Appendix 1 Eap Project Team Cvs

APPENDIX 1 EAP PROJECT TEAM CVS

Gené Main – Principal Environmental Consultant, Pr. Sci. Nat.

Present Appointment Principal Consultant

Professional Registration South African Council for Natural Scientific Professions (SACNASP) registration 400370/13 (Environmental Science)

IAIAsa member Membership number 5932

Date of Birth 23 May 1980

Nationality South African

Education BSc (Botany & Environmental Science), Rhodes University, 2002 BSc Hons (Environmental Science), Rhodes University, 2003 MSc (Botany), University of the Western Cape, 2006

Languages English, Afrikaans

Synopsis Gené has twelve years of experience working on environmental and social aspects of development projects related to mining, waste management and water management, including EIAs, EMPs, closure and rehabilitation plans, monitoring and auditing. She has also been project lead in several environmental due diligence and technical review projects, most of these in terms of the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines.

Project History

Environmental and social assessments (including EIA1, EMP2, ESIA3, PFS4) Project Location Year ESIA for gold mine Pakrut, Tajikistan 2008 PFS for shaft upgrade Limpopo, SA 2008 EIA for Siyanda Coal, Koornfontein Mine Mpumalanga, SA 2008 - 2009 EIA for T-Project Colliery Kinross, Mpumalanga, SA 2008 - 2010 Order of Magnitude Study for iron ore mine Zanaga Republic of Congo 2009

1 Environmental Impact Assessment 2 Environmental Management Plan 3 Environmental and Social Impact Assessment 4 Prefeasibility Study

Project Location Year EIA Vlakvarkfontein Colliery Mpumalanga, SA 2009 - 2010 Prospecting EMP for phosphate project Cabinda, Angola 2010 PFS for phosphate project Cabinda, Angola 2010 Prospecting EMP for De Beers Namaqualand Mines Northern Cape, SA 2010 PFS for platinum mine Tjate, Limpopo, SA 2011 PFS for nickel project Araguaia, Brazil 2011 - 2012 PFS for iron ore project Malelane, South Africa 2012 EIA for New Kleinfontein Goldmine Gauteng, SA 2012 EIA for KaNgwane South Anthracite Mine Mpumalanga, SA 2012 EIA for Modder North and Holfontein Gauteng, SA 2014 - 2016 EIA for Ventersburg Gold Mine Free State, SA 2016 - 2017 EIA for Cons Modder Gold Mine Gauteng, SA 2017 - 2018 New Kleinfontein Goldmine Gauteng, SA Current

Rehabilitation and Closure Planning Project Location Year T-Project Colliery Kinross, Mpumalanga, SA 2009 - 2010 Vlakvarkfontein Colliery Mpumalanga, SA 2009 - 2010 New Kleinfontein Goldmine Gauteng, SA 2012 Holfontein Project Gauteng, SA 2014 - 2016 Ventersburg Gold Mine Free State, SA 2016 - 2018 Cons Modder Gold Mine Gauteng, SA 2017 - 2018 Annual update of Middelvlei Gold Mine Gauteng, SA 2018 Annual update of Sekoko Resources, Perth Mine Northern Cape, SA 2018 New Kleinfontein Goldmine Gauteng, SA Current

Water Use Licence Applications Project Location Year T-Project Colliery Kinross, Mpumalanga, SA 2009 - 2010 Vlakvarkfontein Colliery Mpumalanga, SA 2009 - 2010 New Kleinfontein Goldmine Gauteng, SA 2012 Holfontein Project Gauteng, SA 2014 - 2016 Ventersburg Gold Mine Free State, SA 2016 - 2018 Cons Modder Gold Mine Gauteng, SA 2017 - 2018 New Kleinfontein Goldmine Gauteng, SA Current

Atmospheric Emission Licence Applications Project Location Year New Kleinfontein Goldmine Gauteng, SA 2017 Ventersburg Gold Mine Free State, SA 2018

Environmental audits Project Location Year Quarterly compliance audits for landfill sites Gauteng, SA 2008 to 2017 Rustenburg Platinum Mines, Union Section North West, SA 2009 Klipspringer Diamond Mine Limpopo, SA 2013 Interwaste Hazardous Waste Transfer Facility Germiston, Gauteng, SA 2011 to current Interwaste Transfer and Recovery Facility Bellville, Western Cape, SA 2011 to current Vlakfontein Colliery Mpumalanga, SA 2014

Due diligence / Technical review / Ongoing monitoring for compliance Project Location Year New Kleinfontein Goldmine Gauteng, SA 2010 Kipoi Central RDFS’s operations Democratic Republic of Congo 2010 Anvil’s Kinsevere Copper Mine Democratic Republic of Congo 2010 Koidu Kimberlite Project’s expansion project Sierra Leone 2010 - 2011 Kalagadi Manganese Mine Northern Cape, SA 2010 to current Sekoko Resources Limpopo, SA 2010, 2014 Bafokeng Rasimone Platinum Mine North West, SA 2010 Blyvooruitzicht Gold Mine Gauteng, SA 2011 Rand Uranium West Rand Operations Gauteng, SA 2011 Harmony tailings storage facilities Welkom, SA 2011 - 2012 Western Bushveld Joint Venture Project 1 North West, SA 2011 - 2014 Tharisa Platinum Mine North West, SA 2011 to current Pilanesberg Platinum Mine North West, SA 2012 North River Resources, Lead and Zinc project Namibia 2012 Steenkampskraal project Northern and Western Cape, SA 2012 - 2013 Kudumane Manganese Mine Northern Cape, SA 2012 - 2016 Kipoi Stage 2 Phase 1 project Democratic Republic of Congo 2013 Beacon Hill Resources, Moatize Coal Mozambique 2013 - 2014 Ghaghoo Diamond Mine Botswana 2013 - 2015 Maamba Colliery’s expansion project Zambia 2013 to current Liqhobong Diamond Mine Lesotho 2013 to current Khoemacau Copper and Gold Mine Botswana 2018 Bisha Mine Eritrea 2018

Strategic Research Projects / Investigations Project Location Year Vaal Racecourse air quality investigations Gauteng, SA 2017 to current Alternatives to discharge of excess mine water Gauteng, SA 2016 - 2017 Resettlement options for communities living near Gauteng, SA 2017 - 2018 mining projects

Louise Jones – Environmental Scientist | GIS Specialist

Present Appointment Environmental Scientist, Prime Resources (Pty) Ltd

Period February 2013 - Present

Nationality South African (English Speaking)

Education MSc Environmental Sciences, University of the Witwatersrand, 2013

BSc (Hons.) Applied Chemistry, University of the Witwatersrand, 2010

BSc, Environmental Science and Chemistry, University of the Witwatersrand, 2009

Synopsis

Louise has four years of experience in environmental consulting. She has experience in performance assessments, social and labour plans, financial liability assessments associated with mine closure and rehabilitation, environmental impact assessments and management programmes and environmental compliance auditing. Louise also has experience in Geographic Information Systems.

Project History

Environmental Authorisation Processes (Basic Assessments, EIA’s, Stakeholder Engagement and EMP’s)

• Newshelf, Gedex Project, Gauteng Province, South Africa • Gold One Africa, Ventersburg Project, Free State Province, South Africa • Vale Fertil, Lucunga Phosphate Project, Angola • Horizonte Minerals, Araguaia Nickel Project, Brazil • Gold One International, Holfontein Project, Gauteng Province, South Africa • Mbila Resources (Pty) Ltd, Mbila Anthracite Mine, KwaZulu-Natal, South Africa • Mbila Resources (Pty) Ltd, Msebe Opencast Mining Activities, KwaZulu-Natal, South Africa • ENCO Hlabisa, Kwa-Zulu Natal, South Africa • Moongate Barberton Iron Ore, Mpumalanga, South Africa • Anglo American Platinum, Amandelbult Chrome Recovery Plant, Limpopo, South Africa • Samancor Chrome, Scheiding Chrome Mine, Limpopo, South Africa

Water, Waste Management and Compliance Auditing

• Integrated Water Use Licence and GN704 compliance audit for the Modikwa Platinum Mine, Limpopo Province, South Africa • Water Monitoring, Ekurhuleni Metropolitan Municipality, Closed Landfill Sites, Gauteng Province, South Africa • Water Monitoring, Ekurhuleni Metropolitan Municipality, Ekurhuleni Metropolitan Municipality, operational landfill sites, Gauteng Province, South Africa • Environmental Compliance Auditing, Ekurhuleni Metropolitan Municipality, operational landfill sites, Gauteng Province, South Africa • Environmental compliance auditing of the Marble Hall Landfill Site, Ephraim Mogale Local Municipality, Limpopo Province, South Africa • Groundwater Monitoring and Environmental Compliance Auditing, Interwaste Klinkerstene Landfill Site, Mpumalanga Province, South Africa • Groundwater Monitoring and Environmental Compliance Auditing, Interwaste F.G. Landfill Site, Gauteng Province, South Africa • Bi-annual Environmental Compliance Audit, Interwaste Hazardous Waste Transfer Facility, Germiston, Gauteng Province, South Africa

Environmental Authorisation and Environmental Management Programme Compliance Auditing

• Environmental Control Officer and Environmental Compliance Monitoring for the Interwaste Klinkerstene Landfill Site, Delmas, Mpumalanga Province, South Africa

Soil and Agricultural / Land Capability Impact Assessment

• Newshelf, Gedex Project, Gauteng Province, South Africa • Vale Fertil, Lucunga Phosphate Project, Angola • Holfontein Project, New Kleinfontein Goldmine (Pty) Ltd, Modder East Operations, Gauteng, South Africa

Social and Labour Plans

• Newshelf, Gedex Project, Gauteng Province, South Africa • Gold One Africa, Ventersburg Project, Free State Province, South Africa • Mbila Resources (Pty) Ltd, Msebe Opencast Mining Activities, KwaZulu-Natal, South Africa • Jubilee Platinum, Tjate Platinum Mine, Mpumalanga, South Africa • SAMDC, Mooiplaats Platinum Mine, Limpopo, South Africa

Due Diligence

• Review of Liqhobong Diamond Mine, Lesotho • Review of Maamba Colliery’s existing and proposed expansion project, Zambia • Environmental and social baseline report (pre-feasibility) for the Horizonte Minerals, Araguaia Nickel Project, Brazil • Review and gap analysis preparation for T-Project Colliery, Kinross, Mpumalanga Province, South Africa

Mine Closure Liability and Performance Assessments

• Care and Maintenance Plan for the Samancor Chrome, Western Chrome Mines, Lannex Mine, Limpopo Province, South Africa • Closure Plans and Annual assessment of the Quantum for Closure-Related Financial Provision for the Modikwa Platinum Mine, Limpopo Province, South Africa • Performance Assessment and Evaluation of the Quantum for Closure-Related Financial Provision, Mbila Resources and various SamancorCr prospecting right areas • Annual Financial Liability Auditing, Shiva Uranium, Dominion Reefs Uranium Mine, North West Province, South Africa

GIS (Proficient with ArcGIS software (currently using ArcGIS 10.1))

• Mapping and spatial analysis of the mine layout, underground mine plan, farm portions and environmental information for various projects listed above • High level environmental review to identify environmentally sensitive areas by mapping all available environmental information, ENCO Hlabisa, Kwa-Zulu Natal Province, South Africa • Mapping and spatial analysis of newly mined, previously mined and rehabilitated areas for the annual financial liability audit, Shiva Uranium, Dominion Reefs Uranium Mine, North West Province, South Africa • Mapping of boreholes forming part of the water monitoring network, Ekurhuleni Metropolitan Municipality, operational landfill sites and closed landfill sites, Gauteng Province, South Africa • Mapping of boreholes forming part of the water monitoring network, Interwaste F.G. Landfill Site, Gauteng Province, South Africa

Bronwyn Grover –Environmental Scientist

Present Appointment Environmental Scientist, Prime Resources (Pty) Ltd

Period January 2017 - Present

Professional Registration South African Council for Natural Scientific Professions (SACNASP) Candidate Natural Scientist Registration No. 116334

Education PhD (Environmental Analytical Chemistry), University of the Witwatersrand BSc Hons. Chemistry with distinction, University of the Witwatersrand BSc. Geology and Chemistry with distinction, University of the Witwatersrand

Synopsis

Prior to her involvement at Prime Resources, Bronwyn researched and worked as a geochemist with a specialisation in water chemistry. Bronwyn has gained valuable experience in assessing and reporting impacts of mine residue stockpiles on surface and ground water systems. In recent projects at Prime Resources Bronwyn has undertaken water monitoring and geochemical studies as well as assisted with Water Use Licence Applications and Environmental Authorisation processes including Environmental Impact Assessments, public participation processes; rehabilitation planning; socio-economic assessments; and environmental compliance auditing.

Current Projects and Project History

Geochemical, Air and Water Quality Assessments

 Geochemical assessment of Deccan Gold Mines Ltd, Ganajur Project, India  Water quality monitoring at Interwaste, Klinkerstene Landfill, South Africa  Water quality monitoring at Interwaste, FG Landfill, South Africa

 Water quality assessment of Gold One International, Modder East Operations, Gauteng Province, South Africa  Soil impact assessment and land capability assessment, Cons Modder, Gauteng Province  Review of geochemical analyses and international waste classification standards, Unki Slag, Zimbabwe  Dust source analysis and identification, Vaal Racecourse, South Africa

Environmental Authorisation Processes and Public Participation

 Environmental Impact Assessment, Gold One Africa, Ventersburg Project, Free State Province, South Africa  Environmental Impact Assessment, Cons Modder Gold Mine, Gauteng Province, South Africa  Basic Assessment, Prospecting Right, Pan African Mineral Development Company, Northern Cape, South Africa

Water and Waste Management and Licensing

 Water Use Licence Application and Integrated Waste and Water Management Plan for the proposed Ventersburg Gold Mine, Free State Province, South Africa  Water Use Licence Application and Integrated Waste and Water Management Plan for the proposed Samancor Haakdoorndrift Chrome Mine, Limpopo Province, South Africa  Water Use Licence Application and Integrated Waste and Water Management Plan for the proposed Cons Modder Gold Mine, Gauteng Province, South Africa  Water management strategy and Water Use Licence Application for New Kleinfontein Goldmine, Gauteng Province, South Africa

Mine Closure Planning

 Rehabilitation Plan for the proposed Cons Modder Gold Mine, Gauteng Province, South Africa  Rehabilitation Plan for the proposed Samancor Chrome Mine, Limpopo Province, South Africa

Waste Management and Compliance Auditing

 Environmental compliance auditing of operational landfill sites, Ekurhuleni Metropolitan Municipality, Gauteng Province, South Africa  Environmental compliance auditing of operational landfill sites, Interwaste, Gauteng and Mpumalanga Provinces, South Africa

Socio-Economic Studies

 Cons Modder Gold Mine, Gauteng Province, South Africa

Itumeleng Morosele – Environmental Scientist | GIS Technician

Present Appointment Environmental Scientist, Prime Resources (Pty) Ltd

Period March 2018 - Present

Nationality South African

Education BSc (Hons.) Geography with distinction, University of Johannesburg

BSc Life and Environmental Sciences, University of Johannesburg

Synopsis

Itumeleng is an environmental scientist with experience in Geographic Information Systems (GIS). She has been involved with conducting environmental compliance audits, as well as assisting with Environmental Authorisation and Water Use Licence Applications, Due Diligence reporting, and Financial Liability Assessments associated with mine closure and rehabilitation.

Current Projects and Project History

Waste Management and Compliance Auditing

• Groundwater Monitoring and Environmental Compliance Auditing, Interwaste F.G. Landfill Site, Gauteng, South Africa

Water Quality Assessments

• Water quality monitoring at Interwaste, Klinkerstene Landfill, South Africa

• Water quality monitoring at Interwaste, FG Landfill, South Africa

Environmental Authorisation Processes and Public Participation

 Basic Assessment, Prospecting Right, Tawana Investment Holdings (Pty) Ltd, Northern Cape, South Africa

Water Use Licensing

 Water Use Licence Application and Integrated Waste and Water Management Plan for the proposed Cons Modder Gold Mine, Gauteng Province, South Africa

 Water Use Licence Application and Integrated Waste and Water Management Plan for the proposed Ventersburg Gold Mine, Free State, South Africa

Due Diligence

• Review of Snowden Maamba Colliery project, Zambia

Mine Closure Planning and Liability and Performance Assessments

• Rehabilitation Plan for the proposed Cons Modder Gold Mine, Gauteng, South Africa

• Closure Plans and Annual assessment of the Quantum for Closure-Related Financial Provision for the Modikwa Platinum Mine, Limpopo, South Africa

• Assessment of the Quantum for Closure-Related Financial Provision for the Sebilo Manganese Mine, Northern Cape, South Africa

GIS (Proficiency with Esri ArcGIS software 10.1 – 10.5)

• Conversion of CAD files into GIS readable formats for various projects

• Performing different spatial analyses available in the ArcGIS package for the mapping of natural and man-made features including mine layouts, underground mine plans, farm portions and environmental information for projects listed above

• Experience with the SANBI BGIS database

Claire Kennedy – Civil and Environmental Engineer

Present Appointment Environmental Consultant - Prime Resources (Pty) Ltd

Period July 2018 – Present

Date of birth 11 December 1988

Nationality South African & British

Education BSc (Eng) Civil, University of Cape Town 2011 Msc Environmental Engineering, University of Strathclyde

Languages Afrikaans and English

Synopsis Claire Kennedy is a civil and environmental engineer that has 4years work experience in design of components of water infrastructure projects including structural design and stability analysis . She also has experience in water use and waste licence applications for a multitude of facilities from mines, to waste disposal sites and stream crossings.

Professional History Candidate Civil Engineer at Department of Water and Sanitation from January 2012 – August 2016. She worked in the directorate Dam Design conducting designs and drawings for components of water infrastructure projects. Claire was part of the engineering review panel reviewing water use and waste licences submitted to the Department from 2012 to 2016.

Current Projects and Project History

Water Quality Assessments

 Water quality monitoring result assessment and report at Interwaste, Klinkerstene Landfill, South Africa

Environmental Authorisation Processes and Public Participation

 Basic Assessment, Prospecting Right, Tawana Investment Holdings (Pty) Ltd, Northern Cape, South Africa

 Environmental Authorisation Application, Gold One , Modder East Operations, South Africa

Mine Closure Planning and Liability and Performance Assessments

 Assessment of the Quantum for Closure-Related Financial Provision for the Sebilo Manganese Mine, Northern Cape, South Africa

APPENDIX 2 COMPANY PROFILE

COMPANY PROFILE

Prime Resources (Pty) Ltd is a medium-sized group of consulting environmental engineers and scientists serving clients across a wide range of industries, although the majority of our project work is based around natural resources, waste and mining.

The company was established in Johannesburg in 2003. Our head offices are located in Parktown North, Johannesburg, South Africa.

Prime Resources employs a talented and innovative group of professional people. We also have an extensive network of specialist sub-contractors who, together with our team, provide specialist environmental and civil design services. We provide consulting services and solutions to clients in a wide range of fields including:

 Project Management and implementation of  Geographic Information Systems (GIS) environmental solutions services

 Environmental Social Impact Assessments  Environmental / civil / geotechnical (ESIA) and Environmental Management engineering solutions Programmes (EMPr)  Geotechnical and tailings dam assessments  Public consultation and engagement with  Feasibility studies Interested and Affected Parties (IAPs)  Environmental advisors on purchase and  Water Use Licence Applications (WULA) sale transactions – Independent Technical  Waste management strategies and licensing Advisors

 Mining Right Applications  Environmental and social due diligence and risk assessments both in terms of national  Mine closure and rehabilitation planning legislation and international best practice  Social and Labour Plans (SLP)  Advising on compliance with international best  Environmental and social compliance auditing practice, most importantly the Equator and performance assessments Principles, IFC Performance Standards, and World Bank EHS Guidelines

KEY STAFF AND QUALIFICATIONS

PROFESSIONAL STAFF ROLE QUALIFICATIONS Peter Theron Company Director Professional Engineer (Pr. 950329) Environmental Engineer BSc Eng. (Civil) Project Manager GDE Environmental Engineering, Tailings & Geotechnical Jonathan van de Wouw Project Manager BSc (Hons) Microbiology and Biotechnology Principal Environmental Scientist Gené Main Project Manager Pr. Sci. Nat. (Environmental Science) Principal Environmental MSc Botany Scientist BSc (Hons) Environmental Science Stephan Geyer Civil Engineer BSc Eng. (Civil) Dr Bronwyn Grover Environmental Scientist PhD Environmental Analytical Chemistry Geochemistry BSc Geology and Chemistry Claire Kennedy Civil and Environmental BSc Engineering (Civil) Engineer MSc (Environmental Engineering) Itumeleng Morosele Environmental Scientist BSc (Life and Environmental Sciences) BSc (Hons) Geography Fernanda Smook Office Manager Business Management courses

ASSOCIATES: PROFESSIONAL STAFF ROLE QUALIFICATIONS Romy Antrobus-Wuth Environmental Scientist MSc Conservation Biogeography BSc (Hons) Environmental Science Niel Scheepers Civil Engineering B Tech (Civil) Technician Dr Walter Fourie Principal Chemical Ph.D. Environmental Engineering Engineer B Eng (Chemical) Engineering

PROJECT EXPERIENCE

Environmental aspects include due diligence and independent technical reviews; pre-feasibility and baseline studies; Environmental and Social Impact Assessments (ESIAs) and associated specialist environmental impact studies; Environmental Management Plans / Programmes (EMPs/EMPrs) and associated reporting including Environmental Awareness Plans, Emergency Preparedness and Response Plans and Closure and Rehabilitation Plans; compliance auditing and performance assessments. Social aspects include Social Impact Assessments (SIAs); public consultation processes; the compilation of Resettlement Action Plans (RAPs); Social and Labour Plans (SLPs); and Public Consultation and Disclosure Plans (PCDPs). Technical aspects include the technical review and design of mine waste facilities as well as geotechnical investigations.

We are further experienced with international best practice, most notably the Equator Principles, IFC Performance Standards, and World Bank Environmental, Health and Safety Guidelines.

Previous major projects, carried out since 2009, are summarised below. Additional project details are available upon request.

INTERNATIONAL PROJECTS

 Araguaia Nickel Project, Brazil . Detailed design of slag disposal facility for Feasibility Study . Site geotechnical investigations . Detailed design of cooling water dam and river abstraction pipeline  Lindi Jumbo Graphite Project, Tanzania . Surface geotechnical study . Site selection for tailings storage facility . Pre-Feasibility Study design for tailings storage facility . Definitive Feasibility Study design for tailings storage facility . Terracing design for plant infrastructure  Cacata Phosphate Project, Angola . Environmental licensing according to Angolan legislative requirements . Environmental and Social Impact Assessment process according to international best practice  Ganajur Gold Project, India . Review of environmental aspects for Feasibility Study . Surface geotechnical study . Site selection for tailings storage facility . Feasibility Study design for tailings storage facility  Salamanca Uranium Project, Spain . Feasibility Study design for lined surface waste disposal facilities . Feasibility Study design and detailing for an in-pit waste disposal liner system  Mpokoto Gold Project, Democratic Republic of Congo . Surface geotechnical study . Site selection for tailings storage facility . Pre-Feasibility Study design for tailings storage facility . Bankable Feasibility Study design for tailings storage facility . Terracing design for plant infrastructure

 Lucunga Phosphate Project, Angola . Environmental licensing according to Angolan legislative requirements  Veduga Gold Project, Russia . Technical review of environmental and mine waste disposal aspects  Ghaghoo Diamond Project, Botswana . Independent technical review of the environmental, social and permitting documentation according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines . Preparation of an Equator Principles environmental and social action plan  Debswana Diamond Projects, Botswana . Peer review of environmental and mine waste aspects for Pre-Feasibility Studies  Liqhobong Diamond Mine, Lesotho . Independent technical review of the environmental and social aspects, permitting, water management and residue management - according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  Koidu Diamond Project, Sierra Leone . Review of environmental, social, groundwater and tailings documentation for compliance with Equator Principles, IFC Performance Standards and EHS Guidelines  Araguaia Nickel Project, Brazil . Environmental and social baseline report Pre-Feasibility Study . Preliminary design of slag disposal facility for Pre-Feasibility Study  Maminskoye Gold Project, Central Urals, Russia . Environmental and social audit of the Pre-Feasibility Study  Cabinda Phosphate Project, Angola . Social impact plan and Environmental Management Plan for prospecting . Environmental and social baseline report towards the Definitive Feasibility Study stage  Owere Gold Project, Ghana . Independent technical review of the environmental, social and permitting documentation  Kinsevere Copper Project, Democratic Republic of Congo . Review of tailings dam risks and opportunities for compliance with Equator Principles  Kipoi Copper Mine, Democratic Republic of Congo . Review of environmental, social, heap leach and tailings of the Kipoi Central RDFS operations, Tiger Resources . Independent technical review of the environmental, social and permitting documentation according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  Zanaga Iron Ore Project, Democratic Republic of Congo . Environmental and social section of the order of magnitude study  Pakrut Gold Mine, Tajikistan . Social and Environmental Impact Assessment process, baseline evaluations according to international best practice requirements  Lece Gold Mine, Serbia . Tailings technical review and concept design work for a tailings retreatment project  Langer Heinrich Uranium Mine, Namibia . Independent technical review of the tailings storage facility and storage strategy

 Maamba Coal Mine, Zambia . Independent technical review of the environmental, social, permitting, discard and water management according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  North River Resources Lead Zinc, Namibia . High level review of the environmental and social documentation according to Namibian legislative requirements  Minas Moatize Coal Expansion Project, Mozambique . Independent technical review and due diligence of mine residue facilities (slurry and discard), water management, environmental and social aspects  Aquarius Shipping International, Warehouse and Container Depot, Beira, Mozambique . Geotechnical investigation  Passendro Gold Project, Democratic Republic of Congo . Independent peer review for tailings storage facility  Banro Twangiza Project, Democratic Republic of Congo . Independent technical review of the environmental, social, tailings and water management aspects according to the Equator Principles

NATIONAL PROJECTS

Projects are all conducted in terms of relevant National legislation, including the National Environmental Management Act, No. 107 of 1998 (NEMA); the Mineral and Petroleum Resources Development Act, No. 28 of 2002 (MPRDA); the National Environmental Management: Waste Act, No. 59 of 2008; the National Water Act, No. 36 of 1998 etc.

 Newshelf, Gedex Project, Gauteng Province, South Africa . Social and Labour Plan . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application  Imperial Cargo Solutions, Flammable Goods Store, Gauteng Province, South Africa . Environmental Impact Assessment and Environmental Management Programme  Gold One Africa, Ventersburg Project, Free State Province, South Africa . Social and Labour Plan . Environmental Impact Assessment and Environmental Management Programme . Waste Management Licence . Water Use Licence Application . Atmospheric Emission Licence  WRE – EJV Gold Project, Free State, South Africa . Site selection for tailings storage facility . Pre-Feasibility Study design for tailings storage facility  Rietvlei Mine, Mpumalanga, South Africa . Technical input on discard dump and pollution control dam design  Holfontein Gold Project, Gauteng, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application and water dam designs

 New Kleinfontein Goldmine Modder East Operations, Gauteng, South Africa . Environmental Impact Assessment and Environmental Management Programme and amendments thereto . Basic Assessment for a return water dam and Environmental Management Programme amendment . Water Use Licence Application and amendments thereto . Atmospheric Emission Licence application . Rehabilitation Strategy and Implementation Programme . Social and Labour Plan revision . Equator Principles and IFC compliance review . Alien invasive vegetation eradication plan . Emergency preparedness and response plan . Stormwater management plan  Interwaste, Gauteng, Mpumalanga, Western Cape, South Africa . Environmental compliance auditing at various landfill sites and depots . Water quality monitoring and reporting . External environmental control officer for the Klinkerstene Landfill Site, Environmental Authorisation and construction Environmental Management Programme compliance auditing  Ekurhuleni Metropolitan Municipality, Gauteng, South Africa . Environmental compliance auditing at various landfill sites and transfer stations . Permit amendment application . Water quality monitoring and reporting  Royal Bafokeng Platinum, North West, South Africa . Annual assessment of the quantum for rehabilitation-related financial provision for Prospecting Rights  SamancorCr, Limpopo, South Africa . Performance assessments and assessment of the quantum for rehabilitation-related financial provision for various Prospecting Rights  Modikwa Platinum Mine, Mpumalanga, South Africa . Water Use Licence compliance audit and action plan . Annual assessment of the quantum for rehabilitation-related financial provision . Annual Rehabilitation Plan . Final Rehabilitation Decommissioning and Closure Plan . Environmental Risk Assessment . Waste Management Licence Amendment  Coal of Africa, Vele Colliery, Limpopo, South Africa . Independent technical review of the environmental, social, tailings and water management aspects according to the Equator Principles and IFC Performance Standards  Canyon Springs Coal Mine, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application . Waste Management Licence application . High level bulk water supply assessment

. External environmental control officer, construction Environmental Management Programme compliance auditing . Water Use Licence execution  Elsmore Pafuri Camp, Limpopo, South Africa . Environmental Authorisation amendment  Elsmore Luvuvhu Camp, Limpopo, South Africa . External environmental control officer, Environmental Authorisation and construction Environmental Management Programme compliance auditing  Bio-2-Watt Biogas Plant, Gauteng, South Africa . External environmental control officer, construction Environmental Management Programme compliance auditing . Technical advice  SamancorCr, Scheiding Chrome Mine, Limpopo, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application  African Exploration Mining Finance Corporation, T-Project Colliery, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application . Closure and rehabilitation plan . Bulk water supply assessment . Equator Principles compliance review and gap analysis . Stakeholder engagement plan and grievance mechanism . Emergency preparedness and response plan . Alien invasive vegetation eradication plan . Water Use Licence execution  Mbila Anthracite Mine, KwaZulu-Natal, South Africa . Basic Assessment and Environmental Management Programme . Water Use Licence amendment  Msebe Opencast Anthracite Mine, KwaZulu-Natal, South Africa . Environmental Impact Assessment and Environmental Management Programme  Tjate Platinum Mine, Limpopo, South Africa . Environmental and social baseline report . Baseline environmental assessments and project management of the environmental inputs into the Pre-Feasibility Study . Social and Labour Plan update . Site selection and preliminary design for a tailings storage facility  Tharisa Platinum Mine, North West, South Africa . Due diligence for independent technical engineers report (ITE), review of the environmental, social and tailings documentation and reporting and annual updates thereto  Anglo American Platinum Limited, Rustenburg Platinum Mines, Limpopo, South Africa . The consolidation of existing approved Environmental Management Programmes and the alignment thereof with the requirements of the MPRDA

