseudocordylus Cordylidae transvaalensis Northern Crag Lizard Not Evaluated x Cordylidae Smaug breyeri Waterberg Girdled Lizard x Not Evaluated x 4 3 2 9 Elapidae Aspidelaps scutatus Speckled Shield Cobra Not listed Elapidae Dendroaspis polylepis Black Mamba Not Evaluated 1 1 2 Elapidae Elapsoidea boulengeri Boulenger's Garter Snake Not Evaluated Elapidae Naja annulifera Snouted Cobra Not Evaluated 1 1 Elapidae Naja mossambica Mozambique Spitting Cobra x Not Evaluated Afroedura nov sp. 10 Flat Gecko sp. 10 Gekkonidae (waterbergensis) (waterbergensis) Not listed Gekkonidae Chondrodactylus turneri Turner's Gecko Not Evaluated

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Funnel Additional trap drift sampling: fence Frogging & night- arrays General- and active sampling drive combinations

Red list Atlas region Random 17- 18- 19- Species Family Species Common name 2427DA Unlikely category endemic 1 2 sampling ASP1 ASP2 ASP3 ASP4 ASP5 Nov Nov Nov totals Common Tropical House Gekkonidae Hemidactylus mabouia Gecko Not Evaluated 3 3 Gekkonidae Homopholis walbergii Wahlberg's Velvet Gecko Not Evaluated Gekkonidae Lygodactylus capensis Common Dwarf Gecko x Not Evaluated 1 3 2 1 1 8 Gekkonidae Lygodactylus waterbergensis Waterberg Dwarf Gecko Not Evaluated x Gekkonidae Pachydactylus affinis Transvaal Gecko x Not Evaluated x 1 1 Gekkonidae Pachydactylus capensis Cape Gecko Not Evaluated Yellow-throated Plated Gerrhosauridae Gerrhosaurus flavigularis Lizard x Not Evaluated 1 2 3 3 9 Common Giant Plated Gerrhosauridae Gerrhosaurus validus Lizard Not Evaluated Lacertidae Ichnotropis capensis Cape Rough-scaled Lizard Not Evaluated Common Rough-scaled Lacertidae Ichnotropis squamulosa Lizard Not Evaluated Lacertidae Nucras holubi Holub's Sandveld Lizard Not Evaluated Leptotyphlopidae Leptotyphlops scutifrons Peters' Thread Snake x Not listed Pelomedusidae Pelomedusa subrufa Marsh Terrapin Not Evaluated 1 1 Pelomedusidae Pelusios sinuatus Serrated Hinged Terrapin Not Evaluated Scincidae Acontias occidentalis Western Legless Skink Not Evaluated Wahlberg's Snake-eyed Scincidae Afroablepharus walbergii Skink Not Evaluated 1 1 2 Scincidae Mochlus sundevallii Sundevall's Writhing Skink Not Evaluated Scincidae Trachylepis capensis Cape Skink Not Evaluated Scincidae Trachylepis margaritifer Rainbow Skink Not Evaluated Scincidae Trachylepis punctatissima Speckled Rock Skink x Not Evaluated 1 4 5 Scincidae Trachylepis varia Variable Skink x Not Evaluated 1 2 3 6 Testudinidae Kinixys lobatsiana Lobatse Hinged Tortoise Not Evaluated

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Funnel Additional trap drift sampling: fence Frogging & night- arrays General- and active sampling drive combinations

Red list Atlas region Random 17- 18- 19- Species Family Species Common name 2427DA Unlikely category endemic 1 2 sampling ASP1 ASP2 ASP3 ASP4 ASP5 Nov Nov Nov totals Testudinidae Kinixys spekii Speke's Hinged Tortoise Not Evaluated Testudinidae Stigmochelys pardalis Leopard Tortoise Not Evaluated 1 1 Delalande's Beaked Blind Typhlopidae Rhinotyphlops lalandei Snake Not Evaluated Varanidae Varanus albigularis Rock Monitor Not Evaluated Varanidae Varanus niloticus Water Monitor x Not Evaluated Viperidae Bitis arietans Puff Adder x Not Evaluated 1 1 Viperidae Bitis caudalis Horned Adder x x Not Evaluated Viperidae Causus defilippii Snouted Night Adder x Not Evaluated 64 Brevicepitidae Breviceps adspersus Bushveld rain frog x Least Concern x x Bufonidae Amietophrynus garmani Eastern olive toad x Least Concern x x Bufonidae Amietophrynus gutturalis Guttural toad x Least Concern 1 x x 1 Bufonidae Amietophrynus maculatus Flat-backed toad Least Concern Bufonidae Amietophrynus rangerii Raucous toad Least Concern 2 2 Bufonidae Poyntonophrynus fenoulheti Northern pygmy toad Least Concern Bufonidae Schismaderma carens Red toad x Least Concern 2 4 x x x 6 Hyperoliidae Kassina senegalensis Bubbling Kasina x Least Concern 1 1 1 x x x 3 Microhylidae Phrynomantis bifasciatus Banded rubber frog x Least Concern 2 x x 2 Phrynobatrachidae Phrynobatrachus natalensis Snoring puddle frog x Least Concern Pipidae Xenopus laevis Common platanna Least Concern Ptychadenidae Hildebrandtia ornata Ornate frog x Least Concern Ptychadenidae Ptychadena anchietae Plain grass frog x Least Concern x x x Ptychadenidae Ptychadena mossambica Broad-banded grass frog x Least Concern Ptychadenidae Ptychadena porosissima Striped grass frog Least Concern Pyxicephalidae Amietia angolensis Common river frog x Least Concern 2 4 6 Pyxicephalidae Cacosternum boettgeri Boettger's Caco x Least Concern Pyxicephalidae Pyxicephalus adspersus Giant Bullfrog x Least Concern

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Funnel Additional trap drift sampling: fence Frogging & night- arrays General- and active sampling drive combinations

Red list Atlas region Random 17- 18- 19- Species Family Species Common name 2427DA Unlikely category endemic 1 2 sampling ASP1 ASP2 ASP3 ASP4 ASP5 Nov Nov Nov totals Pyxicephalidae Pyxicephalus edulis African Bullfrog Least Concern Pyxicephalidae Strongylopus fasciatus Striped stream frog x Least Concern Pyxicephalidae Strongylopus grayii Clicking stream frog x Least Concern Pyxicephalidae Tomopterna cryptotis Tremolo sand frog x Least Concern x x x Pyxicephalidae Tomopterna natalensis Natal sand frog x Least Concern 1 3 x 4 Rhacophoridae Chiromantis xerampelina Southern foam nest frog x Least Concern 1 1 25 Unique species 3 5 21 4 1 2 7 1 10 5 5 Grand total 89 Individuals 3 7 35 8 3 5 21 1

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1.1.9 Surface water As part of the integrated water management, a Storm Water Management Plan (based on the Best Practice Guidelines G1 (DWAF, 2006)) was developed by Shangoni Management Services for Aquila titled: “Storm Water Management Plan, Aquila Steel (S Africa) (Pty) Ltd”, dated January 2014. The mentioned plan describes the water flow over and around all the proposed activities, and provides strategies for optimising the separation of clean and affected runoff water. Refer to Appendix E6 for a copy of the mentioned Storm Water Management Plan

1.1.9.1 Site description The proposed site is located in the Limpopo River Catchment within, referred to as the A24 drainage region by the Department of Water Affairs (hereafter referred to as the DWA) and is mainly located in the A24H quaternary catchment refer to Figure 15.

The northern part of the site falls within the River FEPA (Freshwater Ecosystem Protected Area). River FEPA’s achieve biodiversity targets for river ecosystems and threatened/near threatened fish species. The drainage lines in the area were identified as rivers that are currently in a good condition (A or B ecological category). Their FEPA status indicates that they should remain in a good condition to contribute to national biodiversity goals and support sustainable use of water resources. FEPA status applies to the actual river reach within such a sub-quaternary catchment.

1.1.9.1.1 Surface water quantity

Catchment hydrology The proposed mining site is located in the Limpopo River Catchment area.

Net catchment areas The A24H quaternary catchment area has a surface size of 29 400 km². This area is within the Limpopo/Olifants drainage region. The Sand River, a tributary to the Limpopo River, flows south past the Klipgat tenement. To the west flows the Sondags River through the Sandrivierpoort. The Sandspruit is a tributary to the Sand River and flows through the farm Donkerpoort. There are also many drainage lines from the mountainous areas towards the Sand River flowing in a southerly direction.

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Figure 15: Quaternary catchment

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Normal dry weather flow There are no perennial streams in the actual study area, but there are several non-perennial drainage lines feeding into permanent streams in the valley below the mountain. The non-perennial drainage lines, flows only during rainfall events.

Mean annual runoff The natural surface Mean Annual Runoff (MAR) is approximately 646 million m3/annum.

Flood peaks Flood peaks and volumes for recurrence intervals of 1:20, 1:50 and 1:100 years and the regional maximum flood are given in Table 17 below. The results are based on the Rational Method and storm rainfall for the station Kalkheuwel (550612).

The rational method was used to determine flood peaks and volumes for of the sub-catchment. The rational method is based on a simplified representation of the law of conservation of mass. Rainfall intensity is an important input for calculations. It is one of the best-known and the most widely used methods for determining peak flows from small catchments (< 15 km2). The peak flow is obtained from the formula that indicates that Q = CIA, where Q is the peak flow, C the runoff coefficient, I the rainfall intensity and A the effective area of the catchment.

Table 17: Flood Peaks and Volumes

POSITION 1:20 YEARS 1:50 YEARS 1:100 YEARS RMF

Crocodile River 358 m³/s 584 m³/s 895 m³/s 2 790 m³/s

Drainage density Numerous drainage lines occur from the higher peaks in the north-eastern parts of the site and flows down towards the Sand River south of the site. The drainage area in the vicinity of the site is well vegetated with grass and tree species accompanied by a combination of sandy and rocky areas forming initial hilly and steep topography that gradually flatten towards the south. The sub-catchment drainage density of the area is 1.56 km / m².

1.1.9.1.2 Surface water quality The following information was extracted from a report titled “The Ecological integrity of the aquatic habitat at the proposed Aquila mine on Donkerpoort 448 KQ remaining extent and Randstephne 455 KQ, Thabaizmbi district, Limpopo Province, South Africa. For comprehensive details on this study refer to Appendix E10.

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The Present Ecological Status (PES) of the river is expressed in terms of various components that is drivers (physic-chemical, geomorphology, hydrology) and biological responses (fish, riparian vegetation and aquatic invertebrates), as well as an integrated state, the ecostatus refer to table 18. The scale used for river health describes five different states of health, from an A class (natural) to an E class (unacceptable). The results of applying the biological and habitat indices during a river survey provide the contexts for determining the degree of ecological modification at the monitoring site. Thus, the degree of modification observed at a particular site translates in to Present Ecological State.

Figure 16 illustrates the 6 sites that were selected for bio-aquatic monitoring. Table 19 shows the results of the study.

Figure 16: The location of all the sites visited and / or sampled. The black arrows indicate the main non-perennial drainage lines

Table 18: Present Ecological Status Classes

Class Ecological State of River Description A Natural No measurable modification B Good Largely unmodified C Fair Moderately modified D Poor Largely modified E Unacceptable Seriously/critically modified

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Table 19: Sites monitored during the study Site No. GPS Co- River Sampling Details Present Ecological & ordinates Status (Name) Site 1 S24o34’ 23.2” Non-perennial None No water at the time of N/A E027o41’32.2 drainage line of visit due to late rains. ” Sand River Crosses the road. Site 2 S24o34’ 46.4” Non-perennial None No water at the time of N/A E027o41’13.9 drainage line of visit due to late rains. ” Sand River Observed some macro- invertebrates gyrinnidae, crabs and adult dragon flies. Site 3: S24o35’ 02.6” Non-perennial None Significant flow at the N/A Sand E027o41’03.6 drainage line of time of visit due to late tributary ” Sand River rains. Murky water. Site 4: S24o 35’ Sand River Fish Flowing water. Surveyed B and C class stream Sand 15.8” Macro between the bridge and Road E027o 41’ Invertebrat fence downstream. 03.4” es Surrounding vegetation Habitat SVcb 16 mainly, Water marginally SVcb 17. quality Site 5: S24o 35’ Sand River Fish Flowing water. Surveyed C to B class stream Sand 38.7” Macro below the weir in front of Lodge E027o 41’ Invertebrat the lodge. Dirt road 05.0” es crosses the stream. Habitat Surrounding vegetation Water SVcb 16 mainly. quality Site 6: S24o 37’ Sondagsrivier Fish Flowing water. Surveyed C class stream Sondags 10.45” Macro the bridge. Surrounding Bridge E027o 36’ Invertebrat vegetation SV cb 16 24.67” es mainly. Much wider than Habitat Sand River. Before the Water confluence with the quality Sand.

1.1.9.1.3 Surface water use Surface water in the area is used mainly for agricultural purposes; with little domestic use.

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1.1.9.1.4 Wetlands There are no wetland systems in the vicinity of the proposed site (Prospecting Right EMP, 2012).

1.1.9.2 Water management area The proposed site fall within the Crocodile (west)/Marico water management area (Crocodile). The North West Department of Water Affairs is the responsible water authority. The Crocodile River is a major tributary of the Limpopo River. The Pienaars, Apies, Moretele, Hennops, Jukskei, Magalies and Elands rivers are the major tributaries of the Crocodile River. The upper portion of the catchment, south east of Hartbeespoort Dam, is located in the Gauteng Province. The north and north-east corners lie in the Limpopo Province whereas the central or western sections fall within the North West Province.

1.1.10 Ground water

1.1.10.1 Ground water quality regional description The following information was extracted from the report titled Geohydrological investigation as part of the EIA and EMP dated March 2014 done by Groundwater Complete.

Regional groundwater quality information is available for a total of 31 hydrocensus localities. According to the Geohydrology investigation the regional hydrocensus boreholes are dominated by fresh, clean, relatively young groundwater that has started to undergo mineralization with especially magnesium ion exchange. Groundwater sampled from surrounding groundwater users is generally of good quality and is suitable for human consumption according to the South African National Standards for drinking water (SANS241:2011). The groundwater is dominated by magnesium cations, while bicarbonate alkalinity dominates the anion content. Exceptions do however occur as the nitrate concentration measured in VENTER07 exceeds the ambient conditions. Even though the nitrate content of VENTER07 still complies with the SANS drinking water guidelines, the borehole is undoubtedly affected by an unknown source of nitrate contamination. The groundwater fluoride content measured in boreholes BH08, Dp1, Dp2, Dp3 and MELETSE12 exceed the permissible SANS concentration of 1.5 mg/l and may cause chronic health affects should the groundwater be consumed. Regional groundwater TDS concentrations vary between ± 80 mg/l and 670 mg/l, which are below the permissible SANS value of 1 200 mg/l (Table 20). A positive linear correlation generally exists between groundwater salinity and aquifer residence time and because gravity dictates that groundwater moves from higher to lower hydraulic gradients, overall higher salinities are generally measured in the lower lying areas and valley bottoms. A similar correlation was identified for the Meletse Project area.

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Table 20: Concentrations of indicator chemical parameters of the regional sampling localities for Meletse (mg/l) EC TDS Ca Mg Na K Cl SO4 NO3-N F Al Fe Mn THardness BH pH mS/m mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l AVANCOLLER1 8.5 29.3 170.0 28.6 9.3 21.8 2.0 10.4 2.1 0.4 0.4 <0.006 <0.006 <0.001 110.0 BH01 8.0 85.8 484.0 86.1 48.5 24.9 2.5 25.3 14.2 2.5 0.6 <0.006 <0.006 <0.001 415.0 BH02 7.8 79.7 456.0 82.2 46.8 19.2 2.7 20.4 12.7 2.3 0.7 <0.006 <0.006 <0.001 398.0 BH05 7.8 64.6 348.0 64.4 36.3 15.6 2.4 16.9 7.8 0.9 0.8 <0.006 <0.006 <0.001 310.0 BH08 7.7 123.0 671.0 79.8 64.4 79.1 10.9 98.0 42.9 3.1 2.1 <0.006 <0.006 <0.001 465.0 Dp1 8.1 73.0 393.0 51.1 17.3 87.1 4.8 80.9 14.5 <0.057 2.7 <0.006 <0.006 <0.001 199.0 Dp2 7.7 56.2 322.0 54.4 18.3 54.2 2.5 43.8 12.6 2.2 2.3 <0.006 <0.006 0.01 211.0 Dp3 7.9 51.6 300.0 32.8 18.5 64.8 4.0 37.5 6.1 <0.057 2.1 <0.006 <0.006 0.1 158.0 JANCOETZER1 8.0 46.4 264.0 56.8 15.3 19.8 1.8 10.3 6.6 0.3 0.4 <0.006 <0.006 <0.001 205.0 JANCOETZER3 7.4 49.5 269.0 42.5 21.9 27.7 2.1 18.5 0.9 0.3 0.4 <0.006 <0.006 0.5 196.0 MARTIN11 7.9 87.5 507.0 98.0 48.8 24.6 4.6 13.7 4.9 0.2 0.5 <0.006 <0.006 <0.001 446.0 MARTIN12 8.2 30.1 168.0 29.9 16.5 7.7 2.6 8.9 4.9 0.5 0.5 <0.006 <0.006 <0.001 142.0 MARTIN2 7.6 83.7 470.0 81.0 47.4 28.3 2.6 25.4 10.0 1.5 1.0 <0.006 <0.006 <0.001 397.0 MARTIN3 7.8 81.7 447.0 78.8 44.9 29.7 2.8 27.9 10.6 1.7 1.0 <0.006 <0.006 <0.001 382.0 MARTIN6 7.9 70.8 385.0 66.1 37.6 24.7 3.0 22.1 9.7 1.3 1.3 <0.006 <0.006 <0.001 320.0 MARTIN8 7.7 87.0 487.0 91.5 48.8 22.9 4.2 22.6 10.0 0.9 1.0 <0.006 <0.006 <0.001 430.0 MELETSE06 7.4 14.6 83.0 10.1 8.6 6.7 3.6 7.6 0.8 0.2 0.3 <0.006 <0.006 <0.001 61.0 MELETSE09 8.0 86.7 494.0 76.9 59.0 25.6 2.5 17.2 7.0 1.0 0.4 <0.006 <0.006 <0.001 435.0 MELETSE12 7.4 37.0 205.0 29.2 10.0 33.5 3.7 20.0 4.9 0.2 3.1 <0.006 <0.006 0.2 114.0 MELETSE15 8.2 61.9 335.0 55.9 33.4 21.3 2.4 17.4 6.7 0.6 1.2 <0.006 <0.006 <0.001 277.0 VENTER01 7.7 85.3 470.0 80.6 49.2 14.6 11.1 24.4 8.1 0.8 0.3 <0.006 <0.006 <0.001 404.0 VENTER03 8.1 87.9 513.0 86.2 67.7 7.2 2.5 13.1 11.7 2.2 0.4 <0.006 <0.006 <0.001 494.0 VENTER06 7.8 86.3 493.0 93.3 51.6 15.2 2.7 24.0 19.7 0.5 0.5 <0.006 <0.006 <0.001 446.0 VENTER07 7.5 108.0 616.0 109.0 73.4 3.4 2.1 42.0 20.9 9.8 0.4 <0.006 <0.006 <0.001 574.0 Wv1 7.7 86.3 461.0 75.6 67.4 23.0 1.7 20.3 10.3 0.8 0.4 <0.006 <0.006 <0.001 466.0 Wv2 7.5 83.6 434.0 65.7 63.9 19.6 1.8 18.6 8.9 0.4 0.4 <0.006 <0.006 <0.001 427.0 Wv3 7.7 102.6 472.0 62.9 72.4 14.1 2.2 12.8 19.1 0.4 0.4 <0.006 <0.006 0.05 455.0 Wv4 8.4 63.0 349.0 59.7 49.6 15.2 1.3 5.6 5.2 <0.057 0.3 <0.006 <0.006 <0.001 353.0 Wv5 7.8 81.0 453.0 59.3 68.1 19.0 5.5 45.8 32.6 0.9 0.4 <0.006 <0.006 <0.001 429.0 Wv6 7.7 23.1 125.0 21.8 10.0 13.7 3.1 11.5 5.4 <0.057 0.4 0.01 <0.006 <0.001 95.0 Wv7 8.0 76.1 409.0 68.4 49.7 22.1 1.9 22.6 15.4 <0.057 0.6 <0.006 <0.006 0.01 375.0 Note: Values shaded with red are those exceeding the permissible SANS concentrations for drinking water purposes.

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1.1.10.2 Ground water quality site description Site specific groundwater quality information was obtained from eight newly drilled groundwater monitoring and water supply boreholes. The monitoring boreholes were sited mainly down gradient from potential sources of groundwater contamination, whereas geological structures such as dykes and faults were targeted by the water supply boreholes.

An overall domination in bicarbonate alkalinity suggests the absence of pyrite oxidation within the immediate vicinity of the project area. The baseline groundwater quality on site is good and water from the majority of boreholes is suitable for human consumption (SANS241:2011).The groundwater manganese content measured in boreholes MMBH03 and WBH08 exceeds the permissible SANS value of 0.5 mg/l. Only sensitive users are expected to be affected at these concentrations, however taste and colour impairments may be noticed at concentrations as low as 0.1 mg/l. Fluoride concentrations measured in boreholes WBH08 and MWBH05 exceed the permissible SANS concentration of 1.5 mg/l.

1.1.10.2.1 Depth of water tables Groundwater levels in the proposed mining area are available from purpose drilled monitoring and water supply boreholes. Water levels were also measured in user boreholes located within a ± 20 km radius of the project area. The groundwater level depth varies from approximately 10 to 194 meters below surface and is expected to be even deeper in the northern half of the mining rights area where the proposed opencast mining will occur. Most groundwater levels (>20 meters below surface) are representative of the deeper fractured rock aquifer and not of the shallow weathered zone aquifer.

The water table in the area generally follows the surface topography, except in the mountainous areas where groundwater levels are expected to be much deeper. Some groundwater levels measured during the hydrocensus were significantly deeper than the general trend due to groundwater abstraction for the purpose of domestic use. Due to the generally low aquifer transmissivities the groundwater abstraction causes a deep drawdown of the groundwater levels/piezometric heads and depression cones form that are deep, but very limited in lateral extent

All available groundwater levels will be used as calibration points for the numerical groundwater flow model to verify the conceptual model and construction thereof. Seen in the light of water level differences because of mining, pumping and recharge effects, filtering and processing of water levels are conducted to remove water levels considered anomalous high or low. In order to identify the water level anomalies a statistical analysis were conducted during which the correlation between the water level elevations and the elevations of the boreholes were calculated.

After the anomalies were identified and removed, a ± 77% correlation was achieved. This correlation is not very good and is considered to be a direct result of the highly variable topography, especially

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 86 of 328 Management Programme under the MPRDA, 2002 the steep and high mountain range. The correlation graph is indicated in Figure 17. The final interpolated digital terrain model of the water levels is thus bound to contain local over- or under estimations of the actual water levels, but it will be representative of the general regional trend of the static groundwater level.

Groundwater Elevation vs Surface Elevation 1180

1160 R² = 0.7748

1140

1120

1100

1080

1060 GroundwaterElevation (mamsl)

1040

1020

1000 960 980 1000 1020 1040 1060 1080 1100 1120 1140 1160 Surface Elevation (mamsl)

Figure 17: Water level elevation and topography correlation

For the purpose of numerical modelling, however, some representative average groundwater level has to be specified as a starting point. There are also not enough groundwater level measurements available in each of the co-existing aquifer systems to produce a separate water level contour map for each system. It is thus likely that over-estimation in some areas and under-estimation of the water level in other areas will arise in the model. With the immense heterogeneous characteristics of fractured rock aquifers, interpolation of the water level with recognised techniques is preferable. The resulting groundwater level contours represent average static water levels expected among an unknown number of co-existing aquifers.

The natural interpolated groundwater level contours (without impacts from mining/other) were estimated through Bayesian interpolation and are presented in Figure 18. The natural flow direction of groundwater in the weathered zone aquifer in the project area was derived from the abovementioned figure and is generally towards the south, south-east and south-west in the direction of the Sand River. According to Figure 18 the lowest groundwater level elevation is approximately 900 mamsl and occurs to the south of the mining rights area, while the highest elevation of ± 1 650

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 87 of 328 Management Programme under the MPRDA, 2002 mamsl occurs in the mountainous region where the proposed opencast mining is planned to take place.

Meletse 1650 -2717000 MRA 1600 Proposed 1550 opencast pit 1500 -2719000 1450

1400

1350 -2721000 1300

1250

1200

-2723000 1150

1100

1050

1000 -2725000 Sand 950 River 900 63000 65000 67000 69000 71000 Figure 18: Bayesian interpolated groundwater level contours

1.1.10.2.2 Groundwater zones The following aspects typically delineate the applicable “groundwater zone”:  The thickness, soil characteristics, infiltration rate and water bearing properties of the unsaturated zone,  The geological properties and dimensions of each unit in the geological column that could potentially be impacted upon by groundwater contamination. This includes rock type, thickness of aquifer(s) and confining units, aerial distribution, structural configuration, storativity, water levels, infiltration or leakage rate, if appropriate,  Aquifer recharge and discharge rates,  The direction and rate of groundwater movement in potentially impacted units,  Groundwater and surface water relationships,  Background water quality of potentially impacted units,

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 Potential sources and types of contamination.

Unsaturated Zone Soil development in the northern half of the mining rights area is virtually non-existing with the unsaturated zone mainly being composed of scree and weathered rock. The unsaturated zone in the southern portion is however composed of freely drained and structureless soils of varying depths. Underneath the soils the unsaturated zone is characterised by weathered or fresh rock and scree originating from the mountain. The unsaturated zone impacts on the aquifer in terms of both groundwater quality and quantity.

The permeability and thickness of the unsaturated zone are some of the main factors determining the infiltration rate, the amount of runoff and consequently the effective recharge percentage of rainfall to the aquifer.

The type of material forming the unsaturated zone as well as the permeability and texture will significantly influence the mass transport of surface contamination to the underlying aquifer(s). Factors like ion exchange, retardation, bio-degradation and dispersion all play a role in the unsaturated zone.

The thickness of the unsaturated zone was determined by subtracting the pre-mining static water levels in the study area from the topography. Water level measurements in boreholes of users in the area as well as in purpose drilled monitoring and water supply boreholes showed that the depth to water level, and thus the unsaturated zone, generally varies between ± 10 and 194 meters below surface. The thickness of the unsaturated zone is expected to be even deeper in the northern half of the mining rights area with a depth of >500 meters estimated for the area underlying the proposed opencast pit.

1.1.10.3 Groundwater use Numerous hydrocensus and groundwater user surveys were conducted within a ± 20 km radius of the proposed site. A summary of the findings is provided in Table 21. A total of 76 boreholes were located and their positions are indicated in Figure 19.

Table 21: Summary of hydrocensus and groundwater user survey BH South East Use SWL (m) Depth (m) AVANCOLLER1 -24.58330 27.68368 Domestic 9.4 27 AVANCOLLER2 -24.58328 27.68428 N/A 6.9 27 AVANCOLLER3 -24.58190 27.68621 N/A 9.8 57 AVANCOLLER4 -24.58374 27.68484 N/A N/A N/A AVANCOLLER5 -24.56857 27.67384 N/A 7.8 >120

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BH South East Use SWL (m) Depth (m) JANCOETZER1 -24.56841 27.68844 Domestic, 31.2 60 livestock JANCOETZER2 -24.56715 27.68794 Livestock 14.3 65 JANCOETZER3 -24.57600 27.68726 Domestic, 15.8 60 livestock MARTIN1 -24.63128 27.63526 Not working 21.1 30 currently MARTIN2 -24.63128 27.63526 Irregation 22.9 50 MARTIN3 -24.63036 27.63514 Irregation N/A 50 MARTIN4 -24.63045 27.63476 Irregation 21.7 30 MARTIN5 -24.63045 27.63476 N/A N/A 30 MARTIN6 -24.63039 27.63395 Domestic N/A 30 MARTIN7 -24.63011 27.63250 Dry @ 17 m Dry 17 MARTIN8 -24.63646 27.63157 Domestic, 23.1 30 irrigation MARTIN9 -24.64911 27.64080 Livestock N/A N/A MARTIN10 -24.63506 27.65187 Livestock N/A N/A MARTIN11 -24.62933 27.65396 Livestock N/A N/A MARTIN12 -24.62277 27.64078 Livestock N/A N/A MARTIN13 -24.63272 27.63546 N/A 17.2 60 MARTIN14 -24.62747 27.62203 Dry @ 8 m N/A N/A MELETSE01 -24.62388 27.87577 Domestic 23.3 60 MELETSE02 -24.62605 27.88131 Livestock N/A N/A MELETSE03 -24.59718 27.84512 Domestic 29.4 60 MELETSE04 -24.59499 27.82561 Future plans N/A N/A MELETSE05 -24.59945 27.79777 Domestic 14.3 50 MELETSE06 -24.60241 27.79946 Domestic 17.4 86 MELETSE07 -24.61225 27.80557 Livestock 31.2 75 MELETSE08 -24.61225 27.80557 Dry @ 34.7 m N/A N/A MELETSE09 -24.61202 27.80616 Domestic 31.4 90 MELETSE10 -24.59658 27.73955 Pump fitted not N/A N/A working MELETSE11 -24.59516 27.74009 Blocked @ 7.4 N/A N/A m MELETSE12 -24.60330 27.71133 Domestic 25.6 100 MELETSE13 -24.60693 27.72320 Livestock 20.6 75 MELETSE14 -24.60693 27.72320 N/A 20.7 75 MELETSE15 -24.62373 27.72262 Irrigation N/A N/A MELETSE16 -24.62192 27.73928 Livestock 47.1 100 MELETSE17 -24.60626 27.74775 Future plans N/A N/A MELETSE18 -24.61406 27.75972 Future plans 39.1 100 MELETSE19 -24.61406 27.75972 Future plans 37.2 100

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BH South East Use SWL (m) Depth (m) VENTER01 -24.62246 27.59105 Domestic 49.0 60 VENTER02 -24.62233 27.59059 Domestic N/A 100 VENTER03 -24.62023 27.56646 Domestic N/A 100 VENTER04 -24.57466 27.48286 Livestock N/A 100 VENTER05 -24.62062 27.60671 N/A 6.7 100 VENTER06 -24.61810 27.60648 Livestock N/A 100 VENTER07 -24.61497 27.64282 Livestock N/A 100 BH01 -24.62490 27.60960 Domestic, N/A 30 livestock BH02 -24.62557 27.61039 Irrigation, N/A 24.8 livestock and domestic BH03 -24.62758 27.60998 Future use 14.2 130 BH04 -24.62512 27.60964 New use 14.6 30 BH05 -24.62784 27.61596 Rooiberg water N/A 28.25 supply BH06 -24.63239 27.60565 Future use 8.8 32 BH07 -24.62555 27.60953 Future irrigation 14.6 20.25 BH08 -24.63512 27.61957 Domestic, 13.3 100 livestock BH09 -24.63554 27.62339 Blocked @ 14 N/A N/A m BH10 -24.63903 27.62253 Blocked @ N/A N/A 20.6 m Wv 1 -24.62250 27.59100 Domestic N/A N/A Wv 2 -24.62238 27.59054 Domestic N/A N/A Wv 3 -24.62030 27.56646 Wildlife N/A N/A Wv 4 -24.62078 27.53723 Wildlife N/A N/A Wv 5 -24.60717 27.54849 Wildlife 16.8 N/A Wv 6 -24.61953 27.57075 Wildlife N/A N/A Wv 7 -24.61796 27.60618 Wildlife N/A N/A Wv 8 -24.61484 27.64274 Wildlife N/A N/A Dp 1 -24.61912 27.60669 Domestic N/A N/A Dp 2 -24.59742 27.67999 Domestic 34.1 N/A Dp 3 -24.59677 27.67635 N/A 46.3 N/A DT1W -24.58997 27.67222 Domestic and 103.0 N/A exploration DT4L -24.59205 27.68135 Domestic and 72.0 N/A exploration Waterhole1 -24.59728 27.67996 Domestic N/A N/A and exploration

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BH South East Use SWL (m) Depth (m) Waterhole2 -24.59313 27.66863 Domestic 194.0 N/A and exploration DT81 -24.59483 27.67011 Domestic 80.1 N/A and exploration DT79 -24.58568 27.67646 Domestic N/A N/A and exploration DT80 -24.59436 27.67307 Domestic 68.8 N/A and exploration

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Figure 19: Localities recorded during the Meletse user surveys

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Groundwater use

Domestic Exploration Irrigation Livestock Not in use

29% 33%

9%

5% 24%

Figure 20: Results of groundwater user survey

The pie chart provided above in Figure 20 indicates that approximately 29% of boreholes located during the user surveys are used for domestic water supply, while ± 24% are used to provide water for livestock. A large portion of the boreholes (± 33%) are however currently not in use as a result of obstacles blocking access to their water levels or pumps not being operational. Only approximately 5% of boreholes located during the numerous surveys are used for small scale irrigation.

Widespread pollution or depletion of the groundwater resource will impact negatively on: the groundwater resource itself and interrelations with other natural resources (e.g. rivers and streams), and the users that depend on groundwater as sole source of domestic water as well as for livestock and gardening.

1.1.11 Air quality

1.1.11.1 General description The proposed site falls within the Waterberg district municipality. Waterberg is currently not an air pollution ‘hot spot’ but has been declared a priority area anticipating the future developments in the area which could result in the area experiencing severe air pollution problems. As a priority area, the area is considered to exceed ambient air quality standards and cause a significant negative impact on air quality and human health. Other mining operations in the Thabazimbi area that impact on the air quality include Thabazimbi Mine and other industrial activities in or closer to the town of Thabazimbi. Existing mining operations in the area include Amandelbult Platinum Mine and Cronimet Chrome Mine

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1.1.11.2 Site specific description Airshed Planning Professionals (Pty) Ltd was commissioned to measure atmospheric deposition from May 2011 to Nov 2013 on the Donkerpoort and Klipgat prospecting rights, in Thabazimbi, Limpopo province as part of an Environmental Impact Assessment (EIA) process to be followed (Refer to Appendix E7). According to these studies values continue to be well within proposed residential limits. Refer to Table 22 for deposition results of November 2013.

Table 22: Atmospheric deposition results (mg/m²/day) at Aquila Iron site: June 2011 to July 2012 taken from the atmospheric deposition monitoring report compiled by Airshed Planning Professionals Location 30 May to 30 Jun to 1 Aug to 28 Aug to 28 Sept to 31 Oct to number 30 Jun 2011 1 Aug 2011 28 Aug 2011 28 Sept 31 Oct 2011 28 Nov 2011 2011 Days 31 32 27 31 33 28 1 47 258 284 145 393 212 2 81 269 201 46 Overturned Replaced 3 57 130 179 24 102 78 4 177 76 84 0 150 58 5 291 160 62 48 210 111 6 262 126 139 Overturned 211 113 Location 28 Nov 2011 27 Jan to 27 Feb to 29 Mar to 7 May to 4 June to number to 27 Jan 27 Feb 2012 29 Mar 2012 7 May 2012 4 June 2012 5 July 2012 2012 Days 60 31 31 38 28 31 1 80 127 475 83 160 72 2 Damaged 119 403 25 53 63 3 95 101 Damaged 7 Damaged 74 4 249 Damaged 410 22 39 69* 5 81 162 412 55 79 156* 6 172 124 401 27 Damaged 33 Location 5 July to 2 Aug to 30 Aug to 27 Sept to 31 Oct to 29 Nov 2012 number 2 Aug 2012 30 Aug 2012 27 Sept 31 Oct 2012 29 Nov 2012 to 31 Jan 2012 2013 Days 28 28 28 35 29 63 1 133 - - 142 20 216 2 141 101 317 122 87 133 3 25 82 52 37 8* 99 4 61 69* 66 61 24 - 5 109 118* 141* 104 115 120 6 101 116 132 125 87 123 Location 31 Jan to 7 Mar to 14 Apr to 10 May to 12 Jun to 20 Jul to 15 number 7 mar 2013 14 Apr 2013 10 May 2013 12 June 20 Jul 2013 Aug 2013

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2013

Days 35 38 26 33 38 26 1 85 - - - - - 2 172 42 36 56 38 143 3 132 19 20 47 17 * 4 145 20 32 68 18 102 5 125 49 58 37 45 30 6 205 46 59 102 43 47 Location number 15 Aug to 30 Sep 2013 30 Sep to 31 Oct 2013 31 Oct to 28 Nov 2013 Days 46 31 28 1 - - - 2 209 79 115 3 52 95 87 4 50 76 79 5 61 83 80 6 85 97 102

1.1.12 Noise An environmental noise survey was conducted by Varicon from April 2011 to February 2012 around the proposed mining area as part of the Environmental Impact Assessment (EIA) process to be followed (Refer to Appendix E8 for comprehensive details on this survey). The sound levels were evaluated against the standards as specified in the SABS Code of Practice 0103 of 2008 (The measurement and rating of environmental noise with respect to land use, health, annoyance and to speech communication) with reference to Code SABS 0328 of 2003 (Environmental Noise Impact Assessments).

For the purpose of this survey and according to SABS 0103 of 2008, it is probable that the noise will be annoying, or otherwise intrusive to the community, or to a group of people, if the rating level of the ambient noise under investigation exceeds the typical rating levels for the ambient noise as given in Table 23 below. Applicable values in the tabulation are highlighted.

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Table 23: Typical rating levels for ambient noise in districts

Type of Equivalent Continuous Rating Level (LReq.T) for Ambient Noise District Outdoors Indoors, with open windows Day-night Day-time Night-time Day-night Day-time Night-time (a) Rural 45 45 35 35 35 25 Districts

(b) 50 50 40 40 40 30 Suburban with little road traffic

(c) Urban 55 55 45 45 45 35 Districts

(d) Urban 60 60 50 50 50 40 districts with some workshops, business premises and with main roads. (e) Central 65 65 55 55 55 45 Business Districts

(f) 70 70 60 60 60 50 Industrial Districts

Stationery noise levels were measured at pre-selected position around the proposed mining area on the top of the mountain and some measurements were also taken at the bottom of the hill at the main entrance as part of the baseline. The measurement positions were selected around the proposed mining area and at specific locations down the mountain side. Fortunately all activities on the mountain are remote and secluded from any formal or informal communities. The noise levels all were measured within the recommended levels that could cause disturbance to any community that could be affected. Refer to Table 24 for noise results in February 2012. According to Varicon’s findings the noise levels in Portion 4 is 24.9dBA and Portion 5 is 33.6dBA. These levels are well within the prescribed requirements of rural districts which are 45dBA for daytime and 35dBA for night time. The noise levels of Portion 1, 2 and 3 were slightly above the prescribed requirements, but these should have no influence on any surrounding communities. The sound levels at the farmhouse are perfectly within prescribed requirements and the activities should present no disturbance to the farming communities.

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Table 24: Typical rating levels for ambient noise in districts INITIAL NOISE LEVELS AT VARIOUS SAMPLING LOCATIONS AROUND THE PROPOSED MINING SITE AMBIENT NOISE (dB(A)) Day Time Levels

Average Results Typical Excess ∆LReq,T Rating (dBA) Measuring Positions (SABS 0103) Remarks (Category A) April August November February April August November February 2011 2011 2011 2012 2011 2011 2011 2012

Position 1: 51,6 55,9 35,6 39,4 45,00 +6,6 + 10,9 -9,4 -5,6 Day Time: - Noise from the drill ± 450m North East of machine. Machine is secluded the D043 Drill from the measuring position. Position 2: 61,6 60,5 41,4 42,0 45,00 +16,6 -15,5 -3,6 -3,0 Day Time: - Again the noise from ± 1000m North East of the drill machine. Measuring the D043 Drill and position on top of the hill. Drill North East of the machine was deeper into the proposed mining site. valley and therefore the noise levels are lower. Measurement more direct in line with machine noise. Position 3: 62,6 52,1 44,4 46,7 45,00 +17,6 +17,6 -0,6 +1,7 Day Time: - Main noise source is South East of the the drill machine. Measuring mining pit and ±1000m position on top of the hill. Drill from both the drill Machine was deeper into the machines valley and therefore the noise levels are lower. Position 4: 24,9 29,7 28,8 28,5 45,00 -20,1 -15,3 -16,2 -16,5 Day Time: - General background West of the mining and bushveld noise. Totally area halfway down the isolated from the noise generated

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mountain. ±2000 m by the drill machines. from the drill activities

Position 5: 33,6 31,7 32,2 31,0 45,00 -11,4 -13,3 -12,8 -14,0 Day Time: - General bushveld Main entrance into the noise and some vehicle traffic on mining property at the the dirt road. No influence from the bottom of the activities at the mine site on top of mountain. the mountain.

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1.1.13 Sensitive landscapes According to an ecological evaluation report for the proposed mining project, compiled by Pachnoda Consulting CC (refer to Appendix E1 for comprehensive details on Ecological evaluation); sensitive landscapes located on the site include the kloofs, indigenous forest and the grassland.

Donkerpoort also supports a healthy population of Cheilanthes deltoidea subsp. silicicola with an approximate area of occupancy of 124 ha. This locality represents the second known population of C. deltoidea subsp. silicicola in the Waterberg region. The bulk of the population corresponds to primary floristic communities at higher elevations and mostly on relatively steep slopes. It is typically associated with grassland communities dominated by an open Loudetia flavida - Monocymbium ceresiiforme and Protea caffra - Bewsia biflora alliance. However, it is also confined to woodland dominated by an Acacia caffra - Combretum molle - Diheteropogon amplectens composition, albeit its occurrence is scattered and of low density. Both the Protea caffra – Loudetia flavida savannoid grassland and the Acacia caffra – Combretum molle – Diheteropogon amplectens woodland represent primary compositions. These communities together with the forest are considered as sensitive.

Sensitive landscape identified within Randstephne includes the cave [as described in the Cultural Heritage Resources Assay Report for the farms Donkerpoort 448KQ, Randstephne 455KQ and Waterval 443KQ, Thabazimbi, Limpopo Province; dated June 2011; compiled by Sidney Miller of African Heritage Consultants CC (For comprehensive details on the heritage study refer to Addendum 8)] and the indigenous forest [as described in an ecological evaluation report for the Aquila Steel project, Thabazimbi Donkerpoort dated January 2012; compiled by Pachnoda Consulting CC]. The indigenous forest is situated on the north western side of Donkerpoort and overlaps to the north- eastern border of the farm Randstephne. The indigenous forest is recognised as an area of special concern. The forest does not stretch from the foot slopes of the mountain but starts higher up in the mountain towards the top of the mountain. The cave is situated some four kilometres SSW of the proposed mining site and over 600m lower in elevation. The cave is known to be used as a roosting site for the Short-eared Trident Bat (Cloeotis percivali), which conservation status is listed as Critically Endangered by the Endangered Wildlife Trust. The cave is also situated at the foot slope of the mountainous area and is not situated at the higher altitudes where the location of Meletse iron ore mine is proposed. The protection of cave roosting sites is an essential management tool for the survival of this species. It is not known if this species roosts in the specific caves throughout the year.

The proposed site is located outside of the Waterberg biosphere reserve.

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1.1.14 Visual aspects The following information was extracted from a Visual Impact Assessment study compiled by Zoneland Solutions, dated January 2014, attached hereto in Appendix E9. As part of the study, one dominant view corridor was identified in the region, namely the:  P240, which is the main movement route along the southern boundary of the contravened site. The nearest settlement to the proposed site is the district town of Thabazimbi, approximately 30km west of the site. The P240 connects with the D928 (approximately 4.5km west of the site) and the D1485 (15km from the site) en route to Thabazimbi. All of these roads have a gravel surface and carries little load. None of these roads where therefore regarded as dominant view corridors.

The proposed site is located between contour levels 1000 and 1582m above sea level. This represents a 582m vertical climb over ±4.3km. The Meletse peak is the highest peak within 10km from the contravened site. The mountain is therefore particularly visually exposed and visible from most observation points in the landscape as all observation points are located at a height below the contravened site.

1.2 Concise description of each of the existing environmental aspects both on the site applied for and in the surrounding area which may require protection or remediation All environmental aspects that may require protection from the proposed mine’s potential impacts were described in detail in the above sections. This includes:  Red Listed Species: The proposed site supports a healthy population of Cheilanthes deltoidea subsp. silicicola with an approximate area of occupancy of 124 ha. The threatened (“vulnerable”; Raimondo et. al., 2009) pteridophyte Cheilanthes deltoidea subsp. silicicola was confirmed from the Loudetia flavida – Monocymbium ceresiiforme grassland of the mountain summit. This species is restricted to the rock crevices and sheltered soil pockets of the large boulders that are located in open grassland.  Gatkop Cave (24º 37’ 05.2” S, 27º 39’ 08.4” E) is a sizeable dolomitic cavern set in gently sloping, semi-arid thornveld terrain on the southern foothills of the Gatkop – Meletse mountain range, Limpopo Province. The cave is situated some four kilometres SSW of the mining area and over 600m lower in elevation. This site must be treated with utmost care from a cultural point of view.  The indigenous forest situated on the north western side of Donkerpoort and overlaps to the north-eastern border of the farm Randstephne. The indigenous forest is recognised as an area of special concern. The forest does not stretch from the foot slopes of the mountain but starts higher up in the mountain towards the top of the mountain  The Homestead

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 The Graves  Land use and capability;  All water resources  Air quality in terms of dust generation;

1.3 Concise description of the specific land uses, cultural and heritage aspects and infrastructure on the site and neighbouring properties/farms in respect of which the potential exists for the socio-economic conditions of other parties to be affected by the proposed mining operation

1.3.1 Land use

1.3.1.1 Pre-mining land use The area is characterised by wilderness and thicket and is utilised as a residence and for highly limited eco-tourism activities; mainly game farming and game lodging. Prospecting has also been conducted on the land; however, no mining has taken place.

1.3.1.2 Present land use There are crop fields towards the western side of the Crocodile River and irrigated land some distance to the east of the river. The current land use on the site is a mix of residential and highly limited eco-tourism. Prospecting has also been conducted on the land; however, no mining has taken place.

1.3.1.3 Land misuse Within the district area the challenges that are found include degradation of the land caused by overgrazing and deforestation.

1.3.2 Sites of archaeological and cultural interests The Gatkop cave, situated some four kilometres SSW of the main mining area and over 600m lower in elevation, is of considerable cultural, historical and archaeological significance, as recognised in the study of Iron Age archaeology of the Rooiberg region, Limpopo, by Hall (1981). The Gatkop cave is regularly visited for religious purposes. It is well defined by a sturdy game fence and is under supervision. Gatkop Cave probably played a role as a refuge site from Mzilikazi’s Ndebele impis during the early nineteenth century Mfecane, and perhaps also later following the arrival of the European trekboers. It is apparent that the archaeological resources within the cave – such as the wooden kraals and abundant pottery recorded by Hall in the large entrance chamber - have since

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 102 of 328 Management Programme under the MPRDA, 2002 been considerably degraded. Surface scatters of archaeological material are still apparent in front of the mouth of the cave. These include ostrich eggshell beads, abundant shards of Iron Age pottery assignable to the Late Iron Age (Hall’s 1981 Rooiberg Unit 3, approximately dated to the Fifteenth Century) as well as Middle Stone Age flakes of ferruginous quartzite (Amanda Esterhuysen, Madelon Tusenius, pers. comm., 2011).

1.3.2.1 Heritage remains inside mine boundary area The following information was extracted from the Cultural Heritage Resources Assay Report for the farms Donkerpoort 448KQ, Randstephne 455KQ and Waterval 443KQ, Thabazimbi, Limpopo Province; dated June 2011; compiled by Sidney Miller of African Heritage Consultants CC. For comprehensive details on the heritage study refer to Appendix E4 and to Figure 21 below for a Google image showing concentrations of heritage resources on the farms that were assessed. The following sites of heritage significance were identified.

Site 1. The grave of one J.H.T.O. PERREIRA is located on the banks of the Sondagsrivier close to the bridge. On the 1: 50 000 map 2427DA SANDRIVIERSPOORT the abbreviation ‘R’ represents a watering point (possibly an old ‘drif’ and ‘uitspanning’) on the ‘old road’. The inscriptions on his headstone gives the following information; born in 1881 being a ‘Burger’ of the Z.A.R., occupation as ‘KRUITMAKER and cause of death as ‘VERMOOR’ IN 1901.

Site 3a the original Randstephne homestead. It contains classical ‘South African Edwardian’ features in the flanked front veranda where both flanking rooms support Cape Dutch Gables. This building is one of few remaining in the region from this period as few were originally built, and of those most were lost in the processes of ‘upgrading and modernization’.

Site 3b. Closely associated with this homestead is the graveyard and former dwellings of the farm labourers that (one must assume), was the workforce of the dwelling on Randstephne. Owing to the physical nature of these dwellings they have long since disappeared, but the graves remain, and are obviously still tended to from time to time by relations. The dwellings will not benefit with any further attention and need not to be protected. The 13 (?) graves on the other hand are also protected under other laws apart from the National Heritage Act. These may be left in situ, and visiting rights may be negotiated with relations. Alternatively they may be exhumed and reburied in a formal burial site.

Site 4. The rest of the sites are all related to the early nineteenth century Iron Age period and has been treated as a collective. These include ‘mines’ (3?), ‘smelting sites’ (1), ‘animal enclosures’ (Site 4a,4b, 4d and 4e) and ‘living areas’ (2?). The ‘group’ is assumed to date from the stressful civil war period known as the Mfecane, or Defecane dating to the period of Mzilikazi, the renegade Zulu General that ruled most of the central and south ‘Transvaal’ circa1800 to 1845.

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The sites are individually not rare, or of outstanding quality, they are not deemed to be particularly worthy of preservation on their own.

Site 5. The last subjects are the weir and bridge over the Sondagsrivier, possibly dating to circa 1940 and 1960. Owing to ‘progress’ South Africa is fast losing these type of structures that had in fact opened the ‘frontiers for ‘development’.

