Environmental Management Plan

NAME OF APPLICANT: Platinum Group Metals (RSA) (Pty) Ltd. (“PTM”)

REFERENCE NUMBER: LP30/5/1/1/2/10805PR

ENVIRONMENTAL MANAGEMENT PLAN

SUBMITTED IN TERMS OF SECTION 39 AND OF REGULATION 52 OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002, (ACT NO. 28 OF 2002) (the Act)

STANDARD DIRECTIVE

Applicants for prospecting rights or mining permits, are herewith, in terms of the provisions of Section 29 (a) and in terms of section 39 (5) of the Mineral and Petroleum Resources Development Act, directed to submit an Environmental Management Plan strictly in accordance with the subject headings herein, and to compile the content according to all the sub items to the said subject headings referred to in the guideline published on the Departments website, within 60 days of notification by the Regional Manager of the acceptance of such application. This document comprises the standard format provided by the Department in terms of Regulation 52 (2), and the standard environmental management plan which was in use prior to the year 2011, will no longer be accepted. 3

IDENTIFICATION OF THE APPLICATION IN RESPECT OF WHICH THE ENVIRONMENTAL MANAGEMENT PLAN IS SUBMITTED.

ITEM COMPANY CONTACT DETAILS

Name Platinum Group Metals (RSA) (Pty) Ltd. (“PTM”) Tel no +27 (011) 782 2186 (Ext. 200) Fax no: +27 (011) 782 4338 Cellular no 082 448 8955 E-mail address [email protected] Postal address Postnet Suite No. 81, Private Bag X12, Rooseveltpark, 2129

ITEM CONSULTANT CONTACT DETAILS (If applicable) Name Digby Wells Environmental Tel no +27 (011) 789 9495 Fax no: +27 (011) 789 9498 Cellular no 082 332 1717 E-mail address [email protected] Postal address Private Bag X10046, Randburg, 2125

1 REGULATION 52 (2): Description of the environment likely to be affected by the proposed prospecting or mining operation

1.1 The environment on site relative to the environment in the surrounding area. Platinum Group Metals (RSA) (Pty) Ltd. (the Applicant) applied for various Prospecting Rights for five (5) years in terms of Section 16 of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) (MPRDA). The term ‘Project Area’ used within this report refers to the entire area which includes the following prospecting right applications:  LP30/5/1/1/2/10667 PR;  LP30/5/1/1/2/10668 PR;  LP30/5/1/1/2/10804 PR;  LP30/5/1/1/2/10805 PR;  LP30/5/1/1/2/10809 PR; and  LP30/5/1/1/2/10810 PR. The specialist studies conducted for this Environmental Management Plan (EMP) covered the entire project area as a whole and not only focussing on this specific prospecting application area. The prospecting application area applied for (LP30/5/1/1/2/10805 PR) includes the following farms:  BONNE ESPERANCE 356 LR;  TOO LATE 359 LR;  MONT BLANC 328 LR;  NIEUWE JERUSALEM 327 LR;  GALLASHIELS 316 LR;  SWEETHOME 315 LR;  BLACKHILL 317 LR;  BOGNAFURAN 318 LR;  LEIPSIG 264 LR; AND  THE PARK 266 LR. The prospecting area is located on the Northern Limb of the Bushveld Complex (“BC”). The proposed prospecting area is located in the Limpopo Province approximately 60 km north east of Marken and falls within the jurisdiction of the Capricorn District Municipality and the Blouberg Local Municipality (BLM). 5

The total area applied for measures approximately 22209.51 hectares. Refer to Plan 1 (Appendix A) indicating the locality of the proposed project area as well as the specific prospecting application area. The Regulation 2(2) Plan indicating the prospecting application area is also attached in Appendix A to this document. Current prospecting activities are taking place to the south of the application area on the farm, KETTING 368 LR. 6

1.1.1 Socio-Economic Baseline Profile A desktop Social Impact Assessment (SIA) Report is attached as Appendix B to this Document. The information presented below was obtained from the SIA. The project area cover a total of 44 farms that form a contiguous area of about 1 155 km2 (Refer to Plan 1, Appendix A). The project area straddles the border of the Blouberg and Mogalakwena Local Municipalities in Limpopo Province. The greater part of the project area falls within the Blouberg municipal area, with only 77 km2 (about 7%) falling in Mogalakwena. 1.1.1.1 Regional Profile Blouberg Local Municipality is one of five local municipalities comprising the Capricorn District Municipality – the other four being Aganang, Modemole, Lepelle Nkumpi and Polokwane Local Municipalities. The local municipality covers a total of 9 248 km², and its largest population centre is the town of Alldays, situated some 45 km to the north of the project area. Mogalakwena Local Municipality, with an area of 6 166 km², falls within the Waterberg District Municipality. This magisterial district comprises six local municipalities: Mogalakwena, Lephalale, Modimolle, Thabazimbi, Bela-Bela and Mookgopong. Its main population centre is the town of Mokopane (formerly Potgietersrus), situated about 100 km to the south of the project area. Demographics Key demographic and social indicators relating to the Blouberg and Mogalakwena local municipal areas are presented in Table 1 and Figure 1 to Figure 8 below. As can be seen from these statistics (which are based on 2011 Census results1), the population of Mogalakwena is nearly twice that of Blouberg, even though it has a smaller surface area. This reflects the more rural character of Blouberg, with the relative absence of large towns and burgeoning economic activity. The population of Blouberg is also slowly shrinking (due in part to rural-urban migration and the effects of the HIV/AIDS pandemic), while that of Mogalakwena shows a slight increase. The conjecture that the municipality is characterised by significant rural-urban migration of its population is supported by the fact that women outnumber men (Figure 4) and that more than half of households are headed by females (Figure 7). These characteristics are also shared by the Mogalakwena population. The two municipal areas share a number of other socio-economic characteristics – e.g. a predominantly young population (with about one-third of the population being under 15 years of age; see Figure 3), high unemployment (Figure 6), a relative scarcity of informal dwellings (Figure 7, central column) and good access to electricity (Figure 8, last column). However, there are other indications that Blouberg is less developed and affluent than Mogalakwena. For instance, education levels in Blouberg are significantly lower than in Mogalakwena, with more than one-quarter of persons over twenty years of age having had no schooling (Figure 5). In addition, access to water and sanitation services in Blouberg is significantly lower than in Mogalakwena (Figure 8). The

1 Statistics South Africa (2012). 7 municipality also suffers from significant backlogs in other services, such as roads, education, health and recreational facilities (Blouberg Local Municipality, IDP, 2011- 2016).

Table 1: Key population statistics

Indicator Blouberg LM Mogalakwena LM

Population (2011) 162 629 307 682

No. households (2011) 41 192 79 395

Average Household Size 3.9 3.9

Figure 1: Population density

Figure 2: Population growth rate per annum (2011)

Figure 3: Age distribution

Figure 4: Sex ratio

Figure 5: Education (over 20 year-olds)

Figure 6: Unemployment rates

Figure 7: Household dynamics

Figure 8: Access to services

Economy As suggested by the statistics presented above, the Blouberg municipal area, as a predominantly rural municipality, encounters economic challenges in terms of high unemployment levels, low education levels, skills mismatch, and insufficient infrastructure to support job creation initiatives. Its relative lack of development is partially due to the fact that it is a mountainous area, with large parts of the municipal area being unsuited for development.

The main economic sectors in the local municipal area are:  Agriculture. The area consists of two economies in the farming sector – the established and commercial (mostly White) farming community, and the less established, subsistence-orientated traditional African farming community. The Strategy identifies even game farming as one of the pillars of the agricultural sector especially the one practiced in areas around Alldays and the surrounding farms. The subsectors of the agricultural sector in the Blouberg area are:2 o Livestock and game farming. Livestock farming is practiced by participants in both the commercial and subsistence levels of the economy, although at varying degrees of intensity. Game farming is mainly practised in the northern and south-western parts of the municipality, including the Alldays, Vivo, Tolwe, Maastroom and Baltimore areas. Private game farms are prevalent in such areas and this has attracted massive tourist influx, especially during the winter hunting season. o Crop and vegetable farming. The area is well known for the production of tomato and potato products that are mainly sold to national and international markets. The fruit of the Marula tree, which is found in abundance in the area, is used to make traditional Morula beer and the world-famous Amarula Cream Liquor.3  Tourism. As mentioned above, the prevalence of game farms has stimulated the area’s tourism industry by attracting large numbers of hunters. The area’s attractiveness as a tourist destination is also partly due to its rich cultural and heritage background, which includes rock art paintings at the Makgabeng Mountains, the Malebogo\Boer battlefields that have been declared a Provincial Heritage Site, the footprints of the missionaries at areas such as Leipzig and Milbank, and the presence of two nature reserves (Malebogo and Blouberg). The area’s potential as a tourism development node is further reinforced by its geographical location between the Waterberg wetlands and the Dongola Trans- frontier Park (which encompasses the Mapungubwe World Heritage Site).  Mining. In addition to the proposed project, a number of mineral deposits have been identified in the local municipal area. These include deposits in areas such as Harriet’s Wish (situated directly to the south of the project area) and Arrie (some 40 km to the north of the project site). There is also significant potential for sand mining within the Blouberg area, especially in areas such as Indermark and Eussorinca. There are mining prospects at Dalmyn, Windhoek- Papegaai, Silvermyn and Towerfontein.4 Despite its relatively undeveloped character, the area, therefore, has some potential for economic growth. This potential is further supported by the municipality’s geographical

2 Blouberg Local Municipality IDP (2011-2016) 3 http://www.golimpopo.com/municipalities/blouberg-.html 4 Blouberg Local Municipality IDP (2011-2016) 12 location – in particular, its proximity to Lephalale, Botswana and Zimbabwe – and the fact that it boasts three border posts (at Platjan, Zanziber and Groblersbrug).5 1.1.1.2 The Project Area Figure 9 shows the main land uses, roads and settlements in the project area. The area is dominated by medium- to low-density rural villages; these are mostly scattered along the north-eastern and southern parts of the project area, with the central part being mountainous and relatively unpopulated. The areas surrounding most villages are dominated by subsistence agricultural fields. Roughly 12 300 ha (11%) of the project area is occupied by settlements, and 25 100 ha (22%) by agricultural fields. Within the prospecting right application area (LP30/5/1/1/2/10805PR), nine (9) communities were identified.

5 Blouberg Local Municipality IDP (2011-2016) 13

Figure 9: Land uses in the project area 14

Visual inspection of satellite imagery of populated areas (the yellow polygons in Figure 9) places the average population density of these areas at 2.1 households per hectare. Multiplying this by the total area covered by settlements gives an estimate of the number of households in the project area – namely, 26 000 households. At an average household size of 3.9 persons per household, this places the total population of the project area at about 101 000 persons. The most densely-populated settlements in the project area are the town of Blouberg (situated in the north-eastern part of the project area) and Indermark (at its extreme north-eastern corner). There are a total of 48 other villages of varying sizes in the project area; these are:

 Bergendal;  Ga-Sebotlane;  Bodi;  Ga-Tshabalala;  Botlokwa;  Keiting;  Broadhill;  Kgatalala;  Brodie Hills;  Kristespruit;  Buffelshoek;  Kwaring;  Callashield;  Matshira;  Carlsruhe Junior;  Mmankgodi;  Dansicht;  Mokerong;  Ditatsu;  Mokudung;  Dithabaneng;  Mokumuru;  Ga-Hlako;  Mongalo;  Ga-Kibi;  Mophamamona;  Ga-Kobe;  Nonono;  Ga-Madibeng;  Polen;  Ga-Malokela;  Sekhung;  Ga-Mamohwibidu;  Sekiding;  Ga-Masekwa;  Sesalong;  Ga-Mmatemana;  Sewale;  Ga-Mokopane;  Springfield Tiekeline;  Ga-Motshemi;  Thalahane;  Ga-Ngwepe;  Tsolametse;  Ga-Nkobo;  Tswatsane; and  Ga-Rawesi;  Uitkyk. 15

There is little evidence of current economic or industrial development in the project area. The area directly opposite its eastern border, however, shows significantly more signs of development. The area is dominated by commercial farming, with large number of pivot irrigation schemes, and also includes the towns of Bochum, Avon and Vivo. The municipal IDP makes mention of the Puraspan-Avon-Indermark-Vivo Corridor, which comprises the D1468 road (running directly past the eastern border of the project area and connecting these towns to one another), as well as the R522 that leads from Vivo to Makhado (formerly Louis Trichardt) some 80 km to the east. Recent upgrading of the D1468 road from gravel to tar has contributed to massive mobility of transport along this corridor. Upgrading of the remaining 10 kilometres of unpaved road is planned (although it is not certain when this will take place), and it is anticipated that this will enable the corridor to act as a link between the Vhembe, Capricorn and Waterberg areas. This may create significant economic spinoffs for the area as a result of the mass movement of people along the corridor. 1.1.2 Climate 1.1.2.1 Temperature Limpopo falls in the summer rainfall region with the western part semi-arid and the eastern part largely sub-tropical. The western and far northern parts experience frequent droughts. Winter throughout Limpopo is mild and mostly frost-free. The climatic conditions vary within the Limpopo Water Management Area (WMA), which ranges from the Waterberg Mountains in the south, northwards to the hot, dry Limpopo River valley on the border with Zimbabwe. The region in general has an average maximum monthly temperature of 26.3°C and an average minimum monthly temperature of 13.0°C (SRK, 2012). 1.1.2.2 Rainfall The largest portion of the province has a mean annual rainfall of between 300 and 500 mm. The south-western part has an annual rainfall of up to 700 mm and in the Lowveld the rainfall can exceed 1 000 mm a year in places. The Blouberg Local Municipality (BLM) is a hot area with annual rainfall varying between 380 and 550mm. Most rainfall is experienced during the summer months. Evapo-transpiration during the rainy season is very high. The area is prone to frequent drought that has an adverse effect on the local economy. The only perennial river is the Mogalakwena River, which feeds the Glen-Alpine dam, which is the only source of pipeline water in the area. (http://www.blouberg.gov.za) The Mogalakwena Local Municipality (MLM) which falls under the Waterberg District Municipality, has a typical summer rainfall climate, receiving the majority of its rainfall in summer with mean annual rainfall of 421 (mm/a) and mean annual run-off of 7 (mm/a) in the period between October and April and having a cool and dry winter. During the rainy season a maximum of 8 to 12 rain days per month is typically expected, whilst in the dry season a maximum of 1 rain day may be expected per month. The rainfall is mainly in the form of thunderstorms. Hail, which is often 16 associated with thunderstorms, does occur during the hot summer months. Frost is rare, and may occur during June or July (SRK, 2012). In accordance with the rainfall patterns the relative humidity is higher in summer than in winter. Humidity is generally highest in February (the daily mean ranges from 64% in the west to above 70% in the east). 1.1.3 Protected Areas and Nature Reserves Several Nature Reserves as well as a National Priority Area is located in the vicinity of the proposed prospecting area. The Wonderkop Nature Reserve is located to the west of the project area and the Blouberg Nature Reserve located to the north. The North Eastern Escarpment National Spatial Biodiversity Assessment (NSBA) Priority Area borders the prospecting right application area towards the north and the northern most section of the prospecting right application area covers a small portion of the North Easter Escarpment NSBA Priority Area. Refer to Plan 2 (Appendix A) indicating the nature reserves and NBSA priority areas identified in the area. 1.1.4 Flora According to Mucina and Rutherford (Mucina and Rutherford, 2006) the project area is located within three major vegetation types (Plan 3, Appendix A). These vegetation types include:  Roodeberg Bushveld (SVcb 18);  Makhado Sweet Bushveld (SVcb 20); and  Soutpansberg Mountain Bushveld (SVcb 21). The proposed prospecting area is characterised as a largely mountainous area with some low lying areas. The vegetation types occurring within the proposed prospecting area are classified as the Soutpansberg Mountain Bushveld occurring on the high lying areas and the Roodeberg Bushveld occurs at lower altitudes. Plan 3 (Appendix A) depicts the vegetation types occurring on the proposed site as well as the surrounding areas. It is expected that the extreme topographic diversity and altitude changes over short distances within the study area result in various microclimates which support high levels of plant diversity. Roodeberg Bushveld (SVcb 18) This vegetation type straddles the Tropic of Capricorn, at an altitude of approximately 850 – 1100 metres above sea level (masl).The vegetation occurs on slightly undulating plains, including some low hills, and comprised of short, shrubby bushveld with a poorly developed grass layer. The area is transitional between the higher lying Polokwane Plateau and the lower lying vegetation units of the Limpopo River Valley. This vegetation type occurs on slightly undulating plains and low hills, with short closed woodland to tall open woodland with a poorly developed grass layer. Rainfall occurs in summer with very dry winters. Mean annual rainfall is about 400 – 550mm. This vegetation type is regarded to be vulnerable. This is due to the south- 17 western half of the unit being densely populated with rural communities. This vegetation type is not regarded to be threatened. Makhado Sweet Bushveld (SVcb 20) This vegetation type straddles the Tropic of Capricorn, occurring on the plains of the Soutpansberg, east of the Waterberg and on the apron surrounding the Blouberg Mountains at an altitude of approximately 850 – 1200 masl. The vegetation occurs on slightly to moderately undulating plains and comprised of short, shrubby bushveld with a poorly developed grass layer. The area is transitional between the higher lying Polokwane Plateau and the lower lying vegetation units of the Limpopo River Valley. Rainfall occurs in summer with very dry winters. Mean annual rainfall is about 350 – 550mm. This vegetation type is regarded to be vulnerable. This is due to the south- western half of the unit being densely populated with rural communities. Soutpansberg Mountain Bushveld (SVcb 21) This vegetation type occurs on the slopes of the Blouberg Mountain, extending from an altitude of 600-1500 masl. There is a dense tree layer and poorly developed grass layer. The topography of the area changes drastically resulting in orographic rain on the southern ridges and rain shadow effect on the northern ridges. Because of this topographic diversity, the Soutpansberg Mountain bushveld comprises of a complex mosaic of sharply contrasting kinds of vegetation within limited areas. The main vegetation variations within the Soutpansberg Mountain Bushveld are subtropical moist thickets (mainly along the lower lying slopes), mist belt bush clumps, open savannah sandveld, and arid bushveld. A high number of endemic and important taxa occur within this vegetation type; Aloe vossi, Huernia whitesloaneaena, Orbea conjuncta, Stapelia clavicorona, Combretum vendae, Vangueria soutpansberensis, Blepharis spinipes, Dicoma Montana, Justicia montis-salinarum, Tylophora coddii, Kalachoe crundallii, Ipomea bisavium, Panicum dewinteri, Streptocarpus caeruleus, Aloe swynnertonnii, Huernia nouhuysii. This vegetation type is regarded to be Vulnerable due to high rural densities resulting in transformation and erosion. 1.1.4.1 Potential Red Data/Protected flora species which could occur in the region According to the PRECIS (National Herbarium Pretoria Computer Information System) eighteen (18) Red Data listed species are expected to occur within the study area; these occur in the Quarter Degree Square (QDS) 2328BA, 2328BB, 2329AA, 2328BC, 2328BD and 2329AC.

