BASIC ASSESSMENT REPORT – DRAFT 1

SAND MINING PERMIT APPLICATION

Application to mine silica sand over an approximate 4,15ha section of the Tugela River on the KwaZulu-Natal North Coast in the Ilembe District Municipality

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

Prepared for Prepared by

Hlanganisa Sands (Pty) Ltd Representative: Mr. Marc Dunlop

FMI House, PO Box 184 Darnall 2 Heleza Blvd, 4480 Sibaya

082 445 8471 031 566 2858 [email protected] [email protected]

DMR EIA Reference Number: KZN30/5/1/3/2/10697MP March 2020

1. IMPORTANT NOTICE

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

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

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

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

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

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2. Objective of the Basic Assessment process

The objective of the basic assessment process is to, through a consultative process

(a) Determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context;

(b) Identify the alternatives considered, including the activity, location, and technology alternatives;

(c) Describe the need and desirability of the proposed alternatives,

(d) Through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage , and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to determine:

(i) The nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and (ii) The degree to which these impacts— (aa) Can be reversed; (bb) May cause irreplaceable loss of resources; and (cc) Can be managed, avoided or mitigated;

(e) Through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity to—

(i) Identify and motivate a preferred site, activity and technology alternative; (ii) Identify suitable measures to manage, avoid or mitigate identified impacts; and (iii) Identify residual risks that need to be managed and monitored.

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DETAILS OF THE INDEPENDENT ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) FOR THE BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PLAN

Compiled by:

EAP: Justin Ellero (ID 9001305086083)

Qualifications: MSc (Geography) (UKZN) • BSSH (Environmental Science – Cum Laude) (UKZN) • BSS (Geography and Environmental Management) (UKZN) • Advanced Course (Environmental Law) (UNISA)

Work Experience: Justin Ellero is an Environmental Assessment Practitioner with five years’ experience in conducting Environmental Impact Assessments, Water Use License Applications, Mining applications and Waste Management Licensing. His project experience list includes municipal pipelines, Eskom powerlines, Eco-Lodge developments, residential estates, industrial parks, mining permits and development at the King Shaka International Airport. As of the 30th of November 2019, Justin is a fully registered Environmental Assessment Practitioner with The Environmental Assessment Practitioners Association of South Africa.

I, Justin Pietro Ellero confirm:

 The correctness of all information within the BAR and EMP;

 All I&APs comment and inputs have been included in this Report;

 The inclusion of inputs and recommendations from the specialist reports where relevant; and

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

An undertaking of oath can be found at the end of this application.

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Project Team for the proposed Hlanganisa Sand Mine (Tugela River):

Name Role Company Qualifications

IDM Environmental Project Team

Mr. Justin Pietro Environmental IDM Environmental – MSc Geography (UKZN) Ellero Assessment EAP Practitioner EAPSA Registration (2019/178)

Mr. Karl Wiggishoff Internal Reviewer of Managing Director of Masters in Environmental, all Reports IDM Environmental Planning and Development Law (Stel)

Environmental Specialists

Ms. Louise Zdanaw Botanical and Managing Director of BSC Honours Botany (UCT) Freshwater Specialist EnviroSwift KZN (Pty) Ltd. SACNASP Registered (114072)

Mr. Alex Whitehead Ichthyofaunal (fish) Sustainable BSc Honours Specialist Development Projects cc SACNASP Registered

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TABLE OF CONTENTS

1 BACKGROUND INFORMATION ...... 12

1.1 INTRODUCTION ...... 12

1.2 LOCATION OF THE PROJECT ...... 12

1.3 EIA REGULATIONS OF 2014 (AS AMENDED) TRIGGERED ACTIVITIES..... 16

1.4 TERMS OF REFERENCE ...... 16

1.5 APPROACH AND METHODOLOGY ...... 16

1.6 REPORT STRUCTURE ...... 17

1.7 APPLICABLE LEGISLATION, POLICIES AND GUIDELINES ...... 17

2 DESCRIPTION OF PROPOSED ACTIVITIES ...... 23

2.1 ACTIVITY DESCRIPTION ...... 23 Extent of the Mine ...... 23 Site Planning ...... 23 Site preparation and establishment ...... 24 Operation ...... 25 Sediment replenishment ...... 26 Duration of Activity ...... 26 Mine Closure and Rehabilitation ...... 26

2.2 SERVICE PROVISION ...... 27

2.3 ACCESS TO THE MINING SITE ...... 27

2.4 SOCIAL RESPONSIBILITY OF THE APPLICANT ...... 29

2.5 NEED AND DESIRABILITY OF THE PROPOSED TUGELA RIVER SAND MINE ...... 29

2.6 CONSIDERATION OF ALTERNATIVES ...... 30

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Activity alternatives ...... 30 Location alternatives ...... 31 Layout Alternatives...... 31 Scheduling Alternatives ...... 31 Infrastructure/input alternatives ...... 31 “No-go” alternative ...... 31

3 PUBLIC PARTICPATION ...... 33

3.1 REQUIREMENTS OF THE ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS OF 2014 (AS AMENDED) ...... 33

3.2 COMMENTS AND RESPONSE REPORT ...... 34

4 BASELINE ENVIRONMENT OF THE PROPOSED SITE ...... 36

4.1 CLIMATE...... 36

4.2 LANDSCAPE CHARACTERISTICS/EXISTING SITUATION ...... 36

4.3 GEOLOGY AND SOILS ...... 37

4.4 FLORA ...... 37

4.5 FRESHWATER CHARACTERISTICS ...... 40 The Present Ecological State and Ecological Importance and Sensitivity scores ...... 43 4.5.1.1 The PES of all impacted watercourses...... 43 4.5.1.2 EIS of all impacted watercourses ...... 44

4.6 ICHTHYOLOGICAL OF THE TUGELA RIVER ...... 46

4.7 SITES WITH ARCHAEOLOGICAL INTEREST ...... 48

4.8 SOCIAL-ECONOMIC ENVIRONMENT ...... 48

4.9 REGIONAL ENVIRONMENTAL SENSITIVITIES ...... 49

4.10 PHOTOGRAPHIC REPRESENTATION OF THE PROPOSED TUGELA RIVER SAND MINING SITE ...... 50 7 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

5 IMPACT ASSESSMENT ...... 54

5.1 INTRODUCTION ...... 54

5.2 IMPACT ASSESSMENT CRITERIA ...... 54 Nature of impact ...... 54 Extent/Scale ...... 54 Duration ...... 54 Intensity ...... 55 Probability ...... 55 5.2.5.1 DETERMINATION OF SIGNIFICANCE ...... 56

5.3 IMPACT HIERARCHY ...... 56

5.4 IMPACTS FROM SIMILAR TYPES OF DEVELOPMENT/MINING OPERATIONS ...... 57

5.5 ENVIRONMENTAL IMPACTS OF THE PROPOSED PREFERRED ALTERNATIVE...... 57 Soil Erosion, loss of topsoil and contamination ...... 58 Freshwater Impacts...... 60

5.6 CUMULATIVE IMPACTS ...... 70

5.7 SUMMARY OF IMPACTS PER THE DIFFERENT PHASES OF THE HLANGANISA SAND MINE...... 71

5.8 ALTERNATIVES IMPACT ASSESSMENT ...... 72

5.9 SUMMARY OF SPECIALIST STUDIES ...... 72

5.10 ENVIRONMENTAL IMPACT STATEMENT AND SUMMARY ON NEED AND DESIRABILITY ...... 72 Environmental Impact Statement ...... 72

5.11 IMPLEMENTATION OF BUFFERS ...... 74

5.12 FINANCIAL PROVISION...... 74

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5.13 EXPLAIN HOW THE FINANCIAL PROVISION WAS OBTAINED ...... 75

5.14 UNCERTAINTIES/GAPS IN KNOWLEDGE ...... 75

6 SUMMARY RECOMMENDATIONS OF EAP ...... 76

LIST OF ANNEXURES:

Annexure A: Regional Map

Annexure B: Schematic Layout Plan of the proposed Hlanganisa River Sand Mine

LIST OF APPENDICES:

Appendix 1: Environmental Management Plan

Appendix 2: Public Participation Report (to be provided in final submission)

Appendix 3: Freshwater and Vegetation Assessment

Appendix 4: Ichthyofaunal (fish) Survey

Appendix 5: Mining Operational Plan

Appendix 6: Mine Closure and Rehabilitation Report

Appendix 7: Hlanganisa Sands Social Plan

Appendix 8: Financial and Technical ability

Appendix 9: EAP CV and Specialist Declarations

LIST OF TABLES Table 1.1: Summary of the proposed property details for the Hlanganisa River Sand Mine ...... 12 Table 1.2: Triggered Activities for the proposed Hlanganisa River Sand Mine ...... 16 Table 1.3: Other Applicable Legislation to the proposed Hlanganisa River Sand Mine ...... 18 Table 3.1: Public Participation Comments and EAP Responses table example to be utilised for final BAR Report .. 35 Table 5.1: Advantages and Disadvantages of the proposed Hlanganisa River Sand Mine ...... 73

LIST OF FIGURES 9 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Figure 1.1: Regional location of proposed Hlanganisa River Sand Mine ...... 14 Figure 1.2: Locality map of the proposed Hlanganisa River Sand Mine ...... 15 Figure 2.1: Schematic layout of the proposed Hlanganisa River Sand Mine ...... 23 Figure 2.2: Pathway of the existing access ramp to the Tugela River sand bar ...... 25 Figure 2.3: Access from the N2 to the proposed Hlanganisa River Sand Mine...... 28 Figure 4.1: The location of the mine extent within areas which are indicated as Biodiversity Areas and transformed areas by the KZN TSCP (2010) ...... 39 Figure 4.2: Watercourses considered to be at risk as a result of the proposed sand mining activities ...... 40 Figure 4.3: Watercourses located within the DWS 500m regulated zone...... 43 Figure 4.4: Protected Areas as per the DEA Database in close proximity to the proposed Mine ...... 49 Figure 5.1: T Watercourse buffers for the proposed Hlanganisa River Sand Mine ...... 74

LIST OF IMAGES

Image 2.1: Existing access ramp to the Tugela River ...... 28 Image 4.1: The greater portion of the applicant’s property is cultivated with sugarcane ...... 36 Image 4.2: The former iLembe District San Souci Water Treatment Works ...... 37 Image 4.3: L molybdinis caught within the sample site ...... 47 Image 4.4: E trimaculatus caught within the sample site ...... 48 Image 4.5: The proposed mining site facing downstream ...... 50 Image 4.6: The proposed mining site facing the opposite northern bank ...... 51 Image 4.7: The proposed mining site facing upstream ...... 52 Image 4.8: Existing sandbar within the proposed mining extent ...... 53

ABBREVIATIONS BA Basic Assessment BAR Basic Assessment Report C Construction CA Competent Authority CBA Critical Biodiversity Area DAFF Department of Agriculture, Forestry and Fisheries DEA Department of Environmental Affairs DMR Department of Mineral Resources EA Environmental Authorisation EAP Environmental Assessment Practitioner

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EDTEA Department of Economic Development, Tourism and Environmental Affairs (KZN) EIA Environmental Impact Assessment EKZNW Ezemvelo KwaZulu-Natal Wildlife EMP Environmental Management Plan ESA Ecological Support Area ETo Potential Evaporation FEPA Freshwater Ecosystem Priority Area IDM Integrated Development Management Consultants IDME Integrated Development Management Consultants Environmental LM Local Municipality KZN KwaZulu-Natal NBA National Biodiversity Assessment NDP National Development Plan NEMPAA National Environmental Management: Protected Areas Act (57 of 2003) NFEPA National Freshwater Ecosystem Priority Area O Operational PGDP KZN Provincial Growth and Development Plan PP Public Participation PPP Public Participation Process PSDF KZN Provincial Spatial Development Framework SCC Species of Conservation Concern SANBI South African National Biodiversity Institute WM With Mitigation WMA Water Management Area WOM Without Mitigation WUL Water Use License WULA Water Use License Application

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1 BACKGROUND INFORMATION

1.1 INTRODUCTION An application to mine silica sand along a 4,15ha section of the Tugela River has been submitted to the Department of Mineral Resources (DMR) under reference (KZN30/5/1/3/2/10697MP) on behalf of Hlanganisa Sands (Pty) Ltd. IDM Environmental (IDME) has been appointed as the independent Environmental Assessment Practitioner (EAP) by Hlanganisa Sands (the applicant) to conduct a Basic Assessment (BA) for the proposed mining permit.