 Kalagadi Manganese Mine, Northern Cape, South Africa . Review of environmental documentation to determine compliance with Equator Principles and international best practice, on behalf of Standard Bank  African Exploration Mining Finance Corporation, Vlakvarkfontein Colliery, Mpumalanga, South Africa . Water Use Licence Application . Closure and rehabilitation plan . The technical design, 3D modelling and detailing of the conceptual backfill plan for an opencast pit . Compilation of an alien invasive vegetation eradication plan . Social and Labour Plan amendment . Basic Assessment and Environmental Management Programme for a haul/ access road and above ground diesel storage area  Western Bushveld Joint Venture Project 1, North West, South Africa . Review of environmental, hydrology and tailings dam documentation for compliance with Equator Principles, IFC Performance Standards and EHS Guidelines, on behalf of Standard Bank  Anglo American Platinum Limited, Amandelbult Chrome Recovery Plant, Limpopo, South Africa . Basic Assessment and Environmental Management Programme for a chrome recovery plant . Addendum to the existing Environmental Impact Assessment and Environmental Management Programme in terms of the MPRDA  Steenkampskraal Project, Western Cape, South Africa . Review of environmental, hydrology and tailings dam documentation for compliance for PEA Canadian NI 43-101 filing  Malelane Iron Ore Project, Mpumalanga, South Africa . Preliminary environmental and social baseline studies  Rand Uranium, Reclamation of Lindum Tailings Storage Facility, Gauteng, South Africa . Environmental Impact Assessment and Environmental Management Programme addendum  Hlabisa Coal, KwaZulu-Natal, South Africa . High-level, desktop environmental evaluation (sensitivity analysis)  Anglo American Platinum Limited, Kilken Tailings, Limpopo, South Africa . Independent technical review of the environmental and social aspects permitting and water management according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  Mooiplaats Platinum Mine, Limpopo, South Africa . Social and Labour Plan  Rietkuil Coal Project, Mpumalanga, South Africa . Independent technical review and due diligence of environmental documentation  Evander Gold Mine, Mpumalanga, South Africa . Review of environmental, social and tailings dam documentation for compliance with South African Environmental and Social Standards

 Holgoun Energy, Springbok Flats Coal Fields, Limpopo, South Africa . Competent Persons Report . High level bulk water supply assessment . High level environmental review for the Western Complex Project  Kudumane Manganese Mine, Northern Cape, South Africa . Independent technical review of the environmental and social aspects  ZYL Limited, KaNgwane Anthracite Mine, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application . Closure and rehabilitation plan  ZYL Limited, Southern Anthracite Project, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme  DRDGold, Blyvooruitzicht Mining Operation, Gauteng, South Africa . High level environmental review  Lonmin, Akanani Platinum Project, Limpopo, South Africa . Pre-Feasibility Study, review of the environmental and social documentation and reporting of high level risks and opportunities  Anglo American Platinum Limited, Dishaba Mine, Limpopo, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence amendment  Majuba Colliery, Mpumalanga, South Africa . Closure and rehabilitation plan  Rietfontein Prospect, Limpopo, South Africa . Geotechnical investigation . Environmental Management Programme amendment  Namaqualand Mines, Northern Cape, South Africa . Independent technical review of the environmental, social and tailings aspects according to the Equator Principles and IFC Performance Standards  Leeuwfontein and Blinkpan project areas, Mpumalanga, South Africa . Geotechnical investigation  Bafokeng Rasimone Platinum Mine, North West, South Africa . Preliminary closure and rehabilitation plan  Umtu (Manganese) Mine Project, Northern Cape, South Africa . Independent technical review of the environmental and social aspects according to the Equator Principles and IFC Performance Standards  Koornfontein Mines, Mpumalanga, South Africa . Environmental Impact Assessments and Environmental Management Programmes for the separate sections of the mining operations . Environmental Impact Assessments and Environmental Management Programmes amendment for the Leeuwfontein Block . Water Use Licence Applications for the separate sections of the mining operations . Identification of a suitable host area and conditions for resettlement and the compilation of the Resettlement Action Plan and agreement on timeframes and responsibilities

 Bafokeng Rasimone Platinum Mine, North West, South Africa . Due diligence on environmental and tailings dam documentation for listing purposes on the JSE stock exchange . Competent Persons Report including environmental, social, hydrological and tailings aspects  Simmer & Jack Limited, Elandsdrift Heap Leach Pad, Mpumalanga, South Africa . Geotechnical and slope stability investigation . As built drawings for the Elandsdrift heap leach pad  Simmer & Jack Mines Limited Transvaal Gold Mining Estates, Mpumalanga, South Africa . Design, quality control/assurance manual, site support and part time project management for the design and construction of a heap leach dam extension  Afrikander Leases Gold Mine, North West, South Africa . Environmental Impact Assessment and Environmental Management Programme amendment  Grass Valley Platinum Project, Limpopo, South Africa . Update the environmental aspects in the Pre-Feasibility Study report  Lonmin PLC Western Platinum Mine, North West, South Africa . Basic Assessment and Environmental Management Programme for a hazardous waste storage facility . Waste Management Licence application  Samancor Chrome – Ferrometals, Emalahleni, Mpumalanga . EMP performance assessment for decommissioning of the IC3 facility . Slag dump waste management licence compliance audit . Water use license compliance audit  Pan African Mineral Development Corporation . Prospecting Right Application . Environmental Authorisation process incl. BAR, EMP and closure plan  Freightmax, a division of Imperial Group, Bayhead, KwaZulu-Natal . Environmental Authorisation for dangerous goods storage facility, incl. EIR and EMP

APPENDIX 3 PRE-APPLICATION WATER USE ENQUIRY Gené Main

From: Jon Hericourt Sent: 22 October 2018 14:42 To: Gené Main Subject: FW: Pre-Application Water Use Enquiry have been submitted to the department

From: [email protected] Sent: Monday, 22 October 2018 12:03 To: Jon Hericourt Subject: Pre-Application Water Use Enquiry have been submitted to the department

Dear Mr Jonathan Hericourt (Manager : Mining Projects)

A request for consultation for the following Pre-Application Water Use Enquiry have been submitted to the department:

New Kleinfontein Goldmine

Your request for consultation was submitted to:

Name : Mr K. Mudau (WULA Manager) e-Mail : [email protected] Tel : +27123921360

Thank you, e-WULAAS Team

In Production DISCLAIMER: This message and any attachments are confidential and intended solely for the addressee. If you have received this message in error, please notify the system manager/sender. Any unauthorized use, alteration or dissemination is prohibited. The Department of Water and Sanitation further accepts no liability whatsoever for any loss, whether it be direct, indirect or consequential, arising from this e-mail, nor for any consequence of its use or storage.

APPENDIX 4 NEED AND DESIRABILITY REPORT

NEW KLEINFONTEIN GOLDMINE (PTY) LTD

NEED AND DESIRABILITY REPORT FOR THE PROPOSED NEW KLEINFONTEIN GOLDMINE PROJECT, EAST RAND, GAUTENG

OCTOBER 2018

PREPARED FOR:

New Kleinfontein Goldmine (Pty) Ltd Corner Cloverfield and Outeniqua Road Eastvale Springs 1560

TABLE OF CONTENTS | REPORT STRUCTURE

1 Introduction ...... 1

2 Aspects to be Considered ...... 3

2.1 Securing Ecological Sustainable Development and Use of Natural Resources ...... 3 2.1.1 How will this development (and its separate elements/aspects) impact on the ecological integrity of the area? ...... 3 2.1.2 How will this development disturb or enhance ecosystems and/or result in the loss or protection of biological diversity? ...... 7 2.1.3 How will this development pollute and/or degrade the biophysical environment? ...... 7 2.1.4 What waste will be generated by this development? What measures were explored to firstly avoid waste, and where waste could not be avoided altogether, what measures were explored to minimise, reuse and/or recycle the waste? What measures have been explored to safely treat and/or dispose of unavoidable waste? ...... 8 2.1.5 How will this development disturb or enhance landscapes and/or sites that constitute the nation's cultural heritage? ...... 8 2.1.6 How will this development use/ or impact on non-renewable natural resources? ...... 8 2.1.7 How will this development use and/or impact on renewable natural resources and the ecosystem of which they are part? Will the use of the resources and/or impact on the ecosystem jeopardise the integrity of the resource and/or system taking into account carrying capacity restrictions, limits of acceptable change, and thresholds? ...... 9 2.1.8 How were a risk-averse and cautious approach applied in terms of ecological impacts? ...... 9 2.1.9 How will the ecological impacts resulting from this development impact on people's environmental right? 10 2.1.10 Describe the linkages and dependencies between human wellbeing, livelihoods and ecosystem services applicable to the area in question and how the development's ecological impacts will result in socio- economic impacts? ...... 11 2.1.11 Based on all of the above, how will this development positively or negatively impact on ecological integrity objectives/targets/considerations of the area? ...... 11 2.1.12 Considering the need to secure ecological integrity and a healthy biophysical environment, describe how the alternatives identified (in terms of all the different elements of the development and all the different impacts being proposed), resulted in the selection of the "best practicable environmental option" in terms of ecological considerations? ...... 12 2.1.13 Describe the positive and negative cumulative ecological/biophysical impacts bearing in mind the size, scale, scope and nature of the project in relation to its location and existing and other planned developments in the area? ...... 12 2.2 Promoting Justifiable Economic and Social Development ...... 13 2.2.1 What is the socio-economic context of the area, based on, amongst other considerations, the following considerations?...... 13 2.2.2 Considering the socio-economic context, what will the socio-economic impacts be of the development (and its separate elements/aspects), and specifically also on the socio-economic objectives of the area? ...... 15 2.2.3 How will this development address the specific physical, psychological, developmental, cultural and social needs and interests of the relevant communities? ...... 15 2.2.4 Will the development result in equitable (intra- and inter-generational) impact distribution, in the short- and long-term? Will the impact be socially and economically sustainable in the short- and long-term? .... 16 2.2.5 In terms of location, describe how the placement of the proposed development will:...... 16 2.2.6 How were a risk-averse and cautious approach applied in terms of socio-economic impacts?...... 18

Project Name: New Kleinfontein Goldmine - discharge pipeline project i Report Title: Need and Desirability Report Project number: 180969 2.2.7 How will the socio-economic impacts resulting from this development impact on people’s environmental right in terms of the following: ...... 18 2.2.8 Considering the linkages and dependencies between human wellbeing, livelihoods and ecosystem services, describe the linkages and dependencies applicable to the area in question and how the development's socio-economic impacts will result in ecological impacts (e.g. over utilisation of natural resources, etc.)? 19 2.2.9 What measures were taken to pursue the selection of the "best practicable environmental option" in terms of socio-economic considerations? ...... 19 2.2.10 What measures were taken to pursue environmental justice so that adverse environmental impacts shall not be distributed in such a manner as to unfairly discriminate against any person, particularly vulnerable and disadvantaged persons (who are the beneficiaries and is the development located appropriately)? Considering the need for social equity and justice, do the alternatives identified, allow the "best practicable environmental option" to be selected, or is there a need for other alternatives to be considered?...... 20 2.2.11 What measures were taken to pursue equitable access to environmental resources, benefits and services to meet basic human needs and ensure human wellbeing, and what special measures were taken to ensure access thereto by categories of persons disadvantaged by unfair discrimination? ...... 20 2.2.12 What measures were taken to ensure that the responsibility for the environmental health and safety consequences of the development has been addressed throughout the development's life cycle? ...... 20 2.2.13 What measures were taken to: ...... 20 2.2.14 Considering the interests, needs and values of all the interested and affected parties, describe how the development will allow for opportunities for all the segments of the community (e.g. a mixture of low-, middle-, and high-income housing opportunities) that is consistent with the priority needs of the local area (or that is proportional to the needs of an area)? ...... 21 2.2.15 What measures have been taken to ensure that current and/or future workers will be informed of work that potentially might be harmful to human health or the environment or of dangers associated with the work, and what measures have been taken to ensure that the right of workers to refuse such work will be respected and protected? ...... 21 2.2.16 Describe how the development will impact on job creation in terms of, amongst other aspects:...... 22 2.2.17 What measures were taken to ensure: ...... 22 2.2.18 What measures were taken to ensure that the environment will be held in public trust for the people, that the beneficial use of environmental resources will serve the public interest, and that the environment will be protected as the people's common heritage?...... 23 2.2.19 Are the mitigation measures proposed realistic and what long-term environmental legacy and managed burden will be left? ...... 23 2.2.20 What measures were taken to ensure that the costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects will be paid for by those responsible for harming the environment? ...... 23 2.2.21 Considering the need to secure ecological integrity and a healthy bio-physical environment, describe how the alternatives identified (in terms of all the different elements of the development and all the different impacts being proposed), resulted in the selection of the best practicable environmental option in terms of socio-economic considerations? ...... 24 2.2.22 Describe the positive and negative cumulative socio-economic impacts bearing in mind the size, scale, scope and nature of the project in relation to its location and other planned developments in the area? . 24

Project Name: New Kleinfontein Goldmine - discharge pipeline project ii Report Title: Need and Desirability Report Project number: 180969 ACRONYMS

BRP Bioregional Plan CBAs Critical Biodiversity Areas EAP Environmental Assessment Practitioner EBOSS Ekurhuleni Biodiversity and Open Space Strategy EIA Environmental Impact Assessment EIAR Environmental Impact Assessment Report EMPr Environmental management Programme ESAs Ecological Support Areas FEPA Freshwater Ecosystem Priority Area Gauteng C-Plan Gauteng Conservation Plan GDP Gross Domestic Product GIS Geographical Information System GPEMF Gauteng Province Environmental Management Framework HDPE High Density Polyethylene IAPs Interested and Affected Parties IBA Important Birds and Biodiversity Area IDP Integrated Development Plan LED Local Economic Development LoM Life of Mine LSDF Local Spatial Development Framework NEMA National Environmental Management Act, No. 107 of 1998 NEMBA National Environmental Management: Biodiversity Act, No. 10 of 2004 NFEPA National Freshwater Ecosystem Priority Areas RSDF Regional Spatial Development Framework SDF Spatial Development Framework SLP Social and Labour Plan

Project Name: New Kleinfontein Goldmine - discharge pipeline project iii Report Title: Need and Desirability Report Project number: 180969 1 INTRODUCTION

New Kleinfontein Goldmine (Pty) Ltd (NKGM) is an existing mine with existing mining rights, several Environmental Authorisations, and an approved Water Use Licence in place. The mine is located in the City of Ekurhuleni Metropolitan Municipality (CoE) of Gauteng, near the suburbs of Eastvale and Springs. The remaining life of mine is approximately 6 years and the mine is expected to operate until 2024. Decommissioning is expected to commence in 2025.

NKGM is applying to amend its water management strategy through the introduction and formalization of an underground water treatment facility, which will treat underground water using Cold Lime Softening (CLS). Treated water is expected to largely comply with SANS 241:2015 drinking water standards. Treated water will be pumped to a surface facility which will also serve as an emergency containment facility should the water quality not meet the required specifications. A water quality monitoring system will be implemented to contain any non- compliant water within this facility, which will allow for emergency repairs to be made to the water treatment facility underground, while preventing the discharge of non-compliant water to the environment.

NKGM is applying to discharge up to 22.5 megalitres (ML) of treated water per day. Treated water will be discharged via a pipeline (approximately 1.6 km in length) to the wetland downstream of Cowles Dam. Attenuation facilities and erosion protection measures will be constructed at the point of discharge. The pipeline is expected to be constructed of steel, concrete or high density polyethylene (HDPE) within the boundaries of the mine’s currently leased property (RE of Cloverfield 75 IR). Once it leaves this property, the pipeline will be constructed of either concrete or HDPE and will be buried. The pipeline will follow a south-easterly route, crossing Transnet’s railway line (via the culvert) on portion 3 of Cloverfield 75 IR. The pipeline is then directed in an easterly direction across RE Cloverfield 75 IR, and will then follow the railway line south to the discharge point. The final discharge point will be located on portion 104 of Geduld 123 IR.

The artificial wetland created as a result of historical discharge will be rehabilitated. The current extent of the surface water associated with the artificial wetland is 13.8 ha. Preliminary recommendations from the wetland specialist include waiting for approximately a year after pipeline construction before commencing with rehabilitation. Additional studies may need to be undertaken prior to the rehabilitation.

Further treatment of up to 500 m3/day of treated water is being considered for potable water requirements at the mine.

NKGM is pursuing an application for an Environmental Authorisation for activities listed in terms of the National Environmental Management Act, 1998 (NEMA) EIA Regulations (GNR982 of 2014). Relevant listed activities include 10, 12, 16 and 30 of GNR983 of 2014; activities 6 and 25 of GNR984 of 2014; and activities 12 and 14 of GNR985 of 2014. A Water Use Licence is also required for the above activities.

The aim of this report is to motivate the need and desirability of the proposed development, including the need and desirability of the development in the context of the preferred location. The

Project Name: New Kleinfontein Goldmine - discharge pipeline project 1 Report Title: Need and Desirability Report Project number: 180969 report was compiled in line with the requirements of the NEMA Need and Desirability Guideline (GN891 of 2014) and the Integrated Environmental Management Guideline on Need and Desirability of 2017.

The concept of “need and desirability” relates to, amongst others, the nature, scale and location of the development being proposed, as well as the wise use of land. Essentially, the concept can be explained in terms of the general meaning of its two components in which “need” primarily refers to time and “desirability” to place (i.e. is this the right time and is it the right place for locating the type of land-use / activity being proposed?) However, “need” also relates to the interests and needs of the broader public. These two components are interrelated and must be considered in an integrated and holistic manner (Need and Desirability Guideline, GN891 of 2014).

The consideration of “need and desirability” during an environmental authorisation application process, must consist of a preliminary description of the relevant considerations, as highlighted within the Guidelines, which is addressed in Section 2 of this report. The incorporation of the above-mentioned considerations into the environmental authorisation application process will ensure that all the relevant aspects are taken into account in order to adequately consider “need and desirability”.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 2 Report Title: Need and Desirability Report Project number: 180969 2 ASPECTS TO BE CONSIDERED

2.1 Securing Ecological Sustainable Development and Use of Natural Resources

2.1.1 How will this development (and its separate elements/aspects) impact on the ecological integrity of the area?

Threatened ecosystems

Section 52 of the National Environmental Management: Biodiversity Act, No. 10 of 2004 (NEMBA) provides for listing of threatened or protected ecosystems. The proposed pipeline route falls within the Blesbokspruit Highveld Grassland ecosystem which is currently listed as Critically Endangered and the Soweto Highveld Grassland ecosystem, which is currently listed as Vulnerable in terms of Section 52 of NEMBA. Due to historical mining activities and current anthropogenic activities within the area, Soweto Highveld Grassland no longer exists along the pipeline route.

Preferred faunal and floral habitat has been negatively affected by historic mining activities and current anthropogenic activities, as vegetation composition has changed and high levels of alien and invasive vegetation proliferation are present. Long term alien plant proliferation combined with on-going anthropogenic impacts will result in the continued large scale loss of indigenous floral diversity within the project area.

Sensitive, vulnerable, highly dynamic or stressed ecosystems

The pipeline is mostly located within areas of low ecological importance and sensitivity and passes through the already disturbed mine property. It will however pass through an area of Critical Biodiversity Area (CBA) according to the Gauteng Conservation Plan (C-Plan, 2011) near the artificial wetland and discharge point. According to the 2018 specialist wetland baseline study, the geomorphology and vegetation of Cowles Stream is Largely Modified and its hydrology is Seriously Modified. Ecosystem services given a high rating include stream flow reduction, and nitrate and toxicant removal, while services scored with a moderately high rating include flood attenuation, sediment and phosphate trapping, and erosion control. The maintenance of biodiversity is important due to it flowing into the Blesbokspruit Ramsar Wetland (approximately 1.5 km downstream).

Critical biodiversity areas and ecological support areas

The Gauteng C-Plan (2011) makes provision for CBAs and Ecological Support Areas (ESAs). According to the Gauteng C-Plan, there are no ESAs along the pipeline route. A portion of the route and the discharge point falls within a CBA. This CBA is considered an important area for primary vegetation. A CBA in general is an area considered important for the survival of threatened species and includes valuable ecosystems such as wetlands, untransformed vegetation and ridges.

The ecological conditions encountered on site were not considered representative of CBAs as a result of the degraded terrestrial ecology associated with the project area.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 3 Report Title: Need and Desirability Report Project number: 180969 According to the Mining and Biodiversity Guideline (2013), a portion of the pipeline route and discharge point falls within an area considered to be of Highest Biodiversity Importance. These are areas where mining is not legally prohibited, but where there is a very high risk that due to their potential biodiversity significance and importance to ecosystem services (e.g. water flow regulation and water provisioning). The remainder of the pipe route falls within an area considered to be of Moderate Biodiversity Importance. These include ESAs, vulnerable ecosystems as well as focus areas for protected area expansion. These areas are of moderate biodiversity value and mining poses a moderate risk to them.

According to the City of Ekurhuleni Bioregional Plan (BRP) 2014, most of the pipeline route is listed as a no natural area remaining, with a short section near the discharge point listed ESA 1, which are largely natural or near-natural landscapes (e.g. river buffers helping to moderate water flow during floods).

Conservation targets

According to the National Biodiversity Assessment, the Soweto Highveld Grassland vegetation type is classified as not protected, as less than 5 % of its biodiversity target area is located within protected areas. Conservation targets and protection levels of ecosystems used in the City of Ekurhuleni BRP 2014 have been aligned with the Gauteng C-Plan. However, the 2018 wetland study indicates that vegetation in the project area has been greatly disturbed and transformed, and Soweto Highveld Grassland is absent (most notably from the “artificial wetland” delineation, which is now dominated by Juncus and Phragmites).

Ecological drivers of the ecosystem

The key ecological drivers operating in the wetland associated with the Cowles Stream include stream flow reduction, and nitrate and toxicant removal.

Environmental sensitivity

According to the CoE Geographical Information System (GIS) website, the pipeline is classified as having an overall environmental sensitivity ranging between 0 and 6 (low to high) along its route. This is comprised of a Hydro Sensitivity of 0 and 1 (None and Water Course/Dam), a Dolomite Sensitivity of 1 (Dolomite) and a Vegetation Sensitivity of 0, 2 and 3 (Altered/urban, Soweto Highveld Grassland and Water Courses and Pans).

Spatial development framework

The CoE Regional Spatial Development Framework (RSDF) (2015) provides the framework for making resource-effective decisions regarding planning. The project area falls within Region D. Region D is characterised by three well-established urban nodes: Benoni, Brakpan and Springs. These areas are in a state of decay and are in need of maintenance and upgrade. Low-density residential housing components are associated with each of these urban nodes. Approximately 22 % of the land in Region D is affected by surface mining (disturbed land, mine dumps and slimes dams). These surface mined areas are not considered practical for future development due to the high rehabilitation costs. Areas of underground mining could be at risk of mining-induced subsidence, but this is dependent on the depth of mining below ground level. Numerous areas of

Project Name: New Kleinfontein Goldmine - discharge pipeline project 4 Report Title: Need and Desirability Report Project number: 180969 existing mining-induced subsidence or sinkholes have been identified and appear to follow the gold bearing reef outcrop. Approximately 60 % of Region D is classified as dolomitic land and 17 % of the region is affected by surface exposed dolomite. Region D is located favourably in terms of the economic activity and employment area of Gauteng and Benoni, Brakpan and Springs are considered important growth nodes.

According to the CoE RSDF, the mine operations fall within an area classified as mining, although part of the operations are not classified on this map. The pipeline largely falls within unclassified areas, however a part of it and the discharge point straddles areas of open space and industrial classification (refer to Figure 1). Areas classified as open space have functioning processes that should be maintained. According to the RSDF and the CoE Biodiversity and Open Space Strategy (EBOSS) (2009), corridors are open space areas that form part of the hydrological system, are natural areas that are shallowly undermined, or are areas with high quality natural vegetation that link different nodes to each other. Areas indicated as open space areas form part of the overall open space system where natural sensitivities may occur. It therefore does not imply that no development will be permitted in these areas but rather that future development should be sensitive to the fact that it may form part of a larger open-space system.

The objective of the RSDF is to ensure continued functioning of the area (ecological/ agricultural/ open space) and to ensure that the area is not compromised. Developments within these areas should be limited to existing footprints, if present, and should avoid encroaching on natural or agricultural landscapes. Development should be undertaken in such a way that ecological and open space networks remain intact, and that fragmentation of the system, resulting in the isolation of ecologically important areas and open space, does not occur. The relevant environmental assessments should be undertaken for any proposed development within these areas. In addition, the relevant national, provincial and local legislative requirements must be adhered to for all proposed developments. The pipeline will be constructed below ground thus not causing fragmentation of the system. The relevant national, provincial and local legislative requirements will be adhered to for the proposed development as described above.

According to the CoE Local Spatial Development Framework (LSDF), the project area falls into areas that have no current LSDF.

Environmental Management Framework

The Gauteng Province Environmental Management Framework (GPEMF) (2015) provides a framework to guide decision-making regarding land-use at all levels of planning. According to the GPEMF, NKGM operations fall within Zone 4: Normal Control. Part of the pipeline is also within this zone while a section of the pipeline and the discharge point falls within Zone 3: High Control (Outside Urban Development Zone) (refer to Figure 2). Zone 3 is considered to be sensitive to development activities and in some cases has specific values that need to be protected. As a result the intention with Zone 3 is to ensure that conservation and related tourism and recreation activities are dominant developments within this zone. Zone 4 is dominated by agricultural uses outside of urban development, thus the intention is to promote agriculture and rural development that supports agriculture in these areas.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 5 Report Title: Need and Desirability Report Project number: 180969 Figure 1. Proposed project relative to the City of Ekurhuleni RSDF

Figure 2. Proposed project relative to the GPEMF zoning

Project Name: New Kleinfontein Goldmine - discharge pipeline project 6 Report Title: Need and Desirability Report Project number: 180969 Global and international responsibilities relating to the environment

The Blesbokspruit Ramsar site is located approximately 2 km to the south of the project area and Marievale Nature Reserve is located 8 km to the south east, with the 5 km buffer just reaching the southern edge of Cowles Dam.

2.1.2 How will this development disturb or enhance ecosystems and/or result in the loss or protection of biological diversity?

During construction of the pipeline, vegetation will be removed and soil disturbed. Clearing of vegetation, removal of topsoil, and levelling of ground is anticipated to increase the extent of bare ground and hardened surfaces with implications for infiltration, run-off and sedimentation. The disturbance of surrounding vegetation due to vehicle and personnel movement during all the phases may result in the introduction and spread of alien invasive plant species. Alteration of the soil profile within the artificial wetland and Cowles Stream wetland could have implications for vegetation recovery and hydrological regimes. Any disturbance of the soil profile has the potential to have serious consequences on the water distribution and retention patterns of any wetland, by disrupting both the vertical infiltration and horizontal movement of water through the system. Additionally, trenches excavated for the pipeline are likely to fill, as water seeps in from the saturated wetland soils. This is likely to result in a slight and temporary decrease in hydrological zonation, as water is channelled into the trench effectively draining the wetlands. If left unfilled or if the soil profile is returned incorrectly, this drainage effect may be permanent.

The surrounding environment could be polluted by contaminants such as fuel and oil from vehicles, litter generated by employees, spillages of hazardous materials, soil runoff resulting in sedimentation of surrounding watercourses, etc.

Rehabilitation of the artificial wetland will only be carried out after the pipeline is constructed and will result in the enhancement and protection of biological diversity such that it contributes positively to the Blesbokspruit environment as a whole. Conversely, left as is, the artificial wetland system will likely continue to be represent a dangerous sink for local biodiversity, livestock and people due to its levels of contamination. The unsuccessful rehabilitation of the artificial wetland could lead to permanent loss of habitat and species diversity and altered surface flow.

The inability to maintain treatment standards of the discharged water from the water treatment facility may pollute the Blesbokspruit catchment.

2.1.3 How will this development pollute and/or degrade the biophysical environment?

The extent of the works required to develop the discharge pipeline are minimal. The risk of degradation to the environment is most likely during the construction phase, due to the movement

Project Name: New Kleinfontein Goldmine - discharge pipeline project 7 Report Title: Need and Desirability Report Project number: 180969 of vehicles and construction vehicles. The impacts are minimised as the pipeline runs along the service road to Transnet’s railways. The project may result in dust generation which may impact on the biophysical environment, however depending on the season of construction this may be limited or dust suppression may be incorporated. Erosion is a greater cause for concern however erosion prevention and flow attenuation measures will be incorporated into the design.

2.1.4 What waste will be generated by this development? What measures were explored to firstly avoid waste, and where waste could not be avoided altogether, what measures were explored to minimise, reuse and/or recycle the waste? What measures have been explored to safely treat and/or dispose of unavoidable waste?

The treatment process will result in a slurry / brine being created, which will be processing through the processing plant and ultimately deposited on the tailings dam as part of the current process.

Underground water will be treated below ground, using Cold Lime Softening, and pumped to a surface facility before being discharged via the pipeline. This treated water will largely comply with the SANS 241:2015 drinking water standards. Ongoing monitoring will ensure that the water being discharged meets the required standards.

2.1.5 How will this development disturb or enhance landscapes and/or sites that constitute the nation's cultural heritage?

A palaeontological impact assessment was undertaken in April 2012 and July 2018 for the New Kleinfontein Project. Based on these specialist reports the area is considered to be non- fossiliferous, and no sites of archaeological or paleontological significance were identified. There is potential to find impressions of fossil leaves, stems, roots and fructifications, and chance find procedures will be included in the EMPr.

The area around the pipeline is used for livestock activity as well as informal and illegal dumping. There are no significant cultural heritage resources within close proximity to the proposed pipeline route.

The landscapes will not be negatively impacted as the pipeline will be buried once it leaves the mine property therefore no visual impacts are anticipated.

2.1.6 How will this development use/ or impact on non-renewable natural resources?

Resources which will be utilised for the project include water and electricity. Electricity supplies, which will be required during construction of the pipeline and for the continued operation of the pumps, to bring the treated groundwater to surface, will be provided to the project from the existing Modder East operation (sourced from Eskom) or from backup diesel generators. NKGM is already pumping the groundwater to surface; therefore additional electricity requirements are unlikely for this project.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 8 Report Title: Need and Desirability Report Project number: 180969 Soil is also considered a non-renewable resource. The pipeline will have limited impact on utilisable soil resources as the soil resources along the pipeline route have largely already been impacted or transformed by anthropogenic land use – either by previous mining or agriculture. The rehabilitation of the artificial wetland will have a positive impact on the soil resources.

2.1.7 How will this development use and/or impact on renewable natural resources and the ecosystem of which they are part? Will the use of the resources and/or impact on the ecosystem jeopardise the integrity of the resource and/or system taking into account carrying capacity restrictions, limits of acceptable change, and thresholds?

Does the proposed development exacerbate the increased dependency or increased use of resources to maintain economic growth or does it reduce resource dependency?

The only resources to be utilised include water and electricity. Water can be considered to be a renewable resource. Electricity supplies, which will be required during construction of the pipeline and for the continued operation of the pumps, bringing the treated groundwater to surface, will be provided to the project from the existing Modder East operation or from backup diesel generators. NKGM is already pumping the groundwater to surface; therefore additional electricity requirements are unlikely for this project.

Does the proposed use of natural resources constitute the best use thereof?

Minimal resources are required for the project and this project does not pose any competition for use of resources.

Do the proposed location, type and scale of the development promote a reduced dependency on resources?

The small scale of the development means that it will only require resources during the construction. Operation of the facilities and infrastructure will not require any additional non- renewable resources. The potential for the project to include treating groundwater to potable standards for mine use will result in a decreased reliance on municipal water supply.

2.1.8 How were a risk-averse and cautious approach applied in terms of ecological impacts?

What are the limits of current knowledge?

