BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE
STRATEGY REPORT – SOUTHERN SITE
DECEMBER 2020
VERSION 2
DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03
DOCUMENT CONTROL
BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC PROJECT ZONE REPORT TITLE STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
DATE DECEMBER 2020
REPORT NO 20MC-MMSEZ-BIOD-03
PROJECT TEAM
THE FOLLOWING PERSONNEL HAVE AUTHORED AND REVIEWED THIS DOCUMENT:
ROLE NAME DESIGNATION MS. AYANDA ZIDE BIODIVERSITY SPECIALIST
AUTHORS DR OLA AKINSHIPE ENVIRONMENTAL SPECIALIST
MR. MPHO RAMALIVHANA ECOLOGIST AND BIODIVERSITY SPECIALIST
REVISION RECORD
DATE STATUS DESCRIPTION 24TH AUGUST 2020 VERSION 1A ISSUED FOR INTERNAL REVIEW
25TH AUGUST 2020 VERSION 1B ISSUED FOR COMMENTS
RESTRUCTURE, EXPANSION OF SCOPE AND INCORPORATION OF 25TH NOVEMBER 2020 VERSION 2A INITIAL PUBLIC COMMENTS
6TH DECEMBER 2020 VERSION 2B ISSUED FOR PUBLIC INPUT
MMSEZ APPROVAL AND SIGNOFF
APPROVED BY RESPONSIBILITY SIGNATURE DATE APPROVED
DISCLAIMER:
WHILST ALL CARE HAS BEEN TAKEN BY MAMADI & COMPANY SA (PTY) LTD IN THE PREPARATION OF THE OPINIONS, FORECASTS AND INFORMATION
CONTAINED IN THIS DOCUMENT, MAMADI DOES NOT ASSUME LIABILITY FOR ANY LOSSES ARISING FROM INCORRECT OR UNCONTROLLED USE OF THIS
REPORT AND SERIES OF REPORTS.
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03
TABLE OF CONTENTS
TABLE OF CONTENTS ...... 3
INTRODUCTION ...... 11
PROJECT DESCRIPTION ...... 12
Objective and Scope of Work ...... 16 Assumptions, Limitations and Gaps in Information ...... 17
STUDY APPROACH AND REGULATORY FRAMEWORK ...... 18
Approach to the Study ...... 18 Regulatory Framework and Policy Review ...... 18
OFFSET FRAMEWORK AND DESIGN ...... 29
Goal of the Offset...... 29 Framework for Offset Design and Implementation ...... 29
SPATIAL PLANNING TOOLS (REGIONAL AND LOCAL CONTEXT) ...... 34
Focus Areas and South African Protected Areas ...... 34 Vhembe Biosphere Reserve ...... 36 5.2.1 Important Bird Areas ...... 36 Limpopo Conservation Plan ...... 40 Vhembe Bioregional Plan ...... 43
ENVIRONMENTAL ATTRIBUTES AT MMSEZ ...... 44 Climatic Conditions ...... 44 Land-use and cover ...... 44 Topography and Drainage ...... 46
BIODIVERSITY FEATURES AT MMSEZ ...... 49
Flora ...... 49 7.1.1 Regional Vegetation ...... 49 7.1.2 Limpopo Ridge Bushveld (SVmp 2) ...... 49 7.1.3 Musina Mopane Bushveld (SVmp 1) ...... 49 7.1.4 Vegetation Communities ...... 51 7.1.5 Alien invasive and Bush Encroaching Species ...... 55 Fauna ...... 56
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03
7.2.1 Mammals ...... 56 7.2.2 Avi-fauna ...... 57 7.2.3 Herpetofauna ...... 57 7.2.4 Invertebrates ...... 57 Ecosystem Goods and Services ...... 58
ASSESSMENT OF ALTERNATIVES ...... 59
SENSITIVITY ...... 60
Adequacy of the Proposed Mitigation Measures ...... 61 Assessment of Residual Impacts ...... 79
BIODIVERSITY STRATEGY FOR THE MMSEZ ...... 81
Setting Biodiversity Offset Goals and Objectives ...... 81 Biodiversity Offset Requirements ...... 81 Wetland Offset Requirements ...... 87 Wetland functionality target ...... 88 Ecosystem Conservation ...... 89 10.5.1 Species of Conservation Target ...... 93 10.5.2 Botanical SCC ...... 93 10.5.3 Fish SCC ...... 95 10.5.4 Avifaunal SCC ...... 96 10.5.5 Herpetofauna SCC ...... 97 10.5.6 Mammal SCC ...... 98 Identification of Potential Offset Areas ...... 100 10.6.1 Site option 1: Offsetting on the Southern Section of the MMSEZ study area ...... 100 10.6.2 Site Option 2: Offsetting on the North Site of the MMSEZ...... 103 10.6.3 Option 3: Offsetting on the North Site of the MMSEZ...... 106 Summary on Offset Site ...... 110
MANAGEMENT, MONITORING AND EVALUATION SYSTEMS ...... 111 Stakeholder Engagement Process for Proposed Offset Site ...... 111 Roles and Responsibilities for Offset Implementation ...... 113 Offset Enforcement ...... 113 Offset Monitoring and Evaluation ...... 114 Auditing and Verification ...... 114
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Offset Area Proclamation ...... 114 Mechanism For Funding the Offset ...... 115 11.7.1 Funding Options ...... 115 11.7.2 Funding Instruments ...... 115 Community Involvement and Research ...... 117 Building Sustainability and Societal Benefits into the Offset Funding Programme ...... 117
BIODIVERSITY OFFSET FINANCIAL PROVISION ...... 119
RECOMMENDATIONS ...... 123
REFERENCES ...... 126
DETAILS OF THE AUTHORS ...... 130 LIST OF TABLES
Table 2.1: Proposed Activities for phase two of the proposed MMSEZ ...... 12 Table 3.1: Applicable laws and regulations informing and directing Biodiversity Offsets ...... 19 Table 4.1: Offset mitigation hierarchy (DEA, 2017) ...... 31 Table 5.1: Key Biodiversity Species found in the Soutpansberg IBA and their likelihood of occurring in the MMSEZ study area ...... 39 Table 7.1: Threats to protected trees occurring in the MMSEZ study area...... 52 Table 7.2: Distribution of the four Tree species, “other”, “unclassified” areas using remote sensing. ... 55 Table 9.1: Impacts ratings, mitigation measures as per the various specialist reports that are associated with biodiversity...... 63 Table 9.2: Residual Impacts associated with the proposed MMSEZ project relevant to biodiversity offsetting...... 79 Table 10.1: Guidelines of appropriate offset ratios based on the impacted biodiversity feature provided by (DEA, 2017)...... 82 Table 10.2: Determining the adjustment factor/multiplier to determine the biodiversity offset area required for the MMSEZ study area...... 83 Table 10.3: Determining the adjustment factor/multiplier to determine the biodiversity offset area required for the MMSEZ study area...... 86 Table 10.4: Variables used to Calculate the Wetland Offset. Spreadsheet with Calculation has been added...... 92 Table 10.5: Tree Species of Conservation Concern on proposed SEZ project area...... 93
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REPORT NO 20MC-MMSEZ-BIOD-03
Table 10.6 Fish Species of Conservation Concern on proposed SEZ project area...... 95 Table 10.7: Bird Species of Conservation Concern on proposed SEZ project area...... 96 Table 10.8: Herpetofauna Species of Conservation Concern that occur in the region of the SEZ project area...... 97 Table 10.9: Herpetofauna Species of Conservation Concern that occur in the region of the SEZ project area...... 98 Table 12.1: Projected cost of acquiring, securing, rehabilitating and managing the offset site(s) (if half of the land area required for offset is already owned by MMSEZ and earmarked for offsetting or conservation) ...... 120
LIST OF FIGURES
Figure 2.1: Proposed Infrastructure Layout, with zone number for the MMSEZ as per the Master plan.13 Figure 2.2: Musina-Makhado SEZ Locality (Southern site) ...... 15 Figure 4.1: The mitigation hierarchy matrix for Biodiversity Offsets utilized for MMSEZ (Business and Biodiversity Offsets Programme, 2009)...... 32 Figure 4.2: Approach towards developing the biodiversity offset strategy for the MMSEZ ...... 33 Figure 5.1: NPAES Focus Area (Blouberg Langjan) and various Protected Areas found in the surrounding areas of the MMSEZ study area...... 35 Figure 5.2: Important Bird Areas (IBAs) in the surrounding areas of the MMSEZ study area...... 37 Figure 5.3: Vegetation and NFEPA rivers found to occur in the Soutpansberg IBA in the surrounding areas of the MMSEZ study area...... 38 Figure 5.4: CBA, ESA and ONA classification according to the Limpopo Conservation Plan (2013). .... 41 Figure 6.1: GTI Land Cover (2014) of the proposed SEZ project area as mapped by DELTA (2019). .. 45 Figure 6.2: Indication of the natural vegetation dominating area ...... 45 Figure 6.3: NFEPA rivers and wetlands in the project area and surrounding areas. FEPA area falls within the study area. Drainage lines, pans, and dams (artificial impoundments) as delineated by the Freshwater Impact Assessment (Digby Wells, 2019)...... 47 Figure 6.4: Typical pans identified within the Project area (Digby Wells, 2019) ...... 48 Figure 7.1: Limpopo Ridge Bushveld and Musina Mopane Bushveld vegetation types occurring in the SEZ proposed project area (National Vegetation Map, 2012)...... 50
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03
Figure 7.2: Large Baobab (Adansonia digitata) (A) and Shepard Tree (Boscia albitrunca) (B) individuals found to occur in the project area...... 53 Figure 9.1: Sensitivity Map using the Flora and Fauna Impact Assessment (Digby Wells, 2019), Freshwater impact assessment (Digby Wells, 2019), 500 m added to the pans/wetlands...... 61 Figure 10.1 Pans delineated by the Freshwater Assessment for the proposed SEZ project area (Digby Wells, 2019). A 500 m buffer has been added to each pan...... 88 Figure 10.2: Critical Biodiversity Areas of the pans delineated as per the Freshwater Assessment (Digby Wells, 2019) for the proposed SEZ project area (Limpopo Conservation Plan, 2013)...... 90 Figure 10.3: Pans occurring on the SEZ fall within the Musina Mopane Bushvelds and Limpopo Ridge Bushveld according to the National Vegetation Map (Mucina and Rutherford, 2012)...... 90 Figure 10.4: Proposed Site Option 1 occurs primarily the southern portion and a small portion in the northern portion of the MMSEZ study area...... 101 Figure 10.5: South African Protected Areas and NPAES Focus Area occurring in the surrounding areas of the North Site MMSEZ...... 103 Figure 10.6 South African Protected Areas and NPAES Focus Area occurring in the surrounding areas of the North Site MMSEZ ...... 104 Figure 10.7: South African Protected Areas and NPAES Focus Area occurring in the surrounding areas of the North Site MMSEZ ...... 104 Figure 10.8: NFEPA Rivers and Wetlands occurring the North Site MMSEZ ...... 105 Figure 10.9: Site Option three, showing Farm portion numbers, vegetation types, and proximity to MMSEZ study area , protected areas and Focus area...... 107 Figure 10.10: CBA areas , NFEPA rivers and wetlands found in Site Option 3 area...... 108 Figure 11.1: Stakeholder engagement management ...... 112 Figure 11.2: Stakeholder analysis and classification based on influence ...... 113
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
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REQUIREMENTS FOR BIODIVERSITY OFFSET REPORTS
Minimum requirements for information included in a Biodiversity Offset Report as outlined in the Page/section Biodiversity Offset Policy Guideline: An evaluation of the adequacy of measures considered and adopted to avoid, minimize and rehabilitate Chapter 5, 7 and 10 potentially significant negative impacts on biodiversity. (That is, were these measures sufficient; were reasonable and feasible alternative measures investigated, or could greater effort have been made particularly to avoid and minimize these impacts?) A clear statement regarding the appropriateness of considering biodiversity offsets in this case. (That is, Chapter 3.2, 9.2 are there any residual impacts of ‘very high’ significance that could lead to irreplaceable loss of biodiversity and/ or priority ecosystem services?). A reliable measure of residual negative impacts on significant biodiversity and ecosystem services Chapter 5, 7 and 10 requiring offsets. • It must take into account gaps in information or low levels of confidence in the predicted negative impacts. • It must give due consideration to uncertainties or low levels of confidence in the outcome of proposed measures to avoid, minimise and/ or rehabilitate negative impacts. The duration of residual negative impacts of the proposed activity on biodiversity, taking a risk-averse Chapter 9.2 approach, to determine the minimum duration of the biodiversity offset(s). An explicit statement on the required size of the biodiversity offset to remedy these residual negative Chapter 10.6 impacts, applying the basic offset ratio and adjustments as appropriate. A description of the offset options considered (like for like habitat, trading up, or other), giving defensible Chapter 9 (9.1.1) reasons for arriving at the proposed offset type Where the proposed offset comprises land to be secured and managed: Chapter 10.6 a) Evaluation of the probable availability of suitable offset site(s) in the surrounding landscape to meet Chapter 10.6 offset requirements. b) Description of potential site(s) for biodiversity offset(s). Chapter 10.6 c) Description of stakeholder engagement process in identifying and evaluating the adequacy and Chapter 11.1 acceptability of the proposed offset site. d) Description of proposed approach to securing the offset site(s) (e.g. conservation servitude, protected Chapter 10.6, 11 area consolidation/ stewardship) and how it would be managed. e) Evaluation of probable adequacy of proposed offset site(s) by biodiversity specialist(s) and, where Chapter 11 relevant, a social/ livelihood specialist: Is there a high level of confidence that offset site(s) would remedy residual impacts on a) biodiversity pattern (threatened ecosystems, threatened species and special habitats), b) biodiversity process, and c) on ecosystem services, while making a positive contribution to the long term conservation of biodiversity in the South Africa? ) • Would the offset sites be located in recognised ‘offset receiving areas’? • If relevant, is the motivation for a ‘trading up’ offset defensible in the specific context?