Table 2: Expected Red Data Flora Species

Family Species Threat status QDS ACANTHACEAE Blepharis uniflora Rare 2328BB ACANTHACEAE Justicia montis-salinarum Rare 2328BB ACANTHACEAE Justicia montis-salinarum Rare 2329AA APOCYNACEAE Tylophora coddii Rare 2328BB 18

Family Species Threat status QDS ASTERACEAE Berkheya radyeri Rare 2328BB ASTERACEAE Cineraria cyanomontana EN 2328BB ASTERACEAE Dicoma montana. Rare 2328BB ASTERACEAE Senecio hederiformis Rare 2328BB ASTERACEAE Cineraria alchemilloides Rare 2329AA CANELLACEAE Warburgia salutaris EN 2328BB CANELLACEAE Warburgia salutaris EN 2329AA FABACEAE Acacia erioloba Declining 2328BC GESNERIACEAE Streptocarpus longiflorus VU 2328BB HYACINTHACEAE Bowiea volubilis VU 2328BB LAURACEAE Cryptocarya transvaalensis Declining 2329AA POACEAE Panicum dewinteri NT 2328BB POACEAE Sartidia jucunda VU 2328BB POACEAE Panicum dewinteri NT 2329AA 1.1.4.2 Threatened Ecosystems The threatened ecosystem in the area can be described as follows:  Soutpansberg Mountain Bushveld (SVcb 21) is regarded to be Vulnerable due to high rural densities resulting in transformation and erosion. 1.1.5 Fauna The fauna which is expected to occur on site include assemblages within terrestrial and wetland ecosystems: mammals, birds, reptiles, amphibians and invertebrates. Each of these assemblages occurs within unique habitats, the ecological state of these habitats directly relates to the number of species found within them. Animals reported to be found within the Blouberg Nature Reserve, which is adjacent to the study area include various species which are not confined to areas by fences, and, therefore, would be expected to occur within the study area. Two hundred and thirty (230) species of birds have been recorded in the area. Additionally 56 reptile species have been recorded within the area. 1.1.5.1 Fauna species of special concern Three (3) mammal species of concern which occur within Blouberg Nature Reserve, and are expected to occur within the study area, include Leopard (Pathera pardus), Cheetah (Acinonyx jubatus) and Brown Hyena (Hyaena brunnae) (Table 3).

Table 3: Red Data Mammals which are expected to occur within the study area

Scientific Name Common Name Status Acinonyx jubatus Cheetah VU Hyaena brunnea Brown Hyena VU Panthera pardus Leopard NT Nine (9) Red Data listed Birds, which are expected to occur within the study area, are listed in Table 4 below. A Cape Vulture (Gyps coprotheres) breeding colony, hosting more than six hundred and fifty (650) breeding pairs, forms a stronghold for this 19 threatened species [Listed as Vulnerable according to the International Union for Conservation of Nature (IUCN)] in Southern Africa occurs within the adjacent Blouberg Nature Reserve.

Table 4: Red Data Birds which are expected to occur within the study area

Scientific Name Common Name Status Bucorvus leadbeateri Hornbill Southern Ground- VU Circus macrourus Harrier Pallid NT Gyps africanus Vulture White-backed EN Gyps coprotheres Vulture Cape VU Phoeniconaias minor Flamingo Lesser NT Polemaetus bellicosus Eagle Martial NT Sagittarius serpentarius Secretary bird VU Torgos tracheliotus Vulture Lappet-faced VU Trigonoceps occipitalis Vulture White-headed VU 1.1.6 Sensitive Areas No pans/marshlands were identified within the borders of the prospecting right application area. Refer to Plan 4 (Appendix A), indicating the sensitive areas identified in the wider area with 500m buffer zones created around these features. Sensitive landforms will include areas with a unique or sensitive ecological system such as wetlands, ridges and Red Data species habitat.  Ridges/Elevated landscape: Elevated areas within the project area act as a refuge for a number of fauna. Furthermore the high altitude present conditions for specific vegetation growth including many flowering plants, forbs, herbs and succulents. This vegetation is therefore unique to this altitude and, therefore, important to conserve.  Drainage lines: Drainage within the project area acts as an important water source for plant and animal life. These also form wetlands that are protected by various Acts. Drainage lines are habitat for animal life including mammals, birds, frogs and insects. Drainage lines form an integral part of the ecological system and need be conserved where possible in order to maintain ecological functioning.  Forest habitat which may occur within the project area: The adjacent vegetation type (which forms part of the Blouberg Nature Reserve) may occur in fragments within the study area. This would represent a unique habitat for forest flora and fauna. Forests are an important bird habitat and Red Data forest trees may also occur within these areas. Due to the fact that many fruiting trees are found within forests they also present itself as a foods source for mammals.  Mountain slopes: The slopes are vegetated with the Vulnerable Soutpansberg Mountain Bushveld (Mucina and Rutherford, 2006) which is host to a high number of endemic and important taxa. This vegetation type is regarded to be due to high rural densities resulting in transformation and erosion. 20

1.1.7 Land Types, Land Capability and Recommended Land Use Option The land types present in the project area are A, B, D, F and I. Each land type is further sub divided into several sub units. Short descriptions of each land type and land type sub unit are presented in Table 5 below. Also refer to the Land Types Map attached as Plan 5 in Appendix A.

Table 5: Descriptions of land type map units and remarks on dominant soil properties.

Land type map unit Land type sub unit Remarks

A b Mostly red soils (dystrophic and or mesotrofic) soils occur in this land type. Yellow soils occupy less than 10% of the land type area.

e Red high base status soils occur in this land type, the soil depth is greater than 0.3m.

g Shallow red high base status soils occur in this land type, depth is less than 0.3m.

B c Plinthic soils occur covering more than 10% of the land type area. Mostly red eutrophic soils.

d Plinthic soils occur covering more than 10% of the land type area. Mostly yellow eutrophic soils.

D b Duplex clay soils non red in B horizon covering more than 50% of the land type area.

F a Shallow soil containing no lime in the soil profile.

b Shallow soil containing lime in the soil profile.

c Shallow soil containing lime in the soil profile regularly.

I a At least 60% of the landscape is occupied by young soil more than 1m deep. 21

Land type map unit Land type sub unit Remarks

b At least 60 – 80% of the area covered by exposed rock.

c More than 80% of the area covered by exposed rock.

Table 6 contains a summary of the dominant soils present, classified land capability and suggested land use option.

Table 6: Land types, land capability and potential land use of each exploration area

Exploration application Dominating Dominating Classified Suggested number land types soils present land Land use present capability option group

LP30/5/1/1/2/10805PR Ae Ae335 Red and Arable yellow shallow soil (68%)

Ag Red Hutton Arable Poorly soils dominant adapted (60%) cultivation

Fa Rock (43%) Grazing Moderate grazing Red and yellow Hutton and Clovelly shallow soil dominant (27%)

Db Dominated by Arable Poorly heavier adapted Valsrivier clay cultivation soil (70%)

Ib Dominated by Grazing Moderate rock (40%) grazing and shallow soils (20%).

Ic Dominated by Wildlife Wildlife rock outcrops 22

1.1.8 Geohydrology A desktop Groundwater Study was conducted by Digby Wells and the findings are detailed in the section below. 1.1.8.1 Aquifer Type The geology (Refer to Plan 6, Appendix A) of the BLM is predominantly from the Swazian era, consisting of Alldays gneiss, with portions of Mount Dowe Quartzite and Messina Anorthosite, Serpentinite and Pyroxinite. The lithology is described as undifferentiated rocks of various mixed lithologies, predominantly meta-arenaceous rocks. Groundwater occurs in the intergranular and fractured rocks. The MLM area has a thin soil cover of black silt clay that overlies weathered and fractured norite and pyroxenite. The bedrock is weathered to a silt clay or sandy silt between 1 m and 35 m thick. Beneath pockets of weathering, at depths greater than 30 m, slightly weathered, fractured hard rocks, that may contain both the unsaturated and saturated zones, occur. 1.1.8.2 Groundwater Levels Regionally, the water table of the BLM and MLM ranges between 5 – 20 m below ground level and groundwater flow is generally in a south – south westerly direction, at a velocity of less than 1 m/day. The formation below 50 m contains very little water and below 250 m may be considered dry. The numerous fault zones in the Mogalokwena Mining area act as preferential flow paths for groundwater. 1.1.8.3 Groundwater Recharge The estimated recharge in the BLM is between 6.2 (mm/a) and 10.1 (mm/a). Groundwater base flow in the MLM probably recharges the Lephalala River, which runs alongside of the western boundary of the Phahladira cluster, but the relationship between river abstractions and the groundwater potential is not provided in the data available. The estimated groundwater recharge is between 0.038 million m3/annum and 0.047 million m3/a. 1.1.8.4 Borehole Yields Borehole yields within the BLM range between 0.5 – 2.0 l/s. The mean borehole yield in the area is 1.0l/s. The regional hydrogeological map of South Africa indicates that the regional aquifers identified in and around the MLM correspond to intergranular and fractured aquifers with a groundwater potential between 0.5 L/s and 2.0 L/s. 1.1.8.5 Groundwater Use Groundwater is the primary source of water in the BLM area and local communities are dependent on it for domestic purposes, including drinking, cooking and bathing, stock watering and small-scale irrigation. Water is abstracted from boreholes situated in the villages. 23

Although groundwater is the only domestic water source for the BLM, a small volume of 0.001 Million (m3/a) is registered for water supply services. Data indicates that there are only two boreholes in the area which serve the supply area with domestic water. Based on the mean borehole yield (1.0l/s), it is calculated the current domestic abstraction is 0.063 Million m3/a; well below the needs of the Alldays settlement. Water Services records indicate that there are 14 equipped boreholes situated in close proximity to the Alldays settlement, giving a potential estimated abstraction of 0.441 Million m3/a. There are also 11 known windmills in the BLM area, which could indicate and even higher abstraction, although this abstraction would need to be confirmed. The registered volumes include 0.001 Million (m3/a) for urban industry, and 0.650 Million (m3/a) for agricultural irrigation. Groundwater is also utilized for irrigation in the agricultural sector, and for industrial supply within the Alldays settlement. Groundwater supply to the MLM is through well fields and dispersed boreholes. The Planknek well fields provide the Mokopane cluster with an additional 1.6 million m3/annum. These well fields are owned by the Mogalakwena Local Municipality and supplies augmented water to Mokopane and Mahwelereng towns. The Rooisloot well fields supply a small amount of water to Mahwelereng for domestic needs. This well field is located west of Mahwelereng. These boreholes provide an additional 0.2 million m3/annum. It is estimated that 50 additional boreholes will be located in Mokopane/ Mahwelereng and the dense settlements surrounding these towns. The accumulative yield of these boreholes reaches an estimate of 0.76 million m3/annum. Invasive alien plants in the vicinity of Mokopane cluster have a significant impact on the available yield. An additional 0.63 Mm3/annum is registered for irrigational use. The accumulative yield from the Planknek, rooisloot and dispersed equipped local boreholes within the Mokopane cluster provide an available yield of 2.57 Mm3/annum for domestic use. 1.1.8.6 Groundwater Quality The general water quality in the BLM is marginal to poor with mean Total Dissolved Solids (TDS) of 843.8 mg/l. The high salt content reduces water quality, in terms of the South African National Standards (SANS) drinking water quality guidelines, to Class 2 due to elevated chloride, sodium and fluoride. In some cases, elevated magnesium and nitrates reduce the quality further (Class 3). Water quality is influenced by the underlying geology and the impact of human activities in the surrounding communities. There have been no reported water quality problems and no available records in the MLM. There is however a risk that surface water in the Mogalakwena Local Municipality may be affected by the diffuse population from densely populated informal settlements and mines. Specific borehole and well field water quality data is not available. Generally the groundwater quality in the Mogalakwena Local Municipality is threatened by pollution. This is due to mine water decant, the high concentration of pit latrines in certain areas and the naturally occurring fluorides, emulating from the underlining granite. 24

1.1.9 Surface Water 1.1.9.1 Catchment Description The proposed project area is located within the Limpopo Water Management Area (WMA 01) and is located over 4 quaternary catchments namely the A62J, A62H, A63A and A72A (Plan 7, Appendix A). The distribution of the prospecting right application areas in the various catchments is summarised in Table 7 below.

Table 7: Summary of the percentage distribution of the prospecting right application areas within the different quaternary catchments

% PRA area in the total Quaternary Prospecting Area Catchment A72A A63A A62J A62H LP30/5/1/1/2/10667PR & LP30/5/1/1/2/10809PR 0.55 3.04 2.73 LP30/5/1/1/2/10804PR 11.1 1.71 4.79 6.36 1.05 8.67 LP30/5/1/1/2/10805PR 2.19 0.02 LP30/5/1/1/2/10810PR 4.87 13.0 LP30/5/1/1/2/10668PR % of the catchment area covered by the project area 20.2 1.05 18.31 20.52 There are several streams draining the project area boundary which form part of the Limpopo River Basin. These rivers flow towards the Limpopo River which marks the boundary of South Africa and Botswana (Plan 8, Appendix A). The rivers draining the project area are described below:  The Mogalakwena River flows along the Western boundary of the proposed project area in a Northern direction towards the Limpopo River. There is dam on the Mogalakwena River namely the Glen Alpine Dam ;  The Natse/ Seepabana River drain the southern part of the project area in a Easterly to Westerly direction towards the Mogalakwena River;  The Gamamoleka River drains the Northern part of the project area, downstream outside the project boundaries towards the Mogalakwena River;  The Bosehla River drains inside the project area in a North Westerly direction and forms a confluence with the Kubu River (flowing in a South Eastern direction) about 5 km South of Blouberg town;  The Tswatsane River flows along the Eastern side outside the project area towards from South to North in a direction where the Kubu and Boshela Rivers drain; and  The Brakrivier drains the North Western side, outside the project area and is fed by the Tswatsane, Boshela and Kubu Rivers. Other several unnamed non-perennial streams drain the various prospecting right application areas. The perennial and non-perennial streams and rivers were used to further characterise the prospecting areas. A total of 41 subcatchments were delineated (Plan 9, Appendix A) from the river catchments and the catchments sizes determined. The summary of the delineated subcatchments is presented in Table 8. 25

Table 8: Summary of the delineated subcatchments

Subcatchment Area (km2) Subcatchment Area (km2) 1 151 17 40.6 2 119 18 38.7 3 116 19 38.1 4 111 20 37.6 5 94.6 21 37.5 6 89.9 22 35.3 7 89.4 23 33.5 8 86.0 24 31.2 9 76.6 25 31.2 10 74.8 26 29.3 11 64.8 27 28.2 12 56.8 28 24.8 13 55.5 29 23.2 14 48.7 30 20.7 15 44.4 31 19.1 16 44.0 32 18.9 33 17.7 37 12.8 34 14.9 38 12.6 35 14.2 39 7.82 36 13.9 40 6.89 41 5.59 A large number of subcatchments is consistent with the large size of the project area (1 008 km2) and the numerous streams that drain the area. 1.1.9.2 Surface Water Quantity/Hydrology The surface water attributes of the quaternary catchments namely Mean Annual Runoff (MAR), Mean Annual Precipitation (MAP) and Mean Annual Evaporation (MAR) were obtained from the Water Research Commission (WRC) Report No.TT 380/08 (WRC, 2005) as indicated in Table 9. The area is characterised by relatively low proportion of MAP that is converted to runoff. The conversion of MAP to MAR in the four catchments ranges between 1.03 and 1.53%. This indicates that there is a scarcity of surface water within the area as is consistent with the characteristics of the Limpopo WMA.