1.3.2.2 Heritage remains outside mine boundary area Site 4c: This is a part of the wall of the cattle enclosure at this site. It has a diameter of approximately 10 meters. Although apparently isolated it is part of the greater use of land by people under stress where they retain their cattle at the base of their mountain retreat so as to avoid climbing the mountain every day. It is a fair copy of the enclosure at site 4a and 4b but is located a fair distance to the east. This may be associated with a different settlement.

1.3.3 Existing infrastructure A homestead exists on the farm Randstephne. The homestead is one of the few remaining buildings in the region from this period as few were originally built, and of those most were lost in the processes of ‘upgrading and modernization’.

1.3.4 Regional socio-economic structures This section was compiled using the following documents:  Waterberg District Municipality 2011/12 Integrated Development Plan,  Thabazimbi Local Municipality Integrated Development Plan 2012/13 and  The Social Baseline Scoping Report; compiled by Ptersa Environmental Management Consultants: San-Marié Aucamp dated November 2011. For comprehensive details on this report refer to Appendix E12.

1.3.4.1 Demographic Profile

1.3.4.1.1 Population and population distribution Limpopo Province Limpopo’s population stands at 5.5 million, the largest proportion of which (27.2%) is resident in the Vhembe district municipality.

Unemployment in the province averages 48% (as against the national average of 26%) and about 65% of the population is classified as living in poverty. Its considerable reserves of agriculture, mineral and tourism resources remain hugely under-exploited.

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Waterberg District Municipality The Waterberg District Municipality has a total population of 596,092 of which the majority of people in villages and townships are still trapped in poverty. The state of local economy is such that 21% of households are rated as low income households as they earn less than R1,000 per month, with 20% of the potentially economically active population unemployed.

While 86% of South African households have access to a piped water source, 83% do so in WDM while 96% do so in TLM. It is however important to note that on average less households access their water from their own yard in South Africa than in TLM and WDM. Only 40% of the WDM residents have flush toilet sanitation. Statistics South Africa estimates that TLM fares better with 58% having access to flush toilet sanitation.

The water supply situation is that some of the schools particularly those in rural areas have no access to on-site water. The schools are also in need of refurbishment and services such as water and sanitation. There is also a great need for high schools in the rural areas; the majority of education facilities are primary schools

In the case of WDM, the lack of access to electricity is most acute in remote rural areas. In TLM, almost 50% of households rely on gas, paraffin and candles. The majority of households which do not have access to electricity in the municipality are located in the informal settlements and new settlements. Ipeleng is by far the most electrified host community, with over 99% of household having electricity. The remaining settlements have electricity access of between 55 and 65%.

On the health front, 110 villages (representing nearly 65% of the population) are situated outside the clinic catchment areas.

Thabazimbi Local Municipality The TLM has a total population of 85,234. Most of the people in the area are between the ages of 30 and 49 years (37.87%) followed by the 5-19 year age group, which represents 22.18% of the population.

Males outnumber females with approximately 58% of the total population being male; this can be ascribed to the number of mine workers employed locally and job seekers who have settled in the area. The mines are the largest employers, followed by agriculture and the service sectors. Approximately 20.6% of potentially economically active people are unemployed.

In national terms it is a mature population with only 34% of the population under the age of 20. This possibly reflects the high degree of labour migrancy as a result of the mines in the region. Population projections from 2001 onward show a steady annual increase of 2.63% per annum to a total of about 85,234 in 2011. The statistics used here are based mainly on the 2011 figures released by Stats SA.

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Approximately 9,879 young people within the TLM are currently not attending school. 26.1% of economically active individuals in the TLM have attained a Grade 12 education. Alarmingly, only 8.1% have an education level higher than grade 12. The majority of economically active individuals have an education level that is below Grade 7. Refer to Table 25 below for Thabazimbi Local Municipality Population Statistics.

Table 25: Thabazimbi Municipality Population Statistics (Census 2011) Population group Figures Black African 72 103 Coloured 511 Indian or Asian 341 White 12 274 Total population 85 234 (*Source: Census 2011 Community Profiles Database. Statistics South Africa.)

1.3.4.1.2 Age Table 26 below shows the age distribution for the Thabazimbi Local Municipality according to Census 2011. The Thabazimbi LM has the largest proportion of people aged between 25 – 49 years, while Ward 2 of the Thabazimbi LM has the largest proportion of people aged between 50 – 64 years.

Table 26: Age distribution Age interval Age distribution 0-14 21.1 15-24 16.7 25-34 25.5 35-49 23.6 50-64 10.7 65+ 2.4 (*****Source: Census 2011)

1.3.4.2 Education Profile Education plays a pivotal role on community development, providing basic skills for development, creativity and innovative abilities within individuals. Constitution of SA provides that everyone has a right to education but Education profile of Thabazimbi is another area of concern such that approximately 9027 of the population in 2007 comprised of matriculants who can be classified as semi-skilled. Some factors could be drop-outs due to extreme poverty, child headed families, teenage pregnancy etc. School curriculum should be responsive to economic need. Very few people within the Municipal area attend Colleges, Technikons, Universities and adult education Centre.

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Table 27 below indicates that majority of people attended Grade 7-9 in all the given years. There is a need for tertiary as the numbers decreases from matric only to matric and Post-graduate degree. Table 27 also indicates that 6 661 people within the Municipal area never attended school. This means that 9, 4% of the population never had access to formal education

Table 27: Education level for Thabazimbi municipality Highest level of Education 2007 Grade 0 973 Grade 1 832 Grade 2 1 403 Grade 3/ std1/ ABET 1 1 932 Grade 4/ std 2 1 840 Grade 5/ std3/ ABET 2 2 630 Grade 6/ std4 2 874 Grade 7/std5/ ABET 3 3 305 Grade 8/ std6 4 631 Grade 9/std7/ ABET 4 4 665 Grade 10/ std8/ NTC i 5 340 Grade 11/ std9/ NTCII 3 196 Attended Grade 12 but not completed 1 608 Grade 12/ std10/ NTC III without university exemption 5 897 Grade 12 with university exemption 919 Certificate with std 10/ Grade 12 2 040 Diploma with std 10 1 906 Bachelor’s Degree 374 Post Graduate Diploma 377 Honours Degree 509 Higher Degree (Masters/ PHD) 427 No schooling 3 887 Out of scope ( children under 5 years of age) 5 486 Institutions 834 TOTAL 60 038 ***Source: Stats SA: Community Survey, 2007

1.2.4.3 Economic Profile The surrounding land is mainly focussed on agricultural activities and tourism with game farms. Mining is also a key economic activity in the municipality. The following information was extracted from the Thabazimbi Municipality Integrated Spatial Development dated MARCH 2007 compiled by: Thabazimbi Municipality.

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1.2.4.3.1 Industries

Mining Thabazimbi Local Municipality (TLM) is endowed with a wealth of minerals and metals especially platinum and iron ore. A number of platinum mining operations such as Amandelbult and Union Mine (Anglo Platinum) and Northam Platinum Mine are situated south of Thabazimbi Town in addition; the Thabazimbi Iron Ore Mine is located in the municipality. Other commodities such as andalusite and dolomite are mined from the Rhino Andalusite Mine and PPC’s Dwaalboom Cement Operation. There are seven active mines in the TLM area. The mining sector is the primary pillar of the TLM economy and employs 62% of the labour force.

The mining industry has been affected in several ways by the global economic meltdown in the final quarter of 2008. This has led to mine closures and retrenchments across all commodities. Before the global economic crisis, mines were expanding in the municipality and new mining projects were in early planning phases. The expectations were that more employment opportunities and increased residential and business development would be created in the area. The high prices of bulk commodities such as iron ore were expected to continue in the near future and this would contribute towards development in all economic sectors.

The situation in 2009 and beyond seemed challenging for both platinum producers as well as Thabazimbi Mine as commodity prices went down significantly. Recently some signs of recovery in metal prices have been noticed.

Agriculture Agriculture farms a very big part of community life and local economic activities in Thabazimbi. Commercial agriculture contributes a total of 6% to the GVA. Although the sector’s contribution to the economy of the area is minimal; it is the second largest (12%) employer after mining in the area.

Farming Activities in the area include Crops, Livestock and Game Farming (Hunting and game ranches) that makes a substantial contribution to the GVA and GGP and are becoming increasingly popular.

Manufacturing Sector The manufacturing sector in the Thabazimbi is the smallest creator of value and income in the local economy, contributing less than 4% in 2004 to the local GVA, the third highest after agriculture. This is a worrying factor because it shows that with its wealth of mineral and agriculture resources, there is no beneficiation taking place in the area. Its contribution to employment is only 3 - 4%. The sector has a significant multiplier effect due to its backward and forward linkages with the primary sectors of agriculture and mining, as well as with the tertiary sectors such as trade, transport and communication. This multiplier effect is not limited to the value added in respect of the downstream

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 108 of 328 Management Programme under the MPRDA, 2002 processing of raw materials, but includes the direct and indirect job opportunities created. In this regard, it has been calculated that for every job opportunity generated in the manufacturing sector, between three to four jobs are generated in the economy at large.

Building and construction Construction is demand driven and subjective to the other sectors in the economy. The construction sector contributed less than 2% to the GVA of the local economy during 2004. The situation has changed since 2004. Dynamism in the building sector is currently found in the following actions:  Residential development especially in Thabazimbi and Northam.  Road building, upgrade and maintenance works (i.e. public works)  Maintenance an upgrading of public funded social facilities such as hospitals, schools, government buildings etc.  Buildings by other government departments.  Other contributes to this sector include ESKOM, business and private individuals.

Trade sector The Trade sector is an important economic sector as it is an important provider of jobs (especially for unskilled labour), it is the most effective and inexpensive entry point for entrepreneurs to start a business, and it is the system through which goods and services are distributed in the most effective manner. The main products traded in Thabazimbi, surveyed in 2003 are:  Snacks, fruit & tobacco: 69.7%  Groceries: 19.5%  Fuel sales: 12.2%  Clothing: 12.1%  Beauty products and services (incl. Hair): 9.8%  Public telephone services: 9.1%

Residents in Thabazimbi also spend money in urban centres such as Gauteng. This situation is descriptive of leakages in the local economy and should this situation be reversed, additional new employment opportunities in Thabazimbi can be created.

Transport, communication and storage sector The Transport and Communication sector contributed less than 2% to the local GVA but only 2.45% to formal employment in Thabazimbi during 2002. The main form of motorised transport in Thabazimbi consists of passengers who travel by car. In this regard 42.4% of people in Thabazimbi depend on people with vehicles for their transport to work or school. Busses and taxi’s convey most of the passengers who do not have access to private vehicle. Relative to bus transport, private vehicle ownership in Thabazimbi is relatively high. According to Census 2001 information 15.0% of the

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 109 of 328 Management Programme under the MPRDA, 2002 households in the area do not have their own telephone and is dependant on the use of a public telephone in the area. Important to note is the fact that 60.8% of households have a cell-phone. This presents business opportunities for the sale of pre-paid cellular vouchers within the Study Area. Only 55 % of households have access to a cell-phone and a land-line phone within their houses.

Financial sector There are sufficient financial services at Thabazimbi but only in the CBD. The former black areas still do not have access to financial services except those in town. Branch offices of financial institutions are located in Thabazimbi and Northam and most of the financial services are rendered by ATM machines in the rest if the municipal area. This means that residents have to commute to Thabazimbi and Northam which increase their cost of purchasing essential goods and services. The finance sector contributes 2% to the GVA of the local economy with 1.9% of formal employment. As a tertiary sector, the performance of the finance sector is dependent on growth in the other economic sectors. This means the finance sector will only maintain this growth with the expansion and development of the other sectors.

Community services sector There are a sufficient number of schools and other social and community facilities throughout the Thabazimbi Municipal area. Health care facilities are not sufficient. With further residential development particularly in Thabazimbi and Northam additional provision should be made for social community services such as Schools, Clinics and a new Provincial Hospital etc.

Tourism sector Tourism is an important activity in Limpopo and particularly in the Waterberg District. This is a popular destination for both foreign and domestic tourists. There is a rapid growth expected in the tourism sector of the Province and District. This is mainly because of the growing annual flow of tourists to Limpopo who regard the bushveld as a popular tourism destination. The presence of the Marakele National Park also adds to the increased tourism potential. The number of visitors to the Park has been growing steadily. The Thabazimbi area is one of the most popular investment destinations in respect of tourism related properties.

The proposed Heritage Park in the North West Province, which is likely to be a cross border project between North West Province and Limpopo Province, location relative to Gauteng and to North West – Sun City and Pilansberg, will have spill over effects on the tourism sector in Thabazimbi. Currently tourism activities are well established in the larger Thabazimbi. These include game farms, private resorts, eco-estates, lodges, 4x4 trails, hiking trails and so on. Tourism thus constitutes a large part of the local economy and serves as an important employer of the local population. Key attractions in this municipality include the Atherstone Nature Reserve, Ben Alberts Nature Reserve, Thabazimbi – Tholo Eco-Park and Marakele National Park. Some of the features of this Park are elephant, rhinos, leopards, buffalos and spectacular mountains. There are also several resorts and lodges, which

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 110 of 328 Management Programme under the MPRDA, 2002 receive large numbers of tourists, mainly hunters (meat and trophy) and visitors on safaris, with the proportion of foreign hunters being on the increase.

The importannce of game farming in the Thabazimbi Municipal area is of the particular significance. Game farming in itself is not a single community but a comprehensive set of activities with a wide spectrum of products and services. Although this industry has over the last few years developed as one of the major components of Agriculture/ Tourism in the Province, accurate and components information is not readily available, as most game ranch owners do not regard this activity as an independent form of agriculture.

1.2.4.3.2 Unemployment According to the Census 2011 statistics, approximately 20.6% of the labour force in the Thabazimbi Municipality is unemployed. Table 28 below presents the economic status of the labour force population of Thabazimbi Municipality.

Table 28: Economic Status of Thabazimbi Labour Force Population (Census 2011) ECONOMIC FIGURES STATUS

Employed 52 132

Unemployed 4 306

Not economically active* 22 502

Total Labour Force 78 940 *Note: Not economically active includes students, homemakers, the disabled, those too ill to work and anyone seeking work.

Of the total population of some 85,234 people, about 76.4% are aged between 15 and 65, which can be considered as potentially economically active. Of these, 20.6% are unemployed and 26.9% is the youth unemployment rate.

These figures are not surprising in light of the character of the main industries in the Municipal Area. The fact that the mining and agricultural sectors rely substantially on unskilled labour for hard physical labour is reflected also in the income distribution. More than 10,521 of the employed (51.8%) within the TLM earn below the minimum level of R 1,500 per month. The gender distribution of the income is considerably skewed towards the males, perhaps a reflection of the occupations available at Thabazimbi.

However, these figures cannot be accepted at face value. It is common to understate unemployment as many of those reflected as economically inactive are actually unemployed; also many of those reflected as self-employed (as, for instance, vendors) are actually unable to make a living.

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1.2.4.4 Community, social and personal services Electricity The municipality has electricity distribution license issued by NERSA in terms of the Electricity Act 41 of 1987. The license covers the following areas for distribution and retail:  Greater Northam RLC (Portion)  Thabazimbi TLC (Whole)  Warmbad- Pienaarsrivier RLC (Portion)  Rooiberg

Currently the municipality is an Electricity Service Provider in Thabazimbi town, Regorogile extensions 3, 5, 6, 7, 9, Rooiberg and Raphuti. Eskom is for Northam, Regorogile extensions 2, 4, farms and mining areas.

Housing TLM is dominated by farmland and small settlements. It boasts 3 towns (urban nodes); namely Northam town, Thabazimbi town and Amandelbult town. The towns are the result of the economic development associated with the mining activities taking place in the area.

Almost 26% of dwellings in TLM are informal in nature. The present demand for housing in the Thabazimbi urban node is high, and 30 serviced plots are available in Extension 8. However, owing to the poor economic climate, very few houses are being built there. The demand for houses in the new Regorogile Residential Area is also very high, and sufficient stands are available. Table 29 below indicates the types of accommodation available in the Thabazimbi Urban Node.

Table 29: Housing Available in the Thabazimbi Urban Node TYPE OF ACCOMMODATION QUANTITY AVAILABLE Houses 1 069 (Thabazimbi Town) Houses 199 (Ipelegeng) Houses 59 (Town Council) Houses 102 (Regorogile) Plot Houses 30 *Source: TLM Intergated development plan

Formal settlements: Thabazimbi / Regorogile are the largest urban node in the area. The quality of housing (structural maintenance, gardening, etc.) in particularly the Kumba Resources Staff Village is visibly better than that available in the adjacent municipal village. Northam Town and Northam Platinum are located in the south of the Municipal Area and Rooiberg and Leeuwpoort located in the

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 112 of 328 Management Programme under the MPRDA, 2002 south-west of the area. Amandelbult is located to the south of Thabazimbi Town and between Thabazimbi and Northam. There are no former homeland areas located within the Municipal Area.

Sanitation Thabazimbi are using water borne sewer systems. The treatment plant caters for Thabazimbi, Regorogile and Ipelegeng. The current capacity is 1800kl/day. The treatment plant has recently been upgraded to ±3000kl/day and will be further upgraded to 5285kl/day which will be sufficient for the long term. Based on the recent residential development as well as proposed residential township the second phase of upgrading should commence immediately.

Water provision Formal settlements: Thabazimbi / Regorogile are the largest urban node in the area. The quality of housing (structural maintenance, gardening, etc.) in particularly the Kumba Resources Staff Village is visibly better than that available in the adjacent municipal village. Northam Town and Northam Platinum are located in the south of the Municipal Area and Rooiberg and Leeuwpoort located in the south-west of the area. Amandelbult is located to the south of Thabazimbi Town and between Thabazimbi and Northam. There are no former homeland areas located within the Municipal Area.

Thabazimbi, Regorogile and Northam currently have a quota of 9 mega litres per day from Magalies board. Regorogile and Thabazimbi have additional supply from seven boreholes. The boreholes are located at Group 5, 12 and Kumba Iron Ore Mine. Rooiberg and Leeupoort/Raphuti currently source their water from local boreholes. Schilpadnest water is also supplied from three working boreholes without any chlorination facilities.

Thabazimbi and Regorogile are using water borne sewer system. The existing water treatment plant caters for Thabazimbi town including Regorogile and Ipelegeng. The current capacity of the plant is 28 litres per second but the average daily flow is about 60 litres per second. The current sanitation system in Northam is 60% water borne and 40% septic tank. Leeupoort is septic tank. The Municipality empty the septic tanks for all the residents regularly and discharges the sewerage into the existing oxidation pounds. The outfall sewer has been partially constructed in Northam and the project is still outstanding. The municipality does not provide bulk water to the mines within its area of jurisdiction The main sources of potable water are:  Pienaars River  Crocodile River  Vaalkop Dam- Magalies Water Board

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1.4 Annotated map showing the spatial locality and aerial extent of all environmental, cultural/heritage, infrastructure and land use features identified on site and on the neighbouring properties and farms

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Figure 21: Environmental features existing at the proposed site

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1.5 Confirmation that supporting documents in the form of specialist studies are attached as appendices

An ecological evaluation for the Aquila Steel project, Thabazimbi Appendix E1 Aquila Steel Meletse Iron Ore Project: Report on geohydrological Appendix E2 investigation as part of the EIA and EMP. Palaeontological Assessment: Site Visit Report. Gatkop cave on farm Appendix E3 Randstephane 415 KQ near Thabazimbi, Limpopo province Cultural heritage resources essay for the farms Donkerpoort 448 KQ, Appendix E4 Randstephne 455KQ and Waterval 443KQ, Limpopo province Assessment of the bats at Gatkop Cave, and possible mitigation measures Appendix E5 Stormwater management plan Appendix E6 Air Quality impact study Appendix E7 Noise study Appendix E8 Visual impact assessment report 2014 Appendix E9 The Ecological Integrity of the aquatic habitat at the proposed Aquila Steel Appendix E10 mine on the Farms Donkerpoort 448KQ and Randstephne 455KQ, Thabazimbi district, Limpopo Province, South Africa. Environmental Impact Assessment: Ground Vibration and Air Blast Study Appendix E11 Aquila Steel (Pty) Ltd. Meletse Project Traffic impact study Appendix E12 Economic impact study Appendix E13

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2 The proposed mining operation

2.1 The mineral to be mined The type of mineral to be mined is Hematite Iron Ore.

2.2 The mining method to be employed

2.2.1 Mining method An open pit iron ore mine is proposed. The open pit will be mined through conventional truck and shovel mining techniques. The topsoil (seed bearing soil) will be stripped prior to mining and placed on a separate dump to be used during rehabilitation. The overburden and waste rock material will be stripped and dumped on the waste rock dump that will be established on the contour of 1620mamsl on the south-eastern side of the open pit. During the final years of the open pit, an in-pit waste rock dump will be established in the north-eastern section of the open pit,

2.2.2 Estimated reserves and extend of target area This Resource has been based on a total of 168 holes drilled for 45,856m across three phases of exploration; 42,136m for Reverse Circulation drilling and 3,720m for Diamond core drilling. The Resource comprises 7 iron ore lodes and a number of lenses. The updated Resource has been calculated on a 50%Fe lower cut-off and is classified as Measured (46%), Indicated (29%) and Inferred (25%). Classification of the resources is in accordance with JORC. Refer to Table 30 for Meletse iron ore resource and to Table 31 for reserve and saleable product.

Table 30: Meletse Iron Ore Resource Category Tonnes Fe % SiO₂ Al₂O₃ K₂O P % S % MnO CaO MgO LOI RD % % % % % % Measured 37.1 62.28 7.57 0.68 0.101 0.045 0.0328 0.884 0.161 0.164 1.26 4.72 Indicated 23.5 60.85 9.35 0.75 0.110 0.052 0.038 0.956 0.185 0.211 1.59 4.64 Inferred 20.2 59.20 11.15 0.83 0.112 0.059 0.037 1.148 0.145 0.231 1.76 4.56 Grand 80.8 61.09 8.99 0.73 0.107 0.051 0.033 0.971 0.164 0.195 1.48 4.66 Total

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Table 31: Meletse Iron Ore Reserve and Saleable Product @62%Fe Resource Gross Geological MTIS Mining Mining Un- ROM Loss Total Tonnes Losses x 106 Losses Dilution economical Reserve on Saleable in Situ (10%) (10%) x 106 Yield Product x 106 for x 106 62%Fe Product

Open Pit 80.80 8.10 72.70 7.30 6.50 5.10 66.80 1.30 65.50

2.2.3 Production rate All indications are that the proposed mine will span a timeframe of at least 18 years. The project objective is to produce 4,100,000 tonnes per annum of Run of Mine (ROM) material from the open pit with an objective of 4,000,000 tonnes saleable product.

From the Figure 22 below, it can be seen that the waste stripping in the open pit mine is high. The stripping ratio is initially very high and then tapers off to below 10 after year 5. In years 12 and 13 there is a further spike in the stripping due to further pushbacks to open up the mining area. The average stripping ratio for the life of mine is 8.6 to 1.

Figure 22: Mining Production (*** source: Aquila Steel Mining works programme)

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2.2.4 Life of mine The current Life of Mine (LOM) at 4Mtpa option is set at 18 years but with on-going exploration this may well be extended.

2.3 List of the main mining actions, activities, or processes

2.3.1 Mining activities The open pit will be started through creating an initial boxcut. The objective of the boxcut will be to expose sufficient iron ore reserves for the first production year, and will be positioned optimally to act as a future ramp access ramp, and at a location in close proximity to the ROM crusher location. The mining sequence in the open pit environment will be as follows:  Creating initial free faces by making a boxcut,  Drilling and blasting of overburden,  Loading and hauling of overburden to waste dumps or backfilling after iron ore extraction,  Drilling and blasting of waste rock,  Loading and hauling of waste rock to waste dumps or backfilling after iron ore extraction.  Drilling and blasting of Iron Ore lodes,  Loading and hauling of the Iron Ore to primary crusher/ ROM stockpile.

2.3.1.1 Mining method The open pit will be mined through conventional truck and shovel mining techniques. The topsoil (seed bearing soil) will be stripped prior to mining and placed on a separate dump to be used during rehabilitation. The overburden and waste rock material will be stripped and dumped on the waste rock dump that will be established on the contour of 1620mamsl on the south-eastern side of the open pit. During the final years of the open pit, an in-pit waste rock dump will be established on the eastern side of the open pit (option 3).

The final pit is planned with four push backs. The production benches are 12m high based on the mining consideration.

The pushbacks and final pit selection were based on:  Incremental pit based on pit shells which sit at inflection points of Figure 23.  Maximising life of mine (“LOM”) tonnage

The starter pit (pit shell 29) followed by subsequent pushback pit 34, 45 and 61 are illustrated in figures 23-26 below. Refer to figure 27 for a mine layout plan.

Production will be ramped up over a period of 4 years as the pit space increases and the waste rock mining decreases. Waste dumps will be designed for safety as well as minimum environmental

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 119 of 328 Management Programme under the MPRDA, 2002 impact. Once the mining faces have advanced sufficiently, all future waste will be backfilled in the mined out areas.

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Figure 23: Starter pit – pit shell 29 (green) with ore blocks (red and blue)

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Figure 24: Pushback 2 – pit shell 34

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Figure 25: Pushback 3 – pit shell 45

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Figure 26: Final pit – pit shell 61

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2.3.1.2 Preferred Mine layout plan

Figure 27: Mine layout plan

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2.3.1.3 Explosives An explosive store shall be established as well as warehousing (stores) for the consumables (i.e. fuel, tyres, ground engaging and explosives) and maintenance spares (i.e. engine parts, filters, and steel for fabrication) needed for all the equipment.

The proposed mine will have a contract for Down-the-Hole explosives services, and will receive bulk delivery into magazines and silos every second day by trucks with 5t to 30t payloads. The logistics function for the ordering, receiving and distribution of explosives will be the responsibility of the Down- the-Hole Service supplier.

2.3.1.4 Mine and plant residue There will be a waste rock dump during operational phase adjacent to the open pit. Free dumping from a static elevation of 1,620m will take place. A final slope angle of 32.5° is assumed with a bulking factor of 1.3 for broken waste rock. The proposed design caters for 156 million m³ of waste rock. A plant discard dump of 2 million tonnes is also proposed. The overburden dump and discard dump will be located 1.5 km south of the pit area on Randstephne.

2.3.2 Ore processing activities The proposed mine will produce a combination of high grade ROM ore, direct shipping ore (“DSO”), which will not require beneficiation, as well as DMS ore which will benefit from beneficiation. The crushing and screening facilities will be designed to process both ore types and deliver these onto two separate -32 mm stockpiles.

The DMS beneficiation plants will process up to 1.65Mtpa using a single 610mm DMS cyclone for the +1 mm fraction and spirals for the fines.

The DMS product and DSO will be combined in the product handling area, before classifying the product into a lumpy (-32mm +6.3mm) and fines (-6.3mm) fraction. The ultra-fine product will be combined with the fine product before stacking on a conical stockpile, with the lumpy product being stacked on a separate conical stockpile.

Waste from the two beneficiation areas will be combined before disposal. Water recovery will be done by means of a thickener, with the thickener underflow being dewatered by a belt press filter before disposal on the waste dump.

2.3.2.1 Primary and Secondary Crushing A ROM bin will be required into which the ore will be tipped by front end loader (“FEL”) or haul trucks. The capacity of the bin should be at least three haul truck loads. An apron feeder will be located

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 126 of 328 Management Programme under the MPRDA, 2002 below the bin and will feed the ore directly into the jaw crusher. The jaw crusher has been sized to handle a top size of 1000mm. A mobile hydraulic hammer unit will be required to break oversize material causing blockages to the jaw crusher. The jaw crusher will operate with a closed side setting of 175mm. From the jaw crusher, the crushed ore will be fed onto a scalping screen which will remove undersize material prior to the oversize reporting to a secondary cone crusher. The screen oversize will feed into a bin from which the feed to the secondary crusher will be controlled. The secondary crusher will operate at a closed side setting of 40mm. The screen undersize and crusher product will then be stockpiled using a radial stacker.

2.3.2.2 Tertiary Crushing and Stockpiling From the stockpile, ore will be recovered using FELs. The ore will be fed onto a scalping screen to remove undersize material prior to tertiary crushing. The screen oversize will feed into a bin from which the feed to the tertiary crusher will be controlled. The crusher product will be recycled back to the scalping screen. The screen undersize will be 32mm. A flopper gate system will be installed on the screen undersize. The flopper gate will be used to direct the ore to a direct shipping ore stockpile or a beneficiation feed stockpile using radial stackers.

2.3.2.3 Beneficiation plant DMS Beneficiation Fresh feed will first be deslimed using a prewash screen with spray water to remove any fines. As the ore has been sprayed, it will retain water when it leaves the screen. The amount of water is typically 7-10% of the volume of the solids, depending upon the particle size range and screen operation. This material will then be mixed with a circulating medium of the required density in a mixing box. The combined ore plus the medium will then be pump fed to the dense medium cyclone. Within the cyclone, the ore splits into a light fraction (floats) and a heavy fraction (sinks). The split is determined by the densimetric properties of the ore and the circulating medium density.

The floats and sinks fractions will then be passed through a medium recovery circuit. The sinks fraction first passes over a static screen. The majority of the medium will pass through the screen and the ore with the remaining medium will pass over the static screen onto the drain and rinse screen. The drain and rinse screen is a vibrating screen which is divided into two sections, being the drain section (normally 1/3 of the screen length) and the rinse section (the remaining 2/3 of the screen length). In the drain section, most of the remaining medium, which was not recovered over the static screen, is recovered to the screen undersize. The screen undersize from the drain section and the undersize from the static screen are fed to the correct medium (“CM”) sump.

In the rinse section of the screen, water is used to wash off any medium which still adheres to the ore particles. The diluted stream containing medium and spray water is then fed to the dilute medium (“DM”) sump. The floats fraction undergoes exactly the same process to recover the medium. From

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 127 of 328 Management Programme under the MPRDA, 2002 the dilute medium sump, the dilute medium will be fed to a magnetic separator (“mag sep”). The magnetic fraction will be recovered and fed back to the correct medium sump. The effluent from the magnetic separator consists primarily of water, non-magnetic particles and some magnetic medium. A portion will be re-used as spray water on the rinse screens and the balance will be sent to thickener. The density of the correct medium is measured and control water is added to maintain the correct medium at the required set point.

Spirals beneficiation The pre-wash screen undersize will be minus 1mm and in the absence of magnetic properties, gravity separation will be used to beneficiate this size fraction. The screen undersize will be fed to a de- sliming cyclone. The function of the de-sliming cyclone is twofold. Firstly, ultrafine material (minus 30 micron) will be removed to the overflow as this fraction does not beneficiate on spirals and if present could adversely affect both the yield and quality of beneficiated material from the spiral circuit. Secondly, the de-sliming cyclone dewaters the screen undersize enabling the rougher spiral to be fed at a controlled slurry density. The cyclone overflow is sent to the thickener.

The rougher spiral produces two streams, a concentrate and a tails. The concentrate stream will not be at the final product quality, and the tails will still contain some recoverable haematite. The rougher concentrate stream will be fed to a cleaner spiral. The cleaner concentrate stream will be of the required quality for final product. The cleaner tails will be dewatered using a dewatering screen to produce a conveyable product. The cleaner tails will be recycled to the scavenger circuit to recover any haematite that may still be present. The rougher tails is combined with the cleaner tails and fed to a dewatering cyclone. The function of the cyclone is to remove water so that the scavenger spirals can be fed at the required density. The cyclone overflow will be sent to the thickener. The scavenger spiral concentrate will be recycled back to the cleaner spiral and the scavenger spiral tails will be fed to a dewatering screen to produce a conveyable waste stream.

Product Handling The DSO will be combined with the product of the dense medium circuit and then screened at 6mm into a lumpy (-32mm +6mm) and fines (-6mm) fraction. The lumpy fraction will be stockpiled using a radial stacker. The concentrate from the spiral circuit will be combined with the fines fraction and stockpiled using a radial stacker.

Water recovery The magnetic separator effluent and cyclone overflow from the spiral circuit will be fed to the thickener. With the aid of flocculent, a high density underflow will be produced and clear water will be recycled to the process water tank for re-use in the plant.

Slimes Disposal

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Typically a filter press will be used to settle out the fine material and recover additional water for use in the plant. A filter press is an alternative which eliminates the need for a slimes dam. For the capital estimate it has been assumed that a belt press filter will be used to dewater the slimes.

Spiral plant waste The dense medium and spiral plant waste will be combined for disposal on the discard dump.

2.3.2.2 Product and run of mine The ROM will be stockpiled on a ROM stockpile in close proximity to the ROM Primary crusher to be used for blending purposes and to eliminate production fluctuations.

The Product Stockpile will be located at the plant and will consist of a Lump stockpile and a Fines stockpile.

2.3.3 Support services

2.3.3.1 General and hazardous waste facilities

2.3.3.1.1 General waste Domestic waste will be accumulated within the offices, canteen and other infrastructure. The waste stream will be domestic and household waste, and business and commercial waste, which are all non-hazardous. The Council for Scientific and Industrial Research’s Human Settlement Planning and Design (2000) and the Department of Water Affair’s Minimum Requirements for Waste by Landfill (1998) were used to calculate the volume of waste and subsequent disposal or conveyance of the waste. The initial rate of deposition per capita per day was assumed to be 2kg (range 0.5- 3.5kg/capita/day).

For 446 personnel the initial rate of deposition is assumed to be 0.9t/day. If the waste density is assumed to be 0.5t/m3, the total waste requiring handling is 1.8m3/day. It is suggested that on site storage be used in the form of 11m3 load luggers which would be stored on the foundations provided and are explained in the infrastructure section of this document. The load luggers will need to be transported to a suitable landfill site where the waste will be disposed of permanently.

There are two landfill sites located in Thabazimbi; the one is owned and operated by Northam Platinum Limited and the other Thabazimbi Transitional Local Council. They are both G:S:B- (general waste: small: negative water balance) landfill sites and either could be used for ultimate disposal of the domestic waste.

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2.3.3.1.2 Hazardous waste Hazardous wastes are those wastes, which can, even in low concentrations, have a significant adverse effect on public health and / or the environment. If any hazardous wastes and greases are accumulated at the proposed site, this waste shall be handled in a similar manner as domestic waste, namely, stored on-site in suitable containers located on reinforced concrete slabs and transported off- site for final disposal. Hazardous waste generated by the mine shall be collected by a waste contractor and disposed of at appropriately licensed waste facilities. Aquila has submitted a waste license application to the Department of Environmental Affairs. Refer to Table 32 below for activities applied for as part of the waste licence application.

Table 32: Activities applied for. NO. & DATE OF THE ACTIVITY NUMBERS (AS ACTIVITY AS PER THE RELEVANT NOTICE RELEVANT NOTICE: LISTED IN THE WASTE MANAGEMENT ACTIVITY LIST) :

Government Category A, No. 1 Project description: Gazette No. 32368 Temporary storage of general waste in excess of 100m³. of 3 July 2009. No. The general waste will be kept in skips in a bunded area. 718. Listed Activity: The storage, including the temporary storage of general waste at a facility that has the capacity to store in excess of 100m³ of general waste at any one time, excluding the storage of waste in lagoons.

Government Category A, No. 2 Project description: Gazette No. 32368 Temporary storage of hazardous waste in excess of 35 of 3 July 2009. No. m³. The hazardous waste will be kept in skips in a 718. bunded area.

Listed Activity: The storage, including the temporary storage of hazardous waste at a facility that has the capacity to store in excess of 35m³ of general waste at any one time, excluding the storage of hazardous waste in lagoons.

Government Category A, No. 18 Project description: Gazette No. 32368 Construction of facilitates which includes a bunded area of 3 July 2009. No. for the temporary storage of hazardous and general 718. waste.

Listed Activity: The construction of facilities for activities listed in Category A of this Schedule (not in isolation to associated activity).

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Government Category B, No. 7 Project description: Gazette No. 32368 A sewerage treatment package plant will be used to treat of 3 July 2009. No. a staff compliment of 446 people. Sludge from the 718. treatment package plant will be used as compost for vegetable gardens.

Listed Activity: The treatment of effluent, waste water or sewage with an annual throughput capacity of 15 000 cubic metres or more

Government Category B, No. 11 Project description: Gazette No. 32368 The construction of a lay down area for the sewerage of 3 July 2009. No. treatment package plant.

718.

Listed Activity:

The construction of facilities for activities listed in Category B of this Schedule (not in isolation to associated activity).

2.3.3.1.3 Sewerage Waste It is estimated that a staff compliment of 446 will be required for the project. Sewerage is expected to be generated at 88 litres per person per day, resulting in a total of 39,600 litres per day. Two separate systems shall be constructed. One serving the administration offices, workshops and stores that is expected to account for 50% of the sewerage generated, and the second serving the production area, accounting for the remaining 50%. Peak flow generated for each of these areas will be approximately 1.4l/s. It is proposed that the sewer be gravity fed to two central treatment plants where it will be processed, generating minimal outfall.

For maintenance purposes, 160mm diameter uPVC pipes, laid underground at a minimum slope of 1:80, are to be utilised. From the preliminary layout, a total pipe length of approximately 2,865m is expected. Two Lilliput SBC 48000 FK BT CL sewerage effluent treatment plants, equipped with pre-digestion, balancing, bio-reactor and clarifier and disinfection stages are proposed. The sewage from the septic tanks (pre-digestion) shall be pumped at a constant rate to the Lilliput Bio-Reactor. The effluent shall enter the bio-reactor below the AWW Mark Two fixed-growth media where it mixes with an air diffuser. The effluent shall rise through the media where the microbial population attached to the media shall remove and aerobically degrades the organic material contained in the aerated effluent. Refer to figure 28 for the typical effluent treatment plant layout.

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Figure 28: Typical effluent treatment plant layout

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2.3.3.2 Water management

2.3.3.2.1 Groundwater

Dewatering The proposed opencast pit will have no impact on the natural aquifer discharge within the Meletse Project area as no mine dewatering will be required. Only surface water run-off from rainfall events will have to be managed.

Boreholes Refer to section 1.1.10.1 of the report for information on boreholes.

2.3.3.2.2 Surface water The proposed catchment area is delineated to the west of the site by the haul/mine access road and to the east by a proposed boundary and is 6.308km2. The catchment area delineates all mining activities, proposed waste dumps, roads, processing operations and infrastructure. Clean surface water and dirty surface water must be distinguished and separated.

The following areas were identified as dirty storm-water areas which would require surface water management: • The open pit area; • The wash bay and waste storage areas;

All excess water and precipitation which accumulates within the two areas mentioned above will be pumped or gravitated along concrete channels (to mitigate any infiltration) directly into the Pollution Control Dam (“PCD”).

The process plant area All waste water within the processing plant will be pumped or gravitated along concrete channels (to mitigate any infiltration) directly into the pollution control dams. This water will not require any further treatment, as by volume it will be diluted within the raw water, which will be supplied by the chosen water source.

All roads within the catchment area: All run-off water along the roads will be gravitated along concrete channels or safety berms directly into the PCD. The concrete channels dedicated to convey the dirty storm-water will be sized accordingly and necessary silt traps will be placed consequently. All other run off which falls within the proposed catchment area will be deemed as clean storm-water. This water will be allowed to infiltrate

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 133 of 328 Management Programme under the MPRDA, 2002 and gravitate towards its natural watercourse. Some of it may however gravitate towards the PCD and allowances will be made for this potential in-flow.

In order to size the PCD and other storm water infrastructure, the catchment area was divided into 11 sub-catchment areas (refer to general layout). The rainfall data along with other hydrological data was used to determine the hydrological flood estimation using the Rational Method for the proposed delineated catchment area. The 1:50 year storm water run-off for each sub-catchment area is shown in table 33 below:

Table 33: Sub catchment areas Sub- Area (km2) Slope Hydraulic Time of 1:50 year catchment (m/m) length (km) concentration runoff (h) (m3/s) 1 0.876 0.115 1.1 0.16 16.9 2 0.261 0.243 0.68 0.08 6.6 3 0.371 0.447 1.1 0.10 9.0 4 0.519 0.385 1.65 0.14 10.7 5 0.396 0.386 1.4 0.12 8.7 6 0.255 0.365 1.3 0.12 5.7 7 0.363 0.387 0.97 0.09 8.9 8 0.125 0.915 0.2 0.02 2.8 9 0.426 0.218 1.3 0.15 8.7 10 0.383 0.392 0.9 0.09 9.6 11 0.151 0.212 0.5 0.07 4.1

Sub-catchment areas 3 to 11 discharge clean water underneath the haul road through culverts equipped with energy breaking outlet structures. These culverts will be sized for a 1:50 year storm event.

The pollution control dam The recycled or excess mine water will be of such small quantities that it can be treated as negligible for this phase of the study. Therefore, the only contributor to the pollution control dam will be delineated dirty run-off water and small volumes of clean run-off water. The pollution control dam will be lined and equipped with a leakage detection system.

From statistical data available it was determined that the depth of rainfall which would occur during a 24 hour storm event for a 50 year return period was 112mm (i50/24 ). The total area of the locations which were identified as areas which require dirty-storm management are presented below. For this phase of the study, the pollution control dam was sized by multiplying this area by the i50/24 to determine a required volume:

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Sub-catchment areas 1 and 2, with a combined catchment area of 1.137km2 and a peak flow of 23.5m3/s, will drain dirty water towards the pollution control dam, located to the east of the production area. The dam should be able to contain the 24 hour, 1:50 year storm event that is estimated at 112mm. Assuming a C value of 0.8 would require a storage pond with a volume of: 1,137,000m² x 0.112m x 0.8 = 102,000m³

Process water supply Potential water sources include groundwater extraction or alternatively taking water from the Crocodile River which is approximately 40km away. If suitable groundwater or boreholes are not established, the option to pump from the Crocodile River may be the only viable option as a water source to meet the water demand.

The feasibility of constructing an extraction point and pumping station along the Crocodile River, for the sole use of the Meletse Project, and construct pipelines from the extraction point to the mine site was investigated. Two potential extraction points were identified and connecting pipe routes were planned. The pipe line could either be constructed along the southern path (option A) or the northernpath (option B). The two options are explained and shown in Figure 29 and Figure 30 respectively.

Figure 29: Crocodile River southern pipe route (Option A)

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The southern pipe line will be 37km long, with a maximum head requirement of 193m. A suitable size and type of pipe will be selected to convey the required flow rate either above or below ground. The recommended pipe system is an underground pipe network using 200mm (“HDPE”) piping. The pipe system Capex and Opex is approximately R922,000/km (almost half the cost of a subsurface pipeline) with an assumed Opex of R100,000/annum. The pump station will be a 25m2 concrete structure with two supply pumps and switch-gear.

The northern pipe line will be 44.4km long, with a maximum head requirement of 204m. The recommended pipe system is an underground pipe network using 200mm HDPE piping. The pipe system’s Capex is approximately R908,000/km (almost half the cost of a subsurface pipeline) with an assumed Opex of R100,000/annum. The pump station will be a 25m² concrete structure with two supply pumps and switchgear.

Figure 30: Crocodile River northern pipe route (Option B)

Storm water As part of the integrated water management, a Storm Water Management Plan (based on the Best Practice Guidelines G1 (DWAF, 2006)) was developed by Shangoni Management Services for Aquila titled: “Storm Water Management Plan, Aquila (Pty) Ltd”, dated January 2014. The mentioned plan describes the water flow over and around the proposed site, and provides strategies for optimising the

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 136 of 328 Management Programme under the MPRDA, 2002 separation of clean and affected runoff water. Refer to Appendix E6 for a copy of the mentioned Storm Water Management Plan.

Plant, overburden- and discard dump The plant, overburden dump and discard dump will be located 1.5 km south of the pit area and the WRD. There are a number of non-perennial drainage lines upstream of the plant and the associated dumps as mentioned previously. According to the current designs, the discard dump will be constructed over and next to non-perennial drainage lines originating from the hilly areas in the north- western parts of Donkerpoort. General drainage from the area flows in a southern direction towards the Sand River that drains into the Crocodile River. Adjacent landowners are mostly farmers who depend on clean water resources.

Pit area, haul roads and Waste Rock Dump Mining of iron ore will take place in the north-western section of the Donkerpoort property. The size of the pit and the waste rock dump (WRD) will be approximately 150 ha. A number of non-perennial drainage lines originate from these hilly areas and drain south towards the Sand River which eventually joins the Crocodile River.

Figure 31 below indicates the anticipated runoff directions within the sub-catchments towards the natural watercourse and do not indicate if the directions is controlled or not. Reference should be made to the discussion with regards to proposed storm water control measures.

The following main storm water measures are recommended with respect to stormwater control:  A network of dirty channels will intercept contaminated runoff from the plant area and will drain towards PCD 1 for re-use in the process.  Cut-off trenches and berms will separate clean and affected water from the overburden- and discard dump. Contaminated runoff will attenuate in PCD 2 below the dumps.  The topography at the discard dump will cause runoff to drain towards the middle of the dump. It is recommended to install a sump within this particular area. It is recommended to pump the affected water from the sump to the lined trench draining to PCD 2.  It is recommended to line the two PCD’s with HDPE lining to prevent seepage and possible groundwater contamination.  The safety berm around the open cast pit will act as a storm water measure thereby preventing surface runoff from entering the pit.  Energy dissipaters should be installed along the haul roads to divert runoff away from the roads into the adjacent veldt areas. Note that it will be necessary to implement velocity reducing measures to limit erosion as runoff will be concentrated.

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It is the responsibility of the Aquila to ensure that storm water control measures are designed and constructed to be capable of withstanding the maximum design flood. It should be taken into consideration that the potential for erosion increases where the surface runoff is concentrated and must be addressed within the designs. Designs should incorporate gradual drainage to avoid siltation of storm water infrastructure.

Storm water management measures discussed should be prioritised to prevent damage or failures during flood events. After implementation of the storm water management plan, regular inspections and maintenance should be conducted to ensure that all infrastructures are functioning according to design capabilities. Effective management of surface water runoff and clean/affected water separation at the Meletse iron ore project will contribute to conservation of downstream clean water resources.

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Figure 31: General runoff

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2.3.3.2.3 Potable water

Domestic water demand The estimated areas for the offices and other occupied buildings on site are shown below. For each building, the assumed daily water demand per 100m² floor area, based upon the recommendations of the “Guidelines for human settlement planning and design” is used, to determine the total daily domestic water demand.

The daily demand of 39,600 litres translates into 88 litres per person per day. The bulk of this water, estimated at 80%, could be captured and recycled via the sewer treatment plant, reducing the amount of water that needs to be extracted from the boreholes.

Table 34: Daily domestic water demand BUILDINGS Area Water demand Water demand (kl/100m2) (kl/day) Main admin 964 0.6 5.784 Workshop 2,328 0.6 13.968 Service bay 364 0.6 2.184 MHPP Workshop 228 0.6 1.368 Wash bay 28 0.6 0.168 Wash ablution 28 0.6 0.168 Workshop offices 100 0.6 0.6 Weighbridge 66 0.6 0.396 Guardhouse 66 0.6 0.396 Plant offices 364 0.6 2.184 Canteen 100 0.6 0.6 Lab 200 0.6 1.2 Change rooms 600 0.6 3.6 Quality 200 0.6 1.2 Stores 600 0.6 3.6 Plant ablution 364 0.6 2.184 TOTAL 6600 39.6

Domestic water supply The water source will ultimately determine the level of treatment required to attain potable quality water. If the water is supplied from a river, an intense treatment process is required. The process is displayed graphically in Figure 32.

The river water will be pumped from its source into a storage tank. From the storage tank it will be pumped through a polymer into a Dissolved Air Flotation (“DAF”) tank which will clarify the wastewater through the removal of suspended matter and solids. The excess sludge will be conveyed to sludge

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 140 of 328 Management Programme under the MPRDA, 2002 drying beds and the clarified water will be pumped through a sand filter pressure system. This will induce waste backwash water but the majority of flow will then enter the Granular Activated Carbon (“GAC”) phase of treatment. This water will then be of potable quality and will be conveyed to storage reservoirs for end use.

Figure 32: River water treatment process

If borehole water is used, a simplistic treatment process is required. Similarly, the water will be pumped from its source into a storage tank. From the storage tank it will only be required to be pumped through a sand filter pressure system after which a hypochlorite will be added to chlorinate the water. Again, this water will then be of potable quality and will be conveyed to storage reservoirs for end use. The process is displayed in Figure 33.

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Figure 33: Borehole water treatment process

If borehole water is available this would be the recommended source for the potable water demand. Indications are that boreholes would be able to supply sufficient water for domestic use. Water that would be expected to contain high amounts of iron would be pumped to a temporary storage tank from where it will be pumped to a potable water treatment plant where it will be dosed, filtered, clarified and disinfected. The resulting potable quality water will be pumped to the storage reservoir from where it will gravitate to the office areas via underground pipes.

An average borehole water extraction rate of 1,650l/hr (0.46l/s) would be required in order to meet the demand. It is estimated that a 50mm diameter pipeline with a total length of 5,000m would be required to convey water from the source to the treatment plant at a maximum head of 100m. This would require a 1.0kW pump. The domestic water supply would also be utilised for fire protection, based on a moderate risk fire category. The peak water demand is given in Table 35 and includes the demand for fire.

Table 35: Water demand for infrastructure and fire protection Peak flow factor Volume Peak domestic flow (l/s) 1.83 Fire flow (l/s) 15.00 Peak water supply (l/s) 16.83 Maximum flow speed (m/s) 1.5 Single line 120.00

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Peak flow factor Volume Ring 85.00

The on-site reservoir should be sized to supply the higher of 4 hours of instantaneous peak demand, 2 hours fire flow or 2 days domestic daily demand. A reservoir size of 108m3 is recommended with a 160mm main feed line linking to a 110mm ring feed around the main buildings. A minimum head of 24m would be required under instantaneous peak demand, with 15m under fire conditions. Friction losses of 9.2m would require the reservoir to be elevated at least 25m higher than the plant area offices.

2.3.3.2.4 Domestic wastewater It is estimated that a staff compliment of 446 will be required for the proposed mine. Sewerage is expected to be generated at 88 litres per person per day, resulting in a total of 39,600 litres per day.