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03
• Would the offset site(s) be functionally viable in the long term? f) A reliable estimate of the costs of acquiring or securing, rehabilitating and managing the necessary Chapter 12 offset site(s) for the duration of residual negative impacts;
Responsibility for managing, monitoring and auditing the biodiversity offset; • Who would be responsible for implementing, managing and auditing the biodiversity offset? • Statement regarding the adequacy of capacity of the institution, organization or other party to meet obligations in terms of above responsibilities; agent?) h) What measures would be taken to ensure that society as a whole, and affected communities in Chapter 11, 13 particular, would not be left more vulnerable or less resilient as a consequence of the proposed development [i.e. where offsets are to remedy loss of biodiversity underpinning valued ecosystem services, would the proposed offset(s) be affordable, accessible and acceptable to the main affected parties]; • Any negative impacts on local communities and/or society as a whole as a consequence of the proposed offset. If yes, how would these negative impacts be avoided; • Would the proposed use of the biodiversity offset site(s) be compatible with biodiversity conservation objectives? In particular, where an offset for residual negative impacts on biodiversity also provides offsets for residual impacts on ecosystem services, assurance must be provided that the latter would not compromise the biodiversity value of that offset (e.g. if biodiversity is to be a direct-use resource, then use could lead to degradation of that biodiversity / ecosystem). i) What mechanism is to be used to provide sufficient funds for acquiring/ securing and managing the Chapter 11.6 biodiversity offset site(s) for the duration of residual negative impacts of the proposed activity (i.e. Who will be the recipient of money? How will funds flow to the implementing
ABBREVIATIONS AND ACRONYMS
ADU Animal Demographic Unit
BAP Biodiversity Action Plan
BBOP Business and Biodiversity Offsets Programme
BIOFIN The Biodiversity Finance Plan
BPO Best Practicable Offset
CBA Critical biodiversity areas
CITES Convention on International Trade in Endangered Species
DAFF Department of Agriculture Forestry and Fisheries
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
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DEA Department of Environmental Affairs
DEFF Department of Environment Forestry and Fisheries
ESA Ecological Support Areas
FEPA The Freshwater Ecosystem Priority Areas
IBA Important Bird Area
IUCN The International Union for Conservation of Nature
LEMA Limpopo Environmental Management Act
MMSEZ Musina Makhado Special Economic Zone
NAPAES The National Protected Area Expansion Strategy
NBA National Biodiversity Assessment
NBF National Biodiversity Framework
NBSAP National Biodiversity Strategy and Action Plan
NDP National Development Plan
NEM:BA National Environmental Management: Biodiversity Act
NEM:PAA National Environment Management Protection Areas Act
NFA National Forest Act
NFEPA The National Freshwater Ecosystem Priority Areas
NPAES National Protected Areas Expansion Strategy
NSBA National Spatial Biodiversity Assessment
NWA National Water Act
ONA Other Natural Areas
SANBI South African National Biodiversity Institute
SAPAD South African Protected Areas Data
SCC Species of Conservation Concern
WULA Water Use License Application
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
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INTRODUCTION
Limpopo Economic Development Agency (LEDA) proposes to develop a Special Economic Zone which overlaps the Makhado and Musina Local Municipalities. The proposed Musina-Makhado SEZ (MMSEZ) will be specifically designated to focus on energy and metallurgical processing, agro-processing, petrochemical, and logistics. This SEZ will compromise of a connected pipeline of a minimum of eight catalytic projects. It will be established across eight farms.
Currently, the project is subjected to an environmental assessment process in accordance with the National Environmental Management Act, 1998 and the EIA regulations of 2017 as amended. The present phase of this project is the setting up of the SEZ, which triggers Activity 15 listed in GN R325 (Listing Notice 2) for the clearance of more than 20 ha of indigenous vegetation. The setting up of the SEZ involves changing its current land use from agricultural/game farming to an industrial zone. The SEZ will provide space which various individual businesses would have to apply for space and thus the final layout of the SEZ will be dependent on the outcome of the various Basic Assessments or Environmental Assessment that will be conducted as a result of the various activities. Thus for this current impact assessments, the specialist studies have evaluated based on the target activities that are proposed for the SEZ, these include a Coal Power Plant; Coke Plant; Ferrochromium Plant; Ferromanganese Plant; Pig Iron Plant; Carbon Steel Plant; Stainless Steel Plant; Lime Plant; Silicon-Manganese Plant; Metal Silicon Plant and Calcium Carbide Plant.
The Fauna and Flora Assessment has recommended the use of Biodiversity offsetting to further mitigate the potentially moderate to high significance rating post mitigation measures. The DEA (2017) also requires that residual impacts ranging from medium to high require biodiversity offsetting.
Mamadi and Company SA (Pty) Ltd has been appointed by Limpopo Economic Development Agency to develop a biodiversity offset strategy for the Project to ensure that the biodiversity loss as a result of residual impacts within the proposed site is compensated.
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
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PROJECT DESCRIPTION
The MMSEZ is made up of two sites and hosted by two municipalities namely, Musina and Makhado located in the Vhembe district of the Limpopo Province. The first site is referred to as North Site (Antonvilla) approximately 3900 HA and it is situated between the Musina town and Limpopo riverbanks. This site is earmarked for the development of light and medium manufacturing industries, which includes logistics and agro-processing. The second site is commonly referred to as the South Site (Mopani) approximately 8000 HA, and it is situated next to the Mopani railway station on the west side of the Baobab Toll Gate, at the border of both Musina and Makhado Municipalities.
This proposed project is earmarked for the development of the energy and metallurgical cluster and other associated heavy industries. Among the targeted industrials projects are those listed in Table 2.1, which are predominantly heavy (noxious) industrial plants, their footprint and zone are also provided. Figure 2.1 shows a schematic illustration of the proposed layout for the proposed MMSEZ, the layout as per the Master plan. Table 2.1: Proposed Activities for phase two of the proposed MMSEZ
Activity Area (ha) Zone Thermal power plant (and ash yard) 600 1 Coal Washery 110 2 Coke Plant 420 3 High Vanadium Steel 130 4 High Manganese steel 280 5 Ferromanganese Plant 100 6 Silicon-Manganese Plant 100 7 Domestic waste transfer area 4 8 Cement Plant 108 9 Refractories Plant 30 10 Stainless Steel Plant 300 11 Ferrochromium Plant 500 12 Lime Plant 160 13 Vanadium – Titanium Magnetite Project 1000 14 SEZ Administrative Centre 110 15 Logistics Centre 50 16 Bonded Area 300 17
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Activity Area (ha) Zone Machinery Zone 400 18 Light Industrial Processing Zone 400 19 Sewage Treatment Plant 20 20 Water Treatment Plant 10 21 Environmental Conservation 2020 22 Fuel Storage Facility 6 23 Gas Storage Facility 2 24 Reservoirs TBC 25 Visitors guest lodge TBC 26 Existing dolomite mine 66 27
NOTE: TBC means “to be confirmed”
Figure 2.1: Proposed Infrastructure Layout, with zone number for the MMSEZ as per the Master plan.
The proposed MMSEZ will be located across the Musina and Makhado local municipalities which fall under the Vhembe District Municipality in the Limpopo Province. The nearest towns are Makhado (which
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03 is located approximately 31 km south) and Musina (located 36 km north) of the proposed SEZ site. A locality map of the site is provided in Figure 2.2.
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Figure 2.2: Musina-Makhado SEZ Locality (Southern site)
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OBJECTIVE AND SCOPE OF WORK
The main purpose of this study is to develop a biodiversity (including wetland) offset strategy as part of the environmental impact assessment to assist Musina Makhado SEZ in its pursuit of sustainable development.
The scope and extent of work for the Project as provided by MMSEZ are outlined as follows: • Review of existing studies (Biodiversity Study Reports) and literature; • Review other EIA Specialist studies conducted; • Undertaking of updated baseline assessments; • Using the information to compile a collated baseline assessment of terrestrial biodiversity, biomass, wetlands, habitat, ecosystem services and sensitive features of the proposed development sites. • The collated assessment will include but not be restricted to: o Verification of the extent of direct and indirect impact on various biodiversity features within the development site. The degree of impact must be translated into impacted locale footprint measured in hectares; o Evaluation of ecosystem services impacted by the development; and o Affirmation and /or adjustment of potential impacts and potential losses to biodiversity and wetlands. o Contribute to the determination of offset necessities for impacts on biomass, habitat, fauna, ecosystems, and sensitive features in terms of the Draft National Biodiversity Offset Policy; o Contribute to the purpose of offset requirements for impacts on wetlands. o Categorize potentially suitable offset receiving opportunities and/or areas/sites within the SEZ footprint area; o From a desktop investigation the identification of 2 to 3 aspirant areas outside of the SEZ footprint area that could be considered for offset opportunities. This will be supported by an inspection of the identified areas to assess at a high level the suitability of these areas; o Compile an offset analysis report incorporating baseline evaluation offset necessities, and investigation of suitable offset receiving areas; and
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o Compilation of an offset strategy for the proposed SEZ sites, in deliberation of offset opportunities identified within the SEZ sites and the 2 to 3 aspirant areas outside of the SEZ sites.
