APPLICATION FOR A MINING PERMIT AND RELATED ENVIRONMENTAL APPROVALS FOR BORROW PIT 3 ADJACENT TO THE R61 SECTION 6 KM 52.6, EASTERN CAPE PROVINCE.

DRAFT SCOPING REPORT

DMR REFERENCE: Pending.

Prepared for: On behalf of:

South African National Roads Agency Ltd (SANRAL)

Prepared by:

EOH Coastal & Environmental Services EAST LONDON 25 Tecoma Street, Berea East London 5214 043 726 7809 Also in Grahamstown, Cape Town, Johannesburg, Port Elizabeth and Maputo (Mozambique) www.cesnet.co.za or www.eoh.co.za

October 2017

Draft Scoping Report – October 2017

This Report should be cited as follows: EOH Coastal & Environmental Services, October 2017: Rehabilitation of National Route R61 Section 6: Borrow Pit 3, Draft Scoping Report, EOH CES, East London.

REVISIONS TRACKING TABLE

EOH Coastal and Environmental Services Report Title: Application for a mining permit and related environmental approvals for borrow pit 3 adjacent to the R61 section 6 km 52.6: Borrow Pit 3, Scoping Report Report Version: Draft Project Number: 204 Name Responsibility Date

Thina Mgweba Report Writer October 2017

Caitlin Smith Project Manager/ Report Writer October 2017

Dr Alan Carter Reviewer October 2017

Copyright This document contains intellectual property and propriety information that are protected by copyright in favour of EOH Coastal & Environmental Services (EOH CES) and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of EOH CES. The document is prepared exclusively for submission to SANRAL in the Republic of South Africa, and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.

EOH Coastal & Environmental Services iii SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 TABLE OF CONTENTS

INTRODUCTION ...... 1 Background to the Study ...... 1 Environmental Authorisation in South Africa ...... 1 Scoping Phase ...... 1 Nature and Structure of this Scoping Report ...... 1 Assumptions and Limitations ...... 1 Mining Right Application ...... 1 Details and Expertise of the Environmental Assessment Practitioner ...... 2 1.7.1 Details of the EAP...... 2 1.7.2 Expertise of the study team ...... 2 LOCATION OF ACTIVITY ...... 4 Property Locality ...... 4 Property Locality ...... 4 PROJECT DESCRIPTION ...... 6 Description of Proposed Activity ...... 6 Listed activities triggered ...... 8 RELEVANT LEGISLATION ...... 9 Relevant Legislation and Guidelines used in the Compilation of this Scoping Report ...... 9 Relevant policy ...... 10 4.2.1 National Policy ...... 10 4.2.2 Provincial Policy ...... 10 4.2.3 Municipal planning documents ...... 11 The Engcobo IDP (2014/2015) ...... 11 PROJECT NEED & DESIRABILITY ...... 12 PROJECT ALTERNATIVES ...... 13 Reasonable and Feasible Alternatives ...... 13 Fundamental Alternatives ...... 13 Incremental Alternatives ...... 13 No-Go development ...... 13 Analysis of alternatives ...... 14 PUBLIC PARTICIPATION ...... 18 Notification of Interested and Affected Parties ...... 18 7.1.1 Public Participation ...... 18 7.1.2 Newspaper advertisement ...... 18 7.1.3 On-site Notice ...... 18 7.1.4 Stakeholders and I&APs ...... 18 7.1.5 Background information document ...... 19 7.1.6 Proof of notification ...... 19 7.1.7 Issues raised by stakeholders/ I&APs ...... 19 DESCRIPTION OF THE ENVIRONMENT ...... 20 The Bio-Physical Environment ...... 20 8.1.1 Current land use ...... 20 8.1.2 Climate ...... 21 8.1.3 Topography ...... 21 8.1.4 Geology and soils ...... 22 Rivers and wetlands ...... 23 Vegetation ...... 24 8.3.1 Mucina and Rutherford ...... 24 Conservation and spatial planning tools ...... 25 8.4.1 Eastern Cape Biodiversity Conservation Plan ...... 25 8.4.2 Protected Areas (NEMPAA & NPAES) ...... 26 8.4.3 Photographs of the borrow pit site: ...... 27 Socio-Economic Profile...... 28 8.5.1 Population ...... 28 8.5.2 Employment ...... 28

EOH Coastal & Environmental Services iv SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 8.5.3 Education ...... 28 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED ...... 29 Possible Environmental Issues and Impacts ...... 29 PLAN OF STUDY FOR EIA PHASE ...... 32 Scope and Intent of the EIA Phase ...... 32 10.1.1 Specialist Studies ...... 32 10.1.2 Environmental Impact Report...... 32 10.1.3 Issues and Response Trail...... 32 10.1.4 Environmental Management Programme ...... 33 10.1.5 Record of Decision of Environmental Authorisation and Appeals Process...... 33 The Public Participation Process ...... 33 10.2.1 Public Review Of The Draft Scoping Report ...... 33 10.2.2 Public Review Of The Draft Environmental Impact Report ...... 33 10.2.3 Notification Of Environmental Authorisation ...... 33 Environmental Impact Report ...... 34 10.3.1 Structure of the EIA Report ...... 34 Specialist Studies ...... 35 10.4.1 Paleontological Assessment ...... 35 10.4.2 Heritage Assessment ...... 35 Methodology for assessing the significance of impacts ...... 35 CONCLUSIONS AND RECOMMENDATIONS ...... 39 Activity and Possible Impacts ...... 39 Fatal Flaws ...... 39 The EIA Phase ...... 39 REFERENCES...... 40 APPENDICES ...... 41 Appendix A: Public participation documents ...... 41 13.1.1 Newspaper advert: ...... 41 13.1.2 Background Information Document: ...... 43 13.1.3 Notice board ...... 50 13.1.4 Letter of notification...... 52 13.1.5 Landowner permission from the Chief: ...... 54 13.1.6 Public Meeting Minutes ...... 58 13.1.7 Public Meeting Attendance Register ...... 61 13.1.8 Interested and affected parties database ...... 65

LIST OF FIGURES

Figure 1.1 The EIA process...... 3 Figure 2.1. Locality map of the proposed borrow pit site...... 5 Figure 3.1 Proposed layout of the borrow pit...... 7 Figure 8.1. Land use map for the study area...... 20 Figure 8.2 Sheep grazing on the borrow pit site...... 21 Figure 8.3: Engcobo average monthly temperatures (°C) and rainfall (mm) (Adapted from http://www.saexplorer.co.za/south-africa/climate/engcobo_climate.asp) ...... 21 Figure 8.4 Topography of the study area...... 22 Figure 8.5. Geology of the study area...... 23 Figure 8.6 Rivers in the study area...... 24 Figure 8.7 SANBI vegetation map of the study area...... 25 Figure 8.8. ECBCP map of the study area...... 26 View looking east towards the borrow pit ...... 27 View looking west from the borrow pit site ...... 27 Graves near the borrow pit site ...... 27 Sheep grazing on site ...... 27 Figure 8.9. Employment figures for the ELM (ELM IDP, 2014/2015)...... 28

EOH Coastal & Environmental Services v SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 LIST OF TABLES

Table 1.1: Listed activities triggered by the proposed borrow pit...... 1 Table 2.1: Property details ...... 4 Table 2.2: Coordinates of the corner points of the borrow pit site...... 4 Table 3.3: Listed activities triggered by the proposed borrow pit...... 8 Table 4.1: Environmental legislation considered in the preparation this Scoping Report...... 9 Table 6.1: The alternatives considered for the proposed mudstone borrow pit...... 15 Table 9.1: Issues and impacts identified in the planning and design phase of the proposed borrow pit...... 29 Table 9.2: Issues and impacts identified in the construction phase of the proposed borrow pit...... 30 Table 9.3: Issues and impacts identified in the operation phase of the proposed borrow pit...... 30 Table 9.4: Issues and impacts identified in the decommissioning phase of the proposed borrow pit...... 31 Table 10.1. Significance Rating Table ...... 36 Table 10.2. Impact Severity Rating ...... 36 Table 10.3. Overall Significance Rating ...... 37