As per the Mining Operational Plan (Appendix 5) mechanical mining will be utilized to mine the sand bar along the Tugela River. The mechanical mining method involves the use of various earth moving equipment such as an excavator which will be positioned onto the sand bar that is exposed and lift the surface sand and place it into an articulated dump truck (ADT). The ADT will traverse a fixed pathway along the sand bar and exit the river along an established access ramp. This sand will then be deposited into the stockpiling area before being taken off site for sale.

1.2 LOCATION OF THE PROJE CT The site of the proposed Hlanganisa Sand Mine is located along a portion of the Tugela River, approximately 6,5km west of the small town of Mandeni in the Ilembe District Municipality (Figure 1.1 and 1.2). A more in-depth locality and regional map are provided in Annexure A. Table 1.1 below contains a summary of the locality description.

Table 1.1: Summary of the proposed property details for the Hlanganisa River Sand Mine

Farm Name Remainder of Sunbury No. 6610 and Reserve no. 21 No 16882 Property Owners Hlanganisa Sands (Pty) Ltd; and Ingonyama Trust Board (A small portion of the mine layout extends into the river section of the neighboring Ingonyama property. No further intrusion into Ingonyama land will occur) SG Number N0FU0000000066100000 N0FU00000001688200000 Magisterial District Mandeni Local Municipality

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Ilembe District Municipality

Distance and Direction to nearest town 6,5km west from the outskirts of Mandeni Town

17km north west from the Tugela River Mouth

The proposed Tugela River Sand Mine is located outside the estuarine functional zone. Coordinates - Midpoint 29°10'17.78"S 31°20'9.09"E Property Zoning Agricultural

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Figure 1.1: Regional location of proposed Hlanganisa River Sand Mine

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Figure 1.2: Locality map of the proposed Hlanganisa River Sand Mine

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1.3 EIA REGULATIONS OF 2014 (AS AMENDED) TRIGGERED ACTIVITIES The Environmental Impact Assessment Regulations of 2014 (As amended), requires Environmental Authorisation from the competent authority (The Department of Mineral Resources – The Regional KwaZulu-Natal Branch) for activities listed in Government Notices R 327 which pertain to mining. Table 1.2 below identifies the activity in the Environmental Impact Assessment Regulations of 2014 (as amended) that has been triggered for the proposed mining permit application.

Table 1.2: Triggered Activities for the proposed Hlanganisa River Sand Mine

Activity Number Description Impact on the proposed project Any activity including the operation of that activity The proposed activity will which requires a mining permit in terms of section require a mining permit (area 27 of the Mineral and Petroleum Resources under 5ha) from DMR as it GNR Development Act, 2002 (Act No. 28 of 2002), involves a basic method of 327/Listing including associated infrastructure, structures and river sand mining. Notice 1 – earthworks directly related to the extraction of a Activity 21 mineral resource, including activities for which an exemption has been issued in terms of section 106 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002).

The triggered activity for the proposed Hlanganisa River Sand Mine is Activity 21 of GN 327 (Listing Notice 1). Listing Notice 1 requires a BA process to be conducted as per the EIA Regulations of 2014 (as amended).

1.4 TERMS OF REFERENCE Regulation 19 of the EIA Regulations 2014 (as amended), determines that a BA procedure must be followed for all activities listed in Government Notices R327 and R324. IDM Environmental has been appointed as the independent Environmental Consultant by the Applicant and will therefore be responsible for the BA procedures concerned with the proposed development. This includes formulating of the BAR, Environmental Management Plan (EMP), appointing experts in their respective fields to undertake specialist and engineering studies and the undertaking of a detailed stakeholder engagement process as per the EIA Regulations of 2014 (as amended) requirements.

1.5 APPROACH AND METHODO LOGY The overall approach to this assessment include the following activities: 16 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

 Apply for Environmental Authorisation from DMR for the proposed Hlanganisa Sand Mine (Tugela River).  Provide a detailed analysis of the proposed development, site and region sensitivity and the identification of potential impacts and associated mitigation measures.  Conduct a detailed Public Participation Process.  Comply with all legislative requirements in terms of the EIA Regulations and to provide the DMR with sufficient information to make an informed decision regarding the development.

1.6 REPORT STRUCTURE Appendix 1 and 4 of GN326 of the EIA Regulations of 2014 (as amended) were used in the formulating of the content and structure of the BA and EMP Reports. The BAR is structured as follows:  Section 2 consists of a summary of the proposed mining method to be utilised, the different project phases of the mine lifecycle, services supplied during mining operations, the need and desirability of the proposed Hlanganisa Sand Mine, as well as all alternatives considered as part of the application process.  Section 3 describes the Public Participation Process to be followed.  Section 4 provides a description of the receiving environment (baseline environment) that may be impacted by the activities to be authorised.  Section 5 consists of a detailed assessment of all the potential impacts of the proposed Hlanganisa Sand Mine and all alternatives taken into consideration. Mitigation measures for all possible impacts are further stipulated. These mitigation measures are legally binding on the Applicant during all phases of the mine lifecycle.  Section 6 provides a Summary of the recommendations and conclusion. Supporting documents, reports, correspondence and other relevant information are contained in various annexures and appendices attached to this Report.

1.7 APPLICABLE LEGISLATION, POLICIES AND GUIDELINES In addition to the EIA Regulations of 2014 (as amended), Table 1.3 below indicates all other applicable legislation and guideline documents that have been considered in the preparation of this Draft BAR.

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Table 1.3: Other Applicable Legislation to the proposed Hlanganisa River Sand Mine

Legislation Relevance to the development The Constitution The Constitution of the Republic The Constitution stipulates that everyone has the right to an of South Africa environment that is not harmful to their health or well-being; and the right to have the environment protected, for the benefit of the present Section 24 and future generations, through reasonable legislative and other measures. The Constitution has thus paved the way for environmental legislation and NEMA in South Africa post-1994 and the need to find a new approach to protecting the environment in an integrated and sustainable manner. This BAR embodies the principals of the Constitution in its formulation. Applicable Legislation Minerals and Petroleum The Minerals and Petroleum Resources Development Act, 2002 (Act Resources Development Act (No. No 28 of 2002) was developed to ensure that provision is made for 28 of 2002) equitable access to, and sustainable development of, South Africa’s mineral and petroleum resources and to provide insight, guidance and control for matters connected thereto. It seeks to provide management tools that ensure that all mining operations are undertaken in an environmentally sound manner according to government approved documents that hold the applicant responsible for any environmental degradation that their mining actions might cause.

This BA and EMP has been compiled in accordance with this Act. An application will be submitted to DMR for a Mining Permit and Environmental Authorization. National Environmental The BA is being undertaken as per the requirements of this Act. The Management Act (Act No. 107 of triggered activity for the proposed Hlanganisa Sand Mine is Activity 1998) 21 of GN 327 of Listing Notice 1.

and All possible impacts from the mining activity have been assessed and appropriate mitigation measures as per the impact hierarchy tool have

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The Environmental Impact been recommended. This to ensure the impacts from the mining Regulations of 2014 (as amended) activities are reduced to acceptable sustainable levels. National Water Act (No. 36 of A Water Use License Application (WULA) is in the process of being 1998) applied for from the Department of Water and Sanitation (DWS) due to the risk posed by the mining operations on the Tugela River and surrounding watercourses. Section 21 C (related to impeding or diverting the flow of water in a watercourse) and I (related to altering the bed, banks, course or characteristics of a watercourse) Water Uses will be applied for authorisation from DWS.

The Public Participation Process (PPP) of both the BA and WULA will run in parallel to each other, with the only difference being that the WULA PPP will be conducted over a 60 day period. All WULA documentation will be available for review on the IDM Consultants website Home page. National Environmental The objectives of this Act are (within the framework of NEMA) to Management: Biodiversity Act provide for: (No. 10 of 2004)  The management and conservation of biological diversity within the Republic of South Africa and of the components of such diversity;  The use of indigenous biological resources in a sustainable manner; and  The fair and equitable sharing among stakeholders of benefits arising from bio-prospecting involving indigenous biological resources.

Furthermore, NEMBA specifies that a person may not carry out a restricted activity involving either: a) A specimen of a listed threatened or protected species; b) A specimen of an alien species; or c) A specimen of a listed invasive species without a permit.

Accordingly, no nationally protected species were located on site.

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Alien plant species will be required to be removed from the site as per the Alien Management Plan contained in the EMP (Appendix 1). The removal of alien species will take place prior to site establishment, during mine operation and finally after closure. The ECO (during operation) and Mine Manager will ensure compliance with this. National Environmental The Applicant is required to minimize the generation of waste Management: Waste Act (No. 59 created. All waste generated on site will need to be dealt with of 2008) according to the EMP (Appendix 1). Limited waste volumes will be generated during the different phases of the proposed Mine, which will be disposed of at a registered landfill site. Key to the limiting of waste is appropriate training programmes being implemented and enforced. Environmental Management: Air Mitigation measures to control air and dust pollution will be Quality Act (No. 39 of 2004) implemented during the different phases of the mine lifecycle as per the EMP (Appendix 1) to ensure compliance with this Act. National Forests Act (No. 84 of In terms of section 15(1) of the National Forests Act (NFA), no 1998) person may cut, disturb, damage or destroy any 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 product derived from a protected tree, except under a licence or exemption granted by the Minister to an applicant and subject to such period and conditions as may be stipulated. National Veld and Forest Act (No. The purpose of this Act is to prevent and combat veld, forest and 101 of 1998) mountain fires throughout the Republic. The Act provides for a variety of institutions, methods and practices for achieving this purpose. Firefighting equipment will be available on site during the different phases of the mine lifecycle. Conservation of Agricultural To provide for control over the utilization of the natural agricultural Resources Act (No. 43 of 1983) resources of the Republic in order to promote the conservation of the soil, water sources and the vegetation. The Act further requires the combating of weeds and invader plants.