ASSUMPTIONS, LIMITATIONS AND GAPS IN INFORMATION
The following assumptions, limitations, and gaps in information should be noted regarding the study: • Significant aspects of the information regarding the study was sourced from technical reports and specialist assessment conducted by third-party in 2019 and 2020. While every effort was made to verify the information obtained, it is however assumed that all information and data obtained from third-party specialist are valid (citations of sourced information and data are adequately provided). • Data deficiency on accurate population numbers of certain species are noted and therefore provides an uncertainty in determining the actual biodiversity metrics for specific species or features. • A direct extrapolation from the surveyed area to the entire site was made when quantifying population count for flora and fauna species. The gap in data provides an uncertainty in determining the actual population count for flora and fauna species. • There are still outstanding reports that provide input into this biodiversity offset strategy that need to be taken into consideration prior to agreements and finalisation of the offset area. These include: ▪ Avifaunal Assessment ▪ Flora and Faunal Assessment ▪ Climate change Assessment ▪ Final Air Quality Assessment ▪ An updated hydrological Assessment/ Final Water Report • Additional information regarding limitations and gaps in information are provided within this document wherever contexts are relevant.
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STUDY APPROACH AND REGULATORY FRAMEWORK
APPROACH TO THE STUDY
The approach applied in undertaking the offset strategy is as follows:
1. A comprehensive review of the existing biodiversity study reports, literature and specialist studies conducted for the environmental authorization was undertaken. This evaluation set the tone for the Strategy and presented a baseline for the study area. 2. Relevant information was sourced from the Limpopo Economic Development Agency regarding previous studies conducted: a. the review of the biodiversity report and the Freshwater impact report – both compiled by Digby Wells; and b. the review of the protected trees survey for the proposed Musina – Makhado Special Economic Zone compiled by The Biodiversity Company. c. review of various regulations and policies that informs biodiversity offsets 3. A site visit was undertaken to identify and verify biodiversity features on site (including critical habitat, natural habitat, and priority biodiversity features). 4. The compilation of a biodiversity strategy report detailing suitable offsets for unavoidable losses of vegetation and habitat incurred during construction and operation of MMSEZ.
REGULATORY FRAMEWORK AND POLICY REVIEW
A review of regulations and policies that informs and directs biodiversity offsets and ground-truthing is presented in Table 3.1. These regulations and policies apply to direct and/ or indirect biodiversity offset measures and other compensatory measures.
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Table 3.1: Applicable laws and regulations informing and directing Biodiversity Offsets Regulations/ Policies Brief Description Relevance to proposed MMSEZ Constitution of the Republic of South “everyone has the right to have the environment protected, for the benefit of - MMSEZ is alleged to have the potential to promote Africa, 1996, article 24 (b) – (c) present and future generations, through reasonable legislative and other economic and social development. measures that prevent pollution and ecological degradation; promote - Impact assessments have been conducted to conservation; and secure ecologically sustainable development and use of determine all possible impacts by MMSEZ and natural resources while promoting justifiable economic and social development” provide mitigation measures and recommendation that will promote the prevention of pollution, ecological degradation, and sustainable development. This is to ensure that the economic and social development does not come at the expense of the environment. - Residual impacts range from Moderate to High, thus Biodiversity Offset aims to incorporate measures to compensate for the loss and attempt to achieve sustainable development, promote conservation through the improvement and protection of biodiversity in the offset area. - This aim of this process is to achieve sustainable development. National Environmental Management The National Environmental Management Act,1998 (Act 107, 1998) states in The MMSEZ biodiversity offsets objective is to remedy the Act, 1998 (Act No. 107 of 1998) section 2(4)(k) that The environment is held in public trust for the people, the loss of biological diversity after impacts have been beneficial use of resources must serve the public interest and the environment avoided and minimised by the application of offset must be protected as the people’s common heritage. activities and avoiding unnecessary disturbance.
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Regulations/ Policies Brief Description Relevance to proposed MMSEZ Section 2(4)(a) (‘the NEMA principles’) specifies that sustainable development requires the consideration of all relevant factors including the following: The offset strategy attempts to provide an estimation of - that the disturbance of ecosystems and loss of biological diversity are the costs that may be incurred as a result of the avoided, or, where they cannot be altogether avoided, are minimised implementation, management and audit of the offset area. and remedied; This will be on the onus of MMSEZ and should be agreed - that the development, use and exploitation of renewable resources and upon as a condition of the EIA authorisation, should it be the ecosystems of which they are part do not exceed the level beyond granted. which their integrity is jeopardised; - that a risk-averse and cautious approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions - that negative impacts on the environment and on people’s environmental rights be anticipated and prevented, and where they cannot be altogether prevented, are minimised and remedied; and - that equitable access to environmental resources, benefits and services be pursued to meet basic human needs and ensure well- being. Special measures may be taken to ensure access by categories of persons disadvantaged by unfair discrimination.
Section 2(4)(p) states that the costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment.
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Regulations/ Policies Brief Description Relevance to proposed MMSEZ
National Environmental Management: The objectives of this Act are within the framework of the National Environmental - No Tops plant species were found to occur Biodiversity Act, Management Act, include: during the assessment, but these could be 2004 (Act No. 10 of 2004) - The management and conservation of biological diversity within the found on the MMSEZ study area during ground- Republic of South Africa and the components of such biological truthing prior to the construction. diversity o Thus, relevant permits would need to - Protection of species and ecosystem be obtained prior to their removal. - The use of indigenous biological resources in a sustainable18 manner; - Ten Alien invasive species were found to occur in the and project area, with 5 alien species falling under category 1b - Giving effect to ratified international agreements relating to biodiversity of the NEM:BA. The five other species are indicators of which are binding on the Republic. bush encroachment (Digby Wells, 2019). The Act, amongst others, provides the framework for biodiversity management - Alien invasive species on the MMSEZ study and planning, comprising a national biodiversity framework, bioregions and area should be eradicated and controlled bioregional plans, and biodiversity management plans and agreements. according to the Alien Invasive Management Threatened and protected ecosystems (section 52) have been listed (December Plan. 2011) and activities or processes within those ecosystems may be listed as ‘threatening processes’, thus triggering the need to comply with the NEMA EIA regulations. Lists of critically endangered, endangered, vulnerable and protected species have also been promulgated in terms of this Act (2007), covering species affected by ‘restricted’ activities; effectively those species hunted, bred or traded for economic gain. In addition, regulations addressing alien and invasive species and their management/ control were promulgated in 2014.
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Regulations/ Policies Brief Description Relevance to proposed MMSEZ The Act further provides (section 43) for ‘biodiversity management plans’ approved by the Minister to manage ecosystems or species that warrant special conservation attention. The Act establishes the South African National Biodiversity Institute (SANBI), with a range of functions and powers (Chapter 2 Part 1). National Environmental Management The objectives of this Act within the framework of the National Environmental No Protected Areas occur in the proposed MMSEZ area. Protected Areas Management Act, include the protection and conservation of ecologically viable Two protected areas occur in proximity of the MMSEZ, Act, 2003 (Act No.57 of 2003) areas representative of South Africa’s biological diversity and its natural which is the Baobab Private Nature reserve (~ 4,2 km) and landscapes and seascapes to: on the adjacent farm portions the Avarel Private Nature - Protect areas with significant natural features or biodiversity Reserve. - Protect areas in need of long-term protection for the provision of environmental goods and services It is anticipated that the approved offset area(s) for the - Provide for sustainable flow of natural products and services to meet MMSEZ would be proclaimed as a protected area. the needs of a local community involvement of private landowners. The Act provides for the involvement of parties other than organs of State in the declaration and management of protected areas. Conservation of Plants of alien origin may invade ecosystems and become problem plants in Alien and weed species found to occur in the MMSEZ Agricultural Resources Act areas away from their natural habitats. The mandate to combat invasive plants study area must be eradicated and controlled through the (Act 43 of 1983) (defined as ‘weeds and invader plants’) rests with this Act. Alien Invasive Management Plan. National Forests Act, 1998 (Act No. 84 According to the National Forests Act, 1998 (Act No.84 of 2014) in terms of Protected tree species occur in the proposed MMSEZ of 1998) section 15 (1) of the Forests Act,1998 (DAFF, 2014), no person may cut, disturb, project area, thus permits from Department of damage or destroy any protected tree or possess, collect, remove, transport, Environment, Forestry and Fisheries (previously export, purchase, sell, donate, or in any other manner acquire or dispose of any Department of Agriculture, Forestry and Fisheries (DAFF))
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REPORT NO 20MC-MMSEZ-BIOD-03
Regulations/ Policies Brief Description Relevance to proposed MMSEZ protected tree or any product derived from a protected tree, except under a would need to be applied for. No damage, destruction, license or exemption granted by the Minister to an applicant and subject to such removal etc may occur prior to these being granted. period and conditions as may be stipulated. Contravention of this declaration is To compensate for residual impacts due to MMSEZ, regarded as a first category offence. biodiversity offsets have been deemed necessary as the loss of species of conservation concern (SCC) impact is Offsets may be required where damage or loss is deemed significant moderate (negative) and thus significant. National Water Act (Act No 36 of 1998) Protection of water resources from pollution, Section 19 of the Act refers to the This Act is relevant as the proposed activities will have Prevention and remedying effects of pollution negative impacts on the watercourses found on the project area. - Pollution prevention, particularly, a situation where pollution of a water resource occurs or might occur due to activities on land. The person who 17 pans and drainage lines are situated in the proposed owns, controls, occupies, or uses the land in question is responsible for project area and will require mitigation measures to ensure taking measures to prevent pollution of water resources. If these measures that pollution is prevented and may require remedying of are not taken, the catchment management agency concerned may itself do the residual impacts. whatever is necessary to prevent the pollution or to remedy its effects, and to recover all reasonable costs from the persons responsible for the Section 21 is relevant to MMSEZ; thus a water use license pollution. application (WULA) will be required to be obtained prior to the construction activities commencing on the proposed General principles of the water use includes taking and storing water, activities MMSEZ. which reduce stream flow, waste discharges and disposals, controlled activities (activities which impact detrimentally on a water resource), altering a A waste management plan will need to be put in place for watercourse, removing water found underground for certain purposes, and the MMSEZ to ensure that the pollution of the watercourse recreation. In general a water use must be licensed unless it is listed in is prevented.
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REPORT NO 20MC-MMSEZ-BIOD-03
Regulations/ Policies Brief Description Relevance to proposed MMSEZ Schedule I, is an existing lawful use, is permissible under a general authorisation, or if a responsible authority waives the need for a licence. Spatial Planning and Land Use Sustainability and resilience principles apply to all aspects of spatial development The MMSEZ biodiversity offset strategy has been Management Act,2003 (Act No. 16 of planning, land development and land use management, specifically with developed to ensure sustainable development. 2013) reference to ensuring sustainable livelihoods in communities most likely to suffer the impacts of environmental shocks. Income Tax Inclusion of ‘conservation, rehabilitation or protection of the natural environment, This may be relevant to the MMSEZ as the proposed Act, 1962 (Act No. including flora, fauna or the biosphere’ as approved public benefit activities for offset area(s) (where offset activities are to be 58 of 1962) purposes of section18A (1) (a) of the Income Tax Act (GN 403 of 26 April 2006). implemented) will be used for conservation purposes. [In order to qualify as a ‘public benefit organisation’ under this Act and thus qualify for tax exemptions or reductions, the organisation must, amongst others, be a trust or association of persons, be incorporated under Section 21 of the Companies Act, register as a non-profit organisation under the Non-profit Organisations Act, and the organisation’s sole objective must be to carry on a ‘public benefit activity’.] Revenue Laws Amendment Insertion of section 37C into the Income Tax Act, 1962: “Deductions in respect of This may be relevant to the MMSEZ as the proposed Act,2008 (Act No. 60 of 2008) environmental conservation and maintenance”: offset area(s) (where offset activities are to be Tax relief for expenditure incurred by the taxpayer in conserving or maintaining implemented) will be used for conservation purposes. land that forms part of either (i) a biodiversity management agreement of at least 5 years’ duration in terms of s44 of the NEM Biodiversity Act, (ii) a declaration of at least 30 years’ duration in terms of s20, 23 or 28 of the NEM Protected Areas Act; or (iii) a national park or nature reserve in terms of an agreement under
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03
Regulations/ Policies Brief Description Relevance to proposed MMSEZ section 20(3) or 23(3) of the NEMPAA and the declaration has been endorsed on the title deed for a period of 99 years. Limpopo Environmental Management The Limpopo Environmental Management Act (LEMA) was compiled to Protected tree species (Adansonia digitata) under Act (Act no. 7 of 2003) (LEMA) consolidate and amend the environmental management of the Limpopo Province. schedule 12 was found to occur in the MMSEZ study area. This act includes regulations which call for the protection of indigenous plants More species maybe found in the area during the and animals which require a permit from the provincial authority for its picking, construction activities, thus relevant permits would have to selling, removal, donation, and/or export in the province. The list of protected be applied for. plants and animals are itemised under Schedule 8, 11 and 12.