Table 9: Summary of the surface water attributes of the quaternary catchments of the project area indicating area, MAP, MAR and MAE

Area MAP MAR MAR MAE %MAR Catchment form MAP (km2) (mm) (mm) m3* 106 (mm)

A62J 930 450 6.09 5.66 1 950 1.35

A62H 871 439 6.51 5.67 1 900 1.48

A63A 1 928 433 6.61 12.74 1 950 1.53 26

Area MAP MAR MAR MAE %MAR Catchment form MAP (km2) (mm) (mm) m3* 106 (mm)

A72A 1 908 465 4.79 9.14 1 900 1.03

1.1.9.3 Design Rainfall The extreme event rainfall patterns are determined from the rainfall data collected by the South African Weather Services (SAWS). The data from the rainfall stations located within the catchment (Plan 10, Appendix A) was used to estimate the design rainfall events for the 1: 50 and 1: 100 year event, respectively. The software used is the Design Rainfall Estimation (DRE) in South Africa (Smithers and Schulze, 2003). A representative rainfall station was determined for each of the quaternary catchments. The estimated 24 hour design rainfall and the associated rainfall stations are summarised in Table 10. 27

Table 10: Summary of the rainfall station utilised for the DRE

24 Hr. Design Rainfall Record Quaternary (mm) Station Name SAWS Number Length Latitude (°) Longitude (°) Catchment (years) Represented 1:50 1:100

Kgatalala 0720727_W 64 23.11666667 28.91666667 A72A 192 218

Normandy 0720521_W 32 23.18333333 28.8 A63A 173 196

Oatlands 0720198_W 27 23.28333333 28.6 A62J 185 210

Cromford 0676783_W 45 23.53333333 28.95 A62H 147 166

1.1.9.4 Streamflow Two DWA streamflow measurement gauges within the proposed project area vicinity are located along the Mogalakwena River (Plan 11, Appendix A). The A6H007 is located upstream of the proposed project area whilst the A6H029 is located further downstream adjacent to the proposed project area. The location and data availability for the two stations are summarised in Table 11.

Table 11: Summary of the DWA streamflow measuring gauges location

DWA gauge Stream Gauge Name Latitude Longitude Record Period number

Mogalakwena River A6H007 -23.43712 28.62444 1977 - 1980 @Steiloop

Mogalakwena @Glen A6H029 -23.18415 28.69964 1970 - 2013 Alpine Dam The streamflows at both stations follow similar patterns but with different magnitude peaks. Peaks are observed earlier on upstream point that the downstream point, this can be attributed to the travel time it takes from water to move from upstream to downstream. Where high peaks are observed downstream at the Glen Alpine Dam, this can be attributed to the contribution to streamflow from other tributaries downstream of stream gauge A6H007. The streamflow at A6H029 had sudden peaks whilst that at A6H007 indicated a fluctuating and almost constant peaks hydrograph with more volume at a 95th percentile (Table 12). The hydrograph for the A6H029 was also analysed to determine if there has been changes historical and now. Streamflow for the 1977- 1980 and 2010- 2013 analyses are illustrated in Table 12.

Table 12: Summary of the hydrograph statistics for the streamflow gauges

A6H007 (1977-1980) A6H029 (1977-1980) A6H029 (2010-2013) Streamflow Statistic 3 3 3 m /s m /s m /s

Maximum 125 161 112 50 percentile 0.04 0.65 0.13 75 percentile 1.10 1.38 2.56 95 percentile 60.3 30.8 18.1 The streamflow measured at A6H029 which contains more recent data was plotted to illustrate the hydrograph for the past decade (Figure 10) and indicates seasonal fluctuations in the streamflow.

120

100

40 Streamflow(m3/s)

2004/01/01 2005/07/01 2003/01/01 2003/07/01 2004/07/01 2005/01/01 2006/01/01 2006/07/01 2007/01/01 2007/07/01 2008/01/01 2008/07/01 2009/01/01 2009/07/01 2010/01/01 2010/07/01 2011/01/01 2011/07/01 2012/01/01 2012/07/01 2013/01/01

Time (Calendar date) Figure 10: The streamflow for A6H029 over the 2003-2013 period

1.1.9.5 Surface Water Quality DWA Water Management System (WMS) is a water quality database used to record all water quality data for the sited sampled by the DWA. This database was utilized for the desktop analysis water quality characterization of the project area. The DWA WMS database has several surface water quality monitoring points located within the project area. However for this assessment a selection of sampling sites within the affected quaternary catchments were considered to represent downstream and upstream of the proposed project area (Plan 12, Appendix A) in order to enable the determination of pre-prospecting water quality. The Glen Alpine Dam monitoring site had the longest record of water quality data. The rest of the sites were sampled in 2007 in the winter season (in the months May – July) for a single event, however another site A62 1000004250 was sampled in 2009 in the wet season. These results would therefore not depict the present water quality status except for the Alpine Dam. The water quality results from the database were benchmarked against the South African National Standards (SANS) 241: 2011 Drinking Water (SANS, 2011) and analyzed in Windows Interpretation System for Hydrogeologists (WISH). A summary of the DWA water quality sites and the parameters that exceeded Class II water quality levels are illustrated on Plan 13 (Appendix A) – Water Quality Parameters Exceeding SANS 241. 30

1.1.9.6 Surface Water Use The DWA has a Water Users Registration management Systems (WARMS) database for each of the WMAs and quaternary catchments. This database indicated that there are various water uses per quaternary catchments (Table 13).

Table 13: Summary of the registered water uses and water sources for the catchments

Quaternary Water Source Comment Catchments Type

A62H Borehole All water uses registered

Borehole For irrigation and watering livestock A62J

Spring/eye For irrigation water uses

Scheme For irrigation water uses

Borehole Agriculture irrigation and water supply services A63A Non-urban industry using the Mogalakwena River and River/stream irrigation agriculture using the Mutale River Scheme Irrigation agriculture scheme All the identified six water uses are supplied water from A72A Borehole boreholes

River/stream River and stream water uses are all for irrigation agriculture Dam Dams are used for irrigation agriculture The WARMS data was filtered to determine the surface water users in the catchments associated with the PRA (Plan 14, Appendix A). The surface water uses identified from the WARMS database are:  Agriculture (for Irrigation);  Agriculture (Livestock watering);  Industry (Non-urban);  Industry (Urban);  Schedule 1 (Domestic use); and  Water Supply Service. Table 14 is a summary of the number of registered users per surface water use as filtered from the WARMS database.

Table 14: Summary of the registered and active surface water users per catchment

Quaternary Catchments % Water Uses Allocation Registered Water Uses A62H A62J A63A A72A Agriculture: irrigation 3 20 8 Industry (non-urban) 1 31

The predominant surface water use is irrigated agriculture in the catchment A63A while the least water use is non-urban industry in catchment A63A. Table 15 is a summary of the volume range for the registered water users per water use in each of the quaternary catchments. This data indicates that there were no registered surface water users in subcatchments A62H. From the water uses, agriculture is the highest surface water abstracter with a maximum abstraction in catchment A63A (806 000 m3/yr).

Table 15: Summary of the registered abstraction volumes for the surface water uses

Agriculture: irrigation Industry (non-urban) Quaternary Catchment 3 3 (m /yr.) (m /yr.)

A62H

A62J 13 800 - 55 800 A63A 18 600 - 806 000 49 000 A72A 4 170 - 792 671 1.1.9.7 Geology and Paleontological Potential The project area is dominated by sedimentary rocks of the Matlabas Subgroup of the Waterberg Group. The Waterberg Group is of Mongolian age (2 070 to 1 080 mya) and is predominantly arenaceous (consisting of sand or sand-like particles). The Makgabeng Formation of the Matlabas Subgroup is a large-scale trough with planar cross-beds of fine-medium grained sandstone which area Aeolian in origin. The Makgabeng Plateau in the project area and is one of the most interesting geological phenomena in the Soutpansberg area. The scientific geological research of the mid-1970s proposed that the rocks of the Makgabeng Plateau were deposited in a desert environment. This idea is supported by more recent work which shows that the Makgabeng rocks have been deposited under sub-aerial (wind-blown) conditions as opposed to sub-aqueous (water driven) conditions (Eriksson, Simpson, Eriksson, Bumby, Steyn, & Sarkar, 2000; Simpson, Eriksson, Eriksson, & Bumby, In press). An example of these geological features were identified during the Heritage Screening Assessment (HAS) and illustrated in Figure 11 and Figure 12 below. 32

Figure 11: Example of palaeodune deposited during a desert conditions in the Makgabeng

Figure 12: Detail of palaeodune, note the striation evident, indicative of windblown sand deposit

In addition, evidence of playa lakes within the Makgabeng strata where trace fossils of cyanobacteria were discovered in the playa lake deposits (Eriksson, Simpson, Eriksson, Bumby, Steyn, & Sarkar, 2000). Important fossil deposits in the south-western sections of the Study Area (i.e. greater regional study area) include the plant fossils associated with the Ecca Group of the Karoo Supergroup and Plio-Pleistocene hominin fossils found in the prehistoric cave fills in the dolomitic rocks at Historic Cave (part of the Makapans Cave complex) north of Mokopane and about 85 km south of the project area. The sedimentary Kransberg Group rocks are considered sterile of any macrospcopic fossils due to the 2 070 mya to 1 080 mya age range of these rocks (Durand, 2013). 33

1.1.9.8 Pedological Background, Land Capability and Land Use A desktop pedological study was completed by Digby Wells for the proposed project area. Land type data represents generalised soil patterns and terrain types for South Africa published in the form of maps with a scale of 1:250 000. Data was collected from the Agricultural Geo-Referenced Information System (AGIS). Five land types and several subunits were identified. Each land type and subunit is characteristic of the geology and topography (i.e. slopes) of the area. Land capability, i.e. arable, grazing, wetland and wilderness, is linked to slopes, topsoil texture, affective rooting depth and topsoil permeability. Land capability of the project area was classified into three groups: arable, grazing and wilderness. Grazing far outweighed arable and wilderness capability, comprising 72% of the entire proposed prospecting licence area. Arable capability comprised 22% and wilderness only 6%. Grazing capability was further considered to be equally moderate to intensive, but may reflect topographical differences. In terms of arable land, only 12% of the proposed project area was considered to be suited to agriculture with the remaining 88% considered as poorly adapted cultivation areas illustrated in Figure 13. This may be due to the predominance of shallow sandy soils that are in general easily leached, resulting in low fertility and high acidity.

Figure 13: General view of landscape south of Blouberg. Note general absence of cultivated fields, possibly due to low arable capability

As soil forms only change over extended periods of time, current conditions and historic land use can be used to extrapolate past land capabilities. The project area therefore represented relatively low arable capability that would be required for more extensive, longer-term occupation by early farming communities. However, grazing capability was shown to be high that may have resulted in seasonal grazing activities by pastoralists and farming communities over the past two millennia. 34

1.1.9.9 Archaeological Background and Potential A Heritage Statement Report was compiled by Digby Wells Environmental and is attached as Appendix C. The Early Stone Age (ESA) dates between one million years ago (mya) and 200 thousand years ago (ka). The Middle Stone Age (MSA) dates between 200 ka and 20 ka. The ESA in the Soutpansberg area is relatively rare, whilst MSA occurrences are more common. Little research has been undertaken on the ESA and MSA of the Makgabeng Plateau and Blouberg: any occurrence of such sites should thus be considered significant. The Later Stone Age (LSA) dates between 20 ka and 1000 years ago. Van der Ryst (The Waterberg Plateau in the Northern Province, Republic of South Africa, in the Later Stone Age, 1998) is of the opinion that the Limpopo Province was sparsely occupied during the LSA when compared to the areas further south. This may be due to a lack of research but also as a result of climatic conditions during the LSA. However, the LSA is significant better documented in the Makgabeng and Soutpansberg areas than the ESA and MSA. In the Makgabeng, LSA sites are frequently associated with rock art sites (discussed separately below). Archaeological research commenced in the area during the 1950s when Jean Humphreys excavated the Makgabeng Shelter. Material culture that was identified there included typical lithics from the Smithfield industry, dated from about 1 020 ± 150 BP (Mason, 1962; Sampson, 1974; Eastwood & van Schalkwyk, The Makgabeng Plateau: its prehistory, subregional context and rock art. Introducing the rock art of Limpopo Province, 2003). These lithics were very similar to the Smithfield series at Olieboompoort about 160 km south east of the project area. According to Mason (Prehistory of the Transvaal, 1962), the Olieboompoort groups have been associated with LSA groups in the Makgabeng. More intangible aspects associated with LSA hunter-gatherer groups are the so-called ‘Bushmen water holes’ found on the Makgabeng Plateau as well as in the Soutpansberg area. These features comprise circular or ovoid openings found in horizontal beds of sandstone, frequently covered by a stone ‘lid’ (Cnoops, 1998). Significantly, the presence of both these waterholes and the presence of Bushmen communities in the region are celebrated through the name change of Bochum to Senwabarwana. Senwabarwana in the local Sotho dialect means ‘the place where the Bushmen found water’. Although there is a relative continuation of the Stone Age in the study area, clear evidence of specific Bushmen and Khoi group identities only appear during the Early Iron Age (EIA) alongside the arrival of Bantu-speaking farming communities. These Bantu-speaking EIA farmers entered the Blouberg-Makgabeng and Soutpansberg areas from approximately 700 CE, settling in permanent villages usually near permanent water sources. The EIA communities practiced mixed agriculture: sorghum and/or millet were cultivated whilst stock was kept, notably sheep and goats and cattle. However, these sedentary agricultural practices were significantly supplemented by hunting and collecting plant food. Evidence for pottery production and iron working has also been found at sites in both the Makgabeng and the southern parts of the Blouberg 35

(Holt, 2009). In the Blouberg-Makgabeng area, EIA sites were found on the southern side of Blouberg and on the northern side of the Makgabeng Plateau. This is consistent with the land capability of the area, as the most arable land (12% of the entire proposed prospecting licence area) occurs on the plains at below the Makgabeng plateau and Blouberg. The archaeological evidence also suggests that the autochthonous LSA Bushmen and later pastoralist Khoi groups were not replaced by the farming communities. Instead, there is sufficient evidence to indicate co-existence in an independent relationship (Eastwood & van Schalkwyk, The Makgabeng Plateau: its prehistory, subregional context and rock art. Introducing the rock art of Limpopo Province, 2003). However, there is clear evidence that both the Bushmen/Khoi and EIA communities were replaced or absorbed by Late Iron Age (LIA) groups entering the area from 1300 CE onwards. These (LIA) groups are generally considered to be the direct ancestors of modern Sotho (Tswana and Pedi), Venda and Ndebele language groups. These groups entered the Blouberg-Makgabeng area at different times between 1350 CE and 1850 CE. The terminal phase of LIA occupation in the Makgabeng/Blouberg area is considered to be associated with the Hananwa who were firmly established by the mid-19th century when the first whites – European missionaries and Boers – arrived (Eastwood & van Schalkwyk, The Makgabeng Plateau: its prehistory, subregional context and rock art. Introducing the rock art of Limpopo Province, 2003). There is though evidence to suggest that the protohistoric Difeqane period that took place throughout most of South Africa from the late 18th century to early 19th century significantly changed LIA occupation in the area. The Difeqane may have been the catalyst that drove the Hananwa to sanctuary in the Blouberg. Mzilikazi was the dominant driving force of the Difeqane throughout the Zuid- Afrikaanse Republiek (ZAR) or Transvaal. His Ndebele (Matabele) army entered and subjugated or destroyed numerous communities in the region. During the early 19th century a combined Boer and Pedi force successfully expelled the Matabele from the region and drove them into Southern Rhodesia, where Mzilikazi finally settled. 1.1.9.10 Background to Rock Art The Makgabeng Plateau is one of four distinct rock art areas in the Central Limpopo Basin: the other being the Soutpansberg, the Limpopo-Shashe Confluence area, and north-eastern Venda. Over 460 rock art sites have been documented in the region. A rock art survey that started in 2001 identified and recorded 120 previously unrecorded/unknown sites on the eastern plateau alone. This area only constitutes about a fifth of the plateau’s entire surface area (Eastwood, van Schalkwyk, & Smith, Archaeological and rock art survey of the Makgabeng Plateau, Limpopo Basin, 2002). Three rock art traditions are represented on the Makgabeng Plateau, each associated with particular cultural groups:  The first and oldest tradition is the fine line paintings associated with autochthonous LSA and Bushmen hunter-gatherer groups; 36

