Table D1: Comments/Objections on the Proposed Project and Responses by the Project Team
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PPM Plant Expansion Project 710.16002.00026 TABLE D1: COMMENTS/OBJECTIONS ON THE PROPOSED PROJECT AND RESPONSES BY THE PROJECT TEAM Response provided by SLR (unless otherwise specified) (updated Specific issue Issue raised By whom, when, how where necessary) Procedural Time period We are informed by the EIA/EMPR Report that meetings pertaining to the Mariëtte Liefferink, FSE The proposed process plant changes represents a significant financial Scoping Phase of the project were held with key stakeholders during 2013 Email received 25 March 2019 commitment by PPM and therefore the mine conducted detailed and 2014. Reference is made on page 37 of the EIA/EMPR Report that a investigations, including pilot plant testing, over the last few years to scoping meeting was held with the FSE on the 8th of May 2014. investigate the viability of the new technology (PPM). The Environmental Impact Assessment / Environmental Management Following the test work the specialist studies required as part of the Programme Report (EIA/EMPR) is dated March 2019 and we are advised on EIA were finalised. Results from the test work were used to inform the page (i) of the Report that the comment period is from 18 March to 7 May air quality specialist study and residue material from the pilot testing 2019 after which the final EIA/EMPR will be submitted to the DREAD and the was subjected to geochemical testing to inform the groundwater DMR for decision-making. specialist study. Kindly provide clarity why there was an effluxion of 5 (five) years between the Scoping Phase and the EIA phase. Municipal plans We failed to find reference to the BPDM EMF in the EIA/EMPR. Since the Mariëtte Liefferink, FSE Reference to the Environmental Management Framework (EMF) for EMF functions as a support mechanism in the EIA process and is a decision Email received 25 March 2019 the Bojanala Platinum District Municipality has been included in the support tool, which ensures that the competent authority has sufficient EIA and EMPr (see Section 5.1 of the EIA and EMPr). In terms of the information to guide EIA authorization decisions within a specific EMF, PPM and the proposed project are located in Zone C, geographical area, the EIA/EMPR ought to have included the findings and Development Zone III (Mining). The PPM mine falls within an area of recommendations of the BPDM EMF namely: moderate hydrological, biodiversity and agricultural potential. Mining the environmental management priorities of the area; activities within Zone C should as far as possible be confined to Zone the kind of developments or land uses that would have a significant C, be conducted in a sustainable manner, avoid wetlands/ aquatic impact on those attributes and those that would not; features/high or sensitive biodiversity areas/sensitive topography the kind of developments or land uses that would be undesirable in the areas and follow the guidelines in the EMF if they are within a area or in specific parts of the area; biosphere buffer zone. The proposed project is aligned with inclusion and exclusion areas (if deemed feasible/necessary), or areas of guidelines for the specific management zone. particular sensitivity in terms of the proposed NEMA EIA Regulations list of activities. Consultation Are you sensitising the Council or require permission from the Council? The Obed Phaladi, BBKTA. The project is technical in nature given that it relates to changes to the process information provided is too technical and we won't remember this Comments received 23 April processing facilities at the mine. The purpose of the meeting with the presentation 3 months from now. 2019 at BBKTA Meeting BBKTA Traditional Council was to share information on the project and the outcome of the EIA process, to record any comments or issues and to agree on further public participation within the communities. 1 PPM Plant Expansion Project 710.16002.00026 Response provided by SLR (unless otherwise specified) (updated Specific issue Issue raised By whom, when, how where necessary) Consultation English advertisements are a problem. Most of the people in the village David Pheto, Lesetlheng Land SLR placed site notices in key areas in the communities inviting process cannot read. Committee Chairman community members to the planned open day. The site notices were Comments received 04 April both in English and in Setswana. 