Zirco Roode Heuwel (Pty) Ltd 25 Mark Street Stellenbosch, 7600, South Africa

KAMIESBERG PROJECT, NAMAQUALAND

SOUTH AFRICA

FINAL SCOPING REPORT

Reference Numbers: NC/EIA/13/NAM/KAM/RLS1/2013 NCP/EIA/0000249/2013

Prepared for:

Zirco Roode Heuwel (Pty) Ltd 25 Mark Street Stellenbosch, 7600, South Africa

Prepared by:

Coastal& Environmental Services Grahamstown P.O. Box 934 Grahamstown, 6140 South Africa (+27) 46 622 2364 Also in East London www.cesnet.co.za

January 2014

i Final Scoping Report – January 2014

This Report should be cited as follows: Coastal & Environmental Services, January 2014: Kamiesberg Project, Namaqualand, South Africa, Final Scoping Report, CES, Grahamstown, South Africa.

COPYRIGHT INFORMATION This document contains intellectual property and proprietary information that is protected by copyright in favour of Coastal & Environmental Services and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal & Environmental Services. This document is prepared exclusively for submission to World Titanium Resources Ltd, and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa and Madagascar

Coastal & Environmental i Services i Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

CES Report Revision and Tracking Schedule

Document Title Final Scoping Report – Kamiesberg Project, Zirco Roode Heuwel

Client Name & Mark McKinney Address 25 Mark Street, Stellenbosch, 7600 Document Reference

Status Final

Issue Date January 2014

Lead Author Dr Chantel Bezuidenhout – [email protected]

Ms Tarryn Martin – [email protected]

Ms Hannah de Wet – [email protected]

Mr Thomas King – [email protected]

Reviewer Dr A.M. Avis [email protected]

Study Leader or Registered Dr A.M. Avis Environmental [email protected] Assessment Practitioner Approval Report Distribution Circulated to No. of hard No. copies electronic copies Mark McKinney 0 1

This document has been prepared in accordance with the scope of Coastal & Environmental Services (CES) appointment and contains intellectual property and proprietary information that is protected by copyright in favour of CES. The document may Coastal & Environmental Services therefore not be reproduced, used or distributed to any third party Grahamstown without the prior written consent of Coastal & Environmental 67 African Street Services. This document is prepared exclusively for use by Zirco Grahamstown 6039 Roode Heuvel (Pty) Ltd. CES accepts no liability for any use of this P.O. Box. 934 South Africa document other than by Zirco Roode Heuwel (Pty) Ltd and only for Tel: +27 46 622 2364/7 the purposes for which it was prepared. No person other than the Fax: +27 46 622 6564 client may copy (in whole or in part) use or rely on the contents of [email protected] this document, without the prior written permission of CES. The www.cesnet.co.za document is subject to all confidentiality, copyright and trade Also in East London, Port Elizabeth & Maputo secrets rules, intellectual property law and practices of South Africa.

Coastal & Environmental Services ii Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

EXECUTIVE SUMMARY

INTRODUCTION

The preparation of this Scoping Report is the first stage of a comprehensive Environmental and Social Impact Assessment (ESIA) of the Kamiesberg Project, the purpose of which is to exploit proven heavy mineral sand deposits 35 km to the southwest of the town of Garies in the Northern Cape Province of South Africa.

Zirco holds the prospecting rights to the Roode Heuvel and Leeuvlei deposits, and are also in the process of acquiring prospecting rights for a further deposit immediately east of and adjacent to Roode Heuvel, referred to as “Sabies”. This report deals with all three areas which combined form Zirco’s Kamiesberg Project. Information regarding the deposits has been based on a drilling programme on the Roode Heuvel and Leeuvlei portions, as Zirco has not drilled the Sabie deposit yet. To date Zirco has completed 12 843 m of air core drilling and fully delineated the deposits on Roode Heuvel and Leeuvlei. Drilling was extended to the basement rock to fully define the depth of the deposit. Global total heavy mineral grades (THM) are in the order of 3%, with both deposits together projected to contain some 1 400 million tons of mineralised sand. These sands consist of surface aeolian sand (referred to as Red Aeolian Sands - RAS), and higher slimes, mineralised sand (referred to as Orange Feldspathic Sands – OFS). These make up the bulk of the deposit. Basal grits and conglomerates are locally developed immediately above the basement.

In addition to the mining and associated infrastructure (mineral separation plant, primary concentrator plant, tailings dam, offices, workshops and stores, for example.), the project will also require the construction of various ancillary infrastructure such as, but not limited to, the following:

 Seawater intake, desalination plant, pumping station and pipeline  Waste water treatment works  Product transfer stations  Airstrip  Upgrade of the provincial road to and junction with the N7 road  Fuel Depot  Temporary construction accommodation at the mine site.  Provision of erven in Garies for the creation of staff accommodation, either owner built or built by Zirco.

The exact infrastructure requirements are not known at this stage, as this varies with the various alternatives to be assessed.

THE EIA PROCESS AND APPLICABLE LEGISLATION

The legal framework which has guided the EIA includes both international standards and South African legislation. The International Finance Corporation’s (IFC) Performance Standards 1-6 and 8 were applied to this project. Performance Standard 7 (indigenous peoples) was deemed not to apply, and the IFC General Environment, Health and Safety (EHS) guidelines and IFC Mining EHS guidelines were also applied. All relevant South African legislation was applied, in particular the legislation regarding impact assessments and mining.

The EIA process is initiated through a Scoping phase, which includes submitting an application to the regulatory authorities. From this, the Terms of Reference for the full EIA are formulated, and any expectations that the authorities may have of the process must be clarified at this stage. The scoping process brings stakeholders on board, involves consultation with all the relevant government departments, and identifies and confirms issues and concerns.

Coastal & Environmental Services iii Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

PROJECT DESCRIPTION

Zirco Roode Heuwel (Pty) Ltd (hereafter referred to as Zirco) currently holds the prospecting right to the Roode Heuvel and Leeuvlei deposits, located approximately 500 km north of Cape Town in the Northern Cape Province of South Africa. They are also in the process of acquiring prospecting rights for a further deposit immediately east of and adjacent to Roode Heuvel, referred to as “Sabies”. This report deals with all three areas which combined form Zirco’s Kamiesberg Project.

Based on the drilling programme completed, mineral resource estimates and mining studies undertaken at the Roode Heuvel deposit show that it alone has an estimated mineral reserve of 270 million tons at 4.8% THM which could support 20 years of mining at a rate of 1 500 to 2 300 tons per hour (tph). Mining operations are planned to cover approximately 3 500 hectares.

Dry mining using front end loaders is the most likely scenario. It is a low risk option and does not require as much water as a dredge mining operation. The latter could also be unsuitable given the high amounts of slimes in the deposit. Initial mining will target the higher grade areas at an initial rate of 1 000 to 1 500 tph. After year 6 the operation will move to the lower grade areas and the mining rate will increase to 1 800 to 2 300 tph to maintain an average output of about 520 000 tons per annum (tpa) of heavy mineral concentrate. Over a 20 year mine life a total of some 270 million tons would be mined.

The mineralised sand will first be concentrated in the Primary Concentrator Plant (PCP) to produce a Heavy Mineral Concentrate (HMC).The HMC will then be processed in a Mineral Separation Plant (MSP) where the final products - ilmenite, monazite, zircon and rutile - will be produced.

Two options exist for the transport of products from the mining operation to the markets:

1. A combination of rail and road haulage. 2. Road transport only.

While the project has been designed to minimise overall infrastructure requirements, mineral sands mining and processing plants require substantial quantities of water and energy (both in the form of fuel and electricity) to operate. Either groundwater or sea water will be used for the wet separation of HMC from sand in the PCP. The amount of sea water required for the PCP is estimated at 12 million m3 per annum. Three types of Sea Water Intake works have been proposed as a source of water for the mine, these include:

 Open Water Intake in Khnyp Bay as a stand-alone installation;  An Open Water Intake in Khnyp Bay as part of the envisaged new harbour development;  Gully Intakes (various location options).

The quantity of freshwater required has been estimated at 690 000 m3 per annum. This will be used for potable water and to remove salt from the HMC prior to it going into the MSP.

To provide this fresh water a reverse osmosis desalination plant is planned to be constructed at the mine site. The desalination plant will either treat brakish ground water or sea water brought to the mine site as process water. A small quantity of this seawater will be bled off to supply the desalination plant with raw water. The freshwater produced from the desalination plant will be used to wash salt from the HMC prior to separation in the MSP. Water used to wash HMC will be recycled into the process water.

Feasibility study project managers and international experts in heavy mineral mining, TZMI, have estimated a power requirement of 15 MW, to be sourced from the national power grid. This line would need to be constructed from the Frontier Rare Earths project at Zandkops Drift. They intend to construct a high voltage transmission line to service their project. The 35 km line from Frontier to Roode Heuwel would be subject to a separate EIA undertaken directly on behalf of Eskom.

Coastal & Environmental Services iv Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Approximately 10 million litres of fuel will be required for the MSP and related project use per annum. Both diesel and paraffin will be required, necessitating the need for constructing a fuel depot. This will be done by a fuel supply company who will sell fuel on site to the mine.

Ancillary infrastructure will include the following:

 Construction and Operation Accommodation  Sewage Treatment Works  Airstrip  Landfill Site

THE NATURAL ENVIRONMENT

Climate

Namaqualand is a semi-desert area with dry summers and rainfall occurring during the winter months, with most rainfall between May and August (Desmet, 2007). The area receives an average of 95 mm rainfall per annum, fluctuating between the highest rainfall in June (16.7 mm average) and the lowest in December (0.8 mm average). Other important sources of precipitation are in the form of coastal fog and heavy dew, the source of which is the nearby Atlantic Ocean. The temperature regime is moderate with a mean maximum summer temperature of less than 30°C, and average of 18.4°C in July.

The area experiences wind on a daily basis, peaking in the evening where average wind speeds are 25km/hr. During the day wind speeds are much lower dropping to below 10km/hr.

Landscape

Namaqualand covers 55 000 km2 of quartz-strewn plains, undulating hills, granite outcrops and rugged mountains (Olivier, 2005). Namaqualand is bordered to the north by the Orange (Gariep) River and to the south by the Olifants River. To the east it borders Bushmanland, and to the west the Atlantic Ocean. The project site occurs in the southern half of this area, in a belt within 20 km of the Atlantic Ocean.

Geohydrology

Schlumberger Water Services recently performed a hydrocensus of the project area. During this study they located 11 boreholes within the three prospecting areas. No data is currently available on the yields of these boreholes. The water is extracted using wind mills and is used for livestock watering and to a lesser extent for domestic use. All groundwater obtained from these boreholes was found to be brackish. For drinking water, local residents harvest rain water.

Groundwater levels in the area ranged from 1.6 metres to 80.5 metres below surface, and groundwater flows in a westerly direction, towards the Atlantic Ocean (Schlumberger Water Services, 2012). All groundwater samples exhibit similar geochemical signatures, indicating a similar source of groundwater.

Surface Water

The project area is drained by the Bitter and Outeep rivers to the north of the Leeuvlei prospecting area. The Outeep River is a tributary of the Bitter River. To the south is the Groen River, which defines the southern border of the Roode Heuvel prospecting area. All these rivers are ephemeral, meaning that they only flow temporarily after heavy rainfall.

Coastal & Environmental Services v Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Marine Environment

The littoral zone (the area from the high water mark to shoreline areas that are permanently submerged) along the west coast consists of alternating zones of rocky and sandy shores (i.e. sandy beaches), which is true for the coastal area near the proposed Kammiesberg Project. Two key vegetation types occur along the coastal zone above the littoral zone, namely: seashore dunes and coastal duneveld. Seashore dunes occur as a belt along the coastline, above the high tide water mark, generally behind sandy beaches, and on the seaward side of the Coastal Duneveld. Essentially the seashore dunes are covered in Namaqualand Seashore Vegetation, but there are also transition zones of seashore vegetation occurring on white dune sands, which have taller shrubs, but are not considered part of the Coastal Duneveld. Coastal duneveld is situated on the inland side of the seashore dunes, and eventually merges into Strandveld further inland.

Vegetation and Floristics

The project site is located within the Succulent Karoo Biome which stretches from the Luderitz district of Namibia along the western belt of the Northern Cape down to the Western Cape. It is the fourth largest biome in South Africa and is characterised by a mostly flat to undulating terrain with hilly and more rugged terrain occurring in Namaqualand (Mucina and Rutherford, 2006).

Globally there are very few areas that are as biologically distinct as this biome, as none of these regions are dominated by dwarf leaf-succulent shrubs within a winter-rainfall desert (Mucina and Rutherford, 2006). The Succulent Karoo has a rich diversity of species (6 356 species of vascular plants in 1002 genera and 168 families) with 26% of its species being strict endemics and a further 14% being near endemics (Driver et.al., 2003). Seventeen percent are listed as Red Data Species by the International Union for Conservation of Nature 1994 (IUCN).

A survey of the three deposits was undertaken, with notes and photographic evidence recorded at a total of 17 sites across the three deposits and in some cases slightly outside the area. The following vegetation types, based on the SANBI vegetation map (Mucina and Rutherford, 2006) are found within the deposit areas:

 Namaqualand Strandveld – The hilly, irregular terrain in the north-east of Leeuvlei and south-east of Sabies is dominated by Namaqualand Strandveld.  Namaqualand Sand Fynbos – Dominates most of the Roode Heuvel deposit and portions of Sabies. It is associated with the irregular topography of these areas, typified by small hummock and transverse dunes with low lying, inter-dune areas.  Namaqualand Heuweltjieveld – Occurs in the north east of Leeuvlei and the south east of the Sabies deposit, where basement material becomes exposed. These areas will not be mined.

Fauna

Reptile diversity is generally highest in the north eastern extremes of South Africa and declines to the south and west (Alexander and Marais, 2010). However there are localized patches that are high in species richness. The Northern Cape is one of these regions with relatively high species richness and a high proportion of endemics. Most species in this region are confined to rocky habitats and several species are threatened.

Based on species distribution maps, approximately 40 reptile species are likely to occur within the project area. Of those 40 species only one, the Armadillo Girdled Lizard, is listed as a species of special concern.

Amphibians are well represented in sub-Saharan Africa, from which approximately 600 species have been recorded. However, amphibian distribution in southern Africa is uneven both in terms of species distribution and in population numbers (du Preez and Carruthers, 2009). Climate, centres of origin and range restrictions are the three main factors that determine species distribution; with the eastern

Coastal & Environmental Services vi Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014 coast of South Africa having the highest species diversity and endemicity. In contrast, the Northern Cape has a low amphibian endemicity and diversity.

Based on species distributions it is estimated that as many as 10 species may occur in the project area, provided there are suitable micro-habitats to support them. Of these 10 species, one species, the Desert Rain Frog, is a species of conservation concern.

Historical data obtained from the South African National Biodiversity Institute (SIBIS) show that 178 bird species have been recorded within the quarter degree square that the project area occurs in. Of the 178 species, 11 are species of special concern.

Large game makes up less than 15% of the mammal species in South Africa and a much smaller percentage in numbers and biomass. In the Succulent Karoo, large mammals are not generally a feature with the majority of mammals present being small to medium-sized (Driver et.al.; 2003). Mammal species that have adapted to these harsh conditions include klipspringer, aardvark, baboon, steenbok, duiker, porcupine, black-backed jackal and leopard.

Approximately 70 mammal species have been recorded in the Succulent Karoo. Nine percent of these are strict endemics and a further 16% are near endemics. Thirty-six of these species are likely to occur around and within the study site. Of these 36 species, 3 are listed as Vulnerable.

SOCIO ECONOMIC ENVIRONMENT

Located within the Northern Cape Province, the Namakwa District Municipality is the largest municipality (geographically) in South Africa. The District Municipality comprises of 6 Local Municipalities, among them, Kamiesberg Local Municipality. The project area falls within Ward 2 of the Kamiesberg Local Municipality.

Mining and agriculture are the predominant economic activities in the area. Despite the largely semi- arid and arid environment of the province, the fertile land that lies alongside the Orange River supports the production of some quality agricultural products (table grapes produced along the Orange River are exported). The area is further renowned for the quality of the meat produced, including Karoo lamb, ostrich, beef and venison (NDM LEDS 2009: 46).

The farms within the project area typically focus on sheep-farming and consist of family farms which have been subdivided over a few generations. The reduced size of the farms and the semi-arid nature of the land result in farms operating largely as sub-economic units. No large, thriving, agribusiness ventures are present in the project area.

The Northern Cape Province is renowned for its rich mineral content and thus substantial mining activity. Copper, iron ore, manganese, diamonds and asbestos, as well as semi-precious stones and marble are all mined in the Province.

The mining sector has in the past provided the largest contributor to the GDP (52%) of the Namakwa District Municipality, and provided the bulk of employment opportunities within the area, as well as the basis on which many of the small and larger towns in the area are centred upon. However, the relative contribution of mining has declined notably.

The largely semi-arid and arid environment of the District makes the area additionally suitable for tourism and conservation, as well as renewable energy and star-gazing.

Coastal & Environmental Services vii Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

STAKEHOLDER ENGAGEMENT

At the commencement of the project Zirco provided a list of all landowners of the proposed farms directly affected by the mining activities and adjacent landowners. Members of CES conducted a site visit on the 22nd to the 26th of July 2013. During this time members of CES met which each available landowner personally to inform I&APs of the proposed development and provide them with a background information document. In addition to this, all landowners and adjacent landowners were notified of the proposed development via registered mail.

Furthermore, letters of notification and background information documents where sent to landowners that may be affected by the pipeline. Since the servitude for the proposed pipeline has not yet been finalised all property owners within the overall area where notified of the proposed project.

A number of key stakeholders were identified at national, provincial and local level, and information on these are available in Chapter 6. These stakeholders were notified of the proposed development via registered mail. Members of CES met personally with Ms Deidre Williams from the Department of Mineral Resources and Ms Lucille Karsten from the Department of Environment and Nature Conservation in Springbok on the 25th of July 2013.

Registered interested and affected parties as well as key stakeholders were notified of the release of the draft scoping report on 14 November 2013. Stakeholders as well as I&APs were invited to attend a public meeting held at Sophia’s Guesthouse in Garies on 02 December 2013. Affected landowners attended a meeting at Groenriviermond on 03 December 2013 where any questions they had were answered. The comment period to submit comments on the draft scoping report ended on 17 January 2014. These comments were included in this report.

IDENTIFICATION OF ALTERNATIVES

Various alternatives have been identified (Chapter 8 of this report) and will be investigated in the EIA phase. These include, but are not limited to, the no development option, layout options, technology alternatives and operational alternatives.

KEY ISSUES TO BE INVESTIGATED

Activities associated with the design and pre construction phase pertain mostly to exploration. As the project has an exploration license, impacts associated with exploration and the mitigation of these impacts were included in the Exploration EMP compiled to obtain this license and are therefore not repeated here.

Construction phase: The following issues will need to be investigated:

 Issue 1: Impacts on topography  Issue 2: Impacts on traffic  Issue 3: Impacts on health and safety  Issue 4: Impacts on vegetation  Issue 5: Removal of top soil and soil erosion  Issue 6: Impacts on air quality  Issue 7: Noise Impacts  Issue 8: Surface and groundwater pollution  Issue 9: Pollution from solid waste  Issue 10: Impacts on archaeological, palaeontological and/or cultural sites  Issue 11: Impacts on fauna  Issue 12: Impacts on soils  Issue 13: Impacts on the marine and nearshore environment Impacts that may result from the Operational Phase:

Coastal & Environmental Services viii Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

 Issue 1: Loss of agricultural land  Issue 2: Visual impacts  Issue 3: Socio-economic impacts  Issue 4: Noise impacts  Issue 5: Faunal impacts  Issue 6: Impacts on vegetation  Issue 7: Impacts on topography and soils  Issue 8: Loss of topsoil  Issue 9: Soil contamination  Issue 10: Impacts on surface or groundwater resources  Issue 11: Impacts on the marine environment  Issue 12: Impacts on air quality  Issue 13: Radiation related impacts

Impacts that may result from the Decommissioning Phase:

 Issue 1: Impacts on Topography and Soils  Issue 2: Impacts on surface and groundwater resources  Issue 3: Loss of social services  Issue 4: Retrenchment  Issue 5: Pollution of land and water  Issue 6: Impacts on air quality  Issue 7: Impacts related to Noise  Issue 8: Visual Impacts

THE WAY FORWARD – EIA PHASE

This Final Scoping Report includes the Plan of Study (PoS) for the EIA phase, which includes Terms of Reference (ToR) for specialist studies as they are currently envisaged and the methodology that will be used to assess impacts and rate their significance. Consultation with the Department of Environment and Nature Conservation (refered to as DENC) in the Northern Cape will be ongoing throughout this EIA. However, it is anticipated that DENC will provide relevant comment with respect to the adequacy of this Plan of Study for the EIAR, as it informs the content of the Environmental Impact Assessment Report (EIAR) and sufficiency thereof.

The significance of impacts is assessed based on specialist input using a standardised rating methodology. “Significance” includes the spatial and temporal scales of impacts, the likelihood of impacts occurring, and the severity of impacts or potential benefits.

The following specialist studies are proposed for the EIA phase of the proposed development:

 Vegetation Assessment  Biodiversity and Faunal Assessment  Soils and Agricultural Assessment  Ground and Surface Water Assessment  Heritage, Archaeological and Paleontological Impact Assessment  Rehabilitation Assessment  Socio-economic Impact Assessment  Scoping Level Health Impact Assessment  Visual Impact Assessment  Air Quality Assessment  Baseline Radiation Assessment  Waste Management Study  Materials Handling, Transport and related Infrastructure Assessment

Coastal & Environmental Services ix Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

 Marine and Rocky Shore Assessment

An EIAR will be prepared that will draw on the information contained in the above specialists studies to describe the nature of the proposed project and its environmental setting, summarise the results of the specialist studies, and recommended practical and reasonable mitigation measures to avoid, minimise or offset any negative impacts. In this regard the EIA Phase will actively engage and contribute to the planning process so as to mitigate environmental impacts through improved design and layout. The overall objective of the EIAR is to provide DENC with sufficient information about the proposed project and its associated environmental and social impacts on which to make an informed decision.

An Environmental Management Programme (EMPr) will be prepared that provides practical and actionable management, monitoring and institutional measures to be undertaken during the construction, operation and decommissioning of the proposed development. Such measures are designed to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. The public participation process initiated in the Scoping Phase will continue throughout the EIA Phase.

A critical outcome of the EIA phase will be the Draft EIAR and Draft EMPr. These reports will be released for public review and comment, and will also be presented to I&APs during public meetings, before they are finalised and presented to DENC. An environmental authorisation may be granted or rejected by the authority based on the review of these reports. The decision will be advertised, and registered I&APs will also be informed in writing and given the opportunity to appeal the decision.

Coastal & Environmental Services x Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

TABLE OF CONTENTS

1. INTRODUCTION ...... 1

1.1 THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS ...... 2 1.2 MOTIVATION FOR THE ACTIVITY ...... 12 ...... 12 ...... 13 ...... 14 ...... 14 1.3 SCOPING PHASE ...... 14 ...... 15 ...... 15 1.4 ASSUMPTIONS AND LIMITATIONS ...... 16 1.5 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER...... 16 ...... 16 ...... 16 ...... 16 ...... 17 2. THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT PROCESS (ESIA) ...... 18 2.1 ENVIRONMENTAL LEGISLATION IN SOUTH AFRICA ...... 18 ...... 18 ...... 18 ...... 19 ...... 20 ...... 21 ...... 21 ...... 21 ...... 23 ...... 23 ...... 23 ...... 24 ...... 24 ...... 25 ...... 26 ...... 27 ...... 27 ...... 28 2.2 INTERNATIONAL INSTRUMENTS ...... 28 ...... 28 ...... 30 ...... 32 ...... 32 3. PROJECT DESCRIPTION ...... 34

3.1 INTRODUCTION ...... 34 ...... 34 ...... 34 3.2 PROPOSED MINING METHODOLOGY ...... 36 3.3 MINERAL PROCESSING ...... 37 ...... 37 ...... 38 3.4 TRANSPORTATION OF PRODUCT ...... 39 ...... 39 ...... 40 ...... 40 3.5 TAILINGS DISPOSAL ...... 41 3.6 INFRASTRUCTURE ...... 41

Coastal & Environmental Services xi Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

...... 41 ...... 41 ...... 43 ...... 43 3.7 ANCILLARY INFRASTRUCTURE ...... 44 ...... 44 ...... 44 ...... 44 ...... 44 4. THE NATURAL ENVIRONMENT ...... 45

4.1 CLIMATE ...... 45 4.2 LANDSCAPE ...... 45 4.3 GEOHYDROLOGY ...... 48 4.4 SURFACE WATER ...... 49 4.5 MARINE ENVIRONMENT ...... 49 4.6 VEGETATION AND FLORISTICS ...... 49 ...... 49 ...... 54 ...... 54 4.7 FAUNA ...... 60 ...... 60 ...... 61 ...... 62 4.8 CONSERVATION AND PLANNING TOOLS ...... 62 5. SOCIO-ECONOMIC ENVIRONMENT ...... 70

5.1 ADMINISTRATIVE STRUCTURES ...... 70 5.2 DEMOGRAPHICS ...... 70 5.3 ECONOMY OF THE AREA ...... 71 ...... 71 ...... 71 ...... 71 ...... 72 5.4 EDUCATION ...... 72 5.5 HEALTH ...... 72 5.6 POVERTY ...... 72 5.7 HOUSING AND ACCESS TO BASIC SERVICES ...... 72 5.8 ARCHAEOLOGY AND HERITAGE ...... 73 6. STAKEHOLDER ENGAGEMENT (PUBLIC PARTICIPATION)...... 75

6.1 OBJECTIVES OF PUBLIC PARTICIPATION ...... 75 6.2 BENEFITS OF PUBLIC PARTICIPATION ...... 75 6.3 INTERNATIONAL PRINCIPLES OF PUBLIC PARTICIPATION ...... 75 6.4 REGULATIONS AND REQUIREMENTS FOR PUBLIC PARTICIPATION ...... 76 ...... 76 ...... 78 6.5 PUBLIC PARTICIPATION TO DATE ...... 79 ...... 79 ...... 89 6.6 FUTURE ENGAGEMENT ACTIVITIES ...... 90 ...... 90 7. KEY ISSUES ...... 94

7.1 PLANNING AND DESIGN PHASE ...... 94 7.2 IMPACTS THAT MAY RESULT FROM THE CONSTRUCTION PHASE ...... 94 ...... 94 ...... 94 ...... 94

Coastal & Environmental Services xii Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

...... 94 ...... 95 ...... 95 ...... 95 ...... 95 ...... 95 ...... 95 ...... 95 ...... 95 ...... 96 7.3 IMPACTS THAT MAY RESULT FROM THE OPERATIONAL PHASE ...... 96 ...... 96 ...... 96 ...... 96 ...... 96 ...... 96 ...... 97 ...... 97 ...... 97 ...... 97 ...... 97 ...... 97 ...... 97 ...... 98 7.4 IMPACTS THAT MAY RESULT FROM THE DECOMMISSIONING PHASE ...... 98 7.4.1 Issue 1: Impacts on Topography and Soils ...... 98 7.4.2 Issue 2: Impacts on surface and groundwater resources ...... 98 7.4.3 Issue 3: Loss of social services ...... 99 7.4.4 Issue 4: Retrenchment ...... 99 7.4.5 Issue 5: Pollution of land and water ...... 99 7.4.6 Issue 6: Impacts on air quality ...... 99 7.4.7 Issue 7: Impacts related to Noise ...... 99 7.4.8 Issue 8: Visual Impacts ...... 100 8. ALTERNATIVES ...... 101

8.1 FUNDAMENTAL ALTERNATIVES ...... 101 8.2 INCREMENTAL ALTERNATIVES ...... 101 8.2.1 Layout Alternatives ...... 101 8.2.2 Technology Alternatives ...... 101 ...... 104 8.3 NO DEVELOPMENT ALTERNATIVE ...... 104 9. PLAN OF STUDY FOR THE EIA PHASE ...... 105

9.1 SCOPE AND INTENT OF THE EIA PHASE ...... 105 9.2 THE PUBLIC PARTICIPATION PROCESS ...... 106 9.3 ENVIRONMENTAL IMPACT ASSESSMENT REPORT (EIAR) ...... 106 9.4 SPECIALIST STUDIES...... 108 9.5 SPECIALIST STUDIES: DRAFT TERMS OF REFERENCE ...... 108 9.5.1 Vegetation Assessment ...... 108 9.5.2 Biodiversity and Faunal Assessment ...... 109 9.5.3 Soils and Agricultural Assessment ...... 110 9.5.4 Ground and Surface Water Assessment ...... 110 9.5.5 Heritage Impact Assessment ...... 110 9.5.6 Rehabilitation Assessment ...... 111 9.5.7 Socio-economic Impact Assessment ...... 112 9.5.8 Scoping Level Health Impact Assessment ...... 112 9.5.9 Visual Impact Assessment ...... 113 9.5.10 Air Quality Assessment ...... 113 9.5.11 Baseline Radiation Assessment ...... 114

Coastal & Environmental Services xiii Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

9.5.12 Waste Management Study ...... 115 9.5.13 Materials Handling, Transport and related Infrastructure Assessment...... 115 9.6 OPTIONAL SPECIALIST STUDY: MARINE AND ROCKY SHORE ASSESSMENT ...... 115 9.7 METHODOLOGY FOR ASSESSING THE SIGNIFICANCE OF IMPACTS ...... 116 10. REFERENCES ...... 117 11. APPENDICES ...... 118

LIST OF FIGURES

FIGURE 1.1: KAMIESBERG MINERAL SANDS PROJECT IN THE NORTHERN CAPE (SOURCE: ZIRCO) ...... 1 FIGURE 1.2: PRIORITY AREAS AND NATIONAL PARKS IN PROXIMITY TO THE PROPOSED PROJECT SITE RESULTING IN LISTED ACTIVITIES BEING TRIGGERED FROM GNR 546 (LISTING NOTICE 3)...... 12 FIGURE 1.3: GLOBAL SULPHATE ILMENITE SUPPLY/DEMAND BALANCE UP TO 2020 ...... 13 FIGURE 1.4: GLOBAL ZIRCON SUPPLY/DEMAND BALANCE UP TO 2020 ...... 13 FIGURE 1.5: GLOBAL RUTILE SUPPLY/DEMAND BALANCE UP TO 2020 ...... 14 FIGURE 3.1: THE PROSPECTING AREAS IN RELATION TO GARIES...... 35 FIGURE 3.2: ROODE HEUVEL LITHOLOGICAL CROSS SECTION, 20:1 VERTICAL EXAGGERATION ...... 36 FIGURE 3.3: MINING OPERATION AND ORE DELIVERY FLOW DIAGRAM ...... 37 FIGURE 3.4: SIMPLIFIED FLOW SHEET FOR A SINGLE PRIMARY CONCENTRATOR ...... 38 FIGURE 3.5: SIMPLIFIED FLOW SHEET FOR A MINERAL SEPARATION PLANT ...... 39 FIGURE 3.6: SINGLE POINT MOORING ...... 40 FIGURE 3.7: PROPOSED INTAKE WORKS AT KHNYP BAY ...... 42 FIGURE 3.8: ALTERNATIVE GULLIES LOCATIONS FOR SEAWATER INTAKE ...... 43 FIGURE 4.1: SUMMARY OF NAMAQUALAND WEATHER, SHOWING AVERAGE TEMPERATURE, PRECIPITATION AND WIND SPEED...... 45 FIGURE 4.2: NAMAQUALAND WITH THE PROJECT AREA INDICATED BY THE RED RECTANGLE...... 46 FIGURE 4.3: GEOLOGY OF THE SITE ...... 48 FIGURE 4.4: MUCINA AND RUTHERFORD VEGETATION MAP INDICATING THE VEGETATION TYPES THAT OCCUR IN THE PROJECT AREA ...... 52 FIGURE 4.5: SKEP VEGETATION MAP INDICATING THE VEGETATION TYPES THAT OCCUR IN THE PROJECT AREA...... 53 FIGURE 4.6: GOOGLE IMAGE OF THE THREE PROSPECTING RIGHTS, SHOWING LOCATION OF THE OBSERVATION POINTS DESCRIBED IN TABLE 5.2 BELOW ...... 55 FIGURE 4.7: CRITICAL BIODIVERSITY AREAS FOUND WITHIN THE PROJECT AREA. (CBA = CRITICAL BIODIVERSITY AREA; EAS = ECOLOGICAL SUPPORT AREA) ...... 66 FIGURE 4.8: FORMAL PROTECTED AREAS, NATIONAL PROTECTED AREAS EXPANSION STRATEGY AND SKEP PRIORITY AREAS ...... 67 FIGURE 4.9: POSSIBLE EXPANSIONS OF THE NAMAQUA NATIONAL PARK ...... 68 FIGURE 4.10: VERTEBRATE PRIORITY AREAS IDENTIFIED BY SKEP ...... 69 FIGURE 6.1: MAP SHOWING THE PROPOSED PROSPECTING AREAS AS WELL AS PROPERTIES ADJACENT TO THESE .... 84 FIGURE 6.2: MAP SHOWING ALL PROPERTIES SOUTH OF THE MINING AREA THAT MAY BE AFFECTED BY THE PIPELINE 85 FIGURE 6.3: COPY OF ADVERTISEMENT PLACED IN DIE BURGER ...... 90 FIGURE 8.1: PROPOSED INTAKE WORKS AT KHNYP BAY ...... 102 FIGURE 8.2: ALTERNATIVE GULLIES LOCATIONS FOR SEAWATER INTAKE ...... 103