 The second tradition is the finger paintings associated with the later arrival of Khoi pastoralists; and  The last, third tradition is finger paintings associated with much later and possibly historic Sotho-speaking farming communities. All three rock art traditions are well-preserved and co-occur differentially. The co- occurrence suggests that there were some cultural interactions between the three groups. Bushmen rock art was produced using fine brushes, quills or sticks. Realistic and proportionally correct animals such as various antelope species are often found. In addition, human figures and more symbolic beings are also represented. A few partially finger-painted images are associated with Bushman art, but these are predominantly of men, women, and animals as well as of loincloths and aprons white (Eastwood, van Schalkwyk, & Smith, Archaeological and rock art survey of the Makgabeng Plateau, Limpopo Basin, 2002). In contrast to the Bushman tradition, Khoi (or Khoekhoen) pastoralists are typified by predominantly finger-painted geometric images. The geometric designs are composed entirely of circles, finger lines, finger dots, and handprints that are mostly painted in red pigment, sometimes in red and white, and occasionally only in white (Eastwood, van Schalkwyk, & Smith, Archaeological and rock art survey of the Makgabeng Plateau, Limpopo Basin, 2002). The most recent of the three traditions is that associated with Sotho-speaking Iron Age and historical groups. These paintings may be related to nearby archaeological and early historical Sotho settlements. The paintings are predominantly anthropomorphic, zoomorphic and geometric and are mostly white in colour. Evidence of this tradition continuing into the historical period is through the appearance of people in western dress, trains, wagons and at least one painting of a camel. Four unrecorded rock art sites were found during the HSA, representing all three traditions. 1.1.9.11 Historical Background White settlement in the region began in the 1840s and increased after the defeat of Mzilikazi when Schoemansdal was established in the Soutpansberg, approximately 67 km east of the project area near modern Makhado (previously Louis Trichardt). This was soon followed by missionary settlement, particularly by the Berliner Missionsgesellschaft or the Berlin Mission Society (BMS). The BMS was instrumental in establishing schools and hospitals in the area. Historical sites associated with the BMS are found throughout the area notably a mission station near Blouberg built by Christoph Sonntag. Sonntag was also a confidant of Maleboho, chief of the Bahanwa (Sontag 1983). Conflict between Boer settlers and terminal LIA groups arose early. Many LIA groups were already scattered as a result of the Difeqane, and the Boers occupied their vacant lands. The most important conflict in the region is perhaps that between the Boers and the Hananwa in 1894, known as the Maleboch War. As noted above the Hananwa was already well established in the Blouberg by the time whites began entering the region. Maleboho refused to pay taxes or be subjugated by the ZAR government. As a result, 37 the ZAR under General Piet Joubert declared war on Maleboho and laid siege to the Hananwa stronghold on Blouberg. The siege lasted from May to July 1894. During this period several forts encircling the Hananwa capital were built, cutting off the Hananwa from all food and water supplies (Van Schalkwyk & Moifatswane, 1991). At least 20 fortifications were built by the burghers. These structures are characterised by loopholes that were used to position guns, cartridge cases, and pieces of metal – possibly shrapnel (Van Schalkwyk & Moifatswane, 1991). Forts have been recorded across Blouberg that extends approximately 27 km north of the project area. The current population of the Makgabeng/Blouberg comprises descendants of earlier LIA groups as well as Hananwa, Ndebele and Koni groups and whites. Racial prejudice was evident from early on, but became legislatively entrenched soon after the establishment of the Union of South Africa in 1910. This increased after the National Party came into power in 1948 creating the Apartheid government. A radical move towards institutionalised racial segregation forced countless black communities into the notorious homelands after the Republic of South Africa was founded in 1961. However, no records of forced removals of black communities within the project area were found during the period between 1960 and 1980. The nearest significant records that were found related to evictions that took place in then Louis Trichardt. From 1960 to 1980, the black community living in Louis Trichardt were evicted from their homes and relocated to the black townships Vleikfontein and Tshikota (Case 3216 - Muzila Phulwana, 1997). The townships are located just outside of Louis Trichardt. The intention of the then apartheid government was to incorporate these two townships into Venda. The eviction of blacks from that area was also intended to create a white- only space in Louis Trichardt with a tarred road and houses (Case 3216 - Muzila Phulwana, 1997). A direct reaction against the 1961 Apartheid government was the formation in the same year of Mkhonto weSizwe (MK), the armed militant wing of the African National Congress (ANC). The armed action of MK included a sabotage campaign against the government. Mpasa Jacob Rapholo was born on the farm Uitkyk 394 and joined MK in the 1980s after which he received training in Angola and Yugoslavia. He infiltrated South Africa through Swaziland, along with Willy Maditsi to prepare underground bases for future attacks on the government (Jacob Mpasa Rapholo Applicant (AM 5298/97) - AC/2000/081, 2000). According to the Truth and Reconciliation (TRC) case, Rapholo, decided to operate in the area of his birth. However, it is unclear where attacks, if any, took place in the area. The case report mentions a number of attacks on civilians by Rapholo in the Pietersburg (now known as Polokwane) area. It may be possible that the ‘area’ referred to in the case report includes the wider Polokwane area and not specifically the Bochum area. 1.1.9.12 Heritage Screening Assessment The HSA was a high-level, extensive survey aimed at further characterising the cultural landscape, specifically in terms of Sections 34 to 36 of the NHRA. The results of the HSA are presented in this section. Heritage resources were identified and recorded in 38 five of the six proposed prospecting licence areas. A total of 25 sites were recorded that included historical settlements and graves, Iron Age, Stone Age and rock art sites. The findings on the prospecting right application area are summarised in Table 16 below.

Table 16: Summary of heritage resources identified and recorded during the HAS for LP 30/5/1/1/2/10805 PR

Short Farm Site_ID Site Type Map No. Lat. Lon. Name name

LP 30/5/1/1/2/10805 PR

S.34 - Leipsig PLA2162/2328BD/S.34_05 S.34_05 2328BD -23.16094 28.90101 historical 264 LR

Sweetho S.34 - PLA2162/2328BB/S.34_06 S.34_06 2328BB me 315 -23.19694 28.8267 historical LR

Nieuwe S.35 - Iron PLA2162/2328BD/S.35_18 S.35_18 2328BD Jerusale -23.26451 28.89769 Age m 327 LR

Mont S.34 - PLA2162/2328BB/S.34_20 S.34_20 2328BB Blanc 328 -23.23949 28.84958 historical LR

S.34 - Leipsig PLA2162/2328BB/S.34_21 S.34_21 2328BB -23.16241 28.90013 historical 264 LR

Leipsig PLA2162/2328BB/S.36_22 S.36_22 S.36 - BGG 2328BB -23.16077 28.90035 264 LR

Gallashiel PLA2162/2328BD/S.35_23 S.35_23 S.35 - rock art 2328BB -23.23124 28.88136 s 316 LR

Gallashiel PLA2162/2328BD/S.35_24 S.35_24 S.35 - rock art 2328BB -23.23497 28.8787 s 316 LR

Gallashiel PLA2162/2328BD/S.35_25 S.35_25 S.35 - rock art 2328BB -23.23451 28.87902 s 316 LR

Areas of interest and potential sites were identified via aerial imagery prior to the team entering the fields. Access routes into the project area were primarily on municipal road, and where possible, through private / unofficial routes. Areas visible from the vehicle that displayed qualities for potential heritage resources (i.e. clearings, alien vegetation, clusters of rocks etc.) were examined by foot. During the pedestrian survey of unaffected areas, dense vegetation posed limits and an adaptive survey technique was adopted. Where possible, the group would divide and transect an area to cover the maximum surface area and increase the potential to identify heritage resources. 39

Identified heritage resources were recorded through GPS, photographs and detailed notes. Informal interviews with community members were conducted during the course of the HSA, specifically requesting information regarding intangible and living heritage in the area. Based on the interviewees’ responses, some intangible and/or living heritage exists in the project area that included:  Rainmaking sites on Blouberg mountain and possibly other hills – however, most interviewees consistently said that rainmaking is not actively being practiced;  Initiation sites in the area of Jerusalem (farm Nieuw Jerusalem 327 LR) where boys’ initiation rites are still practiced;  Use of at least one shelter with rock art as a ZCC gathering place; and  All burial grounds and graves were considered as living heritage sites as evidence of active, current use of these sites by local communities were evident. Nine heritage resource sites were identified in this prospecting area. These are summarised in Table 16 above. These included:  Four historical sites;  A burial ground associated with one of the historical sites; and  Three rock art sites. Site S.34_05 and S.34_21 were located on the southern foot of Blouberg between Ga- Kobe and Ga-Malokela. Both sites comprised low terrace walling on the contours of the slope towards Blouberg. Although two ‘sites’ were recorded, this is probably an arbitrary distinction as the sites are separated only be a drainage channel originating upslope. These sites may be associated with existing structures visible on 1965 historical aerial photographs. As a result, the sites may represent earlier, now- abandoned wards of either one of the named villages. Large concentrations of ceramics were noted at the lowest point of the sites, adjacent to modern, occupied homesteads. Most ceramics were undecorated and all were undiagnostic. However, several fragments were clearly burnished with red ochre and graphite, indicating a late Sotho ceramic tradition. These ceramic concentrations evidently washed down the mountain slope and no context could be determined as indicated in Figure 14. 40

Figure 14: Area with extensive ceramic concentration below Site S34_21. Note the sisal plants in the left middle ground, indicating relative recent historical occupation. Site S.34_21 is located on the low elevations visible behind the first line of trees.

The sites are characterised by terraces that divide the sites into individual household units and activity areas, consistent with early historical settlement. Ash middens were noted at the back and sides of households. Hut melt (i.e. remains of unfired mud walls) was noted in most household areas. Site S.34_05 still exhibited existing structures seen in Figure 15. At least three types of stone walls were noted. Free standing walls in the areas located higher upslope – and therefore presumably older – comprised double-coursed walls with stone and gravel fill illustrated in Figure 17. Terrace and retaining walls in these areas indicated great skill and technique seen in Figure 16.

Walls in the lower areas were predominantly single packed walls illustrated in Figure 18. These may either have delineated gardens, or may indicate decreased skill in stone masonry over time. 41

Figure 15: View of existing structures at S.34_05. Note the decaying structure in the left foreground creating typical hut melt. Also note dry packed stone retaining wall to the right of the structures.

Figure 16: Retaining wall at Site S.34_05 showing level of skill and technique typical of walling in household areas higher up the slope and presumably older.

Figure 17: Freestanding double-coursed wall with stone infill near Site S.34_21.

Figure 18: Terraces on lowest slope below site S.34_21. Note difference in walling compared to walling in Figure 16 and Figure 17.

The burial ground is associated with site S.34_21. At least five graves were noted surrounded by a circular stone wall. Each grave consisted of a low stone cairn a large stone placed on the western end as a headstone illustrated in Figure 19. The graves were oriented approximately east-west. The orientation and fact that the graves had some form of dressing as well as headstones indicate Christian influence and thus more historical dates for the graves. This is consisted with the evidence of the sites and historical photographs. 43

Figure 19: Burial ground S.36_22 associated with S.34_21. The headstone is being pointed out by K. Rammutloa.

1.2 The specific environmental features on the site applied for which may require protection, remediation, management or avoidance. No pans/marshlands were identified on the prospecting area applied for. Refer to Plan 4: Sensitive Areas, for confirmation of this. 1.3 Map showing the spatial locality of all environmental, cultural/heritage and current land use features identified on site. Nine heritage resources were identified within the prospecting right application area. These heritage sites include historical sites, burial grounds and graves as well as rock art sites. Refer to Plan 15 attached in Appendix A indicating the position of these sites. Figure 9 depicts the land uses identified within the project area. 1.4 Confirmation that the description of the environment has been compiled with the participation of the community, the landowner and interested and affected parties. The Environmental Management Plan (EMP) will be made available to all registered Interested and Affected Parties (I&APs) on submission of the Report to the DMR.

2 REGULATION 52 (2) (b): Assessment of the potential impacts of the proposed prospecting or mining operation on the environment, socio- economic conditions and cultural heritage.

2.1 Description of the proposed prospecting or mining operation. The proposed prospecting activities will be conducted over a five (5) year period as the applicant applied for a prospecting right in terms of section 16 of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) on the following farms:  BONNE ESPERANCE 356 LR;  TOO LATE 359 LR;  MONT BLANC 328 LR;  NIEUWE JERUSALEM 327 LR;  GALLASHIELS 316 LR;  SWEETHOME 315 LR;  BLACKHILL 317 LR;  BOGNAFURAN 318 LR;  LEIPSIG 264 LR; AND  THE PARK 266 LR. The minerals applied for on the prospecting right application area which is in extent of 22209.51 hectares (ha) include:  Platinum Group Metals (PGM);  Gold (Au);  Chromium (Cr);  Nickel (Ni);  Copper (Cu);  Iron (Fe); and  Vanadium (V). The Prospecting Work Programme (PWP) is structured around three fundamental stages, namely:  Area selection;  Data gathering; and  Data evaluation. At any stage during the prospecting operation, if results are negative and no- economical mineralization is delineated, the program could be stopped. The opposite is also applicable – if any sign of viable economical mineralization (mine scale) be delineated, it could lead to fast tracking of the program. 46

The PWP consists of both Non-Invasive and Invasive Prospecting Methods. Non- Invasive Activities will include:  Desktop study on data availability on generic/conceptual geological model. Use of datasets supplied by the Government (Council of Geoscience) could include regional geological and geophysical plans that could be used. o Any data available including previous work, generic/conceptual geological models will be studied to aid the planning of the work programme and determine possible size and extent of potential mineralization / ore body. o Use of datasets supplied by Government (Council of Geoscience) could include regional geological and geophysical plans aided by remote sensing methods including satellite imagery, aerial photography and airborne geophysical surveys. o Field reconnaissance of the area will be conducted to ascertain access and determine possible outcrop / sub crop relation of potential mineralization / ore body. This will be done to determine the possible extent of the mineralization / ore body in terms of strike length, thickness, dip and depth below surface. o Re-evaluation of previously explored areas of similar nature is very important at this stage to build conceptual geological modes.  Geological Mapping to be conducted with the use of ortho-photos and aerial photography and satellite imagery of the area. o More detailed geological mapping will be conducted regionally and possibly also on lines/grids across area. This will be done utilizing 1:10 000 Ortho photos of the area but also using aerial photography, satellite imagery to accurately record the nature, location and structure of the various rocks in the target area. The end product of geological mapping is a map which accurately documents rock types, alteration mineralogy and structural data such as faults, folds and dip of strata.  Geophysical Survey methods on the target area. o Adding to the 1:250 000 Regional Gravity and Total Field Magnetic data sets (obtained from the Council of Geoscience); various methods of geophysical surveys will be applied (if value adding) on the target areas and might include: ground magnetic, gravity and radiometric traversing on irregular grids where road infrastructure allows for it and symmetrical grid traversing in areas where possible. This will aid in further defining possible extent of mineralization / ore body.  Geochemical survey methods. o Geochemical surveys are aimed at locating dispersion halos of indicator elements by systematic sampling and chemical analysis of rocks, soils, water or vegetation. Soil/stream sediment sampling and field fragment (grab) sampling are to be conducted across the target areas identified 47

by the geological mapping where access allow for it and will be based on a lines/grid approach where possible to assist to indicate possible presence of concealed mineralisation/ore body. It is important to select at this stage the possible pathfinder elements for the deposit style from case histories or an orientation survey. Invasive (physical drilling) activities will include:  Diamond Drilling. o The presence of concealed mineralization / ore body can only be confirmed and outlined by drilling. Core boreholes will be drilled to ascertain the sequence stratigraphy and potential prospective reef horizons. A follow up exploration drilling program will be conducted as the source for gaining ground truth information of the potential ore body and to prove continuity in the third dimension. o Core drilling of BQ (outside diameter core of 36.4mm) size will be the preferred drilling method but as the nature of the mineralization are established other forms of drilling could be used such as percussion, reverse circulation and rotary blast be used. o The drilling will be conducted in a basic two phase approach: Primary Exploration drilling on a widely spaced grid which are intended to simply delineate the mineralisation (~500m) and Secondary Exploration drilling on more tightly spaced grid which defines grade and tonnage (~250m drill-grid). o It must be emphasized that each of the above activities follows as logical and systematic exploration events and are driven by the success of the previous phases. o If mineralisation proves to be shallow the drilling could be replaced or enhanced by trenching. o At this stage the extent of the drilling on the target area will be focused on the determined anomalies as this is dependent on the previous phases and based on a conceptual structural geological model. A first generation wide grid (usually 500m) diamond drilling effort is planned to confirm the geometry and local stratigraphy and to aid in the generation of SAMREC compliant resources. If mineralized horizons are found, more detailed drilling will be undertaken to define the orientation and shape of the ore body and to define the grade and tonnage. o Drill core will be geologically (structure, lithology and facies) logged, sampled and analysed for PGM’s and associated minerals. Additional hole-deflections or holes will be drilled for value verification/metallurgical sampling purposes.  Trenching o Depending on depth below surface and potential for opencast extraction excavations, trenching and pitting could be applied to determine the 48

extent of mineralisation and if near surface the extent/depth of oxidation. Trenching and pitting are traditional methods of exposing concealed bedrock or taking samples for analysis. Trenching is generally used for taking bulk samples of known mineralisation/ore body for detailed testing prior to mining. With the above being said, non-invasive prospecting methods will not have an impact on the receiving environment. Invasive activities (drilling and trenching) will have an impact, although limited, on the receiving environment. The surface geology of the project area is represented by rocks belonging to the Waterberg Group, which unconformably overlie rocks of the Bushveld Complex (“BC”). In the project area, the Waterberg overlies the Rustenburg Layered Suite. Here, Platreef-type mineralization is known to occur along the basal contact of the sequence, and the target is possibly alluvial platinum mineralization developed in the lowermost units of the overlying Waterberg, as well as the Platreef itself. Most of the erosion of the BC visible today occurred in the pre-Dwyka times. Dwyka glaciation was responsible for some of this erosion, but much may have occurred prior to the onset of this glacial event. Prior to the Dwyka, the next oldest sedimentary deposit overlying the BC is the Waterberg Group, some 1 500 million years older than the Dwyka. The Waterberg Group consists primarily of fluvial deposits, which may have been amenable to placer development. The possibility therefore exists that the Layered Sequence became exposed in pre-Waterberg times, and that platiniferous placers developed in the base of the Waterberg Group. The BC outcrops in three areas known as the Northern Limb, the Western Limb and the Eastern Limb. The Northern Limb is characterised by the development of a platiniferous horizon at the base of the BC known as the Platreef. The mineralized zone is now known to be developed along the entire floor rock contact. The far northern portion of this limb, i.e., the proposed prospecting area, disappears under the cover of the Waterberg Group. It is likely that the Platreef continues undercover of the Waterberg Group. The Platreef horizon will be targeted during the exploration programme.