 The exact boundaries of the artificial wetland were difficult to determine due to the scattered presence of wetland indicators. The full extent of the surface water was therefore used for the wetland delineation.  The contamination levels of the soil within the artificial wetland are largely unknown.  The 2018 and pre-2018 surface water quality data were not strictly comparable as the data were obtained from different localities.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 9 Report Title: Need and Desirability Report Project number: 180969  Some aspects of the ecology may have been overlooked. Due to the nature and habits of most faunal taxa, the high level of surrounding anthropogenic activities and the time (season) of the assessment, it is unlikely that all species would have been observed. Therefore, site observations were compared with literature studies where necessary. Some species and taxa within the study area may have been missed during the assessment.

What is the level of risk associated with the limits of current knowledge?

The contamination levels of the soil within the artificial wetland are largely unknown and a contaminated land assessment may be required.

Based on the limits of knowledge and the level of risk, how and to what extent was a risk-averse and cautious approach applied to the development?

Several independent specialists have been appointed to identify and assess potential impacts of the project. The pipeline route chosen follows the route of an existing railway line, and runs along the edge of a wetland, limiting the isolation of sections of wetland that may be caused by the construction of the pipeline. The proposed discharge point is located above the natural wetland delineation, allowing for flow attenuation prior to entering the natural wetland. A surface facility is available at the mine in case of treated water not meeting the required specification, allowing sufficient time for repairs to be undertaken to the treatment system.

2.1.9 How will the ecological impacts resulting from this development impact on people's environmental right?

South Africa’s Constitution guarantees all its citizens the right to an environment that is not harmful to their health and / or wellbeing; and to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that prevent pollution and ecological degradation. The Constitutional obligations of the State to protect the environment with respect to new development can only be met through the implementation, enforcement and monitoring of effective legislation. In order to protect the environment and ensure that the proposed development is undertaken in an environmentally responsible manner, the relevant national and local legislation, policies and guidelines were reviewed and incorporated into the Scoping Report.

Negative impacts: e.g. access to resources, opportunity costs, loss of amenity (e.g. open space), air and water quality impacts, nuisance (noise, odour, etc.), health impacts, visual impacts, etc. What measures were taken to firstly avoid negative impacts, but if avoidance is not possible, to minimise, manage and remedy negative impacts?

The negative environmental impacts will be contained along the pipeline route and discharge point. Some negative impacts will be felt during the construction phase (noise, dust) but operation of the pipeline is expected to improve the surrounding environment and reduce the current negative impacts of discharge. The selected route impacts least on residential communities (i.e. does not pass through residential areas), occurs within degraded areas (previously impacted by mining and

Project Name: New Kleinfontein Goldmine - discharge pipeline project 10 Report Title: Need and Desirability Report Project number: 180969 agriculture), and the proposed discharge point will be designed in such a way as to attenuate the flow and minimise any potential for erosion.

Positive impacts: e.g. improved access to resources, improved amenity, improved air or water quality, etc. What measures were taken to enhance positive impacts?

After construction of the pipeline, the discharge water will be contained thereby limiting the impacts on surface and groundwater, and allowing for the potential rehabilitation of the artificial wetland created on portion 37 of Geduld 123 IR by historical discharge. The improvement in water quality may have a positive influence on the Blesbokspruit. Rehabilitation of the artificial wetland will improve the quality of water running off this area and into the wetland associated with Cowles Dam.

2.1.10 Describe the linkages and dependencies between human wellbeing, livelihoods and ecosystem services applicable to the area in question and how the development's ecological impacts will result in socio-economic impacts?

After construction of the pipeline, the discharge water will be contained thereby limiting the impacts on surface and groundwater, and allowing for the potential rehabilitation of the artificial wetland. Rehabilitation of the artificial wetland will result in the enhancement and protection of biological diversity so that it contributes positively to the Blesbokspruit environment as a whole. Conversely, left as is, the artificial wetland system will likely continue to be represent a sink for local biodiversity, livestock and people due to its levels of contamination.

2.1.11 Based on all of the above, how will this development positively or negatively impact on ecological integrity objectives/targets/considerations of the area?

The proposed pipeline will have positive impacts in the long term, if implemented and operated appropriately. The land is zoned for mining, industrial and agriculture. The land use categories of the area are open space and agriculture. After construction of the pipeline, the discharge water will be contained thereby limiting the impacts on surface and groundwater, and allowing for the potential rehabilitation of the artificial wetland. The water treatment, and discharge of treated water, will improve the downstream water quality as a whole. The rehabilitation of the wetland may allow for quality open space, and potentially agriculture to occur in the future. The area impacted by the pipeline is limited to 0.4 ha. Impacts will be felt during construction and decommissioning but once the pipeline has been installed (considering the water treatment continues effectively) the ecological impacts are considered low to very low, and the project will not impact on the land use considerations for the area.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 11 Report Title: Need and Desirability Report Project number: 180969 2.1.12 Considering the need to secure ecological integrity and a healthy biophysical environment, describe how the alternatives identified (in terms of all the different elements of the development and all the different impacts being proposed), resulted in the selection of the "best practicable environmental option" in terms of ecological considerations?

No alternative site locations were assessed as the mine is an existing facility, and discharge needed to occur to a watercourse within reasonable distance (to ensure economic viability). Landowners were consulted during the initial phases of project consideration, and the current route is the most favourable in terms of landowner support. Infrastructure has been restricted to areas previously transformed by mining activities or has been kept to the minimum extent possible.

A longer route was also considered but this would have involved construction (and associated impacts) within a natural wetland. The current discharge point allows for flow attenuation and erosion protection features to be constructed prior to the discharge water entering a wetland.

Options for an above-ground or below-ground pipeline were also investigated. It was determined that a buried pipeline would be the most effective protection of the pipeline (from fire and vandalism), and would reduce the visual impact and potential impact on the landowner.

2.1.13 Describe the positive and negative cumulative ecological/biophysical impacts bearing in mind the size, scale, scope and nature of the project in relation to its location and existing and other planned developments in the area?

The potential positive and negative impacts, including cumulative impacts, of project will be further assessed in the EIA phase. The zoning of the land is mining, industrial and agriculture. The land use categories of the area are open space, and agriculture. Noise levels are low, typical of a suburban area with noise emanating from pedestrians, animals, birds, local roads and air traffic. Currently there are no other planned (known) developments for the project area. This project is of a small scale and it is expected that any impacts will be localised. There may however be some cumulative impact:

 Inadequate rehabilitation of the wetland, and activities during decommissioning, will result in a further habitat transformation and decrease in biodiversity in the project area and Cowles Dam wetland.  Unsuccessful rehabilitation of the wetland area may result in contaminants from the artificial wetland being transported to other environments.  If the attenuation and erosion protection measures are unsuccessful there is potential for severe erosion which will also result in sediment transfer to the downstream watercourses.

Positive impacts of the project include:

 Rehabilitation and improvement of a wetland area significantly impacted by historical and current mining activities, resulting further in the improvement of downstream water quality

Project Name: New Kleinfontein Goldmine - discharge pipeline project 12 Report Title: Need and Desirability Report Project number: 180969  Successful rehabilitation of the artificial wetland area removes contaminants and allows for alternative land uses to occur on that property.

2.2 Promoting Justifiable Economic and Social Development

2.2.1 What is the socio-economic context of the area, based on, amongst other considerations, the following considerations?

The IDP (and its sector plans' vision, objectives, strategies, indicators and targets) and any other strategic plans, frameworks or policies applicable to the area

The following documents have been referred to:

 City of Ekurhuleni RSDF: Region D (Final 2015)  City of Ekurhuleni Built Environment Performance Plan (2016)  City of Ekurhuleni Growth and Development Strategy (2025)  GPEMF (2014)

The objective of the GPEMF is to guide sustainable land use management within the Gauteng Province and to raise areas of concern, for example in CoE, open spaces make up only 6 % of the land area. The GPEMF was used by municipalities to further develop local frameworks and strategies.

The Growth and Development Strategy (GDS) defines the land use of the CoE broadly as covering three main components – a central, east, west orientated mining and industry activity belt; residential developments surrounding these activity belts; and rural / agricultural areas to the north east and central portion. Based on the RSDF the various defined land uses have location- specific guidelines on development in these areas.

The pipeline traverses areas classified as “open land” and “agriculture”, where the “open land” further classifies into “conservation”, “maintain” and “manage” areas. Conservation areas are those with high conservation requirements where it is recommended that development not take place within these areas. It does however not restrict development, and provides guidelines if development in such areas is necessary, such as limiting development to degraded / developed footprints, and to avoid fragmentation of such area. Areas classified as “maintain” have a functioning process that should be maintained, this would be the key ecological drivers operating in the wetland associated with the Cowles Stream including stream flow reduction, and nitrate and toxicant removal. Development in such areas should maintain the functionality, prevent fragmentation and try to avoid encroaching on natural areas. The areas requiring management should ensure mitigation measures of impacts are provided for, compatibility of the land use should be assessed to prevent / mitigate impacts on the area and that the land use should not introduce new negative impacts on the receiving environment.

The agricultural classification of the area is for the provision of urban farms. This recommendation is a general guideline of the enterprises that can be developed within the area. The area classified as high potential agricultural land which the CoE Built Environment Performance Plan (BEPP),

Project Name: New Kleinfontein Goldmine - discharge pipeline project 13 Report Title: Need and Desirability Report Project number: 180969 recommends for use as a measure of improving food security and assisting emerging farmers. As a result of land fragmentation, and lack of infill development strategies, equal proportion of land use classes (infrastructure and cultivation) has resulted in high potential agricultural land. In some instances there is a conflict between economic development and environmentally sensitive areas, resulting in strong competition for land use. The GDS proposes minimising the conflict of high potential agricultural land through mixed land use, and intensive agriculture.

Spatial priorities and desired spatial patterns (e.g. need for integration of segregated communities, need to upgrade informal settlements, need for densification, etc.)

At the time of compiling the GDS, 2.5 million people were living in the CoE, of which nearly a third lived in poverty, with unemployment estimated at ±40 %, most of whom were living in informal settlements on the urban periphery. The informal settlements typically lack the four basic services of water, sanitation, electricity and social services, and are situated on unsuitable land (e.g. low lying areas, underlain by dolomitic formations or undermined at shallow depth). Although literacy is high, the technical skills level is low, which is a poor fit for the demands of the local economic activities of the area.

As discussed in the GPEMF, social elements are incorporated in the different land uses, for example agriculture has a strong social element in that it may provide employment and housing. Consideration of social development, upliftment and inclusion needs to be incorporated in determining land use and development as well as social requirements such as mobility and services. The BEPP specifies the need to meet the defined objectives including promoting the development of sustainable compact urban structure and integrating disadvantaged communities into the urban fabric amongst others. As part of achieving these objectives, a fixed urban edge will be defined to accommodate further growth. Social development requirements are required in the form of improved and sustainable public transport and promoting access to social and municipal services. The RSDF indicates an additional need for further schools, particularly crèche, and healthcare facilities. Further social development requirements as per GDS include addressing poverty in a sustainable way, creation and promotion of sustainable human settlements, improved healthcare access, improved safety and security, and to improve the adequacy and equitable distribution of parks, recreational areas and sports facilities.

Environmental management framework

According to the GPEMF, the proposed pipeline route falls within Zone 3: High Control (Outside Zone 1 – Urban Development Zone) and Zone 4. The intention with Zone 3 is to ensure that conservation and related tourism and recreation activities are dominant developments within this zone. Zone 4 is dominated by agricultural uses outside of urban development, thus the intention is to promote agriculture and rural development that supports agriculture in these areas.

Spatial development framework

According to the RSDF the project area falls within Region D, which is characterised by three well- established urban nodes: Benoni, Brakpan and Springs. The pipeline route largely falls within unclassified areas, however a part of it and the discharge point straddles areas of open space and industrial classification. Areas classified as open space have functioning processes that should be

Project Name: New Kleinfontein Goldmine - discharge pipeline project 14 Report Title: Need and Desirability Report Project number: 180969 maintained. According to the RSDF and the CoE Biodiversity and Open Space Strategy (EBOSS) (2009), corridors are open space areas that form part of the hydrological system, are natural areas that are shallowly undermined, or are areas with high quality natural vegetation that link different nodes to each other. Areas indicated as open space areas form part of the overall open space system where natural sensitivities may occur. It therefore does not imply that no development will be permitted in these areas but rather that future development should be sensitive to the fact that it may form part of a larger open-space system.

Spatial characteristics (e.g. existing land uses, planned land uses, cultural landscapes, etc.)

The project area is surrounded by existing mining operations to the north, industrial development to the south and west, agriculture to the west, and a railway network to the north, east and south.

Municipal Economic Development Strategy

According to the CoE Growth and Human Development Strategy (2025) the following are the objectives to be met by the CoE: provision of social and economic infrastructure and services that will build sustainable communities and contribute to halving poverty; accelerated, labour-absorbing economic growth that increases per annum and that will create long-term sustainable jobs and contribute to halving unemployment; sustainable development; enhanced government efficiency, co-operative governance; and deepening participatory democracy, provincial and national unity, as well as citizenship.

2.2.2 Considering the socio-economic context, what will the socio-economic impacts be of the development (and its separate elements/aspects), and specifically also on the socio-economic objectives of the area?

Will the development complement the local socio-economic initiatives (such as local economic development (LED) initiatives), or skills development programs?

The project is an extension of an existing mining operation but does not result in any further economic benefits for the employees or nearby communities. The main socio-economic benefit would be that the water quality downstream is improved as a result of treatment of excess water, and that the artificial wetland is rehabilitated, allowing for alternative land uses to be considered in the area.

2.2.3 How will this development address the specific physical, psychological, developmental, cultural and social needs and interests of the relevant communities?

Project Name: New Kleinfontein Goldmine - discharge pipeline project 15 Report Title: Need and Desirability Report Project number: 180969 2.2.4 Will the development result in equitable (intra- and inter-generational) impact distribution, in the short- and long-term? Will the impact be socially and economically sustainable in the short- and long-term?

The project is not expected to have significant economic impacts. The project is an extension of an existing mining operation and does not result in any further economic benefits for the employees or nearby communities. The main socio-economic benefit would be that the water quality downstream is improved as a result of treatment of excess water, and that the artificial wetland is rehabilitated, allowing for alternative land uses to be considered in the area.

2.2.5 In terms of location, describe how the placement of the proposed development will:

Result in the creation of residential and employment opportunities in close proximity to or integrated with each other

The project is an extension of an existing mining operation but does not result in any further economic benefits for the employees or nearby communities. It will not result in residential opportunities. Employment opportunities will be limited to contract work during the construction period.

Reduce the need for transport of people and goods

The project will not impact on transportation, and will not generation an additional need for transport.

Result in access to public transport or enable non-motorised and pedestrian transport (e.g. will the development result in densification and the achievement of thresholds in terms of public transport)

The project will not improve access to public transport or enable non-motorised and pedestrian transport.

Complement other uses in the area

The surrounding mining, industrial and residential land uses will continue to operate concurrently with the project development. The land uses will not specifically complement each other although the improvement in water quality may have a positive influence on the Blesbokspruit Ramsar Wetland and the associated users of this area.

Be in line with the planning for the area

The SDF indicates that in Region D, the finance sector is the largest contributor to the economy with the manufacturing sector in second place. Availability of land for development in Region D is constrained significantly due to environmental aspects within the region. The environmental constraints are however not prohibitive, but rather restrictive in terms of the type of development that can occur within them. Approximately 22% of the land in Region D is affected by surface mining (disturbed land, mine dumps and slimes dams). These areas are not considered feasible for future development due to the high rehabilitation costs.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 16 Report Title: Need and Desirability Report Project number: 180969 According to the CoE RSDF for Region D, the majority of the land associated with the study area is classified as mining / open space. The pipeline will have a limited effect on the potential for development of the land in which it is situated.

For urban related development, make use of underutilised land available with the urban edge

The project is not related to urban development.

Optimise the use of existing resources and infrastructure

The pipeline route chosen follows the route of an existing railway line, and runs along the edge of a wetland, limiting the isolation of sections of wetland that may be caused by the construction of the pipeline. It also limits the sterilisation of land should alternative land uses be considered to the west of the pipeline route.

Opportunity costs in terms of bulk infrastructure expansions in non-priority areas (e.g. not aligned with the bulk infrastructure planning for the settlement that reflects the spatial reconstruction priorities of the settlement)

The project will not result in the construction of bulk infrastructure.

Discourage "urban sprawl" and contribute to compaction/densification

Due to the size and nature of the project, it is unlikely that the project will result in urban sprawl as no permanent jobs will be created and thus there should not be an influx of job seekers.

Contribute to the correction of the historically distorted spatial patterns of settlements

The surrounding mining, industrial and residential land uses will continue to operate concurrently with the project development. No impacts on settlements are expected to result as an impact of this project.

Contribute to the optimum use of existing infrastructure in excess of current needs.

The project will not affect existing infrastructure such as public roads. The pipeline route has been aligned with existing infrastructure (railway line).

Encourage environmentally sustainable land development practices and processes

Infrastructure has been restricted to areas previously transformed by mining activities or has been kept to the minimum extent possible. No land development is expected to occur as a result of the project.

Take into account special locational factors that might favour the specific location (e.g. the location of a strategic mineral resource, access to the port, access to rail, etc.)

Most of the pipeline route is within areas already transformed by mining or agricultural activities, however attempts to minimise the extent of the route were implemented, taking into consideration the requirements of the affected landowners. The pipeline route is aligned with the existing railway network to limit the impact on undeveloped land.

The investment in the settlement or area in question will generate the highest socio-economic returns (i.e. an area with high economic potential)

Project Name: New Kleinfontein Goldmine - discharge pipeline project 17 Report Title: Need and Desirability Report Project number: 180969 The project has limited footprint, and is unlikely to stimulate the manufacturing or service industries.

Impact on the sense of history, sense of place and heritage of the area and the socio-cultural and cultural-historic characteristics and sensitivities of the area

The pipeline route is aligned within areas that have been impacted on historically by agriculture, mining or industry. The area is currently surrounding by those land uses. A single farm house was located in proximity to the pipeline route, however this building was in a bad state of preservation.

In terms of the nature, scale and location of the development promote or act as a catalyst to create a more integrated settlement?

The project is unlikely to result in further development in the project area.

2.2.6 How were a risk-averse and cautious approach applied in terms of socio- economic impacts?

What are the limits of current knowledge (note: the gaps, uncertainties and assumptions must be clearly stated)?

The census data used in the report is assumed to be the most current source of official statistics and this been used to generate a baseline profile of the area. This data may now be out of date to some degree and may no longer accurately reflect the current socio-economic profile. The potential for in-migration of job seekers (and associated impacts), as a result of this project is limited.

What is the level of risk (note: related to inequality, social fabric, livelihoods, vulnerable communities, critical resources, economic vulnerability and sustainability) associated with the limits of current knowledge?

Current information indicates that no risk is posed to the local communities in the project area due to the size of the project and the aspects involved. Inappropriate development and rehabilitation may impact on the landowners of the project area.

Based on the limits of knowledge and the level of risk, how and to what extent was a risk-averse and cautious approach applied to the development?

Several recommendations from the specialist studies are included to prevent further land degradation, which would potentially have an impact on the landowners.

2.2.7 How will the socio-economic impacts resulting from this development impact on people’s environmental right in terms of the following:

Negative impacts: e.g. health (e.g. HIV-Aids), safety, social ills, etc. What measures were taken to firstly avoid negative impacts, but if avoidance is not possible, to minimise, manage and remedy negative impacts?

Project Name: New Kleinfontein Goldmine - discharge pipeline project 18 Report Title: Need and Desirability Report Project number: 180969 No risk is posed to the local communities in the project area due to the size of the project and the aspects involved. Inappropriate development and rehabilitation may impact on the landowners of the project area - which would be an economic impact rather than being related to safety or social ills.

Positive impacts. What measures were taken to enhance positive impacts?

The scale of the project does not allow for significant socio-economic benefits. Limited employment will be created during the construction period. Measures to ensure appropriate and responsible development and rehabilitation will maximise the benefits on the current landowners.

2.2.8 Considering the linkages and dependencies between human wellbeing, livelihoods and ecosystem services, describe the linkages and dependencies applicable to the area in question and how the development's socio-economic impacts will result in ecological impacts (e.g. over utilisation of natural resources, etc.)?

The project is not anticipated to result in socio-economic impacts other than short term employment. This is further not anticipated to result in in-migration or additional use of natural resources, and is therefore not expected to have a knock-on impact on the natural environment.

2.2.9 What measures were taken to pursue the selection of the "best practicable environmental option" in terms of socio-economic considerations?

Project Name: New Kleinfontein Goldmine - discharge pipeline project 19 Report Title: Need and Desirability Report Project number: 180969 2.2.10 What measures were taken to pursue environmental justice so that adverse environmental impacts shall not be distributed in such a manner as to unfairly discriminate against any person, particularly vulnerable and disadvantaged persons (who are the beneficiaries and is the development located appropriately)? Considering the need for social equity and justice, do the alternatives identified, allow the "best practicable environmental option" to be selected, or is there a need for other alternatives to be considered?

The project’s socio-economic impacts are limited to short term employment during construction, and to potential impacts on the landowners should implementation not be undertaken appropriately. No feasible alternatives are available for consideration.

2.2.11 What measures were taken to pursue equitable access to environmental resources, benefits and services to meet basic human needs and ensure human wellbeing, and what special measures were taken to ensure access thereto by categories of persons disadvantaged by unfair discrimination?

Socio-economic impacts are generally positive, i.e. short term employment for the selected contractor. Mitigation measures have been put in place to ensure appropriate development is undertaken so that no negative impacts arise as a result of the project.

2.2.12 What measures were taken to ensure that the responsibility for the environmental health and safety consequences of the development has been addressed throughout the development's life cycle?

There are unlikely to be any health and safety impacts on the community as the pipeline is proposed to be buried, and therefore not accessible. Health and safety policies currently in place at NKGM operations will be implemented during construction of the pipeline.

2.2.13 What measures were taken to:

Ensure the participation of all interested and affected parties

A comprehensive public participation process, according to the requirements of Chapter 6 of the EIA regulations (GNR982 of 2014), will be undertaken.

Provide all people with an opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation

Background information documents will be made available to nearby communities. Documentation will be available in public libraries for review. Options for commenting via email, SMS, telephone and in writing are available. Considering the limited socio-economic impacts on the local communities, these measures are considered acceptable. Discussions will be held with landowners as requested. Focus group meetings will be held during the environmental process.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 20 Report Title: Need and Desirability Report Project number: 180969 Ensure participation by vulnerable and disadvantaged persons

No particularly vulnerable and disadvantaged groups have been identified in proximity to the proposed pipeline. Notification by means of site notices, Background Information Documents, and media notices (newspapers) is considered acceptable to inform the nearby communities of the project.

Promote community wellbeing and empowerment through environmental education, the raising of environmental awareness, the sharing of knowledge and experience and other appropriate means

During the public participation process, IAPs will be made aware of the legislated environmental processes and their rights. The specialist findings will also be made available during the EIA and feedback process.

Ensure openness and transparency, and access to information in terms of the process

All the relevant State Departments, landowner, adjacent landowners and land occupiers and IAPs will be notified of the project via the same legislated processes - site notice, Background Information Documents, and media notices. The same documents will be made available for review by all. All comments received will be incorporated into the documentation.

Ensure that the interests, needs and values of all interested and affected parties were taken into account, and that adequate recognition were given to all forms of knowledge, including traditional and ordinary knowledge

All IAPs will be provided with opportunities to comment on or raise concerns about the project. All comments will be incorporated into the documentation. The EAP contact details are available for any reporting on additional knowledge or information.

Ensure that the vital role of women and youth in environmental management and development were recognised and their full participation therein be promoted?

Women and the youth, as part of the greater affected communities, will be included in information dissemination, and will be allowed equal opportunities to participate in the process.

2.2.14 Considering the interests, needs and values of all the interested and affected parties, describe how the development will allow for opportunities for all the segments of the community (e.g. a mixture of low-, middle-, and high-income housing opportunities) that is consistent with the priority needs of the local area (or that is proportional to the needs of an area)?

Employment opportunities will be made available to the contractor selected for the construction work. The procurement process considers the needs of the local communities.

2.2.15 What measures have been taken to ensure that current and/or future workers will be informed of work that potentially might be harmful to human health or the environment or of dangers associated with the work, and what measures have been taken to ensure that the right of workers to refuse such work will be

Project Name: New Kleinfontein Goldmine - discharge pipeline project 21 Report Title: Need and Desirability Report Project number: 180969 respected and protected?

The Applicant will comply with the requirements of the Mine Health and Safety Act, No. 29 of 1996 and will ensure that itself and the contractor employed will comply with the Occupational Health and Safety Act, Act 85 of 1993. Employees will be made aware, as part of the EIAR / EMPr (specifically the environmental awareness programme), of Section 4(j) of NEMA, which relates to the right of workers to refuse work that is harmful to human health or the environment and to be informed of dangers. The environmental awareness programme will be included in induction material for all employees and contractors.

2.2.16 Describe how the development will impact on job creation in terms of, amongst other aspects:

The number of temporary versus permanent jobs that will be created

Construction and will be carried out by contractors, who will likely have their own staff complement suited to the required skills. It is unlikely that additional permanent jobs will be created during construction.

Whether the labour available in the area will be able to take up the job opportunities (i.e. do the required skills match the skills available in the area)

Employment opportunities will be made available to the contractor selected for the construction work. The procurement process considers the needs of the local communities.

The distance from where labourers will have to travel

This is unknown and dependent on the appointment of the contractor.

The location of jobs opportunities versus the location of impacts (i.e. equitable distribution of costs and benefits)

Limited impacts will be felt as a result of the project. Employment levels are low in the local communities as well as the larger municipal area.

The opportunity costs in terms of job creation (e.g. a mine might create 100 jobs, but impact on 1000 agricultural jobs, etc.)

The construction of the pipeline will result in the employment of contractors for the duration of the construction phase only. No employment will be created for the operations or implementation phase of the pipeline. No impact will be felt on other jobs as the pipeline does not affect the proposed land use of the area.

2.2.17 What measures were taken to ensure:

That there were intergovernmental coordination and harmonisation of policies, legislation and actions relating to the environment

Project Name: New Kleinfontein Goldmine - discharge pipeline project 22 Report Title: Need and Desirability Report Project number: 180969 All relevant national and local legislation, policies and guidelines were reviewed and incorporated into the Scoping Report, prior to being made available for authority review. All relevant State Departments were provided with copies of environmental documentation for comment.

That actual or potential conflicts of interest between organs of state were resolved through conflict resolution procedures?

No conflict of interest between organs of state has been identified as a result of the project.

2.2.18 What measures were taken to ensure that the environment will be held in public trust for the people, that the beneficial use of environmental resources will serve the public interest, and that the environment will be protected as the people's common heritage?

The improved quality of discharge water from the mine will have a positive effect on the environment and improve the ecosystem services and functioning of the Cowles Stream especially with regards to maintaining biodiversity. The maintenance of this biodiversity, as well as the improved water quality entering the Blesbokspruit, will have a positive impact on the Blesbokspruit Ramsar site downstream of the project area. Upon closure of the mine, the pipeline will be removed and the treatment and discharge of excess water will cease.

2.2.19 Are the mitigation measures proposed realistic and what long-term environmental legacy and managed burden will be left?

The mitigation measures provided are realistic and practical. The improvement in water management of the mine will create a better environmental legacy than the current practises. The discharge flow to the environment will be of an improved standard, thus improving the quality of the natural environment.

2.2.20 What measures were taken to ensure that the costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects will be paid for by those responsible for harming the environment?

Section 28 of NEMA relates to the duty of care and remediation of environmental damage and states that anyone who causes, has caused or may cause significant pollution or degradation of the environment is strictly liable and must take reasonable measures to prevent the pollution or degradation from occurring, continuing or recurring. The proposed project is being implemented as a means of preventing pollution from occurring and continuing. Ongoing monitoring of the discharge water, as well as the maintenance of an emergency storage facility, will ensure that required quality specifications for discharge water are met. A preliminary cost estimate for rehabilitation and closure of the pipeline has been calculated at approximately R325 000 excl. VAT, using the NEMA Financial Provisioning Regulations (GNR1147 of 2015).

Project Name: New Kleinfontein Goldmine - discharge pipeline project 23 Report Title: Need and Desirability Report Project number: 180969 2.2.21 Considering the need to secure ecological integrity and a healthy bio-physical environment, describe how the alternatives identified (in terms of all the different elements of the development and all the different impacts being proposed), resulted in the selection of the best practicable environmental option in terms of socio-economic considerations?

2.2.22 Describe the positive and negative cumulative socio-economic impacts bearing in mind the size, scale, scope and nature of the project in relation to its location and other planned developments in the area?

Positive impacts of the project include:

 Rehabilitation and improvement of a wetland area significantly impacted by historical and current mining activities, resulting further in the improvement of downstream water quality

Project Name: New Kleinfontein Goldmine - discharge pipeline project 24 Report Title: Need and Desirability Report Project number: 180969  Successful rehabilitation of the artificial wetland area removes contaminants and allows for alternative land uses to occur on that property.

Project Name: New Kleinfontein Goldmine - discharge pipeline project 25 Report Title: Need and Desirability Report Project number: 180969

APPENDIX 5.1 LANDOWNER NOTIFICATION

12 October 2018

City of Ekurhuleni Real Estate Department Property Management Division PO Box 45 Springs 1560

For attention: Winza Marumo Email: [email protected]

Sent via email

PROPOSED PIPELINE ON PORTION RE OF CLOVERFIELD 75 IR - TO DISCHARGE TREATED GROUNDWATER INTO THE WETLAND DOWNSTREAM OF COWLES DAM, SPRINGS

Dear Winston

According to the latest information at the Deeds office, City of Ekurhuleni (previously Ekurhuleni Metropolitan Municipality) is the landowner of the farm RE Cloverfield 75 IR within the Gauteng Province. New Kleinfontein Goldmine (Pty) Ltd (NKGM) is currently conducting mining activities on this property and has in place a lease with the City of Ekurhuleni for the use of this property until February 2026. NKGM is applying to amend its water management strategy by treating underground water and discharging it to the wetland downstream of Cowles Dam. The proposed pipeline route traverses, among others, portion RE of Cloverfield 75 IR.

The water treatment facility will be constructed underground and will be comprised of settling dams and a dosing plant, which will apply a Cold Lime Softening (CLS) treatment to groundwater to improve the water quality. The slurry arising as a result of the treatment will be processed in the existing processing plant

and disposed of on the existing tailings disposal facility. Associated activities include the construction of attenuation features at the discharge point (to reduce the flow and prevent erosion) and the rehabilitation of an artificial wetland on the adjacent property. Please refer to Figure 1.

Prime Resources is conducting the Environmental Authorisation and Water Use Licence Application processes for the proposed project. As the landowner of one of the properties affected by the project, the applicant (NKGM) is required to notify you of the proposed project. Your contact details have also been added to the Interested and Affected Party (IAP) database. Should you wish to nominate an alternative contact person, or remove your contact details from the IAP database, please advise via email.