LIST OF TABLES

TABLE 1-1: LISTED ACTIVITIES TRIGGERED BY THE PROPOSED KAMIESBERG PROJECT ...... 3 TABLE 1.1: FARM NAMES AND CO-ORDINATES OF THE MINING DEPOSISTS ...... 34 TABLE 4.1: A SUMMARY OF THE NUMBER OF PLANT SPECIES THAT OCCUR ON THE VARIOUS CONSERVATION BODIES LISTS...... 54 TABLE 4.2: DESCRIPTION OF SITE OBSERVATION POINTS AND SELECTED PHOTOGRAPHS SHOWING RELEVANT DETAILS OF THE SITE ...... 56 TABLE 4.3: REPTILE SPECIES IN THE REGION THAT ARE LISTED IN THE INTERNATIONAL RED DATA BOOK OF REPTILES AND AMPHIBIANS ...... 60 TABLE 4.4: THREATENED AND ENDEMIC FROGS LIKELY TO OCCUR IN THE PROJECT AREA ...... 61 TABLE 4.5: THREATENED BIRD SPECIES LIKELY TO BE ENCOUNTERED IN THE PROJECT AREA AND SURROUNDS ...... 61 TABLE 4.6: VULNERABLE MAMMALS THAT ARE LIKELY TO OCCUR WITHIN THE PROJECT AREA ...... 62

Coastal & Environmental Services xiv Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

TABLE 4.7: CONSERVATION AND PLANNING TOOLS CONSIDERED FOR THE PROPOSED PROJECT...... 62 TABLE 5.1: POPULATION BY POPULATION GROUP ...... 70 TABLE 5.2: PERCENTAGE DISTRIBUTION OF HOUSEHOLDS BY TYPE OF TOILET FACILITIES ...... 73 TABLE 5.3: PERCENTAGE DISTRIBUTION OF KAMIESBERG LM HOUSEHOLDS BY TYPE OF ENERGY FUEL USED ...... 73 TABLE 6.1: DETAILS OF LANDOWNERS AND OCCUPIERS DIRECTLY AFFECTED BY MINING ACTIVITIES (NAMES IN RED WERE NOT MET PERSONALLY) ...... 79 TABLE 6.2: DETAILS OF LANDOWNERS AND OCCUPIERS ADJACENT TO PROPOSED MINING ACTIVITIES (NAMES IN RED WERE NOT MET PERSONALLY) ...... 81 TABLE 6.3: DETAILS OF LANDOWNERS AND OCCUPIERS WHICH MAY BE AFFECTED BY THE CONSTRUCTION OF THE PIPELINE ...... 82 TABLE 6.4: KEY STAKEHOLDERS IDENTIFIED DURING THE SCOPING PHASE ...... 86 TABLE 6.5: OTHER INTERESTED AND AFFECTED PARTIES WHICH HAVE REGISTERED ...... 89 TABLE 6.6: COMMENTS AND RESPONSE TABLE RECEIVED AT DISCLOSURE OF DRAFT SCOPING REPORT MEETINGS.... 91

LIST OF PLATES

PLATE 3.1: TYPICAL LOADER AND HOPPER DRY MINING OPERATION ...... 36 PLATE 4.1: PICTURES INDICATING THE TOPOGRAPHY OF THE SITE ...... 47 PLATE 6.1: (A) SITE NOTICE ALONG PROPERTY BOUNDARY; (B) SITE NOTICE ALONG MAIN ACCESS ROAD ...... 77 PLATE 6.2: (A) SITE NOTICE AT AGRIMARK IN GARIES; (B) SITE NOTICE AT OK IN GARIES (C) SITE NOTICE AT TOURIST CENTRE IN GARIES (D) SITE NOTICE AT SANPARKS OFFICE ...... 77

Coastal & Environmental Services xv Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

ACRONYMS AND ABBREVIATIONS

CBA Critical Biodiversity Area CES Coastal and Environmental Services CV curriculum vitae DAFF Department of Agriculture Fisheries and Forestry DENC Department of Environment and Nature Conservation DEA Department of Environmental Affairs DMR Department of Mineral Resources DoA Department of Agriculture DWA Department of Water Affairs EAP Environmental Assessment Practitioner EHS Environmental, Health and Safety EIA Environmental Impact Assessment EPFI Equator Principles Financial Institutions EMP Environmental Management Programme EMPr Environmental Management Programme Report ESIA Environmental and Social Impact Assessment HMC Heavy Mineral Concentrate I&APs Interested and Affected Parties IDP Integrated Development Plans IFC International Finance Corporation IUCN International Union for Conservation of Nature LUPO Land Use Planning Ordinance MPRDA Minerals and Petroleum Resources Development Act NDM Namakwa District Municipality NEMA National Environmental Management Act NEMAA National Environmental Management Amendment Act OFS Orange Feldspathic Sands PCP Primary Concentrator Plant PoS Plan of Study PPP Public Participation Process PS Performance Standards RAS Red Aeolian Sand REE Rare Earth Elements SAHRA South African Heritage Resources Agency SANBI South African National Biodiversity Institute SIBIS South African National Biodiversity Institute SKEP Succulent Karoo Ecosystem Plan SSC Species of Special Concern SSU Small Stock Unit STEP Subtropical Thicket Ecosystem planning THM Total Heavy Mineral tpa tons per annum tph tons per hours TZMI TZ Minerals International VIA Visual Impact Assessment Zirco Zirco Roode Heuwel (Pty) Ltd

Coastal & Environmental Services xvi Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

GLOSSARY OF TERMS

Altered ilmenite: A general term used to describe the alteration products of ilmenite, having a chemical composition between ilmenite and pseudorutile. Such products are often termed leucoxene.

Heavy mineral concentrate (HMC): Heavy minerals present in the mined ore are concentrated by means of a gravity separation process at the primary concentrator to produce a heavy mineral concentrate. Typically the heavy mineral concentrate will contain upwards of 90% heavy minerals with the balance being silica sand.

Heavy minerals (HM): Any heavy mineral having a specific gravity greater than 2.9, and including ilmenite, zircon, rutile, leucoxene, monazite, magnetite and chromite.

Ilmenite (FeTiO3): The most abundant titanium mineral, and has a theoretical composition of 52.7% TiO2. However, naturally occurring ilmenite may have a TiO2 content ranging from 35% to 65% depending on its geological history. Ilmenite may contain hematite (an iron oxide mineral) in crystal solution, which can lower the TiO2 content of the ilmenite to less than the theoretical level. Examples of such occurrences are the rock ilmenite deposits at Tellnes in Norway, Lac Allard in Canada, and Panzhihua in China.

Mineral separation plant (MSP): Plant where the heavy mineral concentrate is separated into the final products of ilmenite and the rutile / zircon concentrate.

Non-magnetics: The process stream that is rejected from the magnetic stream using magnetic separation equipment. In mineral sands processing this would typically include minerals such as rutile, zircon and quartz.

Primary concentrator plant (PCP): The plant located at the mine site where the mined ore is processed to remove the bulk of the silica sand to produce a heavy mineral concentrate.

Rutile: A valuable heavy mineral composed essentially of crystalline titanium dioxide and, in its pure state, would contain close to 100% TiO2. Naturally occurring rutile exhibits minor impurities and commercial concentrates of the mineral typically contain between 94 and 96% TiO2.

Total heavy minerals (THM): All heavy minerals in the mineral suit present in the ore body made up of valuable heavy minerals and other or trash heavy minerals.

Valuable heavy minerals (VHM): Minerals that are of commercial value including ilmenite, rutile and zircon.

Zircon (zirconium silicate, ZrSiO4): The most important economic mineral of zirconium. It is commonly found in alluvial deposits in conjunction with other heavy minerals, most typically titanium minerals, in which it can represent up to 30% of the mineral suite. These are the only commercial sources of zircon, and there are no currently known sources that are exploited economically for the zircon content alone.

Coastal & Environmental Services xvii Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

1. INTRODUCTION

Zirco holds the prospecting rights to the Roode Heuwel (6 314 ha) and Leeuvlei (6 005 ha) deposits, and are also in the process of acquiring prospecting rights for a further deposit immediately east of and adjacent to Roode Heuwel, referred to as “Sabies” (8 600 ha). This report deals with all three areas which combined form Zirco’s Kamiesberg Project. Information regarding the deposits has been based on a drilling programme on the Roode Heuvel and Leeuvlei portions, as Zirco has not drilled the Sabie deposit yet. To date Zirco has completed 12 843 m of air core drilling and fully delineated the deposits on Roode Heuvel and Leeuvlei. Drilling was extended to the basement rock to fully define the depth of the deposit. Global total heavy mineral grades (THM) are in the order of 3%, with both deposits together projected to contain some 1 400 million tons of mineralised sand. These sands consist of surface aeolian sand (referred to as Red Aeolian Sands - RAS), and higher slimes, mineralised sand (referred to as Orange Feldspathic Sands – OFS). These make up the bulk of the deposit. Basal grits and conglomerates are locally developed immediately above the basement.

Figure 1.1: Kamiesberg mineral sands project in the Northern Cape (Source: Zirco) In addition to the mining and associated infrastructure (mineral separation plant, primary

Coastal & Environmental Services 1 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014 concentrator plant, tailings dam, offices, workshops and stores, for example.), the project will also require the construction of various ancillary infrastructure such as, but not limited to, the following:

The exact infrastructure requirements are not known at this stage, as this varies with the various alternatives to be assessed.

1.1 The Environmental Impact Assessment Process

However, section 14(2) of NEMAA states that “any provision relating to prospecting, mining, exploration and related activities comes into operation on a date 18 months after the date of commencement of” either NEMAA (62 of 2008) or MPRDAA (49 of 2008), whichever is the later date. The former commenced on 1st May 2009, and the latter on 7th June 2013, so the proposed changes to align the MPRDA with NEMA, and to make the Minister of Mineral Resources the responsible authority for rmining-related environmental matters, will come into operation on 7th December 2014.

Therefore, taking the above analysis into consideration1, it has been established that the current position is that all applications for environmental authorisation must be submitted to the relevant environmental authority, national or provincial as appropriate, and not to the Minister of Mineral Resources.

Accordingly, this EIA process is guided by Regulations made in terms of Chapter 5 of the National Environmental Management Act, 107 of 1998 as amended (NEMA), published as Government Notice No R.543 in Government Gazette No 33306 of 2 August 2010. The Regulations set out the procedures and criteria for the submission, processing and consideration of, and decisions on applications for the environmental authorisation of activities.

Two lists of activities, published on 21 April 2006 and amended 2 August 2010, as Government Notice Numbers R.544 and R.545, define the activities that require, respectively, a Basic Assessment (applies to activities with limited environmental impacts), or a Scoping and Environmental Impact Assessment (applies to activities which are significant in extent and duration). A third list of activities, in GN R.546, is province specific, and lists activities for which environmental authorisation is required if the activities take place in or in the vicinity of certain specified areas, including estuaries, protected or sensitive areas, and areas listed in international conventions such as the Ramsar Convention on Wetlands.

The activities triggered by the proposed development are listed in Table 1-1 below.

1 The analysis was conducted by Warburton Gunn Attorneys, Sustainabiolity Law Specialists of Johannesburg

Coastal & Environmental Services 2 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Table 1-1: Listed Activities triggered by the proposed Kamiesberg Project Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice Listing (2) The construction of facilities or infrastructure for the This listed activity will apply Notice 1 of storage of ore or coal that requires an atmospheric should it be required to store GNR.544 emissions license in terms of the National and/or handle more than EIA Environmental Management: Air Quality Act (Act No. 100 000 tons of ore in an area Regulations 39 of 2004). other than the mine site. dated18 June 2010 Listing (9) The construction of facilities or infrastructure The proposed construction of a Notice 1 of exceeding 1000 metres in length for the bulk pipeline from the coast to GNR.544 transportation of water, sewage or storm water - supply water for mining EIA (i) with an internal diameter of 0,36 metres or activities will be constructed Regulations more; or outside an urban area and/or a dated18 (ii) with a peak throughput of 120 litres per second road reserve, therefore the June 2010 or more, exclusions do not apply. excluding where: Alternatives for the intake of a. such facilities or infrastructure are for bulk this pipeline is yet to be transportation of water, sewage or storm water assessed and may consist of or storm water drainage inside a road reserve; an open water intake at Khnyp or Bay or a gully intake (8 b. where such construction will occur within urban possible locations identified). areas but further than 32 metres from a Either way it is anticipated that watercourse, measured from the edge of the the proposed pipeline will be in watercourse. excess of 1 000 m in length. Listing (11) The construction of: This listed activity will apply to Notice 1 of (i) canals; the construction of the pipeline GNR.544 (ii) channels; which will have to traverse a EIA (iii) bridges; watercourse (i.e. the Groen Regulations (iv) dams; River). dated18 (v) wESIRs; June 2010 (vi) bulk storm water outlet structures; (vii) marinas; (viii) jetties exceeding 50 square metres in size; (ix) slipways exceeding 50 square metres in size; (x) buildings exceeding 50 square metres in size; or (xi) infrastructure or structures covering 50 square metres or more

where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line. Listing (14) The construction of structures in the coastal public Coastal public property refers Notice 1 of property where the development footprint is bigger to coastal waters, land GNR.544 than 50 square metres, excluding submerged by coastal waters, EIA (i) the construction of structures within existing any island in coastal waters, Regulations ports or harbours that will not increase the the seashore, any admiralty dated18 development footprint or throughput capacity reserve owned by the state, June 2010 of the port or harbour; any other state land declared (ii) the construction of a port or harbour, in which as coastal public property and case activity 24 of Notice 545 of 2010 applies; any natural resource occurring (iii) the construction of temporary structures within within any of these areas. It is the beach zone where such structures will be therefore anticipated that the demolished or disassembled after a period not intake of the pipeline, a portion exceeding 6 weeks. of the pipeline itself and possibly the pumping stations

Coastal & Environmental Services 3 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice and port related infrastructure will be situated within what is defined as coastal public property. In addition to this, a portion of the subsea pipeline to the Single Point Mooring (SPM) buoy will also be anticipated to cross coastal public property. Listing (15) The construction of facilities for the desalination of Approximately 690 000 m3 of Notice 1 of sea water with a design capacity to produce more freshwater per annum will be GNR.544 than 100 cubic metres of treated water per day. required for potable water EIA and to remove salt from the Regulations HMC. dated18 To provide this fresh water a June 2010 reverse osmosis desalination plant is planned to be constructed at the mine site. Listing (16) Construction or earth moving activities in the sea, It is anticipated that Notice 1 of an estuary, or within the littoral active zone or a construction of the pipeline to GNR.544 distance of 100 metres inland of the high-water transport seawater to the mine EIA mark of the sea or an estuary, whichever is the site (and possibly the pumping Regulations greater, in respect of – station) and the pipeline to the dated18 (i) fixed or floating jetties and slipways; SPM will occur within 100 m of June 2010 (ii) tidal pools; the highwater mark and the (iii) embankments; littoral active zone. The (iv) rock revetments or stabilising structures exclusions relating to this including stabilising walls; activity do not apply. (v) buildings of 50 square metres or more; or (vi) infrastructure covering 50 square metres or more – but excluding (a) if such construction or earth moving activities will occur behind a development setback line; or (b) where such construction or earth moving activities will occur within existing ports or harbours and the construction or earth moving activities will not increase the development footprint or throughput capacity of the port or harbour; (c) where such construction or earth moving activities is undertaken for purposes of maintenance of the facilities mentioned in (i)- (vi) above; or (d) where such construction or earth moving activities is related to the construction of a port or harbour, in which case activity 24 of Notice 545 of 2010 applies. Listing (18) The infilling or depositing of any material of more The construction of the Notice 1 of than 5 cubic metres into, or the dredging, pipeline to transport seawater GNR.544 excavation, removal or moving of soil, sand, shells, to the mine site (and possibly EIA shell grit, pebbles or rock or more than 5 cubic the pumping station) and the Regulations metres from: pipeline to the SPM will require dated18 (i) a watercourse; excavation and subsequent June 2010 (ii) the sea; infilling within 100 m of the (iii) the seashore; highwater mark and the littoral (iv) the littoral active zone, an estuary or a active zone. distance of 100 metres inland of the high-

Coastal & Environmental Services 4 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice water mark of the sea or an estuary, whichever distance is the greater- but excluding where such infilling, depositing , dredging, excavation, removal or moving; (a) is for maintenance purposes undertaken in accordance with a management plan agreed to by the relevant environmental authority; or (b) occurs behind the development setback line. Listing (22) The construction of a road, outside urban areas, It may be required to construct Notice 1 of (i) with a reserve wider than 13,5 meters or, a haul road from the mine site GNR.544 (ii) where no reserve exists where the road is to existing roads such as the EIA wider than 8 metres, or N7 for the transport of product Regulations (iii) for which an environmental authorisation was for export. dated18 obtained for the route determination in terms of June 2010 activity 5 in Government Notice 387 of 2006 or activity 18 in Notice 545 of 2010. Listing (23) The transformation of undeveloped, vacant or This activity applies to the Notice 1 of derelict land to – construction of the GNR.544 (i) residential, retail, commercial, recreational, accommodation for workers EIA industrial or institutional use, inside an urban and the water treatment facility. Regulations area, and where the total area to be The footprints of these areas dated18 transformed is 5 hectares or more, but less are currently unknown. Should June 2010 than 20 hectares, or the footprint of these areas be (ii) residential, retail, commercial, recreational, less than 1 ha, this activity industrial or institutional use, outside an urban would not apply. area and where the total area to be transformed is bigger than 1 hectare but less than 20 hectares; - Listing (24) The transformation of land bigger than 1000 square At this stage the land use of Notice 1 of metres in size, to residential, retail, commercial, the various areas proposed for GNR.544 industrial or institutional use, where, at the time of the construction is unknown. If any EIA coming into effect of this Schedule or thereafter such of these areas are currently Regulations land was zoned open space, conservation or had an zone as private or public open dated18 equivalent zoning. space or for conservation June 2010 purposes this activity will apply. This may especially pertain to areas classified as coastal public property. Listing (26) Any process or activity identified in terms of section Section 53(1) refers to Notice 1 of 53(1) of the National Environmental Management: threatening processes in listed GNR.544 Biodiversity Act, 2004 (Act No. 10 of 2004). ecosystems and states that the EIA Minister may, by notice in the Regulations Gazette, identify any process dated18 or activity in a listed ecosystem June 2010 as a threatening process and have therefore been included. Listing (47) The widening of a road by more than 6 metres, or Various existing roads within Notice 1 of the lengthening of a road by more than 1 kilometre - close proximity to the mine site GNR.544 (i) where the existing reserve is wider than 13,5 may require upgrading. EIA meters; or Regulations (ii) where no reserve exists, where the existing dated18 road is wider than 8 metres – June 2010 excluding widening or lengthening occurring inside urban areas. Listing (3) The construction of facilities or infrastructure for the A fuel depot will be constructed Notice 2 of storage, or storage and handling of a dangerous at the mine site. GNR.545 good, where such storage occurs in containers with EIA a combined capacity of more than 500 cubic Regulations metres.

Coastal & Environmental Services 5 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice dated18 June 2010 Listing (14) The construction of an island, anchored platform or This listed activity applies to Notice 2 of any other permanent structure on or along the sea the alternative of a single point GNR.545 bed excluding construction of facilities, mooring. EIA infrastructure or structures for aquaculture Regulations purposes. dated18 June 2010 Listing (15) Physical alteration of undeveloped, vacant or The proposed mining area and Notice 2 of derelict land for residential, retail, commercial, associated infrastructure will GNR.545 recreational, industrial or institutional use where the be in excess of 20 ha. EIA total area to be transformed is 20 hectares or more; Regulations except where such physical alteration takes place dated18 for: June 2010 (i) linear development activities; or (ii) agriculture or afforestation where activity 16 in this Schedule will apply. Listing (20) Any activity which requires a mining right or renewal Zirco will be applying to DMR Notice 2 of thereof as contemplated in sections 22 and 24 for mining rights. GNR.545 respectively of the Mineral and Petroleum Resources EIA Development Act, 2002 (Act No. 28 of 2002). Regulations dated18 June 2010 Listing (24) Construction or earth moving activities in the sea, an This listed activity applies to Notice 2 of estuary, or within the littoral active zone or a distance the alternative of a single point GNR.545 of 100 metres inland of the high-water mark of the sea mooring. EIA or an estuary, whichever distance is the greater, in Regulations respect of: dated18 (i) facilities associated with the arrival and June 2010 departure of vessels and the handling of cargo; (ii) piers; (iii) inter- and sub-tidal structures for entrapment of sand; (iv) breakwater structures; (v) coastal marinas; (vi) coastal harbours or ports; (vii) structures for reclaiming parts of the sea; (viii) tunnels; or (ix) underwater channels; but excluding — (a) activities listed in activity 16 in Notice 544 of 2010, (b) construction or earth moving activities if such construction or earth moving activities will occur behind a development setback line; (c) where such construction or earth moving activities will occur in existing ports or harbours where there will be no increase of the development footprint or throughput capacity of the port or harbour; or where such construction or earth moving activities takes place for maintenance purposes. Listing (4) The construction of a road wider than 4 metres with a It may be required to construct Notice 3 of reserve less than 13.5 metres. a haul road from the mine site GNR.546 (a) In Eastern Cape, Free State, KwaZulu- to existing roads such as the EIA Natal, Limpopo, Mpumalanga and Northern N7 for the transport of product Regulations Cape provinces: for export. Depending on the (i) In an estuary; position it may transect

Coastal & Environmental Services 6 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice dated18 (ii) Outside urban areas, in: Succulent Karoo Ecosystem June 2010 (aa) A protected area identified in terms of Plan Priority Areas and is in NEMPAA, excluding conservancies; close proximity to the (bb) National Protected Area Expansion Strategy Namaqua National Park Focus areas; (Figure 1.2) (cc) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; (dd) Sites or areas identified in terms of an International Convention; (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (ff) Core areas in biosphere reserves; (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; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. (iii) In urban areas: (aa) Areas zoned for use as public open space; (bb) Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority or zoned for a conservation purpose; (cc) seawards of the development setback line or within urban protected areas. Listing (8) The construction of aircraft landing strips and The proposed airstrip will be Notice 3 of runways 1.4 kilometres and shorter. shorter than 1.4 km and in GNR.546 (a) In Eastern Cape, Free State, KwaZulu-Natal, close proximity to mining EIA Limpopo, Mpumalanga and Northern Cape activities. Regulations provinces: dated18 (i) In an estuary; June 2010 (ii) Outside urban areas, in: (aa) A protected area identified in terms of NEMPAA, excluding conservancies; (bb) National Protected Area Expansion Strategy Focus areas; (cc) World Heritage Sites; (dd) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; (ee) Sites or areas identified in terms of an International Convention; (ff) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (gg) Core areas in biosphere reserves; (hh) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area

Coastal & Environmental Services 7 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice identified in terms of NEMPAA or from the core of a biosphere reserve; (ii) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined; (jj) Areas on the watercourse side of the development setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined. (iii) In urban areas: (aa) Areas zoned for use as public open space; (bb) Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority or zoned for a conservation purpose. Listing (12) The clearance of an area of 300 square metres or See Figure 1.2 included below. Notice 3 of more of vegetation where 75% or more of the GNR.546 vegetative cover constitutes indigenous vegetation. EIA (a) Within any critically endangered or Regulations endangered ecosystem listed in terms of dated18 section 52 of the NEMBA or prior to the June 2010 publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; (b) Within critical biodiversity areas identified in bioregional plans; (c) Within the littoral active zone or 100 metres inland from high water mark of the sea or an estuary, whichever distance is the greater, excluding where such removal will occur behind the development setback line on erven in urban areas. Listing (13) The clearance of an area of 1 hectare or more of See Figure 1.2 included below. Notice 3 of vegetation where 75% or more of the vegetative GNR.546 cover constitutes indigenous vegetation, except EIA where such removal of vegetation is required for: Regulations (1) the undertaking of a process or activity dated18 included in the list of waste management June 2010 activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008), in which case the activity is regarded to be excluded from this list. (2) the undertaking of a linear activity falling below the thresholds mentioned in Listing Notice 1 in terms of GN No. 544 of 2010. (a) Critical biodiversity areas and ecological support areas as identified in systematic biodiversity plans adopted by the competent authority. (b) National Protected Area Expansion Strategy Focus areas (c) In Eastern Cape, Free State, KwaZulu-Natal, Limpopo, Mpumalanga, Northern Cape and Western Cape: (i) In an estuary; (ii) Outside urban areas, the following:

Coastal & Environmental Services 8 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice (aa) A protected area identified in terms of NEMPAA, excluding conservancies; (bb) National Protected Area Expansion Strategy Focus areas; (cc) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; (dd) Sites or areas identified in terms of an International Convention; (ee) Core areas in biosphere reserves; (ff) Areas within10 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; (gg) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. (iii) In urban areas, the following: (aa) Areas zoned for use as public open space; (bb) Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority or zoned for a conservation purpose; (cc) Areas seawards of the development setback line; (dd) Areas on the watercourse side of the development setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined. Listing (14) The clearance of an area of 5 hectares or more of See Figure 1.2 included below. Notice 3 of vegetation where 75% or more of the vegetative GNR.546 cover constitutes indigenous vegetation, except EIA where such removal of vegetation is required for: Regulations (1) purposes of agriculture or afforestation inside dated18 areas identified in spatial instruments adopted June 2010 by the competent authority for agriculture or afforestation purposes; (2) the undertaking of a process or activity 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 the activity is regarded to be excluded from this list; (3) the undertaking of a linear activity falling below the thresholds in Notice 544 of 2010. (a) In Eastern Cape, Free State, KwaZulu- Natal, Gauteng, Limpopo, Mpumalanga, Northern Cape, Northwest and Western Cape: All areas outside urban areas. Listing (16) The construction of: This listed activity will apply to Notice 3 of (i) jetties exceeding 10 square metres in size; the construction of the pipeline GNR.546 (ii) slipways exceeding 10 square metres in size; which will have to traverse a EIA (iii) buildings with a footprint exceeding 10 square watercourse (i.e. the Groen Regulations metres in size; or River).

Coastal & Environmental Services 9 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Number Activity Description of each listed activity based on the Comments and relevant No(s) project description observations notice dated18 (iv) infrastructure covering 10 square metres or June 2010 more where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line. (a) In Eastern Cape, Free State, KwaZulu-Natal, Limpopo, Mpumalanga and Northern Cape: (i) In an estuary; (ii) Outside urban areas, in: (cc) A protected area identified in terms of NEMPAA, excluding conservancies; (aa) National Protected Area Expansion Strategy Focus areas; (bb) World Heritage Sites; (cc) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; (dd) Sites or areas identified in terms of an International Convention; (ee) Critical biodiversity areas or ecosystem service areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (ff) Core areas in biosphere reserves; (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; (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined. (iii) In urban areas: (aa) Areas zoned for use as public open space; (bb) Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority, zoned for a conservation purpose; or (cc) Areas seawards of the development setback line.

Based on the NEMA EIA listed activities identified by CES, namely the Listing Notice 2 listed activities in GNR.545, the proposed Zirco project’s EIA application will be subject to the scoping and environmental impact assessment reporting process as stipulated in Part 3 of the EIA Regulations (GN R.543 of 18 June 2010, as amended).

The determination of who the relevant competent authority is stipulated in the Listing Notices as the provincial environmental authority unless the application is for an activity/ies contemplated in section 24C(2) of the Act. In this case the competent authority would be the Minister or an organ of state with delegated powers in terms of section 42(1) of the Act. Based on the information provided (and subject to the MSP facility being located at the mine site), the relevant competent authority for the Zirco environmental authorisation application is the Northern Province environmental authority. This has been confirmed by the national Department of Environmental Affairs (see

Coastal & Environmental Services 10 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Appendix 6).

Coastal & Environmental Services 11 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 1.2: Priority areas and National Parks in proximity to the proposed project site resulting in listed activities being triggered from GNR 546 (Listing Notice 3). Additional licensing requirements may include, but not be limited to the following:

 Northern Cape Provincial Heritage Resources Agency: Should any resources of heritage, archaeological and/or paleontological significance (these include national and provincial heritage sites, protected areas, heritage areas, and archaeological and paleontological sites, including wrecks and meteorites) be found on site by the proposed specialist a permit will need to be obtained from the provincial heritage authority (Ngwao Boswa Kapa Bokoni - commonly known as Boswa) for their removal and/or damaging. As a matter of course Boswa is included in the public participation process for this EIA and is given opportunity to comment. The responsibility of obtaining these permits is the responsibility of the proponent.  Department of Water Affairs: It is anticipated that the proposed infrastructure of the mine (viz the proposed pipeline) will cross the Groen River and thus a water use licence will be required from the Department of Water Affairs. Additional water use licences will be required should there be any additional crossings of water resources, including: rivers, wetlands, drainage areas and estuaries.  Department of Agriculture Fisheries and Forestry: There is a range of legislation that list species of special concern. These include but are not limited to The National Forestry Act, NEM: Biodiversity Act, and provincial ordinances. Should any species of special concern be present on site a suitably qualified botanist should be employed to identify these species and apply to DAFF or the Northern Cape Department of Environment and Nature Conservation for the relevant permits for their removal.  Air Quality: An atmospheric emissions licence will be required if it is necessary to store and/or handle more than 100 000 tons of ore in an area other than the mine site.  Department of Environmental Affairs: The construction of a package plant for the treatment of sewage and an on-site landfill site may require waste management licences if thresholds are above those listed in terms of the National Environmental Management: Waste Act 59 of 2008. Disposal of brine, either in on-site evaporation pnds or by discharge into the ocean via a sea outfall, may also require a waste manmagement licence.  Department of Mineral Resources: The relevant mining licences will have to be obtained from the DMR.  Land Use Planning Ordinance: The proponent with the assistance of a town planner will have to apply for a LUPO application should a change in land use be required for the proposed project. In accordance with the Subdivision of Agricultural Land Act (Act 70 of 1970) this rezoning application must also be submitted to the Department of Agriculture Fisheries and Forestry.

1.2 Motivation for the Activity

Under currently foreseen market conditions, and in the absence of major new entrants to the titanium feedstock supply industry, adequate market opportunities exist for the sale of the total output from the Kamiesberg project.

Forecasts indicate that the overall global demand for sulphate ilmenite will increase at a rate of 4.2% over the next 7 years (up to 2020).

Based on the forecast by TZ Minerals International (TZMI) (TZMI, 2012), the global sulphate ilmenite supply/demand is expected to be close to the balance between 2012 and 2013, before moving into moderate surplus in 2014 and 2015 as new supply from a number of approved projects come on line. The market is then expected to move into a progressively larger deficit beyond 2016 if no new supply is brought online to meet the demand for the product. As such, it is expected that the planned 500 000 tpa of sulphate ilmenite from the Kamiesberg Project, which compares favourably to most other competing products, can be absorbed by the market. Figure 1.3 below shows the global sulphate ilmenite supply/demand balance up to 2020. This includes supply from new projects.

Coastal & Environmental Services 12 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 1.3: Global sulphate ilmenite supply/demand balance up to 2020 (Source: TZMI)

Based on the forecast by TZMI, the global zircon supply is expected to remain relatively steady after 2014 even with new supply from several potential projects to be commissioned over the next few years taken into account. Thus beyond 2020 a sharp decline in global supply is inevitable. For this reason new discoveries will be required to sustain supply levels. As such, it is expected that the zircon from the Kamiesberg Project, which compares favourably to most other competing products, can be absorbed by the market. Figure 1.4 below shows the global zircon supply/demand balance up to 2020. This includes supply from new projects.

Figure 1.4: Global zircon supply/demand balance up to 2020 (Source: TZMI)

Coastal & Environmental Services 13 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Based on the forecast by TZMI, global rutile supply deficits are expected to occur after 2014, unless new sources of supply are commissioned. If no new supply becomes available global underlying demand will decrease to match supply. Consumers of rutile pigment will therefore need to use alternative feedstocks such as synthetic rutile and chloride slag. As such, it is expected that the rutile from the Kamiesberg Project, which compares favourably to most other competing products, can be absorbed by the market. Figure 1.5 below shows the global rutile supply/demand balance up to 2020. This includes supply from new projects.

Figure 1.5: Global rutile supply/demand balance up to 2020 (Source: TZMI)

A shortage of rare earth elements (REE) has re-energised interest in monazite as a source of REE. According to TZMI, should monazite become a serious source of REE, the trade for this mineral would be expected to develop quickly into a classic supply/demand scenario as there are many existing sources of monazite that are simply replaced in mine tailings due to the lack of markets. It is therefore assumed that the 4 800 tpa of monazite could be absorbed by the market.

1.3 Scoping Phase

The proposed project is currently in the Scoping Phase. The principal objectives of the Scoping Phase in accordance with the regulatory requirements are to:

 Describe the nature of the proposed project;  Enable preliminary identification and assessment of potential environmental issues or impacts to be addressed in the subsequent EIA phase;  Define the legal, policy and planning context for the proposed project;  Describe important biophysical and socio-economic characteristics of the project-affected environment;  Undertake a public participation process that provides opportunities for all Interested and Affected Parties (I&APs) to be involved;  Identify feasible and reasonable alternatives, that meet the general purpose and requirements of the activity, that must be assessed in the EIA phase; and  Define the Plan of Study (PoS) for the EIA phase.

Coastal & Environmental Services 14 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

This report is the first of a number of reports that will be produced in the EIA process. This Scoping Report has been produced in accordance with the requirements set out in section 28 of the EIA regulations (GNR.543), which clearly outlines the content of a Scoping Report, and sections 54-57 which cover the activities necessary for a successful Public Participation Process (PPP).

Section 1.3.2 below provides the detailed structure of this scoping report.