LIST OF ACRONYMS

BAR Basic Assessment Report BID: Background Information Document CBA: Critical Biodiversity Areas CITES: Committee for International Trade in Endangered Species DEA: Department of Environmental Affairs DWS: Department of Water and Sanitation EAP: Environmental Assessment Practitioner ECO Environmental Control Officer EIA: Environmental Impact Assessment EIR: Environmental Impact Report EMPr: Environmental Management Programme GNR: Government Notice Regulation ha: Hectare I&APs: Interested and Affected Parties IDP: Integrated Development Plan NEMA: National Environmental Management Act 107 of 1998 as amended NFEPA National Freshwater Ecosystem Priority Area PoS: Plan of Study PAES Protected Areas Expansion Strategy PPP: Public Participation Process RDB: Red Data Book SAHRA South African Heritage Resources Agency SANBI South African National Biodiversity Institute SSC: Species of Special Concern ToR: Terms of Reference

EOH Coastal & Environmental Services vi SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 INTRODUCTION

Background to the Study

The South African National Roads Agency Ltd. (SANRAL) will be constructing various safety improvements on Section 6 of the R61 National Route from (KM 52.6) in the Engcobo Local Municipality in the Eastern Cape Province.

A mudstone borrow pit is required to supply the necessary hard rock material for road construction. A suitable borrow pit has been identified approximately 750m off the R61 Section at Km 52.6 in the Beyele Administrative Area in the Engcobo Local Municipality, Eastern Cape.

In terms of Section 106 of the Mineral and Petroleum Resources Development Act (Act No. 28 of 2002; MPRDA) SANRAL is exempted from the application for a Mining Right for the borrow pit but is not exempted from the application for environmental authorisation for the borrow pit. EOH Coastal and Environmental Services (EOH CES) has been appointed by Mott Macdonald (the project managers) as the EAP to undertake the Environmental Impact Assessment (EIA) for the proposed borrow pit.

Environmental Authorisation in South Africa

The regulation and protection of the environment within South Africa occurs mainly through the application of various items of legislation, within the regulatory framework of the Constitution (Act 108 of 1996).

The primary legislation regulating Environmental Impact Assessments (EIA) within South Africa is the National Environmental Management Act (NEMA, Act 107 of 1998). NEMA makes provision for the Minister of Environmental Affairs to identify activities which may not commence prior to authorisation from either the Minister or the provincial Member of the Executive Council (MEC). In addition to this, NEMA also provided for the formulation of regulations in respect of such authorisations.

The EIA regulations (2014) (amended 2017) allow for a Basic Assessment process for activities with limited environmental impact (listed in GNR. 327 and 324, 2017) and a more rigorous two- tiered approach for activities with potentially greater environmental impact (listed in GNR. 325, 2017). This two-tiered approach includes both a Scoping and EIA process (Figure 1.1).

The listed activities that have been applied for are provided in Table 1.1 below. The proposed borrow pit triggers the need for a Full Scoping and EIA process under the NEMA Regulations (2014) (amended 2017) in terms of Listing Notices 1 and 2 published in Government Notices No. R. 327 and R. 324, respectively.

The proposed borrow pit requires a Full Scoping and EIA due to the following triggers in terms of GNR 325:

Table 1.1: Listed activities triggered by the proposed borrow pit. Government Activity Relevance to this project Activity Description Notice Number Any activity including the operation of that  The project involves the activity which requires a mining right as development of a mudstone contemplated in Section 22 of the MPRDA borrow pit and this requires that (2002), including – (a) associated an application for environmental GNR 325 17 infrastructure, structures and earthworks, authorisation be submitted to directly related to the extraction of a mineral DMR (as per GNR 325 No. 17). resource or (b) the primary processing of a mineral resource including winning, extraction, classifying, concentrating,

EOH Coastal & Environmental Services 1 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

Government Activity Relevance to this project Activity Description Notice Number crushing, screening or washing. Any activity including the operation of that  Processing of mineral resources; activity associated with the primary specifically crushing and GNR 984 processing of a mineral resource including screening onsite. 21 winning, reduction, extraction, classifying, concentrating, crushing, screening and washing.

The Department of Mineral Resources (DMR) is the competent authority that will consider this EIA.

EOH Coastal & Environmental Services 2 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

Contextualise Proposed Development

Pre-Application Planning

Adopt the Scoping & Environmental Impact Assessment Process

Submit Application to Relevant Authority

Conduct Public Participation Process

Scoping Report and Plan of Study for the EIA

Public Review of Scoping Report and Plan of Study of the EIA

Authority Review of Scoping Request Report and Plan of Study of the EIA Amendments

Accept

Conduct Environmental Impact Assessment. Compile EIR and EMPr

Public Review of EIR and EMPr

Authority Review of EIR and EMPr Request Amendments

Accept

Issue Environmental Authorisation and notify applicant of conditions and appeal provisions

Notify I&APs of Environmental Authorisation and appeal provisions

Consider Appeals if any

Figure 1.1 The EIA process.

EOH Coastal & Environmental Services 3 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Scoping Phase

The Scoping Phase is designed to determine the “scope” of the subsequent Environmental Impact Assessment (EIA), conducted in fulfilment of the application for authorisation. The overall aim of the Scoping Phase is to determine those environmental issues and impacts associated with the proposed borrow pit that require further investigation in an EIA. The purpose of scoping is therefore to identify:

 Environmental Issues  Impacts  Alternatives

Also integral to the Scoping Phase is the initial public participation process (PPP). This process ensures that all possible interested and affected parties (I&APs) are informed of the proposed activity and are provided with an opportunity to comment and identify issues.

Nature and Structure of this Scoping Report

This Scoping Report fulfils the requirement of the EIA Regulations (2014) (amended 2017) for the documentation of the Scoping Phase. The structure of this report is based on APPENDIX 2 of GNR No. 326, of the Environmental Impact Assessment Regulations (2014) (amended 2017), which clearly specifies the required content of a Scoping Report.

Assumptions and Limitations

This Scoping Report is based on currently available information and, as a result, the following limitations and assumptions are implicit–

 The report is based on project information provided by the client.  Descriptions of the natural and social environments are based on limited fieldwork and available literature. More information will be provided in the EIA phase.

Mining Right Application

SANRAL is exempted from the application for a Mining Right for the borrow pit, but is not exempted from the application for Environmental Authorisation (EA). The borrow pit requires an application for EA in terms of NEMA (Act 107 of 1998) and a mining authorisation in terms of the MPRDA (No. 28 of 2002).

EOH Coastal & Environmental Services 1 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Details and Expertise of the Environmental Assessment Practitioner

In terms of APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report must include –

(a) Details of– (i) The EAP who prepared the report; and (ii) The expertise of the EAP, including a curriculum vitae.

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

1.7.1 Details of the EAP

EOH was established in 1990 as a specialist environmental consulting company and has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, State of Environment Reporting (SOER), Integrated Waste Management Plans (IWMP), EMPs, Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the EIA and Strategic Environmental Assessment (SEA) processes.

1.7.2 Expertise of the study team

Dr Alan Carter (EAP) Alan is the executive of the CES East London Office. He holds a PhD in Marine Biology and is a certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years’ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP). He is also registered as an EAP by the Environmental Assessment Practitioners of South Africa (EAPSA).

EOH Coastal & Environmental Services 2 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Ms Caitlin Smith Senior Environmental Consultant. Caitlin holds a BSc degree with majors in Geology and Geography and a BSc Honours Degree (with distinction) in Geology both obtained from Nelson Mandela Metropolitan University. Caitlin is a qualified geologist and has managed and been involved in various Environmental Impact Assessments. Her interest lies in the water sector, specifically in wetland related studies. She has completed various Aquatic and Wetland assessments for road and infrastructure projects. She is currently studying her MSc degree in Hydrology at Rhodes University focusing on the groundwater and surface water interactions of the Kromme River wetlands.