More detail regarding the project will be made available during the Scoping and EIA phases of the process, and relevant documentation will be submitted to you for review and comment. Specialist studies are currently underway and will be incorporated into the environmental documentation. The public consultation processes for Scoping and EIA are anticipated to occur during November / December 2018, and March / April 2019, respectively.

Should you wish to discuss the project, or associated regulated processes further, please feel free to contact us at:

Applicant Environmental Assessment Practitioner New Kleinfontein Gold Mine / Modder East Operations Prime Resources Jon Hericourt Gené Main Email [email protected] Email [email protected] Tel. 010 594 2871 Tel. 011 447 4888

Yours sincerely

Gené Main Principal Environmental Consultant Prime Resources (Pty) Ltd

P180969 Modder East discharge pipeline project Landowner notification October 2018

Figure 1. Properties affected by the pipeline and associated activities proposed by NKGM

P180969 Modder East discharge pipeline project Landowner notification October 2018 Gené Main

From: Mail Delivery System To: [email protected] Sent: 12 October 2018 08:34 Subject: Relayed: Landowner notification - proposed pipeline on CoE-owned property

Delivery to these recipients or groups is complete, but no delivery notification was sent by the destination server:

[email protected]

Subject: Landowner notification - proposed pipeline on CoE-owned property

1 Gené Main

From: Winston Marumo (Springs) Sent: 17 October 2018 10:18 To: Gené Main Subject: Read: Landowner notification - proposed pipeline on CoE-owned property Attachments: Read Landowner notification - proposed pipeline on CoE-owned property

Importance: High

To read City of Ekurhuleni's Disclaimer for this email click on the following address or copy into your Internet browser: http://www.ekurhuleni.gov.za/email-disclaimer

1 Gené Main

From: Winston Marumo (Springs) Sent: 17 October 2018 10:32 To: Gené Main Cc: Tersia Visser (Springs); Michelle Adams Subject: FW: Landowner notification - proposed pipeline on CoE-owned property Attachments: NKGM Pipeline Landowner notification - City of Ekurhuleni MM.pdf

Importance: High

Good day Gené

Receipt of your email below is hereby acknowledged. Kindly be advised that your request will be forwarded to our relevant departments for their comments.

Further communication will be forwarded to you as soon as circumstances permit.

Kind regards

Winza Marumo Springs Customer Care Area EKURHULENI METROPOLITAN MUNICIPALITY Room 304, Block F, Third Floor Springs Civic Centre Cnr South Main Reef and Plantation Roads, Springs P O Box 45 SPRINGS 1560 (011) 999-8698 [email protected]

From: Gené Main Sent: Friday, October 12, 2018 8:29 AM To: Winston Marumo (Springs) Subject: Landowner notification - proposed pipeline on CoE-owned property Importance: High

Dear Winston

Attached please find the updated notification of the proposed project – with activities occurring on property owned by the City of Ekurhuleni Metropolitan Municipality.

Kind Regards

Gené Main Principal Consultant Pr. Sci. Nat. (Env Science)

1 T: +27 11 447 4888 F: +27 86 604 2219 E: [email protected]

the workshop ▪ 70 - 7th avenue ▪ parktown north ▪ johannesburg ▪ 2193 po box 2316 ▪ parklands ▪ 2121

www.resources.co.za

This e-mail is confidential and it is intended only for the addressees. Any review, dissemination, distribution, or copying of this message by persons or entities other than the intended recipient is prohibited. If you have received this e-mail in error, kindly notify us immediately by telephone or e-mail and delete the message from your system. The sender does not accept liability for any errors or omissions in the contents of this message which may arise as a result of the e-mail transmission

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12 October 2018

SAPPI Manufacturing

For attention: Renée van Hoeve; Penny Jenkins Email: [email protected]; [email protected]

Sent via email

PROPOSED ACTIVITIES ON PORTION 37 OF THE FARM GEDULD 123 IR - REHABILITATION OF ARTIFICIAL WETLAND TO THE NORTH OF COWLES DAM, SPRINGS

Dear Ms van Hoeve and Ms Jenkins

According to the latest information at the Deeds office, SAPPI Manufacturing is the landowner of Portion 37 of the farm Geduld 123 IR within the Gauteng Province. New Kleinfontein Goldmine (Pty) Ltd (NKGM) is currently conducting mining activities on RE of Farm Cloverfield 75 IR. NKGM is applying to amend its water management strategy by treating underground water and discharging it to the wetland located downstream of Cowles Dam. The proposed pipeline route does not traverse portion 37 of Geduld 123 IR, but NKGM is applying for Environmental Authorisation for the rehabilitation of the artificial wetland created as a result of historical discharge onto portion 37. Please refer to Figure 1.

Should you wish to discuss the project, or associated regulated processes further, please feel free to contact us at:

Yours sincerely

Gené Main Principal Environmental Consultant Prime Resources (Pty) Ltd

P180969 Modder East discharge pipeline project Landowner notification October 2018

Figure 1. Properties affected by the pipeline and associated activities proposed by NKGM

P180969 Modder East discharge pipeline project Landowner notification October 2018 Gené Main

From: Van Hoeve, Renée Sent: 16 October 2018 10:02 To: Gené Main; Jenkins, Penny Subject: RE: [EXT] RE: Landowner notification of activities occurring on Sappi-owned properties

Hi Gené Noted. Regards

Renée Van Hoeve Regional Environmental Manager Sappi Southern Africa Limited | 108 Oxford Road Rosebank Johannesburg | South Africa Tel +27 11 407 8367 | Mobile +27 82 876 7656

[email protected]

Please recycle all printed documents. www.sappi.com

This email is subject to the Sappi email legal notice available at www.sappi.com If you cannot access this notice please contact the webmaster for a copy to be sent to you.

From: Gené Main Sent: Monday, 15 October 2018 10:00 AM To: Jenkins, Penny ; Van Hoeve, Renée Subject: [EXT] RE: Landowner notification of activities occurring on Sappi-owned properties

Hi Penny and Renée

Apologies, it appears that the previous version of this PDF was slightly corrupted (links not working correctly). Hopefully this version is clean.

Kind regards Gené

From: Gené Main Sent: 12 October 2018 08:29 To: Jenkins, Penny ([email protected]); Van Hoeve, Renée ([email protected]) Subject: Landowner notification of activities occurring on Sappi-owned properties Importance: High

Dear Penny and Renée

Attached please find the updated notification of the proposed project – with activities occurring on property owned by Sappi Manufacturing.

1 Kind Regards

Gené Main Principal Consultant Pr. Sci. Nat. (Env Science)

T: +27 11 447 4888 F: +27 86 604 2219 E: [email protected]

the workshop ▪ 70 - 7th avenue ▪ parktown north ▪ johannesburg ▪ 2193 po box 2316 ▪ parklands ▪ 2121

www.resources.co.za

2 Gené Main

From: Jenkins, Penny Sent: 15 October 2018 10:25 To: Gené Main Subject: RE: [EXT] RE: Landowner notification of activities occurring on Sappi-owned properties

Received, thanks Gene.

Penny Jenkins Senior Legal Advisor Sappi Southern Africa | Pvt Bag X1001 | 4170 Global Business Services - Amanzimtoti | South Africa

Tel +27 87 808 9652 - GBS ext. 6017 | Mobile +27 82 329 5317 | Fax

[email protected]

Please recycle all printed documents. www.sappi.com

This email is subject to the Sappi email legal notice available at www.sappi.com If you cannot access this notice please contact the webmaster for a copy to be sent to you.

From: Gené Main Sent: Monday, 15 October 2018 10:00 AM To: Jenkins, Penny ; Van Hoeve, Renée Subject: [EXT] RE: Landowner notification of activities occurring on Sappi-owned properties

Hi Penny and Renée

Apologies, it appears that the previous version of this PDF was slightly corrupted (links not working correctly). Hopefully this version is clean.

Kind regards Gené

Dear Penny and Renée

Attached please find the updated notification of the proposed project – with activities occurring on property owned by Sappi Manufacturing.

Kind Regards

Gené Main

1 Principal Consultant Pr. Sci. Nat. (Env Science)

T: +27 11 447 4888 F: +27 86 604 2219 E: [email protected]

the workshop ▪ 70 - 7th avenue ▪ parktown north ▪ johannesburg ▪ 2193 po box 2316 ▪ parklands ▪ 2121

www.resources.co.za

2 Gené Main

From: Mail Delivery System To: [email protected]; [email protected] Sent: 12 October 2018 08:29 Subject: Relayed: Landowner notification of activities occurring on Sappi-owned properties

Delivery to these recipients or groups is complete, but no delivery notification was sent by the destination server:

[email protected]

Subject: Landowner notification of activities occurring on Sappi-owned properties

12 October 2018

Transnet Ltd

For attention: Neo Mosebo E-mail:[email protected]

Sent via email

PROPOSED PIPELINE ON PORTIONS 3 AND 6 OF CLOVERFIELD 75 IR AND PORTIONS 104 AND 107 OF GEDULD 123 IR - TO DISCHARGE TREATED GROUNDWATER INTO THE WETLAND DOWNSTREAM OF COWLES DAM, SPRINGS

Dear Maureen

According to the latest information at the Deeds office, Transnet Ltd is the landowner of Portions 3 and 6 of the farm Cloverfield 75 IR and Portions 104 and 107 of the farm Geduld 123 IR within the Gauteng Province. New Kleinfontein Goldmine (Pty) Ltd (NKGM) is currently conducting mining activities on the RE of Cloverfield 75 IR. NKGM is applying to amend its water management strategy by treating underground water and discharging it to the wetland downstream of Cowles Dam. The proposed pipeline route traverses, among others, Portions 3 and 6 of Cloverfield 75 IR and Portions 104 and 107 of Geduld 123 IR.

NKGM is applying for Environmental Authorisation in terms of the National Environmental Management Act (1998), as amended and the Environmental Impact Assessment (EIA) Regulations (2014), for the underground treatment and subsequent discharge of 23 megalitres of water per day (MLD), and the construction and operation of a pipeline approximately 2 km in length to facilitate the discharge of this treated water. Associated with the pipeline will be the construction of attenuation features at the discharge point and potentially along parts of the pipeline route (to reduce the flow and prevent erosion) and the rehabilitation of an artificial wetland on the adjacent property. Please refer to Figure 1.

Prime Resources is conducting the Environmental Authorisation and Water Use Licence Application processes for the proposed project. As the landowner of properties affected by the project, the applicant (NKGM) is required to notify you of the proposed project. Your contact details have also been added to

the Interested and Affected Party (IAP) database. Should you wish to nominate an alternative contact person, or remove your contact details from the IAP database, please advise via email.

Should you wish to discuss the project, or associated regulated processes further, please feel free to contact us at: Applicant Environmental Assessment Practitioner New Kleinfontein Gold Mine / Modder East Operations Prime Resources Jon Hericourt Gené Main Email [email protected] Email [email protected] Tel. 010 594 2871 Tel. 011 447 4888

Yours sincerely

Gené Main Principal Environmental Consultant Prime Resources (Pty) Ltd

P180969 Modder East discharge pipeline project Landowner notification October 2018

Figure 1. Properties affected by the pipeline and associated activities proposed by NKGM

P180969 Modder East discharge pipeline project Landowner notification October 2018 Gené Main

From: Nomusa Zungu Transnet Freight Rail JHB Sent: 12 October 2018 13:46 To: Gené Main Subject: RE: Landowner notification - proposed pipeline on Transnet-owned properties

Importance: High

Good Day Gene

I have acknowledge your e-mail on behalf of Neo, she will get one of her colleague to contact you.

Apology for the late response.

Kind Regards, Nomusa

From: Neo Mosebo Transnet Freight Rail JHB Sent: 12 October 2018 01:43 PM To: Nomusa Zungu Transnet Freight Rail JHB Subject: FW: Landowner notification - proposed pipeline on Transnet-owned properties Importance: High

From: Gené Main [mailto:[email protected]] Sent: 12 October 2018 08:30 AM To: Neo Mosebo Transnet Freight Rail JHB Subject: Landowner notification - proposed pipeline on Transnet-owned properties Importance: High

Dear Neo

Attached please find notification of the proposed project – with activities occurring on properties owned by Transnet Ltd.

Kind Regards

Gené Main Principal Consultant Pr. Sci. Nat. (Env Science)

T: +27 11 447 4888 F: +27 86 604 2219 E: [email protected]

the workshop ▪ 70 - 7th avenue ▪ parktown north ▪ johannesburg ▪ 2193 po box 2316 ▪ parklands ▪ 2121

www.resources.co.za

DISCLAIMER: The information contained in this email and its attachments is both confidential and subject to copyright. If you are not the intended recipient, you are hereby notified not to read, disclose copy or use the contents thereof in any manner whatsoever, but are kindly requested to notify the sender and delete it immediately. This e-mail message does not create any legally binding contract between Transnet SOC LTD and the recipient, unless the contrary is specifically stated. Statements and opinions expressed in e-mails may not represent those of Transnet SOC LTD. While Transnet will take reasonable precautions, it cannot give any guarantee or warrant that this email will be free of virus infections, errors, interception and, therefore, cannot be held liable for any loss or damages incurred by the recipient, as a result of any of the above-mentioned factors.

2 Gené Main

From: Mail Delivery System To: [email protected] Sent: 12 October 2018 08:30 Subject: Relayed: Landowner notification - proposed pipeline on Transnet-owned properties

Delivery to these recipients or groups is complete, but no delivery notification was sent by the destination server:

[email protected]

Subject: Landowner notification - proposed pipeline on Transnet-owned properties

APPENDIX 5.2 IAP DATABASE

Name Department / Community / Property Designation Physical / Postal Address

PO Box 3389, Springs, 1560. Mr Rameshlal Sheodin Ward Councillor (Ward 72) Private Bag X120, Pretoria, 0001

Mr Jamie Moodley Acting HOD: Risk Management

Ms Kgothatso Cokoto Secretary to HOD: Risk Management

Mr Caiphus Chauke EMM Department of Economic Development

Mr Sizwe Cele HOD: Roads and Stormwater

Mr Mduduzi Shabangu City of Ekhurhuleni (COE) HOD: Water and Sanitation

Ms Nthabiseng Sereko Secretary to HOD: Water and Sanitation

Ms Anel Hietbrink

Mr Sifiso Ndwandwe Edenvale Civic Centre, Cnr Department of Environmental Resource Hendrik Potgieter Avenue and Management Van Riebeeck Street, Edenvale, Ms Cecilia Rakgoale 1610

Ms Lilian Kwakwa

Mr Sunday Mabaso Regional Manager Mineralia Building, Cnr De Korte Ms Carol Khanyile Secretary and De Beer Street, BRAAMFONTEIN, 2017 Gauteng Department of Mineral Resources Mr Musa Mangobe

Mr Jimmy Sekgale

Authorities Umnotho house, 56 Eloff Street, Gauteng Department of Agriculture Rural Steven Mukhola Director - Environment Johannesburg, Mr Development (GDARD) 2000

15th Floor, Bothongo Plaza East, Ms Phyllis Maphakela Catchment officer 285 Francis Baard Street, Department of Water and Sanitation Authorities Pretoria, 0001

Mr Bashan Govender Mine Water Management

Delpen Building (Room 211, 2nd floor) Department of Agriculture, Fisheries and Forestry Ms Phyllystas Mmakola Land Use & Soil Management Cnr Annie Botha and Union (DAFF) Street, Riviera, Pretoria, 0084

Ms Cindy Benyane

Gauteng Department of Rural Development and Office of the Regional Land Claims Ms Edith Mokgoto 9 Bailey Lane, Arcadia, Pretoria Land Reform (DRDLR) Commissioner: Gauteng Province

Mr Solomon Maruma

Provincial Heritage Resources Authority Gauteng Surrey House, 35 Rissik Street, Mr Tebogo Molokomme Assistant Director (PHRAG) Johannesburg, 2000

Mr Phindile Mbanjwa HOD

Umnotho House, 56 Eloff Street, Gauteng Department of Economic Development Johannesburg, 2000

Ms Mmatshepo Seabela Personal Assistant to the HOD Authorities

Yoliswa Makhasi HOD Game Building, 5th floor, 64 Gauteng Department of Community Safety Pritchard Street, Johannesburg, 2001

Mr Sipho Maseko Personal Assistant to the HOD

C/oKingsway and van Riebeeck Mr Jan Mitchell Street/PO Box 727, Nigel, Gauteng, 1491

Group Customer Service Division - Gauteng Mr Christo Kotzee Operations Unit - Top Customers - Medium Eskom Segment

Ms Deidre Herbst

Environmental Management Department

Tobile Bokwe

Mr Giepie Hefer ERWAT Welgedacht site

Organs of State of State Organs

Ms Elize Rudolph ERWAT

Mr Mikgane Tsotetsi ERWAT

Mr Craig Hasenjager TCTA - Eastern Basin Treatment Facility

Mr Ezekiel Monyamane Transnet Ltd Senior Manager: Env and Sustainability

Mr Winza Marumo Real Estate Department

Ms Tersia Visser Real Estate Department Ekurhuleni Metropolitan Municipality, Real Estate Department (landowner RE of Cloverfield 75 IR) Ms Levona Appls Real Estate Department

Landowners and occupants Landowners Ekurhuleni Metropolitan Municipality, Real Estate Department (landowner RE of Cloverfield 75 IR)

Ms Michelle Adams Real Estate Department

Ms Maureen Kunene Freight Infrastructure Manager

Ms Nomusa Zungu Transnet Ltd (landowner portions 3 and 6 of Real Estate Management Department Cloverfield 75 IR, and portion 104 of Geduld 123 IR) Ms Neo Mosebu Real Estate Management Department

Mr Nsumbulana Mtsenga Real Estate Management Department

Landowners and occupants Landowners SAPPi South Africa Limited, 108 Ms Renée van Hoeve Regional Environmental Manager Oxford Road, Rosebank

SAPPI Manufacturing (landowners portion 37 of Geduld 123 IR)

SAPPI Southern Africa Pvt Bag Ms Penny Jenkins Senior Legal Council 1001, 4170

Ms Carol le Roux Environmental Specialist PO Box 3246, Springs 1560 Technopack Eastern Cape (Pty) Ltd / Enstra Paper Ms Msimelelo Mnyameni Environmental Specialist

Ms Tersia Visser Springs Municipality - Now City of Ekurhuleni (Real Estate Department) Ms Levona Appls

Eskom Holdings Ltd (Portion 117 of Geduld 123 Adjacent landowners / occupiers landowners Adjacent Mr Amos Mboweni Land Development IR)

S. Mosai Rand Water C.O.O

Philimon Khwinana Blesbokspruit Forum Chairperson Marc de Fontein Rand Water / Blesbokspruit Forum

Wico Swanepoel Chairman

AfriForum Springs

Marie Naude Secretary

APPENDIX 5.3 MEDIA NOTICE

NOTIFICATION OF PUBLIC PARTICIPATION PROCESS New Kleinfontein Goldmine (Pty) Ltd (NKGM) is pursuing an application for an Environmental Authorisation for activities listed in terms of the National Environmental Management Act, 1998 (NEMA) EIA Regulations (GNR982 of 2014). The activities are related to underground treatment of mine water, establishment of a 1.6 km pipeline, and the discharge of treated water to the wetland east of Cowles Dam, Springs. The planned activities will occur within the City of Ekurhuleni in Gauteng Province, approximately 3 km west of Slovo Park and 3.2 km south-east of Eastvale. Affected farm portions include RE and portions 3 and 6 of Cloverfield 75 IR, and portions 37 and 104 of Geduld 123 IR. Environmental Authorisation is required in terms of the National Environmental Management Act (108 of 1998) and the EIA Regulations (2014). Relevant listed activities include 10, 12, 16 and 30 of GNR983 of 2014; activities 6 and 25 of GNR984 of 2014; and activities 12 and 14 of GNR985 of 2014. A Scoping and EIA process will be followed. A Water Use Licence is also required for the above activities. Prime Resources (Pty) Ltd has been appointed as the Environmental Assessment Practitioner to facilitate the above processes. REGISTER AS AN INTERESTED AND AFFECTED PARTY (IAP) Individuals and organisations can register as Interested and Affected Parties (IAPs) by submitting their contact details to Prime Resources. To register, SMS “NKGM pipeline” followed by your name and contact number to 072 288 3818 or email [email protected]. PUBLIC COMMENT INVITED The Scoping Report can be downloaded from http://www.primeresources.co.za/downloads/ during the public commenting period, from 5 November to 7 December 2018. The Scoping Report can also be viewed at the Springs and Bakerton Public Libraries or provided by email upon request. Please forward comments to Prime Resources by 7 December 2018. For more information, please contact Claire Kennedy or Itumeleng Morosele at Prime Resources. (T) 011 447 4888 (F) 086 604 2219 (E) [email protected] (W) www.resources.co.za

APPENDIX 5.4 SITE NOTICE

NOTIFICATION: PUBLIC PARTICIPATION PROCESS FOR NEW KLEINFONTEIN GOLDMINE’S DISCHARGE PIPELINE, SPRINGS, GAUTENG

New Kleinfontein Goldmine (Pty) Ltd (NKGM) is applying for LEGAL PROCESS

Environmental Authorisation for activities listed in terms of the Environmental Authorisation is required for several activities National Environmental Management Act, 1998 (NEMA) EIA listed in terms of the National Environmental Management Act Regulations (GNR982 of 2014). and Regulations. A Scoping and EIA process will be followed.

NKGM is an existing mine located within the City of Ekurhuleni A Water Use Licence (WUL) is also required in terms of Section in the Gauteng Province. The project activities are related to 21 of the National Water Act (1998). The WUL will be applied underground treatment of mine water, establishment of a for online via the eWULAAS system. 1.6 km pipeline, rehabilitation of an artificial wetland, and the Prime Resources (Pty) Ltd has been appointed as the discharge of treated water to the wetland east of Cowles Dam, Environmental Assessment Practitioner to facilitate Springs. The planned activities will occur approximately 3 km these processes. west of Slovo Park and 3.2 km south-east of Eastvale. REGISTER FOR MORE INFORMATION Affected farm portions include RE and portions 3 and 6 of Cloverfield 75 IR, and portions 37 and 104 of Geduld 123 IR. Individuals and organisations can register on the Interested and Affected Party (IAP) database or request additional NKGM proposes to introduce Cold Lime Softening (CLS) information by submitting their contact details to Prime treatment to its underground water. Once treated, water will Resources. Those registered will be notified of further be pumped to surface, and discharge via a pipeline. documentation available for comment. To register SMS “NKGM Attenuation and erosion protection measures will be Pipeline” followed by your name and contact number to 072 constructed at the point of discharge. A surface water facility 288 3818 OR e-mail [email protected]. on site will be used for emergency storage in the event that the treated water quality does not meet the required OPPORTUNITY TO PARTICIPATE specifications. Approximately 22.5 megalitres of water per day The Scoping Report will be available for review and comment will be treated and discharged to the environment. from 5 November to 7 December 2018. It is available at Further treatment of up to 500 m3/day of treated water is the Springs and Brakpan Public Libraries, on the Prime being considered for potable water requirements at the mine. Resources website (www.resources.co.za/downloads/) or a

copy can be requested via email.

Please contact Prime Resources with any questions, concerns or comments by

7 December 2018.

Claire Kennedy /

Itumeleng Morosele

Tel: 011 447 4888

Fax: 011 447 0355

Email: [email protected] (subject line “NKGM Pipeline”)

APPENDIX 5.5 BACKGROUND INFORMATION DOCUMENT

Environmental Authorisation process for the New Kleinfontein Goldmine (Pty) Ltd (NKGM) Discharge pipeline project

Scoping Phase Information Booklet

5 November – 7 December 2018

This document summarises the information currently available. Additional information will be included in the EIA Phase Information Booklet, which is anticipated to be made available in January / February 2019. The full Scoping Report is currently available for public review and comment at the Springs and Bakerton Public Libraries. You are invited to review the Scoping Report and/or this Information Booklet and provide comments. Please submit comments by 7 December 2018. All comments submitted will be included into the final documentation to be sent to the Department of Mineral Resources.

Project description

New Kleinfontein Goldmine (Pty) Ltd (NKGM) (also referred to as Modder East Operations) is an existing mine located on the East Rand of Gauteng, near the town of Modder East / Eastvale. The remaining life of mine is approximately 6 years. NKGM is applying to install an underground water treatment facility, to treat up to 22.5 megalitres of underground water per day, using Cold Lime Softening (CLS) treatment. Water will be treated to a standard considered acceptable for discharge by the Department of Water and Sanitation (DWS). Treated water will be pumped to a surface facility, from which it will be discharged via a pipeline (approximately 1.6 km in length) to the wetland to the east of Cowles Dam. Attenuation facilities and erosion protection measures will be constructed at the discharge point. A surface facility will be available for emergency storage in the event that the treated water quality does not meet the required specifications. A water quality monitoring system will be implemented to contain any non-compliant water within this facility, which will allow for emergency repairs to be made to the water treatment facility underground, while preventing the discharge of non- compliant water to the environment. Further treatment of up to 500 m3/day of treated water is being considered for potable water requirements at the mine. The artificial wetland created as a result of historical discharge will be rehabilitated. The current extent of the surface water associated with the artificial wetland is 13.8 ha.

Please refer to the map on the final page.

Legal process

South Africa’s main environmental law is the National Environmental Management Act, 1998 (NEMA). NEMA contains Regulations which include lists of activities which have been identified as potentially harmful to the environment. These are referred to as “listed activities”. Before undertaking any of these activities, a company is required to apply for Environmental Authorisation (EA) for these activities. Depending on the nature of these activities, a Basic Assessment (BA) or Scoping and Environmental Impact Assessment (EIA) process will be required to support the application for EA.

For the NKGM discharge pipeline project, an EIA process is required, which has two phases - a Scoping phase and an Environmental Impact Assessment (EIA) phase. Each of these phases has a 30 day public participation period. The relevant listed activities associated with the project include:

Notice Activity Applies to: No. No. 10(ii) Construction of a pipeline longer than 1 km Construction of pipeline and erosion protection features 12(ii) within 32 m of a watercourse GNR983 Treatment of water for potable use - more than 100 m3 / 16 day Activity identified in terms of the National Environmental 30 Management: Biodiversity Act, 2004 (NEMBA) 6 Development of facilities requiring a Water Use Licence GNR984 Treatment of water underground - more than 15 000 m3 / 25 day Clearance of more than 300 m2 of indigenous vegetation, 12 within a Critical Biodiversity Area (CBA) or Ecological GNR985 Support Area (ESA) Construction of pipeline and erosion protection features 14 within 32 m of a watercourse in sites listed as CBAs or ESAs

The Department of Mineral Resources (DMR) is considered the Competent Authority for this process because the activities occur within a mining site. All of the information gathered during the Scoping and EIA phases and all comments made by the public are provided to the DMR for their consideration. The DMR will then decide whether to grant Environmental Authorisation. NKGM also requires a Water Use Licence for water uses in terms of Section 21 of the National Water Act, 1998. The following water uses are associated with the pipeline project:

Water Activity Applies to: use Construction of pipeline and attenuation facilities within 500 m of a watercourse Section Activity within 500m Discharge of treated water within 500 m of a 21c&i of a watercourse watercourse Rehabilitation of an artificial wetland Section Discharge of water Discharge of treated water 21f into the environment Section Water and waste Existing dams and stockpile areas will be 21g storage facilities incorporated into the online application

NKGM will apply for a WUL online via the eWULAAS system. The application will consolidate all of the water uses on site, including new water uses (as above) and those that have been included in previous applications.

• Public notified via site notices, media notices WE ARE and background information documents HERE • Registration of IAPs. • Public consultation process 5 November to 7 December 2018 SCOPING • All comments and concerns sent to DMR PHASE

• Registered IAPs notified of the EIA / EMPr and Closure Plans available for review and ENVIRONMENTAL comment IMPACT ASSESSMENT • IAPs send comments to Prime Resources. (EIA) • All comments included in the final report to be sent to the DMR

• IAPs notified of the decision by the DMR DECISION (accept or reject application) MAKING • IAPs informed of Appeals Process

Prime Resources has been appointed as the independent Environmental Assessment Practitioner (EAP) to conduct the regulated environmental processes for the project.

How will the project impact on the environment and the nearby communities?

Specialists have been appointed to undertake baseline and impact assessment studies for the project. The baseline information indicates the current or pre- project conditions. The impact assessment determines the potential impacts on the baseline conditions. Specialists and EAPs have no vested interest in the project proceeding. They are paid for their scientific service only and sign a Declaration of Independence.

At the Scoping Phase, potential impacts are identified but the significance of these impacts is not yet known as the specialist studies have not been

completed. The potential negative impacts of the project are currently being assessed, and include (but are not limited to):

 Dust generated from clearing and construction activities (short term)  Noise generated from construction activities (short term)  Erosion of cleared areas  Compaction of soil due to construction activities  Erosion and contamination of watercourse / wetland as a result of discharging water  Destruction of fauna / flora habitat as a result of construction and operation of the pipeline  Change to flow patterns of the watercourse downstream of the discharge point The assessment of potential impacts will be made available during the EIA phase of the project.

Opportunity to participate

The Scoping Report is available for review at the Springs and Bakerton Public Libraries, for download from the Prime Resources website (www.resources.co.za) or a copy can be requested via email. All comments regarding the proposed project are welcome. In particular we would like to invite comments or suggestions on:  How the project might affect you and your community  Information on any environmental or social features that may have been overlooked  Suggestions to lessen any anticipated environmental or social impacts  Suggestions as to the standard you feel the site should be rehabilitated to  Information about how your land is currently used (e.g. subsistence farming, business, residential) and if you are concerned that this will be impacted by the project

All comments received during the Scoping Phase will be included in the final Scoping Report to be submitted to the DMR, and within the Comments and Responses Report (CRR) in the EIA.

Register as an Interested and Affected Party (IAP) If you would like to register as an IAP, please submit your contact details to Prime Resources via SMS (to 072 288 3818) or email ([email protected]). Please include the subject line “NKGM pipeline” and indicate your interest if applicable (e.g. resident of Eastvale or member of NGO group). Submit comments or concerns The Scoping Phase public consultation process runs from 5 November to 7 December 2018. Please ensure that you submit your comments or concerns to Prime Resources by 7 December 2018.  Email ([email protected])  Fax (+27 86 604 2219)  Telephone (+27 11 447 4888)

APPENDIX 6 WETLAND ASSESSMENT (2018)

Wetland Assessment – Gold One: Modder East

GOLD ONE: MODDER EAST WETLAND BASELINE & IMPACT ASSESSMENT

Compiled By:

Natural Scientific Services CC 64A Coleraine Drive River Club Ext. 7, Sandton 2191, Johannesburg Tel: (011) 787-7400 Fax: (011) 784-7599

COPYRIGHT WARNING With very few exceptions the copyright of all text and presented information is the exclusive property of Natural Scientific Services. It is a criminal offence to reproduce and/or use, without written consent, any information, technical procedure and/or technique contained in this document. Criminal and civil proceedings will be taken as a matter of strict routine against any person and/or institution infringing the copyright of Natural Scientific Services.