The site infrastructure layout dictates that two separate systems be constructed. One serving the administration offices, workshops and stores that is expected to account for 50% of the sewerage generated, and the second serving the production area, accounting for the remaining 50%.

Peak flow generated for each of these areas will be approximately 1.4l/s. It is proposed that the sewer be gravity fed to two central treatment plants where it will be processed, generating minimal outfall. For maintenance purposes, 160mm diameter uPVC pipes, laid underground at a minimum slope of 1:80, are to be utilised. From the preliminary layout, a total pipe length of approximately 2,865m is expected. Two Lilliput SBC 48000 FK BT CL sewerage effluent treatment plants, equipped with pre digestion, balancing, bio-reactor and clarifier and disinfection stages are proposed.

The sewage from the septic tanks (pre-digestion) is pumped at a constant rate to the Lilliput Bio- Reactor. The effluent enters the bio-reactor below the AWW Mark Two fixed-growth media where it mixes with an air diffuser. The effluent then rises through the media where the microbial population attached to the media removes and aerobically degrades the organic material contained in the aerated effluent.

2.3.3.2.5 Water balance The water balance is presented in Figure 34 with associated values in m3/day for each stream within the water balance.

Aquila commissioned Shangoni Management Services to prepare a water balance for the activities associated with the proposed operation. This water balance has been compiled for the inclusion into this Integrated Water and Waste Management Plan (IWWMP).

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Aquila is committed to update and expand the current water balance, if and when required, so that the water balance can be effectively utilised as a management tool, for example in simulating the effect of additional water management measures on the water management system. Updating and expanding of the water balance will reveal the areas of concern for water management at the operation.

The following will be adhered to by Aquila:  The current water balance will be improved and updated, as and when required, to reflect a water balance as required by the DWA policy as contained in the Best Practice Guideline, dated 2006,  The water balance will be used on a frequent basis to assess the quantity, quality and source of all water at the Aquila operation,  The water balance will be used to focus on key performance areas and to achieve the desired targets, such as (DWA, 2006):  To audit water usage from various source areas,  To identify areas of high water consumption and wastage,  To identify and quantify imbalances,  Locate and quantify sources of leakage,  Assist with the design and verification of storage requirements and minimising the risk of spillage, and  Assist in decision-making.  The water balance will be utilised as a tool in long-term water and waste management strategies,  The water balance will be reviewed on a yearly basis in terms of applicability, evaluation of new projects, changes in water management, availability of new technology and changes in regulatory and legislative requirements, and  The latest policy of the DWA, as contained in the relevant Best Practice Guideline, will be reflected in the yearly review of the water balance.

Water Balance Objectives and Purpose It should be noted that the function of the water balance is not to deliver an audit of the surface water infrastructure at the operation, but rather to assess the functionality of the proposed infrastructure and balance the flows based on estimated information.

A dynamic water balance is fundamental to optimising water management and minimising water use on any site. Dynamic water balances enable instantaneous examination of the changing situation of an operation. They also allow the investigation of different rainfall scenarios, such as flood and drought conditions, and process changes or new developments, which are critical to the planning process. A dynamic water balance is an important operational and regulatory tool for water and

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The primary purpose of this water balance is to characterise the water use at the Aquila operation. The objectives in terms of this project are therefore reflected as follows:  Develop a water balance for the Aquila operation,  The primary objective of the water balance will be to quantify and understand proposed surface water usage in and around the operation, to identify possible areas of loss, wastage and inappropriate utilisation of water.  The primary objectives in terms of surface water management are:  Optimisation of water usage,  Assured water supply for production,  Identify possible areas of loss,  Identify wastage and inappropriate utilisation, and  Make recommendations for improvements.

Aquila Water Balance Data utilised in this water balance analyses was drawn from a combination of data provided by specialist studies.

The following information and assumptions were used for this water balance:

Table 36: Water balance Information and assumptions Information Assumption Discard and Overburden Dumps surface area 512 900 m2 Pollution Control Dam 2 surface area 13 800 m2 Plant surface area 177 500 m2 Pollution Control Dam surface area 51 000 m2 Potable water usage requirement 60 m3 / day Water requirement for mining 715 m3 / day Estimated water to be abstracted from open pit 30 m3 / day Water to be used for dust suppression 110 m3 / km / day Distance of haul roads 6.5 km Water recovery from sewage treatment plant 80% Plant water requirement 547 m3 / day 4.5% of all water passing Percentage water loss in product through the plant 30% moisture in plant in Percentage water loss in discard filter cake discards

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Three separate water balances were developed for Aquila (monthly average, dry season average and wet season average).

Figure 34 shows the water balance for the monthly average water scenario at the proposed Aquila operation (average m3 per month). The main water supply to the system will be from the either the Crocodile River or the boreholes and affected water runoff collected in the Pollution Control Dam 1 (PCD 1) and Pollution Control Dam 2 (PCD 2). Main water losses will included water used for dust suppression, water used for mining activities and water lost as evaporation. The water balance also shows a significant quantity of unaccounted water loss at the plant.

Figure 35 shows the water balance for the wet season at the Aquila operation (average m3 per month). Affected mine water collected in PCD 1 and PCD 2 will be sufficient in supplying water to the plant during the wet season. Water losses will again be from water used for dust suppression, water used for mining activities and water lost as evaporation.

Figure 36 shows the water balance for the dry season at the Aquila operation (average m3 per month). During the dry season a negative water balance can be expected from PCD 1. This means that no mine affected water will be available for use in the process activities during the dry season. There will also not be enough mine affected water from PCD 2 to be used for dust suppression during the dry season. Additional water will be required for dust suppression activities from the Galvanised Bolted Steel Tank. Water losses will again be from water used for dust suppression, water used for mining activities and water lost as evaporation.

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WATER BALANCE 3 UNITS - m / month

Figure 34: Water balance diagram for Aquila (monthly average)

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WATER BALANCE 3 UNITS - m / month

Figure 35: Water balance diagram for Aquila (wet season)

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WATER BALANCE 3 UNITS - m / month

Figure 36: Water balance diagram for Aquila (dry season)

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2.3.3.3 Transport and conveyance

2.3.3.3.1 Inbound logistics Employees Personnel employed for the purpose of mining, ore beneficiation and maintenance and all other related activities on the project, will be transported to their respective work areas via three alternatives; bus, company vehicle or private vehicle. Entry to the site for all three modes of transport will be controlled at the main gate. The access control system will be designed for personnel access control and efficient flow of personnel, especially at shift changes. Deliveries not associated with weight based validation, as well as visitors to the mine, will also gain access through this access control point and will be managed in such a way that where possible it does not coincide with shift changes.

Bus Transportation Employees will be sourced from the local labour sending areas in close proximity to the site. Potential labour sending communities are located to the west and south of the project in Regorogile, Thabazimbi and Rooiberg approximately 20-40km from site.

Personnel will be collected from the various informal and formal settlement locations in the labour sending communities by sixty-five (65) seat busses, operated by a bussing enterprise. These busses will travel mainly on the Thabazimbi to Alma and Rooiberg to Thabazimbi/Alma gravel road to the site and deliver personnel to the security and access control point.

Fuel A fuel supply contract will be concluded with an established and reputable supplier. The contractor will have to maintain minimum fuel stock levels at site. Fuel will be delivered to site through the security access control point, as it will not require a weight based validation.

Maintenance Items It is envisaged that a logistic contractor will be identified through a tendering process. Such a contractor will have to establish a depot in the Gauteng area. Suppliers of spares, parts and other consumables will deliver the ordered goods to this depot by a suggested cutoff time daily. These goods will then be delivered overnight to site by truck, light delivery van or any suitable vehicle. This delivery vehicle will access and deliver to the stores within the site through the security access control point, unless a weight based validation is required. Some maintenance items, i.e. on-time deliveries and heavy items will be delivered directly to workshops by the contractor.

Explosives The Project will have a contract for Down-the-Hole explosives services, and will receive bulk delivery into magazines and silos every second day by trucks with 5t to 30t payloads. The logistics function for

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Roads and parking areas Haul roads A heavy duty haul road is proposed between the south western edge of the mine pit and the process area to the east of the mine area, which is 700m lower. Haul trucks will travel down to the process area and return along the same route, empty. A two way haul road is considered to be the preferred option when used for production purposes.

The fully laden downhill operating speed is estimated at 25km/h, whilst the empty uphill speed is estimated at 30km/h. Due to the nature of the topography, the minimum horizontal radius of 200m cannot always be maintained and therefore a radius of between 80m and 90m is implemented on four curves, requiring reduced speeds of approximately 16km/h. A design haul road gradient of 10% is adopted. Based on the above criteria, the road length between the mine and process area will be 6.5km and the earthwork volumes for a balanced cut to fill design:  Cut to fill: 2.45 x 6m3  Layer work volume: 122,000m3.

Plant internal roads The estimated length of internal 7m wide gravel roads is 5,000m, resulting in a total layer work area of 35,000m2. It is assumed that the bulk of the material required for the construction of the roads will be sourced from the site as well as from the mining discard.

The cumulative equivalent traffic is expected to be below 0.8 x 106 E80/lane

Parking areas Labour transportation parking 200m² have been provided for buses to collect and drop-of staff and park whilst waiting for staff during shifts. The pricing was based on installed 80mm thick paving.

Staff parking 200m² have been provided outside the main office block for permanent employee’s using their private vehicles. The pricing was based on installed 60mm thick paving.

Visitors parking 100m² have been provided at the main entrance to the site for visitors. The pricing was based on installed 60mm thick paving. The capital and operation costs are given in the relevant chapters.

General Consumables and Other items

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Deliveries of items not associated with weight based validation, for instance office consumables, maintenance associated parts & spares and general stock items destined for the stores, as well as visitors to the site, will also gain access through the access control point, which will be ideally managed so as not to coincide with shift changes.

2.3.3.3.2 Outbound Logistics Security and Weighbridge The validation and control of saleable iron ore products will be weight based and will therefore be transported from the site stockpiles over a single lane weighbridge, with an upgrade to a double lane weighbridge planned during the life of the project.

Product Logistics All saleable iron ore will either be road hauled from the stockpile to a suitable rail siding stockyard location in the Thabazimbi or Alma area. Or it will be transported by long distance conveyor to a siding location either in the Thabazimbi or Alma area or alternatively the rail line will be extended to the Project from where the ore wagons can be loaded directly from the stockpiles.

Plant Stockpiles Iron ore will be stacked and blended in stockpiles from where the product will be reclaimed by Front End Loaders (“FELs”) and loaded onto trucks or onto a conveyor feeding either the long distance conveyor or the load out station at the rail siding.

Road Haul The proposed mine is located on the farms RE Donkerpoort 448-KQ and RE Randstephne 445-KQ in Limpopo Province. The farms are located along Road P240-1 approximately 30km east of Thabazimbi.

Access to the proposed mine on these farms can be obtained from various roads, of which two routes were identified. For the purpose of this report we will use a siding south of Thabazimbi as reference point where product will be transferred from road to rail; the Chromedale siding along Road R510 approximately 16km south of the intersection with Road R511. The different routes investigated are depicted in Figure 37 and are as follows:

Southern Route: The existing gravel road is followed from the mine along Road P240/1 to the intersection with Road D928, then along Road D928 to the intersection with Road D1031 and then along Road D1031 to the intersection with Road R511/P110/1. At this intersection the R511/P110/1 becomes a surfaced road up to the intersection with Road R510 and then along the R510 to the Chromedale siding. This route is approximately 60.9km long.

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Northern Route: The existing gravel road is followed from the mine along Road P240/1 to the intersection with Road D928 then along Road D928 to the intersection with Road D1485. At this intersection Road D1485 becomes a surfaced road through Thabazimbi. In Thabazimbi it becomes Road R510 to the Chromedale siding. This route is approximately 62.8km long.

Two other routes were also identified as possible transport routes, and these include the following:

Alma Route: The existing gravel road from the mine along Road P240/1 is followed all the way to Alma. In Alma the section of P24-/1 is a surfaced road. This route was indicated as a possible route for product to the Alma railway station. This route is ±45km long.

Rooiberg Route: The existing gravel road is followed from the mine along Road P240/1 to the intersection with Road D928 then along Road D928 to Rooiberg. This route was indicated as a possible route for supplies, product and staff. In Rooiberg the road becomes a surfaced road. This route is ±36.7km long.

The position of the siding in Alma is unknown at this stage.

.

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Figure 37: Proposed traffic route options (***source: Traffic impact assessment)

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2.3.3.4 Energy supply

2.3.3.4.1. Main 22kV electrical Supply It is recommended that a main incoming 22kV substation be built on the boundary, comprising the following.  Substation building and yard;  A 22kV HT panel;  A 22/11kV, 10MW reducing transformer;  Earthing system;  Fencing around the substation and yard.

It is recommended that the 22kV supply be reduced to an 11kV supply, as it is less costly to distribute onsite at 11kV.

2.3.3.4.2. 11kV Electrical Supply An 11kV underground cable reticulation network is to be installed from the 11kV supply point at the main substation to the various mini-substations (buildings or skid mounted) at the infrastructure units, feeding an HT panel and an 11/0.4kV transformer.

A mini-substation is to be built at each infrastructure unit for the HT panel, transformer and main low voltage distribution panel.

2.3.3.4.3. Low Voltage Electrical Supply The 0.4kV transformer supply point is to feed a main 400 Volt low voltage supply distribution panel that will feed the various infrastructure units through distribution circuit breakers in the panel and through low voltage underground cables.

It is assumed that Eskom will be able to supply a 22kV supply from the existing network, approximately 10km away from the mine site. A new 22kV overhead line will have to be built by Eskom from their existing network to the proposed new main substation yard at the mine site.

2.3.3.5 Chemical and hazardous substances facilities

2.3.3.5.1 Diesel and lubrication storage facility Provision will be made for an on-site diesel and lubrication oil storage facility. The facility will be constructed to the requirements of the chosen fuel supply company, who will operate the facility on behalf of the mine. Bulk supply of fuel and lubricants would be by road from the bulk storage facilities in the area. A commercial service agreement needs to be set up with a supplier / distributor that has the capacity to supply the quantities required by the project.

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2.3.3.6 Maintenance facilities The following maintenance facilities are proposed:  Boiler workshop 400m²,  Washbay 200m²,  Doser workshop 500m²,  Tyre workshop 400m²,  Electrical workshop 400m² and,  Diesel workshop 500m².

2.3.3.7 Administration and other buildings The buildings will be divided into prefabricated structures for administrative use, whilst cladded, steel structures with concrete flooring will normally be constructed for workshops and similar applications. The estimated building requirements are summarised in Table 37 below.

Table 37: Estimated building requirements

Structure Area

Weighbridge 66

Heavy vehicle wash bay 28

General waste 55

Hazardous waste 55

MHPP Workshops 228

Heavy vehicle service bay 364

Workshops and store 2,928

Prefabricated structures 2,986

TOTAL 6,710

2.3.3.8 Housing, recreation and other employee facilities There are four hundred fourty six (446) employees including senior management required for a proposed 4Mtpa open pit production scenario. Key skills required are management, technical and operational skills and it is planned to recruit these during the construction phase.

Skilled and semi-skilled labour recruitment will primarily focus on the local communities and will focus on Historically Disadvantaged South Africans (“HDSA”) and Women in Mining (“WIM”). It is planned that the Project will exceed the requirements of the Mining Charter, with staffing for HDSA at 72% and 20% WIM (target is 10%).

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According to the Housing and Living Conditions for the Minerals Industry (2009) and the Amendment of the Mining Charter (2010), the government encourages the development of acceptable and sustainable housing and living conditions for mining employees and contractors. Accommodation plays a critical role in terms of the recruitment, attraction and retention of employees with the required skills.

Based on a study by RBS, the following three options appear most feasible to accommodate the 176 employees planned to come from outside the Project area. These are:

Option 1: Interim Solution – construction phase This option applies an accommodation model which is fairly general to mining operations found in the South African Development Community (“SADEC”), which is based on a “fly in, fly out” basis, utilizing localised single employee accommodation in the form of either guest houses or temporary management and skills camps. These accommodation costs would be covered by the employer, as employees would be away from families during the week.

This approach should be established during the construction phase in order to accommodate construction employees. In the case of the Project, there would be no need for flying as the site is relatively close to the main centres of Pretoria, Johannesburg and Rustenburg.

Option 2: Permanent Solution – Existing Accommodation This reflects a more contemporary approach where permanent employees’ families are accommodated. In this regard, given the Project location, the residential areas in close proximity to the Project are Thabazimbi, Regorogile and Rooiberg.

Although these residential areas are approximately 30-40 km away, travelling times and safety would be better than one would experience in Gauteng. It would be the employees’ responsibility to pay for their own accommodation by means of a housing allowance that is provided for in their TCTC salaries.

Option 3: Permanent Solution – New Accommodation There may be a requirement that units are constructed by the Company and then sold or rented to employees.

2.3.3.9 Security and lighting Project area An allowance has been made for 3,000m of fencing around the mining site. The fencing will be 2.4m section diamond mesh fencing.

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Plant area An allowance has been made for 3,000m of fencing around the plant area. The fencing will be the same as above.

Explosives storage area An allowance has been made for 150m of fencing around the blasting & explosives store. The fencing will be an electric fence.

Store and scrap yard Area An allowance has been made for 200m of fencing around the scrap yard. The fencing will be the same as above.

Security building A permanent guard hut will be constructed at the main entrance to the site. From here the security will control trucks and visitors both entering and leaving the building. Access control and a time attendance system have been allowed for.

2.4 Plan showing the location and aerial extent of the aforesaid main mining actions, activities, or processes as required to calculate the financial provision Refer to the Mine layout Plan (Figure 27)

2.5 Listed activities (in terms of the NEMA EIA Regulations) which will be occurring within the proposed project In terms of the National Environmental Management Act 1998, as amended, and the Government Notice R543 published in Government Gazette 33306 of 18 June 2010, for the following listed activities R544, R545 and R546, and Section 21 of the National Water Act, 1998 (Act 36 of 1998) published in the Government Gazette No. 20119 on 4 June 1999 under Government Notice GN 704, an Environmental Impact Assessment is triggered. Refer to Table 38 below for the listed activities.

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Table 38: EIA Listed activities triggered Number and Activity No (s) Listed activity as per project description date of the (in terms of the relevant notice relevant notice) R. 544, 18 June 2 Project description: 2010 The storage of ore stockpiles that will create dust and diesel that will create fumes will require an atmospheric emissions license.

Listed Activity: The construction of facilities or infrastructure for the storage of ore or coal that requires an atmospheric emissions license in terms of the National Environmental Management: Air Quality Act (Act No 39 of 2004). R. 544, 18 June 9(a) Project description: 2010 The construction of 200mm pipelines from the water supply to the reservoir and distribution of water on site.

Listed Activity: The construction of pipelines exceeding 1000 metres in length for the bulk transportation of water, sewage or storm water - (i) with an internal diameter of 0,36 metres or more; or (ii) with a peak throughput of 120 litres per second or more, R. 544, 18 June 12 Project description: 2010 The construction of lined Pollution control dam of 102,000m3 that will be equipped with a leakage detection system.

Listed Activity: The construction of facilities or infrastructure for the off-stream storage of water, including dams and reservoirs, with a combined capacity of 50 000 cubic meters or more, unless such storage falls within the ambit of activity 19 of Notice 545 of 2010 R. 544, 18 June 13 Project description: 2010 The storage of 490m³ of diesel for the vehicles on the mine, storage of explosives at the explosive magazine.

Listed Activity: The construction of diesel and petrol storage facilities, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 cubic metres; R. 544, 18 June 22 Project description: 2010 The construction of new access and haul roads where no reserve

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Number and Activity No (s) Listed activity as per project description date of the (in terms of the relevant notice relevant notice) exists and the road is wider than 8 meters.

Listed Activity: The construction of a road, outside urban areas, With a reserve wider than 13,5 meters or, Where no reserve exits where the road is wider than 8 meters, R545, 18 June 5 Project description: 2010 The construction of coarse tailings facilities, waste rock dump, ROM pad and stockpiles would require a license under Section 21 (c) & (i) and (g) of the National Water Act, 1998 (Act 36 of 1998).

Listed Activity: The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply. R545, 18 June 15 Project description: 2010 Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more;

Except where such physical alternation takes place for: Linear development activities, or Agriculture or afforestation where activity 16 in this Schedule will apply.

Listed Activity: Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more; except where such physical alteration takes place for: (i) linear development activities; or (ii) agriculture or afforestation where activity 16 in this Schedule will apply R.546, 18 June 2 Project description: 2010 The construction of a reservoir 25m x 25m.

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Number and Activity No (s) Listed activity as per project description date of the (in terms of the relevant notice relevant notice) Listed Activity: The construction of reservoirs for bulk water supply with a capacity of more than 250 cubic metres. (ff) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; R.546, 18 June 3 Project description: 2010 The construction of telecommunication masts.

Listed Activity: The construction of masts or towers of any material or type used for telecommunication broadcasting or radio transmission purposes where the mast:

(a) Is to be place on a site not previously used for this purpose, and (b) Will exceed 15 metres in height, but excluding attachments to existing buildings and masts on rooftops.

(gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; R.546, 18 June 4 Project description: 2010 The construction of new access and haul roads where no reserve exists and the road is wider than 8 meters.

Listed Activity: The construction of a road wider than 4 metres with a reserve less than 13,5 metres.

(a) In Limpopo province:

ii. Outside urban areas, in:

gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core areas of a biosphere reserve; R.546, 18 June 10 Project description: 2010 The storage of 490m³ of diesel for the vehicles on the mine, storage of explosives at the explosive magazine.

Listed Activity:

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Number and Activity No (s) Listed activity as per project description date of the (in terms of the relevant notice relevant notice) The construction of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres. (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core areas of a biosphere reserve;

2.6 Indication of the phases and estimated time frames in relation to the implementation of these actions, activities or processes and infrastructure

2.6.1 Implementation or construction phase The construction phase will include removal of topsoil, vegetation and overburden for open pit preparation and for construction of associated infrastructures. The topsoil (seed bearing soil) will be stripped prior to mining and placed on a separate dump situated close to the coarse tailings to be used during rehabilitation. The open pit will be started through creating an initial boxcut. The objective of the boxcut will be to expose sufficient iron ore reserves for the first production year, and will be positioned optimally to act as a future access ramp, and at a location in close proximity to the run of mine (ROM) crusher location.

2.6.2 Operational phase The open pit will be mined through conventional truck and shovel mining techniques. Drilling and blasting of overburden. The overburden and waste rock material will be stripped and dumped on the waste rock dump that will be established on the contour of 1620 mamsl on the south-eastern side of the open pit. During the final years of the open pit, an in-pit waste rock dump will be established in the north-eastern section of the open pit, should the pit design and geotechnical parameters allow. The final pit is planned with four push backs. The production benches are 12m high based on the mining equipment considerations.

The mining sequence in the open pit environment will be as follows: • Creating initial free faces by making a boxcut; • Loading and hauling of overburden to waste dumps or backfilling after iron ore extraction; • Drilling and blasting of waste rock; • Loading and hauling of waste rock to waste dumps or backfilling after iron ore extraction; • Drilling and blasting of Iron Ore lodes;

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• Loading and hauling of the Iron Ore to primary crusher/ ROM stockpile.

The waste rock dump will be located on the mountain top of Donkerpoort 448 KQ. The supporting mining infrastructures will be located on the lower lying Randstephne area.

The proposed infrastructure will consists of the following: Access & haul roads to plant area 200mm pipeline running from the Hazardous and general waste & other mining infrastructure water supply to reservoir storage area Dense medium separator (DMS) Access control Sewer treatment plant of 13m x 9m Plant Area serving 492 people Change rooms 600m² Diesel workshop 500m² Blasting & explosive stores

Stores 200m² & 800m² Boiler workshop 400m² Coarse tailings

Offices 1300m² Washbay 200m² Waste rock dump 200 million m³

First aid bay 100m² Dozer workshop 500m² ROM pads of 1 million tonnes

Staff & Visitor’s parking 300m Tyre workshop 400m² Plant discard dump 2 million tonnes

Weigh bridge Electrical workshop 400m² Ore stockpiles

Salvage yard 2500m² Fuel storage 35m x 25m Reservoir 25m x 25m

Security 165m² Lab and core shed 250m² Pollution control dam 102,000m3

2.6.3 Decommissioning phase The decommissioning phase will include the final backfilling of the pit, reshaping of the final void, rehabilitation of mine residue deposits, rehabilitation of final footprints including shaping, replacement of topsoil and re-vegetation.

The final mining void will not be in-filled. In order to limit access, an open rock enviro-bund to a height of at least 3m with its inside toe 20m from the long term break-back line of the pit/void, will be constructed. The corridor between the inside toe and the pit lip/edge will be vegetated with native thorny vegetation to limit access even further. The bund and associated vegetated corridor will serve the following purposes:  Safety measure to isolate the pit from people and animals by restricting access to the pit;  Visual screening of the pit void; and  Divert surface water runoff away from and around the pit, preventing erosion of the lip/edge of the pit void.

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2.7 Confirmation if any other relevant information is attached as appendices

An ecological evaluation for the Aquila Steel project, Thabazimbi Appendix E1 Aquila Steel Meletse Iron Ore Project: Report on geohydrological Appendix E2 investigation as part of the EIA and EMP. Palaeontological Assessment: Site Visit Report. Gatkop cave on farm Appendix E3 Randstephane 415 KQ near Thabazimbi, Limpopo province Cultural heritage resources essay for the farms Donkerpoort 448 KQ, Appendix E4 Randstephne 455KQ and Waterval 443KQ, Limpopo province Assessment of the bats at Gatkop Cave, and possible mitigation measures Appendix E5 Stormwater management plan Appendix E6 Air Quality impact study Appendix E7 Nnoise survey Appendix E8 Visual impact assessment report 2014 Appendix E9 The Ecological Integrity of the aquatic habitat at the proposed Aquila Steel Appendix E10 mine on the Farms Donkerpoort 448KQ and Randstephne 455KQ, Thabazimbi district, Limpopo Province, South Africa. Environmental Impact Assessment: Ground Vibration and Air Blast Study Appendix E11 Aquila Steel (Pty) Ltd. Meletse Project Traffic impact study Appendix E12 Economic impact study Appendix E13

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3 The Potential Impacts

3.1 List of the potential impacts, on environmental aspects separately in respect of each of the aforesaid main mining actions, activities, processes, and activities listed in the NEMA EIA Regulations Refer to sub-section 7 of this Section 1 (EIA) for a complete list of impacts associated with the proposed activities (i.e. the proposed pit and associated infrastructure) during the Construction, Operational and Decommissioning Phase.

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3.2. List of all potential cumulative environmental impacts Table 39: Cumulative impacts ASPECT MINE ASPECT OTHER LAND USES IMPACT DESCRIPTION Dust generation from mining operations and Dust generation from agricultural activities and community Potential impact on air quality. According to atmospheric transportation. driving on roads. deposition monitoring conducted as part of prospecting and the EIA phase, deposition values continue to be well within proposed residential limits.

The area within which the proposed activity is to be undertaken is very rural and only accessible by gravel roads. The occurrence of the proposed mining activity and the introduction of heavy hauling trucks will contribute to the cumulative effect of dust in the area. Noise generation from mining operations and Noise generation from agricultural activities and community Nuisance to the community from noise. However according transportation driving on roads. to the noise survey, the noise shall be contained within the valleys of the mountains where the mining and plants will be concentrated and shall have no effect on any surrounding communities. Invader plants establishing on disturbed areas Invader plant already established due to agricultural Disturbance and destruction of natural vegetation activities and rural community

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ASPECT MINE ASPECT OTHER LAND USES IMPACT DESCRIPTION Removal of natural vegetation for mining activities Removal of naural vegetation used for crop production According to an ecological evaluation conducted on the proposed site, the proposed mining activities will result in the large-scale loss of primary vegetation units and important faunal habitat types. Consequently, the loss of habitat will lead to the displacement of fauna, the loss of certain threatened species and increased fragmentation of key functional habitat types that are already under pressure from developments in other parts of the country (e.g. loss of Highveld grasslands due to mining and cultivation).

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ASPECT MINE ASPECT OTHER LAND USES IMPACT DESCRIPTION Siltation of water resources due to run-off from Siltation of water resources due to crop production The impact of the proposed mine, the associated road plant residues, WRD, plant area system and other related activities will result in an increase in erosion and run-off of water into the non-perennial drainage lines. This will result in an increase in sedimentation in the perennial streams into which they drain (Zandspruit & Sondagsrivier). This will be exacerbated by the increase in water used during the mining processes, therefore resulting in an increase of (unseasonal) water into the non-perennial drainage lines. The increase in sediment can be detrimental to the aquatic ecosystem because the water becomes silted making it difficult for fish and aquatic macro-invertebrates to breathe and feed amongst other ecological processes. The increased sedimentation and thus embeddedness of cobble and gravel substrate will negatively compromise the spawning beds of fish and therefore reduce the breeding success. It will also silt up the nursery areas and lessen the feeding ability of fish fry because of the loss of macro- invertebrate habitat. The riffles and rapids are important for recharging the oxygen content of the water which is critical to the river system as a whole and in particular flow dependent species; this function will be lost or reduced significantly with the increase of sediment loads in a river. There will also be an impact to irrigation operations and could also have varying degrees of impacts on the livestock and other animals drinking this water.

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ASPECT MINE ASPECT OTHER LAND USES IMPACT DESCRIPTION The construction of new access roads and haul Roads constructed during prospecting activities create a Visual aspect. With the proposed mining activities being road for proposed mining activities creates a large large visual scar in the area. elevated on the mountain with 800m difference from foot to visual scar in the area. tip, the visibility is extremely high from far away. There is however a large component of screening due to the bushveld surroundings reducing the visibility significantly. Receptors likely to be affected are local residents passing through and holiday visitors at tourism destinations in the area. Local residents will in time get used to the scenery along the road, whereas holiday visitors will be majorly affected should the development be visible from their destination. The proposed mine will definitely create an intrusion on the overall sense of place for the surrounding areas.

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3.3 State specifically whether or not there is a risk of acid mine drainage or potential groundwater contamination associated with the mineral to be mined The following information was extracted from the report titled Geohydrological investigation as part of the EIA and EMP dated March 2014 done by Groundwater Complete (Appendix E2).

The two most common processes by which groundwater are contaminated include interstitial release and ion exchange release. Argillaceous sediments such as shale and mudstone are known to contain pore water with high saline content. Significant amounts of contaminants may therefore be released as these sediment structures disintegrate because of weathering or when exposed and crushed through the mining process. The most commonly released ions during this weathering process are sodium and chloride.

Pyrite in coal-bearing material and base metal sulphides are very prone to oxidation when brought into contact with water under oxidising conditions. The chemical reactions are collectively referred to as acid mine drainage (AMD). The root of the problem lies in chemical and bacteriological oxidation of pyrite occurring in the coal, other carbonaceous material and base metals. The following are the most commonly occurring reaction train:

2FeS2 + 7O2 + 2H2 – 2FeSO4 + H2SO4 (1)

4FeSO4 + 2H2SO4 + O2 – 2Fe2 (SO4)3 + 2H2O (2)

3Fe2 (SO4)3 + 12H2O – 2HFe3 (SO4) 2 (OH)6 + 5H2SO4 (3)

The pH and bicarbonate value of the water is expected to decrease. Metals go into solution and sulphate (SO4) and Total Dissolved Solids (TDS) values increase. As the water leaves the mining area, it usually mixes with better quality water and the pH and bicarbonate values will be buffered back to more acceptable levels. Metals then also precipitate and the SO4 and TDS concentrations decrease.

The in situ ore and host rock are chemically inert and ion exchange and accompanying groundwater contamination is not expected to occur as a result of the geochemistry of the ore and waste rock. Ore and waste rock consist of banded iron formation, consisting of alternate layers of chert and hematite, both of which are chemically inert.

A good case example to support these statements is Thabazimbi Iron Ore Mine situated approximately 30 km to the west. Thabazimbi Mine is situated in exactly the same geological environment and produces the same products as earmarked for Meletse. Thabazimbi has been in

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 170 of 328 Management Programme under the MPRDA, 2002 operation for nearly a century and the surface and groundwater has a basic character with pH generally around 8. No AMD effects are observed at all.

The only water quality impacts that might occur result from the physical mining operation itself and from seepage or accidental spills of hazardous substances imported into the mining area for a variety of uses like fuel, lubricants, cleaning agents and solvents.

The types and sources of contamination that usually occur in the iron ore environment, and also expected at Meletse, are:  Organic/hydrocarbon contamination sources like fuels, lubricants and organic cleaning agents/solvents used in mining equipment and workshops.  Nitrate contamination inside the pit areas where nitrate-based explosives are used in large quantities.  Contamination by suspended solids, especially haematite dust and mud particles created by the physical impact of the mining operation.

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Regulation 50 (b)

4 The alternative land use or developments that may be affected

4.1 Concise description of the alternative land use of the area in which the mine is proposed to operate The following information was extreacted from the Economic report Aquila Meletse alternative land- use economic impact assessment. The alternative land-use to the proposed mine is that of eco- agricultural (a combination term for eco-tourism and agriculture.) Mining Right Application is made over a 1 563 hectares area and this site falls in the centre of an ecologically sensitive area where farming and conservation are intentionally combined to increase the sustainable development potential for the local economy.

The paramount feature of the proposed mine is its close proximity to the Waterberg Biosphere where local farmers have embraced game-farming as part of the conservationist ethos. Bushveld tranquillity and serenity is a critical part of the alternative land-use. The Biosphere stretches from Marakele National Park in the south west to Wonderkop nature reserve in the north-east. Ringed by escarpments on three sides, the Waterberg forms a wide basin in which four of the main rivers in Limpopo originate.

Biosphere reserves are areas of terrestrial and/or coastal ecosystems promoting solutions to reconcile the conservation of biodiversity with its sustainable use. They are internationally recognised, nominated by national governments and remain under sovereign jurisdiction of the states in which they are located.

The Marakele Game Reserve is near the proposed mine, almost equidistant to the existing Thabazimbi mine, and the inter-connectedness between this reserve and private game reserves around the proposed mine is noteworthy. Private game reserves feed off the nearby biosphere tourist attractions and have become an integral part in game and environmental conservation. In essence, the needs of the alternative land-users in the immediate area are diametrically opposed to a mine development and hence conflict over land is a certainty.

The proposed mine itself is on the Meletse Mountain, which is 1800 to 1830 meters above sea-level in places and this peak is a prominent eco-tourist feature for the alternative land-users in the area.

The Thabazimbi Integrated Spatial Development Framework (2007) recognises the importance of tourism, particularly in the Waterberg District. It is furthermore stated that there is a rapid growth expected in the tourism sector of the Province and District. This is mainly because of the growing

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 172 of 328 Management Programme under the MPRDA, 2002 annual flow of tourists to Limpopo who regard the Bushveld as a popular tourism destination. Opposed to this view, the value of the mining sector, as the primary pillar of the local economy, is also recognised. The SDF, for instance, states that the areas surrounding the Marakele National Park, particularly the mountainous areas, are identified as potentially environmentally sensitive areas.

The mining sector makes up 90% of Thabazimbi’s GDP and 67% of employment. The eco- agricultural sector employs under 10% of the local active workforce.

The SDF continues as stated that sensible development should take place around the Park to contribute towards the Park’s long term development. It is of utmost importance that activities in these areas are managed according to planning and environmental guidelines to prevent a substantial detrimental effect on the environment. In terms of mining activities, the SDF concludes that from a development and environmental perspective it is important that mining takes place in a responsible manner.

The SDF furthermore states that approximately 40% of the land situated within the municipal area is utilised for game farming, ±2% for irrigation, ±3% for dry-land farming, mining 0.4% and approximately 5% for towns, roads and other infrastructure. The remainder of the area is utilised for extensive cattle farming. A large percentage of the surface area of the municipality cannot be considered for development as a result of topographical features such as mountains and riverine areas. The latter statement is also particularly valid for the subject property which is characterised by topographical features of its own in the Meletse Peak. The Meletse Peak is the highest mountain peak within 10km of the project site. It is specifically these mountainous areas on site which is to be targeted for its underground iron ore deposits.

Thabazimbi/Regorogile is the main hub of the Municipal area and is the town/settlement closest to the project site. It is located fairly central to the entire municipal area and provides the majority of services to the rest of the municipal area. It has a well-established business and industrial area and is currently experiencing tremendous residential expansion.

The area was mined since the 1930's when iron and steel production started. The town itself was proclaimed in 1953. Today Arcelor Mittlas Steelworks in Gauteng still draw much of their raw material from Thabazimbi Kumba Resources (Iron Ore mine). More than 2 million tonnes of ore are mined every year and hauled by train to Arcelor Mittal's iron and steel works.

In Rooiberg itself, an area under 10 km away from the mine site, a tin mine was in operation historically and the exact date of mine closure is not certain. Rooiberg today is a small township and can be described as the remains of the historic mine.

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4.2 List and description of all the main features and infrastructure related to the alternative land uses or developments The rural nature of the area is particularly evident on the project site. No infrastructural improvements (e.g. airstrip, telecommunication towers, irrigation pipelines or large electrical transmission lines) have been observed on site. Only small-scale power lines to individual farmsteads are present. The site is however traversed by several, what appear to be, haul roads. These roads are not evident and traverse the site up to the mountainous peaks on the property. The following presents an abbreviated list of such farms, eco-lodge and safaris found within 5km of the project site:

 Buffelshoek Boerdery,  ThabaPulani Game Lodge,  Chaheng Hunting Safaris,  Motlapi Wildsplaas,  Boschfontein,  Meletse Game Reserve,  Meletse Game Breeders,  Bôna Taba.

4.3 Plan showing the location and aerial extent of the aforesaid main features of the alternative land use and infrastructure related to alternative land developments identified during scoping Figure 38 illustrates the current infrastructure on site are current roads and roads constructed for prospecting, lodge, old farmstead, stores, shed, reservoir, and surface dam

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Figure 38: Plan showing current infrastructure related to alternative land developments

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5 The Potential Impacts of the Alternative Land Use or Development

5.1 List of the potential impacts of each of the aforesaid main features and infrastructure related to the alternative land use or development and related listed activities

The ratings of impacts are discussed elsewhere in this report. Table 40 merely outlines the potential impacts as it relates to alternative land-use from an economic perspective.

Table 40: Potential impacts of main features and infrastrucute related to the alternative landuse Feature Potential Impact Impact on current infrastructure on The current infrastructure on the proposed mine is not material in terms of the proposed mining site economic alternative land-use analysis and need not be expanded upon. The potential cumulative impacts, as described below, are material and are discussed below.

5.2 Description of all potential cumulative impacts of the main features and infrastructure related to the identified alternative land uses or developments

Table 41: Potentail cumulative impacts on main features and infrastructure Feature Potential Impact Mining of the Meletse Peak in an The critical impact of disturbing this visible peak is the potential of decline ecologically sensitive area in the income of neighbouring farmers from eco-tourism sources. The farmers that derive income from eco-lodges, safaris and eco-tourists may be negatively impacted.

A further impact is that of the disturbance of sense of place, a disturbance that cannot be quantified.

In addition to this, depending on the degree of rehabilitation, the 1563 hectares of proposed mining land may well be perceived as sterile by future investors due to unknown environmental liabilities and hence the land may well never be used for economic purposes again by this economic generation.

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Feature Potential Impact Traffic Impacts In its unmitigated form the haulage of ore on gravel roads will pose a significant threat to current road-use for the purpose of eco-tourism. It is estimated that a truck may pass scores of game farms on either of its optional routes to the extent of a truck every three minutes.

On this basis, the reputation as a pristine eco-tourist area will most certainly be tarnished and the practice of eco-tourism as it exists (thus high-end premium eco-tourism) will certainly be impaired in the short term. In addition to this, eco-tourism operators would have to change their marketing strategies to exclude words such as “quiet”, “serene”, “tranquil”, “peaceful”, “relaxing”, “soothing” and the like.) Employment Both the above impacts (the visual and traffic disturbances) could have retrenchment impacts for local farm workers and employees. This needs, however, to be compared to the jobs created by the mine.

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Regulation 50 (c)

6 Identification of potential social and cultural impacts

6.1 List of potential impacts of the proposed mining operation on the socio-economic conditions of other parties’ land use activities Refer to sub-section 7.1 of Section 1 (EIA), for a complete list of impacts, on environmental aspects separately in respect each of the aforesaid mining activities, ore processing activities, support services, general activities and mine-wide impacts.

6.2 Description of the cultural aspect that will potentially be affected, and describe the potential impact on such cultural aspect Refer to sub-section 7.1 of Section 1 (EIA), for a complete list of impacts, on environmental aspects separately in respect each of the aforesaid mining activities, ore processing activities, support services, general activities and mine-wide impacts.

6.3 Description of heritage features and the potential impact on such heritage feature Refer to sub-section 7.1 of Section 1 (EIA), for a complete list of impacts, on environmental aspects separately in respect each of the aforesaid mining activities, ore processing activities, support services, general activities and mine-wide impacts.

6.4 Quantification of the impact on the socio-economic conditions of directly affected persons, as determined by the findings and recommendations of a specialist report in that regard

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6.4.1 The amount of the quantified potential impact on property or infrastructural assets In terms of the property value increase on the farms where the proposed mine will operate and against the valuation of an 8 km radius of sterilisation of eco-agriculture land, at a very robust R40 000 per hectare, the value increase in mine land outstrip that of eco-agriculture over the life of mine. To this effect, we reproduce table 43 and this shows that both the property values and GDP’s are better than for mining to alternative land-use. The value of mine land is set at investment value less economic write of value in 18 years’ time of the property. The net value of the 1500 hectare land on which the mine will be situated in current rand will equate to R2.172 billion. The potential agricultural value loss of an 8 km radius is R805 m.

Table 42: Alternative land-use analysis 18 years (2013 rand values)

Alternative land-use analysis 18 years (2013 rand values) Value Worse Case hectares displaced 20 113 ha Start-up capital (year 2015 + 2016) R 3 084 m Operating GDP over 18 years R 6 230 m Total GDP (investment and operating) of mine 18 years R 9 314 m Provision for mine failure -R 1 863 m Less potential agricultural property values lost -R 805 m Economic write off of potential sterile mining land -R 912 m Less Agricultural GDP lost -R 2 020 m Net GDP over 18 years R 3 714 m

6.4.2 State the amount of the quantified potential impact on commercial, economic or business activity which will be impacted upon as a result of the mining activity Error! Reference source not found. above works with the worse-case scenario and should one average the different scenarios, then, it can be concluded that the net GDP addition is R5.3 billion over an economic generation of 0.8% of the GDP of Thabazimbi.

Table 43: GDP addition under different land-sterilisation scenarios % to Thabazimbi Scenario Ha impacted Increase in GDP GDP 3714.437388 Best 1 500 ha R 6 328 m 1.0% Second Best 3 564 ha R 6 038 m 0.9% Middle 8 466 ha R 5 350 m 0.8% Worse 20 113 ha R 3 714 m 0.6% Average R 5 358 m 0.8%

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Employment Table 44 below shows that in the worse-case scenario, 105 jobs may well be lost to the local economy, as opposed to the best case of 267 net new jobs. Should one take the average of all the scenarios, then one can expect 129 economic lifetime new jobs and this will increase employment by 0.3% locally. As a statistic, this is very low, however, as a reality in the life of one person, this is significant.

The total staff complement at optimum mining is budgeted at 446 people. Full time economic generation equivalent jobs, thus the total employment by the mine is scaled down by 18/32 years to adjust for a LOM of 18 years and an assumed economic generation of 32 years. The question of what and why an economic generation of 32 years when in fact environmental impacts may last several generations, is simply that economic justice dictates that this generation has a right to increase their wealth within the confines of the laws of society and that of sustainable development. For this reason the economic benefits of the mine is scaled down by 18/32 years, as opposed for example 18/100 years, which would discriminate unfairly against the mine development.

Table 44: Potential jobs created or lost Sceario Hectares (137) Employment

Best (1,500) 267 0.7%

Second Best (3,564) 226 0.6%

Middle (8,466) 128 0.3%

Worse (20,113) (105) -0.3%

Average 129 0.3%

Household expenditure and multipliers The argument is often made that at a local level a large portion of GDP is lost through leakages and for this reason the real comparison is between the potential increase and decrease in local household expenditure.

There is much truth in this from a local perspective, for example the mining industry made up R18 billon in GDP in Thabazimbi compared to a total of R20 billion in 2011 In its extreme case, this means the mine’s multiplier is not higher than 1.11 locally and if anything, it will be lower. These low multipliers are often found in relatively small economies or economies not well-diversified, as is the case with Thabazimbi’s.

On the other hand, it can be estimated that eco-agriculture’s GDP multiplier would be much larger, possibly 3.3 for the local area. This number is estimated working on the basis that the eco-agriculture industry has a GDP of R300m and assuming R1000m GDP is generated based on this industry. This assumption is made as the 2011 GDP of Thabazimbi was R20 billion and mining accounted for

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R18 billion (90%). If one assumes that half of the R2 billion economy left after deducting mining is as a result of the eco-agriculture industry, then it stands to reason that this GDP multiplier could be 3.3. By the same token, because of the quantities involved, without the mining sector the Thabazimbi economy may well be smaller than R2 billion, which indicates the critical mass of mining in the Thabazimbi economy.

Similarly, for employment multipliers very similar patterns hold true, that the mine employment multiplier in the local economy cannot be higher than 1.5 times and that of eco-agriculture could be as high as 3.0 times. Should one run this scenario to its end conclusion then the question is this: if all new mining jobs are halted, then how many new direct jobs would have to be created in eco- agriculture to obtain full employment in the local economy? It is estimated that 6 500 direct jobs would have to be created in the eco-agriculture sector to get Thabazimbi to its full employment potential. An amount of 6 500 new jobs in eco-agriculture is in this specialists view way beyond the potential of this industry, and hence the municipality has to look at other sectors for job creation.

When one moves beyond the municipality to district borders, then Bojanala has nearly 100 000 people unemployed and thus upon the creation of new jobs, many of these unemployed will simply migrate to Thabazimbi seeking new jobs, hence the unemployed in Thabazimbi itself is dynamic number in that it will wax and wane in accordance to the perceptions of job-seekers of where the jobs are. In essence, the task of creating adequate jobs for the SA economy is a never-ending one and one regions’ job opportunities become the country’s opportunities.

The reality of SA’s economics is that eco-agriculture and mining has to find a meaningful manner to co-exist in the interest of the betterment of the South African society, not just regionally-specific as unemployment migrates from region to region.

Foreign exchange Foreign exchange may be defined as currency or other financial instruments that allow one country to settle amounts owed to other countries. Amounts owed by SA to the United States, for example, are settled in foreign exchange, that is, in US dollars. Foreign exchange is earned by residents of a country through the sale of goods and services to the international community (exports) and may also be acquired through foreign investments and foreign borrowings.

Its importance lies in the concept of international business confidence. The less foreign exchange a country has, the weaker its currency generally becomes, the higher its interest rate has to be to attract foreign investment and the less confidence there is in a nation’s economy. The importance of foreign exchange is often overlooked in a local context because stakeholders act in their local best-interest without considering the importance of a stable currency. Game-farms may argue that a low exchange rate is in their favour, but in reality when an exchange rate drop dramatically it is because events are occurring that make international investors, and by definition international tourists, uneasy about that

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 181 of 328 Management Programme under the MPRDA, 2002 national economy. In other words, a very low exchange rate has the risk of reduced international tourists and this in the long term is not to the benefit of the game-farms.

Over the proposed mine’s life there is the potential to earn R54 billion’s worth of foreign exchange assuming the ore and the steel produced in SA is exported. This equates to possible foreign exchange of just over R3 billion per annum. Compared to this R5.4 billion over a 32 year period or R298 million per annum is the worse-case foreign exchange losses as a result of potential land- sterilisation. This foreign exchange earnings estimate of the impacted eco-agriculture sector is a liberal estimate in favour of game-farmers and is simply much less favourable than mining.

6.4.3 The sum of the amounts, referred to in paragraphs 6.4.1 and 6.4.2 above In terms of the property value increase on the farms where the proposed mine will operate and against the valuation of an 8 km radius of sterilisation of eco-agriculture land, at a very robust R40 000 per hectare, the value increase in mine land outstrip that of eco-agriculture over the life of mine. The value of mine land is set at investment value less economic write of value in 18 years’ time of the property. The net value of the 1500 hectare land on which the mine will be situated in current rand will equate to R2.172 billion. The potential agricultural value loss of an 8 km radius is R805 m.

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7 Assessment and evaluation of potential impacts

7.1 List of each potential impact identified in paragraphs 3 and 6 above This section is divided into 3 sub-sections. Section 7.1.1 includes all mining activities from construction phase to decommissioning phase. Section 7.1.2 includes support services such as waste, water, storage areas, transport, etc. from construction phase to decommissioning phase. Section 7.1.3 includes all additional, general activities. These activities are therefore not included in the other sections. No ore processing activities will take place; therefore there is no risk register for these activities. A detailed description of monitoring is given in sub-section 15 of section 1 (EIA); a detailed description of environmental emergencies is given in sub-section 7 of section 2 (EMP). Refer to sub-section 7.2 of section 1 (EIA) for the significance rating methodology.