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Mine Health and Safety Act The Mine Health and Safety Act, 1996 (No 26 of 1996) provides for (No. 26 of 1996) the protection of health and safety of employees and other persons at mines and serves- • To promote a culture of health and safety; • To provide for the enforcement of health and safety measurements; • To provide for appropriate systems for employee, employer and state participating in health and safety matters; • To provide effective monitoring systems and inspections, investigations and inquiries to improve health and safety; • To promote training and human resources development; • To regulate employers’ and employees’ duties to identify hazards and eliminate, control and minimise the risk to health and safety; and • To entrench the right to refuse to work in dangerous conditions. Occupational Health and Safety The employer needs to manage his/her staff and crew in strict Act (No. 85 of 1993) accordance with the Occupational Health and Safety Act in order to prevent injuries to the staff. National Heritage Resources Act This Act has been put into place to protect and conserve heritage (No. 25 of 1999) resources. If anything of heritage importance is found on the proposed site, the operation will be halted and a suitably qualified specialist will be contacted. In consultation with the Applicant no heritage resources were located on site. Thus no Heritage assessment was undertaken. It is highly unlikely that any heritage resources will be located on site due to its small size, transformed nature and the majority of operations occurring within the River itself. KwaZulu-Natal Heritage Act (No. This Act has been put into place to conserve, protect and conserve 4 of 1998) heritage resources in the KZN province. If anything of archaeological significance is uncovered, a specialist will be contacted. In consultation with the Applicant no heritage resources were located on site. Development Framework and Plans KZN Provincial Spatial Alignment of the proposed mine to the KZN Provincial Spatial Development Framework Development Framework (PSDF) has been made. The PSDF is a long term (i.e. > 5 year) spatial framework from which various plans

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will be implemented. It is informed by the NDP and related spatial policies, and takes its strategic direction from the KZN’s development strategy and related policy frameworks. It conveys the KZN’s spatial agenda to National and Provincial departments, as well as state owned enterprises (SOEs) so that their sector plans and programmes are grounded in a sound and common spatial logic. Part of this plan is development and growth and the promotion of sustainable job creation and local economic development in rural underdeveloped areas. KZN Provincial Growth and The proposed development is aligned with the PGDP, as it addresses Development Plan the first goal of the PGDP which is that of job creation and local economic development. Guideline Documents Public Participation Guideline in Guideline document for Public Participation Process for all EIAs. terms of National Environmental This document was used to guide the Public Participation Process for Management Act, 1998 - the proposed application and ensure the stakeholder engagement Department of Environmental process is inclusive. The aim is to communicate as early as possible, Affairs, 2017. with as many people as possible through as many different channels as possible. Guideline on Need and This Guideline was utilised in the formulation of the needs and Desirability - Department of desirability of the proposed application. Environmental Affairs, 2017. Mining and Biodiversity The Guideline interprets the best available biodiversity knowledge Guideline: Mainstreaming and science in terms of the implications and risks for mining in a biodiversity into the mining sector practical guideline and user-friendly decision support tool for both – industry and regulators to ensure that biodiversity issues are Department of Environmental consistently incorporated into the decision making processes for Affairs, Department of Mineral mining projects. The Guideline was used to ensure the proposed Resources, Chamber of Mines, Hlanganisa Sand Mine embodies the principals of sustainability and South African Mining and integrated environmental management. Biodiversity Forum, and South African National Biodiversity Institute, 2013.

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2 DESCRIPTION OF PROPOSED ACTIVITIES

2.1 ACTIVITY DESCRIPTION EXTENT OF THE MINE The total extent of the proposed mining permit area is a 4,15ha section over the Remainder of Sunbury No. 6610 and Part of Reserve no. 21 No 15841 along a section of the Tugela River. Please see proposed layout of the Hlanganisa Sand Mine (Tugela River) in Figure 2.1 below.

Figure 2.1: Schematic layout of the proposed Hlanganisa River Sand Mine

SITE PLANNING Before the mine site establishment, operation and closure can commence, careful planning must take place which will lay the foundations for the abovementioned phases. This will ensure that impacts can be identified at the earliest possible stage and appropriate mitigation measures employed. This in order to prevent/ minimise impacts to acceptable/low levels. The Basic Assessment Report (BAR) and associated Appendices, forms one part of this planning process. Before site establishment and operation can occur, it is of the utmost importance that the Applicant and Mine Manager must ensure plans are in place to

23 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

implement mitigation measures in the EMP (Appendix 1) and that rehabilitation is an on-going process, which is not solely defined to the Closure phase.

SITE PREPARATION AND ESTABLISHMENT No permeant infrastructure will be developed on site, however the site will however be prepared for mining commencement. These activities will include:  Environmental training and awareness for all employees;  The demarcation of the mining site and strict ‘no-go’ areas (especially around the surrounding watercourses and riparian vegetation. These may not be impacted on under any circumstances). This includes clearly marking the mining site boundaries by the placing of painted white rocks and/or pegs;  The erecting of signage and fences. This includes erecting of signage warning the public that mining activities are taking place on the property and the provision of a contactable number on this sign in the event of an emergency situation. Access to the mining area must as far as possible be further restricted;  The placement of a portable toilet (as far away from the River and surrounding watercourses as possible), bins (this must be secured and emptied regularly), spill kits and first aid kits. There must be a dedicated first aider on site at all times;  The stockpiling of fertile topsoil for use in rehabilitation of the stockpiling area;  The preparing of the stockpiling area outside the relevant freshwater buffers and riparian zone. The stockpiling area was chosen as it is located adjacent to the existing access ramp to the River and at the end point of the existing access track. The stockpiling area is located on transformed land farmed with sugarcane;  Preparing the existing track for movement of heavy vehicles;  Facilitating the access point/s into the Tugela River sand bar. There is an existing access ramp leading from the proposed stockpiling area/existing dirt track to the Tugela River sand bar (Figure 2.2). This access ramp will undergo upgrading in order to be utilised during mining operation. The usage of this access ramp will necessitate the need to clear further riparian vegetation as it is already established;  Preparing equipment and vehicles for operation;  Ensuring that there are no protected species or endangered vegetation species on site; and  Implementing erosion and stormwater control on site. This includes, but not limited to:  The Access track;  The Access Ramp to the River;  The stockpiling area; and  Any further areas subject to stormwater runoff and erosion.

24 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Berms and trenches (silt fences and traps) will be placed on the downward slope of the stockpiling area. This to prevent uncontrolled runoff into surrounding watercourses.

Figure 2.2: Pathway of the existing access ramp to the Tugela River sand bar

OPERATION This section should be read in conjunction with the Mining Operational Plan in Appendix 5. The mechanical mining method involves the use of various earth moving equipment to systematically remove sand from the River sandbar. This method of mining can only be used when the sand bars of the river are exposed and accessible from the access ramp. The excavator will be positioned onto the sand bar that is exposed and evacuate the surface sand and place it into an articulated dump truck (ADT). The ADT will traverse a fixed pathway along the sand bar and exit the river along an established access ramp that

25 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

conjoins the deposited sand bar to the river bank. The ADT will then deposit the material into the designated stockpiling area. The sand will then be taken to the market to be sold. No processing will take place on site.

The use of mechanical diesel driven equipment on the exposed sand banks will require the strictest possible equipment maintenance regime to ensure that absolutely no fluids associated with typical earthmoving equipment are leaked into the river system. The daily and shift check procedures will disqualify any piece of equipment from being deployed onto the sandbar should any leakages or other mechanical deficiency give rise the any possibility of fluids being deposited into the river system. The exhaust fumes generated by the mining equipment will be limited by ensuring that all OEM scheduled services are competed in accordance with the suppliers recommendations and the observation of any excessive exhaust fumes will be grounds for removing such equipment from service until such emissions are curtailed and contained to within acceptable limits.

SEDIMENT REPLENISHMENT A key finding of the Freshwater Assessment in Appendix 3 (results discussed in greater detail in Section 4 of this Report) was that in order for the mining operations to be sustainable, mining volumes must be strictly monitored and must be based on the measured annual replenishment of sand as determined by a suitably qualified professional. River sand extracted must not exceed that replaced through natural sedimentation processes.

It must be noted when the Freshwater Report was formulated, mining of both the sand bar and the River bed by a floating barge system was proposed. However, mining will only involve mining of the exposed sand bank. This sand will be replenished during the rainy season and this annual replenishment rate will not be exceeded when only mining the sand bar. No mining of the active channel will take place.

DURATION OF ACTIVITY The mine will operate for a period of two years from the time of issuing of a mining permit, and thereafter will become renewable for three further consecutive one-year periods, which totals a maximum five year operational period.

MINE CLOSURE AND REHABILITATION After the five year period has been completed, the Applicant is required to implement a Mine Closure and Rehabilitation phase. This involves:  Removing of all temporary infrastructure (Portable toilets and bins), equipment (mining vehicles), signage, fencing and demarcation beacons;

26 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

 The rehabilitation of the stockpiling areas and access points into the Tugela River. This includes the planting of grasses and removal of invasive alien species;  The continuation of erosion control if required; and  The monitoring of the rehabilitation process to ensure successful revegetation, the prevention of erosion and spread of invasive alien plants.

2.2 SERVICE PROVISION Limited services are required for the proposed Hlanganisa Sand Mine (Tugela River). These include: Water: Drinking water for consumption will be provided to all workers on site. This will be sourced from the local municipal supply. Electricity: to be provided by a generator (if required). Sewage: The provision of a portable toilet. The toilet will be regularly serviced. Solid waste disposal: A bin will be provide onsite for waste disposal. It is not envisioned that large quantities of waste will be generated due to the nature of activities. Hazardous waste: A separate bin must be available for hazardous waste (if required).

2.3 ACCESS TO THE MINING SITE Access to the proposed site is easily accessible from the N2 Freeway. From the N2 Freeway, one takes the R102 exit before crossing the Tugela River travelling north bound (Figure 2.3). Travel westwards towards the establishment of Sand Soucis. Carry on past the establishment for approximately 3 km and turn right onto a gravel farm road for 8km until the site is reached. This access route will be further utilised when traveling to market to sell the sand.

27 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Figure 2.3: Access from the N2 to the proposed Hlanganisa River Sand Mine

Furthermore, there is an existing informal access track on site which will be utilised in order to gain access to the stockpile area and the river access ramp. This access track is established and will require maintenance to keep it in good order. There further exists an informal river access ramp (Image 2.1) leading from the stockpiling area to the Tugela River itself. This access ramp will be used during mining operations to gain access to the river. The access ramp will however require upgrading to ensure heavy vehicle usage.

Image 2.1: Existing access ramp to the Tugela River 28 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

2.4 SOCIAL RESPONSIBILITY OF THE APPLICANT As part of the Mines social responsibility plan, the mine will not only provide building sand to the local community, but will assist in community upliftment programmes. Currently the local schools cannot handle the large volume of students. The Applicant has had requests from multiple schools in the area to assist in upgrading their existing facilities.

Hlanganisa Sands with the cooperation of Doornkop Sugar Estate Limited, have allocated land for the extension of the Saint Christopher’s Primary School. Currently the school is not able to service the demand of local scholars. The upgrade has been formally lodged at the relevant municipality and has been accepted in the local development plan.

Furthermore, local community builders will receive the following benefits:  Building expenses will be reduced for local community members; and  Local contractors will have access to easily accessible raw materials.

2.5 NEED AND DESIRABILITY OF THE PROPOSED TUGELA RIVER SAND MINE  The need for the proposed mining activities The proposed project will co-operate and collaborate with the Traditional Council, local community members, schools, emerging farmers and contractors from the outset of the initiative. The operation aims to provide high quality building sand at a reasonable price to local people while creating jobs, assisting small businesses and encouraging development in the local community. Currently building sand is in high demand by local construction and development companies, small contractors and builders as well as government and municipal projects. Therefore, the proposed Hlanganisa Sand Mine will help address this shortage of building sand. The provision of sand will result in broader socio-economic benefits including job creation and local economic development through the availability and affordability of building sand in the area and secondary job opportunities. The area has been affected by a drastic loss of job opportunities leaving local community members unemployed. Many companies in the Isithebe Industrial Development have closed, leaving thousands of local people and their dependants without an income. The sugar industry (the dominant industry in the area) has recently seen large financial troubles resulting in the loss of jobs in the area. Farmers are looking to other crops and opportunities. The proposed Hlanganisa River Sand Mine will further aid the property owner in diversifying economic generation options without comprising the sugarcane plantation that makes up the majority of the property. This is important as the sugarcane industry

29 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

has been in decline for the last 20 years and it is important for farmers to explore alternative income generation opportunities.  The desirability of the proposed site The site is desirable for a number of reasons:  The site has existing access tracks which will be utilised during mining operations. No clearance of vegetation is thus required.  The site has an existing access ramp from the access track to the river sand bed. This was most likely created during the operation of the municipal water pump station. No riparian vegetation will thus be removed when accessing the Tugela River.  The site is already disturbed due to the surrounding agricultural activities and the adjacent former iLembe District San Souci Water Treatment Works. The stockpiling area is positioned to be located on a portion of land formally cultivated with sugarcane. The stockpiling area is further outside the respective buffers.  The mining site is located adjacent to a large labour pool. These communities are largely rural in nature with systemic levels of unemployment and poverty.  The mining site is located close to a large growing market.  The proposed site does not contain any protected flora and fauna.

