ELANDSFONTEIN PHOSPHATE MINE ON FARM 349/4 AND A PORTION OF ARM 349/2, MALMESBURY RD, WEST COAST, WESTERN CAPE
‘
COMMENTS AND RESPONSES REPORT
Prepared for:
Prepared by:
September 2014
Report number: BEP SC140416C
Reference No:
WC30/5/1/2/2/10043 ELANDSFONTEIN PHOSPHATE MINE ON FARM 349/4 AND A PORTION OF ARM 349/2, MALMESBURY RD, WEST COAST, WESTERN CAPE
Comment and Response Report
Billet Trade (Pty) Ltd T/A Braaf Environmental Practitioners P O Box 692 KUILS RIVER 7579 Tel (0860) 111 382 Fax (086) 658 7676 Email: [email protected]
BEP Project Number 10043
September 2014
Compiled by:
Olivia Braaf
Contents 1. Introduction ...... 1 2. Public Participation Activities Undertaken to Date ...... 2 2.1 Overview of Application ...... 2 2.2 Scoping ...... 3 2.3 EIA-EMP Consultation ...... 4
APPENDICES
Appendix : Comment received
1. Introduction
This Comment and Response Report (CRR) records the issues of concern, suggestions and other comments expressed by stakeholders in writing (comment sheets accompanying the Background Information Document distributed during project announcement), and a series of meetings held during the scoping and EIA-EMP phase regarding the Elandsfontein Phosphate Mine Project. Comments have been summarized to capture the key concerns as raised1.
Meetings have taken place since December 2013 – September 2014. The list of meetings is presented in Table 1-1. These are largely meetings that have been held with key stakeholders.
Table 1-1: List of meetings held to date
Stakeholder Group Date Venue Adjacent landowners December 2013 – September 2014 Open day/public meeting: 6 January 2014 Hopefield Self-Catering Hopefield Chalets and Recreational Park Open day/public meeting: 8 January 2014 Dial Rock Hall, Saldanha bay Saldanha
Hopefield 13 February 2014 Hopefield CapLandebNoatuvuerere niging 18 February 2014 CapeNature H/O, Saldanha Bay Municipality 10 March 2014 SBBridMg etown SANParks, DWA & Cape 18 March 2014 Cape Research Centre, Tokai Research Centre ESKOM 26 March 2014 WCOU - Network Planning PGWC: Roads 10 April 2014 & 6 June 2014 9 Dorp Street, Cape Town
Portnet ongoing SBM: Air Quality Department 30 January 2014 (telephonic discussion) DEA&DP 15 May 2014 1 Dorp Street, Cape Town
District Roads Engineer 11 September 2014 Ceres
Hopefield Public Meeting 11 September 2014 Hopefield
Saldanha Public Meeting 12 September 2014 Diazville
Langebaan Public Meeting 15 September 2014 Langebaan
Meetings with affected See signed document September 2014 landowners (infrastructure) indicating consultation
Meeting with SANParks 11 September 2014 Bellville
1 All supporting documentation such as comment sheets, minutes, etc are deemed to be captured in this report if in part or full contained within the main report or as an appendix. PAGE: 1 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Meeting with DWA 12 July 2014 Bellville
Ongoing consultation with September 2014 DWA regarding Water Use License (DMR – Jan Briers, copied into correspondence) HWC – telephonic August 2014 correspondence August 2014
Meetings and August 2014 (refer to written correspondence with correspondence). Saldanha Bay Municipality
Written correspondence with August – September 2014 CapeNature
This report also records the responses by members of the BEP EIA team and the Elandsfontein Exploration and Mining (EEM) project team to the issues, questions, comments and suggestions received from stakeholders.
The comments captured in this report include comments received on the Scoping Report and EIA-EMP received by 15 September 2014.
The comments raised at the public meetings are dealt with in the minutes/notes of the meetings.
Please note that the comments received during the Scoping Phase have been responded to based on the information available at that time and thus will not be altered. However, where questions posed related to specialist studies during the scoping phase, these will be addressed and will be underlined to indicate additional responses. This report has been divided into a Scoping phase comments and response table and the EIA-EMP Comments and Responses Table.
2. Public Participation Activities Undertaken to Date
2.1 Overview of Application Elandsfontein Exploration and Mining (Pty) Ltd submitted their mining right application to the Department of Mineral Resources in December 2013. On 11 December 2013, the application was accepted. DMR instructed EEM to:
- Submit a Scoping Report on or before 10 January 2014; - Submit an EMPR on or before 10 June 2014; - To notify in writing and consult with the landowner or lawful occupiers and any other affected party and if applicable the Land Restitution commission.
In keeping with the requirements of the Mineral and Petroleum Resources Development Act, 2002 (MPRDA) the following activities were conducted.
PAGE: 2 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
2.2 Scoping At the onset of the public participation process (PPP) required in terms of the MPRDA (Scoping) the following activities were undertaken:
Identification of Interested and Affected Parties A key principle informing the PPP is that it should be an inclusive process. Given the sensitivities around the biodiversity associated with the Project location and high rate of unemployment in the region, it is important that stakeholders from the district and local municipalities, environmental bodies and landowners are given the opportunity to participate in the process.
Notification activities have been designed to ensure that stakeholders are invited to be involved in the process.
Stakeholders were invited to become part of the process in two ways: - Through notification activities which were designed to ensure that the broader public were informed of the process and invited to be involved; - Through BEP proactively registering stakeholders identified as potentially interested or affected - through the mining right application process; and - Networking with key stakeholders throughout consultations. - Stakeholders have been notified and invited to register as I&APs in the Project through a series of English and Afrikaans PPP notification materials.
The stakeholder database was updated throughout the application as this is a continuous process.
Newspaper advertisement Notification of the scoping process and availability of information was advertised for public comment (as required in terms of regulation 49(f) of the MPRDA) (on 19 December 2013 in the local Weslander newspaper [English and Afrikaans] and in the regional Die Burger newspaper [Afrikaans]) in order to include the views and concerns of IAPs. I&APs were provided with a 30 day comment period. I&APs were informed that all comments submitted to BEP by 8 January 2014 would be included in the Scoping Report submission to DMR on 10 January 2014 in order to meet the deadline, but that comments received afterward within the 30 day comment period, ending 19 January 2014 would be included in the EIA/EMP. These comments were however, included in the revised Scoping Report. Comments were categorised into key environmental categories, which in turn were divided into key issues. All the key issues were responded to by BEP.
I&AP Notification I&APs were notified via email, fax, and post of the project which included the Background Information Document.
Site Notices A number of site notices were placed at entrances to the proposed mine site and in the greater Saldanha Bay Municipal Area.
Public Meetings Two Open Days and Public Meetings (see table below) were held and notes were taken at the meetings.
PAGE: 3 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Date and Time Meeting format Venue Monday, 6 January 2014 Open House Session (posters and one-on- Hopefield Self-Catering one sessions was held with the project team) Chalets and Recreational Park from 16h00 – 18h00 Public Meeting (a formal presentation by the project team followed by a question and answer session) from 18h00-20h00 Wednesday, 8 January 2014 Language: English/Afrikaans Dial Rock Hall, Saldanha Bay
Refer to Appendix B5 for the minutes of the meeting and attendance registers.
On submission of the results of scoping to the DMR, they consulted the Scoping Report with other Government Departments in terms of Regulation 49(3) of GN No. R 527 of 23 April 2004, under section 107(1) of MPRDA, and requested for these organs of state to provide written comment, namely:
• DEA&DP; • CapeNature; • Department of Water Affairs; • SANParks; • Local Authority (Saldanha Bay Municipality); and • Heritage Western Cape.
After review of the Scoping Report by DMR and the organs of state listed above they sent a letter to EEM on 14 March 2014 providing them with the key issues that required further input. Amongst others, EEM were requested to submit a revised scoping report addressing the outstanding issues indicted by DMR.
Revised Scoping Report This report was made available for public review and comment from 2 May 2014 till 2 June 2014 at the following venues.
Hopefield Public Library Diazville Public Library Louwville Public Library
Saldanha Bay Library Langebaan Public Library Project website: www.braafsa.com
Newspaper advertisement and I&AP Notification The release and availability of the report was advertised in the Weslander and Die Burger on 1 May 2014 (in English and Afrikaans) and 5 May 2014, respectively. All registered I&APs were notified of the release and availability of the report. All comments received by 2 June 2014 were incorporated as part of the draft EIA/EMP which is to be submitted to the DMR on 10 June 2014.
Comments and Response Report (CRR) The Comments and Response Report (CRR) was updated and included in the Revised Scoping Report which was released for comment. This included all comments received up till April 2014.
2.3 EIA-EMP Consultation
Notification of the EIA-EMP for comment and Public Meetings
PAGE: 4 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Release and availability of the EIA/EMPR in terms of the MPRDA as well as the 30 day comment period .The DMR has requested the submission of the proof of I&AP consultation on the EIA/EMP by 16 September 2014. Comments submitted as a part of the proof of consultation to the DMR which are received by 15 September 2014 will be included in the final EIA-EMP. All comments received after 15 September 2014 will be forwarded to the DMR for consideration as part of the application process.
Newspaper advertisement The release and availability of the report was advertised in the Weslander (English and Afrikaans) and Die Burger (Afrikaans) on 28 August 2014. All registered I&APs were notified of the release and availability of the report, the public meetings, the comment period and where the report is available.
Site notices and posters A number of site notices and posters were placed at entrances to the proposed mine site and in the greater Saldanha Bay Municipal Area. These notices informed I&APs of the release and availability of the report, the public meetings, the comment period and where the report is available.
Report availability The report has been made available at the following venues: • Langebaan Public Library • Hopefield Public Library • Saldanha Bay Public Library • Vredenberg Public Library • Project website: www.braafsa.com
In addition, a number of reports were made available to I&APs on CD on request (SANParks, affected landowners, I&APs attending the public meetings, and registered I&APs. Reports were also made available on Dropbox on request from SANParks for CRC/independent specialists. Hard copies were provided to the WCBR and Saldanha Bay Municipality.
Public meetings Public meetings were held at:
Item Date and Time Where? Public Meetings Hopefield 11 September 2014 - 6pm – Hopefield Sports Club 8pm Saldanha Bay 12 September 2014 - 6pm – Diazville Community Centre 8pm Langebaan 15 September 2014 - 6pm – Langebaan Country Estate 8pm
Refer to Appendix B5 for the minutes of the meetings and attendance registers of the public meetings.
Meetings In addition to the public meetings for both the Scoping and EIA-EMP processes a host of one-on-one meetings were held with key stakeholders and state departments which include: - Western Cape Departement of Roads – Malcolm Watters - District Roads Engineer – Lars Starcke - DEA&DP - CapeNature - SANParks - Saldanha Bay Municipality
PAGE: 5 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
- ESKOM (powerlines) - DWA – a water steering committee has been established by DWA for this project which comprises representatives from the CSIR, SANParks, Saldanha Bay Water Quality Trust (SBWQT), Elandsfontein Exploration and Mining (EEM), West Coast Cape Biosphere Reserve (WCBR), DWA National and Regional Representatives - Adjacent affected landowners - As part of the socio-economic assessment, one-on-one interviews were undertaken with municipal officials, representatives from the Saldanha Industrial Development Zone, surveys and interviews were done on businesses in the Saldanha Bay Municipal Area.
Refer to Appendix B5 for the notes of these meetings/proof of consultation.
PAGE: 6 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
SCOPING PHASE Willem Louw, Manager: Conservation Planning Conservation Services, South African National Parks (SANParks)– emailed – 28/02/2014
Please note the following: Noted. The proposed mine area which will take place on private land, namely a) SANParks’ legal mandate is to protect, control and manage National Farm 349/4 and a portion of Farm 349/2, which abuts the WCNP. It must be Parks and other defined protected areas and their biological diversity, stated that currently prospecting activities is being undertaken on the farm in (NEM:PAA 57 of 2003); line with the prospecting right granted to the Applicant by the DMR on 3 April b) SANParks manage WCNP in terms of a management plan, approved by 2013 for a period of 3 years. The prospecting right extends over 1428.81 ha. the National Minister of Environment and Water Affairs, on 05-09-2013. The prospecting rights were awarded to EEM prior to the remainder of the In terms of the approved management plan, the proposed mining area WCNP being declared in November 2013. falls within WCNP core expansion and buffer areas;
Biodiversity and Ecology There are four primary vegetation types on site c) The area contains endangered vegetation types – the site is also listed Namely: by SANBI and Saldanha Bay Municipality’ SDF as a Critical Biodiversity • Hopefield Sand Fynbos and in terms of the National List of Threatened Area or (CBA); Ecosystems is regarded as Vulnerable. d) The Site is therefore of very high biodiversity value, including two very • Saldanha Flats Strandveld - Vulnerable in the National List of Threatened important aquifers; SANParks is therefore concerned about possible Ecosystems (DEA 2011). groundwater contamination: • Langebaan Dune Strandveld - Least Threatened on a national basis (DEA 58 SANParks is concerned regarding possible negative impacts on the 2011) Langebaan Lagoon, an international Ramsar site, which is • Saldanha Limestone Strandveld – Least threatened. administered by the West Coast National Park; Severe harm could be done to the Park and the Lagoon through It is noted that the area is identified as a Critical Biodiversity Area. pollution of groundwater; SANParks, therefore encourage the applicant to do a thorough hydrological Currently a baseline water quality study of adjacent surface waters (groen and sout assessment of all possible impacts of rivers) is being undertaken as well as a geohydrological study which accompany the e) The impact of dust, noise generation, spread of alien species, loss of updated EMP which will be submitted to DMR and circulated for comment. (refer to threatened species and habitats, possible decrease in natural beauty Appendix C4 of the EIA-EMP for the groundwater study). and aesthetics of the area should also be investigated. f) These impacts may also be felt by the fishing and agricultural industries Further specialist studies to address the potential impacts of the mine related to noise, and the knock-on effects of impacts to the park and lagoon will air quality, flora and fauna is being undertaken. As there is cross collaboration between significantly impact on the tourism industry of the area and many many of the studies the specialists will investigate the direct and potentially indirect livelihoods. impacts of the project on natural resources. (these studies have been undertaken refer to Appendix C of the EIA-EMP).
We therefore encourage the applicant to review similar cases where severe Noted. The scoping report which was released for comment included the draft Terms of PAGE: 7 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
environmental damage has resulted from phosphate mining, and to learn Reference of the Specialist studies and hence your comment on that report will be from the mistakes made. We would like to request that SANParks have taken into account in terms of the scope of the studies. input into the terms of reference that are drawn up for each of the impact studies that are to be conducted.
In particular (and identified in the scoping report in some instances), we The following studies are currently being undertaken which will be made available for believe that the following additional studies are required: comment as part of the updated EMP: Baseline water quality studies in Langebaan Lagoon; -baseline water quality study Ecological baseline studies in the Sout- and Groen Rivers; -air quality and noise study Assessment of dust impact (including impact on plants, pollinators - flora and fauna study and other animals); -avifauna study A full scale vegetation survey considering plant species of special -visual assessment which will investigate the impact of the mien on the surrounding concern – carried out and monitored in the appropriate seasons aesthetics of the area (this would require winter and spring assessments); -a socio-economic study Noise assessment (including impact on animals); -the rehabilitation plan will be submitted to the DMR as a requirement of the MPRDA Light pollution assessment (including impact on animals); process – mining right. A full scale hydrological impact assessment including assessment of the impacts of polluted water on the park, local communities, In terms of the EIA-EMP the following specialist studies were undertaken: farmers and tourism; - Botanical, fauna, avifauna, socio-economic, Geohydrology, freshwater assessment, air quality and noise assessment, visual study, traffic, waste An socio-economic cost benefit assessment; management, paleontological and heritage, and rehabilitation plan including a A more thorough assessment of reptile and amphibian species; study on the economic significance of the deposit (refer to Appendix C of the A detailed rehabilitation/mitigation/reclamation plan. EIA-EMP)
Buffer Zone policy (Government Gazette, dated 8 Feb 2012, Notice no. 35020) As mentioned earlier in this report, the remainder of the proposed mining Noted. The proposed mine is to take place on private owned land which includes Farm area falls within the expansion footprint and buffer zone of the West Coast 349/4 and a portion of Farm 349/2, Malmesbury RD. SANParks issued a letter to EEM National Park. stating that the buffer zone has not been gazetted as yet (refer to Appendix B6). The purpose of a National Park buffer Zone is to: Protect the purpose and values of a national park, which is explicitly defined in the management plan, submitted in terms of sec 39(2) of the NEM:PAA; Goal 3 of the strategy reads as follow: ‘Discourage development in areas in which biodiversity and ecological function would be adversely affected. …all development in the buffer zone which may have a negative impact on the national park will be strictly controlled. The Buffer zone policy explicitly defines mining as “… PAGE: 8 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
development which may have a negative impact or effect on a national park…”
Mining and Biodiversity Guideline, 2013 The Mining and Biodiversity guidelines rate the proposed mining area as Your comment is noted. According to the updated information it appears that the area Category B, – highest risk for mining; extreme caution should therefore be on which the mine is to be located is on an area identified as a CBA which has exercised in all proposed mining activities - due to the very sensitive nature however not as yet been declared by the competent authority (and not indicated as of the area, which: gazette bioregional plans for the area). In addition, SANParks has indicated that the falls in a critical biodiversity area (CBA); buffer zone around the WCNP has not been gazetted as yet. The potential impact of Is adjacent to a national park, (in buffer the buffer zone of WCNP); the mine on groundwater sources has been assessed in the geohydrological study in Is located on two aquifers, (Elandsfonten – and Langebaanweg the EIA-EMPR (refer to Appendix C4). Further climate change assessments will be Aquifers); undertaken as part of the NEMA EIA process. In a key climate and ecological corridor
The guidelines further states that environmental authorisation may or may not be granted and that biodiversity offsets should be considered; however, strict limitation should be set and must be written into authorisations. SANParks fully supports the provisions and guidelines of the 2013 Mining and Biodiversity guidelines.
Cape Research Centre (CRC) Attached herewith, please note additional and detailed comments relating to Noted. Environmental Authorizations will include Conditions which will have to be the Scoping report – report compiled by a team of SANParks scientists at implemented by the applicant. CRC.
Please also note that SANParks - a key stakeholder in this mining application – did not receive the Scoping Report, as officially distributed by your department (DMR); no annexures were attached to the scoping report which was reviewed by CRC. We request that this oversight urgently be attended to. We request that all correspondence and reports regarding this mining application should be addressed to: Willem Louw, PO Box 440, SANLAMHOF, 7532 The DMR is responsible for circulating the Scoping Report to state departments and SANParks therefore reserves the right to revise initial comments based on organs of state. This matter was taken up with them and therefore Braaf Environmental additional information that may be received. Practitioners issued another copy directly to SANParks.
PAGE: 9 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The SANParks Cape Research Centre (CRC) Report compiled by Nicola van Wilgen – emailed – 02/03/2014
General comments Noted. The terms of reference of the specialist studies were made available for public Overall we found the report lacking in the detail required to determine the comment as part of the revised Scoping Report as well as to SANParks – CRC. The scope of potential positive and negative impacts of the proposed mining studies looked not only at the mine footprint. A socio-economic study was completed activities. Given the sensitive location of the area (threatened vegetation refer to Appendix C10 and Appendix C12 for the rehabilitation plan. types, underground aquifer, location in the buffer zone of a national park), we feel that a much more comprehensive and rigorous assessment, with better attention to detail, is required to highlight the full scope of potential impacts that this proposal encompasses. There were a number of minor 59 mistakes and inconsistencies throughout the report, which we have listed in the sectional comments below. Though most were not particularly serious, they do raise questions about the rigour of the work done. There are three priority areas which require urgent attention: 1) the wider impact of the mine on the ecosystem and particularly water, and 2) the socio-economic impact of mining activities and 3) the absence of a detailed rehabilitation/mitigation/reclamation plan. Several other issues are also raised. 1. Wider impact and water A detailed geohydrological study is currently underway which will look at the direct Firstly, although several negative impacts of the proposed mining activities potential impacts of the mining activity as well as the indirect potential impacts. This have been cited in the report, no reference is made to how these impacts report will be included in the updated EMP which will be made available for comment. will be experienced away from the mining site itself. The potential impact on groundwater is likely to be the most serious oversight in this regard. It A geohydrological study has been completed and provided to SANParks for comment. appears that there has been no groundwater study conducted. The These comments have been included in this CRR. conservation importance of the Langebaan Lagoon is given on pg 23, but we need to know how the mining will impact on the freshwater and 60 groundwater supplies to the Lagoon. This lagoon is a RAMSAR site, i.e. a wetland of international importance and a marine protected area which forms part of a national park. The lagoon also constitutes about 20% of South Africa’s total saltmarsh/eel grass populations (Zostera capensis) and potential reductions in water quality through seepage into the lagoon will negatively impact on these important beds. Furthermore, the lagoon provides an important source of income for local fishermen and is a very important tourist attraction for the region. Yet none of these issues are
PAGE: 10 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
discussed in report. There is some mention of studies underway, but these are dealt with superficially and none of the detail expected in a report of this nature is evident. A more focussed and detailed study of the impact of the mining activities on groundwater is imperative. Any contamination of this important water source will also impact people and the farmers who use this water for their household and agricultural purposes. This along with the potential negative impact on the tourism industry means that the impact of less or contaminated water will be felt across all socio-economic and environmental sectors. 2. Socio-economic impact A socio-economic study is currently underway and will be included in the updated EMP The second priority requirement is an assessment of the socio-economic which will be made available for comment which will address many of the issues listed impacts of the proposed mining. The report mentions benefits in terms of by you. The Social and Labour Plan which was submitted in the DMR as a requirement jobs to local people, but in section three it becomes clear that these jobs will of the Mining Right focuses on the direct social investment of the mine into key projects not be sustainable in the long term. No exit strategy or re-skilling is provided identified in consultation with the municipality and key stakeholders. The exit strategy for. It is simply stated that the jobs will end, meaning that local benefits may procedure (downscaling, retrenchments, upskilling related to direct and indirect be few. There is the likelihood that many of the beneficiaries, especially the employment) is all addressed in the SLP. skilled labour will not be local and that there will be an influx of people from other areas who will compete with locals for these jobs. Housing, transport As the mine will not accommodate any workers on site, all labour will be sourced from and amenities for labour are not dealt with in any detail in the report. In the nearby labour sending towns with the Saldanha Bay Municipality. This further addition, it is likely that crime, loitering and other social ills will increase informed the location of the mine’s main access road to the R45, so as to include (section 3) while the environment will be damaged, possibly decreasing towns like Hopefield. future opportunities for people as well as causing noise, pollution and unsightliness during the operational phase. These latter factors are all likely Refer to Appendix C10 of the EIA-EMP. 61 to be detrimental to the tourism industry which is one of the areas’ primary current industries and economic drivers. Pollution, unsightliness (negative aesthetics) and labour disputes could drive down tourism and cost significant numbers of associated jobs. It is therefore highly questionable that the socio-economic conditions of local people will be benefited by the proposed mining in the short, medium and long term, but they could be worsened.
It would be useful if subsequent reports provided information regarding the extent of the economic contribution from mining compared to existing contributions from conservation, tourism, agriculture and fishing which are currently substantial and come at a much lower risks to the people and the environment. Generally mines tend to enrich the owners of the companies whereas the municipalities where mining occurs receive minimal benefits. The short term nature of the jobs which may displace long-term agricultural PAGE: 11 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
and ranching jobs must be clarified. 3. Rehabilitation plan The rehabilitation plan is currently being prepared and will be included in the updated No clear rehabilitation plan was detailed in the scoping report. It is EMP which will be made available for comment which will address many of the issues appreciated that the land under mining cannot be fully restored, but should listed by you. This plan will include the cost of rehabilitation to which EEM will have to mining proceed, reclamation of the landscape is critical. The best possible provide guarantees to the DMR prior to the mining right being issued. Refer to the EIA- restoration will rely on implementation of mitigation measures throughout all EMP and Appendix C12 of the latter document. phases of setting up, operation and. decommissioning. Detailed plans at each of these phases are required. Adequate land reclamation must A geohydrological study is currently investigating the potential impact of the mien on consider relevant conservation goals, especially due to proximity of the groundwater resources and will be included in the updated EMP which will be the mine to the park, game ranching ventures and other important made available for comment. conservation-dependent tourist attractions. The environmental costs versus 62 benefits must be clearly stipulated since removal of the proposed extensive volumes of soil or contamination of water could hinder reclamation once the 10 years of mining is done. Costs of clean up in case of contamination could be millions of Rands and need to be taken into consideration by the mining company.
Another important component of reclamation will include ensuring a sustainable water source for communities near the mining site (i.e. agriculture, livestock farming and related activities should not lose the potential to provide drinking water for their animals). 4. Report content Noted. In terms of the report content, there are some contradictions in terms of which studies have been conducted vs. which are underway. For example on p. 34 it is stated that a study on noise is still to be conducted, whereas in section 3 (in several places) and on p. 99, it is stated that the mine will not have an impact through noise. On p. 99 it also mentions that a geohydorological study has been conducted, but no results from this were included in the current scoping report and on p. 89 it says 63 that such a study will only be conducted in January to April 2014.
4.1 Maps 4.1 The quality of the maps is poor and with some have no legends while for Noted. Maps indicating the mining area and related infrastructure routes, aquifers and others the legends are incomplete (i.e. not all the features and colours river courses included the Department of Water Affairs monitoring boreholes will be present on the maps are shown in the legends of those maps that do have provided in the Geohydrological Report and updated EMP. This has been addressed one). A better understanding of the mining area in relation to all the natural refer to the EIA-EMP and related appendices. features and ecological footprint is required. Specifically, a map showing the mining area, the aquifers, river courses and the Department of Water Affairs PAGE: 12 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
monitoring boreholes is essential. We would like to see a composite map along these lines, including the proposed route for the new road and power lines, also indicating the underlying vegetation types and their status as well as the status of alien plants. This map should form the basis for interpreting the impacts of the mine, which is not currently possible with the current series of inadequate maps.
4.2 Impact of mining activities on Species of Special concern SANParks has conducted some of its own work on species of special 4.2 concern (SSC). This includes mainly species present in the West Coast Noted. The updated fauna will be provided in the specialist studies currently National Park which may be impacted if the groundwater is impacted. We underway.Refer to Appendix C6 and C9 of the EIA-EMP. feel that not considering the impact of mining on species offsite is an oversight as many impacts will be transferred in space from the mining site itself. Groundwater, air, dust, noise and light pollution can all have impacts far from the mining site itself. We would like to have the Cape Research Centre’s SSC list compared to the one in the report, which appears to have omissions. As an example, flamingos, which are nationally near threatened and charismatic tourism species, use the Langebaan lagoon as an important site (though they were not included on bird red list). We would like to propose that a comprehensive SSC list be compiled for the entire ecological footprint area of the mining activity so as to ensure a more holistic approach in assessing the potential impacts.