7.1.1 Construction phase

Impact per phase⁴ Risk rating Environmental Mitigatory action plan⁸ Timeframe⁹ Responsibility¹⁰ Risk rating Applicable (before objective⁷ (after legislation mitigation)⁵ mitigation)⁵ and other

documents

Probability Magnitude Severity Probability Magnitude Severity Activity²: Planning and design Aspect³: Potential inadequate planning and design Planning Impacts on the environment that could 4 4 H To effectively plan and Site selection for the proposed activities will include consideration of the Complete prior to Project manager 4 4 H  Summary of potentially have been avoided. design the proposed following: commencement with the Mine engineer legislation and mine and associated  Sloping / gradient factors. project activities. SHE manager documentation infrastructure taking the  Contractor requirements and communication. ECO used. Note a on-site environment  Design and construction requirements for spillage control, stormwater Environmental breakdown is into consideration management and erosion control measures. manager given below in  Environmental legal requirements. Specialists (where risk register.  Water reticulation system (water balance). required)  NEMA,  Access to and from the proposed site  NWA,  The location of nearby drainage systems, watercourses and sensitive  MPRDA, landscapes.  NEMAQA,  The habitats of fauna and flora species.  NEMBA,  Protected plant and tree species.  NHA,  Available water supplies.  CARA and  Fire protection services and their reaction times.  All specialist  Security and general service facilities in the area. studies.  Future expansions (if applicable).  General housekeeping practices.  Government Authority requirements and permit conditions.  Possible heritage or archaeological resources on-site.  Soil types and land capability.  Surface water quality (pre-project status) and possible impacts that would result from proposed activities.  The above listed information will be recorded before the construction at the site commences and will be used for future monitoring purposes. Construction, The activity is not applicable to the construction, operational, or decommissioning phases operational, and decommissioning Activity²: Site preparation will include the following activities: Opening of the pit Construction of maintenance facilities (diesel; dozer tyre; electrical; plant and boiler workshop). Construction of waste management facilities (scrap and salvage yard; hazardous and general waste temporary storage facility, and sewerage treatment plant). Construction of administrative buildings (administrative offices; stores; lab; core shed; staff/visitors parking and labour transport; first aid bay; weighbridge; change rooms and security offices). Construction of water management facilities (pollution control dam; reservoir and pipeline running from the water supply to reservoir). Construction of supporting infrastructures (dense medium separator (DMS), plant area; wasterock dumps; coarse tailings, blasting & explosive stores; ore stockpile areas, ROM pads, fuel storage area and a reservoir).

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Impact per phase⁴ Risk rating Environmental Mitigatory action plan⁸ Timeframe⁹ Responsibility¹⁰ Risk rating Applicable (before objective⁷ (after legislation mitigation)⁵ mitigation)⁵ and other

documents

Probability Magnitude Severity Probability Magnitude Severity Construction of haul roads The introduction of lighting along the road infrastructure and with the new built infrastructure. Aspects³: Removal of vegetation, Topsoil and sub-soil stripping Removal of overburden. Construction (the Loss of topsoil resource. Soil 3 2 M To conserve topsoil  Topsoil shall be stripped and stockpiled separately. During construction phase Mine engineer 3 1 L  Section 28 activity is not compaction and topsoil loss leading to resources  Topsoil shall be marked with a signboard. SHE manager NEMA applicable to the reduced fertility.  A topsoil balance and topsoil management plan shall be developed. ECO  Section 37, 38, operational and Environmental 39 MPRDA decommissioning manager  Regulation 70 phases; however, MPRDR i.t.o impacts will be MPRDA ongoing until Soil erosion due to bare areas. The 3 2 M To prevent soil loss  Site clearance and alteration activities will be planned for the dry season 3 1 L  Section 28 after intensity of erosion is increased by and erosion  The period of exposure of soil surfaces will be minimised through dedicated NEMA rehabilitation and rainfall, and windy conditions. planning.  Section 37, 38, closure)  Stripping operations will be done when soil moisture content is low, during 39 MPRDA dry seasons to minimise the risk of compaction.  Regulation 70  If dust mitigation measures cannot be applied, working on windy days will MPRDR i.t.o be minimised. MPRDA  Aquila must comply with the requirements of GN 704, dated 1999, and  Stormwater must implement the measures as contained in the Storm Water management Management Plan. plan

Generation of TSP, PM2.5 and PM10 3 2 M To ensure that the  The extent of open areas shall be kept to a minimum 3 1 L  Section 28 windblown emissions resulting from mine remains  The frequency of disturbance shall be kept to a minimum NEMA open areas. compliant with the Air  Wet suppression shall be implemented where feasible  Section 37, 38, quality legislation. 39 MPRDA  Regulation 70 MPRDR i.t.o MPRDA  Air quality impact assessment The stripping of topsoil and subsoil 2 2 L Establish and  A soil management plan shall be developed and effectively implemented to 2 2 L  Section 28 from the infrastructure surface areas is implement an effective eventually feed into the rehabilitation plan to ensure that long-term land use NEMA considered negligible since no soil conservation and objectives can be obtained.  Section 37, 38, chemical interaction is envisaged that management plan 39 MPRDA could have an adverse impact on  Regulation 70 groundwater quality. A slight increase MPRDR i.t.o in the effective recharge can be MPRDA expected.  Geohydrologic al investigation report Destruction of the vegetation 5 5 H To prevent the loss of  The amount of vegetation removed shall be limited to the least amount 5 5 H  Section 28 communities. The proposed open-cast vegetation and if not possible and any disturbance to the adjoining natural vegetation cover shall NEMA pit will coincide with Protea-dominated possible minimise the be avoided.  Section 37, 38, grassland and will replace the core area of disturbance  A permit shall be applied for to remove or disturb protected plants. It is 39 MPRDA population of C. deltoidea subsp. recommended that protected plants in danger of becoming destroyed  Ecological silicicola (situated in an area of high during any of the planned activities be removed prior to the evaluation ecological sensitivity) along with a commencement of construction activities and translocated to suitable report number of other range-restricted habitat, or used during the rehabilitation phase. (mainly taxa with Afro-tropical  Consideration of an offset area situated in the same habitat with high Highland affinities such as the Buff- ecological sensitivity excluding Marakele National Park. streaked Chat, Oenanthe bifasciata)  A ‘Plant Rescue and Rehabilitation Plan’ shall be developed and effectively and k-selected species. In addition, be implemented. the proposed haul road traverses a

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Probability Magnitude Severity Probability Magnitude Severity large portion of Protea-dominated grassland, thereby amplifying edge and barrier effects caused by road transformation. Clearing of vegetation communities 5 5 H To conserve animals  Activities will be restricted to daylight hours to prevent any disturbance to 5 5 H  Section 28 will alter the current dynamics of fauna and prevent fauna in the area NEMA assemblage and result in a loss of disturbance of animal  Artificial lighting will be restricted to areas under construction  Section 37, 38, habitat. habitats.  Yellow sodium lights shall be used on site as they do not attract as many 39 MPRDA Any loss of habitat will lead to the invertebrates at night and will not disturb the wildlife;  Ecological displacement of fauna, the loss of  Fencing shall be friendly to faunal species allowing for movement between evaluation threatened species and increased areas. This can be achieved by applying culverts and an open mesh; report fragmentation of key functional habitat  As much of the natural vegetation as possible will be left intact in order to types. maintain ecological corridors for the movement of faunal species.  Should the faunal species need to be removed from the study area, a faunal capture and relocation plan shall be developed and implemented Potential impacts on the Kransberg 5 5 H To minimise any  A Cape Vulture study specific to the Kransberg colony shall be undertaken 5 5 H  Section 28 Cape Vulture colony situated 10 potential impacts on by a registered avifauna scientist with the relevant experience. The study NEMA kilometres north of the proposed mine. the Kransberg Cape shall assess the following activities/threats and recommendations shall be  Section 37, 38, Vulture colony. made as to possible mitigation of any negative impacts: 39 MPRDA  Air pollution – blast/beneficiation  Ecological  Noise/blast effects – potential impacts evaluation  Increased human activities/disturbance at colony report  Habitat destruction  Potential impact on foraging area  Interaction between Cape Vultures and mining/beneficiation activities which might affect foraging  Need for monitoring of vultures’ activities subsequent to initiation of mining activities Clearing of natural vegetation for the 5 5 H To conserve the  Natural areas that are transformed or degraded shall be kept to a 5 5 H  Section 28 development of the infrastructure critically endangered minimum. NEMA required for the mine may reduce the bats species that occur  Natural vegetation patches shall be managed to maximize the vegetative  Section 37, 38, forage habitat and food resource in the Gatkops cave. biodiversity value by, i.e. removal of alien vegetation, and reduction of 39 MPRDA (insects), used by the cave dwelling wood harvesting so that there is sufficient insect habitat in the degrading  Bat bat species. Reduced access to biomass. assessment natural foraging areas and food  A fire management plan shall be developed and effectively implemented. report resources (insects) will negatively The fire management plan shall aim to reduce the threat of intense fires impact the fitness and survival of the that could destroy natural woody vegetation, but also allow nutrients cave dwelling bat species. Increased accumulated in the dead biomass (e.g. phosphorus) to be released back stress to these species may also into the local environment. increase the risk of zoonotic disease outbreaks. The introduction of lighting along the 3 2 M To conserve the  Different species-specific responses of the cave dwelling bats to different 2 1 L  Section 28 road infrastructure and with the new critically endangered lighting types shall be identified. NEMA built infrastructure may reduce the bats species that occur  Insect response to different lighting types shall be identified  Section 37, 38, foraging area for those cave dwelling in the Gatkops cave.  Lighting shall be planned and implemented taking into account 39 MPRDA bat species that are deterred by requirements of each bats species. (i.e. lighting shall be avoided on busy  Bat artificial light. It could also reduce their roads to avoid collisions, regions of darkness shall be maximised) assessment prey base if insect densities drop in report darker areas, being attracted instead to artificial lights. For those species not deterred by lights, and if the lights attract insects they would prey on, then the lights could increase their foraging efficiency. However, this may only be for the short term, if the densities and

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Probability Magnitude Severity Probability Magnitude Severity composition of the insect communities themselves change in response to the introduction of lighting. The introduction of new infrastructure, 3 1 L To eliminate roost sites  The distance between the cave and the position of new buildings shall be 1 1 L  Section 28 in particular buildings, may create for other, more maximized. NEMA roost sites for other, more generalist, generalist, non-cave  New buildings shall be constructed to exclude bats.  Section 37, 38, non-cave roosting species of bat. roosting species of bat.  New infrastructure shall be monitored, on a monthly basis in the 39 MPRDA These non-cave roosting species may wet/summer months, looking for roosts of non-cave roosting bat species,  Bat then compete for food resources with and should these be found the bats should be excluded using ethically assessment the cave dwelling bat species. acceptable methods. report Water appears to be important for 3 1 L To conserve the  Provide two open sources of clean water within 1 km from the cave, but 1 1 L  Section 28 certain bat species, including the critically endangered away from roads with identified ‘bat road crossings’, and high vehicular NEMA Long-fingered Bat, and more so for bats species that occur traffic shall be provided.  Section 37, 38, lactating females in the period from in the Gatkops cave.  The new, open sources of water shall be a minimum surface area of 3 x 39 MPRDA late November to early January. 0.76 m, a minimum depth of 5 cm, and to avoid bats becoming trapped in  Bat Reduced access to water will have a the water source. assessment negative impact on recruitment;  The surface level of the water shall be kept as close to the level of the report reducing juvenile survival rates. The sides of the water containment structure increased stress may also increase the risk of zoonotic disease outbreaks. Potential destruction of the modern 5 4 H To prevent to loss of  A heritage management plan shall be drafted and implemented. The 5 3 H  Section 28 labourers’ graves associated with the heritage resources. heritage management plan shall include all the known and surviving NHA Randstephne dwelling as well as heritage sites and shall form part of the normal environmental audit  Heritage potential destruction of the grave of process. impact one J.H.T.O. PERREIRA located on  The grave of one J.H.T.O. PERREIRA shall be fenced-in, cleaned and assessment the banks of the Sondagsrivier close to managed. No demolition shall be considered. report the bridge.  Access shall be provided to descendants and family members to visit their grave sites.  The graves closely associated with the Randstephne homestead shall be advised relocated. A professional archaeologists that specialise in relocation of the graves shall be appointed to facilitate the relocation process.  All of these sites shall need to be submitted to second phase investigation and demolition permits applied for Potential destruction of the Gatkop 2 2 L To prevent to loss of  A well renowned anthropologist shall be appointed to investigate the 1 1 L  Section 28 cave site which appears to be of high cultural resources. significance of the cave site as well as the importance of the mountain NHA value to local, provincial and even names MELETSE, MAKAPANE AND GATKOP as this may hold the key to  Heritage national spiritual practitioners, the social ancestral importance of the area. impact generally known as SANGOMAS. The  Although the other Gatkop cave site will be sufficiently safe from any of the assessment cave is situated some four kilometres present proposed mining impact, it still lie inside the boundaries of the report SSW of the mining area area and over prospecting licence and therefore stay the responsibility of Aquila. The  Palaeontologic 600m lower in elevation. Any cave site shall also have to be documented and placed in the heritage al assessment unrecorded paleontological heritage management plan as described by the environmental Act. report resources here are therefore unlikely to be directly or indirectly affected by the proposed mining activities. Potential destruction of the cattle 2 2 L To prevent to loss of  The remaining cattle enclosures, precolonial mine, living enclosures and 1 1 L  Section 28 enclosures, precolonial mine, living cultural resources. smelting site shall be submitted for a second phase investigation and NHA enclosures and smelting site. The demolition permits will be required.  Heritage Heritage impact assessment described impact the sites individually to be of low assessment significance, however collectively they report are worthy of further investigation  Change to the pre-mining land use 4 4 H Investigate the possible  Correct rehabilitation will take place to obtain the agreed upon end land 3 3 M  Section 28 and land capability. post-mining land use use. NEMA and set objectives for  Section 37, 38,

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Probability Magnitude Severity Probability Magnitude Severity rehabilitation and 39 MPRDA closure Excavations for clearing and levelling 5 5 H To prevent the loss of Due to the nature and location of the proposed activity, very little mitigation During construction phase Mine engineer 5 5 H  Section 28 areas; and stockpiling soil and vegetation and if not measures can be implemented. Most of these measures are aimed at the SHE manager NEMA overburden would damage or remove possible minimise the activities and infrastructure to be established on the lower-lying portions ECO  Section 37, 38, vegetation and expose bare soil. This area of disturbance (Randstephne) of the project site. The following mitigation measures are Environmental 39 MPRDA impact is therefore in conflict with the To minimise the visual proposed: manager  Regulation 70 current sense of place of the impact of the open pit  Areas of disturbed shall be kept to a minimum. MPRDR i.t.o immediate area. as far as possible.  No clearing of land shall take place outside the demarcated footprint. MPRDA  A permanent vegetated buffer of at least 100m shall be maintained along  Visual impact the southern boundary of the project site – north of the P240 – to limit assessment direct views onto the project site. report Aspect³: Siltation and affected water run-off from construction areas

Construction (the Increase in erosion and run-off of 4 3 H To minimise  The mine shall comply with the requirements of GN 704, dated 1999, and During construction phase Mine engineer 3 2 M  Section 28 activity is not water into the non-perennial drainage sedimentation and implement the measures as contained in the Storm Water Management SHE manager NEMA applicable to the lines. This will result in an increase in improve water surface Plan, dated February 2014 (refer to Appendix 12) from construction ECO  Section 37, 38, operational and sedimentation in the perennial streams water quality through to decommissioning Phase. Environmental 39 MPRDA decommissioning into which they drain (Zandspruit &  Infrastructure will be constructed and maintained so as to comply with the manager  Aquatic study phases; however, Sondagsrivier). requirements contained in the National Water Act (NWA) (Act 36 of 1998). impacts will be  Silt traps in the forms of small dams or artificially created wetlands (with ongoing until indigenous species) shall be positioned in the non-perennial drainage lines after identified. rehabilitation and  The silt traps shall be located down towards the bottom of the drainage closure) line, where the gradient and velocity is reduced. The silt traps shall be positioned before the confluence with the perennial streams. Any excess water and sediment originating from the mining site and mining activities, shall be strictly monitored to ensure that high quality water is deposited into the streams.  Regular site inspections shall be conducted in order to verify the effectiveness of the water separation system and to identify possible erosion. Activities²: Opening of the pit Construction of maintenance facilities, waste management facilities, administrative buildings, water management facilities and supporting infrastructures. Construction of haul roads Deposition of mine residue material in designated areas. Aspect³: Establishment of alien vegetation. Construction (site Invasive plant might be established. 4 2 M To control and  Alien invasive species that were identified within the study area shall be Throughout LoM Mine engineer 3 1 L  Section 5 & 6 preparation is not This may lead to: eradicate all listed removed prior to ripening of seeds. By removing these species, the spread SHE manager of CARA applicable to the Displacement of indigenous invasive species by of seeds will be prevented into disturbed soils; which could thus have a ECO  Regulation 15 operational and vegetation; means of methods that positive impact on the surrounding natural vegetation. Environmental of CARR decommissioning Change in plant species composition; are appropriate for the  All alien seedlings and saplings shall be removed immediately for the manager  Regulation 61 phases; however, Change in vegetation composition and species concerned and duration of the mine operation and after closure. & 62 of impacts for site structure; the environment in  Manual / mechanical removal is preferred to chemical control. MPRDR preparation and Competition for sunlight and ‘living which it occurs.  An alien invasive eradication plan shall be compiled and implemented on  Guidelines for mine residue will space’ will increase between site. the be ongoing until indigenous and alien species; rehabilitation of after Competition for water and minerals mined land rehabilitation and between alien and indigenous  Ecological closure) vegetation; evaluation Change in plant-pollinator report composition;  Alien invasive Loss of habitat; eradication Change in flammability of existing plan

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Probability Magnitude Severity Probability Magnitude Severity vegetation structure – pending the introduction of the alien species; The spread of alien vegetation in areas previously free from such species causing a change in biodiversity. Aspect: Construction of surface infrastructure Construction (site The construction of infrastructure will 2 2 L To minimize the extent  No construction of any water management measures shall be undertaken During construction phase. Mine engineer 2 2 L  Section 28 preparation is not cause a very small reduction in of disturbance of the with potentially hazardous material. SHE manager NEMA applicable to the recharge to the aquifer system due to aquifer,  All dams shall be constructed to comply with the relevant DWA ECO  Section 37, 38, operational and the compaction of the surface of the requirements in an effort to minimize the seepage of poor quality leachate Environmental 39 MPRDA decommissioning roads and foundation layers. No To limit degeneration of  Clean surface water shall not come into contact with dirty water. manager  Regulation 70 phases; however, adverse impact is foreseen on groundwater quality. MPRDR i.t.o impacts for site groundwater quality since soil and rock MPRDA preparation and material of the area is chemically inert  Geohydrologic mine residue will al investigation be ongoing until report after rehabilitation and closure) Aspect³: Changes to the community composition Construction (site The linear gap created between the 5 5 H To conserve animals  Activities will be restricted to daylight hours to prevent any disturbance to During construction phase. Mine engineer 5 5 H  Section 28 preparation is not road servitude and neighbouring and prevent fauna in the area SHE manager NEMA applicable to the natural vegetation introduces a new disturbance of animal  Artificial lighting will be restricted to areas under construction ECO  Section 37, 38, operational and microclimate, which differ in physical habitats.  Yellow sodium lights shall be used on site as they do not attract as many Environmental 39 MPRDA decommissioning conditions (e.g. temperature and invertebrates at night and will not disturb the wildlife; manager  Ecological phases; however, humidity) to the natural vegetation.  Fencing shall be friendly to faunal species allowing for movement between evaluation impacts for site This newly created habitat often areas. This can be achieved by applying culverts and an open mesh; report preparation and provides “nurseries” for edge species  As much of the natural vegetation as possible will be left intact in order to mine residue will that are generally absent from the maintain ecological corridors for the movement of faunal species. be ongoing until natural floristic communities. Most of  Should the faunal species need to be removed from the study area, a after these species are r-selected or faunal capture and relocation plan shall be developed and implemented rehabilitation and atypical in the region, although having closure) the ability to outcompete other plant species that occur naturally in the surrounding landscape. Activity²: Topsoil temporary storage and stockpiling from the constructed areas. Aspect³: Incorrect placement of topsoil stockpiles. Construction and Erosion of stockpiles leading to 3 2 M Establish and  A topsoil management plan shall be developed. During construction and Mine engineer 3 1 L  Section 28 operational reduction of fertility of soil. implement an  Topsoil stockpiles shall be placed on a free draining location to limit erosion operational phase. SHE manager NEMA Leaching of minerals due to 3 2 M effective soil loss and waterlogging; ECO 3 1 L  Section 37, 38, inadequate maintenance of stockpile, conservation and  Topsoil stockpiles shall be vegetated to avoid wind and water erosion loss; Environmental 39 MPRDA resulting in infertile soils. management plan  Looseness of topsoil stockpiled soil shall be maintained by fertilising and manager  Regulation 70 seeding the soil by hand; MPRDR i.t.o  Topsoil stockpiles shall be monitored for fertility by sampling and testing; MPRDA  Topsoil and organic surface material such as root mats shall be stockpiled separately from overburden and return it to the surface of the restored site where feasible.

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7.1.2 Operational (Mining activities) phase

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Activities²: Drilling and blasting of rock Conventional drilling estimates are as follows: 130 holes per day Distance between holes 5m Depth of holes 10 m Area drilled per day 4,000 m2 Aspects³: Ground Vibration and human perception Vibration impact on national and provincial road Vibration will upset adjacent communities Cracking of houses and consequent devaluation Impact of fly rock Noxious fumes shall be generated Construction, Ground vibration and air blast 3 1 L To reduce dust  A 500m safe distance shall be maintained from any blast done. This may Throughout LoM Mine engineer 2 1 L  Section 5 & 11 operational generally upset communities or generation be greater but not less. SHE manager MHSA people living in the vicinity of mining To limit public  All persons within 500m from a blast shall be cleared and where ECO  Section 28, 32, operations. There are farm steads, exposure to necessary evacuation shall be conducted with all the required pre-blast Environmental 33, 63 houses and farm worker’s housing unacceptable health negotiations. manager NEMAQA that are within the evaluated area of risks.  There are no public roads close to the project area that are of concern  Regulation 64 influence. To prevent, cease, with regards to ground vibration and fly rock. Farm roads that are present MPRDR i.t.o The influence of ground vibration on 3 1 L modify or control any and not identified in this report shall be monitored and considered for 2 1 L MPRDA tarred roads are expected when levels act or process causing closing during blasting operations.  HPAAQMP is in the order of 150 mm/s and pollution;  A blast monitoring program shall be developed and effectively  NFAQM greater. Or when there is actual To remedy the effects implemented.  SANS 1929 movement of ground when blasting is of pollution;  There are no private structures closer than 2000m from the proposed pit  Waterberg/Boj done to close to the road or To eliminate any area. It is however recommended to consider the current relationships anala Priority subsidence is caused due to blasting source of the pollution; with I&AP whether a photographic survey is necessary or not. It may be area To contain or prevent operations. The only time damage worthwhile to consider a limited survey prior to blasting operations.  Basic the movement of can be induced is when blasting is  Standard blasting times shall be set. atmospheric pollutants. done next to the road and there is  Blasting notice boards shall be put up at various entrance routes that will impact movement of ground. Fly rock will inform the people of dates of blasting and blast. assessment have greater influence on the road as  A further consideration of blasting times is when weather conditions report damage from falling debris may could influence the effects yielded by blasting operations. Recommended  Blasting & impact on the road surface if no is not to blast too early in the morning when it is still cool or the possibility Vibration report control on fly rock is considered. The of inversion is present or too late in the afternoon in winter as well.  Ecological P240 is the nearest road to the project  No blasting shall be undertaken in fog or low overcast clouds. evaluation area. The road is located  No blasting shall be undertaken in the dark. report approximately 2.1km south of the  Prevail from blasting when wind is blowing strongly in the direction of an mining area. Expected ground outside receptor. vibration levels at the P240 below the  Third party consultation and monitoring should be considered for all levels of concern. Possible fly rock is ground vibration and air blast monitoring work. This will bring about also not considered problematic as unbiased evaluation of levels and influence from an independent group. distance between mining area and Monitoring could be done using permanent installed stations. Audit road is further than potential fly rock functions may also be conducted to assist the mine in maintaining a high impact distances. level of performance with regards to blast results and the effects related Fly rock related effects might cause 3 1 L 2 1 L to blasting operations. injury or death to faunal species. Due

to both the noise generated by blasting as well as the direct physical danger, displacement of species from the risk areas may occur, causing significant ecological effects for the adjacent properties. In addition, the

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boundary fence of the mine may be compromised by the blasted rock, allowing for faunal species, especially mammals to escape from the reserves and/or allow outside parties to enter the properties containing species of significant value (rhinoceros and disease free buffalo). The sensitive hearing of most 3 1 L 2 1 L mammals is impaired by enhanced noise levels resulting in increased vulnerability to predation and/or emigration from the affected area. Trampling of young may occur in response to blasting effects. Black, white rhinoceros and buffalo may come into direct conflict with the mine, due to the proximity of essential water sources or home ranges to the blasting area. The most significant Negative effect will be on reproductive success of the species as well as stress related mortality. Permanent displacement of local populations of these species may occur, further disruption the husbandry/ wildlife management status quo of the adjacent lands The effects of ground vibration and air 3 1 L 2 2 L blast will have an influence on people. These effects tend to create noises in structures in various forms and people react to these occurrences even at low levels. People will experience ground vibration at very low levels. These levels are below damage capability for most structures. Ground vibrations will be mostly 3 1 L 2 2 L responsible for cracks in structures if high enough. Mining operations may not have an impact in the change to the status quo of any property. There are no known formal structures found within 2000m range from the mining area Construction, Air pollution, dust fall-out nuisance 5 5 H To reduce dust  A vegetated buffer of at least 100m along the road boundary shall be Throughout LoM Mine engineer 3 3 M  Section 5 & 11 operational and impact on surrounding generation maintained to act as bio-filters. Continuously monitor PM10 SHE manager MHSA agricultural, game farming (Breeding To limit public  Such a bio-filter shall be maintained along the entire length of the gravel and PM2.5 ECO  Section 28, 32, and scarce game), eco-tourism areas exposure to road en route to Thabazimbi to prevent dust plumes spreading onto Monthly monitoring dust fall- Environmental 33, 63 through total suspended particulates. unacceptable health farming activities neighbouring the road. out manager NEMAQA It is accepted that game and cattle will risks.  Approved dust suppression techniques shall be implemented to reduce  Regulation 64 be present to some extent in the area. and control dust as and when required. MPRDR i.t.o The presence is not specifically  Consider fitting drills with dust collection systems. MPRDA known and at what specific distance  A fugitive emission monitoring plan which consists of continuous  HPAAQMP from the mining area monitoring of ambient PM10 and PM2.5 and dust fall out monitoring of  NFAQM Construction, Health hazard to community and 4 4 H 4 4 H

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operational livestock from PM10 TSP will be implemented.  SANS 1929  Monitoring will take place prior to establishment of the mining operations  Declaration of as well as throughout the LoM, to collect baseline information and record the Highveld any increase as a direct result of the mining operations; Priority area  The PM10 and 2.5 monitoring station will also record basic hourly  Air quality average meteorological measurements of the following parameters: specialist  Wind direction assessment  Wind speed  Temperature  Rainfall  Solar radiation/Surface heat flux  Dust deposition will be measured according to the Society for Testing and Materials standard 1739- 98 method recommended in SANS 1929- 2004. This involves exposure of a standard bucket for a month, with weighing and chemical analysis of the dust collected. Weighing and chemical analysis is to be done by a suitable offsite or onsite laboratory; and  Dust buckets as well as PM10 and 2.5 monitoring stations will initially be placed as per the Atmospheric Impact Report, based on simulated impacts and prevalent wind fields recorded in the area. The fugitive emission monitoring plan and subsequent placement of dust buckets and PM10 and 2.5 monitoring stations should be revised after the first monitoring year.  Background ambient air quality will be requested from the South African Air Quality Information System (SAAQIS) to be used in the revision of the fugitive emission monitoring plan as well as the determination of the mining operations cumulative impact contribution to the Highveld Airshed Priority area.  The authorities will be informed if the incidence of respiratory disease in the area increases.  Should any out-of-the-ordinary risks to health and safety arise it will be widely communicated to the surrounding community, including employees, farmers and all other stakeholders. Decommissioning Not applicable during decommissioning. Activities²: Removal of iron ore resource, and associated rock material. The planned production rate is 4,100,000 tonnes per annum of Run of Mine (ROM) material from the open pit with an objective of 4,000,000 tonnes saleable product. The current Life of Mine (LOM) is set at 18 years but with ongoing exploration this may well be extended. Aspect³: Removed ore resource, and associated rock material as waste rock or product. This could be increased due to incorrect mining plan or not following the mining plan. Operational and The loss of geology. 5 4 H To prevent  Mining practices will be applied according to approved mining plan During mining activities - Mine manager 5 4 H  Section 25(c) decommissioning Mining will cease during the unnecessary loss of depicting geological features that could affect mining to reduce waste operational phase until Environmental MPRDA decommissioning phase, however, geology. rock. backfilling of open pit is manager the loss of geology will be ongoing  Effective implementation of the mining plan. completed. throughout the decommissioning  Concurrent backfilling of open pit shall take place. phase until concurrent backfilling is  Refer to backfilling of open pit in rehabilitation section. completed. This activity will not take place during the construction phase. Activities²: Deposition of mine residues (i.e. waste rock and overburden) and plant residues (i.e. discard) on designated areas. The discard is to be deposited on a discard dump proposed to the northeast of the beneficiation plant. The amount of overburden and waste rock to be removed is expected to be in the vicinity of 40.3 million tonnes per annum, with a stripping ratio of 9.8. The life of mine is estimated at 18 years. Aspects³: Deposition of mine residues (i.e. waste rock and overburden) and plant residues ( i.e. discard) on designated areas non-perennial drainage lines Operational and Altering, diverting or impeding surface 5 3 H To improve the quality  Energy dissipaters shall be constructed on the access ramp on the Throughout LoM Mine engineer 5 3 H  Stormwater decommissioning water flow patterns. According to the and flow of the surface Waste Rock Dump (WRD) to divert runoff and limit erosion SHE manager management current designs, the discard and water  Effective silt traps shall be constructed at the outlets of the energy ECO plan waste rock dump will be constructed dissipaters to limit siltation of natural drainage lines. Environmental  Regulation 6 & over and next to non-perennial  Runoff infiltrating into the waste rock shall be monitored for the pollution manager 7 GN704 i.t.o drainage lines originating from the

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hilly areas in the north-western parts potential. NWA of Donkerpoort. General drainage  A berm/diversion channel shall be constructed to divert clean runoff past  Section 19 from the area flows in a southern the dump towards the natural drainage line. This activity shall form part NWA direction towards the Sand River that of the water use license application.  Geohydrologic drains into the Crocodile River.  al investigation Nitrate enriched seepage may 3 3 M To reduce the change  Seepage or run-off from all rock dumps or stockpiles shall be contained During mining activities - 2 2 L originate from the waste rock dump in groundwater quality or diverted to the dirty water containment system (PCD). operational phase until during periods of rainfall resulting in backfilling of open pit is potential groundwater contamination completed. Groundwater quality monitoring to take place on quarterly basis. Activities²: Removal of iron ore resource, and associated rock material. Deposition of mine residues (i.e. waste rock and overburden) and plant residues ( i.e. discard) on designated areas Deposition of RoM.. The RoM will be deposited in the south-western corner of the site. There is no information regarding the size of the RoM stockpile. Aspects³: Change in topography due to removed ore resource, and associated rock material as mine residue or product. This could be increased due to incorrect mining plan or not following the mining plan. The total removal of ore material will lead to a depression in the topography. Change in topography as a result of the deposition of mine residues (i.e. waste rock and overburden) and plant residues (i.e. discard) on designated areas. The waste rock. Shall be utilised to backfill the mined out areas. Only about 10 million m³ of the mined out area will be backfilled in the end. The rest will remain a void on the mountain top. It is anticipated that concurrent backfilling will not begin immediately but will only be conducted once the mining faces have advanced sufficiently. This will most likely be in year 12. Change in topography as a result of the deposition of RoM Construction Visual impact due to change in 5 5 H To minimise the visual  As a result of the nature and location of the proposed activity, very little During mining activities - Mine engineer 5 3 H  Visual impact operational and topography from the deposition of impact of the mine mitigation measures could be implemented. Most of these measures are construction phase until SHE manager assessment decommissioning mine and plant residues. residue dumps and the aimed at the activities and infrastructure to be established on the lower- backfilling of open pit is ECO The proposed site is visible from the open pit as far as lying portions of the project site. The following mitigation measures are completed. Environmental following viewsheds: possible proposed: manager The D2450 road on the west of the  Disturbed areas shall be kept to a minimum. project site,  A permanent vegetated buffer of at least 100m shall be maintained along The entrance to the Motlapi the southern boundary of the project site – north of the P240 – to limit Wildsplaas direct views onto the project site. Towards the main gate of the  Visual screening berms, other structures, or trees (where possible) will Marakele National Park, be used in areas where there are sensitive receptors. Entrance gate to the Meletse Private  Only indigenous plant species to be introduced and planted. All waste Game Reserve, rock areas must be vegetated with a suitable ground cover immediately SAPS Operational and Tactical after or contemporaneously with disturbance activities to prevent erosion Academy off the P240, and mud slides. Along the D794 as it crosses the Marakele National Park to the north. The visual impact will be ongoing throughout the decommissioning phase and closure phase. Construction and Visual impact due to change in 5 5 H 5 5 H operational topography from the RoM. There is no information regarding height specifications of the stockpiles. Visual impact due to change in topography from the RoM will cease in the decommissioning phase. Operational and The removal of iron ore resource will 4 2 M 2 2 L decommissioning have a visual impact due to depression in topography. Mining will cease during the decommissioning phase, however, the visual impact will be ongoing throughout the decommissioning

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phase until concurrent backfilling is completed. Aspects³: Inadequate stormwater management systems around the mine and plant residue stockpiles and/or RoM. Operational and The change in topography from 3 3 M To minimise the  The mine shall comply with the requirements of GN 704, dated 1999, During mining activities - Mine engineer 3 2 M  Regulation 6 & decommissioning removal of iron ore will result in a disturbance of the and implement the measures as contained in the Storm Water operational phase until SHE manager 7 GN704 i.t.o change in surface water flow patterns natural flow of Management Plan, dated February 2014 (refer to Appendix E6) from backfilling of open pit is ECO NWA and loss of surface water to the open watercourse. construction through to decommissioning Phase. completed. Environmental  Section 19 pit. This water will be removed as  Infrastructure will be constructed and maintained so as to comply with manager NWA affected water. the requirements contained in the National Water Act (NWA) (Act 36 of  Section 28 Mining will cease during the 1998) and the GN704, dated June 1999. This includes the following NEMA decommissioning phase, however, requirements:  Section 37, 38, the change in surface water flow  Necessary erosion control measures shall be constructed to control 39 MPRDA patterns and loss of surface water will surface water run-off from the mine and plant residue stockpiles and/or  Regulation 63 be ongoing throughout the RoM. & 68 MPRDR decommissioning phase until  Regular site inspections shall be conducted in order to verify the i.t.o MPRDA concurrent backfilling is completed. effectiveness of the water separation system and to identify possible  Stormwater There will also be a permanent void erosion. management after concurrent backfilling is  Closure objectives will include strategies to manage the open void at plan completed. closure. The removal of iron ore will not take  A surface water monitoring programme shall be developed and place during the construction phase. effectively implemented. Construction, The change in topography from the 3 3 M 3 2 M operational deposition of mine residue will result in a change in surface water flow patterns. Operational Changes in surface water flow from 3 3 M 3 2 M RoM will take place in the operational phase. There will be no RoM during decommissioning phase. The deposition of RoM will not take place during construction phase. Surface water pollution due to run-off 3 3 M 3 2 M from mine residue stockpiles will take place in the operational phase Aspects³: Foundation and/or slope instability of stockpiles. There is no CoP currently in place to assess the environmental and safety classification of the mine residue deposits Construction, Safety hazard to community will be 2 4 M To maintain and use  A COP for the mine residue deposits shall be compiled, in accordance During mining activities - Mine engineer 2 3 L  Regulation 73 operational, and ongoing until backfilling is completed. the stockpiles so that with the requirements as per Regulation 73 of the MRDA and the Mine construction phase until SHE manager MPRDR i.t.o decommissioning the water or waste Health and Safety Act. backfilling of open pit is ECO MPRDA therein, or falling  Safety aspects shall be taken into consideration during the initial stages completed. Environmental  Section 5 & 11 therein, will not result of material deposition planning. manager of the MHSA in the failure thereof or  Regular site inspections shall be conducted in order to verify the correct impair the stability deposition methods / phases as well as in relation to the approved thereof. footprint area.  Strict access control shall be implemented in the vicinity of the stockpiles. Activities²: Exposure of underlying geology. Aspects³: Contact of groundwater with underlying geology. Recharge of groundwater due to mine residue. Recharge will be increased along porous groundwater zones due to an increased head of open water collecting the pit. The creation of stockpiles will result in the development of mounding of water within them. This will result in infiltration of mounding water into the phreatic zone. Seepage from RoM stockpile. Operational and Exposure of geological strata and 2 2 L To prevent, cease,  Minimise surface area where operations would contaminate water During mining activities - Mine engineer 2 2 L  Regulation 6 & decommissioning reactions resulting in potential impacts modify or control any (smaller disturbed areas mean smaller manageable volumes). operational phase until SHE manager 7 GN704 i.t.o

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on the quality of groundwater. act or process causing  Continuous rehabilitation will form part of the active mining progress backfilling of open pit is ECO NWA Groundwater quality impacts are pollution; which will include backfilling and capping of the backfilled area. completed. Environmental  Section 19 caused by seepage of effluent or To remedy the effects  Closure objectives will include strategies to manage the open void at Groundwater quality manager NWA contaminated water or through of pollution; closure. monitoring to take place on  Section 28 formation of poor quality leachate to To eliminate any  Sufficient lined storage space will be available in order that no stockpiling quarterly basis. NEMA the underlying aquifer. Very little source of the pollution; of iron ore will take place on natural soils.  Section 37, 38, impact is expected since no water To contain or prevent  Roll-over practices will be applied, whereby backfilling of mine residue 39 MPRDA seepage or abstraction is involved the movement of will take place as per rehabilitation plan.  Regulation 63, that could affect water levels, and no pollutants.  Groundwater quality monitoring will take place within a 1km radius of any 68, 69 & 73 leachate or contaminated seepage is To prevent pollution of mining activities. MPRDR i.t.o involved that may affect groundwater water used by  Alternative water supply will be provided to external users in the event MPRDA quality. community. that their groundwater resources have been detrimentally affected.  Geohydrologic al investigation The final pit floor elevation should be report in excess of 100 meters above the  Groundwater local groundwater level elevation. monitoring results Activities²: Removal of iron ore resource, and associated rock material. The planned production rate is 4,100,000 tonnes per annum of Run of Mine (ROM) material from the open pit with an objective of 4,000,000 tonnes saleable product. The current Life of Mine (LOM) is set at 18 years but with on-going exploration this may well be extended. Aspects³: Pit instability and void Construction, Safety hazard to community and 2 5 H To prevent hazards to  The pit stability shall be monitored. Throughout LoM Mine engineer 1 5 M  Regulation 73 operational and natural occurring game. community, natural  Berms, fencing and signs shall be erected around the pit. Pit stability monitoring will be SHE manager MPRDR i.t.o decommissioning Damage to infrastructure. 2 4 M occurring game and  Additional management measures shall be included in the CoP. assessed as part of CoP ECO 1 3 L MPRDA damage to Environmental  Section 5 & 11 infrastructures manager of the MHSA Activities²: Progressive mining of the open cast pit. Aspects³: Accumulation of rainwater in the open cast pit. Operational Contamination of groundwater from 3 1 M To prevent  Dewatering of the pit will take place as soon as water ingression takes During mining activities - Mine engineer 2 1 L  Regulation 7 seepage of in-pit water. groundwater place. operational phase until SHE manager GN704 i.t.o contamination  Compliance to conditions as set out in the WUL. backfilling of open pit is ECO NWA  Rainwater pumped from the open pit is deemed affected will be completed. Environmental  Section 28 contained within the PCD. Groundwater levels monitoring manager NEMA  Water pumped from the mine will be monitored by means of a water to take place on monthly basis.  Section 37, 38, balance. 39 MPRDA  The mine shall comply with the requirements of GN 704, dated 1999,  Section 19 and implement the measures as contained in the Storm Water NWA Management Plan, dated February 2014.  Regulation 68 MPRDR i.t.o MPRDA  Geohydrologic al investigation  Stormwater management plan  WUL Reduction in catchment yield 3 1 M To minimise the  Construct berms of channels around the pit. During mining activities - Mine engineer 1 1 L  Regulation 7 reduction of catchment  Water pumped by from mine will be monitored by means of a water operational phase until SHE manager GN704 i.t.o yield. balance. backfilling of open pit is ECO NWA  Implement water monitoring up-stream and down-stream from the completed. Environmental  Section 28 proposed mine. Groundwater levels monitoring manager NEMA to take place on monthly basis.  Section 37, 38, 39 MPRDA  Section 19

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NWA  Regulation 68 MPRDR i.t.o MPRDA  Geohydrologic al unvestigation  Stormwater management plan  WUL Activities²: Primary, Secondary and tertiary crushing: The proposed iron ore facility will consist of a crushing and screening plant for direct shipping of ore, and a dense medium separation (DMS) plant for material that needs to be beneficiated to comply with market specification. The Run of Mine (ROM) material undergoes primary, secondary and tertiary crushing. Material handling operations includes the following activities: The transfer of material by means of tipping, loading and off-loading Offloading and loading of ROM at ropeway Offloading of ROM at crusher plant Crushing of the ROM material Offloading of crushed ore to stockpiles Loading of crushed ore to trucks Aspects³: Dust fallout and inhalable PM emissions shall be generated due to crushing of ore products. Fugitive dust emissions shall be generated from materials handling operations. Crusher generates localised nuisance noise Operational Potential dust pollution 4 4 H Minimise the  Crushing operations as well as storage piles where tipping occurs shall Throughout LoM Mine engineer 3 2 M  Section 5 & 11 generation of dust be enclosed as far as possible to reduce dust Continuously monitor PM10 SHE manager MHSA pollution.  Chemical suppressants or water sprays on the primary crusher and and PM2.5 ECO  Section 28, 32, drydust extraction units with wet scrubbers on the secondary and tertiary Monthly monitoring dust fall- Environmental 33, 63 crushers and screens shall be implemented to reduce cumulative dust out manager NEMAQA impacts.  Regulation 64  A fugitive emission monitoring plan which consists of continuous MPRDR i.t.o monitoring of ambient PM10 and PM2.5 and dust fall out monitoring of MPRDA TSP will be implemented.  HPAAQMP  The PM10 and 2.5 monitoring station shall also record basic hourly  NFAQM average meteorological measurements of the following parameters:  SANS 1929  Wind direction  Declaration of  Wind speed the Highveld  Temperature Priority area  Rainfall  Air quality  Solar radiation/Surface heat flux specialist  Dust deposition will be measured according to the Society for Testing assessment andMaterials standard 1739- 98 method recommended in SANS 1929- 2004. This involves exposure of a standard bucket for a month, with weighing and chemical analysis of the dust collected. Weighing and chemical analysis is to be done by a suitable offsite or onsite laboratory; and  Dust buckets as well as PM10 and 2.5 monitoring stations will initially be placed as per the Atmospheric Impact Report, based on simulated impacts and prevalent wind fields recorded in the area. The fugitive emission monitoring plan and subsequent placement of dust buckets and PM10 and 2.5 monitoring stations should be revised after the first monitoring year.  Background ambient air quality will be requested from the South African Air Quality Information System (SAAQIS) to be used in the revision of the

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fugitive emission monitoring plan as well as the determination of the mining operations cumulative impact contribution to the Highveld Airshed Priority area.  The authorities will be informed if the incidence of respiratory disease in the area increases.  Should any out-of-the-ordinary risks to health and safety arise it will be widely communicated to the surrounding community, including employees, farmers and all other stakeholders. Noise pollution from plant activities 4 4 H To ensure that the  The mining workers shall be protected through standards and Throughout LoM 2 1 L  Regulation 66 impacting on mine workers and mine remains procedures and the personal exposure levels shall d be monitored as MPRDR i.t.o surrounding communities. According compliant with the Air part of the legal requirements of Section 12 of the MHSA. MPRDA to the environmental noise survey quality legislation.  Plant equipment shall be effectively maintained report, noise generation will have no  Hearing conservation programme as per DMR guidelines on Noise harmful impact on any farming or Control shall be implemented. other form of community, based on  High noise areas shall be zoned the fact that the activities are confined  Approved hearing protection devices shall be utilised by mine workers. to the valley on the top of the  Complaints register shall be made available for recording of complaints mountain. relating to noise. Activity²: Dense Medium Separation Water recovery Aspect³: Inadequate process water recovery within the water reticulation system for reuse Operational Loss of water resource 3 3 M To prevent loss of  Reclamation and recycling of process water shall be undertaken as far Throughout LoM Mine engineer 3 1 L  Section 19 water resource as possible. SHE manager NWA To ensure that the  The water balance for the mine shall be refined on an ongoing basis ECO  Section 28 mine’s use of water during the LoM. Environmental NEMA does not impact on the  An annual report on water balance shall be submitted to DWA. This will manager  Section 37, 38, availability of water to provide information on the status of the water balance in the wet season 39 MPRDA lawful water users. and the dry season and under conditions of extreme rainfall. Activity²: Pumping and storage of affected water to be used in the process plant and final disposal in the PCD. The PCD will not be used during decommissioning phase. Aspects³: Spillages due to inadequate capacity to contain affected water. Seepage due to incorrect sealing/lining of dam. Spillages from damaged pipelines due to lack of maintenance. Operational Soil pollution form affected water. 2 3 M To prevent, cease,  The dam capacity shall allow for normal operation and be maintained During mining activities - Mine engineer 1 3 L  Regulation 6 & Pollution of surface water. This can be 2 3 M modify or control any with a freeboard of 0.8m plus a 1:100 year rainfall event. operational phase until SHE manager 1 3 L 7 GN704 i.t.o through direct pollution of surface act or process causing  The water balance shall be updated to monitor the quantity of water to be backfilling of open pit is ECO NWA water during rain events or surface pollution; pumped to the dam. completed. Environmental  Section 19 water run-off from polluted soils. To remedy the effects  The dam shall be maintained (reeds removed and de-silted – when and Groundwater quality manager NWA Groundwater pollution from seepage 3 3 M of pollution; where applicable). monitoring to take place on 2 2 L  Section 28 of PCD dam. To eliminate any  The dam shall be sealed adequately during construction. quarterly basis. NEMA source of the pollution;  The PCD shall be lined to prevent the seepage of poor quality leachate. Surface water quality  Section 37, 38, To contain or prevent Care shall be taken to ensure that the lining of the dam is not damaged monitoring to take place on 39 MPRDA the movement of when de-silting takes place. Should this occur, the extent of the damage monthly basis.  Regulation 63, pollutants. will be determined and damaged areas will be repaired immediately. 68, 69 & 73 To prevent pollution of  All pipes shall be kept in a good condition to prevent leaks. MPRDR i.t.o water used by  All leaks shall be reported and remediate immediately. MPRDA community.  All pipelines that cannot be repaired shall be replaced.  Geohydrologic

 All water system will be kept free from any matter or obstruction, which al investigation may affect the efficiency thereof. report  Flow-meters shall be installed, maintained and replaced on and on-going  Groundwater basis to allow for an accurate water balance compilation. monitoring  Trenches shall be inspected to ensure that it has adequate capacity for results

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water flow.  Clean surface water shall not come into contact with dirty water or bearing material

7.1.3 Decommissioning phase

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Activities²: Backfilling of overburden. These backfilling activities will be ongoing concurrently throughout LoM (backfilling will only take place from year 12). Aspect³: Seepage of affected water into the saturated aquifer Decommissioning Groundwater pollution. This impact will 4 3 M To prevent, cease,  Establishment of a network of monitoring boreholes placed in the mining During decommissioning Rehabilitation expert 3 2 M  Section 28 be insignificant due to the pit being modify or control any area as well as upslope and downslope is required as part of the phase and after closure. ECO NEMA located in excess of 500m above the act or process causing monitoring programme that will be reported to DWA and DMR. Environmental  Section 37, 38, groundwater level. pollution; manager 39 MPRDA Polluted groundwater could potentially 4 3 M To remedy the effects 3 2 M  Regulation 63, seep to surface and pollute surface of pollution; 68 & 73 water courses. To eliminate any source MPRDR i.t.o Polluted surface could potentially 4 3 M of the pollution; 3 2 M MPRDA pollute and damage sensitive To contain or prevent  Section 19 vegetation. the movement of NWA pollutants.  Regulation 7 Groundwater flow paths will be 4 3 M To prevent the During decommissioning Rehabilitation expert 3 2 M GN 704 (1999) disturbed through physical disruption disturbance of phase and after closure. ECO i.t.o NWA or saturation of backfilled material groundwater flow Environmental  Section 10 ECA along path of opencast pit manager  Geo- development. hydrological study Activity²: Dismantling of Infrastructure (i.e. administrative buildings, waste management facilities, supporting infrastructures, maintenance facilities, water management facilities - pollution control dams) Aspect³: Ineffective removal of infrastructure Decommissioning The inadequate or no dismantling of 3 3 M To minimise the visual  Infrastructure will either be used or removed during decommissioning. During infrastructure removal ECO 3 3 M  Guidelines for structures could result in a permanent impact of the plant and  Removal of concrete foundations will be done to 1m below natural ground Environmental the visual impact. associated level manager rehabilitation of infrastructure on the  Planned demolition of concrete foundations and removal of contaminated mined land surrounding area soil will take place in a phased and structure manner as to prevent ‘cross- contamination’ (i.e. contamination of clean areas)  Identification of extent of surface contamination (concrete and soil) and

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demarcation of such will be done. Aspect³: Incorrect profiling of the rehabilitation areas will result in the deviation from the natural topography Decommissioning Visual aspect 4 4 H To minimise the visual  As a result of the nature and location of the proposed activity, very little During decommissioning and ECO 4 4 H  Visual impact impact of the WRD on mitigation can be implemented. The following mitigation measures are post closure phase Environmental assessment the surrounding area. proposed manager  The applicant should be accessible to the public when concerns, complaints or questions arise.  All waste rock shall be vegetated with a suitable ground cover immediately after disturbance activities has taken place to prevent erosion and mud slides  Monitoring of the waste rock dump’s rehabilitation success shall take place for at least a 5 year period and will include a follow up corrective action plan. Activity²: Rehabilitation Activities: Ripping of haul, internal mine roads and compacted areas Sloping of waste rock, discard, overburden dumps and areas where infrastructure was located. Topsoil replacement, Re-vegetation of rehabilitation areas Control of invader plants species Aspect³: The ripping of compacted areas during rehabilitation will result in dust generation. Compacting of rehabilitated areas Erosion of rehabilitation areas Decommissioning Air pollution 3 3 M To ensure that the  Ripped up areas shall be re-vegetated as soon as is practically possible to During decommissioning ECO 3 3 M  Section 28, 32, applicant remains reduce the amount of open areas exposed to wind erosion. Environmental 33, 63 compliant with air  If dust pollution levels exceed the relevant requirements as described manager NEMAQA quality legislation. under the NEMAQA, dust shall be managed by means of a water bowser  NFAQM To reduce dust and the implementation of lower speed limits.  SANS 1929 generation  Waterberg/Boja To limit public exposure nala Priority to unacceptable health area risks. Loss of topsoil 3 3 M To conserve topsoil  A detailed plan with regards to rehabilitation of disturbed areas shall be 3 2 M resources developed by a rehabilitation specialist registered at the South African Council for Natural Scientific Professions. The rehabilitation plan shall include the following, including the following:  Soil sourcing and usage,  Vegetation establishment,  Most suitable plant and seed mixtures to be utilised  Sloping methods  End land use requirements.  Long-term erosion prevention  Confirmatory monitoring  Security measures  Rehabilitation will be undertaken to the natural angle of repose.  Compacted areas shall be ripped and seeded (following recommendation made by a rehabilitation specialist) improving the soil structure and functioning.  Compaction shall be minimised by using the right equipment. Too heavy machinery must not be used to replace the soil. Rather use a dozer than a grader.  Soils shall also only be moved when it is dry to minimise soil compaction.  Soil on bare patches shall be loosened by using a tooth implement with re- sowing.