2.1.1 The main prospecting activities (e.g. access roads, topsoil storage sites and any other basic prospecting design features). No permanent infrastructure will be constructed for the prospecting activities and only mobile equipment will be used during the invasive prospecting phase. Activities associated with drilling and trenching will include the establishment of temporary access roads where existing access roads cannot be used. These access roads will be tracks and will be utilised for the duration of the prospecting phase. A number of small drilling sample sites will be cleared of vegetation in order to allow for the drilling operation to continue. A mobile contactors camp will also be established which will be a mobile container which can be moved from one area to another as prospecting sites shift across the prospecting right application area. 49

Water will be sourced off site in the event where no water is available on site. Water will be circulated throughout the drilling operation and is needed to cool the drill rig. Circulated water will be stored in temporary plastic lined oil-sludge-water separation sumps. Three sump holes will be dug on-site for oil-sludge-water separation and the sumps will be lined with a plastic liner. The soil removed during the construction of the sumps will be stockpiled adjacent to the sumps and not exceeding a height of 1m (Figure 20). The soil will be used during the rehabilitation phase to backfill the sumps and levelling of the area. The area to be cleared will generally not exceed 10m X 20m. The prospecting area will be fenced with a single entrance gate. Figure 21 illustrates a typical drill site with the mobile drill rig, lined sumps, topsoil stockpile area and sampled drill core to be sent for analysis.

Figure 20: Plastic lined oil-sludge-water separation sumps

Figure 21: Typical drill site

2.1.2 Plan of the main activities with dimensions. No permanent infrastructure will be constructed as the proposed activities are only applicable to prospecting and not to mining. The individual prospecting sites measures approximately 10m x 20m which is equal to 200m2. Only mobile equipment will be used during the invasive prospecting phase and the equipment will be removed from the site once prospecting activities have ceased. At the contractors camp, concrete slabs are constructed for comfort reasons, however once prospecting have ceased these slabs will be demolished and the area will be ripped and levelled to ensure that natural conditions return to the affected area. Mobile homes in the form of containers are used to house the contractors and working crew. Chemical toilet facilities are installed at the contractor camps. Waste disposal bins are also located at each site for waste sorting and disposal. The table below summarizes the prospecting work schedule. It is important to note that it is result driven and the outcome of any one phase may dictate the direction of the next.

Table 17: Time required for each phase of the proposed prospecting operation.

What technical Timeframe for Phase Activity Skill(s) required Timeframe Outcome expert will sign off outcome on the outcome? Geologist, A library with all Non-invasive Geologist. Mineral economist historical information 1 3 Months 6 Months Project geologist. GIS Specialist. available on the study Desktop studies Technical manager Data compliers area, Reports. Non-invasive Geologist A detail map of rock Geologist. 1 Geological field- 3 Months types, soil types and 6 Months Project geologist. Geological field mapping assistant outcrop positions Technical manager Geophysicist. Geophysical report on Geophysicist. Non-invasive Geologist structure and possible Geologist 1 Field assistants. 3 Months 8 Months magnetic and Technical manager Geophysics Pilots geophysical anomalies Director Labourers Geologist Detail maps and report Geologist. Non-invasive Geological field with possible 5-Months Project geologist. 1 assistants 3 Months geochemical anomalies Technical manager Geochemical surveys Mineralogist for further investigation Mineralogist Labourers Geologist A detail report on reef Environmentalist. horizons, structure Geologist. Diamond drilling Invasive grade and 3 Project geologist manger dimensional space Environmentalist 1 Drilling foreman 12 months 16 Months Primary Diamond drilling orientations. As well as Technical manager Field assistants and sampling anomalies to be Mineralogist Samplers investigated in next Directors Core cutters phase Mineralogist Geologist Geologist. Invasive Environmentalist Report on the Project geologist 2 Sampler 1 Months weathered zone of reef 2 Months Environmentalist Trenching Field assistants outcrop Technical manager Back-actor Mineralogist 53

operator Directors Geologist A more detailed report Environmentalist. on reef horizons, Geologist. Diamond drilling structure grade and 3 Project geologist manger Secondary diamond drilling dimensional space Environmentalist 2 Drilling foreman 12 months 16 Months and sampling orientations This Technical manager Field assistants information could Mineralogist Samplers potentially be used for Directors Core cutters a Feasibility study Mineralogist Geologist Geologist Mineralogist Mineralogist Mine engineer Mine engineer Mine designer Mine designer A report on the Environmentalists 3 Feasibility study Environmentalists 12 Months economical feasibility of 12 Months Ventilation officer Ventilation officer the project. Rock engineer

Rock engineer Metallurgist Metallurgist Mineral economist Mineral economist Directors

2.1.3 Description of construction, operational, and decommissioning phases. Establishment / Construction phase: No physical construction activities will take place as no permanent infrastructure will be established within the prospecting right application area. Activities will relate to the possible establishment of temporary access roads as well as the clearing of vegetation on prospecting sites / drill sites. Temporary access roads will be constructed from existing road infrastructure with the shortest possible route to the drill site, which will minimise the environmental impact related to this activity. These temporary access roads will not be used by haulage trucks; however these roads will be utilised by personnel vehicles for general site inspections and pick-up of drill core during the operational phase. Three oil-sludge-water separation sumps will be constructed within the boundary of the fenced prospecting site. Topsoil will be stockpiled adjacent to the sumps to allow for future rehabilitation. Topsoil stockpiles are covered during windy and rainy months in order to limit soil erosion. A contractors camp will be constructed, concrete slabs are constructed for comfort reasons, however once prospecting have ceased these slabs will be demolished and the area will be ripped and levelled to ensure that natural conditions return to the affected area. Mobile homes in the form of containers are used to house the contractors and working crew. Chemical toilet facilities are installed at the contractor camps. Operational phase: The mobile drill rig will be brought onto site for drilling. The drill rig will target the Platreef horizon for drill core which will be sent to a laboratory for analysis. Water stored in the oil-sludge-water sumps will be circulated to cool the drill rig (tip) until drilling on the site is complete. The drill rig will move systematically from one site to another up until the desired number of prospecting holes has been drilled. It can take from a couple of days to more than a month to drill one site depending on technical problems or geotechnical rock conditions. Depending on depth below surface and potential for opencast extraction excavations, trenching and pitting could be applied to determine the extent of mineralisation and if near surface the extent/depth of oxidation. Trenching and pitting are traditional methods of exposing concealed bedrock or taking samples for analysis. Trenching is generally used for taking bulk samples of known mineralisation/ore body for detailed testing prior to mining. In most instances the drill crew stay close to the drill site in temporary accommodation facilities (such as mobile homes). The energy source utilised is gas. Fire is not permitted, especially during the winter months. Waste is separated on site in accordance with the principles of waste recycling and reuse as stipulated by the National Environmental Management Waste Act (NEM:WA).

Decommissioning and Rehabilitation phase: After prospecting has ceased at a particular prospecting site rehabilitation needs to commence. All mobile equipment will be removed from site in order for rehabilitation activities to commence. Rehabilitation activities will entail the following:  Rehabilitation of each drill site concurrently with drilling program. As the drill rig moves off a particular site the site will be rehabilitated;  Ensure that all hydrocarbons are removed from the site and separated from the water;  All hydrocarbons to be removed from the drill site and disposed of at a registered municipal waste handling facility;  All other domestic waste drums removed from the site and waste disposed of at a registered municipal waste management facility. No waste is to be burned or buried at any time during prospecting;  Plastic liners used in the sumps will be removed prior to final rehabilitation. Where possible liners will be reused or alternatively disposed of;  Oil-sludge-water sumps will be backfilled;  Topsoil as previously removed and stockpiled will be spread evenly over the area;  The area will be ripped where needed (i.e. in cases where subsoil have been compressed);  Generally topsoil contains seeds needed for future rehabilitation however, vegetation establishment will be monitored and where needed additional seeds planted for indigenous vegetation establishment; and  Ultimately all equipment will be removed from the prospecting right application area. The following recommendations are made with respect to rehabilitation: DAY 1:  Water from the sumps should be pumped into water drums for re-use;  Sludge remaining in the sumps on the plastic liners be removed by shovels and disposed of in bins for final disposal off-site;  Plastic liners should then be folded (to prevent sludge spills) and disposed of in bins for final disposal off site;  Grease should also be disposed of in used oil drums for disposal off site; and  The sumps should be closed by backfilling with previously removed soil.

DAY 2:  Site inspection by manager to determine the need for the application of degreasers and soil fix kits;  If needed the application of these should be done and the area be levelled as best possible; and  Borehole should be sealed and pegged. WEEK 2  Final site inspection and levelling of the area; and  Determine the need for additional rehabilitation. WEEK 3  The site should be ready for sign-off. The sites where rehabilitation still has to commence needs to be properly cleaned up before topsoil is spread over the area and then levelled. It is recommended that the major sludge spills be cleaned up first with a shovel by disposing the dry sludge clots into an appropriate drum for final disposal. Degreasers should be used to clean the soil surrounding the steel pegs where grease oozed out of the borehole during the prospecting activities. Pieces of the liners lying about should be disposed of in a proper manner. The sludge spills and the soil containing grease and hydrocarbons should not be merely covered up by the spread of topsoil. Should the rehabilitation not be done properly, future negative impacts on the receiving environment will be evident. Soil fix kits should be added to the areas contaminated with sludge and hydrocarbons. It is also important that all the boreholes are properly capped with a steel peg.

2.1.4 Listed activities (in terms of the NEMA EIA regulations). Due to the small scale of the prospecting activities and the temporary nature of these activities, no listed activities will be triggered. It will be ensured that no prospecting activities be undertaken within 32 metres of a watercourse which will be the only probable listed activity that could be triggered. No electricity or bulk water supply construction will be necessary.

2.2 Identification of potential impacts

2.2.1 Potential impacts per activity and listed activities. 2.2.1.1 Activity: Earth Clearing and Site Establishment This activity will relate to earth clearing for the establishment of prospecting drill sites. These sites will not be larger 10m x 20m each. A number of these sites might be established, the number of sites will be determined from the non-invasive prospecting methods. Temporary access roads will also be established. These temporary access roads will be developed based on the shortest route from existing road infrastructure to the drill sites. 57

The activity will entail the clearing of vegetation, small shrubs (i.e. herbaceous layer) and grasses. Indigenous trees will not be removed. Vegetation will be removed by means of manual labour or by means of mobile earth moving equipment. Topsoil will then be removed and stockpiled for future site rehabilitation. Site establishment will include setting up of contractors camp (mobile homes), bringing equipment including the mobile drill rig onto site. Service and mechanical equipment will also be brought onto site. No permanent infrastructure will be established. All equipment will be removed from the site once prospecting has ceased. The impacts associated with this activity could relate to: Groundwater Impacts The clearing of the drill site can lead to an increase of rainwater infiltrating to the subsurface due to removal of vegetation, which is a positive aspect in terms of groundwater quantity. The small areas (it is assumed < 10m3) that will be disturbed, together with the depth of the water table (> 5m) from the surface however limits the likelihood and significance of this occurring to highly unlikely and insignificant. Soil Impacts Activities during early works and establishment / construction in the exploration areas could lead to the following impacts on soils:  Soil compaction and topsoil loss leading to reduced agricultural potential; and  Soil erosion (sediment release to land and surface water). The construction camp and access roads need to be stripped of vegetation. Stripping the vegetation causes the soil surface to be exposed. Compaction and increased erosion from increased exposure to wind and water are likely to cause changes in the soil structure and degradation of soil quality. The extent to which these occur is dependent on the sandy properties of the soils in combination with the climate. Water erosion may happen when water (for example runoff) comes in contact with bare soil on cleared patches, especially on sloped terrain or running down compacted road surfaces. An occasional heavy rainstorm during the rainy season can initiate erosion on bare patches. Most of the erosion is expected to occur along main unpaved compacted roads. The impacts of stripping vegetation, water runoff and erosion of soils will be negative and restricted to on-site. Limited impacts are expected due to the limited annual rainfall in the Limpopo Province. Impact significance to soil resources and land capability pre-mitigation is expected to be low. Fauna and Flora Impacts Loss of vegetation communities The clearing of vegetation and removal of topsoil at the drilling locations will result in loss of vegetation communities.

Loss of biodiversity in general, Loss of Floral SSC, Loss of Faunal SSC Prospecting activities will definitely result in a loss of biodiversity in general through the clearing and removal of vegetation as well as potential loss of species through disturbances by activities. Loss of Ecosystem Function i.e. Fragmentation and edge effects and Influx of alien invasive species Construction of roads and development of areas for prospecting will result in the area becoming more fragmented as microhabitats become isolated. Edge effect will be increased with the construction of roads leading to the increase of alien invasive species and encroachment of development in areas previously undeveloped. Surface Water Quality Impacts Earth clearing for the establishment of temporary prospecting drill sites, contractor camp, access roads and oil-sludge-water separation sumps may result in increased turbidity and silt in the surface water resources as a result of dust and soil erosion due to increased vehicular movement. Site establishment and mobilizing of equipment to each prospecting site has a high potential for accidental spillage of hazardous (chemicals) and hydrocarbon containing (oils and greases) material. Surface Water Quantity Impacts The isolation of the clean and dirty area will result in runoff prevented from reporting to the catchment during the earth clearing to establish temporary drill sites, access roads, contactors camp and mobilization of equipment. 2.2.1.2 Activity: Drilling Drilling of the area will be undertaken by core drilling using a core drilling technique. A drill bit with a diameter of 36,4mm will be used. The drill bit is attached to the drill string, which is suspended from the drill rig’s derrick and then rotated in the hole. During the first part of the drilling operation the drill bit would crush the rock into small particles called cuttings. The cuttings will be removed from the bottom of the hole by the drilling fluid. Once the top section of the hole has been drilled a steel casing would be inserted to secure the wall of the hole and also to prevent any groundwater contamination. This being said, the impacts associated with drilling are listed below: Groundwater Impacts Possible breakdowns or fuel spillages on the drilling site has the potential to impact on the groundwater environment, should the fuel, oil or grease finds its way down a borehole. The likelihood of this occurring is highly unlikely though. The drilling of water supply boreholes and abstraction of groundwater for the prospecting operations may impact on groundwater quantity in the immediate surroundings (100m radius) of the water supply borehole. The small volumes (± 10 – 20 m3) per day of water that is required for drilling will have a very low impact and the most boreholes worth pumping for water can sustain this supply. 59

Soil Impacts The potential for contamination of soil resources exists during site preparation and drilling as a result of spills or leaks of fuels, oils and lubricants from drill rigs. Fluids used for vehicles and machinery may spill during filling, or leak directly in the event that damage to the hydraulic fluid system goes unnoticed. Impacts to soil resources are dependent on the size of the spill and the speed with which it is addressed and cleaned up. If contaminated, the ability of soil to carry out its essential functions can be compromised thus affecting the land capability of the soil. Contaminants transported by water would very rapidly infiltrate into sandy soils increasing the risk of groundwater contamination. The impacts of hydrocarbon pollution of soils will be negative and restricted to on-site. Limited impacts are expected due to the limited annual rainfall in the Limpopo Province. Impact significance to soil resources and land capability pre-mitigation is expected to be low. Noise and Dust Impacts Drilling could increase the ambient noise levels in the area. This impact will be considered to be low to very low as the recommended noise levels of 50dBA during daytime will not be exceeded. No drilling will take place during the night-time at drill sites in close proximity to residential areas. Dust could be generated from vehicles using the existing access roads to travel to the drilling sites on a daily basis. Dust could become a nuisance during windy days as additional surface areas will be earth cleared of vegetation however, it is anticipated that the impact will be of short duration and hence low significance. Fauna and Flora Impacts Loss of biodiversity in general, Loss of Floral SSC, Loss of Faunal SSC Prospecting activities will definitely result in a loss of biodiversity in general through the clearing and removal of vegetation as well as potential loss of species through disturbances by operational activities. Loss of Ecosystem Function i.e. Fragmentation and edge effects and Influx of alien invasive species Edge effect will be increased during the operational phase with the established roads and prospecting sites leading to the increase of alien invasive species and encroachment of development in areas previously undeveloped. Traffic Impacts Traffic could slightly increase to the sites on the existing access roads. This could have a negative impact on the safety of the roads in the vicinity of the prospecting sites. This impact is however anticipated to be of low significance.