Ms Thina Mgweba Thina is an Environmental Consultant. She holds a BSc degree in Economics and Environmental Science as well as a BSc Honours degree in environmental science both from Rhodes University. Her honours dissertation investigated climate change resilience and adaptation in the coastal villages of Hamburg, Eastern Cape. Her professional interests include the development of climate change strategies, environmental economic analyses as well as social impact assessments.

EOH Coastal & Environmental Services 3 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 LOCATION OF ACTIVITY

In terms of APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report must include –

b) The location of the activity, including – (i) The 21 digit Surveyor General code of each cadastral land parcel; (ii) Where available, the physical address and farm name; (iii) Where the required information in terms of (i) and (ii) is not available, the coordinates of the boundary of the property or properties; c) PropertyA plan whichLocality locates the proposed activity or activities applied for at an appropriate scale

Property Locality

The proposed borrow pit is located approximately 750m off the R61 Section at Km 52.6 (from Qumanco River to Engcobo CBD) in the Beyele Administrative Area in Engcobo Local Municipality, Eastern Cape. Figure 2.1 illustrates the proposed borrow pit site.

Property details are illustrated in Table 2.1 below. Coordinates of the proposed borrow pit site is illustrated in Table 2.2.

Table 2.1: Property details Province Eastern Cape District Municipality Chris Hani District Municipality (CHDM) Local Municipality Engcobo Local Municipality (ELM) Erf details Beyele Administrative Area

Table 2.2: Coordinates of the corner points of the borrow pit site. Latitude (S) (DDMMSS) Longitude (E) (DDMMSS) 31°45'4.15"S 27°57'11.68"E 31°44'56.88"S 27°57'17.60"E 31°44'55.41"S 27°57'21.33"E 31°44'56.52"S 27°57'23.12"E 31°44'57.10"S 27°57'28.18"E 31°44'59.12"S 27°57'28.39"E 31°45'6.16"S 27°57'18.47"E 31°45'8.09"S 27°57'11.68"E

EOH Coastal & Environmental Services 4 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

Figure 2.1. Locality map of the proposed borrow pit site.

EOH Coastal & Environmental Services 5 SANRAL R61 Road Upgrade Mudstone Borrow Pit Draft Scoping Report – October 2017 PROJECT DESCRIPTION

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a

Scoping Report must include -

d) A description of the scope of the proposed activity, including –

(i) All listed and specified activities triggered;

(ii) A description of the activities to be undertaken, including associated

structures and infrastructure

Description of Proposed Activity

SANRAL will be constructing various safety improvements on Section 6 of the R61 National Route from Qumanco River to Engcobo in the Eastern Cape Province. Mott MacDonald, the project managers, have appointed EOH CES as the EAP to undertake the Environmental Impact Assessment for this project.

A mudstone borrow pit is required to supply the necessary rock material for road construction. A suitable borrow pit site has been identified approximately 750m off the R61 at Km 52.6 in the Beyele Administrative Area in the Engcobo Local Municipality, Eastern Cape.

A perimeter fence will be constructed around the borrow pit site (Figure 3.1). The borrow pit area is approximately 8.8 hectares in size. The fence has a perimeter of approximately 1285 m. Approximately 45 129 m3 of topsoil will be taken off the borrow pit site and stockpiled. The topsoil stock pile area is 0.30 Ha in size. The borrow pit should yield approximately 405 394.16 m3 of mudstone rock for crushing. Rock will only be stored temporarily in stockpiles on site (taking up a total area of 0.54 Ha) before being crushed and taken off site.

EOH Coastal & Environmental Services 6 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

Figure 3.1 Proposed layout of the borrow pit.

EOH Coastal & Environmental Services SANRAL R61 Road Upgrade Borrow Pit 7 Draft Scoping Report – October 2017 Listed activities triggered

The proposed borrow pit triggers the need for a Full Scoping and EIA process under the NEMA Regulations (2014) (amended 2017) in terms of Listing Notices 1 and 2 published in Government Notices No. R. 327 and R. 325 respectively. The listed activities that have been applied for are provided in Table 3.3 below.

Table 3.3: Listed activities triggered by the proposed borrow pit. Government Activity Relevance to this project Activity Description Notice Number The decommissioning of any activity  Decommissioning of the requiring (i) a closure certificate in terms borrow pit once mining is GNR 327 22 of Section 43 of the MPRDA (2002). complete will require a closure certificate. The clearance of an area of 1 hectare or  The borrow pit will require GNR 327 more, but less than 20 hectares of clearance of more than 1 27 indigenous vegetation. hectare of indigenous vegetation. Any activity including the operation of  The borrow pit will be used for that activity which requires a mining right mining material to be used in as contemplated in Section 22 of the road construction MPRDA (2002), including – (a) (approximately 8.8 ha in size). associated infrastructure, structures and  Any activity which requires a GNR 325 17 earthworks, directly related to the mining right, including extraction of a mineral resource, or (b) activities for which an the primary processing of a mineral exemption has been issued, require that an application for resource including winning, extraction, environmental authorisation classifying, concentrating, crushing, be submitted to DMR. screening or washing.

EOH Coastal & Environmental Services 8 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 RELEVANT LEGISLATION

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report must include –

e) A description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that

are applicable to this activity and are to be considered in the assessment process.

Relevant Legislation and Guidelines used in the Compilation of this Scoping Report

The table below (Table 4.1) summarises the legislation and policy guidelines that are relevant to the proposed borrow pit.

Table 4.1: Environmental legislation considered in the preparation this Scoping Report. Title of Environmental Legislation, Policy or Implications for the proposed borrow pit Guideline Constitution Act  Obligation to ensure that the borrow pit will not result in (108 of 1996; CA) pollution and ecological degradation; and  Obligation to ensure that the proposed borrow pit is ecologically sustainable, while demonstrating economic and social development. National Environmental  The developer must be mindful of the principles, broad liability Management Act (NEMA) and implications associated with NEMA and must eliminate or and the EIA Regulations mitigate any potential impacts. 2014 (amended 2017): GN R.  The developer must also be mindful of the principles, broad 327 and GN R.324 (No. 107 liability and implications of causing damage to the of 1998) environment.  The developer must also comply with the EIA Regulations (2014) (amended 2017) in the terms of the Act which specifies when an environmental authorisation is required and the nature of the EIA process. Mineral and Petroleum  The purpose of the Act is to regulate the prospecting for and Resources Development Act the optimal exploitation, processing and utilization of minerals; (No. 28 of 2002; MPRDA) to regulate the orderly utilization and the rehabilitation of the surface of land during and after prospecting and mining operations; and to provide for matters connected therewith.  SANRAL is exempted from the application for a Mining Permit/Right, but is not exempted from an application for Environmental Authorisation.  Any activities requiring extraction of sand or hard rock for construction purposes will require the submission of an application to DMR for Environmental Authorisation. National Environmental  The proponent must ensure that all activities associated with Management: Waste Act (No the project address waste related matters in compliance with 59 of 2008; NEM:WA) the requirements of the Act. National Water Act  Appropriate measures must be taken to prevent the pollution (No. 36 of 1998; NWA) of watercourses.  Riparian zones must be protected.  Any mining activity that takes place within 100 m of a watercourse or within 500 m of a wetland will require a water use licence (section 21(c) and (i) of the National Water Act).

EOH Coastal & Environmental Services 9 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Title of Environmental Legislation, Policy or Implications for the proposed borrow pit Guideline National Heritage Resources  The Act requires all developers (including mines), to undertake Act (No. 25 of 1999) cultural heritage studies for any development exceeding 5000 m2 in size. It also provides guidelines for impact assessment studies to be undertaken whenever cultural resources may be destroyed by development activities.  ECPHRA needs to be informed of the project.  Should heritage resources be identified during mining, appropriate measures must be undertaken to involve ECPHRA and to protect these resources. Mine Health and Safety Act  The key objectives of the Act are to provide for the health and (No. 29 of 1996) safety of persons at work and in connection with the use of plants and machinery.  This Act will be applicable during all phases of the project and therefore necessary measures should be taken to ensure compliance. National Environmental  The purpose of this Act is to provide for national norms and Management: Air Quality Act standards regulating air quality monitoring, management and (No. 39 of 2004; NEM: AQA) control.  This Act will be applicable during all phases of the project. The necessary measures must be taken to ensure compliance. National Environmental  If any declared weed and/or invader species listed in terms of Management: Biodiversity this Act is present on site, it must be removed. Act (No 10. of 2004), Alien and invasive species (2016)

At this stage in the EIA process, the above list should not be regarded as complete or exhaustive, and it is probable that additional legislative requirements will be identified as the process progresses.