2.6 CONSIDERATION OF ALTERNATIVES Alternatives are seen as different means of meeting the general purpose and need of a proposed activity. Alternatives could include, amongst others, the following:  Activity Alternatives: This requires a change in the nature of the proposed activity. This alternative is most appropriate at a strategic decision-making level.  Location Alternatives: Alternative locations for the entire project proposal, or for components of the project proposal.  Layout Alternatives: This alternative allows different spatial configurations of an activity on a specific site.  Scheduling Alternatives: Also referred to alternative phasing options for the development. This alternative considers different phasing options during the implementation of the development.  Infrastructure/ Input Alternatives: Also referred to as technological or equipment alternatives. This option considers various alternatives that will result in the same end result.

ACTIVITY ALTERNATIVES Activity alternatives refer to the consideration of alternatives requiring a change in the nature of the proposed activity to be undertaken. No further activity alternatives were considered. The property already 30 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

contains extensive sugarcane fields which leaves few further income opportunities available. The Tugela River flows adjacent to the property and provides the sugarcane farmer with alternative income generation options, without comprising sugarcane production.

LOCATION ALTERNATIVES Only portions of the Tugela River adjacent to the Applicants property were considered for mining. No other locational alternatives were considered.

LAYOUT ALTERNATIVES The proposed layout for the sand mining activity is shown in the sketch plan (Annexure B hereto). No site office is required. A portable toilet will be placed away from the vegetation or surrounding watercourses, which will be utilised by the mine’s employees only. The site has been minimised to impact the smallest possible area. The site does not allow for functional layout alternatives due to its small size. No processing will take place on site as it would be an additional environmental impact and is not preferred. The site layout was chosen on the property as it is already disturbed and has the best access to the Tugela River due to the existence of a former iLembe District San Souci Water Treatment Works. Furthermore, the current site layout will result in no vegetation being removed.

SCHEDULING ALTERNATIVES The sand mining activity will commence as soon as the DMR issues the necessary mining permit and any and all other associated statutory authorisations are secured. The sand mining intensity will be based on the demand for silica sand in the area, and subject to weather conditions. Furthermore, mining will only occur when the sand bar is exposed and accessible. Mining will take place Monday to Friday during specified work hours. No mining may take place outside these specified times and after sunset. Mining will be avoided in heavy rains.

INFRASTRUCTURE/INPUT ALTERNATIVES Other than bins and a portable toilet, no other infrastructure is required. In terms of input alternatives, it was initially proposed that a floating barge system will be used to mine sand off the river bed. The floating barge system involves the usage of a floating barge system which is attached to a delivery pipe that snakes along the river surface and delivers sand from the dredge to the shore. The pipe is kept buoyant above the river bed and floated above the surface by means of a series of floats connecting from the floating barge. The head of the pipe contains a jet and suction mechanism which jets out water to agitate the sand, which is then simultaneously sucked back into the pipe. This system was excluded due to the additional impacts on the Tugela River and the availability of sand on the sand bar.

“NO-GO” ALTERNATIVE

31 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

The “no-go” alternative should, in all instances, be considered as part of the EIA process. This scenario assumes that the activity does not proceed, implying a continuation of the current situation. Should this permit not be granted, there will be no socio-economic benefits i.e. no job creation and no local economic development. Wetland 1 and 2, as well as Drainage Line 1 and 2 have already been significantly degraded as a result of surrounding sugarcane cultivation and associated disturbance. As a result, an improvement of the PES and EIS of the features is considered to be unlikely without significant efforts to rehabilitate. It is therefore highly likely that the current status quo of these watercourses will remain unchanged should the sand mining not prove feasible. With the implementation of a closure and rehabilitation plan, these watercourses will be rehabilitated with the planting of indigenous species and the removal of invasive aliens. This may result in an improvement of these systems.

32 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

3 PUBLIC PARTICPATION

3.1 REQUIREMENTS OF THE E NVIRONMENTAL IMPACT ASSESSMENT REGULATIONS OF 2014 (AS AMENDED) The proposed Public Participation Process (PPP) to be followed for the Hlanganisa Sand Mine (Tugela River) Basic Assessment includes:  Identifying and compiling a comprehensive list of potential Interested and Affected Parties including:  The Competent Authority;  Relevant National and Provincial government authorities;  Local Municipal authorities (both district and local);  The local councillors;  Quasi-government institutions  Traditional leadership;  Relevant government state entities/parastatals;  Neighbouring property owners;  Neighbouring communities;  Conservation organisations; and  3rd party stakeholders  Potential Interested and Affected Parties will be notified of the proposed Mining Permit Application through:  Notification emails will be forwarded to all I&APs;  Registered mail will be posted to select I&APs;  Site notices will be placed on the proposed mining site, access track; and local municipal offices. These site notices will be printed on A3 paper and will also be laminated to ensure they do not get destroyed in adverse weather conditions; and  An advert will be published in one local newspaper.  A copy of the BAR: Draft 1 and all appendices will be made available on the Consultants website for download and review. A link to the website will be provided via email notification.  A hard copy of the BAR: Draft 1 and all appendices will be available at the Mandeni Public Library for review.  A hard copy of the BAR: Draft 1 and all appendices will be forwarded to the Competent Authority for review.

33 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

 CD copies of the BAR: Draft 1 and all appendices will be couriered to relevant stakeholders where requested.  A Public open day will be held at the local Mathonsi Tribal Offices on the 24th of March 2020.  All comments and responses will be included in a Public Participation Report for review. Evidence of the PPP being conducted will further be provided as annexures to the Report. This will be provided to DMR with the final submission of the BAR.  As per the NEMA requirements, a PPP of at least 30 days will be conducted after the application for environmental authorisation form has been submitted to DMR. Furthermore, the DEA Public Participation Guideline will be used to guide the PPP.

3.2 COMMENTS AND RESPONSE REPORT Please see below example of comments and response report to be populated after the PPP has been conducted.

34 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Table 3.1: Public Participation Comments and EAP Responses table example to be utilised for final BAR Report Interested Represented Date Comments received Response and action provided by the Inclusion in BAR or EMP and Affected individual/of comment/s EAP or Party ficial were Additional EAP comments received

35 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

4 BASELINE ENVIRONMENT OF THE PROPOSED SITE

4.1 CLIMATE The climate of the region is sub-tropical with hot and humid summers and relatively mild and frost free winters. Rainfall in the region mostly occurs in the summer months of December to February, with the region experiencing a mean annual precipitation of between 900-1000 mm. The highest rainfall is in January (127mm) and the lowest rainfall is received in July (20mm). The reference potential evaporation (ETo) is approximately 1700 mm (Schulze, 2011), which exceeds the annual rainfall. This suggests a high evaporative demand and a water limited system. Mean annual temperatures are approximately 20 ºC, with an annual minimum temperature of 5 ºC and an annual maximum temperature of up to 40 ºC.

4.2 LANDSCAPE CHARACTERISTICS/EXISTING SITUATION The proposed Hlanganisa Sand Mine (Tugela River) site is located 18km inland from the Indian Ocean and is situated at an altitude of approximately 42m. The dominate land use surrounding the site is commercial sugarcane on the south west, tribal lands to the north and bushland to the south. There are no settlements on site or immediately adjacent to site, with the nearest settlement being Sans Soucis, which is located 1km to the south of the proposed mine. The site itself consists of commercial sugarcane (Image 4.1), with some tribal lands and natural grassland pockets on the northern banks of the river. The mine itself is located on the southern bank of the Tugela River. A former iLembe District San Souci Water Treatment Works is located adjacent to the proposed mine site (Image 4.2). There are existing access tracks that lead to this treatment works, as well as an access ramp leading to the River itself.

Image 4.1: The greater portion of the applicant’s property is cultivated with sugarcane 36 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Image 4.2: The former iLembe District San Souci Water Treatment Works

4.3 GEOLOGY AND SOILS The mine extent is indicated to be underlain by Natal Group Sandstone which is characterised by generally reddish, feldspathic and micaceous sandstone. Numerous soil profiles were identified throughout the site. Some of the soil forms identified on the site (outside of the wetland areas) were Glenrosa soils (Orthic A- horizon underlain by Lithocutanic B-horizon), Hutton soil forms (Orthic A-horizon underlain by red a- pedal B-horizon) and Bonheim (Melanic A-horizon underlain by Pedocutanic B-horizon).

4.4 FLORA Please note, this section should be read in conjunction with the specialist Report in Appendix 3 of this application. The proposed Hlanganisa Sand Mine (Tugela River) is not located within a formally or informally protected area, or with a focus area for protection (NBA, 2011 and the NPAES, 2010). However, according to the Vegetation Specialist Report (Appendix 3) the mine extent is located within a Critically Endangered Ecosystem as listed by the National List of Threatened Terrestrial Ecosystems. It should be noted that 37 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

mapping data for threatened terrestrial ecosystems represents the original extent of listed ecosystems in 2004 or earlier; in other words, natural areas which have subsequently been converted to agriculture, mining and urban areas have been included. The mine extent is therefore not presently representative of the natural habitat associated with this listed ecosystem. According to the updated national vegetation map (2018) and provincial vegetation mapping (Scott-Shaw and Escott, 2011), the mine extent is located within the Savanna Biome, the Sub-Escarpment Bioregion, and the KwaZulu-Natal Hinterland Thornveld vegetation type. This vegetation type occurs in KwaZulu-Natal and is characterised by open thornveld dominated by Acacia species on undulating plains found on upper margins of river valleys (Scott-Shaw and Escott, 2011). The KwaZulu-Natal Hinterland Thornveld is listed as Vulnerable at a national level (Mucina and Rutherford, 2006), however it is considered Least Threatened within the KwaZulu-Natal Province (Jewitt, 2011).

According to the KZN TSCP (2010) the majority of the mine extent is located within a Biodiversity Area (Figure 4.1) with exception of the central portion of the existing access road which is located within a transformed area. Biodiversity Areas are not open for wholesale development as important species are usually located within them and should be accounted for in the EIA process (Ezemvelo KZN Wildlife, 2010). However, it must be noted that the majority of the mining activities will occur within the Tugela River itself. Furthermore, the existing access tracks to the site and the existing access ramp to the River will be utilised. Lastly, the stockpiling area will be located outside the respective buffers and over a portion of the property currently cultivated with sugarcane. Therefore no riparian vegetation will be lost in the process. The Vegetation Specialist thus concluded that no important vegetation related biodiversity features or species are likely to be lost due to the current mine design and as a result of the proposed strict mitigation measures as listed within this BA Report.

38 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Figure 4.1: The location of the mine extent within areas which are indicated as Biodiversity Areas and transformed areas by the KZN TSCP (2010)

Four broad vegetation communities were encountered by the Vegetation Specialist during the site visit. These included the transformed terrestrial vegetation community, the riparian vegetation community, the wetland vegetation community and the ephemeral drainage line vegetation community.

Terrestrial vegetation associated with the proposed soil stockpile area has been completely transformed as a result of historical and current cultivation and earth moving activities and can no longer be considered representative of the Vulnerable KwaZulu-Natal Hinterland Thornveld vegetation type. The proposed soil stockpile area is presently covered in its entirety by sugarcane with scattered individuals of alien species including Ageratum conyzoides (Ageratum) and Bidens pilosa in between the sugarcane. There are surrounding pockets of natural forest along the River bank. These forest pockets will not be impacted on by the sand mining activities.

39 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

The riparian and wetland vegetation descriptions are further elaborated under Section 4.5 of this Basic Assessment Report.

4.5 FRESHWATER CHARACTERISTICS Please note, this section should be read in conjunction with the specialist Report in Appendix 3 of this application. The mine extent falls within the North Eastern Uplands Ecoregion, within the Thukela Water Management Area (WMA) and within the Lower Thukela sub-Water Management Area as defined by NFEPA (2011). The quaternary catchment indicated for the mine extent is V50C and the Wetland Vegetation Group for the area is the Sub-escarpment Savanna which is listed as Endangered within the region.