The structure of the report is as follows -

Chapter 1 - Introduction: Provides background information on the proposed project, a brief description of the EIA process required by NEMA and its associated Regulations. The details and expertise of the Environmental Assessment Practitioner (EAP) who prepared this report are also provided.

Chapter 2 – Relevant Legislation: Identifies all the legislation and guidelines that have been considered in the preparation of this Scoping Report.

Chapter 3 – Project description: Provides a description of the proposed development, the properties on which the development is to be undertaken and the location of the development on the property. The technical details of the project to be undertaken are also provided in this Chapter.

Chapter 4 – Description of the affected environment: Provides a brief overview of the bio-physical and socio-economic characteristics of the site and its environs that may be affected by the proposed development, compiled largely from published information, but supplemented by information from a site visit.

Chapter 5 – Public Participation Process: Provides details of the public participation process conducted in terms of Regulation 28(h) including:

 The measures undertaken thus far to notify I&APs of the application;  Proof that notice boards, advertisements and notices notifying potential I&APs of the application have been displayed, placed or given;  A list of all persons and organisations that were identified and registered in terms of Regulation 55 as I&APs in relation to the application.

Chapter 6 – Issues identified during Scoping: Provides a description of the key issues that have been identified by the project team and through discussions with I&APs thus far in the Scoping phase, and that will be assessed in the EIA phase.

Chapter 7 - Alternatives: Provides a discussion of the feasible and reasonable alternatives that have been identified and considered, some of which will be investigated further in the EIA Phase and other which are discounted at this stage.

Chapter 8 - Plan of Study: Sets out the proposed approach to the environmental impact assessment including:

 A description of the scope of work that will be undertaken as part of the EIA phase, including any specialist reports or specialised processes, and the manner in which the described scope of work will be undertaken;  An indication of the stages at which the competent authority will be consulted;  A description of the proposed methodology for assessing the environmental issues and alternatives, including the option of not proceeding with the proposed development;  Particulars of the public participation process that will be conducted during the EIA phase,

Coastal & Environmental Services 15 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

and;  Any specific information required by the authority.

1.4 Assumptions and Limitations

Assumptions and limitations should be defined up front, as they are always part of a study of this nature, and it ensures transparency within the EIA process and the final product. It is important to be aware of limitations such as the availability and access to background information and the language barrier presented by working in areas where the first language is not English, so that the information gathered can be read within an appropriate context.

1.5 Details and Expertise of the Environmental Assessment Practitioner

According to regulation 17 of the EIA regulations (2010), An EAP must – (a) be independent; and (b) have expertise in conducting environmental impact assessments, including knowledge of the Act, these Regulations and any guidelines that have relevance to the proposed activity

In fulfillment of the above-mentioned legislative requirement, provided below are the details of the Environmental Assessment Practitioner (EAP) who prepared this draft scoping report as well as the expertise of the individual members of the study team.

Dr Ted Avis Coastal and Environmental Services (CES) Physical Address: 67 African Street, Grahamstown 6139 Postal Address: P.O. Box 934, Grahamstown 6140 Telephone: +27 46 622 2364 Fax: +27 46 622 6564 Website: www.cesnet.co.za Email: [email protected]

Dr Ted Avis, Managing Director of CES, is a leading expert in the field of Environmental Impact Assessments, having project-managed numerous large-scale EIAs to international standards (e.g. World Bank and International Finance Corporation). Ted has also project managed and provided professional input to the State of Environment reports and Strategic Environmental Assessments produced by CES. Ted is part of the following associations:

 Royal Society of South Africa  Visiting Fellow; Department of Environmental Science; Rhodes University  Certified Environmental Assessment Practitioner (since 2002)  Botanical Society of South Africa  South African Association of Botanists (SAAB)  South African Council for Natural Scientific Professionals  South African Institute of Ecologists and Environmental Scientists  International Association of Impact Assessment

CES is one of the largest specialist environmental consulting firms in southern Africa. Established in 1990, and with offices in Grahamstown, East London, Port Elizabeth and Maputo, we primarily specialise in assessing the impacts of development on the natural, social and economic environments. CES’s core expertise lies in the fields of strategic environmental assessment, environmental management plans, environmental management systems, ecological/environmental

Coastal & Environmental Services 16 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014 water requirements, environmental risk assessment, environmental auditing and monitoring, integrated coastal zone management, social impact assessment and state of environment reporting. In addition to adhering to all relevant national legislative requirements, acquisition of equity funding from the majority of financial institutions demands that developments must meet certain minimum standards that are generally benchmarked against the Policy and Performance Standards of the International Finance Corporation and the World Bank Operational Directives and Policies. The quality of our work during our long and extensive association with heavy mineral mining in Africa (we have worked on large mineral mining EIAs in South Africa, Mozambique, Malawi, Kenya, Madagascar and Egypt) has been acknowledged by international lenders such as the World Bank and the International Finance Corporation, and the large mining companies continue to approach us as their preferred environmental consultant for this type of project.

Provided below are short bio sketches of each of the additional team members involved in the proposed development.

Mr Bill Rowlston (Report Reviewer) Bill has more than 35 years experience in the English and South African water sectors. He spent 24 years with the Department of Water Affairs and Forestry in Pretoria, where he contributed to the development of approaches for protecting water resources, including the determination of the ecological Reserve. Bill was closely involved with the development of the National Water Policy (1997) and the National Water Act (1998), and was responsible for compiling the National Water Resource Strategy, First Edition (2005), much of which he wrote. He also supervised the development of guidelines for the preparation of sub-national catchment management strategies. He joined CES in April 2007.

Dr Chantel Bezuidenhout (Report Production) Chantel holds MSc and PhD degrees in Botany (estuarine ecology) and a BSc degree in Botany and Geography from NMMU. Chantel's main focus is estuarine ecology and she has done extensive work on 13 systems from the Orange River Mouth in the Northern Cape to the Mngazi Estuary in the Transkei. As a result she has been involved in a number of ecological reserve determination studies including the Kromme, Seekoei and Olifants systems. Chantel has been an Environmental Consultant for approximately 5.5 years and as such has been focused on environmental management and impact assessment. Chantel is well versed in environmental legislation and has been involved in number of environmental impact assessments and management plans in South Africa, Zambia and Madagascar. She is currently employed in the Grahamstown office of CES.

Ms Lara Crous (Public Participation Co-ordinator) Lara holds a BSc (Environmental Science and Geography) as well as a BSc Honours (Environmental Science) from Rhodes University. Her honours thesis evaluated Grahamstown's Municipal water supply, focussing on aluminium for which she received a distinction. She is currently writing up her MSc (fisheries science) thesis on using constructed wetland technology in the treatment and beneficiation of brewery effluent. Lara presented her preliminary results at the International Water Association's conference on Wetland Systems for Water Pollution Control in Venice, 2010. She is interested in environmental, municipal and effluent water quality.

Coastal & Environmental Services 17 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

2. THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT PROCESS (ESIA)

According to regulation 28 (1) and (2) of the EIA regulations (2010), A scoping report must include – 1(f) an identification of all legislation and guidelines that have been considered in the preparation of the scoping report (2) In addition, a scoping report must take into account any guidelines applicable to the kind of activity which is the subject of the application.

This environmental impact assessment will comply with the requirements of South African legislation, and will also conform to relevant international principles, performance standards and guidelines that serve as benchmarks for assessments of this nature. These international instruments include the Equator Principles, the International Finance Corporation (IFC) Performance Standards on Environmental and Social Sustainability, and Environmental, Health and Safety (EHS) General Guidelines, and the EHS Guidelines for Mining prepared by the World Bank and the IFC.

2.1 Environmental Legislation in South Africa

The Constitution of the Republic of South Africa is the supreme law of the land. As a result, all laws, including those pertaining to the proposed development, must conform to the Constitution. The Bill of Rights - Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, everyone has the right:

a) To an environment that is not harmful to their health or well-being; and b) To have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that: (i) Prevent pollution and ecological degradation; (ii) Promote conservation; and (iii) Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

Relevance to the proposed mine and associated infrastructure:

 Obligation to ensure that the proposed development will not result in pollution and ecological degradation; and  Obligation to ensure that the proposed development is ecologically sustainable, while demonstrating economic and social development.

The objective of NEMA is: “To provide for co-operative environmental governance by establishing principles for decision-making on matters affecting the environment, institutions that will promote co- operative governance and procedures for coordinating environmental functions exercised by organs of state; and to provide for matters connected therewith.”

A key aspect of NEMA is that it provides a set of environmental management principles that apply throughout the Republic to the actions of all organs of state that may significantly affect the environment. The proposed development has been assessed in terms of possible conflicts or compliance with these principles. Section 2 of NEMA contains principles (see Box 1) relevant to the proposed project, and likely to be utilised in the process of decision making by DEA.

BOX 1: NEMA ENVIRONMENTAL MANAGEMENT PRINCIPLES

Coastal & Environmental Services 18 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Environmental management must place people and their needs at the forefront of its concern, and (2) serve their physical, psychological, developmental, cultural and social interests equitably. (3) Development must be socially, environmentally and economically sustainable. Sustainable development requires the consideration of all relevant factors including the following: i. That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied; (4)(a) ii. That pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; iii. That waste is avoided, or where it cannot be altogether avoided, minimised and re-used or recycled where possible and otherwise disposed of in a responsible manner. Responsibility for the environmental health and safety consequences of a policy, programme, (4)(e) project, product, process, service or activity exists throughout its life cycle. The social, economic and environmental impacts of activities, including disadvantages and (4)(i) benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment. The right of workers to refuse work that is harmful to human health or the environment and to be (4)(j) informed of dangers must be respected and protected. The costs of remedying pollution, environmental degradation and consequent adverse health (4)(p) effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment. Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, (4)(r) wetlands, and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

As these principles are utilised as a guideline by the competent authority in ensuring the protection of the environment, the proposed development should, where possible, be in accordance with them. Where this is not possible, deviation from the principles would have to be very strongly motivated.

NEMA introduces the duty of care concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. A failure to perform this duty of care may lead to criminal prosecution, and may lead to the prosecution of managers or directors of companies for the conduct of the legal persons.

In addition NEMA introduced a new framework for environmental impact assessments, the EIA Regulations (2010) discussed previously.

This Act provides for the management and conservation of South Africa’s biodiversity within the framework of the National Environmental Management Act 107 of 1998 (see Box 2 below). In terms of the Biodiversity Act, the developer has a responsibility for:

 The conservation of endangered ecosystems and restriction of activities according to the categorisation of the area (not just by listed activity as specified in the EIA regulations).  Application of appropriate environmental management tools in order to ensure integrated environmental management of activities thereby ensuring that all developments within the area are in line with ecological sustainable development and protection of biodiversity.  Limit further loss of biodiversity and conserve endangered ecosystems.

Coastal & Environmental Services 19 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

BOX 2: MANAGEMENT AND CONSERVATION OF SOUTH AFRICA’S BIODIVERSITY WITHIN THE FRAMEWORK OF NEMA

CHAPTER 4 Provides for the protection of species that are threatened or in need of national protection to ensure their survival in the wild; o To give effect to the Republic’s obligations under international agreements regulating international trade in specimens of endangered species; and o Ensure that the commercial utilization of biodiversity is managed in an ecologically sustainable way. CHAPTER 5 (Part 2) Section A person who is the owner of land on which a listed invasive species occurs must: 73 a) Notify any relevant competent authority, in writing, of the listed invasive species occurring on that land; b) Take steps to control and eradicate the listed invasive species and to prevent it from spreading; and c) Take all required steps to prevent or minimise harm to biodiversity. Section  Control and eradication of a listed invasive species must be carried out by means or 75 methods that are appropriate for the species concerned and the environment in which it occurs.  Any action taken to control and eradicate a listed invasive species must be executed with caution and in a manner that may cause the least possible harm to biodiversity and damage to the environment.  The methods employed to control and eradicate a listed invasive species must also be directed at the offspring, propagating material and re-growth of such invasive species in order to prevent such species from producing offspring, forming seed, regenerating or re- establishing itself in any manner.

The objectives of this Act are to provide, within the framework of the National Environmental Management Act, for:

 The management and conservation of biological diversity within the Republic;  The use of indigenous biological resources in a sustainable manner.

The Act’s permit system is further regulated in the Act’s Threatened or Protected Species Regulations, which were promulgated in February 2007.

Relevance to the proposed mine and associated infrastructure:

 The proposed development must conserve endangered ecosystems and protect and promote biodiversity;  Must assess the impacts of the proposed development on endangered ecosystems;  No protected species may be removed or damaged without a permit;  The proposed site must be cleared of alien vegetation using appropriate means

The objective of this Act is to monitor and manage the sustainable use of forests. In terms of Section 12 (1) (d) of this Act and GN No. 1012 (promulgated under the National Forests Act), no person may, except under licence:

 Cut, disturb, damage or destroy a protected tree; or  Possess, collect, remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose of any protected tree or any forest product derived from a protected tree.

Coastal & Environmental Services 20 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Relevance to the proposed mine and associated infrastructure:

 If any protected trees in terms of this Act occur on site, the developer will require a licence from the DAFF to perform any of the above-listed activities.

The protection of archaeological and paleontological resources is the responsibility of a provincial heritage resources authority and all archaeological objects, paleontological material and meteorites are the property of the State. “Any person who discovers archaeological or paleontological objects or material or a meteorite in the course of development must immediately report the find to the responsible heritage resources authority, or to the nearest local authority offices or museum, which must immediately notify such heritage resources authority”.

Relevance to the proposed mine and associated infrastructure:

 An archaeological impact assessment must be undertaken during the detailed ESIR phase of the proposed project.  No person may alter or demolish any structure or part of a structure, which is older than 60 years or disturb any archaeological or paleontological site or grave older than 60 years without a permit issued by the relevant provincial heritage resources authority.  No person may, without a permit issued by the responsible heritage resources authority destroy, damage, excavate, alter or deface archaeological or historically significant sites.

As with the Atmospheric Pollution Prevention Act 45 of 1965, the objective of the new Air Quality Act is to protect the environment by providing the necessary legislation for the prevention of air pollution. “To reform the law regulating air quality in order to protect the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecologically sustainable development while promoting justifiable economic and social development; to provide for national norms and standards regulating air quality monitoring, management and control by all spheres of government; for specific air quality measures; and for matters incidental thereto.”

Relevance to the proposed mine and associated infrastructure:

 The “best practicable means” for the abatement of dust during construction and operation if approved have to be taken.  All appliances used for preventing or reducing to a minimum the escape into the atmosphere of noxious or offensive gases have to be properly operated and maintained and the best practice means for achieving this implemented.  The construction of facilities for the storage of ore may require an Air Emissions Licence should it be required to stockpiles ore in excess of 100 000 tons in an area other than the mine site.

The objective of this Act is to provide for the health and safety of persons at work (See Box 3 below). In addition, the Act requires that, “as far as reasonably practicable, employers must ensure that their activities do not expose non-employees to health hazards” (Glazewski, 2005: 575). The importance of the Act lies in its numerous regulations, many of which will be relevant to the proposed development. These cover, among other issues, noise and lighting.

BOX 3: HEALTH AND SAFTY OF PERSONS AT WORK ACCORDING TO THE

Coastal & Environmental Services 21 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

OCCUPATIONAL HEALTH AND SAFETY ACT

8: GENERAL DUTIES OF THE EMPLOYERS TO THEIR EMPLOYEES (1) Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees. (2) Without derogating from the generality of an employer's duties under subsection (1), the matters to which those duties refer include in particular- a) The provision and maintenance of systems of work, plant and machinery that, as far as is reasonably practicable, are safe and without risks to health; b) Taking such steps as may be reasonably practicable to eliminate or mitigate any hazard or potential hazard to the safety or health of employees, before resorting to personal protective equipment; d) Establishing, as far as is reasonably practicable, what hazards to the health or safety of persons are attached to any work which is performed, any article or substance which is produced, processed, used, handled, stored or transported and any plant or machinery which is used in his business, and he shall, as far as is reasonably practicable, further establish what precautionary measures should be taken with respect to such work, article, substance, plant or machinery in order to protect the health and safety of persons, and he shall provide the necessary means to apply such precautionary measures; e) Providing such information, instructions, training and supervision as may be necessary to ensure, as far as is reasonably practicable, the health and safety at work of his employees; f) As far as is reasonably practicable, not permitting any employee to do any work or to produce, process, use, handle, store or transport any article or substance or to operate any plant or machinery, unless the precautionary measures contemplated in paragraphs (b) and (d), or any other precautionary measures which may be prescribed, have been taken; g) Taking all necessary measures to ensure that the requirements of this Act are complied with by every person in his employment or on premises under his control where plant or machinery is used; h) Enforcing such measures as may be necessary in the interest of health and safety; i) Ensuring that work is performed and that plant or machinery is used under the general supervision of a person trained to understand the hazards associated with it and who have the authority to ensure that precautionary measures taken by the employer are implemented; and authority as contemplated in Section 37 (1) (b).

14: GENERAL DUTIES OF EMPLOYEES AT WORK Every employee shall at work:- (a) Take reasonable care for the health and safety of himself and of other persons who may be affected by his acts or omissions; (b) As regards any duty or requirement imposed on his employer or any other person by this Act, cooperate with such employer or person to enable that duty or requirement to be performed or complied with; (c) Carry out any lawful order given to him, and obey the health and safety rules and procedures laid down by his employer or by anyone authorized thereto by his employer, in the interest of health or safety; (d) If any situation which is unsafe or unhealthy comes to his attention, as soon as practicable report such situation to his employer or to the health and safety representative for his workplace or section thereof, as the case may be, who shall report it to the employer; and (e) If he is involved in any incident which may affect his health or which has caused an injury to himself, report such incident to his employer or to anyone authorized thereto by the employer, or to his health and safety representative, as soon as practicable but not later than the end of the particular shift during which the incident occurred, unless the circumstances were such that the reporting of the incident was not possible, in which case he shall report the incident as soon as practicable thereafter.

15: DUTY NOT TO INTERFERE WITH, DAMAGE OR MISUSE THINGS [S. 15 substituted by S. 3 of Act No. 181 of 1993.] No person shall intentionally or recklessly interfere with, damage or misuse anything which is provided in the interest of health or safety.

Relevance to the proposed mine and associated infrastructure:

 The developer must be mindful of the principles and broad liability and implications contained in the OHSA and mitigate any potential impacts.

Coastal & Environmental Services 22 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

The Act regulates the protection, use, development, conservation, management and control of water resources in South Africa. The principal concerns in terms of the Act are the potential for the proposed development to pollute surface and groundwater resources, and to ensure that water is used as efficiently as possible.

Chapter 4 Part 1 of the NWA sets out general principles for regulating water use. “Water use is defined broadly, and includes taking and storing water, activities which reduce stream flow, waste discharges and disposals, controlled activities (activities which impact detrimentally on a water resource), altering a watercourse, removing water found underground for certain purposes, and recreation. In general a water use must be licensed unless it is listed in Schedule 1, as an existing lawful use, is permissible under a general authorisation, or if a responsible authority waives the need for a licence. The Minister may limit the amount of water which a responsible authority may allocate. In making regulations the Minister may differentiate between different water resources, classes of water resources and geographical areas.”

Since the proposed pipeline will cross the Groen River a Water Use License is required in accordance with Section 21 (c) and (i) of the National Water Act.

Relevance to the proposed mine and associated infrastructure:

19 (1) An owner of land, a person in control of land or a person who occupies or uses the land on which— (a) any activity or process is or was performed or undertaken; or (b) any other situation exists, which causes, has caused or is likely to cause pollution of a water resource, must take all reasonable measures to prevent any such pollution from occurring, continuing or recurring.

The Act aims to manage hazardous substances. It is the principal national legislation that controls the transportation, and manufacturing, storage, handling, treatment or processing facilities for any substance that is dangerous or hazardous (Groups I-IV). Specific regulations governing the conveyance of hazardous substances, including Group I substances, by road may also be relevant.

Relevance to the proposed mine and associated infrastructure:

 Manage the hazardous waste in such a manner that it does not endanger human health or the environment.  Prevent the waste from being used for an unauthorised purpose.

The purpose of this Act is to provide for the protection and conservation of ecologically viable areas representative of South Africa’s biological diversity and its natural landscapes and seascapes.

The objectives of this Act are-

 To provide, within the framework of national legislation, including the National Environmental Management Act, for the declaration and management of protected areas;  To provide for co-operative governance in the declaration and management of protected areas;  To effect a national system of protected areas in South Africa as part of a strategy to manage and conserve its biodiversity;  To provide for a representative network of protected areas on state land, private land and communal land;  To promote sustainable utilisation of protected areas for the benefit of people, in a manner that would preserve the ecological character of such areas;

Coastal & Environmental Services 23 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

 To promote participation of local communities in the management of protected areas, where appropriate; and  To provide for the continued existence of South African National Parks.

Implications for the proposed mine and associated infrastructure:

 The proposed mine site is in close proximity to the Namaqua National Park

The purpose of this Act is to provide for control over the utilization of the natural agricultural resources in order to promote the conservation of the soil, the water sources and the vegetation and the combating of weeds and invader plants.

This is achieved by:

 Production potential of land is maintained,  Preventing and combating erosion,  Preventing and combating weakening or destruction of the water sources, and  Protecting vegetation and combating of weeds and invader plants.

The Act provides a list of declared weeds and invader plants as well as indicators of bush encroachment.

In terms of weeds and invader plants:  A land user shall control any category 1 plants that occur on any land or inland water surface.  No person shall, except in or for purposes of a biological control reserve – o Establish, plant, maintain, multiply or propagate weeds and invader plants; o Import or sell propagating material of category weeds and invader plants; and o Acquire propagating material of weeds and invader plants

Implications for the proposed mine and associated infrastructure:

 If any declared weed and/or invader species listed in terms of this Act is present on site, it will have to be removed.

The MPRDA makes “provision for equitable access to and sustainable development of the nation’s mineral and petroleum resources”.

The Mineral and Petroleum Resources Development Amendment Act, 49 of 2008 (MPRDAA), which took effect on 7th June 2013, introduced significant amendments to the MPRDA, 28 of 2002 (Principal Act). In terms of the newly included section 38A, the Minister of Mineral Resources is the “responsible party” for implementing all “environmental provisions” as contained in NEMA. This is supported by section 24C(2A), introduced by the National Environmental Management Amendment Act, 62 of 2008 (NEMAA), which states that the Minister of Mineral Resources is the competent authority where the activity constitutes “prospecting, mining, exploration, production or a related activity occurring within a prospecting, mining, exploration or production area”. However, section 14(2) of NEMAA states that “any provision relating to prospecting, mining, exploration and related activities comes into operation on a date 18 months after the date of commencement of” either NEMAA (62 of 2008) or MPRDAA (49 of 2008), whichever is the later date. The former commenced on 1st May 2009, and the latter on 7th June 2013, so the proposed changes to align the MPRDA with NEMA, and to make the Minister of Mineral Resources the responsible authority for mining- related environmental matters, will come into operation on 7th December 2014.

Coastal & Environmental Services 24 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

The current application process for the submission of an application for environmental authorisation relating to a mining operation appears to remain as it was prior to the introduction of the MPRDAA. The Act, however still applies to the proposed project, since the proponent will have to apply for a mining licence from DMR in accordance with the MPRDA.

Implications for the proposed mine and associated infrastructure:

 The proposed project requires a mining license from DMR.

This legislation aims to enforce an integrated approach to waste management, with emphasis on prevention and reduction of waste at source and, where this is not possible, to encourage reuse and recycling in preference to disposal. Section 16 (Chapter 4) of this Act deals with the general duty in respect to waste management and emphasises that, “A holder of waste must, within the holder’s power, take all reasonable measures to:- avoid the generation of waste and where such generation cannot be avoided, to minimise the toxicity and amounts of waste that are generated; reduce, re- use, recycle and recover waste; where waste must be disposed of, ensure that the waste is treated and disposed of in an environmentally sound manner; manage the waste in such a manner that it does not endanger health or the environment or cause a nuisance through noise, odour or visual impacts; prevent any employee or any person under his or her supervision from contravening this Act; and prevent the waste from being used for an unauthorised purpose”. Chapter 4, Part 3 of this Act deals with reduction re-use and recovery of waste, Part 4 deals with waste management activities, Part 5 covers storage collection and transportation of waste, Part 6 deals with treatment, processing and disposal of wastes, Part 7 covers industry waste management plans and Part 8 deals with contaminated land. Chapter 5 covers all issues regarding the licensing of waste management activities.

This Act is relevant to the proposed development as it is proposed to construct temporary site based accommodation that will be required for construction employees. This proposed facility will not have access to a municipal sewage reticulation network and will thus have to rely on the use of a package sewage treatment plant to cater for the sewage emanating from the facilities. Depending on its throughput capacity, this activity may require a waste management licence. In addition, it is proposed to construct a landfill site in close proximity to the mine, this activity may also require a waste management licence if its storage capacity is above thresholds identified within the NEM: WA listed activities. It is probable that disposal of brine, either in on-site evaporation pnds or by discharge into the ocean via a sea outfall, will also require a waste manmagement licence.

In terms of section 4 of NEM: WA, certain substances are specifically excluded from the application of NEM: WA, as they are regulated by another primary piece of legislation. The purpose of this exclusion is primarily to avoid any duplication in any regulatory processes. It is important to note these exclusions in relation to mining activities as section 4(1)(b) excludes “residue deposits and residue stockpiles that are regulated under the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002)” from the application of NEM: WA. Therefore, all “residue deposits” and “residue stockpiles” will not be regulated by NEM: WA, but will rather by the Minerals and Petroleum Resources Development Act 28 of 2002 (“MRPDA”). It is important to note that the MPRDA has recently been amended by the Minerals and Petroleum Resources Development Act 49 of 2008 (“MRPDAA”).

The MPRDAA came into operation on 7 June 2013 (Proclamation 14 of 31 May 2013 published in Government Gazette 36512) amending the Mineral and Petroleum Resources Development Act 28 of 2002 (the Principal Act) including definitions. Section 1 of the MPRDAA defines “residue stockpile” as:

Coastal & Environmental Services 25 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

“any debris, discard, tailings, slimes, screening, slurry, waste rock, foundry sand, beneficiation plant waste, ash or any other product derived from or incidental to a mining operation and which is stockpiled, stored or accumulated for potential re-use, or which is disposed of, by the holder of a mining right, mining permit, production right or an old order right”

There is, however, an intention to include “residue stockpiles” and “residue deposits” within the ambit of NEM: WA. It is unclear however when this proposed amend will be effected, if at all.

Implications for the proposed mine and associated infrastructure:

 All reasonable measures must be taken to avoid the generation of waste and where such generation cannot be avoided, minimise the toxicity and amounts of waste that are generated; reduce, re-use, recycle and recover waste; where waste must be disposed of, ensure that the waste is treated and disposed of in an environmentally sound manner;  Manage the waste in such a manner that it does not endanger human health or the environment or cause a nuisance through noise, odour or visual impacts.  Prevent any employee or any person from contravening this Act; and prevent the waste from being used for an unauthorised purpose.  Waste management activities should be licensed.

According to Section 2 of the NEM: ICMA, the objects of this Act are:

 To determine the coastal zone of the Republic;  To provide, within the framework of the National Environmental Management Act, for the co‐ ordinated and integrated management of the coastal zone by all spheres of government in accordance with the principles of co‐operative governance;  To preserve, protect, extend and enhance the status of coastal public property as being held in trust by the State on behalf of all South Africans, including future generations;  To secure equitable access to the opportunities and benefits of coastal public property; and To give effect to the Republic’s obligations in terms of international law regarding coastal management and the marine environment.

Section 13 of the NEM: ICMA states that any natural person in the Republic:

 Has a right of reasonable access to coastal public property; and  Is entitled to use and enjoy coastal public property.

Coastal Public Property is defined by the Act as c

The ICM Act unequivocally vests ownership of coastal public property in the citizens of South Africa. Coastal public property cannot be transferred, sold, attached or acquired by prescription, nor can the rights over it be acquired by prescription. It is the duty of the State as trustee to ensure that coastal public property is used, managed, protected, conserved and enhanced in the interests of the whole community, as opposed to only a few individuals or groups.

Section 65(1) (subject to sections 67 and 95) states that no person may occupy any part of, or site on, or construct or erect any building, road, barrier or structure on or in, coastal public property except under and in accordance with a coastal lease awarded by the Minister in terms of this Chapter. This may be relevant to the proposed development as the intake works, pump station and portions of both proposed pipeline (for the transport of seawater to the mine site and the transport of product to the single point mooring) may have to cross what is defined as coastal public property.

Coastal & Environmental Services 26 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Section 69(1) of the Act states that no person may discharge effluent that originates from a source on land into coastal waters except in terms of a general authorisation or a coastal waters discharge permit issued under this section by the Minister after consultation with the Minister responsible for water affairs in instances of discharge of effluent into an estuary. This may be applicable should the option of discharge of brine from the desalination plant at the mine site into coastal waters be considered as an option. However, due to the cost implications to this project this is unlikely to occur.

The abstraction of seawater is not mentioned in the act and therefore it is assumed that this activity does not require any permits from Oceans and Coasts.

Implications for the proposed mine and associated infrastructure:

 A coastal lease may be required from the Minister for the construction of infrastructure within areas defined as Coastal Public Property.

The National Nuclear Regulator Act (No. 47 of 1999) regulates nuclear activities to provide for safety standards and regulatory practices for the protection of persons, property and the environment against nuclear damage and to provide for matters connected therewith.

Section 1(i) defines an “action” as:  The use, possession, production, storage, enrichment, processing, reprocessing, conveying or disposal of radioactive material  Any action, the performance of which, may result in persons accumulating a radiation dose resulting from exposure to ionising radiation; or  Any action involving radioactive material

Based on the above it may be necessary for Zirco to acquire a Certificate of Registration for the Kamiesberg Project, as the heavy minerals contain naturally occurring radionuclides and can thus be classified as naturally occurring radioactive materials (NORM). The heavy mineral sands will be concentrated through the production of the heavy mineral concentrate (HMC) and may therefore be considered to be above the naturally background radiation levels. Appropriate permitting will be identified and applied for by the radiation specialist.

Implications for the proposed mine and associated infrastructure:

 There may be permitting requirements for the production of ilmenite, ziron, rutile and monazite

There will be certain requirements related to health and safety during construction and approval of method statements. Certain activities related to the proposed development may, in addition to National legislation, be subject to control by municipal by-laws including the Namaqua District Municipality and Kamiesberg Local Municipality Integrated Development Plans (IDPs) and Spatial Development Frameworks (SDFs).

Coastal & Environmental Services 27 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

According to the Namaqua District Municipality Integrated Developent Plan (IDP) (Draft IDP 2013- 2014), one of the focus areas will be to optimize natural resource use within the area in a sectoral manner. One of the goals set to achieve this is a mineral beneficiation plant (i.e. process whereby extracted ore from mining is separated into mineral and waste rock or tails). Since the mineral separation plant seperates the HMC into product this qualifies as beneficiation and is thus in line with the IDP.

In addition to the above, the IDP also stresses the need for social development within the area. Various goals such as the establishment of sport, arts, culture and heritage centres, providing support to vulnerable groups, providing infrastructure, etc have been set by the District Municipality.

2.2 International instruments

The Equator Principles (Box 4 below) are a financial industry benchmark for determining, assessing and managing social and environmental risks to projects. They are intended to ensure that projects financed by the Equator Principles Financial Institutions (EPFI) are developed in a manner that is socially responsible and reflects sound environmental management practices. In January 2013 a total of 79 financial institutions from 32 countries across the globe had adopted the Equator Principles.

Box 4: The Equator Principles (EP III - June 2013)

Statement of Principles The EPFI will only provide Project Finance and Project-Related Corporate Loans to Projects that meet the requirements of Principles 1-10.

Principle 1: Review and Categorisation When a Project is proposed for financing the EPFI will, as part of its internal environmental and social review and due diligence, categorise it based on the magnitude of its potential environmental and social risks and impacts. Such screening is based on the environmental and social categorisation process of the International Finance Corporation (IFC). Using categorisation the EPFI’s environmental and social due diligence is commensurate with the nature, scale and stage of the Project, and with the level of environmental and social risks and impacts. The categories are: Category A – Projects with potential significant adverse environmental and social risks and/or impacts that are diverse, irreversible or unprecedented; Category B – Projects with potential limited adverse environmental and social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures; and Category C – Projects with minimal or no adverse environmental and social risks and/or impacts.

Principle 2: Environmental and Social Assessment For all Category A and Category B Projects the EPFI will require the client to conduct an Assessment process to address, to the EPFI’s satisfaction, the relevant environmental and social risks and impacts of the proposed Project (which may include the illustrative list of issues found in Exhibit II [1]). The Assessment Documentation should propose measures to minimise, mitigate, and offset adverse impacts in a manner relevant and appropriate to the nature and scale of the proposed Project. The Assessment Documentation will be an adequate, accurate and objective evaluation and presentation of the environmental and social risks and impacts, whether prepared by the client, consultants or external experts. For Category A, and as appropriate, Category B Projects, the Assessment Documentation includes an Environmental and Social Impact Assessment (ESIA). One or more specialised studies may also need to be undertaken. Furthermore, in limited high risk circumstances it may be appropriate for the client to complement its Assessment Documentation with specific human rights due diligence. For other Projects, a limited or focused environmental or social assessment (e.g. audit), or straightforward application of environmental siting, pollution standards, design criteria, or construction standards may be carried out. For all Projects, in all locations, when combined Scope 1 and Scope 2 Emissions are expected to be more than 100 000 tonnes of CO2 equivalent annually, an Alternatives Analysis will be conducted to evaluate less Greenhouse Gas (GHG) intensive alternatives. Refer to Annex A for alternatives analysis requirements

Principle 3: Applicable Environmental and Social Standards The Assessment process should, in the first instance, address compliance with relevant host country laws, regulations and permits that pertain to environmental and social issues. EPFIs operate in diverse markets: some with robust environmental and social governance, legislation systems and

Coastal & Environmental Services 28 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014 institutional capacity designed to protect the people and the natural environment; and some with evolving technical and institutional capacity to manage environmental and social issues. The EPFI will require that the Assessment process evaluates compliance with the applicable standards as follows: 1. For Projects located in Non-Designated Countries, the Assessment process evaluates compliance with the then applicable IFC Performance Standards on Environmental and Social Sustainability (Performance Standards) and the IFC / World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines) (Exhibit III [2]). 2. For Projects located in Designated Countries, the Assessment process evaluates compliance with relevant host country laws, regulations and permits that pertain to environmental and social issues. Host country laws meet the requirements of environmental and/or social assessments (Principle 2), management systems and plans (Principle 4), Stakeholder Engagement (Principle 5) and, grievance mechanisms (Principle 6). The Assessment process will establish to the EPFI’s satisfaction the Project's overall compliance with, or justified deviation from, the applicable standards. The applicable standards (as described above) represent the minimum standards adopted by the EPFI. The EPFI may, at their sole discretion, apply additional requirements.