4.3 Roads and powerlines Additional work needs to be done to assess the impact of the proposed road and powerlines. Road construction is more than a visual scar (impact 4.3 listed in the report) – it increases the likelihood of animal collisions and road Noted. The impact of the mine and related infrastructure is currently being assessed by kills, which may result in significant losses to particular species like tortoises the specialists. See previous response. and other small animals as well as birds which often feed on roadkills. Roads break connectivity of habitat for many species and are a common pathway for the spread of alien species (especially during building phase and when soil is being transported. This is mentioned very briefly p. 81). On p.16 & p.26 - it seems that parts of the site are heavily invaded and would have a substantial seed bank – this has significant implications for the way in which the top soil should be managed. Roads also bring additional traffic that adds to pollution, access for poachers and lead to more anthropogenic impacts generally.
PAGE: 13 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
4.4 References Although there are several references cited throughout the report, there does not appear to be a reference list. There is a brief list of references on 4.4 p. vi, but these do not cover all the references cited in the report and those Noted. that are provided are incomplete. A full reference list is an essential requirement for a report of this kind. There were several references (e.g. Valiela et al 1990 and Burnett et al 2001, p. 23) which we would wish to consult, but require more information on these in order to follow up. In addition, there are some broad statements in the report that require supporting references or evidence. The report does not flow and in certain places it is very technical with both jargon from geologists, botanists and mines. This makes it very difficult for a lay person (or specialist from an unrelated field) to read, interpret and comment on the report.
4.5 Abbreviations and appendices Abbreviations are only provided for companies, acts and a few mining terms in the abbreviations list on p. vii and none of the scientific and/or technical 4.5 abbreviations and units (which are essential for interpreting components of Noted. the report) are provided in the text, figures or the abbreviations table. Specific examples are listed in the sectional comments below. In addition, the appendices did not form part of the report which means that they could not be consulted. Lack of references, appendices and proper abbreviations make it very difficult to interpret the scope, rigour and accuracy of the work that has been presented. 5. Specific comments These comments are all noted and most relate to technical issues which have been In the sections below, we have outlined our particular comments and addressed in the updated reports and being investigated by specialists, which will be concerns for each section and sub-section. At the end of these comments included in the updated EMP. we have also added some additional comments on the botanical scoping survey. Contents Page 64 Not all sub-sections in the chapters are listed in the table of contents Abbreviations / Acronyms This list is incomplete, leaving out many of the scientific and field specific abbreviations used in the body of the report. Definitions / Terms There are no definitions for the mining terms used.
PAGE: 14 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
SECTION 1: THE METHODOLOGY APPLIED TO CONDUCT SCOPING Refer to the EIA-EMP. 1. Name the communities as defined in the guideline, or explain why no such community was identified Full names and positions should be listed for all persons / communities identified 2. State whether or not the community is also the landowner There is no map or reference explaining the portions of the Elandsfontein farm, so the references to the portions cannot be interpreted. 3. State whether or not the Department of Land Affairs was identified as an interested and affected party 4. State specifically whether or not a land claim is involved Has there been through verification on this, except the word from the current land owner? 5. Name the traditional authority identified by the applicant. 6. List the landowners identified by the applicant There is no map or reference explaining the portions of the Elandsfontein farm, so the references to the portions are not 65 helpful. 7. List the Lawful Occupiers of the land concerned What are the rights involved with prospecting? Act/Law? 8. Explain whether or not other person’s socio – economic conditions will be directly affected by the proposed prospecting or mining operation and if not, explain why not. No mention is made of possible socio-economic impacts of pollution of the aquifer and what impact this might have on natural areas (including the national park, and RAMSAR wetland site) as well as tourism industry that is dependent on these natural sites. This require more detailed explanation of how many jobs will be created, at what level of skill and remuneration each job will be at, where this labour will be recruited from, and what spin-offs are referred to. 9. Name the local municipality identified by the applicant 10. Name the relevant government departments, agencies and institutions responsible for the various aspects of the environment, land and infrastructure which may be affected by the proposed project SANParks should be added here as an organ of state tasked with
PAGE: 15 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
the custodianship of the environment 11. Confirm that 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, and has been appended hereto SECTION 2: EXISTING STATUS OF THE CULTURAL, SOCIO – Refer to the EIA-EMP. A large component of the questions raised relate to specialist ECONOMIC AND BIOPHYSICAL ENVIRONMENT studies and their findings, which is now available as appendices to the EIA-EMP. 1. Existing status of the cultural, socio-economic and biophysical environment The study area has been incorrectly defined: west of Langebaan is in the sea as is south of Cape Town and the two points are unlikely to converge. There is no map or reference explaining the portions of the Elandsfontein farm, so the references to the portions are not helpful. The regional map should show the sea as well as the location of nearby towns and other affected parties such as the West Coast National Park and West Coast Fossil Park. Figure 1 map, shows the incorrect boundary for the Grootefontein section of WCNP The introduction to this section provides only a partial overview of 66 the actual location with little background on the cultural, socio – economic and biophysical environment 2. Confirm that the identified and consulted interested and affected parties agree on the description of the existing status of the environment Were all interested parties present at the meetings to date? If not, then this statement is misleading. Attendance register should be provided. What is the exact depth that the ore is lying at? The current description is insufficient. 3. Existing status of the cultural environment that may be affected This site is of significant cultural value and care should be taken with paleontological and archaeological value. Archaeology: Who issued this research permit and should it not read ‘a research permit’ not ‘the research permit’? Palaeontology: What will the predicted impact be on fossil sites and is this listed in the report? 4. Existing status of any heritage environment that may be affected
PAGE: 16 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Heritage assessment required Heritage Scoping Report Dated December is incomplete as it does not provide any specific detail as to which year (and dates) this study was conducted. How will the mine impact fossil areas and how will they deal with a discovery of a fossil deposit. Fig. 2 – map has no key Dr Braun registered with SANParks p. 10, sub-section Palaeontology, paragraph four: The area is reported to have unproven potential, but strong enough to yield fossil remains additional to the known marine microfossil content; thus an indication for a need to conduct detailed impact assessment and develop mitigation plan 5. Existing status of any current land uses and the socio – economic environment that may be directly affected Please provide a copy of the Social and Labour Plan. How will the mine affect tourism? 6. Western Cape Province The “Saldanha Bay Industrial Development Zone Feasibility Study” is not a principle. The mine is not a long term sustainable entity and therefore does not meet the SO1 objectives. The role of the state is not only to support business as articulated, but to effectively manage the environment for the benefit of future generations. This is a glaring omission. 7. West Coast District Municipality The potential conflict between mining and tourism is not elaborated on or explored anywhere in section 2.4 (or elsewhere in the document). This should be explicated and given due consideration 8. Saldanha Bay Local Municipality Is the Gecko Fert mine active? What impacts does this (if it is operational) or any other phosphate mines in the area have? A sharp increase in employment by mines since 2004 is mentioned. This is contrary to current labour statistics. What mines are these, where are they and how much of the local communities do they employ (are these permanent or casual staff)? What is the likelihood of leakage similar to that in the Kruger Park in PAGE: 17 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
December 2013/January 2014? The Hospitality / Tourism Industry (Catering and Accommodation) need to be a stand-alone as these contributes substantially in the local economy, especially in Langebaan. 9. Land use at proposed site Historic information regarding the area being previously part of the private Nature Reserve is not captured in the State of Environment? Please provide information regarding formal protected area status of the area. 10. Land capability What is land capability? And why does this rely on a socioeconomic study? “Farm Elandsfontein has been identified as a Critical Biodiversity Area by Saldanha Bay Municipality, separating the two eastern portions of the West Coast National Park. It was previously a Private Nature Reserve and due to the nature of the vegetation on site can be seen to form the natural northern extension of the WCNP.” As a CBA it should be protected and included into the WCNP as the first option. It also falls in West Coast National Park’s buffer-zone and will negatively affect SANParks’ ability to consolidate the park. This area was zoned as remote and wilderness in WCNP and if mined this will not be the case. Activities in the buffer zone should be compatible with conservation. This is not usually the case with mining and due consideration should be given to the appropriateness of a phosphate mine in the buffer zone. 11. Sensitive landscapes The vegetation types in this area are all threatened and do not recover well when disturbed. Specialist studies should indicate whether it is indeed possible to completely rehabilitate the disturbed areas and how this would be done. How much of the proposed mining location is made up of Hopefield sand plain fynbos and Saldanha limestone strandveld and how much of this vegetation type will be lost? It might be useful to highlight what proportion of each of these vegetation types are within formal protection. 12. Existing status of any infrastructure that may be affected
PAGE: 18 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
What is the anticipated footprint of the extended Eskom power lines? What are the pros and cons of the haulage road versus the conveyer belt? What is the proposed route of conveyer belt and or road to Saldanha? Clearer details of the proposed road or conveyer system and its route and extent are required to accurately determine their impact. 13. Existing status of the biophysical environment that will be affected including the main aspects 14. Regional Geological Setting The colours on the Figure 3 map are not defined meaning that the geology cannot be interpreted; “The information was drawn from the geohydrological study compiled by GEOSS”- SANParks would like to see this study please. 15. Regional hydrogeological setting P.20 “Prospecting drilling would provide more information with regards to the formations present, their depths, and the occurrence and characteristics of water strikes” SANParks kindly request full report on all drilling results. The information should also be made available to the department of Water affairs. Are there not other methods to determine water depths and presence than drilling? Could existing boreholes not be used to estimate the occurrence and depth of water and likelihood of mining interference? P. 20 abbreviations like Langebaan Road Aquifer System (LARS), LAU, UAU are not provided in the table of abbreviations and would probably make for better comprehension if they were shortened (e.g. Langebaan Aquifer) and not abbreviated. Other abbreviations like EC used in this section are not defined at all. On p. 21 it is noted that the deeper water levels are showing a gradual decline over the past 8 years. What is causing this decline? How will the mining effect the declining water levels? PAGE: 19 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
How will the mining impact on the groundwater as the water levels are fairly close to the surface? What is the water level of the “two shallowest boreholes” mentioned on p. 21?
“It is interesting to note that while the two shallowest water level boreholes have remained stable over the past 6 to 8 years, the deeper water levels all show a similar gradual decline over the past 8 years. Seasonal variations of the water levels are negligible”: Where does this information come from? Please provide the reference. P. 21 Consistency is required where abbreviations are used for measuring units: What is mS/m? and what is mbgl – meters below ground level? m used elsewhere? What is mamsl? What is EC?
“The groundwater quality differs between the UAU and LAU. Groundwater quality is good in the LAU with ECs <120 mS/m (Woodford et al, 2003) while groundwater in the UAU is poorer. The groundwater from the confined LAU has a mixed Na-Ca/Cl alkaline character with an EC generally lower than 70 mS/m. Groundwater from the UAU has a Na/Cl character with higher EC.”: For whom or what is it poorer? Drinking water, agriculture, nature? This statement requires clarification and a complete reference. It is not clear what is meant by poor and good quality in different areas. Is there any link between the two main aquifer systems and the smaller subsection? P. 23 it appears from the report that the aquifer is classified as a special aquifer system and as such has a strictly non-degradation level of groundwater protection. In addition it is thought that the aquifer has high vulnerability to anthropogenic activities: The impact of mining on the aquifer should be thoroughly investigated in the specialist hydrological study?
PAGE: 20 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
“The high conservation status Langebaan lagoon is not fed by overland streams or rivers due to the porous nature of the sediments and the arid conditions, but it has been suggested that groundwater plays asignificant role in sustaining the marsh ecosystem (Valiela et al., 1990; Burnett et al., 2001).”- Further research is required to substantiate this.
“Diagnostic plants indicate significant contributions of groundwater (Adams and Bates, 1999).”- This sentence is difficult to interpret. Frogs present at Langebaan lagoon also indicate fresh water. Ground water use and yields are mentioned but not exact amounts, are these available? 16. Climate Questions that should be asked to anticipate climate change impacts include: What flooding events have happened in the past that could affect the mining operations? What is the possibility that the original Berg River Valley could flood again? What is the average wind speed as this affects the distance that dust can be spread. Table 4: Please average night temperature? 17. Topography A topographic map of the area would be useful here 18. Vegetation P. 27: Who conducted the survey for plants in the focus area (was this part of the Nick Helme Survey? Appendix 2 not attached) and in what season was this done? Would all plants have been identified? The Nick Helme botanical survey was done in late summer and many of the floral species would be dormant. A second survey in the growing season is required to identify a more complete list of threatened species. A survey of Van Niekerks Hoop Farm (Farm 300) was conducted in 1996 by UCT Botany Institute for Plant Conservation (Desmet & Cowling, 1996). This property is adjacent to Elandsfontein. The survey shows that several threatened species, including geophytes, are found on this farm. A botanical
PAGE: 21 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
survey needs to be conducted in the correct flowering season to, ideally July to September, to include geophytic and other flowering species that might have been excluded in the Helme 2013 survey. According to SANBI PRECIS database there are 18 Critically Endangered, 52 Endangered and 60 Vulnerable plant species found in the quarter degree squares 3318 AA,AB and AC in which Elandsfontein and the West Coast National Park are found (identified as species of special concern within the West Coast National Park), while the Desmet & Cowling survey identified 16 Red List species, only three of which overlap with the Helme survey. Reference Desmet, P.G. Cowling R.M., 1996. Assessment of the farm Van Niekerks Hoop (300) for inclusion into the West Coast National Park. Institute for Plant Conservation, Department of Botany, University of Cape Town. Please indicate what plants off site may be impacted by the proposed road, erosion or pollution of the aquifer? P. 27 Are there studies to show that these bulbs survive translocation? Please provide references. P. 27 Are there plans to actually translocate the bulbs and are the locations of each individual actually known? P. 29 the possibility of “search and rescue” as a mitigation measure is mentioned – what mitigation measures have been agreed upon should the mining be approved? SANParks would like to see and be involved in a full scale mitigation plan. P.29, first paragraph “Ecological connectivity across the site is currently regarded as fully functional, and care should be taken not to disrupt this connectivity, especially on a site bordering on a National Park” This statement is important and requires a reference and/or further elaboration. A botanical assessment should be conducted in the peak flowering period. Please provide a map of proposed roads and/or infrastructure in and around the mining area. A map should be produced indicating these red list species in relation to where proposed infrastructure will be located.
PAGE: 22 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
What criteria are used to determine high or low botanical sensitivity areas: are these the authors’ opinions or are they based on the Threatened ecosystem type? Attention should be paid to the potential of infrastructure to disrupt ecological corridors preventing seed or animal movement between corridors. A plan to prevent the loss of any Red List species is required; A vegetation management plan is required which includes rehabilitation of the areas damaged. (Please note additional comment from CRC botanical scoping report at the end of this document. Figure 6 has no legend 19. Animal Life P.30: There are Red List birds that occur in the adjacent WC National Park that might be impacted by contamination of the aquifer and related impacts? (e.g. the flamingo – near threatened nationally).
P.30 “The retention is throughout the day but become bimodal in the warmer and drier summer and autumn months.” – please explain. “The following information was extracted from the report “Terrestrial fauna Report”; compiled by Dr. W. Van Hoven, dated 2010”. The study area falls within the Elandsfontein Private Nature Reserve.”- Please provide a copy.
P. 32 the report uses an old publication to counter / question the status of Grant’s golden mole conservation status – recent references should be consulted.
P32 “Several large wildlife species has been brought into the Elandsfontein reserve during the past three years in the process of establishing a wildlife reserve. See table 6 for the species list and their numbers”. table 6 is a bird list not mammals, there is a bulleted list of mammals with no actual numbers; p. 33 - an ostrich is not a large mammal Further study into amphibians and reptiles is required. 20. Air quality and Noise
PAGE: 23 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Is there a standard level for noise pollution and is it defined? Will this be breached? On what are the dB estimates for the mining operations based? What will the hours of operation be? Will the mine run 24 hours? Why will the noise levels at night be less than during the day? Sounds can appear amplified at cooler temperatures. A dust survey which considers the impacts on people, tourism, vegetation, pollinators and other fauna is required. p. 34 Langebaan lagoon was proclaimed a Ramsar Site or Wetland of international importance in 1988 and not in the 1990s. 21. Visual aspects The information presented in this section is summarised from the Visual Scoping Assessment conducted by Karen Hansen Landscape Architects: Please provide a copy of this to SANParks WCNP was proclaimed in 1981, this should be add to all specialist reports and any other report; Impacts to be addressed in the EIA should also include that the mine is located in the buffer-zone and core expansion area of WCNP; Light impacts are mentioned casually, but light pollution can have significant impacts on fauna, especially invertebrates. With the mine being in the buffer zone of a national park, this is potentially highly significant. How much light would be generated and from how far would it be visible? The visual scar on the landscape could have an impact on tourism. Would the mining site be visible from the national park? Figure 8 is not particularly helpful or informative – see specific comments on figure. 22. Surface water How will the mining impact on the ecology of the two rivers mentioned? There is a River Health Programme monitoring site further down in the Sout River, but very little information is available for the Soutrivier closest to the mining area. 67 SECTION 3: IDENTIFICATION OF THE ANTICIPATED All these queries have been dealt within the various specialist studies and as part of PAGE: 24 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
ENVIRONMENTAL, SOCIAL OR CULTURAL IMPACTS, INCLUDING the updated design and operation of the mine. As there have been changes to the THE CUMULATIVE IMPACTS, WHERE APPLICABLE proposed footprint, layout, location of infrastructure etc, it is recommended that the 1. Identification of the anticipated environmental, social or cultural EIA-EMP be consulted to provided clarity on these issues. impacts, including the cumulative impacts, where applicable With reference to the list of considerations an assessment should undertake: Is there not a step missing between the third and fourth points? The costs and benefits of the impacts should be weighed up to determine whether the action is merited before proceeding and attempting remedial action? “The majority, although not necessarily all of the environmental problems associated with development projects tend to diminish with increasing distance from the proposed mining activity. Consequently, the most easily noticeable environmental problems are usually identified adjacent to the site and on the site of operation.” We disagree
– impacts on the underground water as well as the road and powerlines are likely to have much more far reaching impacts than impacts restricted to the mining site.
We disagree with the definition for indirect impacts – impacts away from the mining area as a direct result of mining activities should still be considered direct impacts 2. Description of the proposed project including a map showing the spatial locality of infrastructure, extraction area and any associated activities Topsoil must not be stockpiled as the seeds present in this soil are buried and die. The sequence should be to replace topsoil such that as a new site is opened another is closed. Australian aluminium mines have demonstrated this. How long will a dump be left for? Will it be covered to prevent wind-blown erosion of the sand? “Once the phosphate ore is mined then the strip is backfilled with the overburden and slimes from the plant (if technically feasible) and…”: Please indicate what would be the measures for environmentally feasible? These should be included. Please name the chemical that the slimes will contain. “As the mining activities intersect the upper aquifer and no bodies of open
PAGE: 25 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
water are permitted, continuous perimeter borehole pumping is required to remove the excess water from the mining strips. The pumped water will be used for activities on site and the excess water will report back to the underground water system.” Does this statement acknowledge that the mining will reach the depth of the subterranean water? This calls for much more thorough investigation on the chances of aquifer contamination. On p. 73 it is suggested that mining will be done at depths of 30-45m which would undoubtedly impact on groundwater. In addition, will the water that is returned to the underground system be treated and how? p. 40 last bullet – how much water is proposed to be extracted and what will the impact of this be on the aquifer and people and natural systems reliant on it? Eskom- power line will need separate EIA 3. Mineral deposit and mine product What is an SG? What is Mt? Presumably metric tonne, but rather spell this out; This section may be incomprehensible for someone outside the field 4. Production rate Why does plant haulage increase from capacity after year 4? Is this due to expansion? 5. Planed life of mine Why would it be extended? The haulage only looks at the first 10 years What will happen to the property once mining is done? No restoration details are provided. 6. Description of mining operations This is a repeat of information in sections before this; How is the ore removed, drills, shovels, explosives? Where will the top soil be stockpiled? (Contains seed bank) and for how long? 7. Plant processing Definitions are required for those who don’t know mining “The fine overflow from the cyclones will be de-watered together with PAGE: 26 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
the flotation tailings in a thickener and temporarily stored in a slimes dam before being back-filled into the mine for rehabilitation.”: Is this a device or a chemical? What chemicals are used in the process and will they then find their way back into the natural system? 8. Surface water facilities “Usually, any solids generated for disposal can be disposed to a general waste, if demonstrated to be a low hazard, or, alternatively, as hazardous waste.” What are considered usual conditions? Fynbos is a low nutrient vegetation type and the proposed mine is in the West Coast National Park buffer zone – who will assess whether the hazard was low and to whom/what the hazard was low? Where is the nearest landfill site? Who will test the water before it is discharged? How will contaminated water be treated and where will it be discharged once it is “clean”? Where will the water storage dams be constructed for the contaminated water? What happens to the top soil if the dams are constructed and where will it be stored or moved to? Regarding the bio sludge that is going to be dried and composted: Please indicate where this process is going to happen and where it’s intended to be released. It is not a good idea to release organically rich mediums in a vegetation type that grows in a nutrient poor habitat. “Details regarding the system to be implemented on site is currently under investigation. Further detail will be provided in the EMPR.” The system should be thoroughly investigated and also be included in the Environmental Impact Assessment rather than conducted post-hoc? 9. Transport A Conveyer belt is preferable to a road as there is no dust, and no borrow pits and an under pass will help small animals cross the R27; Please indicate where the bridge and conveyor belt will be situated? PAGE: 27 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Has there been input from other environmental organizations on this idea? A map and plan of the proposed road or conveyer system is required to assess its potential impact. Roads are known to have serious environmental impacts, including amongst others the direct impact of habitat destruction where the actual road is constructed, fragmentation of habitat, increased spread of invasive alien species, fatalities of a variety of animals as well as additional impacts associated with dust from gravel roads. Furthermore, roads lead to increase in carbon emissions and increase in human traffic which has a variety of secondary impacts which could include poaching of animals and plants (a known problem in the area especially for reptiles). All these impacts need to be explored explicitly. 10. Waste management Waste must be removed and not buried on site – please provide details of what is going to happen to waste. What will happen to waste rock? Will rock not be required to fill the holes created by mining during rehabilitation? What is the composition of the hazardous waste? Where exactly will the hazardous waste be stored on site and how often will it be collected? The Department of Environmental Affairs is referred to with three different names in this paragraph – please use the appropriate name. 11. Description of any listed activities which will be occurring within the proposed project Please explain the implications of a listed activity in the introduction to this section. P. 52 – please indicate direct pollution of water through mining activities other than the waste generated. P.53 to 54: the way in which the activities are triggered and reported make no sense. For example “The mining … may trigger… the following heritage activities: (a) the construction of a road, wall, powerline…” The construction of a powerline is not a heritage activity – additional information on what will be triggered and what
PAGE: 28 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
is required in such instances is required to make this section interpretable. 12. Specifically confirm that the community and identified interested and affected parties have been consulted and that they agree that the potential impacts identified include those identified by them Our comments on this report identify additional impacts of concern 13. A list and description of potential impacts identified on the cultural environment Has a study being conducted of the cultural environment been conducted? Such a complete study is required. Will fossils be saved or destroyed; will mining be stopped if skeletons or deposits of fossils are found? 14. Construction phase Fence should be first. What will be used for the berms? Will they be vegetated? 15. Decommissioning phase Please indicate the decommissioning of roads and rehabilitation. Alien clearing - What is the anticipated cost and how will this decommissioning be paid for? 16. A list and description of potential impacts identified on the heritage environment, if applicable A detailed description of the heritage environment that may be affected is required. 17. Construction phase 18. Operational phase 19. Decommissioning phase 20. A list and description of potential impacts identified on the socio – economic 21. conditions of any person on the property and on any adjacent or non – adjacent property who may be affected by the proposed mining operation 22. Construction phase A dust study should be conducted to determine how far the dust will blow. Hopefield is NW of the mine, therefore, the SE wind will blow dust onto them; A canteen is listed, why would there be open fires? Refuse is not to be burnt;
PAGE: 29 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The footprint of a canteen in terms of water, waste and energy needs to be constrained in the planning and construction phase as well as when it is in use; The noted likely increase in crime, loitering and other social conditions is of particular concern for the tourism industry in the area, which is currently one of the area’s largest industries. The impact on sense of place raises similar concerns. 23. Operational phase Potential problem of invasive alien species establishing P. 62 what kinds of animals are being referred to here and is the risk to the mine site or from the mine site? P.66 worker jobs should preferably be offered to people who can demonstrate a history of living in the area so as to avoid an influx of people in search of work 24. Decommissioning phase P. 66 “Nuisance to the community from noise and dust. However according to the noise survey, the noise shall be contained within the valley where the mining and plants will be concentrated and shall have no effect on any surrounding communities.” [& similar statement on p. 65] According to p.34 and p. 60 the assessment of noise still has to be done? P.67 - The impact of polluted water resources on communities is mentioned, but this is not covered at all in the rest of the report. This is a significant oversight. 25. A list of potential impacts (positive & negative) on: employment opportunities, community health, community proximity, and links to the social and labour plan P. 68 a potential positive impact in terms of increase in quality of life to the local community is mentioned. This will only be realised if the multitude of negative impacts listed elsewhere do not decrease quality of life to a greater degree. For example, if jobs are provided to people outside of local communities, with accompanying influx of labour from other areas, competition for jobs is likely to increase. In addition, the other negative impacts listed such as increased demand for housing and services, loitering, safety risks, increase in crime and other social conditions in combination with the above. In addition, potential pollution of water sources is more likely to lead to
PAGE: 30 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
decrease in quality of life for local communities than an increase. 26. A list and description of potential impacts identified on the biophysical environment including but not be limited to impacts on: flora, fauna, water resources, air, noise, soil etc Please indicate how these impacts will be mitigated? The impacts cited in this section often repeat impacts cited to people and not to the environment. The impact of each action on the environment needs to be assessed and evaluated. 27. Construction phase P.70 (and in several other places where similar reference is made to the dust and noise): “Nuisance to the community from noise and dust. The noise and dust shall be contained within the valleys where the mining and plants will be concentrated and shall have no effect on any surrounding communities. The closest community is located about 14.5km’s away, namely Hopefield.”: The report should also indicate what the impact be on the animal and insect communities that will be affected. Living areas are not listed as being built Dust is not only relevant to people. Dust can have significant impacts on plants as it clogs stomata and related organs. This impact could be reach further than at the mine site. We would like to request that the dust impact study considers potential impacts on plants, their pollinators and the viability of seed produced by plants that occur in dusty areas compared to those where there is limited dust. Likewise noise can have significant impacts on animals – only neighbouring communities considered in the impacts mentioned. Similarly the impact on air quality is not discussed with reference to the environment. P.70 (and related in latter sections) The impact of the contamination of water sources is not discussed with reference to the national park and the species that are supported by the Langebaan lagoon which is fed by the aquifer. The knock on impact on tourism (socio- economic impact) is also not discussed. 28. Operational phase Please indicate of possible poaching of bush meat from the park and surrounding areas as an environmental impact?