Five watercourses are considered to be at risk as a result of the proposed sand mining activities (Figure 4.2). These watercourses include the Tugela River and associated riparian area, two wetlands (hereafter referred to as wetland 1 and 2) and two ephemeral drainage lines (hereafter referred to as drainage line 1 and 2). Sand mining will take place within the channel of the Tugela River; a soil stockpile area is proposed adjacent to wetland 2 and drainage line 2; and an existing informal farm track traversing the wetlands and drainage line 1 will be utilised to access the proposed stockpile area and the proposed sand mining area .

Figure 4.2: Watercourses considered to be at risk as a result of the proposed sand mining activities 40 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

 The Tugela River

The portion of the Tugela River associated with the mine extent is a lower foothill river characterised by a lower gradient, mixed-bed alluvial channel with sand and gravel dominating the bed. Steeply incised riverbanks occur to either side of the wide active channel which ranges from approximately 100m-150m in width. At the time of the Freshwater assessment (the dry season) the active channel of the river was characterised by extensive sand bars with flow largely confined to a channel (approximately 40 -60m wide) running through the sand bars. However, the river is a flood driven system and flow is usually spread across the entirety of the channel during the wet season.

The river has a well-defined woody riparian vegetation community has established on the banks of the river with a composition and physical structure distinct from vegetation communities of adjacent terrestrial areas. The riparian vegetation community was dominated by indigenous tree and shrub species including Ficussycamorus (Sycomore Fig), Vachellia robusta subsp. clavigera (River Thorn), Trema orientalis (Pigeonwood), Spirostachys africana (Tamboti), Pavetta lanceolata (Weeping Brides Bush), Scutia myrtina (Katdoring), Ehretia rigida (Puzzle Bush), Grewia occidentalis (Cross-berry), Gymnosporia buxifolia (Common Spikethorn), Ludwigia octovalvis (Mexican Primrose-willow), Salix mucronata (African Willow), Searsia pyroides (Common Current), Trichilia dregeana (Forest Mahogany) and Sesbania sesban (River Bean). However, disturbance as a result of surrounding agricultural activities has resulted in the encroachment of alien and invasive species such as Solanum chrysotrichum (Devil’s Fig), Chromolaena odorata (Triffid Weed), Ricinus communis (Castor-oil Plant), Senna bicapsularis (Rambling Cassia), Senna pendula (Easter Cassia), Lantana camara (Lantana), Melia azedarach (Syringa) and Ageratum conyzoides (Ageratum). Alien vegetation encroachment is most severe on the outer boundary of the riparian zone in areas in which disturbance as a result of surrounding sugarcane cultivation and the development of the San Souci Water Works has occurred.

 Wetland 1 and 2

Wetland 1 and 2 are located on the gently sloping hillside above the riparian zone of the Tugela River and are best defined as seep wetlands. These wetlands have been significantly degraded and modified as a result of surrounding agricultural activities.

The cultivation of sugarcane within and surrounding the wetlands, the excavation / erosion of channels within the wetlands, and the development of informal access roads through the wetlands has resulted in the loss of wetland habitat and function, in the modification of flow patterns, and in the proliferation of alien and invasive species such as Ageratum conyzoides and Bidens pillosa (Black Jack). However, common

41 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

indigenous obligate and facultative wetland species such as Imperata cylindrica (Cotton-wool Grass), Commelina benghalensis (Wandering Jew), Cyperus ssp. and Pycreus polystachyos (Bunchy Sedge) are still present, and hydromorphic soils with signs of mottling and gleying were encountered upon hand augering.

 Drainage line 1 and 2

Drainage lines 1 and 2 are also located on the gently sloping hillside above the riparian zone of the Tugela River. These drainage lines are ephemeral in nature and are only likely to contained surface water after significant rainfall events.

The cultivation of sugarcane on the banks of the drainage lines and associated disturbance has resulted in the loss of riparian habitat from the features. Drainage line 1 completely lacked a riparian zone and the riparian zone of drainage line 2 was poorly defined and significantly encroached by alien and invasive species such as Chromolaena odorata, Ageratum conyzoides, Lantana camara, Solanum chrysotrichum and Psidium guajava (Wild Guava). However, indigenous tree and shrub species including Vachellia robusta subsp. clavigera, Ficus sycomorus and Searsia pyroides were also encountered scattered within the riparian zone.

An increase in runoff from irrigated sugarcane within the catchment, and from hardened road surfaces traversing the features, has resulted in the alteration of the natural hydrological regime of the drainage lines and in the significant erosion of the channels of the features.

 Additional watercourses within 500m

Additional watercourses identified within the DWS 500m regulated area were desktop delineated and the risk to these features as a result of the proposed mining related activities were considered (Figure 4.3). All additional watercourses are located a considerable distance (more than 30m) upslope of the mine extent and it is therefore the opinion of the Freshwater specialist that negligible risk is posed to these features provided that the mitigation measures as listed in this report are strictly adhered to.

42 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Figure 4.3: Watercourses located within the DWS 500m regulated zone

THE PRESENT ECOLOGICAL STATE AND ECOLOGICAL IMPORTANCE AND SENSITIVITY SCORES Please note, this section should be read in conjunction with the specialist Report in Appendix 3 of this application.

4.5.1.1 The PES of all impacted watercourses The River IHIA was applied in order to determine the PES of the Tugela River and drainage lines 1 and 2. The IHIA is founded on the assessment of two separate modules of a watercourse, namely riparian habitat and instream habitat.

The Tugela River is an extensive linear system which extends kilometres upstream and downstream of the mine extent. However, for the purpose of this assessment it was only considered necessary to determine the PES of the reach of the river which is considered to be at risk of impact as a result of the propose sand mining activities. The IHIA assessment was therefore only applied to portions of the river associated with the proposed mine extent area as well as to portions extending 500m upstream and downstream of the mine extent.

43 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Due to a lack of riparian habitat, the riparian habitat module of the IHIA could not be applied to drainage line 1, and to some degree aspects assessed as part of the instream assessment would not be entirely applicable either. However, to obtain an estimated PES category for this feature, the IHIA instream module was applied.

The IHIA scores calculated for each of the watercourses are listed below:  The instream and riparian scores calculated for the Tugela River falls within IHIA Category C (Moderately modified - a loss and change of natural habitat and biota have occurred but the basic ecosystem functions are still predominantly unchanged).  The instream score calculated for drainage line 1 falls within IHIA Category D (Largely modified – a large loss of natural habitat, biota and basic ecosystem functions has occurred).  The instream and riparian scores calculated for drainage line 2 fall within IHIA Category C (Moderately modified).

The PES of wetlands 1 and 2 was determined with the use of the WET-Health Tool. This technique attempts to assess the deviation of a wetland from its natural / reference state and takes into consideration the hydrological, geomorphological and vegetation health of wetlands in three separate modules. The overall wetland health scores calculated for the wetlands fall within PES Category E (Seriously modified - The change in ecosystem processes and loss of natural habitat and biota is great but some remaining natural habitat features are still recognisable). The PES of the wetlands is likely to remain stable over the next five years should the current sugarcane cultivation activities continue.

4.5.1.2 EIS of all impacted watercourses The EIS method of assessment for rivers and ephemeral drainage lines is based on the approach adopted by the DWA as detailed in the document “Resource Directed Measures for Protection of Water Resources” (1999).  Tugela River According to the Desktop PESEIS assessment (DWS, 2014), fish and invertebrate species expected to occur within the river have a very high intolerance to changes in flow and flow related water quality. However, due to the perennial nature of the river, which is deep with regular periods of high flows, small changes in flow and water quality are not likely to have a significant impact on instream and riparian habitat and biota.

The stretch of the Tugela River associated with the mine extent is characterised by an alluvial bed and no bedrock, boulders or rocky riffles or rapids were encountered. Furthermore, the riparian habitat was limited 44 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

to indigenous woody vegetation with a moderate level of alien infestation. The overall habitat diversity associated with the river is therefore considered to be moderate. No formal assessment of species / taxon richness was undertaken, however, due to the limited impacts to freshwater habitat, it was assumed that species / taxon richness is moderately high.

The overall sub-quaternary reach of the river was indicated to fall within a high EIS Category by the Desktop PESEIS assessment drafted by the DWS (2014). However, this desktop assessment considered an extensive area of the river which extends approximately 30km downstream of the portion of the river within which sand mining activities are proposed, and is therefore not considered to be representative of the EIS

 Drainage line 1 and 2 The drainage lines are only likely to flow for short intervals of time after sufficient rainfall and are not associated with a diversity of habitat units such as riffles, runs or rapids. Furthermore, drainage line 1 lacks a riparian zone entirely and drainage line 2 is associated with a poorly defined riparian zone. The poor diversity of instream habitat units and the non-existent / poorly defined riparian areas decreases the ability of the drainage lines to support a high diversity of species or to provide refugia to aquatic biota. The poor diversity of habitat units also decreases the sensitivity of the features to flow changes and flow related water quality changes. Furthermore, the lack of flowing water for the majority of the year decreases the importance of the drainage lines in terms of the provision of migration corridors for some aquatic biota.

The drainage lines calculated an overall low EIS score (delineations that are not unique at any scale. These rivers (in terms of biota and habitat) are generally not very sensitive to flow modifications and usually have a substantial capacity for use). However, these features do still provide valuable functions such as attenuation of floodwaters and retention of excess sediments. The unnecessary disturbance of the drainage lines must therefore be avoided.

 Wetland 1 and 2 The EIS method applied to wetlands is based on the assessment tool developed by Rountree et al. (2014) and was used in order to determine the EIS of wetland 1 and 2, incorporating the traditionally examined criteria used in EIS assessments of other water resources by DWA and thus enabling consistent assessment approaches across water resource types.

The following was noted in the Freshwater Assessment:

45 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

 Vegetation associated with the wetlands has been significantly degraded as a result of the disturbance associated with the cultivation of sugarcane. It is therefore considered highly unlikely that the features will support rare and endangered species, or populations of unique species.  The wetlands are not located within a formally protected nature reserve and therefore do not have any protection status, however, the wetland vegetation group for the area, the Sub-escarpment Savanna, is considered to be Endangered.  The ecological integrity of the wetlands (PES) has been seriously modified.  The natural hydrology of the wetlands has been significantly altered as a result of extensive sugarcane cultivation within their catchments. Furthermore, the wetlands are dominated by alien and invasive vegetation and common indigenous pioneer species. The sensitivity of the wetlands to changes in water quality, floods and low flows/dry season is therefore considered to be low. Wetland 1 and 2 are considered to be of a low EIS (wetlands that are not ecologically important and sensitive at any scale. The biodiversity of these systems is ubiquitous and not sensitive to flow and habitat modifications. They play an insignificant role in moderating the quantity and quality of water of major rivers).

4.6 ICHTHYOLOGICAL OF THE TUGELA RIVER Please note, this section should be read in conjunction with the specialist Report in Appendix 4 of this application.

The section of the Tugela River to be mined for sand shows a sound diversity of habitat; with areas of high flow, smaller pools and some points of in-stream vegetation. These features are all conducive to increasing diversity in fish assemblages. However, it is also noted that the downstream meander habitat has been significantly affected by sedimentation. It follows that mining operations, if undertaken with due management at this point, will hopefully promote increased habitat diversity and increased diversity in fish diversity within the system due to this removal of sedimentation.

The following results were obtained from the sampling regimen employed at site. Labeo molybdinus (Image 4.3) were found to be common within the system, primarily on account of the seasonal migration of this species, while Labeobarbus natalensis were also considered to be common. Also noted in the system is Enteromius trimaculatus (Image 4.4), Enteromius viviparus, Oreochromis mossambicus, as well as the common African sharptooth catfish.