Principle 4: Environmental and Social Management System and Equator Principles Action Plan For all Category A and Category B Projects the EPFI will require the client to develop or maintain an Environmental and Social Management System (ESMS). Further, an Environmental and Social Management Plan (ESMP) will be prepared by the client to address issues raised in the Assessment process and incorporate actions required to comply with the applicable standards. Where the applicable standards are not met to the EPFI’s satisfaction, the client and the EPFI will agree an Equator Principles Action Plan (AP). The Equator Principles AP is intended to outline gaps and commitments to meet EPFI requirements in line with the applicable standards.

Principle 5: Stakeholder Engagement For all Category A and Category B Projects the EPFI will require the client to demonstrate effective Stakeholder Engagement as an ongoing process in a structured and culturally appropriate manner with Affected Communities and, where relevant, other stakeholders. For Projects with potentially significant adverse impacts on Affected Communities, the client will conduct an Informed Consultation and Participation process. The client will tailor its consultation process to: the risks and impacts of the Project; the Project’s phase of development; the language preferences of the Affected Communities; the decision-making processes; and the needs of disadvantaged and vulnerable groups. This process should be free from external manipulation, interference, coercion and intimidation. To facilitate Stakeholder Engagement the client will, commensurate to the Project’s risks and impacts, make the appropriate Assessment Documentation readily available to the Affected Communities, and where relevant other stakeholders, in the local language and in a culturally appropriate manner. The client will take account of and document the results of the Stakeholder Engagement process, including any actions agreed resulting from such process. For Projects with environmental or social risks and adverse impacts disclosure should occur early in the Assessment process, in any event before the Project construction commences, and on an ongoing basis. EPFIs recognise that indigenous peoples may represent vulnerable segments of project-affected communities. Projects affecting indigenous peoples will be subject to a process of Informed Consultation and Participation, and will need to comply with the rights and protections for indigenous peoples contained in relevant national law, including those laws implementing host country obligations under international law. Consistent with the special circumstances described in with adverse impacts on indigenous people will require their Free, Prior and Informed Consent (FPIC).

Principle 6: Grievance Mechanism For all Category A and, as appropriate, Category B Projects, the EPFI will require the client, as part of the ESMS, to establish a grievance mechanism designed to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social performance. The grievance mechanism is required to be scaled to the risks and impacts of the Project and have Affected Communities as its primary user. It will seek to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate, readily accessible, at no cost, and without retribution to the party that originated the issue or concern. The mechanism should not impede access to judicial or administrative remedies. The client will inform the Affected Communities about the mechanism in the course of the Stakeholder Engagement process.

Principle 7: Independent Review Project Finance For all Category A and, as appropriate, Category B Projects, an Independent Environmental and Social Consultant, not directly associated with the client, will carry out an Independent Review of the Assessment Documentation including the ESMPs, the ESMS, and the Stakeholder Engagement process documentation in order to assist the EPFI's due diligence and assess Equator Principles compliance. The Independent Environmental and Social Consultant will also propose or opine on a suitable Equator Principles AP capable of bringing the Project into compliance with the Equator Principles, or indicate when compliance is not possible. Project-Related Corporate Loans An Independent Review by an Independent Environmental and Social Consultant is required for Projects with potential high risk impacts including, but not limited to, any of the following:  adverse impacts on indigenous peoples  Critical Habitat impacts  significant cultural heritage impacts  large-scale resettlement In other Category A, and as appropriate Category B, Project-Related Corporate Loans, the EPFI may determine whether an Independent Review is appropriate or if internal review by the EPFI is sufficient. This may take into account the due

Coastal & Environmental Services 29 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014 diligence performed by a multilateral or bilateral financial institution or an OECD Export Credit Agency, if relevant.

Principle 8: Covenants An important strength of the Equator Principles is the incorporation of covenants linked to compliance. For all Projects, the client will covenant in the financing documentation to comply with all relevant host country environmental and social laws, regulations and permits in all material respects. Furthermore for all Category A and Category B Projects the client will covenant the financial documentation: a) to comply with the ESMPs and Equator Principles AP (where applicable) during the construction and operation of the Project in all material respects; and b) to provide periodic reports in a format agreed with the EPFI (with the frequency of these reports proportionate to the severity of impacts, or as required by law, but not less than annually), prepared by in-house staff or third party experts, that i) document compliance with the ESMPs and Equator Principles AP (where applicable), and ii) provide representation of compliance with relevant local, state and host country environmental and social laws, regulations and permits; and c) to decommission the facilities, where applicable and appropriate, in accordance with an agreed decommissioning plan. Where a client is not in compliance with its environmental and social covenants, the EPFI will work with the client on remedial actions to bring the Project back into compliance to the extent feasible. If the client fails to re-establish compliance within an agreed grace period, the EPFI reserves the right to exercise remedies, as considered appropriate.

Principle 9: Independent Monitoring and Reporting Project Finance To assess Project compliance with the Equator Principles and ensure ongoing monitoring and reporting after Financial Close and over the life of the loan the EPFI will, for all Category A and, as appropriate, Category B Projects, require the appointment of an Independent Environmental and Social Consultant, or require that the client retain qualified and experienced external experts to verify its monitoring information, which would be shared with the EPFI. Project-Related Corporate Loans For Projects where an Independent Review is required under Principle 7 the EPFI will require the appointment of an Independent Environmental and Social Consultant after Financial Close, or require that the client retain qualified and experienced external experts to verify its monitoring information which would be shared with the EPFI.

Principle 10: Reporting and Transparency Client Reporting Requirements The following client reporting requirements are in addition to the disclosure requirements in Principle 5. For all Category A and, as appropriate, Category B Projects:  the client will ensure that, at a minimum, a summary of the ESIA is accessible and available online.  the client will publicly report GHG emission levels (combined Scope 1 and Scope 2 Emissions) during the operational phase for Projects emitting over 100,000 tonnes of CO2 equivalent annually. Refer to Annex A for detailed requirements on GHG emissions reporting. EPFI Reporting Requirements The EPFI will report publicly, at least annually, on transactions that have reached Financial Close and on its Equator Principles implementation processes and experience, taking into account appropriate confidentiality considerations. The EPFI will report according to the minimum reporting requirements detailed in Annex B. Notes: [1] Exhibit II: Illustrative List of Potential Environmental and Social Issues to be addressed in the Environmental and Social Assessment Documentation. [2] Exhibit III: IFC Performance Standards on Environmental and Social Sustainability and the IFC / World Bank Group Environmental, Health and Safety Guidelines

The IFC Performance Standards to which the Equator Principles refer, specifically in Exhibit III, are those that were published and took effect on 1st January 2012.

The IFC is a member of the World Bank Group, and is the largest global development institution focused exclusively on the private sector in developing countries. Established in 1956 the IFC is owned by 184 member countries, and provides funding for emerging markets to create jobs, generate tax revenues, improve corporate governance and environmental performance, and contribute to the local communities.

The IFC published its Performance Standards (PS) on Environmental and Social Sustainability in April 2006, and published comprehensive Guidance Notes in July 2007. Since then the Performance Standards and Guidance Notes have been revised, and the updated versions were published and took effect from January 2012. The updated Performance Standards are listed in Box 2.2.

Coastal & Environmental Services 30 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Box 5: IFC Performance Standards

Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts Performance Standard 2: Labour and Working Conditions Performance Standard 3: Resource Efficiency and Pollution Prevention Performance Standard 4: Community Health, Safety and Security Performance Standard 5: Land Acquisition and Involuntary Resettlement Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources Performance Standard 7: Indigenous Peoples Performance Standard 8: Cultural Heritage

Note: PS 7 is not applicable to the project, since there is no indication that any group of potentially affected persons in the project’s area of influence falls into the IFC definition of indigenous people (social groups with identities that are distinct from dominant groups in national societies

A summary of the key objectives of the Performance Standards is set out in the table below

Performance Standard Key objectives  To identify and evaluate environmental and social risks and impacts of the project.  To adopt a mitigation hierarchy to anticipate and avoid, or where avoidance is not possible, minimize and, where residual impacts remain, compensate/offset for risks and impacts to workers, Affected Communities, and the environment. PS 1: Assessment and  To promote improved environmental and social performance of clients through management of the effective use of management systems. environmental and social  To ensure that grievances from Affected Communities and external risks and impacts communications from other stakeholders are responded to and managed appropriately.  To promote and provide means for adequate engagement with Affected Communities throughout the project cycle on issues that could potentially affect them and to ensure that relevant environmental and social information is disclosed and disseminated.  To promote the fair treatment, non-discrimination, and equal opportunity of workers.  To establish, maintain, and improve the worker-management relationship.  To promote compliance with national employment and labour laws. PS 2: Labour and Working  To protect workers, including vulnerable categories of workers such as children, Conditions migrant workers, workers engaged by third parties, and workers in the client’s supply chain.  To promote safe and healthy working conditions, and the health of workers.  To avoid the use of forced labour.  To avoid or minimize adverse impacts on human health and the environment by PS 3: Resource efficiency avoiding or minimizing pollution from project activities. and pollution prevention  To promote more sustainable use of resources, including energy and water.  To reduce project-related GHG emissions.  To anticipate and avoid adverse impacts on the health and safety of the Affected Community during the project life from both routine and non-routine PS 4: Community Health, circumstances. Safety and Security  To ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities.  To avoid, and when avoidance is not possible, minimize displacement by exploring alternative project designs.  To avoid forced eviction.  To anticipate and avoid, or where avoidance is not possible, minimize adverse social and economic impacts from land acquisition or restrictions on land use by: - providing compensation for loss of assets at replacement cost and PS 5: Land Acquisition and - ensuring that resettlement activities are implemented with appropriate Involuntary Resettlement disclosure of information, consultation, and the informed participation of those affected.  To improve, or restore, the livelihoods and standards of living of displaced persons.  To improve living conditions among physically displaced persons through the provision of adequate housing with security of tenure at resettlement sites.

Coastal & Environmental Services 31 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Performance Standard Key objectives  To protect and conserve biodiversity. PS 6: Biodiversity  To maintain the benefits from ecosystem services. Conservation and  To promote the sustainable management of living natural resources through the Sustainable Management of adoption of practices that integrate conservation needs and development Living Natural Resources priorities.  To ensure that the development process fosters full respect for the human rights, dignity, aspirations, culture, and natural resource-based livelihoods of Indigenous Peoples.  To anticipate and avoid adverse impacts of projects on communities of Indigenous Peoples, or when avoidance is not possible, to minimize and/or compensate for such impacts.  To promote sustainable development benefits and opportunities for Indigenous Peoples in a culturally appropriate manner. PS 7: Indigenous Peoples  To establish and maintain an ongoing relationship based on Informed Consultation and Participation (ICP) with the Indigenous Peoples affected by a project throughout the project’s life-cycle.  To ensure the Free, Prior, and Informed Consent (FPIC) of the Affected Communities of Indigenous Peoples when the circumstances described in this Performance Standard are present.  To respect and preserve the culture, knowledge, and practices of Indigenous Peoples.  To protect cultural heritage from the adverse impacts of project activities and PS 8: Cultural Heritage support its preservation.  To promote the equitable sharing of benefits from the use of cultural heritage.

The General EHS Guidelines provide an organized, hierarchical, best-practice approach to managing environmental, health and safety issues at facility or project level, which in broad terms comprises the following steps:

 Identifying EHS project hazards and associated risks as early as possible in the facility development or project cycle.  Understanding the likelihood and magnitude of EHS risks, based on the nature of the project activities and the potential consequences to workers, communities, or the environment if hazards are not adequately managed.  Prioritising risk management strategies with the objective of achieving an overall reduction of risk to human health and the environment, focusing on the prevention of irreversible and / or significant impacts.  Favouring strategies that eliminate the cause of the hazard at its source to avoid the need for EHS controls.  When impact avoidance is not feasible, incorporating engineering and management controls to reduce or minimize the possibility and magnitude of undesired consequences.  Preparing workers and nearby communities to respond to accidents, including providing technical and financial resources to effectively and safely control such events, and subsequently restoring workplace and community environments to a safe and healthy condition.  Improving EHS performance through a combination of ongoing monitoring of facility performance and effective accountability. The Guidelines are organised in four main sections:

1. Environmental 2. Occupational Health and Safety 3. Community Health and Safety 4. Construction and Decommissioning.

Coastal & Environmental Services 32 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

The EHS General Guidelines are designed to be used together with the relevant Industry Sector EHS Guidelines, which provide details of risks and impacts specific to particular industries, and guidance on the management.

The IFC EHS Guidelines for Mining (30 April 2007) are applicable to this project. The guidelines detail industry-specific impacts and ways in which to manage them. They cover environmental, occupational health and safety, community health and safety, and performance indicators and monitoring

Coastal & Environmental Services 33 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

3. PROJECT DESCRIPTION

3.1 Introduction

Zirco currently holds the prospecting right to the Roode Heuvel and Leeuvlei deposits, located approximately 500 km north of Cape Town and approximately 35 km to the southwest of the town of Garies in the Northern Cape Province of South Africa. They are also in the process of acquiring prospecting rights for a further deposit immediately east of and adjacent to Roode Heuvel, referred to as “Sabies”. This report deals with all three areas which combined form Zirco’s Kamiesberg Project. Include in the table below are the farm names and the co-ordinates of the properties involved in the proposed mining application.

Table 1.1: Farm names and co-ordinates of the mining deposists Deposit Farm Name Co-ordinates Roode Heuvel Roode Heuvel 30°44'1.94"S 6/502 17°36'51.40"E Roode Heuvel 30°43'47.51"S 5/502 17°37'12.05"E Roode Heuvel 30°43'41.17"S 9/502 17°37'52.00"E Roode Heuvel 30°43'34.77"S 1/502 17°38'59.15"E Klipdam 633 30°43'57.81"S 17°40'8.77"E Leeuvlei Leeuvlei 642 30°36'51.55"S 17°39'30.46"E Leeuvlei 1/437 30°37'47.76"S 17°38'18.67"E De Klipheuvel 30°38'10.76"S 9/435 17°37'7.09"E De Klipheuvel 30°39'23.99"S 10/435 17°38'4.76"E Sabies De Klipheuvel 30°39'42.99"S 11/435 17°39'55.85"E Sabies 2/505 30°41'1.77"S 17°41'56.47"E Hawerland RE/503 30°42'26.05"S 17°40'49.63"E Hawerland 1/503 30°44'42.44"S 17°43'35.75"E Hawerland 2/503 30°44'43.09"S 17°42'17.14"E Hawerland 3/503 30°45'24.12"S 17°41'26.77"E

Figure 1.1 shows the location of the project in relation to the regional setting. The town of Garies is located approximately 35 km in a direct line from the site and approximately 50 km by road. The town of Bitterfontein is located 65 km south of Garies, and Springbok, where the regional administration for the Namakwa area is located, is 117 km north of Garies.

Zirco holds the prospecting rights to the Roode Heuvel and Leeuvlei deposits, and are also in the

Coastal & Environmental Services 34 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014 process of acquiring prospecting rights for a further deposit immediately east of and adjacent to Roode Heuvel, referred to as “Sabies”. This report deals with all three areas which combined form Zirco’s Kamiesberg Project. Information regarding the deposits has been based on a drilling programme on the Roode Heuvel and Leeuvlei portions, as Zirco has not drilled the Sabie deposit yet. The three prospecting rights making up the study area, Roode Heauwel (6 314 ha), Leeuvlei (6 005 ha) and Sabies (8 600 ha) are shown on Figure 3.1.

To date Zirco has completed 12 843 m of air core drilling and fully delineated the deposits on Roode Heuvel and Leeuvlei. Drilling was extended to the basement rock to fully define the depth of the deposit. Global total heavy mineral grades (THM) are in the order of 3%, with both deposits together projected to contain some 1 400 million tons of mineralised sand. These sands consist of surface aeolian sand (referred to as Red Aeolian Sands - RAS), and higher slimes, mineralised sand (referred to as Orange Feldspathic Sands – OFS). These make up the bulk of the deposit. Basal grits and conglomerates are locally developed immediately above the basement.

Figure 3.1: The prospecting areas in relation to Garies.

 Red Aeolian Sand (RAS): This is highly mineralised with thickness varying between a few centimetres to 12 metres and averaging 3 metres. Average slimes levels in the RAS layer is less than 4% (TZMI, 2012).  Orange Feldspathic Sands (OFS): This layer forms the bulk of the Roode Heuvel deposit, with depths varying between a few centimetres and 25 metres and averaging 10-15 m in better developed areas. Average slimes levels for this layer is 21% (TZMI, 2012)  Basal Grits and Conglomerates: This material is typically deep red, poorly sorted grits to polymistic small pebble or boulder conglomerates. However, there is little information available for this layer from the air-core drilling due to blade refusal (TZMI, 2012) A generalised cross section of the Roode Heuvel deposit is depicted in Figure 3.2 below.

Coastal & Environmental Services 35 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 3.2: Roode Heuvel lithological cross section, 20:1 vertical exaggeration (Source: TZMI)

Based on the drilling programme completed, mineral resource estimates and mining studies undertaken at the Roode Heuvel deposit alone has an estimated mineral reserve of 270 million tons at 4.8% THM which could support 20 years of mining at a rate of 1 500 to 2 300 tons per hour (tph). Mining operations are planned to cover approximately 3 500 hectares.

3.2 Proposed Mining Methodology

Mining involves clearing vegetation and stockpiling topsoil ahead of the mine path, excavating the mineralised sand using front end loaders and transferring this material to a hopper from where it will be slurried and pumped to the primary concentration plant. The area would then be back-filled after mining, covered with top soil and rehabilitated.

This approach to mining and delivering the ore to the PCP is easy to manage, and is currently employed at several mineral sands operations around the world. Typical dry mining / slurrying operations are shown in Plate 3.1, and the process is illustrated schematically in Figure 3.3.

Plate 3.1: Typical loader and hopper dry mining operation

Coastal & Environmental Services 36 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 3.3: Mining operation and ore delivery flow diagram (Source TZMI)

The excavated sand (via front end loader) is fed at a controlled rate through a small screen and into a hopper onto a conveyor. The conveyor feeds the material screen that removes oversize material, into the slurrying hopper. Water is added and the slurry is sucked by the transfer pump from the bottom of the slurrying hopper into the high-density polyethylene (HDPE) delivery line. The length of the pipeline between the excavation point and the PCP is a maximum of 2 000 metres. The slurrying / slurry pumping unit, which is mounted on a skid and is easily relocated to the next mining sector, is moved regularly to ensure the front-end loader tramming distance is kept to a minimum.

3.3 Mineral processing

Ore from the mining face will be pumped to the PCP, where it will undergo desliming, to remove silt and clay before treatment on the spiral circuit to remove the quartz. The HMC will be polished by water attritioning to remove surface coatings, and then stockpiled at the concentrator.

Multiple stages of spirals will be used in the PCP(s) to upgrade the ore (± 5% THM) to a heavy mineral concentrate (95% THM). The flow sheet adopted is a standard configuration of spirals, with process water recirculated via a thickener from hydrocyclones to remove slimes from the ore. The water attritioning step has been added to the end of the wet plant to assist in further downstream processing through the removal of any surface coatings from the minerals.

It is important to note that this separation process does not involve any changes to the chemical composition of the ore. The HMC is separated from the ore by gravity using standard spirals, with the waste sand tailings back filled into the mined area. A simplified process flow sheet is presented in Figure 3.4.

Coastal & Environmental Services 37 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 3.4: Simplified flow sheet for a single primary concentrator (Source TZMI)

Once the HMC has been upgraded to 95% total heavy mineral it will be transported from the PCP to the MSP.

Incoming HMC from the PCP will be processed via a series of magnetic and electrostatic separators to produce three final products, ilmenite, a monazite rich concentrate and a combined rutile/zircon concentrate. A tactical stockpile of HMC will be maintained at the MSP site to enable a constant feed rate into the drying equipment (Figure 3.5).

The MSP has two separate sections; an ilmenite circuit and a non-magnetics circuit. The following principles have been adopted to achieve good product quality and very efficient recovery:  The HMC must be fresh water-attritioned to remove surface coatings and salt;  Dry magnetic separation followed by electrostatic cleaning gives superior yield and quality to the ilmenite products;  Monazite removal is a significant process condition throughout the flow sheet;  Conventional wet gravity cleaning is sufficient to remove light-heavy impurity minerals from the non-magnetics products; and  Standard electrostatic and rare earth magnetic separators will be suitable for all of the dry parts of the flow sheet.

It is anticipated that the MSP will process 70 tph of feed to produce 500 000 tpa of ilmenite, 5 000 tpa of monazite and 62 500 tpa of a rutile/zircon concentrate.

Coastal & Environmental Services 38 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 3.5: Simplified flow sheet for a mineral separation plant (Source TZMI)

The MSP will be located at the mine site.

3.4 Transportation of Product

Three options exist for the transport of products from the mining operation to the markets:

1. A combination of rail and road haulage. 2. Road transport only. 3. Marine transport and port facilities

The rail and road option will involve transporting product by road from the mine site to the rail siding at Bitterfontein, approximately 85 km to the south east of the mine site. From there product will be loaded into a silo loading facility, purpose built at the Bitterfontein siding. This will be used to load rail wagons and the product will be railed over a distance of 540 km to Saldanha Port for export to overseas markets. At Saldanha a storage facility to hold 2-3 months of production will be constructed together with loading infrastructure for shore to ship loading (subject to separate environmental impact assessment and thus does not form part of the scope of works for this assessment). The construction of these bulk handling facilities presents challenges as the general goods terminal has no gantry or crane facilities.

In addition to this, transport by rail over a distance of 500 km is a significant operational cost and the preference would be to use the Sishen rail line, which reduces the distance to 240 km. Protracted negotiations to obtain permission to use the Sishen line are anticipated, as this line is dedicated to

Coastal & Environmental Services 39 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Iron Ore shipment and also caters for Namakwa Sands products. It is important to note that the rail option is not feasible due to the significant operational costs involved.

The second option is to transport product by road (N7) all the way from the mine site to Saldanha Port, using a 37 tonne pay load horse plus 2 trailers. This will result in relatively large volumes of road traffic along the N7, estimated at 20 round trips per day. In addition to this the provincial road to and the junction with the N7 may require upgrading in certain sections. These will be defined in the EIA.

In the last option, the heavy minerals will be transported either in the form of a slurry or by truck to the coast from the mine. They wil then be pumped as a slurry directly to the ships hold, using a subsea pipeline and Single Point Mooring (SPM) buoy (Figure 3.6). Three pipes will be required for the subsea section of the piping network although only two will be used simultaneously. The third pipe will function as a back-up route in the case of a failure occurring. The return water pipe is a continuous pipeline from the ship to the mine. The pump station on the ship will be used to pump the water onshore and a booster station onshore will provide the required energy to pump the water the remaining distance to the mine.

Figure 3.6: Single point mooring

Coastal & Environmental Services 40 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

3.5 Tailings disposal

Mining, concentration and tailings disposal will occur as a continuous process. These fall into two categories, the coarser sand (predominantly quartz) and the finer slimes (predominantly clay). The only additives to the material prior to deposition as tailings will be water and a biodegradable flocculent (settling agent). Tailings will be placed in an off mine path tailings facility as well as backfill within the mined areas. A tailings facility is necessary as an initial void must be created prior to being able to deposit tailings back into the mined out areas and as a storage area when the areas being mined are not deep enough, or too steep, for effective slimes backfill.

The area of the tailings storage facility will have topsoil removed and stockpiled prior to walls being constructed with sand to form a dam for the tailings. Upon closure a top layer of sand and then topsoil will be placed over the facility prior to re-vegetation. The sand walls will be constructed at a very low angle to allow the facility to blend into the landscape once vegetated.

Sand will also be used to construct paddock walls within the mined out area to contain slimes pumped into them. These slimes filled paddocks will then be overtopped with sand and re-contoured to a similar profile to pre mining allowing it to blend in with the surroundings prior to topsoil covering and re-vegetation.

3.6 Infrastructure

Even though a dry mining process is anticipated, the proposed operation will require large volumes of water, as a wet separation process is required to separate the HMC from the sand tails. Although water is recycled via the slimes thickener, a certain percentage of water remains tied up with the thickened slimes and sand tails in the backfill areas. TZMI assume that up to 12 Gl (12 million m3) of make-up water will be required per annum, translating to 33 000 m3 per day. It is anticipated that seawater will be used for processing in the PCP as there is insufficient groundwater available for this purpose.

There are, however, currently two options for provision of freshwater for the washing of HMC prior to entering the MSP:

1. The use of groundwater resources. Preliminary groundwater investigations indicate that the ground water is brackish, and therefore will need to be desalinated before being used to wash the HMC prior to entering the MSP. Zirco is in the process of doing further groundwater investigations to determine if a well-field could meet the demand and provide a sustainable yield. This data will be available in the EIA Phase of the proprosed project. 2. The use of seawater: Desalination of seawater to use for HMC washing is a second option, as the use of seawater has been successfully implemented at a number of mining operations worldwide.

A seawater intake will have to be constructed along the coast in close proximity to the proposed mine site. Two types of sea water intake works have been proposed as a source of water for the mine, these include:

 Open Water Intake in Khnyp Bay as a stand-alone installation;  Gully Intakes.

Coastal & Environmental Services 41 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Open Water Intake in Khnyp Bay as a stand-alone installation;

An open water intake in Khnyp Bay will include the following components:

 A beach crossing: Stretching from the head works landward of the primary dune to approximately the low water line. The construction of this section would consist of an open dry excavation which would be protected by a cofferdam.  A surf zone crossing: From the low water line to the limit of the breaker zone. Two methods of construction are currently under investigation for this section. The first consists of an open wet excavation between rock embankments in protected waters, while the second consists of a protected excavation inside a rock cofferdam with the seaward end closed off to exclude wave action inside the cofferdam.  An offshore zone pipeline: From the breakwater zone to the intake structure. This section could be constructed without a cofferdam utilising times of calm sea conditions.  An intake structure.

The above components are shown in the layout diagram in Figure 3.7.

Figure 3.7: Proposed intake works at Khnyp Bay (Source: Bergstan Africa)

Gully Intakes

Due to the rocky nature of the coastline in the area of the proposed development, it is feasible to construct a gully type intake. A number of potential locations from north of the Groen River to Khnyp Bay have been identified as shown on Figure 3.8 below.

Coastal & Environmental Services 42 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 3.8: Alternative gullies locations for seawater intake (Source: Bergstan Africa)

The quantity of freshwater required has been estimated at 690 000 m3 per annum (approximately 5.7% of the seawater requirements). This will be used for potable water and to remove salt from the HMC prior to it going into the MSP.

To provide this fresh water a reverse osmosis desalination plant is planned to be constructed at the mine site. The desalination plant will treat brakish groundwater or sea water brought to the mine site as process water. The freshwater produced from the desalination plant will be used to wash salt from the HMC prior to separation in the MSP. Water used to wash HMC will be recycled into the process water.

TZMI have estimated a power requirement of 15 MW, to be sourced from the national power grid. This line would need to be constructed from the Frontier Rare Earths project at Zandkops Drift. They intend to construct a high voltage transmission line to service their project. The 35 km line from Frontier to Roode Heuwel would be subject to a separate EIA undertaken directly on behalf of Eskom.

Coastal & Environmental Services 43 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

3.7 Ancillary Infrastructure

During the construction phase of the Zirco Mine facilities, temporary site based accommodation will be required for construction employees. On completion of the construction phase, the construction accommodation will be maintained for non-routine operational requirements on a “as needs basis”. Alternative locations for this accommodation will be assessed in the EIA Phase of the proposed development.

Domestic sewage is characterised by a high concentration of nutrients, organic matter and a variety of pathogens. As such, it must be properly treated prior to discharge to avoid negative impacts to human health and the environment. During the life of the mine, the proposed facility will not have access to a municipal sewage reticulation network and will thus have to rely on the use of a packaged sewage treatment plant to cater for the sewage emanating from the facilities. Various technology and layout alternatives for the proposed sewerage treatment works will be assessed during the EIA Phase of the proposed project.

It is proposed to construct an airstrip within the exploration area in close proximity to the mining activities. The airstrip will be approximately 1 300 m in length.

The landfill site will encompass an area of < 1 ha which will be sufficient to meet the mine and processing site waste requirements. The landfill site will cater for non-hazardous waste only (i.e. litter, domestic waste, building rubble etc.). No hazardous waste will be deposited at the landfill site.

Coastal & Environmental Services 44 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

4. THE NATURAL ENVIRONMENT

4.1 Climate

The area experiences wind on a daily basis, peaking in the evening where average wind speeds are 25km/hr. During the day wind speeds are much lower (Figure 4.1 below) dropping to below 10km/hr.

Figure 4.1: Summary of Namaqualand weather, showing average temperature, precipitation and wind speed. (Source: http://www.getamap.net/maps/south_africa/south_africa_%28general%29/_namakwaland/) Namakwa District Municipality

4.2 Landscape

Namaqualand covers 55 000 km2 of quartz-strewn plains, undulating hills, granite outcrops and rugged mountains (Olivier, 2005). Namaqualand is bordered to the north by the Orange (Gariep) River and to the south by the Olifants River. To the east it borders Bushmanland, and to the west the Atlantic Ocean (Figure 4.2). The project site occurs in the southern half of this area, in a belt within 20 km of the Atlantic Ocean.

Coastal & Environmental Services 45 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.2: Namaqualand with the project area indicated by the red rectangle.

Coastal & Environmental Services 46 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

The topography of the area is mostly flat with occasional low hills (Plate 4.1). Elevation is at an average of 143 meters above mean sea level.

Plate 4.1: Pictures indicating the topography of the site

The underlying geology (Figure 4.3) consists of quaternary unconsolidated to cemented sand overlaying Kamieskroon leucocratic gneisses (Zirco, 2012).

The surface aeolian sand varies in thickness over the project area from a few centimetres to 25 m. Dunes are predominantly orientated NNE to SSW due to prevailing wind conditions (Zirco, 2012). The surface sands are part of a typical silicic soil structure, the distribution of which is associated exclusively with arid landscapes (Fey, 2010). Mineralogical work to date shows these soils have a subsurface horizon cemented primarily by kaolin with a minor iron (Fe) in indurated zones, and not silica dorbank, which is more typical of these areas. Silicic soils are generally medium to coarse textured and well to moderately drained (although this depends on the coherence and depth of the underlying kaolin parent material). The pH of the parent material varies between 5 and 10, but typical values are between 7.5 and 9. The physical properties of the silicic soils in the area will depend on the depth at which the kaolin occurs in the profile, and the thickness of any overlying soil material. The often coarse texture of the overlying horizons means that plant available water contents are low. The erosion susceptibility of silicic soils is low to moderate since they are most common on gentle slopes and generally have sufficient cover in the form of grass and short succulent shrubs.

Coastal & Environmental Services 47 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.3: Geology of the site Source: Zirco, 2012

Within South Africa the agricultural use of silicic soils is limited by: the dry environment in which they occur, shallow soil depth, especially high pH in those with sodic properties, and low water holding capacity due to the sandy texture (Fey, 2010). The project site is currently used as grazing for sheep and goats and the area has a low carrying capacity. In Namaqualand the carrying capacity is generally given as 1 small stock unit per 10 to 12 hectares. The official carrying capacity for farms in the Liliefontein area was set at 12 ha per small stock unit, although this changed to 10 ha per small stock unit (SSU) by November of the same year (2002). Current recommended stocking levels in Namaqualand are based on a survey undertaken in the late 1980s by the Department of Agriculture (DoA) to identify carrying capacities for various veld types in the area. It resulted in a map of Namaqualand being developed, which is divided into different units with corresponding carrying capacities. Average carrying capacity for Namaqualand was set at approximately 10 ha per small stock unit. The map produced from this survey is today used by the DoA as a general guide to what the Namaqualand veld can tolerate in terms of grazing pressure. The study area falls into the range of 0 – 48 ha per Large Stock Unit, or 0 – 16 ha per SSU (Lebert 2004).

4.3 Geohydrology

Schlumberger Water Services has recently performed a hydrocensus of the project area. During their study they located 11 boreholes within the three prospecting areas. No data is currently available on the yields of these boreholes. The water is extracted using wind mills and is used for livestock watering and to a lesser extent for domestic use. All groundwater obtained from these boreholes was found to be brackish. For drinking water, local residents harvest rain water.

The aquifers on site were divided by Schlumberger Water Services (2012) into two main units as

Coastal & Environmental Services 48 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014 follows:

Unconsolidated primary aquifer: consists of the surface aeolian sands and basal grits and conglomerates within the weathered profile overlying the bedrock. Minor concentrations of groundwater in low lying areas were noted. Although minor kaolinisation and cementation from the weathering of the feldspars in the underlying granites and gneisses exists, the unit is generally unconsolidated and relatively permeable, with a relatively high slimes content. The undulating nature of the bedrock contact means that only local perched aquifers with limited aerial extent may form, separated by palaeo-highs in the bedrock contact.