Relevant policy

The proposed borrow pit is required to provide construction material for the upgrade of the National Route R61 Section 6. The policy listed below is thus relevant to the road upgrade.

4.2.1 National Policy

National Development Plan

The National Development Plan (NDP) (also referred to as Vision 2030) is a detailed plan produced by the National Planning Commission in 2011 that is aimed at reducing and eliminating poverty in South Africa by 2030. The NDP represents a new approach by Government to promote sustainable and inclusive development in South Africa, promoting a decent standard of living for all, and includes key focus areas, such as improvement of roads and transport facilities.

4.2.2 Provincial Policy

The Eastern Cape Vision 2030 Provincial Development Plan sets out nine key challenges that need to be addressed in the Eastern Cape. The challenge relevant to the proposed project has been extracted below:

EOH Coastal & Environmental Services 10 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 (3) Infrastructure is poorly located, under-maintained and insufficient to foster higher growth and spatial transformation. • The road network is severely stressed and deteriorating.

“…Because there are existing plans for the major arterial routes in the province, the programme will focus on building feeder and secondary roads, particularly rural and access roads, to ensure that no village is without a well-maintained connection to national roads and service centres by 2030.”

4.2.3 Municipal planning documents

The Engcobo IDP (2014/2015)

The Engcobo Local Municipality IDP (ELM IDP, 2014/2015) highlights the fact that there are serious road infrastructure challenges in the Municipality. The ELM IDP mentions the poor conditions of the roads and acknowledges that there are huge backlog challenges with regard to road maintenance.

EOH Coastal & Environmental Services 11 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 PROJECT NEED & DESIRABILITY

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report must include –

f) A motivation for the need and desirability for the proposed development including the need and desirability of the activity in the context of the preferred location.

The proposed borrow pit will supply construction material for the upgrade of Section 6 of the R61 National Road.

The need and desirability of this project is supported by National, Provincial and Municipal policy documents.

 The road upgrade speaks directly to the National Development Plan for 2030. The vision statement of the NDP specifically mentions transport and improvement of roads.

 The Eastern Cape Vision 2030 Provincial Development Plan (PDP) emphasises the challenge of road networks in the Eastern Cape and explains that roads are severely stressed and deteriorating. The PDP continues to explain that there are existing plans for the major arterial routes in the province and focus should be given to the construction of feeder and secondary roads. This is to ensure that no village is without a well-maintained connection to national roads.

 The ELM IDP (2014/2015) highlights the provision and maintenance of road infrastructure in the strategic framework of the LM.

EOH Coastal & Environmental Services 12 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 PROJECT ALTERNATIVES

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report must include –

(g) A full description of the process followed to reach the proposed preferred activity, site and location of the development footprint within the site, including – (i) Details of all the alternatives considered;

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

Reasonable and Feasible Alternatives

Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The no-go alternative must also in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment.

“Alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to; - a) the property on which or location where it is proposed to undertake the activity. b) the type of activity to be undertaken. c) the design or layout of the activity. d) the option of not implementing the activity.

Fundamental Alternatives

Fundamental alternatives are developments that are totally different from the proposed project description and usually include the following:  Alternative property or location where it is proposed to undertake the activity.  Alternative type of activity to be undertaken.  Alternative technology to be used in the activity.

Incremental Alternatives

Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered, including:  Alternative design or layout of the activity.  Alternative technology to be used in the activity.  Alternative operational aspects of the activity

No-Go development

The EIA process is obligated to assess the status quo (i.e. the “No-Go” option). The No-Go alternative provides the assessment with a baseline against which predicted impacts resulting from the proposed development may be compared. A ‘’No-Go” alternative has been assessed for the proposed borrow pit.

EOH Coastal & Environmental Services 13 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Analysis of alternatives

Table 6.1 illustrates the methodology used to assess the identified alternatives. The table assesses the advantages and disadvantages, and provides further comments on the selected alternatives.

EOH Coastal & Environmental Services 14 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Table 6.1: The alternatives considered for the proposed mudstone borrow pit.

Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment Property or location Alternative location  The geology of the  Loss of rural YES YES The main (Fundamental 1 - Current proposed proposed borrow grazing/ determining factors location alternative) site (preferred pit site is ideal for agricultural for selecting the alternative). the material land. proposed location required.  Removal of were:-  The borrow pit is approximately  Appropriate located in close 8.8 hectares of geology of the proximity to the indigenous area. road portion that vegetation.  Location of the will be upgraded.  Possible borrow pit resettlement of relative to the nearby road upgrade residents. site.

Alternative location N/A N/A N/A N/A  Alternative 2 – None identified. locations for the proposed borrow pit are limited and probably not reasonable or feasible due to inappropriate geology.  The appropriate geology was considered a critical aspect.  No alternative location will be assessed in the impact assessment.

EOH Coastal & Environmental Services SANRAL R61 Road15 Upgrade Borrow pit Draft Scoping Report – October 2017 Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment

Type of technology Alternative  Time effective, i.e.  Increase in YES YES This is the preferred This refers to the technology 1 – shorter time noise levels on and feasible mining fundamental Opencast mining required for site and method. technology options using excavators and processing possible required to operate crushing and material disturbance to the borrow pit. screening area on site  Cost effective surrounding (preferred alternative) areas.  Dust disturbance the surrounding areas especially during windy conditions. Alternative  Less noise and  Higher cost to YES NO This mining method technology 2 – dust generated on have a will not be assessed Opencast mining site. crushing and further in the impact using excavators, screening area assessment process transporting material offsite. due to the high costs for crushing and  Materials will involved in screening to an area have to be transporting material offsite transported to an offsite crusher. from the borrow pit site to be processed. Layout alternative Alternative layout 1  The proposed  Possible YES YES This is the preferred Incremental – Current proposed borrow pit layout resettlement of layout and will be alternative. layout (preferred is ideal based on surrounding assessed further in alternative). geological residents the impact conditions. required. assessment. The  This layout also proposed layout has takes into account been subjected to environmental environmental conditions of the screening.

EOH Coastal & Environmental Services SANRAL R61 Road16 Upgrade Borrow pit Draft Scoping Report – October 2017 Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment site. Alternative layout 2 -  N/A  N/A N/A N/A No other layout will none chosen because be assessed further the preferred mining in the impact area layout is assessment. designed based on geological/ geotechnical investigations and environmental issues. No-go option Current land use of - Area will not be - Less job creation. YES YES Will be assessed This refers to the the proposed site is disturbed by - Area will likely further in the impact current status quo rural grazing land. mining operations suffer further assessment and the risks and - Less damage to erosion due to process. impacts associated the environment overgrazing and with it. - Surrounding poor land residents will not management. be affected by - Material from resettlement, noise more distant and dust alternative locations will have to be sourced for upgrading the R61. - Will negatively affect socio- economic development in the region.

EOH Coastal & Environmental Services SANRAL R61 Road17 Upgrade Borrow pit Draft Scoping Report – October 2017 PUBLIC PARTICIPATION

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report and must include - g) A full description of the process followed to reach the proposed preferred activity, site and location of the development footprint within the site, including – (ii) Details of the public participation process undertaken in terms of regulation 41 of the Regulations, including copies of the supporting documents and inputs; (iii) A summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them.