PAGE: 31 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
P. 72 - Reference is made to Table 33 – there is no table 33, I assume 25. Reference is also made to impacts on socio-economic conditions – this section is supposed to focus on environmental impacts? First entry in Table 25 again does not focus on the implications for the environment. “Potential decrease in groundwater quantity due to changed flow characteristics of aquifer, as the ore will be extracted up to a depth of 30-45m which extends into the top aquifer.”- Digging into aquifer is not listed as an impact. Also, the depth at which mining will take place is not mentioned anywhere else in the report. Mining at this depth will undoubtedly impact severely on the aquifer with knock on impacts throughout the national park and for surrounding communities and farmers who make use of this water source. “The depression will make using this area for grazing by fauna impossible until backfilling occurs impossible”- This sentence makes no sense; The impact on water in general in this section should be discuss in the context of the national park and endangered species within it. P.74 - There is very large opportunity for the spread of alien species when soil is disturbed, during road construction and when soil material is transported. It is worth considering each of these impacts separately as each action will exacerbate existing invasions and lead to new ones. P.76 - The potential for drainage to contaminate groundwater is mentioned, but the impacts of this are not discussed here or elsewhere in the report. This is an essential requirement. P.77 - The noise survey is referred again to although elsewhere in the report it is stated that the survey is still to be conducted. P.78 What are the implications of the phosphate contamination of the groundwater? “Ineffective vegetation management and rehabilitation practices on the sidewalls may appear” – there are no details of how proposed rehabilitation would take place, so it is difficult to assess the likelihood of success. P. 78 What type of hazardous waste is being referred to here and
PAGE: 32 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
what are the potential implications of this waste for people and the environment? How long would such waste remain in the system? “Storage of hazardous waste for longer than 90 days” The details of how waste will be stored, where and for how long are not provided in the report. What is the plan for such waste and why might it be on site for longer than 90 days? P.79 “Accidental burning of rubber due to cutting of steel or the storage or tires may start fires”? P.79 “Veld disturbance may take place during the installation or replacing of pipelines.” Pipeline installation and route not mentioned in the body of the report 29. Decommissioning phase This section is listed as 3.8.4 in the report, but there is no Section 4.8.3; There are no details of the plan for decommissioning. Premining photographs of the site is needed to reshape it later; P.83 “In the case of the mine area reshaped incorrectly, it will not be possible to use this area for any agriculture or other type of land use.” So there is a possibility that use of this area for short term gain (10 years) could lead to a non-usable piece of land [possibly extending beyond the mining site?] for the foreseeable future? P. 84 Fertilizers should not be used in fynbos rehab P.85 Loss of employment opportunities should be considered under socio economic impacts and not environmental 30. A description of potential cumulative impacts that proposed operation may contribute to considering other identified land uses Chapter 3.9 is not listed in the table of contents; New impacts are not listed in this section and the other land use types or cumulative impacts are not mentioned. Where else could impacts be observed and/or how would they work in synergy? 31. ADDITIONAL NOTES ON SECTION 3 Prevention of pollination of plants and loss of seedling generations
SECTION 4: LAND USE OR DEVELOPMENT ALTERNATIVES, 68 ALTERNATIVE MEANS OF CARRYING OUT THE PROPOSED OPERATION, AND THE CONSEQUENCES OF NOT PROCEEDING WITH
PAGE: 33 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
THE PROPOSED OPERATION 1. A list of and description of any alternative land uses that exist on the property or on adjacent or non – adjacent properties that may be affected by the proposed mining operation P.88 - Is mining on the surface only an option? If so, the impacts of this need to be assessed separately in subsequent documents. 2. A list and description of any land developments identified by the community or interested and affected parties that are in progress and which may be affected by the proposed mining operation A list and description of any proposals made in the consultation process to 3. adjust the operational plans of the mine to accommodate the needs of the community, landowners and interested and affected parties Contradiction, as the mine is foreseen to not close 4. Information in relation to the consequences of not proceeding with the proposed operation The benefits and lost opportunities in this section have been incorrectly written in places (e.g. consequences of mining include lost export opportunity?) How many new jobs will be created? What new skills will be gained by the local population and how will this happen? Will skilled labour be imported? How will upliftment occur and be measured? The environmental and socio-economic benefits of not mining are far greater than just those on site benefits that have been listed (indigenous vegetation will not be displaced). If mining does not take place then species may remain at site and not go locally extinct (loss of populations), impacts on the lagoon and tourism will not take place and crime and loitering will be reduced. A proper and complete cost benefit analysis is called for. 5. Description of the most appropriate procedure to plan and develop the proposed mining operation SECTION 5: DESCRIPTION OF THE PROCESS OF ENGAGEMENT OF The Public Participation activities is explained in the EIA-EMP and was explained in the IDENTIFIED INTERESTED AND AFFECTED PARTIES, INCLUDING updated Scoping Report (revised) including the documentation which was made 69 THEIR VIEWS AND CONCERNS available for public comment. 1. A description of the information provided to the community, landowners and interested and affected parties to inform them in sufficient detail of
PAGE: 34 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
what the mining operation will entail on the land, in order for them to assess what impact the mining will have on them or on the use of their land 2. A list of identified communities, landowners, lawful occupiers and other interested and affected parties that were consulted How was the list of interested and affected parties compiled? There are 2 places with SANParks as the organisation but no names in the list 3. A list of their views in regard to the existing cultural, socio – economic or biophysical environment, as the case may be Were all parties pro the haulage road? We are not in favour of this option. “The proposed mine will have a dramatic impact on the tourism potential of the greater area and impact on the R27, a main thoroughfare for the West Coast. “: Will this impact be positive or negative? Please provide evidence that additional tourism would result from one additional road rather than increased traffic detrimental to the park? 4. A list of their views raised on how their existing cultural, socio – economic or biophysical environment potentially will be impacted on by the proposed prospecting or mining operation “A request was for examples of similar success stories of phosphor mines in South Africa. Response: This can be provided” Please provide the details and the impacts from these case studies. Please include comment on the impact of the leakage from the phosphate mine into the river of the Kruger park in 2013/14 5. A list of any other concerns raised by the aforesaid parties “A request was for examples of similar success stories of phosphor mines in South Africa”- Please provide evidence Discussion with SANParks to have a road through their land from Hopefield side is mentioned – please provide information whether agreement has been reached in this regard, including maps of this proposed route. 6. The applicable minutes and records of the consultations Refer to appendix. – SANParks did not have access to any appendices, besides the botanical scoping report.
PAGE: 35 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
7. Information with regard to any objections received SECTION 6: DESCRIBE THE NATURE AND EXTENT OF FURTHER Refer to the updated EIA-EMP for the specialist studies. INVESTIGATIONS REQUIRED IN THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT, INCLUDING ANY SPECIALIST REPORTS THAT MAY BE REQUIRED This section states that several studies have already been completed to 70 assess potential impacts (e.g. noise and geohydrological studies) – other sections in this report however indicate that these studies are still to be carried out. The results have also not been made available – please clarify. The section actually contradicts itself in saying in the first paragraph that a geohydrological study has been conducted and in the second that one is still underway. LIST OF FIGURES All figures/maps have been updated in the EIA-EMP and appended specialist reports. Figure 1: Regional locality of proposed mine area This figure needs a better description and legend on the map. It shows the incorrect boundary for Grootefontein section of WCNP Figure 2: Google map showing fossil area on Farm 349/2, Elandsfontein This figure needs a better description and legend. ‘A sensitive landscape indentified in terms of the Heritage and Archaeological Study shows that the Elandsfontein Fossil Area is located on Portion 2 of the Farm Elandsfontein 349 about 3 kilometers from the area to be mined (see figure 2)’ This is not indicated/shown on fig 2.. Figure 3: Geological map of the study area Figure 4: Groundwater map of the study area (1:500 000 DWAF map 71 series) Figure 5: Annual Rainfall Data obtained for Rainfall Station: Langebaan Road Figure 6: Simplified vegetation map of the greater study area and focus area, showing the position of the only drainage line. Unshaded areas are all Saldanha Limestone Strandveld and Langebaan Dune Strandveld mosaic No legend Figure 7: Satellite image of total study area showing a simplified map of botanical sensitivity. Unshaded areas are of Medium Sensitivity, and Low sensitivity areas are in green. Figure 8: Potential Visual Receptors generated on GIS mapping and based on estimated infrastructure elements in one location, up to 12m high above natural ground level, and at a 10km radius. The shielding effect of natural PAGE: 36 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
landform can be seen; the exposed area is coloured cyan. What is cyan? There needs to be a legend describing what the different colours mean and the figure legend as it stands is not sufficient to allow interpretation by a lay person or noncartographer. What are potential visual receptors? Where is one at 12 m and why is this significant? Figure 9: Surface Layout Plan Overburden stockpile is on the WCNP boundary, we need to look at what effect this will have on the park (dust, alien plant seeds etc); Will the overburden have alien clearing on it? LIST OF TABLES All tables have been updated in the EIA-EMP and specialist studies which are Table 1: List of registered Interested and Affected Parties appended. Table 2: Formations and lithologies of the Sandveld Group Table 3: Previous classification of the Bredasdorp and Sandveld Groups with the project relevant Formations underlined Table 4: Weather characteristics for the study area Table 5: Plant Species of Conservation Concern recorded in the greater study area and in the focus area. Key to Vegetation Types: HSF – Hopefield Sand Fynbos; SFS – Saldanha Flats Strandveld; LDS – Langebaan Dune Strandveld; SLS – Saldanha Limestone Strandveld. The ? indicates that this species may be present here but was not recorded during the survey. Although a list of the Red List plant species were provided, the 72 botanical survey was conducted outside flowering season, annuals and bulbs excluded. Possibility of more red data species. Please indicate on a map where these red list species occur in relation to where proposed infrastructure will be located. Table 6: Bird life occurring in the greater area including Elandsfontein Farm 349/2 & 4. Table 7: List of Lizard occurring in the greater area and potentially on Elandsfontein The title should read Lizards not Lizard Table 8: Tortoises occurring naturally in the wider region which includes Elandsfontein are Table 9: Snakes occurring naturally in the wider region which includes Elandsfontein are
PAGE: 37 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Table 10: Small mammals occurring naturally in the wider region which includes Elandsfontein are Table 11: Definitions that shall be used in the assessment and evaluation of impacts Table 12: Resource estimates after Geological Loss Table 13: Listed Activities in Terms of NEMA EIA Regulations Table 14: Potential impacts on the cultural environment during construction phase Table 15: Potential impacts on the cultural environment during operational phase Table 16: Potential impacts on the cultural environment during decommissioning phase Table 17: Potential impacts on the heritage environment during construction phase Table 18: Potential impacts on the heritage environment during operational phase Table 19: Potential impacts on the heritage environment during decommissioning phase Table 20: Potential impacts on the socio-economic conditions during construction phase Table 21: Potential impacts on the socio-economic conditions during operational phase Table 22: Potential impacts on the socio-economic conditions during decommissioning phase Table 23: Potential impacts on the employment opportunities, community health, and community proximity Table 24: Potential impacts on the biophysical environment during construction phase Table 25: Potential impacts on the biophysical environment during operational phase Table 26: Potential impacts on the biophysical environment during decommissioning phase Table 27: Potential Cumulative Environmental Impacts Table 28: Procedure to plan and develop the proposed mining operation LIST OF APPENDICES All appendices have been updated in the EIA-EMP. Appendix 1: Heritage Scoping Study 73 o Has been sent Appendix 2: Botanical Scoping Study PAGE: 38 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
o Has been sent Appendix 3: Visual Scoping Study Appendix 4: Minutes of Meetings Appendix 5: Background Information Document Appendix 6: Advertisements as placed in the Weslander in English and Afrikaans and Die Burger Appendix 7: Attendance registers Appendix 8: Prepared presentations Appendix 9: Comments received and comments table reflecting comments from I&APs Appendix 10: Economic and Strategic Significance of Elandsfontein Phosphate Deposit Appendix 11: Maps of mine area Additional comments We would like to request that SANParks have input into the terms of reference that are drawn up for each of the impact studies that are to be conducted.
In particular (and identified in the scoping report in some instances) we believe that the following additional studies are required: Baseline water quality studies in Langebaan Lagoon 22 Ecological baseline studies in the Sout- and Groen Rivers Assessment of dust impact (including impact on plants, pollinators and other animals) 74 A full scale vegetation surveys considering plant species of special concern – carried out and monitored in the appropriate seasons (this would require winter and spring assessments) Heritage assessment Noise assessment (including impact on animals) Light pollution assessment (including impact on animals) A full scale hydrological impact assessment including assessment of the impacts of polluted water on the park, local communities, farmers and tourism An Socio-economic cost benefit assessment A more thorough assessment of reptile and amphibian species
75 Additional Comments from the report of Nick Helme Botanical Refer to the updated Botanical Assessment in Appendix C2 of the EIA-EMP, as well as
PAGE: 39 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Surveys: Botanical Scoping Report the Rehabilitation Plan and Management and Monitoring Plans identified in the EIA- The Elandsfontein Environmental Scoping report includes certain sections EMP recommended for the proposed mine. of the Botanical Scoping report. However there were important sections and comments that were not included from this report in the Vegetation section of the scoping report. The CRC have highlighted some of these below:
5.2 Plant Species of Conservation Concern “It is also likely that at least four or five other SCC (probably bulbs or annuals) would then become evident, especially if surveyed over the four main seasons.” “Boucher (2010) lists as occurring on site, and at least one of the species (Leucadendron foedum) definitely does not occur on site, but it is possible that the other three are present, all within the Hopefield Sand Fynbos. The likelihood of there being other undetected SCC in both the focus area and in the study area is deemed to be moderate.”
As the author of this report points out, there are likely several more Red List species which would be identifiable through surveys conducted over 4 seasons.
5.4 Ecological Drivers “Lack of fire also means that many bulbs and annuals that normally flourish only in the first few years after a fire, when there is plenty of light and open space, struggle to flower and hence set seed. These species can persist for long periods as bulbs and seeds underground, but obviously they have a limited life span, and the longer they go without fire the greater the chance that they will succumb to pathogens or seed or bulb predators (such as mole rats, common on site).”
This was not mentioned in the scoping report. There are species that will require fire. Fire regime in Sand fynbos is 30 years and strandveld 50+ years. More frequent fires could also be a problem.
5.5 Ecological Corridors “Existing ecological corridors can be inferred wherever there is natural vegetation, and thus one should not take a single line on a map too seriously – in reality it is more like a web than a corridor, with numerous lateral connections and interconnections, and it is important to maintain as PAGE: 40 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
many as these as possible, and the broader and more numerous the links the better.”
Areas of natural vegetation should be indicated on a map. Proposed infrastructure may disrupt these corridors.
6. ISSUES IDENTIFIED “Direct, long term to permanent loss of vegetation and alteration of vegetation structure at the construction phase (mine and associated infrastructure, topsoil stockpiles, including offices, haul and access roads, etc.)” Better maps referencing the location of threatened species and vegetation types in relation to proposed infrastructure and activities are required. “Direct, long term to permanent loss of up to four plant Species of Conservation Concern at the construction phase” A plan to prevent the loss of species is required. “Temporary to long term direct loss of vegetation at the construction phase (disturbance around new powerline, other minor disturbance, including along the edge of the new roads)” A vegetation management plan is required. “Indirect ecological impacts at the operational phase (introduction of invasive alien ants and plants; disruption of natural fire regimes; fragmentation of natural habitat and ecological corridors)” Plans for mitigation of these impacts are required “The opportunity to fund and implement an appropriate and potentially significant biodiversity offset which will enhance the conservation of the vegetation types concerned, and increase the extent of the WCNP” Which land specifically (size, location, biodiversity value) is proposed as an offset?
7. RECOMMENDATIONS FOR THE PLANNING STAGE These are very important recommendations to consider which were not included in the scoping report “Various design and management elements need to be thought about upfront and preferably built into the proposal in order to mitigate what could otherwise be significant negative impacts discretionary infrastructure (buildings, stockpiles, stores, roads, etc.), should be concentrated in the PAGE: 41 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Low and Medium Sensitivity areas identified in Figure 6, and should be as close to the mine area as possible, and occupy as small an area as possible. Fire and alien invasive plant management are two of the most important issues on the greater site. Fire is a much more difficult issue to deal with, but cannot simply be ignored, as it is an essential ecological element, but is difficult to control and potentially dangerous in terms of infrastructure. Detailed fire management guidelines will be put forward during the Impact Assessment phase.” Too frequent fire in these vegetation types will be a disaster. “Partial rehabilitation of the site once mined should be largely possible, but it will require planning and adequate budget upfront.” How much is partial?
8. CONCLUSIONS Authors comments in this section were added to the report but these 2 highlighted points were the most important aspects to consider. “Detailed planning, construction, operational and rehabilitation phase mitigation will be required in order to safeguard the vegetation in the areas outside the actual development footprint. This should be outlined by the botanist at the Impact Assessment phase. A biodiversity offset is very likely to be suggested as the only feasible means of dealing with the unavoidable, residual impacts of loss and disturbance of vegetation in the focus area, which includes habitat fragmentation and loss
The Municipal Manager: West Coast District Municipality– emailed – 02/06/2014
The West Coast District Municipality has no comment at this stage Noted. of the assessment and awaits the EIA phase and specialist reports. Several meetings have been held with the Department of Transport and Public Works However, since the proposed development will have an impact on regarding the proposed road, and a Traffic Impact Study has been undertaken to 76 roads due to increased heavy vehicle traffic, it is recommended that inform the road proposals. This report is appended to the EMP. comments be obtained from the Department of Transport and Public Works. PAGE: 42 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Sharon February: Chairperson; Cape West Coast Biosphere Reserve – mailed – May 2014
The proposed mining area falls within the declared buffer zone of the Noted. The mine is to be located on private land. West Coast National Park and the buffer zone of the Cape West Coast Biosphere Reserve (CWCBR). The proposed mining area borders on three sides of the WCNP. The specific area forms part of one of the last large corridors (inland to ocean) in the country and also forms part of the easterly expansion of the park to connect with the Grootefontein SANParks property in Hopefield. The purpose of a buffer zone is to ensure that activities within a buffer zone of a biosphere reserve and national park are organized so they do not hinder the conservation objectives of the core area, but rather help to protect it. The buffer zone has been implemented due to the following reasons: It is a Noted. Please refer to the EIA-EMP regarding the buffer zones and CBA’s as well as 77 Priority natural area the updated comments received from SANParks, DEA&DP, and West Coast Biosphere Expansion of the national park; regarding these components. The fauna specialist study is appended to the EIA-EMP Corridors for the movement of wildlife as Appendix C6 and C9. Contribution to the conservation of Biodiversity It is a Catchment area Ground water catchment areas or aquifers which feed springs and seeps into national parks (e.g. West Coast National Park).
The role of the state is not only to support business as articulated, but to effectively manage the environment for the benefit of future generations.
PAGE: 43 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Critical Biodiversity Area: The Saldanha Bay Spatial Development Framework identifies the mining area as a The proposed mining area also forms part of a Critical Biodiversity Area CBA. As such the EEM will investigate biodiversity offsets as a consequence of (CBA). The landscape and ecological connectivity is fully functioning, offsetting the impacts of the mining activity on the said land. which has been supported by a specialist. As a CBA it should be protected and included into the WCNP as the first option. It also falls in West Coast There are four primary vegetation types on site National Park's buffer• zone and will negatively affect SANParks' ability to Namely: consolidate the park. This area was zoned as remote and wilderness in • Hopefield Sand Fynbos and in terms of the National List of Threatened WCNP and if mined this will not be the case. Much of the natural occurring Ecosystems is regarded as Vulnerable. vegetation on the West Coast has been transformed, degraded, • Saldanha Flats Strandveld - Vulnerable in the National List of Threatened fragmented and some irreversibly transformed (especially in the IDZ). Ecosystems (DEA 2011). The habitat condition in the proposed mining area i.e. Saldanha Flats • Langebaan Dune Strandveld - Least Threatened on a national basis (DEA Strandveld, Hopefield Sand Fynbos and Saldanha Limestone Strandveld as 2011) well as their eco-tones are in very good condition. The ecosystem status • Saldanha Limestone Strandveld – Least threatened. for all the vegetation types (except Langebaan Strandveld) qualifies as Endangered under either criterion A1 or D1. There are also several species Please refer to the previous comment and EIA-EMP as well as the botanical report. of conservation concern found on the site.
There are conflicting figures given the amounts to be taken out and the The planned life of mine is for 15 -20 years. years of operation. The I&AP meeting held on 8th January stated 940 000 tons over 25 years, while the scoping document states 38 million tones and 35 million tones and then again 17 years are mentions (p42). Can we please get clarity on the exact time which it foresees in operating?
Some re-vegetation may be possible but rehabilitation of the area to pre- Noted. The Rehabilitation Plan will be included in the updated EMP which will be mining will be difficult. We as the CWCBR would like to see the detailed released for comment. The area will be mined in strips so as to allow concurrent rehabilitation plan as devised by Deon van Eeden of VULA included in the rehabilitation. scoping report and EMP.. We understand that strip mining will take place and will prefer that areas to be mined at one time are rather smaller than Refer to Appendix C12 of the EIA-EMP. bigger as to give the rehabilitation work the most chance of succeeding.
Can the botanical survey be expanded into the flowering season, ideally The botanical study will be provided in the updated EMP which will be released for July to September, to include geophytic and other flowering species that comment. Refer to Appendix C2 of the EIA-EMP. might have been excluded in the Helme 2013 survey?
PAGE: 44 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The scoping report does not provide a full vegetation and animal species The botanical, fauna and avifauna study will be provided in the updated EMP which will list, but from it however it is found that about 241 reptile, mammal, be released for comment. These studies will include recommendations to minimise amphibian and bird species will be displaced. These are number of potential impacts related to the mining activity. species not actual numbers of the current populations. Strandveld and Fynbos areas are characterized with low carrying capacity and Refer to Appendix C2, C6 and C9 and EIA-EMP. complicated, specialized relationships (pollinators, plant-herbivore, and predator-prey interactions) within its ecosystems. How will specie loss be monitored mitigated, managed and monitored? Ground water: The geohydrological study will be provided in the updated EMP which will be released Can detailed information coming out of the hydrological working group that for comment. The release of the information from this working group will be looked into. meets monthly at the Department of Water Affairs not be sent to stakeholders on a regular basis, i.e. quarterly. This should help to The discussion and recommendations of this working group has had a direct impact on inform interested and affected parties. the scope of the groundwater study – refer to Appendix C4. The study that indicate the phosphate as a strategic phosphate deposit EEM, in addition to this is currently undertaking prospecting activities on site. Within was done in 1984 i.e. 30 years ago. Have no other studies been done South Africa, South Africa has fourteen known phosphate deposits of which four are since to explore alternative sites in less sensitive and ecologically igneous deposits (Phalaborwa, Schiel, Glenover and Spitskop) with the other ten being important areas? Since that time newer research has emerged which sedimentary deposits located in the Varswater formation in the Western Cape. afforded the government to give the particular aquifer protection status. It is urged that Best Science practices be adopted. According to the Council of Geoscience, Elandsfontein Portion 4 is the only new viable large scale phosphate mine in South Africa. The property is the second largest deposit in South Africa after Foskor, and the highest grade of all of the large scale deposit in South Africa. Refer to Appendix C13. The economic and strategic document of the Scoping report clearly Noted. Refer to Appendix C13. outlines the phosphate industry as non• renewable industry i.e. worldwide resources to be depleted between 75 - 200 years. The gee-hydrological report indicates that this aquifer has been forming over the past 5-10 million years. Socio-economics: A socio-economic study is currently underway. Refer to Appendix C10 of the EIA-EMP. No mention is made of possible socio-economic impacts of pollution of the aquifer and what impact this might have on natural areas (including the national park, and RAMSAR wetland site) as well as the tourism Sector whom are dependent on these natural sites.
PAGE: 45 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The CWCBR would like to see that skill transfers to local people take place. A total of approximately 800 jobs will be created in the construction phase and That people become employable in sustainable jobs. The Scoping Report approximately 300 permanent jobs during the operation phase of the mine. Part of the is not forthcoming on the exact amount of jobs which it will create, what social and labour plan indicates upskilling of the labour force which will be from the type of jobs (pay scales etc.). The economic feasibility report indicates that adjacent labour sending towns. Refer to Appendix C10 of the EIA-EMP. A skills audit of all people in the area will benefit, but does not go into further detail. No the primary beneficiary town, Hopefield will commence shortly. skills analysis was done in towns such as Hopefield to indicate the feasibility of generating employment from these towns. Archaeology and Geology: Noted. The site has been described as one of South Africa's best fossil deposits. The CWCBR thanks the applicant for donating the section containing the fossils to SANPARKS for further conservation. Can the handling of fossil and other heritage finds during the proposed As part of the heritage application, a heritage management plan will be prepared which mining phase; be explained in greater detail and specifically the will be implemented as during the operational phase of the mine. This report will recommendations from Jonathan Kaplan. The Geological Scoping Report provide management details regarding archaeological finds. indicates that the phosphate cemented conglomerate is rich in whale, Please refer to the Paleontological report appended to the EIA-EMP as Appendix C1. penguin, shark and mollusc fossils including teeth of a three toed horse Hipparion. Eskom Power lines, servitudes, conveyor belt and roads: This information will be provided in the updated EMP. The scoping report is vague on the exact footprint of these planned activities. It is known that there are always secondary impacts Refer to the updated EIA-EMP and Avifauna Study see Appendix C6. associated with such undertakings. We request further clarification on these activities. Fire: Noted. The Greater Cederberg Fire Protection Association has assisted EEM in Fire was identified as a high risk. We have learnt that the land-owner have preparing the Fire Management Plan refer to Appendix H of the EIA-EMP. joined the Greater Cederberg Fire Protection Association. We would like to see that their recommendations are followed taking into consideration that Elandsfontein is a very sensitive place in terms of bio-diversity.
Conclusion: Noted. SANPARKS were in negotiations with acquiring the Elandsfontein properties but unfortunately these fell through. The right of the land-owner to apply for development rights is supported by the CWCBR.
PAGE: 46 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The Cape West Coast Biosphere Reserve supports development within the Noted. The EIA-EMP outlines the various alternatives that was investigated and why West Coast, but this needs to be sustainable i.e. without impacting future they were screened out. generations negatively. It further needs to be in line with UNESCO's Man and the Biosphere vision of activities within a buffer zone. Overall the likelihood of the area loosing critical habitat, species, connectivity, the functioning of a five million year old aquifer, exploitation of a non• renewable resource, impacting on archaeological findings are very high. Impacts will be on a local and regional scale. Detailed information regarding alternative areas is also lacking. Some of the information within the report are also incorrect i.e. an ostrich being classified as a 'large mammal'. We request that decision precedents regarding mining and other activities Noted. in important water management areas be considered and that the competent authorities adopt a precautionary approach and not make a decision if there is insufficient information. The Cape West Coast Biosphere Reserve, as a custodian of the area, will Noted. support the application if all issues from Capenature and Sanparks are addressed and proper workable mitigation measures are put in place. The total property should be handed over to SANPARKS post mining and Noted. This issue is to be addressed between relevant parties. A biodiversity offset rehabilitation, if a mining permit and water use license are issued. study may be undertaken as part of the EIA (NEMA) application it the impacts cannot be sufficiently mitigated (pertaining to vegetation loss). The CWCBR reserves the right to revise initial comments and request any Noted. additional information that may be received.
Mev. Rachel Jason– mailed – 14/05/2014
Dankie datdaar werk geskep word. Ons is reeds werkloos. Ons wag vir die Noted. 78 werk.Baie dankie
Lesley Wellman– emailed – 03/05/2014
I would like to ask if you can forward me the EEM Report to me. I am The report has been forwarded. 79 currently very hard busy with Chapter 5 and the article on ArcellorMittals
PAGE: 47 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
role in regional development. I do not have time to read the document in the library. I attend all your sessions in Saldahna and Hopefield.