Table 2: Applicable policies, plans and guidelines relevant to the MMSEZ Biodiversity Offsets Strategy Regulations/ Policies Brief Description Relevance to proposed MMSEZ Draft National Biodiversity Offset Policy Purposed of the Policy is to standardise the requirements for biodiversity Residual impacts for the proposed MMSEZ are medium to (2017) offsets in South Africa, thus ensuring that there is consistency in high. The Draft National Biodiversity Offset Policy was used approaches and implementation. to determine if the use of the biodiversity offsets would be This policy: suitable for the proposed MMSEZ. - Defines offsets; the purpose and desired outcomes of biodiversity offsets in the country; The Policy also provides the content and requirements that - Specifies when biodiversity offsets would and would not be should be included in the biodiversity offset report; these have appropriate; been included in this document. - Requires offsets to be considered as an integral part of the mitigation sequence during the planning of all EIAs conducted in terms of the NEMA EIA Regulations. It should therefore also apply to the following activities insofar as they trigger the NEMA EIA process:
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Regulations/ Policies Brief Description Relevance to proposed MMSEZ o changes in land use in terms of the Spatial Planning and Land Use Act, 2013 (Act No. 16 of 2013); and o other relevant planning and land use change legislation where proposed development may have a significant negative impact on the environment; - Sets out the legal framework and principles of offsets; - Specifies the requirements of the offset process in South Africa; - Sets standards and create consistency and predictability in the use of biodiversity offsets across the country.
National Climate Change Response Points to the need to conserve, rehabilitate and restore natural systems to This is relevant to the study in the sense that a well White Paper, 2011 (DEA, 2011). improve our resilience to climate change impacts and/ or to reduce impacts. implemented biodiversity offset has the potential to improve It also advocates expanding the protected area network where it improves the offset area, protect and conserve biodiversity features, resilience to climate change, and to manage threatened ecosystems and and improve the areas’ resilience to the impacts of climate species to minimize the risks of species extinction. change. Limpopo Conservation Plan Version 2 (C- Biodiversity plan provides two primary products namely the map of priority The MMSEZ study area occurs in the Ecological Supporting Plan 2) areas or Critical Biodiversity Areas (CBA) and guidelines for the associated Area 1 (ESA1) and Critical Biodiversity Area 2 (CBA 2). land-use planning and decision making. Wetlands offsets: A best-practice The guideline is primarily aimed at wetland offsets required as part of water The MMSEZ has the potential to negatively impact wetlands, guideline for South Africa, 2014 use authorization processes (e.g. in an application for a Water Use Licence even after the application of mitigation measures. As part of (Macfarlane, D., Holness, S.D., von Hase, under the National Water Act) where wetland offsets are significant to the EIA process, this guide has been used to calculate the A., Brownlie, S. & Dini, J., 2014). achieving water resource objectives, including both National Water offsetting area that may be required for the pans occurring in Resource the MMSEZ project site.
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Regulations/ Policies Brief Description Relevance to proposed MMSEZ Management and Water Resource Quality Objectives, through their use to ensure sustainable ecosystem functioning and use at a catchment level. The guideline is also relevant for use in environmental impact assessment (e.g. as part of an Environmental Impact Assessment process undertaken under the National Environmental Management Act or in an application for a mining licence or development of an Environmental Management Plan under the Mineral and Petroleum Resources Development Act). Buffer Zone Guidelines for Wetlands, The guideline provides tools to determine buffer zones which are intended This guideline was used to determine the buffer zones for the Rivers and Estuaries (Macfarlane and to be a preventative measure to avoid degradation of rivers, estuaries, and watercourses in the MMSEZ project area. The buffer zones Bredin, 2017) wetlands. The reduction in impacts to these aquatic resources also protects offer a mechanism for avoiding and minimising the negative the goods and services that they provide. impact associated with the proposed activities on the watercourses. The Biodiversity Finance Plan (BIOFIN) The overall aim of the Biodiversity Finance Plan is to ensure adequate Biodiversity offsets fall under the Protected Areas category funding of conservation and management interventions to protect and thus the BIOFIN is relevant to the MMSEZ Biodiversity maintain South Africa’s unique and valuable biodiversity. Based on a Strategy. The funding model for the MMSEZ biodiversity offset rigorous selection process and a systematic approach, the Plan proposes may utilize one of the BIOFIN finance solutions in offset land a set of 15 possible finance solutions which are vehicles for attaining acquisition (if needed), maintenance and management of sustainable development and creating jobs through strengthened offset activities. biodiversity conservation and management. The 15 solutions are clustered around three biodiversity outcomes, as follows:
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Regulations/ Policies Brief Description Relevance to proposed MMSEZ Protected areas: PA revenues; property rates reforms; revolving land trusts; biodiversity tax incentives; biodiversity offsets; and making the case for public funding of PAs. Ecosystem Restoration: government grants for ecological infrastructure; water tariffs; NRM value-added industries; global climate funding; carbon tax offsets; NRM land-user incentives. Sustainable Use: Tourism Conservation Funds; biodiversity-related fines and penalties; wildlife-ranching. The BIOFIN plan also provides concise technical proposals on how to operationalize the financial solutions and consolidated estimates of expected results.
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DOCUMENT TITLE BIODIVERSITY OFFSET STRATEGY FOR THE MUSINA MAKHADO SPECIAL ECONOMIC ZONE: STATUS QUO AND STRATEGY REPORT – SOUTHERN SITE
REPORT NO 20MC-MMSEZ-BIOD-03
OFFSET FRAMEWORK AND DESIGN
GOAL OF THE OFFSET
The goal of biodiversity offset for the MMSEZ is to achieve no net loss and preferably a net gain of biodiversity with respect to species composition, habitat structure, ecosystem function, use and cultural values associated with biodiversity in the Project area.
FRAMEWORK FOR OFFSET DESIGN AND IMPLEMENTATION
The following principles for designing and implementing biodiversity offsets and verifying their success have been considered in this strategy. The biodiversity offsets were designed to comply with all relevant regulation, with implementation plans and design set out in accordance with the Convention on biodiversity offsets, as articulated in the draft National Biodiversity Strategy and Action Plans. 1 No net loss: The biodiversity offset was designed to achieve measurable conservation outcomes that can reasonably be expected to result in no net loss and preferably a net gain of biodiversity (where possible). Offset liabilities of each biodiversity feature were assessed against the most stringent requirement (worst case scenario). 2 Additional conservation outcomes: The biodiversity offset was designed to achieve conservation outcomes above and beyond results that would have occurred if the offset had not taken place. 3 Adherence to the mitigation hierarchy: The biodiversity offset was designed as a commitment to compensate for significant residual adverse impacts on biodiversity identified after appropriate avoidance, minimization and on-site rehabilitation measures have been taken according to the mitigation hierarchy. 4 Limits to what can be offset: There maybe situations where residual impacts cannot be fully compensated for by a biodiversity offset because of the irreplaceability or vulnerability of the biodiversity affected. This has been given due consideration in the strategy 5 Landscape context: The biodiversity offset was designed considering the landscape context of the area to achieve the expected measurable conservation outcomes considering available information on the full range of biological, social, and cultural values of biodiversity and supporting an ecosystem approach.
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6 Stakeholder participation: In developing the strategy, stakeholder participation, as part of the environmental authorization and specialist studies for the project, was considered. Further protocol for stakeholder engagement in implementing biodiversity offset at an off-site location was considered. 7 Equity: The biodiversity offset was designed in an equitable manner, which means the sharing among stakeholders of the rights and responsibilities, risks and rewards associated with a project and offset in a fair and balanced way, respecting legal and customary arrangements as well as recognized rights of indigenous peoples and local communities. 8 Long-term outcomes: The design and implementation of the biodiversity offset was based on an adaptive management approach, incorporating monitoring and evaluation, with the objective of securing outcomes that last as long as the project’s impacts and preferably in perpetuity. 9 Establishing ‘like-for-like’ (in-kind) conservation outcomes: The impact and offset areas must be compared in the field with respect to current and similar vegetation patterns. The rationale is that in situations of similar impact and land use, a similar (or dissimilar) remnant vegetation composition and structure or similar (or dissimilar) ‘reaction’ to the impact would indicate that the original state in both areas was likely similar (or dissimilar). Survey element included landscape position, land use history, vegetation structure, dominant woody and grass species, alien species etc.
The design of the MMSEZ biodiversity offset is based on the mitigation hierarchy published in the Draft National Biodiversity Offset Policy, 2017, depicted in Table 4.1.
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Table 4.1: Offset mitigation hierarchy (DEA, 2017)
The hierarchy considers the following steps: • “Avoid or prevent” – is aimed at considering options in project location, siting, scale, layout, technology, and phasing to avoid or prevent impacts on biodiversity features and ecosystem services in the area. Where this is not possible, the “minimize” option is considered. • “Minimize” – is aimed at considering options in project location, siting, scale, layout, technology, and phasing to reduce impacts on biodiversity features and ecosystem services in the area. Where this is inadequate, the “rehabilitate” option is considered. • “Rehabilitate” – is aimed at providing measures to restore impacted areas to near-natural state or pre-development state. However, should rehabilitation measures fall short or be deemed to fall short of replicating the diversity and complexity of a natural system, then “offset” option is considered as a last resort. • “Offset” – is aimed at providing measures over and above rehabilitation that will compensate for the residual effects on biodiversity after every effort has been made to minimize and rehabilitate impacts.
The matrix for assessing offset mitigation hierarchy to ensure biodiversity offset gains are achieved is presented in Figure 4.1. In designing and implementing the biodiversity offset for the MMSEZ, the steps
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REPORT NO 20MC-MMSEZ-BIOD-03 highlighted in Figure 4.2 was followed. These steps were undertaken as part of this study or adopted from specialist studies conducted as part of the environmental authorization process.
Figure 4.1: The mitigation hierarchy matrix for Biodiversity Offsets utilized for MMSEZ (Business and Biodiversity Offsets Programme, 2009).
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Figure 4.2: Approach towards developing the biodiversity offset strategy for the MMSEZ
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REPORT NO 20MC-MMSEZ-BIOD-03
SPATIAL PLANNING TOOLS (REGIONAL AND LOCAL CONTEXT)
FOCUS AREAS AND SOUTH AFRICAN PROTECTED AREAS
Focus Areas are areas of high importance, identified for protected area expansion as these would contribute to meeting national biodiversity targets. The National Protected Area Expansion Strategy (NAPAES, 2009) has identified 42 Focus areas for land-based protected area expansion, these areas have been identified through detailed ecosystem level targets The NAPAES has a 20-year target, as seen in Figure 5.1, newer Protected Areas such as Baobab Private Nature Reserve and Musina Nature Reserve occur in the Blouberg Langjan Focus Area thus contributing to the set out targets for this area. The Blouberg Langjan Focus Area lies about 7.5 km away from the proposed MMSEZ study area.