Notification of Interested and Affected Parties

7.1.1 Public Participation

Public consultation is a legal requirement throughout the EIA process. The proponent is required to conduct public consultation throughout the Scoping and EIR phase. Formal EIA documents are required to be made available for public review and comment by the proponent, these include the Project Brief, Scoping Report and Terms of Reference for the EIA, the draft and final EIA reports and the decision of the Competent Authority. The method of public consultation to be used depends largely on the location of the development and the level of education of those being impacted on by the project. Required means of public consultation include:

 Site notice/s;  Newspaper advertisements;  Letter of Notification to affected landowner(s), stakeholders and registered I&APs;  Background Information Document (BID) distribution;  Focus group site meeting (Attendance register and meeting minutes);  Authority and Stakeholder engagement (DMR, DEDEAT, DWS).

7.1.2 Newspaper advertisement

The borrow pit was advertised in the Daily Dispatch on 24 October 2016. This advert included notification that a mining authorisation would be lodged with DMR for the proposed borrow pit. This advert provided detail about the proposed project and provided Interested and Affected Parties with an opportunity to register and comment on the project.

7.1.3 On-site Notice

A notice board was placed at the entrance of the access road to the borrow pit in close proximity to the site (see Appendix A).

7.1.4 Stakeholders and I&APs

Certain stakeholders were identified based on their potential interest in the project. These stakeholders were contacted either via e-mail or telephone for comment and were sent a Letter of Notification (LoN) and a Background Information Document (BID). A public meeting will be held about the proposed borrow pit on the 10 November 2016 where any issues raised by the community will be incorporated in the Scoping and EIA Reports. A list of stakeholders and I&APs is available in Appendix A. These stakeholders will notified of the EIA process for the borrow pit and will be notified of the availability of the draft Scoping Report for public review. Any new I&APs registered will be added to this list.

EOH Coastal & Environmental Services 18 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017 7.1.5 Background information document

A Background Information Document (BID) for the proposed borrow pit was distributed to identified stakeholders and I&APs on 31 October 2016 (see Appendix A).

7.1.6 Proof of notification

Stakeholders and I&APs were notified via email/registered mail/telephone about the proposed borrow pit (Appendix A).

7.1.7 Issues raised by stakeholders/ I&APs

The Issues and Response Trail is updated throughout the EIA process and will include all comments received until submission of the final EIR to the competent authority.

EOH CES will hold a public meeting during the Scoping phase where the proposed borrow pit will be discussed.

EOH Coastal & Environmental Services 19 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017 DESCRIPTION OF THE ENVIRONMENT

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report must include –

g) A full description of the process followed to reach the proposed preferred activity, site and location of the development footprint within the site, including – (iv) The environmental attributes associated with the alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

The Bio-Physical Environment

8.1.1 Current land use

The study area falls within degraded unimproved grassland and cultivated land. The area is generally overgrazed by livestock such as goats and sheep (Figure 8.1).

Figure 8.1. Land use map for the study area.

EOH Coastal & Environmental Services 20 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017

Figure 8.2 Sheep grazing on the borrow pit site.

8.1.2 Climate

Engcobo receives about 700 mm of rain per year, with most rainfall occurring during summer. It receives the lowest rainfall (approximately 6 mm) in June and the highest (approximately 110 mm) in February (Figure 8.3). The average midday temperatures for Engcobo ranges from 18.6°C in June to 27°C in January. The region is the coldest during July when the temperature drops to 3.8°C on average during the night.

Figure 8.3: Engcobo average monthly temperatures (°C) and rainfall (mm) (Adapted from http://www.saexplorer.co.za/south-africa/climate/engcobo_climate.asp)

8.1.3 Topography A Figure 8.4 indicates the topography of the study area. The local region is mainly flat or has undulating plains intersected by mountains. The site is located on the slopes of a small hill which peaks at approximately 860 m above sea level (Figure 8.4).

EOH Coastal & Environmental Services 21 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017

Figure 8.4 Topography of the study area.

8.1.4 Geology and soils

The study area is located within mudstones and sandstones of the Tarkastad Subgroup (Beaufort Group). In the surrounding area these rocks are intruded by Karoo Dolerite. Further studies will be conducted by a paleontological specialist during the EIA phase as this site has a high paleontological sensitivity.

EOH Coastal & Environmental Services 22 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017

Figure 8.5. Geology of the study area.

Rivers and wetlands

No wetlands or rivers will be affected by the borrow pit site. The nearest wetland listed on the National Freshwater Ecosystem Priority Area (NFEPA) database is approximately 2 km northeast of the site. The closest non-perennial tributary is more than 100 m from the site with the Mgwali River approximately 1 km north of the site (Figure 8.6).

EOH Coastal & Environmental Services 23 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017

Figure 8.6 Rivers in the study area.

Vegetation

8.3.1 Mucina and Rutherford

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

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

Mucina and Rutherford (2006) define the vegetation type that occurs within the project area as Tsomo Grassland Biome (Figure 8.7).

 Tsomo Grassland usually occurs in the region to the east of Queenstown in the Eastern Cape, including Engcobo. This vegetation is a grassland or open thornveld, often grazed short or replaced by dwarf shrub. Mucina and Rutherford (2006) classify the Tsomo Grassland as having a vulnerable conservation status. According to the National Spatial Biodiversity Assessment (NSBA) 50% of this vegetation is conserved.

A site visit was conducted on the 22nd of September 2016, this visit revealed that the site is already transformed due to over-grazing and human impacts.

EOH Coastal & Environmental Services 24 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017

Figure 8.7 SANBI vegetation map of the study area.

Conservation and spatial planning tools

8.4.1 Eastern Cape Biodiversity Conservation Plan

The Eastern Cape Biodiversity Conservation Plan (ECBCP) is a first attempt at detailed, low-level conservation mapping for land-use planning purposes. Specifically, the aims of the Plan were to map critical biodiversity areas through a systematic conservation planning process. The current biodiversity plan includes the mapping of priority aquatic features, land-use pressures, and critical biodiversity areas which develops guidelines for land and resource-use planning and decision- making.

The main outputs of the ECBCP are the identification of “critical biodiversity areas” or CBAs, which are allocated the following management categories:

 CBA 1 = Maintain in a natural state  CBA 2 = Maintain in a near-natural state Land use outputs not classified as CBAs are called Biodiversity Land Management Classes (BLMCs) and are allocated the following management categories.

 BLMC 3 (CBA3) = Functional Landscapes  BLMC 4 (CBA 4) = Towns & Settlements, Woodlots & Plantations, Cultivated Land

EOH Coastal & Environmental Services 25 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017 The ECBCP maps CBAs based on extensive biological data and input from key stakeholders. Critical Biodiversity Areas (CBA 1 and 2), as defined by the ECBCP, form the foundation areas where conservation is priority. These areas provide essential ecosystem services. CBA Areas provide the spatial framework for future spatial development planning, particularly indicating those areas where development needs to be avoided or at best, carefully managed. The ECBCP, although mapped at a finer scale than the National Spatial Biodiversity Assessment (Driver et al., 2005) is still, for the large part, inaccurate and "coarse". Therefore it is imperative that the status of the environment, for any proposed development MUST first be verified before the management recommendations associated with the ECBCP are considered (Berliner and Desmet, 2007). In spite of these short-comings, the ECBCP has been adopted by the provincial department of Economic Development, Environmental Affairs and Tourism (DEDEAT) as a strategic biodiversity plan for the Eastern Cape.

Figure 8.8 illustrates that the proposed borrow pit site falls within an area classified as BLMC 3 (CBA 3). The site can be considered to have a low sensitivity. This was also confirmed at the site visit which revealed that the site is already transformed by over-grazing and human impacts.

Figure 8.8. ECBCP map of the study area.

8.4.2 Protected Areas (NEMPAA & NPAES)

There are no known National, Provincial or locally protected areas found within the general study area. There are no National Environmental Management Biodiversity Act (NEMBA) (National list or ecosystems that are threatened and in need of protection; 2014) classified ecosystems found within the study area.

EOH Coastal & Environmental Services 26 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017 8.4.3 Photographs of the borrow pit site:

View looking east towards the borrow pit View looking west from the borrow pit site

Graves near the borrow pit site Sheep grazing on site

EOH Coastal & Environmental Services SANRAL R61 Road27 Upgrade Borrow pit Draft Scoping Report – October 2017 Socio-Economic Profile

The borrow pit falls within the Engcobo Local Municipality (ELM) in the Chris Hani District Municipality (CHDM). The ELM consists of 20 wards and covers an area of approximately 2 259 km2.