Ref No: 2455 & 2462 Date: September 2018

Natural Scientific Services CC ii Wetland Assessment – Gold One: Modder East

DECLARATION

I, Caroline Lötter, in my capacity as a specialist consultant, hereby declare that I - . Act as an independent consultant; . Do not have any financial interest in the undertaking of the activity, other than remuneration for the work performed in terms of the National Environmental Management Act (NEMA; Act 107 of 1998); . Have and will not have vested interest in the proposed activity proceeding; . Have no, and will not engage in, conflicting interests in the undertaking of the activity; . Undertake to disclose, to the competent authority, any material information that has or may have the potential to influence the decision of the competent authority or the objectivity of any report, plan or document required in terms of NEMA; . Will provide the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not; . As a registered member of the South African Council for Natural Scientific Professions, will undertake my profession in accordance with the Code of Conduct of the Council, as well as any other societies to which I am a member; . Based on information provided to me by the project proponent and in addition to information obtained during the course of this study, have presented the results and conclusion within the associated document to the best of my professional ability; and . Reserve the right to modify aspects pertaining to the present investigation should additional information become available through ongoing research and/or further work in this field.

Dr Caroline Lötter Pr.Nat.Sci. September 2018 SACNASP reg. no. 400182/09 Date (Zoological Science)

Natural Scientific Services CC iii Wetland Assessment – Gold One: Modder East

TABLE OF CONTENTS

1. Introduction ...... 1

2. NSS Team ...... 3

3. Applicable Legislation, Guidelines & Plans ...... 3 3.1. International Agreements, Guidelines & Plans ...... 4 3.2. National Legislation, Guidelines & Plans ...... 4 3.3. Gauteng Legislation, Guidelines & Plans ...... 5

4. Study Area Description ...... 5 4.1. Location & Land-use ...... 5 4.2. Climate ...... 7 4.3. Geology & Soils ...... 7 4.4. Vegetation ...... 10 4.5. Hydrology ...... 12 4.6. Key Conservation Considerations ...... 15

5. Methodology ...... 23 5.1. Wetland Extent ...... 23 5.2. Wetland Classification ...... 24 5.3. Wetland Present Ecological State ...... 26 5.4. Wetland Ecosystem Services ...... 31 5.5. Wetland Ecological Importance & Sensitivity ...... 32 5.6. Wetland Buffer Requirements ...... 33 5.7. Limitations & Assumptions ...... 33

6. Results ...... 34 6.1. Wetland Classification & Extent ...... 34 6.2. Wetland Present Ecological State ...... 39 6.3. Wetland Ecosystem Services ...... 55 6.4. Wetland Ecological Importance & Sensitivity ...... 56 6.5. Summary ...... 57

7. Impact Assessment ...... 63 7.1. Historical Impacts ...... 63 7.2. Current Impacts ...... 63 7.3. Future Impacts ...... 66

8. Way Forward ...... 73

9. References ...... 79

Natural Scientific Services CC iv Wetland Assessment – Gold One: Modder East

LIST OF TABLES

Table 2-1 NSS team with associated areas of specialisation ...... 3 Table 4-1 Regional lithostratigraphic units and principal rock types ...... 7 Table 4-2 Regional soil forms (GAPA 2002) ...... 7 Table 4-3 Dominant flora in Soweto Highveld Grassland (Mucina & Rutherford 2006) ...... 10 Table 4-4 Dominant flora in Eastern Temperate Freshwater Wetlands (Mucina & Rutherford 2006)...... 11 Table 4-5 Summary of the Blesbokspruit’s eco-status and impacts (DWS 2014) ..... 15 Table 5-1 Impact scores and Present Ecological State categories ...... 27 Table 5-2 Trajectory of change classes, scores and symbols ...... 27 Table 5-3 In-stream Water Quality Guidelines for the Blesbokspruit and TWQR Guidelines for aquatic ecosystems ...... 30 Table 5-4 Ecosystem services assessed using the WET-EcoServices tool (Kotze et al. 2008) ...... 31 Table 5-5 EIS categories (interpretation of median scores for biotic and habitat determinants) ...... 32 Table 6-1 Average water quality parameter values for each selected sampling site . 40 Table 6-2 Ecological Importance and Sensitivity of Cowle’s Stream ...... 56 Table 6-3 Summary baseline description of the artificial wetland ...... 58 Table 6-4 Summary baseline description of Cowle’s Stream ...... 60 Table 6-2 Significance rating of future potential impacts from the proposed pipeline, with and without mitigation ...... 74

LIST OF FIGURES

Figure 1-1 Location of the NSS Study Area and the Gold One proposed discharge pipeline route ...... 2 Figure 4-1 Aerial imagery of the Study Area from the 1960s ...... 6 Figure 4-2 Monthly total rainfall (www.weathersa.co.za) and average ambient temperatures (www.weatherunderground.com; www.accuweather.com) measured in Springs or *Johannesburg since January 2017 ...... 8 Figure 4-3 Regional land and vegetation types ...... 9 Figure 4-4 Eco-Region and quaternary catchment wherein the Study Area is situated ...... 13 Figure 4-5 Extent of wetlands in the region, as determined during the Ekurhuleni Metropolitan Municipality Wetland audit ...... 14 Figure 4-6 Blesbokspruit Ramsar wetland and IBA ...... 17 Figure 4-7 Extent of Freshwater Ecosystem Priority Areas in the region ...... 19 Figure 4-8 Location of the Study Area in the Bushveld-Bankenveld Priority Area and Blesbokspruit Highveld Grassland Threatened Ecosystem ...... 21

Natural Scientific Services CC v Wetland Assessment – Gold One: Modder East

Figure 4-9 Study Area in relation to the current Gauteng C-Plan ...... 22 Figure 5-1 Terrain units typically found in land type Ba1 (AGIS 2010) ...... 23 Figure 5-2 Primary HGM units with their dominant water inputs, throughputs and outputs (Ollis et al. 2013) ...... 25 Figure 5-3 Location of the selected water quality sampling sites ...... 29 Figure 6-1 NSS “wetland” sampling points ...... 35 Figure 6-2 Extent of the artificial wetland in the Study Area ...... 36 Figure 6-3 Floral communities in the Study Area ...... 37 Figure 6-4 Dominant flora in the Study Area ...... 38 Figure 6-5 pH during and before water treatment ...... 43 Figure 6-6 Electrical conductivity during and before water treatment ...... 43 Figure 6-7 Calcium levels during and before water treatment ...... 43 Figure 6-8 Chloride levels during and before water treatment ...... 43 Figure 6-9 Fluoride levels before water treatment ...... 44 Figure 6-10 Magnesium levels during and before water treatment ...... 44 Figure 6-11 Sodium levels during and before water treatment ...... 44 Figure 6-12 Nitrate levels during and before water treatment ...... 44 Figure 6-13 Precipitation of salt in the Study Area in July 2015 ...... 45 Figure 6-14 Precipitation of salt in the Study Area in August 2018 ...... 46 Figure 6-15 Sulphate levels during and before water treatment ...... 48 Figure 6-16 Aluminium levels during and before water treatment ...... 48 Figure 6-17 Beryllium levels during and before water treatment ...... 48 Figure 6-18 Chromium levels during and before water treatment ...... 48 Figure 6-19 Copper levels during and before water treatment...... 49 Figure 6-20 Iron levels during and before water treatment ...... 49 Figure 6-21 Manganese levels during and before water treatment ...... 49 Figure 6-22 Nickel levels during and before water treatment ...... 49 Figure 6-23 Lead levels during and before water treatment ...... 50 Figure 6-24 Zinc levels during and before water treatment ...... 50 Figure 6-25 Cyanide levels before water treatment ...... 50 Figure 6-26 Growth of algae in the artificial wetland due to organic enrichment ...... 51 Figure 6-27 Ammonium levels during and before water treatment ...... 52 Figure 6-28 Chemical oxygen demand before water treatment ...... 52 Figure 6-29 Ortho-phosphate levels before water treatment ...... 52 Figure 6-30 Suspended solid levels before water treatment ...... 52 Figure 6-31 Dead birds and a Water Mongoose found during NSS surveys in the Study Area ...... 54 Figure 7-1 Examples of current disturbances in the Study Area ...... 65

Natural Scientific Services CC vi Wetland Assessment – Gold One: Modder East

LIST OF ACRONYMS & ABBREVIATIONS

ACRONYM / DESCRIPTION ABBREVIATION AGIS Agricultural Geographic Information System Al Aluminium Be Beryllium BOD Biological oxygen demand CBA 2 Important Critical Biodiversity Area CI Conservation Important (i.e. threatened, Protected, rare or otherwise conservation important) Cl- Chloride CN- Cyanide COD Chemical oxygen demand CoJ City of Johannesburg C-Plan Conservation Plan Cr Chromium CR Critically Endangered Cu Copper DEA Department of Environmental Affairs DO Dissolved oxygen DWA Department of Water Affairs (previously DWAF) DWAF Department of Water Affairs and Forestry DWS Department of Water and Sanitation (previously DWA) EC Electrical conductivity EI Ecological Importance EIS Ecological Importance and Sensitivity EMC Ecological Management Class EN Endangered ES Ecological Sensitivity ESA Ecological Support Areas F Fluoride Fe Iron FEPA Freshwater Ecosystem Priority Area

FeS2 Pyrite GDARD Gauteng Department of Agriculture and Rural Development GG Government Gazette GN Government Notice Gold One Gold One Modder East Mine Hg Mercury HGM Hydro-geomorphic IBA Important Bird Area Mg2+ Magnesium Mn Manganese MW Mine Water Na+ Sodium

Natural Scientific Services CC vii Wetland Assessment – Gold One: Modder East

ACRONYM / DESCRIPTION ABBREVIATION NBA National Biodiversity Assessment NEM:BA National Environmental Management: Biodiversity Act (Act 10 of 2004) NEPAD New Partnership for Africa’s Development NFEPA National Freshwater Ecosystem Priority Areas project

NH3 Ammonia + NH4 Ammonium Ni Nickel - NO3 Nitrate NSS Natural Scientific Services CC NT Near Threatened NWA National Water Act (Act 36 of 1998) OA Oxygen absorbed Pb Lead PES Present Ecological Status 3- PO4 Ortho-phosphate Pr.Nat.Sci. Professional Natural Scientist (registered with the South African Council for Natural Scientific Professions) QDS Quarter degree square SABAP 2 Second Southern African Bird Atlas Project SANBI South African National Biodiversity Institute SANS 241 South African National Standard 241 SAPPI South African Pulp and Paper Industries Ltd SAS Scientific Aquatic Services Sb Stibium SASS5 South African Scoring System Version 5 for aquatic macro-invertebrates 2- SO4 Sulphate SS Suspended solids SW Surface Water TDS Total dissolved soilds TPH Total petroleum hydrocarbons TWQR Target Water Quality Range VU Vulnerable WMA Water Management Area WWT Waste water treatment Zn Zinc

Natural Scientific Services CC viii Wetland Assessment – Gold One: Modder East

1. Introduction

On the Witwatersrand, gold and uranium mining have resulted in significant wetland destruction and contamination. Associated negative impacts on biodiversity, soil, ground water and air quality include, inter alia: acid mine drainage; increased salinity; high accumulations of heavy metals, radio-nuclides and other contaminants; and wetland creation and hydrological alteration from discharges and increased flow (Coetzee 2003; GDARD 2008). Protection of these wetlands and associated biodiversity from further degradation is, therefore, of vital importance in Gauteng Province.

In South Africa, all wetlands are protected under the National Water Act (Act 36 of 1998) which defines a wetland as: “land which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which in normal circumstances supports or would support vegetation typically adapted to life in saturated soils.” Although the above definition does not specifically include artificially created wetlands, wetlands are defined under the Ramsar Convention (Iran, 1971) as: "areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt..."

Gold One Modder East Mine (Gold One) has been discharging effluent for a number of years from the Mine’s evaporation dams, along a trench into a nearby un-named tributary of the Blesbokspruit (hereon referred to as Cowle’s Stream). The discharge has created an artificial wetland, and Cowle’s Stream feeds into the Critically Endangered Blesbokspruit Ramsar wetland and International Bird Area (IBA). In 2015, 10-15ML of effluent was being discharged per day, and Natural Scientific Services CC (NSS) was appointed to provide an assessment and management plan for the artificial wetland in the Study Area shown in Figure 1-1. By 2017 the discharge volume had reached 18–22ML per day, which increased the extent of the artificial wetland, and which required the initial NSS (2015) wetland assessment and management plan to be updated. Based in part on management recommendations made by NSS (2015 and 2017), Gold One recently started a pilot project in treating its ground water with lime, and proposes to install a pipeline to transfer the treated discharge water from the Mine directly to Cowle’s Stream (Figure 1-1). Presented in this 2018 report is the latest updated baseline description of the artificial wetland, together with an impact assessment for the proposed pipeline.

Natural Scientific Services CC 1 Wetland Assessment – Gold One: Modder East

Figure 1-1 Location of the NSS Study Area and the Gold One proposed discharge pipeline route

Natural Scientific Services CC 2 Wetland Assessment – Gold One: Modder East

2. NSS Team

All aspects of this assessment were conducted and managed by NSS. The NSS team (Table 2-1) has extensive experience with baseline and impact assessments for flora, fauna, wetlands and aquatic ecology. The team has also been involved in the management of Environmental Impact Assessments, Environmental Management Programme Reports, Strategic Management Plans and Environmental Management Plans for the conservation, mining, waste, commercial, industrial and conservation sectors.

The followings professional registrations and accreditations apply to NSS: Senior NSS personnel are registered Professional Natural Scientists (Pr.Nat.Sci.) in the ecological, environmental and zoological fields. NSS wetland specialists represent competent wetland delineators. The NSS aquatics team is accredited with the Department of Water and Sanitation (DWS) to perform the SASS5 macro-invertebrate monitoring method.

Table 2-1 NSS team with associated areas of specialisation ROLE NAME QUALIFICATIONS Flora, Project Susan Abell M.Sc. Resource Conservation Biology1 Management & Review Pr.Nat.Sci. – Ecology & Environmental Science NSS Wetland Kathy Taggart M.Sc. Resource Conservation Biology1 Specialist (Initial 2 Pr.Nat.Sci. – Ecology & Environmental Science reports) NSS Wetland Tyron Clark M.Sc. – Zoology1– in progress Specialist & Fauna Fauna & 2018 Dr Caroline Lötter PhD Zoology2 Report Update Pr.Nat.Sci. – Zoology GIS Mapping & Field Tim Blignaut B.Sc. Hons – Geography3 Assistant 1University of the Witwatersrand; 2University of Pretoria; 3University of Johannesburg

3. Applicable Legislation, Guidelines & Plans

Listed next are international, national and provincial legislation, guidelines and spatial biodiversity conservation plans of direct or indirect relevance to wetlands. Although the list is extensive, additional legislation, guidelines and plans, which are not mentioned, may also apply.

Natural Scientific Services CC 3 Wetland Assessment – Gold One: Modder East

3.1. International Agreements, Guidelines & Plans Convention on International Trade in Endangered Species of Wild Fauna and Flora. Ramsar Convention on Wetlands of International Importance, especially as Waterfowl Habitat. Stockholm Convention Concerning the Protection of World Cultural and Natural Heritage. Bonn Convention on the Conservation of Migratory Species of Wild Animals. Convention on Biological Diversity. Agenda 21. International Finance Corporation Performance Standard 6: Biodiversity Conservation and Sustainable Natural Resource Management. Johannesburg Declaration and Plan of Implementation. Action Plan of the Environmental Initiative of NEPAD. Good practice guidance for mining and biodiversity. Paris Agreement to reduce climate change, and the Paris Pledge for Action. Important Bird Areas.

3.2. National Legislation, Guidelines & Plans Conservation of Agricultural Resources Act (Act 43 of 1983). Constitution of the Republic of South Africa (Act 108 of 1996). South African Water Quality Guidelines. Water Services Act (Act 108 of 1997). White Paper on Environmental Management Policy for South Africa. National Water Act (Act 36 of 1998). National Veld and Forest Fire Act (Act 101 of 1998). National Environmental Management Act (Act 107 of 1998). National Heritage Resources Act (Act 25 of 1999). National Mineral and Petroleum Resources Development Act (Act 28 of 2002). National Environmental Management: Biodiversity Act (NEM:BA; Act 10 of 2004): National list of Ecosystems Threatened and in need of Protection (GG 34809, GN 1002, 9 December 2011). Alien and Invasive Species Regulations (GG 37885, 1 August 2014). Threatened or Protected Species Regulations (GG 587, GN 3860031, 31 March 2015). National Biodiversity Strategy and Action Plan (Driver et al. 2004). National Environmental Management: Air Quality Act (Act 39 of 2004). Strategic review of the status of biodiversity management in the South African mining industry (Kuntonen-van ‘t Riet 2007). National Environmental Management: Waste Act (Act 59 of 2008). National Aquatic Ecosystem Health Monitoring Program and River Eco-status Monitoring Programme (DWAF 2008).

Natural Scientific Services CC 4 Wetland Assessment – Gold One: Modder East

National Freshwater Ecosystem Priority Areas project (Driver et al. 2011). National Spatial Biodiversity Assessment (DEA & SANBI 2012) including Terrestrial Priority Areas and Threatened Ecosystems (Jonas et al. 2012). Grasslands Programme of the South African National Biodiversity Institute (SANBI 2013). Mining and Biodiversity Guideline (DEA et al. 2013). National Water Resource Strategy 2 (DWA 2013). Draft National Biodiversity Offset Policy (GG 40733, GN 276, 31 March 2017).

3.3. Gauteng Legislation, Guidelines & Plans Gauteng Nature Conservation Ordinance (Ordinance 12 of 1983), amended by Gauteng General Law Amendment Act (Act 4 of 2005). City of Joburg Biodiversity Strategy and Action Plan 2015 (CoJ 2009). Gauteng Conservation Plan (C-Plan). Version 3.3 (GDARD 2011). GDARD Requirements for Biodiversity Assessments. Version 3 (GDARD 2014). Ekurhuleni Metropolitan Municipality Wetland Inventory Report (Naledzi 2007). Draft Gauteng Nature Conservation Bill, 2014.

4. Study Area Description

4.1. Location & Land-use The Gold One Modder East Mine is situated near Springs, Gauteng (Figure 1-1). The Gold One artificial wetland, which is the subject of this assessment, is situated south- east of the Mine’s Return Water Dam, and approximately 1.5km to the west and upstream of the Critically Endangered Blesbokspruit Ramsar wetland and IBA.

In addition to the discharge of Mine effluent, which has created the artificial wetland, and which is entering downstream water resources, the Study Area was historically disturbed by agriculture, mining, roads, and railway and power lines (Figure 4-1). The Study Area is also currently being disturbed by uncontrolled livestock activity, rubbish dumping, infilling, excavations, sewage overflow and invasive alien flora.

Natural Scientific Services CC 5 Wetland Assessment – Gold One: Modder East

Figure 4-1 Aerial imagery of the Study Area from the 1960s

Natural Scientific Services CC 6 Wetland Assessment – Gold One: Modder East

4.2. Climate The Study Area is situated in southern Africa’s summer rainfall region. Mean annual precipitation is 461mm, and ambient temperature ranges on average from a minimum of 4oC in July to a maximum of 28oC in February. Monthly total rainfall and average daily temperatures measured in Springs since January 2017 are shown in Figure 4-2. During the 12 month period preceding the August 2018 field survey for the present assessment, the region received a slightly above-average amount of 552mm rainfall. This is in contrast to the field survey for the NSS (2017) updated assessment, which was preceded by limited, below average rainfall, and when the observed excessive surface water in the Study Area could not be attributed to rainfall.

4.3. Geology & Soils As indicated in Figure 4-3, the Study Area falls within the Ba1 land type. Regional topography is typical of the East Rand and is mostly gently undulating in nature, with drainage typically occurring in broad valley bottoms. The region’s geology comprises the Vryheid, Dwyka and Malmani subgroups. The principle rock types for each subgroup are listed in Table 4-1. The regional Hutton (Hu6) and Avalon (Av9) soil forms (GAPA 2002) have limited depth, and are described in more detail in Table 4-2.

Table 4-1 Regional lithostratigraphic units and principal rock types LITHOSTRATIGRAPHIC UNITS PRINCIPAL ROCK TYPES Dwyka: Tillite with subordinate sandstone, mudstone, shale; intruded by dolerite dykes and sheets. Malmani Subgroup: Dolomite, chert, subordinate quartzite, conglomerate, shale; Assen and Black Reef Formations: diabase and syenite dykes and sills. Vryheid: Arenite, shale and coal.

Table 4-2 Regional soil forms (GAPA 2002) SOIL- DOMINANT DESCRIPTION OF SOIL GROUP SLOPE SLOPE DOMINANT SOILS UNIT CLASS (%) Moderately well-drained, yellow- sAv9 0-5 Shallow (300 - 500 mm), brown, apedal on soft plinthite soils of dystrophic to mesotrophic the Avalon (Av) form, usually loam in association with overlying hydromorphic, weathering similar soils of the rock or unconsolidated materials. Glencoe form and other Soils are wet in the deep subsoil for shallow, brown, coarse short periods during the year. sand on weathering rock of the Glenrosa form. Well-drained, red, apedal soils of the mHu6 0-5 Moderately deep (500 - Hutton (Hu) form overlying 1000 mm), dystrophic to weathering and hard rock and various mesotrophic loam. other unconsolidated materials.

Natural Scientific Services CC 7 Wetland Assessment – Gold One: Modder East

180 30

160 C) 25 ° 140 120 20 100 15 80

60 10 Total rainfall Totalrainfall (mm) 40 5

20 Average ambienttemperature (

0 0

July

May

June

April

*July

*May

*June

*April

March

August

*March

October

*August

*January *January

February

*February

*December

September *November 2017 2018 Year and month

Rainfall Max Temperature Min Temperature Mean Temperature

Figure 4-2 Monthly total rainfall (www.weathersa.co.za) and average ambient temperatures (www.weatherunderground.com; www.accuweather.com) measured in Springs or *Johannesburg since January 2017

Natural Scientific Services CC 8 Wetland Assessment – Gold One: Modder East

Figure 4-3 Regional land and vegetation types

Natural Scientific Services CC 9 Wetland Assessment – Gold One: Modder East

4.4. Vegetation The Study Area is situated in the poorly conserved and Endangered Soweto Highveld Grassland vegetation type (Mucina & Rutherford 2006; Figure 4-3). This short to medium-high grassland is comprised almost entirely of Themeda triandra (Red Grass). Other dominant flora are listed in Table 4-3, and include grass species such as Elionurus muticus (Wire Grass), Eragrostis racemosa (Narrow Heart Love Grass), Heteropogon contortus (Spear Grass) and Tristachya leucothrix (Trident Grass). Grass cover is mostly continuous and is interrupted only by scattered wetlands; pans; narrow stream alluvia and occasional rocky outcrops.

However, vegetation in the Study Area has been greatly disturbed and transformed, and Soweto Highveld Grassland is absent. During the NSS 2015 field survey, very limited flora indicative of wetland conditions were observed. During the NSS 2017 field survey, scattered patches with wetland plant species such as Juncus and Phragmites were seen, which appeared to be encroaching in a northerly and easterly direction from Cowle’s Dam.

It was noticed, during the brief survey of the Study Area in August 2018, that these species had further encroached into the surrounding areas specifically where long term pooling of surface water has occurred.

Table 4-3 Dominant flora in Soweto Highveld Grassland (Mucina & Rutherford 2006) GROWTH FORM DOMINANT SPECIES Low Shrubs: Anthospermum hispidulum, Anthospermum rigidum subsp. pumilum, Berkheya annectens, Felicia muricata, Ziziphus zeyheriana Herbaceous Rhynchosia totta. Climber: Graminoids: Andropogon appendiculatus, Brachiaria serrata, Cymbopogon pospischilii, Cynodon dactylon, Elionurus muticus, Eragrostis capensis, Eragrostis chloromelas, Eragrostis curvula, Eragrostis plana, Eragrostis planiculmis, Eragrostis racemosa, Heteropogon contortus, Hyparrhenia hirta, Setaria nigrirostis, Setaria sphacelata, Themeda triandra, Tristachya leucothrix Herbs: Hermannia depressa, Acalypha angustata, Berkheya setifera, Dicoma anomala, Euryops gilfillanii, Geigeria aspera var. aspera, Graderia subintegra, Haplocarpha scaposa, Helichrysum micronifolium, Helichrysum nudifolium var. nudifolium, Helichrysum rugulosum, Hibiscus pusillus, Justicia anagalloides, Lippia scaberrima, Rhynchosia effusa, Schistostephium crataegifolium, Selago densiflora, Senecio coronatus, Vernonia oligocephala, Wahlenbergia undulata. Geophytic Herbs: Haemanthus humilis subsp. hirsutus, Haemanthus montanus *Species in green were identified during NSS field surveys

Natural Scientific Services CC 10 Wetland Assessment – Gold One: Modder East

The nearby Blesbokspruit represents an Endangered Eastern Temperate Freshwater Wetland (Mucina & Rutherford 2006). These wetlands occur in flat landscapes or shallow depressions, and represent temporary water bodies supporting zoned systems of aquatic and hydrophilous1 vegetation of temporarily flooded grasslands and ephemeral herblands2. The dominant floral species in these wetlands are listed in Table 4-4. Endemic floral taxa include the geophytic herbs Disa zuluensis, Kniphofia flammula and Nerine playpetala and the succulent herb Crassula tuberella. A biogeographically important taxon is the herb Rorippa fluviatilis var. caledonica. About 5% of Eastern Temperate Freshwater Wetlands are statutorily conserved and some are protected in private nature reserves. Approximately 15% have been transformed by cultivation, urbanization and plantations (Mucina & Rutherford 2006).

Table 4-4 Dominant flora in Eastern Temperate Freshwater Wetlands (Mucina & Rutherford 2006) GROWTH FORM DOMINANT SPECIES

Marshes: Cyperus congestus Graminoids: Agrostis lachnantha, Carex acutiformis, Eleocharis paulstris, Eragrostis plana, Eragrostis planiculmis, Fuirena pubescens, Helictotrichon turgidulum, Hemarthia altissma, Imperata cylindrica, Leersia hexandra, Paspalum dilatatum, Paspalum urvillei, Pennisetum thunbergii, Schoenoplectus decipiens, Scleria dieterlenii, Setaria sphacelata, Andropogon appendiculatus, Andropogon eucomus, Aristida aequiglumis, Ascolepis capensis, Carex austro-africana, Carex schlechteri, Cyperus cyperoides, Cyperus distans, Cyperus longus, Cyerus marginatus, Echinochloa holubii, Eragrostis micrantha, Ficinia acuminata, Fimbristylis complanata, Fimbristylis ferruginea, Hyparrhenia dregeana, Hyparrhenia quarrei, Ischaemum fasciculatum, Kyllinga erecta, Panicum schinzii, Pennisetum sphacelatum, Pycreus macranthus, Pycreus nitidus, Setaria pallide-fusca, Xyris gerrardii Herbs: Centella asiatica, Ranunculus multifidus, Berkheya radula, Berkheya speciosa, Berula erecta subsp. thunbergii, Centella coriacea, Chironia palustris, Equisetum ramosissimum, Falckia oblonga, Haplocarpha lyrata, Helichrysum difficile, Helichrysum dregeanum, Helichrysum mundtii, Hydrocotyle sibthorpioides, Hydrocotyle verticillata, Lindernia conferta, Lobelia angolensis, Lobelia flaccida, Mentha aquatica, Monopsis decipiens, Pulicaria scabra, Pycnostachys reticulata, Rorippa fluviatilis var. fluviatilis, Rumex lanceolatus, Senecio inornatus, Senecio microglossus, Sium repandum, Thelypteris confluens, Wahlenbergia banksiana Geophytic herbs: Cordylogyne globosa, Crinum bulbispermum, Gladiolus papilio, Kniphofia ensifolia, Kniphofia fluviatilis, Kniphofia linearifolia, Neobolusia tysonii, Nerine gibsonii (only in Eastern Cape), Satyrium hallackii subsp. hallackii Reed & sedge beds: Megagraminoids: Phragmites australis, Schoenoplectus corymbosus, Typha capensis, Cyperus immensus Graminoid: Carex cernua Water bodies: Aquatic herbs: Aponogeton junceus, Ceratophyllum demersum, Lagarosiphon major, Lagarosiphon muscoides, Marsilea capensis, Myriophyllum spicatum, Nymphaea lotus, Nymphaea nouchali var. caerulea, Nymphoides thunbergiana, Potamogeton thunbergii Carnivorous herb: Utricularia inflexa Herb: Marsilea farinosa subsp. farinosa *Species in green were identified during NSS field surveys

1 Hydrophilous = pollinated by the agency of water 2 Herblands = lands on which herbaceous species dominate the vegetation A herbaceous plant is a plant that has leaves and stems that die down at the end of the growing season to the soil level and they have no persistent woody stem above ground. Natural Scientific Services CC 11 Wetland Assessment – Gold One: Modder East

4.5. Hydrology The Study Area is situated in the Upper Vaal Water Management Area (WMA) 8, the Level 1 (Highveld) Ecoregion 11, Quaternary Catchment C21D (Figure 4-4), and the Blesbokspruit / Suikerbosrand sub-quaternary catchment. The sub-catchment incorporates a large area of the East Rand including Benoni and Brakpan. The Gold One artificial wetland drains into wetland habitat associated with Cowle’s Stream. Approximately 1.7km further downstream, Cowle’s Stream drains into the Blesbokspruit. The Blesbokspruit merges with the Suikerbosrand River, prior to merging with the Vaal River at the Vaal River Barrage approximately 70km south-east of the Study Area. The Blesbokspruit catchment falls within the jurisdiction of Rand Water, which also manages the water quality of the Vaal River Barrage Reservoir.

Large quantities of urban and industrial effluent, together with urban wash-off and mine pumpage, have had a major impact on water quality in some (e.g. the Waterval, Blesbokspruit, Natalspruit and Klip River) tributaries within the north-western part of the WMA. Water quality problems in the sub-catchment relate to salinity, organic loads, eutrophication and public health. The salinity problems are largely related to mining and other industrial impacts such as dewatering and contaminated discharge and seepage. A number of waste water treatment (WWT) plants, which discharge into the sub-catchment, can also contribute to salinity levels if industrial effluent is received. The WWT discharges add organic nutrient loads, which are often linked to local public health issues. Storm water run-off from dense regional settlements also adds nutrients and sediment (DWAF 2004). Low dissolved oxygen levels and elevated Escherichia coli and phosphate values in the Blesbokspruit regularly exceed Rand Water guideline values. On average, E. coli values exceed 1000 counts / 100ml, which far exceeds the ‘High risk of gastrointestinal disorders value’ of >400 counts/100ml. Predicted symptoms of E. coli exposure are skin irritations, infections and intestinal disorders (Randwater 2015).

Indeed, water quality and flow patterns in the Blesbokspruit are dominated by point discharges. There is water flowing across a number of outcrops in the river bed, and these outcrops are often holed and allow water into mine workings. The water is then pumped from the workings during dewatering. The inflow of additional water increases pumping costs, and the quality of the water entering the workings deteriorates before it is returned to the river. The additional water and nutrients have led to the development of extensive wetlands, shown in Figure 4-7 as determined during Ekurhuleni Metropolitan Municipality Wetland audit (Naledzi 2007). These have reduced the capacity of the river system to convey water and increased the level of sedimentation. The excess water that continuously flows in the Blesbokspruit was cited as an issue by the Blesbokspruit Catchment Forum. In addition, local flooding problems are experienced in the Blesbokspruit and Klip River (DWAF 2004).