Fractured secondary aquifer: this aquifer underlies the primary aquifer and comprises predominantly fractured bedrock within gneisses and granites which underlie the site. The topography of the bedrock contact with the overlying weathered material corresponds with structures in the bedrock such as faults and fractures generally oriented NNW-SSE, NE-SW and WNW-ESE. Although it is possible that significant groundwater flow may be encountered in faults and fracture zones, overall storativity is likely to be very limited. Based on the apparent depths of drilling, it is clear that all the boreholes in the area are drilled into fracture or fault zones in the bedrock.

Schlumberger Water Services conducted on site measurements of the groundwater extracted from the 11 boreholes found in the project area. Some key water quality parameters were measured and their averages (for the 11 boreholes) are as follows: Electrical Conductivity = 10.31 mS/cm; pH = 7.69; Total Dissolved Solids (TDS) = 7.23 parts per thousand; Salinity = 5.13 parts per thousand; Dissolved Oxygen = 3.42 mg/l; Oxidation-Reduction Potential = 214.81 mV.

4.4 Surface Water

The project area is drained by the Bitter and Outeep rivers to the north of the Leeuvlei prospecting area. The Outeep River is a tributary of the Bitter River. To the south is the Groen River, which borders the southern border of the Roode Heuvel prospecting area. All these rivers are ephemeral, meaning that they only flow temporarily after heavy rainfall.

4.5 Marine Environment

The littoral zone (the area from the high water mark to shoreline areas that are permanently submerged) along the west coast consists of alternating zones of rocky and sandy shores (i.e. sandy beaches), which is true for the coastal area near the proposed Kammiesberg project. Two key vegetation types occur along the coastal zone above the littoral zone, namely: seashore dunes and coastal duneveld. Seashore dunes occur as a belt along the coastline, above the high tide water mark, and on the seaward side of the Coastal Duneveld. Essentially the seashore dunes are covered in Namaqualand Seashore Vegetation, but there are also transition zones of seashore vegetation occurring on white dune sands, which have taller shrubs, but are not considered part of the Coastal Duneveld. Coastal duneveld is situated on the inland side of the seashore dunes, and eventually merges into Strandveld further inland.

4.6 Vegetation and Floristics

There are two vegetation classifications pertinent to the area. These are the National Vegetation map developed by Mucina and Rutherford (2006) and the Succulent Karoo Ecosystem Plan (SKEP). Each of these projects and descriptions of the relevant vegetation types are described below.

Mucina and Rutherford

Coastal & Environmental Services 49 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Mucina and Rutherford (2006) have developed the National Vegetation map as part of a South African National Biodiversity Institute (SANBI) funded project: “It was compiled in order to provide floristically based vegetation units of South Africa, Lesotho and Swaziland at a greater level of detail than had been available before.” The map was developed using a wealth of data from several contributors and has allowed for the best national vegetation map to date, the last being that of Acocks developed over 50 years ago. This map forms the base of finer scale bioregional plans such as STEP and SKEP.

The map and accompanying book describe each vegetation type in detail, along with the most important species including endemic species and those that are biogeographically important. This is the most comprehensive data for vegetation types in South Africa.

Mucina and Rutherford (2006) define the following vegetation types (Figure 4.4) from which source these descriptions are derived:

Namaqualand Strandveld This vegetation type occurs in the Northern and Western Cape Provinces and is characterised by a flat to slightly undulating landscape of coastal peneplain. The vegetation is typically low species-rich shrubland dominated by a variety of erect and creeping succulent shrubs. Namaqualand Strandveld is classified as Least Threatened with a conservation target of 26%. None is currently statutorily conserved and approximately 10% has been transformed. This vegetation type occurs in the study area.

Namaqualand Heuweltjieveld This vegetation type occurs in the Northern Cape along the western foothills of the Namaqualand Escarpment. It characterised by undulating plains that lead up the escarpment. The vegetation cover comprises a mosaic of low shrubland communities dominated by leaf-succulent shrubs that occur on slightly raised, rounded termite mounds or “heuweltjies”. It is classified as “not under immediate threat” with a conservation target of 28%. Approximately 11% has been statutorily conserved and 3-4% has been transformed by cultivation. This vegetation type occurs in the study area.

Namaqualand Klipkoppe Shrubland This vegetation type occurs in the Western and Northern Cape in the central and north-central regions of Namaqualand. It is typified by dramatic landscapes of large granite and gneiss domes and disintegrating boulder koppies that support open shrubland dominated by dwarf shrubs with ericoid or succulent leaves. It is classified as Least Threatened with a conservation target of 28%. Approximately 6% has been statutorily conserved and very little has been transformed.

Namaqualand Sand Fynbos The Namaqualand Sand Fynbos occurs in the Western and Northern Cape along the coastal plains. The vegetation occurs on slightly undulating plains and is dominated by restionaceae that occur between scattered shrubs. It is classified as Least Threatened with a conservation target of 29%. Only 1% is statutorily conserved and 2% has been transformed by cultivation. This vegetation type occurs in the study area.

Namaqualand Riviere Namaqualand Riviere occurs in the Western and Northern Cape along dry riverbeds throughout Namaqualand. It is characterised by a complex of alluvial shrubland interspersed with patches of tussock graminoids (grasses). In places low thickets of Acacia karroo and Tamarix usneoides are found. It is classified as Least Threatened with a conservation target of 24%. Only a small percentage has been statutorily conserved while almost 20% has been transformed through cultivation. This vegetation type occurs in the study area. Namaqualand Coastal Duneveld

Coastal & Environmental Services 50 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

This vegetation type occurs in the Western and Northern Cape along the coastal plains. The vegetation is typically dwarf shrubland dominated by erect succulent shrubs and non-succulent shrubs. Spiny grasses are common on the windblown semi-stable dunes. The Namaqualand Coastal Duneveld is classified as Least Threatened with a conservation target of 26%. None is statutorily conserved and 8% has been transformed through diamond mining. This vegetation type occurs in the study area, along the coast at Khnyp Punt.

SKEP

The Succulent Karoo biome extends from the south-west through to the north-west of South Africa and up into Namibia (Driver et al.; 2003). It is classified as one of the 25 internationally recognised biodiversity hotspots and is the world’s only arid hotspot. It is remarkably diverse with 6 356 plant species, 40% of which are endemic and 17% of which are listed on the Red Data list. Despite this rich diversity and high level of endemism, only 3.5% of the biome is formally conserved. As a result the biome’s diversity is under pressure from human impacts, especially mining, agriculture, overgrazing and climate change.

The goal of the Succulent Karoo Ecosystem Plan (SKEP) is therefore to provide a framework to guide conservation efforts of this unique biome (Driver et. al.; 2003). The three main aims of the project are to:

 “Provide a hierarchy of priority actions to guide conservation efforts and donor investment in the biome (both on and off formal reserves);  Build human resource capacity to implement the plan by including training and mentorship activities as part of the planning process; and  Generate the institutional and government support required to ensure its effective implementation”

Four of the six vegetation types described by SKEP are found to occur in the project area (Figure 4.5):

 Sandveld  Strandveld  Lowland Succulent Karoo  Fynbos

Coastal & Environmental Services 51 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.4: Mucina and Rutherford vegetation map indicating the vegetation types that occur in the project area

Coastal & Environmental Services 52 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.5: SKEP vegetation map indicating the vegetation types that occur in the project area.

Coastal & Environmental Services 53 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

As described above, the project area falls within the Succulent Karoo Biome. Globally there are very few areas that are as biologically distinct as this biome, as none of these regions are dominated by dwarf leaf-succulent shrubs within a winter-rainfall desert (Mucina and Rutherford, 2006). The Succulent Karoo has a rich diversity of species (6 356 species of vascular plants in 1002 genera and 168 families) with 26% of its species being strict endemics2 and a further 14% being near endemics3 (Driver et.al., 2003). Seventeen percent are listed as Red Data Species by the International Union for Conservation of Nature 1994 (IUCN4).

Potential Species of Special Concern (PSSC)

Potential Species of Special Concern (PSSC) include all those plants listed in terms of the IUCN, CITES and both national and provincial legislation that may occur in the area of study. If any of these species are found to occur on site, they are given the status of Confirmed Species of Special Concern (CSSC). Such a list should be produced in the EIA stage of the proposed development. The list of PSSC includes species that are listed individually by the IUCN red data list, the South African National Biodiversity Institute (SANBI), the National Forests Act and the Provincial Nature Conservation Ordinance (PNCO) 16 of 1974.

Species endemic to the area are described by Mucina and Rutherford (2006). In addition to the endemic taxa, there are also a number of species expected to be found in the study area, some of which are listed as protected by various conservation bodies (Table 4.1). The taxa with many data deficient species include specifically the Mesembryanthemaceae family, as well as members of the Amaryllidaceae (Amaryllids), Iridaceae (Irises), Orchidaceae (Orchids) and Apocynaceae (Lianas), as well as members of the genus Aloe.

Table 4.1: A summary of the number of plant species that occur on the various conservation bodies lists IUCN Status Number of Species Vulnerable 1 CITES Appendix I 0 Appendix II 15 PNCO Schedule 4 247 Protected Tree Species List 0 NEMBA5 0

A reconnaissance level survey of the three deposits was undertaken, with notes and photographic evidence recorded at a total of 17 sites across the three deposits and in some cases slightly outside the area (Figure 4.6). The following vegetation types, based on the SANBI vegetation map (Mucina and Rutherford, 2006) are found within the deposit areas:

2 Strict Endemic: Species with distributions that are restricted to the Succulent Karoo 3 Near Endemics: Species that have their centre of distribution within the Succulent Karoo 4 The International Union for Conservation of Nature (IUCN) is recognized globally as one of the most comprehensive and objective approaches for evaluating the conservation status of plant and animal species. The IUCN aims to provide information and analyses on the status, trends and threats to species in order to inform and take action for the conservation of biodiversity

5 National Environmental Management: Biodiversity Act (No. 10 of 2004), (NEMBA)

Coastal & Environmental Services 54 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

 Namaqualand Strandveld – The hilly, irregular terrain in the north-east of Leeuvlei and south-east of Sabies is dominated by Namaqualand Strandveld.  Namaqualand Sand Fynbos – Dominates most of the Roode Heuvel deposit and portions of Sabies (Figure 4.6). It is associated with the irregular topography of these areas, typified by small hummock and transverse dunes with low lying, inter-dune areas.  Namaqualand Heuweltjieveld – Occurs in the north east of Leeuvlei and the south east of the Sabies deposit, where basement material becomes exposed. These areas will not be mined.

Figure 4.6: Google image of the three prospecting rights, showing location of the observation points described in Table 5.2 below

Coastal & Environmental Services 55 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Table 4.2: Description of site observation points and selected photographs showing relevant details of the site Site No. Description Photo 1 Western boundary of Roode Heuvel within Exxaro site. Namaqualand Strandveld

2 Located in Exxaro site, showing area No photo provided cleared for planting some years back. 3 View North-east towards Leeuvlei, within an area of Namaqualand Sand Fynbos

Coastal & Environmental Services 56 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Site No. Description Photo 4 Old quarry site in north west portions No photo provided of Leeuvlei deposit 5 View across Leeuvlei showing very level terrain and homogenous cover of Namaqualand Strandveld vegetation. This area is dominated by shallow red aeolian sands. Small dunes are evident, but in general interdune areas are difficult to identify as the landscape is so level.

6 Inter-dune area in Leeuvlei deposit showing greater abundance of restio species in these lower lying areas of Namaqualand Strandveld vegetation

7 Sabies deposit, on north east boundary of Roode Heuvel deposit, within No photo provided Namaqualand Strandveld vegetation

Coastal & Environmental Services 57 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Site No. Description Photo 8 Drainage line in Sabies deposit, eastern boundary in vicinity of homestead Jan Engelbrecht. These drainage lines are dominated by grasses and herbs, with almost no woody shrubs. Namaqualand Heuweltjieveld in the background.

9 Eastern edge of No photo provided Sabies deposit 10 Southern boundary of Roode Heuvel deposit, in disturbed Namaqualand Sandveld. Note increased abundance of unpalatable grasses and reduced cover of woody shrubs.

11 Rehabilitation site. No photo provided 12 Southern portion of Roode Heuvel with No photo provided Namaqualand Sandveld 13 Pilot plant area, showing No photo provided rehabilitation of bulk mined area.

Coastal & Environmental Services 58 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Site No. Description Photo 13(2) Low lying area dominated by Restio spp in Namaqualand Sand Fynbos, central portion of Roode Heuvel

14 Low lying area within central Roode Heuvel dominated by Namaqualand Sand Fynbos which has been cleared in the past to plant crops. Restio’s dominate the unplanted area, whereas the cleared area is covered in a herbaceous layer of herbs with limited grass cover.

15 Level, low lying area in the northern portion of Roode Heuvel, dominated by Namaqualand sand Fynbos. Note the conspicuous dominance of the Restio.

16 Northern boundary No photo provided of Roode Heuvel

Coastal & Environmental Services 59 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

4.7 Fauna

Table 4.3: Reptile species in the region that are listed in the International Red Data Book of Reptiles and Amphibians Source: Branch, 1998 Species Common Name IUCN Status

Chamaeleo namaquensis Armadillo girdled Lizard Vulnerable

Acontias litoralis Southern Spiny Agama Least Concern

Acontias Lineatus Namaqua chameleon Least Concern

Agama atra Giant ground gecko Least Concern

Agama hispida Dwarf Plated Lizard Least Concern

Aspidelaps lubricus Common Egg Eater Least Concern

Bitis arietans Namaqua Plated Lizard Least Concern/ near threatened

Bradypodian occidentale Speckled Padloper Least Concern/ near threatened

Based on species distributions it is estimated that as many as 10 species may occur in the project area, provided there are suitable micro-habitats to support them. Table 4.4 lists species of frogs that are likely to occur in the region. Of these 10 species, one species, the Desert Rain Frog, is a species of conservation concern.

Coastal & Environmental Services 60 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Table 4.4: Threatened and endemic frogs likely to occur in the Project area Source: du Preez and Carruthers, 2009 Scientific Name Common Name IUCN Status

Breviceps macrops Desert Rain Frog Vulnerable

Amietia fuscigula Cape River Frog Least Concern

Breviceps namaquensis Namaqua Rain Frog Least Concern

Breviceps rosei Roses Rain Frog Least Concern Namaqua Caco, Namaqua Cacosternum namaquense Least Concern Dainty Frog Strongylopus springbokensis Namaqua Stream Frog Least Concern

Tomopterna delalandii Delalande's Sand Frog Least Concern

Vandijkophrynus gariepensis Karoo Toad Least Concern

Vandijkophrynus robinsoni Paradise Toad Least Concern

Xenopus laevis Common Platanna Least Concern

Table 4.5: Threatened bird species likely to be encountered in the project area and surrounds Source: SABIF, 2012 Scientific Name Common Name IUCN

Neotis ludwigii Ludwig's Bustard Endangered

Circus maurus Black Harrier Vulnerable

Morus capensis Cape Gannet Vulnerable

Procellaria aequinoctialis White-chinned Petrel Vulnerable

Sagittarius serpentarius Secretary Bird Vulnerable

Charadrius pallidus Chestnut-banded Plover Near Threatened African Black Oystercatcher, African Haematopus moquini Near Threatened Oystercatcher Phalacrocorax capensis Cape Cormorant Near Threatened

Phalacrocorax coronatus Crowned Cormorant Near Threatened

Polemaetus bellicosus Martial Eagle Near Threatened

Puffinus griseus Sooty Shearwater Near Threatened

Coastal & Environmental Services 61 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Table 4.6: Vulnerable Mammals that are likely to occur within the project area Mouton and Alblas; 2003 Scientific Name Common Name IUCN

Felis lybica African Wild Cat Vulnerable

Erimitalpa granti Grant’s Golden Mole Vulnerable

Macroscelides proboscideus Elephant Shrew Vulnerable

4.8 Conservation and Planning Tools

Several conservation planning tools are available for the area. These tools allow for the determination of any sensitive and important areas from a vegetation and faunal point of view. They allow for the fine-tuning of plans with a view to reducing potential environmental impacts at the planning stage of the development. The tools used are outlined in Table 4.7 below.

Table 4.7: Conservation and planning tools considered for the proposed project. Tool Motivation Relevancy Implications Namaqua The purpose of the Relevant. The north east These areas should be District Namaqua District and southern portion of managed to maintain near Biodiversity Biodiversity Sector Plan is the project area falls natural landscapes with Sector Plan to guide land-use planning, within an “Ecological minimal loss in ecosystem environmental Support Area”. These are functioning. assessments and defined as areas that authorisations and natural meet ecological process resource management to targets or achieve ensure that development in biodiversity persistence this region occurs in a objectives (Figure 4.7). sustainable manner, The potential servitude particularly within the area and landholding fall identified Critical within a CBA 2 area. CBA Biodiversity Areas (CBA) 2 areas are defined as (Namaqua Bioregional areas of high biodiversity Plan, 2008). CBA’s are that are important for areas that have been ecological processes and identified as irreplaceable climate change as well as key to the adaptation. maintenance of ecosystem services.

Coastal & Environmental Services 62 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Tool Motivation Relevancy Implications SKEP SKEP has identified nine Relevant. The majority of This confirms that the area Protected broad geographic priority the project site falls within will be regarded as Area areas for conservation in the Central Namaqualand ecologically sensitive, and the Succulent Karoo biome. Coast Priority Area that an ecological These areas were selected (Figure 4.8). assessment will be required. based on collections of high irreplaceability planning units, medium to high land- use pressures and the incorporation of spatial components of key ecological processes Protected Protected areas are areas Relevant. The study site Since the study area is less Areas that are already conserved. is less than 10 km from than 10 km from a national Areas in close proximity to the Namaqua National protected area the activity will the proposed development Park (Figure 4.8) trigger activities on Listing may be affected by the Notice 3 of the National development and thus must Environmental Management be taken into account. Act. Protected The objective of the PAES Not Relevant. The study Eventhough there are no Areas is to form an overarching site occurs more than 5 areas earmarked for Expansion strategic framework for a km from the “Namaqua” expansion according to the Strategy protected area network that area which is the closest PAES, the proposed ‘conserves a area earmarked for boundary for the comprehensive, expansion. (Figure 4.8). Namaqualand Marine representative and Protected Area extend south adequate sample of to 30°55’00 S and biodiversity and maintains 17°36’27.10 E (shown as key ecological processes Prossible Expansion 1 on across the landscape and Figure 4.9). This has been seascape.’ The areas extensively work-shopped earmarked by this study and planned with DMR and should be protected. other stakeholders. (Pers Comm, Bernard van Lente, Park Manager, Namaqua National Park) The land portion of the Namaqua National Park will thus also expand to this point. In addition to this, there is also a possibility that the park will be extended south to include the whole Admiralty Zone/ State land up to Strandfontein (approximate co-ordinate 30°56’17.68” S and 17°37’46.43” E; marked as Possible Expansion 2 on Figure 4.9)

Coastal & Environmental Services 63 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Tool Motivation Relevancy Implications SKEP To supplement data on Relevant. A section of the This is a potential issue and a Vertebrate biodiversity areas provided project area falls within a faunal assessment will be Priority Areas by the SKEP vegetation bird priority area. In required. map, experts in different addition, a reptile priority taxonomic groups area occurs less than 5 (amphibians, birds, fish, km from the project site invertebrates, reptiles and (Figure 4.10). small mammals) mapped centres of endemism and species richness, unique habitats and key areas for maintenance of biological processes for various taxonomic groups. Important Bird Important Bird Areas are Not Relevant. The study N/A Area (IBA) globally recognized areas site does not occur within essential for the protection or close to any IBA’s. of bird species. In order to be classified as an IBA, an area must contain Globally threatened species, restricted range species, biome restricted species or congregations of species. National List The National Environmental Not Relevant. The N/A of Ecosystems Management: Biodiversity project area does not that are Act provides a list of occur in any areas Threatened threatened terrestrial identified as threatened and in need of ecosystems. This has been ecosystems. Protection. established as little (NEMBA, Act attention has historically 10 of 2004) been paid to the protection of ecosystems outside of protected areas. The purpose of listing threatened ecosystems is primarily to reduce the rate of ecosystem and species extinction. This includes preventing further degradation and loss of structure, function and composition of threatened ecosystems.

Coastal & Environmental Services 64 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Tool Motivation Relevancy Implications The National The coastal protection Relevant. The proposed Since the proposed Environmental zone, as defined by The project site extends down landholding and a portion of : Integrated Integrated Coastal to the coast and therefore the servitude extends down to Coastal Management Act, is the into the coastal protection the coast, listing notice 3 of Management continuous strip of land, zone. the NEMA regulations will be Act starting at the High Water triggered. Mark and extending 1000 metres inland in areas that are undeveloped and 100 metres inland of developed urban areas zoned as residential, commercial or public open space (Celliers et. al.; 2009). The coastal protection zone was established to manage, regulate and restrict the use of land that is adjacent to coastal public property or that plays a significant role in the coastal ecosystem.

Coastal & Environmental Services 65 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.7: Critical Biodiversity Areas found within the project area. (CBA = Critical Biodiversity area; ESA = Ecological Support Area)

Coastal & Environmental Services 66 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.8: Formal Protected Areas, National Protected Areas Expansion Strategy and SKEP priority Areas

Coastal & Environmental Services 67 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.9: Possible expansions of the Namaqua National Park

Coastal & Environmental Services 68 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 4.10: Vertebrate priority areas identified by SKEP

Coastal & Environmental Services 69 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

5. SOCIO-ECONOMIC ENVIRONMENT

This Chapter describes the socio-economic conditions which characterise the project area.

5.1 Administrative Structures

5.2 Demographics

One of the defining features of the Namakwa District is its low population size and density. While the NDM is very large geographically (at 126 747 km2 it is the largest District in South Africa), it has the smallest District population size in the country (estimated at 126 512 in 2007); population density is thus extremely low. The NDM has a population density of approximately 0.9 people per km2, compared to figures for the Northern Cape - 2.62 people per km2 and South Africa - 3.91 people per km2. Consistent with this trend, the Kamiesberg Local Municipality is sparsely populated (with a population estimated at approximately 12 116), and a population density of about 1 person per square kilometre over its 11 742.47 square kilometres. The Kamiesberg LM population comprises 10% of the DM population (NDM LEDS 2009:27), as measured in the 2007 Community Survey.

Like the District, the Kamiesberg Municipality is predominantly rural, and settlements are dispersed; small towns are typically centred around activities such as mining, tourism and agriculture. Major settlements within the LM include Hondeklip Bay, Garies and Kamieskroon. The project area comprises a number of farms (approximately 8). Consistent with the low population density of the area, these farms are typically home to the resident land-owning couple, and often an elderly set of parents, and up to two families of resident farm labourers per farm.

The District Municipality population is comprised by a gender ratio of 50.28% men to 49.72% women. The significant majority of the population are Coloured (population groupings are outlined below), and the predominant language spoken is Afrikaans.

Table 5.1: Population by Population Group Source: Census data, 2001 Population Kamiesberg Namakwa DM Group LM Black African 3% 2% Coloured 88% 87% Indian or 1% 0.1% Asian White 9% 11%

The District population is further characterised by a notable youth population (below 15 years) of 24.63% and a significant working age population (between 15 and 64 years) of 67.98%. This results in a dependency ratio of 47%, meaning that there are 47 people of working age for every 100 people within in the District.

A number of demographic distortions should be noted in the District population, namely lower than usual populations in the 15-29 age-groups, and particularly of women in these age-groups. This suggests a trend of youth out-migration. An additional distortion noted is a declining birth-rate – populations in the 0-4 and 5-9 age groups are lower than the 10-14 and 15-19 age groups. This is possibly attributable to the out-migration of economically active women.

Coastal & Environmental Services 70 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

A scoping level analysis of the demographic patterns on the farms within the project area indicates that while farm residents do not reflect the generalised high youth population (farmers are typically middle-aged couples, often accompanied by elderly parents), patterns of out-migration of the young adult population in the area are reflected by the absence of these younger generations living on the farm properties.

5.3 Economy of the area

The Namakwa District Municipality is described as a District “in distress” in the National Spatial Development Framework (see REF), and as a “situation in despair”. A significant service delivery backlog is coupled with an undiversified economy (overly) reliant on primary sector activity, which has declined steadily over recent years. Because the economy is highly concentrated, this economic dislocation impacts the population more than would be the case in a more diversified economy.

Mining and agriculture are the predominant economic activities in the area. The largely semi-arid and arid environment of the District makes the area additionally suitable for tourism and conservation, as well as renewable energy and star-gazing.

Despite the largely semi-arid and arid environment of the province, the fertile land that lies alongside the Orange River supports the production of some quality agricultural products (table grapes produced along the Orange River are exported). The area is further renowned for the quality of the meat produced, including Karoo lamb, ostrich, beef and venison (NDM LEDS 2009: 46).

In 2010, the mining sector provided 14.51% of total employment figures, agriculture provided 17.93%, trade contributed 18.51% and community services contributed 24.6%. The unemployment rate, as well as the number of unemployed people in the District has increased. Labour absorption rates are estimated to be 60%, thus 40% of the working age population is not employed6. In 2010 there were 10 156 unemployed people in the District, of whom 95.91% were Coloured, 2.51% African and 1.55% White and 0.01% Asian. Of the employed population, the greatest percentage of workers work in elementary jobs, and a high proportion of them are unskilled or semi-skilled workers (NDM LEDS 2009:50).

The isolated nature of the District results in a challenge to attracting investment in the area, and, to a degree, inhibits the expansion of economic linkages beyond the area.

These figures were measured in 2008, see LED:

Coastal & Environmental Services 71 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

The Local Economic Plan for the District (2009) prioritises “job creation with a focus on identified economic sectors through the exploitation of the region’s rich mineral, agricultural, natural and tourism-related endowments”. Among the key planned actions to achieve this, Mining Sector Development has been identified as a core local economic development strategy (NDM LEDS 2009:6).

The stimulation of the mining sector would provide a much-needed stimulus to the local economy, and also provide jobs in the area. This is important as the recent decline in mining production may result in the stagnation of many of the key towns within the District, a number of which have developed around the mining industry. It is anticipated that this would result in rapid rural-urban shifts to towns outside of the District (such as Kimberly and Upington).

5.4 Education

Education levels within the District are low, and this is directly linked to the low levels of skills in the population. According to data from the 2001 Census, approximately 5% of the population at the District level has no schooling, 36.42% of the population have some secondary education, while 10.79% have a matric certificate. Only 1.54% of the population has a higher education. The Kamiesberg Local Municipality similarly displays very low figures of high school completion and tertiary education.

5.5 Health

In terms of health, official figures (circa 2007) indicate that 5.1% of the District population is HIV positive; however, figures are likely to be higher now, due both to increasing infection rates and the possibility of under-recorded incidences due to a lack of accessible testing facilities. Additional health challenges include tuberculosis and substance abuse. Health care provision is limited, due to a lack of hospitals and clinics and the rural, dispersed nature of settlement (NDM LEDS 2009:41).

5.6 Poverty

Poverty is widespread throughout the District (74.96% of the District population is classified as falling below the poverty level (see NDM LEDS 2009:2)); this is related to the high levels of unemployment, as well as the fact that much of the jobs which people have access to are unskilled or semi-skilled labour, and therefore low-paying. The District is characterised by low-income households; a large percentage of the population (25.06% - measured in 2005) accesses and relies on social grants, including a portion of economically active people. 51% of households in Kamiesberg Local Municipality were registered as indigent in 2005, which is significantly higher than the Namakwa District Municipal rate of 36% of all households (NDM LEDS 2009:34). Very few households within the District enjoy high spending power – just 1.8% of households are classified as high-income (earning more than R 307 201 per annum) (as recorded in the 2001 Census, and reported in the NDM LEDS 2009).

Conditions of poverty are also related to poor service delivery (which is inhibited both by the service delivery backlog, as well as by the dispersed and isolated nature of settlements within the area), as well as social ills. The NDM IDP 2012-2016 describes these social ills, noting that “alcohol and drug abuse remains the leading cause of crime, poverty, reduced productivity, dysfunctional family life, the escalation of chronic diseases such as HIV and AIDS and related health factors, injury and premature death.”

5.7 Housing and access to Basic Services

Coastal & Environmental Services 72 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

The majority of the Namawka District Municipality population resides in formal dwelling structures, with 5% of households in informal dwellings and 2.4% in traditional huts. Within the Kamiesberg Local Municpality, 77.1 % of the population live in formal housing, with 5.5% of the population living in informal dwellings and 0.9% in traditional huts. Approximately 14% of the population reside in worker’s hostel accommodation.

In terms of the services accessed by the Kamiesberg LM population within their households, 56% of the population has access to piped water within their dwellings, 24.3% within their yards, and a further 15.5 from a point outside of their yard. 80.3% of the population has access to refuse removal services on a weekly basis. The table below provides an indication of the type of toilet facilities households’ access.

Table 5.2: Percentage distribution of households by type of toilet facilities % Type of toilet facility Households Flush toilet (connected to sewerage system) 49.2 Flush toilet (with septic tank) 5.3 Dry toilet facility 19.5 Chemical toilet 20 Pit latrine with ventilation 1.6 Pit latrine without ventilation Bucket latrine 0.5 None 3.8

Only about 9% of households do not have access to electricity. The table below provides an overview of electricity and fuel usage patterns within households across the local municipality.

Table 5.3: Percentage Distribution of Kamiesberg LM households by type of energy fuel used Source: Community Survey 2007 data Energy/Fuel Lighting Heating Cooking Electricity 85.2 74 77.4 Gas 3.7 6.2 15.4 Paraffin 0.1 0.2 Wood 17.5 5.5 Coal 0.4 Animal dung Solar 0.4 0.4 0.4 Candles 8.2 1.3 Other 2.5 1.2

5.8 Archaeology and Heritage

Research has shown that the majority of coastal zone archaeological sites occur within 300 m of the High Water Mark, while the density of sites visibly decreases as one moves further inland (Kaplan 1993). Inland sites, it would seem, appear to be concentrated along river courses, streams and floodplains, but unknown springs and pans may also occur away from these obviously predictable water supply sources. Rocky outcrops and boulders would definitely have been targeted by Stone Age people in the past, and several such rock shelters with archaeological deposits, shellfish, stone tools, pottery, ostrich eggshell, and even rock art have been documented south of Groenrivier, near Kotzesrus (Orton & Hart 2011). However, by its very nature, human behaviour is unpredictable and archaeological remains are often encountered in the most unlikely landscapes

Coastal & Environmental Services 73 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014 and settings.

Historical graves are usually well marked and mostly occur in small farm graveyards. Pre-colonial graves, on the other hand, can occur at any location where sand suitable for excavation and burial exists. Pre-colonial graves are unmarked and have been found in various locations throughout the western coastal region of South Africa, including several in Namaqualand. A human burial was found at the mouth of the Groenrivier (Jerardino et al 1992). These locations cannot be predicted and no plans can be made to avoid intersecting such graves.

Apart from a few quartz and quartzite stone flakes that were encountered, very little archaeological heritage was documented during the site visit. Single quartz flakes were located in the sandy flatlands, and alongside a small pan on the farm Leeuvlei, while several quartz and quartzite flakes were also found on exposures of natural gravel below some hilly koppies on Leeuvlei. One single quartz flake was found in the existing (small) sand mining area on the Farm Roode Heuvel, where the lands have recently been mined and rehabilitated.

Ruins of small mud brick structures were noted within the mining application area and are usually found associated with farm complexes. Their state of preservation is very poor.

Based on a short, 1-day field assessment, it is the archaeologist’s professional opinion that the proposed mining of mineral sands at Leeuvlei and Roode Heuvel will not have a severe or especially significant impact on the archaeological heritage. While some archaeological heritage may occur within the mining application area, it is felt that any important remains that might be documented can easily be mitigated, if required. Early (ESA) and Middle Stone Age (MSA) artefacts are almost certainly distributed below the mantle of sand that covers many less eroded areas, while Later Stone Age (LSA) artefacts and scatters of pottery and ostrich eggshell may occur among the small heuweltjies and in any wind deflated sand basins. LSA rock shelters, and possibly older MSA occurrences may also occur among more hilly and rocky terrain in the Leeuvlei application area.

Mining will focus on the undulating dune areas where the sands are much deeper, and unmarked pre-colonial human burials may therefore be exposed or uncovered during mining operations and associated activities (excavations for services, construction of access roads, and mining camp site, etc.).

Coastal & Environmental Services 74 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

6. STAKEHOLDER ENGAGEMENT (PUBLIC PARTICIPATION)

This Chapter of the report provides the details of the Public Participation (PPP) followed during the Scoping Phase of the EIA. The Scoping phase of the EIA provides for the involvement of Interested and Affected Parties (I&APs), in forums that allow them to voice their opinions and concerns, at an early stage of the proposed project. Such engagement is critical in the EIA, as it contributes to a better understanding of the proposed project among I&APs, and raises important issues that need to be assessed in the EIA process.

6.1 Objectives of Public Participation

Public Participation during scoping aims to:

 Disclose activities planned by the project proponent and the EIA team.  Identify concerns and grievances from interested and affected parties.  Harness local expertise, needs and knowledge from the interested and affected parties.  Respond to grievances and enquiries of project-affected people.  Identify additional or new stakeholders.  Gather perceptions and comments on the proposed terms of reference for the specialist studies.  Ensuring that all issues raised by stakeholders have been adequately assessed.  Sharing the findings, mitigation measures, management actions, management and monitoring programmes and recommendations of the specialists.  Including any new concerns or comments that arise.