Dr Ernst Board, Executive Director: Biodiversity Support mailed – 26/05/2014
CapeNature would like to thank you for the opportunity to comment on the Noted. All CapeNatures comments have now been included. The SANParks comments revised Scoping Report for the proposed mining activities. We are largely relate to specialist investigations and project description. This has now been disappointed to note that the consultant did not include our previous updated as part of the EIA-EMP. comments (dated 18 February 2014) on the Scoping Report in the revised scoping report, either as a copy of the letter we sent or in the comments and response report. Although CapeNature's comments on the BID were included (letter dated 08 January 2014) , many additional important points were raised in our letter which was submitted based on the previous scoping report which should have been addressed and made available for the competent authorities to view as well as other interested and affected parties. We have therefore attached a copy of these comments again. We also note that although a copy of SANParks comments dated 28 February 2014 is included, they have not been addressed in the comments 80 and response report. The revised scoping report should be updated to a final Scoping Report Noted. which includes and addresses all comments raised by all authorities and interested and affected parties. Meeting minutes from discussions regarding the offset study do not comprise part of CapeNature's official response to the application at this stage and it was made clear at this meeting that CapeNature was of the opinion that discussions regarding offset were premature as the extent to which it will be possible to minimise and mitigate certain impacts was not yet clear and that CapeNature agreed to partake in discussions regarding offsets only to ensure that the process took a precautionary approach and made use of best available science and made it clear that our participation did not imply support for the proposed mine.
PAGE: 48 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
We would like it to be noted that all of our previous comments in our letter Noted. These are included in the Comments and Reponses Report dated April 2014. dated 18 February 2014 remain applicable. In addition, we would like to make the following further comments on the revised scoping report: Maps, Layouts and assessment of associated infrastructure: Noted. All maps have been updated refer to the EIA-EMP. 1. A clear fine-scale layout plan of the mining area and inland port as well as all associated infrastructure still needs to be provided. Figure 3-2 in the report is broad scale, blurred and unclear. Although layouts are also provided in some of the specialist studies, these also do not clearly show all infrastructure including buildings, roads, sewage treatment facilities, pipelines, powerlines etc. for both the proposed mining area and inland port area. Exact footprints and an indication of scale need to be provided on all layouts. 2. Roads and powerlines can have a significant footprint and secondary The specialist studies will be included in the updated EMP. The NEMA EIA process impacts of their own. Considerable road upgrades and widening will be has not yet commenced. The EMP, with specialist studies will be released for public required. Powerline and road routes must be finalized and their impacts comment. These components have been assessed as part of the specialist studies assessed before the Environmental Impact Report and Environmental which are appended to the EIA-EMP. Management Programme is submitted to DMR and DEA&DP for review. All commenting authorities and I&APs must also be given an opportunity to comment on roads, access points and powerlines.
3. The inland port site is an additional considerable footprint. The report The inland port option is no longer being considered. states that the site is old agricultural lands. This needs to be confirmed by the botanical specialist. All specialists also need to consider potential edge effects and indirect impacts on surrounding areas (for both the proposed mining area and the inland port area) which may be impacted by inter alia air emissions dust and other wind-blown pollutants which may arise from excavating, processing, transport and storage. 4. Please note that Figure 4-3, which supposedly shows the relation of Noted. All plans have been updated in the EIA-EMP. the proposed mine and inland port site to the West Coast National Park (WCNP) is missing - the Figures in the report jump from Figure 4- 2 to Figure 4-3. 5. The Critical Biodiversity Area (terrestrial) map provided in Annexure A3 Noted. All plans have been updated in the EIA-EMP. is incorrect.
PAGE: 49 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Impacts on Groundwater: The potential impact on groundwater is currently being investigated. In addition, a Water Committee consisting of the Department of Water Affairs, independent aquifer 6. A geohydrological report has been made available in the revised recharge specialists, hydrogeologists and ground water specialists from SANParks, the Scoping Report which did not form part of the first Scoping Report. This mine’s appointed hydrogeologists, and representatives from EEM attend monthly is key information that should have been available in the first round of meetings to discuss and determine the best approach and designs related to commenting. It is clear that potential impacts on the aquifers are of very management of water to minimise potential impacts on the groundwater. high concern with the aquifers having a vulnerability rating of high to very high which requires a high to strictly non-degradation level of Refer to the Geohydrological Report which is appended to the EIA-EMP as Appendix groundwater protection. It remains unclear exactly how the applicant C4. intends to avoid and minimise the impact on the upper and lower aquifers. Monitoring and detecting contamination after it has already occurred is not sufficient mitigation. Landowners in the area have indicated to CapeNature that the aquifers are important for agriculture and are extremely concerned about contamination of groundwater. As mentioned previously by CapeNature and the Scoping Report, as well as other specialist studies conducted previously the aquifer does appear to be an important source of freshwater to Langebaan Lagoon, a RAMSAR site. In addition, any water draw down may affect the vegetation on and around the site as well as re-establishment of vegetation. 7. The geohydrological report provided does not contain sufficient baseline Noted. This report is being updated and will be available for comment. information. It mentions that the impacts of prospecting are likely to be acceptable but does not make any statements regarding the impacts of Refer to the Geohydrological Report which is appended to the EIA-EMP as Appendix mining. Sufficient baseline data must be obtained before the C4. geohydrologists can accurately determine potential impacts. Baseline data should include collection of data through at least one dry season and one wet season. Wet season determination should be based on data collected throughout a winter with an average to higher than average rainfall. Average rainfall should be calculated preferably from at least 30 years of data for the Saldanha region. We ask that the competent authorities adopt a precautionary approach and not make a decision if there is insufficient information. We also ask that decision precedents for mining and other activities in other important water management areas in South Africa are considered.
PAGE: 50 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Plan of Study and Terms of Reference: Noted. 8. Please refer to our comments on the previous Scoping Report with regards to the application of best available science. 9. Please note that the list of specialist studies to be undertaken on A botanical study is underway. Refer to the Botanical Assessment which is appended page 148 under Section 9 of the revised Scoping Report does not to the EIA-EMP as Appendix C2. include a botanical study. 10. With regard to Species of Conservation Concern (SCC), the Noted. Refer to the Botanical Assessment which is appended to the EIA-EMP as botanical and faunal specialists must determine how well species Appendix C2, C6 and C9. that will be impacted by mining are represented in areas outside of the mining footprint in areas that will be conserved. Clear maps indicating the locations of SCC must be provided. 11. More information in general needs to be provided on technology Noted. Refer to the updated EIA-EMPR for more detail, and layout alternatives being considered and how this will lessen impacts on the environment. We will provide additional comment during the next phase of the application process once more detailed specialist reports and maps indicating sampling points and tracks (including botanical, faunal and groundwater) and detailed descriptions of alternatives, rehabilitation and other mitigation measures have been provided. CapeNature reserves the right to revise initial comments and request further Noted. information based on any additional information that may be received.
Dr Ernst Board, Executive Director: Biodiversity Support mailed – 18/02/2014
PAGE: 51 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
CapeNature would like to thank you for the opportunity to comment on Noted. the scoping report for the proposed mining activities. CapeNature is the statutory custodian of biodiversity in the Western Cape1 and commenting authority concerning potential impacts on biodiversity. CapeNature are recognized as an official commenting authority with regard to NEMA, LUPO, Agricultural and Mining applications. We do not authorize any of these applications but we do have a mandate to advise the relevant authorities as to whether the biodiversity information and assessment provided by the applicant is sufficient, relevant and reliable (i.e. has the best available biodiversity information been used).
All of the issues raised by CapeNature are noted. Biodiversity and Conservation Planning:
1. We are satisfied with the general findings of the botanical specialist Noted. EEM is of the opinion the legal listing of these vegetation types should be with regard to the vegetation present. The larger area consists applied, in line with the feedback they received from the competent authority (refer to mostly of Saldanha Flats Strandveld and Hopefield Sand Fynbos the EEM executive summary attached to the EIA-EMP. with elements of Saldanha Limestone Strandveld and Langebaan Dune Strandveld. The focus area consists mostly of Saldanha Flats 79 Strandveld with a mosaic of Langebaan Dune Strandveld and Saldanha Limestone Strandveld. The specialist has noted that Hopefield Sand Fynbos and Saldanha Limestone Strandveld should be listed as Endangered under Criterion D1 (number of species of conservation concern) but we request that he also takes the
following into consideration:
Ecosystem threat status tells us about the degree to which ecosystems are still intact or alternatively losing vital aspects of their structure, function and composition, on which their ability to provide ecosystem services ultimately depends. Ecosystem types are categorized as critically endangered (CR), endangered (EN), vulnerable (VU) or least threatened (LT), based on the proportion of each ecosystem type that remains in good ecological condition relative to a series of thresholds.2
National figures reflecting the proportion of each ecosystem type remaining in good ecological condition, and supporting the list of PAGE: 52 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
threatened ecosystems published in 2011 under NEMBA, are based on land cover datasets primarily derived from satellite imagery taken in 1994-95 or 2000- 20012. This means that, in some instances, the most current National ecosystem threat statuses are based on
conditions which have changed considerably.
Although not comprehensive, more recent land cover informants do . exist with which to assess habitat loss. Further, SANBI has released
an update of the 2006 South African Vegetation Map (Mucina and
Rutherford), which aims to provide floristically based vegetation units
at a greater level of detail than had been available before. Thus, in an
effort to utilize best available science (including the abovementioned
land cover and ecosystem mapping datasets) and to generate figures
which more accurately reflect the current degree of habitat loss in the
Western Cape, CapeNature has recently produced updated provincial
ecosystem status statistics in accordance with the National principles,
criteria, and approach 3
We understand that this assessment was not available to the botanical specialist at the time that he wrote the botanical report (November 2013) but the details regarding the methodology and detailed statistics are now available on request. The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Hopefield Sand Fynbos can be considered Vulnerable and Saldanha Flats Strandveld, which only has 36% of its original extent remaining, meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act.
2. The Mining and Biodiversity Guidelines strongly advocate the use of Noted. best available biodiversity information, which includes not only the use of information such as the above but also the use of spatial biodiversity plans which have come out of a process of Systematic Conservation Planning, which have been produced not only in the Western Cape but throughout South Africa. Spatial biodiversity planning has supported the identification of biodiversity priority areas which are important for conserving a representative sample of ecosystems and species and/or for maintaining ecological processes PAGE: 53 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
and/or for the provision of ecological services.
3. Biodiversity Priority Areas that are relevant to this site include inter alia: Noted. Protected Area buffers Endangered Ecosystems Critical Biodiversity Areas High Water Yield Areas (this includes not only Mountain
Catchment Areas but also important aquifers)
Ramsar Sites (The Elandsfontein Aquifer eventually seeps
into the Langebaan Lagoon) Vulnerable Ecosystems CapeNature would like to note the following with regard to Critical Biodiversity Area maps for the Western Cape: CBAs represent the best available science and for that reason need to be considered in decision-making. No promulgation/proclamation/ endorsement still needs to happen in order for this to be applicable. The only manner in which the CBAs may not yet legally be applied, is to activate certain activities in listing Notice 3 of the EIA Regulation, i.e. CBAs are not yet legally recognized as triggers for EIAs. However, there are other reasons pertaining to the biodiversity present on site that would trigger an EIA. CBA maps which are a product of systematic biodiversity planning are supported not only by CapeNature but also by SANBI and have been produced as Biodiversity Sector Plans 5 which also outline the implications of CBAs for development.
4. Furthermore, the Saldanha Bay Municipality Spatial Development Your comment is noted. The Draft EMF was released in February 2013. The EMF may Framework (2011)6 and the Draft Environmental Management still be amended during the finalisation process and must be adopted by the Minister. Framework for the Greater Saldanha Area7 have taken the CBA Once adopted, EMFs must be taken into consideration in decision making. maps into consideration for planning purposes and indicate the application area as Core 1 and Environmental Management Zone 1 respectively.
5. The CBA relevant to this site was determined for the following reasons: Noted. a. The landscape and ecological connectivity of the site- the site is located within the SANParks buffer zone between two parcels of land forming part of the West Coast National Park, belonging to SANParks. The connectivity is currently regarded as fully functional and this has PAGE: 54 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
been supported by the botanical specialist. b. Habitat condition - the natural vegetation on site, namely Saldanha Flats Strandveld, Hopefield Sand Fynbos and Saldanha Limestone Strandveld and eco-tones between the above, are in very good condition (it should be noted that Saldanha Flats Strandveld and other vegetation types occurring elsewhere in the Saldanha Bay Municipality, excluding the West Coast National Park, are generally more degraded and fragmented and are already under threat of being irreversible transformed, especially in the IDZ.) c. The presence of species of conservation concern. d. Edaphic interface - there is significant difference in soil types present on site, ranging from limestone ridges to acid sands, lime-rich coastal dune sands etc. e. Ecosystem Status for all vegetation types - all except Langebaan Dune Strandveld qualify as Endangered under either criterion A1 or 01.
6. The site also forms part of an important climate change adaptation Noted. As such a climate change study will be undertaken as part of the NEMA EIA corridor between the West Coast National Park and the Berg River. Process. These types of corridors will become increasingly important for mitigation of impacts of climate change. On a regional scale there are very few substantial corridors connecting the coast to the inland area.
7. Vegetation and habitat loss as a result of mining is considered Noted. long-term to permanent. Some revegetation may be possible but
rehabilitation of the site to the same species composition as prior to
mining is unlikely (as can be shown from other excavated sites in the
area) as the soil structure and landscape features will be destroyed.
Due to the conservation importance of the site and the large size of CapeNature would like to note the following with regard to Critical Biodiversity Area maps for the Western Cape: CBAs represent the best available science and for that pristine vegetation regardless whether the vegetation type is listed as Endangered or Vulnerable. We disagree with the botanical specialist that the impact prior to mitigation is medium negative and maintain that the impact should be considered at least high negative.
PAGE: 55 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Groundwater:
8. A detailed geohydrological report has not yet been provided for A baseline geohydrological report was provided in the revised scoping report. The comment but it is apparent that the proposed mining area is located detailed study is currently underway and will be provided in the updated EMP which will above the Elandsfontein Aquifer System and borders on a high be released for public comment. yielding region and the susceptibility of the aquifer to contamination from anthropogenic activities is high. The depth of the ore to be A detailed geohydrological study has been undertaken – refer to Appendix C4 of the extracted extends into the top aquifer. Any activities that have the EIA-EMP. potential to negatively impact on the aquifer below the site should not be supported. Not only is this aquifer is likely to become an increasingly important supply of water for human needs in the future but has also been determined as an important water source for the Langebaan Lagoon, which is a RAMSAR site.
Associated infrastructure and required services:
9. The proposed powerline and haulage routes require far The detail regarding this is provided in the EMP. Refer to the updated EIA-EMP. more detailed investigation. New powerlines and roads will result in additional loss of vegetation. Water use has also not yet been determined as well as means of transporting the required volume of water to the site and the impacts thereof will also need to be determined.
10. Considerations of where labour will be sourced from, how they will be Labor will be sourced for adjacent towns with the Saldanha Bay Municipality. Refer to transported to and accommodated on site also has potential the updated EIA-EMP. secondary impacts on the biodiversity on and surrounding the site and needs to be assessed in more detail.
Alternatives and Offsets:
11. All applications for any mining or development application should Noted. Refer to the updated EIA-EMP. be able to provide comprehensive evidence that there are no suitable alternative sites, especially when the potential negative impacts on the environment (in this case this includes biodiversity as well as sense of place and other landscape level impacts) are high. This is also supported in the Mining and Biodiversity Guidelines 4 . According to the guidelines proponents must also demonstrate that PAGE: 56 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
cumulative impacts have been taken into account, the mitigation hierarchy has been systematically applied and the issues related to biodiversity priority areas have been incorporated into a robust EMP as the main tool for describing how the operational environmental impacts are to be mitigated and managed. Assessment of the potential direct, indirect and cumulative impacts of mining on biodiversity and ecosystem services must show that there will be no irreplaceable loss or irreversible deterioration.
12. Alternatives should also be investigated as to the size of the mine, Various alternatives were investigated as part of the application and is outlined in the especially in instances such as this or authorising the mine in phases EMP. Refer to the updated EIA-EMP. so that the applicant can prove that rehabilitation is feasible and can meet set measurable rehabilitation standards (i.e. species composition, coverage, faunal presence and use of habitat, alien removal etc.) Technology and layout alternatives should also be explored and described in detail in the next phase of the application process. All alternatives should be assessed by all specialists.
13. If offsets are to be considered, it must be shown that the mitigation Noted. hierarchy was strictly implemented and avoiding, minimising and rehabilitating were first considered in detail. Offsetting for probable residual impacts must be feasible and assured, taking into account associated risks and time lags.
14. Areas to be used as biodiversity offsets should be priority The biodiversity offset study will be undertaken by Mark Botha, who has considerable conservation areas. experience in biodiversity offset studies. Prioritisation should be done by considering a combination of conservation importance and threat of transformation to determine if an area is suitable as a biodiversity offset and should not be pre- selected based on the desired outcomes of the application. Alternatives are also required to be considered when assessing whether a suitable offset exists. In some instances, areas not currently prioritised for protection may have to also be included to compensate for loss of biodiversity priority areas. Funding and management tools must also be investigated for any proposed
offsets.
PAGE: 57 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Conclusion:
1.5. CapeNature acknowledges that as with all mining projects there can Noted. Refer to the updated EIA-EMP and specialist studies. be social and economic benefits. However, our mandate is to protect the exceptional biodiversity found within the Western Cape. CapeNature's stance of non-support for this project therefore remains at this stage. We will provide additional comment during the next phase of the application process once more detailed specialist reports and maps indicating sampling points and tracks (including botanical, faunal and groundwater) and detailed descriptions of alternatives (including layout, technology and methodology), rehabilitation and other mitigation measures have been provided
Malcolm Watters and Rod Boyes: PGWC: Department of Transport and Roads Minutes of meeting-06/06/2014
PGWC has no objection to hauling the product to the port via road, as Noted. long as EEM complies with the legal road requirements (weight, legal vehicles etc). EEM road design to comply with requirements of the PGWC. This will be evaluated once the road application is submitted to PGWC for approval.
DEA&DP (Taryn Maart, Melanese Schippers, Andre Oosthuizen, Albert Ackhust) Minutes of meeting – 15 May 2014
DEA&DP indicated that it would be favourable if one single NEMA Noted and agreed. application is submitted for the mine and related infrastructure excluding the powerline application which should be a separate application.
The waste management licence application will be submitted to DEA. Biodiversity offsets must be considered as a last alternative if impacts Noted. cannot be mitigated, but this study must be done according to the regulatory requirements.
Dr Ernst Baard: Executive Director: Biodiversity Support
PAGE: 58 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Emailed 31 July 2014
CapeNature would like to thank you for the opportunity to comment Noted. DMR distributes the report for consultation to state departments for comment. on the Environmental Management Programme. We would like to note BEP has however, notified CapeNature of all documents available for comment . upfront that the applicant and consultant have not been able to adequately address all the comments and concerns put forward on the Seeping Report and revised Seeping Report. We also note that the consultant has acknowledged this and plans to submit a revised Environmental Management Programme with more information. Ideally, the applicant should have applied for authorisation in terms of NEMA before applying for the mining right as the application process in terms of NEMA allows for longer time frames between submission of documents as well as a more comprehensive public participation process (note that we have only received notification of the EMPr through DMR and not through the consultant despite being registered as commenting authorities). Note also that CapeNature was not informed of the availability of the LUPO application for departure and therefore did not have an opportunity to submit comments to the municipality.
Note that this application qualifies under high to very high public Noted. sensitivity and requires maximum opportunity for I&APs to be informed, view documents and provide comment via the right channels. Sufficient
time also needs to be provided between application phases so that
comments and concerns from the public and organs of state can be
addressed.
Although our previous comments have now been placed in a comments Noted. and response table, most of the comments are responded to as merely "noted". This is not adequate, responses should be detailed and indicate where in the report or specialist studies concerns have been(or will be) addressed. If concerns cannot be addressed this should also be
clearly explained and motivated.
Thus, most of our previous comments in our letters dated 18 February Noted. 2014 and 26 May 2014 remain applicable. However, we do note the
inclusion of better maps and that it is currently no longer the PAGE: 59 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
applications intention to use the inland port site. All of the following comments must be considered in conjunction with our previous comments.
Importance of Critical Biodiversity Areas and other conservation planning on the si te:
1. Please refer to our comments on the Scoping Report with These comments are noted. DEA&DP has indicated that the property does not fall regards to the application of best available science. Please also within an endangered ecosystem. refer to the attached letter from DEA&DP which endorses the use of Critical Biodiversity Areas as best available science in decision-making. Critical Biodiversity Areas have also been supported and taken up by many municipalities throughout the Western Cape, including Saldanha Bay, through using them to inform SDFs and EMFs for the municipality and region.
2. Unfortunately, no other CBA within the Saldanha region is as Noted. pristine or as well connected as the one that the mining area will impact on. Other CBAs have already been impacted on within the IDZ and on the Saldanha peninsula. If this CBA is irreversibly transformed it is likely that conservation targets will not be met for pattern or process in this region.
3. The site falls within the buffer zone of the West Coast SANParks has indicated that the Buffer Zone has not been gazetted as yet. National Park. Buffer zones are essential for SANParks to achieve their national objectives which includes protection of biodiversity and ecosystem services, probably the most important of which is provision of clean water. The area in which the proposed mining is to take place has been considered vital to the park's expansion strategy since before the current landowners purchased the land and applicants/landowners were aware that the site is of high
conservation value before they purchased it.
Layouts and road network:
4. Roads and powerline routes still require finalization. In Refer to the updated EIA-EMP. PAGE: 60 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
addition more information is required on the type of upgrades and widening of roads that will be required to accommodate large trucks and heavy machinery. Even if the powerline will be authorized as part of a separate EIA the proposed footprint must still be clarified as part of this application process.
Air pollution:
5. In addition to assessment of potential air pollution from the mine Refer to the air quality study – Appendix C7. site, risk of pollution from wind-blown pollutants during transport and storage needs quantification.
Impacts on Ground Water
6. The geohydrological report in the EMPr is the same as that Refer to Appendix C4 for the groundwater study. provided in the revised Scoping Report and did not form part of the first Seeping Report. Information in the main report refers to various proposals to ensure that the aquifer does not become contaminated or that significant draw down of water levels occurs. However, the contamination risk from all potential sources has n·ot been quantified. Monitoring is proposed but the report does not state what remediation will be taken if contamination is detected. The applicant/consultant also needs to provide examples of where similar technology they propose to use has been used successfully elsewhere. Elandsfontein has a high groundwater sensitivity (which is linked to at least one important surface water feature) and overall the site is of high conservation importance and should not be used as a test site for unproven technology.
Rehabilitation:
7. More detail with regard to rehabilitation and end-use of the site is Refer to the EIA_EMP and Rehabilitation Plan in Appendix C12 required. Certain aspects of the development including buildings and slimes dams are likely to be permanent features after mining is completed.
8. We note that it is proposed to commence rehabilitation within Noted. Refer to the Rehabilitation Plan in Appendix C12 PAGE: 61 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
4 years after mining has commenced. Many plant species' seed banks do not remain viable within the topsoil for such a long time period. In addition, disturbed areas and stockpiled topsoil is prone to invasion by alien plants and pioneer species.
Conclusion:
CapeNature is expecting an opportunity to comment on the revised Noted. EMPr. Currently, sufficient baseline information as well as proof that the impacts of this application will not result in irreversible loss or damage to biodiversity including ecosystem services has not been provided and CapeNature's objections remain in place at this stage.
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received.
Jaco Nel: Conservation Services – South African National Parks (SANParks) Elandsfontein Freshwater Specialist Report review – 22 July 2014
The report by Blue Science titled “Freshwater Assessment Report for Noted. the Proposed Elandsfontein Phosphate Mine” dated June 2014 has reference. The purpose of the Freshwater Assessment Report was to provide a screening level freshwater impact assessment and serve as baseline data to evaluate risks to ecosystems as a result of the proposed Elandsfontein mining development.
The Freshwater assessment report and protocols (SASS5, Habitat Noted. Integrity and WET- EcoServices methodologies) are largely focused on surface water ecosystems and not on groundwater or the interactions between the aquifers and surface water systems. Surface water ecosystems are however often a feature of groundwater contribution to the surface water system, especially in the arid west coast regions of South Africa. At the Elandsfontein site the groundwater system consists PAGE: 62 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
of an upper unconfined aquifer as well as a lower confined aquifer unit. These two aquifer units will respond differently to any potential impacts and should be considered as such as part of the impact assessment.
The Freshwater Assessment report was reviewed with three (3) main objectives in mind:
1. To obtain insight regarding the dependence of ecosystems surrounding the proposed
Elandsfontein mining area on the aquifers underlying the site;
2. To evaluate any risks related to impacts between the proposed Elandsfontein mining activities, the aquifers underlying the site and the (freshwater) aquifer dependent ecosystems;
3. To identify whether comprehensive protection could be provided to the surrounding ecosystems based on the insight provided by the Fresh Water Assessment report.
Ecosystem dependence
The Langebaan lagoon is regarded as largely natural, but sensitive to nitrogen loading from sewage water releases causing algal blooms (Section 5.2.2, P22). Langebaan Lagoon receives fresh water contribution from the Elandsfontein and Langebaan road primary aquifers. The exact mechanism of fresh water discharge is not clear from the different research results at the site, but mostly suggests that the lower aquifer unit contributes most of the freshwater to the lagoon (Saayman et al., 2005).
The Sout- and Groen Rivers are unique saline systems with “less saline reaches” (Section
5.3.1, p25; Section 5.3.5, p30) possibly due to fresh groundwater contribution to the rivers. Surface flow is due to the occurrence of springs and seeps (Section 5.3.1, P26), confirming the localised groundwater
PAGE: 63 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
contribution.
The Sout- and Groen Rivers obtained low SASS scores due to the low abundance of macro- invertebra, consisting mostly of hardy species and air breathers. From the report (Section
5.3.3, P29) it seems that this is due to the “high natural salinity” as well as “low dissolved oxygen levels”. Both these conditions are expected from groundwater discharge, confirming the role of groundwater in the maintenance of the Sout and Groen River systems. The isolated pools (Section 5.3.4, p29) further confirm the groundwater contribution during the dry months.
Based on the information provided in the Freshwater assessment report it is concluded that both the Langebaan lagoon and Groen/Sout River systems are dependent on groundwater for their ecological functioning and could be negatively influenced by groundwater abstraction in the catchment.