Surface Water Quality Impacts During the drilling there is increased potential for spillage of sludge/ oil or contaminated water as well as hydrocarbon containing material. Surface Water Quantity Impacts There will be no additional quantity impacts as the isolated area will remain the same throughout prospecting. 2.2.1.3 Activity: Site Rehabilitation This activity will involve the removal of all equipment and personnel from the site. Plastic linings in sumps will be removed and could be transported to the next site if still usable. If no longer usable it will be disposed of offsite. Once all equipment has been removed the sumps can be backfilled and the area levelled with the topsoil as stockpiled during initial earth clearing activities. As a result of site rehabilitation the following could be impacted on: Soil Impacts If the area is backfilled and levelled with topsoil prior to a major rain event soils could wash off into drainage and water systems resulting in the permanent loss of valuable topsoil and sedimentation of rivers and streams. Surface Water Quality Impacts During site clearing and removal of general waste and other rubble there will be increased vehicular movement and this will result in the dust and potential soil erosion. The most significant impact will be mobilization of contaminants (include hazardous and hydrocarbon containing material) from the surface environment and these could find way to the surface water resources. The sump decommissioning could result in the mobilization of material that leaked during the operational phase and the accidental spillage of material contained in the sump (sludge, water and hydrocarbon containing material) could result in negative water quality impacts. No impact on the surface water quality is expected during the borehole sealing and pegging. Surface Water Quantity Impacts During sump clean-up, disposal of sump material and sump backfilling the return of runoff to the catchment will be a positive impact with a net neutral benefit as the drainage pattern has been altered and cannot be returned to pre-prospecting state. Backfilling and profiling of backfill material must be ensured to as much as possible resemble pre-prospecting state. Contouring of the site must ensure that there is free drainage which as much as possible resembles the pre-prospecting state.

Flora Impacts With soil erosion is the associated poor establishment of a vegetation cover which is difficult to rehabilitate after the occurrence of such an impact. This could also impact fauna species as a result of a poor vegetation cover. Fauna Impacts Fauna species will return to the area after rehabilitation provided that the area is rehabilitated well in terms of vegetation establishment. This will result in a neutral impact.

2.2.2 Potential cumulative impacts. Should an impact occur the following potential cumulative impacts could occur:  Cumulative impacts on surface water in the event that spills aren’t cleaned up immediately after occurring.  Sedimentation of watercourses in the area in the event of poor topsoil management which will increase TDS and Electric Conductivity (EC).  Surface water quality impacts that are associated with accidental spillage of large volume of hydrocarbon containing and hazardous material may take a long-period to be mitigated. The effect of such a spillage could also result in the alternation of the water ecosystems and plants that are on the surface water environment.  Surface water quantity impacts that are cumulative include the permanent alternation of the drainage pattern that cannot be fully returned to the pre- prospecting state.  Soil erosion which could contribute towards the national loss of soils with agricultural potential.  Contribution towards invasion of alien species which leads to reduced water quantities in local rivers and streams and a contribution towards the national problem of invasion of alien species in South Africa’s water systems. 2.2.3 Potential impact on heritage resources. The proposed prospecting activities will be limited to relatively small footprints associated with invasive methods such as diamond and/or percussion drilling. These activities will result in localised land disturbances. These disturbances will however undergo site rehabilitation and project-related mitigation measures will be implemented throughout the prospecting process. Consultation with affected communities will take place prior to any prospecting activities, thus reducing and avoiding impacts on tangible resources such as burial grounds and graves protected in terms of Section 36 of the NRHA, as well as more intangible resources such as sacred places. Actual drilling should pose minimal risk to heritage resources protected in terms of Section 35 of the NHRA, i.e. archaeological and palaeontological sites, features and objects, as the footprints will be relatively small. Historical structures protected in terms of Section 34 of the NHRA should not be impacted on at all. 62

Notwithstanding the above, sources of risk to heritage resources may include the following:  Site clearing and/or levelling of drill platforms;  Creation of prospecting access roads to drill sites; and  Increased and concentrated human activity that may result in vandalism of sites. Specific types of heritage resources that should be considered most sensitive due the identified sources of risk include:  Rock art sites that may occur in shelters in cliff faces near prospecting activities;  Archaeological sites that may occur in areas where access roads will be required, as well as at drill sites; and  Unknown burial sites or graves that may be exposed during access road construction or site levelling. The impacts on the above identified resources are significantly reduced where prospecting activities take place within human settlement and through consultation with local communities. However, in more remote areas the risks to sites increase. No impacts on significant surface or exposed palaeontological resources, i.e. fossils are expected. Should viable outcrops be established and trenching and sampling be initiated, the identified sources of risk will increase exponentially given the area of trenching, additional equipment and larger workforces that will be required. 2.2.4 Potential impacts on communities, individuals or competing land uses in close proximity. The proposed prospecting activities are expected to have both negative and positive consequences for surrounding communities. However, none of the potential impacts are expected to be highly significant. The most significant positive impact is likely to be the in the form of downstream benefits for the local economy, but these will be fairly limited due to the relatively short time duration as well as the limited potential for local job creation. On the negative side, the most significant impact is likely to be physical and/or economic displacement of households and their assets – particularly subsistence agricultural fields. This impact can, however, be managed through adequate compensation measures and relocation (should the latter be required). The potential impact on the socio-economic environment is further discussed below. Recommended mitigation measures for reducing negative impacts and enhancing positive ones are also discussed in section 3.2.2.3. 2.2.4.1 Economic Benefits During the public participation process undertaken for the proposed project, economic benefits and job creation featured repeatedly as some of the main concerns among 63 local communities.6 Prospecting activities are expected to give rise to some positive economic impacts for the local and regional population. More specifically, the following positive impacts are anticipated:  The creation of local and regional employment opportunities. It is not currently known how many employment opportunities will be created by the project, or the percentage of these that could feasibly be allocated to members of local communities. Skills levels in the surrounding area are low; moreover, the required workforce for prospecting is likely to be relatively small (involving, for instance, security guards for drilling machines, etc.). It is therefore expected that direct job creation through the project will be fairly limited.  Increased business opportunities for local entrepreneurs, as well as indirect economic benefits created through local spending by the construction workforce. 2.2.4.2 Physical and Economic Displacement Physical displacement refers to the necessity to relocate entire households, while economic displacement refers to instances where households will lose access to agricultural land or other livelihood resources because of a project. A relatively large proportion of the project area is occupied by rural villages and their subsistence agricultural fields, with the project area as a whole being populated by an estimated 26 000 households or 101 000 individuals. Thus, although the surface disturbance associated with prospecting activities may be fairly limited, the possibility cannot be ruled out that some households or agricultural fields will be displaced by the project. 2.2.4.3 Community Well-being and Safety The local community’s well-being and safety may be affected by project activities in the following ways:  There is likely to be an influx of job-seekers into the area during the construction phase of the project. This may have a negative impact on the local community by engendering competition for limited job opportunities, placing pressure on local resources and services, and possibly giving rise to conflict and social pathologies (such as an increase in crime, etc.); and  Prospecting activities could pose safety risks for local community members. Sources of such risk include project traffic and the possibility that local persons (especially children) and livestock could wander into sampling trenches. 2.2.4.4 Physical Intrusion Construction activities will constitute a physical intrusion that may affect local residents in various ways:  Vibration, noise and air (dust) pollution due to traffic and other project activities may have a detrimental effect on the local communities, both by damaging structures and by constituting a nuisance;

6 Digby Wells Environmental (2013). Platinum Group Metal prospecting right application: Comments and Response Report. March 2013. 64

 Construction-related traffic and other activities may cause disruptions of the daily movement patterns of local communities; and  Impacts associated with a labour camp (if such a camp will be required to house construction workers). Such impacts could include inappropriate behaviour by occupants (e.g. littering, conflict with local community members, etc.) or environmental health risks as a result of inadequate ablution facilities.

2.2.5 Confirmation that the list of potential impacts has been compiled with the participation of the landowner and interested and affected parties. Refer to section 7 of this report.

2.2.6 Confirmation of specialist report appended. A desktop Social Impact Assessment has been compiled and attached to this report as Appendix B A Heritage Statement Report has been compiled and attached to this report as Appendix C.

3 REGULATION 52 (2) (c): Summary of the assessment of the significance of the potential impacts and the proposed mitigation measures to minimise adverse impacts.

3.1 Assessment of the significance of the potential impacts 1. Significance = Consequence x Probability 2. Consequence = Severity + Spatial Scale +Duration 3. Probability = Likelihood of an impact occurring

Please refer to the table below for the criteria used to assign significance to potential impacts. 65

3.1.1 Criteria of assigning significance to potential impacts Table 18: Criteria used to assign significance to the potential impacts.

Rating Severity Spatial scale Duration Probability Environmental Social / Cultural Heritage 7 Very significant impact on the environment. Irreparable damage to highly International Permanent to Certain/ Definite Irreparable damage to highly valued species, habitat valued items of great cultural mitigation or ecosystem. Persistent severe damage. significance or complete breakdown of social order.

6 Significant impact on highly valued species, habitat Irreparable damage to highly National Permanent Almost certain/ High or ecosystem. valued items of cultural significance mitigated probability or breakdown of social order. 5 Very serious, long- term environmental impairment of Very serious widespread social Province/ Region Project life Likely ecosystem function that may take several years to impacts. Irreparable damage to (The impact will rehabilitate. highly valued items. cease after the operational life span of the project)

4 Serious medium term environmental effects. On-going serious social issues. Municipal area Long term Probable Environmental damage can be reversed in less than Significant damage to structures / (6-15 years) a year. items of cultural significance 3 Moderate, short- term effects but not affecting Ongoing social issues. Damage to Local Medium term Unlikely/ Low ecosystem function. Rehabilitation requires items of cultural significance. (1-5 years) probability intervention of external specialists and can be done in less than a month

2 Minor effects on biological or physical environment. Minor medium-term social impacts Limited Short term Rare/ improbable Environmental damage can be rehabilitated internally on local population. Mostly (Less than 1 year) with/ without help of external consultants. repairable. Cultural functions and processes not affected. 66

Rating Severity Spatial scale Duration Probability Environmental Social / Cultural Heritage 1 Limited damage to minimal area of low significance, Low-level repairable damage to Very Limited Immediate Highly Unlikely/ None (e.g. ad hoc spills within plant area). Will have no commonplace structures (Less than 1 impact on the environment month)

Table 19: Probability Consequence Matrix

Significance Consequence (severity + scale + duration) 1 3 5 7 9 11 15 18 21 1 1 3 5 7 9 11 15 18 21

2 2 6 10 14 18 22 30 36 42 3 3 9 15 21 27 33 45 54 63 4 4 12 20 28 36 44 60 72 84

5 5 15 25 35 45 55 75 90 105

Likelihood Probability / / Probability 6 6 18 30 42 54 66 90 108 126 7 7 21 35 49 63 77 105 126 147 Table 20: Significance threshold limits

Significance High 108- 147

Medium-High 73 - 107

Medium-Low 36 - 72

Low 0 - 35 67

Table 21: Significance Scale

Score Description Rating <35 An acceptable impact for which mitigation is desirable but not essential. Negligible The impact by itself is insufficient even in combination with other low impacts to prevent the development being approved. These impacts will result in either positive or negative medium to short term effects on the social and/ or natural environment. 36-72 An important impact which requires mitigation. The impact is Minor insufficient by itself to prevent the implementation of the project but which in conjunction with other impacts may prevent its implementation. These impacts will usually result in either a positive or negative medium to long term effect on the social and/ or natural environment. 73-108 A serious impact, if not mitigated, may prevent the implementation of Moderate the project (if it is a negative impact). These impacts would be considered by society a constituting a major and usually a long term change to the (natural and/ or social) environment and result in severe effects or beneficial effects. >108 A very serious impact which, if negative, may be sufficient by itself to Major prevent implementation of the project. The impact may result in permanent change. Very often these impacts are immitigable and usually result in very severe effects, or very beneficial effects

3.1.2 Potential impact of each main activity in each phase, and corresponding significance assessment Please refer to the tables below.

Table 22: Construction / Establishment Phase (Earth Clearing and Site Establishment)

Activity, Phase and Impact Impact rating (before mitigation)

(7)

Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Consequence

Probability

Spatial Spatial Scale(7)

Significance(147) Natureof Impact (positive /

Biophysical Impacts

Soil erosion C N 2 3 4 9 5 45

Soil Compaction C N 2 3 3 8 4 32

Noise C N 2 3 2 7 4 28

Access roads - Generation of C N 2 3 2 7 3 21 dust C N 3 3 2 8 4 32 Access roads- Traffic Access roads - Surface C N 3 3 1 7 3 21 damage on roads 69

Activity, Phase and Impact Impact rating (before mitigation)

(7)

Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Consequence

Probability

Spatial Spatial Scale(7)

Significance(147) Natureof Impact (positive /

Biophysical Impacts C N 1 3 4 8 5 40 Hydrocarbon spillages C N 1 3 2 6 4 24 Ablutions C N 1 3 2 6 4 24 Domestic Waste Surface Water Quantity C N 2 2 3 7 4 28

Surface Water Quality C N 2 2 3 7 5 35

Loss of Biodiversity C N 3 3 3 9 5 45 Loss of Vegetation C N 2 3 3 8 5 40 Communities Loss of Ecosystem Function C N 3 3 2 8 4 32

Table 23: Operational Phase (Drilling and Possible Trenching)

Activity, Phase and Impact Impact rating (before mitigation

Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact (positive /

Biophysical Impacts

Drilling - Removal of water O N 1 3 2 6 3 18 generated during drilling

Drilling - Spread of alien invasive plant speces to other O N 3 2 4 9 5 45 sites Access roads - Generation of O N 2 3 2 7 3 21 dust

Access roads - Traffic O N 3 3 2 8 4 32

Access roads - Surface O N 3 3 1 7 3 21 damage on roads 71

Activity, Phase and Impact Impact rating (before mitigation

Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact (positive /

Biophysical Impacts Hydrocarbon uses and O N 1 3 4 8 5 40 spillages - Soil Contamination

Loss of Biodiversity O N 3 3 3 9 5 45

Loss of Ecosystem Function O N 3 3 2 8 4 32

Ablutions O N 1 3 2 6 4 24

Domestic Waste O N 1 3 2 6 4 24

Surface Water Quantity O N 2 2 3 7 2 14

Surface Water Quality O N 4 3 3 10 4 40

Noise O N 2 2 3 7 4 28 72

Table 24: Decommissioning Phase

Activity, Phase and Impact Impact rating (before mitigation)

Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact (positive /

Biophysical Impacts

Access roads - Generation of D N 2 3 2 7 3 21 dust

Access roads- Traffic D N 3 3 2 8 4 32

Hydrocarbon uses and D N 1 3 4 8 5 40 spillages - Soil Contamination

Surface Water Quality - Removal of General Waste and D N 2 2 3 7 2 14 other Rubble 73

Activity, Phase and Impact Impact rating (before mitigation)

Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact (positive /

Biophysical Impacts

Surface Water Quality - Sump D N 2 2 3 7 2 14 Clean-up and backfilling

Surface Water Quantity - Sump D N 2 2 3 7 2 14 Clean-up and backfilling

3.1.3 Assessment of potential cumulative impacts. Cumulative Impacts were discussed in section 2.2.2 above. Due to the fact that full baseline information is not available for the region it is not possible to assess the cumulative impacts based on a quantitative scale but rather on a qualitative scale. Cumulative impacts, should they occur, have been assessed as indicated in the table below. It should be noted that cumulative impacts will only occur should site specific impacts occur and no mitigation be employed or be effective. Based on the nature of prospecting activities it is unlikely that significant cumulative impacts will occur.

Table 25: Cumulative impact table

Cumulative Impact Impact Mitigation Rating Mitigation is possible at source which will reduce Surface water Low to Medium Low the likelihood of the occurrence of this cumulative impact Mitigation is possible at source which will reduce Groundwater Low the likelihood of the occurrence of this cumulative impact Mitigation is possible however should this impact occur during the rainy Sedimentation of Rivers season and no mitigation is Low to Medium Low and watercourses in place this cumulative impact will occur depending on the location of the drill site. On a regional to national scale this impact, should it Soil erosion Low occur, will have a low significance. Mitigation is possible Alien species can be introduced by equipment brought onto site. Should Introduction of Alien Low to Medium Low this impact occur all site species could be vulnerable to invasive alien species. Mitigation is possible. Should noise levels exceed 50dBA during daytimes and 40dBA during night times a cumulative impact Elevated noise levels Low might be experienced. Mitigation is possible by limiting operations to daytime hours especially close to residential areas.