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 Ripping must penetrate through soil into the underlying overburden materials in order to ensure free drainage and to ensure root penetration.  Vehicle access onto the rehabilitated area shall be limited in order to avoid compaction. Rehabilitated areas shall be disturbed as little as possible, primarily by rehabilitation and maintenance equipment only. Vehicles speeds should be maintained to reduce the duration of applied pressure.  Topsoil shall be placed only on the top of the waste rock dump.  Mulching and hydro-seeding shall be done on the long slopes. Aspect³: Incorrect sloping of the waste rock dump, discard and overburden dump Decommissioning Instability of the waste rock dump 4 3 H To minimise the  A detailed rehabilitation and decommissioning plan shall be developed. During decommissioning ECO 3 3 M  Guidelines for resulting in mud slides and erosion instability of the waste The following mitigation measures but not limited to shall be implemented. Environmental the rock dumps.  WRDs shall be rehabilitated by reducing the top portion of the WRD slope manager rehabilitation of (slope at 35) to between 18° and 24° by moving the crest of the WRD mined land back towards the mountain. Moonscapes shall then be created on these  Stormwater flatter slopes with a bulldozer and vegetated. The moonscapes not only management serve the purpose of providing the vegetation with a growth area and plan collecting runoff rainwater for the plant but also help prevent erosion due to water runoff  The lower part of the WRD (long slopes) will remain between 35° and 37º due to the natural angle of repose.  A berm shall be constructed at the toe of the WRD with discard material for stabilisation of the toe.  The slopes of the discard and overburden dumps shall be sloped to 18º and topsoil shall be used to help establish re-vegetation.  Flat surfaces shall be ripped 30 – 50 cm deep with a bulldozer. The furrows shall be ± 6 m apart. Furrows shall be ripped rectangular to the slope to prevent soil erosion. The flat surfaces are vegetated. Incorrect sloping of areas where 3 3 M To minimise the  A detailed rehabilitation and decommissioning plan shall be developed. During decommissioning Rehabilitation expert 3 2 M infrastructure was located will result in change in topography. The following mitigation measures but not limited to shall be implemented: ECO the topography remaining changed  The general guideline is to regrade spoiled areas to approximate contours Environmental from natural topography. and to ensure that the rehabilitated topography links seamlessly to the manager surrounding topography.  A bulldozer tends to create convex slopes when sloping an area. A concave slope is a more stable slope form; therefore it is advised to rather create concave slopes.  Slopes should further be contoured. Paddocks will be implemented on these contours in the form of whale-back tops. Aspect³: Lack of storm water control on the top of the WRD Increased surface water runoff due to inadequate placement of storm water control structures (i.e. contours or drains around the waste rock dump). Decommissioning Soil erosion 3 3 M To prevent erosion  The mine shall comply with the requirements of GN 704, dated 1999, and Monthly site inspections ECO 3 3 M  Guidelines for implement the measures as contained in the Storm Water Management Surface water monitoring to Environmental 3 2 M the Plan, dated February 2014 from construction through to decommissioning be done monthly. manager rehabilitation of Siltation of surface water and erosion 3 3 M To manage surface Phase. 3 2 M mined land of side walls water drainage  Necessary erosion control measures shall be constructed to control  Stormwater surface water run-off from the on and around the waste rock dump. management  Monthly site inspections and required maintenance shall be conducted in plan order to verify the effectiveness of the water separation system and to identify possible erosion.  Closure objectives will include strategies to manage the waste rock dump at closure.  A surface water monitoring programme implemented during operational phase shall continue as part of the decommissioning and closure phase. Aspect³: Re-vegetation

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Insufficient quantity and quality of growth medium applied to profile slopes Replacement of species not adapted to the local conditions Decommissioning Potential decrease in vegetation 3 3 M To return the landscape  A rehabilitation and decommissioning plan inclusive of monitoring During decommissioning ECO 3 2 M  Visual impact growth as closely as possible timeframes shall be developed in consultation with the botanical specialist. phase and after closure. Environmental assessment Replacement of species not adapted 3 2 M to its original state.  Rehabilitation shall be in accordance with the Waterberg Spatial manager 2 2 L  Ecological to the local conditions may lead to development framework dated 2009 broader development strategy. Botanical specialist evaluation bare areas. To promote the  Rehabilitation trials shall be conducted to determine which species report establishment of establish faster.  Guidelines for vegetation and  The areas will be planted within indigenous vegetation typical of the area. the enhance species  All waste rock shall be vegetated with a suitable ground cover immediately rehabilitation of biodiversity after disturbance activities has taken place to prevent erosion and mud mined land slides.  Waterberg  During rehabilitation, colonisation of the disturbed areas by plants species Spatial from the surrounding natural vegetation will be monitored to ensure that development vegetation cover is sufficient within one growing season. framework  If not, then the areas will be rehabilitated with a grass seed mix containing species that naturally occur within the study area.  Monitoring of the rehabilitation success on the site will take place for at least 5 years and include corrective follow-up action.  Access to rehabilitated areas will be prevented until such time that rehabilitation was successful. Aspect³: Inadequate replacement of topsoil Decommissioning Disturbance of the natural balance of 3 2 M To adequately replace  The area shall be re-landscaped to resemble the land form prior to the During soil replacement ECO 2 2 L  Guidelines for the soil’s physical and chemical topsoil mining activities. Environmental the characteristics. Soil compaction and  The soil fertility status shall be determined by soil chemical analysis after manager rehabilitation of topsoil loss leading to reduced fertility. levelling (before seeding / re-vegetation) and soil enrichment will be done mined land Inadequate placement of topsoil in 3 2 M advised by a soil specialist in order to correct the pH. 2 2 L slopes or the placement of topsoil  Topsoil shall not be compacted during the rehabilitation process. creating a catena.  Sediment barriers shall be kept in place until restoration and rehabilitation is complete. Activity²: Control of invader plants on area Aspect³: Potential ineffective rehabilitation activities Decommissioning Ineffective rehabilitation activities may 4 3 H To prevent, cease,  A detailed eradication and monitoring programme shall be developed and During invader control ECO 3 3 M  Section 37, 38, result in the establishment of alien modify or control any effectively implemented and continued monitoring of the effectiveness of Environmental 39 MPRDA invasive vegetation and a disturbance act or process causing removal of alien invasive species shall be monitored. The following manager  Regulation 63 & of natural vegetation. It is possible pollution;  Areas where alien weeds and invasive plants occur on rehabilitated areas Botanical specialist 68 MPRDR i.t.o that the soil and organic material used To remedy the effects shall be identified. MPRDA for rehabilitation may contain seeds of of pollution;  The size of stands, and plant species to be removed identified shall be  Section 19 alien invasive vegetation. To eliminate any calculated. NWA Replacement of soil containing alien source of the pollution;  Appropriate resources to remove or control all identified plants in shall be  Regulation 7 of vegetation may lead to: To contain or prevent identified in the form of an action plan. GN 704 i.t.o  Displacement of indigenous the movement of  Any action taken to control and eradicate a listed invasive species shall be NWA vegetation. pollutants. executed with caution and in a manner that may cause the least possible  Section 28  Change in plant species harm to biodiversity and damage to the environment. NEMA composition.  The methods employed to control and eradicate a listed invasive species  Regulation 15  Change in vegetation shall also be directed at the offspring, propagating material and re-growth CARA composition and structure. of such invasive species in order to prevent such species from producing  Section 5 CARA offspring, forming seed, regenerating or re-establishing itself in any  Section 3 & 10 manner. FFFARSRA  Alien invasive vegetation shall be removed according to area and not  PCOR species.  Guidelines for  Any action taken to control and eradicate a listed invasive species shall be the executed with caution and in a manner that may cause the least possible rehabilitation of

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harm to biodiversity and damage to the environment. mined land

7.1.4 General

Impact per phase⁴ Risk rating Environmental Mitigatory action plan⁸ Timeframe⁹ Responsibility¹⁰ Risk rating (after Applicable (before objective⁷ mitigation)⁵ legislation and other mitigation)⁵ documents

Probability Magnitude Severity Probability Magnitude Severity Section¹: General and hazardous non-mining waste Activity²: Waste sorting. Waste sorting will not take place during the decommissioning phase. Aspects³: Spillages of hazardous materials mixed with general waste during transportation due to the incorrect separation of non-hazardous and hazardous waste at all sources throughout the mine. Excess waste transported to waste site, due to the incorrect separation of non-hazardous and hazardous waste at all sources throughout the mine. Waste contaminated by hazardous substances disposed at the domestic waste landfill site, due to the incorrect separation of non-hazardous and hazardous waste at all sources throughout the mine. Construction and Pollution of soil. 3 2 L To separate waste  A waste inventory will be developed, reflecting all waste streams, general During mining activities. Project manager 2 2 L Section 16 & 17 operational Pollution of surface water. 3 2 L correctly. and hazardous, area of generation, temporary storage requirements, Surface water quality Mine manager 2 2 L NEMWA This can be through direct pollution of To avoid as far as classification if hazardous, contractor for removal, and disposal monitoring to take place on SHE manager Regulation 4 & 5 surface water during rain events or possible the generation methodology. monthly basis. Environmental GN R634 i.t.o surface water run-off from polluted and production of  A waste management procedure shall be developed. Control Officer NEMWA soils. waste.  An ‘at-source’ waste separation system will be implemented. Contractors Section 20 of ECA Where the generation  General waste bins will be available in all areas including along walkways, Minimum Surface resources along and production of waste at security, the parking area, offices, workshops, etc. Requirements for transportation routes not known at cannot altogether be  Hazardous waste bins will be available everywhere where oil / grease / the handling, this stage. Thabazimbi Local avoided, to minimise, diesel / paint or chemicals are used. classification and Municipal waste landfill site to be re-use or recycle.  Bins and skips will be labelled and/ or coloured according to the relevant storage of used. When recycling or re- types of wastes to be disposed of into the bins / skips. hazardous waste – Depletion of space at landfill sites. 3 2 L use, to use fewer  All waste will be removed by a certified contractor to a licensed landfill 2 2 L Second Edition Potential wastage of recyclable 3 2 L natural resources than site. 2 2 L Chapter VIII NRTA disposal of such waste, GN R225 (2000) material.  The hazardous containers will be labelled with the correct name and and to the extent that it i.t.o NRTA description of the contents. Labelling of hazardous substances will be is possible, is less SANS 10231:2006 – done according to the SABS Code 0233. When Hazardous Waste is harmful to the Transport of transported, further labelling of bulk containers and placarding of the environment than the dangerous goods – vehicle is also required. disposal of such waste. Operational  Vehicles will be licensed as hazardous transporting vehicles. To prevent the waste requirements for  Driver will be trained on the hazardous waste transporting, have the from being used for an road vehicles correct driver’s license and be aware of he / she responsibilities. unauthorised purpose SANS 10232–  The load will be secured when loading. To dispose waste in a 1:2007–Transport of  Every employee will be responsible to put waste into the correct bins. responsible and dangerous goods – sustainable manner –  Environmental awareness training will be continued with through posters, Emergency environmentally sound and training. Information manner.  Surface water monitoring will take place. Systems, Part I: To dispose waste, liquid Emergency or solid, at an approved information system demarcated site. for road transport To prevent, cease, Section 28 NEMA modify or control any Section 37, 38, 39 act or process causing MPRDA pollution; Regulation 63, 68,

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Probability Magnitude Severity Probability Magnitude Severity To remedy the effects of 69 & 73 MPRDR pollution; i.t.o MPRDA To eliminate any source Section 19 NWA of the pollution; Regulation 7 GN To contain or prevent 704 (1999) i.t.o the movement of NWA pollutants. Storm water management report. Activity²: Temporary storage of hazardous waste. Waste will not be stored during the decommissioning phase. Aspect³: Incorrect handling of hazardous waste while off-loading and storage at non-designated areas and/or incorrect design and inadequate maintenance of the bunded area for hazardous waste. Construction and Pollution of soil. 3 2 L To prevent, cease,  All waste material will be placed into the correct bins During mining activities. Project manager 2 2 L Section 16 & 17 operational Pollution of surface water. 3 2 L modify or control any  Hazardous waste (including drums containing old oil) will be stored on an Surface water quality Mine manager 2 2 L NEMWA This can be through direct pollution of act or process causing impermeable cement slab surrounded by a bund wall and will be covered or monitoring to take place on SHE manager Regulation 4 & 5 surface water during rain events or pollution; placed under a roof (at each temporary waste storage area) to prevent monthly basis. Environmental GN R634 i.t.o surface water run-off from polluted To remedy the effects of rainwater from coming into contact with the hazardous waste. Control Officer NEMWA soils. pollution;  Only closed, marked oil drums containing old oil will be received by the Contractors Section 20 of ECA To eliminate any source temporary waste storage areas. Minimum of the pollution;  Stormwater control / management measures will be established and Requirements for To contain or prevent implemented around the temporary waste areas. the handling, the movement of  Rainwater from the area surrounding the temporary waste storage areas will classification and pollutants. be diverted away from the temporary waste areas. storage of  Rainwater falling within the temporary waste storage areas will be contained hazardous waste – as process water. Second Edition  These areas will be clearly demarcated and inaccessible to un-authorised Section 28 NEMA persons. Section 37, 38, 39 MPRDA  A weatherproof, durable and clearly legible notice-board in official languages Regulation 63, 68, will be placed at the entrance of the temporary waste area with the words 69 & 73 MPRDR “Hazardous Waste: un-authorised entry prohibited” will be erected. i.t.o MPRDA Section 19 NWA Regulation 7 GN 704 (1999) i.t.o NWA Storm water management report. Activity²: Production of building rubble during decommissioning. Only applicable to the decommissioning phase. Aspect³: Incorrect disposal of buildings rubble due to inadequate rehabilitation plan and implementation of plan. Decommissioning Depletion of space at landfill site. 3 3 M To minimise the  Building rubble will be removed to a licensed waste disposal facility. During decommissioning Project manager 2 2 L Section 16 & 17 depletion of landfill sites phase. Mine manager NEMWA through correct SHE manager Regulation 4 & 5 decommissioning and Environmental GN R634 i.t.o rehabilitation. Control Officer NEMWA Destruction of natural vegetation. 3 3 M 2 2 L Contractors Section 20 of ECA

Section¹: Additional (non-mining) water management Activity²: The use of water from the Crocodile River. Aspect³: Over extraction of water from the Crocodile River. Construction, Depletion of water resource. 3 3 M To ensure that the  All pipes will be kept in a good condition to prevent leaks. Throughout the LoM. Project manager 2 2 L Section 21 NWA operational and mine’s use of water  All leaks will be reported and remediate as soon as possible. Mine manager decommissioning does not impact on the  Employees will be made aware to conserve water as a natural resource. SHE manager availability of water to Environmental lawful water users. Control Officer Contractors

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Probability Magnitude Severity Probability Magnitude Severity Activity²: The use of chemical toilets and cleaning of chemical toilets. Aspect³: Spillages of affected water during usage and cleaning of chemical toilets. Construction and Pollution of soil. 3 3 M To prevent, cease,  Sufficient ablution facilities will be provided. Throughout the LoM. Project manager 2 3 L Section 28 NEMA decommissioning modify or control any Surface water quality Mine manager Section 37, 38, 39 Pollution of surface water. 3 3 M  The mine, as well as the contractor, will ensure that no spillage occurs and 2 3 L act or process causing monitoring to take place on SHE manager MPRDA This can be through direct pollution of that the contents are removed from site according to approved methods. pollution; monthly basis. Environmental Regulation 63, 68 & surface water during rain events or To remedy the effects of Control Officer 73 MPRDR i.t.o surface water run-off from polluted pollution; Contractors MPRDA soils. To eliminate any source Section 19 NWA of the pollution; Regulation 7 GN To contain or prevent 704 (1999) i.t.o the movement of NWA pollutants. Storm water management report Activity²: Domestic wastewater Aspect³: Spillages or leakages of sewerage network due to lack of maintenance. Potential polluted soil due to residue spillages. Discharge of domestic wastewater into the PCD Operational Pollution of surface water 3 3 M To prevent discharges of  All pipes shall be kept in a good condition to prevent leaks. Throughout the LoM. Project manager 2 3 L Section 28 of NEMA groundwater and soil. contaminated water to  All leaks shall be reported and remediate as soon as possible. Groundwater water quality Mine manager Section 19 NWA the environment. monitoring to take place on a SHE manager Section 16 & 17 To ensure that the mine’s quarterly basis. Environmental NEMWA use of water does not Surface water quality Control Officer Geo-hydrological impact on the availability monitoring to take place on Contractors study monthly basis. of water to lawful water users. Section¹: Transport and conveyance Activity²: Driving on roads, this includes all transportation activities on road. Aspect³: Elevated surface water run-off due to inadequate or lack of stormwater control, and linear structures. Construction, Increased surface water runoff 3 3 M To protect watercourses  The condition of all unpaved roads will be monitored for potential water Throughout the LoM. Project manager 2 3 L Section 28 NEMA operational and and prevent alteration of Monitoring as necessary. Mine manager Section 37, 38, 39 Soil erosion due to surface water run- 2 3 L runoff and erosion on unpaved roads, especially during the rainy season. 1 2 L decommissioning these habitats directly SHE manager MPRDA off. and indirectly through Environmental Regulation 70 sedimentation and Control Officer MPRDR i.t.o pollution. Contractors MPRDA To protect soil resources. Activity²: Driving on roads, this includes all transportation activities on road. Aspect³: Emissions and dust from hauling and driving on gravel roads. Construction, Air pollution 3 3 M To ensure that the mine  Service / maintenance data / annual roadworthy inspections of all vehicles Throughout the LoM. Project manager 2 2 L Section 2 NEMAQA operational and remains compliant with will be reflected. Mine manager Regulation 64 decommissioning air quality legislation.  Visual inspections on vehicles for black smoke will be undertaken. SHE manager MPRDR i.t.o  Vehicles will be prioritised from oldest vehicles to newest. Environmental MPRDA  Vehicles will be submitted for vehicle emission testing as per GN R 1651 Control Officer Air Quality study  Contractors undertaking transporting on behalf of the mine will be requested Contractors to provide evidence of their vehicle emission levels compliance to the maximum levels set out in GN R1651 or at least proper maintenance on their vehicles.  Implementation of dust fallout and dust concentration monitoring at specified points.  It is therefore recommended that PM2.5 and PM10 concentrations be monitored at the closest sensitive receptor to the Project prior to operations,

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Probability Magnitude Severity Probability Magnitude Severity in order to verify baseline ambient air quality levels, and once operations commence in order to ensure NAAQS are met. Initially monitoring can be done for a short monitoring period (i.e. a three month monitoring campaign) to understand whether NAAQS are met. If exceedance of the NAAQS is found, continuous PM10/PM2.5 monitoring can be undertaken with mitigation measures at the Meletse Iron Ore Project being refined accordingly (if necessary) in order to meet NAAQS. Activity²: Driving on roads, this includes all transportation activities on road. Loading and hauling of ore Aspect³: Noise generation. This will increase due to inadequate maintenance of vehicles. Construction, Elevated noise levels. 4 2 M To ensure that the mine  An environmental noise monitoring programme will be implemented. Throughout the LoM. Project manager 3 1 L Regulation 66 operational and remains compliant with Noise monitoring to take Mine manager MPRDR i.t.o Disturbance to nearby community. 4 2 M  Effective maintenance of vehicles and machinery will take place. 3 1 L decommissioning air quality legislation.  Machinery will, where possible, be equipped with silencers. place on quarterly basis. SHE manager MPRDA Disturbance of fauna assemblages in 4 2 M 3 1 L  Complaints register will be available for the recording of complaints relating Environmental Ecological area. Noise results primarily from the to noise. Control Officer evaluation report movement of vehicles. The proposed Contractors Noise repot site is located in an area where road noise is limited, the effect of noise displacement will be more severe during the mine operations since the proposed site has a history of virtually no traffic or traffic volumes were very low. In contrast, areas where traffic is already high (e.g. along most of our highways or national roads), most animals in the region have become accustomed to the noise and will avoid the proximity of the road where possible. Such avoidance and displacement will lead to increased, albeit in an indirect way, to the fragmentation of animal populations. Aspect³: Compaction of roads surface Operational A reduction in recharge will result due 4 1 L To ensure that  The mine shall comply with the requirements of GN 704, dated 1999, and Throughout the LoM. 2 2 L Geohydrological to the compaction of the surface of contaminated surface implement the measures as contained in the Storm Water Management investigation the roads relating to the hauling of water runoff from haul Plan, dated February 2014 (refer to Appendix 12) from construction through ore. roads do not come into to decommissioning Phase. contact with clean  Infrastructure will be constructed and maintained so as to comply with the surface water runoff, or requirements contained in the National Water Act (NWA) (Act 36 of 1998) infiltrate into the and the GN704, dated June 1999. groundwater system.  All contaminated surface water runoff from haul road areas shall be collected in the dirty water management system, minimising the infiltration of contaminated water.  Regular site inspections shall be conducted in order to verify the effectiveness of the water separation system and to identify possible erosion.  A surface water monitoring programme shall be developed and effectively implemented. Aspect³: Increased traffic on roads due to the use of roads, also used by community. Construction, Safety hazard to drivers. 3 4 H To identify the relevant  A road safety policy shall be compiled and effectively implemented for Throughout the LoM. Project manager 2 3 M Regulation 255 i.t.o operational and hazards and assess the Mine manager NRTA Damage to road infrastructure in the 3 3 M employees, contractors and suppliers. The plan shall include aspects such 2 2 L decommissioning related risks to which SHE manager Traffic impact study area. as road signs warning of danger, speed limits and fines for transgressors. the community may be  Upgrading of the following roads from gravel to a surfaced road: Environmental

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Probability Magnitude Severity Probability Magnitude Severity exposed.  New access on P240/1; Control Officer  Road P240/1 from the mine’s access to the intersection with Road Contractors D928 (± 6km);  Road D928 from Road P240/1 to the intersection with Road D1031 (± 7km); and  Road D1031 from D928 to R510 (±24,5km).  The existing culvert on Road D1031 needs to be widened to accommodate two-way traffic.  The minimum road width should be 3,7m lanes with 0,5m surfaced shoulders.  The structural capacity of Road R510 and R511 should be evaluated to determine if the road can carry the additional heavy vehicles to the Chromedale siding; if not, it should be upgraded.  Road D927 from the intersection with Road D1031 to Rooiberg shall be upgraded and a maintenance plan shall be developed and implemented to keep the road in a good condition.  Approval to access the Chromedale siding on Road R510 shall be obtained from SANRAL. R510 shall be upgraded as per the design standards of SANRAL. The minimum requirements shall be as follows:  60m right turn lane on both approaches of Road R510  60m left turn lanes on both approaches of Road R510 Increased traffic volumes (in 3 2 M To conserve animals  No immediate mitigation measures can be implemented during operational Throughout the LoM. Project manager 3 2 M  Section 28 combination with the presence of and prevent disturbance phase due to the nature of the activity. Rehabilitation shall be conducted Mine manager NEMA haul roads) will invariably deter of animal habitats during the decommissioning and post closure phase. Rehabilitation shall SHE manager  Section 37, 38, animals from crossing these roads, be conducted such that it attracts fauna to areas where rehabilitation is Environmental 39 MPRDA especially when haul traffic is implemented. Control Officer  Ecological anticipated to run for seven days a Contractors evaluation report week and 24 hours a day. Low- frequency noise will also generate a significant amount of vibration, which will be detected by smaller ground- dwelling animals such as reptiles and invertebrates. Most of these animals depend on the detection of vibrations to escape predation since they have poor hearing. However, increased traffic noise and vibration will interfere with their ability to detect potential predators or to escape predation. Road mortalities: Any animal 4 4 H To identify the relevant  Vehicular activities must be restricted to daylight hours to prevent any Throughout the LoM. 3 2 M  Section 28 attempting to cross a road risk being hazards and assess the disturbance to fauna in the area; NEMA killed by vehicles. Animals at risk will related risks to which  Fragments shall be linked by preserving corridors  Section 37, 38, include those with poor hearing, poor the animal may be  The gravel roads shall be cordon off from surrounding natural vegetation to 39 MPRDA vision or nocturnal animals that are exposed. prevent any disturbances into the surrounding areas.  Ecological blinded by the headlamps of  Rehabilitation shall be conducted during the decommissioning and post evaluation report oncoming traffic. In addition, many closure phase. Rehabilitation shall be conducted such that it attracts wildlife smaller animals, especially to areas where rehabilitation is implemented. ectothermic taxa (e.g. scorpions and  Appropriate speed limits must be set. nightjars), will be attracted to the warmer road surfaces at night (the roads have a higher potential to absorb solar heat during the day), making them vulnerable to road mortalities. Other animals that area at

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Probability Magnitude Severity Probability Magnitude Severity risk includes scavengers that are attracted to the road kills – this guild is well defined and prominent on the study site (e.g. jackals, civets, hyaenas). Increased travelling speed and 3 2 M To identify the relevant  Using visual and acoustic methods the important ‘bat road crossings’ within Throughout the LoM. Project manager 2 1 L  Section 28 vehicle traffic on the roads around hazards and assess the the landscape, shall be identified for the different cave dwelling bat species Mine manager NEMA the cave at emergence times, will related risks to which  Once a week, during and after the emergence of M. natalensis between SHE manager  Section 37, 38, likely result in regular, direct the bats may be November and March, the number of injured or dead bats shall be Environmental 39 MPRDA collisions with bats, in particular with exposed. quantified, by visual inspection of the identified roads. Control Officer  Bat assessment the Long-fingered Bat, which will  The mine shall monitor, in the early evening, from sunset to two hours Contractors report have a negative impact in the thereafter, between November and March if reduced speeds of 10-15 km at medium to long-term; by decreasing the ‘bat road crossings’ is sufficient to reduce collisions and mortality of the the population size. An increase in bats. both the size of the vehicle and the  Alternatively, crossing structures that attempt to provide the linear elements speed at which the vehicle travels will in the landscape that bats rely on for commuting along existing routes, shall increase the risk of collision, and the be installed to allow the bats under or over the road degree of damage and mortality of  The distance between open water sources and busy roads shall be bats flying across the road, maximized. particularly during the emergence  On busy roads, in order to avoid collisions, lighting shall not attract insects period. and bats. Section¹: Energy supply Activity²: Electricity supply (mine wide) Aspect³: Over utilisation of electricity as a result of faulty or old wiring Construction, Depletion of energy resource. 3 3 M To prevent over-  All wiring will be regularly inspected and old or faulty wiring will be replaced. Throughout the LoM Project manager 2 2 L NEMA operational and utilisation of electricity.  Employees will be made aware of energy saving through an environmental Mine manager decommissioning awareness campaign. SHE manager Environmental Control Officer Contractors Section¹: Chemical and hazardous substances and maintenance facilities Activity²: Storage, handling, transportation, loading and off-loading of hazardous substances (such as chemicals) (mine wide). Welding and cutting. Not applicable during the decommissioning phase. Aspect³: Fire hazard due to fire accident, inadequate firefighting equipment, and/or inadequate emergency preparedness and training. Construction and Air pollution. 2 1 L To ensure that the mine  No smoking or naked flames will be allowed near the storage area. Throughout the LoM Project manager 1 1 L Section 2 NEMAQA operational Health/safety hazard to nearby 2 2 L remains compliant with  Only trained persons will use welding, cutting and grinding equipment. Mine manager 1 2 L Regulation 64 residential areas. air quality legislation.  No welding, cutting and grinding will take place in an unventilated area. SHE manager MPRDR i.t.o Damage to infrastructure and 2 2 L To limit public exposure  Firefighting equipment will be available and maintained on site. Environmental 1 2 L MPRDA agricultural areas. to unacceptable health  Emergency preparedness and response procedures and codes of practices Control Officer risks. will be established and implemented. Contractors To identify the relevant  Regular fire drills will be conducted. hazards and assess the  The authorities will be informed if the incidence of respiratory disease in the related risks to which area increases. the community may be  Should any out-of-the-ordinary risks to health and safety arise it will be exposed. widely communicated to the surrounding community, including employees, farmers and all other stakeholders. Activity²: Influx of people to the area Aspects³: Increase in crime in the area

Construction, Safety and security 3 3 M To minimise the  The construction camp shall be established in accordance to the IFC Throughout the LoM Project manager 3 2 M Operational, and increase of crime in the guidelines for Workers’ Accommodation. Mine manager

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Impact per phase⁴ Risk rating Environmental Mitigatory action plan⁸ Timeframe⁹ Responsibility¹⁰ Risk rating (after Applicable (before objective⁷ mitigation)⁵ legislation and other mitigation)⁵ documents

Probability Magnitude Severity Probability Magnitude Severity Decommissioning area.  The location of the construction camp shall be agreed on with surrounding SHE manager neighbours. Environmental  An Influx management strategy shall be developed and implemented an as Control Officer per IFC Guidelines on Influx Management. Contractors  A safety and security plan shall be compiled with the input from stakeholders from the community (including local police). The safety protocol shall cover aspects such as visible security (patrols, uniforms), protocol for accessing land, marked vehicles and contractor identification.  A transport policy shall be developed and implement for workers to prevent them from walking through farm areas. The plan shall include picking them up and dropping them off in residential areas. Activity²: Generation of employment. Aspect³: Job creation Construction, and The mine will create a much larger 3 3 M+ To meet requirements  The SLP measures shall be implemented. Throughout the LoM Project manager 3 4 H+ Part 2 MPRDR i.t.o operational number of jobs during construction of SLP  Unreasonable expectations with regards to employment opportunities will Mine manager MPRDA and for a period of 18 years during not be created. SHE manager SLP operational phase.  The mine shall commence with skills development as required by the Environmental Decommissioning The decommissioning and closure of 3 3 M MPRDA before the mine becomes operational to ensure sufficient skills are Control Officer 3 2 L the mine will bring about a reduction present in the local labour sending communities. Contractors in available employment which could  The mine shall develop and implement a recruitment policy and the policy increase the unemployment rate of shall be communicated to local people. the area.  The mine shall procure locally as far as possible.  Goods shall be procured locally as far as possible.

Activity²: Socio-economic contributions Aspect³: Positive contribution to the country’s economy Construction, Contribution to the country’s 3 3 M+ To contribute positively  Stakeholders and affected parties shall be kept informed of any Throughout the LoM Project manager 3 4 H+ Economic report operational and economy. to the Thabazimbi Local developments during all four the project phases. decommissioning Municipality economy.  The mine shall engage with local entrepreneurs and provide them with Mine manager relevant economic opportunities.  The mine shall employ local labour from closest communities for low skilled SHE manager opportunities.  Involve community in updates of the SLP. Environmental Control Officer

Contractors Activity²: General mining Aspect³: Change in sense-of-place Construction, Negative visual impact and change to 5 5 H To minimise the impact  The applicant should be accessible to the public when concerns, complaints Throughout the LoM Project manager 4 4 H operational and the sense of place of residents in the on the change in sense- or questions arise. decommissioning area of-place.  Effective Implementation of mitigation measures as stipulated in the Visual Mine manager Impact Assessment. SHE manager

Environmental Control Officer

Contractors 1: Refer to paragraph 2.3.1 of section 1 (EIA); 2: Refer to paragraphs 3.1, 6.1, 6.2, 6.3, 10 and 15.1 of section 1 (EIA); and paragraphs 2.2 and 5.1 of section 2 (EMP); 3: Refer to paragraphs 3.1, 6.1, 6.2, 6.3, 10 and 15.1 of section 1 (EIA); 4: Refer to paragraphs 3.1, 6.1, 6.2, 6.3, 10 and 15.1 of section 1 (EIA); 5: Refer to paragraph 7.2 of section 1 (EIA);

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6: Refer to paragraphs 3 and 4 of section 2 (EMP); 7: Refer to paragraph 15.2 of section 1 (EIA); and paragraphs 2.1 and 8.1 of section 2 (EMP); 8: Refer to paragraphs 5.2 and 7 of section 2 (EMP); 9: Refer to paragraphs 7.3 and 15.4 of section 1 (EIA); and paragraph 2.3 of section 2 (EMP); 10: Refer to paragraph 15.3 of section 1 (EIA); and paragraph 2.4 of section 2 (EMP);

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7.2 Concomitant impact rating for each potential impact listed in paragraph 7.1 above in terms of its nature, extent, duration, probability and significance

7.2.1 Introduction and approach followed The environmental risk of any aspect is determined by a combination of parameters associated with the impact. Each parameter connects the physical characteristics of an impact to a quantifiable value to rate the environmental risk.

Impact assessments should be conducted based on a methodology that includes the following:  Clear processes for impact identification, predication and evaluation;  Specification of the impact identification techniques;  Criteria to evaluate the significance of impacts;  Design of mitigation measures to lessen impacts;  Definition of the different types of impacts (indirect, direct or cumulative); and  Specification of uncertainties.

After all impacts have been identified, the nature of each impact can be predicted. The impact prediction will take into account physical, biological, socio-economic and cultural information and will then estimate the likely parameters and characteristics of the impacts. The impact prediction will aim to provide a basis from which the significance of each impact can be determined and appropriate mitigation measures can be developed.

The risk assessment methodology is based on defining and understanding the three basic components of the risk, i.e. the source of the risk, the pathway and the target that experiences the risk (receptor). Refer to Figure 39 below for a model representing the above principle (as contained in the DWA’s Best Practice Guideline: G4 – Impact Prediction.

Figure 39: Impact prediction model

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7.2.2 Methods used to identify impacts PROBABILITY of the impact is determined by calculating the average between the frequency of the aspect and the availability of a pathway to the receptor and the availability of receptor.

Tables 43 and 44 below indicate the methodology to be used in order to assess the Probability and Magnitude of the impact, respectively, and Table 45 provides the Risk Matrix that will be used to plot the Probability against the Magnitude in order to determine the Severity of the impact.

Table 45: Determination of Probability of impact FREQUENCY OF ASPECT / SCORE AVAILABILITY OF PATHWAY FROM THE SOURCE SCORE AVAILABILITY OF SCORE UNWANTED EVENT TO THE RECEPTOR RECEPTOR Never known to have happened, but 1 A pathway to allow for the impact to occur is never 1 The receptor is never 1 may happen available available Known to happen in industry 2 A pathway to allow for the impact to occur is almost 2 The receptor is almost 2 never available never available < once a year 3 A pathway to allow for the impact to occur is 3 The receptor is sometimes 3 sometimes available available Once per year to up to once per 4 A pathway to allow for the impact to occur is almost 4 The receptor is almost 4 month always available always available Once a month - Continuous 5 A pathway to allow for the impact to occur is always 5 The receptor is always 5 available available Step 1: Determine the PROBABILITY of the impact by calculating the average between the Frequency of the Aspect, the Availability of a pathway to the receptor and the availability of the receptor.

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Table 46: Determination of Magnitude of impact SOURCE RECEPTOR Duration of Score Extent Score Volume / Score Toxicity / Score Reversibility Score Sensitivity of Score impact Quantity Destruction environmental / Effect component Intensity Lasting days 1 Effect limited 1 Very 1 Non toxic 1 Bio-physical and/or 1 Current 1 to a month to the site. small (e.g. water) social functions environmental (metres); quantities / Very low and/or processes will component(s) / volumes potential to remain unaltered. are largely / intensity create disturbed from (e.g. < damage or the natural 50L or < destruction state. 1Ha) to the Receptor of low environment significance / sensitivity Lasting 1 2 Effect limited 2 Small 2 Slightly toxic 2 Bio-physical and/or 2 Current 2 month to 1 to the activity quantities / Harmful social functions environmental year and its / volumes (e.g. diluted and/or processes component(s) immediate / intensity brine) / Low might be negligibly are moderately surroundings. (e.g. 50L potential to altered or enhanced / disturbed from (tens of to 210L create Still reversible the natural metres) or 1Ha to damage or state. 5Ha) destruction No to the environmentally environment sensitive components. Lasting 1 – 3 Impacts on 3 Moderate 3 Moderately 3 Bio-physical and/or 3 Current 3

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SOURCE RECEPTOR Duration of Score Extent Score Volume / Score Toxicity / Score Reversibility Score Sensitivity of Score impact Quantity Destruction environmental / Effect component Intensity 5 years extended quantities toxic (e.g. social functions environmental area beyond / volumes slimes) and/or processes component(s) site boundary / intensity Potential to might be notably are a mix of (hundreds of (e.g. > create altered or enhanced / disturbed and metres) 210 L < damage or Partially reversible undisturbed 5000L or destruction areas. 5 – 8Ha) to the Area with some environment environmental sensitivity (scarce / valuable environment etc.). Lasting 5 4 Impact on 4 Very 4 Toxic (e.g. 4 Bio-physical and/or 4 Current 4 years to Life local scale / large diesel & social functions environmental of adjacent quantities Sodium and/or processes component(s) Organisation sites (km’s) / volumes Hydroxide) might be are in a natural / intensity considerably altered state. (e.g. or enhanced / Environmentally 5000 L – potentially sensitive 10 000L irreversible environment / or 8Ha– receptor 12Ha) (endangered

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SOURCE RECEPTOR Duration of Score Extent Score Volume / Score Toxicity / Score Reversibility Score Sensitivity of Score impact Quantity Destruction environmental / Effect component Intensity species / habitats etc.). Beyond life 5 Extends 5 Very 5 Highly toxic 5 Bio-physical and/or 5 Current 5 of widely large (e.g. arsenic social functions environmental Organisation (nationally or quantities or TCE) and/or processes component(s) / Permanent globally) / volumes might be are in a pristine impacts / intensity severely/substantially natural state. (e.g. > 10 altered or enhanced / Highly Sensitive 000 L or Irreversible area > 12Ha) (endangered species, protected habitats etc.) Step 2: Determine the MAGNITUDE of the impact by calculating the average of the factors above.

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Table 47: Determination of Severity of impact

ENVIRONMENTAL IMPACT RATING / PRIORITY MAGNITUDE 1 2 3 4 5 PROBABILITY Minor Low Medium High Major

5 Almost Certain Low Medium High High High

4 Likely Low Medium High High High

3 Possible Low Medium Medium High High

2 Unlikely Low Low Medium Medium High

1 Rare Low Low Low Medium Medium

Step 3: Determine the SEVERITY of the impact by plotting the averages that were obtained above for Probability and Magnitude in the table below

7.2.3 Definitions used in the assessment and evaluation of impacts Severity - The magnitude of the potential impact Probability - The likelihood of the impact occurring Magnitude

7.3 Indication of the phases and estimated time frames in relation to the potential impacts rated Refer to sub-section 7.1 of Section 1 (EIA), for an indication of the phases and estimated time frames in relation to the potential impacts rate

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Regulation 50 (d)

8 Identification of the alternative land uses which will be impacted upon

Gross Domestic Product The impact on the GDP of Thabazimbi is outlined in this section and as will be shown, this is significantly positive. The impacts were calculated on four scenarios as is shown in the table 48 below.

Table 48: Impact Assessment Scenario Scenario Km Radius Ha Sq km Best 2.2 1 500 ha 15 Second Best 3.4 3 564 ha 36 Middle 5.2 8 466 ha 85 Worst 8.0 20 113 ha 201

The scenarios are simply the possible extent of alternative land-use hectares that may be “sterilised” by the mine. The best impact would be to “sterilise” only the 1500 ha potential mining area, thus from the centre point of the mine’s land a radius of 2.2 km would ensue. The second best would be 3.4 km’s, the middle 5.2 km’s and the worse-case an 8 km radius. As can be seen above each of these scenarios can be expressed in radia, hectares and square km’s.

These scenarios take into consideration the fact that the visual impact on the Meletse Peak cannot be mitigated, thus even though it may be visible beyond a 8 km radius, its impact is limited to an this distance in order to be fair in this analysis. Given that this analysis considers that eco-agriculture land will be sterilised, whereas in reality most land continue to have economic value, an 8 km radius was deemed a good-enough cut-off point.

The logistical options are considered in the sense that should one road be used and its impacts are say forty kilometres by half-a-kilometre, the total hectares impacted would be 2 000. This 2 000 ha would thus be considered as part of the 8 km2 (or 20 106 ha) worst case land-sterilisation scenario.

The alternative land-use being impacted is that of game-farming, which offers hunting, eco-tourism, accommodation, game-breeding and other products. The marketing mix, which consists of product, price, people and place will most probably have to change for most of the land-owners. The reputation of the potentially impacted area as a tranquil, serene and pristine eco-tourism area will most likely change permanently in the minds of customers. A good example of this is the

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Johannesburg CBD where the perception of property investors was that the market mix of the property landscape had changed and the flight of property capital occurred. The change that the proposed mine will bring to the game-farms’ businesses in the local area will be of the same nature. Economic activity will not seize, on the contrary, it can be shown that the hospitality industry (restaurants and accommodation), grow in line with an increase in mining activity in an area. The marketing mix, however, changes, thus the hospitality industry starts catering for a new market segment.

In addition to this, it needs to be stated that negative visual impacts, to this specialist knowledge, is not sufficient grounds to halt a development, simply because if such a ruling was to exist, very little development would take place, (e.g. high rise buildings would be opposed on those grounds and development would be impeded.) In the event of such a restriction to development, clearly the current economic generation would not be able to improve their quality of lives.

The traffic impact, should road haulage be used, regardless of the fact the the mine needs to comply with provincial road regulations, will change the marketing mix of the current eco-operators to such an extent that one needs to conclude that this may not be simple justice between stakeholders.

Table 49: Alternative land-use analysis 18 years (2013 rand values)

Alternative land-use analysis 18 years (2013 rand values) Value Worse Case hectares displaced 20 113 ha Start-up capital (year 2015 + 2016) R 3 084 m Operating GDP over 18 years R 6 230 m Total GDP (investment and operating) of mine 18 years R 9 314 m Provision for mine failure -R 1 863 m Less potential agricultural property values lost -R 805 m Economic write off of potential sterile mining land -R 912 m Less Agricultural GDP lost -R 2 020 m Net GDP over 18 years R 3 714 m

The above table shows the key assumptions in the GDP analysis. The first point is that the mine’s investment (start-up capital), is potentially large at over R3 billion rand over two years. The second is that its potential GDP is R9.3 billion over the same period and this is a 2.5% increase in GDP of Thabazimbi. This is a significant increase in GDP and if there was a win-win coexistence between the mine and its surrounding land-owners, this would be the net benefit to the economy. Unfortunately, in its worst case this drops to 0.6% and this gives an indication of the cost to an economy should productive co-existence not be found between stakeholders – in essence the whole of society pays an opportunity cost for poor stakeholder relations.

It is noteworthy that GDP is measured for the mine as economic value add, which is the difference between total sales and all intermediary inputs (thus goods and services from third parties to the

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 216 of 328 Management Programme under the MPRDA, 2002 mine.) Economic value therefore is salaries and wages plus earnings before interest, tax, depreciation and amortisation.

The third point regarding the above table is that this specialist “discriminates” against the mine by deducting the possibility of failure (generally mine studies are sophisticated enough to avoid business failure), and the GDP per hectare lost on game-farms have been inflated to accommodate the argument by local land-owners that their game-farms are of much higher economic value than industry averages. For this reason, potential property values lost to game-farmers was set at R40 000 per hectare, even though in Quarter 4 2013 when a survey of property prices were undertaken, it seemed that R25 000 per hectare was the norm. It was also interesting to note that some game-farmers indicated that the prices of land continues to increase despite the knowledge that the proposed mine are seeking a mine license, which is in itself either an anomaly or other stakeholders may see investment opportunities.

Furthermore, based on modelling, the average agricultural output and hectares used in Thabazimbi, using a respectable economics database provided by Quantec Economic Services, the GDP per hectare of game-farms was as low as R129 per hectare. In the light of site visits and obtaining local information through interviews, this specialist adjusted this upwards to R3 138 per hectare. This number was derived at through modelling and educated estimates, and it implies that a game-farm of 1000 hectare could generate R3.1 million in GDP, (EBTDA and salaries and wages), which based on other studies is not unrealistic. Based on much field studies by this specialist, a typical cattle farm on the other hand of 1 000 hectare manages a GDP of around R1m, thus putting this number in perspective. This also attests the extent to which this specialist endeavours to give game-farmers in the area the benefit of the doubt.

In the table 49 a further deduction of economic land-value lost due to sterilisation of the mine footprint is also made as it can be argued that at the end of 18 years few investors would take over the mine site for fear of environmental liabilities, as is evidenced in many cases in South Africa today.

The above calculation does not include the cost of animal stock, thus the value of game or other livestock on the farms because these are movable assets and can be sold off on auctions, hunted for trophies or send to an abattoir for venison or biltong. Thus this asset class can be liquidated.

The conclusion that is drawn is that in any scenario, the potential GDP added to the economy, regardless whether its national, regional or local, will be favourable to the proposed mine development.

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9 Listed results of a specialist comparative land use assessment

With the above in mind, from an economic perspective the mine is undoubtedly a better GDP contributor than the current alternative land-use. See the table 50 below.

Table 50: GDP net difference between the proposed mine and eco-agriculture alternative land- uses Scenario Ha impacted Increse in GDP % to Thabazimbi GDP Best 1 500ha R 6 328 m 1.0% Second Best 3 546ha R6 038 m 0.9% Middle 8 466ha R5 350 m 0.8% Worse 20 113 ha R 3 714 m 0.6% Average R5 358 m 0.8%

Table 50 shows that even in the worst-case scenario, thus in a 8 km radius around the mid-point of mine operations, the net increase in GDP over an 18 year LOM period is positive and the Thabazimbi local GDP would increase by 0.6%, all things being equal. Moving to the better scenarios, in the best case the GDP of Thabazimbi could increase by 1.0%. However, these increases are based on “discriminating” heavily against mining, thus the calculations deliberately disadvantage mining to the benefit of the alternative land-use. The reason for this discrimination is that the proposed mine is a new economic activity and it needs to be shown beyond doubt that its macro-economic value exceeds the alternative land-use.

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Regulation 50 (e)

10 List of all the significant impacts as identified in the assessment conducted in terms of Regulation 50 (c)

Site Preparation - Clearance of Top Soil Clearance of topsoil and vegetation for construction of roads and excavation activities shall expose soil resulting in soil erosion while also exposing natural vegetation. Such impacts will affect the red data species the most. In addition, the destruction of natural vegetation coupled with soil erosion shall enable the establishment of invasive vegetation in areas of disturbance. Clearing soil shall also impact on biodiversity and plant species composition, causing fragmentation and destruction of habitats.

Site Preparation – Construction of roads and other structures The construction of roads is expected to cause disturbance of soil due to increased movement of heavy vehicles and equipment. As such, it may also expose soil to leakages from these vehicles and machinery. The activity is also expected to cause increases in dust particles in the air. The construction and utilisation of roads will also expose the area to the potential for increased run off as a result of compaction of soil.

Drilling, Blasting and Stockpiling Stockpiling of mine and plant residues will have several impacts including visual impacts. The stockpiles will modify the topography of the local area; this will in turn cause visual impacts as the stockpiles will be visible from some surrounding homes. In addition, the change in topography will impact on surface flow patterns due to soil compaction and the storage of overburden and top soil. Should this take place, the result may be increased silt loads which may impact on the aquatic ecology of nearby river systems. The activities are likely to generate noise and dust.

Removal of ore Removal of ore shall result in a loss of geology. The landuse and land capability shall also be altered.

Haulage Haulage of material is expected to have a number of impacts, the most important of which being the generation of dust and noise as well as damage to public roads.

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Storage and disposal of waste It is important that the disposal of hazardous and other waste be done in accordance with best practice. The incorrect storage or disposal of waste may result in the contamination of soil, groundwater and surface water. If waste is burnt, it will present a fire hazard.

Increase in Human presence The increase in the number of people on the site has the potential to increase existing hazards such as fire hazards and littering. These can pose a risk to the ecology of the area if not carefully monitored and mitigated.