Risk related to site
Various activities at the site are discussed. These can relate to different risks to the groundwater system and should be further investigated:
In Section 6.1 (p36) mention is made of slimes from the plant that Noted. The groundwater study considered the geochem results from the tailings and will be backfilled as part of the strip rehabilitation. The composition of current arisings. Refer to Appendix C4. geochemical characteristics of the slimes backfill has not been provided in any of the reports provided for review. The quality of the slimes should not be allowed to deteriorate the water quality of the groundwater and potentially affect the down-gradient fresh water ecosystems. In Section 6.1 (p37) mention is made of continuous perimeter pumping and the re- introduction of the water via horizontal trenches. No reporting or evaluation on this topic has been provided yet. Re-introduction of the water might be required both up-gradient as well as down-gradient from the site. It was also noted during a site visit to the Elandsfontein site that the space available between the proposed open pit and the PAGE: 64 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
SANParks border was limited and that it might be difficult to abstract on the perimeter as well as inject a few metres from the pit to stay within the mine property. More detail in this regard should be provided.
The Freshwater report states that water draining to the pit will A water balance was undertaken for the project refer to the EIA-EMP. be consumed for activities on the site (Section 6.1, P37). This volume could be significant if the perimeter dewatering is not efficient and should be evaluated as soon as aquifer test results are available.
Section 6.1( p37) states that waste rock and residue disposal facilities will be established on the site. The geochemical nature Refer to the waste management study – Appendix C11 of the material and the waste classification thereof needs to be provided in order to quantify possible impact.
Ecosystem protection and Impact assessment
The Freshwater report statements that the impacts will be related to Noted longer term impacts (section 8) might be correct for the upper unconfined
aquifer. However, any potential impacts to the lower confined aquifer can
cause pressure changes and reduction in flow over large distances. The
interaction between the proposed Elandsfontein mining site and the
Lower aquifer unit is still under investigation according to my information.
The Langebaan Road aquifer data showed springs drying up several
kilometres from the abstraction site.
The Freshwater assessment report indicates an unlikely impact on the Noted. Where required the study may be expanded to investigate this. Groen- and Sout rivers (Table 17, P44). I am not entirely convinced that this impact is unlikely. The Elandsfontein site groundwater levels are between 55 and 70 mamsl, while the Sout River at Hopefield is situated at an elevation of below 20mamsl. With the Sout River situated a similar distance from the Elandsfontein site as the Langebaan Lagoon, the relative influence on both fresh water ecosystems is regarded as similar.
There is sufficient uncertainty in the understanding of groundwater flow characteristics in the Elandsfontein and Langebaan Road paleo channels to not regard impact on the Sout- and Groen Rivers as insignificant at this stage. Especially the lower confined aquifer system can provide changes PAGE: 65 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
in discharge over large distances where pressure differences dictate the discharge and not the actual flow gradients.
Although it might be possible to state that a limited consumptive use is Noted. Additional groundwater studies are underway. A detailed stormwater expected at the Elandsfontein site, the inflows into the pit can be management plan has been included in the EIA-EMP. significant and difficult to mitigate. This water will be seen as dirty water and could change the status quo regarding the water use volumes dramatically. This should be reviewed as soon as more data regarding the aquifer parameters become available. The potentially high yielding phosphate layer at the bottom of the pit could especially make the management of pit inflows difficult.
The risk of water pollution is not quantified in this Freshwater Noted. Refer to the waste management study for geochem results. assessment report or the Hydrogeology scoping report. Elandsfontein Mining should confirm the geochemical behaviour and leach results of the discard, tailings, waste rock. Based on the field visit to the Old Phosphate mine there are some elements leaching from the mine site causing at least a change in colour of the water in the open pits.
Conclusion
The following conclusions and recommendations are made based on the review of the Freshwater Specialist report:
The Freshwater Assessment report confirms the groundwater Noted. contribution to the Langebaan Lagoon, Sout- and Groen Rivers. Fresh water contributions on all these surface water systems seem to be important for their ecological functioning.
The abstraction and dewatering of the proposed Elandsfontein Noted. opencast pit still has some uncertainty and could be difficult to manage. The dewatering of the site could impact on any of the surrounding fresh water ecosystems. Noted. Refer to the groundwater study. Impacts regarding water level changes to the upper aquifer could
be localised and over the life of mine, but impacts to the lower
confined aquifer could be rapid and over large distances causing
a reduction in flow rates from the aquifer. Monitoring boreholes in
both the upper and lower aquifer would be required.
PAGE: 66 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The resulting drawdown of at least the upper aquifer could Noted. Refer to the groundwater study. be mitigated by introducing water back into the aquifer. This assessment has not been done yet and could be difficult close to the SANParks border due to space limitations.
The site would contain waste rock dumps, discard dumps and Noted. Refer to the waste study. tailings backfill. It is known that the fresh water ecosystems are sensitive to salinity as well as nutrients. The geochemical leaching characteristics for the phosphate rock and discard have not been shown yet. A waste classification of the waste streams is recommended to confirm that no elements of concern would be released.
Dirk Roux : Freshwater Conservation Specialist, South African National Parks Notes on Freshwater Assessment Report for the Proposed Elandsfontein Phosphate Mine (June 2014), by Toni Belcher Emailed 24 July 2014
I found this report informative and of a high technical and editorial quality. The report aims to advise decision making regarding a classic conservation- development conflict: whether or how mining of the second biggest known phosphate resource in South Africa will impact on the ecological processes and integrity (specifically related to freshwater) associated with an adjacent National Park and other protected landscape features. Both of these land use activities (mining and conservation) offer value to society. The mine will deliver value for a period of 1.5 decades (according to my understanding of the report) and this value can be quantified in economic terms. A National Park offers services and value to people over a much longer time frame. However, the latter value is less tangible and more difficult to quantify. Tradeoffs in these situations are problematic because there is not a common currency to enable direct comparison.
Freshwater ecosystems
PAGE: 67 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The freshwater assessment presented in the above report incorporates important developments such as the Freshwater Ecosystem Priority Areas (FEPAs) of South Africa and draws on recent and sound classification and assessment methods. There are no river and wetland FEPAs in the study area. The Sout River is a Phase 2 FEPA meaning that this river would probably have been identified as a conservation priority if it was in a better ecological condition. Given its modified state and existing land use in the catchment, it is difficult to see significant restoration of this river’s ecological Noted. Refer to the groundwater study – Appendix C4 integrity taking place. No further degradation seems a more realistic objective. The report has largely convinced me that the proposed mining will not impact on any important freshwater conservation features, at least not via surface flows and contamination. Concerns remain regarding the link between groundwater and surface water (including the Langebaan Lagoon), the uncertainty associated with groundwater contamination, and the critical importance of groundwater contribution (quantity and quality) to the integrity and functioning of surface water ecosystems.
Monitoring and research Many impact studies conclude with a recommendation for monitoring. Noted. Refer to the EIA-EMP for the section on management and monitoring and However, such monitoring is rarely implemented in a truly beneficial way. I Environmental Management Programme in addition to the specialist studies. would strongly recommend creative thinking about a monitoring programme that will enable active learning and feedbacks to management on both the conservation and mining side. Surface and groundwater monitoring are the obvious issues related to the report. However, I am also thinking of broader conservation issues such as potential modifications to the soundscape (e.g. introduced noise from mining activities and additional traffic) and viewsheds (e.g. roads, pipelines, mine dump and dust) that can impact on the ‘meaningful nature experiences’ of people. I believe that both soundscapes and viewsheds are conservation features that should receive more attention in our parks. In addition to an active monitoring programme, I would also recommend formalizing a relationship with a research institution to enable action research (research that are influenced by, and can influence, actions) specifically designed to learn about having to achieve conservation objectives in a landscape of use. Research could cover technical aspects such as groundwater and surface water interactions but also social aspects such as societal value perceptions. Support for a few post-graduate students to enable such learning feedbacks seems like an intuitively desirable condition for developments such as these. PAGE: 68 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Finally On a philosophical note, two matters come to mind: Firstly, buffer zones are a legal mechanism that, as with National Noted. SANParks confirmed that the buffer zone has not yet been gazetted. Parks and other proclaimed protected areas, represents an expression of socio-political values. These zones are deemed
necessary for National Parks to achieve their objectives. To this
end a mining operation does not sound compatible with the rationale behind buffer zones. Secondly, Earth has a stock of approximately 1.4 billion cubic Noted. kilometers of water, all connected through various forms as part of one global hydrological cycle. Of this vast volume, about 97% is salt
water in oceans. Less than 3% of the total stock is in the form of
freshwater, of which the majority occurs in glaciers, permanent snow or in deep groundwater that is practically inaccessible to humans. Only about 0.008% of Earth’s water occurs in freshwater lakes, wetlands and rivers. The well-being of humanity is highly dependent on the quality and availability of, and the ecological processes and ecosystem services supported by, this tiny fraction
of water. Surely this freshwater fraction must be the most precious
natural resource on Earth. If so, then surely the ‘infrastructure’ (e.g. wetlands, riparian zones, river channels) that supports the provisions of this resource and its many ecosystem services should be maintained with great care. Unfortunately, freshwater-based ecological infrastructure has already deteriorated to critical levels, worldwide and in South Africa.
PAGE: 69 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
De Wet Steyn – Owners of farm Wolfiesfontein Emailed: 14 Sept 2014 The pipeline is no longer a considered an alternative in this application. Can you please tell me the route that the pipeline will follow from Vredenburg sewage farm and Elandsfontein? We own some property between Vredenburg and Elandsfontein.
Dr Graham Avery – Hon Research Associate, Iziko Museum and UCT Archaeology Dept Emailed: 14 Sept 2014 Noted. A Heritage Management Plan will be compiled to manage and implement Middle Pleistocene fossils from Elandsfontein on what is know as the monitoring methods which should be implemented during operations. Refer to Hopefield Fossil site, and adjacent farms, including Elandsfontein Wes, Appendix C1. have been recovered and published. This site is important and, in addition to the adverse fauna, has yielded the oldest Human remains in the Western Cape (400,000 to 700,000 years old). It is highly probable that fossil bearing sediments will be encountered during the proposed mining project(s). you will be aware of the provisions of the South African Heritage Resources Act. I have worked on the site and published results.
Carika van Zyl Emailed: 14 Sept 2014 Your objections are noted. I am an affected party to the mining operations and am opposed to this based on the following: Buffer Zone SanParks (Buffer Policy). Core area of the Cape West Coast Biosphere. Elandsfontein aquifer – high vulnerability and susceptibility to pollutants + anthropogenic impacts.. Critical Biodiversity Area. Informal Conservation Area Saldanha Bay Municipality. High Biodiversity Importance area – Mining + Biodiversity Guidelines. Threatened ecosystem. Climate change adaptive corridor. I have a Masters Degree in Nature Conservation so I am an expert.
PAGE: 70 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Keith Harrison – West Coast Bird Club Posted: 15 Sept 2014
4. Birds. I am pleased to see that the Bird Report now represents local species. The bird study has been expanded and management and mitigation measures will be Rodent Control, disturbance of the site will lead to an increase in rodent implemented. Refer to Appendix C6. populations, rather than use rodenticides for control, biological control
by providing nest boxes for Barn Owls and Rock Kestrels should be
considered (as some local farmers do.).
Lighting, because the Mine will be a '24 hour' operation, the site will Noted. This will be considered in the mitigation measures. require lighting and also for security. To reduce bird collisions all cables must be under ground. The beam of fixed lights should be directed downwards in order to reduce the attraction for insects and where possible security lights should be motion activated.
5. West Coast National Park. Although incorrect information had been received from DEA&DP to the environmental status of the mining area, the following should be taken into consideration. Quoting from the WCNP Environmental Plan.
The Management Focus has broadened to include the terrestrial surroundings as representative sites of the ecosystem of the West Coast National Park. The WCNP is a Ramsar Site for which the WCNP is the Managing Noted, the specialist studies make reference to gazette and non-gazetted/proclaimed Authority and therefore is responsible for what may enter the Ramsar environmental sensitive areas, CBA’s etc and consider these in the studies. Site through the air. over the land or through the earth. The Elandsfontein Aquifer provides fresh water that drains into the Lagoon.
3. Oshkosh BID Elandsfontein 349 Portion 6. What effect will open pit wet mining for commercial and silica sand This mine is located on the boundary of Farm 349/2 outside of the EEM Mine area and adjacent to Portion 2, have upon the water situation in the phosphates it is not expected to impact the operation. The groundwater study shows that water operation? from the EEM site flow in a north west direction. However this will be workshopped with Also the effect of an additional 160,000 tonnes a year to be transported the groundwater specialist. PAGE: 71 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
upon the haul road to the R45? The OSHKOSH application is for a permit which is valid for 2 years. However this will be considered in traffic report which will form part of the NEMA:EIA Process. 4. Traffic. All vehicles used by Elandsfontein Exploration and Mining (EEM), Noted. It is EEM’s intention to use local contractors. Contractors and Sub• contractors during both construction and production phases should be registered through the Saldanha Bay Municipality Traffic
Department to defray some of the cost for routine maintenance of the local
road infrastructure.
5. Employment opportunity. Noted. Once the skills audit is completed this will be done. The labour required for both construction and production phases should be detailed into:• Highly Skilled (Supervision and Engineers). Skilled (Drivers and Machine Operators). Semi-skilled/ Un-skilled (Labourers) To be recruited from people with at least 5 years proven residence in the Saldanha Bay Municipality, preferably from Hopefield and Green Village (an ex-mining community). Highly Skilled and Technical personnel would be expected to come from outside the area.
Skilled 80% locally recruited. Semi-skilled/un-skilled 95% locally recruited. (This ratio is being set by another development within the SBM area.)
6. Fossils. The Fossil Area and finds should be concentrated within the new Education Noted. Centre being developed in the West Coast Fossil Park, in order that visitors, educators and researchers can have access to the total Paleontological History of the West Coast in one site.
PAGE: 72 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Mr Ernst & Salome Scullard Emailed: Sept 2014 Noted, you have been registered on the project database. We are the owners of Savico Game Lodge and would like info on the project and most of all the road that EEM plants to build right next to our property.
We have questions and concerns that we would like to address and be clear on also the finale decisions made where it does concern us.
Please be so kind as to register us both Ernest and Salome Scullard c/o Savico and keep us updated and informed of all meetings and developments.
We need info on the road and use thereof also intended traffic and noise The traffic and noise report has been sent to you. levels.
DMR Comments Emailed: 14 Sept 2014 The Department consulted the EIA/EMP reports with other Government The final comments have been included in the updated consultation report appended Departments in terms of section 40 of the Mineral and Petroleum to the EMPR. All comments received after 15 September will be collated at the end Resources Development Act, 2002 (Act No.28 of 2002) and requested of the 30 day comment period and submitted to DMR. these organs of state to provide comment. Please make sure that you have considered, addressed and incorporated these comments and those received in the Scoping process and in the final EIA and EMP:
• The Department of Water Affairs. · • The Department Environmental Affairs and Development Planning. • Cape Nature. • National Parks Board. • Heritage Western Cape. • Local Authority. The final EIA/EMP reports must include only the comments/ objections and The EIA-EMP and appendices have been updated and includes all comments and your responses, allow I&APs to comment on the EIA-EMP document before objections received to date. it is submitted to this office.
PAGE: 73 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
All parties directly affected by the access road(s), and power lines must be Refer to Appendix B6 for the signed consultation proof of all affected landowners identified and their names, contact numbers, property names given over which infrastructure will be located, as well as the cadastral map in the EIA- separately and indicated on a map. EMP. Consult the appropriate roads authority regarding access and haul- road The Provincial Roads and District Roads Engineer were consulted regarding the alternatives and submit the designs for the upgraded access roads road infrastructure. Refer to Appendix B5 and the Traffic Impact Assessment. alternatives. Consult with DWA and submit proof that your application for a water use In terms of the Standard Operating Procedure between government departments the licence for dewatering, and release of water as well as for the water loss WULA has been initiated with DWA with a request for a formal pre-application due to evaporation from the proposed slimes dam and end-land-state (if consultation. For further understanding regarding this SOP refer to the DEA&DP final mining levels will leave groundwater exposed). Submit proof that such Acknowledgement of Receipt of the EIA Applications in Appendix D. application was accepted by DWA and include the information required by DWA to allow such decision or proof of the approval of such water uses and final state of the land. The report must provide the specific "prospecting information" that indicates Refer to the Geological Report – Appendix G and Project description in the EIA- the depth and properties of the soil, overburden and ore layers for all the EMP. holes (30 holes plus others). The grades of the product and depths of the ore that will be mined at each prospecting site must be provided. Specific and detailed prospecting information is vital to plan the mine in order to determine, predict and assess impacts, to enable input, to do a cost benefit analysis and to assess alternatives. A report with the required information, compiled by a geologist, must be submitted and used to plan the plant and compile the mine plans. Explain the areas included in the proposed mine area where no prospecting Refer to the Geological Report – Appendix G and Project description in the EIA- was done. EMP. The project description and alternatives in the report are not sufficient to (i) Refer to Section 5 of the EIA-EMP. list or prioritise possible impacts (ii) avoid or minimise impacts or (iii) to make informed consultation comment possible. The project description, alternatives considered, resource requirements and releases into the environment must be made clear and without ambiguity.
The closure objectives. Refer to Section 9.6 of the EIA-EMP and Appendix C12 for the Rehabilitation Plan. The depth of topsoil/subsoil, overburden and of the minable material to be Refer to the Geological Report and EIA-EMP Project Description. mined must be provided for all drill holes (discrepancies in the data provided for depth to be mined and depth of phosphate indicated was found).
PAGE: 74 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The size, shape (depth and slopes) and location or the excavation must be Refer to Appendix E and G and EIA-EMP Project Description. based on prospecting information per prospecting holes and mining methods to be used. The size, location, slope and height of the topsoil/subsoil and overburden Refer to the Geological Report and EIA-EMP Project Description. dump must be given and based on information of the prospecting results and on the proposed backfilling. The buffer zones along the WCNP boundary must be made clear. Refer to Section 4 of the EIA-EMP and Appendix A.
The report must indicate the alignment of all access roads as well as the Refer to Appendix A and Appendix C8. proposed design thereof. Make a commitment to close all access roads but the selected access road and indicate the roads to be closed on the map. The report must further indicate all haul roads, conveyers, power lines, and Refer to Appendix A. rail or pipelines routes and give details of the design thereof. Provide details regarding the volume and weight of traffic out of and onto Refer to Appendix C8. the site. The specific size, location, slope and height of the slimes dam must be Refer to Section 4 and Appendix A. determined based on the volume of the slimes that will be produced based on the process, the prospecting information and backfilling (backfill as soon as possible or use excavation). The volume of water to be used by the plant, people and dust suppression Refer to Section 4 of the EIA-EMP. and the proposed source thereof.
The chemical content, concentration and volume of all Refer to Section 4 of the EIA-EMP and Appendix C11. chemicals/substances used in the process as well as flotation must be provided. Details regarding the volume and type and concentration of each chemical Refer to Section 4 of the EIA-EMP and Appendix C11. used and released in the environment by all the different processes in the plant and include an opinion of a specialist with regards to the appropriate handling thereof. The volume and quality of water that will be released into the environment. Refer to Section 4 of the EIA-EMP.
PAGE: 75 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The electricity demand of the total project. Refer to Section 4 of the EIA-EMP.
The volume and method of fuel storage must be explained and the Refer to Section 4 of the EIA-EMP. proposed location/s indicated. Indicate all offices, other infrastructure required and if any housing will be Refer to Appendix A. provided on the site. A map/plan of a suitable scale must be included to indicate such infrastructure. The design of a sewage plant with a capacity for the total number staff Refer to Section 4 of the EIA-EMP. members for (i) the construction period and (ii) operational period (as per the number of people to be employed) must be given. The predicted volume and concentration of N and P in the effluent from the plant must be given. The map of the layout plan of the mine must be at a scale of at least 1:5 Refer to Appendix A. 000. The maps included in the report must be drawn up by a surveyor and with a scale suitable to describe the impacts. · It must Indicate the depth (of mining and final depth), phases, slope and depth of the excavation, dumps
and all infrastructure to be used to describe the mining phases. Define impacts and explain proposed mitigation measures and allow the monitoring of compliance. The phases must explain backfilling by waste- rock and slimes and topsoil replacement. Describe and weigh up alternatives and please ensure that the relevant Refer to Section 5 of the EIA-EMP. specialist studies cover the areas under consideration as well. The revised final report must provide all the relevant information that allows the comparative investigation and assessment of project alternatives (site, size, design, location, access, transport, rate of mining, technology and No-Go option) as required in terms of IEM and Reg. 49 1 (d) of the MPRDA.
Please note that the four "land use alternatives" mentioned but not considered in the report are all No-go alternatives. A No-go alternative (only one) is a requirement of the MPRDA and is used as a baseline and leaving the resource intact for the time being. The No-Go option being the current land use of conservation of biodiversity and tourism of the farm and surrounding farms as well as safeguarding water catchment for Elandsfontein aquifer. Include alternatives for:(i) underground mining as option for the western area (ii) placing of the tailings dump and topsoil / subsoil and waste rock dumps, plant, workshops, storage and salvage yard, offices and processing or (iii) portions thereof, offsite or inside of the PAGE: 76 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
excavation area (iii) the rate of mining (either at a fast rate in order to export or slower rates in order to satisfy local phosphate requirements) and (iv) access road and hauling including using a pipeline (v) reducing the mine excavation area where sensitive areas overlap lower grades or areas costly to mine and (vi) mine plan in phases to allow backfilling with waste rock and slimes, shaping, replacement of soil and rehabilitation immediately.
Public Consultation. Please note that notification that a revised document Refer to Appendix B – Comments and Responses Report and Comment Received. was placed at particular spots is not regarded as sufficient for affected landowners, the WCNP and objectors. Consult the proposed project details of the disturbance, infrastructure and operations of all alternatives considered (site, size, access, traffic volumes, etc.) with all I&AP's. The impact of both the construction and operational phases of the project must be consulted.
The buffer between the National Park and the mine is not explained and the map does not allow an understanding thereof. Consult all landowners and people affected by the preferred access road, the haulroad and/or conveyer and/or pipeline and the powerline and submit proof thereof. Submit proof of only this final/additional consultation in the revised report. The geohydrological study must make use and give data of all the drilled Refer to Appendix C4. The study did consider the geochemistry of the ore holes available and determine the groundwater elevation map at this time overburden and tailings. (winter time) as well as the determine dewatering and infiltration as mentioned In its conclusion. The report must investigate the effect of (i} dewatering and mining activity at this particular site (ii) possible long-term evaporation and (iii) water use and loss, (iv) other current and future users of the aquifer (v) groundwater movement and rate of movement (vi) possible impact on the Langebaan Lagoon and (vii) baseline studies that
allow measuring deviations from it.
The hydrological study must also (viii) take into account the geochemistry of the ore overburden, slims in the slimes dam and the predicted releases to the environment. This impact must be based on an understanding of the actual complexity and properties of the geological layers, groundwater flow and the interaction between surface and groundwater in the area.
PAGE: 77 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Set clear and specific standards for the salinity, chemistry and turbidity of the groundwater and an appropriate monitoring programme must be proposed of surrounding boreholes and sample sites as well as predict the impact of domestic and plant waste water on the water resource.
The botanical specialist must (i) include all disturbances, (ii} make use of Refer to Appendix C2 and C12. studies that was done in the area, (iii) do collections in winter rainfall season. The study must include (i) a baseline study that describes the plant communities/unites of each vegetation type and provide a comprehensive inventory of all species present in each unite (li} survey to find possible red listed plant species and determine their distribution (iii) the conservation status of the area (iv) focus on corridors, habitat fragmentation, and size as contributing to the conservation value of the National Park (together with
faunal specialist) (v) the condition/state of the vegetation (vi) include a phased rehabilitation plan for the mine with clear time frames and targets and then (vii) consider the impact on vegetation and (viii) taking into account the natural rate of recovery. The specialist must also include a (ix) fire and alien invasive plant management plan and (x) advise on slopes and topsoil use and the future state of the rehabilitation that can/should be achieved (target) and must described and how to achieve this.
The fauna specialist study must (i) focus (Include an Intensive on site Refer to Appendix C6 and C9. Investigation) on the reptiles and small mammals as well as (ii} address corridors, habitat fragmentation (with
special reference to risks of the access and other roads) and size as contributing to the conservation value of the National Park (together with flora specialist). Undertake a Heritage Impact and Paleontology Impact assessment as Refer to Appendix C1. required by the National Heritage Resources Act (25 of 1999) and advised by the letter by Heritage dated 27 February 2014. A heritage study must cover the proposed mining activity and disturbance of all associated
activities. Heritage study must make use of the logs of all the drill sites (this was a requirement by Heritage) and investigate/predict the probability of finding fossil rich layers profile in the area to be mined and explain/give recommendations how it should be address in operations
PAGE: 78 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
A traffic impact assessment must be done on the preferred alternative Refer to Appendix C8. (transport of the 300- 400 staff members as well as the more than 5 000 000 ton I annum of ore) along the road or conveyor is required. Consult the state, maintenance and safety along the access road up to the main road
with the relevant roads authority (District Road Engineer or PAWC: Department of Transport). The Traffic assessment must include access and haulage and consider different feasible traffic alternative courses and include a train link to Langebaanweg Noise and dust studies must measure the base line sate, predict impact Refer to Appendix C7. based on all the proposed activities and recommend specific targets that
can be achieve and shall be committed to.
Visual assessment based on the actual project specifications and the Refer to Appendix C3. access alternatives and it must include light.
Cost Benefit analysis must include possible conflict of tourism and mining This has largely been dealt with in the overall EIA-EMP and specialist studies. activities, address the short life of mine (compare benefits to longer live supplying local demand as well), exporting such phosphate instead of supplying local demand, ground water and its use, impact on infrastructure,
risks, effect of the mine on future development plans and potential of the WC National Park and the cost of others possible impacts. The water and electricity demand of the project must be considered against the total current use and possible alternative users. Social-economic study must be done with sustainability as an underlying Refer to Appendix C10 principal and inform on the social impact of the short life of mine (closing down in 20 years) as well as propose measures to address this, and propose an exit strategy and consider and advise on alternatives to make optimum use of such resource. Integrate the input of the consultation process and the findings and Refer to Section 9 of the EIA-EMP. recommendations of the specialist studies. The mitigation measures in impact assessment and risk ratings under point 9 in the report and EMP under point 10 in the report as well as Monitoring plan in point 11 Awareness plan under point 15 is given without these specialist reports
being finalized. These points must be revised and contain specific standards/targets and measures to achieve them. In addition the measures to achieve set targets must be clearly explained and refer to maps that clearly delineate areas that will or will not be impacted and show the phases of the activity. PAGE: 79 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The EMP must include (based on recommendations of the specialist Refer to Section 4 of the EIA-EMP. studies) amongst others the following: Dewatering plan. A storm water management plan as well as a detailed water quality Refer to Section 4 of the EIA-EMP. management and monitoring plan. A detailed water supply and sewage disposal management plan with Refer to Section 4 of the EIA-EMP. specific targets.
A vegetation management plan for areas not intended for mining. Refer to Section 9 and Appendix C12. A phased rehabilitation plan (at least 300mm of top/sub soil must be Refer to Section 9 and Appendix C12. removed for replacement during rehabilitation).
An alien invasive plant control plan. Refer to Section 9 and Appendix C12.
Heritage management plan. Refer to Section 9 and Appendix C1. A noise and dust management plan that sets clear and specific standards Refer to Section 9 and Appendix C7. for noise, dust, and visual levels and commit to monitor these levels.