This information is used to:

 Identify underestimated or unanticipated impacts.  Alert the project to possible communication breakdowns and emerging problems and concerns.  Encourage the use of local resources and knowledge in the project.  Identify development opportunities and community projects.

6.2 Benefits of Public Participation

The benefits from a successful PPP process are as follows:

 Interested and affected parties (I&APs) can influence the project to reduce adverse effects, maximise ancillary benefits and ensure they receive appropriate compensation.  Additional opportunities will arise during project design to ensure that equity issues are considered and the needs of the poor receive priority.  Management plans which result from the environmental assessment process are more effective.  Fewer conflicts will develop and where they develop they can be addressed timeosly.

6.3 International Principles of Public Participation

The principles for the PPP have been adopted from the guidelines for stakeholder engagement developed by the International Finance Corporation (IFC). These are listed below:

 Inclusiveness: Inclusion of all stakeholders in the process is ensured and the Stakeholder Engagement Team (SET) remains alert to the emergence or formation of new stakeholder groups during the process. Attempts are made to ensure that the voices of the least powerful stakeholders are heard.  Communication: Communication on different aspects of the project (i.e. ESIA procedures,

Coastal & Environmental Services 75 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

mining operations, infrastructure, etc.) is co-ordinated in a coherent and efficient communication mechanism in order to avoid excessive meetings and duplication.  Communication mechanisms: The mechanisms are familiar, culturally accepted and convenient to all stakeholders.  Consistent communication: There is consistency and continuity in the communication mechanisms used, and in the SET, to avoid contradiction and confusion within and between the stakeholder groups.  Communication techniques: Information is communicated in a form that is appropriate and meaningful to all stakeholders. This implies that different materials and methods of communication may be needed for different stakeholders. Written and oral communications in local language and readily accessible formats is used. Use of visual methods to explain information to non-literate people is important.  Genuine Consultation: Two-way communication is enabled in which both the SET and the stakeholders contribute to discussions and to the shaping of the ESIA and the project.  Grievances: From stakeholders must be heard and addressed  Transparency and trust: The SEP builds on a relationship of trust and respect between all stakeholders. This can be achieved through an attitude of transparency and openness to different cultural values and knowledge bases.  Flexibility: The planning of the engagement activities is flexible in order to allow appropriate and timely responses to changes in the process.  Evaluation: The efficiency of the SEP process is evaluated.

6.4 Regulations and Requirements for Public Participation

According to Section 54(2) of the National Environmental Management Act, 107 of 1998 as amended (NEMA) “the person conducting a public participation process must take into account any guidelines applicable to public participation as contemplated in section 24J of the Act and must give notice to all potential interested and affected parties of the application which is subjected to public participation by:

(a) Fixing a notice board at a place conspicuous to the public at the boundary or on the fence of (i) The site where the activity to which the application relates is or is to be undertaken; and (ii) Any alternative site mentioned in the application.”

Site notices were placed on the boundary of the project area as well as along the main access road to the Groen River Estuary (Plate 6.1). In addition to this smaller notices (A3) were placed on notices boards at the Agrimark and the OK Bazaars in Garies as well as the tourist centre in Garies and SANParks offices close to the Groen River Estuary (Plate 6.2).

A B

Coastal & Environmental Services 76 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Plate 6.1: (A) Site notice along property boundary; (B) Site notice along main access road

Plate 6.2: (A) Site notice at agrimark in Garies; (B) Site notice at OK in Garies (C) Site notice at tourist centre in Garies (D) Site notice at SANParks Office

(b) Giving written notice to:

(i) The owner or person in control of that land if the applicant is not the owner or person in control of the land; (ii) The occupiers of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken; (iii) Owners and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken; (iv) The municipal councillor of the ward in which the site or alternative site is situated and any organisation of ratepayers that represent the community in the area; (v) The municipality which has jurisdiction in the area; (vi) Any organ of state having jurisdiction in respect of any aspect of the activity; and (vii) Any other party as required by the competent authority;

Contact details of all stakeholders identified are available in Section 6.6. Copies of the letters of notification and proof of receipt are available in Appendix 3 of this report.

(c) Placing an advertisement in: (i) One local newspaper; or (ii) Any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations.

Coastal & Environmental Services 77 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

(d) Placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in [subregulation (c)(ii)] paragraph (c)(ii); and

(e) Using reasonable alternative methods, as agreed to by the competent authority, in those instances where a person is desiring of but unable to participate in the process due to: (i) Illiteracy; (ii) Disability; or (iii) Any other disadvantage.”

In addition to the above and according to Section 55 (1) of the NEMA Regulations “an EAP managing an application must open and maintain a register which contains the names, contact details and addresses of:

(a) All persons who, as a consequence of the public participation process conducted in respect of that application in terms of regulation 54, have submitted written comments or attended meetings with the applicant or EAP; (b) All persons who, after completion of the public participation process referred to in paragraph (a), have requested the applicant or the EAP managing the application, in writing, for their names to be placed on the register; and (c) All organs of state which have jurisdiction in respect of the activity to which the application relates.”

According to Section 56(1) of the NEMA Regulations “a registered interested and affected party is entitled to comment, in writing, on all written submissions, including draft reports made to the competent authority by the applicant or the EAP managing an application, and to bring to the attention of the competent authority any issues which that party believes may be of significance to the consideration of the application, provided that:

(a) Comments are submitted within: (i) The timeframes that have been approved or set by the competent authority; or (ii) Any extension of a timeframe agreed to by the applicant or EAP. (b) A copy of comments submitted directly to the competent authority is served on the EAP; and (c) The interested and affected party discloses any direct business, financial, personal or other interest which that party may have in the approval or refusal of the application.”

Lastly, Section 57(1) states that: “the EAP managing an application for environmental authorisation must ensure that the comments of interested and affected parties are recorded in reports and that such written comments, including records of meetings, are attached to the report, submitted to the competent authority in terms of these Regulations.”

In terms of international standards, the IFC’s environmental and social performance standards are regarded as the benchmark for international best practice. IFC Performance Standard 1 stipulates the following for stakeholder engagement:

 When local communities may be affected by risks or adverse impacts from a project, the project will include consultation with them.  Community engagement will be free of external manipulation, interference or coercion and intimidation and conducted on the basis of timely, relevant, understandable, inclusive, culturally appropriate and accessible information.  Disclosure will occur early in the social and environmental assessment process (scoping

Coastal & Environmental Services 78 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

phase) and on an ongoing basis.  The project proponent will disclose the ESIA assessment document, which is the result of a social and environmental assessment. It will focus on the social and environmental risks and adverse impacts and the proposed measures and actions to address impacts.  Affected communities will be provided with opportunities to express their views on project risks, impacts and mitigation measures and allow the project proponent to consider and respond to them.  The proponent will establish a grievance mechanism to receive and facilitate resolution of the affected communities’ concerns and grievances about the proponent’s environmental and social performance. It should address concerns promptly, using an understandable and transparent process that is culturally appropriate and readily accessible to all segments of the community at no cost and without retribution. The mechanism should not impede access to judicial or administrative remedies.

Stakeholder engagement must be underpinned by the principle of free, prior and informed consent, which states that individuals and communities should be informed, in appropriate accessible language, about projects that might take place on their land. It also “guarantees that they are given the opportunity to give, withhold or negotiate land use and related issues” (IFC, 2007). The principle of free, prior and informed consent is also subscribed to in IFC Performance Standard 1.

6.5 Public Participation to date

At the commencement of the project Zirco provided a list of all landowners of the proposed farms directly affected by the mining activities (Table 6.1) and adjacent landowners (Table 6.2). Members of CES conducted a site visit on the 22nd to the 26th of July 2013. During this time members of CES met which each available landowner (landowners not available are shown in red in Table 6.1 below) personally to inform I&APs of the proposed development and provide them with a background information document (Appendix 2). In addition to this, all landowners and adjacent landowners were notified of the proposed development via registered mail (see Appendix 3 for copies of the letters and proof of receipt). Figure 6.1 below shows the various properties directly affected by mining activities and adjacent to mining activities.

In addition to the above, letters of notification and background information documents were sent to landowners that may be affected by the pipeline. Since the servitude for the proposed pipeline has not yet been finalised all property owners within the overall area where notified of the proposed project (list provided in Table 6.3). Figure 6.2 below shows all properties from the proposed mine site to Khynp Punt.

A number of key stakeholders were identified at national, provincial and local level, information on these are available in Table 6.4 below. These stakeholders were notified of the proposed development via registered mail (see Appendix 3 for copies of the letters and proof of receipt). Members of CES met personally with Ms Deidre Williams from the Department of Mineral Resources and Ms Lucille Karsten from the Northern Cape Department of Environment and Nature Conservation in Springbok on the 25th of July 2013.

Table 6.1: Details of landowners and occupiers directly affected by mining activities (names in red were not met personally)

Coastal & Environmental Services 79 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Farm Porti Landow Cont Postal Name on ner act Address Num Num ber ber Klipda 633 Jacob 027 5 P.O. Box m No van Zyl 31 334, 633 1014 Garies, 8220 Roode 1/502 Marius 027 5 P.O. Box Heuwel van Zyl 31 8, 502 1010 Garies, 8220 Roode 5/502 Izak 027 P.O.Box Heuwel Engelbre 531 190, 502 ght 1027 Garies, 8220 Roode 6/502 Izak 027 P.O.Box Heuwel Engelbre 531 190, 502 ght 1027 Garies, 8220 Roode 9/502 Alwyn 083 P.O.Box Heuwel van Zyl 353 905, 502 4598 Vredendal, 8160 Leeuvle 642 Jan C. 027 5 P.O. Box i Engelbre 31 10, 642 cht 1030 Vanrhynsd orp, 8170 Soutkra 1/437 Johan 027 5 P.O. Box al Engelbre 81 338, 437 cht 1095 Garies, 8220 Klipheu 9/435 Jan C. 027 5 P.O. Box wel Engelbre 31 10, 435 cht 1030 Vanrhynsd orp, 8170 Klipheu 10/43 Jan C. 027 5 P.O. Box wel 5 Engelbre 31 10, 435 cht 1030 Vanrhynsd orp, 8170 Klipheu 11/43 Ian 082 P.O.Box wel 5 Coetzee 726 133, 435 9297 Lutzville, 8165 Sabies 2/505 Jan C. 027 5 P.O. Box 505 Engelbre 31 10, cht 1030 Vanrhynsd orp, 8170 Hawerl 1/503 Deon 021 P.O. Box and Engelbre 851 1163, 503 ght 2420 Somerset West, 7129 Hawerl 2/503 Izak 027 P.O. Box and Engelbre 531 190, 503 ght 1027 Garies, 8220 Hawerl 3/503 Miemie 027 5 P.O. Box and Englebre 31 190, 503 cht 1029 Garies, 8220

Coastal & Environmental Services 80 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Hawerl RE/5 Miemie 027 5 P.O. Box and 03 Englebre 31 190, 503 cht 1029 Garies, 8220

Table 6.2: Details of landowners and occupiers adjacent to proposed mining activities (names in red were not met personally) Farm Name Portion Contact Person Contact Postal Number Number Address Roode 4/502 Tronox Mineral 022 701 115 West Heuwel 502 Sands (Pty) Ltd 3911 Street, Sandton, 2196 Roode RE/502 Dirk van Zyl 027 531 P.O. Box 8, Heuwel 502 1016 Garies, 8220 Klipheuwel 3/435 Johan 027 581 P.O. Box 338, 435 Engelbrecht 1095 Garies, 8220 KWASS 501 RE/501 Namaqua 0276721948 P.O. Box 117, National Park Kamieskroon, Petrus 8241 Schreuder Rooiheuwel 634 Dirk van Zyl 027 531 P.O. Box 8, 634 1016 Garies, 8220 Klipheuwel RE/435 Gert and 027 581 P.O. Box 79, 435 Hestelle 1021 Garies, Engelbrecht 8220 Klipheuwel 7/435 Gert and 027 581 P.O. Box 79, 435 Hestelle 1021 Garies, Engelbrecht 8220 Klipheuwel 3/435 Johan 027 581 P.O. Box 338, 435 Engelbrecht 1095 Garies, 8220 Soutfontein 2/436 J.C.C de Villiers 021 581 P.O. Box 113, 436 1020 Garies, 8220 Soutfontein 3/436 J.C.C de Villiers 021 581 P.O. Box 113, 436 1020 Garies, 8220 Soutfontein 6/436 Gert and 027 581 P.O. Box 79, 436 Hestelle 1021 Garies, Engelbrecht 8220 Soutkraal 3/437 J.C.C de Villiers 021 581 P.O. Box 113, 437 1020 Garies, 8220 Soutkraal 4/437 J.C.C de Villiers 021 581 P.O. Box 113, 437 1020 Garies, 8220 Groenrivier's 2/504 W.D.Engelbrecht 027 531 P.O. Box 48, Vallei 1032 Garies, 504 8220 Groenrivier's 3/504 G.G Kotze 027 531 P.O. Box 1, Vallei 1026 Garies, 504 8220 Groenrivier's 5/504 G.G Kotze 027 531 P.O. Box 1, Vallei 1026 Garies, 504 8220

Coastal & Environmental Services 81 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Farm Name Portion Contact Person Contact Postal Number Number Address Groenrivier's 6/504 W.D.Engelbrecht 027 531 P.O. Box 48, Vallei 1032 Garies, 504 8220 Groenrivier's 7/504 W.D.Engelbrecht 027 531 P.O. Box 48, Vallei 1032 Garies, 504 8220 Sabies RE/505 W.D.Engelbrecht 027 531 P.O. Box 48, 505 1032 Garies, 8220 Sabies 1/505 Jan C. 027 531 P.O. Box 10, 505 Engelbrecht 1030 Vanrhynsdorp, 8170 Sabies 6/505 W.D.Engelbrecht 027 531 P.O. Box 48, 505 1032 Garies, 8220 Klipheuwel 3/435 Johan 027 581 P.O. Box 338, 435 Engelbrecht 1095 Garies, 8220

Table 6.3: Details of landowners and occupiers which may be affected by the construction of the pipeline

Coastal & Environmental Services 82 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Farm Name Portion Landowner Contact Person Contact Postal Address Number Number Klipkuil 547 2/547 Willem Petrus Willem Petrus 083 275 P.O. Box 85 Auret Auret 9791 Lamberts Bay 8130 Klipkuil 8/547 Groenriviersm A.A. Niewoudt 027 531 P.O. Box 37 Garies 547 ond Trust 1046 8220 Klipkuil 10/547 Groenriviersm A.A. Niewoudt 027 531 P.O. Box 37 Garies 547 ond Trust 1046 8220 Rooiheuwel 634 Dirk van Zyl Dirk van Zyl 027 531 P.O. Box 8, Garies 634 1016 8220 Roode Heuvel RE/502 Dirk van Zyl Dirk van Zyl 027 531 P.O. Box 8, 502 1016 Garies, 8220

Eiland Punt 1/549 Willem Petrus Willem Petrus 083 275 P.O. Box 85 Noord Auret Auret 9791 Lamberts Bay 8130 549 Eiland Punt 2/549 De Beers 053 839 P.O. Box 616 Noord Consolidated 4111 Kimberley, 8300 549 Mines (Pty) 053 839 Ltd 4210 Eiland Punt 3/549 Groenriviersm A.A. Niewoudt 027 531 P.O. Box 37 Garies Noord ond Trust 1046 8220 549 Eiland Punt 4/549 Groenriviersm A.A. Niewoudt 027 531 P.O. Box 37 Garies Noord ond Trust 1046 8220 549 Eiland Punt RE/549 De Beers Anton Meyer 0538394248 P.O. Box 616 Noord Consolidated anton.meyer@de 053 839 Kimberley 549 Mines (Pty) beersgroup.com 4210 8300 Ltd Strandfontein RE/559 Sedex Stuart Smith 214 466 040 P.O. Box 8399, Cape 559 Desalination ssmith@frontierra town, 8012 reearths.co.za Eiland Punt 1/550 Kambrolandsk [email protected] 082 773 P.O. Box 95 Zuid ap Koop Ltd et 2524 Orania 550 taljaard@needadr 8752

eam.com Eiland Punt 2/550 Willem Petrus Willem Petrus 083 275 P.O. Box 85 Zuid Auret Auret 9791 Lamberts Bay 8130 550 Eiland Punt 3/550 Groenriviersm A.A. Niewoudt 027 531 P.O. Box 37 Garies Zuid ond Trust 1046 8220 550 Eiland Punt RE/550 De Beers Aletta Dreyer 0538394248 P.O. Box 616 Zuid Consolidated aletta.dreyer@de 0278072801 Kimberley 8300 550 Mines (Pty) beersgroup.com Ltd William Macdonald william.macdonald @debeersgroup.c om

Coastal & Environmental Services 83 Kamiesberg Project, Namaqualand, South Africa

Final Scoping Report – January 2014

Figure 6.1: Map showing the proposed prospecting areas as well as properties adjacent to these

Coastal & Environmental Services 84 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Figure 6.2: Map showing all properties south of the mining area that may be affected by the pipeline

Coastal & Environmental Services 85 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Table 6.4: Key Stakeholders identified during the Scoping Phase Stakeholder Contact Person Contact Number Postal Address Email Address National

DEA: Oceans and Chief Directorate - Integrated 021 819 2432 Private Bag X447, Pretoria, [email protected] Coasts Coastal Management: 0001 Dr Razeena Omar

South African National SANRAL Corporate Office 124 266 000 PO Box 415, Pretoria, 0001 [email protected] Roads Agency (SANRAL)

Department of Office of the Minister : 012 319 7150 (PTA) Private Bag x9087, Cape [email protected] Agriculture, Forestry Mr Andrew Bartlett 021 467 4502 (CPT) Town, 8000 and Fisheries

Department Of Minister For Agriculture And 538 314 049 Private Bag X5018, [email protected] Agriculture Land Affairs: Kimberley 8300 Ms Tina Joemat-Petterson

Department Of Head Of The Department: 053 838 9100. Agriculture Mr Viljoen Mothibi [email protected]

Eskom Transmission: Itumeleng Moeng 118 004 114 Megawatt Park – D1 Y39, [email protected] Grid connectivity and PO Box 1091, capacity Johannesburg, 2000

Transnet National Transnet National Port Authority 113 519 001 P O Box 32696, [email protected] Ports Authority (TNPA) Head Office Braamfontein, 2017

Department Of Water Media Liaison Officer: Tel: 012 336 8733 / 90 Private Bag X313, Affairs (DWA) Pretoria,0001 Mr Mandla Mathebula Cell: 083 235 8675 [email protected]

South African Heritage Head Office 214 624 502 PO Box 4637, Cape Town, [email protected] Resources Agency 8000 (SAHRA) Department of Mineral Director General's Office: 124 443 308 Private Bag X59, Arcadia, Resources (DMR) 0007 Mr Khayalethu Matrose [email protected]

Coastal & Environmental Services 86 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Stakeholder Contact Person Contact Number Postal Address Email Address

Provincial – Western Cape

SANRAL (Western Colene Runkel 219 574 600 Private Bag X19, Bellville, 7535 [email protected] Region)

SANRAL (Western Rene De Kock 27 21 957 4607 Parc du Cap Building 5 cnr Mispel Street & [mailto:[email protected]] Region) Willie van Schoor Avenue

Department: Roads Head of Department: 214 832 826 Private Bag X9185, Cape Town, 8001 [email protected] and Public Works Johan Fourie (Western Cape)

Transnet National Port of Saldanha 022 701 4302/4 Private Bag X1, Saldanha, 7395 [email protected] Ports Authority (TNPA) Department of Media Liaison Officer: Tel: 021 483 Private Bag X9179, Cape Town, 8000 Agriculture – Western Agriculture 4930

Cape Mr Wouter Krie Cell: 079 694 [email protected] 3085 Department Of Water Chief Director: Western Cape Tel: 021 941 Private Bag X16, Sanlamhof, 7532 Affairs (DWA) 6000

Mr R Khan Cell: 082 809 [email protected] 2218

Heritage Western Andrew Hall 214 835 959 3rd Floor, Protea Assurance Bldg, [email protected] Cape Greenmarket Square, Cape Town, 8000

Department of Mineral Regional Manager: 214 271 000 Private Bag X 9, Roggebaai, 8012 [email protected] Resources (DMR) Sivuyele Mpakane [email protected] Provincial – Northern Cape

Department: Roads Director: Roads 053 861 9600 P.O. Box 3132, Kimberley, 8301 [email protected] and Public Works (Northern Cape) SANRAL (Western 219 574 600 Private Bag X19, Bellville, 7535 Region)

Department of Media Liaison Officer: Tel: 053 838 Private Bag X5018, Kimberley, 8300 [email protected] Agriculture, Land Agriculture, Land Reform and 9159 Reform and Rural Rural Development

Development – Mr Ali Diteme Cell: 083 4529 [email protected] Northern Cape 851

Department Of Water Chief Director: Northern Cape Tel: 053 830 Private Bag X6101, Kimberley, 8300 [email protected] Affairs 8803

Coastal & Environmental Services 87 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Stakeholder Contact Person Contact Number Postal Address Email Address

Mr A Abrahams Cell: 082 883 [email protected] 6741 Department of Mineral Regional Manager: 538 071 700 Private Bag X 6093, Kimberley , 8300 Resources (DMR) Ntsundeni Ravhugoni (Acting) [email protected] Department of Mineral Deidre Williams 0277128160 Private Bag X14, Springbok, 8240 [email protected] Resources (DMR) WESSA Northern Regional Chairperson: 053 839 2717 PO Box 316, Kimberley, 8300 Cape Suzanne Erasmus [email protected]

ESKOM ( Northern Andre Malgas 538 072 660 Eskom Building, 3rd Floor, 66 Jones [email protected] Cape Regional Office) Street, Kimberly, 8300

PHRA Northern Cape Andrew Timothy 079 036 9294 PO Box 4637, Cape town, 6000 [email protected] DNEC Ms A.T Makaudi 0538077430 90 Long Street, Sasko Building, Kimberly DNEC springbok Lucille Karsten 0277188800 corner of voortrekker and magasyn street, springbok [email protected] Local

Namakwa District Municipal Manager: 277 128 000 Private Bag X20, Van Riebeeckstreet [email protected] Municipality Ms. Madeleinne Brandt Springbok, 8240

Kamiesburg Local Municipal Manager: 276 528 011 Private Bag X200, Garies, 8220 [email protected] Municipality Municipal Manager

Bird Life – Northern Gariep Bird Club: Chairman: 079 494 4525 16 Milner Street, Kimberley, 8301 [email protected] Cape Spangenberg 153 833 1948

BirdLife South Africa Terrestrial bird conservation: 117 891 122 P O Box 515, Randburg, 2125 [email protected] Headquarters Dr Hanneline Smit-Robinson Ward Councillor Councillor 2: 082 266 5871 Private Bag X200, Garies, 8220

Patro Willems [email protected]

Namaqua National 276 721 948 P O Box 117, Kamieskroon, 8241 [email protected] Park

Coastal & Environmental Services 88 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Table 6.5: Other interested and affected parties which have registered

Organisation Name Contact Address Email address number Individual Lambertus 0818193404 Po Box 334 Garies Sebastian van zyl Namaqua Bernard van 0276721948 Posbus 117, [email protected]

National Park Lente Kamieskroon g Petrus [email protected]

Schreuder g University of Dr. Cornelia 7701 Rondebosch Cornelia Klak Tel: 021 Cape Town - Klak [email protected] 6503724 Bolus Herbarium

Hoof D.J. du (082-495 Kambrolandskap [email protected] Uitvoerende Plessis 7378) Posbus 11206 Beampte Universitas 9321 Weskus Ontwikkelings Frontier Rare Derick R de 27 11 234 Sound Mining Derick de Wit Earths SA (Pty) Wit 6216 House. 2A Fifth [email protected] Ltd (Vice Avenue, Rivonia, a President Project 2128 Development) Individual Nellie Spangenberg Spangenberg [email protected] Individual Karen van 27 De Villiers Drive der Sandt Durbanville 7550

WESSA Suzanne [email protected] Chairman Erasmus Northern Cape region.

Chairman of the Judd Kirkel [email protected] Succulent Society : Gauteng area Griqua Gnus Beryl Wilson [email protected] (editor)

Scoping was initiated using the stakeholders listed in Tables 6.1-6.4 above as a starting point. Public participation during the Draft Scoping Report review period focused on providing information on the new project and gathering stakeholders’ views on the proposed terms of reference for the EIA specialist studies, to identify additional or new I&APs, and to gather perceptions and comments on the proposed terms of reference for the specialist studies.

An advertisement was placed in Die Burger on Monday 25 November 2013 (Figure 6.3) announcing the availability of the draft scoping report for public review as well as details regarding the public meeting on 02 December 2013 in Garies.

Notification emails, letters as well as smses were sent to registered I&APs as well as key stakeholders on the 14th of November 2013 (Appendix 4). These letters informed I&APs that the draft scoping report was available for review, that it could be found on the CES website or at Sophia’s Guesthouse and that a public meeting would be held on 02 December 2013 at the guesthouse in Garies. The notification letters also stipulated that the review period for comment was from 14 November 2013 until 17 January 2014.

As previously mentioned, a public meeting was held at Sophia’s Guesthouse in Garies on Monday

Coastal & Environmental Services 89 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

02 December 2013 between 16:00 and 20:00 (see Appendix 5 for attendance register). The landowners directly affected by the project were invited to a private meeting on Tuesday 03 December 2013 at 19:00 (Appendix 5). The comments received at these meetings have been included in comments and response table (Table 6.7). No additional comments were received via emails, SMS’s or as written correspondence.

Consultations were held with a diversity of I&APs at national, provincial, district and local level. All efforts were made to follow a broad and inclusive consultation process to ensure that any new I&APs are identified and included in the EIA process.

In addition, a grievance mechanism was developed and presented to the local communities during the scoping disclosure. The grievance mechanism will enable local communities to submit grievances about the mining and EIA process and receive responses in a formalised manner.

Comments received thus far have been incorporated into an issues and response trail tabulated below.

6.6 Future engagement activities

An opportunity will be provided for all the reports produced during the EIA to be reviewed by I&APs. Comments from theses I&APs will be elicited, discussed and documented. The overall objectives of disclosing the EIAR to I&APs is to provide information to them about the project and the results of the impact assessment, consult and report back, and where possible, encourage opportunities for collaboration between I&APs and the project proponent.

This should help ensure that all issues raised by I&APs have been adequately assessed, and provides an opportunity to share the findings, mitigation measures, management actions, management and monitoring programmes and recommendations of the specialists.

Figure 6.3: Copy of advertisement placed in Die Burger

Coastal & Environmental Services 90 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Table 6.6: Comments and response table received at disclosure of draft scoping report meetings

Public meeting at Sophia’s Guesthouse 02 December 2013 4pm – 8pm

Comment Response Where will the desalination plant go? The desalination plant will be located at the mine site. What is the cost of the desalination plant? The detailed design for the desalination plant has not yet been undertaken and thus costing is not yet available. However, it is important to note that the costing of the desalination plant does not fall within the ambit of the EIA process. Have farmers asked for freshwater? Not at this stage. What is the feedback from the parks? The proposed boundary for the Namaqualand Marine Protected Area extends south to 30°55’00.000 S and 17°36’27.106 E. This has been extensively work-shopped and planned with DMR and other stakeholders. The land portion of the park will thus also expand down to this point (the Admiralty land- state land). SANPARKS is therefore concerned that the seawater intake will be situated within this area. There is also a possibility that the park will be extended south to include the whole Admiralty Zone/ State land up to Strandfontein. How far is Knhyp Punt from Groenriviermond? Approximately 20 km Is Zirco Resources an Australian company? The applicant is Zirco Roode Heuwel Pty Ltd a RSA company How long has Zirco been busy with this process? Exploration began in 2011 How deep will you mine? 15-20 meters Is there sufficient quantity and quality of material Yes, no fatal flaws have been identified What is the lifetime of the mine expected to be? 20 years How many work opportunities will there be? Approximately 300 during the operational phase of the project. Where will the workers come from? As far as reasonably possible, Zirco will employ the local population from a number of labour- sending communities, including Garies, Kamieskroon, Karkams, Spoegrivier, Lepelsfontein, Kheis and Tweerivier. What roads will be used? The existing access road currently utilised by the farmers in the area and the National Road 7 (N7). This is important to the area in terms of work opportunities Noted and agreed. What is the response from farmers to mine their farms? To date we have had limited responses from the farmers in the region, however a focus group meeting is scheduled for the 3rd of December 2013. All comments from this meeting will be incorporated into the comments and response trail which will be made available in the Final Scoping Report. The construction camp to upgrade the road (current) is located A Social Impact Assessment will be undertaken for the proposed development that will assess the in Garies and there is prostitution there. What will you do to impacts of increased social pathologies such as prostitution within the area as a result of the project prevent a similar situation? and provide mitigation measures in accordance with these. How many farms / farmers are involved? 15 Farm Portions and 9 landowners What is the plan with the farms after 20 years of mining? The mining area will be rehabilitated and returned to its current land use

Coastal & Environmental Services 91 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Comment Response How far is Garies to the mine? ±60km Will there be onsite accommodation? It is anticipated that labour will be sourced from the labour sending communities and thus no on- site accommodation will be required. Are you definitively going to use seawater? Yes, seawater will be used for processing in the PCP as there is not sufficient groundwater available for this purpose. However, for freshwater requirements (washing of HMC and potable water) both the use of groundwater and the use of seawater will be assessed in the EIR. How many skilled vs unskilled positions will there be? The following is anticipated: Professionally qualified and experienced specialists and mid management (11) Skilled technical and academically qualified workers, junior management, supervisors, foremen and superintendents (86) Semi-skilled and discretionary decision making (176) Unskilled and defined decision making (42) It is important to get a bank here as there is only one ATM but it Noted doesn’t get ‘replenished’ How many houses will be built for workers of the mine? Zirco will help employees get financing to buy/build houses in labour sending areas, not on the mine. Zirco will not provide housing. Water is very important in Garies. There will be an increased CES is currently in the process of compiling a social and labour plan for the proposed development. strain on water resources should mine workers be housed in The KLM has identified the need for assistance to provide rainwater tanks to households (especially Garies. in wards 1 and 2). Zirco therefore proposes to invest in a project which would entail the erection and installation of rainwater tanks in consultation with KLM. In addition to this Zirco will invest funds to assist the municipality with the erection of a desalination plant to provide Garies with potable water. If it rains the electricity goes out. It has been on the books to Noted upgrade the electricity line from Springbok to Garies for years now. The sewerage treatment works does not have sufficient Noted capacity. The sewerage runs in the river.

Coastal & Environmental Services 92 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Landowners meeting at Groenrivier akkommodasie 03 December 2013 18:00

Comment Response Will the MSP occur here at the mine site? Yes What type of road will be used? Tar road? Two options are currently being assessed. The first is to tar the existing access road and the second is to keep it as a well maintained gravel road. These options will be fully assessed in the EIR. If gravel is used for the road what about dust? Various mitigation measures for the control of dust will be suggested in the EIR, one of which will be to water down areas during periods of increased dust levels. Where will the desalination plant go? The desalination plant will be located at the mine site. Do you have to be BBEEE compliant? Yes Will you have to hire previously disadvantaged people from The project is obligated to hire previously disadvantaged people in accordance with the Mineral and outside Garies area? Petroleum Resources Development Act (2002) and the Broad-Based Socio-Economic Empowerment Charter of the South African Mining and Minerals Industry (2010). Although people from outside the area will be recruited to perform higher skilled positions, the proponent is committed to ensure that most of the labour is sourced from Garies and its surrounding areas. How will people in the surrounding area benefit? Apart from employment, community members will benefit from skills development opportunities, higher educational training opportunities (both to the workers and community members), community learnerships and bursaries. In addition, the client will also be investing in several Local Economic Development Programmes in Garies. How long until the mine is in operation? It is anticipated that production will commence in 2017 I have heard that houses will be built in Garies, is that for this The client is obligated to budget for its workforce’s housing and living conditions in accordance with project? the Mineral and Petroleum Resources Development Act (2002) and the Broad-Based Socio- Economic Empowerment Charter for the South African Mining and Minerals Industry (2010). Several housing options for employees only are currently being considered in consultation with the local municipality. Will the workers be bussed to work every day or will they use There will be a bus service from the mine to Garies. Should large amount of workers be sourced their own transport? from other labour sending communities the bus route could potentially be extended. Are you using an Eskom line for electricity and are you paying Yes, Zirco pays for the construction of the line. If some-one else wants to ‘tap’ into the line they have for it? to pay a proportional fee. Will white people also be employed? Yes I understand the importance of protecting the environment but I Noted. feel that giving people work who needs it is more important.

Coastal & Environmental Services 93 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

7. KEY ISSUES

According to regulation 28 (1) of the EIA regulations (2010), A scoping report must include – 1(g) a description of the environmental issues and potential impacts, including cumulative impacts that have been identified

In line with the above-mentioned legislative requirement, this chapter provides a summary of the issues and concerns identified during the Scoping Phase prior to the preparation of this Draft Scoping Report.

7.1 Planning and Design Phase

Activities associated with the design and pre construction phase pertains mostly to exploration. As the project has an exploration license impacts associated with exploration and the mitigation of these impacts were included in the Exploration EMP compiled to obtain this license and will therefore not be repeated in this section. Other activities associated with the design and pre construction phase will not have impacts on the biophysical environment as this phase consists of planning and design of the proposed development, and is done at a desktop level. In some cases site visits need to take place but the impact of these visits is negligible, if any, e.g. photographs, borehole pump testing, botanical and other field surveys, etc.