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Figure 4-4 Eco-Region and quaternary catchment wherein the Study Area is situated

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Figure 4-5 Extent of wetlands in the region, as determined during the Ekurhuleni Metropolitan Municipality Wetland audit

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The Blesbokspruit’s reported Present Ecological State (PES), Ecological Importance, Ecological Sensitivity and main impacts are presented in Table 4-5. According to DWS (2014), the PES of the Blesbokspruit is Largely Modified (i.e. a D ecological category). The Blesbokspruit has Low Ecological Importance because many of its associated seepage wetlands are artificial. No protected or special species, and no sensitive fish or macro-invertebrates remain in the Blesbokspruit due to the deterioration in water quality from mining, industrial, urban and rural effluent. Due to its moderate size, its morphology and geomorphic habitat units, the Blesbokspruit has Moderate Ecological Sensitivity to modified flow conditions and water level changes.

Table 4-5 Summary of the Blesbokspruit’s eco-status and impacts (DWS 2014) PRESENT QUATERNARY WATER ECOLOGICAL ECOLOGICAL ECOLOGICAL CURRENT IMPACTS CATCHMENT RESOURCE IMPORTANCE SENSITIVITY STATE Daveyton, road crossings, Welgedacht & C21D Blesbokspruit D LOW MODERATE Daveyton Waste Water Treatment works, Holfontein toxic waste dump

4.6. Key Conservation Considerations

4.6.1 Blesbokspruit Ramsar Wetland The Blesbokspruit downstream and south-east of the Study Area (Figure 4-6) is recognised under the Ramsar Convention (on wetlands of international importance, especially as waterfowl habitat) as internationally important. The Ramsar Convention (Iran, 1971) is an intergovernmental treaty that embodies the commitments of its member countries to maintain the ecological character of their Wetlands of International Importance but also to plan for the "wise use", or sustainable use, of all of the wetlands in their territories.

Prior to the 1930s, the Blesbokspruit was recognised as a narrow, meandering, non-perennial Highveld stream with associated hydromorphic grassland. Since then, the area became exposed to development including gold mining. Roads and embankments transecting the system affected flow, and caused flooding of upstream areas, which slowly became colonized by reeds such as Typha and Phragmites. By October 1986, when it was declared a Ramsar Site, the Blesbokspruit had been transformed into a permanent wetland system, providing habitat for a diverse array of avifauna (supporting up to 20 000 water birds in the past; www.birdlife.org.za).

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In 1996, the Blesbokspruit was placed on the Montreux Record due to high salt levels and a change in flow, which resulted in a loss of the system’s ecological character (Ambani 2013). This meant that the Blesbokspruit was at risk of losing its Ramsar status if management action was not taken to improve the surface water quality of the wetland (Macfarlane & Muller 2011; Ambani 2013). Closure of the pulping plant at Sappi Enstra paper mill, and the cessation of mining operations by Grootvlei Mine in 2011 fortunately resulted in some reduction in pollutants being discharged into the Blesbokspruit (DWA 2013; Ambani & Annegarn 2015).

The Blesbokspruit wetland fits the following Ramsar criteria: 1c: Wetland is a particularly good representative example of a wetland which plays a substantial hydrological, biological or ecological role in the natural functioning of a major river basin; 2a: It supports an appreciable assemblage of rare, Vulnerable or Endangered species or subspecies of plant or animal, or an appreciable number of individuals of any one or more of these species; 3b: It regularly supports substantial numbers of individuals from particular groups of waterfowl, indicative of wetland values, productivity or diversity

The Blesbokspruit’s peri-urban location close to schools and universities also makes this Ramsar Site well placed for education and research (MacFarlane & Muller 2011).

4.6.2 Blesbokspruit International Important Bird Area The Blesbokspruit Important Bird Area (IBA) is situated near the confluence of Cowle’s Stream with the Blesbokspruit (Figure 4-6). This International IBA represents a large, highly modified, high-altitude wetland with a narrow fringe of degraded grassland that extends along the Blesbokspruit, from the Grootvly Wetland Reserve in the north, to Marievale Bird Sanctuary in the south. More than 220 bird species have been recorded in the IBA during the SABAP 2 (www.birdlife.org.za). The highly productive system provides ample food for the Near Threatened Lesser and Greater flamingos, and supports a high diversity of other water bird species including Goliath Heron, Purple Heron, African Spoonbill, Glossy Ibis, Pied Avocet, Red-knobbed Coot and White-winged. The Endangered African Marsh Harrier is a breeding resident, but has been displaced from much of the surrounding veld as a result of intense industrialisation, urbanisation and habitat modification. The Vulnerable African Grass-owl is now rarely recorded along the Blesbokspruit, its local population decline being attributed to a reduction in its preferred rank grassland habitat adjacent to the wetland. Large volumes of water discharged upstream have increased the extent and permanence of flooded ground, while reed encroachment, unplanned fires, uncontrolled grazing by cattle and invasion by alien forbs contribute to the degradation of the remaining terrestrial habitat.

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Figure 4-6 Blesbokspruit Ramsar wetland and IBA

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4.6.3 National Water Resources In additional to the international protection of a Ramsar wetland, a broad spectrum of regional and national legislation and guidelines applies to the protection of wetlands and their biodiversity. The National Water Act (NWA; Act 36 of 1998) is the principle legal instrument relating to water resource management in South Africa. Under the NWA, all wetlands and their buffer zones are protected.

4.6.4 National Freshwater Ecosystem Priority Areas The National Freshwater Ecosystem Priority Area project (Driver et al. 2011) provides strategic spatial priorities for conserving freshwater ecosystems and supporting sustainable use of water resources in South Africa. The “Freshwater Ecosystems” refer to all inland water bodies whether fresh or saline including rivers, lakes, wetlands, sub-surface waters and estuaries. In South Africa more than 60% of wetlands are threatened, with 50% Critically Endangered, and more than 80% poorly or not protected (NBA 2011).

The section of the Blesbokspruit adjacent to Gold One is an Endangered Lowland River system (Driver et al. 2011; Nel & Driver 2012), and both the Blesbokspruit and Cowle’s Stream represent Wetland Freshwater Ecosystem Priority Areas (FEPAs; Figure 4-7). The Blesbokspruit is classified as a Wetland FEPA due to its Ramsar status and the presence of threatened water bird species. Cowle’s Stream is classified as a Wetland FEPA due to its intersection with a Ramsar wetland and records of threatened water birds in or within 500m of this stream.

Driver et al. (2011) state that FEPAs should be regarded as ecologically important and as generally sensitive to changes in water quality and quantity, owing to their role in protecting freshwater ecosystems and supporting sustainable use of water resources. Wetlands FEPAs that are in a good condition (equivalent to an A or B ecological category) should remain so. Wetlands FEPAs that are not in a good condition, such as Cowle’s Stream and the Blesbokspruit, should be rehabilitated to their best attainable ecological condition.

This means that: Land-use practices or activities that will lead to deterioration in the current condition of a wetland FEPA are not acceptable. Land-use practices or activities that will make rehabilitation of a wetland FEPA difficult or impossible are not acceptable.

Driver et al. (2011) further state that “Applications for mining and prospecting in FEPAs and associated sub-quaternary catchments should be subject to rigorous environmental and water assessment and authorisation processes, as mining has a widespread and major negative impact on freshwater ecosystems.” Management guidelines associated with the concentration of flow, discharge of effluent, and other impacts on FEPAs are mentioned in Section 0.

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Figure 4-7 Extent of Freshwater Ecosystem Priority Areas in the region

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One of the most important benefits provided by wetlands is their ability to maintain and improve water quality through the removal of toxicants and nutrients. However, their capacity to do so is finite, and a broad spectrum of anthropogenic pressures hampers their efficiency in this regard. Aside from direct physical disturbances to their hydrological and geomorphological functioning, activities such as mining have the potential to contaminate wetland ecosystems with potentially deleterious consequences for the varied biota dependant on them. Nowhere are these effects more pressing than in water-stressed regions. South Africa and the Blesbokspruit, in particular, are a case in point (Du Plessis et al. 2014). This globally significant wetland provides not only a source of water for irrigation, livestock, recreational, domestic and industrial use, but also functions as an important refuge and corridor for biota within a highly urbanised and industrial landscape (AmbaniI & Annegarn 2015). Given the significant strategic and biological importance of the Blesbokspruit system, the effluent discharge into Cowle’s Stream needs to be addressed.

4.6.5 Priority Areas & Threatened Ecosystems The National Spatial Biodiversity Assessment (DEA & SANBI 2012), including Terrestrial Priority Areas and Threatened Ecosystems (Jonas et al. 2012), resulted in the identification of nine spatial Priority Areas for terrestrial biodiversity. These Priority Areas represent areas with high concentrations of biodiversity features, and/or areas where there are few options for meeting biodiversity targets. The Study Area falls within the highly pressurized and threatened Bushveld-Bankenveld Priority Area (Figure 4-8).

The list of identified ecosystems, which are threatened and in need of protection, has been gazetted (GG 34809, GN 1002, 9 December 2011). This is not only to reduce the rate of ecosystem and species extinction, but also to prevent further degradation of ecosystem structure, function and composition. The Study Area is situated directly within the Critically Endangered Blesbokspruit Highveld Grassland threatened ecosystem (Figure 4-8).

4.6.6 Gauteng Conservation Plan The Gauteng Conservation Plan or C-Plan (version 3.3; GDARD 2011) is the outcome of systematic conservation planning by the Gauteng Department of Agriculture and Rural Development for improved conservation of biodiversity in this province. The latest C-Plan indicates that the Study Area falls partly in an Important Critical Biodiversity Area (CBA 2), neighbouring an Ecological Support Area (ESA) for provincial biodiversity (Figure 4-8).

Important CBAs represent sensitive areas that are important for the conservation of biodiversity in Gauteng. Land uses incompatible with biodiversity, must be avoided in these areas. ESAs have been identified to ensure sustainability in the long term, and include e.g. dolomite outcrops, rivers, wetlands, pans, corridors for climate change and species migration, rocky ridges, and low cost areas for Johannesburg and Tshwane (GDARD 2011).

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Figure 4-8 Location of the Study Area in the Bushveld-Bankenveld Priority Area and Blesbokspruit Highveld Grassland Threatened Ecosystem

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Figure 4-9 Study Area in relation to the current Gauteng C-Plan

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5. Methodology

Prior to the 2015 field survey, the Study Area was surveyed at a desktop level using 1:50 000 topographical maps, aerial photographs from the 1960’s, Google Earth™ satellite imagery, and available contour data, to identify possible historical disturbances and the location and extent of natural and artificial wetlands.

The NSS (2012) Wetland Assessment for the Gold One Return Water Dam and associated infrastructure, and the SAS (2015) Ecological Scan and Wetland Assessment for the proposed SAPPI Enstra Mill pipeline, were consulted for background reference material.

Presented in this report are findings from NSS field surveys that were conducted in July 2015, April 2017 and August 2018. The surveys were principally focused on the artificial wetland created by the discharge of effluent from Gold One, but Cowle’s Stream was also briefly assessed.

Note that the below-mentioned wetland assessment protocols do not apply to artificial wetlands and were therefore only used to assess the Cowle’s Stream wetland system.

5.1. Wetland Extent The Study Area was traversed on foot and in-field wetland delineation was performed in accordance with the field procedure for identification and delineation of wetlands and riparian areas by DWAF (2005), which is based on the following three indicators:

Terrain Indicator: The topography of the area was used to determine where in the landscape wetlands are likely to occur. McVicar et al. (1977) defines five terrain units. Most wetlands will be found in valley bottoms (unit 5), but can occur on crests, midslopes and footslopes (units 1, 3 and 4). Depicted in Figure 5-1 are the terrain units most typically found in land type Ba1 wherein the Study Area is situated (AGIS 2010).

Figure 5-1 Terrain units typically found in land type Ba1 (AGIS 2010)

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Vegetation Indicator: Vegetation can be used as an indicator of wetland conditions, and is a key component of the NWA definition of a wetland. The presence / absence of hydrophytes provides a useful additional criterion for delineating wetlands. Vegetation in the Study Area was surveyed and assessed using Braun Blanquet and standard vegetation data analysis methods. Soil Wetness Indicator: At selected points a hand auger was used to extract soil samples from the first 50cm of the soil profile, and deeper where necessary. Soil wetness and the duration of wetness are indicated by the colour of the soil. A grey soil matrix such as a G-horizon is an indication of wetness for prolonged periods of time, and mottles indicate a fluctuating water table. According to DWAF (2005), signs of soil wetness must be found within the top 50cm of the soil surface to classify as a wetland. The permanent zone of a wetland is therefore characterised by grey soil, the seasonal zone has a high frequency of low chroma mottles, and the temporary zone has less, high chroma mottles. These mottles are normally most prominent just below the A-horizon. Mottles may occur in non-wetland soils that have a high chroma matrix, and the colour of the matrix must always be considered in conjunction with the presence of mottles.

5.2. Wetland Classification Wetlands were classified using the recently-published “Classification system for Wetlands and other Aquatic Ecosystems in South Africa” by Ollis et al. (2013), hereafter referred to as “the Classification System.” Ecosystems included by the Classification System encompass all those that are listed under the Ramsar Convention as “wetlands”, and include all freshwater (non- marine) systems.

The Classification System recognizes three broad inland systems: rivers, wetlands and open waterbodies. Like Kotze et al’s (2008) classification of wetlands based on hydro-geomorphic (HGM) units, the Ollis et al. (2013) Classification System asserts that the functioning of an inland aquatic ecosystem is determined fundamentally by hydrology and geomorphology.

The Classification System has a six-tiered structure where under the determination of a system’s HGM unit (Level 4) is the most fundamental (Figure 5-2): Level 1 – Type of Systems (Marine, estuarine or Inland) Level 2 – Regional Setting (Level 1 Ecoregions; NFEPA WetVeg units etc) Level 3 – Landscape Unit (Valley Floor, Slope, Plain, Bench) Level 4 – Hydrogeomorphic (HGM) Unit Level 5 – Hydrological Regime Level 6 – Descriptors (e.g. Natural vs Artificial; Salinity; pH etc)

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Figure 5-2 Primary HGM units with their dominant water inputs, throughputs and outputs (Ollis et al. 2013)

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5.3. Wetland Present Ecological State The PES of Cowle’s Stream was assessed using the Macfarlane et al. (2008) Level 1 WET- HEALTH tool based on the main wetland drivers of geomorphology, hydrology and vegetation.

The system uses: An impact-based approach for those activities that do not produce clearly visible responses in wetland structure and function. The impact of irrigation or aforestation in the catchment, for example, produces invisible impacts on water inputs. This is the main approach used in the hydrological assessment. An indicator-based approach for activities that produce clearly visible responses in wetland structure and function such as the presence of erosion gullies or alien plant species. This approach is mainly used in the assessment of geomorphological and vegetation health.

The wetland is first classified into HGM units (as described in the previous subsection). Each HGM unit is then assessed separately for hydrological, geomorphological and vegetation health based on extent, intensity and magnitude of impact. This is translated into a health score, calculated as follows: The extent of impact is measured as the proportion of a wetland and/or its catchment that is affected by an activity. Extent is expressed as a percentage. The intensity of impact is estimated by evaluating the degree of alteration that results from a given activity. The magnitude of impact for individual activities is the product of extent and intensity. The magnitude of individual activities in each HGM unit is combined in a structured and transparent way to calculate the overall impact of all activities that affect hydrological, geomorphological or vegetation health. Present State health categories are scored on a scale of A-F (Table 5-1).

Using a combination of threat and/or vulnerability, an assessment is also made in each module on the likely Trajectory of Change within the wetland (Table 5-2). Overall health of the wetland is then presented for each module by jointly representing the Present State and likely Trajectory of Change. This approach not only provides an indication of hydrological, geomorphological and vegetation health, but also highlights the key causes of wetland degradation.

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Table 5-1 Impact scores and Present Ecological State categories COMBINED ECOLOGICAL DESCRIPTION IMPACT CATEGORY SCORE A Unmodified, natural 0-0.9 Largely natural with few modifications. A slight change in B ecosystem processes is discernable and a small loss of natural 1-1.9 habitats and biota may have taken place. Moderately modified. A moderate change in ecosystem processes C and loss of natural habitat has taken place but the natural habitat 2-3.9 remains predominantly intact. Largely modified. A large change in ecosystem processes and loss D 4-5.9 of natural habitat and biota has occurred. Seriously modified. The change in ecosystem processes and loss E of natural habitat and biota is great but some remaining natural 6-7.9 habitat features are still recognizable. Critically modified. Modifications have reached a critical level and F the ecosystem processes have been modified completely with an 8-10 almost complete loss of natural habitat and biota. Source: Modified from Macfarlane et al. (2008)

Table 5-2 Trajectory of change classes, scores and symbols TRAJECTORY CHANGE CLASS DESCRIPTION SYMBOL CLASS SCORE RANGE* Improve Condition is likely to improve 2 1.1 to 2  markedly substantially over the next five years Condition is likely to improve over the Improve 1 .3 to 1  next five years Condition is likely to remain stable over -0.2 to Remains stable 0  the next five years +0.2 Deterioration Condition is likely to deteriorate slightly -1 -0.3 to -1  slight over the next five years Deterioration Condition is likely to deteriorate -2 -1.1 to 2  substantial substantially over the next five years Source: Modified from Macfarlane et al. (2008) * Used when determining a trajectory score for a wetland comprising several HGM units

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Impacts on wetland geomorphology and vegetation were visually assessed during each survey in the Study Area. Impacts on wetland hydrology were assessed both visually and in terms of water quality, as described next.

5.3.1 Water Quality Gold One has for a number of years been monitoring ground and surface water quality encompassing 119 physio-chemical parameters at 139 localities. In 2018 Gold One commenced with a pilot study using lime to treat its ground water, prior to discharge at the surface.

For the evaluation of wetland hydrology and PES in this report, the available Gold One water quality data were limited to water quality parameters, which are of relevance to wetland ecosystems, and which were measured in samples from one or more of the six sites mapped in Figure 5-3.

The Overflow site is located where the Mine’s ground water overflows at the surface. Sites MW- 2 and MW-8 represent Mine Water discharge points. Sites 1550 and 1545 were only sampled once-off by NSS to assess whether or not the artificial wetland might help to improve the quality of the discharge water. Site SW6 represents a Gold One Surface Water sampling point situated outside the NSS Study Area within the Blesbokspruit.

Sampling was performed at the: MW-2 site intermittently between October 2007 and June 2017. MW-8 site intermittently between July 2011 and June 2017. SW6 site intermittently between June 2012 and June 2017. 1550 and 1545 sites only on 21 June 2017. Overflow site intermittently during March, April and May 2018.

The available data from the selected sites were compared with the In-stream Water Quality Guidelines for the Blesbokspruit (The Reservoir 2015), and the Target Water Quality Range (TWQR) guidelines for Aquatic Ecosystems, which are provided in Table 5-3.

Lastly, to evaluate the efficacy of the Mine’s recent ground water treatment, the available pre-2018 untreated water quality data (especially from the MW-2 site) were compared with the available 2018 treated water quality data from the Overflow site.

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Figure 5-3 Location of the selected water quality sampling sites

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Table 5-3 In-stream Water Quality Guidelines for the Blesbokspruit and TWQR Guidelines for aquatic ecosystems IN-STREAM IDEAL ACCEPTABLE TOLERABLE WATER QUALITY UNIT TWQR CATCHMENT MANAGEMENT INTERIM UNACCEPTABLE PARAMETER BACKGROUND TARGET TARGET Physical Electrical conductivity (EC) mS/m 70 <45 45-70 70-120 >120

Dissolved oxygen (DO) mg/ℓ O2 >6.0 5.0-6.0 <5.0 pH 6.5-8.5 <6.5; >8.5 Suspended solids (SS) mg/ℓ 5 <20 20-30 30-55 >55 Organic Chemical oxygen demand (COD) 20 <20 20-35 35-55 >55 Macro elements Aluminium (Al) mg/ℓ 0.005 <0.3 0.3-0.5 >0.5

Ammonia (NH3) mg/ℓ 0.007 <0.1 0.1-1.5 1.5-5.0 >5 Chloride (Cl-) mg/ℓ 50 <80 80-150 150-200 >200 Fluoride (F) mg/ℓ 0.75 <0.19 0.19-0.70 0.70-1.00 >1.00 Iron (Fe) mg/ℓ 0.1 <0.1 0.1-0.5 0.5-1.0 >1.0 Magnesium (Mg2+) mg/ℓ 70 <8 8-30 30-70 >70 Manganese (Mn) mg/ℓ 0.18 <0.2 0.2-0.5 0.5-1.0 >1 - Nitrate (NO3 ) mg/ℓ 1 <0.5 0.5-3.0 3.0-6.0 >6.0 3- Phosphate (PO4 ) mg/ℓ 0.3 <0.2 0.2-0.4 0.4-0.6 >0.6 Sodium (Na+) mg/ℓ 50 <70 70-100 100-15 >150 2- Sulphate (SO4 ) mg/ℓ 80 <150 150-300 300-500 >500 Bacteriological Escherichia coli counts/100ml <130 130-200 200-400 >400 Faecal coliforms counts/100ml <126 126-1000 >1000 Biological Daphnia % survival 100 90-100 80-90 <80

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5.4. Wetland Ecosystem Services The WET – EcoServices tool (Kotze et. al. 2008) was used to assess the ecosystem services supplied by Cowle’s Stream. The tool has been designed for inland palustrine wetlands, i.e. marshes, floodplains, vleis and seeps, and has been developed to help assess the goods and services that individual wetlands provide to support planning and decision-making.

The wetland benefits included in the WET-EcoServices model (Table 5-4) were selected based on their importance for South African wetlands, and how readily these can be assessed. Benefits such as ground water recharge / discharge and biomass export may be important but are difficult to characterise at a rapid assessment level, have thus been excluded.

Table 5-4 Ecosystem services assessed using the WET-EcoServices tool (Kotze et al. 2008)

The spreading out and slowing down of floodwaters in the Flood attenuation wetland, thereby reducing the severity of floods downstream Streamflow regulation Sustaining streamflow during low flow periods Sediment The trapping and retention in the wetland of sediment trapping carried by runoff waters

s Phosphate Removal by the wetland of phosphates carried by runoff

enefits assimilation waters

B Nitrate

Removal by the wetland of nitrates carried by runoff waters

supporting benefits assimilation

& Toxicant Removal by the wetland of toxicants (e.g. metals, biocides

Water quality assimilation and salts) carried by runoff water

enhancement

Indirect

etlands Controlling of erosion at the wetland site, principally through Erosion control

W the protection provided by vegetation The trapping of carbon by the wetland, principally as soil Regulating Carbon storage organic matter Through the provision of habitat and maintenance of natural Biodiversity maintenance process by the wetland, a contribution is made to maintaining biodiversity Biodiversity maintenance is not an ecosystem service as such, but encompasses attributes widely acknowledged as having potentially high value to society

Provision of water for The provision of water extracted directly from the wetland for

ervices supplied by ervices human use domestic, agriculture or other purposes

Provision of The provision of natural resources from the wetland,

enefits harvestable resources including livestock grazing, craft plants, fish, etc.

Provision of cultivated The provision of areas in the wetland favourable for the

Ecosystem

Provisioning benefits foods cultivation of foods

Direct

Places of special cultural significance in the wetland, e.g., Cultural heritage for baptisms or gathering of culturally significant plants Sites of value for tourism and recreation in the wetland, Tourism and recreation often associated with scenic beauty and abundant birdlife

Education and research Sites of value in the wetland for education or research Culturalbenefits

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5.5. Wetland Ecological Importance & Sensitivity The Ecological Importance and Sensitivity (EIS) of Cowle’s Stream was assessed using the tool by Rountree & Kotze (2012). The purpose of determining the EIS of a water resource is to identify those systems that provide higher than average ecosystem services and/or biodiversity support functions, and/or which are especially sensitive to impacts. The tool uses three criteria: Ecological importance and sensitivity, incorporating the traditionally examined criteria used in EIS assessments of other water resources by DWS, thus enabling consistent assessment approaches across water resource types; Hydro-functional importance, which considers water quality, flood attenuation and sediment trapping ecosystem services that the wetland may provide; and Importance in terms of basic human benefits - this suite of criteria consider the subsistence uses and cultural benefits of the wetland system.

It is recommended that the highest of these three suites of scores be used to determine the overall EIS category of the wetland system (Table 5-5).

Table 5-5 EIS categories (interpretation of median scores for biotic and habitat determinants) RANGE OF RECOMMENDED ECOLOGICAL IMPORTANCE & SENSITIVITY MEDIAN EMC Very high Wetlands that are considered ecologically important and sensitive on >3 and a national / international level. The biodiversity of these systems is A <=4 usually very sensitive to flow and habitat modifications. They play a major role in moderating the quantity and quality of water of major rivers. High Wetlands that are considered to be ecologically important and >2 and sensitive. The biodiversity of these systems may be sensitive to flow B <=3 and habitat modifications. They play a role in moderating the quantity and quality of water of major rivers. Moderate Wetlands that are considered to be ecologically important and >1 and sensitive on a provincial or local scale. The biodiversity of these C <=2 systems is not usually sensitive to flow and habitat modifications. They play a small role in moderating the quantity and quality of water of major rivers. Low/Marginal Wetlands which are not ecologically important and sensitive at any >0 and scale. The biodiversity of these systems is ubiquitous and not D <=1 sensitive to flow and habitat modifications. They play an insignificant role in moderating the quantity and quality of water of major rivers.

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5.6. Wetland Buffer Requirements GDARD (2014) stipulates that: “The wetland and a protective buffer zone, beginning from the outer edge of the wetland temporary zone, must be designated as sensitive. Rules for buffer zone widths are as follows:  30m for wetlands occurring inside the urban edge; and  50m for wetlands occurring outside the urban edge. Note that these buffer zones are essential to ensure healthy functioning and maintenance of wetland ecosystems. Larger buffer zones may be required for wetlands supporting sensitive species. In addition, the catchment of all pan wetlands must be designated as sensitive.”

As the Study Area is outside the urban edge, a minimum 50m buffer for wetlands applies. In addition to this, Cowle’s stream is a recognized FEPA Wetland (Figure 4-7), and Driver et al. (2011) stipulate that a 100m buffer should apply to all FEPA Wetlands. Although the 100m buffer is considered adequate from a water quality perspective (in providing functional filtering capacity), additional biodiversity information should be taken into consideration to ensure that the buffer adequately addresses risks to the receiving environment. Development of the proposed pipeline and implementation of recommended impact mitigation measures should respect the recommended 100m buffer on the Cowle’s FEPA Wetland.

5.7. Limitations & Assumptions The main subject of this assessment is an artificial wetland and, therefore, the standard tools to assess wetland PES, EIS and ecosystem services were not applicable. The tools that were used to assess the PES, EIS and ecosystem services of Cowle’s Stream are highly subjective. The exact boundaries of the artificial wetland were difficult to determine due to the scattered presence of wetland indicators where significant surface water pooling and saturation had occurred. The 2015 and 2018 field surveys were performed during winter, when a large proportion of the Study Area was burnt and therefore, the identification of wetland vegetation indicators was limited to species such as Typha, Phragmites and Cyperus. The 2017 field survey was performed in late summer at the end of the growing season; but vegetation was not burnt (although heavily transformed by past anthropogenic disturbances), and most plant species were identifiable. The soil profile was modified in places by past excavation activities and other earthworks. Such modification of hydrological conditions limits the accuracy of wetland delineation, which relies heavily on the interpretation of undisturbed soil morphology and characteristics. The 2018 and pre-2018 surface water quality data were not strictly comparable as the data were obtained from different localities. Also, no measurements of Hg, Sb and Se were

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available from sampling sites MW-2, MW-3, 1550, 1545 and SW6, and no measurements 3- of TDS, SS, COD, DO, OA, BOD, TPH, PO4 and F were available from the Overflow site.

6. Results

As mentioned previously, the afore-mentioned wetland assessment protocols do not apply to artificial wetlands and were therefore only used to assess the Cowle’s Stream system.

6.1. Wetland Classification & Extent The NSS “wetland” sampling points and the delineated extent of the artificial wetland are shown in Figure 6-1 and Figure 6-2, respectively. Identified floral communities in the Study Area are mapped in Figure 6-3, and photographs of dominant flora are shown in Figure 6-4.

From the Mine’s discharge point to a nearby railway line, limited vegetation has established on the steep slopes of the trench. In the trench itself, observed wetland indicator plant species include Typha, Phragmites, Plantago, and Cyperus. At the point where the discharge water moves through culverts under the railway line, the trench is less defined and some pooling has occurred, which has allowed a small patch of Phragmites to develop.

The trench then intersects a large stand of Robinia pseudoacacia (an alien tree species that tolerates a pH of 4.6 to 8.2) and Arundo donax (Giant Reed). At this point the trench is shallow, and the discharge water spreads into surrounding areas. Here, the continual presence of surface water has resulted in the progressive development of an “artificial wetland.” Although soil wetness indicators (mottling) are not yet obvious in this area, wetland vegetation indicators have become increasingly noticeable during the NSS surveys as well as water saturation within the ‘drier’ deep red soils. The vegetation mainly features large patches of Pennisetum clandestinum (Kikuyu) and Cynodon; but patches of Juncus cf rigidus, Typha, Phragmites are steadily establishing throughout the area where water drains and fans over the surface.

Phragmites is present along the remainder of the trench, which reaches the unchannelled valley bottom wetland associated with Cowle’s Stream. Finally the trench discharges into the Cowle’s Stream channelled valley bottom wetland. A channelled valley bottom wetland is defined by Ollis et al (2013) as “a mostly flat wetland area located along a valley floor with a river channel running through it.” The channelled valley bottom wetland is dominated by Phragmites, with Juncus present on the edges. Beyond the artificial wetland, where the landscapes remains dry, the disturbed grassland mainly comprises Hyparrhenia hirta, Verbena species*, Cirsium vulgare*, Bidens pilosa, Tagetes minuta, and Eragrostis species.

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Figure 6-1 NSS “wetland” sampling points

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Figure 6-2 Extent of the artificial wetland in the Study Area

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Figure 6-3 Floral communities in the Study Area

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Sparse Phragmites stand Robinia patch

Juncus cf rigidus Phragmites and Juncus

Hyperhennia and Pennisetum (Kikuyu) Phragmites encroachment into Hyparhennia grassland Figure 6-4 Dominant flora in the Study Area

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6.2. Wetland Present Ecological State The geomorphology and vegetation of Cowle’s Stream is Largely Modified (D ecological category), and its hydrology is Seriously Modified (E ecological category). This downstream environment has been primarily impacted by the increased quantity (or volume) and reduced quality of water from the Gold One effluent discharge. Similarly, in the Blesbokspruit Ramsar Management Plan (Macfarlane & Muller 2011), deterioration in water quality (from industry, mining and sewage works), and increased water inputs (resulting in hydrological alteration) are stated as two of the major threats impacting the Blesbokspruit. The PES of Cowle’s Stream has also been affected by invasive alien flora, livestock activity, and other forms of disturbance. These key issues are discussed next.