The mine plans in the EMP must be drawn up by a qualified surveyor and Refer to Appendix 1. must be based on the prospecting information. The maps and information provided in the report must be of a suitable scale (at least 1:5000 with elevation lines) to (i) describe the activity I define the impact(s) (ii) to make an assessment of the impacts impossible to, (iii) describe the mining phases and backfilling and soil replacement in detail and (iv) explain the proposed mitigation measures and (v) monitor compliance. The document must contain mine plans of the proposed mining area and associated infrastructure that are of a sufficient scale to be used for planning and monitoring of the activities at the mine. All infrastructures (offices, parking, fuel storage, conveyers, sewage plant, power lines, and/ or pipelines routes and give details of the design thereon. The position and design of the access road/s must be clearly provided. The location, size, depth and slopes of the excavation. The position, size, height and slope of all the topsoil/subsoil dumps. The position, size, height and slope of the overburden dumps and
PAGE: 80 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
explain the proposed backfilling to avoid impact and reduce cost. A phased mine and rehabilitation plan that indicates the different phases of mining activities, backfilling and based on the actual figures and at the minimum size possible. The slimes dam must be designed to optimise concurrent rehabilitation and limit its size to the minimum. Explain when the slimes can be located in the excavation and how backfilling will be done. The buffer zones along the WCNP boundary and all other no-go areas must be made clear. Clearly delineate the no-go areas along the boundaries for each activity to Refer to Appendix 1 and Maps in EIA-EMP indicating sensitive habitats. limit the impact and indicate the roads (access and other) that you intend to
use or commit to close.
The quantum for financial provision for remediation and rehabilitation must Refer to Appendix C12 and Section 11. be calculated on all proposed disturbances.
The applicant must sign the undertaking in the EIA/EMP and layout plans to Refer to Section 12. comply with the provisions of the Act and regulations. The applicant must commit to monitoring of all main risks and impacts that Refer to Section 9 can be mitigated and Indicate the standards, methods and timeframes when monitoring and performance assessment of the EMP will be done. The EMP should provide a layout and a description of such a monitoring and performance assessment report. The applicant must include an environmental awareness programme in Refer to Section 9 terms of section 39(3)(c) of the Act. Inter alia, the awareness programme should inform and sensitise the personnel regarding all main Impacts that can be mitigated of environmental management programme and the main possible environmental risk involved (for example, groundwater loss, creeping of activities, topsoil not removed, topsoil loss or mix, heritage, rehabilitation success. traffic, oil pollution,). The applicant must include the procedures that relate to emergencies and Refer to Section 9 the proposed remediation thereto, for example, discuss the contingency plans with respect to accidental spills and management of hazardous material such as oil, diesel, etc. in the proposed mining area.
PAGE: 81 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
The applicant must clearly state its closure objectives at his point. Refer to Section 9 and Appendix C12. The applicant should indicate what process would be followed to reach these objectives. Risk factors that should be considered are exposure and disturbance of groundwater flow, the Langebaan lagoon functioning, soil/topsoil use (quantity and quality), rehabilitation success, alien invader plants and other aspects raised by scoping and the EIA. The applicant should indicate whether this operation would require an Refer to Section 2. authorisation from any other organ of state or local authority and if so, submit proof that such an application was lodged. All the above must be addressed and a revised EIA/EMP report compiled Noted and done. that must be consulted and 2 copies of a final report submitted to this office on or before 16 September 2014. During the EIA/EMP development phase of the application, I&APs and relevant authorities must be consulted before the final EIA/EMP is submitted. Attempt to resolve possible concerns I objections with the relevant affected parties and provide proof of an agreement that objections and concerns have been resolved and/or incorporated in the EIA/EMP. Include in the final EIA/EMP only the "results" of further consultation of the EIAIEMP (i.e. written agreement /solved disagreements /deliberated disagreements) with the affected parties to this office on or before the final EIA/EMP is submitted.
Mr Ernst Baard: Executive Director, Biodiversity Support Emailed: 31 July 2014 Noted. CapeNature would like to thank you for the opportunity to comment on the Environmental Management Programme. We would like to note upfront that the applicant and consultant have not been able to adequately address all the comments and concerns put forward on the Scoping Report and revised Seeping Report. We also note that the consultant has
acknowledged this and plans to submit a revised Environmental Management Programme with more information. Ideally, the applicant should have applied for authorisation in terms of NEMA before applying for the mining right as the application process in terms of NEMA allows for longer time frames between submission of documents as well as a more comprehensive public participation process (note that we have only
PAGE: 82 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
received notification of the EMPr through DMR and not through the consultant despite being registered as commenting authorities). Note also that CapeNature was not informed of the availability of the LUPO application for departure and therefore did not have an opportunity to submit comments to the municipality.
Note that this application qualifies under high to very high public sensitivity Refer to Section 2 for the legal requirements and activities undertaken to date for the and requires maximum opportunity for I&APs to be informed, view project, including the outline of public participation in this comments and responses documents and provide comment via the right channels. Sufficient time also report.
needs to be provided between application phases so that comments and
concerns from the public and organs of state can be addressed.
Although our previous comments have now been placed in a comments Noted. Responses do make reference to the specific specialist studies which were and response table, most of the comments are responded to as merely undertaken to assess potential impacts. "noted". This is not adequate, responses should be detailed and indicate where in the report or specialist studies concerns have been (or will be) addressed. If concerns cannot be addressed this should also be clearly explained and motivated.
Thus, most of our previous comments in our letters dated 18 February 2014 and 26 May 2014 remain applicable. However, we do note the Noted. inclusion of better maps and that it is currently no longer the applications intention to use the inland port site. All of the following comments must be considered in conjunction with our previous comments.
Importance of Critical Biodiversity Areas and other conservation planning on the si te:
1. Please refer to our comments on the Seeping Report with regards to the application of best available science. Please also refer to the attached Noted. letter from DEA&DP which endorses the use of Critical Biodiversity Areas as best available science in decision-making. Critical Biodiversity Areas have also been supported and taken up by many municipalities throughout the Western Cape, including Saldanha Bay, through using them to inform SDFs and EMFs for the municipality and region.
PAGE: 83 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
2. Unfortunately, no other CBA within the Saldanha region is as pristine or Your comment is noted. Refer to the Botanical Report (Appendix C2) for more as well connected as the one that the mining area will impact on. Other information. CBAs have already been impacted on within the IDZ and on the Saldanha peninsula. If this CBA is irreversibly transformed it is likely that conservation targets will not be met for pattern or process in this region.
3. The site falls within the buffer zone of the West Coast National Park. Noted. Refer to SANParks letter dated 10 September 2014 indicating that the Buffer Buffer zones are essential for SANParks to achieve their national Zones have not been declared (attached to the Comments and Responses Report). objectives which includes protection of biodiversity and ecosystem services, probably the most important of which is provision of clean water. The area in which the proposed mining is to take place has been considered vital to the park's expansion strategy since before the current landowners purchased the land and applicants/landowners were aware that the site is of high conservation
value before they purchased it.
Layouts and road network:
4. Roads and powerline routes still require finalization. In addition more A Traffic Impact Assessment was undertaken refer to Appendix C8 for more detail information is required on the type of upgrades and widening of roads regarding roads. The powerline has been explained in Section 4 of the EIA-EMP and that will be required to accommodate large trucks and heavy machinery. it’s position indicated on the maps in Appendix 1. The specialist studies assessed the Even if the powerline will be authorized as part of a separate EIA the powerline as part of their studies as well. proposed footprint must still be clarified as part of this application process.
Air pollution:
An Air Quality Assessment was undertaken refer to Appendix C7. The material will be 5. In addition to assessment of potential air pollution from the mine site, risk transported in sealed skip tainers to the Port, also the material will have a moisture of pollution from wind-blown pollutants during transport and storage content of 8-10%. Refer to the EIA-EMPR Section 4 for more detail. needs quantification.
Impacts on Groundwater:
6. The geohydrological report in the EMPr is the same as that provided in Refer to Appendix C4 for the updated geohydrological study. Section 4.9.2.6 of the the revised Scoping Report and did not form part of the first Scoping EIA-EMPR provides examples of mines with similar pit dewatering methods. Report. Information in the main report refers to various proposals to PAGE: 84 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
ensure that the aquifer does not become contaminated or that significant draw down of water levels occurs. However, the contamination risk from all potential sources has n·ot been quantified. Monitoring is proposed but the report does not state what remediation will be taken if contamination is detected. The applicant/consultant also needs to provide examples of where similar technology they propose to use has been used successfully elsewhere. Elandsfontein has a high groundwater sensitivity (which is linked to at least one important surface water feature) and overall the site is of high conservation importance and should not be used as a test site for unproven technology. Rehabilitation:
7. More detail with regard to rehabilitation and end-use of the site is Refer to Appendix C12 for the rehabilitation plan. The project infrastructure has been required. Certain aspects of the development including buildings and updated and no longer contains a slimes dam. Tailings will be co-disposed with slimes dams are likely to be permanent features after mining is overburden which after 33 months (reaching a steady state) will be backfilled into the completed. pit as part of the rehabilitation. The geochem results are addressed in the Waste management plan – Appendix C11. 8. We note that it is proposed to commence rehabilitation within 4 years after mining has commenced. Many plant species' seed banks do not Noted. Refer to the botanical and rehabilitation studies (Appendix C2 and C12). remain viable within the topsoil for such a long time period. In addition, disturbed areas and stockpiled topsoil is prone to invasion by alien plants and pioneer species.
Conclusion:
CapeNature is expecting an opportunity to comment on the revised Noted. CapeNature as a registered I&AP was informed of the release and availability of the updated EIA-EMPR and where it can be accessed (www.braafsa.com) as well as EMPr. Currently, sufficient baseline information as well as proof that the relevant comment period. An electronic copy of the report can be provided to the impacts of this application will not result in irreversible loss or CapeNature upon request. damage to biodiversity including ecosystem services has not been
provided and CapeNature's objections remain in place at this stage.
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received.
PAGE: 85 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Department of Water Affairs: Chief Director – Melissa Litnaar-Strauss Emailed: 18 June 2014
1 The Department objects to the proposed mining right application in the Noted. The geohydrological study has been updated to include additional boreholes for current format. The Department has found the information in the Revised monitoring use (refer to Appendix C4). Additional studies are currently underway Scoping Report insufficient. The Department requests that a Groundwater (numerical modelliing – hydrocensus etc). The results of the additional studies will be Study be conducted which must address the following issues: included in the Water Use License Application to DWA. Monitoring boreholes in both upper and lower aquifer that would form the backbone of a monitoring network to get a baseline for the current situation before any additional activities takes place. The monitoring programme should commence as soon as possible in order to provide the necessary data to provide information on the important decisions to be made. Data from the monitoring programme must be stored in a safe place and be available to the The data will be available to DWA on request. Department on request.
The following information from the monitoring programme should be included Refer to Appendix C4 for more detail. in the groundwater specialist study report: o Details of boreholes -location, construction, lithology, etc. o Waterlevels o Water chemistry o Any other additional information that may aid in the decision making process 2 Pump tests, done on the proposed pump test boreholes to be drilled. The Pump tests were done as part of the updated Geohydrological Study. Refer to Appendix effect of this should be monitored in the monitoring boreholes in both upper C4 for more detail. and lower aquifer to determine: o lnterconnectivity between the upper and lower aquifer units, o Extent of cone of depression o Aquifer characteristics o Details of pump test. 3. Boreholes for dewatering Refer to Appendix C4 for more detail. Additional studies are currently underway Proposed location (numerical modelliing – hydrocensus etc). The results of the additional studies will be Construction details included in the Water Use License Application to DWA. Volumes to be pumped Additional information that may be needed 4. Artificial recharge Refer to Appendix C4 for more detail. Permeability tests were undertaken to determine
PAGE: 86 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Proposed location infiltration. The data can be made available on request. Additional studies are underway. Infiltration data that will give an indication of the feasibility of using artificial recharge to return the abstracted water to the aquifer. o lnfiltrometer tests o Transmisivity as measured from samples Construction details Additional information 5. Water balance on the volumes of water to be used on site, including: Refer to Section 4 of the EIA-EMPR for the water balance details. Potable use Mining operations Sanitation needs/sewage treatment 6. Storm water handling procedures Refer to Section 4 of the EIA-EMPR for the stormwater management details. 7. Handling of waste and other activities that may have an impact on water Refer to Section 4 of the EIA-EMPR for the details on waste management and Appendix resources C11 for the Waste Management Report. Domestic waste Hazardous waste Slimes dam and spoil areas 8. Hydrocensus - 2km radius from the outer perimeter of the mining area A hydrocensus will be undertaken as part of the geohydrological study which will form Location of boreholes, dug wells, springs, etc. part of the Water Use License Application – the scope of the current study has been Depth, diameter, waterlevel, type of equipment expanded to include this. Yield Chemistry o Field readings- EC, pH, Temperature, redox potential o Samples to be sent to SANAS accredited laboratory for chemical analysis-metals, anions, cations, stable isotopes Use and approximate volumes abstracted Details of owners Any other relevant information 9. Additional information as set out in terms for reference for specialist studies Noted. Groundwater dependent ecosystems should also be taken into consideration
PAGE: 87 PROJECT NUMBER: 10043
REPORT NUMBER: 10043CRR DATE:15/09/2014
Appendix: Comments
Tel: 021 949-6414 Fax: 021 949-6416 E-mail: [email protected] PO Box 440 SANLAMHOF 7532
28 February 2014
Mineral Regulation and Administration Western Cape Private Bag X9 Rogge Bay 8012
Attention: Mr Jan Briers
Re: Application for a mining right on a portion of 2 and portion 4 of the Farm Elandsfontein No. 349, Malmesbury RD – Scoping Report. DMR Ref No: W30/5/1/2/2/10043
Thank you for the opportunity to comment on the Scoping Report.
The West Coast National Park (WCNP) was initially proclaimed in 1985 as the Langebaan National Park (Proclamation 138 in GG 9904 of 30 August 1985), with the name later being changed to the West Coast National Park (GN 1135 in GG 10789 of 26 June 1987).
Page 2 of 5
The West Coast National Park is situated approximately 100km northwest of Cape Town, on the Atlantic seaboard in the Western Cape Province. The park covers some 35,700 hectares from Yzerfontein in the south, to Langebaan in the north and from the Atlantic Ocean in the west, (approximately 30 km of coastline), across the West Coast road (R27) towards Hopefield in the east.
Please note the following: a) SANParks’ legal mandate is to protect, control and manage National Parks and other defined protected areas and their biological diversity, (NEM:PAA 57 of 2003); b) SANParks manage WCNP in terms of a management plan, approved by the National Minister of Environment and Water Affairs, on 05-09- 2013. In terms of the approved management plan, the proposed mining area falls within WCNP core expansion and buffer areas;
Biodiversity and Ecology (c) The area contains endangered vegetation types – the site is also listed by SANBI and Saldanha Bay Municipality’ SDF as a Critical Biodiversity Area or (CBA); (d) The Site is therefore of very high biodiversity value, including two very important aquifers; SANParks is therefore concerned about possible groundwater contamination: SANParks is concerned regarding possible negative impacts on the Langebaan Lagoon, an international Ramsar site, which is administered by the West Coast National Park; Severe harm could be done to the Park and the Lagoon through pollution of groundwater; SANParks, therefore encourage the applicant to do a thorough hydrological assessment of all possible impacts of underground water pollution, including possible impacts of the Langebaan lagoon. Page 3 of 5
(e) The impact of dust, noise generation, spread of alien species, loss of threatened species and habitats, possible decrease in natural beauty and aesthetics of the area should also be investigated. (f) These impacts may also be felt by the fishing and agricultural industries and the knock-on effects of impacts to the park and lagoon will significantly impact on the tourism industry of the area and many livelihoods.
We therefore encourage the applicant to review similar cases where severe environmental damage has resulted from phosphate mining, and to learn from the mistakes made. We would like to request that SANParks have input into the terms of reference that are drawn up for each of the impact studies that are to be conducted.
In particular (and identified in the scoping report in some instances), we believe that the following additional studies are required: Baseline water quality studies in Langebaan Lagoon; Ecological baseline studies in the Sout- and Groen Rivers; Assessment of dust impact (including impact on plants, pollinators and other animals); A full scale vegetation survey considering plant species of special concern – carried out and monitored in the appropriate seasons (this would require winter and spring assessments); Noise assessment (including impact on animals); Light pollution assessment (including impact on animals); A full scale hydrological impact assessment including assessment of the impacts of polluted water on the park, local communities, farmers and tourism; An socio-economic cost benefit assessment; A more thorough assessment of reptile and amphibian species; A detailed rehabilitation/mitigation/reclamation plan
Page 4 of 5
Buffer Zone policy (Government Gazette, dated 8 Feb 2012, Notice no. 35020) As mentioned earlier in this report, the remainder of the proposed mining area falls within the expansion footprint and buffer zone of the West Coast National Park.
The purpose of a National Park buffer Zone is to: Protect the purpose and values of a national park, which is explicitly defined in the management plan, submitted in terms of sec 39(2) of the NEM:PAA; Goal 3 of the strategy reads as follow: ‘Discourage development in areas in which biodiversity and ecological function would be adversely affected. …all development in the buffer zone which may have a negative impact on the national park will be strictly controlled. The Buffer zone policy explicitly defines mining as “… development which may have a negative impact or effect on a national park…”
Mining and Biodiversity Guideline, 2013 The Mining and Biodiversity guidelines rate the proposed mining area as Category B, – highest risk for mining; extreme caution should therefore be exercised in all proposed mining activities - due to the very sensitive nature of the area, which: falls in a critical biodiversity area (CBA); Is adjacent to a national park, (in buffer the buffer zone of WCNP); Is located on two aquifers, (Elandsfonten – and Langebaanweg Aquifers); In a key climate and ecological corridor The guidelines further states that environmental authorisation may or may not be granted and that biodiversity offsets should be considered; however, strict limitation should be set and must be written into authorisations. SANParks fully supports the provisions and guidelines of the 2013 Mining and Biodiversity guidelines.
Page 5 of 5
Cape Research Centre (CRC) Attached herewith, please note additional and detailed comments relating to the Scoping report – report compiled by a team of SANParks scientists at CRC.
Please also note that SANParks - a key stakeholder in this mining application – did not receive the Scoping Report, as officially distributed by your department; no annexures were attached to the scoping report which was reviewed by CRC. We request that this oversight urgently be attended to. We request that all correspondence and reports regarding this mining application should be addressed to: Willem Louw PO Box 440 SANLAMHOF 7532
SANParks therefore reserves the right to revise initial comments based on additional information that may be received.
Yours faithfully
______Willem Louw Manager: Conservation Planning Conservation Services South African National Parks (SANParks)
COMMENTS ON THE ENVIRONMENTAL SCOPING REPORT FOR ELANDSFONTEIN EXPLORATION AND MINING
PERSONAL INFORMATION Name: Report compiled by Nicola van Wilgen on behalf of the SANParks Cape Research Centre (CRC) Comments received from Ruth-Mary Fisher, Carly Cowell, Trevor Adams, Debbi Winterton, Zishan Ebrahim, Mbulelo Dopolo, Mmoto Masubelele and Wendy Annecke Stakeholder Group / SANParks Organisation: Date: February 2014 Email: [email protected] GENERAL COMMENTS
General comments
Overall we found the report lacking in the detail required to determine the scope of potential positive and negative impacts of the proposed mining activities. Given the sensitive location of the area (threatened vegetation types, underground aquifer, location in the buffer zone of a national park), we feel that a much more comprehensive and rigorous assessment, with better attention to detail, is required to highlight the full scope of potential impacts that this proposal encompasses. There were a number of minor mistakes and inconsistencies throughout the report, which we have listed in the sectional comments below. Though most were not particularly serious, they do raise questions about the rigour of the work done.
There are three priority areas which require urgent attention: 1) the wider impact of the mine on the ecosystem and particularly water, and 2) the socio-economic impact of mining activities and 3) the absence of a detailed rehabilitation/mitigation/reclamation plan. Several other issues are also raised.
1. Wider impact and water
Firstly, although several negative impacts of the proposed mining activities have been cited in the report, no reference is made to how these impacts will be experienced away from the mining site itself. The potential impact on groundwater is likely to be the most serious oversight in this regard. It appears that there has been no groundwater study conducted. The conservation importance of the Langebaan Lagoon is given on pg 23, but we need to know how the mining will impact on the freshwater and groundwater supplies to the Lagoon. This lagoon is a RAMSAR site, i.e. a wetland of international importance and a marine protected area which forms part of a national park. The lagoon also constitutes about 20% of South Africa’s total saltmarsh/eel grass populations (Zostera capensis) and potential reductions in water quality through seepage into the lagoon will negatively impact on these important beds. Furthermore, the lagoon provides an important source of income for local fishermen and is a very important tourist attraction for the region. Yet none of these issues are discussed in report. There is some mention of studies underway, but these are dealt with superficially and none of the detail expected in a report of this nature is evident. A more focussed and detailed study of the impact of the mining activities on groundwater is imperative. Any contamination of this important water source will also impact people and the farmers who use this water for their household and agricultural purposes. This along with the potential negative impact on the tourism industry means that the impact of less or contaminated water will be felt across all socio-economic and environmental sectors.
2. Socio-economic impact The second priority requirement is an assessment of the socio-economic impacts of the proposed mining. The report mentions benefits in terms of jobs to local people, but in section three it becomes clear that these jobs will not be sustainable in the long term. No exit strategy or re-skilling is provided for. It is simply stated that the jobs will end, meaning that local benefits may be few. There is the likelihood that many of the beneficiaries, especially the skilled labour will not be local and that there will be an influx of people from other areas who will compete with locals for these jobs. Housing, transport and amenities for labour are not dealt with in any detail in the report. In addition, it is likely 2 that crime, loitering and other social ills will increase (section 3) while the environment will be damaged, possibly decreasing future opportunities for people as well as causing noise, pollution and unsightliness during the operational phase. These latter factors are all likely to be detrimental to the tourism industry which is one of the areas’ primary current industries and economic drivers. Pollution, unsightliness (negative aesthetics) and labour disputes could drive down tourism and cost significant numbers of associated jobs. It is therefore highly questionable that the socio-economic conditions of local people will be benefited by the proposed mining in the short, medium and long term, but they could be worsened.
It would be useful if subsequent reports provided information regarding the extent of the economic contribution from mining compared to existing contributions from conservation, tourism, agriculture and fishing which are currently substantial and come at a much lower risks to the people and the environment. Generally mines tend to enrich the owners of the companies whereas the municipalities where mining occurs receive minimal benefits. The short term nature of the jobs which may displace long-term agricultural and ranching jobs must be clarified.
3. Rehabilitation plan No clear rehabilitation plan was detailed in the scoping report. It is appreciated that the land under mining cannot be fully restored, but should mining proceed, reclamation of the landscape is critical. The best possible restoration will rely on implementation of mitigation measures throughout all phases of setting up, operation and. decommissioning. Detailed plans at each of these phases are required. Adequate land reclamation must consider relevant conservation goals, especially due to proximity of the mine to the park, game ranching ventures and other important conservation-dependent tourist attractions. The environmental costs versus benefits must be clearly stipulated since removal of the proposed extensive volumes of soil or contamination of water could hinder reclamation once the 10 years of mining is done. Costs of clean up in case of contamination could be millions of Rands and need to be taken into consideration by the mining company.
Another important component of reclamation will include ensuring a sustainable water source for communities near the mining site (i.e. agriculture, livestock farming and related activities should not lose the potential to provide drinking water for their animals).
4. Report content In terms of the report content, there are some contradictions in terms of which studies have been conducted vs. which are underway. For example on p. 34 it is stated that a study on noise is still to be conducted, whereas in section 3 (in several places) and on p. 99, it is stated that the mine will not have an impact through noise. On p. 99 it also mentions that a geohydorological study has been conducted, but no results from this were included in the current scoping report and on p. 89 it says that such a study will only be conducted in January to April 2014.
4.1 Maps
The quality of the maps is poor and with some have no legends while for others the legends are incomplete (i.e. not all the features and colours present on the maps are shown in the legends of those maps that do have one). A better understanding of the mining area in relation to all the natural features and ecological footprint is required. Specifically, a map showing the mining area, the aquifers, river courses and the Department of Water Affairs monitoring boreholes is essential. We would like to see a composite map along these lines, including the proposed route for the new road and power lines, also indicating the underlying vegetation types and their status as well as the status of alien plants. This map should form the basis for interpreting the impacts of the mine, which is not currently possible with the current series of inadequate maps.
4.2 Impact of mining activities on Species of Special concern SANParks has conducted some of its own work on species of special concern (SSC). This includes mainly species present in the West Coast National Park which may be impacted if the groundwater is impacted. We feel that not considering the impact of mining on species offsite is an oversight as many impacts will be transferred in space from the mining site itself. Groundwater, air, dust, noise and light pollution can all have impacts far from the mining site itself. We would like to have the Cape Research Centre’s SSC list compared to the one in the report, which appears to have omissions. As an example, flamingos, which are nationally near threatened and charismatic tourism species, use the 3
Langebaan lagoon as an important site (though they were not included on bird red list). We would like to propose that a comprehensive SSC list be compiled for the entire ecological footprint area of the mining activity so as to ensure a more holistic approach in assessing the potential impacts.
4.3 Roads and powerlines Additional work needs to be done to assess the impact of the proposed road and powerlines. Road construction is more than a visual scar (impact listed in the report) – it increases the likelihood of animal collisions and road kills, which may result in significant losses to particular species like tortoises and other small animals as well as birds which often feed on roadkills. Roads break connectivity of habitat for many species and are a common pathway for the spread of alien species (especially during building phase and when soil is being transported. This is mentioned very briefly p. 81). On p.16 & p.26 - it seems that parts of the site are heavily invaded and would have a substantial seed bank – this has significant implications for the way in which the top soil should be managed. Roads also bring additional traffic that adds to pollution, access for poachers and lead to more anthropogenic impacts generally.
4.4 References Although there are several references cited throughout the report, there does not appear to be a reference list. There is a brief list of references on p. vi, but these do not cover all the references cited in the report and those that are provided are incomplete. A full reference list is an essential requirement for a report of this kind. There were several references (e.g. Valiela et al 1990 and Burnett et al 2001, p. 23) which we would wish to consult, but require more information on these in order to follow up. In addition, there are some broad statements in the report that require supporting references or evidence. The report does not flow and in certain places it is very technical with both jargon from geologists, botanists and mines. This makes it very difficult for a lay person (or specialist from an unrelated field) to read, interpret and comment on the report.
4.5 Abbreviations and appendices Abbreviations are only provided for companies, acts and a few mining terms in the abbreviations list on p. vii and none of the scientific and/or technical abbreviations and units (which are essential for interpreting components of the report) are provided in the text, figures or the abbreviations table. Specific examples are listed in the sectional comments below. In addition, the appendices did not form part of the report which means that they could not be consulted. Lack of references, appendices and proper abbreviations make it very difficult to interpret the scope, rigour and accuracy of the work that has been presented.