3.2 Proposed mitigation measures to minimise adverse impacts.

3.2.1 List of actions, activities, or processes that have sufficiently significant impacts to require mitigation. 75

The following activities or actions would require mitigation:  Drilling: Disturbance of vegetation will cause soil erosion and habitat degradation;  Drilling: Water generated during drilling will cause soil, surface and ground water pollution;  Access Roads: Damage to gravel roads and increase in dust;  Use of Hydrocarbons: Soil, ground and surface water pollution;  Ablutions: Soil, ground and surface water pollution; and  Domestic Waste: Soil, ground and surface water pollution. 3.2.2 Concomitant list of appropriate technical or management options 3.2.2.1 Environmental Mitigation Measures The prospecting activities will have low to medium-low impacts on the receiving environment. Prospecting sites to be impacted will be small however, in the event of an impact occurring the following should be done:  In the event of a major spill, for example an oil spill, all prospecting operations at that specific site should be stopped and the spill be cleaned immediately. In the event of any hydrocarbon spill bioremediation measures should be employed to clean contaminated soil via the correct bioremediation procedures;  Topsoil should be stockpiled on-site and not exceeding a height of 1m;  Should the site show evidence of soil erosion daily inspection, monitoring and remediation will be required. In the event of topsoil erosion, soil should be placed back onto the topsoil dump with additional mitigation measures to be employed i.e. berm construction or placement of larger plastic liner over topsoil dump;  Only the footprint areas, earmarked for the temporary prospecting sites and contractor’s camp should be cleared of vegetation. This area should also be fenced off to ensure that areas surrounding the prospecting site are not impacted on in terms of vegetation destruction. This also has to apply to the establishment of access roads, which will be in the form of tracks; these roads should be established by using the shortest route from existing roads;  Noise and dust pollution could be a significant impact. Should any complaints be received from the public, drilling should stop until the problem has been resolved and both parties have come to an agreement;  Sensitive areas identified in this EMP should be avoided;  No prospecting activities should take place within 32m of any watercourse;  Dust suppression methods should be implemented to reduce impacts related to dust; 76

 Ensure that spillage control kits to contain the mobilization of the contaminants from point of spillage are available on-site throughout all three phases;  The sump should be constructed by authorized / qualified personnel to ensure the correct design is implemented;  Ensure that the correct type and size of lining is installed in the sump for use during drilling;  Ensure that trained personnel undertake drilling and a senior/ supervisor personnel is on site to implement mitigation measures;  Implement site clearance, rehabilitation, sign-off and monitoring as and when prospecting is completed within a specific area;  Ensure that trained personnel undertake decommissioning;  During the decommissioning phase, undertake surface inspection to detect any pro-longed leaks on the surface environment;  Ensure disposal of the various material to the correct disposal site by accredited / approved contractors and the disposal certificates to be submitted for record keeping;  Trained personnel should undertake sump clearing and different materials (sludge and water) should be disposed in relevant containers (clearly marked) for appropriate disposal;  Site inspection should be carried out and all completed work should be recorded in a log-book; and  Where rehabilitation (grass seeding of topsoil cover) is not effective, the associated soil erosion should be mitigated by installing silt traps at areas where the surface runoff enters the surface water resources. 3.2.2.2 Heritage Mitigation Recommendations Due to the large surface area of the proposed project area and individual prospecting licence areas, an intensive, comprehensive Heritage Impact Assessment (HIA) will not be feasible considering regulated MPRDA timeframes. In addition, the actual impact of the individual prospecting activities will, arguably, be negligible especially in current human settlement areas. A recommendation for a Letter of Request of Exemption (LRE) of a HIA and any other studies is therefore made. This recommendation is however made with the following provisions:  Prospecting activities that may take place in locations near cliff faces where a greater potential for rock art can be expected, especially where shelters and/or caves are evident: o Drill sites must be placed at least 500 m from the cliff faces; o Workers’ movement must be restricted and cliff faces assigned ‘no-go’ areas; and 77

o Manual geological exploration of cliff faces, if required, must be conducted by a qualified geologist with attention paid to the possible existence of rock art.  Where access routes are required, especially in remote, uninhabited areas: o A Phase 1 Archaeological Impact Assessment (AIA) should be completed for the proposed access route in terms of Section 38 of the NHRA; and o Where access routes will exceed 300 m in length a Phase 1 AIA is a legislated requirement independent of any other legislated requirements in terms of Section 38(1)(a) of the NHRA.  Where trenching may be required, especially in remote areas: o A Phase 1 AIA should be completed in terms of Section 38 of the NHRA; o Where trenching and associated activities such as site clearing and levelling will require more than 5 000 m2 (half hectare) a Phase 1 AIA is a legislated requirement independent of any other legislated requirements in terms of Section 38(1)(c)(i) of the NHRA.  General provisions in terms of this recommendation further include that should any heritage resource protected in terms of the NRHA be found, exposed and/or accidentally damaged during prospecting activities: o Digby Wells will be notified immediately; o Chance find procedures must be implemented; and o All work in the immediate area must temporarily cease until a proper assessment can be made by Digby Wells specialists. 3.2.2.3 Socio-Economic Mitigation Measures Recommended Enhancement Measures for Economic Benefits Clear policy guidelines and careful management of implementation will be required to ensure that benefits for the local population and economy are maximised where feasible. Without such measures, it is possible that the main benefits may be diverted elsewhere – either because of the majority of unskilled workers being sourced from outside the local area or because of corruption, bribery and nepotism amongst persons responsible for recruiting construction workers. Potential management measures include:  Development and implementation of a Social and Labour Plan (SLP) which makes provision for preferential local community and skills training; and  Consider undertaking a skills audit to determine the types of skills that are available locally and what types of training can be provided. It should be noted, however, that most of these mitigation measures will only become applicable or feasible at the time that the mine is established, rather than during prospecting. 78

Recommended Mitigation Measures for Physical and Economic Displacement Prospecting activities should be carried out in such a way to avoid damage to agricultural fields and other assets as far as this is possible. Measures to avoid unnecessary damage would include clear guidelines and codes of conduct for contractors, as well as subsequent enforcement of these. Where prospecting activities cause unavoidable damage, prompt and fair compensation should be paid to affected parties. A reasonable rate should be set for compensation for different kinds of assets (e.g. per hectare for different types of crops) and should be consistently applied. Local community members should be informed in advance of the compensation regime, and of the channels of communication available to bring infringements or damages to the attention of the relevant parties. It the event that physical displacement of households proves to be unavoidable, it will be necessary to develop a Resettlement Action Plan (RAP) to describe how impacts associated with such displacement would be managed and mitigated (either through relocation or compensation). The project proponent as indicated that, should relocation be required, it will be undertaken according to international best-practice standards.7 Recommended Mitigation Measures for Community Well-being and Safety Likely mitigation measures to minimise the influx of job-seekers would include clear communication of the project proponent’s intent to give preference to local employment, while awareness programmes on road and project-related safety could reduce safety risks associated with construction activities. Adequate fencing of hazardous areas is also recommended. Recommended Mitigation Measures for Physical Intrusion With regard to vibration, noise and air pollution, technical input is required from the relevant specialist studies (air quality, noise, etc.) to identify suitable mitigation measures. In order to mitigate impacts on daily movement patterns, it will be necessary to identify the roads, footpaths and other movement corridors frequently used by local communities, and then to determine whether the effect on these (if any) could be avoided or ameliorated through appropriate placement of infrastructure, through the establishment of crossing points or walkways, etc. As was agreed during the public participation process conducted for the project,8 local communities should be consulted during the arrangement of site access. If a construction camp is established, strict management of camp conditions, clear codes of conduct for camp occupants and adequate security measures will be required. 3.2.3 Review the significance of the identified impacts

Please refer to the tables below.

7 Digby Wells Environmental (2013). Platinum Group Metal prospecting right application: Comments and Response Report. March 2013. 8 Digby Wells Environmental (2013). Platinum Group Metal prospecting right application: Comments and Response Report. March 2013. 79

Table 26: Construction / Establishment Phase (Earth Clearing and Site Establishment)

Activity, Phase and Impact Impact Rating (after mitigation)

(147) Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Consequence

Probability(7)

Spatial Spatial Scale(7)

Significance Natureof Impact (positive /

Biophysical Impacts Soil erosion C N 1 2 1 4 3 12

Soil Compaction C N 1 3 2 6 4 24

Noise C N 1 3 1 5 3 15

Access roads- Generation of C N 1 1 1 3 3 9 dust

Access roads- Traffic C N 2 2 1 5 3 15

Access roads- Surface C N 1 2 1 4 3 12 damage on roads 80

Activity, Phase and Impact Impact Rating (after mitigation)

(147) Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Consequence

Probability(7)

Spatial Spatial Scale(7)

Significance Natureof Impact (positive /

Biophysical Impacts Hydrocarbon spillages C N 1 2 1 4 3 12 Ablutions C N 1 1 1 3 1 3 Domestic Waste C N 1 1 1 3 1 3 Surface Water Quantity C N 1 1 2 4 4 16

Surface Water Quality C N 1 1 1 3 5 15

Loss of Biodiversity C N 2 3 3 8 4 32

Loss of Vegetation C N 2 2 2 6 4 24 Communities

Loss of Ecosystem Function C N 2 3 3 8 4 32 81

Table 27: Operational Phase (Drilling and Possible Trenching)

Activity, Phase and Impact Impact Rating (after mitigation)

Phase impact Impacted Environment occurs (C,

O, D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact (positive /

Biophysical Impacts

Drilling - Removal of water O N 1 1 1 3 2 6 generated during drilling

Drilling - Spread of alien invasive plant species to O N 1 1 1 3 1 3 other sites

Access roads - Generation of O N 1 1 1 3 3 9 dust

Access roads - Traffic O N 2 2 1 5 3 15

Access roads - Surface O N 1 2 1 4 3 12 damage on roads 82

Activity, Phase and Impact Impact Rating (after mitigation)

Phase impact Impacted Environment occurs (C,

O, D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact (positive /

Biophysical Impacts

Hydrocarbon uses and O N 1 2 1 4 3 12 spillages - Soil Contamination

Loss of Biodiversity O N 2 3 3 8 4 32

Loss of Ecosystem Function O N 2 3 3 8 4 32

Ablutions O N 1 1 1 3 1 3 Domestic Waste O N 1 1 1 3 1 3 Surface Water Quantity O N 1 2 1 4 1 4

Surface Water Quality O N 3 3 3 9 2 18 Noise O N 2 2 2 6 3 18

Table 28: Decommissioning Phase

Activity, Phase and Impact Impact Rating (after mitigation)

(positive / Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact

Biophysical Impacts Access roads - Generation of D N 1 1 1 3 3 9 dust

Access roads- Traffic D N 2 2 1 5 3 15

Hydrocarbon uses and D N 1 2 1 4 3 12 spillages - Soil Contamination

Surface Water Quality - Removal of General Waste and D N 1 2 1 4 1 4 other Rubble 84

Activity, Phase and Impact Impact Rating (after mitigation)

(positive / Phase impact Impacted Environment occurs (C, O,

D, PC)

Negative

Severity (7) Severity

Duration(7)

Significance

Consequence

Probability(7)

Spatial Spatial Scale(7) Natureof Impact

Biophysical Impacts

Surface Water Quality - Sump D N 1 2 1 4 1 4 Clean-up and backfilling

Surface Water Quantity - Sump D N 1 2 1 4 1 4 Clean-up and backfilling

4 REGULATION 52 (2) (d): Financial provision. The applicant is required to-

4.1 Plans for quantum calculation purposes. Non-invasive prospecting methods will identify the locations of the drill and possible trenching sites. It is currently anticipated that there will be 10 drill sites on the prospecting right application area. Each drill site will have approximate dimensions of 10m x 20m in size hence a footprint of 200m2. A sump will be constructed on-site and approximately 4m3 of soil will be removed for this purpose. 4.2 Alignment of rehabilitation with the closure objectives In order to align rehabilitation initiatives with the closure objectives it is imperative to firstly define the closure objectives. Closure objectives are defined as follow:  The holder of a prospecting permit must, as far as it is reasonably practicable, rehabilitate the environment affected by the prospecting operations to its natural or predetermined state, or to a land use which conforms to the generally accepted principle of sustainable development, through: restoration, remediation, rehabilitation, and stabilisation;  Correct allocation of closure funds according to the closure plan and ensure adequate financial provision;  To ensure that good water quality is maintained on site; and  Monitoring will continue until such a time that it can be proven that there are no more negative impacts on the environment and site closure can be achieved. In line with the above objectives rehabilitation will include:  All evidence of impacts associated with or resultant to prospecting should be rehabilitated;  Sites should be left waste free and stable;  All the soil that has been removed by the drilling activity be replaced and shaped and the affected areas due to drilling will then be rehabilitated;  Soil/surface rehabilitation must be conducted in such a way as to ensure that the site is left stable with no further impacts relating to soil erosion;  The topography of the disturbed area should be reinstated to its former natural state as far as possible;  All new tracks will be rehabilitated;  All boreholes will be sealed;  Monitoring on the success of rehabilitation i.e. vegetation establishment, should be conducted regularly (at least monthly) to ensure that the sites have been rehabilitated successfully; and  Should rehabilitation prove not to have been successful additional a fertilisation and seeding programme must be followed by a qualified ecologist. 86

4.3 Quantum calculations.

Financial Provision Calculations - Rehabilitation

Item Unit Quantity Rate Cost 1 Sump Topsoil m3 4 R 50.69 R 202.74 Fill sump Labour 1 R 150.00 R 150.00

2 Drill area Re-vegetate ha 0.02 R 22 260.00 R 445.20 Shape ha 0.02 R 1 378.00 R 27.56

3 Borehole Fill borehole (100m) m3 7 R 17.17 R 120.17 Concrete m3 0.7 R 27.21 R 19.05

4 General Clean-up Labour 1 R 150.00 R 150.00

5 Inspection hrs 0.5 R 800.00 R 400.00

Total R 1 514.72

*GRAND TOTAL - MULTIPLIED BY 10 BOREHOLES Grand Total R 15 147.25

4.4 Undertaking to provide financial provision The amount provided above will be made available as a Bank Guarantee on approval of this EMP. 5 REGULATION 52 (2) (e): Planned monitoring and performance assessment of the environmental management plan.

5.1 List of identified impacts requiring monitoring programmes. 1. Drilling- Removal of vegetation; 2. Drilling- Soil erosion; 3. Drilling- Air and noise; 4. Drilling- Water generated; 5. Drilling- Cleaning of machinery before using on next site to prevent spreading alien invasive plants; 6. Drilling- Rehabilitation; 7. Access roads- Damage to road surface; 8. Hydrocarbon usage; 9. Ablutions; 10. Domestic waste; and 11. Fires. Wetlands, pans and lakes will be avoided during prospecting. 5.2 Functional requirements for monitoring programmes. 1. Removal of vegetation- Vegetation removed from the site will be stored outside the prospecting site. All topsoil removed will be stored and protected from erosion for use during rehabilitation. 2. Air and Noise- Roads must be sprayed with water to suppress dust. The drill should be maintained and serviced regularly and a silencing system should be fitted on it if possible. Drilling is only to take place between sunrise and sunset. 3. Water generated from drilling should be captured and treated as hazardous waste since drill fluids will be present in water. 4. Access roads- Machinery operators and drivers should be made aware of the possible safety hazards they could pose. 5. Gravel roads should be repaired. 6. Ablutions- The contents of the chemical toilets should be emptied on a regular basis (weekly) to prevent spillages. 7. Domestic waste- Bins will be placed at each site to collect domestic waste and will be disposed of at a registered site. 8. Use of hydrocarbons- During drilling a spill tray will be placed under the machinery. Should spillages occur the soil will be removed and treated as hazardous waste. 9. Cleaning of machinery and equipment will be performed to avoid the spread of alien invasive species to other areas. 10. Wetlands will be avoided. 11. No open fires are allowed to be made in the project area. 88

5.3 Roles and responsibilities for the execution of monitoring programmes. Supervisors should be appointed to monitor potential impacts of the above mentioned activities. Project Managers will foresee that all the management plans are implemented. The applicant will appoint an independent environmental control officer (ECO). The ECO will conduct a site visit during the drilling program to assess compliance with the EMP and a compliance audit report will be sent to the DMR. Once the prospecting program has been completed the ECO will conduct a site visit to audit the rehabilitation from which a closure plan and environmental risk report will be compiled and submitted to the DMR. 5.4 Committed time frames for monitoring and reporting.

Potential impact Frequency of monitoring Removal of vegetation Daily Air and Noise Daily Access roads Daily Ablutions Weekly Domestic waste Daily Use of hydrocarbons Daily Cleaning of Before next prospecting site. machinery/equipment Rehabilitation After prospecting activity completion on each site. Performance monitoring and reporting will be conducted annually as prescribed by the DMR. General environmental monitoring will be continuous throughout the prospecting operations.