46 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Other species not caught during the sample, but may exist on site include Awaous aeneofuscus, Anguilla bengalensis, Anguilla marmorata, Anguilla mossambica, Amphillius natalensis, Eleotris fusca, Enteromius viviparous, Glossogobius callidus, Glossogobius giuris, Labeo rubromaculatus and Oreochromis mossambicus.

Image 4.3: L molybdinis caught within the sample site

47 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Image 4.4: E trimaculatus caught within the sample site

4.7 SITES WITH ARCHAEOLOG ICAL INTEREST No archaeological features were located on site or adjacent to the proposed mining site. Therefore no further heritage investigations were undertaken. If anything of heritage importance is located, a suitably qualified heritage person will be contacted. However, this is extremely unlikely due to the transformed nature of site.

4.8 SOCIAL-ECONOMIC ENVIRONMENT The Mandeni Local Municipality (formerly eNdondakusuka Local Municipality) is a Category B municipality in the iLembe District Municipality. It covers the area from the Amatikulu River to a line just south of Mtunzini in the north, and to a line south of the uThukela River just north of Darnall. It is the smallest of four municipalities that make up the district. Mandeni includes substantial areas of commercial agriculture, with the bulk of these areas under sugarcane. Agriculture is the main employment sector in the area. Manufacturing, elementary work and plant and machine work are the highest non-farming categories of labour. The Mandeni Local Municipality is strategically located midway between Durban and Richards

48 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Bay, and lies on the development corridor on the north coast between these two major port cities in KwaZulu-Natal. It is located on the major railway and road transportation routes which link these two economic hubs. This strategic location is also acknowledged in the Provincial Spatial Framework, which has identified Mandeni as the growth node in the north coast corridor. The construction of the new Dube Trade Port and King Shaka International Airport has much economic, social and employment implications for the municipality because of its location. Mandeni is the only urban settlement of substance and functions as the service centre for a substantial hinterland. Mandeni consists of fragmented pockets of intensive urban settlement separated by areas of little or no development.

The site and adjacent areas do not contain any formal or informal settlements. The nearest settlement is Sans Soucis which is 1km to the south. The Proposed mine will thus not impact on social-economic or the community. Regional

4.9 REGIONAL ENVIRONMENTA L SENSITIVITIES The proposed Hlanganisa Sand Mine (Tugela River) is located approximately 8,7km directly west of the Harold Johnson Nature Reserve which is administered by Ezemvelo KwaZulu-Natal Wildlife. The proposed Mine is 23km downstream of the proposed Reserve as well as the start of the uThukela Marine Protected Area. With strict mitigation and management measures, these protected areas should not be adversely impacted on.

Figure 4.4: Protected Areas as per the DEA Database in close proximity to the proposed Mine 49 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

4.10 PHOTOGRAPHIC REPRESENTATION OF THE PROPOSED TUGELA RIVER SAND MINING SITE

Image 4.5: The proposed mining site facing downstream

50 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Image 4.6: The proposed mining site facing the opposite northern bank

51 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Image 4.7: The proposed mining site facing upstream

52 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Image 4.8: Existing sandbar within the proposed mining extent

53 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

5 IMPACT ASSESSMENT

5.1 INTRODUCTION The impact assessment aims at identifying potential environmental impacts (both positive and negative impacts) and evaluating these impacts in terms of its significance. This assessment is provided in the form of a systematic analysis framework to evaluate the nature, extent, duration, intensity, probability and significance of the various impacts considered both without and with mitigation and management measures. The impact assessment assesses both the impacts of the preferred alternative, as well as the other alternative options considered in the development proposal and unforeseen cumulative impacts. The mitigation hierarchy was applied during the BA process and contains steps to mitigate potential impacts of the proposed Tugela River Sand Mine. The aim of the mitigation hierarchy is to avoid/minimize impacts over rehabilitation and offsetting.

5.2 IMPACT ASSESSMENT CR ITERIA The assessment of the potential impacts of the envisaged development is undertaken in accordance with the broad criteria required by the integrated environmental management procedure and includes the following:

NATURE OF IMPACT A brief description of the type of impact the proposed development will have on the affected environment.

EXTENT/SCALE The physical extent of the impact. i. Footprint The impacted area extends only as far as the actual footprint of the activity. ii. Site The impact will affect the entire or substantial portion of the site/property. iii. Local The impact could affect the area including neighbouring properties and transport routes. iv. Regional Impact could be widespread with regional implication. v. National Impact could have a widespread national level implication.

DURATION The duration of the impact. i. Short term The impact is quickly reversible within a period of one year, or limited to the construction phase, or immediate upon the commencement of floods. ii. Medium term

54 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

The impact will have a short-term lifespan (project lifespan 1 – 10 years). iii. Long term The impact will have a long-term lifespan (project lifespan > 10 years). iv. Permanent The impact will be permanent beyond the lifespan of the development.

INTENSITY This criteria evaluates intensity of the impact and are rated as follows: i. Minor The activity will only have a minor impact on the affected environment in such a way that the natural processes or functions are not affected. ii. Low The activity will have a low impact on the affected environment. iii. Medium The activity will have a medium impact on the affected environment, but function and process continue, albeit in a modified way. iv. High The activity will have a high impact on the affected environment which may be disturbed to the extent where it temporarily or permanently ceases. v. Very high The activity will have a very high impact on the affected environment which may be disturbed to the extent where it temporarily or permanently ceases.

PROBABILITY This describes the likelihood of the impacts actually occurring. i. Improbable The possibility of the impact occurring is highly improbable (less than 5% of impact occurring). ii. Low The possibility of the impact occurring is very low, due either to the circumstances, design or experience (between 5% to 20% of impact occurring). iii. Medium There is a possibility that the impact will occur to the extent that provision must be made therefore (between 20% to 80% of impact occurring). iv. High There is a high possibility that the impact will occur to the extent that provision must be made therefore (between 80% to 95% of impact occurring). v. Definite

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The impact will definitely take place regardless of any prevention plans, and there can only be relied on migratory actions or contingency plans to contain the effect (between 95% to 100% of impact occurring).

5.2.5.1 DETERMINATION OF SIGNIFICANCE Significance is determined through a synthesis of the various impact characteristics and represents the combined effect of the extent, duration, intensity and probability of the impacts. • No significance The impact is not substantial and does not require any mitigatory action. • Low The impact is of little importance, but may require limited mitigation. • Medium The impact is of importance and therefore considered to have a negative impact. Mitigation is required to reduce the negative impacts to acceptable levels. • High The impact is of great importance. Failure to mitigate, with the objective of reducing the impact to acceptable levels, could render the entire development option or entire project proposal unacceptable. Mitigation and management is essential.

The following assessment scale is used to determine the significance of the identified potential impacts on the environment.

Significance = (probability + duration + scale) x intensity Probability: 1 – 5 Extent: 1 – 5 Duration: 1 – 4 Intensity: 1 – 10

Significance rating criteria >75 High environmental significance 50 – 75 Medium environmental significance <50 Low environmental significance

5.3 IMPACT HIERARCHY The mitigation hierarchy tool was used to guide the process in dealing with potential impacts of the proposed Hlanganisa Sand Mine (Tugela River) and the formulating of the various mitigating measures specified in the section below and the Final EMP (Appendix 1). The mitigation hierarchy is typically used

56 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

when planning and implementing development projects in order to provide a systematic, logical and sustainable approach in dealing with possible impacts associated with the development. This to ensure the positive impacts are amplified and negative impacts have the lowest possible effect on the receiving environment.

The following steps/hierarchy was utilised as the core in dealing with possible impacts. When mitigation measures were being formulated to deal with potential impacts, the below measures in the table were used. The favoured mitigation option was the avoidance of impacts and the least preferred option is offsetting

Avoidance The first step of the mitigation hierarchy comprises of measures taken to avoid creating impacts from the outset. This is the most environmentally sustainable and cost effective option. Minimization The second preferred option involves measures taken to reduce the duration, intensity and/or extent of impacts that cannot be completely avoided. Restoration The third preferred option is restoration measures which aim to rehabilitate degraded or removed ecosystems following exposure to impacts that cannot be completely avoided or minimised. Offsetting The least preferred option is offsetting. This involves implementing measures taken to compensate for any residual, adverse impacts after full implementation of the previous three steps of the mitigation hierarchy.

5.4 IMPACTS FROM SIMILAR TYPES OF DEVELOPMENT/MINING OPERATIONS As part of the impact assessment process, impacts from similar types of developments/sand mining applications were analysed and used to help guide the assessment process for the current Basic Assessment. While the EAP notes that all projects are unique depending upon local environmental conditions and engineering designs; examining previously undertaken Basic Assessments of similar types of projects can assist the EAP in the Impact Assessment process. This to strengthen the quality of the EIA.

5.5 ENVIRONMENTAL IMPACTS OF THE PROPOSED PREFERRED ALTERNATIVE Below contains a description of the anticipated impacts of the proposed preferred alternative as discussed in Section 2.6 of this Report.

NB: For each Impact identified corresponding mitigation measures have been proposed that are legally binding on the Applicant. Mitigation measures are provided in the 9th block of the impact tables below

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Kindly note, that these blocks do not contain all the mitigation measures to be implemented by the Applicant during the different phases of the proposed mine. Rather the important mitigation measures are stipulated due to space limitations. A full list of all the mitigation measures as well as timeframes and responsible persons can be found in the EMP (Appendix 1).

SOIL EROSION, LOSS OF TOPSOIL AND CONTAMINATION Soil erosion, contamination, compaction and loss of top soil are significant impacts that may occur during the site establishment, mine operation and the decommissioning phases of the proposed Hlanganisa Sand Mine. This as once soil is disturbed by mining related activities (EG: mining site set up, the stockpiling of sand and the indiscriminate and uncontrolled movement of vehicles and equipment) the soil becomes far more susceptible to erosion, compaction, soil loss and an overall decrease in quality. This makes ongoing rehabilitation significantly more difficult and favours the spread of invasive alien plants.

Erosion of the soil surface greatly increases the risk of losing topsoil to erosion and impairing the soils ability to support vegetation growth. Nutrients and seed banks are lost to sun baking and humus content will often be reduced (oxidised). This disturbance will further result in an increase in the runoff of sediment into the Tugela River and surrounding wetlands and drainage lines, with the latter already being significantly degraded. Excavation may also result in the destabilisation of the River banks and in bank slump which will add to the impact as a result of sedimentation.

A further concern is soil contamination due to chemical spills (Waste, sewage, herbicides and hydrocarbon spills/leaks/breakdowns from mining equipment etc). This may pose a serious hazard to not only the surrounding environment, but also to human health. Soil contamination can also compromise future rehabilitation of the site.

Lastly, compaction of soil due to unrestricted vehicle movement on site can potentially occur resulting in impacts on soil structure which determines the ability of soil to hold water, nutrients, and air.

While all the above impacts are significant, it must be noted that these impacts can easily be avoided or at the very least be mitigated to acceptable levels with the implementation of strict mitigation measures as specified in the EMP. Furthermore, mitigation measures will need to be continued during the Mine Closure and Rehabilitation phase to ensure the abovementioned impacts do not occur post-mining.

58 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

Nature Phase Type Extent Duration Intensity Probability WOM WM Mitigation 1. Machine and equipment maintenance must as far as possible be undertaken off site and on a regular basis. 2. Inspect all storage facilities, machinery and vehicles daily for the early detection of deterioration or leaks 3. Fuel, chemicals and other hazardous substances should preferably be stored 1. Soil offsite, or as far away pollution as possible from the and no-go areas. These contaminat substances must be stored in suitable ion Site secure weather proof  Hydrocarbon prepar containers. Low leaks/spills ation Negative Site Medium High High Medium 4. Dispose of used oils  Chemical spills and and other pollutants Operat  Sewage at an appropriate ion leaks/spills licensed landfill site.  Herbicides 5. Provide portable toilets where work is being undertaken. These toilets must be located outside of the no-go areas and should preferably be located on level ground. Portable toilets must be regularly serviced and maintained. 6. Train employees and contractors in spillage management and provide them with absorbent spill kits and disposal containers to handle spillages.