6.2.1 Water Quantity The Blesbokspruit was historically (pre-1930) a narrow, meandering, non-perennial Highveld stream with associated hydromorphic grassland. Thereafter, disturbances (e.g. discharged effluent) from gold mining, damming, road construction and other forms of development impacted the system’s flow, and transformed the system into a permanent wetland colonized by reeds such as Typha and Phragmites. The increased flow has effectively “drowned” the Blesbokspruit, which amongst other things, has reduced the availability of wading habitat for birds (www.birdlife.org.za). The large volume of water discharged from Gold One is part of what has created the downstream Blesbokspruit system as it is known today. In addition to the volume of discharge water directly entering Cowle’s Stream, there is a large volume of discharge water flowing into surrounding disturbed grassland. Thus, now a previously terrestrial ecosystem is inundated with effluent.

6.2.2 Water Quality In Table 6-1 the average value of each selected water quality parameter is shown (where available) for each of the six selected sampling sites mapped in Figure 5-3. Colour coding in this table allows for comparison of the data with the In-stream Water Quality Guidelines for the Blesbokspruit and the TWQR guidelines for aquatic ecosystems (both provided in Table 5-3). The Blesbokspruit guidelines are indicated by table cells coloured blue (ideal), green (acceptable), yellow (tolerable) and red (unacceptable). Values exceeding the TWQR are indicated by brown text.

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Table 6-1 Average water quality parameter values for each selected sampling site TREATED UNTREATED VARIABLE Overflow MW-2 MW-8 1550 1545 SW6 pH 9.82 7.75 7.60 7.97 8.16 7.46 EC (mS/m) 210.00 232.88 240.29 207.00 207.00 70.20 TDS (mg/L) 1688.36 1756.20 1503.08 1491.04 450.85 SS (mg/L) 5.31 20.59 0.40 2.80 188.00 Ca2+ (mg/L) 194.82 189.78 205.29 177.27 171.15 44.08 Cl- (mg/L) 136.62 180.79 190.17 145.00 145.00 79.77 Na+ (mg/L) 122.95 119.08 134.64 116.14 112.44 75.64 Mg2+ (mg/L) 55.58 130.54 123.11 105.62 103.45 15.95 2- SO4 (mg/L) 647.59 854.41 868.18 753.00 748.00 105.92 - NO3 (mg/L) 6.17 25.28 23.64 32.00 32.50 0.75 Al (mg/L) 0.003 0.12 0.13 0.01 0.01 0.09 Be (mg/L) 0.000 0.02 0.02 0.02 CN- (mg/L) 0.03 0.01 0.01 0.01 0.01 Cr (mg/L) 0.000 0.02 0.01 0.01 0.01 0.02 Cu (mg/L) 0.001 0.02 0.02 0.01 0.01 0.02 Ni (mg/L) 0.013 0.48 0.48 0.25 0.25 0.04 Pb (mg/L) 0.000 0.01 0.01 0.01 0.01 0.01 Zn (mg/L) 0.008 0.13 0.11 0.02 0.01 0.02

NH3 (mg/L) 5.50 10.17 6.31 3.35

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Prior to the underground treatment of water in 2018, water at sites MW-2, MW-8, 1550, 1545 and SW6 exhibited the following: pH: generally ideal (neutral). Most alkaline at 1545. Most acidic at SW6. EC: unacceptable at all sites except SW6 (where mostly acceptable to tolerable). TDS: TWQR exceeded at all sites (at SW6 average TDS almost equalled TWQR). SS: mostly an issue at SW6 where SS was unacceptable. Ca2+: TWQR exceeded at all sites except SW6. Cl-: mostly an issue at MW-2 and MW-8 where Cl was tolerable. Na+: TWQR exceeded at all sites. Mg2+: unacceptable at all sites except SW6. 2- SO4 : seriously unacceptable at all sites except SW6. - NO3 : seriously unacceptable at all sites except SW6. Al, Be, Cr, Cu, Ni, Pb, Zn: TWQR exceeded at virtually all sites. Mn: TWQR exceeded at MW-2. CN-: TWQR exceeded at all sites.

NH3: seriously unacceptable at MW-2 and MW-8.

Following the treatment of water with lime in 2018, water at the Overflow site exhibited the following: pH: unacceptable (too alkaline). EC: unacceptable. TDS: unknown. SS: unknown. Ca2+: TWQR exceeded. Cl-: TWQR exceeded, but acceptable. Na+: TWQR exceeded. Mg2+: tolerable, but within TWQR. 2- SO4 : unacceptable. - NO3 : unacceptable. Al, Be, Cr, Cu, Fe, Mn, Ni, Pb: within TWQR. ZN: TWQR exceeded. CN-: unknown.

NH3: unacceptable.

Overall water quality has been poorest at the two discharge points MW-2 and MW-8 (where chlorine and sulphate concentrations, in particular, have been excessively high). In contrast, the downstream site SW6 is considerably less impacted (with only suspended solids exceeding the Blesbokspruit guidelines) - indicative of a dilution effect. At NSS sampling sites 1550 and 1545, which were situated in the artificial wetland, the various water quality parameters generally showed a slight improvement (with the exception of an increase in nitrates). The improvement in water quality through the artificial wetland is likely attributable to the small but growing amount of wetland vegetation that is present there. Although this

Natural Scientific Services CC 41 Wetland Assessment – Gold One: Modder East finding should be interpreted with caution (due to the once-off sampling at sites 1550 and 1545), it highlights the importance of wetlands in improving water quality. Unfortunately, due to the high volume of discharge water, and the marginal recorded improvement in water quality, the effect is currently not sufficient to meet relevant guidelines.

Prior to 2018, the pH of the water at the relevant sampling sites was on average ideal (i.e. neutral) and, therefore, not indicative of acid mine drainage – although the pH of the water did drop to an unacceptably low (acidic) 5.9 at MW-8 (Figure 6-5). Recent treatment of the Mine’s ground water with lime is now responsible for the unacceptably high (alkaline) 9.8 pH at the Overflow site.

Electrical conductivity (EC) was unacceptably high (>120mS/m) for the Blesbokspruit catchment at all sites except SW6. The elevated EC and total dissolved solids (TDS) was due to high concentrations in the discharge water of ions and salts of calcium (Ca²+), chloride (Cl¯), + + ¯ magnesium (Mg² ), sodium (Na ) and nitrate (NO3 ). Post-treatment, at the Overflow site, EC remained unacceptable (Figure 6-6). This was because the average concentrations of calcium (Figure 6-7) and especially sodium (Figure 6-11) were above the TWQR (and higher than previously measured at MW-2 and MW-8), and the average concentration of nitrate was unacceptable (Figure 6-12 - albeit lower than previously measured at MW-2 and MW-8). This was also despite tolerable magnesium (Figure 6-10) and acceptable chloride (Figure 6-8) concentrations (compared with unacceptable magnesium and tolerable chloride concentrations measured previously at MW-2 and MW-8).

High salt loads were one of the major factors resulting in the Blesbokspruit Ramsar wetland being placed on the Montreaux Record in 1996, and must be addressed going forward (Ambani 2013). Elevated EC and total dissolved solids (TDS) reduces the buffering capacity of water and thus the metabolism of aquatic organisms (DWAF 1996). Different aquatic species differ in their tolerance to EC and TDS, and juvenile stages are often more sensitive than adults (James et al. 2003). Increased salt concentrations can also sensitise aquatic organisms to heavy metals, biocides and other pollutants (Dallas & Day 2004). Apart from elevating EC and TDS, little is known about potential direct effects of calcium, chloride, magnesium and sodium on aquatic life. Magnesium can reportedly interfere with nutrient availability, and fluoride (Figure 6-9) reacts readily with magnesium in alkaline water to form complexes which are not easily absorbed by aquatic biota (DWAF 1996). At very high concentrations, nitrate can be toxic to fish because it interferes with oxygen uptake, causing fish to die of anoxia during activity when high oxygen demand is required (Dallas & Day 2004).

The elevated EC and salt concentrations in the discharge water, pre- and post-treatment of the underground water, corresponds with NSS’s observations of precipated salt on the ground and vegetation throughout and adjacent to the discharge trench, and along the banks of Cowle’s Stream, during all surveys (Figure 6-13 and Figure 6-14).

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pH EC (mS/m) 12.0 350

10.0 300 250 Min 8.0 Min 200 Average 6.0 Average 150 Max 4.0 Max 100 WQG (Blesbokpsruit) Unacceptable Levels 2.0 50 TWQR Unacceptable Levels 0.0 0 Unacceptable Levels

Figure 6-5 pH during and before water treatment Figure 6-6 Electrical conductivity during and before water treatment Ca2+ (mg/l) Cl- (mg/l) 500 600 450 500 400 Min 350 400 Min Average 300 300 250 Average Max 200 200 Max WQG (Blesbokpsruit) 150 TWQR 100 TWQR 100 0 Unacceptable Levels 50 0 Overflow MW-2 MW-8 1550 1545 SW6

Figure 6-7 Calcium levels during and before water treatment Figure 6-8 Chloride levels during and before water treatment

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F- (mg/l) Mg2+ (mg/l) 1.60 200 1.40 180 160 1.20 Min 140 Min 1.00 Average 120 Average 0.80 100 Max Max 0.60 80 60 0.40 WQG (Blesbokpsruit) WQG (Blesbokpsruit) 40 0.20 TWQR 20 TWQR 0.00 Unacceptable Levels 0 Unacceptable Levels

Figure 6-9 Fluoride levels before water treatment Figure 6-10 Magnesium levels during and before water treatment

+ - Na (mg/l) NO3 (mg/l) 400 140 350 120 300 Min 100 Min 250 Average 80 Average 200 Max 60 Max 150 100 WQG (Blesbokpsruit) 40 WQG (Blesbokpsruit) 50 TWQR 20 TWQR 0 Unacceptable Levels 0 Unacceptable Levels

Figure 6-11 Sodium levels during and before water treatment Figure 6-12 Nitrate levels during and before water treatment

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Salt precipitation along the trench

Salt precipitation in the disturbed grassland and Robinia patches adjacent to the trench

Salt precipitation along the banks of Cowle’s Stream Figure 6-13 Precipitation of salt in the Study Area in July 2015

Many local indigenous flora probably cannot handle the high salt loads, inter alia, because salinity reduces a plant’s ability to take up water. An example is the dominant species in Soweto Highveld Grassland, Themeda triandra (Red Grass), which is sensitive to water stress specifically during germination (Saleem et al. 2009). In some plants, high intracellular salt inhibits metabolic processes including protein synthesis. Sodium can rise to toxic levels in older leaves, causing them to die and reducing leaf area available for photosynthesis, which ultimately impacts plant growth (Munns 2002).

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Salt precipitation in disturbed grassland adjacent to trench

Salt precipitation in artificial wetland

Salt precipitation near Cowle’s Stream Figure 6-14 Precipitation of salt in the Study Area in August 2018

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The impact of salt on the vegetation is aggravated by annual wild fires and overgrazing. African Sporobolus grasses, for example, exhibit high mortality when exposed to both sodium and defoliation (Griffith & Anderson 2013). In comparison, halophytic vascular plants can survive on soils with salt concentrations around 6% (and potentially up to 20%) by using stress proteins and compatible cytoplasm osmotic solutes. An example is Phragmites australis, which is becoming increasingly prevalent in the Study Area. Under very high salt stress, however, the growth of even Phragmites is inhibited (Al-Garni 2006).

2- Concentrations of sulphate (SO4 ) have seriously exceeded the TWQR and Blesbokspruit guidelines at MW-2, MW-8, 1550 and 1545. The concentration of sulphate was also unacceptable at the Overflow site post-treatment (Figure 6-15). Mine run-off and discharged effluent are, respectively, the diffuse and point sources of the sulphate. The host material for gold contains pyrite (FeS2), and when this is uncovered and exposed to the oxidizing action of air, water, and chemosynthetic bacteria, the inorganic sulphur is converted to sulphate and sulphuric acid. Even though sulphate is not toxic, its high concentration increases the concentrations of other ions resulting in salinisation (Rikard & Kunkle 1990; Dallas & Day 2004; Colvin et al. 2011). High sulphate concentrations can also leach heavy metals from mineral and rock formations (Colvin et al. 2011), and can sensitise aquatic organisms to various pollutants such as biocides and heavy metals (Dallas & Day 2004).

Prior to 2018, various heavy metals exceeded the TWQR at the relevant sites. All these metals are toxic to aquatic life at high concentrations. Aluminium (Al) can cause neuromuscular dysfunction in fish. Although not directly lethal, chromium (Cr) inhibits both plant and animal growth, which inter alia increases their respective vulnerability to herbivory and predation. Dissolved iron (Fe) causes respiratory distress in fish by damaging the epithelial lining of their gills. Elevated levels of iron are also known to increase the susceptibility of fish to infectious disease (DWAF 1996b). Little is known about the effects of manganese (Mn) on aquatic organisms but according to Heal (2001), elevated levels of manganese are toxic to fish. Lead (Pb) impacts fish by disrupting haemoglobin synthesis, and the uptake of calcium and potassium through the gills. Long-term exposure of fish to low levels of lead causes toxic changes in their immune system, making them more susceptible to infectious disease. Acute lead toxicity causes renal disorders in fish (DWAF 1996b). Prolonged exposure to sub-lethal concentrations of zinc (Zn) has caused oedema and liver necrosis in fish fry. The lethal effect of zinc on fish is considered to be from the formation of insoluble compounds in the mucus covering the gills (DWAF 1996). However, post-treatment at the Overflow site, the concentrations of aluminium, beryllium (Be), cromium, copper (Cu), iron, manganese, nickel (Ni) and lead were all within the TWQR (Figure 6-16 to Figure 6-23). Zinc was an exception (Figure 6-24).

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2- SO4 (mg/l) Al (mg/l) 1400 2.50 1200 2.00 Min 1000 Min Average 800 Average 1.50 Max 600 Max 1.00 SANS 241 400 WQG (Blesbokpsruit) 0.50 WQG (Blesbokpsruit) 200 TWQR TWQR 0 Unacceptable Levels 0.00 Unacceptable Levels

Figure 6-15 Sulphate levels during and before water treatment Figure 6-16 Aluminium levels during and before water treatment Be (mg/l) Cr (mg/l) 0.04 0.25

0.03 0.20 0.03 Min Min 0.02 0.15 Average Average 0.02 Max Max 0.10 SANS 241 0.01 TWQR 0.05 TWQR 0.01

0.00 0.00 Overflow MW-2 MW-8 1550 1545 SW6 Overflow MW-2 MW-8 1550 1545 SW6

Figure 6-17 Beryllium levels during and before water treatment Figure 6-18 Chromium levels during and before water treatment

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Cu (mg/l) Fe (mg/l) 0.16 2.50 0.14 2.00 Min 0.12 Average 1.50 0.10 Min Max 0.08 Average 1.00 SANS 241 0.06 Max 0.50 WQG (Blesbokpsruit) 0.04 TWQR TWQR 0.02 0.00 Unacceptable Levels 0.00 Overflow MW-2 MW-8 1550 1545 SW6

Figure 6-19 Copper levels during and before water treatment Figure 6-20 Iron levels during and before water treatment Mn (mg/l) Ni (mg/l) 1.00 2.50 0.90 0.80 Min 2.00 0.70 Average Min 0.60 0.50 Max 1.50 Average 0.40 SANS 241 Max 0.30 1.00 0.20 WQG (Blesbokpsruit) SANS 241 0.10 TWQR 0.50 TWQR 0.00 Unacceptable Levels 0.00 Overflow MW-2 MW-8 1550 1545 SW6

Figure 6-21 Manganese levels during and before water treatment Figure 6-22 Nickel levels during and before water treatment

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Pb (mg/l) Zn (mg/l) 0.06 0.80 0.70 0.05 0.60 0.04 Min 0.50 Min Average 0.03 0.40 Average Max 0.30 Max 0.02 SANS 241 TWQR TWQR 0.20 0.01 0.10 0.00 0.00 Overflow MW-2 MW-8 1550 1545 SW6 Overflow MW-2 MW-8 1550 1545 SW6

Figure 6-23 Lead levels during and before water treatment Figure 6-24 Zinc levels during and before water treatment CN- (mg/l) 0.35

0.30

0.25 Min 0.20 Average 0.15 Max 0.10 TWQR 0.05

0.00 Overflow MW-2 MW-8 1550 1545 SW6

Figure 6-25 Cyanide levels before water treatment

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The most concerning water quality parameter is cyanide (CN-), which exceeded the TWQR at MW-2, MW-8, 1550, 1545 and SW6 (Figure 6-25). Concentrations of cyanide at the relevant sites post-treatment are not known. Cyanide toxicity is not easily diagnosed and the condition is usually indicated by sudden mortalities associated with eutrophication and mass production of blue-green bacteria. Mortalities in fish exposed to sub-lethal concentrations of cyanide may not occur immediately, although most of the fish will eventually die as a result of starvation or liver failure. Atrophy of the alimentary tract may occur. Cyanide interferes with oxygen metabolism, and fish respond to cyanide poisoning by increasing water flow over their gills and by decreasing their heartbeats (bradycardia). Other effects of cyanide on fish may include liver degeneration, histopathological damage to intestines, and degeneration of their stomach lining, concomitant with a loss of appetite and disorientation (DWAF 1996b).

High concentrations of ammonia (NH3), nitrate, chemical oxygen demand (COD), ortho- 3- phosphate (PO4 ) and suspended solids (SS) were indicative of organic enrichment at the relevant sites, especially SW6. In the artificial wetland, prominent algal growth in the pooling surface water was also indicative of organic enrichment (Figure 6-26).

Figure 6-26 Growth of algae in the artificial wetland due to organic enrichment

Post-treatment, at the Overflow site, the average concentration of ammonia was unacceptable (albeit lower than previously measured at MW-2 and MW-8; Figure 6-27). The chemical and physical changes caused by organic enrichment of the water subsequently drive biological changes in the receiving aquatic ecosystems. Although organic enrichment is not directly toxic to aquatic life, its effects may significantly change biotic community structure and biological processes. These include a reduction in dissolved oxygen, an increase in nutrient concentrations, suspended solids and turbidity, and possible bacterial contamination of the water resource (Dallas & Day 2004). Ammonia impacts the respiratory system of many animals by either inhibiting cellular metabolism or by decreasing the oxygen permeability of cell membranes (Gammeter & Frutiger 1990). Acute toxicity in fish causes loss of equilibrium, hyper-excitability, increased breathing rate, cardiac output and oxygen intake, and in extreme cases convulsions, coma and death.

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NH3 (mg/l) COD 25 60

20 50 Min Min 40 15 Average Average 30 10 Max Max 20 WQG (Blesbokpsruit) WQG (Blesbokpsruit) 5 TWQR 10 TWQR 0 Unacceptable Levels 0 Unacceptable Levels

Figure 6-27 Ammonium levels during and before water treatment Figure 6-28 Chemical oxygen demand before water treatment

3- PO4 (mg/l) SS (mg/L) 5.00 3500 4.50 3000 4.00 3.50 Min 2500 Min 3.00 Average 2000 Average 2.50 2.00 Max 1500 Max 1.50 WQG (Blesbokpsruit) 1000 WQG (Blesbokpsruit) 1.00 500 0.50 TWQR TWQR 0.00 Unacceptable Levels 0 Unacceptable Levels

Figure 6-29 Ortho-phosphate levels before water treatment Figure 6-30 Suspended solid levels before water treatment

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+ In contrast, ammonium (NH4 ) has little or no toxicity (Williams et al. 1986), though it does contribute to eutrophication and the production of excessive algae, toxic nitrites and poor oxygen levels (Dallas & Day 2004). Ammonium usually results from the decomposition of nitrogenous organic matter in surface or ground water, but in the Study Area the effluent discharge is responsible for unacceptably high ammonia concentrations. Of further concern is that at pH values greater than eight, non-toxic ammonium is converted to highly toxic ammonia. Post-treatment, at the Overflow site, the water’s pH was on average 9.8, but sometimes as high as 10.2.

Chemical oxygen demand is a measure of oxygen depletion during the degradation of organic waste. Although COD is routinely measured in effluents, it is less relevant for aquatic ecosystems, where it is unlikely that all organic matter will be fully oxidised. COD is, therefore, more useful for evaluating the impact of effluent that are discharged into aquatic systems (DWAF 1996). No COD measurements were available from the Overflow site, but COD was mostly Ideal to Tolerable at the relevant sampling sites prior to 2018 (Figure 6-28).

Elevated phosphate concentrations were only recorded in the Blesbokspruit and, therefore, cannot be attributed to Gold One’s effluent discharge. Rather, the unacceptable level of phosphate in the Blesbokspruit is probably attributable to urban run-off, decomposition of organic matter, and run-off from agricultural lands where fertilizers have been used. Phosphates stimulate the growth of aquatic plants, which corresponds with the dense reedbeds that have established in the Blesbokspruit.

Suspended solids were similarly unacceptable in the Blesbokspruit. High concentrations of suspended solids decrease light penetration and primary production, thereby reducing the availability of food for organisms higher up the food chain. Suspended solids can impact benthic invertebrates by changing the suitability of their substrates, by increasing drift, and by impacting their respiration and feeding activities. Suspended solids can impact fish physiology (e.g. gill function, and immunity), habitat, migration, predation and food availability (Dallas & Day 2004).

Although difficult to elucidate without further investigation, poor water quality (especially the + 2- - high EC and concentrations of Na , SO4 and NO3 ) almost certainly contributes to the regular observation of dead fauna in the Study Area (Figure 6-31). Within the contaminated portion of the Study Area, during the 2015 field survey, NSS found a dead mongoose and more than six dead birds including scavenger species such as the Pied Crow (Corvus albus). During the 2017 field survey, NSS found several dead water birds including cormorants, and during the 2018 field survey, NSS again found several dead birds and a dead Water Mongoose (Atilax paludinosus). Further investigations including an ecotoxicology study are required to explain and mitigate the observed mortality of birds and mongooses in the Study Area.

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Figure 6-31 Dead birds and a Water Mongoose found during NSS surveys in the Study Area

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6.2.3 Vegetation In addition to impacts of the effluent discharge, vegetation in the Cowle’s Stream wetland and its catchment has also been impacted by past crop cultivation, industrial and mining activities, and uncontrolled invasive alien flora, livestock activity and wild fires.

Invasive alien flora are perhaps of greatest current concern given their potential to spread far beyond the Study Area, causing: unnatural loss of water within the catchment; loss of native plant diversity; structural vegetation changes; changes to the natural incidence and intensity of wild fires; increased soil erosion and sedimentation; and degradation or loss of faunal habitats.

Note that under NEM:BA, Category 1 invasive alien species now include Verbena bonariensis and V. brasiliensis, which were recorded all along the trench line from the Mine to Cowle’s Dam. Category 1 also includes Eucalyptus species in the Grassland Biome. These and other Category 1 species in the Study Area, such as Cirsium vulgare and Arundo donax, should be incorporated in an Invasive Alien Control Plan for effective control by Gold One.

6.3. Wetland Ecosystem Services Although the artificial wetland created by Gold One has no natural functions, it assists the Mine with attenuating the flow and slightly improving the quality of the discharge water. If the recommended piping of treated water does not occur then both of these functions could be enhanced, should the discharge of effluent continue (refer to NSS 2017 Reports Management Plan). It was recommended that Gold One take water samples immediately up- and downstream of the artificial wetland to properly assess it’s apparent role in improving the quality of the discharge water.

Cowle’s Stream has a number of opportunities to supply ecosystem services due to all the disturbances in its catchment. Eco-system services, which were given a High rating included streamflow regulation, and nitrate and toxicant removal. Services scored with a Moderately High rating included flood attenuation, sediment and phosphate trapping, and erosion control. Maintenance of biodiversity was scored with an Intermediate rating to the FEPA status of Cowle’s Stream, which takes into account its entry into the Blesbokspruit Ramsar wetland, and records of threatened water birds in or within 500m of the Stream.

The main eco-service provided by the Blesbokspruit is its provision of habitat for waterfowl and other birds, which was also the main motivation for its declaration as a Ramsar wetland (MacFarlane & Muller 2011). Mharakurwa (2016) reported that “The provisioning services from

Natural Scientific Services CC 55 Wetland Assessment – Gold One: Modder East the Blesbokspruit wetland to the surrounding communities include water used for both domestic and agricultural activities. Both subsistence and commercial farming are taking place along the wetland (crop farming and livestock rearing). The wetland is therefore providing a safety net to disadvantaged households who are able to supplement their food. The wetland is also able to regulate climate change (carbon sequestration and flood attenuation) and water quality due to the presence of vegetation. The wetland also supports high biodiversity (flora and fauna) such as within the Marievale Bird sanctuary. Recreational services of the wetland come from the scenic views noted at both Marievale (picnic spots) and Putfontein (evidenced by children playing and swimming).”

6.4. Wetland Ecological Importance & Sensitivity As explained in Section 4.5, the DWS (2014) has rated the Blesbokspruit with Low Ecological Importance and Moderate Ecological Sensitivity.

Provided in Table 6-2 is the EIS scoring for Cowle’s Stream. Although SAS (2015) scored it with overall Moderate EIS, NSS rated Cowle’s Stream with overall High EIS given: it’s classification as a national Wetland FEPA, based on: its nearby entry into the Blesbokspruit Ramsar wetland; and records of threatened water birds in or within 500m of the Stream; and the Critically Endangered status of the wetland FEPA vegetation type.

Table 6-2 Ecological Importance and Sensitivity of Cowle’s Stream CRITERION SCORE Ecological importance and sensitivity 4.0 (Very High) Hydrological/Functional importance 2.6 (Moderate) Direct human benefits 1.0 (Low)

Although the EIS of the artificial wetland could not be assessed using the same tool, NSS did consider the likelihood of threatened, Protected or otherwise Conservation Important (CI) faunal species occurring in the area.

The only evidence of CI fauna, which was found during NSS surveys in the Study Area, was otter scat. This most likely belonged to the Near Threatened (NT) African Clawless Otter (Aonyx capensis), which appears (NSS pers. obs.) to be somewhat more resilient to degradation and transformation of aquatic habitat compared to the NT Spotted-necked Otter (Hydrictis maculicollis). Given the Seriously Modified hydrology of Cowle’s Stream, it is not certain whether local otters are healthy, resident, successfully breeding and persisting.

Patches of tall, wet grassy habitat in the Study Area provide potentially suitable habitat for the NT Serval (Leptailurus serval), a species that can be surprisingly tolerant of mining and agricultural activity (NSS pers. obs.). There are also at least two records of Serval from the quarter degree square (QDS) 2628AB wherein the Study Area is situated. There is also one

Natural Scientific Services CC 56 Wetland Assessment – Gold One: Modder East record from the QDS of the Endangered (EN) Oribi (MammalMap 2018). Serval and Oribi have similar habitat requirements but high levels of disturbance (especially from hunting dogs) usually preclude Oribi from an area.

The NT Southern African Vlei Rat (Otomys auratus) and NT Swamp Musk Shrew (Crocidura mariquensis) are both generally common along the margins of grassy wetlands, and there are, respectively, at least three and four records of these species from QDS 2628AB (MammalMap 2018). However, it is difficult to predict whether these species would inhabit the fringes of the artificial wetland and Cowle’s Stream, given the quality of the water in these systems. The EN African White-tailed Rat (Mystromys albicaudatus) is considered unlikely to occur given the long history of disturbance in the Study Area.

Breeding within the Study Area by regionally occurring CI bird species is extremely unlikely given its transformed state, and the risks posed by livestock, wild fires, traffic, overhead power lines and other forms of disturbance. At best, the Study Area might be visited by foraging EN African Marsh Harriers (Circus ranivorus), Vulnerable (VU) African Grass-owls (Tyto capensis) and NT Lanner Falcons (Falco biarmicus). Foraging by NT Abdim’s Stork (Ciconia abdimii), NT Bar-tailed Godwit (Limosa lapponica), NT Black-tailed Godwit (Limosa limosa), NT Black- winged Pratincole (Glareola nordmanni), VU Blue Crane (Anthropoides paradiseus), NT Blue Korhaan (Eupodotis caerulescens), NT Curlew Sandpiper (Calidris ferruginea), NT Greater Painted-snipe (Rostratula benghalensis) and VU Secretarybird (Sagittarius serpentarius) is considered unlikely (but not impossible).

In addition to the Study Area’s transformed state and high levels of disturbance, there is limited refuge in the form of termitaria and rocks, for the regionally-occurring NT Striped Harlequin Snake (Homoroselaps dorsalis) and NT Coppery Grass Lizard (Chamaesaura aenea). At best, the rare Aurora House Snake (Lamprophis aurora) and NT Giant Bullfrog (Pyxicephalus adspersus) might occur. Within QDS 2628AB there is one Aurora House Snake record (ReptileMap 2018) and at least four Giant Bullfrog records (FrogMap 2018). Although the artificial wetland provides shallow, standing water with emergent grassy vegetation, the permanency and quality of the discharge water is unlikely to support bullfrog breeding.

The regionally-occurring rare Marsh Sylph (Metisella meninx) and EN Mijburgh’s Blue (Orachrysops mijburghi) are unlikely to occur in the Study Area due to the observed absence of their respective larval food plants Indigofera evansiana and I. dimidiate, and Leersia hexandra.

6.5. Summary Summary baseline descriptions of the artificial wetland and Cowle’s Stream are provided in Table 6-3 and Table 6-4 respectively.