7.2 Impacts that may result from the Construction phase

Cause and comment: The construction of the associated infrastructure such as the mining camp will require excavations in order to lay adequate foundations. Furthermore, minor excavations will be required for the construction of the pipeline, upgrading of the existing gravel access road and upgrading of the junction with the N7 (if required).

Cause and comment: During the construction phase large construction vehicles will be utilizing the existing road network. This may result in the impeding of traffic flow and damage to the existing roads such as the N7 and the main access road to the proposed development site.

Cause and comment: Health and safety aspects will mostly pertain to activities defined under the Occupational Health and Safety Act (Act No. 85 of 1993).

Cause and comment: During the construction phase there may be impacts on natural vegetation including destruction of or damage to, indigenous and riparian vegetation, the removal of intact communities, species of special concern and/or trees protected in terms of the Forest Act, and the introduction of alien species.

Coastal & Environmental Services 94 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Cause and comment: The construction of the associated infrastructure such as the pipeline, desalination plant, construction and operation accommodation, establishment of the mine pit and the tailings area etc. will require the clearing of vegetation which will result in exposed soil surfaces. This will increase the chances of soil erosion.

Cause and comment: Impacts on air quality during the construction phase will primarily result from increased dust levels associated with the required excavation, vegetation clearing, grading and other construction activities.

Cause and comment It is anticipated that there will be an increase in noise levels during the construction phase of the development which will be associated with the operation of construction vehicles and equipment.

Cause and comment Various substances may result in the pollution of surface and groundwater sources. Construction activities may lead to sediment being deposited into drainage lines (specifically the crossing of the Groen River), pollution from litter and general construction wastes may occur due to improper site management. Washing down of vehicles and equipment may result in the pollution of drainage areas and the Groen River, and pollution may occur from poor vehicle maintenance and improper storage of hazardous materials such as fuel, etc.

Cause and comment It is anticipated that the proposed development will produce solid waste in the form of building rubble such as excavated soil and vegetation and excess concrete, bricks, etc. and general waste such as litter during the construction phase.

Cause and comment It could be possible that sites of archaeological, palaeontological and/or cultural significance are present on or near the proposed development site.

Cause and comment Impacts associated with fauna may primarily be due to habitat disturbance and/or loss and the restriction of migration corridors.

Cause and comment Impacts on soil may primarily be due to compaction, erosion and contamination.

Coastal & Environmental Services 95 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Cause and comment The construction of the intake and a section of the pipeline, as well as the construction of the single point mooring and associated infrastructure may adversely impact on the marine and nearshore environment.

7.3 Impacts that may result from the Operational Phase

Cause and comment: The proposed development site is currently zoned as agriculture. The proposed development will therefore result in a loss of agricultural potential.

Cause and comment: Relatively large buildings and structures at the mine site will stand in high contrast to the surrounding natural landscape. There are no structures similar to these in the existing landscape. Due to their height they are likely to extend above the surrounding vegetation and their straight lines and smooth surfaces will be highly noticeable in the natural setting. Large vehicles and increased human activity will also have an impact on the sense of remoteness of the region. Dust from mining activity could potentially increase the extent of the visual impact.

Cause and comment: The proposed development will create various socio-economic impacts including but not limited to the following:

 An increase in employment and related economic benefits;  The in-migration of large numbers of economic migrants and job seekers;  Increased economic displacement resulting from the loss of land;  The expansion of infrastructure and service provision;  An increase in social pathologies; and  Loss of productive land and natural resources due to mining.

Cause and comment: The operational phase could generate noise during different activities such as:

 Bush clearing by means of a bulldozer;  Mining of the mineral bearing sand by front end loader;  Pumping of slurry to the PCP where the Heavy Mineral Concentrate (HMC) is extracted using spirals;  Loading of the HMC from a stockpile by front end loader into a feed hopper; and  Transporting the final products to the export port by road.

Cause and comment: Impacts associated with fauna may primarily be due to habitat disturbance and/or loss and the restriction of migration corridors due to mining.

Coastal & Environmental Services 96 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Cause and comment: During mining there will be impacts on natural vegetation including destruction of or damage to indigenous and riparian vegetation, the removal of intact communities, species of special concern and/or trees protected in terms of the Forest Act and the introduction of alien species.

Cause and comment: Mining activities will result in the excavation of large areas which will change the natural surface topography. Although the area is largely flat and mainly used for grazing, the growth and agricultural potential will be compromised after mining.

Cause and comment: Stripping, handling and placement of soil associated with pre construction land clearing, construction and the mining process could lead to significant loss of topsoil. The main cause in combination with a lack of a detailed topsoil stripping plan is poor stripping and lack of recovery of as much usable soil material as possible.

Cause and comment: Leakages and spillages from storage and infrastructure facilities could have a negative effect on the pH and salinity of the soil.

Cause and comment: Various substances, including hydrocarbons, may result in the pollution of surface and groundwater sources. Mining activities may lead to sediment being deposited into drainage lines (specifically the Groen River), pollution from litter and general household wastes may occur due to improper site management. Washing down of vehicles and equipment may result in the pollution of drainage areas and the Groen River, pollution may occur from poor vehicle maintenance and improper storage of hazardous materials such as fuel and lubricants. Sea water from the tailings backfill and TSF may also adversely affect surface and groundwater resources within the area if not properly managed.

In addition, the alternative to utilise groundwater resources for processing purposes may adversely impact the aquifer(s) and groundwater users if abstraction is not controlled within the long-term sustainable aquifer yield. It will also be necessary to understand the interactions between ground and surface water resources to develop an integrated approach to water abstraction and use.

Cause and comment: Abstraction of seawater for processing purposes may result in adverse impacts on the marine environment.

In addition, increased shipping traffic making use of the proposed single point mooring may have adverse impacts on the marine environment, including pollution from litter, hydrocarbons and bilge water, and propeller wash effects in the relatively shallow water.

Coastal & Environmental Services 97 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Cause and comment: Fugitive PM2.5, PM10 and TSP emissions during the operation phase of the proposed project will be generated by the following activities:

 Topsoil bulldozing;  Ore excavation and handling;  Ore and HMC screening;  HMC, ilmenite and zircon/rutile handling;  Wind erosion of stockpiles;  Material transport by trucks and front end loaders on unpaved surfaces;  Transportation of day and shift workers by bus on unpaved surfaces;  Transportation of diesel by diesel tanker on unpaved surfaces; and  Transportation of containers on unpaved surfaces.

In addition to this the dryer stacks and baghouse stack at the MSP are expected to result in PM10, PM2.5, TSP, NOx, SO2, CO and SO3 emissions and the use of diesel earth moving equipment will result in PM2.5, PM10, TSP, NOx, HC and SO2 emissions.

Cause and comment: The radionuclide concentrations in the various solid waste streams will be significantly different from the original concentrations in the ore body. For example the radionuclide concentrations in the PCP coarse sand tails will be significantly lower than in the ore body as the majority of the uranium and thorium will report to the HMC sent to the MSP. At the MSP, physical separation of the various minerals in the HMC results in a variety of mineral streams. The radionuclide concentrations in the various solid waste streams will be highly variable and in some cases will be significantly enhanced compared to the ore body.

The handling and transport of the various product and waste streams that contain enhanced concentrations of the radionuclides of the uranium and thorium decay chains could result in workers and members of the public in close proximity to these materials being exposed to radiation.

7.4 Impacts that may result from the Decommissioning Phase

7.4.1 Issue 1: Impacts on Topography and Soils

Cause and comment: Rehabilitation and therefore backfilling and sloping will be undertaken progressively and therefore minimal disturbance will occur during the decommissioning of the mine. The impact on topography and soils is therefore negligible.

7.4.2 Issue 2: Impacts on surface and groundwater resources

Cause and comment

Quantity During the decommissioning phase relatively small volumes of water may be required for on-going rehabilitation and human consumption. However, compared to volumes required for mining purposes, this will be negligible.

Quality

Coastal & Environmental Services 98 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Various substances may result in the pollution of surface and groundwater sources. Decommissioning activities may lead to sediment being deposited into riverine areas, pollution from litter and general decommissioning wastes due to improper site management.

7.4.3 Issue 3: Loss of social services

Cause and comment

During the decommissioning of the mine various social projects initiated during the various phases of the proposed project may be lost, or placed at risk.

7.4.4 Issue 4: Retrenchment

Cause and comment

During the decommissioning phase of the proposed project the majority of staff previously employed will be retrenched as all mining activities would have ceased.

7.4.5 Issue 5: Pollution of land and water

Cause and comment

Inappropriate storage of wastes, particularly those exhibiting harmful properties (hazardous wastes), can result in the contamination of land and water resources. As a result of rainfall events, leachate may be formed as water percolates through the solid waste, and this leachate may contain nutrients and a variety of toxic compounds, including metals. As such, it could result in the contamination of water and land.

7.4.6 Issue 6: Impacts on air quality

Cause and comment

The main decommissioning activities likely to result in noticeable impacts of PM10 and TSP include vehicle entrainment from unpaved roads and wind erosion from rehabilitating surfaces. Dust fall impacts are generally confined to the near-field (<1 km to 3 km) of sources. This is due to the fact that larger particles, which contribute most to dust fall rates given their mass, are likely to settle out in close proximity to the source (assuming a ground-based source). The area influenced by the operations off course depends on the dispersion potential of the site, the extent of the decommissioning operations and the mitigation measures applied.

Vehicle-entrainment of dust from decommissioning sites represents a relatively large source of fugitive dust emissions during decommissioning.

7.4.7 Issue 7: Impacts related to Noise

Cause and comment

The decommissioning phase could generate noise during different activities such as:

 Site remediation and earthworks;  Building decommissioning using mobile equipment, cranes, concrete mixing and pile driving equipment (If required);  Vehicle use and movement;  Mobile generators etc.

Coastal & Environmental Services 99 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

7.4.8 Issue 8: Visual Impacts

Cause and comment

There are various aspects of the decommissioning phase that will potentially affect sensitive visual receptors.

 Increase in traffic, both small vehicles for workers and large decommissioning-related vehicles such as excavators and graders.  Worker presence and activity.  Dust emissions from decommissioning activity.  Decommissioning work against the skyline.

Coastal & Environmental Services 100 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

8. ALTERNATIVES

According to regulation 28 (1) and (3) of the EIA regulations (2010), A scoping report must include – (j) a description of identified potential alternatives to the proposed activity, including advantages and disadvantages that the proposed activity or alternatives may have on the environment and the community that may be affected by the activity (3) The EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in subregulation (1)( c), exist.

One of the objectives of an EIA is to investigate alternatives to the proposed project. There are two types of alternatives - Fundamental Alternatives and Incremental Alternatives.

8.1 Fundamental Alternatives

Fundamental alternatives are developments that are totally different from the proposed project and usually involve a different type of development on the proposed site, or a different location for the proposed development. Since the core business of the project proponent is heavy mineral mining, the fundamental alternative of a development other than the proposed mine and associated infrastructure is therefore technically not feasible in this instance, as there is no proponent for any alternative land use. For this reason no fundamental alternative to mining has been considered in this EIA, aside from the status quo. However, alternative locations for infrastructural components of the project that are not locality bound are considered in section 7.2, except for the location of the mine path. This is because the mine path is locality bound, as its location is entirely dependent on the resource being mined.

8.2 Incremental Alternatives

Incremental alternatives are modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered, including:

 The design or layout of the activity (see section 8.2.1 below);  The technology to be used in the activity(see section 8.2.2 below);  The operational aspects of the activity.

8.2.1 Layout Alternatives

The majority of the proposed development site is currently utilized for farming purposes. In the EIA phase, various layouts (siting of the pipeline and intake, construction and operation accommodation, sewerage treatment facility, air strip, etc.) will be assessed to determine which will have the least impact on fauna, flora and ecological processes. A number of specialists (ecological, heritage, air quality etc.) will be appointed to assess the status of the fauna and flora and to determine the conservation status of the proposed development, as well as assess a range of related impacts, as described in Chapter 9. The following criteria will be considered in determining the final layout: (1) recommendations from the various specialists (2) guidelines from relevant bioregional plans (3) comments from I&APs and other stakeholders (4) site visits and (5) scientific publications.

8.2.2 Technology Alternatives

Various technology alternatives are currently being considered and will be presented and assessed in the EIA. These include the following:

Coastal & Environmental Services 101 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Open Water vs Gully Intake

Two types of sea water intake works have been proposed as a source of water for the mine, these include:

 Open water intake in Khnyp Bay or elsewhere as a stand-alone installation;  Gully Intakes.

Open Water Intake in Khnyp Bay or elsewhere as a stand-alone installation;

An open water intake would include the following components:

 A beach crossing: Stretching from the head works landward of the primary dune to approximately the low water line. The construction of this section would consist of an open dry excavation which would be protected by a cofferdam.  A surf zone crossing: From the low water line to the limit of the breaker zone. There are two methods of construction for this section. The first consists of an open wet excavation between rock embankments in protected waters, while the second consists of a protected excavation inside a rock cofferdam with the seaward end closed off to exclude wave action inside the cofferdam.  An offshore zone pipeline: From the breakwater zone to the intake structure. This section could be constructed without a cofferdam utilising times of calm sea conditions.  An intake structure.

The above components are shown in the layout diagram in Figure 8.1.

Figure 8.1: Proposed intake works at Khnyp Bay (Source: Bergstan Africa)

Coastal & Environmental Services 102 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Gully Intakes

Figure 8.2: Alternative gullies locations for seawater intake (Source: Bergstan Africa)

Transportation of Product

Three options exist for the transport of products from the mining operation to the markets:

1. A combination of rail and road haulage. 2. Road transport only. 3. Marine Transport and Port Facilities.

Rail and Road Haulage

The rail and road option will involve transporting product by road from the mine site to the rail siding at Bitterfontein, approximately 85 km to the south east of the mine site. From there product will be loaded into a silo loading facility, purpose built at the Bitterfontein siding. This will be used to load rail wagons and the product will be railed over a distance of 540 km to Saldanha Port for export to overseas markets. At Saldanha a storage facility to hold 2-3 months of production will be constructed together with loading infrastructure for shore to ship loading. The construction of these bulk handling facilities presents challenges as the general goods terminal has no gantry or crane facilities.

Coastal & Environmental Services 103 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Due to the extreme costs involved in this option it has been deemed unfeasible and therefore will not be assessed further in the EIA.

Road Transport Only

The second option is to transport product by road (N7) all the way from the mine site to Saldanha Port, using 37 tonne pay load horse plus 2 trailers. This will result in relatively large volumes of road traffic along the N7, estimated at 20 round trips per day.

In the last option, the heavy minerals will be transported to the coast by truck or pumped there as a slurry. They wll then be pumped as a slurry directly to the ships hold, using a subsea pipeline and Single Point Mooring (SPM) buoy. Three pipes will be required for the subsea section of the piping network although only two will be used simultaneously. The third pipe will function as a back-up route in the case of a failure occurring. The return water pipe is a continuous pipeline from the ship to the mine. The pump station on the ship will be used to pump the water onshore and a booster station onshore will provide the required energy to pump the water the remaining distance to the mine.

Water Use

There are, however, currently two options for provision of freshwater for the washing of HMC prior to entering the MSP:

8.3 No Development Alternative

The no development option assumes the site remains in its current state, i.e. agricultural land. The no-go alternative will be used as a baseline throughout the assessment process against which potential impacts will be compared in an objective manner and will be fully assessed in the EIA.

Coastal & Environmental Services 104 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

9. PLAN OF STUDY FOR THE EIA PHASE

According to regulation 28 (1) of the EIA regulations (2010), A scoping report must include – (n) a plan of study for environmental impact assessment which sets out the proposed approach to the environmental impact assessment of the application, which must include – (i) a description of the tasks that will be undertaken as part of the environmental impact assessment process, including any specialist reports or specialised processes, and the manner in which such tasks will be undertaken; (ii) an indication of the stages at which the competent authority will be consulted; (iii) a description of the proposed method of assessing the environmental issues and alternatives, including the option of not proceeding with the activity; and (iv) particulars of the public participation process that will be conducted during the environmental impact assessment process; (o) any specific information required by the competent authority; and (p) any other matters required in terms of sections 24(4}(a) and (b) of the Act.

In line with the above-mentioned legislative requirement, this Chapter sets out the Plan of Study (PoS) for the EIA phase of the assessment. Consultation with DENC will be on-going throughout this EIA. However, it is anticipated that DENC will provide relevant comment with respect to the adequacy of this Plan of Study for the EIA, as it informs the content of the EIAR and sufficiency thereof.

9.1 Scope and Intent of the EIA Phase

This phase includes the following steps:

1. Specialist Studies which include the specialist assessments identified in the Scoping Report and any additional studies required by the authorities. This requires the appointment of specialists to gather baseline information in their fields of expertise, to assess the impacts and make recommendations to mitigate negative impacts and optimise benefits. The resulting information is synthesised into the Environmental Impact Assessment Report (EIAR). 2. Environmental Impact Assessment Report. The main purpose of this report is to gather and evaluate environmental information, so as to provide sufficient supporting arguments to evaluate overall impacts, consider mitigation measures and alternative options, and make a valued judgement in choosing the best development alternative. The EIAR is made available for public and authority review. The availability of the report is advertised in the local newspaper and is situated at easily accessible locations. 3. Issue Response Trail which compiles comments, issues and concerns raised by I&APs and the authorities and the relevant responses to these comments. 4. Environmental Management Programme informs the client and the technical team of the guidelines which will need to be followed during the various phases of the project to ensure that there are no lasting or cumulative negative impacts of the construction process on the environment.  The standards and guidelines that must be achieved in terms of environmental legislation and IFC requirements.  Mitigation measures and environmental and social specifications which must be implemented for all phases of the project in order to minimise the extent of environmental and social impacts, to manage environmental and social impacts and where possible to improve the condition of both the biophysical and social environment.  Provide guidance through method statements that are required to be implemented to achieve the environmental and social specifications.  Define corrective action that must be taken in the event of non-compliance with the specifications of the EMPr.  Prevent long-term or permanent environmental degradation.

Coastal & Environmental Services 105 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

5. Public Participation Process. As for the Scoping Phase, opportunities are provided for interested and affected parties to voice concerns and issues regarding the project. At this stage the project details may have changed in response to the preliminary findings of the Scoping Report. I&APs and key stakeholders are also given the opportunity to review the Environmental Impact Assessment Report and the Specialists Reports before they are submitted to the authorities. These comments are then included in the Final EIAR, and modifications and changes to this report and the specialist reports are made in response to these comments, if required. 6. Environmental Authorization and Appeals Process. Upon thorough examination of the various reports, the authority will either issue an environmental authorization, which either authorises the project or rejects it, or they may require further details to clarify certain issues. Should authorisation be granted, it usually carries Conditions of Approval. The proponent is obliged to adhere to these conditions. Once the authorization has been issued, it is publicised and the public are given 20 calendar days from the issuing of the authorization to lodge an appeal with the authorities. An appeal must be submitted within 30 days after the lapsing of the 20 day notice of intention to appeal

9.2 The Public Participation Process

Upon review of the comments received from DENC, the Public Participation Programme (PPP) will likely include the following:

 Notice of the EIAR and Specialists Report availability will be placed in the Die Burger newspaper.  Registered I&APs will be informed in writing – either by email or post.  I&APs will be given 40 calendar days to review and comment.

After the public review period, all relevant comments and questions received from the public will be considered and responded to in an Issues and Response Trail, which will be included in the Final EIAR. These final documents, which may require editing, will then be formally submitted to the authorities for final review and decision-making.

The competent authority’s decision will be advertised in the newspaper mentioned above and registered I&APs will be informed within seven days of receipt of the Decision. Once the public have been notified of the Environmental Authorisation they will also be notified of the appeal provisions and process related thereto.

9.3 Environmental Impact Assessment Report (EIAR)

The following is the proposed Table of Contents for the Environmental Impact Assessment Report (EIAR):

CHAPTER 1: INTRODUCTION This Chapter will provide background information on the proposed project and the overall objectives of the EIAR.

CHAPTER 2: CONTEXT AND JUSTIFICATION FOR THE PROJECT This Chapter will include details and experience of the proponent, the proponent’s environmental and sustainable development policies, the details and expertise of the Environmental Assessment Practitioner (EAP) who compiled this report, an overview of the project and its location and a detailed motivation and justification (need and desirability) for the project.

CHAPTER 3: LEGISLATED REQUIREMENTS This Chapter will outline the requirements of prevailing South African legislation as well as relevant international principles, performance standards and guidelines, and describes the process that will be followed during the Environmental and Social Impact Assessment.

Coastal & Environmental Services 106 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

CHAPTER 4: PROJECT DESCRIPTION This Chapter will describe the proposed mining project, including the mining process, the mineral separation and processing plants, the transportation of materials between the mine site and, the port, the loading of vessels, and infrastructural requirements for water and power. The production of heavy minerals at the project site is contextualised in terms of the global market for these commodities.

CHAPTER 5: DESCRIPTION OF THE BIOPHYSICAL ENVIRONMENT This Chapter will describe the biophysical environment of the proposed development site.

CHAPTER 6: DESCRIPTION OF THE SOCIAL ENVIRONMENT This Chapter will describe the socio-economic environment of the proposed development site.

CHAPTER 7: PUBLIC PARTICIPATION PROCESS This Chapter will provide details of the public participation process conducted in terms of regulation (31) sub-regulation (1) including:

 Steps undertaken in accordance with the Plan of Study (PoS);  A list of all persons, organisations and organs of state that were identified and registered as I&APs in relation to the application.  A summary of the comments received from, and a summary of the issues raised by registered I&APs (as part of the Issues and Response Trail), the date of receipt of these comments and the response of the EAP to those comments; and  Copies of any representations, objections and comments received from registered I&APs.

CHAPTER 8: KEY FINDINGS OF THE SPECIALIST STUDIES This Chapter will provide a summary of the findings of the specialist studies undertaken for the project.

CHAPTER 9: METHODOLOGY FOR ASSESSING IMPACTS This Chapter will provide an indication of the methodology used in determining the significance of potential environmental and social impacts.

CHAPTER 10: ASSESSMENT OF BIOPHYSICAL IMPACTS This Chapter will provide a description of all environmental issues relating to all phases of the proposed development that were identified during the EIA process, an assessment of the significance of each issue and an indication of the extent to which the issue could be addressed by the adoption of mitigation measures.

CHAPTER 11: ASSESSMENT OF SOCIO-ECONOMIC IMPACTS This Chapter will provide a description of all socio-economic issues relating to all phases of the proposed development that were identified during the EIA process, an assessment of the significance of each issue and an indication of the extent to which the issue could be addressed by the adoption of mitigation measures.

CHAPTER 12: ASSESSMENT OF WASTE AND PROCESS RELATED ISSUES This Chapter will provide a description of all waste related issues relating to all phases of the proposed development that were identified during the EIA process, an assessment of the significance of each issue and an indication of the extent to which the issue could be addressed by the adoption of mitigation measures.

CHAPTER 13: THE EFFECTS OF THE KAMIESBERG PROJECT ON GLOBAL CLIMATE CHANGE This Chapter will provide an overview of the potential effects of the Kamiesberg Project on global climate change.

Coastal & Environmental Services 107 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

CHAPTER 14: ALTERNATIVES This Chapter will provide a description of the alternatives to the proposed development or parts of the proposed development. It also includes a comparative assessment of viable alternatives.

CHAPTER 15: ENVIRONMENTAL MANAGEMENT PROGRAMME This Chapter will provide a draft Environmental Management Programme for the proposed Kamiesberg Project.

CHAPTER 16: MONITORING PROGRAMME This Chapter will provide a Monitoring Programme for the proposed Kamiesberg Project.

CHAPTER 17: DECOMMISSIONING AND CLOSURE PLAN This Chapter will provide a Decommissioning and Closure Plan for the proposed Kamiesberg Project.

CHAPTER 18: CONCLUSIONS AND RECOMMENDATIONS This Chapter will present a synthesis of the project after all mitigation and compensation measures have been applied, detailing the residual impacts.

9.4 Specialist Studies

The following specialist studies are proposed for the EIA phase of the proposed development:

The terms of reference for the above-mentioned studies are provided in section 9.5 below.

9.5 Specialist Studies: Draft Terms of Reference

9.5.1 Vegetation Assessment

Mining will result in the clearing of vegetation not only during the operational stage but also for the construction of associated infrastructure. Vegetation is an important aspect of the landscape and the ecological functioning of the area and provides important habitats for many faunal species particularly birds, insects and reptiles. Clearing the vegetation will, therefore, affect the ecological functioning of the area, as well as the faunal diversity. Removal of the vegetation will also create a habitat for the invasion of alien species. Consequently baseline data on the vegetation of the area is needed to assess impacts related to this loss of vegetation, and to facilitate rehabilitation.

Coastal & Environmental Services 108 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

The specific terms of reference are as follows:

 To record the plant species that occur within the study area, based on field surveys.  To identify, and locate where possible, any plant Species of Conservation (special) Concern, namely Threatened, Near Threatened, Rare (species with conservation status and which are endemic to the area).  To comment on the conservation status of specific plant species (all SSC will be discussed in detail).  To compile a broad-scale vegetation or habitat map of the area. This vegetation map should indicate the extent that mining activities would affect each vegetation or habitat type, such as the impacts on wetlands located in the concession area.  To identify alien invasive species and the levels of infestation, with particular focus on rehabilitation that would reduce the significance of this impact.  To work in consultation with other specialists to ensure that the linkages between the various systems are understood.  To address all issues and concerns raised by I&APs during the scoping phase.  To provide a sensitivity map of the study (concession and coastal) areas in order for the proponent to better place the layout of the project’s infrastructure.  Once a sensitivity map has been created, the specialist must suggest ecological corridors around or adjacent to the project area.  Identify ecosystem services provided by the vegetation types in the project area.  Identify and assess the environmental significance of the identified botanical impacts using the methodology prescribed by CES, as this methodology is compliant with international best practice in EIA.  To provide practical and realistic recommendations to mitigate the identified botanical impacts

9.5.2 Biodiversity and Faunal Assessment

Mining requires the removal of extensive vegetation and habitat. It is important to assess the level of impact on biodiversity, and especially the faunal groups that make use of the habitats that will be lost as a result of mining. It is necessary to determine the baseline condition of the area to assess the impacts on faunal species arising through the further loss of habitat and food sources. Specific terms of reference include:

 Assess the conservation value of the various plant communities and ecological habitats in the area, in order to assess the significance of habitat loss on faunal groups as a result of the development.  Define and map faunal habitats that are sensitive and require conservation. These may need to be defined as No-Go or Restricted Development areas.  Review the mine path and compare it to the vegetation sensitivity maps. Any conflicts or areas that may be impacted will need to be noted and assessed  Ensure that the study deals with the issues raised during scoping.  Carry out a rapid survey to assess the diversity of amphibian, reptile, bird and mammal species in the area.  Identify any rare or endangered faunal species that require consideration in the conservation programme.  Describe the impacts of current land use, so that the potential impacts from the development on the natural environment can be understood in this context.  Determine the impacts of the construction and operation of the proposed development on the faunal biodiversity in the area.  The significance of the potential impacts and benefits must be assessed using the CES methodology (described in Appendix 1). Any predictions will need to include the confidence in the impacts occurring, and the significance of these impacts occurring on the local fauna.  Provide recommendations and mitigation measures that will reduce negative impacts on the local ecology and optimise conservation benefits.

Coastal & Environmental Services 109 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

9.5.3 Soils and Agricultural Assessment

The overall objective of this study is to understand the existing soils and agricultural use and the impacts the proposed mining project would have on soils and agricultural use within the mining area. Specific terms of reference include:  Provide, at a reconnaissance level, a soils map of the proposed mining area.  Identify and comment on the different land use patterns within the concession.  Evaluate the land capability/suitability of the area at a reconnaissance level and comment on the productive potential of the area for agriculture.  Map existing land use, and align land use categories with the vegetation map.  Identify the major impacts resulting from present agricultural practices.  Identify and assess the significance of impacts on the soil and agricultural environments that could result from the project.  Ensure that the study deals with any other issues related to land use raised during scoping.  Assess the environmental significance of these impacts using the methodology prescribed by CES.

9.5.4 Ground and Surface Water Assessment

Although no dredge mining will take place, the wet separation process will involve the use of sea water. Tailings disposed into the mined-out pits will be saturated with sea water. In terms of water resources, use of groundwater during mining activities may be utilised to provide water to the desalination plant for the freshwater requirements of the mine. The following issues need to be addressed:

 Ascertain the ecological state and functioning of the drainage network.  Provide a basic characterisation of the water resources, including seasonal variations, based on existing information.  Identify any environmental impacts on water resources that may result from the mining process.  Determine the risks of polluting groundwater resources at the mine site.  Address the impact that process water use may have on water supplies.  Identify any other significant impacts that may result, either directly or indirectly through the mining process on water resources.  Assess the significance of the impacts, and provide practical and realistic recommendations (from a cost perspective) to mitigate impacts  Address all issues and concerns raised by interested and affected parties during the scoping stage, and reported on in the Scoping Report.

9.5.5 Heritage Impact Assessment

In terms of the Heritage Resources Management Act (No 25 of 1999) Section 38(1)) an assessment is required in case of:

 The construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length;  The construction of a bridge or similar structure exceeding 50 m in length;  Any development or other activity which will change the character of a site o Exceeding 5 000 m2 in extent; or o Involving three or more existing erven or subdivisions thereof; or o Involving three or more erven or subdivisions thereof which have been consolidated within the past five years.  The costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority;  The re-zoning of a site exceeding 10 000m² in extent; or

Coastal & Environmental Services 110 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

 Any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority.

Consequently, an in-depth Phase 1 Heritage Impact Assessment of the mining area and servitude is required, which must address the following:

 Provides an overview of relevant legislation;  Describes the results of all site investigations;  Determines the significance of heritage resources in terms of criteria defined in the methodology.  Assesses the significance of these resources;  Assesses impacts (including cumulative impacts) associated with all the stages of the project.

9.5.6 Rehabilitation Assessment

Rehabilitation is a key mitigation action to reduce many of the impacts on the natural environment. A study is therefore required to draw on baseline information that will be collected during baseline soil, vegetation and fauna studies to develop a practical rehabilitation strategy.

Initial studies are required to address the rehabilitation of the mining area using natural vegetation, as well as non-indigenous species that might be more useful in initial stages of sand stabilisation. This study will need, in the first instance, to develop a conceptual rehabilitation strategy for the mined-out area, paying particular attention to the technical feasibility and cost effectiveness of any strategy. Secondly, the study must report on the success of the rehabilitation that has been undertaken to date, and thirdly a detailed rehabilitation programme, including cost estimates and practical guidelines and specifications must be developed. This will need to be based on local experience, and especially the rehabilitation programme at the Namakwa Sands operation. The specific terms of reference for this study will be as follows:

 Define the objectives of a rehabilitation programme, including options for post-mining land use.  Present conceptual rehabilitation strategies for the re-vegetation of the mined area, paying close attention to the technical feasibility and cost effectiveness of any rehabilitation strategy.  Define topsoil depth, and provide recommendations on the storage of topsoil, spreading rates and other recommendations which could influence the mining operation, especially in terms of bulk earth works and material handling.  Investigate the nature of the local plant communities to identify important plant species that could be used in the rehabilitation programme, and to understand successional pathways.  Discuss the rehabilitation of soils in the mined out areas, and the limitations imposed by a loss of fine material and use of sea water in the process.  Provide an overview of alternative rehabilitation strategies, with particular focus on the re- establishment of the natural ecosystem.  Develop any rehabilitation strategies in consultation with relevant government departments and key stakeholders.  Identify experimental studies needed to ensure the technical feasibility of the suggested rehabilitation programme.  Investigate ways of initially stabilising the sand surface through the use of a layer of clay, possibly bio-crusts or conventional techniques such as brush wood packing and wind row establishment, to determine the best option(s).

Coastal & Environmental Services 111 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

9.5.7 Socio-economic Impact Assessment

The project will result in national, regional and local economic benefits. It could also provide support for infrastructural development and, at a local level, will provide job opportunities and benefits arising from the multiplier effects associated with these. The primary objectives of this study will be:

 To provide a detailed description of the socio-economic environment in and around the project area.  Analyse the potential impacts of the proposed project.  Provide guidelines for limiting or mitigating negative impacts and optimising benefits, taking into account the experience at the original project to date.

The specific terms of reference are as follows:

 Describe the local socio-economic environment, and undertake the required surveys to quantify the number of households (and people) that will be directly affected as a result of the project.  Ensure that the study deals with the issues raised during scoping.  Assess the significance of potential economic and social impacts and benefits on the local populace and the Local and District Municipality.  Assess the local social infrastructure (health, education, markets, community);  Describe the formal and informal governing structures;  Identify the division of gender tasks and other relevant gender issues;  Identify income and expenditure trends;  Describe landownership and property rights;  Quantify the direct and indirect economic benefits of the project at local, regional and national levels. As an option, consider using economic models that could quantify direct and indirect economic benefits, as well as backward and forward linkages, multiplier effects and real benefits that might arise from employment opportunities.  Identify project-related impacts and provide recommendations for mitigating negative impacts and optimising positive impacts.

9.5.8 Scoping Level Health Impact Assessment

Community and public health is increasingly regarded as an important consideration when evaluating project developments. Health and well-being is regarded as a basic need and is recognised as a fundamental human right. Health effects can influence projects from many directions and need to be considered in all phases of the project life cycle.