5. Specific comments In the sections below, we have outlined our particular comments and concerns for each section and sub-section. At the end of these comments we have also added some additional comments on the botanical scoping survey. CONTRIBUTIONS PER SECTION (Contributions relating to specific sections of the report) Contents Page Not all sub-sections in the chapters are listed in the table of contents Lists of Tables/Figures Abbreviations / This list is incomplete, leaving out many of the scientific and Acronyms field specific abbreviations used in the body of the report. Definitions / Terms There are no definitions for the mining terms used. SECTION 1: THE METHODOLOGY APPLIED TO CONDUCT SCOPING 1.1 Name the communities Full names and positions should be listed for all persons/ as defined in the guideline, communities identified or explain why no such community was identified 1.2 State whether or not There is no map or reference explaining the portions of the the community is also the Elandsfontein farm, so the references to the portions cannot be landowner interpreted. 1.3 State whether or not the Department of Land Affairs was identified as an interested and affected 4 party 1.4 State specifically Has there been through verification on this, except the word whether or not a land claim from the current land owner? is involved 1.5 Name the traditional authority identified by the applicant 1.6 List the landowners There is no map or reference explaining the portions of the identified by the applicant Elandsfontein farm, so the references to the portions are not helpful. 1.7 List the Lawful What are the rights involved with prospecting? Act/Law? Occupiers of the land concerned 1.8 Explain whether or not No mention is made of possible socio-economic impacts of other person’s socio – pollution of the aquifer and what impact this might have on economic conditions will be natural areas (including the national park, and RAMSAR directly affected by the wetland site) as well as tourism industry that is dependent on proposed prospecting or these natural sites. mining operation and if not, explain why not This require more detailed explanation of how many jobs will be created, at what level of skill and remuneration each job will be at, where this labour will be recruited from, and what spin-offs are referred to. 1.9 Name the local municipality identified by the applicant 1.10 Name the relevant SANParks should be added here as an organ of state tasked government departments, with the custodianship of the environment agencies and institutions responsible for the various aspects of the environment, land and infrastructure which may be affected by the proposed project 1.11 Confirm that 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, and has been appended hereto ADDIOTINAL NOTES ON SECTION 1 SECTION 2: EXISTING STATUS OF THE CULTURAL, SOCIO – ECONOMIC AND BIOPHYSICAL ENVIRONMENT 2. Existing status of the The study area has been incorrectly defined: west of cultural, socio-economic Langebaan is in the sea as is south of Cape Town and the two and biophysical points are unlikely to converge. environment There is no map or reference explaining the portions of the Elandsfontein farm, so the references to the portions are not helpful.
The regional map should show the sea as well as the location of nearby towns and other affected parties such as the West Coast National Park and West Coast Fossil Park. 5
Figure 1 map, shows the incorrect boundary for the Grootefontein section of WCNP
The introduction to this section provides only a partial overview of the actual location with little background on the cultural, socio – economic and biophysical environment 2.1 Confirm that the Were all interested parties present at the meetings to date? If identified and consulted not, then this statement is misleading. Attendance register interested and affected should be provided. parties agree on the description of the existing What is the exact depth that the ore is lying at? The current status of the environment description is insufficient. 2.2 Existing status of the This site is of significant cultural value and care should be cultural environment that taken with paleontological and archaeological value. may be affected Archaeology: Who issued this research permit and should it not read ‘a research permit’ not ‘the research permit’?
Palaeontology: What will the predicted impact be on fossil sites and is this listed in the report?
2.3 Existing status of any Heritage assessment required heritage environment that Heritage Scoping Report Dated December is incomplete as it may be affected does not provide any specific detail as to which year (and dates) this study was conducted. How will the mine impact fossil areas and how will they deal with a discovery of a fossil deposit. Fig. 2 – map has no key Dr Braun registered with SANParks p. 10, sub-section Palaeontology, paragraph four: The area is reported to have unproven potential, but strong enough to yield fossil remains additional to the known marine microfossil content; thus an indication for a need to conduct detailed impact assessment and develop mitigation plan 2.4 Existing status of any Please provide a copy of the Social and Labour Plan. current land uses and the How will the mine affect tourism? socio – economic environment that may be directly affected 2.4.1 Western Cape The “Saldanha Bay Industrial Development Zone Feasibility Province Study” is not a principle. The mine is not a long term sustainable entity and therefore does not meet the SO1 objectives. The role of the state is not only to support business as articulated, but to effectively manage the environment for the benefit of future generations. This is a glaring omission. 2.4.2 West Coast District The potential conflict between mining and tourism is not Municipality elaborated on or explored anywhere in section 2.4 (or elsewhere in the document). This should be explicated and given due consideration 2.4.3 Saldanha Bay Local Is the Gecko Fert mine active? What impacts does this (if it is Municipality operational) or any other phosphate mines in the area have? A sharp increase in employment by mines since 2004 is mentioned. This is contrary to current labour statistics. What mines are these, where are they and how much of the local communities do they employ (are these permanent or casual staff)? What is the likelihood of leakage similar to that in the Kruger 6
Park in December 2013/January 2014? The Hospitality / Tourism Industry (Catering and Accommodation) need to be a stand-alone as these contributes substantially in the local economy, especially in Langebaan. 2.4.4 Land use at proposed Historic information regarding the area being previously part of site the private Nature Reserve is not captured in the State of Environment? Please provide information regarding formal protected area status of the area. 2.4.5 Land capability What is land capability? And why does this rely on a socio- economic study?
“Farm Elandsfontein has been identified as a Critical Biodiversity Area by Saldanha Bay Municipality, separating the two eastern portions of the West Coast National Park. It was previously a Private Nature Reserve and due to the nature of the vegetation on site can be seen to form the natural northern extension of the WCNP.” As a CBA it should be protected and included into the WCNP as the first option. It also falls in West Coast National Park’s buffer-zone and will negatively affect SANParks’ ability to consolidate the park. This area was zoned as remote and wilderness in WCNP and if mined this will not be the case. Activities in the buffer zone should be compatible with conservation. This is not usually the case with mining and due consideration should be given to the appropriateness of a phosphate mine in the buffer zone. 2.4.6 Sensitive landscapes The vegetation types in this area are all threatened and do not recover well when disturbed. Specialist studies should indicate whether it is indeed possible to completely rehabilitate the disturbed areas and how this would be done.
How much of the proposed mining location is made up of Hopefield sand plain fynbos and Saldanha limestone strandveld and how much of this vegetation type will be lost?
It might be useful to highlight what proportion of each of these vegetation types are within formal protection. 2.5 Existing status of any What is the anticipated footprint of the extended Eskom power infrastructure that may be lines? affected What are the pros and cons of the haulage road versus the conveyer belt? What is the proposed route of conveyer belt and or road to Saldanha? Clearer details of the proposed road or conveyer system and its route and extent are required to accurately determine their impact. 2.6 Existing status of the biophysical environment that will be affected including the main aspects 2.6.1 Regional Geological The colours on the Figure 3 map are not defined meaning that Setting the geology cannot be interpreted; “The information was drawn from the geohydrological study compiled by GEOSS”- SANParks would like to see this study please. 2.6.2 Regional P.20 “Prospecting drilling would provide more information with hydrogeological setting regards to the formations present, their depths, and the occurrence and characteristics of water strikes” SANParks kindly request full report on all drilling results. The information should also be made available to the department of 7
Water affairs. Are there not other methods to determine water depths and presence than drilling? Could existing boreholes not be used to estimate the occurrence and depth of water and likelihood of mining interference? P. 20 abbreviations like Langebaan Road Aquifer System (LARS), LAU, UAU are not provided in the table of abbreviations and would probably make for better comprehension if they were shortened (e.g. Langebaan Aquifer) and not abbreviated. Other abbreviations like EC used in this section are not defined at all. On p. 21 it is noted that the deeper water levels are showing a gradual decline over the past 8 years. What is causing this decline? How will the mining effect the declining water levels? How will the mining impact on the groundwater as the water levels are fairly close to the surface? What is the water level of the “two shallowest boreholes” mentioned on p. 21?
“It is interesting to note that while the two shallowest water level boreholes have remained stable over the past 6 to 8 years, the deeper water levels all show a similar gradual decline over the past 8 years. Seasonal variations of the water levels are negligible”: Where does this information come from? Please provide the reference.
P. 21 Consistency is required where abbreviations are used for measuring units: What is mS/m? and what is mbgl – meters below ground level? m used elsewhere? What is mamsl? What is EC?
“The groundwater quality differs between the UAU and LAU. Groundwater quality is good in the LAU with ECs <120 mS/m (Woodford et al, 2003) while groundwater in the UAU is poorer. The groundwater from the confined LAU has a mixed Na-Ca/Cl alkaline character with an EC generally lower than 70 mS/m. Groundwater from the UAU has a Na/Cl character with higher EC.”: For whom or what is it poorer? Drinking water, agriculture, nature? This statement requires clarification and a complete reference. It is not clear what is meant by poor and good quality in different areas. Is there any link between the two main aquifer systems and the smaller subsection?
P. 23 it appears from the report that the aquifer is classified as a special aquifer system and as such has a strictly non-degradation level of groundwater protection. In addition it is thought that the aquifer has high vulnerability to anthropogenic activities: The impact of mining on the aquifer should be thoroughly investigated in the specialist hydrological study?
“The high conservation status Langebaan lagoon is not fed by overland streams or rivers due to the porous nature of the sediments and the arid conditions, but it has been suggested that groundwater plays a 8
significant role in sustaining the marsh ecosystem (Valiela et al., 1990; Burnett et al., 2001).”- Further research is required to substantiate this.
“Diagnostic plants indicate significant contributions of groundwater (Adams and Bates, 1999).”- This sentence is difficult to interpret. Frogs present at Langebaan lagoon also indicate fresh water.
Ground water use and yields are mentioned but not exact amounts, are these available? 2.6.3 Climate Questions that should be asked to anticipate climate change impacts include: What flooding events have happened in the past that could affect the mining operations? What is the possibility that the original Berg River Valley could flood again? What is the average wind speed as this affects the distance that dust can be spread. Table 4: Please average night temperature? 2.6.4 Topography A topographic map of the area would be useful here 2.6.5 Vegetation P. 27: Who conducted the survey for plants in the focus area (was this part of the Nick Helme Survey? Appendix 2 not attached) and in what season was this done? Would all plants have been identified?
The Nick Helme botanical survey was done in late summer and many of the floral species would be dormant. A second survey in the growing season is required to identify a more complete list of threatened species. A survey of Van Niekerks Hoop Farm (Farm 300) was conducted in 1996 by UCT Botany Institute for Plant Conservation (Desmet & Cowling, 1996). This property is adjacent to Elandsfontein. The survey shows that several threatened species, including geophytes, are found on this farm. A botanical survey needs to be conducted in the correct flowering season to, ideally July to September, to include geophytic and other flowering species that might have been excluded in the Helme 2013 survey.
According to SANBI PRECIS database there are 18 Critically Endangered, 52 Endangered and 60 Vulnerable plant species found in the quarter degree squares 3318 AA,AB and AC in which Elandsfontein and the West Coast National Park are found (identified as species of special concern within the West Coast National Park), while the Desmet & Cowling survey identified 16 Red List species, only three of which overlap with the Helme survey.
Reference Desmet, P.G. Cowling R.M., 1996. Assessment of the farm Van Niekerks Hoop (300) for inclusion into the West Coast National Park. Institute for Plant Conservation, Department of Botany, University of Cape Town.
Please indicate what plants off site may be impacted by the proposed road, erosion or pollution of the aquifer?
P. 27 Are there studies to show that these bulbs survive translocation? Please provide references.
9
P. 27 Are there plans to actually translocate the bulbs and are the locations of each individual actually known?
P. 29 the possibility of “search and rescue” as a mitigation measure is mentioned – what mitigation measures have been agreed upon should the mining be approved? SANParks would like to see and be involved in a full scale mitigation plan.
P.29, first paragraph “Ecological connectivity across the site is currently regarded as fully functional, and care should be taken not to disrupt this connectivity, especially on a site bordering on a National Park” This statement is important and requires a reference and/or further elaboration.
A botanical assessment should be conducted in the peak flowering period.
Please provide a map of proposed roads and/or infrastructure in and around the mining area.
A map should be produced indicating these red list species in relation to where proposed infrastructure will be located.
What criteria are used to determine high or low botanical sensitivity areas: are these the authors’ opinions or are they based on the Threatened ecosystem type?
Attention should be paid to the potential of infrastructure to disrupt ecological corridors preventing seed or animal movement between corridors.
A plan to prevent the loss of any Red List species is required;
A vegetation management plan is required which includes rehabilitation of the areas damaged. (Please note additional comment from CRC botanical scoping report at the end of this document.
Figure 6 has no legend 2.6.6 Animal Life P.30: There are Red List birds that occur in the adjacent WC National Park that might be impacted by contamination of the aquifer and related impacts? (e.g. the flamingo – near threatened nationally).
P.30 “The retention is throughout the day but become bimodal in the warmer and drier summer and autumn months.” – please explain.
“The following information was extracted from the report “Terrestrial fauna Report”; compiled by Dr. W. Van Hoven, dated 2010”. The study area falls within the Elandsfontein Private Nature Reserve.”- Please provide a copy.
P. 32 the report uses an old publication to counter / question the status of Grant’s golden mole conservation status – recent references should be consulted. P.32 “Several large wildlife species has been brought into the Elandsfontein reserve during the past three years in the process of establishing a wildlife reserve. See table 6 for the species list and their 10
numbers”. table 6 is a bird list not mammals, there is a bulleted list of mammals with no actual numbers; p. 33 - an ostrich is not a large mammal
Further study into amphibians and reptiles is required. 2.6.7 Air quality and Noise Is there a standard level for noise pollution and is it defined? Will this be breached? On what are the dB estimates for the mining operations based? What will the hours of operation be? Will the mine run 24 hours? Why will the noise levels at night be less than during the day? Sounds can appear amplified at cooler temperatures. A dust survey which considers the impacts on people, tourism, vegetation, pollinators and other fauna is required. p. 34 Langebaan lagoon was proclaimed a Ramsar Site or Wetland of international importance in 1988 and not in the 1990s. 2.6.8 Visual aspects The information presented in this section is summarised from the Visual Scoping Assessment conducted by Karen Hansen Landscape Architects: Please provide a copy of this to SANParks WCNP was proclaimed in 1981, this should be add to all specialist reports and any other report; Impacts to be addressed in the EIA should also include that the mine is located in the buffer-zone and core expansion area of WCNP; Light impacts are mentioned casually, but light pollution can have significant impacts on fauna, especially invertebrates. With the mine being in the buffer zone of a national park, this is potentially highly significant. How much light would be generated and from how far would it be visible? The visual scar on the landscape could have an impact on tourism. Would the mining site be visible from the national park? Figure 8 is not particularly helpful or informative – see specific comments on figure. 2.6.9 Surface water How will the mining impact on the ecology of the two rivers mentioned? There is a River Health Programme monitoring site further down in the Sout River, but very little information is available for the Soutrivier closest to the mining area. ADDIOTINAL NOTES ON References are needed for much of the broad statements made in this SECTION 2 section SECTION 3: IDENTIFICATION OF THE ANTICIPATED ENVIRONMENTAL, SOCIAL OR CULTURAL IMPACTS, INCLUDING THE CUMULATIVE IMPACTS, WHERE APPLICABLE 3. Identification of the With reference to the list of considerations an assessment should anticipated environmental, undertake: social or cultural impacts, Is there not a step missing between the third and fourth points? including the cumulative The costs and benefits of the impacts should be weighed up to impacts, where applicable determine whether the action is merited before proceeding and attempting remedial action?
“The majority, although not necessarily all of the environmental problems associated with development projects tend to diminish with increasing distance from the proposed mining activity. Consequently, the most easily noticeable environmental problems are usually identified adjacent to the site and on the site of operation.” We disagree 11
– impacts on the underground water as well as the road and powerlines are likely to have much more far reaching impacts than impacts restricted to the mining site.
We disagree with the definition for indirect impacts – impacts away from the mining area as a direct result of mining activities should still be considered direct impacts 3.1 Description of the Topsoil must not be stockpiled as the seeds present in this soil proposed project including are buried and die. The sequence should be to replace topsoil a map showing the spatial such that as a new site is opened another is closed. Australian locality of infrastructure, aluminium mines have demonstrated this. extraction area and any How long will a dump be left for? associated activities Will it be covered to prevent wind-blown erosion of the sand? “Once the phosphate ore is mined then the strip is backfilled with the overburden and slimes from the plant (if technically feasible) and…”: Please indicate what would be the measures for environmentally feasible? These should be included. Please name the chemical that the slimes will contain.
“As the mining activities intersect the upper aquifer and no bodies of open water are permitted, continuous perimeter borehole pumping is required to remove the excess water from the mining strips. The pumped water will be used for activities on site and the excess water will report back to the underground water system.” Does this statement acknowledge that the mining will reach the depth of the subterranean water? This calls for much more thorough investigation on the chances of aquifer contamination. On p. 73 it is suggested that mining will be done at depths of 30-45m which would undoubtedly impact on groundwater. In addition, will the water that is returned to the underground system be treated and how? p. 40 last bullet – how much water is proposed to be extracted and what will the impact of this be on the aquifer and people and natural systems reliant on it? Eskom- power line will need separate EIA 3.1.1 Mineral deposit and What is an SG? mine product What is Mt? Presumably metric tonne, but rather spell this out; This section may be incomprehensible for someone outside the field 3.1.2 Production rate Why does plant haulage increase from capacity after year 4? Is this due to expansion? 3.1.3 Planed life of mine Why would it be extended? The haulage only looks at the first 10 years What will happen to the property once mining is done? No restoration details are provided. 3.1.4 Description of mining This is a repeat of information in sections before this; operations How is the ore removed, drills, shovels, explosives? Where will the top soil be stockpiled? (Contains seed bank) and for how long? 3.1.5 Plant processing Definitions are required for those who don’t know mining “The fine overflow from the cyclones will be de-watered together with the flotation tailings in a thickener and temporarily stored in a slimes dam before being back-filled into the mine for rehabilitation.”: Is this a device or a chemical? What chemicals are used in the process and will they then find their way back into the natural system? 3.1.6 Surface water “Usually, any solids generated for disposal can be disposed to a facilities general waste, if demonstrated to be a low hazard, or, alternatively, as 12
hazardous waste.” What are considered usual conditions? Fynbos is a low nutrient vegetation type and the proposed mine is in the West Coast National Park buffer zone – who will assess whether the hazard was low and to whom/what the hazard was low? Where is the nearest landfill site? Who will test the water before it is discharged? How will contaminated water be treated and where will it be discharged once it is “clean”? Where will the water storage dams be constructed for the contaminated water? What happens to the top soil if the dams are constructed and where will it be stored or moved to?
Regarding the bio sludge that is going to be dried and composted: Please indicate where this process is going to happen and where it’s intended to be released. It is not a good idea to release organically rich mediums in a vegetation type that grows in a nutrient poor habitat.
“Details regarding the system to be implemented on site is currently under investigation. Further detail will be provided in the EMPR.” The system should be thoroughly investigated and also be included in the Environmental Impact Assessment rather than conducted post-hoc? 3.1.7 Transport A Conveyer belt is preferable to a road as there is no dust, and no borrow pits and an under pass will help small animals cross the R27; Please indicate where the bridge and conveyor belt will be situated? Has there been input from other environmental organisations on this idea? A map and plan of the proposed road or conveyer system is required to assess its potential impact. Roads are known to have serious environmental impacts, including amongst others the direct impact of habitat destruction where the actual road is constructed, fragmentation of habitat, increased spread of invasive alien species, fatalities of a variety of animals as well as additional impacts associated with dust from gravel roads. Furthermore, roads lead to increase in carbon emissions and increase in human traffic which has a variety of secondary impacts which could include poaching of animals and plants (a known problem in the area especially for reptiles). All these impacts need to be explored explicitly. 3.1.8 Waste management Waste must be removed and not buried on site – please provide details of what is going to happen to waste. What will happen to waste rock? Will rock not be required to fill the holes created by mining during rehabilitation? What is the composition of the hazardous waste? Where exactly will the hazardous waste be stored on site and how often will it be collected? The Department of Environmental Affairs is referred to with three different names in this paragraph – please use the appropriate name. 3.2 Description of any Please explain the implications of a listed activity in the listed activities which will introduction to this section. be occurring within the P. 52 – please indicate direct pollution of water through mining proposed project activities other than the waste generated. 13
P.53 to 54: the way in which the activities are triggered and reported make no sense. For example “The mining … may trigger… the following heritage activities: (a) the construction of a road, wall, powerline…” The construction of a powerline is not a heritage activity – additional information on what will be triggered and what is required in such instances is required to make this section interpretable. 3.3 Specifically confirm that Our comments on this report identify additional impacts of concern the community and identified interested and affected parties have been consulted and that they agree that the potential impacts identified include those identified by them 3.4 A list and description of Has a study being conducted of the cultural environment been potential impacts identified conducted? Such a complete study is required. Will fossils be on the cultural environment saved or destroyed; will mining be stopped if skeletons or deposits of fossils are found? 3.4.1 Construction phase Fence should be first. What will be used for the berms? Will they be vegetated? 3.4.2 Operational phase 3.4.3 Decommissioning Please indicate the decommissioning of roads and phase rehabilitation. Alien clearing - What is the anticipated cost and how will this decommissioning be paid for? 3.5 A list and description of A detailed description of the heritage environment that may be potential impacts identified affected is required. on the heritage environment, if applicable 3.5.1 Construction phase 3.5.2 Operational phase 3.5.3 Decommissioning phase 3.6 A list and description of potential impacts identified on the socio – economic conditions of any person on the property and on any adjacent or non – adjacent property who may be affected by the proposed mining operation 3.6.1 Construction phase A dust study should be conducted to determine how far the dust will blow. Hopefield is NW of the mine, therefore, the SE wind will blow dust onto them; A canteen is listed, why would there be open fires? Refuse is not to be burnt; The footprint of a canteen in terms of water, waste and energy needs to be constrained in the planning and construction phase as well as when it is in use; The noted likely increase in crime, loitering and other social conditions is of particular concern for the tourism industry in the area, which is currently one of the area’s largest industries. The impact on sense of place raises similar concerns. 3.6.2 Operational phase Potential problem of invasive alien species establishing P. 62 what kinds of animals are being referred to here and is the risk to the mine site or from the mine site? P.66 worker jobs should preferably be offered to people who can demonstrate a history of living in the area so as to avoid an 14
influx of people in search of work 3.6.3 Decommissioning P. 66 “Nuisance to the community from noise and dust. phase However according to the noise survey, the noise shall be contained within the valley where the mining and plants will be concentrated and shall have no effect on any surrounding communities.” [& similar statement on p. 65] According to p. 34 and p. 60 the assessment of noise still has to be done? P.67 - The impact of polluted water resources on communities is mentioned, but this is not covered at all in the rest of the report. This is a significant oversight. 3.7 A list of potential P. 68 a potential positive impact in terms of increase in quality impacts (positive & of life to the local community is mentioned. This will only be negative) on: employment realised if the multitude of negative impacts listed elsewhere do opportunities, community not decrease quality of life to a greater degree. For example, if health, community jobs are provided to people outside of local communities, with proximity, and links to the accompanying influx of labour from other areas, competition for social and labour plan jobs is likely to increase. In addition, the other negative impacts listed such as increased demand for housing and services, loitering, safety risks, increase in crime and other social conditions in combination with the above. In addition, potential pollution of water sources is more likely to lead to decrease in quality of life for local communities than an increase. 3.8 A list and description of Please indicate how these impacts will be mitigated? potential impacts identified The impacts cited in this section often repeat impacts cited to on the biophysical people and not to the environment. The impact of each action environment including but on the environment needs to be assessed and evaluated. not be limited to impacts on: flora, fauna, water resources, air, noise, soil etc 3.8.1 Construction phase P.70 (and in several other places where similar reference is made to the dust and noise): “Nuisance to the community from noise and dust. The noise and dust shall be contained within the valleys where the mining and plants will be concentrated and shall have no effect on any surrounding communities. The closest community is located about 14.5km’s away, namely Hopefield.”: The report should also indicate what the impact be on the animal and insect communities that will be affected. Living areas are not listed as being built Dust is not only relevant to people. Dust can have significant impacts on plants as it clogs stomata and related organs. This impact could be reach further than at the mine site. We would like to request that the dust impact study considers potential impacts on plants, their pollinators and the viability of seed produced by plants that occur in dusty areas compared to those where there is limited dust. Likewise noise can have significant impacts on animals – only neighbouring communities considered in the impacts mentioned. Similarly the impact on air quality is not discussed with reference to the environment.
P.70 (and related in latter sections) The impact of the contamination of water sources is not discussed with reference to the national park and the species that are supported by the Langebaan lagoon which is fed by the aquifer. The knock on impact on tourism (socio-economic impact) is also not discussed. 15
3.8.2 Operational phase Please indicate of possible poaching of bush meat from the park and surrounding areas as an environmental impact?
P. 72 - Reference is made to Table 33 – there is no table 33, I assume 25.
Reference is also made to impacts on socio-economic conditions – this section is supposed to focus on environmental impacts? First entry in Table 25 again does not focus on the implications for the environment.
“Potential decrease in groundwater quantity due to changed flow characteristics of aquifer, as the ore will be extracted up to a depth of 30-45m which extends into the top aquifer.”- Digging into aquifer is not listed as an impact. Also, the depth at which mining will take place is not mentioned anywhere else in the report. Mining at this depth will undoubtedly impact severely on the aquifer with knock on impacts throughout the national park and for surrounding communities and farmers who make use of this water source.
“The depression will make using this area for grazing by fauna impossible until backfilling occurs impossible”- This sentence makes no sense; The impact on water in general in this section should be discuss in the context of the national park and endangered species within it.
P.74 - There is very large opportunity for the spread of alien species when soil is disturbed, during road construction and when soil material is transported. It is worth considering each of these impacts separately as each action will exacerbate existing invasions and lead to new ones.
P.76 - The potential for drainage to contaminate groundwater is mentioned, but the impacts of this are not discussed here or elsewhere in the report. This is an essential requirement.
P.77 - The noise survey is referred again to although elsewhere in the report it is stated that the survey is still to be conducted.
P.78 What are the implications of the phosphate contamination of the groundwater?
“Ineffective vegetation management and rehabilitation practices on the sidewalls may appear” – there are no details of how proposed rehabilitation would take place, so it is difficult to assess the likelihood of success.
P. 78 What type of hazardous waste is being referred to here and what are the potential implications of this waste for people and the environment?
How long would such waste remain in the system?
“Storage of hazardous waste for longer than 90 days” The details of how waste will be stored, where and for how long are not provided in the report. What is the plan for such waste and why might it be on site for longer than 90 days? 16
P.79 “Accidental burning of rubber due to cutting of steel or the storage or tires may start fires” ?