Site 1. Where roads or soil 2. Compactio prepar have become n of soils ation Negative Site Medium Medium Medium Medium compacted, they will Low

and be ploughed, ripped

Operat and re-vegetated. ion

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1. On any areas where Site the risk of erosion is prepar evident, appropriate ation Negative Site Long Medium High High temporary or Low and permanent works and Operat water energy ion dispersion structures must be installed. 2. There needs to be minimal vegetation clearance and 3. Soil exposure of soils. Erosion 3. The excavation of soils must only be undertaken during Deco agreed times and mmiss Negative Site Long Medium High High under suitable Low ioning weather conditions. Should heavy rains be forecast, clearing activities must be put on hold. 4. The Stormwater measures stipulated in the EMP must be implemented. 1. Topsoil stripped from Site the footprint must not prepar be spoiled, but ation Negative Site Medium Medium Medium Medium stockpiled and Low and preserved for later Operat use in rehabilitation. ion 2. Stockpiled topsoil should be used as the final cover for all disturbed areas where 4. Loss of re-vegetation is Topsoil required. 3. All stockpiles must Deco Medium Medium Medium be protected from mmiss Negative Site Medium Low windy conditions or ioning heavy rain. This includes cloth or vegetation. 4. All stockpiles must be kept neat and tidy and free of weeds.

FRESHWATER IMPACTS The impact of the proposed Hlanganisa Sand Mine on the watercourses for the different phases can be divided into a number of categories. These are  The disturbance of the five watercourses;  The alteration of the bed, banks and flow characteristics of the Tugela River;  Water quality impairment;

60 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

 Erosion and sedimentation of watercourses; and  Impact on fish and fish movement within the Tugela River.

Impact 1: The disturbance of the surrounding watercourses The indiscriminate movement of vehicles and personnel during:  The clearing of vegetation and topsoils from the proposed stockpile area;  The inappropriate storage or dumping of spoil material; and  Movement within the riparian area and Tugela system itself. may result in the disturbance of riparian, instream and wetland habitat. This disturbance may in turn result in the further proliferation of alien and invasive vegetation within watercourses.

Habitat associated with the wetlands and drainage lines has been significantly degraded as a result of surrounding agricultural activities and these features are already significantly encroached by alien and invasive species. However, although the Tugela River has been impacted as a result of alien vegetation encroachment, woody indigenous vegetation still dominates the riparian area. The potential impact is therefore considered to be of a medium (negative) significance prior to the implementation of mitigation measures.

Impact 2: Alteration of the bed, banks and flow characteristics of the Tugela River The excavation of sand may result in possible diversion of flow of the river as well as the erosion of the River banks. The extraction of sand will result in the alteration of the natural sediment balance of the river and will reduce sediment reaching areas downstream of the mining operations which may ultimately result in downstream erosion and channel incision. It is not possible to avoid the alteration of the bed of the river in areas where sand will be extracted. However, with the implementation of the mitigation measures as listed below, the alteration of the banks of the river and the natural low flow patterns through the river can be largely avoided. Furthermore, should sand excavated from the sandbars be restricted to that replaced through natural sedimentation processes, excavated areas will be replenished with sand during annual flood events.

Impact 3: Water quality impairment The proposed mining activities may impact on the quality of the Tugela River and surrounding watercourses. The movement of vehicles and machinery during site preparation and the mining operational phase itself increases the possibility of the contamination of the surrounding watercourses by hydrocarbons,

61 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

oils and grease which may leak from the vehicles/machinery or spill during poor dispensing practices and enter into the watercourses with stormwater runoff. This is especially possible with the movement of vehicles through the riparian area and riverbed of the Tugela River. Contamination of the watercourses by sewage may occur as a result of leakages from portable chemical toilet facilities, or the informal use of the watercourses by workers. The informal use of the watercourses by workers may also result in contamination of the features. Additional impacts to watercourses as a result of the disposal of solid waste including litter may also occur.

Impact 4: Erosion and sedimentation of the watercourses The removal of vegetation (not indigenous, consisting of sugarcane) and topsoil from the stockpile area will result in the exposure of soils to erosive elements. Uncontrolled stormwater runoff and velocities from bare, disturbed and compacted areas may result in the formation of erosion gullies and rills, and in the erosion of the banks of the Tugela River which is located downslope of the stockpile area, as well as wetland 2 and drainage line 2 which are located adjacent to the stockpile area. Furthermore, earth moving activities associated with the preparation and clearing of the stockpile area as well as mining operation itself may lead to increased disturbance of soils and uncontrolled runoff and sedimentation of the Tugela River. Erosion may further occur on poorly maintained access tracks due to the movement of heavy earth moving equipment. The sedimentation of rivers continues to be one of the biggest threats to the systems and is damaging to the ecological health of watercourses by reducing their environmental, social and cultural values. With strict mitigation measures this sedimentation and uncontrolled runoff can largely be avoided.

Impact 5: Impact on fish and fish movement within the Tugela River The proposed mining activities may impact on fish and fish movement within the Tugela River if appropriate mitigation measures are not employed. The erosion of banks, sedimentation of the Tugela River and pollution may all impact on fish within the system. However, the Fish specialist noted that the removal of sand from the sand bars can have a beneficial impact on the River itself. This as the downstream meander habitat has been significantly affected by sedimentation. It follows that mining operations, if undertaken with due management at this point, will hopefully promote increased habitat diversity and increased diversity in fish diversity within the system due to this removal of sedimentation.

Nature Phase Type Extent Duration Intensity Probability WOM WM Mitigation 1. Impact on Site 1. Mitigation measures Water prepar Negative Local Short Medium Medium Low are the same as Low Quality ation measures proposed

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under the soil  Hydrocarbon pollution section leaks/spills above.  Chemical spills 2. Hazardous  Sewage substances must be leaks/spills stored away from the  Increase in buffer areas sediments surrounding any water bodies on site to avoid pollution. 3. The 32m buffer for the Tugela River and 20m buffer for all other watercourses must be strictly enforced. 4. Place silt fences / traps strategically on Operat Negative Local Long High Definite High the periphery of the Low ion temporary stockpile areas in order to trap sediment carried by stormwater runoff before it is conveyed into the river channel. 5. Ensure silt fences / traps are adequately maintained and monitored. 6. No water may be abstracted from any surrounding watercourse without receiving authorisation from DWS. 2. The disturbance 1. Clearly demarcate of the five the mine extent and watercourses strictly prohibit the movement of Site Negative vehicles and prepar Local Long Medium Medium Medium personnel outside of Low ation the demarcated areas 2. Limit the movement of vehicles and personnel through

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the river channel as far as possible, no activity must be permitted within the river channel other than the excavation of sand from the river Operat Negative Local Long Medium Definite Medium sandbars. Low ion 3. Only the existing access ramp may be used to enter the Tugela River. 4. Control alien invasive species.

3. Alteration of the 1. River sand extracted bed, banks and must not exceed that flow replaced through characteristics natural of the Tugela sedimentation River processes. 2. The extraction of sand must not compromise the flow Site Negative of the river or divert prepar Local Permeant High High High Low the main flow of the ation river. 3. The natural flow of the River must not be permanently diverted or blocked. 4. Strictly prohibit the excavation of a new channel or drainage canals for the diversion of water away from the construction area. 5. Extraction of sand from the riverbanks must be prohibited. Operat Negative Local Permeant High Definite High Low ion

4. Erosion and 1. The Rehabilitation sedimentation Plan (Appendix 6) of the and all mitigation watercourses and management measures must be Site Negative Local Long Low Medium Medium implemented. prepar Low 2. Reshape and ation reprofile disturbed areas associated with the temporary stockpile areas to resemble pre-

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disturbance terrain units. Avoid steep slopes and concentrated flow paths. Operat Negative Local Long Low Medium Low 3. Loosen disturbed and Low ion compacted soils to a depth of 100mm- 300mm to assist with the re-establishment of vegetation. 4. Stabilise areas at risk of erosion with ‘soft’ stabilization techniques as determined upon consultation with a suitably qualified specialist (e.g. geotextiles, fibre mats / nets / blankets / bags, brush Deco Local Long High Medium Medium mattresses, live mmiss Negative Low staking etc.). ioning 5. Revegetate disturbed areas as soon as possible after the stabilizing of soils. Indigenous grass plugs can be used in combination with an indigenous grass seed mix for revegetation. 5. Impact on fish 1. Mining of the River existing within banks will be the Tugela avoided. River 2. Mud banks and clay deposition points should be avoided, where encountered. Operat Local Long High Medium Medium Negative 3. Stockpiling of Low ion sediments in the River will be avoided, as well as curtailment of flow by the establishment of wide berms and dams.

FLORA AND FAUNA The proposed mining related activities will have impacts on both the flora and to a smaller degree fauna of the area. The most significant impact will be the potential loss of small areas of riparian vegetation due to the indiscriminate movement of vehicles. The disturbance of the riparian vegetation and surrounding areas may lead to an increase in proliferation of alien and invasive species within the disturbed areas and along

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the access track. Alien vegetation is likely to proliferate in areas disturbed. With the implementation of rehabilitation measures, this will reduce the intensity of the impact; however, without follow up alien vegetation control, encroachment is still highly likely to occur. An increase in stormwater runoff from the hardened surface of the access routes and the concentration of runoff at stormwater outlet points could potentially result in erosion damage to adjacent areas and in the associated disturbance of vegetation. These impacts can be avoided with mine site demarcation, appropriate management plans and regular monitoring.

Minor impacts on fauna may further occur. This due the presence of human activities and movement of vehicles. However, there are significant fauna habitat surrounding the site, which fauna may move in to. Smaller fauna species such as snakes, small mammals can be moved to the adjacent areas under the supervision of the ECO and a suitably qualified expert in the field.

Nature Phase Type Extent Duration Intensity Probability WOM WM Mitigation 1. No trapping, snaring, 1. Impact on hunting, fishing or faunal killing of any animal activity may occur on the site. 2. Any malicious damage to any fauna species present on site will be considered a punishable offence, All Negative Local Medium High High High and the appropriate Low Phases measures will be followed. 3. Limit the clearing of vegetation, removal of logs, rocks etc. 4. Contact an appropriate professional when smaller animals need to be removed from the mining site. 2. Spread of Site 1. Invasive alien plants invasive prepar must be immediately alien ation Negative Local Medium High High High removed from the Low plants and mining site. Operat 2. Alien species ion removal is to take place manually, by hand as far as possible. The use of herbicides should be Deco Negative Local Medium High High High avoided. Should the mmiss Low use of herbicides be ioning required, only herbicides which have been certified safe for use in aquatic

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environments by an independent testing authority may be considered. 3. Dispose of removed alien plant material at a registered waste disposal site or burn on a bunded surface where no stormwater runoff is expected. 4. Remove vegetation before seed is set and released. 5. Cover removed alien plant material properly when transported, to prevent it from being blown from vehicles. 6. Rehabilitation measures must be undertaken concurrently with mining activities and must ensure that post-mining land use requirements are met.

NOISE IMPACTS Mining activities are likely to result in the creation of increased noise levels. This due to the operation of machinery essential for the mining process.

Probabili Nature Phase Type Extent Duration Intensity WOM WM ty Mitigation 1. Noise levels must be kept within Site acceptable limits. prepar 1. Noise impacts 2. Noise suppression ation Low Negative Local Medium Medium Definite Medium measures must be and applied to all Operat construction ion equipment.

AIR QUALITY Dust is likely to be created due to the movement of mining equipment along the existing dirt access track and the stockpiling of sand. Dust can be a nuisance but can, to a large extend, be controlled (especially due to the project footprint being small).

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Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM 1. During windy or dry periods, dust suppression techniques must be implemented. This includes wetting 1. Air of the stockpiling area. Site pollutio 2. Vehicles and preparat n and equipment must be ion and Negative Local Short Short High Low Low creation properly maintained to Operatio of dust limit the release of n harmful gases. 3. Exhaust emission control devices are to be installed on vehicles and/or machinery where practical.