NAPAES (2009) updated the spatial data layer of Protected Areas of the National Spatial Biodiversity Assessment (NSBA, 2004); in 2008, about 3.6% of the Limpopo Province was classified as Protected Areas and Conservation Areas. These have since been updated on the South African Protected Areas Data (SAPAD) provided by DEFF. Currently there are five Protected areas in the vicinity of the proposed MMSEZ, namely; Baobab Private Nature Reserve (~ 4,6 km), Musina Nature Reserve (~ 26,8 km), Honnet Nature Reserve (~ 24,2 6 km), Nzhelele Nature Reserve (~ 19,4 km) and the Avarel Private Nature Reserve, adjacent to the project area (~ 0 km).
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Figure 5.1: NPAES Focus Area (Blouberg Langjan) and various Protected Areas found in the surrounding areas of the MMSEZ study area.
Comment regarding application of the mitigation hierarchy: Avoid, Mitigate, Rehabilitate or Restore: - The MMSEZ site does not occur in a Focus Area, or a Protected Area, but does occur near these areas. Development in a Protected area and Focus area should be avoided. - The occurrence of the proposed MMSEZ near the Avarel Protected Area may negatively affect the area, with regards to indirect or residual impacts that affect a region such as increase in noise, air pollution and climate change impacts etc. Biodiversity Offset: - The expansion of protected areas has been shown to increase conservation and biodiversity. Thus, the MMSEZ offset plan could target these Focus areas which has already been set out by the NPAES. The suitability of this area and whether it would achieve the objectives of the MMSEZ Biodiversity Offset strategy is investigated in subsequent chapters.
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REPORT NO 20MC-MMSEZ-BIOD-03
VHEMBE BIOSPHERE RESERVE
The Vhembe Biosphere Reserve covers 3,037,590 ha, with core areas classified as protected areas, including national parks, nature reserves, world heritage sites and Ramasar site which are used for conserving biological diversity, monitoring minimally disturbed ecosystems, undertaking non-destructive research and low impact uses such as education. These areas are generally surrounded by buffer zones and transitional areas. Core areas found in the Vhembe Biosphere Reserve includes the Northern Part of the Kruger National Park, Mapungubwe National Park, Makgabeng Plateau (National Heritage Site) and Several Provincial Nature Reserve.
5.2.1 IMPORTANT BIRD AREAS
The Important Bird Areas (IBA) programme identifies and works to conserve a network of sites that are critical for the long-term survival of bird species that are globally threatened, have restricted range, and are restricted to specific biomes/vegetation types or sites that have a significant population.
A few IBAs are found in the surrounding areas of the MMSEZ (Figure 5.2), these include the Soutpansberg, situated 7 km from the MMSEZ site; the Mapungubwe (~ 56 km away), Blouberg (~ 78 km away) and Kruger National Park (~ 110 km away).
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Figure 5.2: Important Bird Areas (IBAs) in the surrounding areas of the MMSEZ study area.
The Southpansberg IBA covers 260 000 ha (Figure 5.3), featuring a number of rivers including the Sand river and Mutale river, has thick forest vegetation in the valley and basins, protea woodland and bushveld on the slopes, supporting the key biodiversity species listed in Table 5.1 (BirdLife International, 2020).The main vegetation type found to occur in the IBA is the Soutpansberg Mountain Bushveld (Sv cb 21) which is part of the Southpansberg Centre of plant Endemism (Musina and Rutherford, 2006). This vegetation type occurs on the slopes of the Soutpansberg mountain and the Blouberg and Leratuapje mountains, it is characterised by four main vegetation communities including the subtropical moist thicket, mistbelt bush clumps, fairly open savanna sandveld and ariel mountain bushveld (Musina and Rutherford, 2006). Other vegetation types include the Limpopo Ridge Bushveld and the Musina Mopani Bushveld generally occurring in comparatively small sections of some of the boundary areas. These two vegetation types are also found in the MMSEZ study area. Table 5.1 shows key biodiversity species which are supported by the Southpansberg IBA and the likelihood of these species occurring in the project area.
The Southpansberg IBA meets the following criteria as per the 1998 assessment:
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- A1: A few globally threatened species are found to occur in this area including the Cape Vulture (Gyps coprotheres). - A2: The area has significant populations of at least two range-restricted species, such as Knysna Turaco (Tauraco corythaix) and Chorister Robin-chat (Cossypha dichroa). - A3: The area contains a number species that are restricted to the Savanna Biome such as Forest Buzzard (Buteo trizonatus) and Gurney's Sugarbird (Promerops gurneyi). - A4ii: The area is known or thought to hold congregations more than 1% of the global population of one or more species on a regular or predictable basis.
Figure 5.3: Vegetation and NFEPA rivers found to occur in the Soutpansberg IBA in the surrounding areas of the MMSEZ study area.
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Table 5.1: Key Biodiversity Species found in the Soutpansberg IBA and their likelihood of occurring in the MMSEZ study area Common Name (Scientific Name) Conservation Status IUCN Cape Vulture (Gyps coprotheres) Endangered (IUCN, 2020), showing a decreasing population trend. Cape Parrot (Poicephalus robustus) Vulnerable (IUCN, 2020), showing a stable population trend. Crowned Eagle (Stephanoaetus coronatus) Near Threatened (IUCN,2020), showing a decreasing population trend. Forest Buzzard (Buteo trizonatus) Near Threatened (IUCN,2020), showing a stable population trend. Knysna Turaco (Tauraco corythaix) Least Concern (IUCN, 2020), showing a decreasing population trend. Chorister Robin-Chat (Cossypha dichroa) Least Concern (IUCN, 2020), showing a decreasing population trend. Narina Trogon (Apaloderma narina) Least Concern (IUCN, 2020), showing a stable population trend. Grey Cuckooshrike (Coracina caesia) Least Concern (IUCN, 2020), showing a stable population trend. Olive Bushshrike (Chlorophoneus olivaceus) Least Concern (IUCN, 2020), showing a decreasing population trend. Many-coloured Bush-shrike (Chlorophoneus Least Concern (IUCN,2020), showing a stable population trend. multicolor) Green Twinspot (Mandingoa nitidula) Least Concern (IUCN,2020), showing a stable population trend. Forest Canary (Crithagra scotops) Least Concern (IUCN,2020), showing a stable population trend. Gorgeous Bush-shrike (Telophorus quadricolor) Least Concern (IUCN, 2020), showing a stable population trend. White-throated Robin-chat (Cossypha humeralis) Least Concern (IUCN, 2020), showing a stable population trend. Burnt-necked Eremomela (Eremomela usticollis) Least Concern (IUCN, 2020), showing a stable population trend. Gurney's Sugarbird (Promerops gurneyi) Near Threatened (IUCN,2020), showing a decreasing population trend. African Finfoot (Podica senegalensis) Least Concern (IUCN, 2020), showing a decreasing population trend. White-backed Night-heron (Gorsachius leuconotus) Least Concern (IUCN, 2020), showing a decreasing population trend. Pel's Fishing-owl (Scotopelia peli) Least Concern (IUCN, 2020), showing a decreasing population trend.
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LIMPOPO CONSERVATION PLAN
Critical Biodiversity Areas (CBA’s) are terrestrial and aquatic features in the landscape that are critical for retaining biodiversity and supporting continued ecosystem functioning and services (Macfarlane, D., Holness, S.D., von Hase, A., Brownlie, S. & Dini, J., 2014). These form the key output of a systematic conservation assessment and are the biodiversity sectors inputs into multi-sectoral planning and decision-making tools.
The primary purpose of CBA’s is to inform land-use planning and the land-use guidelines attached to CBA’s aim to promote sustainable development by avoiding loss or degradation of important natural habitat and landscapes in these areas and the landscape as a whole. CBA’s can also be used to inform protected area expansion and development plans. The use of CBA’s here follows the definition laid out in the guideline for publishing bioregional plans:
• “Critical biodiversity areas (CBAs) are areas of the landscape that need to be maintained in a natural or near-natural state in order to ensure the continued existence and functioning of species and ecosystems and the delivery of ecosystem services. In other words, if these areas are not maintained in a natural or near-natural state then biodiversity conservation targets cannot be met. Maintaining an area in a natural state can include a variety of biodiversity-compatible land uses and resource uses”. • Ecological support areas (ESA) are areas that are not essential for meeting biodiversity representation targets/thresholds but which nevertheless play an important role in supporting the ecological functioning of critical biodiversity areas and/or in delivering ecosystem services that support socio-economic development, such as water provision, flood mitigation or carbon sequestration. The degree of restriction on land use and resource use in these areas may be lower than that recommended for critical biodiversity areas.”
According to the Limpopo Conservation plan (Desmet et al., 2013), most of the site is located within an Ecological Support Area 1 (ESA1) with the lower section of the site categorised as Critical Biodiversity Area 2 (CBA 2). A smaller portion of the site is regarded as Other Natural Area (ONA) (Figure 5.4).
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Figure 5.4: CBA, ESA and ONA classification according to the Limpopo Conservation Plan (2013).
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Comment regarding application of the mitigation hierarchy: Avoid, Minimise, Mitigate: - The MMSEZ South Site occurs in areas classified as ESA 1, CBA 2 and a small portion of ONA. - The CBA 2 area need to be maintained in a near natural or natural state, thus development in this area should be avoided completely. Should complete avoidance not be possible, minimal development could be allowed without widespread clearing or loss of natural vegetation and habitat. The avoidance of this area will also increase the land readily available for conservation (offset). According to the Fauna and Flora Impact Assessment study, the sensitivity of the area is deemed to be “Medium”.
From the site layout provided by MMSEZ, the following proposed development zones occurs in the CBA1: 1. Zone 21: Water treatment plant (10 ha) • It is recommended that this be revised and relocated from this area. 2. Zone 22: Environmental conservation (2020) • appropriate for the area if deemed suitable for conservation. 3. Zone 25: Reservoirs, size of area is unknown. 4. Zone 26: Visitors guest lodge (excluded from township), size of area is unknown. - The relocation of the infrastructure in the CBA2 area and the inclusion of the whole CBA 2 area into the conservation area would reduce the residual impacts and increase the conservation area by ~50 ha, making it ~2070 ha. Development in an ESA area is not as restricted as within the CBA but should be minimised and mitigation measures (detailed in the various specialist studies) should be put in place that will ensure sustainable development. As per the flora and Fauna Assessment (Digby Wells, 2019), the highly sensitive areas within this class should be avoided. The HIGH Sensitive areas are based on the Riparian vegetation and wetlands (pans), whilst the rest of this area is classified as MEDIUM-HIGH Sensitivity.
Biodiversity Offset: - The land portions classified as an ESA 1 will require compensation through a biodiversity offset. Large areas of the ESA 1 (about 6048 ha) are expected to be lost post mitigation measures. - The land portions classified as CBA 2 has been earmarked as a proposed offset area for the project, should this area be deemed suitable for biodiversity offset. In theory, implementing offset activities on the CBA2 would provide better conservation purposes since the area has higher value than the area that is potentially being lost.
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VHEMBE BIOREGIONAL PLAN
The Vhembe Bioregional Plan (LEDET, 2017) quantifies 451 942 ha, (equating to 21.5%) of the district municipality land area to be categorised as a CBA 2, while 220 643 ha (equating to 8.6%) is categorised as ESA 1. The proposed MMSEZ footprint mainly occurs in the ESA 1 covering 6048 ha (equating to 2.7%) of the total ESA1 in the Vhembe district municipality. A small portion (330 ha) of this area has been identified as HIGH sensitivity in the Flora and Fauna Impact Assessment, whilst the CBA 2 mainly covers the area which has been earmarked for biodiversity offset.