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Regulation 50 (f)

11 Identification of interested and affected parties

11.1 Introduction The following Public Participation Process was conducted for the proposed mining activities:  Identification of key Interested and Affected Parties (all adjacent landowners);  Identification of key stakeholders;  Informing the key stakeholders of the process by means of correspondence (registered letters, e- mails and facsimiles),  Placement of a press notice in the Kwevoel 17th of January 2014 and Die Pos 17th of January 2014, informing the public of the process as well as inviting them to a public meeting;  Placement of site notices at the site; and  Correspondence with IAP’s and stakeholders and the addressing of their comments.  A public meeting was held on the 1st of February 2014 at the Thabazimbi Mine Cinema Hall.  Public meeting minutes were circulated to all the attendees of the public meeting.

11.2 Objectives of the public participation process

 To ensure that I&APs are well informed about the proposed Project;  To provide a broad set of I&APs sufficient opportunity to engage and provide input and suggestions on the proposed Project;  To verify that I&APs’ issues have been accurately recorded and considered and/or addressed;  To draw on local knowledge in the process of identifying environmental and social issues associated with the proposed Project, and to involve I&APs in identifying ways in which these can be addressed; and  To comply with legal requirements.

11.3 The guidelines followed for the public participation process The National Environmental Management Act, 1998 (Act 107 of 1998) Publication of Public participation guideline dated 10 October 2012 was followed with regards to the Public participation process. Refer to appendix D9.

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11.4 Interested and affected parties database The Interested and Affected parties are tabled in table 46 below and Stakeholders in table 47.

Table 51: Interested and affected parties (including adjacent landowners) Name Post/Email Post/Email sent Adam Barnard [email protected] E Attie Jonker [email protected] E Charlotha E. Fransolet P.O. Box 16812 Pretoria-North P Chris van Rooyen PO Box 1960, Bedfordview P Christopher York [email protected] E (Imberbe (Pty) Ltd) Dr Adriaan Martin (Arries [email protected] E Family Trust) E.B. Nieuwoudt [email protected] (DEFACTO INV 72 PTY E LTD EJ Pelser PO Box 541 Thabazimbi 0380 P Frik Eloff [email protected] E Gerald Chapman [email protected] E Hilton Botha (SHIRLTON [email protected] ESTATES cc or E [email protected] J. L. Human Posbus 244 Thabazimbi 0381 P J.H. Schutte Posbus 822 Thabazimbi E [email protected] Gerard Boshoff [email protected] E J.M. Greyvenstein [email protected] E Jacoba Johanna Aletta [email protected] E Maree Jennifer Gehm [email protected] E Lyon’s Lodge [email protected] E Marakele NP P.O. Box 800, Thabazimbi, 0380 P Mr Marius Schrenk - P.O. Box 647 Thabazimbi, 0380 P Familie Trust Michael White (Bethel [email protected] E Farm CC) MJ Raath (Rookpoort [email protected] E Beleggings Pty Ltd)

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Name Post/Email Post/Email sent Mr Barry Sigmund York E Mr Derek Grant Preece Mr Jan Coetzer [email protected] E Mr LLS van der Watt [email protected] E Mr. P.I. de Wet P.O.Box 141 Thabazimbi, 0380 P MSA Erasmus PO BOX 564 THABAZIMBI, 0380 P Petrus Albertus van P.O Box 7244 Pretoria 0001 P Niekerk PH Reeders PO Box 88 Thabazimbi P Pierre Mostert [email protected] E

Piet Steenkamp Posbus 1630 Thabazimbi,0380 P

Piet Venter [email protected] E

Tony Visser [email protected] E John Trollope [email protected] E Mr. Piet van Staden [email protected] VAN STADEN (THABAZIMBI Or E JAGPLAAS EDMS BKP - [email protected] Mrs Claudia Coetzee [email protected] E Mr Roelf Crouse [email protected] E Mr Gerrit van der Berg [email protected] E Mr Fred Stow [email protected] E Mr EN Sonnenbergs [email protected] E Cecil White Mr [email protected] E Mr Andrew Nicholson [email protected] E Mr Ampie Venter [email protected] E Dr Wilhelm Schack [email protected] E Dr Peter Oberem [email protected] E Dr Andre van Coller [email protected] E Charles Cornal Jones [email protected] E A. Le Roux Call M. Grobler ( Solu Gratia) [email protected] E J. Blaauw (Chairperson - [email protected] E Thabazimbi Business

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Name Post/Email Post/Email sent Chamber) George Ferreira [email protected] E [email protected] Tokkie Swanepoel ( [email protected] E TBBV, Chamber, TVF)

S. McKernan ( Champion [email protected] E Wildlife) [email protected]

W.T.A. Wilkinson Call

A.R. Ramogale [email protected] E (Thabazimbi Municipality)

B.K. Makaepea (AISP) [email protected] E

L. Erasmus (Manager –

Leopard Cave)

F.J. Niemand (Manager – [email protected] E Meletse Game Breeders) [email protected]

C. Barkhuizen (Chamber [email protected] E of Commerce) [email protected]????

B.S. Swanepoel [email protected] E

P. Steenekamp Call

E. Fouche ( Marekele [email protected] E Eco Estate)

Darius (Reserve Manager - Meletse [email protected] E Game Reserve)

Wilhelm Schack [email protected] E

E. Bisshoff [email protected] E

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Name Post/Email Post/Email sent

Ampie Venter (JAU) [email protected] E

Harold Braack [email protected] E

Lizzie Wilkinson Call

A.H. Combrink Call

Patrick Benson [email protected] E

Johan van Rooy [email protected] E

Roelf Crause / Talitha [email protected] E Crause

Mrs. Foti Contact through Fred Stow Meeting

Werksmans Attorneys Representing Mr Cosmos [email protected] E Cavaleros

Table 52: Stakeholder details Name Contact Post/Email Post/Email details Sent DOA – [email protected]. E Makananisi Funzani Mary za DWA – A. Matukane (Chief 015 290 [email protected] E Director) 1209 LEDET – [email protected] E Tinyiko Malungani SAHRA – [email protected] E Phillip Hine Thabazimbi [email protected] Env/Infra/Planning – E Piet Van Rensburg Thabazimbi LED – [email protected] Molatlhegi Peter E Motlhabane Thabazimbi LM – Private Bag X530, Thabazimbi, P Councillor Patricia 0380

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Name Contact Post/Email Post/Email details Sent Moshito Waterberg DM – Private Bag X1018, Modimolle, Muncipal Manager Mr. 0436 P M.V. Letsoalo L.P Nel [email protected] E Kennth Mabila P.O box 800 Thabazimbi 0380 P DMR – [email protected] E Thivhulawi Kolani DMR – [email protected] E Vinesh Devchander DMR – [email protected] E Aaron Kharivhe DMR – [email protected] E Tebogo Mangaba Thabazimbi – Head of 014 777 [email protected] Technical Department 1525 (code E Mr. C.G Booysens 155) Ward 2 Councillor – 083 278 Paul Scruton 9214

Ward 9 Councillor – 072 957 P.O Box 769 Moatsi 0548 Thabazimbi 0380 Birdlife South Africa – [email protected] E Simon Gear

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12 The Details of the Engagement Process

12.1 Advertisement Two advertisements were placed in two separate newspapers namely the Kwevoel which serves Thabazimbi, Dwaalboom, Northam areas and Die Pos serves Modimolle, Thabazimbi and Bela-Bela areas. The advert was in both papers on the 17th of January 2014. Refer to figures 40 & 41 below.

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Figure 40: Advertisement in the Kwevoel

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Figure 41: Advertisment in Die Pos

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12.2 Site Notices Site notices were placed at the following localities:  Thabazimbi town Absa bank parking lot,  Alma/Thabazimbi crossing,  On the corner of Eland street in Northam,  At the junction of Modimolle and Rooiberg roads,  Thabazimbi Local Municipality offices in Thabazimbi,  Thabazimbi NG church,  Thabazimbi Post Office,  Rooiberg town,  Thabazimbi local gym,  On the entrance gate to Aquila Steel exploration office in Thabazimbi.

Figure 42: Site notice in Thabazimbi town Absa bank parking lot

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Figure 43: Site notice Alma/Thabazimbi crossing

Figure 44: Site notice at the corner of Eland street in Northam

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Figure 45: Site notice at the Modimolle and Rooiberg road

Figure 46: Site notice at Thabazimbi Local Municipality offices

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Figure 47: Site notice at the Thabazimbi NG church

Figure 48: Site notice at the Thabazimbi Post office

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Figure 49: Site notice in Rooiberg town

Figure 50: Site notice at Aquila Steel entrance gate

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Figure 51: Site notice at Thabazimbi gym

12.3 Written Notices All Interested and Affected parties including landowners, and stakeholders were notified of the proposed project by means of a letter. The letter was either sent via registered post, e-mailed or faxed to the parties. Proof of such correspondence is attached in appendix D3.

12.4 Public Meeting A public meeting was held on the 1st of February 2014 at the Thabazimbi Mine Cinema Hall from 10:00-13:30. The public meeting minutes are tabled in Table 48 below. Refer to appendix D7 for the public meeting minutes, attendance register, and presentation.

Table 53: Public Meeting Minutes ISSUES RAISED RESPONSE HB asked on what the sensitivity map was based. JN responded that before Aquila Steel (S Africa) Pty Ltd (ASSA) started with prospecting, a biodiversity assessment was done by Christo Gagiano on a six monthly basis to gather historical data required for

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prospecting. An extensive fauna and flora biodiversity assessment was done on site for the two different farms from January last year over the entire spectrum of the year. The biodiversity report identifies all the fauna and flora sensitivity areas based on the biodiversity. HB also asked what Section 24G process is. JN responded that the S24G will be discussed afterwards to explain the process. JVB responded that Klipgat is part of the prospecting rights. Prospecting is continuing and not part of this mining right application.

JVB responded that it is the road that runs past the proposed mine on the Rooiberg road running parallel MS asked the following questions: to the mountain going down the road in the direction of 1. What the situation is at Klipgat. We don’t know if Thabazimbi, and where it joins with the tar-road. This Klipgat is in the picture or not? is route 1 (Southern route) as indicated in slide 24 on

the presentation. 2. The routes that were discussed earlier is

somewhat vague. There is a possible route to JVB answered that “the upgrades will not be started Alma and there is a possible route to Thabazimbi, until ASSA has received all rights/authorizations. it sounds as if Thabazimbi is the preferred route. When construction on the mine starts, we will also We would like to know which road will be used by start construction on the road. It is planned for 2016. the mine. The road will be upgraded by ASSA during  construction. By upgrading, we mean the road will 3. That road is currently almost inaccessible. How receive a new foundation. whether it will be a gravel soon will this road be used and who will be road or a tarred road, we are not sure yet.” responsible for the upgrades. If it is the

government, I would like to know. JVB responded that there will be approximately 400  trucks on that road per day. It may be possible that a

truck may pass every minute. JN said that they

received the draft traffic impact study the previous

week. “The study compares the four routes based on

the present volumes of traffic at crossings on the

roads. The technical detail will form part of the EIA, so

IAPs will be able to see it and comment on it. The 4. How does the mine see the use of the road, will study will make provision for alternatives and there be a railroad alongside the road, or will it be recommendations on what the best option is,:for used for vehicles? example, in the study one option was to use the route through Thabazimbi town this we removed as it is impossible to have more traffic on this already busy route.

DH Although we are in the scoping phase of the

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project and there are baseline studies and the report is in draft form the specialists can go back to the specialist studies and add in additional information during the process.

JN stated that the specialist studies had not been completed yet and that only the baseline studies were completed. He also stated that now that ASSA had their preferred mine layout the specialists would use this information and determine the impact on the environment. “This information will form part of the scoping study which you will have time to review and give your inputs.” AN asked when the last documentation would be JN responded that it is the EMP and it was due on 26 submitted to the Department of Mineral Resources March. (DMR). Would it be the 26th of March?

AN stated that “The decision will be made by the JVB responded that when you look at the mining right DMR based on all the documentation, whether to application, that is actually when you only start with a grant the mining right based on information lot of the studies. He also stated that they have found submitted on the 26th of March. Yet you are still not that 6 months from the date of getting a letter of aware of what is happening in numerous aspects. acceptance from the DMR you are never going to deal On the 26th of March a potential decision is going with all the studies and they will not be done in time. to be made on whether to grant a mining right. This is why we commenced earlier with the studies. Why was the mining right application submitted Then you have the information, and some additional when all the specialist studies are still in progress? information is going to come in. This is going to have He enquired why did they proceed with a mining to be incorporated into the final document. right. JN added that “these are the timeframe that they have, and what I see as the mitigating factor in the process is that when it is submitted on the 26th, the document will be amended after that. That amendment will be based on all the Interested and Affected Party’s (I&AP’s) inputs as well as any new information that becomes available in that six months after submission. The specialist studies will be finalized two weeks before the 26th of March, so the documentation will be available for submission in the EMPR.”

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WS stated that his question covers the traditional JVB responded that an economic impact study had land use pattern of the whole area (including the been done. Waterberg Biosphere, Marakele, and all the adjacent land, the Rooiberg area, the Sandrivier In the scoping report there are certain comments on valley and the Alma Plato). He stated that he has the economic impact study. JVB also stated that, asked repeatedly in the past that a specialist study speaking under correction, at the time that the study must be done in terms of the impact on the was done, there was no cooperation from the economy on the traditional land use patterns (with community. ASSA had to rely on information from the specific focus on conservation, eco-tourism, game specialist who conducted the economic study. MM breeding and agriculture). He felt that he got a added that the economic impact study specialist cold shoulder in the past from Aquila’s side, as (Gerrie Muller) used baseline information from a there was no indication that such a study would be variety of sources. conducted. His concern was that the mine would be placed squarely in the middle of this area, on JN responded that they were not ignoring WS, and the southern side of the Waterberg’s biosphere reminded everyone that they are in the scoping phase and that it would destroy the land along with its of the project. They started with the economic land use pattern associated economy. He also baseline study, and a socio-economic impact study stated that it is such a critical question, that he was also underway. JN also responded that the believes that you (Aquila Steel) are not willing to reason for the deficiency in the economic study was let these studies be done. He enquired what Aquila the lack of information. He stated that the problem is Steel is going to do about this specific question. that it is difficult to quantify the economic aspects of the farms in the area. The specialist asked questions on specific parameters, but was ignored and told that he could not get the information. JN said that they quantified the economic aspects based on provincial data (which he also questioned because it is high level data).

DH asked if the project team could send out specific information to the I&AP’s so that they could understand the requirements of the study. He said “We have to do justice to the study.” EBN stated that he’d spoken to Gerrie Muller JN apologized for any generalizations. He also said (economic specialist) personally and that he that the specialist was busy with the study, and that he offered him information regarding scarce game- would make contact with him so that they could reach farming in the area, and also gave him studies. He all the people. asked that there must not generalize that the information was not given.

EBN stated, in his opinion, that they conducted a one-sided impact study and that an impact study was not done on what is happening in the environment. He asked that WS’s request must be completed so that an impact study can be done on

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what is happening in the environment and that it should not be proved that mine is positive. EBN stated that he has been on his farm for 14 years and that they have a life of mine of 18 years. He stated that they scar the environment, but we are that ones who are going to live here. He requested that the economic study must please be completed.

EBN stated that if they asked the people of the community in the correct manner, they will receive the information. We need to establish the impact on the surrounding communities. EBN stated that there is a mistrust issue. He JVB responded that as a representative of ASSA he stated that “ASSA called in 2007 and told them took responsibility for the mistrust, he stated that they that they were going to do a little prospecting. did do that. In the first meeting, it was said “no more Some people asked what the impacts would be, blasting” and then blasting took place. JVB stated that but they were ignored at that point in time. There is it happened, and they cannot take it away. He stated an EMP that gives an indication of what activities that they have progressed from that point. They will take place like: which includes no blasting, amended their EMP’s and added to their rehabilitation roads 1.6 to 3 km. These are simple things, but guarantees. JVB stated that these guarantees had they can have a big impact on us. If you are man been approved by the DMR and were going to be enough – tell us how many km of roads there are, submitted in the next week. He stated that the a minimum of 30 km. It is permanent damage. You guarantee was roughly R 900 000 for Donkerpoort. have a rehabilitation fund of R50 000 to fix those JVB stated that everyone had to keep in mind that roads.” ASSA had budget allocated to repair work where they have constructed roads. He stated that it is not He asked that JVB to please address the issue of necessarily always incorporated into the amount that trust. EBN stated that he does not trust JVB (in is in the rehabilitation plan. terms of ASSA) as he had blatantly lied to them and promised them that there would be no blasting. He requested that ASSA be open and transparent with us (I&APs). He asked “Why do you need your baseline before you have to apply for your water license? You couldn’t care less about my water.” CC stated that “this mountain is iconic, it has been DH said “lets allow ASSA to answer. There’s a lot of here for millions of years. You come here and you people who also want to ask questions. “ say 18 years, you will make a big hole there, bugger everyone else. We do not care about your JVB stated that they say we fooled them, but that it is mining. It is a hit and run, you bugger off and leave their opinion. He stated that when Shangoni came 600 workers behind and who is stuck with the aboard on this project, they conducted an problem? We are. It is a disgrace what you are environmental performance assessment. Based on doing with this mountain. This is not the last that that, ASSA looked at EMP’s for both Klipgat and

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you are going to hear from us. All these people, Donkerpoort, and amended them. He stated that the are good people (I am not saying you aren’t) but IAPs had access to the amended EMPs as well and you are doing it just for money. This is our country that in those EMPs the guarantee is roughly and we are going to protect this mountain. Best R900 000-00 for Donkerpoort. you pack your bags and go. It is not fair, if you do pack up and go and leave all the pollution behind, JVB stated that in terms of the waste dump, in terms you have about R50 000 to rehabilitate 33 km. You of overall rehabilitation there would more than likely be fooled everybody. What happens if my water gets a point where ASSA would have to grass it and try to polluted? What are you going to do about it? This make it visually acceptable and, like the surrounding mine dump that you are going to have, are you environment. JVB stated that in terms of their going to plant grass? Are we going to get all the mitigation, those are the aspects that they would have dust and noise? These guys are going on camps to address. and they are spending millions, tourists coming JVB stated that another aspect that was named is here will hear your mine going on, I would like dust and in terms of that there are specific rules to answers.” which they must abide. “As far as the EIA and law side is concerned, I have my attorneys on that, I am not going to get JVB also stated that he fully understood the I&APs’ involved in that.” frustration but reiterated that a mine is more visible than prospecting activities and people take chances – “and it is unfortunate”. He also said that they constantly had a fight with their exploration offices, because ASSA make certain commitments and then they go and do something else.

JVB then addressed the water quality issue. He stated that he could not answer it at the moment, except that from his understanding the ore body is an oxide ore, so there is no potential for acid mine drainage. From a siltation point of view, those are aspects that ASSA would have to look at and understand better. That is why the geohydrology study in required.

In answering EBN’s question, JVB stated that from a water level perspective the information was needed because ASSA needs to apply for a water use license. As part of everything else is the geohydrology; ASSA “needs to understand what the potential impact on the ground water will be, where groundwater is located and what the impacts on your (IAPs) land will be from the actions that ASSA take. We require water for dust suppression. We need to understand if there is enough groundwater available without impacting you (IAPs) so significantly. Can we use groundwater or do

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we have to go to the Crocodile river system to get water from there?”

JVB responded that from the perspective of putting down money, when you start a mine you have to do a rehabilitation guarantee again, which is based on premature closing. This is a calculation that still needs to be done on all the impacts that we will have. The calculation then gets submitted to the DMR, who can approve it or request a recalculation.

DH asked that this discussion must be continued later, as he wants to move on to other people with questions. CC enquired why they don’t put up a hundred or a hundred and fifty million rand with the mining DH requested that Wilhelm and Jan, in terms of this commissioner and say that money may be held in specialist study which is close to many people’s the event that we do depart so that it all can be hearts, take this up in a focus meeting or send out fixed. “Give us something, you can do what you terms of reference to the from the specialist to IAPs. want and if it does not work, goodbye.” CC stated that they are presuming that it is going to work. CC asked who approved the R50 000 for the rehabilitation of the road. He stated that they can’t answer that.

AV asked the following questions: WS stated that he represents 14 farmers on the Alma 1. Is a representative of ALMA present at this Plato. meeting? DH asked if WS was going to give feedback to the  AV thanked him and stated that he members. He also asked for the contact details of the  was worried because he also spoke to members of the Alma Plato.  the people from Alma, and they did not

 know about this meeting.

 He requested that all the farmers from

 Alma must also be invited to this meeting.



2. AV asked if a representative from SANPARKS is JN responded that they were invited, but that they present at the meeting. were not present. 

3. He stated that he saw on the internet that impact JN responded that there are 8 species, and it would study on bats was done, and that there are bats in be addressed. that cave that are a threatened species. He asked

whether it is going to be addressed.

 AV enquired if the cave is inside the mine area.

 JN responded that it is outside the mine area.

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4. Lastly he asked whether a specialist study been done on the colony of vultures breeding on a very small portion of the ‘kransberge’ directly north of JN we will look into that and commission a Cape the mine. He stated that it is very important that a Vulture study. specialist study be conducted on the vultures. MS stated that regarding the study which WS Noted. talked of earlier, no contact was made with him throughout this whole process. He stated that they are welcome to come speak to the people of the Zandrivier valley. EF made the following statements. JN responded with the following statement: 1. “It was said that you are still in the scoping phase, “The EIA consists of 4 processes. The MPRDA and that you have got 2 months left. I cannot process, the NEMA process, the WULA process and understand that, you have already been busy for 2 Waste process. The MPRDA process started last year years on the EIA.” July with the application of the mining right and scoping report being submitted and EMPR in March 2014. In the NEMA process the EIA is only starting now. The EIA report will be submitted in September.”

The specialist studies from a geo-hydrological 2. He stated that the same goes for the geo- perspective have been ongoing for almost a year and hydrology tests that were done and still need to be a half. Assessments have been completed on farms done. It is going to take 6 months. He asked how where permission was granted. We did an assessment these studies would be completed in two months on Randstephne and Donkerpoort. The only reason before the documents must be submitted. He why we want to conduct more assessments is asked Jan Nel to do the studies (throwing because we want to ensure that we are covering all chemicals in and assessing how far they travel). the areas. The outstanding farms on the left will be covered in the next two months. The quality information gathered will be entered into the existing model. 3. Ecco estates are busy with their water license, and have done some studies. It was found that the Noted. Estate’s water comes from that area.

EF asked the following questions: 1. “In this document it is indicated that there will be an application for the storage of coal, but in the JVB responded that the storage of coal is a listed presentation no mention was made of coal.” activity in terms of Regulation 544 as indicated in the Background Information Document. He stated that ‘the storage of ore or coal’ is a phrase from the Act. JN stated that the activity covers both ore and coal 2. Was the impact study for surface- and together, but it applies to ore in this case, not the coal groundwater done in the normal rain season or in sector. the flood season?

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 It is a pity that you do not make it available before JN responded that “the hydrological study focused on you submit it to the DMR, so that the questions the entire rain season for the whole year. Flood lines can go in to the DMR. and flood seasons were incorporated.”  JN responded that during the scoping phase 12 of the 15 specialist studies were made available, on the Shangoni website and comments were received on the reports. We did receive comments on the reports. He stated that for the NEMA EIA all the information would be available before the submission of 3. In terms of the application for section 21(c) – the documentation.. deflection of underground water, is that pre- empting the deflection of water? JN stated that it is: ‘impeding the flow of surface water.’ It would be relative to the water coming from the mountain. He explained that if one is going to impede the flow of water from the mountain, then the party would have to apply for a section 21(c) & (i) water license.

DH indicated that “Section 21 (c) refers to surface water as per the act not underground water.” 4. EF stated that, in terms of the 3D pictures, it would be good for everybody to see a section from 360º JN responded that it forms part of the Visual Impact advantage points of the dumps (to see the visual Assessment. This would be incorporated into the impacts). study.

5. “In the presentation it was said that at the start of mining, your overburden is not that much (on slide JVB responded that on pre-stripping was not 20). So if you say in the beginning it is not that necessary (as displayed on the Presentation). much, it is going to get more to the back of the mine as you mine. What is the stripping ratio going JVB referred EF to the map displaying the footprint of to be and how big is this mountain going to be that the rock dump. This is the final dump. you are going to create?” 

 EF responded that it is a footprint, but that he wants to know how high this thing is going to be. JVB responded that it can only go as high as where the pit is, it can’t go higher.

DH stated that if you do a 360º views cape on the model that these specialists are going to run, it would show how visible it is going to be.

AN enquired how they are going to determine the JVB responded by saying that he had started off by

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final layout if the specialist studies are not even saying that it is the proposed layout. He said that he completed yet. named the different options that have to go through the impact assessment to finalize where it would be. He stated that all those positions had been provided for the visual assessment and other assessments. This was done to decide what the best position will be for it.

6. EF then stated that from studying the scale and DH responded that the height and the extent is exactly picture – they are going to have a ‘lekker’ what goes into the model, and then they run it. mountain. JVB responded that ASSA would get backfill material 7. EF said that it was stated that there would be no from the waste rock dump. Not backfill like you have slime dams, but with the dense media separation on the Platinum mines. (DMS) approach system in future “ASSA is looking at backfilling some parts of the pit.” He enquired where they would get their backfill material if the mine won’t have a slimes dam.  8. He stated that there is going to be two distinct JVB stated that he could put the I&APs’ minds at dumps, the one would be for run of mine that ease: “as when material has gone through DMS, it would be sent as is and the other one would be a would be the same size as the material that is direct dense medium separation dam. The impact study shipping, which is -32 + 6. That is the lump portion for the groundwater pollution must take this into which is approximately 65% of the product.” He further account. stated that there would also be a portion which is -6 mm to +1 mm, this would be dewatered in a belt-press filter, and the resulting cake would get dumped onto the plant discard dump. He stressed that there would be no tailings dam but there would be a pollution control dam which would capture all the polluted water that would run from the dumps and the infrastructure areas. The captured water would be reused in the mine’s processes, instead of letting it run into the environment.

JVB responded that the quantity of material that would EF stated that he is familiar with the cakes, and be so little compared to the rest of the dump, that it is questioned whether the cakes that are created is not even rated as a risk. rehydratable. He stated that his reason for asking JN added that for the storage of that, ASSA would is because when there are heavy rains coming need a water license. If the department does not down, it will form sludge if it is rehydratable. accept that, the mine would have to make another decision on how to store it. 9. Lastly EF asked if ASSA would be doing blasting close to the vultures, and what type of impact it JN responded that he will make sure that it is included

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would have. in the blasting and vibration specialist study. EBN stated that they “need to include the scarce Noted. game breeding as well in terms of what you are planning to do here.” FS asked that a fire risk analysis study be Noted. completed as fires pose a risk. WS stated that he became aware of the Gatkop JVB responded that “firstly in terms of the Limpopo cave 40 years ago. He stated that he found Environmental Act, one needs a permit to access the archaeological artefacts deep inside on the first cave. Secondly the cave has caveous diseases and floor. He said that he had also talked to a lot of that is the reason why it was locked. On the sign it black people who regard this cave as a sacred says that we can be contacted if somebody wants to place, they go there for spiritual reasons (possibly access it.” from as far back as 400 – 800 years). It was always and open path, until he recently noticed that there is a big lock on the gate and a big sign- board saying that it is a criminal offence to enter the cave. His questions to ASSA are the following: “Would you regard it as a criminal offence when black people go there to conduct their spiritual activities? Why is ASSA all of a sudden preventing them from going there?” WS interjected that there is no contact number on Noted. the sign.

WS stated that there is a little yellow sign board JVB responded that it is on their land and in terms of hanging skew there with the name of a black LEDET they must prevent access, and as a result of person, and on the sign it says that he must be the disease in the cave it is for their own safety that it contacted when they want to enter the cave. There is being done. JVB also stated that the religious is no contact number. He enquired what the people who go into the cave, make fires which affects people must do when they want to do their the protected species of bats in the cave. We (ASSA) spiritual, traditional activities. have to try and handle both of those aspects. We have had a public meeting with the people who mainly take people into the cave, and they threatened us. They did not attend the meeting, so we had to send them a letter because we had to decide on a management plan for the cave. They replied that “you (ASSA) is not our boss, we report to a higher power, we will do and break the law as we wish.”

JVB responded that they have done that on numerous occasions, and that was the response that they got. WS asked whether they have “consulted with the black community about the closure and the fact that it is a criminal offence to come there and do JVB replied that the bat people came out to assist

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their religious activities?” them because they want to create a management plan for the cave where the local people can still utilize it for WS stated that he was talking about the ‘black’ their religious experiences. However it needs to be in community, not the ‘bat’ people. a controlled environment.

DH requested that feedback be given after the meeting regarding the meeting about the cave. AR (introduced himself as the chairperson of Thabazimbi Municipality public account and stated that he is also representing Waterberg). He stated that if someone is doing wrong on finance or in Thabazimbi, they will be arrested immediately. AR stated that he was only attending this meeting to observe. He stated that all problems must be identified, and that the community present at the meeting must be able to contribute to the solution of the problems. He stated that they cannot continue with the project while problem is still being identified. It does not help that you come so far to destroy everything and then you just leave. He said that they talked about the ancestors, and that the difference between black and white people must be identified. Black people believe in ancestors, and the ancestors are here. He stated that therefore you have to meet with all the stakeholders of Thabazimbi to deal with this issue. Every person should be satisfied. After that we analyse all the problems, and we deal with all the problems going forward. TS stated that she was born in Thabazimbi and EB responded that they are specifically aware of the grew up there. At the mountain where they have points that Mrs Swanepoel mentioned. started prospecting, is where Gatkloof’s water comes from. She stated that “that small area where ASSA prospected, had already had an impact downwards.” TS stated that her father has fountains on the JN responded that it is part of the study. farm, which has already started delivering less water as a result of the activities in the mountain. DH told Mrs Swanepoel that she was welcome to send She stated that this area in the mountain is a great through more information regarding the impacts. source of water to the surrounding area and as a result is an important matter. She asked if they have included the fountains in the studies as well. AN stated that in the Presentation on the first slide JN replied that the minutes would reflect all the issues

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it is specified that they must use a comment sheet from the meeting. attached to the Background Information Document (BID). He would just like confirmation that everything they have raised, in whichever way, will be addressed.

He further stated that on one of the slides it was DH said “we have taken note of your concerns.” indicated 1 million tons per annum starting 2016. He stated that in terms of timeframes this seems very unrealistic and not accurate. “There are numerous duplication of information that is inaccurate in documents that have been provided to us. This makes it very hard to understand what is going on (gave an example of the scoping report which contained a statement of 336 employees, and now it said 446 in the BID). There are a lot of inaccuracies and all of these things have significant impacts.”

AN requested that the information that is given through to them must be accurate. He also requested that when documents are supplied to them with changes, the changes must be highlighted.

AN also commented that the documentation that Noted. was launched on the Shangoni website, was draft documents with track changes in. He stated that from a review point of view of an I&AP it is extremely frustrating wondering if the information is accurate. “From the legal authorizations processes, in terms JVB responded that from his perspective and a mining of history, you can understand the frustration and right perspective; ASSA would not commence with worries of the I&AP’s because in the past, there anything which they do not have authorization for. has been in things which started illegally. The concern is that potentially by the end of this year you might have a mining right. “AN requested that ASSA Steel must make a vow to all of I&Aps that they will not proceed without all authorizations in place.

AN requested in terms of legal authorizations, that JVB could look at the rezoning requirements from the municipality point of view and also evaluate the

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requirement for an air emission license for the stockpiles.

In terms of the specialist studies, AN requested that a meeting be held “where all the specialists are present, and it can be an information sharing session where all I&AP’s would get specific answers from specific specialists.”

In terms of the process description AN said, “it is literally six weeks before you submit the final documentation for a mining right. The information that is available at this point in time in terms of what the impact will be on each individual here, is completely inadequate. We have no indication in terms of construction, how frequently you will blast, the traffic volumes and logistics. The information submitted thus far is completely insignificant, and cannot be used to provide a meaning. AN requested more detail in terms of the process description so that it more understandable.” EBN stated that “ASSA needs to live up to their JVB stated that he “cannot give them any commitment commitments.” that we will only start once everything is in place. I can AN added that some of the activities associated give you commitment that we won’t start an activity with mining don’t trigger EIA authorizations. that we don’t have an authorization for.” HB stated that the cave could not just be closed DH stated that they would have to go back to the off. If you want to evaluate the impact on the bats, community, and the study must be revised to take the you cannot close off activities with which they are comments into account. involved.

As far as the economic viability / economic Noted. process is concerned, the Life of Mine (LOM) does not determine that, the impact of the mine is going to extend another 50, 60 or 100 years. So when we look at economic impact, we have to look at the entire duration of that impact and not just LOM. Tourists will be impacted upon.

HB also stated that Johann said there was a low DH the minimal risk refers to residual risks. risk or minimal risk for material to flow down and seepage. He stated that there is either a risk or no risk, it can’t be a minimal risk. EBN stated that there is a discussion about 446 JVB responded “no”. people, he asked if they would live there on the

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mine site.

He further enquired if there will be a town there, Once again JVB said no. because his water comes from there.

He also stated that one of the biggest impacts will JVB responded that he “cannot give him a response at be the transport from there to the railway which will this point in time”, as he doesn’t even know, “Transnet lead to dust. does not even know. At this time, the best information He stated that there must be more clarity over this that we have is that it will be the Thabazimbi line.” at the moment. He also stated that he suspects JVB stated “that the problem is that sometimes you that it is kept ‘velvety’ at the moment so that the have to apply for some things that you do not even people don’t ask too much questions. EBN also know anything about yet. Unfortunately if you don’t said that he believes there is an alternative have a mining right, then they don’t even look at you. towards Alma, and that he thinks that it will have They have to be convinced that you are down the road less of an impact. and that you know this is going to be real before they start committing.”

JVB stated that in terms of the whole route out of the Waterberg, there are five phases which will improve EBN stated that he calculated that the mine is the capacity of the line from 4 million tons to 27 million worth R14 billion, so they have enough money to tons. mitigate. He stated that “if the mine is going to He also said that they must rely on the fact that they destroy people and their businesses, you must will keep to their project plan and that the project plant expect that we are going to stand against you as will halt right there if Meletse does not get capacity on much as we can.” We have not started yet the line. On the Alma line, for example, it will only be because we do not have details. He stated that us on that line. There is a lot of factors that Transnet there has to be detail on the plans for the roads has to study for one mine, but right now it looks as if and transport. Transnet is going to tell us that we are on the Thabazimbi line. JVB said that he can say for sure, that the road will be upgraded as will be their responsibility as they will not be able to get any ore out without an upgrade. MS stated that the Thabazimbi mine with their JVB responded that he does not know Thabazimbi’s stockpiles along the road is currently using the background and is therefore speaking under road, they are not using the railroad. He enquired correction: The ore which is placed at ‘Meyer’ mine is why this is. The Brits road is full of pot holes. owned by ArcelorMittal and it is ArcelorMittal’s responsibility to get it from there to Vanderbijl. He said that it is not the Thabazimbi mine, but he may be wrong.

DH stated that they must come to a point where they can give information from the traffic study. This must be done so that the I&AP’s can look at it objectively and possibly understand the impact better.

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JN responded that there is a study that will cover the roads. EBN once again asked where the 446 people were JVB responded that in terms of accommodation “MM going to stay. may have a bit more information on that, but it will basically be Thabazimbi, potentially Rooiberg and maybe even Alma. We have no plans to establish a village on the mine. Thabazimbi’s town planning may have available space and in the Social and Labour Plan (SLP) it must be look at how they can assist people in obtaining their homes.” AR stated that they are not going to take people DH Your comment is noted. from outside Thabazimbi for work, while they have people in Thabazimbi, who have the relevant qualification, looking for work. He said that we have to deal with this issue and we have to provide oversight. JB stated that “it is important to understand where Noted. people are going to live. If you look at the local infrastructure it cannot serve today’s population. The Waterberg is a year behind schedule, sewage treatment plants are already not up to standard. The economic study which everybody is asking for, including the chamber of business, must not focus solely on job creation from a mining perspective, but also on what job opportunities will fall away.” JB also stated that “although mining is a primary sector, the business chamber has quite clearly established that for the next 20 - 25 year tourism will keep this town running. Look at what is viable with mines, not after mines. “ “With reference to the traffic impact study if the chosen route is used, there will be an impact in town as well because who would be willing to drive past 400 trucks to get into town. It must be established how the road network will look and it must be ensured that the towns business does not suffer from it.” JB made reference to the local economic DH indicated that it would be actioned. development plan which was presented to the municipality, enquired if they could see a copy of it and as stakeholders have an opportunity to comment on it.

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PS asked Johann if he was sure that they were JVB asked to who it belongs to. going to upgrade the Thabazimbi Southern Road, and no other roads. He stated that in the week there were people measuring the road saying it was for the mine. After 6 km on the road, it has been locked for 10 years as it is private property.

PS responded that it belongs to the landowners JVB responded that he was not aware that the road (Grobler, himself and his neighbour Richard). goes through like that.

DH responded that what he thinks is also important, that “if they do the traffic study they will have maps which will display exactly what the roads are, along with its names and numbers.” He stated that this would ensure that the I&AP’s would be able to see if is a road that would affect them. EF asked regarding the road infrastructure, before JVB responded “there will be a noise from the it came to this amount of traffic, if the industrial conveyor running constantly.” He stated that they did engineers looked at alternative means of transport look at it, more specifically they looked at cost of that (i.e. conveyor belts or railway) while they were towards Alma using conveyor and even rail, and that it doing the feasibility studies. He stated that if they is a little bit more complicated coming through the put a conveyor belt or a railway they can totally Thabazimbi’s side. enclose the thing and there will be no dust and no traffic. JVB replied that it will be the company who will make EF stated that “if you look at impact studies, he the decisions and whether it will be approved will be thinks the decision of cost-effectiveness versus decided by the DMR. impact assessment should be weighed against each other.” He asked who will make the decisions, if it is the company or the DMR. JVB stated that the question comes down to a number EF also asked if they as the public would see the of aspects, “ASSA needs to find a route that can be decision as well as why it was made. He stated utilized, the second issue is that if they have a that an industrial engineer will tell you that a truck conveyer for example, it will be running for 24 hours is the most useless mode of transport. He stated and you will be able to hear the conveyor working. that he is asking that they must not just look at it One has to weigh up all those aspects. At this point in from a capital cost perspective. time, depending on what the impact study tells us, we will still put forward that the proposed solution at this stage is trucking.”

DH suggested to JN that in terms of the EIA study, they show all the alternatives that they looked at and EF stated that it is exactly what they want, as in the pros and cons. the presentation there was only made mention of

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trucks and no alternatives. Noted. MS stated that in this study they cannot only look at your costs, “you must look at the neighbours’ costs as well.” He said that they are going to destroy him with 400 trucks going through there, he stated that they can buy his farm if they want it. FS stated that this activity is affecting their JVB stated that he cannot answer the question business and investors and at face value he can because he does not have that type of background. see that this activity is essentially sterilizing that investment completely. “It is simply slap-bang, He stated that the only thing that he could say is that, dead centre of our proposed lodge, it also affects to his knowledge, when the principals bought the land, 75% of the view line from the reserve itself. This they were aware of the prospecting right on Meletse essentially is taking away an entire economic and everything else. avenue that was there for us.” He asked if he is “at the moment correct in assuming that they are at JN stated that it will definitely be included in the the moment directly at risk or is there any form of economic study. compensating mechanism or are you taking the entire economic spectrum out of the loop for us.” He added that of course land values are directly affected by this as well. DH stated that a person needs to look at all the FS also stated that they must not only look at what specialist studies to get the bigger picture, it is not just is here today, they have to look at future visual, water quality and the economic study. investment potential of the area, where the activity will essentially sterilize the area for much longer than 18 years. TS stated that she would just like to add to what DH stated than the specialists will sit around a table JB said, “if you look at the business chamber, one once they have all their findings and discuss can see that there are a lot of opportunities, but if everything. He also stated that now is the time for the you go look at the local government with all these I&AP’s to ask all the questions and give their inputs. shortages, meanwhile there is a lot of things that are happening, but each of us keeps it to JN responded that the traffic impact study did consider ourselves.” She stated that she thinks it can be a both. An average was taken of the amount of people big opportunity for everyone to work together and per vehicle that will drive to the mine. He also stated make decisions. “But certain people in certain that morning and afternoon peak times were taken into positions just decide that there will be a mine, and account. then he starts building a road, and at the end of the day it has a big impact on the normal people because the farmer who has only a 100 ha farm, his farm will be sold for R 10 000 per ha, and this in turn will impact his estate planning.” She requested that this must be kept in mind in the long term. TS also stated that if the mine should

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have accommodation there, it would also impact the traffic.

It was also stated that the impact of the workers driving to work and the impact of the transport of the ore are two different things. JN responded that it is in a draft format. It was enquired if this study has already been done. DH stated that baseline information is important as it is a screening of the receiving environment. “It is EBN stated that the baseline is not the baseline, important to understand what the issues are when you as in 2007 they started activities in the area. He start with a project or with layouts. Then studies must stated that “if you look at the roads it looks like the be completed with inputs from the departments and mine’s roads, along with the dust. It does not help I&AP’s.” that you baseline it now.” DH asked if AN is asking for a meeting with the specialists. DH suggested to Jan and Johann that they AN stated that the people would like to go to the must come together and talk about this meeting. JN specialist and have him explain in layman’s terms said that they are talking about 19 specialists. what a baseline study is, what air quality is, etc. Have offsets been considered? JVB stated that he thinks that they have committed to bring the specialist studies here on the next public meeting, on the 3rd of May. “We will definitely do that.” EBN asked if it the specialist meeting could be held before the 26th of March (before the EMP is JN added by saying that this is not the norm to have submitted). specialists defend their specialist studies. Jan said that he could understand their request, but that he tried this once a few months ago and it ended up in a disaster. EBN stated that it is less about a reliance with the This was because the people who were listening to the specialists. “We do not have the opportunity, you specialist didn’t believe what they were saying. the don’t know who the specialists are, you don’t know first potential problem that participants could run into. their CV’s, and you don’t know what their JN stated that he had no issue about bringing the experience is.” He stated that if he could speak to specialists to discuss with the I&AP’s, but was weary the specialist and tell them where he is, and ask of having all specialists give presentations. He stated them specific questions of concern it would help.. that he would like to have groups which go with “We are here ask the questions, but they cannot specific questions to specific specialists. answer us because they rely on the specialist study, someone needs to answer”.

EB contributed that they do not have to bring all 19 at once, but that there are some serious issues that need to be addressed. MS stated that the transport specialist must be JN responded that he saw the draft traffic report and

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present. that “it is a good study which brings all the impacts and is showing the number of vehicles etc. and it will address all the concerns related to traffic.”

JN responded that he agrees, the safety risk regarding MS stated that the Klipgat T-junction is a blind the vehicles on the roads have been addressed in the corner. He said that he would like to see how they traffic-study. get a truck in there. JVB stated that if the Traffic study shows issues they EBN responded to this by saying: “this is the would indicate mitigating aspects such as to move the chicken and egg, tell us what you are going to do, point of connection and the length of the sight lines, then we can raise issues. We need to have a because ASSA still need to go to SANRAL to apply. definitive view of what is happening and then we can respond.” DH stated that “specialist studies get triggered through significant issues, therefore the IAP’s must write down their issues so that they can ask the specialists at the next public meeting.” CB stated that “there are people present at this meeting that do all their business here, and there are too many what if’s.” He also added that “the presentation that was presented did not really say anything to allow people to make a constructive decision about their futures.” He stated that he thinks that a lot of homework still needs to be done. “This thing started in 2007, and this is all that has been done to date, I don’t know how they will start mining in 2016. There are too many things of: if this happens, then this will happen.” He stated that there are not enough constructive answers, and that trust has been an issue since the beginning of this process. AV asked that the reports be made available on Noted. the internet so that the IAPs could go through it prior to submitting. AN stated that “this is more for the I&AP’s to understand, in terms of getting a mining right – there are three main documents which form your legal rights. Those document are: Mining Work Programme (MWP), Social Labour Plan (SLP) and the Environmental Management Programme (EMP). You need to adhere to those three documents, to ensure that you mine legally and in an acceptable way as per your environmental authorizations.” He stated that in terms of this

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process, the SLP and the MWP are already finished. “Theoretically the MWP must state how they are going to mine, how they are going to process, how many people are going to be there, labour cost, revenue etc. So based on the fact that this MWP is finished and was submitted in September, I would like to understand a few things that are in this document: 1. What was in the MWP in terms of transportation? JVB responded that the trucking was included as well 2. How many kilometres did you quote? as the cost of trucking (no route was included). 3. What environmental costs did you add for premature closing? JVB replied 40 km. 4. How that is calculated and is that in the documentation? JVB responded that it is the one that he calculates, 5. What is your schedule in terms of when you will which is not the same as the one that they calculate, start construction? and it is R 54 000 000. 6. Do we get a copy of that document? 7. May I have a copy of the document JVB responded that it is in the documentation in the excluding the financials? MWP, and they give a very specific format in which it has to be calculated.

JVB responded approximately 2016.

JVB responded “no, you can request a copy from DMR. The DMR very specifically stated that we may not give you a copy of the document.”

JVB responded that he would consider it, and get back to him. HB stated that he thinks that they are being against each other. “We are looking at an existing life and we are potentially going to stuff it up through incorrect activities.” He stated that “we are not looking at today, but the next day and the next day.” He stated that “you (Johan van Breda) stand there and you say no, well then I say we say no, and the hell with you.” CY stated that “you want us to give you all our JVB responded that there is a misunderstanding in financials and all our pertinent information about that sense. In terms of the MWP he could not give that our water and our usage thereof, but you cannot out. He said that he was very clearly told by the DMR give us any sort of guarantee that that information (which is his regulator) that he may not give out that won’t go anywhere else. That was said at the last information as it is not an approved document. He meeting, that the quantities would stay in-house stated that IAPs were welcome to apply for it from the

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and any new information that you got out of those DMR. studies would be given back to us. So what is the point? Why should we help you if you are not prepared to help us back?”

CY said to “forget about that stuff, we are talking JVB responded that he would give them the same about the economic information.” type of detail that they give him. “You will not give me your detailed information, you will tell me this is your business, and so forth, then I can share with that same detail of information with you. It is a question of we sharing all the baseline information and our process, you are requesting an economic impact study, and in order to do that study efficiently and properly we need that information from you otherwise we will base it on incorrect information.”

He stated that the water studies’ information would be given back.

JVB responded that “any study that we do, you get information and feedback on. I have got no issues with providing information from the geo-hydrological study, and for that matter, any other baseline study.”

JVB said that if he did say that he cannot guarantee that it wouldn’t go anywhere else, those studies get compiled and would not specifically say that: “Mr York earns R X million per month.”

DH stated that “a non-disclosure agreement should be created so that the numbers are only used in the modelling for crunching.”

CY stated that it was also said that “you couldn’t guarantee that it wouldn’t be shared.”

CY stated that he would be happy with that. DH closed the meeting. He thanked the people who contributed with the technical information and all the other people who took part.

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13 Details regarding the manner in which the issues raised were addressed

Table 54: Comments and responses report

INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY A letter dated the 13th of December 2013 Umhlaba Environmental Consulting CC has received from Andrew Nicholson from been commissioned to act on behalf of Calshelf Umhlabla Consulting Investments 171 (Pty) Ltd, Calshelf Investments 172 (Pty) Ltd and Calshelf 173 (Pty) Ltd

(hereinafter referred to as “the owners”) in all matters relating to prospecting and mining activities, on portions of the Farms Buffelshoek 446 KQ, Buffelshoek 680 KQ, Donkerpoort 448 KQ and Dassiesrand 447 KQ, located within the Thabazimbi region.

The owners land is adjacent to the land covered

by the submitted mining right application by Aquila. Hence, the owner is an interested and affected party (I&AP). The owner utilizes the land as a private game reserve.

This letter serves to provide an official objection on behalf of the owners in relating to

the mining right application (referenced above) submitted by Aquila Steel (Aquila).

Overall, the documentation provided for review is inadequate, flawed and not detailed enough for interested and affected parties (I&AP’s) to effectively partake within a legally required process.

Through the documentation provided, Aquila continues to disregard both the environment and I&AP’s.

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY Based on my review on the documentation provided, I could generate extensive comments, however, this feedback aims to focus on the main issues which need to be rectified before Noted. The specialist studies were justifying the time to provide an in-depth critic. updated and reloaded on Shangoni’s website. Specialist Reports:

A number of the specialist reports downloaded from the Shangoni website (on the 14th November 2013) are draft copies and some even include comments made by other The specialists CV’s will form part of the reviewers. This is very unprofessional. An I&AP EMPR annexures which will be cannot be expected to trust the information or submitted on the 26th of March 2014. review an incomplete report.

With the exception of the Blast Management Consultant, no other CV of the specialists has been made available, leading me to question that the specialists appointed are suitably qualified or registered with the relevant bodies.

As an example of my concerns (on all Noted. The specialist studies were specialists) I have specifically provided feedback updated and reloaded on Shangoni’s on the Alternative Land Use Economic Impact website. Initial Assessment – Appendix 11.

Although this report was reviewed, it must be stressed that the copy available for download off the Shangoni website is not a final copy as the report still contains “tracked changes” that have This study will be updated as part of the not been accepted / rejected and balloon EMPR submission. Refer to annexure comments from what appears to be an internal E13. review.

A major concern with the report is that the first paragraph of the introduction shows the bias of the report. It states “The objective of this initial economic impact assessment is to establish the degree to which the Aquila Meletse Iron Ore Refer to annexure E13. This study has

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY Project (“The Project”) is a better alternative land been updated as part of the EMPR. use for the TLM.” It is very concerning that the “objective” is to prove that mining is better than other alternatives rather than an objective to evaluate the economic benefits of the mine

versus the other alternatives, using facts. Given the above, this report cannot be seen as in independent evaluation of the economic benefits of mining versus other activities.

The report continually focuses on the life of mine Noted. (which is considered 20 years rather than the 18 years stated in the Scoping Report) or an economic generation (32 years). If these are the

time frames considered, I fail to see how the report considers sustainable development - “Development that meets the needs of the present without compromising the ability of future generations to meet their own needs”. The time frames considered cannot consider / determine if the future generation are able to “meet their own needs” as their

requirements are not considered in a 20 or 32 year period.