LIGHT Light pollution may be created during the operational phase of the mine.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM 1. Operational hours Site during construction 1. Light preparat will be restricted pollution ion and Negative Site Short Minor Definite Low Low from Monday to Operatio Friday 07h00 to n 17h00.

VISUAL The proposed mining area, stockpiling area and the usage of mining related equipment will impact on the aesthetic value of the surrounding area, which is largely natural/rural in state.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM 1. The site must be kept neat and tidy at all Site times. prepar 2. Solid waste disposal ation must regular occur. Low Negative Site Medium Minor High Medium and 3. After Closure all 1. Visual Operat mining machinery, Impact ion equipment, fencing, signage and toilets must be removed from the proposed site. Deco mmiss Negative Site Medium Minor High Medium Low ioning

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SOLID WASTE DISPOSAL Inappropriate location of solid waste storage and disposal services may lead to litter, pollution and general nuisances and health hazards. This solid waste may enter into the River and be transported further downstream. The site is currently free of litter and construction waste and this must be continued.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM 1. Ensure sustainable waste management practises Site are in place. 1. Waste prepar 2. Bins must be provided on disposal ation site and coded. Negative Local Short Medium Medium Medium and 3. Littering by the workers Low Operat must not be allowed. ion 4. Construction waste must be disposed of at a registered landfill site.

TRAFFIC Limited traffic volumes will be created during the site preparation phase and the hauling of sand to the market during mine operation. Due to the small size of the proposed mine, this impact will be low.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM 1. Vehicle access must be strictly contained onsite. Vehicles may only use designated routes and access points as Site 1. Increase determined by the ECO prepar in and Mine Manager ation Negative Local Short Low Low Low Traffic before operations and Low commence. Operat 2. Access road and loading ion area will be properly maintained, and this includes appropriate stormwater management and dust control.

SOCIAL The proposed mining related activities will have positive impacts on the local economy, which will in turn have numerous social benefits. The operational phase will result in employment opportunities being created for the surrounding communities. Sand for the local building industry will further be available. However, mining activities will also pose a risk to workers on site as well as surrounding communities if proper health and safety measures are not implemented.

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Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM

N/A Positive Regional Long Long Definite N/A N/A

1. Access to the mining site will be restricted. Site 2. All workers must wear prepar 1. Social identifiable clothing at all ation impacts times while on the and property. Operat Negativ 3. All workers must be Local Long Low Medium Low Low ion e provided with safety equipment as required (respirators, masks, helmets, safety boots, safety gloves, aprons, goggles etc.)

5.6 CUMULATIVE IMPACTS Cumulative impacts are impacts that result from the incremental impact of the proposed activity on freshwater systems within a greater catchment, ecoregion and wetland vegetation group when added to the impacts of other past, present or reasonably foreseeable future activities. The proposed sand mining activities will not require the removal of additional wetland or riparian habitat and will therefore not add to the cumulative loss of this sensitive habitat from the region. Furthermore, should the mitigation measures as listed within this report be strictly implemented, the unnecessary disturbance of wetland and riparian habitat can be avoided.

Additional sand mining operations were noted downstream of the mine extent and the proposed sand mining activities will therefore add to the cumulative loss of sediment from the river system. However, only mining of the sand bars is proposed. Furthermore, the Harold Johnson Nature Reserve and the uThukela Marine Protected area are located downstream of the proposed Hlanganisa Sand Mine. Impacts on the Tugela River from the mining operations includes pollution, sedimentation and the altering of the flow of the Tugela River. These impacts may combine and have a significant impact on the two sensitive nationally important protected areas downstream of the site. However, it must be noted that the proposed mining site is located more than 20 kms from these two protected areas. Furthermore, with the mining of only the sand bars (thus not exceeding replenishment rates or mining of the river bed) and the implementation of strict mitigation measures, it is highly unlikely that the downstream protected areas will be impacted on.

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Duratio Intensit Probab Nature Phase Type Extent WOM WM n y ility Mitigation Implement strict 1. Impact on the Site mitigation measures as Tugela preparation Negati Region Permea High Low High specified in Sections Low watercourse and ve al nt 5.5.1, 5.5.2 and 5.5.3. system Operation

5.7 SUMMARY OF IMPACTS PE R THE DIFFERENT PHASES OF THE HLANGANISA SAND MINE Activities Phases Impacts Demarcation of mining site and Site Establishment Soil erosion, soil compaction, soil mining site Set up. and Preparation contamination, loss of fertile top soil, impact on water quality, disturbance of watercourses, erosion and sedimentation of watercourses, flora and fauna impacts, spread of invasive plants, noise impacts, air pollution, creation of waste and visual impacts. Mining of the sand – Mechanical Operation Soil erosion, soil compaction, soil Mining contamination, loss of fertile top soil, (This includes the movement of impact on water quality, alteration of vehicles in the watercourse and watercourses, impact on fish and fish mining of the sand bars) migration, disturbance of watercourses, flora and fauna impacts, noise impacts, visual and air pollution. Stockpiling of the sand Operation Soil erosion, soil compaction, soil contamination, loss of fertile top soil, impact on water quality, disturbance of watercourses, flora and fauna impacts, spread of invasive plants, noise impacts air pollution, impact on traffic, creation of waste and visual impacts. Transportation of sand to the Operation Soil erosion, soil compaction, soil market for sale contamination, loss of fertile top soil, impact on water quality, disturbance of

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watercourses, flora and fauna impacts, spread of invasive plants, noise impacts air pollution, impact on traffic and creation of waste. Decommissioning of the sand mine Site Closure and Soil erosion, soil compaction, soil and the implementation of a Rehabilitation contamination, loss of fertile top soil, Closure and Rehabilitation Plan erosion and sedimentation of watercourses, flora and fauna impacts, spread of invasive plants and visual impacts.

5.8 ALTERNATIVES IMPACT ASSESSMENT Only one alternative option was considered in the assessment phase. This involved the usage of a floating barge system to mine the riverbed. This may result in the increase of sedimentation of the Tugela River as well as the exceeding of annual replenishment rates of natural sand within the system. This mining method may further disturb fish species along the River bed.

Duratio Intensit Probab Nature Phase Type Extent WOM WM n y ility Mitigation 1. Impact on the Implement strict Tugela mitigation measures as watercourse specified in Sections system due to Negati Permea 5.5.1 and 5.5.2 Operation Local High High High Low the mining via ve nt the usage of a floating barge system.

5.9 SUMMARY OF SPECIALIS T STUDIES The following specialist studies was undertaken as part of the Basic Assessment process:  Freshwater Study;  Fish Survey;  Botanical Study; and  Mining Operations Plan

5.10 ENVIRONMENTAL IMPACT STATEMENT AND SUMMARY ON NEED AND DESIRABILITY ENVIRONMENTAL IMPACT STATEMENT 72 Basic Assessment Report (Draft 1): The proposed Hlanganisa Sand Mine (Tugela River)

The impact assessment for the proposed Hlanganisa Sand Mine (Tugela River) illustrates that there is a potential for both positive and negative impacts on the local environment. The impact assessment noted that due to the sensitivity of the site and surrounding areas, many of the potential impacts from the proposed mine may be significant and have long lasting negative impacts unless strict mitigation, management and monitoring measures are implemented. This especially in terms of impacts on the Tugela River and the surrounding watercourses. Impacts on these watercourses may include impacts on water quality, instream habitat, erosion, sedimentation, impact on fish migration and diversion of flow.

It is however the opinion of the EAP that with the strict implementation of mitigation measures as specified in this Report, and set out in the EMP - based on the comprehensive specialist studies conducted and the embracing of the principals of the impact mitigation hierarchy guiding the assessment process which aims to avoid impacts over rehabilitation or offsetting - the positive impacts can be enhanced while the majority of the negative impacts can be mitigated to Low/ Acceptable levels. This includes the impacts on all the watercourses. It is further important to note mining operations are likely to have positive impacts in terms of economic and social benefits, as well as the removal of heavy sediment impacting on fish and fish habitat and the removal of invasive alien plants heavily impacting on the surrounding watercourses riparian areas. An extensive list of engineering, freshwater and ichthyological measures have been proposed to protect this environmental system.

Table 5.1 below considers both the advantages and disadvantages of the proposed development: Table 5.1: Advantages and Disadvantages of the proposed Hlanganisa Sand Mine Advantages Disadvantages Provides a high grade of sillca sand for the The impact on the sensitive and environmentally building industry. There is a large demand important Tugela River (in terms of water in the region for building sand. quality, diversion, river bank erosion, fish movement and migration). Creation of employment opportunities. The impact on adjacent wetlands and drainage lines. Local economic development. Removal of invasive alien plants during rehabilitation. This will positively impact on all surrounding watercourses.

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5.11 IMPLEMENTATION OF BUFFERS Sand mining will need to take place within the Tugela River channel; an existing informal access road which traverses wetland and 2 and drainage line 1 will be utilised to gain access to the stockpile area; and the existing access ramp to the river is located directly adjacent to drainage line 2. It will therefore be impractical to designate a ‘no-go’ buffer zone around the watercourses within which all mining related activities are prohibited. However, the Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016) was utilised in order to determine a buffer for the watercourses in which the proposed establishment of a stockpile area as well as non-essential mining related activities (e.g. indiscriminate movement of vehicles, dumping of excavated material, locality of temporary toilets etc) must be strictly prohibited in order to avoid any unnecessary additional impact. Considering the additional mitigation measures which will be implemented in order to avoid disturbance to the watercourses (Section 6), a final buffer zone of 32m was calculated for the Tugela River and a final buffer zone of 20m was calculated for the drainage lines and wetlands. These buffers must be applied during all phases of the sand mining activities (Figure 5.1).

5.1: Watercourse buffers for the proposed Hlanganisa Sand Mine

5.12 FINANCIAL PROVISION

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In the event of environmental damage, an amount must be made available for premature closure, as facilitated through the DMR and its own internal policy and permit application processing procedures. The rehabilitation fee will be provided in the final report, following consultation with the DMR.

5.13 EXPLAIN HOW THE FINANCIAL PROVISION WAS OBTAINED The amount allocated for Financial Provision was calculated according to the guideline for the Calculation of the Quantum for Rehabilitation as provided by DMR. The rehabilitation fee is thus calculated based on the size of a mining operation less than 5 ha.

5.14 UNCERTAINTIES/GAPS IN KNOWLEDGE There were no uncertainties noted in the Assessment undertaken by the EAP.

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6 SUMMARY RECOMMENDATIONS OF EAP

It is the opinion of the EAP that the project can be supported on condition that the Mitigation and Management measures described in Section 5 hereof and the EMPr (Appendix 1 hereto) should be strictly adhered to by the Applicant.

A variety of mitigation measures have been identified that will serve to mitigate the scale, intensity, duration and significance of the impacts of the proposed Hlanganisa Sand Mine (Tugela River). The proposed mitigatory measures, if implemented, will reduce the significance of the majority of the identified impacts and allow for the proposed Hlanganisa Sand Mine to proceed with minimal effect to the environment, local community and surrounding land use practice.

IDM Environmental recommends the following (must be included in the EMP):  Implement pollution control measures;  Implement mitigation measures specified in the various specialist reports undertaken;  Implement the proposed Freshwater Buffers;  Ensure strict erosion control and stormwater management measures are in place;  Rehabilitate and restore the surrounding environment; and  Appoint an independent ECO to monitor the implementation of the EMP.

It is the opinion of the EAP that the information contained in the Basic Assessment Report, and the specialist studies, have been compiled to address specific areas of concern, and provide sufficient information to undertake a sound assessment of the proposal and provide an informed recommendation with a sufficient degree of confidence.

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Annexure A: Regional Map

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Annexure B: Schematic Layout Plan of the proposed Hlanganisa Sand Mine (Tugela River)

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