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ENVIRONMENTAL ATTRIBUTES AT MMSEZ
CLIMATIC CONDITIONS
The proposed MMSEZ location falls within a semi-arid climatic zone of Southpansberg, which is characterized by warm to hot summers and with cool, dry winters (May to August). Rainfall occurs mainly during the summer months (October to March), with April and September being transition months. The mean annual precipitation is between 246 mm to 348 mm, the lowest rainfall (0 mm) occurs in June and the highest (55mm) in January. The area is generally frost free, with temperature ranges from 9°C to 40°C. The proposed site is dominated by south-eastern wind with speeds ranging from 0.5 – 3.6 m/s and 2.1 - 3.6m/s. Secondary winds have been noted coming from the east.
LAND-USE AND COVER
The GTI Land Cover (2013/2014) was used to map the land-use and cover of the larger area, this includes surrounding area. The map illustrates that a large area of the study area is classified as grassland, with some areas with thicket/dense bush, woodlands/open bush and shrubland. Very small areas urban built up (open trees/bush) and cultivated common fields (low) were also found to occur in the area.
The Land cover of the broader area comprised of the following
• Largely natural area • Degraded land • Natural Areas • Water Bodies.
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Figure 6.1: GTI Land Cover (2014) of the proposed SEZ project area as mapped by DELTA (2019).
Figure 6.2: Indication of the natural vegetation dominating area
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TOPOGRAPHY AND DRAINAGE
The area within the Limpopo Water Management Area is characterised by a flat topography with grassland, sparse bushveld shrubs and trees. Consequently, in addition to the prevalence of sandy soils in the area, surface runoff is regarded as low despite the presence of some loam and clay soils.
The project area is predominantly located in the A71K quaternary catchment which is classified as a River FEPA, with a smaller portion on the south which falls within the A80F quaternary catchment, both the two catchments are within the Limpopo Water Management Area as revised in the 2012 water management area boundary descriptions. The Mokolo, Lephalala, Mogalakwane, Sand and Nzhelele are the main rivers of the water management area. These rivers together with a few small tributaries, flow northwards into the Limpopo River. However, the Sand River is the only major river within this quaternary catchment (approximately 8 km North-west of the project area). The Sand River flows from the South- west side of the project area towards the north-east side where it eventually joins the Limpopo River approximately 50 km away from the project area.
The flows in the lower Sand River (adjacent to the project area), its tributaries and minor streams are highly intermittent. Run-off occurs after rainfall events, with flow in the main stem of longer duration after major, wide-spread rainfall in its catchment area. A number of ephemeral drainage lines (296.21 ha) occur in the project area (as delineated by Digby Wells, 2019 ; Figure 6.3). Runoff from this area flows towards the northern direction via these drainage line and finally reports to the Sand River.
The Freshwater Assessment study delineated 17 pans (1.3 ha) which were found to be ephemeral in nature, largely homogenous and relatively small (Figure 6.4). Present Ecological State (PES) of most of these pans were classified as Category B and a small portion are classified as Category A according to the level 1 WET-Health assessment carried out by Digby Wells (2019). The study also delineated artificial impoundments or dams (Digby Wells, 2019). The former covers approximately 296.21 ha, with varying types, including wide, deep, sandy, small, rocky; whilst for the latter these covered about 6.23 ha of the project area and were constructed to cater for livestock (cattle) farming, is the current land use.
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Figure 6.3: NFEPA rivers and wetlands in the project area and surrounding areas. FEPA area falls within the study area. Drainage lines, pans, and dams (artificial impoundments) as delineated by the Freshwater Impact Assessment (Digby Wells, 2019).
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Figure 6.4: Typical pans identified within the Project area (Digby Wells, 2019)
Comment regarding application of the mitigation hierarchy: Avoid, Minimise, Mitigate, Rehabilitate: - Negative impacts on the pans (wetlands) should be avoided, a 500 m buffer area has been added to each wetland area. To safeguard these pans, it is recommended that no development should occur within the 500 m buffer. - It is anticipated that development within this area will require a WULA. - Some infrastructure may be affected, and thus will have to be resituated. - Drainage lines will be impacted by the proposed project area thus will also require a WULA. Biodiversity Offset: - Residual impacts are anticipated for the drainage lines. There is no guideline in how these could be compensated for, thus it was not considered. - There may be a reduction in the current health status of the wetlands, with a conservative approach quantifying a 10% decrease in functionality after the application of avoid, minimise and mitigate options (due to residual impacts) has been taken. - Consequently, it is anticipated that the proposed offset area selected should possess wetland features which would be rehabilitated, conserved, or improved, to compensate for the potential reduction in functionality of the pans. To determine how much of offsetting would be required, the Wetland Calculator and guide has been used. The quantification and assessment are presented in Chapter 9.
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BIODIVERSITY FEATURES AT MMSEZ
A comprehensive flora and fauna impact assessment was undertaken by Digby Wells (Digby Wells, 2019). Additional site visit was undertaken by Mamadi to investigate and confirm the assessment undertaken by Digby Wells. This section summarizes the findings of the assessment conducted for flora and fauna features.
FLORA
7.1.1 REGIONAL VEGETATION
According to Mucina and Rutherford (2006), a large portion of the study area is located within the Limpopo Ridge Bushveld (SVmp 2) whilst a smaller portion is located within the Musina Mopane Bushveld (SVmp 1) as depicted in Figure 7.1.
7.1.2 LIMPOPO RIDGE BUSHVELD (SVMP 2)
This unit is distributed in the Limpopo province and occurs on hills and ridges in the lower Mogalakwena River basin. The Altitude ranges from 300m in the east to 700m with a few hills reaching about 1000 m in the west.
7.1.3 MUSINA MOPANE BUSHVELD (SVMP 1)
The Musina Mopane Bushveld vegetation unit is distributed in the Limpopo Province on undulating plains from around Baines Drift and Alldays in the west, remaining north of the Soutpansberg and south of the Limpopo River (but also occurring to the north of Zimbabwe), through Musina and Tshipise to Malongavlakte, Masis and Banyini Pan in the east. It is characterised by undulate terrain to very irregular plains, and some hills. In the western section, open woodland to moderately closed shrubveld dominated by Colophospermum mopane on clayey bottomlands and Combretum apiculatum on hills. In the eastern section on basalt, moderately closed to open shrub-veld is dominated by Colophospermum mopane and Terminalia prunioides. On areas with deep sandy soils, moderately open savanna dominated by Colophospermum mopane, Terminalia sericea, Grewia flava and Combretum apiculatum.
Both vegetation units are categorised as least threatened with about 19% statutorily conserved mainly in the Kruger and Mapungubwe National Parks as well as Nwanedi and Honnet Nature Reserve.
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Comment regarding application of the mitigation hierarchy: Avoid, Minimise, Mitigate:
- The Limpopo Ridge Bushveld has been mapped as HIGH Sensitivity in the Fauna and Flora Assessment, thus removal of vegetation in this area should be avoided. - Musina Mopane Bushveld will be the most impacted, though several mitigation measures have been proposed by the Fauna and Flora Impact Assessment study. This area has been delineated as MEDIUM- HIGH Sensitivity.
Biodiversity Offset: - The Musina Mopane Bushveld vegetation found in the SEZ study area covers 8728 ha. Accounting for the proposed conservation area (2020 ha), vegetation loss (assuming complete loss) will be less than 5698 ha. This is an overestimation as it does not consider other sensitive areas, including wetlands and their buffers (which may cover an estimated 1 230 ha if completely conserved). Additionally, the vegetation communities could not be mapped (in the Fauna and Flora assessment study), sensitive areas may occur within these
communities that must be avoided. Furthermore, the footprint of the proposed development does not completely cover the whole area, presenting additional room for conservation (an estimation is provided in the Section 9). -
Figure 7.1: Limpopo Ridge Bushveld and Musina Mopane Bushveld vegetation types occurring in the SEZ proposed project area (National Vegetation Map, 2012).
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7.1.4 VEGETATION COMMUNITIES
The Fauna and Flora assessment study identified the following vegetation communities; Mopane Bushveld unit and sub types; Riparian habitat and sub types, Ridge Bushveld and Transformed habitat unit. According to the assessment, these units could not mapped, but their description are provided in the report (Digby Wells, 2019). Key species found in the project area and alien invasive species are discussed below.
7.1.4.1 PROTECTED TREES
The Protected Trees Survey conducted by The Biodiversity Company (The Biodiversity Company, 2020) found four (4) protected tree species in the MMSEZ study area. These are Adansonia digitata (Boabab), Combretum imberbe (Leadwood), Boscia albitrunca (Shepherd tree) and Sclerocarya birrea subsp. Caffra (Marula). A later study by Naledzi Environmental Consultants (NEC, 2020), also confirmed the occurrence of these species.
According to TBC (2020), the dominant species in the Limpopo Ridge Bushveld habitat was Boscia albitrunca (Shepherds tree), with an average of 6.3 trees per hectare and most individuals were adult trees. Whilst for the Musina Mopane Bushveld habitat, the dominant species was the Sclerocarya birrea subsp. Caffra (Marula), with an average of 5.6 trees per hectare. The riparian habitat had the highest densities of Shepard trees (11.7 trees/ha) as well as Baobab trees (1.7 trees/ha) of all the habitat types. A total of 507 Baobab individuals were observed in the riparian habitat (TBC, 2020).
Using remote sensing technology, NEC (2020) estimated that Marula trees dominated the area, covering about 771.95 ha, followed by Leadwood (134.30 ha), Shepherd tree (131.91 ha), and lastly Baobab covering 45 ha. The overall accuracy of this assessment was quantified as 77% and the Kapp Statistic was 0.47. This accounts for about 1/8th of the proposed project area including the conservation area (Figure 7.2).
These two assessments demonstrate that the protected tree species occur on a large area of the project area. Since a comprehensive tree count was not conducted and the accuracy of the estimation could not be ascertained, a deviation from applying offset based on estimated number of trees have been taken, and an ecosystem hectare approach has been applied.
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Table 7.1: Threats to protected trees occurring in the MMSEZ study area.
Common Name (Scientific Threat Name)
- According to the National Forest Act (NFA), this species may have been placed on this Baobab (Adansonia digitata) list as it was not adequately protected in other legislation when there were reasons to. - Threats include climate change which has resulted in the decline in its populations (Sanchez et al., 2011)
- According to the NFA, this species may have been placed on this list as it was not Shepherd tree (Boscia adequately protected in other legislation when there were reasons to. albitrunca) - Threats to this species include increased pressure on harvesting of branches during drought conditions (Alias et al., 2003).
- According to the NFA, this species may have been placed on this list as it was not Leadwood (Combretum adequately protected in other legislation when there were reasons to. imberbe) - This species occurs in Southern Africa region. In South Africa, it occurs in Gauteng, KZN, Limpopo, Mpumalanga and the North West in bushveld regions and mixed forests. - Prior to it being placed on the list, Herman et al., 2003 reported that this species may require protection because of its livelihood and commercial value. - According to the NFA, this species may have been placed on this list as it was not Sclerocarya birrea subsp. adequately protected in other legislation when there were reasons to. Caffra (Marula)
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A B
Figure 7.2: Large Baobab (Adansonia digitata) (A) and Shepard Tree (Boscia albitrunca) (B) individuals found to occur in the project area.