8.5.1 Population

According to StatsSA (2011) the total population in the ELM is 155 513 and comprises predominantly black African people of which the majority is Xhosa speaking. 56% of the population is female. The average household size is 4 people and 57.7% of the households are female headed.

8.5.2 Employment

According to StatsSA (2011), 40% of the ELM population is not economically active and therefore depends on the 60% of the economically active population. The wholesale and retail trade sector employs the majority of people (3 318) followed by community services (3 076). Mining and quarrying is reported to be declining over the years and has an insignificant contribution to the ELM’s economy, employing just 33 people (ELM, IDP 2014/2015).

Figure 8.9. Employment figures for the ELM (ELM IDP, 2014/2015).

8.5.3 Education

According to StatsSA (2011) 19.7% of the population aged over 20 years and older have no form of education. Approximately 9.6 % of the population have completed Matric. 5.2% of the population have received Higher Education.

EOH Coastal & Environmental Services 28 SANRAL R61 Road Upgrade Borrow pit Draft Scoping Report – October 2017 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report

must include –

g) A full description of the process followed to reach the proposed preferred activity, site and location of the development footprint within the site, including – (v) The impacts and risks which have informed the identification of each alternative, including the nature, significance, consequence, extent, duration and probability of such identified impacts, including the degree to which these impacts –  Can be reversed;  May cause irreplaceable loss of resources; and  Can be avoided, managed or mitigated; (vi) The methodology used in identifying and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks associated with the alternatives; (vii) Positive and negative impacts that the proposed activity and alternatives will have on

the environment and on the community that may be affected focusing on the

geographical, physical, biological, social, economic, heritage and cultural aspects;

(viii) The possible mitigation measures that could be applied and level of residual risk; (ix) The outcome of the site selection matrix; (x) If no alternatives, including alternative locations for the activity were investigated, the motivation for not considering such; and (xi) A concluding statement indicating the preferred alternatives, including preferred location of the activity.

Possible Environmental Issues and Impacts

Table 9.1 to 9.4 lists the environmental issues that have been identified in the following phases of mining: planning and design, construction, operation and closure/decommissioning. A full impact assessment (which will include specialist impact assessments) will take place during the EIA phase once the Plan of Study and Final Scoping Report has been accepted by the competent authority.

Table 9.1: Issues and impacts identified in the planning and design phase of the proposed borrow pit. PLANNING AND DESIGN PHASE Further Issue Impact Significance Assessment Failure to adhere to existing policies and legal obligations could lead to the project conflicting with local, provincial and Compliance with national policies, legislation etc. This relevant policy HIGH NEGATIVE EIA could result in a lack of institutional and legislation support for the project, overall project failure or delays in mining and undue disturbance to the natural environment. An inappropriately designed borrow pit Design of the can lead to subsidence, face collapses, HIGH NEGATIVE EIA borrow pit erosion and stormwater issues. Inappropriate Inappropriate location of stockpiles, and location of processing area within the mining site can HIGH NEGATIVE EIA stockpiles and negatively impact on the surrounding processing area environment Topography – Permanent disturbance to the topography MODERATE EIA disturbance to of the study area due to mining activity. NEGATIVE

EOH Coastal & Environmental Services 29 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

PLANNING AND DESIGN PHASE Further Issue Impact Significance Assessment the topography of the study area Loss of communal grazing land. MODERATE EIA NEGATIVE Socio-economic Possible relocation of surrounding HIGH NEGATIVE EIA residents. Impact on Loss of Tsomo Grassland due to mining MODERATE EIA natural flora activity. NEGATIVE Sites of Loss of sites of archaeological, EIA archaeological, paleontological and cultural significance Heritage Impact cultural and due to poor planning of mining area. HIGH NEGATIVE Assessment paleontological Paleontological significance Impact Assessment

Table 9.2: Issues and impacts identified in the construction phase of the proposed borrow pit. CONSTRUCTION PHASE Further Issue Impact Significance Assessment Visual intrusion Construction activity on site and the associated with presence and use of large machinery on MODERATE the site and along access roads will result in a EIA NEGATIVE establishment of visual disturbance of the landscape. the mining area Location of Inappropriate siting of sanitation facilities MODERATE sanitation could result in contamination of surface EIA NEGATIVE facilities and ground water.

Table 9.3: Issues and impacts identified in the operation phase of the proposed borrow pit. OPERATION PHASE Further Issue Impact Significance Assessment Visual intrusion The mining activities could result in a MODERATE associated with negative impact on the aesthetic value of EIA NEGATIVE mining activities the study area and immediate surrounds. Storm water Surface water runoff due to mining MODERATE run-off related activities can result in soil erosion and EIA NEGATIVE issues impact surface water quality. Inadequate demarcation and fencing off of Demarcation of the borrow pit could lead to unnecessary HIGH NEGATIVE EIA borrow pit site environmental impacts. Spillage of Spillage of any hazardous substances hazardous such as fuel, chemicals, etc. can lead to substances the contamination of surface and MODERATE EIA such as fuel, groundwater. NEGATIVE chemicals, paint, etc. Dust will be generated from mining activities and from vehicles travelling on Dust control HIGH NEGATIVE EIA dirt roads. This might be a nuisance during windy conditions. Mining activities and movement of heavy Noise vehicles could result in an increase in HIGH NEGATIVE EIA ambient noise levels on site and on

EOH Coastal & Environmental Services 30 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

OPERATION PHASE Further Issue Impact Significance Assessment surrounding properties. During operation littering on site may Waste attract vermin, detract from the visual MODERATE EIA management appeal of the area, and pollute the NEGATIVE surrounding areas. During the operation phase, jobs will be Socio-economic created which will benefit the local BENEFICIAL EIA workforce. Identification of Sites of archaeological or cultural archaeological, significance might be uncovered and EIA paleontological damaged. Heritage Impact and sites of HIGH NEGATVIE Assessment cultural Paleontological significance Impact Assessment during the operation phase Inappropriate disturbance beyond the borrow pit footprint could result in EIA Impact on flora HIGH NEGATIVE unnecessary damage and loss of vegetation.

Table 9.4: Issues and impacts identified in the decommissioning phase of the proposed borrow pit. DECOMMISSIONING/CLOSURE PHASE Further Issue Impact Significance Assessment Compliance with Non-compliance with legislation and relevant policy closure requirements. HIGH NEGATIVE EIA and legislation Rehabilitation of Failure to rehabilitate site properly using HIGH NEGATIVE EIA site indigenous vegetation. Sloping and Failure to refill and level out the site HIGH NEGATIVE EIA landscaping sufficiently.

EOH Coastal & Environmental Services 31 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 PLAN OF STUDY FOR EIA PHASE

In terms of Section APPENDIX 2(2)(1) of the EIA Regulations (2014) (amended 2017), a Scoping Report must include: h) a plan of study for undertaking the environmental impact assessment process, including–

(i) a description of the alternatives to be considered and assessed within the preferred site, including the option of not proceeding with the activity.; (ii) a description of the aspects to be assessed as part of the environmental impact assessment process; (iii) aspects to be assessed by specialists; (iv) a description of the proposed method of assessing the environmental aspects, including aspects to be assessed by specialists; (v) a description of the proposed method of assessing duration and significance; (vi) an indication of the stages at which the competent authority will be consulted; (vii) particulars of the public participation process that will be conducted during the environmental impact assessment process; and (viii) a description of the tasks that will be undertaken as part of the environmental impact assessment process; (ix) identify suitable measures to avoid, reverse, mitigate or manage identified impacts and to determine the extent of the residual risks that need to be managed and monitored.

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

Scope and Intent of the EIA Phase

This phase includes the following steps:

10.1.1 Specialist Studies

Specialist studies include the specialist assessments identified in the Scoping Report and any additional studies required by the authorities. This requires the appointment of specialists to gather baseline information in their fields of expertise, and to assess the impacts and make recommendations to mitigate negative impacts and optimise benefits. The resulting information is synthesised into the Environmental Impact Report (EIR).