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Table 6-3 Summary baseline description of the artificial wetland ARTIFICIAL WETLAND

Flow Direction

Large areas with surface water run-off, scattered wet vegetation indicators CLASSIFICATION (Ollis et al. 2013) Level 1: System Inland Level 3: Terrain Unit Slope Level 2: Ecoregion 11.03 Level 4: HGM Unit Seep (artificial)

CONSERVATION STATUS Internationally Upstream of Blesbokspruit Ramsar Site Upstream of Blesbokspruit IBA Nationally Wetland HGM Type Not Protected Upstream of a Wetland FEPA Highest Biodiversity Importance and Risk for Mining Provincially Gauteng C-Plan Important Area (CBA 2) SETTING Quaternary catchment C21D Geology Land type Ba1 Well-drained, red, Hydrology Artificially created by the apedal soils of the discharge of effluent from Hutton form overlying Gold One weathering and hard rock and various other unconsolidated materials

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WETLAND INDICATORS

Typha within the trench Juncus within the artificial wetland area CONCERNS  Artificially created due to Gold One effluent discharge  Poor water quality in trench and in areas covered by surface water run-off  Invasive alien flora  Erosion along trench  Evidence of salt precipitate on surrounding disturbed grassland  Road and railway crossings and associated culverts  Leaking sewage pipelines in the Study Area

Salt precipitate in disturbed grassland adjacent to trench

Erosion along trench Large stands of invasive alien Robinia

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Table 6-4 Summary baseline description of Cowle’s Stream Cowle’s Stream

Study Area

Flow Direction

Cowles Dam Downstream of Cowle’s Dam LEVEL 1 TO 4 CLASSIFICATION (Olliset al. 2013) Level 1: System Inland Level 3: Terrain Unit Valley Floor Level 2: Ecoregion 11.03 Level 4: HGM Unit Channelled Valley Bottom Level 2: WetVeg Mesic Highveld Grassland Group 3 CONSERVATION STATUS Internationally Enters Blesbokspruit Ramsar wetland Enters Blesbokspruit IBA Nationally Represents a Wetland FEPA Wetland HGM Type Not Protected CR Mesic Highveld Grassland Group 3 CR Channelled Valley Bottom (≤ 20% of total extent of ecosystem type in good condition) Immediately upstream of the CR Mesic Highveld Grassland Group 4 Highest Biodiversity Importance and Risk for Mining Provincially Gauteng C-Plan Important Area (CBA 2) SETTING Quaternary catchment C21D Geology Land type Ba1 Well-drained, red, apedal soils Slope of Catchment < 3 % of the Hutton form (Hu) Slope of HGM Unit 0.2% overlying weathering and hard Surface and sub-surface rock and various other Hydrology water, with a number of unconsolidated materials artificial surface water inputs

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Cowle’s Stream PRESENT ECOLOGICAL STATE ECOLOGICAL IMPORTANCE AND SENSITIVITY NSS: NSS: Hydrology: E (Seriously Modified) C (Moderate), based on: Geomorphology: D (Largely Modified)  Wetland FEPA status. Vegetation: D (Largely Modified)  CR WetVeg.  Proximity to the Blesbokspruit Ramsar wetland.  Records of threatened water bird species in or within 500m of Cowle’s Stream. DWS (2014): D (Largely Modified) DWS (2014) ratings for the Blesbokspruit: EI: Low; ES: Moderate MAIN ECOSYSTEM FUNCTIONS High rating: streamflow regulation; nitrate and toxicant removal. Moderately High rating: flood attenuation; sediment and phosphate trapping; erosion control. All of the services that scored High or Moderately High scored higher for opportunity than for effectiveness, due to the system’s high level of disturbance. Maintenance of biodiversity scored an Intermediate, mainly due to the FEPA status of the wetland, the downstream Ramsar wetland and the records of threatened water birds at or within 500m of this wetland. WETLAND INDICATORS

Phragmites (2017) Juncus (2015) CONCERNS  Numerous large and small dams, e.g. the Cowle’s and Alexander dams  Heavy industry adjacent to the system, for example Gold One, SAPPI Enstra, Geduld Proprietary Mines and a number of other current and historical mining operations  Discharge of effluent from adjacent industries, resulting in poor water quality  Numerous road and railway crossings and associated culverts  River diversions  Increased stormwater run-off and peaks due to hardened surfaces in the catchment  A number of waste water treatment works discharging into the system  Leaking sewage pipelines in the Study Area

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Cowle’s Stream

Excavation within the channel Excavations / Infilling

Leaking sewage pipes Stream diversion, mining and human settlement

Railway lines, roads and culverts intersecting the system Numerous in-stream dams

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7. Impact Assessment

In this report section, historical wetland impacts are briefly mentioned, followed by a summary of current observed impacts in the Study Area, and a full assessment of potential impacts of the proposed pipeline to transfer Mine effluent directly to Cowle’s Stream.

7.1. Historical Impacts

7.1.1 Mining Local topography and hydrological characteristics suggest that a natural seep was present in the Study Area prior to mining. Subsequently, aerial imagery from the 1960’s (Figure 4-1) shows that the Study Area was covered almost entirely by mine tailings. Indeed, most of where Gold One currently stands was previously a large tailings facility. The tailings evidently drained directly into the Blesbokspruit via Cowle’s Stream, with probable deleterious consequences for aquatic biodiversity.

7.1.2 Crop Cultivation Portions of the Study Area that were not previously under tailings were cultivated. Collectively, cultivation and mining destroyed natural vegetation, and drastically altered natural soil and hydrological regimes in the Study Area. Cultivation has since stopped, and within the fallow crop fields, weedy and invasive alien flora have established. Probable past application of fertilizers, pesticides and other agricultural substances likely altered natural soil composition in the Study Area.

7.2. Current Impacts Photographs of observed impacts in the Study Area are provided in Figure 7-1.

7.2.1 Livestock Farming Livestock were observed during all NSS surveys and their presence in the Study Area is concerning. The water in Cowle’s Dam and elsewhere in the Study Area is unfit for consumption, and the livestock are aggravating the degraded state of the local environment through over-grazing, trampling, erosion and the eutrophication of water resources from manure.

7.2.2 Harvesting of Natural Resources During the NSS 2018 survey a number of snares were found and removed from the Study Area. These were likely meant to catch Bushpig (Potamochoerus larvatus), which appeared to be abundant in the Study Area based on numerous observed signs of their presence. However, other wildlife such as small antelope, porcupines, otters and mongooses are susceptible to capture by these indiscriminate traps.

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7.2.3 Degraded Water Quality Numerous dead birds and dead mongooses were found during NSS surveys in the Study Area, which is likely attributable to the toxicity of local surface water. The evaluated water quality data (discussed in Section 6.2.2) indicate that, in spite of marginal improvements following the treatment of underground water with lime, Mine effluent entering Cowle’s Stream is still contaminated with a number of constituents that are exceeding Blesbokspruit and/or 2- - TWQR guidelines unacceptably. These include pH, EC, SO4 , NO3 and NH3. Following treatment, the previously neutral pH of the effluent is now unacceptably alkaline which, inter alia, can convert non-toxic ammonium to highly toxic ammonia. EC and salt loads remain unacceptably high and precipitated salt is clearly visible in the artificial wetland downstream of the Mine. High levels of salt affect the buffering capacity of water and, in turn, the metabolic rates and basic osmoregulation requirements of aquatic organisms. Non-halophytic wetland vegetation is also adversely affected by high salt loads. This is evident in the Study Area where natural wetland vegetation is absent in places with obvious salt precipitation. According to Gold One (pers. comm.) the nitrate concentrations in the discharge water will be reduced when nitrate-contaminated water in an underground compartment is pumped for use in a closed system of mine process water.

7.2.4 Increased Flow Volumes Surface water flow in the Study Area has been greatly altered primarily by the high volumes of effluent discharge, but also by trenches, other excavations, culverts, and infilling. The increased flow volumes from mine and sewage effluent have ultimately altered the hydrology of the Blesbokspruit, effectively drowning a once narrow, hydromorphic grassland stream (pre- 1930), and turning it into a permanent wetland colonized by reeds such as Typha and Phragmites. This drowning effect has been hardest felt by the wading birds which, according to Coordinated Waterbird Counts, once congregated in vast numbers along the system, but have since declined following the rising waters.

7.2.5 Invasive Alien Flora There has been uncontrolled proliferation of invasive alien flora in the Study Area in the wake of its long history of disturbance from mining and crop cultivation. Patches that are permanently inundated by surface water are characterised by Pennisetum clandestinum and Arundo donax, while species such as Cirsium vulgare, Bidens pilosa, Tagetes minuta and Robinia pseudoacacia occur in most other areas.

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Excavation of trenches

Discharge of Mine effluent

Precipitation of excessive salt

Excavations and infilling Figure 7-1 Examples of current disturbances in the Study Area

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7.3. Future Impacts The proposed pipeline route from the Mine to Cowle’s Stream is shown in Figure 6-2, which indicates that the pipeline will largely run along the eastern boundary of the artificial wetland. The significance rating of each future potential impact, with and without mitigation, is shown in Table 8-1.

7.3.1 Construction: Transport & Storage of Materials & Equipment

Impact: Wetland disturbance as a result of the transport and storage of construction materials. Transport and storage of construction materials on site has the potential to negatively impact the more natural downstream Cowle’s Stream wetland. Although the artificial wetland is degraded and of comparatively low value (especially in light that it will be effectively drained by the installation of the pipeline) driving and storing materials in this system should also be avoided as they have the potential to indirectly impact upon Cowle’s Stream. The disturbance effects from driving through these wetlands is likely to be intensified following high rainfall events. Soil disturbances from vehicles can trigger the proliferation of invasive alien flora while tyre tracks can leave long standing marks on wetlands. Storage of pipes and other construction materials will inadvertently lead to a die-back of vegetation underlying the laydown area, and may be particularly deleterious if placed within a wetland. Increased soil compaction is likely to accompany laydown and construction areas with the effect of decreasing infiltration, and overall runoff within the wetland systems. Heavy excavation vehicles and other machinery have the potential to contaminate the wetland with petrochemicals and other hydrocarbons, to increase suspended solids and sedimentation, and release toxins which have accumulated in the sediments. The overall significance rating of this impact is considered to be Low.

Mitigation: . Keep the main vehicle access route to the existing two-track road that runs along the eastern boundary. . Clearly demarcate the boundaries of the artificial and natural (Cowle’s Stream) wetland areas on the ground, and sign post them as sensitive ecological areas (see wetland extent and sensitivity maps and request where necessary the spatial /gpx files). Make sure that the boundary for Cowle’s Stream includes a 100m buffer as per the NFEPA guidelines, and that the artificial system receives a precautionary 30m buffer (during construction) based on GDARD’s guidelines for buffers on wetlands outside the urban edge. . Ensure that all construction materials and heavy vehicles are stored at a single designated laydown area situated not only outside of the delineated wetland areas and their associated buffers, but also the 100m or 1:100 year Blesbokspruit floodline - whichever is larger. . Avoid driving to the pipeline construction site following high rainfall events.

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7.3.2 Construction: Site Preparation

Impact: Alteration of wetland sediment regime. Clearing of vegetation, removal of topsoil, and levelling of ground is anticipated to increase the extent of bare ground and hardened surfaces with implications for infiltration, run-off and sedimentation. The overall significance of this impact is considered to be Low, given the small scale of the proposed project and the extent of past soil and vegetation disturbances. However, the potential effects of sedimentation and erosion should be taken seriously given the proximity of the site to the Cowle’s Stream Wetland FEPA.

Mitigation: . Place excavated soil on the eastern side of the pipeline trench (if opting for below ground installation). . Clearly demarcate (on the ground) the construction footprint area and strictly limit all construction activities to within this area. . Keep clearing to a minimum. . Commence (and preferably complete) construction during winter . The use of herbicides is not recommended, and all tree alien plant species should be removed mechanically. . Care must be taken so as to not disturb/destroy any fauna found on site.

7.3.3 Construction: Underground Installation of Pipeline

Impact: Deterioration in wetland integrity as a result of below ground pipeline construction The pipeline will reportedly be constructed below the ground. Alteration of the soil profile within the artificial system and, in the south, the Cowle’s Stream Wetland FEPA is perhaps one of the more significant impacts with implications for vegetation recovery and hydrological regimes. Any disturbance of the soil profile has the potential to have serious consequences on the water distribution and retention patterns of any wetland, by disrupting both the vertical infiltration and horizontal movement of water through the system. Additionally, trenches excavated for the pipeline are likely to fill, as water seeps in from the saturated wetland soils. This is likely to result in a slight and temporary decrease in hydrological zonation, as water is channelled into the trench effectively draining the wetlands. If left unfilled or if the soil profile is returned incorrectly, this drainage effect may be permanent. NSS has frequently observed that in areas where soil horizons have not been replaced in the correct order (nutrient poor anoxic clays below humus rich top soils) vegetation recovery is severely impaired or non-existent. Additionally, soil disturbances of this nature are almost invariably associated with a longstanding proliferation of invasive alien flora.

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Degradation of wetland integrity from disturbance of the soil profile during underground installation of the pipeline has been rated with High significance.

Mitigation: . Currently the pipeline is planned to be installed below ground. For wetlands this is considered less preferable to above ground alternatives which do not impact as adversely on the hydrology, soil profile and vegetation of the wetland. If an above ground pipeline option is feasible NSS would advocate this over below ground. . If below ground - ensure that all soil removed is carefully stockpiled and returned in the same order it was removed . Ensure that trenches remain open for as brief a time as possible . Appropriately deal with ingress water into the trench by pumping using sandbags to minimise erosion from overland flow.

7.3.4 Operation: Use & Maintenance of Pipeline Service Road

Impact: Wetland disturbance as a result of pipeline maintenance The construction and operation of the service road along the pipeline route is likely to be associated with increased soil compaction, surface runoff, vegetation trampling and dust deposition. These impacts are likely to be accompanied by a decrease in water infiltration and retention time within the wetland, an increased concentration of storm flows and consequently increased prevalence of erosion and proliferation of alien and invasive vegetation. Additionally the use of dust suppressant chemicals when spraying roads poses as threat of wetland contamination. Given the presence of existing service roads to the east of the proposed pipeline route this impact is considered to be of Moderate significance.

Mitigation: . Ensure, if the service road crosses a delineated wetland or drainage feature, that the appropriate culverting systems are installed. . Clearly mark the start and exit of the Cowles wetland system with signage. This is to inform the construction contractors that they are entering a wetland area and as such, should not store construction materials within it, minimize disturbances and not contaminate it. . Switch off dust suppression sprayers when passing into a wetland system.

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7.3.5 Operation: Discharge of Mine Water through the Pipeline

Impact: Deterioration in wetland integrity as a result of flow modifications The maximum volume of treated water to be discharged is reportedly not likely to exceed 20 Mℓ per day at steady state. This water is currently entering the Cowle’s Stream via diffuse flow through the artificial wetland. In theory, provided the water quality being discharged into the artificial wetland is of an acceptable standard, a setup such as this would be an ideal situation, since flows would be effectively attenuated, dissipated and dispersed, while toxicants and nutrients would be efficiently removed. However, the reality is that water quality within this system is not of an acceptable standard and the artificial wetland which receives the effluent is not situated on Gold One’s property. It is also important to understand that although the wetlands provide a service of being a pollution trap they do not have infinite capacities to do so. A decision has been made to pipe the water directly into Cowle’s Stream. The concern is that a once substantial but diffuse flow is now concentrated at a small discharge point. This, together with increased velocities and decreased sediment loads may lead to significant erosion at Cowle’s Stream. The design of the pipeline receiving environment interface is, therefore, important. If the discharge point is inappropriately engineered (i.e. flow energy inappropriately dissipated and attenuated) the high volumes of water may result in significant bed erosion and bank incisement. The likely consequence of such an impact would be a general draining effect, ultimately resulting in a decrease in hydrological zonation and contraction of the outer wetland margin within Cowle’s Stream.

Mitigation: . It is generally preferable to have an outlet enter a wetland in as diffuse a flow as possible before entering the main wetland system. According to the NFEPA Guidelines this is particularly true for outflows entering a FEPA wetland or river, in this case the Cowle’s Stream, which is a wetland FEPA. The guidelines further suggest that outlets spread ensure that the flow is as diffuse as possible and advocate the use of flow attenuation / dispersion structures and / or the use of multiple discharge points. . The final and precise discharge outlet point should, ideally, be chosen strategically following integration workshops between all relevant specialists and carefully engineered, taking cognisance of the various flow related impacts that may result. . There is currently no information regarding the outlet configuration at the discharge point. ideally the outlet pipe should be branched such that the total discharge volume is diverged and each of the branches should discharge over a section of stone pitching/reno mattresses or similar geotextile such as Terratame 2 for energy dissipation and erosion protection. . The discharge points should be landscaped to spread the water as wide as possible to allow the system to vlei out before the active channel of the Cowle’s Stream.

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. Every effort should be taken by the mine to recycle as much of their ground water as possible to limit the amount of flow entering the Cowle’s Stream and the Blesbokspruit. . The discharge point and associated flow attenuation structures must be fenced to prevent direct access of wildlife to the discharge water.

7.3.6 Operation: Contamination

Impact: Deterioration in wetland integrity as a result of contamination Although the quality of the Mine’s discharge water is post-treatment largely within SANS 241 guidelines, several parameters still exceed Blesbokspruit and TWQR guidelines by unacceptable levels (i.e. pH, EC, SO42, NO3, NH3). The high concentration of nitrates is not anticipated to pose a risk to receiving aquatic systems because the mine water accumulations that are rich in nitrate will reportedly be used in closed mine workings (whereas the pools that are lower in nitrates will be discharged).

This approach (below ground treatment with lime) although beneficial in some regards, poses a number of risks. Most notable is that without a properly engineered pollution control dam the ability to promptly detect and importantly isolate and treat major spikes in pollutant levels are limited. As it stands direct discharges of pollutants at the anticipated flow rates with the current treated quality have the potential to have major consequence for the Cowle’s Stream and Blesbokspruit let alone should there be a spike or change in contaminant levels. Contamination may be exacerbated through inadequate maintenance of the underground water treatment facility and discharge pipeline resulting in leaks and erosive overland flow.

An ever present threat associated with gold mining water is contamination through acid mine drainage or AMD. This may arise from tailings seepage or from collection of water in the shaft. In terms of the former it should be noted that a stormwater infrastructure plan has been designed around the tailings and waste rock dumps to capture any runoff (in lined V-drains) from these facilities and direct it into pollution control dams. With regards to the latter, communications with Prime Resources suggest that underground water is being treated with Lime. Certainly the analysis of the data shows that the treated water is no longer acidic but rather alkaline. As such, so long as the water is treated in this way and its pH carefully monitored (with lime adjusted accordingly), AMD should not be a cause for concern during operation. However, without implementation of a thorough mine closure plan, AMD may arise post closure in the water that may collect in the shaft or from tailings runoff following rainfall events. Contamination of the receiving wetlands through these various means will result in further eutrophication of the soils, loss of aquatic biota and the increased prevalence of E. coli, cholera and other waterborne diseases and pathogens.

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Mitigation: . The potential for wetland contamination should be taken seriously given the presence of the FEPA and Ramsar listed receiving wetlands and downstream, Marievale Bird Sanctuary which supports globally significant congregations of waterfowl. As such it is recommended that the opinion of an appropriately qualified ecotoxicologist be sought with regards to the potential effects of the discharge water on wildlife. . The strongly alkaline pH, high salt loads and elevated ammonia levels are still unacceptable for the Blesbokspruit aquatic ecosystem despite the underground treatment efforts and still pose a risk to aquatic health. This needs to be addressed before urgently. . Ensure all water treatment facilities and pipeline infrastructure is regularly maintained. . Test water quality underground and at the discharge point weekly. . Ensure that water quality parameters comply with water use licence requirements and include all parameters usually analysed for gold mining. . Compile a Spill Contingency and Emergency Response Plan that deals with spills into the wetland systems and associated Rietspruit. . Appropriately dispose all flocculent or polluted water as per the water use license requirements. . Compile a thorough mine closure plan that takes deals with the potential for contamination of wetlands with acid mine drainage or any other pollutants as a result of mine decant, mine seepage into groundwater aquifers and tailings or pollution control dam seepages. This plan should include monitoring of water quality at boreholes and at the current water quality sampling sites.

7.3.7 Operation – Fate of the Artificial Wetland

Impact: Potential positive impact for the restoration of a long lost wetland Although mining predates any evidence in the form of historical imagery, the topography and prevailing hydrology of the site (where the current artificial wetland stands) suggests that a natural wetland, albeit far smaller and less saturated, once existed there. As such it is our opinion that in spite of the diversion of mine effluent via a pipeline directly to Cowle’s Stream, a wetland (albeit narrower and less saturated) will still persist on site. Consequently there remains the potential to support, encourage and restore the integrity of this system such that it contributes positively to the Blesbokspruit environment as a whole. Conversely, left as is, the system will likely continue to be represent a dangerous sink for local biodiversity (or livestock and people) due to its levels of contamination.

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Mitigation: If not yet the case, Gold One needs to comply with the National Environmental Management: Waste Act (NEM:WA; Act 59 of 2008) - particularly Part 8 of Chapter 4 (the “Contaminated Land Provisions”) and within this, notably Section 36(5). It is advisable that a contaminated land assessment be done within the artificial wetland and a report be compiled in association with environmental engineers and wetland ecologists or ecotoxicologists to ascertain whether the artificial wetland will, following pipeline construction, still pose a threat to the environment. If so, as per NEM:WA, the report should be submitted to the Minister or MEC acknowledging that a contamination event has occurred and respond to the remediatory stipulations as set for in the issued notice.

If a clean-up is required it is suggested that it be done during winter and only after a year of pipeline operation to allow saturation levels to recede. The main activities should include: . Removal of contaminated topsoil layer particularly where salt precipitation is highest. Dispose at an authorised waste disposal facility such as Holfontein. . Basic landscaping in the form of scraping, levelling and contouring to create a very shallow system (almost indiscernible channel) that slopes gradually toward Cowle’s stream, widening as it enters it. . Remove all trenches and furrows during landscaping. . Plough the land, where possible, with a rotovator or similar seed bed preparation tilling practice after landscaping to aerate the soil. . Restoration efforts should take place in stages whereby certain portions of the wetland are restored at a time. This may help to prevent wildlife kills in downstream systems as a result of the disturbance of large amounts of anoxic and toxic sediments. . Provided a topsoil layer is present re-vegetation should occur naturally within noticeable improvements in cover within a year. However succession should be monitored and seeding or sod planting as well as bank stabilisation (pegged hessian and fibre logs) be implemented where necessary. Only use locally indigenous wetland seed mixes and whole plant transplanting. . If there appears to be early signs of erosion pile up low ridges of soil across the wetland with the excavator to aid in pooling or create fibrous logs (hessian rolls with soil and non- weedy vegetation inside) and place across the wetland. Fill any erosion gullies as soon as possible and encourage plant re-growth using pegged hessian and compost where necessary.

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7.3.8 Decommissioning: Removal & Rehabilitation of Pipeline Infrastructure

Impact: Potential positive impact associated with decommissioning and rehabilitation. Decommissioning and removal of pipeline infrastructure together with landscaping, contouring, soil preparation, and revegetation of any impacted wetlands will have a net positive impact on in situ and downstream wetland areas.

Mitigation: . Remove all pipeline infrastructure. . If a service road was created, till it with a rotovator to loosen the soil surface. . Remove any culverts, gabions, concrete slabs or flow attenuation structures that were constructed. . Landscape and re-vegetate using locally indigenous wetland seed mixes and whole plant transplanting for source material along Cowle’s Stream or the Blesbokspruit.

8. Way Forward

The Ramsar status of the Blesbokspruit is under threat, with the wetland placed on the Montreaux Record in 1996 due to the high salt loads and change in flow in the system (Ambani 2013). Despite Gold One’s recent treatment of underground water with lime, several parameters in the Mine’s 2- - effluent exceed the Blesbokspruit and TWQR guidelines, namely pH, EC, SO4 , NO3 and NH3. Alternative management options for the artificial wetland created by the effluent discharge have been previously recommended by NSS (refer to NSS 2017 Reports Management Plan). Subsequently, in addition to treating its underground water with lime, Gold One proposes to install a pipeline to transfer the discharge water directly to Cowle’s Stream. The impact assessment in this report indicates that with diligent mitigation, the significance of most potential impacts of the proposed pipeline can be reduced to Low.

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Table 8-1 Significance rating of future potential impacts from the proposed pipeline, with and without mitigation No. Receptor / Process/Activity Environmental Impact Magnitude Duration Scale Probability Significance Mitigation and Management Measures Impact Monitoring Resource Impact Effect (M) (D) (S) (P) Mitigation Monitoring Time Rating Value Frame for Monitoring CONSTRUCTION Cowle's Stream Transport and Wetland Negative WITHOUT 6 3 2 4 Medium 44 Keep the main vehicle access route to Commence water quality Twice-weekly and Blesbokspruit storage of disturbance as a the existing two-track road that runs monitoring during construction result of the along the eastern boundary. construction materials transport and (equipment, storage of cement, pipes) construction materials. [WITH] 2 2 1 1 Low 5 Clearly demarcate the boundaries of the Conduct regular site inspection to ensure artificial and natural (Cowle’s Stream) environmental compliance and adherance wetland areas on the ground and to mitigation measures signpost them as sensitive ecological areas (see wetland extent and sensitivity maps and request where necessary the spatial /gpx files). Make sure that the boundary for Cowle’s Stream includes a 100 m buffer as per the NFEPA Guidelines and that the artificial system receives a precautionary 30 m buffer (during construction) based on GDARDs guidelines for buffers on wetlands outside the urban edge. Ensure all construction material including heavy vehicles are stored at a single designated laydown area situated not only outside of the delineated wetland areas and their associated buffers but also the 1:100 year Blesbokspruit floodline or 100 m whichever is larger. Avoid driving to the pipeline construction site following high rainfall events. Cowle's Stream Site preparation Alteration of Negative WITHOUT 6 4 2 4 Medium 48 Place excavated soil on the eastern side Conduct regular site Daily during and Blesbokspruit wetland of the pipeline trench (if opting for below inspection to ensure construction sediment ground installation). environmental compliance regime. and adherance to mitigation measures [WITH] 2 2 1 2 Low 10 Clearly demarcate (on the ground) the construction footprint area and strictly limit all construction activities to within this area. Keep clearing to a minimum. Commence (and preferably complete) construction during winter The use of herbicides is not recommended, and all tree alien plant species should be removed mechanically. Care must be taken so as to not disturb/destroy any fauna found on site.

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No. Receptor / Process/Activity Environmental Impact Magnitude Duration Scale Probability Significance Mitigation and Management Measures Impact Monitoring Resource Impact Effect (M) (D) (S) (P) Mitigation Monitoring Time Rating Value Frame for Monitoring Cowle's Stream Installation of Loss and Negative WITHOUT 8 5 2 5 High 75 Currently the pipeline is planned to be Conduct regular site Daily during and Blesbokspruit pipeline – below deterioration in installed below ground. For wetlands this inspection to ensure construction ground wetland integrity is considered less preferable to above environmental compliance as a result of ground alternatives which do not impact and adherance to below ground as adversely on the hydrology, soil mitigation measures pipeline profile and vegetation of the wetland. If construction an above ground pipeline option is feasible NSS would advocate this over below ground. [WITH] 4 2 1 1 Low 7 If the pipeline must be installed below Check open trenches for ground the reason for doing so should be trapped animals strongly justified. In such an eventually ensure that all soil removed is carefully stockpiled and returned in the same order it was removed Ensure that trenches remain open for as brief a time as possible Appropriately deal with ingress water into the trench by pumping using a sandbags to minimise erosion from overland flow OPERATION Cowle's Stream Use and Wetland Negative WITHOUT 5 5 2 4 Medium 48 Ensure if the service road crosses a Conduct regular Weekly during and Blesbokspruit maintenance of disturbance as a delineated wetland or drainage feature inspections along route, construction pipeline service road result of pipeline that the appropraite culverting systems report on any wetland maintenance are installed disturbances [WITH] 4 4 1 2 Low 18 Clearly mark the start and exit of wetland systems (including their buffers) with signadge Switch off dust surpression sprayers when passing into a wetland system Cowle's Stream Pipeline operation – Deterioration in Negative WITHOUT 9 5 4 5 High 90 It is generally preferable to have an Install guaging point to Once off at and Blesbokspruit routine wetland integrity outlet enter a wetland in as diffuse a effectively monitor flows, start of as a result of flow as possible before entering the keep diligent records. operation flow main wetland system. According to the modifications NFEPA Guidelines this is particularly true for outflows entering a FEPA wetland or river, in this case the Cowle’s Stream which is a wetland FEPA. The guidelines further suggest that outlets spread ensure that the flow is as diffuse as possible and advocate the use of flow attenuation / dispersion structures and / or the use of multiple discharge points. [WITH] 6 4 3 4 Medium 52 The final and precise discharge outlet Conduct water quality As a point should, ideally, be chosen monitoring frequency strategically following integration stipulated in workshops between all relevant WULA specialists and carefully engineered, taking cognisance of the various flow related impacts that may result.

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Every effort should be taken by the mine to recycle as much of their ground water as possible to limit the amount of flow entering the Cowle’s Stream and the Blesbokspruit.

The discharge point and associated flow attenuation structures must be fenced to prevent direct access ofwildlife to the discharge water.

Where possible discharge volumes should be carefully regulated to approximate natural seasonal patterns of high and low flows in summer and winter respectively.

Cowle's Stream Pipeline operation – Deterioration in Negative WITHOUT 10 5 4 5 High 95 The potential for wetland contamination Conductaquatic At least bi- and Blesbokspruit contamination wetland integrity should be be taken seriously given the biomonitoring annualy or events as a result of presence of the FEPA and RAMSAR listed more contamination receiving wetlands and downstream, frequently if Marievale Bird Sanctuary which supports recommended globally significant congregations of in WULA waterfowl. As such it is recommended that the opinion of an appropriately qualified ecotoxicologist be sought with regards to the potential effects of the discharge water on wildlife. [WITH] 6 4 2 4 Medium 48 The strongly alkaline pH, high salt loads Conduct regular water As a and elevated ammonia levels are still quality monitoring in line frequency unacceptable for the Blesbokspruit with the requirements as stipulated in aquatic ecosystem despite the stipulated in the water use WULA underground treatment efforts and still licence pose a risk to aquatic health. This needs to be addressed before urgently. Ensure all water treatment facilities and pipeline infrastructure is regularly maintained. Test water quality underground and at the discharge point weekly. Ensure that water quality parameters comply with water use licence requirements and include all parameters usually analysed for gold mining.

Compile a Spill Contingency and Emergency Response Plan that deals with spills into the wetland systems and associated Rietspruit.

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Cowle's Stream Pipeline operation – Potential positive Negative WITHOUT 8 4 4 4 High 64 Removal of contaminated topsoil layer Monitor progress of At least three and Blesbokspruit fate of the artificial impact particularly where salt precipitation is restoration and vegetation years (DWA wetland associated with highest. Dispose at an authorised waste succession on a monthly standard) decommissioning disposal facility such as Holfontein. basis. Adapt efforts where and nessasary to stem erosion rehabilitation or encourage plant growth. Positive [WITH] 1 5 1 1 Low 7 Basic landscaping in the form of scraping, levelling and contouring to create a very shallow system (almost indiscernible channel) that slopes gradually toward Cowle’s stream, widening as it enters it. Remove all trenches and furrows during landscaping. Plough the land, where possible, with a rotovator or similar seed bed preparation tilling practice after landscaping to aerate the soil. Restoration efforts should take place in stages whereby certain portions of the wetland are restored at a time. This may help to prevent wildlife kills in downstream systems as a result of the disturbance of large amounts of anoxic and toxic sediments.

Provided a topsoil layer is present revegitation should occur naturally within noticeable improvements in cover within a year. However succession should be monitored and seeding or sod planting as well as bank stabilisation (pegged hessian and fibre logs) be implemented where necessary. Only use locally indigenous wetland seed mixes and whole plant transplanting. If there appears to be early signs of erosion pile up low ridges of soil across the wetland with the excavator to aid in pooling or create fibrous logs (hessian rolls with soil and non-weedy vegetation inside) and place across the wetland. Fill any erosion gullies as soon as possible and encourage plant re-growth using pegged hessian and compost where necessary.

DE-COMMISSIONING Cowle's Stream Removal and Positive impact Positive WITHOUT 4 5 2 5 Medium 55 Remove all pipeline infrastructure Monitor progress of Three years and Blesbokspruit rehabilitation of associated with rehabilitation (DWA pipeline decommissioning standard) or infrastructure and as otherwise rehabilitation stipulated by DWA [WITH] 2 4 1 2 Low 14 If a service road was cretated till it with a rotovator to loosen the soil surface Remove any culverts, gabions, concrete slabs or flow attenuation structures that were constructed. Landcape and revegetate using locally indigenous wetland seed mixes and whole plant transplatting for source material along Rietpruit.

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