P.79 “Veld disturbance may take place during the installation or replacing of pipelines.” Pipeline installation and route not mentioned in the body of the report
3.8.3 Decommissioning This section is listed as 3.8.4 in the report, but there is no phase section 3.8.3; There are no details of the plan for decommissioning. Pre- mining photographs of the site is needed to reshape it later; P.83 “In the case of the mine area reshaped incorrectly, it will not be possible to use this area for any agriculture or other type of land use.” So there is a possibility that use of this area for short term gain (10 years) could lead to a non-usable piece of land [possibly extending beyond the mining site?] for the foreseeable future? P. 84 Fertilizers should not be used in fynbos rehab P.85 Loss of employment opportunities should be considered under socio economic impacts and not environmental
3.9 A description of Chapter 3.9 is not listed in the table of contents; potential cumulative New impacts are not listed in this section and the other land impacts that proposed use types or cumulative impacts are not mentioned. Where else operation may contribute to could impacts be observed and/or how would they work in considering other identified synergy? land uses ADDIOTINAL NOTES ON Prevention of pollination of plants and loss of seedling SECTION 3 generations
SECTION 4: LAND USE OR DEVELOPMENT ALTERNATIVES, ALTERNATIVE MEANS OF CARRYING OUT THE PROPOSED OPERATION, AND THE CONSEQUENCES OF NOT PROCEEDING WITH THE PROPOSED OPERATION 4.1 A list of and description P.88 - Is mining on the surface only an option? If so, the of any alternative land uses impacts of this need to be assessed separately in subsequent that exist on the property or documents. on adjacent or non – adjacent properties that may be affected by the proposed mining operation 4.2 A list and description of any land developments identified by the community or interested and affected parties that are in progress and which may be affected by the proposed mining operation 4.3 A list and description of Contradiction, as the mine is foreseen to not close any proposals made in the consultation process to adjust the operational plans of the mine to accommodate the needs of the community, landowners and interested and affected 17 parties 4.4 Information in relation The benefits and lost opportunities in this section have been to the consequences of not incorrectly written in places (e.g. consequences of mining proceeding with the include lost export opportunity?) proposed operation How many new jobs will be created? What new skills will be gained by the local population and how will this happen? Will skilled labour be imported?
How will upliftment occur and be measured?
The environmental and socio-economic benefits of not mining are far greater than just those on site benefits that have been listed (indigenous vegetation will not be displaced).
If mining does not take place then species may remain at site and not go locally extinct (loss of populations), impacts on the lagoon and tourism will not take place and crime and loitering will be reduced.
A proper and complete cost benefit analysis is called for. 4.5 Description of the most appropriate procedure to plan and develop the proposed mining operation ADDIOTINAL NOTES ON SECTION 4 SECTION 5: DESCRIPTION OF THE PROCESS OF ENGAGEMENT OF IDENTIFIED INTERESTED AND AFFECTED PARTIES, INCLUDING THEIR VIEWS AND CONCERNS 5.1 A description of the information provided to the community, landowners and interested and affected parties to inform them in sufficient detail of what the mining operation will entail on the land, in order for them to assess what impact the mining will have on them or on the use of their land 5.2 A list of identified How was the list of interested and affected parties compiled? communities, landowners, There are 2 places with SANParks as the organisation but no lawful occupiers and other names in the list interested and affected parties that were consulted 5.3 A list of their views in Were all parties pro the haulage road? We are not in favour of regard to the existing this option. cultural, socio – economic “The proposed mine will have a dramatic impact on the tourism or biophysical environment, potential of the greater area and impact on the R27, a main as the case may be thoroughfare for the West Coast. “: Will this impact be positive or negative? Please provide evidence that additional tourism would result from one additional road rather than increased traffic detrimental to the park? 5.4 A list of their views “A request was for examples of similar success stories of phosphor raised on how their existing mines in South Africa. Response: This can be provided” cultural, socio – economic Please provide the details and the impacts from these case or biophysical environment studies. 18 potentially will be impacted Please include comment on the impact of the leakage from on by the proposed the phosphate mine into the river of the Kruger park in prospecting or mining 2013/14 operation 5.5 A list of any other “A request was for examples of similar success stories of phosphor concerns raised by the mines in South Africa”- Please provide evidence aforesaid parties Discussion with SANParks to have a road through their land from Hopefield side is mentioned – please provide information whether agreement has been reached in this regard, including maps of this proposed route. 5.6 The applicable minutes Refer to appendix. – SANParks did not have access to any appendices, and records of the besides the botanical scoping report. consultations 5.7 Information with regard to any objections received ADDIOTINAL NOTES ON SECTION 5 SECTION 6: DESCRIBE THE NATURE AND EXTENT OF FURTHER INVESTIGATIONS REQUIRED IN THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT, INCLUDING ANY SPECIALIST REPORTS THAT MAY BE REQUIRED This section states that several studies have already been completed to assess potential impacts (e.g. noise and geohydrological studies) – other sections in this report however indicate that these studies are still to be carried out. The results have also not been made available – please clarify. The section actually contradicts itself in saying in the first paragraph that a geohydrological study has been conducted and in the second that one is still underway. LIST OF FIGURES Figure 1: Regional locality This figure needs a better description and legend on the map. of proposed mine area It shows the incorrect boundary for Grootefontein section of WCNP
Figure 2: Google map This figure needs a better description and legend. ‘A sensitive showing fossil area on landscape indentified in terms of the Heritage and Farm 349/2, Elandsfontein Archaeological Study shows that the Elandsfontein Fossil Area is located on Portion 2 of the Farm Elandsfontein 349 about 3 kilometers from the area to be mined (see figure 2)’ This is not indicated/shown on fig 2.. Figure 3: Geological map of the study area Figure 4: Groundwater map of the study area (1:500 000 DWAF map series) Figure 5: Annual Rainfall Data obtained for Rainfall Station: Langebaan Road Figure 6: Simplified No legend vegetation map of the greater study area and focus area, showing the position of the only drainage line. Unshaded areas are all Saldanha Limestone Strandveld and Langebaan Dune Strandveld mosaic Figure 7: Satellite image of total study area showing a simplified map of botanical sensitivity. Unshaded areas are of Medium Sensitivity, 19 and Low sensitivity areas are in green Figure 8: Potential Visual What is cyan? There needs to be a legend describing what the Receptors generated on different colours mean and the figure legend as it stands is not GIS mapping and based on sufficient to allow interpretation by a lay person or non- estimated infrastructure cartographer. What are potential visual receptors? Where is elements in one location, one at 12 m and why is this significant? up to 12m high above natural ground level, and at a 10km radius. The shielding effect of natural landform can be seen; the exposed area is coloured cyan. Figure 9: Surface Layout Overburden stockpile is on the WCNP boundary, we need to Plan look at what effect this will have on the park (dust, alien plant seeds etc); Will the overburden have alien clearing on it? LIST OF TABLES Table 1: List of registered Interested and Affected Parties Table 2: Formations and lithologies of the Sandveld Group Table 3: Previous classification of the Bredasdorp and Sandveld Groups with the project relevant Formations underlined Table 4: Weather characteristics for the study area Table 5: Plant Species of Although a list of the Red List plant species were provided, the Conservation Concern botanical survey was conducted outside flowering season, recorded in the greater annuals and bulbs excluded. Possibility of more red data study area and in the focus species. area. Key to Vegetation Types: HSF – Hopefield Please indicate on a map where these red list species occur in Sand Fynbos; SFS – relation to where proposed infrastructure will be located. Saldanha Flats Strandveld; LDS – Langebaan Dune Strandveld; SLS – Saldanha Limestone Strandveld. The ? indicates that this species may be present here but was not recorded during the survey. Table 6: Bird life occurring in the greater area including Elandsfontein Farm 349/2 & 4. Table 7: List of Lizard The title should read Lizards not Lizard occurring in the greater area and potentially on Elandsfontein Table 8: Tortoises occurring naturally in the wider region which includes 20
Elandsfontein are Table 9: Snakes occurring naturally in the wider region which includes Elandsfontein are Table 10: Small mammals occurring naturally in the wider region which includes Elandsfontein are Table 11: Definitions that shall be used in the assessment and evaluation of impacts Table 12: Resource estimates after Geological Loss Table 13: Listed Activities in Terms of NEMA EIA Regulations Table 14: Potential impacts on the cultural environment during construction phase Table 15: Potential impacts on the cultural environment during operational phase Table 16: Potential impacts on the cultural environment during decommissioning phase Table 17: Potential impacts on the heritage environment during construction phase Table 18: Potential impacts on the heritage environment during operational phase Table 19: Potential impacts on the heritage environment during decommissioning phase Table 20: Potential impacts on the socio-economic conditions during construction phase Table 21: Potential impacts on the socio-economic conditions during operational phase Table 22: Potential impacts on the socio-economic conditions during decommissioning phase Table 23: Potential impacts on the employment opportunities, community health, and community proximity Table 24: Potential impacts 21 on the biophysical environment during construction phase Table 25: Potential impacts on the biophysical environment during operational phase Table 26: Potential impacts on the biophysical environment during decommissioning phase Table 27: Potential Cumulative Environmental Impacts Table 28: Procedure to plan and develop the proposed mining operation LIST OF APPENDICES Appendix 1: Heritage Has been sent Scoping Study Appendix 2: Botanical Has been sent Scoping Study Appendix 3: Visual Scoping Study Appendix 4: Minutes of Meetings Appendix 5: Background Information Document Appendix 6: Advertisements as placed in the Weslander in English and Afrikaans and Die Burger Appendix 7: Attendance registers Appendix 8: Prepared presentations Appendix 9: Comments received and comments table reflecting comments from I&APs Appendix 10: Economic and Strategic Significance of Elandsfontein Phosphate Deposit Appendix 11: Maps of mine area
Additional comments
We would like to request that SANParks have input into the terms of reference that are drawn up for each of the impact studies that are to be conducted.
In particular (and identified in the scoping report in some instances) we believe that the following additional studies are required: Baseline water quality studies in Langebaan Lagoon 22
Ecological baseline studies in the Sout- and Groen Rivers Assessment of dust impact (including impact on plants, pollinators and other animals) A full scale vegetation surveys considering plant species of special concern – carried out and monitored in the appropriate seasons (this would require winter and spring assessments) Heritage assessment Noise assessment (including impact on animals) Light pollution assessment (including impact on animals) A full scale hydrological impact assessment including assessment of the impacts of polluted water on the park, local communities, farmers and tourism An Socio-economic cost benefit assessment A more thorough assessment of reptile and amphibian species
Additional Comments from the report of Nick Helme Botanical Surveys: Botanical Scoping Report
The Elandsfontein Environmental Scoping report includes certain sections of the Botanical Scoping report. However there were important sections and comments that were not included from this report in the Vegetation section of the scoping report. The CRC have highlighted some of these below:
5.2 Plant Species of Conservation Concern “It is also likely that at least four or five other SCC (probably bulbs or annuals) would then become evident, especially if surveyed over the four main seasons.”
“Boucher (2010) lists as occurring on site, and at least one of the species (Leucadendron foedum) definitely does not occur on site, but it is possible that the other three are present, all within the Hopefield Sand Fynbos. The likelihood of there being other undetected SCC in both the focus area and in the study area is deemed to be moderate.”
As the author of this report points out, there are likely several more Red List species which would be identifiable through surveys conducted over 4 seasons.
5.4 Ecological Drivers “Lack of fire also means that many bulbs and annuals that normally flourish only in the first few years after a fire, when there is plenty of light and open space, struggle to flower and hence set seed. These species can persist for long periods as bulbs and seeds underground, but obviously they have a limited life span, and the longer they go without fire the greater the chance that they will succumb to pathogens or seed or bulb predators (such as mole rats, common on site).”
This was not mentioned in the scoping report. There are species that will require fire. Fire regime in Sand fynbos is 30 years and strandveld 50+ years. More frequent fires could also be a problem.
5.5 Ecological Corridors “Existing ecological corridors can be inferred wherever there is natural vegetation, and thus one should not take a single line on a map too seriously – in reality it is more like a web than a corridor, with numerous lateral connections and interconnections, and it is important to maintain as many as these as possible, and the broader and more numerous the links the better.”
Areas of natural vegetation should be indicated on a map. Proposed infrastructure may disrupt these corridors.
6. ISSUES IDENTIFIED “Direct, long term to permanent loss of vegetation and alteration of vegetation structure at the construction phase (mine and associated infrastructure, topsoil stockpiles, including offices, haul and access roads, etc.)” Better maps referencing the location of threatened species and vegetation types in relation to proposed infrastructure and activities are required. 23
“Direct, long term to permanent loss of up to four plant Species of Conservation Concern at the construction phase” A plan to prevent the loss of species is required. “Temporary to long term direct loss of vegetation at the construction phase (disturbance around new powerline, other minor disturbance, including along the edge of the new roads)” A vegetation management plan is required. “Indirect ecological impacts at the operational phase (introduction of invasive alien ants and plants; disruption of natural fire regimes; fragmentation of natural habitat and ecological corridors)” Plans for mitigation of these impacts are required “The opportunity to fund and implement an appropriate and potentially significant biodiversity offset which will enhance the conservation of the vegetation types concerned, and increase the extent of the WCNP” Which land specifically (size, location, biodiversity value) is proposed as an offset?
7. RECOMMENDATIONS FOR THE PLANNING STAGE
These are very important recommendations to consider which were not included in the scoping report
“Various design and management elements need to be thought about upfront and preferably built into the proposal in order to mitigate what could otherwise be significant negative impacts
discretionary infrastructure (buildings, stockpiles, stores, roads, etc.), should be concentrated in the Low and Medium Sensitivity areas identified in Figure 6, and should be as close to the mine area as possible, and occupy as small an area as possible.
Fire and alien invasive plant management are two of the most important issues on the greater site.
Fire is a much more difficult issue to deal with, but cannot simply be ignored, as it is an essential ecological element, but is difficult to control and potentially dangerous in terms of infrastructure. Detailed fire management guidelines will be put forward during the Impact Assessment phase.”
Too frequent fire in these vegetation types will be a disaster.
“Partial rehabilitation of the site once mined should be largely possible, but it will require planning and adequate budget upfront.”
How much is partial?
8. CONCLUSIONS
Authors comments in this section were added to the report but these 2 highlighted points were the most important aspects to consider. “Detailed planning, construction, operational and rehabilitation phase mitigation will be required in order to safeguard the vegetation in the areas outside the actual development footprint. This should be outlined by the botanist at the Impact Assessment phase. A biodiversity offset is very likely to be suggested as the only feasible means of dealing with the unavoidable, residual impacts of loss and disturbance of vegetation in the focus area, which includes habitat fragmentation and loss of ecological connectivity (particularly important in the context of the adjacent WCNP).”
Garth Adams
From: Elandsfontein [[email protected]] Sent: 09 June 2014 09:40 AM To: [email protected] Subject: FW: copy of EEM
-----Original Message----- From: lesley welman [ mailto:[email protected] ] Sent: 03 May 2014 02:55 PM To: Elandsfontein Subject: Re: copy of EEM thanks Olivia
On 5/3/14, Elandsfontein < [email protected] > wrote: > Dear Lesley > > The report is currently available on the project website at > www.braafsa.com . > > Will this suffice? > > Regards > Olivia Braaf > > > > > > -----Original Message----- > From: lesley welman [ mailto:[email protected] ] > Sent: 03 May 2014 08:40 AM > To: [email protected] > Subject: copy of EEM > > Dear sir/madam > > I would like to ask if you can forward the EEM report to me. I am > currently very hard busy with Chapter 5 and the article on > ArcelorMittals rol in regional development. > I do not have time to read the document in the library. I attend all > your sessions in Saldanha and at Hopefield. > > Kind regards > Lesley Welman (Phd-student from Saldanha) > >
1
SANParks Elandsfontein mining right application
Memo
To: Conservation Services – South African National Parks (SANParks)
Attention: Mr Willem Louw
CC: Dr Mike Knight
Subject: Elandsfontein Freshwater Specialist Report review
From: Dr Jaco Nel
Date: 2014/07/22
The report by Blue Science titled “Freshwater Assessment Report for the Proposed Elandsfontein Phosphate Mine” dated June 2014 has reference. The purpose of the Freshwater Assessment Report was to provide a screening level freshwater impact assessment and serve as baseline data to evaluate risks to ecosystems as a result of the proposed Elandsfontein mining development.
The Freshwater assessment report and protocols (SASS5, Habitat Integrity and WET- EcoServices methodologies) are largely focused on surface water ecosystems and not on groundwater or the interactions between the aquifers and surface water systems. Surface water ecosystems are however often a feature of groundwater contribution to the surface water system, especially in the arid west coast regions of South Africa. At the Elandsfontein site the groundwater system consists of an upper unconfined aquifer as well as a lower confined aquifer unit. These two aquifer units will respond differently to any potential impacts and should be considered as such as part of the impact assessment.
The Freshwater Assessment report was reviewed with three (3) main objectives in mind:
1. To obtain insight regarding the dependence of ecosystems surrounding the proposed Elandsfontein mining area on the aquifers underlying the site;
2. To evaluate any risks related to impacts between the proposed Elandsfontein mining activities, the aquifers underlying the site and the (freshwater) aquifer dependent ecosystems;
3. To identify whether comprehensive protection could be provided to the surrounding ecosystems based on the insight provided by the Fresh Water Assessment report.
SANParks Elandsfontein mining right application
Ecosystem dependence
The Langebaan lagoon is regarded as largely natural, but sensitive to nitrogen loading from sewage water releases causing algal blooms (Section 5.2.2, P22). Langebaan Lagoon receives fresh water contribution from the Elandsfontein and Langebaan road primary aquifers. The exact mechanism of fresh water discharge is not clear from the different research results at the site, but mostly suggests that the lower aquifer unit contributes most of the freshwater to the lagoon (Saayman et al., 2005).
The Sout- and Groen Rivers are unique saline systems with “less saline reaches” (Section 5.3.1, p25; Section 5.3.5, p30) possibly due to fresh groundwater contribution to the rivers. Surface flow is due to the occurrence of springs and seeps (Section 5.3.1, P26), confirming the localised groundwater contribution.
The Sout- and Groen Rivers obtained low SASS scores due to the low abundance of macro- invertebra, consisting mostly of hardy species and air breathers. From the report (Section 5.3.3, P29) it seems that this is due to the “high natural salinity” as well as “low dissolved oxygen levels”. Both these conditions are expected from groundwater discharge, confirming the role of groundwater in the maintenance of the Sout and Groen River systems. The isolated pools (Section 5.3.4, p29) further confirm the groundwater contribution during the dry months.
Based on the information provided in the Freshwater assessment report it is concluded that both the Langebaan lagoon and Groen/Sout River systems are dependent on groundwater for their ecological functioning and could be negatively influenced by groundwater abstraction in the catchment.
Risks related to site
Various activities at the site are discussed. These can relate to different risks to the groundwater system and should be further investigated:
SANParks Elandsfontein mining right application
In Section 6.1 (p36) mention is made of slimes from the plant that will be backfilled as part of the strip rehabilitation. The geochemical characteristics of the slimes backfill has not been provided in any of the reports provided for review. The quality of the slimes should not be allowed to deteriorate the water quality of the groundwater and potentially affect the down-gradient fresh water ecosystems.In Section 6.1 (p37) mention is made of continuous perimeter pumping and the re- introduction of the water via horizontal trenches. No reporting or evaluation on this topic has been provided yet. Re-introduction of the water might be required both up-gradient as well as down-gradient from the site. It was also noted during a site visit to the Elandsfontein site that the space available between the proposed open pit and the SANParks border was limited and that it might be difficult to abstract on the perimeter as well as inject a few metres from the pit to stay within the mine property. More detail in this regard should be provided.
The Freshwater report states that water draining to the pit will be consumed for activities on the site (Section 6.1, P37). This volume could be significant if the perimeter dewatering is not efficient and should be evaluated as soon as aquifer test results are available.
Section 6.1( p37) states that waste rock and residue disposal facilities will be established on the site. The geochemical nature of the material and the waste classification thereof needs to be provided in order to quantify possible impact.
Ecosystem protection and Impact assessment
The Freshwater report statements that the impacts will be related to longer term impacts (section 8) might be correct for the upper unconfined aquifer. However, any potential impacts to the lower confined aquifer can cause pressure changes and reduction in flow over large distances. The interaction between the proposed Elandsfontein mining site and the Lower aquifer unit is still under investigation according to my information. The Langebaan Road aquifer data showed springs drying up several kilometres from the abstraction site.
The Freshwater assessment report indicates an unlikely impact on the Groen- and Sout rivers (Table 17, P44). I am not entirely convinced that this impact is unlikely. The Elandsfontein site groundwater levels are between 55 and 70 mamsl, while the Sout River at Hopefield is situated at an elevation of below 20mamsl. With the Sout River situated a similar distance from the Elandsfontein site as the Langebaan Lagoon, the relative influence on both fresh water ecosystems is regarded as similar.
SANParks Elandsfontein mining right application
There is sufficient uncertainty in the understanding of groundwater flow characteristics in the Elandsfontein and Langebaan Road paleo channels to not regard impact on the Sout- and Groen Rivers as insignificant at this stage. Especially the lower confined aquifer system can provide changes in discharge over large distances where pressure differences dictate the discharge and not the actual flow gradients.
Although it might be possible to state that a limited consumptive use is expected at the Elandsfontein site, the inflows into the pit can be significant and difficult to mitigate. This water will be seen as dirty water and could change the status quo regarding the water use volumes dramatically. This should be reviewed as soon as more data regarding the aquifer parameters become available. The potentially high yielding phosphate layer at the bottom of the pit could especially make the management of pit inflows difficult.
The risk of water pollution is not quantified in this Freshwater assessment report or the Hydrogeology scoping report. Elandsfontein Mining should confirm the geochemical behaviour and leach results of the discard, tailings, waste rock. Based on the field visit to the Old Phosphate mine there are some elements leaching from the mine site causing at least a change in colour of the water in the open pits.
Conclusion
The following conclusions and recommendations are made based on the review of the Freshwater Specialist report:
The Freshwater Assessment report confirms the groundwater contribution to the Langebaan Lagoon, Sout- and Groen Rivers. Fresh water contributions on all these surface water systems seem to be important for their ecological functioning.
The abstraction and dewatering of the proposed Elandsfontein opencast pit still has some uncertainty and could be difficult to manage. The dewatering of the site could impact on any of the surrounding fresh water ecosystems.
Impacts regarding water level changes to the upper aquifer could be localised and over the life of mine, but impacts to the lower confined aquifer could be rapid and over large distances causing a reduction in flow rates from the aquifer. Monitoring boreholes in both the upper and lower aquifer would be required.
The resulting drawdown of at least the upper aquifer could be mitigated by introducing water back into the aquifer. This assessment has not been done yet and could be difficult close to the SANParks border due to space limitations.
SANParks Elandsfontein mining right application
The site would contain waste rock dumps, discard dumps and tailings backfill. It is known that the fresh water ecosystems are sensitive to salinity as well as nutrients. The geochemical leaching characteristics for the phosphate rock and discard have not been shown yet. A waste classification of the waste streams is recommended to confirm that no elements of concern would be released.
______
Jaco Nel
Notes on Freshwater Assessment Report for the Proposed Elandsfontein Phosphate Mine (June 2014), by Toni Belcher
Dirk Roux, 24 July 2014
I found this report informative and of a high technical and editorial quality. The report aims to advise decision making regarding a classic conservation-development conflict: whether or how mining of the second biggest known phosphate resource in South Africa will impact on the ecological processes and integrity (specifically related to freshwater) associated with an adjacent National Park and other protected landscape features. Both of these land use activities (mining and conservation) offer value to society. The mine will deliver value for a period of 1.5 decades (according to my understanding of the report) and this value can be quantified in economic terms. A National Park offers services and value to people over a much longer time frame. However, the latter value is less tangible and more difficult to quantify. Tradeoffs in these situations are problematic because there is not a common currency to enable direct comparison.
Freshwater ecosystems The freshwater assessment presented in the above report incorporates important developments such as the Freshwater Ecosystem Priority Areas (FEPAs) of South Africa and draws on recent and sound classification and assessment methods. There are no river and wetland FEPAs in the study area. The Sout River is a Phase 2 FEPA meaning that this river would probably have been identified as a conservation priority if it was in a better ecological condition. Given its modified state (Table 8) and existing land use in the catchment, it is difficult to see significant restoration of this river’s ecological integrity taking place. No further degradation seems a more realistic objective. The report has largely convinced me that the proposed mining will not impact on any important freshwater conservation features, at least not via surface flows and contamination. Concerns remain regarding the link between groundwater and surface water (including the Langebaan Lagoon), the uncertainty associated with groundwater contamination, and the critical importance of groundwater contribution (quantity and quality) to the integrity and functioning of surface water ecosystems.
Monitoring and research Many impact studies conclude with a recommendation for monitoring. However, such monitoring is rarely implemented in a truly beneficial way. I would strongly recommend creative thinking about a monitoring programme that will enable active learning and feedbacks to management on both the conservation and mining side. Surface and groundwater monitoring are the obvious issues related to the report. However, I am also thinking of broader conservation issues such as potential modifications to the soundscape (e.g. introduced noise from mining activities and additional traffic) and viewsheds (e.g. roads, pipelines, mine dump and dust) that can impact on the ‘meaningful nature experiences’ of people. I believe that both soundscapes and viewsheds are conservation features that should receive more attention in our parks. In addition to an active monitoring programme, I would also recommend formalizing a relationship with a research institution to enable action research (research that are influenced by, and can influence, actions) specifically designed to learn about having to achieve conservation objectives in a landscape of use. Research could cover technical aspects such as groundwater and surface water interactions but also social aspects such as
1 societal value perceptions. Support for a few post-graduate students to enable such learning feedbacks seems like an intuitively desirable condition for developments such as these.
Finally On a philosophical note, two matters come to mind: Firstly, buffer zones are a legal mechanism that, as with National Parks and other proclaimed protected areas, represents an expression of socio-political values. These zones are deemed necessary for National Parks to achieve their objectives. To this end a mining operation does not sound compatible with the rationale behind buffer zones. Secondly, Earth has a stock of approximately 1.4 billion cubic kilometers of water, all connected through various forms as part of one global hydrological cycle. Of this vast volume, about 97% is salt water in oceans. Less than 3% of the total stock is in the form of freshwater, of which the majority occurs in glaciers, permanent snow or in deep groundwater that is practically inaccessible to humans. Only about 0.008% of Earth’s water occurs in freshwater lakes, wetlands and rivers. The well-being of humanity is highly dependent on the quality and availability of, and the ecological processes and ecosystem services supported by, this tiny fraction of water. Surely this freshwater fraction must be the most precious natural resource on Earth. If so, then surely the ‘infrastructure’ (e.g. wetlands, riparian zones, river channels) that supports the provisions of this resource and its many ecosystem services should be maintained with great care. Unfortunately, freshwater-based ecological infrastructure has already deteriorated to critical levels, worldwide and in South Africa.
2
Garth Adams
From: DE WET STEYN [[email protected]] Sent: 14 September 2014 10:02 PM To: Garth Adams Subject: Re: Registrasie
Dear mister Adams, Can you please tell me the route that the pipeline will follow from Vredenburg sewage farm to Elandsfontein? We own some of the property between Vredenburg and Elandsfontein.
Regaurds De Wet Steyn for Steyn Brothers.
On Mon, Sep 8, 2014 at 10:37 AM, Garth Adams < [email protected] > wrote:
Dear Mr Steyn
You have been added as an Interested and Affected Party to this project and will receive all communication regarding this project in the future.
The latest documents in this application process namely the Environmental Management Programme is now available for downloading from our website.
They are available at www.braafsa.com or can be viewed at the Hopefield, Vredenburg, Saldanha or Langebaan Public Libraries.
Regards
Garth
1