7.1.4.2 OTHER KEY SPECIES
Besides protected trees, other species which dominate and characterise the MMSEZ study area; and are noteworthy due to the function they provide in the ecosystem were investigated. These species characterize the Musina Mopane Bushveld and were were found during the Fauna and Flora Assessment (Digby Wells, 2019); and those that are expected to occur in this vegetation type (Musina and Rutherford, 2006). These included: • Colospermum mopane (Mopane Tree) • Combretum apiculatum (Red Bushwillow) • Kirkia acuminata (White Seringa) • Grewia (e.g. Grewia Flava and Grewia Bicolar)
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Comment regarding application of the mitigation hierarchy: Avoid, Minimise, Mitigate: - From the two studies (The Biodiversity Company, 2020 and NEC, 2020), it is evident that the protected tree species are widespread in the project site. It is anticipated that a large amount of these trees will be lost due to the proposed development (Digby Wells, 2019). - The “search and rescue” of these species will only result in a certain proportion being able to be translocated, which will be highly dependent on the size of the trees. - The Biodiversity Company (2020) highlights that there is a high density of these trees in the Northern Section. - The threats to these species are generally associated with the unregulated use of the species – harvesting (prior to their protection); drought, forest fires and other impacts due to climate change.
Biodiversity Offset: - The Musina Mopane Bushveld vegetation found in the SEZ study area covers 8728 ha. Accounting for the proposed conservation area (2020 ha), vegetation loss (assuming complete loss) will be less than 5698 ha. This is an overestimation as it does not consider other sensitive areas, including wetlands and their buffers (which may cover an estimated 1 230 ha if completely conserved). Additionally, the vegetation communities could not be mapped (in the Fauna and Flora assessment study), sensitive areas may occur within these communities and thus must be avoided. Furthermore, the footprint of the proposed development does not completely cover the whole area, presenting additional room for conservation.
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Table 7.2: Distribution of the four Tree species, “other”, “unclassified” areas using remote sensing.
7.1.5 ALIEN INVASIVE AND BUSH ENCROACHING SPECIES
Several alien invasive species and bush encroaching species have been identified in the Flora and Faunal Assessment. Following disturbance due to site clearing during construction, there could be an increase in alien invasive species in the project area and surrounding areas. Alien invasion is one of the biggest threats to biodiversity due to displacing indigenous species and competing for resources, especially competition for water resources in an area that is already water scarce. Bush encroaching species have a similar impact, even though these are indigenous woody species that displace grasses.
The application of mitigation measures and the management of alien invasive species will not completely rid the site of the alien invasive species; a continuous management programme must be instituted.
Also, translocation of plants and animals from the proposed MMSEZ area may result in the unintentional introduction of alien invasive species in the offset site(s), hence translocations must be conducted by professionals (horticulturists and / or translocating specialists). The offset site(s) must also be managed
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REPORT NO 20MC-MMSEZ-BIOD-03 for alien invasive species. Depending on the distance to the offset site, seeds from fruits eaten by animals or carried by their bodies, may facilitate dispersal of alien invasive species when being relocated to much further areas, which is beyond their normal distance range.
Comment regarding application of the mitigation hierarchy: Avoid, Minimise, Mitigate: - Vegetation in Riparian areas and areas with the Limpopo Ridge Bushveld vegetation should be avoided as they have been delineated as Highly Sensitive areas (Digby Wells, 2019). - Removal of vegetation should be minimised and kept within the footprint of the proposed activities and where possible, footprint of development should be reduced to mitigate the high negative impact associated with the loss of vegetation. - Management of alien invasive species - Search and Rescue Programme for Protected Trees.
Biodiversity Offset: - Several Protected Trees will be lost as due to the proposed development even with the application of mitigation measures. - The proposed offset area selected should possess similar vegetation types to the MMSEZ site. - The MMSEZ will result in mainly the loss of vegetation of the Musina Mopane Bushveld. Thus, offset should compensate for this loss, through the conservation of this vegetation type (like-for-like conservation). - Key species found in this study area and those which are indicators of the Musina Mopane will assist in the selection of a suitable biodiversity offset.
FAUNA
The Fauna and Flora Impact Assessment report details the study undertaken to evaluate the fauna and flora composition of the MMSEZ study area (Digby Wells, 2019). A summary of the findings is presented herein.
7.2.1 MAMMALS
Seventeen (17) mammal species were found to occur in the project area, this includes one monkey species, one squirrel species, seven carnivore species, and eight even toed ungulate species. Three of these species are listed as Species of Conservation Concern namely; Equus quagga burchelliii (Zebra)
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REPORT NO 20MC-MMSEZ-BIOD-03 which is “Near Threatened” according to the IUCN redlist, Panthera pardus (Leopard) and Giraffa camelopardalis (Giraffe) which are “Vulnerable” and “Protected” under TOPS (DEA, 2004).
7.2.2 AVI-FAUNA
Recently acquired data (according to Southern African Bird Atlas Project 2) of the project area corresponding to 2229DB (Mopane) as well as old records from Southern African Bird Atlas Project 1 indicate that approximately 262 bird species are likely to occur in the study area. This is also supported by the presence of suitable habitat in the study area as well as the proximity of the Soutspanesberg Important Bird Area (IBA). Of these 262 species, a total of thirteen (13) species are listed as Red Data species. On site, the faunal and flora impact assessment identified the occurrence of 26 bird species, with none of these were listed as species of conservation concern (SCC) (Digby Wells, 2019). It is noted that avifaunal impact assessment study was not undertaken, which presents a limit to the offset options that could be prescribe for specific avifaunal species in the area.
7.2.3 HERPETOFAUNA
Based on the results of the ADU database search, a total of twenty-seven herpetofauna species are listed for the QDS 2229DB. This includes four frog species; one tortoise species; and twenty-two reptile species. Two of these species are listed as Red Data species (Homopholis mulleri and Crocodylus niloticus).
7.2.4 INVERTEBRATES
A total of thirty-nine (39) invertebrates are listed for the QDS 2229DB 1 . This includes three scorpion species, one spider species, four dragonfly species, one antlion species, one dung beetle species, twenty-six butterfly confirmed species, and three moth species.
An extensive network of drainage lines, covering approximately 296.21 ha was observed, ranging from wide, deep, sandy ephemeral systems to small rocky features in isolated parts within the Project area (Digby Wells, 2019).
1 Website link: www.vmus.adu.org.za
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ECOSYSTEM GOODS AND SERVICES
The Musina Mopane Bushveld and the Limpopo ridge bushveld provide a number of important services and goods, these vegetation types have important tree species (some of their uses have been highlighted above, including habitat provision for several faunal species, which include few SCC). The Colophospermum mopane (Mopane tree) is the dominant species in the natural environment and offers various uses to mammals. During times of limited water and scarcity of grasses, many antelope species (such as the impala) will convert from grazing to browsing, and feed on the small branch tips and fresh leaves of the Mopane tree. The tree also offers nesting sites and haven for tree squirrels.
Wetlands provide regulatory, provisioning, supporting and cultural services making them an important ecosystem. Wetlands act as breeding grounds, nurseries, habitat for floral and faunal species, improve water quality, sediment trapping and control flooding and erosion. Several plant and animal species depend on wetlands directly or indirectly, irrespective of whether they are permanent or seasonal. Several ecosystem services provided by the wetland and riparian vegetation was highlighted by the Fauna and Flora Assessment, these included water attenuation, flood protection, habitat creation and food stuff provision (Digby Wells, 2019).
Comment regarding application of the mitigation hierarchy: Avoid, Minimised, Mitigate: - Clearing of vegetation during the construction phase of the Project will directly impact most wetlands and important riparian woodland habitat and their buffer areas. Construction and clearing of this vegetation will disturb natural environments and compromise the ecological services they provide, which are of significance in the context of the area. - The wetlands and important riparian woodland have been delineated as HIGH Sensitivity, thus no construction will occur within these areas, thus will be avoided. -The increase of the buffer area to 500 m will minimise the negative impact to the ecosystem services of pans.
Biodiversity Offset: -The ecosystem services provided by the Mopane Musina vegetation will require offsetting, these have been accounted for when determining the requirements for the biodiversity offset area.
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ASSESSMENT OF ALTERNATIVES
For the proposed MMSEZ, two alternative site locations, the Laphalale and Tubatse sites were considered. The Environmental Impact Assessment Report states that Laphalale was not suitable due to the construction of the Medupi power station, which is poised to significantly contribute to the development of the area. Whilst the Tubatse site was found not to be suitable due to its size, its access to infrastructure, proximity to markets and the costs related to securing the land when compared to the MMSEZ (which is owned by the community through the CPA and would thus be cheaper than purchasing privately owned land). The ecological and environment aspect of the alternative sites were not described in detail in the draft EIA and may be due to the unsuitability of the sites from an environmental perspective.
Alternatives with regards to the layout and technologies have not yet been assessed. According to the EIA draft report, this is a result of the constituting industries, activities, and entities not being finalized yet. The draft EIA report suggests that layout and technologies will be assessed during the second phase when the constituting industries, activities, and entities have been finalized and thus trigger the application of the relevant process (e.g. EIA , Basic Assessment).
The ‘No-Go’ option was assessed, identifying the development of the MMSEZ with the potential for economic growth, job creation and diversification of the predominant mining economy. Therefore, without this development, the area has the potential to continue in the current status, which consist of high level poverty, unemployment and underdevelopment.
In terms of the environment, the area would remain in the condition that it is currently obtainable, with some changes as a result of the current land use (game farming and cattle farming) and an increase in alien invasive species and bush encroachment if practices to control the spread are not incorporated. There would not be a significantly increase in atmospheric emissions and air pollution, and there would not be a significant negative impact on the water capacity etc.
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SENSITIVITY
Using proposed layout (Figure 2.1) a number of specialists reports have been conducted, including the Flora and Faunal Impact Assessment (Digby Wells, 2019), Freshwater Impact Assessment Report (Digby Wells, 2019), Specialist Climate Change Assessment Report (Promethium Carbon, 2019), Draft Air Quality Specialist Report (Airshed, 2019), Draft Integrated water services report (Matukane and Associates, 2020). Some of these impact assessments have demarcated high sensitive areas which should be avoided (refer to Figure 9.1) and provided mitigation measures that should be applied to reduce the impacts associated with the proposed clearance of vegetation as a result of the construction of the SEZ and the operation and decommissioning of the earmarked activities as described in preceding sections. These will result in the offset design highlighting land that is available after the application of mitigation measures and the recommendations of which activities are likely to be unsuitable for the proposed study area.
Recommendations from these studies have resulted in the need for a number of plans, management and monitoring programmes and additional studies which include the Protected Tree Survey (The Biodiversity Company (TBC), 2019) and the Tree relocation report (Naledzi Environmental Consultants (NEC, 2020), Environmental Management Programme (EMPr) which includes the Alien Management Plan, Biodiversity Action Plan, Floral Relocation Plan and Erosion control plan and the Storm Water management Plan (included as part of the draft EIA report). Additional Impact Assessment are missing as proposed by the draft EIA, such as the Avifaunal Impact Assessment and other plans such as management plans for some animals species that may not be capable of relocating on their own should suitable habitats not be within proximity.
All these assessments, proposed plans and studies informed the biodiversity offset strategy, which will provide a strategy on how compensation for the residual impacts maybe achieved.
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Figure 9.1: Sensitivity Map using the Flora and Fauna Impact Assessment (Digby Wells, 2019), Freshwater impact assessment (Digby Wells, 2019), 500 m added to the pans/wetlands.