10.1.2 Environmental Impact Report.

The main purpose of this report is to gather and evaluate environmental information, so as to provide sufficient supporting arguments to evaluate overall impacts, consider mitigation measures and alternative options, and make a valued judgement in choosing the best development alternative. The EIR is made available for public and authority review. The availability of the report is advertised in the local newspaper and is situated at an easily accessible location.

10.1.3 Issues and Response Trail

The issues and response trail consists of the compilation of comments, issues and concerns raised by I&APs and the authorities and the relevant responses to these comments.

EOH Coastal & Environmental Services 32 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 10.1.4 Environmental Management Programme

The EMPr informs the client and the technical team of the guidelines which will need to be followed during construction and operation to ensure that there are no lasting or cumulative negative impacts of the construction/operation process on the environment.

 The standards and guidelines that must be achieved in terms of environmental legislation.  Mitigation measures and environmental specifications which must be implemented for all phases of the project in order to minimise the extent of environmental impacts, to manage environmental impacts and where possible to improve the condition of the environment.  Provide guidance through method statements that are required to be implemented to achieve the environmental specifications.  Define corrective action that must be taken in the event of non-compliance with the specifications of the EMPr.  Prevent long-term or permanent environmental degradation.

In addition to this, the Public Participation Process is continued. As for the Scoping Phase, opportunity is provided for I&APs to voice concerns and issues regarding the project. At this stage the project details may have changed in response to the preliminary findings of the Draft Scoping Report. I&APs and key stakeholders are also given the opportunity to review the Environmental Impact Report before it is submitted to the authorities.

10.1.5 Record of Decision of Environmental Authorisation and Appeals Process.

Upon thorough examination of the EIR, the competent authority will either issue an authorisation or rejection, or will require further details to clarify certain issues. Should authorisation be granted, it usually carries Conditions of Approval. The proponent is obliged to adhere to these conditions. Once the authorisation has been issued, it is publicised and the public are given 20 calendar days from the notification of authorisation to issue an appeal to the authorities.

The Public Participation Process

10.2.1 Public Review Of The Draft Scoping Report

All I&APs on the Register of I&APs will be notified in writing of the availability of the Draft Scoping Report (DSR) for public review. The notification letter will provide details of the 30-day public comment period, the venues and websites where the report could be viewed, the contact details of the PPP consultant and how written comments on the DSR should be submitted, and details of the public meeting to present the DSR (if applicable).

10.2.2 Public Review Of The Draft Environmental Impact Report

All I&APs on the I&AP database will be notified in writing of the availability of the Draft Environmental Impact Report (DEIR) for public review. The notification letter will provide details of the 30-day public comment period, the venues and websites where the report can be viewed, the contact details of the PPP consultant and how written comments on the DEIR should be submitted, and details of the public meeting to present the DEIR (if applicable).

10.2.3 Notification Of Environmental Authorisation

Advertisements announcing the Environmental Authorisation (EA) will be placed in the same regional and local newspapers used to announce the project and the EIA. The adverts will be placed in the Daily Dispatch. The adverts will inform I&APs of the decision and where the decision can be accessed and will draw their attention to their right to appeal the decision and set out the appeal procedures.

EOH Coastal & Environmental Services 33 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Environmental Impact Report

The Specialist Studies described below will inform the Environmental Impact Report (EIR). In addition, the EIR will gather any comments received from I&APs and determine whether it is necessary to increase the scope of work or amend the Terms of Reference for the specialists. The EIR will examine the ‘No Go’ alternative along with the proposed borrow pit, as required in the EIA regulations.

10.3.1 Structure of the EIA Report

In broad terms, the Environmental Impact Report (EIR) will have the following Table of Contents:

PART ONE: INTRODUCTION AND DESCRIPTION OF ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

1. Brief Description of The Proposed Project 2. Environmental Impact Assessment Process 3 Activities triggering the EIA process 4 The environmental study team 5 The environmental assessment process followed 6 Structure of the Report

PART TWO: THE PROPOSED BORROW PIT

1 Project Overview 2 Alternatives 3 Technical Description of Preferred Options

PART THREE: DESCRIPTION OF THE AFFECTED ENVIRONMENT

1. The Natural Environment 2. Socio-Economic Environment 3. The Policy, Legal And Administrative Environment

PART FOUR: PUBLIC PARTICIPATION

1. Public Participation Process followed

PART FIVE: ASSESSMENT OF THE ENVIRONMENTAL IMPACTS ASSOCIATED WITH THE BORROW PIT

1. Impacts Associated with the borrow pit 2. Conclusion

EOH Coastal & Environmental Services 34 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 PART FIVE: ENVIRONMENTAL MANAGEMENT PLAN AND OVERALL RECOMMENDATIONS AND CONCLUSIONS

Specialist Studies

10.4.1 Paleontological Assessment

The Paleontological Assessment will be undertaken for the proposed borrow pit. The findings of the study will be included in the EIR. The Assessment includes the following objectives and terms of reference:

 Identifying exposed and subsurface rock formations that are considered to be paleontologically significant;  Assessing the level of paleontological significance of these formations;  To comment on the impact of the development on these exposed and/or potential fossil resources and  To make recommendations as to how the developer should conserve or mitigate damage to these resources

10.4.2 Heritage Assessment

A Phase 1 archaeological and historical survey will be undertaken to fulfil SAHRAs requirements in accordance with the National Heritage Resources Act (25 of 1999). The National Heritage Resources Act requires that “…any development or other activity which will change the character of a site exceeding 5 000 m², or the rezoning or change of land use of a site exceeding 10 000 m², requires an archaeological impact assessment”.

The terms of reference for the Phase 1 heritage study are:

 Provide a summary of the relevant legislation;  Conduct a site inspection as required by national legislation;  Determine the likelihood of archaeological remains of significance in the proposed site;  Identify and map (where applicable) the location of any significant archaeological remains;  Assess the sensitivity and significance of archaeological remains in the site;  Assess the significance of direct and cumulative impacts of the proposed development and viable alternatives on archaeological and heritage resources;  Identify mitigation measures to protect and maintain any valuable archaeological sites and remains that may exist within the proposed site; and  Prepare and submit any permit applications and the Heritage Report to the South African Heritage Resources Authority (SAHRA) and the Eastern Cape Provincial Heritage Resources Authority (ECPHRA).

The findings of the heritage assessment will be incorporated into the borrow pit EIA.

Methodology for assessing the significance of impacts

To ensure a direct comparison between various specialist studies, a standard rating scale has been defined and will be used to assess and quantify the identified impacts. This is necessary since impacts have a number of parameters that need to be assessed. Five factors need to be considered when assessing the significance of impacts, namely:

Identified impacts will be assessed against the following criteria:

 Temporal scale  Spatial scale

EOH Coastal & Environmental Services 35 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

 Risk or likelihood  Degree of confidence or certainty  Severity or benefits  Significance

The relationship of the issue to the temporal scale, spatial scale and the severity are combined to describe the overall importance rating, namely the significance of the assessed impact.

Table 10.1. Significance Rating Table Temporal Scale (The duration of the impact) Short term Less than 5 years (many construction phase impacts are of a short duration).

Medium term Between 5 and 20 years.

Long term Between 20 and 40 years (from a human perspective almost permanent).

Permanent Over 40 years or resulting in a permanent and lasting change that will always be there. Spatial Scale (The area in which any impact will have an affect) Individual Impacts affect an individual.

Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area. Project Level Impacts affect the entire project area.

Surrounding Areas Impacts that affect the area surrounding the development

Municipal Impacts affect either the Local Municipality, or any towns within them.

Regional Impacts affect the wider district municipality or the province as a whole.

National Impacts affect the entire country.

International/Global Impacts affect other countries or have a global influence.

Will definitely occur Impacts will definitely occur.