Throughout the report reference is made to a number of facts that have been obtained from various sources. However, only those which refer to the company’s data base itself have been referenced. None of the information

obtained from external sources is referenced. Referencing the source of information is standard practice in any scientific field and the EIA process is a scientific field. How can this information be checked / clarified if the source is not provided? Considering the independence of the report is being questioned, it is vital that facts can be investigated by I&AP’s.

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY Due to the fact that the main justification of Refer to annexure E13. This study has proceeding with the proposed mine is the socio- been updated as part of the EMPR. economic benefits, which is favoured by the inadequate, biased specialist study, I would recommend that Aquila commission a second specialist study which fairly represents a

balanced assessment of mining versus alternative land uses.

In light of the serious implications of the above, I would also recommend that interested and Noted. affected parties commission an independent economic evaluation of mining versus alternative land uses.

Economics need to be considered in terms of the mine operating for 18 years where as the alternative land uses that rely on the environment are indefinite.

I&AP’s should be afforded a reasonable timeline to commission an independent expert. Although Most of the specialist studies were the Scoping Report indicates that alternatives revised to include the alternatives have considered environmental impacts, none of assessed. the specialist reports have evaluated alternatives, leading me to assume it did not form part of their scope of work.

Specialist studies can add immense value to a

process if the information obtained is used to guide decision making. In this application it appears that the studies are being done in isolation from the planning, to the point where they have been requested to undertake impact assessments without knowledge of the site layout. With the exception of the blast report none of the studies reviewed included a site

layout. Some studies even contradict information in the Scoping Report; i.e. one study specifically

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY states that there will be no tailings facility, yet it is included in Figure 17 of the Scoping Report. It is difficult to evaluate the reports with any confidence if the specialists have not been

provided with adequate information on which to base their assessments.

Not only are the reports provided for review in most cases seriously flawed, there are a number of specialist report which have yet to be provided. This is a major concern considering that this project is potentially 6 months away

from obtaining a mining right without critical information required to inform the design of the proposed project.

Specifics include; The Scoping Report indicates that a traffic assessment is provided however this

document has not been provided. Transportation logistics will have a significant impact on the local community. The visual impact of the proposed mine will The traffic study was conducted refer to change the sense of place forever (long after annexure E12. the 18 year life of mine). This information is crucial to understand the true impact of the proposed mine. A visual impact study was conducted Groundwater refer to annexure E9. Storm water management plan / Surface water assessment. A groundwater study was conducted Scoping Report: refer to annexure E2. The Scoping Report was provided to I&AP’s for review and comment on the 14th November A storm water plan was conducted refer 2013, with instruction to provide comments on to annexure E6. the document before 13th December 2013. Upon receiving the DMR acceptance letter it is apparent that the Scoping Report was already The Environmental Scoping Report submitted to the DMR as they required the (ESR) in terms of the MPRDA was

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY document by no later than the 26th of October submitted to Department of Mineral 2013. Therefore it stands to reason that there is Resources (DMR) before the 30day no opportunity for I&AP’s to influence the final expiration from acceptance of application Scoping Report. This should have (refer to Regulation 49(2) of the been highlighted to I&AP’s. MPRDA). Due to this time constraint the public participation process (PPP) only With regards to the Scoping Report itself, overall commenced after the submission of the I feel there is extensive misrepresentation within ESR to DMR. the report and a serious lack of information making it impossible for I&AP’s to truly understand the full extent of the potential impacts associated with the proposed mine. Noted.

With regards to misrepresentation, the information concerning the consultation process included within the Scoping Report details the feedback from the consultation undertaken as part of the historical prospecting activities. I&AP’s attending these meetings were mainly focusing their concerns around the illegal prospecting activities taking place and not mining which is now being applied for. A meeting was held between Aquila, To date there has been no public meeting with DMR and IAPs on the 18th of December regards to addressing the planned mining 2013. Subsequent to the meeting a activities. Although it should be highlighted communication strategy was developed. within the report it does indicate that a public meeting would be held 15th of January Shangoni management in October 2013, which to the best of my services met with Mr Andrew Nicholson knowledge has not taken place. from Umhlaba to discuss the MPRDA scoping report and general public I&AP’s should be firstly informed when and how participation. they can contribute to the mining right process, st beafforded sufficient time to assimilate the A Public meeting was held on the 1 of extensive amount of documentation and most February 2014. importantly, be able to influence the design of the project based on valid concerns raised during consultation.

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY Section 4.5.2 is supposed to provide “the most appropriate procedure to plan and develop the proposed mining operation with due consideration of the issues raised in the consultation process.

The information provided is more a list of activities intended to be undertaken during the EIA processand has no bearing on the most appropriate procedure to plan and develop the proposed mining operation while considering I&AP’s real concerns.

To date and through historical engagement with Aquila, it appears as though the consultation process is viewed as a “tick box exercise” rather than one which can have any influence on the design of the project. Thereby completely disregarding valid concerns of people who will be impacted forever by this project, should it go ahead.

The whole of section 2.4.4 again provides misleading information as it includes: Pre-mining land use: “The area is characterized by wilderness and thickets and is utilized as a residence and for highly limited eco-tourism activities; mainly game farming and game lodging. Prospecting has also been conducted on the land; however no mining has taken place.” Present land use: “There are crop fields towards the western side of the Crocodile River and irrigated land some distance to the east of the river. The current land use on the site is a mix of residential and highly limited eco- tourism. Prospecting has also been conducted on the land;

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY however no mining has taken place.” Land misuses: “Within the district area the challenges that are found include degradation of the land caused by overgrazing and deforestation and informal settlements.” What do crop fields towards the western side of the Crocodile River which is approximately 27km away from the project area have to do with present land use. Based on my limited knowledge of the area, I am unaware of informal settlements.

This is an example of inaccurate / poor information provided which the Department of Minerals and Resources use for decision making.

With regards to lack of sufficient information to determine the actual impact of the proposed mine, the main shortfalls include; There is no scheduling of intended timeframes for implementing of various phases of the project or intended operational hours. There is no detail concerning the construction requirements. There is no information on transportation or housing logistics which is a critical requirement for the project and a main concern of I&AP’s. Maps and plans are inadequate (and in some cases completely wrong) as they do not provide enough detail. Sensitive environmental features have not been shown in relation to the proposed mining development and infrastructures. There is no detail concerning the growth and design of the pit / topsoil dump /

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY overburden dump over time. There is no water balance diagram indicating the water needs of the project.

Additional questions and queries will arise as adequate information is provided.

My recommendations going forward would be to; 1) Aquila to actually provide finalized specialist studies and provides the missing specialist studies. 2) Aquila to commission a second specialist to undertake a fair and balance “Alternative Land Use Economic Impact Initial Assessment “. In addition I would recommend interested and affected parties to commission their own independent economic evaluation of the proposed mine versus the existing land uses is commissioned by landowners. In order to undertake this work a copy of the mine works programme should be obtained. 3) Aquila to provide all I&AP’s a detailed indication of how and when they will consult and how I&AP’s will have an opportunity to influence the proposed project. This could be provided in a flow digram. Consideration must be given to provide a reasonable timeframe for interested and affected parties to respond and effectively participate within the process. 4) Aquila provide plans / maps which superimposes the full physical impact of the proposed mine and alternatives compared to the following sensitive habitats; a. Ecological sensitivity b. Water features / drainage lines c. Cultural / heritage sites 5) Aquila to provide feedback on the shortfall of information detailed above.

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY An e-mail received from Andrew Please can you confirm when the application Please find attached a copy of the Please find attached a copy of the Nicholson from Umhlaba Consulting on was lodged and accepted by the DMR. Regulation 2(2) plan as requested by Regulation 2(2) plan as requested the 17th of September 2013. you. Please see Mr. Johan van Breda’s by you. As to your request for the In addition, as a interested and affected party, email below with regards to your request Mining Work Programme, I can please could you; for the MWP. unfortunately not provide you with 1) Provide me a copy of the regulation it. You are welcome to request it 2(2) plan which accompanied the from the DMR in due course but mining right application they have advised Aquila not to 2) Provide me with a copy of the mine provide it. works programme which accompanied the mining right application. We have not hidden the fact that we have applied for a mining right Thank you in anticipation of the above as I have since mentioned in mentioned documents. discussions I have had with persons such as Mr Pierre Mostert An e-mail received from Andrew I am happy not to receive the full MWP. and others with whom we have Nicholson from Umhlaba Consulting on regular meetings. the 18 Ocotber 2013. However in order for me to provide applicable feedback / valuable comments I do require an The reason we have not made it indication of where the physical mining activities known globally yet, is that we are will take place within the mining right area and awaiting instructions from the DMR what the mining activities will entail. in respect of our submission timelines for the Scoping Report,  Where will the pit be located EIA and EMPr as well as our  How will the pit develop over time registration with LEDET under  What depth will the pit be NEMA.  Where will the infrastructure be located  Where will the haul roads be You will be furnished, in due  Etc. – I am sure there will be more course, with all information that questions in future would allow you to contribute meaningfully during the public As an environmental consultants, you would participation processes. understand that this information is critical in order to determine the potential impacts of this Should you have any further project. questions please feel free to contact myself This information is contained within the mine works programme (which is why I asked for a copy). I am happy for you to extrapolate the

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY information and send it through to me.

Thank you in anticipation of your feedback. An e-mail received from Andrew Please can you send me a copy of the mining Thank you for your email. As per your Nicholson from Umhlaba Consulting on right (LP 10071 MR) acceptance letter for Aquila. request, please find attached copy of the the 20th of November 2014. I would like to obtain an indication of the DMR mining right (LP 10071 MR) acceptance imposed timelines for submission of the various letter for Aquila. documentation associated with the mining right process. An e-mail received from Simon Gear Please register BirdLife South Africa as an Thank you for your email. Please find representing Birdlife South Africa on the interested and affected party on the Meletse attached a letter of notification and 11th of February 2014. Mountain EIA. If you can provide us with any background information document documentation or public participation material regarding the application for a mining that has been produced so far, we would right, water use license and appreciate it. In addition, please can you let us environmental authorization for Aquila know who the avifaunal specialist is who has Steel (Pty) Ltd. been appointed to your project team. As per your request we have registered All details will be as per my signature below. BirdLife South Africa as an interested and affected party.

Lucas Niemand is the appointed project avifauna specialist. One of his recommendations was that an additional vulture study be conducted. We are in the process of sourcing a vulture specialist.

An e-mail received from Ernest Retief Can you please send us the AviFaunal report or Thank you for your email. A baseline from Birdlife South Africa on the 12th of let us know where the documentation as well as AviFaunal study was conducted and is in February 2014. the other specialist reports can be downloaded? the process of being updated. This study shall form part of the EMPr and the EIA. Also there is a person that have studied the Kransberg Vulture Colony for more than 30 We have made contact with Mr Pat years! His name is Pat Benson and I am cc-ing Benson. We will be meeting with him him in this email. His email address is: within the next week or so. [email protected] – he would be the best person to contact for any further study about this We are aware of the fact that the

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY colony. application is within the Waterberg System Important Bird Area. You must please note that the application is within the Waterberg System Important Bird Area – see this link for more information: http://www.birdlife.org.za/conservation/important- bird-areas/iba-directory/item/148-sa007- waterberg-system

Thanks looking forward to the EIA reports. For your info please find attached a document (Guide to access Avian Data for EIA) that you might find of value. An e-mail received from Fred Stow who During a meeting with DMR, Shangoni, Aquila Aquila checked their records in is the General Manager of Meletse and Rooiberg Bewaria, at the DMR, Wednesday 2011 and Meletse Private Game Private Game Reserve on the 20th of 18th December, your colleague Jan stated quite Reserve was not sent a letter November 2013. blatantly that permission to access Meletse requesting permission to access Game Reserve (SARPHC Properties) had been their boreholes are part of the requested and denied, citing that this denial had hydrocensus. unduly delayed reporting and the communication processes.

Kindly and URGENTLY forward me copies of this correspondence (both the request and the refusal) before close of play today.

I eagerly await your reply

Kindly respond to my simple request below. It’s now been 3 weeks. An e-mail received from Fred Stow who Thank you for the notification below. I have We acknowledge receipt of your email is the General Manager of Meletse taken over the role of General Manager of and the contents thereof. According to Private Game Reserve on the 22nd of Meletse Game Reserve from Gornal-Jones, as the Public Participation Guideline Series November 2013. of July 2013. If I may kindly ask you for a short 7 (GN 807), dated 10 October 2012, postponement to 13 January 2013 in order for issued by the Department of me to properly review the procedure and Environmental Affairs, public contents and consult with my principals, who are participation/comments period must not based in the UAE, in order to fully comprehend take place during the period of 15 the parameters of, and give meaningful December to 2 January. It is for this

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY feedback on your draft scoping report. reason that we unfortunately cannot extend the comments period to the 13 Thank you for your reply. I am somewhat January 2014. In addition, the MPRDA disappointed at your intransigence in this matter, Environmental Management Plan for this as I am still ill-informed as to the exact size and project has to be submitted to the scope of your client’s proposed mining activity – DMR on or before the 26th of March the information that I have managed to scan on 2014. Therefore from our side we also your website seems (to me as a lay person) have deadlines to stick to. rudimentary and lacking in detail, as to what your client intends doing. Bear in mind that However please be advise that you will Meletse Mountain, which I am under the be granted another opportunity to review impression Aquila intends to remove, is directly and comment on documents during the in the view line of Meletse Game Reserve’s Environmental Impact Assessment premier 30-bed luxury lodge, Babohi, with all the phase. ramifications associated with it.

Kindly excuse my ignorance as to the due process, but exactly how and when do you intend informing me, as a directly interested and effected party, of the exact nature of the proposed mining activity? I need that information so that I can even begin to understand the various impacts, which at face value seem to be somewhat significant, let alone formulate an opinion based on any kind of hard facts.

You say that I will another opportunity, how and when? If I get another opportunity, why then urgent deadlines, when I could obviously not give you an informed response? I get the slight, but possibly incorrect, impression that I am being railroaded here! I need a lot more clarity, both in information and process. Bear in mind I do not understand the mining process or the history behind this application at all, I am a new game reserve manager with some very concerned overseas principals.

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY Please revert urgently, as I need to provide feedback to my principals, who would probably require informed professional opinion on this An e-mail Jacques Blaauw Chairman: of A copy of the EIA & Section 24G To whom it may concern, the Thabazimbi Business Chamber on rectification application presentations Please inform us when the minutes of the the 12th of February 2014. and associated minutes were sent to meeting as well as the slides that were Jacaques Blaauw on the 26th of February presented will be available to the I & AP. 2014. An e-mail received from Louis van der With regards to access to my property for the Noted. Please send us your study so it Watt on the 28th of January 2014. Geo-hydrological study: can be included in the Geo-hydrological model. We have conducted our own study. We have currently a borehole in the western area of the farm that yields almost 130 000 l/hour. We did a stress test last year over a week period and the yield did not drop.

The quality of the water is also exceptional. Letter received on 5/1/2014 from Dr. We are residents of the Alma Valley who will be Noted. Panela Oberem representing Alma affected by the mine. Valley residents, by the following names: -Frank Sullivan We are game and livestock farmers in the valley -Pietie & Natasja le Roux situated along the road from Alma Thabazimbi. -Barry & Diane York Despite the attempt of Aquila to downplay the -Dabchick Wildlife Reserve impact of this intended mine, at the information - Benny Mokala day we learned that we will be drastically affected by these mining operations. We detail our concerns/objections below:

1. The nature of the area: the Meletse property Noted. is situated in the middle of an undeveloped, almost pristine wilderness. Most of the owners represented are livestock and crop farmers but some of us are game farmers who due to the unspoilt wilderness of the Alma Valley enhanced by the surrounding mountains have invested in building tourist camps for visitors. We have also invested time and money in various conservation projects. It is common

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY knowledge that the proposed mine will destroy this current unspoilt environment.

2. Lack of consultation during the license A meeting was held between Aquila, application: it is our contention that only DMR and IAPs on the 18th of December direct farmers were consulted in the initial 2013. Subsequent to the meeting a process. The first that we, the Alma Valley communication strategy was developed. residents became aware of this issue was when we saw the destruction on the Meletse 15th of January Shangoni management Mountain and began to make enquiries from services met with Mr Andrew Nicholson the previous owner. from Umhlaba to discuss the MPRDA scoping report and general public 3. Impact on the area: after attending the participation. information meeting held by Aquila we have learnt that the impact will be as follows: A Public meeting was held on the 1st of February 2014. Massive traffic flow along the Alma- Thabazimbi road; the road is gravel, carries A traffic study was conducted and looked farm traffic of farm animals, horse riders and at a few options for transportation. The escaped game animals. Heavy traffic on this client is looking at a siding from road will cause noise pollution, dust pollution Cronimet. Refer to paragraph 7.1 of and a danger to farming activities. section 1 (EIA) for proposed mitigation measures. Possible reactivation of the inactive railway: this railway was initially used for agricultural purposes. The reactivation of the railway through Alma for the transport of ore will cause severe impact on the rural nature of this area.

Effects on the ground water: This area ofthe Refer to appendix E2 for the geo- Waterberg has a large underground body of hydrolgocial study. the purest water in the country. The high rainfall in the area and the run-off from the Waterberg Mountains will cause contamination of the ground water. This will severely impact on livestock farmers and ecosystems.

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY Destruction of the Meletse Mountain: the A Visual study was conducted for the destruction of this mountain will completely project. deface the visa of the Alma valley in the west.

4. Lack of confidence in Aquila: during the prospecting period Aquila showed their Noted. contempt for environmental issues by making unauthorized roads on the Meletse Mountain and basically devastating the surroundings. They subsequently had to apologies and undertake to rehabilitate the mess (see attached photo- one of many in our possession). There also exists a photo on file of the Thabazimbi group showing Aquila staff in their branded overalls dumping refuse along the Thabazimbi road. When the staff became aware they were being photographed they made rude signs at photographers. Clearly this company has no respect for the environment and are therefore not welcome in our area A fax e-mail received from E.B. As a result of the meeting that we had with the Thank you for the letter. I was a bit Nieuwoudt on the 31st of January 2014. department of Mineral Resources (“DMR”) in disappointed when I read the Polokwane in December 2013, and more contents as I was led to believe specifically because of the request by Mr. Vinesh during a call with one of the other Devchander of DMR, I have tried to convince members of Rooiberg Bewaria that landowners to allow you access to their farms, in the letter would be to inform us that order to carry out the hydrological study. To access has been granted. date, I did not have a lot of success. Never the less, may I enquire whether you will give us access to You must realize that because of the way that your properties? Aquila conducted themselves in the past, and with the misrepresentation, illegal activities, lack of transparency and total disregard for the environment and the landowners in the area, it should come as no surprise that there is a lot of animosity. The landowners do not want to talk to me, or get answers from me, but they want to hear it from you. As you are aware, your last

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY direct meeting with Interested & Affected Parties (I&AP) was in 2012. The people are longing for a direct meeting and want to hear it directly from yourself, what you are planning and what the impact would be on their everyday activities. To you it might be a simple business transaction, but to a lot of people, it means much more –it is their livelihood.

It is opportune that you have a scheduled meeting with I&AP’s tomorrow in Thabazimbi. I urge you to please use the opportunity to be open and transparent, in order to try and restore the total breakdown of trust that exists between I&AP and Aquila. You are in a far better position to make promises, and hopefully this time keep them.

After tomorrow’s meeting, you should have more clarity on the possibility of getting access to landowner’s properties. An e-mail received from Patrick Benson I would like to register as an Interested and Noted have been registered as an on the 11th of February 2014. affected party for this operation. I have been Intrested and Affected Party. studying the Kransberg Cape Vulture colony for the past 33 years. I am associated with the School of animal, plant and environmental sciences at Wits University and study vultures full time. The Kransberg is my main study site.

Thank you. An e-mail received from Gerrit van den Thank you for your mail. Please find attached As part of the EMPR submission a Berg on the 14th of January 2014. document. Please take note that I don't have a Traffic, noise, economic and air quality direct interest, but merely act on behalf of Mr study was conducted. Please refer to the Louis van der Watt. I think that he is already appendices for the specialist studies. registered as an I&AP, I am just sending the information as a backup.

Mnr. Van Der Watt is a direct neighbor, looking onto the proposed mining site.

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY

Various as per all previous communication. Brief summary of concerns:  Infrastructure (roads, water).  Noise Pollution.  Dust pollution.  Esthetically.  Effect on value of farm.  Privacy.  Etc. An e-mail received from Pieter Coetzee Piet Venter is my client and I am a trustee of the Thank you for your email. Aquila Steel on the 27th of January 2014. farms. appreciates the fact that you are willing We will grant you access to our farms, provided: to grant the Geohydrologist permission to 1. You will give us copies of all information access your property for the hydro gain during such investigation. census in support of the completion of 2. You will phone and arrange timeously the geo-hydrological assessment for the beforehand when you want to gain proposed Meletse Iron Ore Mine?s access to our farms. Environmental Impact Assessment.

Piet’s cellphone number is 082082109974 In return and as per your request, Aquila Steel promises to share all information gathered during the geohydrological investigation with all the interested and affected parties. The geohydrologist commissioned to conduct the investigation shall phone and arrange with the property representative timeously beforehand to gain access to his farms. An e-mail received from E.B. Nieuwoudt Thank you for the detailed response, but my Dear Mr EB Nieuwoudt on the 29th of November 2014. question is a more practical one in terms of how much time will be spend on each property and As per your request, below is the what exactly will be done on each property. The detailed information pertaining to the people want to understand the process that will geohydrological study. be followed on their properties if they allow access. The purpose of the hydrocensus is to provide input to the groundwater I hope to hear from you soon. baseline study in terms of:

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY - Groundwater uses (domestic, Thank you for the detail. It will make it easier for livestock, irrigation etc.) in the affected parties to understand what they must vicinity of the proposed project, consider. - Groundwater users (how many, distribution etc.) I will communicate with the affected Rooiberg - Groundwater levels and Bewaria members, but you are also welcome in quantity of water used, and future to please provide this level of detail - Groundwater quality around the directly to the affected parties. mine. The reason is for the authorities, the mining applicant and the existing user to have a good understanding of the groundwater situation and existing lawful uses. Should the proposed mining activities be approved, any potential impacts can be measured against this predetermined baseline. It protects the existing user in the first place but also the mine to have a baseline against which to measure.

Practically we do the following: - The user is contacted to make an appointment to come and do the hydrocensus survey. - A vehicle with one or two persons visit the property. - A questionnaire is filled out with the basic information of the property owner, farm information, number of boreholes, uses etc. - Each borehole or spring or well is visited (shown to the field personnel or his/her representative) and the following questions are asked and information recorded: o Borehole depth?

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY o Yield ? o Equipment in borehole? o Use of borehole water (e.g. domestic – 20 people, or livestock – 100 cattle)? o Any comments on taste, smell etc? o Coordinates (GPS) o Static Water Level (measured with a probe, which is basically a long tape with 15mm rod probe at the end) o A sample will be taken if the borehole is in use – by bailer from the borehole if un- equipped, at discharge point (tank, reservoir, tap etc) if equipped o A photograph will be taken of each groundwater point.

Water samples are analysed and discussed with all other information in the report.

I can’t say exactly how long the survey takes on a property – it depends on distance between boreholes etc. It should take about 30 minutes to fill out the forms and get the overall information. If fairly open and accessible, the measurements at each groundwater point should take about 15

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INTERESTED AND AFFECTED I&AP COMMENT SHANGONI RESPONSES CLIENT RESPONSES PARTY minutes.

Please let me know if this is sufficient information.

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Regulation 50 (g)

14 The appropriate mitigatory measures for each significant impact of the proposed mining operation

14.1 Adequacy of predictive methods utilised The mitigation measures as described in Section 2 (Environmental Management Programme) have been used adequately by various mines and on various other sites. The mitigation measures are specific to the nature of the impact. Based on the continual improvement principle, where mitigation measures can be improved on, this will be done. The main reasons for this would be improvement in technology to address impacts and new developments which may require additional measures.

14.2 Adequacy of underlying assumptions The following specialist studies and technical reports were completed and are attached to this document: An ecological evaluation for the Aquila Steel project, Thabazimbi Appendix E1 Aquila Steel Meletse Iron Ore Project: Report on geohydrological Appendix E2 investigation as part of the EIA and EMP. Palaeontological Assessment: Site Visit Report. Gatkop cave on farm Appendix E3 Randstephane 415 KQ near Thabazimbi, Limpopo province Cultural heritage resources essay for the farms Donkerpoort 448 KQ, Appendix E4 Randstephne 455KQ and Waterval 443KQ, Limpopo province Assessment of the bats at Gatkop Cave, and possible mitigation measures Appendix E5 Stormwater management plan Appendix E6 Air Quality study Appendix E7 Noise survey Appendix E8 Visual impact assessment report 2014 Appendix E9 The Ecological Integrity of the aquatic habitat at the proposed Aquila Steel Appendix E10 mine on the Farms Donkerpoort 448KQ and Randstephne 455KQ, Thabazimbi district, Limpopo Province, South Africa. Environmental Impact Assessment: Ground Vibration and Air Blast Study Appendix E11 Aquila Steel (Pty) Ltd. Meletse Project Traffic impact study Appendix E12 Economic impact study Appendix E13

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14.3 Uncertainties in the information provided

AIR QUALITY

The most important limitations of the air quality impact assessment are summarised as follows:  The quantification of sources of emission was restricted to the Meletse Iron Ore operations and product transport only. Although other background sources were identified, such sources were not quantified.  The information required to calculate emissions from fugitive dust sources for the proposed Meletse Iron Ore operations were provided. The assumption was made that this information was accurate and correct.  The impact assessment was limited to airborne particulates (including total suspended particulates (TSP), particulate matter of less than 10 μm in diameter (PM10) and particulate matter of less than 2.5 μm in diameter (PM2.5)). Although the activities would also emit other gaseous pollutants, primarily by trucks and mining vehicles, the impact of these compounds was regarded to be low and was omitted from this study.  Mining operations were assumed to be twenty-four hours over a 365 day year as a conservative approach.  It was assumed that the discard material from the DMS plant will be wet when deposited on the discard dump, and therefore this materials handling step was not included in the emissions inventory  The sensitive receptors included in the assessment were obtained from the Draft Scoping Report as part of the Cultural and Heritage Resources Assay. Any other areas that may be impacted outside of the mine boundary may be identified from the dispersion modelling contour plots.  A dispersion model represents the most likely outcome of an ensemble of physical quantities and therefore has inherent uncertainties. The total uncertainty can be thought of as the sum of three components: the uncertainty due to errors in the model physics; the uncertainty due to data errors; and the uncertainty due to stochastic processes (turbulence) in the atmosphere. Nevertheless, dispersion modelling is generally accepted as a valuable tool in air quality management practice. BIO-ASSESSMENTS

The health of the aquatic biotic component was evaluated by means of the South African Scoring System (SASS) technique, based on benthic macro-invertebrates (Thirion et al., 1995; Dickens & Graham, 2002). Limitations of the method include:  It does not identify the nature of chemical changes.  Although it is less restrictive in terms of suitable sites than the previous methods used, site accessibility and habitat availability may still be limiting factors. BLASTING AND VIBRATIONS

Considering the stage of the project, the data observed was sufficient to conduct an initial study. Surface surroundings change continuously and this should be taken into account prior to any final design and review of this report. This report is based on data provided and international accepted methods and methodology used for calculations and predictions. Ground vibrations Limitations on ground vibration are in the form of maximum allowable levels for different installations and structures. These levels are normally quoted in peak particle velocity or as ground vibration in millimetres per

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second (mm/s). There are unfortunately no exact South African standard. Thus currently the United States Bureau of Mines (USBM) criterion for safe blasting is applied where private structures are of concern. This is a process of evaluating the vibration amplitudes and frequency of the vibrations according to set rules for preventing damage. The vibration amplitudes and frequency is then plotted on a graph. The graph indicates two main areas:  The Safe Blasting Criteria Area  The Unsafe Blasting Criteria Area

When ground vibration is recorded and the amplitude in velocity (mm/s) is analysed for frequency it plots this relationship on the USBM graph. If data falls in the lower part of the graph then the blast was done safely. If the data falls in the upper part of the graph then the probability of inducing damage to mortar and brick structures increases significantly. There is a relationship between amplitude and frequency due to the natural frequencies of structures. This is normally low - below 10 Hz - and thus the lower the frequency, the lower the allowable amplitude. Higher frequencies allows for higher amplitudes. The extra lines on the graph are more detailed for specific type walls and structure configurations. Locally we are only concerned with the lowest line on the USBM graph. Due to possible poor state structures in the area additionally a 6mm/s and 12.5mm/s limits were added.

Additional limitations that should be considered are as follows, these were determined through research and various institutions:  National Roads/Tar Roads: 150 mm/s  Steel pipelines: 50 mm/s  Electrical Lines: 75 mm/s  Railway: 150 mm/s  Concrete aged less than 3 days: 5mm/s  Concrete after 10 days: 200 mm/s  Sensitive Plant equipment: 12 or 25 mm/s depending on type – some switches could trip at levels less than 25 mm/s.

Limitations with regards to human perceptions A further aspect of ground vibration and frequency of vibration is the human perception. It should be realized that the legal limit for structures is significantly greater than the comfort zones for people. Humans and animals are sensitive to ground vibration and vibration of the structures. Research has shown that humans will respond to different levels of ground vibration and at different frequencies. Ground vibration is experienced as “Perceptible”, “Unpleasant” and “Intolerable” (only to name three of the five levels tested) at different vibration levels for different frequencies. This is indicative of the human’s perceptions on ground vibration and clearly indicates that humans are sensitive to ground vibration. This “tool” is only a guideline and helps with managing ground vibration and the respective complaints that people could have due to blast induced ground vibrations. Humans already perceive ground vibration levels of 4.5 mm/s as unpleasant. Generally people also assume that any vibrations of the structure - windows or roofs rattling - will cause damage to the structure. Air blast also induces vibration of the structure and is the cause of nine out of ten complaints.

Air blast The recommended limit for air blast currently applied in South Africa is 134 dB. This is specifically pertaining

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to air blast or otherwise known as air-overpressure. This takes into consideration where public is of concern. However, all attempts should be made to keep air blast levels generated from blasting operations below 120 dB toward critical areas where the public is of concern. This will ensure that the minimum amount of disturbance is generated towards the critical areas surrounding the mining area.

Based on work carried out by Siskind et.al. (1980)[1], monitored air blast amplitudes up to 135 dB are safe for structures, provided the monitoring instrument is sensitive to low frequencies (down to 1 Hz). Persson et.al. (1994)[2] Have published the following estimates of damage thresholds based on empirical data (Table 8). Levels given in Table 6 are at the point of measurement. The weakest point on a structure is the windows and ceilings.

All attempts should be made to keep air blast levels generated from blasting operations well below 120 dB where public is of concern. This will ensure that the minimum amount of disturbance is generated towards the critical areas surrounding the mining area and limit the possibility of complaints due to the secondary effects from air blast

Limitations with regards to human perceptions Considering the human perception and misunderstanding that could occur between ground vibration and air blast BM&C generally recommends that blasting be done in such a way that air blast levels is kept below 120dB. In this way it is certain that fewer complaints will be received for blasting operations. The effects on structures that startled people are significantly less – thus no reason for complaining. It is the actual influence on structures like rattling of windows or doors or large roof surface’s that startle people. These effects are sometimes misjudged as ground vibration and considered as damaging to the structure.

Initial limits for evaluation conditions have been set at 120dB, 134dB and less than 134dB. USBM limits are 134 dB for nuisance, at this level 5% of residents would be expected to complain, because they are startled and frightened; even 120dB could sometimes lead to rattling windows, feelings of annoyance and fright. FAUNA AND FLORA In order to obtain a comprehensive understanding of the dynamics of the floristic and faunal communities on the study site, as well as the status of endemic, rare or threatened species in any area, ecological assessments should always consider investigations at different time scales (across seasons/years) and through replication. However, due to time constraints such long-term studies were not feasible.

Furthermore, the butterfly sampling was specific to upland (or high altitude) areas and constrained by windy and cloudy conditions with low ambient temperatures that were not optimal for butterfly activity. In general, invertebrate surveys, in particular butterfly surveys, should preferably conform to temperatures of 13-17ºC during sunny conditions (with a minimum of 60 % sunshine) or during both sunny and cloudy conditions above 17ºC (New, 1997).

The information as presented in this document only has reference to the investigated mining right boundary and cannot be applied to any other area without prior investigation. In addition, part of the study site was confined to rugged mountainous terrain and was exceedingly difficult to access, even on foot due to steep rocky slopes and cliffs. This made sampling in these parts, especially the western section of the study site very difficult and in some instances impossible. This company, the consultants and/or specialist investigators

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do not accept any responsibility for conclusions, suggestions, limitations and recommendations made in good faith, based on the information presented to them, obtained from the surveys or requests made to them at the time of this report. HYDROLOGICAL  Whilst all due care has been taken in reviewing the supplied information, the accuracy of the results and conclusions from the SWMP are entirely reliant on the accuracy and completeness of the supplied data.  Flood peak calculations assume rainfall intensity is uniform throughout the duration of the storm. Analysis does not account for runoff retention or artificial acceleration within the catchment.  Calculations are done for complete sub-catchment areas and should be distributed where there is more than one drainage point within the same built up catchment.  Storm water control recommendations are based on industry experience and best practice. Final designs for construction should be authorised by an approved engineer.  Contour and elevation data as provided during the analysis are assumed to be accurate and representative of the site and catchment areas.  Upstream catchment activities are interpreted according to common practices and no detailed insight is available on possible storm water measures beyond the site. The assessment does not guarantee the integrity of downstream infrastructure in the event of release or discharge from site.  The SWMP does not impose preference over proposed measures as this is an operational document to assist in the complete management of all storm water measures.  This storm water management plan does not specifically cover considerations relevant to storm water management for the purpose of safety, like mine flooding and loss of life, the primary focus being environmental management.  Recommendations represented in this report apply to the site conditions and features as they existed at the time of Shangoni’s investigations, and those reasonably foreseeable. The recommendations do not necessarily apply to conditions and features that may arise after the date of this SMWP, for which Shangoni had no prior knowledge nor had the opportunity to evaluate. VISUAL This assessment was undertaken during the planning stage of the project and is based on the information and Terms of Reference provided by Shangoni Management Service (Pty) Ltd. on 10 October 2013, for the mentioned project. Assessments of this nature generally suffer from a number of defects that must be acknowledged:  Limited time: A comprehensive assessment requires a systematic assessment of the environment at different times of the day. Such luxury is not always possible and therefore most assessments are based on observations made at a specific time of day. Educated estimates are made, where applicable, based on the knowledge of the area.  Availability of literature: A thorough assessment requires that all relevant literature on the subject matter is studied, acknowledged and incorporated in the report. Due to a range of factors, forward planning documents are not always available for all spheres of government. Notwithstanding the above, it is believed that this assessment identified all issues of likely importance from a visual point of view. PROJECT Not all specialst studies could assess all six alternative mine layout options due to time constraints. Access to adjacent farms for the Geohydrological study was only obtained at the end of February, resulting in

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project delay as well as a delay in completion of other specialist’s studies that rely on the Geohydrology study. No Soil assessment was done. This will be done as part of the compilation of the rehabilitation plan. Paleotological study will be updated to include the mine layout alternatives. Anthroplogist study will be conducting an indepth study on the Sangoma’s in the area. No Cape Vulture study was done. The avi-fauna specialist is appointed and will commence with his study in Arpil 2014. Social study is currently underway.

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REGULATION 50 (h)

15 Arrangements for monitoring and management of environmental impacts

SECTION 15.1 SECTION 15.2 SECTION 15.3 SECTION 15.4 Monitoring Functional Requirement Roles and Responsibilities Monitoring Timeframes A comprehensive biomonitoring program will be compiled and will be submitted Bio monitoring Specialist. Annually to the DMR for approval prior to commencing with activities. Alien invasive Alien invader plant species control program will be compiled and submitted to ECO Continuously species monitoring the DMR prior to commencing with activities. Environmental manager Seasonally during operational Monitoring of the A program to monitor the survival rate of the C. deltoidea subsp. silicicola will phase and decommissioning survival rate of C. ECO be compiled and will be submitted to the DMR for approval prior to commencing phase. Monitoring shall deltoidea subsp. Environmental manager with activities. continue silicicola Up to five years after closure Dust sampling will be done will be conducted comprehensively as stipulated in ECO Fall out dust Monthly the Air quality specialist assessment study, attached hereto in Appendix E7. Environmental manager Ambient Air quality PM10 and PM2.5 monitoring will be conducted comprehensively as stipulated in ECO Continuously monitoring the Air quality specialist assessment study attached hereto in Appendix E7. Environmental manager

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SECTION 15.1 SECTION 15.2 SECTION 15.3 SECTION 15.4 Monitoring Functional Requirement Roles and Responsibilities Monitoring Timeframes PM 10 monitoring station should also record basic hourly average meteorological measurements of the following parameters: The following meteorological conditions will be monitored: Monitoring of  Wind direction ECO Meteorological Continuously  Wind speed Environmental manager conditions  Temperature  Rainfall  Solar radiation/Surface heat flux Environmental noise monitoring will be conducted comprehensively as stipulated Environmental ECO in the Environmental Noise Survey compiled by Varicon CC, attached hereto in Annually noise Environmental manager Appendix F8. Ground water Ground water quality sampling will be conducted comprehensively as stipulated ECO Quarterly quality in the Geohydrological investigation, attached hereto in Appendix E2. Environmental manager Ground water Ground water levels monitoring will be conducted comprehensively as stipulated ECO Monthly levels in the Geohydrological investigation, attached hereto in Appendix E2. Environmental manager Surface water ECO Monthly quality A Surface water monitoring program will be compiled and submitted to the DMR Environmental manager Surface water prior to commencing with the mining activities. ECO Monthly quantity Environmental manager Regular inspections will be undertaken to identify erosion concerns, and the necessary erosion protection and rehabilitation undertaken. An erosion ECO Soil monitoring Continuously monitoring program will be compiled and submitted to the DMR prior to Environmental manager commencing with the mining activities Rehabilitation will continuously be monitored to determine whether the practices Rehabilitation ECO are effective. A rehabilitation plan will be compiled and submitted to the DMR Continuously monitoring Environmental manager prior to commencing with the mining activities.

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SECTION 15.1 SECTION 15.2 SECTION 15.3 SECTION 15.4 Monitoring Functional Requirement Roles and Responsibilities Monitoring Timeframes Blasting monitoring program will be compiled and submitted to the DMR for ECO Blasting monitoring Continuously approval prior to commencing with mining activities. Environmental manager Pit stability A pit stability monitoring programme will be compiled and submitted to the DMR ECO Continuously monitoring prior to commencing with mining activities. Environmental manager Monitoring MRD as The MRD will continuously be monitored as per the CoP to be compiled and ECO Continuously per CoP submitted to the DMR prior to commencing with mining activities. Environmental manager

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Regulation 50 (i)

16 Technical and supporting information

List of specialist studies that were conducted as part of the MPRDA EMPR:  Air Quality study,  Noise study,  Traffic impact study,  Visual impact study,  Blasting and Vibration study,  Economic study,  Heritage study,  Paleontological study,  Fauna & Flora study,  Bats at Gatskop study,  Bio-assessment (aquatic habitat) study,  Geo-hydrological study,  Hydrological study.

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SECTION 2 – ENVIRONMENTAL MANAGEMENT PROGRAMME

Regulation 51 (a)

1 Description of environmental objectives and specific goals for mine closure

1.1 Environmental aspects that describe the pre-mining environment Refer to Section 1 (EIA), Regulation 50(a) for a complete description of the pre-mining environment.

1.2 Measures required to contain or remedy any causes of pollution or degradation or the migration of pollutants, both for closure of the mine and post-closure

1.2.1 Closure objectives Mine Closure incorporates a process which starts at the commencement of mining and continue throughout the LoM. It is executed within the framework of sustainable development. Risk to elements of the environment is quantified and managed pro-actively. This includes the gathering of relevant information throughout the LoM.

The MPRDA provides specific information on the Closure application, policies, methodology and measures.

The mine’s Closure objectives are the following: Geology and the mineral resource  The removal of material from the pit shall adversely affect the geology.

Topography  To reduce the visual impact of the altered topography by a process of reclamation and rehabilitation.  To dispose of saleable assets.

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Soils  To identify alternate use of as much of the infrastructure as possible.  To the extent to which it is reasonably feasible to do, to remove infrastructure not required in situ and restore the land to grassland.  To cover mining areas with sufficient soil in order to maintain and sustain vegetation.  To treat all soil pollution found during rehabilitation.

Land capability, surrounding land use and landscape character  To identify alternate use of as much of the infrastructure as possible.  To the extent which it is reasonably feasible to do, to remove infrastructure not required in situ and restore the land to grassland.  Investigate what infrastructure can have alternative uses.  Remove all un-sealable infrastructures where it is reasonably feasible to do so.  Reinstate mining land to grasslands infrastructure where is it reasonably feasible to do so.  To hand over land to a person interested in developing the land.

Natural vegetation  To achieve self- sustaining vegetation on all rehabilitated areas.  To treat soil allowing vegetation to sow itself in areas not implemented for other use.

Surface water  To minimise the risk of escape of polluted water from the mine property into natural watercourses.  To reduce, as far as reasonably feasible, the contamination of surface water thus obviating the need to treat excessive quantities of polluted water.  To measure water quality chemical/bacteriological and submit reports – action any anomalies.  Discharged water shall be treated to meet applicable discharged water quality standards.

Groundwater  Minimise all long term affects which individual facilities may have in terms of quality on other groundwater users.  To measure water quality chemical/bacteriological and submit reports – action any anomalies.

Air quality  Dust emanating from rehabilitated land should not exceed normal levels associated with agricultural and residential areas.

Noise  To remove all sources generating noise

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Visual aspects  Limit long term visual impact of mining activities.

Regional socio-economic aspects  To leave structures and infrastructures for future use where appropriate.  To hold meetings with I&AP- communicate any changes.  To hand over to any persons interested to take-over property after closure.

1.2.2 Objectives of the mine Closure process The objective of the mine Closure process is to ensure that with regards to the various elements of the environment, the above objectives are met. In order to achieve these objectives:  To achieve the optimal form of land use for the mining right area commensurate with the needs of local communities and South Africa as a whole;  To achieve closure within a realistic financial framework which is acceptable to the stakeholders involved;  To leave behind a land use and infrastructure asset which meets the needs of the present without compromising the ability of future generations to meet their own needs;  To ensure that all arable land, grazing land, and wilderness areas are left behind as self- sustaining land assets for the use of future generations; and  To ensure, as far as is practically possible, that all mining infrastructure, which cannot be used or demolished, is rendered safe to humans and animals alike

1.2.3 Post closure objectives The objective for the post-closure land use is to rehabilitate the land to a stable condition. The final land use will be agriculture. Refer to Section 1 (EIA) of this document for a description of the pre- mining and current land use.  Prior to applying for mine closure; a detailed risk assessment will be conducted to determine the potential residual and latent impacts associated with the Closure of the mine.  A Closure Plan will be developed in accordance with the requirements of the Minerals Petroleum Resources Development Act (Act 28 of 2002), Regulation 57(a). Furthermore, closure objectives will be set in accordance with Regulation 61 and 62(a).  Aquila will continue to investigate and quantify the residual impacts associated with the mining and related activities so as to ensure the identification, investigation and implementation of suitable mitigation.  In order to ensure that rehabilitation was effective; the aftercare maintenance of the site will take place after mining operation has ceased.

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 The rehabilitation will continuously be monitored to determine whether the practices are effective. If erosion and limited re-vegetation takes place a detailed assessment of the seed mixtures and possible fertilizer to be used, will be done. Once the mining activities have ceased two (2) - year monitoring will take place to ensure that the practices were effective.  Backfill or re-contour mined areas with excess excavation material generated during construction (TEEIC).  Thorough monitoring of biological, hydrologic, and geochemical conditions will take place.  Activities near aquifer recharge areas will be monitored to reduce potential contamination of the aquifer (TEEIC).  Divert surface water (clean water) flowing towards the site of pollution will be diverted.  Groundwater infiltration to a potentially polluting site will be prevented.

1.2.4 Rehabilitation

1.2.4.1 Rehabilitation plan The major goal for surface mine rehabilitation is to ensure the adequate rehabilitation of all areas disturbed by the mining operations. The rehabilitation of the mining area takes place in line with the actions described in this section. Rehabilitation is scheduled in accordance with the financial provision and rehabilitation budget over the life of the mine.

Rehabilitation will continuously be monitored to determine whether the practices are effective. If erosion and limited re-vegetation takes place a detailed assessment of the seed mixture and possible fertilizer to be used will be done. Once the mining activities have ceased monitoring will take place to ensure that the practices are effective. Monitoring will take place until a closure certificate is issued by DMR.

The rehabilitation objectives are as follows:  To rehabilitate the area as close as possible to its former state (game farming)  To slope the landscape to a gradient in line with the current slope  The area will be made free draining to prevent ponding of water to occur.

The rehabilitation process which include shaping of surfaces and stripping and replacing of topsoil should be monitored continuously by a competent third party (a soil specialist registered at the South African Council for Natural Scientific Professions). The rehabilitation process should be documented and the post-mining land capability in terms of game farming should be verified by actual game farms for at least 3 consecutive years to be used for future references. This will be the only way to ensure that rehabilitation of high standards take place. Failure to do this will result in failure to restore soil potential, land capability and land use close to pre-mining conditions which implies deterioration of the most important natural resource which provide national food security.

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Currently the mine does not have a detailed rehabilitation plan. A detailed rehabilitation plan will be compiled and submitted to DMR.

1.2.4.2 Monitoring of Effectiveness of Rehabilitation The monitoring of the compliance with the commitments made in the EMP will be done on an annual basis in line with the performance assessment requirements as stipulated in the Minerals and Petroleum Resources Development Act.

To monitor the effectiveness of the rehabilitation the following aspects will be monitored:  Assess species diversity compared to surrounding area and vegetation study as per EMP  Identify areas of erosion.  Identify any invader plant occurrence on rehabilitated area.  Identify disturbed sensitive areas (red data species) and include these areas in the rehabilitation plan.  On a regular basis, verify alignment between the rehabilitation plan and the post mining topography. Furthermore, aspects such as backlog to rehabilitation should also be noted with timeframes within which this will be.  Further, more detail, as part of the vegetation commitment, should be provided on the management of alien and invasive species, as well as indigenous and red data species.  For each phase of the rehabilitation, ensure that detailed rehabilitation standards have been defined. Further to this, ensure training on these procedures, with regular audits undertaken to assess compliance against the requirements as set out within these procedures.  To ensure sustainability in respect to rehabilitation, and to motivate such, it is critical to conduct at least annual assessments on the effectiveness of rehabilitation, and to track this over time. These assessments will also identify aftercare requirements, and input to future reviews of the rehabilitation standards.  Ensure that records of any effective rehabilitation sign-off are kept on file (critical record).  Develop detailed standards for aftercare and maintenance, which must include aspects such as vegetation and soil surveys, erosion inspections and other parameters which will ensure long term sustainability of rehabilitation (develop Aftercare and Maintenance Programme).  All rehabilitated land and infrastructures will be maintained as described in the previous sections for a period of three years after operations in that particular area have ceased.  For each facility the maintenance on vegetation will be maintained for 18 months after germination. Once rehabilitation has been completed, a three year period will be allowed to ensure that this vegetation is self-sustaining. If so, a partial closure certificate will be applied for. If not, a contingency sum will be allowed for in the trust fund to bring the vegetation to this self-sustaining level.

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1.2.4.3 Control of Invader Plants Alien invasive species that were identified within the study area should be removed. By removing these species, the spread of seeds will be prevented into disturbed soils which could thus have a positive impact on the surrounding natural vegetation.  All alien seedlings and saplings must be removed as they become evident for the duration of mine operation and after closure.  Manual / mechanical removal is preferred to chemical control.

All construction and operation vehicles and equipment, as well as construction material should be free of plant material. Therefore, all equipment and vehicles should be thoroughly cleaned prior to access on to the construction areas. This should be verified by the ECO and Environmental Manager.

Implement an alien invasive plant monitoring and management plan whereby the spread of alien and invasive plant species into the rehabilitated areas are regularly removed and re-infestation monitored for at least five years.  The area should be re-landscaped and resemble the land form prior to the open cast activities.  The areas should be planted within indigenous vegetation typical of the area.

1.2.4.4 Control of red data and indigenous species The threatened and protected plants must be removed if situated within the planned mining and associated infrastructure footprint. These plants should be replanted during rehabilitation, only if its habitat (grassland of the mountain summit) will be recreated. If the plants cannot be conserved in situ or replanted as part of rehabilitation, the plants must be relocated to conserved areas.

These plants can only be removed and relocated with permission (permit) from the LEDET.

A vegetation rehabilitation plan should be implemented. Grassland can be removed as sods and kept in suitable growing conditions. The sods must preferably be removed during the winter months and latest springtime. Relocation of the sods should be into suitable moist growing conditions. In the absence of timely rainfall, the sods should be watered well after planting and at least twice more over the next 2 weeks. These sods can be used in the eventual rehabilitation of the open pit footprint.

Implement a Plant Rescue and Rehabilitation Plan where the pteridophyte Cheilanthes deltoidea subsp. silicicola plants are deemed to be under threat from the open pit footprint, the plants should be removed by a qualified specialist and replanted into suitable conserved areas, or maintained under suitable growing conditions until such time that it can be replanted as part of rehabilitation. The survival of these plants in their new habitat must be monitored for at least five years and corrective

Shangoni Management Services (Pty) Ltd AQUILA STEEL (S AFRICA) (PTY) LTD: Environmental Page 293 of 328 Management Programme under the MPRDA, 2002 action taken, when it is found that the plants are not adapting. Note that these plants may only be removed with the permission of the provincial authority (LEDET).  Cheilanthes deltoidea subsp. silicicola should be removed when dormant (winter months) and relocated prior to first growth in spring. The bulbs should not be watered during winter.  Workers may not tamper or remove these plants and neither may anyone collect seed from the plants without permission from the local authority.  It must be noted that plant removal and relocation measures are no substitute for in situ conservation and, although they may appear to be effective in the short term, have a net effect of shrinking the distribution of the species and increasing their vulnerability to extinction.