2019 at PPM Open Day The credible individuals who can decide/represent the community are only The comment regarding community meetings needing to take place available on weekends. Any meetings need to take place on a Saturday. on weekend is noted by SLR. In February 2019, DMR said Mine must consult us. PPM hasn't come to us to It is SLR’s understanding that the consultation referred to relates to talk about this expansion. They are not allowed to do any projects until they access to the Wilgespruit farm. The proposed project would however consult with us. You cannot speak to the Chief alone and then claim you have take place mainly within the existing plant footprint on the farm consulted the whole community. The Chief cannot have a dual role in Tuschenkomst and Witkleifontein. Nonetheless, following a meeting representing the community and the mine at the same time. He can't be on with the BBKTA in March 2014, scoping meetings were planned with the Board. PPM’s doorstep communities including Lesetlheng, between 7 and 11 April 2014. Unfortunately Lesetlheng cancelled their meeting. A public open day took place on 4 April 2019 in order to provide I&APs with an opportunity to interact with the SLR and PPM project team and provide comments on the outcome of the EIA process and related EIA and EMPr. In addition, a community meeting was planned with Lesetlheng for 19 May 2019 but due to a death of a senior member of the larger community the meeting was cancelled. SLR attempted to reschedule the meeting for 9th June 2019 but the meeting did not take place. Subsequent to this, a decision was taken by the applicant and SLR to finalise the public consultation that had taken place to date and submit this to the regulatory authorities for decision-making. Even for the original EIA in 2007 we were never consulted. In 2005 a social scan of the surrounding villages was conducted by Metago with the assistance of PPM social responsibility personnel. The purpose of the social scan was to identify the closest villages to the planned PPM mine. At the time of the social scan the following villages were identified: Motlhabe, Legkraal/Bofule, Ngweding, Magong, Ntsana-le-Metsing, Tlhatlhaganyane, Mabeleleng and Tlhorosane. Consultation Employees in the Mine were the previous landowners and they have not yet Simon Theledi (BBKTA) It is expected that employees at the mine live in the communities and process been consulted. Need to engage with the Kgosanas, Land Committees and Comments received 04 April would be engaged through the relevant community structures. In CPAs as well as have a meeting at the mine for the workers. When are you 2019 at PPM Open Day addition, site notices were placed at the entrance to the mine for going to have other meetings again? employees to take note of. 2 PPM Plant Expansion Project 710.16002.00026 Response provided by SLR (unless otherwise specified) (updated Specific issue Issue raised By whom, when, how where necessary) Consultation In terms of the proposed Public Meetings, why have you only selected the Thabo, BBKTA. The selected villages are the doorstep villages to PPM. It was agreed process said places if Bakgatla has 32 villages? Comments received 23 April during the traditional council meeting that Lesetlheng, Ramasedi, 2019 at BBKTA Meeting Ramoga and Legkraal would be clustered together; Motlhabe, Ngweding, Ntswana le Metsing, Magong and Magalane would be clustered together and Lekutung would be met with on its own. Why are you here today? Ananius Dube, Motlhabe The purpose of the meeting was to facilitate feedback to the Community Member community on the PPM Plant Expansion project. Comment received 08 June 2019 at Community Meeting What are your overarching objectives for the open day? What general Mesegane Mesegane (III) The purpose of the open day was to provide I&APs with an categories of information would you plan to share with the stakeholders? (BBKTA) opportunity to interact with the SLR and PPM project team, address What would be your indicators of success for the overall engagements? Comments received 04 April any queries of clarification and to provide comments on the outcome 2019 at PPM Open Day of the EIA process and related EIA and EMPr. Information shared at the open day related to the technical project scope and the outcome of the EIA and EMPr process. Would like an electronic copy of the report. Joyce Pule (BBKTA) An electronic copy of the report on CD was provided to Ms Pule at the Comments received 04 April open day. 2019 at PPM Open Day Frustrated with the process. Raising of issues is on-going and there is no Jacob Rasepae (Lesetlheng Questions and comments were addressed during the open day where response or action from the mine. Community) Comments they related to the proposed project. Any comments related to received 04 April 2019 at PPM current PPM operations should be addressed directly with PPM Open Day through their community liaison team. Impact Impact Assessment: Mesegane Mesegane (III) These points have been noted and were considered when compiling Assessment 1. Impact Title changes to social and cultural practices in local communities. (BBKTA) the EIA and EMPr. 2. Impact nature: Whether the impacts are positive or negative and whether Comments received 04 April it is direct or indirect.