Project developments are increasingly evaluated based on environmental and social safeguards. The IFC Performance Standards are generally used as best practice guidelines. Performance Standard 4 addresses community health and safety, and the IFC has supported the methodology of Health Impact Assessment (HIA) to support this element. A Good Practice Note supports this methodology, and should be applied as a consistent and best practice approach. The specific terms of reference are as follows:

 Develop a profile of potentially affected communities and impact areas of concern. This will be completed in conjunction with the social assessments.  Analyze environmental health areas that include health determinants and health outcome, and incorporate both health impacts and health needs. This is the preferred International Finance Corporation (IFC) methodology, which has been adopted to ensure a systematic method is used.  Identify relevant data gaps that may exist in the baseline data. This phase will allow the clear terms of reference to be determined for the comprehensive health impact assessment and future development of the community health management plan, if required.

Coastal & Environmental Services 112 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

 Identify key stakeholders and develop a key stakeholder forum to support the development of the management plan in the next phase.  Highlight key potential health impacts and opportunities that need to be addressed in the next phase, divided into community, project and institutional risk factors.  Determine what additional project specific data needs to be collected. An integrated approach must be adopted, in which health data collection will be incorporated as part of the social impact assessments.  At this stage the health assessment need not include specific quantitative baseline data collection, as this will be informed by the results of scoping study.  Use qualitative data to undertake an impact assessment.  Provide the project with pre-execution advice on how project activities, design, or plans may be changed, modified, or adapted in order to avoid or mitigate negative impacts and enhance anticipated benefits.

9.5.9 Visual Impact Assessment

The overall aim of a Visual Impact Assessment (VIA) is to determine the current landscape quality (scenic views, visual sensitivity) and the visual impact of the proposed development. The terms of reference of the VIA will include the following tasks:

 Undertake a desktop survey using 1:50 000 survey maps, 1:10 000 orthophotos, any digital colour aerial photography and any other high resolution images.  Conduct a site reconnaissance visit and photographic survey of the proposed project site. The focus of this survey should be on natural and cultural features, protected areas, coastal views and landscape, view sites, and scenic routes.  Conduct a desk top mapping exercise and develop a Digital Elevation Model to establish visual sensitivity:- o Describe and rate the scenic character and sense of place of the area and site. o Establish extent of visibility by mapping the view-sheds and zones of visual influence. o Establish visual exposure to viewpoints. o Establish the inherent visual sensitivity and visual absorption capacity of the site by mapping slope grades, landforms, vegetation, special features and land use and overlaying all relevant map layers to assimilate a visual sensitivity map.  Review relevant legislation, policies, guidelines and standards.  Preparation of a Visual Baseline/Sensitivity report which shall include, inter alia: o Assessing visual sensitivity criteria such as extent of visibility, the sites inherent sensitivity, visual sensitivity of the receptor’s, visual absorption capacity of the area and visual intrusion on the character of the area. o Prepare photomontages of the proposed development. o Assess the proposed project against the visual impact criteria (visibility, visual exposure, sensitivity of site and receptor, visual absorption capacity and visual intrusion) for the site. o Assess impacts based on a synthesis of criteria for each site (criteria = nature of impact, extent, duration, intensity, probability and significance). o Establish mitigation measures/recommendations with regards to minimizing visual impacts.

9.5.10 Air Quality Assessment

The MSP has the potential to result air pollution within the vicinity of the plant, in terms of the release of CO2 and the possible release of NOx from the MSP. Dust generation is a potential impact on community and worker health due to elevated concentrations of respirable dust (PM 10’s) which may exceed US-EPA standards, especially along both roads and the cleared mining area. Dust generated from Monazite handling and stockpiles presents an occupational health and safety risk to workers. In light of this, and the sensitivities around GHG emissions, the specific terms of reference are as follows:  Assess the current levels of air pollution (including dust) and characterise current air quality.

Coastal & Environmental Services 113 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

 Identify other risk sources of air pollution from the project, especially dust from mining activities and vehicle entrainment.  Quantify all particulate emissions using local meteorological data, and the proposed throughput for the operational phase of the MSP.  Predict, using suitable dispersion modelling or other appropriate methodologies, the air concentrations and emissions fallout due to each of the identified sources.  Quantify all emissions arising from the plant and transport of materials and products.  Assess what the impact of the project will be on ambient air quality. This will mean determining increased levels of pollution in the area and ranking them in terms of severity, frequency, locality and impact on the receiving environment.  Assess impacts of emissions from the MSP.  Ensure that the study deals with the issues raised during scoping.  Assess the environmental significance of these impacts.  Review IFC General EHS Guidelines – section 1.1 (April 2007) and provide recommendations to ensure emissions comply with those presented in Tables 1.1.1 and 1.1.2.  Suggest ways to avoid, mitigate, or ameliorate the impacts by discussing modifications or improvements to the process design with production engineers.  Develop a monitoring programme to ensure effective implementation of the recommended mitigation measures.

9.5.11 Baseline Radiation Assessment

The purpose of the study is to examine the radiological aspects of the project, since all heavy mineral ore bodies contain minerals enhanced in uranium and thorium, which become concentrated and extracted during mining and processing. In addition, a variety of waste streams with minerals containing uranium and thorium will be produced. The presence of uranium and thorium in the products and wastes streams from the project could result in the exposure of workers to ionising radiation, and a study is required to investigate levels of U and Th in the deposit, and to provide industry standard recommendations to manage these levels. The specific terms of reference are as follows:

 Provide an overview of background radiation sources and exposure.  Provide an overview of naturally occurring radioactive materials in the mining and processing of heavy minerals.  Provide an overview of the international system of dose limitation recommended by the ICRP and IAEA.  Provide a brief review of the safety standards and guideline documents on the mining of NORM and TENORM materials produced by the IAEA and other industry specific agencies.  Make recommendations regarding the components and methodology of a field based baseline radiation and dust survey at the project site.  Provide a summary of the currently available information on the radiological characteristics of the ore body.  Summarise the currently available information on the background gamma radiation levels at the ore body and compare these to world norms. Provide comment on any aspects that require further investigation and data.  Identify the potential radiological exposure pathways to both workers and the public which may result from the proposed mining and processing activities.  Investigate exposure to non-ionizing radiation and provide recommendations to ensure compliance with IFC General EHS Standards.  Provide an overview of the components of the radiological protection programs that will be required during the mining and minerals processing operations.  Provide recommendations regarding the engineered controls that can be used in the plant design to keep doses as low as reasonably achievable, by review design controls to ensure they are correct.

Coastal & Environmental Services 114 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

 Provide recommendations regarding the administrative controls that can be used during operations to keep doses as low as reasonably achievable.  As the MSP will require a Certificate of Registration (COR) from the national Nuclear Regulator (NNR), undertake a hazard assessment for various stages of the project.  Identify and describe the anticipated negative and positive radiological impacts during the construction, operation, decommissioning and mine closure phases.  Describe how the negative issues and impacts should be managed and incorporated into engineering and administrative specifications for the mine, by for example recommending that NORM material is buried in the pit.  Provide recommendations to manage occupational health and safety aspects associated with the operation.

9.5.12 Waste Management Study

This study will focus on the environmental impacts that may arise from the handling, storage and disposal of solid and liquid wastes from the mining and mineral processing activities and ancillary facilities. It will need to identify the various waste streams, and make recommendations on how to handle the additional waste streams. The specific terms of reference are as follows:

 Compile an inventory (identify, describe and, where possible, quantify) the various waste streams to be generated by sources. This will not require the analysis of solid waste samples.  Briefly describe the processes giving rise to the waste streams and the volumes and tonnages of waste streams.  Identify and describe the possible impacts of any solid and liquid wastes on the quality of surface and groundwater.  Assess the environmental significance of these impacts using the methodology prescribed by CES.  Assess the risks to the health and safety of workers at the various operations and related works and residents within the project’s area of influence.  Provide recommendations on the most feasible options for the disposal of solid and liquid wastes.  Describe the levels of hazardous waste on-site, paying particular attention to any material that might be regarded as radioactive, and make recommendations for the disposal and/or recycling of these materials.  Relate levels of any potentially toxic waste to recognised international standards, and ensure that any waste management strategy is in line with these standards.  Provide recommendations on ways in which Green House Gas emissions can be avoided or reduced, to be compliant with IFC requirements.  Ensure that the study deals with the issues raised during scoping.

9.5.13 Materials Handling, Transport and related Infrastructure Assessment

The purpose of this study is to assess the potential impacts on existing local road and related infrastructure, and on public safety, of traffic generated by the mining operation, both during the construction and operational phases. Special attention will be paid to issues arising from the expected increase in regular traffic between the operation and Bitterfontein, as well as issues related to the establishment of a servitude to Khnyp Punt.

9.6 Optional Specialist Study: Marine and Rocky Shore Assessment

Coastal & Environmental Services 115 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

The proposed single point mooring, the marine pipeline option and the establishment of a seawater intake for the desalination plant all have the potential to negatively impact on the marine environment. This study will need to investigate rocky shore biota, near-shore and benthic habitats, although the scope is dependent on options selected. The specific terms of reference for this study are as follows:

 Assess the rocky shore and near-shore environment that could be impacted from the establishment of a seawater intake pipeline.  Describe and rank the importance of the biota that exists in and around the area of the various proposed locations of the seawater intake.  Assess the impacts, especially at the construction phase, of the seawater intake on habitats and marine organisms.  Determine, through the use of underwater visual surveys, what biota exists under the single point mooring and pipeline pathway.  Describe and rank the importance of the biota that exists under the single point mooring and pipeline pathway.  Develop a map that describes areas of high, medium and low sensitivity (if appropriate) to be used as a guide for the final placement of the single point mooring and pipeline.  Ascertain whether any infrastructure, transhipment or increased marine traffic impacts are likely to be of concern on the marine environment.  Assess the significance of impacts on the marine environment, using the predefined rating scales.

Please note that the scope of the Marine Study will be dependent on whether or not the single point mooring option becomes the preferred option for the proposed development. Should this option be excluded during the EIA phase of the proposed project, then only a reduced marine investigation, focusing of the impacts of the seawater intake will be required.

9.7 Methodology for assessing the significance of impacts

A detailed description of the methodology is available in Appendix 1 of this report.

Coastal & Environmental Services 116 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

10. REFERENCES

Alexander, G. And Marais, J. 2010. A Guide to Reptiles Of Southern Africa. Struik Nature, Cape Town. Animal Demography Unit, Department Of Zoology, University Of Cape Town. 2012. Summary Data Of The Frogs Of South Africa, Lesotho And Swaziland.

Desmet, P.G. 2007. Namaqualand – A brief overview of the physical and floristic environment. Journal of Arid Environments: Volume 70, Issue 4, Pages 570 – 586.

Driver, A; Desmet, P; Rouget, M; Cowling, R and Maze, K. 2003. Succulent Karoo Ecosystem Plan Biodiversity Technical Report. Cape Conservation Unit, Report No CCU 1/03 Botanical Society of South Africa.

Du Preez, L. And Carruthers, V. 2009. A Complete Guide To Frogs Of Southern Africa. Struik Nature, Cape Town

Fey, M. 2010. Soils of South Africa. Cambridge University Press, Cape Town.

IUCN 2012. IUCN Red List of Threatened Species. Version 2012.2. . Downloaded on 04 March 2013.

Kaplan, J. 1993. The state of archaeological information in the coastal zone of the Orange River to Ponta do Oura. Unpublished report for the Department of Environmental Affairs and Tourism.

Lebert, T (2004) Municipal Commonage as a form of Land Redistribution: A case study of the new farms of Leliefontein, a communal reserve in Namaqualand, South Africa. Programme for Land and Agrarian Studies November 2004. Research Report No. 18

Mucina, L. & Rutherford, M.C. (eds) 2006. The vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria.

Namakwa District Municipality Local Economic Development Strategy. 2009.

Namakwa District Municipality Integrated Development Plan, 2012- 2016. (NDM IDP 2012-2016), accessible at http://www.namakwa-dm.gov.za/documents/namakwa-district-approved-idp-2012- 2016-2/

Namakwa District Municipality Local Economic Development Plan 2009, accessible at http://www.namakwa-dm.gov.za/wp-content/uploads/2011/08/Namakwa-LED.pdf

Olivier, S. 2005. Touring in South Africa: Page 168. Struik Publishers, Cape Town.

Orton, J. & Hart, T. 2011. Baseline heritage assessment of electrical and road infrastructure for the proposed Ibhubesi gas power plant in southern Namaqualand, Western and Northern Cape. Report prepared for CCA Environmental. ACO Associates Cape Town.

South African Biodiversity Information Facility. 2012. Accessible at http://www.sabif.ac.za/

Schlumberger Water Services, 2012. Scoping Hydrogeological Report For thr Kamiesberg Mineral Sands Project.

TZ Minerals International. 2012. Report No. 594/576: Kamiesburg Project Review.

Zirco Resources (SA) Pty Ltd, 2012. Geological update on the Kamiesberg Heavy Minerals Sands project.

Coastal & Environmental Services 117 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

11. APPENDICES

APPENDIX 1: METHODOLOGY FOR ASSESSING THE SIGNIFICANCE OF IMPACTS

Specialists are required to provide the reports in a specific layout and structure, so that a uniform specialist report volume can be produced. To ensure a direct comparison between various specialist studies, standard rating scales have been defined for assessing and quantifying the identified impacts. This is necessary since impacts have a number of parameters that need to be assessed.

Four factors need to be considered when assessing the significance of impacts, namely:

1. Relationship of the impact to temporal scales - the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact.

2. Relationship of the impact to spatial scales - the spatial scale defines the physical extent of the impact.

3. The severity of the impact - the severity/beneficial scales used in order to scientifically evaluate how severe negative impacts would be, or how beneficial positive impacts would be on a particular affected system (for ecological impacts) or a particular affected party.

The severity of impacts can be evaluated with and without mitigation in order to demonstrate how serious the impact is when nothing is done about it. The word ‘mitigation’ means not just ‘compensation’, but also the ideas of containment and remedy. For beneficial impacts, optimization means anything that can enhance the benefits. However, mitigation or optimization must be practical, technically feasible and economically viable.

4. The likelihood of the impact occurring - the likelihood of impacts taking place as a result of project actions differs between potential impacts. There is no doubt that some impacts would occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident), and may or may not result from the proposed development. Although some impacts may have a severe effect, the likelihood of them occurring may affect the ESIR overall significance.

Each criterion is ranked as presented in Table A1 to determine the overall significance of an activity. The criterion is then considered in two categories, viz. effect of the activity and the likelihood of the impact. The overall significance is determined using Table A2 and the significance is either negative or positive.

Coastal & Environmental Services 118 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Table A1: Ranking of Evaluation Criteria Temporal Scale Short term Less than 5 years Medium term Between 5-20 years Long term Between 20 and 40 years (a generation) and from a human perspective also permanent Permanent Over 40 years and resulting in a permanent and lasting change that will always be there Spatial Scale Localised At localised scale and a few hectares in extent Study Area The proposed site and its immediate environs Regional District and Provincial level National Country

EFFECT International Internationally Severity Severity Benefit Slight Slight impacts of the affected Slightly beneficial to the affected system(s) and system(s) or party(ies) party(ies) Moderate Moderate impacts of the Moderately beneficial to the affected system(s) and affected system(s) or party(ies) party(ies) Severe/ Severe impacts of the affected A substantial benefit to the affected system(s) and Beneficial system(s) or party(ies) party(ies) Very Severe/ Very severe change to the A very substantial benefit to the affected system(s) Beneficial affected system(s) or party(ies) and party(ies)

Likelihood Unlikely The likelihood of these impacts occurring is slight May Occur The likelihood of these impacts occurring is possible Probable The likelihood of these impacts occurring is probable

LIKELIHOOD Definite The likelihood is that this impact will definitely occur

* In certain cases it may not be possible to determine the severity of an impact thus it may be determined: Don’t know/Can’t know

Table A2: Description of Environmental Significance Ratings and associated range of scores Significance Description Rate Low Acceptable impact for which mitigation is desirable but not essential. The impact by itself is insufficient even in combination with other low impacts to prevent the development being approved. These impacts will result in either positive or negative medium to short term effects on the social and/or natural environment. Moderate An important impact which requires mitigation. The impact is insufficient by itself to prevent the implementation of the project but which in conjunction with other impacts may prevent its implementation. These impacts will usually result in either a positive or negative medium to long- term effect on the social and/or natural environment. High A serious impact, if not mitigated, may prevent the implementation of the project (if it is a negative impact). These impacts would be considered by society as constituting a major and usually a long-term change to the (natural &/or social) environment and result in severe effects or beneficial effects. Very High A very serious impact which, if negative, may be sufficient by itself to prevent implementation of the project. The impact may result in permanent change. Very often these impacts are unmitigable and usually result in very severe effects, or very beneficial effects.

Coastal & Environmental Services 119 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

The environmental significance scale is an attempt to evaluate the importance of a particular impact. This evaluation needs to be undertaken in the relevant context, as an impact can either be ecological or social, or both. The evaluation of the significance of an impact relies heavily on the values of the person making the judgment. For this reason, impacts of especially a social nature need to reflect the values of the affected society.

Prioritising The evaluation of the impacts, as described above is used to prioritise which impacts require mitigation measures.

Negative impacts that are ranked as being of “VERY HIGH” and “HIGH” significance will be investigated further to determine how the impact can be minimised or what alternative activities or mitigation measures can be implemented. These impacts may also assist decision makers i.e. lots of HIGH negative impacts may bring about a negative decision.

For impacts identified as having a negative impact of “MODERATE” significance, it is standard practice to investigate alternate activities and/or mitigation measures. The most effective and practical mitigations measures will then be proposed.

For impacts ranked as “LOW” significance, no investigations or alternatives will be considered. Possible management measures will be investigated to ensure that the impacts remain of low significance

Coastal & Environmental Services 120 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

APPENDIX 2: BACKGROUND INFORMATION DOCUMENT

Background Information Document (English)

Coastal & Environmental Services 121 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Coastal & Environmental Services 122 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Background Information Document (Afrikaans)

Coastal & Environmental Services 123 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Coastal & Environmental Services 124 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

APPENDIX 3: COPIES OF LETTERS SENT TO I&APs AND PROOF OF RECEIPT

1. Landowners and occupiers directly affected by mining activities:

1.1 Contact Details

Coastal & Environmental Services 125 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Port Con ion tact Farm Lando Postal Nu Nu Name wner Address mb mb er er 027 P.O. Box Klipda Jacob 531 334, m No 633 van Zyl 101 Garies, 633 4 8220 027 P.O. Box Roode 1/50 Marius 531 8, Heuwe 2 van Zyl 101 Garies, l 502 0 8220 027 P.O.Box Roode Izak 5/50 531 190, Heuwe Engelb 2 102 Garies, l 502 reght 7 8220 027 P.O.Box Roode Izak 6/50 531 190, Heuwe Engelb 2 102 Garies, l 502 reght 7 8220 083 P.O.Box Roode 9/50 Alwyn 353 905, Heuwe 2 van Zyl 459 Vredend l 502 8 al, 8160 027 P.O. Box Jan C. Leeuvl 531 10, Engelbr ei 642 103 Vanrhyn echt 642 0 sdorp,

8170 027 Johan P.O. Box Soutkr 581 1/43 Engelbr 338, aal 109 7 echt Garies, 437 5 8220

027 P.O. Box Jan C. Kliphe 531 10, 9/43 Engelbr uwel 103 Vanrhyn 5 echt 435 0 sdorp,

8170 027 P.O. Box Jan C. Kliphe 531 10, 10/4 Engelbr uwel 103 Vanrhyn 35 echt 435 0 sdorp,

8170 082 P.O.Box Kliphe Ian 11/4 726 133, uwel Coetze 35 929 Lutzville 435 e 7 , 8165 P.O. Box 027 Jan C. 10, Sabies 2/50 531 Engelbr Vanrhyn 505 5 103 echt sdorp, 0 8170

Coastal & Environmental Services 126 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

P.O. Box 021 Hawer Deon 1163, 1/50 851 land Engelb Somers 3 242 503 reght et West, 0 7129 027 P.O. Box Hawer Izak 2/50 531 190, land Engelb 3 102 Garies, 503 reght 7 8220 027 P.O. Box Hawerl Miemie 3/50 531 190, and Englebr 3 102 Garies, 503 echt 9 8220 027 P.O. Box Hawerl Miemie RE/ 531 190, and Englebr 503 102 Garies, 503 echt 9 8220

Coastal & Environmental Services 127 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

1. Details of landowners and occupiers adjacent to proposed mining activities

Coastal & Environmental Services 128 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Po rti Cont Farm on Contact act Postal Name Nu Person Num Address mb ber er Rood Tronox 115 West 022 e 4/5 Mineral Street, 701 Heuw 02 Sands Sandton, 3911 el 502 (Pty) Ltd 2196 Rood P.O. Box RE 027 5 e Dirk van 8, /50 31 Heuw Zyl Garies, 2 1016 el 502 8220 P.O. Box Kliphe Johan 027 5 3/4 338, uwel Engelbre 81 35 Garies, 435 cht 1095 8220 Namaqu a P.O. Box KWA RE National 02767 117, SS /50 Park 21948 Kamieskro 501 1 Petrus on,8241 Schreud er P.O. Box Rooih 027 5 63 Dirk van 8, euwel 31 4 Zyl Garies, 634 1016 8220 Gert and P.O. Box Kliphe RE 027 5 Hestelle 79, uwel /43 81 Engelbre Garies, 435 5 1021 cht 8220 Gert and P.O. Box Kliphe 027 5 7/4 Hestelle 79, uwel 81 35 Engelbre Garies, 435 1021 cht 8220 P.O. Box Kliphe Johan 027 5 3/4 338, uwel Engelbre 81 35 Garies, 435 cht 1095 8220 P.O. Box Soutf 021 5 2/4 J.C.C de 113, ontein 81 36 Villiers Garies, 436 1020 8220 P.O. Box Soutf 021 5 3/4 J.C.C de 113, ontein 81 36 Villiers Garies, 436 1020 8220 Gert and P.O. Box Soutf 027 5 6/4 Hestelle 79, ontein 81 36 Engelbre Garies, 436 1021 cht 8220 P.O. Box Soutk 021 5 3/4 J.C.C de 113, raal 81 37 Villiers Garies, 437 1020 8220

Coastal & Environmental Services 129 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

P.O. Box Soutk 021 5 4/4 J.C.C de 113, raal 81 37 Villiers Garies, 437 1020 8220 Groen P.O. Box 027 5 rivier's 2/5 W.D.Eng 48, 31 Vallei 04 elbrecht Garies,82 1032 504 20 Groen P.O. Box 027 5 rivier's 3/5 G.G 1, 31 Vallei 04 Kotze Garies, 1026 504 8220 Groen P.O. Box 027 5 rivier's 5/5 G.G 1, 31 Vallei 04 Kotze Garies, 1026 504 8220 Groen P.O. Box 027 5 rivier's 6/5 W.D.Eng 48, 31 Vallei 04 elbrecht Garies, 1032 504 8220 Groen P.O. Box 027 5 rivier's 7/5 W.D.Eng 48, 31 Vallei 04 elbrecht Garies, 1032 504 8220 P.O. Box Sabie RE 027 5 W.D.Eng 48, s /50 31 elbrecht Garies, 505 5 1032 8220 Jan C. 027 5 P.O. Box Sabie 1/5 Engelbre 31 10, s 05 cht 1030 Vanrhynsd 505 orp, 8170 P.O. Box Sabie 027 5 6/5 W.D.Eng 48, s 31 05 elbrecht Garies, 505 1032 8220 P.O. Box Kliphe Johan 027 5 3/4 338, uwel Engelbre 81 35 Garies, 435 cht 1095 8220

Coastal & Environmental Services 130 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

1.2 Proof of Notification Letters

Coastal & Environmental Services 131 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Coastal & Environmental Services 132 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

1.3 Proof of Delivery N Trace Status o Name Numbe . r

Jacob RD 1 van 912 238 Zyl 242 ZA

Mariu RD 2 s van 912 238 Zyl 256 ZA

Izak RD Engel 3 912 238 bregh 260 ZA t

Coastal & Environmental Services 133 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Alwyn RD 4 van 912 238 Zyl 273 ZA

Jan RD 5 Engel 912 238 brecht 287 ZA

Johan RD 6 Engel 912 238 brecht 295 ZA

Coastal & Environmental Services 134 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Ian RD 7 Coetz 912 238 ee 300 ZA

Deon RD Engel 8 912 238 bregh 313 ZA t

Petru RD s 9 912 238 Schre 327 ZA uder

Coastal & Environmental Services 135 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

W.D. RD 1 Engel 912 238 0 brecht 335 ZA

A.C. RD 1 de 912 238 1 Villier 344 ZA s

RD 1 G.G. 912 238 2 Kotze 358 ZA

Coastal & Environmental Services 136 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Gert RD 1 Engel 912 238 3 brecht 361 ZA

Miemi RD 1 e 912 238 4 Engle 389 ZA brecht

Trono x RD 1 Miner 912 238 5 al 375 ZA Sand s

Coastal & Environmental Services 137 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

2. Details of landowners and occupiers which may be affected by the construction of the pipeline 2.1 Contact Details Farm Name Portion Landowner Contact Contact Postal Address Number Person Number Klipkuil 2/547 Willem Petrus Auret Willem Petrus 083 275 P.O. Box 85 547 Auret 9791 Lamberts Bay 8130 Klipkuil 8/547 Groenriviersmond A.A. Niewoudt 027 531 P.O. Box 37 547 Trust 1046 Garies 8220 Klipkuil 10/547 Groenriviersmond A.A. Niewoudt 027 531 P.O. Box 37 547 Trust 1046 Garies 8220 Rooiheuwel 634 Dirk van Zyl Dirk van Zyl 027 531 P.O. Box 8, 634 1016 Garies, 8220 Roode Heuvel RE/502 Dirk van Zyl Dirk van Zyl 027 531 P.O. Box 8, 502 1016 Garies, 8220 Eiland Punt 1/549 Willem Petrus Auret Willem Petrus 083 275 P.O. Box 85 Noord Auret 9791 Lamberts Bay 549 8130 Eiland Punt 2/549 De Beers 053 839 P.O. Box 616 Noord Consolidated Mines 4111 Kimberley, 8300 549 (Pty) Ltd 053 839 4210 Eiland Punt 3/549 Groenriviersmond A.A. Niewoudt 027 531 P.O. Box 37 Noord Trust 1046 Garies 549 8220 Eiland Punt 4/549 Groenriviersmond A.A. Niewoudt 027 531 P.O. Box 37 Noord Trust 1046 Garies 549 8220 Eiland Punt RE/549 De Beers 053 839 P.O. Box 616 Noord Consolidated Mines 4111 Kimberley, 8300 549 (Pty) Ltd 053 839 4210 Strandfontein RE/559 Sedex Desalination Stuart Smith 021 446 P.O. Box 8399, 559 6040 Cape town, 8012 Eiland Punt Zuid 1/550 Kambrolandskap onia@ 082 773 P.O. Box 95 550 Koop Ltd telkomsa.net 2524 Orania, 8752 Eiland Punt Zuid 2/550 Willem Petrus Auret Willem Petrus 083 275 P.O. Box 85 550 Auret 9791 Lamberts Bay 8130 Eiland Punt Zuid 3/550 Groenriviersmond A.A. Niewoudt 027 531 P.O. Box 37 550 Trust 1046 Garies 8220 Eiland Punt Zuid RE/550 De Beers 053 839 P.O. Box 616 550 Consolidated Mines 4111 Kimberley, 8300 (Pty) Ltd 053 839 4210

Coastal & Environmental Services 138 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

2.2 Proof of Notification Letter

Coastal & Environmental Services 139 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

2.3 Proof of Delivery Trace Status No. Name Number

RD Sedex 1 912 238 551 Desalination ZA

De Gees RD 912 238 2 Consolodated 565 ZA

Coastal & Environmental Services 140 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

RD 912 238 3 Dirk van Zyl 579 ZA

RD 912 238 4 A.A. Niewoud 582 ZA

RD 912 238 5 W.P. Aurit 596 ZA

Coastal & Environmental Services 141 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Kombrolandskop RD 912 238 6 Koop 534 ZA

Coastal & Environmental Services 142 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

3. Stakeholders of the Project 3.1 Contact Details

Coastal & Environmental Services 143 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Stakeholde Contact Contac Postal r Person t Address Numbe r National Chief Directorate - Integrated Private Bag DEA: Coastal 021 819 X447, Oceans and Managemen 2432 Pretoria, Coasts t: 0001 Dr Razeena Omar South African SANRAL PO Box 415, National 012 426 Corporate Pretoria, Roads 6000 Office 0001 Agency (SANRAL) 012 319 Department Office of the 7150 of Private Bag Minister : (PTA) Agriculture, x9087, Cape Mr Andrew 021 467 Forestry and Town, 8000 Bartlett 4502 Fisheries (CPT) Minister For Agriculture Department And Land 053 831 Of Affairs: 4049 Private Bag Agriculture Ms Tina X5018, Joemat- Kimberley Petterson 8300 Head Of The Department Department: Of 053 838 9100. Mr Viljoen Agriculture Mothibi Megawatt Eskom Park – D1 Transmissio Itumeleng Y39, PO Box n: Grid 011 800 4114 Moeng 1091, connectivity Johannesbur and capacity g, 2000 Transnet Transnet P O Box National National Port 32696, Ports 011 351 9001 Authority Braamfontein Authority Head Office , 2017 (TNPA) Media 012 336 Department Liaison 8733 / Private Bag Of Water Officer: 90 X313, Affairs Mr Mandla 083 235 Pretoria,0001 (DWA) Mathebula 8675 South PO Box African 021 462 Head Office 4637, Cape Heritage 4502 Town, 8000 Resources

Coastal & Environmental Services 144 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Agency (SAHRA) Director Department General's Private Bag of Mineral Office: 012 444 X59, Arcadia, Resources Mr 3308 0007 (DMR) Khayalethu Matrose Provincial – Western Cape SANRAL 021 957 Private Bag (Western 4600 X19, Bellville, Region) 7535 Department: Roads and Head of Private Bag Public 021 483 Department: X9185, Cape Works 2826 Johan Fourie Town, 8001 (Western Cape) Transnet Private Bag National Port of 022 701 X1, Ports Saldanha 4302/4 Saldanha, Authority 7395 (TNPA) Department Media of Liaison 021 483 Private Bag Agriculture – Officer: 4930 X9179, Cape Western Agriculture 079 694 Town, 8000 Cape Mr Wouter 3085 Krie Department Chief 021 941 Private Bag Of Water Director: 6000 X16, Affairs Western 082 809 Sanlamhof, (DWA) Cape 2218 7532 Mr R Khan 3rd Floor, Protea Heritage Assurance 021 483 Western Andrew Hall Bldg, 5959 Cape Greenmarket Square, Cape Town, 8000 Department Regional 021 427 Private Bag X of Mineral Manager: 1000 9, Resources Sivuyele ROGGEBAAI (DMR) Mpakane , 8012

3.2 Proof of Notification Letter

Coastal & Environmental Services 145 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Coastal & Environmental Services 146 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Coastal & Environmental Services 147 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Coastal & Environmental Services 148 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

3.3 Proof of Delivery

Trace Status No. Name Number

RD Dr Razeena 1 912 238 605 Omar ZA

SANRAL RD 2 Corporate 912 238 619 Office ZA

Coastal & Environmental Services 149 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Ms Tina RD 3 Joemat- 912 238 622 Petterson ZA

RD Itumeleng 4 912 238 636 Moeng ZA

RD Mr Andrew 5 912 238 640 Bartlett ZA

Coastal & Environmental Services 150 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Transnet RD National 6 912 238 653 Ports ZA Authority

RD Mandla 7 912 238 667 Mathebula ZA

RD 8 SAHRA 912 238 675 ZA

Coastal & Environmental Services 151 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Department RD 9 of Mineral 912 238 684 Resources ZA

SANRAL RD 10 (Western 912 238 698 Region) ZA

RD Johan 11 912 238 707 Fourie ZA

Coastal & Environmental Services 152 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Transnet RD 12 National 912 238 715 Ports ZA

RD 13 Wouter Krie 912 238 724 ZA

RD 14 R Khan 912 238 738 ZA

Coastal & Environmental Services 153 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

RD 15 Andrew Hall 912 238 741 ZA

RD Sivuyele 16 912 238 755 Mpakane ZA

Department: RD Roads and 17 912 238 769 Public ZA Works

Coastal & Environmental Services 154 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

SANRAL RD 18 (Western 912 238 772 Region) ZA

RD 19 Ali Diteme 912 238 786 ZA

Department RD 20 of Mineral 912 238 809 Resources ZA

Coastal & Environmental Services 155 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

RD 21 A Abrahams 912 238 790 ZA

RD Suzanne 22 912 238 812 Erasmus ZA

RD Andrew 23 912 238 830 Timothy ZA

Coastal & Environmental Services 156 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Namakwa RD 24 District 912 238 843 Municipality ZA

RD Patro 25 912 238 888 Willems ZA

RD Andre 26 912 238 826 Malgas ZA

Coastal & Environmental Services 157 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Kamiesburg RD 27 Local 912 238 857 Municipality ZA

Bird Life – RD 28 Northern 912 238 865 Cape ZA

Hanneline RD 29 Smit- 912 238 874 Robinson ZA

Coastal & Environmental Services 158 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Namaqua RD 30 National 912 238 905 Park ZA

Coastal & Environmental Services 159 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

APPENDIX 3: EMAILS SENT TO I&APS NOTIFYING THE AVAILABILITY OF DRAFT SCOPING REPORT

Coastal & Environmental Services 160 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

APPENDIX 4: ATTENDENCE REGISTER FROM DRAFT SCOPING REPORT DISCLOSURE

Coastal & Environmental Services 161 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

APPENDIX 5: LETTER FROM DEA CONFIRMING COMPETENT AUTHORITY

Coastal & Environmental Services 162 Kamiesberg Project, Namaqualand, South Africa Final Scoping Report – January 2014

Coastal & Environmental Services 163 Kamiesberg Project, Namaqualand, South Africa