The area should be re-landscaped and resemble the land form prior to the open pit activities.  The areas should be planted with indigenous vegetation typical of the area and monitored to ensure that the vegetation progresses through succession stages.  Monitoring of the rehabilitation success as well as the survival of Cheilanthes deltoidea subsp. silicicola on the site should take place for at least five years and include corrective follow-up action.  It is recommended that Landscape Functional Analysis (LFA) forms part of the rehabilitation and monitoring process. Landscape function analysis is a process-based technique that was developed specifically to track post-disturbance recovery of ecosystems. It aims to restore specific and measurable elements of ecosystem function rather than focusing purely on attaining floristic targets and thresholds e.g. nutrient cycling, increase in vegetation patches and infiltration are measured (Tongway & Hindley, 2004).

1.2.4.5 Control of wet areas (drainage lines) No construction / activities should be undertaken within the moist soils until a Water Use License is granted by the Department of Water Affairs (DWA).  Retain vegetation and soil in position for as long as possible, removing it immediately ahead of construction / earthworks in that area (DWAF, 2005).  Protect all areas susceptible to erosion and ensure that there is no undue soil erosion resultant from activities within and adjacent to work areas.  Prevent polluted water from reaching the watercourse and surrounding moist grasslands.  Trucks and equipment should only be washed in dedicated areas and the dirty water is not allowed to discharge into the watercourse or surrounding natural vegetation.  During rehabilitation, colonisation of the disturbed areas by plants species from the surrounding natural vegetation must be monitored to ensure that vegetation cover is sufficient within one growing season. If not, then the areas need to be rehabilitated with a grass seed mix containing species that naturally occur within the study area.

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Cordon off the main mine infrastructures from the surrounding natural vegetation areas to prevent any disturbances into the surrounding areas.  Contain sediment and turbidity at the open cast and work sites by installing diversion or containment structures.  Place and maintain erosion control barriers as appropriate to prevent sedimentation into the watercourse and moist grasslands.  Keep sediment barriers in place until restoration is complete.  Stockpile topsoil and organic surface material such as root mats separately from overburden and return it to the surface of the restored site where feasible.  Systematically remove vegetation as needed, storing it in a manner to retain viability, and replacing it after operation where feasible.  Rehabilitate on an ongoing basis.  All overburden and soils shall be left in a configuration which is in accordance with accepted conservation practices and which is suitable for the proposed subsequent use of the land.  An ecologically sound, storm water management plan must be implemented, including all measures as set out above

Rehabilitation and potential erosion problems should be monitored for at least 5 years after closure.  Monitoring should result in corrective action taken immediately to remediate erosion or failed rehabilitation.  Ensure that rehabilitated areas are free draining.  Topsoil should not be compacted during the rehabilitation process.  Keep sediment barriers in place until restoration and rehabilitation is complete.  Prevent grazing from livestock within the first 2 to 3 years after rehabilitation and prevent access to rehabilitated areas until such time that rehabilitation was successful.  If the plants were replanted as part of rehabilitation, the survival of the population of the threatened Cheilanthes deltoidea subsp. silicicola must be monitored and if the plants are under threat, they should be removed with the permission of the approving authority and transplanted to suitable habitat.

1.2.4.6 Soil Rehabilitation

1.2.4.6.1 Construction Phase Stripping and stockpiling of topsoil within the footprint of the proposed opencast area will probably commence during the construction phase but will be an ongoing action during the operational phase as the opencast expands.

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1.2.4.6.2 Operational Phase Soil Utilisation Guide Sustainable development implies development with as little damage to natural resources as possible. Stripping and stockpiling of topsoil is a very high impact on the most valuable and less reparable natural resource in the world. The cumulative impact by opencast mining on high potential soils in South Africa became devastating. Proper planning, management and execution of rehabilitation procedures are therefore crucial. The ability to do proper rehabilitation depends on precise stripping and replacing of topsoil and proper shaping of spoil surfaces.

As part of the soil stripping study to be conducted a soil utilisation plan should be included. This soil utilisation guide should be implemented during the operational phase.

Stripping and Stockpiling The project description states that the first 3 months will be dedicated to stripping and storing of topsoil and the establishment of storm water diversion channels to ensure compliance with GN 704 of 4 June 1999.

Stockpiling is a process in which the different layers of topsoil (A-G) are removed separately and dumped on separate sites, to replace them back in future as the final topsoil. Where relevant the process includes the following:  The A and B-horizon should be stripped and stockpiled separately (if possible based on the availability) as specified by the Chamber of Mines (Guidelines for the rehabilitation of mined land, Section 3.2). Each stockpile should consist of a section for both the A and B-horizons. The A and B-horizon sections should be marked with a signboard.  The A and B-horizon should be replaced in the same sequence on top of the soft overburden material. The fairly higher organic carbon content of A-horizons provides a buffer against compaction and hard setting. The A-horizon is also a seed source which will escalate the re- establishment of natural species. When B-horizons are replaced on the surface, they tend to seal and compact severely, which intensifies runoff and causes erosion.

The soil fertility status should be determined by soil chemical analysis after levelling (before seeding / re-vegetation) and soil enrichment should be done advised by a soil specialist in order to correct the pH.

The depth of stockpile must not be more than 2.5 to 3 m. Soil should be stockpiled away from any material that may result in contamination and cross-contamination should not be allowed. The soil stockpiles should be stabilised and terraced on the downslope side to avoid erosion of the stockpiles by water runoff. The stockpiles should be re-vegetated using a creeping indigenous grass seeding to ensure stability as well as possible material accumulation.

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Topsoil stockpiles degrade during long-term stockpiling. It loses organic content and fertility. The pH and fertility levels need to be optimal for crop production. It is expensive to reach and sustain and does not occur naturally. Rehabilitation should start as soon as possible.

Replacing of topsoil Proper stripping and stockpiling of the original soil types is the first key to proper rehabilitation which will enable the reconstruction of the pre-mining land capability as far as possible.

Proper shaping of the spoil layer to a freely drained surface and as close to the original topography as possible is the second key to proper rehabilitation. Failing in these 2 critical requirements will definitely adversely affect the post-mining land capability even with other rehabilitation requirements at its best.

The soils should be placed back in consolidated blocks with a pre-assigned land capability class for each block to prevent frequent varying depths which lead to small fragmented land capability units. The land capability class will be determined by the soil type and the thickness of the soil layer placed back on the spoil surface.

Topsoil should be dumped in sufficient quantities to allow a once-off levelling on top to prevent compaction in the lower soil profile which cannot be alleviated with normal agricultural equipment. Topsoil should not be spread over distances with dozers and bowl scrapers should not be used. These precautions will ensure that the rehabilitation process meet the EMPR commitments for closure purposes.

The soil fertility status of the rehabilitated land should be determined and soil amelioration should be take place accordingly before re-vegetation takes place.

Surface and cover-soil surfaces will be shaped to allow free drainage throughout the area to prevent water logging and subsidence

1.2.4.7 Infrastructure Rehabilitation  During the decommissioning phase all non-operational structures and associated infrastructure will be demolished and removed from site.  All equipment not being utilised will be removed from site.  All concrete foundations and contaminated underlying soil will be handled in terms of the closure plan.  On the removal of all buildings and related infrastructures, the surface will be rehabilitated to a pre-determined standard. A rehabilitation programme, as part of the closure plan, is to be implemented to ensure that the area is completely rehabilitated.

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 The pollution control dams and all other water management structures will be rehabilitated in accordance with the water management strategy to be developed. The fence and access gate around the dams will remain and be adequately signposted  The access roads will remain open to allow access for maintenance and inspections. Any roads that do not require usage will be ploughed and vegetated.  The pump station buildings will be stripped and all pumps and associated equipment removed, once these facilities are no longer of use to the rehabilitation programme. All overland pipelines will be removed.  All the fences and access gates will remain and be adequately signposted.

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2 Description of environmental objectives and specific goals for the management of identified environmental impacts emanating from the proposed mining operation

2.1 List of identified impacts which will require monitoring programmes Refer to sub-section 7 of Section 1 (EIA), for a complete description of the monitoring for the mine.

2.2 List of the source activities that are the cause of the impacts which require to be managed Refer to sub-section 7 of Section 1 (EIA), for a complete description of the source activities that are the cause of the impacts that require to be managed.

2.3 Management activities which, where applicable, will be conducted daily, weekly, monthly, quarterly, annually or periodically as the case may be in order to control any action, activity or process which causes pollution or environmental degradation Refer to sub-section 7 of Section 1 (EIA), for the management activities which, where applicable, will be conducted continuously, daily, weekly, monthly, quarterly, annually or periodically as the case may be in order to control any action, activity or process which causes pollution or environmental degradation.

2.4 The roles and responsibilities for the execution of the monitoring and management programmes Refer to sub-section 7 of Section 1 (EIA), for the roles and responsibilities for the execution of the monitoring and management programmes.

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3 Description of environmental objectives and specific goals for the socio-economic conditions as identified in the social and labour plan

3.1 Human resources development plan The primary objectives of the human resource development program are:  To provide skills training opportunities to mine workers during their employment in order to improve their income earning capacity after mine closure  To promote employment and skills development in the local communities and major labour sending areas  To ensure substantially higher levels of inclusiveness and advancement of HDSAs , including women, in the mining industry  To contribute to the development of a pool of skilled South African workers in support of National Economic and Skills Development strategies

The mine will seek to contribute to the economic, social and educational well-being of its employees and communities (associated with their operations), which will include local business development and providing opportunities for workers from disadvantaged backgrounds.

The mine fully subscribes to the principles of the Mining Charter regarding the empowerment and employment of historically disadvantaged South Africans, including women in mining in order to achieve the representative targets.

3.2 Employment equity plan Aquila shall create a culture of equity and build upon the strengths that diversity brings to promote diversity within the mine. In order to achieve this, the following objectives are critical to the process:

 Eliminate unfair discrimination;  Ensure that the company is recognized as an equal opportunities employer;  Establish and exceed the required degree of representation of designated groups in all occupational categories and levels of the mine;  Integrate the mine’s equity initiatives with the terms of the Skills Development Act, as far as is practically possible; and

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 Increase the number of women, as well as HDSAs in management positions, over time and in line with the stipulated targets.

The principles that Aquila will follow to achieve the above are:

 Mining occupations that are suitable to be occupied by women will be identified in the manpower planning exercise  Strategies will be implemented to attract and retain HDSAs (including women) – for example, development of policies that support the retention of HDSAs  Recruitment processes will be focused on HDSAs and women in mining positions  Individual development plans will be a key mechanism to ensure that those HDSAs identified as having potential based on the skills assessments are earmarked for management positions and developed in line with this  HDSAs will be mentored to provide them with support and assistance to ensure that they can assume their roles with success

Aquila recognises that participation of women in the mining industry and HDSA participation in management is not yet at a desirable level in South Africa. In an attempt to address this issue, Aquila commits to ensuring that at least 10% of its mining workforce is comprised of female employees and that HDSA participation in management is at least at the 40% mark for each management level.

3.3 Mine community development The primary objective of mine community development is to meaningfully contribute towards community development, both in terms of size and impact, in keeping with the principle of the social license to operate.

3.4 Measures to address housing and living conditions The proposed Meletse Iron Ore project is located approximately 30km from Thabazimbi town. It is envisaged that all management employees would reside in the town, whilst the majority of the remaining employees would live in the surrounding areas such as Rooiberg and Regorogile areas.

Aquila recognises its responsibilities in this regard by committing to the facilitation of the provision of accommodation to mine employees that allows employees to reside with their families in a stable, healthy and secure environment within commuting distance from their place of work.

For this reason, Aquila has reviewed the Department of Housing’s policy on housing provision and the following will be undertaken by the proposed mine:

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1. In partnership with the Department of Housing and Local Authorities, provision will be made to build houses for its Paterson A and B-band employees. The policies and procedures of the Department of Housing will be followed as outlined below: a. Through partnership with the municipality, land will be identified for future housing development. The Department of Housing will fund the provision of land and infrastructure and the building of the houses will be funded through current Government housing grants and subsidies. The National Housing Fund will also be approached for mortgages. The mine will facilitate this process in partnership with the Department of Housing. b. C-band and upper employees will be accommodated through the normal property market system. The property market is well established in Thabazimbi and there is no doubt that the private sector can easily create supply for the new demand of housing. It may mean that some staff members are accommodated in guest houses for a short period of time, but thereafter the property market will supply private houses.

Systems for the bussing of employees to and from their residential areas would similarly be facilitated. Aquila plans to provide shift-time related transportation on assigned routes for those living in nearby areas.

Aquila’s housing programmes will be flexible, allowing for a variety of solutions based on the affordability levels of employees. Aquila subscribes to meeting the challenges of housing and living conditions through partnerships with all the relevant stakeholders. Engagement with local municipalities, in particular, is vital as they are responsible and accountable for ongoing service delivery.

3.5 Processes pertaining to management of downscaling and retrenchment In accordance with the regulations of the MPRDA, Aquila will establish a Future Forum within two years after the new mining right has been granted. A future forum is a joint labour and management committee established at mine site level that will focus on the implementation and monitoring of the Social and Labour Plan.

Below is an overview of the envisaged functions of the Future Forum at Aquila:  Generate awareness of the Social and Labour Plan and associated activities;  Act as a communication mechanism on mine related issues between workers and their representatives and the operation.  Implement strategies and policies agreed upon by both parties.  Identify solutions to problems and challenges which may arise or impact on operations.  Discuss issues related to retrenchment and downscaling, as well as turn-around strategies.

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 Negotiate and take measures to avoid job losses as well envisage and implement contingency plans.  Develop and implement prevention and redeployment strategies in the management of retrenchments as well as coordinating the notification process.

The forum will also be responsible for:  Notifying the Minerals and Mining Development Board (as required by section 52 of the MPRDA), where retrenchment of 500 employees or 10 percent of the labour force, whichever is the lesser, is to take place in any 12 month period; and  Notifying the Minister of Labour if retrenchment of 500 employees or ten percent of the workforce, whichever is the greater in this case, is contemplated. The Future Forum will include regular consultations between employees and management and meet on a quarterly basis or as regular as its members decide. When closure of the operation is imminent the forum will meet at least monthly.

Aquila commits to making every effort to promote security of employment through sound management of the operations for the entire life of mine. The contracting companies, once appointed will be expected to play a significant role in supporting initiatives that will contribute to avoiding job losses during retrenchment.

The Social and Labour Plan requires extensive investment (time, resources and money) from the contractors in the training and development of employees. It will be required that they endorse a policy that focuses on retaining skills rather than losing them during retrenchment.

Although not yet identified or appointed, the core contractors are likely to have a number of on-going contracts. Thus, they will be encouraged to seek alternative employment for their employees through various initiatives, including seeking to transfer employees to other projects or companies within the same group (if this is feasible). Such transfers could be between mining and non-mining operations depending on the nature of the projects that the contractor is committed to.

Once the contractors have officially been appointed, Aquila will undertake an analysis, in conjunction with the core contractors, of the various operations and projects the contractors are involved in. This will provide some indication as to the opportunities that might exist for transferring skills within the contracting companies should a retrenchment exercise take place.

In addition, in terms of the company’s skills development strategy, there will be a focus on the provision of portable skills within the workforce throughout the life of mine. These skills should provide those employees who either do not wish to be transferred or who cannot be accommodated in other contractor operations to remain economically active when downscaling and/or retrenchments are unavoidable.

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As well as the aforementioned transfer alternative for employees, the following are alternatives that will also be considered to avoid job losses:  Voluntary or compulsory retirement;  Voluntary retrenchment;  Working shorter hours;  Reduction or elimination of overtime work;  Termination of the services of temporary employees and contractors (subject to contractual terms);  Freeze on new recruitment;  Redeployment;  Job-sharing; and  Any other suggestions identified during consultation.

Where retrenchments are unavoidable, they will be managed humanely and through the formulation of appropriate retrenchment proposals and in consultation with all relevant parties. The following legislative process will be employed:  Consultations – including communicating possible retrenchments  Implementing section 189 of the Labour Relations Act, 1995  Notification to the Minerals and Mining Development Board (the Board)  Complying with the Ministerial Directive

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4 Description of environmental objectives and specific goals for historical and cultural aspects

4.1 Environmental objectives and goals in respect of historical and cultural aspects identified in specialist studies conducted during the EIA phase Refer to sub-section 7 of Section 1 (EIA), for the description of environmental objectives and specific goals for historical and cultural aspects.

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Regulation 51 (b)

5 Appropriate technical and management options chosen for each environmental impact, socio- economic condition and historical and cultural aspect in each phase of the mining operation

5.1 Actions, activities or processes, including any NEMA EIA regulation listed activities, which cause pollution or environmental degradation Refer to sub-section 7.1 of Section 1 (EIA), for a complete description of the actions, activities or processes; including any NEMA EIA regulation listed activities, which cause pollution or environmental degradation.

5.2 Concomitant list of appropriate technical or management options chosen to modify, remedy, control or stop any action, activity, or process which will cause significant impacts on the environment, socio-economic conditions and historical and cultural aspects as identified Refer to sub-section 7.1 of Section 1 (EIA), for a concomitant list of appropriate technical or management options chosen to modify, remedy, control or stop any action, activity, or process which will cause significant impacts on the environment, socio-economic conditions and historical and cultural aspects as identified.

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6 Action plans to achieve the objectives and specific goals contemplated in Regulation 50 (a)

No. Commitment Timeframes Geology

From year 12 1. Concurrent backfilling of the pit from year 12. onwards. Soils

Hydrocarbons and other potentially contaminating materials will be stored within 2. At all times. suitable lined or bunded areas. Servicing of vehicles and equipment will be undertaken within workshops that 3. are equipped with suitably lined floors and hydrocarbon spillage management At all times. equipment. Reporting of significant spillage incident to Any spills of hydrocarbons or other contaminating substances will be recorded, authorities within 4. reported and cleaned immediately using appropriate methods (treated as timeframes as per hazardous waste) Section 20 of NWA and Section 30 of NEMA. Hazardous waste will be stored within suitably bunded areas before being 5. removed by a suitably qualified contractor to an appropriately Licensed waste At all times. disposal facility. Records of the volumes of hazardous waste removed, as well as of the actual 6. disposal of the waste at a Licensed disposal site will be obtained from the At all times. contractor and kept on record by the mine. If new infrastructure is constructed, or if additional surface land use areas are Prior to the disturbed during the Life of Mine, the soils will be characterised by a soil commencement of 7. specialist and the pre-activity state of the soils will be documented prior to the construction and / or stripping and stockpiling of the soil that will take place before the implementation expansion activities. of the activity for later use during rehabilitation. A topsoil balance and topsoil management plan will be developed prior to onset The Soil of mining activities. Management Plan (including soil balance) will be 8. submitted to the DMR prior to the commencement of mining activities. Topsoil balance will

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No. Commitment Timeframes be updated annually. Continuously until Erosion will be prevented as far as practicable. Monthly inspections to identify 9. Closure is obtained. erosion. Monitor monthly. Surface areas over which soils are impacted will be minimised as far as Continuously until 10. possible. Closure is obtained. Continuously until 11. Topsoil stockpiles will be limited to 3 m in height. Closure is obtained. Monitor monthly. Continuously until 12. Erosion of topsoil stockpiles will be minimised. Closure is obtained. Monitor monthly. The Rehabilitation plan will be A rehabilitation plan shall be compiled in which will include appropriate submitted to the rehabilitation methods and strategies for the purpose of establishing the best 13. DMR prior to the practical measures that when implemented, will ensure the long-term commencement of sustainability of the soils within rehabilitated surface land use areas. construction and mining activities. The Code of Practice will be A Code of Practice for all Mine Residue Deposits will be developed prior to submitted to the 14. onset of the mining activities. DMR prior to the commencement of mining activities. Land Capability and Land Use

Rehabilitaion shall be implemented following any disturbance in accordance to Continuously until 15. the rehabilitation plan submitted and approved by the DMR. Rehabilitated areas Closure is obtained. shall be monitored monthly in order to ensure that rehabilitation is effective. Monitor monthly. End land use planning to be Site-specific end land use objectives shall be identified by the mine in conducted during 16. conjunction with the relevant Authorities and I&Aps in order to assist with construction phase Closure planning. and submitted to the DMR. Redundant infrastructure, depending on the historical conservation value of the redundant infrastructure, will be removed and, depending on the end land use, 17. At all times. the remaining footprint areas will be rehabilitated to the agreed end land capability. Vegetation

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No. Commitment Timeframes The threatened pteridophyte Cheilanthes deltoidea subsp. silicicola was confirmed from the Loudetia flavida – Monocymbium ceresiiforme grassland of the mountain summit. This species is restricted to the rock crevices and sheltered soil pockets of the large boulders that are located in open grassland. Other important and protected species: Boophone disticha, Adromischus 18. umbraticola subsp. Ramosus, Eulophia bainesii (Orchidaceae) Spirostachys At all times. africana (Euphorbiaceae), Aloe mutabilis (Asphodelaceae). A permit is required to remove or disturb a protected plant. It is recommended that protected plants in danger of becoming destroyed during any of the planned activities be removed prior to the commencement of construction activities and translocated to suitable habitat, or used during the rehabilitation phase. These rehabilitation Depending on the agreed end land use objectives, identified surface land use activities shall be areas that were disturbed during the Life of Mine will be rehabilitated, reshaped implemented at all 19. and re-vegetated. Rehabilitation activities will include the re-establishment of times until the final naturally occurring vegetation and in such a manner so as to ensure a self- rehabilitation plan sustaining ecosystem has been approved by DMR. Haulage of iron ore material from the mine will be limited to the designated haul 20. At all times. roads and railway sidings. An alien / invader plant species control programme to be submitted to the DMR before the An alien / invader plant species control programme will be developed by a 21. commencement of suitably qualified person and implemented by the mine. construction and mining activities. Implemented continuously, audited annually. Compliance of the mine to the alien vegetation programme will be determined on an annual basis. The findings of such an audit will also be used to improve Annually until 22. the effectiveness and applicability of the alien vegetation control programme, if Closure. necessary. Continuously until 23. Fire breaks will be implemented around all areas. Closure. Animal Life

24. No poaching or illegal killing of animals within the mine boundary will be allowed. At all times.

25. A low speed limit will be enforced on vehicles driving within the mine boundary. At all times. Offenders not complying with the speed limits of the mine during the Operation 26. At all times. Phase will be warned and possibly fined.

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No. Commitment Timeframes Employees of the mine will be educated on the importance of the conservation Annually until 27. of animal life, amongst others. Closure. 28. Employees of the mine are discovered poaching will be warned and fined. At all times. Implement mitigation measures and recommendations identified by the Cape Annually until 29. Vulture specialist. Closure. Surface Water

30. Process water will be used on the mine. At all times Water management measures, such as the pollution control dam or the haul 31. At all times. roads will be undertaken with inert material. A Water Management Plan should be developed for the mine and would include an:  erosion and sediment control plan;  surface water and groundwater monitoring;  a surface water and groundwater response plan; A Water  water levels, yield and quality in the region, and privately owned Management Plan boreholes; to be submitted to 32.  details of the groundwater monitoring program including monitoring the DMR prior to the locations, parameters and commencement of  frequency of sampling; construction and  groundwater assessment criteria for investigating any potentially negative mining activities. groundwater impacts;  Description mitigation options to be implemented if other groundwater users are negatively affected by the mine.  Implement minimum design flood specifications. Establish appropriate purpose-designed infrastructure around opencast pits to During construction 33. divert surface water runoff around the pits. phase. End land use planning to be Depending on the end land use objectives, the final void will be rehabilitated in conducted during 34. situ and will be shaped to divert clean runoff water to the surrounding construction phase catchment. and submitted to the DMR. Within 3 months of Footprint areas remaining subsequent to the removal of redundant surface removal of 35. infrastructure will be reshaped to ensure free drainage. redundant surface infrastructure. Submit surface and The surface water and groundwater monitoring programmes will be groundwater 36. implemented at the mine for the purpose of determining the current and long- monitoring term impacts on the surface water and groundwater components. programme to DWA as part of the

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No. Commitment Timeframes IWULA. Surface water monitoring should be conducted on a monthly basis and groundwater monitoring on a quarterly basis or as stipulated in the WUL. Inspected monthly The water management system infrastructure within the mining area will be and after extreme 37. inspected regularly and maintained when necessary by a suitably qualified rainfall events. person. Maintained when necessary. Measures will continuously be investigated and if feasible be implemented to Continuously until 38. optimise the use of water and thus reduce the volumes of water required for the Closure is obtained. successful operation of the mining and related activities. The potential for contaminated water generation will be minimised as far as 39. At all times. practicable. Clean water shall be separated from dirty water in accordance to the stormwater 40. At all times. management plan approved by DWA. No discharge of contaminated water containing waste to the receiving 41. At all times environment will occur without the required authorisation(s). Hydrocarbon management measures will be implemented to ensure that surface 42. At all times. water contamination is prevented. All contaminated water will be re-used for dust suppression, to limit the intake of Continuously until 43. raw water from the Crocodile River. Closure is obtained. Implement and maintain proper storm water management infrastructure in Continuously until 44. compliance with GN704 of 4 June 1999. Closure is obtained. Water Balance to be compiled as part of The water balance to be conducted will be updated frequently to reflect the the IWULA and current situation of water management at the mine, as well as to comply with the submitted to the requirements of the DWA as indicated in the relevant Best Practice Guidelines. DMR before 45. The water balance will be interactive and will allow for flexibility in terms of commencement of alterations to the water management system, in order to ensure that the water construction and balance reflects the actual situation at the mine at all times. mining activities. At least annual update thereafter. Once a Water Use Licence has been issued by the DWA to the mine, the mine 46. At all times. shall implement all conditions in the Licence. No water use activities will be

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No. Commitment Timeframes undertaken without an approved water use license.

Pollution control dams shall be lined and managed properly and mitigation 47. At all times. measures will be implemented to minimise associated impacts. The mine will investigate the necessity of implementing additional storm water 48. measures such as berms around the opencast areas. This will ensure that At all times. clean water is diverted around dirty water management areas. Groundwater

Prior to the commencement of Ensure that site preparation includes sealing of substrate before developing 49. construction and / or waste rock facility. expansion of waste rock dumps. Rehabilitated areas will be reshaped to prevent excessive ponding of surface During 50. water which may also result in groundwater impacts. Rehabilitation. Pollution control dams will be lined in an effort to minimise the seepage of poor During construction 51. quality leachate. of the dams. Prior to the commencement of Ensure adequate basal sealing of areas where stockpiles and waste rock dumps construction and / or 52. are to be placed. expansion of stockpiles and waste rock dumps. Quarterly as part of All external users’ boreholes within a 2 km radius of any mining activities must 53. the groundwater be monitored for water level response. monitoring program. Water accumulating in the active box cut and excess seepage from rehabilitated During Operational 54. areas, must be pumped out or used during the operational phase as soon as Phase. possible to prevent affected water. Water pumped from the operational open cast pits should be categorised as 55. Continuously. contaminated and should be discharged/stored in pollution control dams. Boreholes will be drilled in accordance to the groundwater monitoring Boreholes to be programme to monitor all possible pollution sources to ensure that the direction drilled prior to and rate of movement of the pollution plume(s) can be determined. Sufficient 56. construction. groundwater level and quality monitoring will be instated around the open pits Monitoring to be and pollution source areas (wastewater facilities). The placing of the done quarterly. groundwater boreholes will be undertaken by a qualified geohydrologist. Reporting of significant spillage In the event of a diesel or oil spill, the affected area will be cleaned immediately incident to 57. to prevent / limit seepage of the hazardous waste to the groundwater. authorities within timeframes as per Section 20 of NWA

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No. Commitment Timeframes and Section 30 of NEMA. 58. Pollution of the groundwater resources will be prevented as far as possible. At all times. Groundwater monitoring will be undertaken throughout the Life of Mine to Quarterly, until 59. indicate the occurrence of any groundwater impacts towards groundwater Closure is obtained. quality. Additional mitigation measures will be implemented at the mine should it be 60. evident from the groundwater monitoring results that the groundwater quality As required. within the study area are deteriorating due to current mining activities. The surface of the mining and related areas will be kept free-draining, as far as Continuously until 61. practical, to prevent ponding of contaminated surface water which may lead to Closure is obtained. seepage to the groundwater. The commitments made in the IWULA to be conducted pertaining to the On-going until issue groundwater management aspects will be implemented at the mine. This will of Water Use 62. reduce further impacts on the groundwater regime, possibly reducing long-term Licence by the environmental liabilities. DWA. Air Quality

The surface of unpaved roads should be properly maintained by grading and 63. Continuously. shaping for cross sectional crowing. A fugitive emission monitoring plan to be conducted and A fugitive emission monitoring plan which consists of continuous monitoring of submitted to the ambient PM10 and PM2.5 and dust fall out monitoring of TSP should be DMR before the 64. implemented. Monitoring should take place prior to establishment of the mining commencement of operations as well as throughout the LoM, and record any increase as a direct mining activities. result of the mining operations. Monitoring to commence before construction and mining commences. Dust deposition is to be measurement according to the Society for Testing and Materials standard 1739- 98 methods recommended in SANS 1929-2004. This 65. involves exposure of a standard bucket for a month, with weighing and chemical Monthly. analysis of the dust collected. Weighing and chemical analysis is to be done by a suitable off-site or on-site laboratory. Dust suppression will be undertaken on the haul roads, as well as on all gravel 66. Twice daily. access roads within the mining area. The movement of vehicles within the mine boundary of the mine will be restricted to the haul roads, as well as to the roads accessing various areas of 67. At all times. the mine. Speed limits will be enforced on the heavy vehicles transporting the material from mine to the processing plant. 68. The size of exposed areas subject to dust generation will be minimised. At all times.

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No. Commitment Timeframes Areas available for rehabilitation will be re-vegetated to minimise the exposed The Rehabilitation soil areas, depending on the end land use to be decided upon. plan will be submitted to the 69. DMR before commencement of construction and mining activities. The dust generated from the mine will be monitored and incorporated into the The dust monitoring dust monitoring programme to be conducted at the mine. Analysis and programme will be interpretation of all the dust monitoring data will be undertaken by a suitably submitted to the qualified person. Dust fallout monitoring will continue to be implemented at the DMR before 70. mine until Closure is obtained. commencement of construction and mining activities. Monitoring monthly; Reporting quarterly The mine will investigate the possibility of implementing air quality monitoring to The air quality indicate the effectiveness of the mitigation measures. This monitoring will monitoring indicate any rise in pollutants, where after proper mitigation measures will be programme will be implemented to prevent any significant impacts pertaining to air pollution on the submitted to the 71. surrounding environment, including any Interested and Affected Parties (IAP’s). DMR before the commencement of any construction and mining activities. Noise and Vibration

72. Handle and store blasting material according to manufacturing requirements. At all times. Train staff and implement correct procedures for the handling of blasting 73. material. Only qualified staff should handle these materials. At all times. Speed limits on the haul and access roads will be enforced to limit the impact on 74. the surrounding environment, biota and Interested and Affected Parties (I&APs) At all times. with regards to noise. All equipment, machinery and vehicles will be maintained and regularly serviced 75. At least biannually. to ensure no additional noise generation. The activities such as loading and hauling of iron ore material will be limited to 76. Day time. day time thus preventing nuisance noise to any I&APs. The mining and related activities undertaken with mechanical equipment close to residential areas will be subject to the legal requirement for controlled noise 77. At all times areas, i.e. 69 dB(A) during day time (6h00 to 18h00 from Monday to Saturday) and the ambient noise plus 7 dB(A) for night time.

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No. Commitment Timeframes Monitoring on hearing loss will be undertaken at the mine, the results of which 78. will be documented and kept on file by the person responsible for environmental Continuously management at the mine. Sites of Archaeological and Cultural Interest

Heritage Management Plan to be compiled and submitted to the A cave management plan to be included in the Heritage management plan will 79. DMR before be conducted prior to onset of the mining activities. commencement of any construction and mining activities. A heritage management plan shall be drafted and implemented. The heritage management plan shall include all the known and surviving heritage sites and shall form part of the normal environmental audit process.

Access shall be provided to descendants and family members to visit their grave sites.

The graves closely associated with the Randstephne homestead shall be relocated. A professional archaeologists that specialise in relocation of Heritage the graves shall be appointed to facilitate the relocation process. Management Plan shall be compiled All of these sites shall need to be submitted to second phase investigation and and submitted to the 80. demolition permits applied for. DMR before the commencement of A well renowned anthropologist shall be appointed to investigate the significance construction and of the cave site as well as the importance of the mountain names MELETSE, mining activities. MAKAPANE AND GATKOP as this may hold the key to the social ancestral importance of the area.

Although the other Gatkop cave site will be sufficiently safe from any of the present proposed mining impact, it still lies inside the boundaries of the prospecting licence and therefore remains the responsibility of Aquila. The cave site shall also have to be documented and placed in the heritage management plan as described by the environmental Act. Visual aspects

Implementation – Suitable vegetation will be utilised for rehabilitation to ensure that the commence after 81. rehabilitated areas resemble the surrounding natural occurring vegetation. any disturbance of vegetation and

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No. Commitment Timeframes continue until rehabilitation is self- sustaining Depending on the agreed end land use objectives of the mine, redundant Prior to Closure is 82. infrastructur e will be removed and the remaining footprint areas will be obtained. rehabilitated. Regional socio-economic structure

A Social Impact A Social Impact Assessment will be undertaken as part of Closure planning for assessment to be the mine, to assess the anticipated impacts of mine Closure, as well as to conducted and 83. determine applicable and appropriate management measures that will mitigate submitted to the the impacts on the employees and businesses that are dependent on the mine. DMR before Close of the mine. The Social and Labour Plan will be implemented to minimise the anticipated 84. At all times. impact of the imminent mine Closure on the employees of the mine. The mine will continue with established community projects throughout the 85. Continuously. Operational Phase to strive in uplifting the local community. The mine will provide the employees with training and skills development to enable these employees to obtain employment elsewhere after the Continuously until 86. decommissioning of the mine, by taking the Closure objectives of the mine into Closure is obtained. account. Interested and Affected Parties

Because most social impacts will result from environmental impacts (air pollution, water contamination, etc.) it is recommended that the mitigation measures listed in the comprehensive selection of specialist studies be adhered 87. At all times. to. It is also recommended that those conditions be included in the EIR and EMPR, as well as the conditions of the authorisation, should the project be approved. All of the activities and / or projects in which the mine is taking part will be Continuously until 88. documented and kept on file, so as to be accessible for future audit purposes or Closure is obtained. available for anyone’s perusal, should it be necessary. Consultation between the mine and I&AP’s such as DWA, DMR, LEDET and the 89. Continuously. Municipality, will continue. A complaints register will be kept at the mine to record I&AP’s issues, the name and contact details of the I&AP lodging the complaint, the date on which the complaint was lodged, the action taken to correct the problem, the date on which 90. At all times. corrective action was taken, and the date on which the I&AP was notified of the corrective action taken. The other identified I&APs should also be notified when the action has been taken. A structured compensation protocol, to be compiled in consultation with external A compensation 91. users, will be commissioned for the open cast mine area. This protocol will protocol to be control alternative water supply to external users in the event that their ground conducted and

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No. Commitment Timeframes water resources have been detrimentally affected. submitted to the DMR before the commencement of construction and mining activities, this protocol is to be implemented at all times. The environmental Establishment of an ernvironmental forum to allow for regular consultation forum will sessions where environmental performance is discussed and changes to the commence prior to 92. mining activities to allow I&AP’s to provide inputs and raised aspects that need construction to be considered by the mine. activities tasking place.

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7 Procedures for environmentally related emergencies and remediation

7.1 Fire management 1. This emergency will be minimised by ensuring that fire breaks have been established. 2. Fire breaks will be maintained on an annual basis before the winter season starts to ensure that the potential spreading can be curbed in the case of a fire. 3. No open fires will be allowed on-site. 4. Fire will be extinguished as soon as possible. 5. The Fire Response Procedure will be developed and implemented.

7.2 Spillages removal 1. Spill kits will be available on site. 2. All spillages will be reported and attended to. 3. Should a spill occur, the person responsible / discovering the spill will take the necessary steps to contain the spill in order to minimise the area that will be affected. 4. The contaminated soil will be lifted and removed as hazardous waste and disposed accordingly.

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8 Planned monitoring and environmental management programme performance assessment

8.1 Description of planned monitoring of the aspects of the environment which may be impacted upon Refer to Paragraph 15 of Section 1 (EIA) for the planned monitoring of the aspects of the environment which may be impacted upon.

8.2 Provide a description as to how the implementation of the action plans contemplated in Regulation 51 (b) (ii) as described will be monitored as described in paragraph 6 of the EMP will be monitored An EMP Performance Assessment (EMP PA) will be conducted every two years (biennial basis), to monitor the effectiveness of the implementation of the commitments as contained in this document.

Random site visits or inspections may be done by the government officials and any deviation raised shall be managed through the Environmental Management System of the mine.

Ad hoc inspections shall also be conducted by the mine’s Environmental Management section during the course of their duties and non-conformances shall be addressed through the Environmental Management System of the mine.

8.3 Frequency of proposed reporting for assessment purposes According to section 55(2)(a) of the MPRDA, a Performance Assessment must be conducted every two years, therefore, the EMP Performance Assessments (EMP PA) for the mine shall be done every two years (biennially).

Refer to Paragraph 15 of Section 1 (EIA) for the planned time frames for monitoring.

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9 Financial provision in relation to the execution of the environmental management programme

9.1 Plan showing the location and aerial extent of the aforesaid main mining actions, activities, or processes anticipated Refer to figure 27 for a Mine Layout Plan.

9.2 Annual forecasted financial provision calculation Table 55 below contains the annual financial provision calculation.

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Table 55: Annual forecast financial provision

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Environmental cost Concurrent Rehab Cost

Dust suppression R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 R 20 000.00 Removal of top soil, replacement and revegetation (included in normal R 920 R 920 R 920 operational budget) R 920 033.00 R 920 033.00 R 920 033.00 R 920 033.00 R 920 033.00 033.00 R 920 033.00 R 920 033.00 R 920 033.00 R 920 033.00 033.00 033.00 Water management structures R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 150 000.00 R 0.00 R 0.00 R 0.00 R 0.00 General awareness training R 30 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 30 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 Waste management R.527 Part IV R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 Regulatory cost

Audit on financial provision R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 60 000.00 R 0.00 Monitoring and performance assessment

- Dust Fallout R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 R 10 000.00 - Noise R 0.00 R 0.00 R 45 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 - Bio monitoring R 0.00 R 50 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 50 000.00 R 0.00 R 0.00 R 0.00 - surface and ground water quality and quantity R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 R 30 000.00 - Conducting performance assessment R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 75 000.00 R 0.00 Updating Social and labour plan R 90 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 MHSA requirements R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 R 20 938.33 Social and labour Social and labour plan commitments plan cost R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 Updating of EMP R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 90 000.00 R 0.00 R 1 060 R 1 055 R 1 010 R 1 010 R 1 010 R 1 040 R 1 060 R 1 010 R 1 235 R 1 010 R 1 130 971.33 971.33 971.33 971.33 971.33 971.33 971.33 R 1 160 971.33 971.33 971.33 971.33 971.33

6 percent increase from 2015 to 2016 - CPI increase 2016 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Environmental cost Concurrent Rehab Cost

Dust suppression R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 R 21 200.00 Removal of top soil, replacement and revegetation (normal operational R 975 R 975 R 975 budget) R 975 234.98 R 975 234.98 R 975 234.98 R 975 234.98 R 975 234.98 234.98 R 975 234.98 R 975 234.98 R 975 234.98 R 975 234.98 234.98 234.98 Water management structures R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 160 000.00 R 0.00 R 0.00 R 0.00 R 0.00 General awareness training R 35 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 35 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 Waste management R.527 Part IV R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 Regulatory cost

Audit on financial provision R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 60 000.00 R 0.00

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Monitoring and performance assessment

- Dust Fallout R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 R 12 000.00 - Noise R 0.00 R 0.00 R 47 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 - Biomonitoring R 0.00 R 55 000.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 55 000.00 R 0.00 R 0.00 R 0.00 - surface and ground water quality and quantity R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 R 32 000.00 - Conducting performance assessment R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 Updating Social and labour plan R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 MHSA requirements R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 R 22 194.63 Social and labour Social and labour plan commitments R 305 R 305 R 305 plan cost R 305 166.66 R 305 166.66 R 305 166.66 R 305 166.66 R 305 166.66 166.66 R 305 166.66 R 305 166.66 R 305 166.66 R 305 166.66 166.66 166.66 Updating of EMP R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 0.00 R 1 434 R 1 426 R 1 379 R 1 379 R 1 379 R 1 414 R 1 434 R 1 379 R 1 439 R 1 379 R 1 414 796.27 796.27 796.27 796.27 796.27 796.27 796.27 R 1 539 796.27 796.27 796.27 796.27 796.27

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9.3 Confirmation of the amount that will be provided should the right be granted

Should the right be granted the necessary guarantees will be provided for the amount of R48 507 763.18 as calculated in section 12 below. 9.4. The method of providing financial provision contemplated in Regulation 53 The projected financial provision quantum will be provided as per regulation 53 requirements once the mining right has been granted.

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10 Environmental awareness plan (section 39 (3) (c))

The following Environmental Awareness Plan must be implemented by Aquila Steel (Pty) Ltd in order to inform their employees and contractors of the environmental risk that may result from their work. The plan must be conducted as part of the induction process for all new employees (including contractors) that will perform work in terms of all activities undertaken on the mine. Proof of all training provided must be kept on-site.

The Environmental Awareness Plan is referred to as the “SHE match” training programme. The training programme focuses on the following aspects:

1. Explaining clearly what the environment is and what the environment consist of namely: air, water, soil, fauna, flora and people. 2. Once participants have grasped the description of what the environment entails, the training focuses on the potential impacts that the construction and operational activities may have on each one of these environmental components. This is done by making use of the aspect register, where each one of the environmental aspects and associated impacts has been identified. 3. To ensure that the training is effective, visual aids are used. Photos are taken of actual and potential impacts occurring on site and in some cases role-play is used to illustrate a potential impact. 4. The participants are then exposed to a poster that reflects the various environmental components. The various photos taken are posted on the poster on a rotational basis and the participants indicate (based on the visual component) what environmental component was or could have been affected by the activities portrayed on the photo. 5. By doing this the participants visualise the action as well as the potential consequence (environmental impact) of their action. 6. This General awareness training must be done before construction commences and also when new employees start work. The training should be done every two years during the Operational Phase. The poster is posted in the communal area where the impacts are visualised and the photos rotated on a monthly basis.

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11 Attachment of specialist reports, technical and supporting information

An ecological evaluation for the Aquila Steel project, Thabazimbi Appendix E1 Aquila Steel Meletse Iron Ore Project: Report on geohydrological Appendix E2 investigation as part of the EIA and EMP. Palaeontological Assessment: Site Visit Report. Gatkop cave on farm Appendix E3 Randstephne 415 KQ near Thabazimbi, Limpopo province Cultural heritage resources essay for the farms Donkerpoort 448 KQ, Appendix E4 Randstephne 455KQ and Waterval 443KQ, Limpopo province Assessment of the bats at Gatkop Cave, and possible mitigation measures Appendix E5 Stormwater management plan Appendix E6 Air Quality impact study Appendix E7 Noise survey report February 2014 Appendix E8 Visual impact assessment report 2014 Appendix E9 The Ecological Integrity of the aquatic habitat at the proposed Aquila Steel Appendix E10 mine on the Farms Donkerpoort 448KQ and Randstephne 455KQ, Thabazimbi district, Limpopo Province, South Africa. Environmental Impact Assessment: Ground Vibration and Air Blast Study Appendix E11 Aquila Steel (Pty) Ltd. Meletse Project Traffic impact study Appendix E12 Economic impact study Appendix E13

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12 Section 39 (4) (a) (iii), capacity to manage and rehabilitate the environment

Table 56: Rehabilitation cost estimate Meletse Iron Ore mine - Closure and Rehabilitation costs Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10

1 Infrastructural aspects R 10 340 176 10700176.00 12500176.00 12500176.00 12500176.00 12500176.00 12500176.00 12500176.00 12500176.00 12500176.00

2 Mining areas R 6 084 250 6313750.00 7273750.00 8287000.00 9243250.00 10199500.00 10876000.00 11552500.00 11855125.00 12157750.00

3 General surface reclamation R 11 044 000 11044000.00 11044000.00 11044000.00 11044000.00 11044000.00 11044000.00 11044000.00 11044000.00 11044000.00

4 Water management R 150 000 150000.00 150000.00 150000.00 150000.00 150000.00 150000.00 150000.00 150000.00 150000.00

SUB-TOTAL 1 (Infrastructure and related aspects) R 27 618 426 R 28 207 926 R 30 967 926 R 31 981 176 R 32 937 426 R 33 893 676 R 34 570 176 R 35 246 676 R 35 549 301 R 35 851 926

5 Post-closure aspects R 9 750 000 R 9 750 000 R 9 750 000 R 9 750 000 R 9 750 000 R 9 750 000 R 9 750 000 R 9 750 000 R 9 750 000 R 9 750 000

5.1 Contingency Allowance R 975 000 R 975 000 R 975 000 R 975 000 R 975 000 R 975 000 R 975 000 R 975 000 R 975 000 R 975 000

SUB-TOTAL 2 (Post-closure aspects) R 10 725 000 R 10 725 000 R 10 725 000 R 10 725 000 R 10 725 000 R 10 725 000 R 10 725 000 R 10 725 000 R 10 725 000 R 10 725 000

6 P&Gs (12 percent sub-total 1) R 3 314 211 R 3 384 951 R 3 716 151 R 3 837 741 R 3 952 491 R 4 067 241 R 4 148 421 R 4 229 601 R 4 265 916 R 4 302 231

7 Contingencies (10% of sub-total 1) R 2 761 843 R 2 820 793 R 3 096 793 R 3 198 118 R 3 293 743 R 3 389 368 R 3 457 018 R 3 524 668 R 3 554 930 R 3 585 193

SUB-TOTAL 3 (Additional allowances) R 6 076 054 R 6 205 744 R 6 812 944 R 7 035 859 R 7 246 234 R 7 456 609 R 7 605 439 R 7 754 269 R 7 820 846 R 7 887 424

GRAND TOTAL (Sub-total 1+2+3) R 44 419 480 R 45 138 670 R 48 505 870 R 49 742 035 R 50 908 660 R 52 075 285 R 52 900 615 R 53 725 945 R 54 095 147 R 54 464 350

Table 57: Financial provision calculations as per DMR requirements No Description Unit A B Master C D E=A*B*C*DAmount (rands) Quantity rate Multiplicati Weighting on factor factor 1 Step 4.5 Step 4.3 Step 4.3 Step 4.4 1 Dismantling of processing plant and related structures (Including overland m3 166750 R 12.21 1 1.1 R2 239 839.36 conveyors and power lines)

2(A) Demolition of steel buildings and structures m2 1600 R 170.13 1 1.1 R299 428.80

2(B) Demolition of reinforced concrete buildings and structures m2 5200 R 250.71 1 1.1 R1 434 068.06

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3 Rehabilitation of access roads m2 124000 R 30.43 1 1.1 R4 151 006.64 4(A) Demolition and rehabilitation of electrified railway lines m 0 R 295.61 1 1.1 R0.00

4(B) Demolition and rehabilitation of non-electrified railway lines m 0 R 161.18 1 1.1 R0.00

5 Demolition of housing and/or administration facilities m2 950 R 340.26 1 1.1 R355 571.70

6 Opencast rehabilitation including final voids and ramps ha 31 R 178 1 1.1 R6 082 363.33 368.43 7 Sealing of shafts, adits and inclines m3 0 R 91.33 1 1.1 R0.00

8(A) Rehabilitation of overburden and spoils ha 22 R 118 1 1.1 R2 877 677.27 912.28 8(B) Rehabilitation of processing waste deposits and evaporation ponds (basic, salt- ha 45 R 148 1 1.1 R7 331 103.68 producing waste) 103.10

8(C) Rehabilitation of processing waste deposits and evaporation ponds (acidic, metal- ha 0 R 430 R0.00 rich waste) 161.61

9 Rehabilitation of subsided areas ha 0 R 99 R0.00 571.10 10 General surface rehabilitation ha 45 R 94 1 1.1 R4 662 829.98 198.59 11 River diversions ha 0 R 94 1.1 R0.00 198.59 12 Fencing m 3000 R 107.44 1 1.1 R354 557.28 13 Water management ha 68 R 35 1 1.1 R2 679 107.43 816.94 14 2 to 3 years of maintenance and aftercare ha 68 R 12 1 1.1 R937 686.85 535.92 15 (A) Specialist study Sum 0 R600 000.00 15 (B) Specialist study Sum R730 000.00 Sub Total R34 735 240.37 Preliminary and General 12.5% of Subtotal 1 R4 341 905.05 Contingency 10.0% of Subtotal 1 R3 473 524.04

Total R42 550 669.45

vat 14% R5 957 093.72 R48 507 763.18

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13 Undertaking

The Environmental Management Programme will, should it comply with the provisions of section 39 (4) (a) of the Act and the right be granted, be approved and become an obligation in terms of the right issued. As part of the proposed Environmental Management Programme, the applicant is required to provide an undertaking that it will be executed as approved and that the provisions of the Act and regulations thereto will be complied with.

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14 Identification of the report

Herewith I, the person whose name and identity number is stated below, confirm that I am the person authorised to act as representative of the applicant in terms of the resolution submitted with the application, and confirm that the above report comprises EIA and EMP compiled in accordance with the guideline on the Departments official website and the directive in terms of sections 29 and 39 (5) in that regard.

Full Names and Surname

Identity Number

Shangoni Management Services (Pty) Ltd