Degree of Confidence or Certainty (The confidence with which one has predicted the significance of an impact) Definite More than 90% sure of a particular fact. Should have substantial supportive data.

Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring.

Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring. Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

Table 10.2. Impact Severity Rating Impact severity (The severity of negative impacts or how beneficial positive impacts would be on a particular affected system or affected party)

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Very severe Very beneficial An irreversible and permanent change to the affected A permanent and very substantial benefit to the system(s) or party(ies) which cannot be mitigated. affected system(s) or party(ies), with no real For example the permanent loss of land. alternative to achieving this benefit. For example the vast improvement of sewage effluent quality. Severe Beneficial Long term impacts on the affected system(s) or A long term impact and substantial benefit to the party(ies) that could be mitigated. However, this affected system(s) or party(ies). Alternative ways mitigation would be difficult, expensive or time of achieving this benefit would be difficult, consuming, or some combination of these. For expensive or time consuming, or some example, the clearing of forest vegetation. combination of these. For example an increase in the local economy. Moderately severe Moderately beneficial Medium to long term impacts on the affected A medium to long term impact of real benefit to system(s) or party(ies), which could be mitigated. For the affected system(s) or party(ies). Other ways of example constructing the sewage treatment facility optimising the beneficial effects are equally where there was vegetation with a low conservation difficult, expensive and time consuming (or some value. combination of these), as achieving them in this way. For example a ‘slight’ improvement in sewage effluent quality. Slight Slightly beneficial Medium or short term impacts on the affected A short to medium term impact and negligible system(s) or party(ies). Mitigation is very easy, benefit to the affected system(s) or party(ies). cheap, less time consuming or not necessary. For Other ways of optimising the beneficial effects are example a temporary fluctuation in the water table easier, cheaper and quicker, or some combination due to water abstraction. of these. No effect Don’t know/Can’t know The system(s) or party(ies) is not affected by the In certain cases it may not be possible to proposed development. determine the severity of an impact.

Table 10.3. Overall Significance Rating Overall Significance (The combination of all the above criteria as an overall significance) VERY HIGH NEGATIVE VERY BENEFICIAL These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services, would be regarded by the affected parties as resulting in benefits with VERY HIGH significance. HIGH NEGATIVE BENEFICIAL These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating of HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as people growing crops in the soil) would be HIGH. MODERATE NEGATIVE SOME BENEFITS These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant. LOW NEGATIVE FEW BENEFITS These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly

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unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Example: The temporary changes in the water table of a wetland habitat, as these systems are adapted to fluctuating water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits of LOW significance to people who live some distance away. NO SIGNIFICANCE There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective, but is of NO significance in the overall context. DON’T KNOW In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people’s psychological perspective of the environment.

All feasible alternatives and the “no-go option” will be equally assessed in order to evaluate the significance of the “as predicted” impacts (prior to mitigation) and the “residual” impacts (that remain after mitigation measures are taken into account). Reason for the judgement will be provided when necessary.

EOH Coastal & Environmental Services 38 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 CONCLUSIONS AND RECOMMENDATIONS

Activity and Possible Impacts

The South African National Roads Agency Ltd. (SANRAL) will be constructing various safety improvements on Section 6 of the R61 National Route from (KM 52.6) in the Engcobo Local Municipality in the Eastern Cape Province.

A mudstone borrow pit is required to supply the necessary hard rock material for road construction. A suitable borrow pit has been identified approximately 750m off the R61 Section at Km 52.6 in the Beyele Administrative Area in the Engcobo Local Municipality, Eastern Cape.

The proposed borrow pit is located on rural grazing/cultivated land. However, the activity raises issues pertaining to:

 Visual intrusion of the landscape.  Dust impacts on surrounding land inhabitants.  Noise impacts on surrounding land inhabitants.  Stormwater impacts.  Heritage site impact (close proximity to heritage sites).  Socio-economic impacts and benefits.

Fatal Flaws

The Scoping Phase has not identified any fatal flaws and there is no reason why the proposed activity should not proceed to the EIA phase for further assessment.

The EIA Phase

The following activities will form part of the EIA phase:

 Public participation: public review of documentation, engagement with stakeholders/I&APs;  Specialist studies as described in the Plan of Study;  Evaluation of impacts prior to mitigation;  Compilation of practicable and effective mitigation measures;  Provision of an opinion as to whether or not the activity should be authorised;  Compilation of an environmental impact statement;  Compilation of a draft Environmental Management Programme (EMPr).

EOH Coastal & Environmental Services 39 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 REFERENCES

Constitution Act (No. 108 of 1996).

Eastern Cape Vision 2030 Provincial Development Plan.

Hazardous Substances Act (No. 15 of 1973).

Integrated Development Plan (2014/2015). Engcobo Local Municipality.

Mineral and Petroleum Resources Development Act (No. 28 of 2002).

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

NPC National Development Plan 2030.

National Environmental Management Act (No. 107 of 1998).

National Environmental Management: Air Quality Act (No. 39 of 2004).

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

National Environmental Management: Protected Areas Act (No. 57 of 2003).

National Environmental Management: Waste Management Act (No. 59 of 2008).

National Forests Act (No. 84 of 1998).

National Heritage Resource Act (No. 25 of 1999).

National Water Act (No. 36 of 1998).

Occupational Health and Safety Act (No. 85 of 1993).

StatsSA (http://www.statssa.gov.za/).

EOH Coastal & Environmental Services 40 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 APPENDICES

Appendix A: Public participation documents

13.1.1 Newspaper advert:

Advert placed in the Daily Dispatch on 24 October 2016.

EOH Coastal & Environmental Services 41 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

EOH Coastal & Environmental Services 42 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 13.1.2 Background Information Document:

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EOH Coastal & Environmental Services 47 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

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EOH Coastal & Environmental Services 49 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 13.1.3 Notice board

Sign placed at the entrance of the access road to the borrow pit site (along the R61). Coordinates: 31°45'13.12"S, 27°56'44.10"E.

EOH Coastal & Environmental Services 50 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Notices placed at Engcobo Local Municipal offices:

EOH Coastal & Environmental Services 51 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 13.1.4 Letter of notification

EOH Coastal & Environmental Services 52 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 Initial email notification:

Email invite to public meeting:

EOH Coastal & Environmental Services 53 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 13.1.5 Landowner permission from the Chief:

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13.1.6 Public Meeting Minutes

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EOH Coastal & Environmental Services 59 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

EOH Coastal & Environmental Services 60 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 13.1.7 Public Meeting Attendance Register

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EOH Coastal & Environmental Services 63 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017

EOH Coastal & Environmental Services 64 SANRAL R61 Road Upgrade Borrow Pit Draft Scoping Report – October 2017 13.1.8 Interested and affected parties database

Organisation/association Name/contact person Address e-mail Tel: Fax:

Identified Stakeholders DWS Lizna Fourie (Licensing) [email protected] 043 701 0248 No 74 Alexandra Road, King

ECPHRA (EC Heritage) Mr Sello Mokhanya [email protected] 0436422811 0436422812 Williams Town

DEDEAT(CHDM) Mr Makosonke [email protected]

DMR Deidre Thompson [email protected] Department of Rural Development and Land B. Keikelame [email protected] Reform

M Molokoane [email protected]

[email protected] P Edi [email protected]

Z Pityi [email protected] S Ntamesi [email protected]

Dept Agriculture T Manyisana [email protected]

[email protected]

EC Dept of Rural Dev and Agrarian Reform Patrick Futshane [email protected] Olona Njoteni (Regional

Dept. of Human Settlement Private Bag 5030 [email protected] 0475313511 Director) Chief Mgudlwa Chief PO Box 5 Engcobo 5050 082 949 7264 Mr Bantwini Chief Representative 071 221 2801 Headman Lubawele Mbenyana 0733802567 Ward 7 councillor Nolutho Sifamqala 0789809367

Engcobo LM Zibele Xuba [email protected] 0784058462

Andile Social Facilitator [email protected] 0799938755

Engcobo LM MM Silumko Mahlasela Po Box 24, Engcobo 5050 [email protected] 047 548 5600 I&AP's

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