6 REGULATION 52 (2) (f): Closure and environmental objectives.

6.1 Rehabilitation plan (Show the areas and aerial extent of the main prospecting activities, including the anticipated prospected area at the time of closure). On completion of drilling at a specific site the following activities will take place in chronological order: a) Sealing of borehole by means of a concrete plug below the natural ground level. b) Scarify the area to remove hardened/compacted surfaces. c) Water is pumped from the sumps within 24 hours once drilling has stopped. d) All plastic liners are removed from the sumps. e) A “soil fix kit” is applied which removes any traces of hydrocarbons should accidental spills/seepages have occurred during the event of prospecting. f) The soil is left for a period of 3 to 4 days to ensure that all hydrocarbons are removed. 89

g) Fertilizers are then applied to the area and left for a period of between 3 to 4 weeks. During this period the soils is left to dry. h) The topsoil is levelled over the entire area and all sumps/excavations are backfilled. i) Where necessary the area is ripped then levelled and profiled to its previous state. Note: Topsoil is found from a depth of one metre to 16 metres below surface. According to the soil profile of the area only topsoil, and no subsoil, are removed during prospecting. Should trenching take place, these trenches should be backfilled and levelled with the material taken from the trench once sampling has ceased. From a rehabilitation point of view, all sites will be rehabilitated, as far possible, to its former natural state.

Figure 22: Typical rehabilitated prospecting site 6.2 Closure objectives and their extent of alignment to the pre- mining environment. Refer to closure objectives in section 4.2 of this report.  The site will be rehabilitated to allow for natural vegetation to re-establish. This is generally accomplished by good preservation of topsoil which is generally fertile soils and contains a significant amount of natural seeds.  Trees will not be uprooted however, smaller shrubs may be removed. 90

 The general topography will be maintained where possible but will be reinstated during rehabilitation.  Rocky areas will be avoided (as these are also associated with sensitive habitats).  Alien species will be monitored and where possible existing alien species will be eradicated during the cause of prospecting. Minimal disturbance to subsoil will assist with accomplishing a pre-prospecting environment. 6.3 Confirmation of consultation A comprehensive consultation process has been undertaken with the relevant landowners and I&APs. Refer to section 7 below. 7 REGULATION 52 (2) (g): Record of the public participation and the results thereof.

7.1 Identification of interested and affected parties.

7.1.1 Name the community or communities identified, or explain why no such community was identified. The following farms were identified for the proposed prospecting activities by Platinum Group Metals (RSA) (Pty) Ltd in terms of the Mineral and Petroleum Resources Development Act, 2002 (Act No.: 28 of 2002) (MPRDA), Waterberg District, Limpopo Province:

Application number Farms LP30/5/1/1/2/10805PR Bonne Esperance 356 LR, Too Late 359 LR, Mont Blanc 328 LR, Nieuwe Jerusalem 327 LR, Gallashiels 316 LR, Sweethome 315 LR, Blackhill 317 LR, Bognafuran 318 LR, Liepsig 264 LR RE, Liepsig 264 LR Ptn1, The Park 266 LR

Within the applicable prospecting right application area the following communities were identified and consulted: 91

Prospecting Licence Farm Name Company / Owner Community Occupier, Headman, Chairperson LP30/5/1/1/2/10805PR Bonne Esperance 356 LR Limpopo Department of Rural Development and Land Located in the mountains, no Not applicable Reform Limpopo community Too Late 359 LR Bahanana Tribe Located in the mountains, no Not applicable community Mont Blanc 328 LR Limpopo Department of Rural Development and Land Located in the mountains, no Not applicable Reform Limpopo community Nieuwe Jerusalem 327 LR No information available Located in the mountains, no Not applicable community Gallashiels 316 LR Government Of Lebowa Jerusalem Mr Hlako Sweethome 315 LR Limpopo Department of Rural Development and Land Sweethome P. Maboya Reform Limpopo Blackhill 317 LR Government Of Lebowa Kobe Mr Cairo Kobe Bognafuran 318 LR Malaboch Stam-Tribe Bognafuran Mr Kubu Leipsig 264 LR Bahananoa Tribe / Berliner Missionsgesellschaft Trust Sehlong Mr Waleng The Park 266 LR Bahananoa Tribe Located in the mountains, no Not applicable community

7.1.2 Specifically state whether or not the community is also the land owner. Directly affected stakeholders were identified by means of Windeed searches and the landownership of the relevant farms are provided in Section 7.1.1. A field visit was conducted from 5 – 8 March 2013 in order to identify affected communities together with traditional authorities. 7.1.3 State whether or not the department of land affairs have been identified as an interested or affected party. The Limpopo Department of Rural and Land Reform has been identified as an Interested and Affected Party and included in the Public Participation Process (PPP). Please find the relevant contact details below: Ms Essy Letsoalo, E-mail: [email protected], Phone: (015) 297- 3539. 7.1.4 State specifically whether or not a land claim is involved. A request for land claims information has been submitted to the Limpopo Department of Rural and Land Reform of which the outcome of any land claims over the applicable Farms is still pending. Please find the relevant contact information below: Mr T.A. Maphoto, E-mail: [email protected], Fax: (015) 295- 7404/7403. 7.1.5 Name the Traditional Authority identified. There are two Traditional Authorities in the prospecting area which were identified namely, the Seakamela and Bahananwa Traditional Authorities. 7.1.6 List the landowners identified by the applicant. Please refer to Section 7.1.1. 7.1.7 List the lawful occupiers of the land concerned. Please refer to Section 7.1.1. 7.1.8 Explain whether or not other persons’ (including on adjacent and non-adjacent properties) socio-economic conditions will be directly affected by the proposed prospecting or mining operation if not, explain why not. The proposed prospecting activities will be conducted using invasive and non-invasive methods. Invasive methods will result in land disturbances however, the socio- economic conditions of land occupants will not be directly impacted since site rehabilitation will be undertaken and mitigation measures implemented throughout the prospecting process. Prospecting activities that need to take place close to communities or homesteads will only be undertaken during the day which will ensure that impacts are minimised. It is anticipated that livelihood activities of community members, such as farming, will be marginally affected. Consultation with the affected communities will take place prior to any prospecting activities. 7.1.9 Name the local municipality. The Blouberg Local Municipality, which fall under the Capricorn District Municipality.. 93

7.1.10 Name the relevant Government Departments, Agencies and institutions responsible for the various aspects of the environment and for infrastructure which may be affected by the proposed project. The various Government Departments, agencies and institutions included in the PPP are set out below:

National  Department of Environmental Affairs  Department of Water Affairs  South African Heritage Resources Agency

Provincial  Limpopo Department of Public Works  Limpopo Department of Agriculture  Limpopo Department of Roads and Transport  Limpopo Department of Rural Development and Land Reform  Limpopo Economic Development, Environment and Tourism  Limpopo Provincial Shared Services Centre  Limpopo Provincial House of Traditional Leaders  Limpopo Department of Cooperative Governance, Human Settlements and Traditional Affairs

District and Local  Waterberg District Municipality  Mogalakwena Local Municipality  Blouberg Local Municipality

Non-governmental Organisations  Wildlife and Environmental Society of South Africa (WESSA)  Birdlife SA  SANParks  Wildlife Ranch South Africa  Council for Geoscience  GroundWork - Friends of the Earth  Northern Traansvaal Agricultural Union  Blouberg Nature Reserve  Wonderkop Nature Reserve

A full stakeholder database is included as Appendix D.

7.1.11 Submit evidence that the landowner or lawful occupier of the land in question, and any other interested and affected parties including all those listed above, were notified. A field visit was conducted from 5 – 8 March 2013 in order to identify the relevant communities and traditional authorities within the prospecting right application areas. During this visit meetings were scheduled for the week of 11 – 15 March 2013 and letters were also provided to the community leadership (see Appendix C of the Consultation Report) which provided high level background information of the proposed project. Community meetings were conducted during the week of 11 – 15 March 2013 (see Figure 23 as example) and the relevant attendance registers for these meetings are included as Appendix D of the Consultation Report). At these meetings project information was hand delivered and shared by means of Background Information Documents (BIDs) (see Appendix E of the Consultation Report)) and a site notice that was put up within the community (see Appendix F of the Consultation Report)as example). All I&APs were provide with an opportunity until April 5th 2013 to comment on the BID and proposed project. Community meetings were conducted in Sepedi and site notices (see Figure 24 as example). BIDs distributed at the meetings were in Sepedi also to ensure that community members would be able to read and understand information relating to the proposed project. Other I&APs (Government and NGOs) were notified by means of an English notification letter with comment & registration sheet and English BID that was distributed via email or post between 13 and 15 March 2013 (see Appendix G of the Consultation Report)). Adverts were also placed in English in the Limpopo Informant on 12 March 2013 and in the Capricorn Voice on 13 March 2013 (see Appendix H of the Consultation Report)). All the Public Participation materials provided to stakeholders contained background information about the proposed project, the location of the various prospecting right application areas, the applicable legislation for the prospecting right applications and the needed contact information for stakeholders to reach the Public Participation office at Digby Wells should any comments be provided.

Figure 23: Examples of community meeting

Figure 24: Examples of site notices placed in communities

7.2 The details of the engagement process.

7.2.1 Description of the information provided to the community, landowners, and interested and affected parties. See Section 7.1.11 for detail on the information that was provided to I&APs. Further to the information provided in Section 7.1.11, during the community meetings that were conducted from 11 – 15 March 2013 a presentation (see Appendix I of the Consultation Report) was made to the community leadership and community members (in Sepedi). For the presentation a set of A0 full colour posters were used together with a regional locality map which indicates the various prospecting rights application areas. The presentation was done at community halls or Kgoros and all meeting attendees had the opportunity to provide comments and ask questions about the proposed project. All stakeholder comments, issues of concern or suggestions were captured in a Comment and Response Report (CRR) as included in Appendix J of the Consultation Report. All comments received after the submission of the Consultation Report are included in the updated CRR report attached as Appendix E. 7.2.2 List of which parties identified in 7.1 above that were in fact consulted, and which were not consulted. Meetings were held on the following farms with the communities:

Farm Name Community Occupier, Headman, Chairperson Bonne Esperance 356 LR Located in the mountains, no Not applicable community 97

Farm Name Community Occupier, Headman, Chairperson Too Late 359 LR Located in the mountains, no Not applicable community Mont Blanc 328 LR Located in the mountains, no Not applicable community Nieuwe Jerusalem 327 LR Located in the mountains, no Not applicable community Gallashiels 316 LR Jerusalem Mr Hlako Sweethome 315 LR Sweethome P. Maboya Blackhill 317 LR Kobe Mr Cairo Kobe Bognafuran 318 LR Bognafuran Mr Kubu Leipsig 264 LR Sehlong Mr Waleng The Park 266 LR Located in the mountains, no Not applicable community Email and post correspondence were provided to the following stakeholders:

Name Surname Company Phillip Hine South African Heritage Resources Agency Paul Meulenbeld National Department of Water Affairs Twizwi Ramavhona Department of Environmental Affairs M. Phaladi Department of Environmental Affairs Mpoi Hamese Department of Mineral Resources Sanet van Jaarsveld Department of Water Affairs: Options Analysis Cate Mashapu Department of Mineral Resources Azwi Mulaudzi Department of Mineral Resources M. Mahlatji Department of Water Affairs N. Moloto Limpopo Department of Public Works S. Ntsoane Limpopo Dept of Agriculture Isaac Majadibodu Limpopo Department of Roads & Transport Essy Letsoalo Limpopo Department of Rural Development and Land Reform Foster Baloyi Limpopo Economic Development, Environment and Tourism T. Khuzwayo Limpopo Provincial Shared Services Centre Adam Gunn Limpopo Environmental Action Forum (LEAP) T. Khuzwayo Limpopo Provincial House of Traditional Leaders Limpopo: Cooperative Governance, Human Settlements and Nana Manamela Traditiona Affairs R.M Mabusela Mogalakwena Local Municipality Metse Ramahuma Blouberg Local Municipality M.R. Mogotlane Waterberg District Municipality N. Masupa Waterberg District Municipality Mokopane Letsoalo Waterberg District Municipality Bernice Mnisi Waterberg District Municipality M.A.D Monama Waterberg District Municipality Teboho Ntshangase Waterberg District Municipality S. Mashao Waterberg District Municipality M.R. Mogotlane Waterberg District Municipality Stanley Koenaite Waterberg District Municipality Carolyn Verdoorn Birdlife SA Simon Makhari Wonderkop Nature Reserve 98

Name Surname Company Johan Van Wyk Blouberg Nature Reserve Hector Magume SANParks Louis Meintjes National Water Forum Steven Hofman Northern Traansvaal Agricultural Union (NTLU) Pierra Jacobs NTK Limpopo Agric Megan Lewis GroundWork - Friends of the Earth Rico Euripidou GroundWork - Friends of the Earth Bantu Hanise Council for Geoscience Kerry Batytpp Wildlife and Environmental Society of South Africa (WESSA) Herman Barnard Wildlife Ranch South Africa (WRSA) Wanda Coetzee Wildlife Ranch South Africa (WRSA)

7.2.3 List of views raised by consulted parties regarding the existing cultural, socio-economic or biophysical environment. Please see Appendix E for the Comment and Response Report. 7.2.4 List of views raised by consulted parties on how their existing cultural, socio-economic or biophysical environment potentially will be impacted on by the proposed prospecting or mining operation. Please see Appendix E for the Comment and Response Report. 7.2.5 Other concerns raised by the aforesaid parties. Please see Appendix E for the Comment and Response Report. 7.2.6 Confirmation that minutes and records of the consultations are appended. Please see Appendix E for the Comment and Response Report and Appendix D for the updated Stakeholder Database. 7.2.7 Information regarding objections received. Please see Appendix E for the Comment and Response Report. 7.3 The manner in which the issues raised were addressed. Please see Appendix E for the Comment and Response Report.

8 SECTION 39 (3) (c) of the Act: Environmental awareness plan.

8.1 Employee communication process The applicant has developed Environmental, Health and Safety Policies. The Environmental Policy will be communicated to all personnel (contract or permanent staff). In addition the policy will be erected at each active prospecting site. Employees will receive general environmental awareness training on specific items contained in this EMP as well as on Best Possible Environmental Practices (BPEP).

8.2 Description of solutions to risks Each possible risk item (i.e. potential impact) has been identified in this report. For each impact or risk a mitigation measure was proposed. If employees are trained on these measures risk/impacts will be reduced. 8.3 Environmental awareness training. Training will be done to make employees and contractors aware of:  The importance of conforming with the environmental policy and procedures and with the requirements of the EMP;  The significant social and environmental impact of their work activities and the environmental benefits of improved personal performance;  Their roles and responsibilities in achieving conformance with the environmental policy and procedures and with the requirements of the environmental management system;  The potential consequences of departure from specified operating procedures; and  Possible archaeological finds, action steps for mitigation measures, surface collections, excavations and communication routes to follow in the case of a discovery. The guidelines for training are summarised in the table below, which are in line with the ISO 14001:2004 guidelines with regards to training and awareness creation. Table 29: Training Guidelines

Types of training Audience Purpose

To gain commitment and Raising awareness of the alignment to the strategic importance of Senior management organisation’s environmental environmental management policy.

To gain commitment to the environmental policy, Raising general All employees objectives and to instil a environmental awareness sense of individual responsibility.

Employees with To improve performance in Skills enhancement environmental responsibilities specific tasks.

To ensure that regulatory and Employees whose actions can Compliance internal requirements for affect compliance training are met.

The training programme will consist of the following elements:  Identification of employee training needs; 100

 Development of a training plan to address defined needs;  Verification of conformance of training programme to regulatory or organisational requirements and standards;  Training of target employee groups;  Documentation of training received; and  Evaluation of training received. This training is done on an annual basis for all personnel, together with the annual required induction programmes. The training material provided will be subject to annual review based on such issues as: incidents, accidents, new legislative requirements, modified processes, and environmental and social aspects identified from time to time. This training is to be carried out and coordinated internally by the Applicant. The applicant will therefore develop the capabilities and support mechanisms necessary to achieve its environmental policy, objectives and targets. In addition an Emergency Preparedness Plan will be communicated and trained to all site personnel during the induction process. 9 SECTION 39 (4) (a) (iii) of the Act: Capacity to rehabilitate and manage negative impacts on the environment.

9.1 The annual amount required to manage and rehabilitate the environment. The closure for 10 boreholes was calculated to be approximately R15 000.00 over a period of 3-5 years and the amount to be made available per annum for rehabilitation is calculated to be a minimum of R3000.00 per annum and maximum of R5000.00 per annum. 9.2 Confirmation that the stated amount correctly reflected in the Prospecting Work Programme as required. The above amount was not included in the PWP as submitted. An accurate determination is presented above.

101

10 REGULATION 52 (2) (h): Undertaking to execute the environmental management plan.

Herewith I, the person whose name and identity number is stated below, confirm that I am the person authorised to act as representative of the applicant in terms of the resolution submitted with the application, and confirm that the above report comprises EIA and EMP compiled in accordance with the guideline on the Departments official website and the directive in terms of sections 29 and 39 (5) in that regard, and the applicant undertakes to execute the Environmental management plan as proposed.

Full Names and Ellison Michael Wasserfall Surname

Identity Number 4605315080087

-END-