ADEQUACY OF THE PROPOSED MITIGATION MEASURES
Digby Wells (2019) completed a Fauna and Flora Impact Assessment as part of the Environmental Impact Assessment for the MMSEZ. In the study, the following activities pertaining to the fauna and flora specialist report with special reference to proposed activities listed in EIA Regulations were considered in assessing the impact of the Project: • Activity 27 of GNR 327 LN 1: Cumulative removal of indigenous vegetation, for the development of infrastructure and cultivated areas, will account for more than 20 ha. • Activity 12 of GNR 324 LN 3: The vegetation of the proposed development site meets the definition of indigenous vegetation, as contained in the EIA Regulations, 2014 (as amended). • Removal of indigenous vegetation, in an area that traverses a Limpopo Conservation Plan v2 (LCPv2) Critical Biodiversity Area (CBA) 2 for the development of the 18-day storage Dam will account for more than 300 m2.
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Digby Wells (2019) completed a Freshwater Impact Assessment as part of the Environmental Impact Assessment for the Musina-Makhado Energy and Metallurgy Special Economic Zone Development. In the study, the following activities pertaining to the freshwater specialist report with special reference to proposed activities listed in EIA Regulations were considered in assessing the impact of the Project:
The Land and Capability Study (Digby Wells, 2019) identified a number negative impacts on the land capabilities as the direct result of construction activities for the development of the MMSEZ. These include the impaction of the soil due to the increase in vehicles on the site and preparation of the base area for the various planned infrastructure. Negative impacts during the operation of the MMSEZ included the contamination of the soils e.g. the metallurgy plant.
The Air Quality, Climate Change and the Integrated Water Report primary provides input on the cumulative impacts of the proposed activities, which would affect biodiversity beyond the project area.
This section will only consider the land clearance and the setting up of the service infrastructure to serve the SEZ, including water, stormwater, and sewer pipelines as well as powerlines, electrical substations, and roads within the SEZ boundary. The impact assessment does not include the impacts associated with the development of individual constituent and their cumulative impacts for each specialist study.
The impact ratings generated as part of the Fauna and Flora Impact Assessment for the Project is presented in Table 9.1 (Digby Wells (2019)). The assessment yielded an impact rating of “high” (pre- mitigation) “moderate’ (post-mitigation) for most of the impact areas or issues.
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Table 9.1: Impacts ratings, mitigation measures as per the various specialist reports that are associated with biodiversity.
Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation Floral and Faunal Construction Loss of Mopane Bushveld Major negative Moderate - Mitigation measures for the direct and permanent loss of approximately 4755 ha of natural Assessment negative habitat. Including plant and animal SSC. Limited mitigation measures exist for loss of (Digby Wells, Construction Loss of Ridge Bushveld Major negative Moderate habitat. However, the following are recommended as a minimum: 2019) negative - Use previously disturbed areas where possible and where possible retain as much natural vegetation within the footprint of infrastructure. - Complete a fauna and flora search and rescue program for all protected species to be Construction Loss of Riparian Vegetation Major negative Moderate recorded. negative - No unpermitted disturbance of any kind to protected flora species should occur and fines should be instituted for such actions. - Fencing of construction camps. No equipment or personnel will be allowed outside of the fenced construction camps Construction Loss of Floral SCC Major negative Moderate - Plan to relocate Red Data or protected species prior to site clearing commencing negative
Construction Loss of Faunal SCC Major negative Moderate negative
Construction Loss of Wetlands and Moderate Moderate - Limited mitigation measures exist for loss of ecological services. However, the following Riparian Habitat services negative negative are recommended: - Use previously disturbed areas where possible, avoid sensitive landscapes/areas. - Plan to relocate Red Data or protected species prior to site clearing commencing.
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation - A 100 m buffer is recommended for the pan and woodland habitats. Refer to the wetlands report for suggested buffer sizes. - Ensure that the area is fenced off to limit the ingress of species into the construction areas. - To further mitigate the permanent loss of natural habitat, ecological offsetting must be done.
Construction Road deaths of animals, dust Moderate Moderate - Ensure that the width and length of roads are kept to a minimum. creation. negative negative - Use previously disturbed areas or existing roads where possible. - Commit to relocate Red Data or protected species prior to construction commencing. - Ensure that vehicle speeds are kept to a minimum. - Ensure that noise levels are reduced. - Limit construction to daylight only to reduce noise. - Ensure that the project area is demarcated and no persons or vehicles permitted outside the demarcated area. - Ensure that environmental awareness training is held prior and during construction operations are held.
Operation Habitat loss and continual Moderate Minor - Ensure that a Biodiversity Action Plan addresses these impacts in full. pressure on the ecosystem negative negative - Ensure that the controls of noise, dust, waste generation, vehicle speed limits, food waste and species: disposal, hazardous waste disposal, human interaction with the ecology are monitored Impacts on remaining regularly and controls to prevent adverse conditions arising from the activities which are species likely to affect fauna are updated and implemented. - Ensure continuous environmental awareness training takes place.
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation Operation Habitat loss and continual Moderate Minor - Ensure the use of new technologies, such as electrostatic precipitators, adhere to national pressure on the ecosystem negative negative and international emissions standards. and species: Pollution and - Ensure a waste management plan for water and production waste is in place Waste generation Operation AIP infestation: Further Moderate Minor - Ensure an integrated AIP management plan is in place and adhered to. reduction of natural Habitat negative negative - Specific control measures from an AIP Monitoring Plan must be incorporated into the working procedures. - Regular on-site monitoring for invasive species must be carried out to allow early identification of invasive species before they become established and spread cleared areas. - Regular hygiene inspections of all equipment, vehicle and machinery should be carried to ensure no spread of alien invasive plants occurs.
Decommissioning Habitat loss and continual Moderate Minor - Ensure that a Biodiversity Action Plan addresses these impacts in full. pressure on the ecosystem negative negative - Ensure that the controls of noise, dust, waste generation, vehicle speed limits, food waste disposal, hazardous waste disposal, human interaction with the ecology are monitored and species: Clearing of regularity and controls to prevent adverse conditions arising from the activities which are infrastructure likely to affect fauna are updated and implemented. - Ensure continuous environmental awareness training takes place.
Decommissioning Habitat loss and continual Moderate Minor pressure on the ecosystem negative negative and species: Road deaths
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation Decommissioning Impacts due to correct Positive Positive - Ensure that the rehabilitation plan is updated during the project’s term. rehabilitation practices: - Ensure that the environmental liability assessments are done annually and that the cost Improvement of natural for rehabilitation is updated annually and the funds are available. Habitats - Ensure that the correct specialists are involved well in advance to deal with all the aspects of decommissioning. - Ensure that an ecologist is commissioned to guide the rehabilitation of the natural elements of the project site. - Rehabilitate successfully to bushveld comprised of natural indigenous species with the carrying capacity of pre-disturbance standards. Comment on Alternatives Investigated, Suitability of Mitigation Measures, Monitoring and Management
1. Alternatives: No alternatives have been assessed; the study area has been assessed as per the layout of the Master Plan. 2. No-go option: No details of what would happen if the development of the MMSEZ does not occur. 3. Cumulative Impacts: Cumulative impacts have not been assessed as the quantification of the regional cumulative impacts were not completed during the writing of the Flora and Fauna Impact Assessment Report. 4. Overall Sensitivity Rating: MED-HIGH Sensitivity. 5. Suitability of Mitigation Measures - Study suggests a 100 m buffer around the pans and riparian woodland vegetation. Whilst the Aquatic Impact Assessment suggests a 51 m buffer would be sufficient. It is suggested that to ensure minimum impact occurs that a 100 m buffer should be placed around all the pans. It is also evident that the current layout would remove most of the pans. Thus, the layout should change to accommodate these buffer areas. As seen in the current layout the development does require a WULA. - The study has highlighted the Limpopo Ridge Bushveld as HIGH sensitive, thus the new layout should avoid this area. - The cordoning of the area is an important mitigation measure to prevent access, the loss of intact habitat and thus reduce the impact on certain faunal species. The sensitive areas were the Limpopo Ridge Bushveld vegetation occurs should be cordoned. - The Musina Mopane Bushveld vegetation covers a large area of the MMSEZ study area. This region was mapped as generally moderate, areas which have been disturbed (such as the farmhouses, surrounding areas where vegetation has been cleared, impacted areas by cattle grazing, areas which show signs of erosion) should be targeted as per the recommendation of the Fauna and Flora Impact Assessment. - Ground-truthing of the area prior to the implementation of the search and rescue should and removal of the vegetation on the MMSEZ study area. - Removal of the vegetation should be confined to the footprint of the proposed activity. - It is suggested that minimal impact occurs in the CBA 2 area, infrastructure occurring in this region only be related to the conservation area and only practices aligned to the goals of the conservation area should be implemented.
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REPORT NO 20MC-MMSEZ-BIOD-03
Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation - The assessment recommends a Biodiversity Offset Strategy to compensate for the residual impacts. A biodiversity offset strategy is required as the residual impacts associated with the proposed MMSEZ have a Medium-HIGH Significant Rating. Due to the Residual impact associated with the MMSEZ this is a good recommendation, as without the offsetting of biodiversity this development would not have attempted its best to achieve sustainable development. - It is the suggestion of this strategy that removal of vegetation at this stage should only be that required to set up the SEZ. The are a number of risks associated with any development, for example this one has earmarked activities which still require successful bidding etc, thus removal of vegetation should be done in phases based on the current need and finding the balance between the environment and the SEZ thus achieving sustainable development. - Mitigation measures regarding the operation phase are general and are too be evaluated further in the Biodiversity Action Plan when the targeted activities area known. These mitigation measures are not specific as there are still unknowns and uncertainties with what would be the final activities. - Rehabilitation takes a long period, is not guaranteed and due to the large area, bush encroachment and alien invasive species it maybe difficult to restore the area to its original status. 6. Monitoring and Management: Impact Assessment suggest an Ecological Management Plan, Rehabilitation Plan, Biodiversity Action Plan with the Alien Invasive Management Plan. These are important Integrated Water Construction and Taking Groundwater from a 23 2 Geo-hydrological assessment of abstraction potential for the site. Services Draft Operation Resource: Individual borehole test analysis and abstraction determination. Design of pump installation Report -Groundwater abstraction within the limits of recommended abstraction. Abstraction monitoring, recording and control to Northern prevent over abstraction and dewatering of any particular borehole. and Southern Sites. -From a view of aquifer sustainability for all users on the relevant aquifers. Taking Water from Musina 23 3.5 Due agreement (MOU) to be reached with the Musina LM and VDM (WSA) with respect to the Resources following: - Principal agreement defining the various resources, the volume to be abstracted and the duration of the agreement pertaining to a specific resource. - Capacity of the abstraction infrastructure, the operational condition, design limitations, upgrade requirements, planning and design, funding and implementing of the required upgrades.
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REPORT NO 20MC-MMSEZ-BIOD-03
Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation - Source monitoring to manage resource deterioration. - Operational requirements and capacity. Compliance to WUL and Environmental procedures, Utilizing 4.4 Mm3/a from 23 5.5 From the MOU between the MM SEZ and WSA, ensure that: Musina LM - Infrastructure - technical requirements are met. - Monitoring and recording requirements are met. - Operations within functional guidelines. Compliance to WUL and Environmental procedures and conditions. Using 1 Mm3/a from Musina 23 5.5 From the MOU between the MM SEZ and the WSA: Copper Mine - Design the required infrastructure according to functional requirements, applicable standards, guidelines and procedures. - Obtain the required approvals, wayleaves and servitudes as may be applicable. - Construction according to design. - Operations within functional guidelines. Compliance to WUL and Environmental procedures and conditions. Scientific Motivation for 26 7 The uptake of water beyond the current Musina LM allocation of 11 Mm3/a, both from the Taking Water from the alluvial aquifer and from flood water, will be subject to the main-stem hydrological study of the Limpopo River: Limpopo River that will clarify the available water in the alluvial aquifer and as storm water to Taking Water from a further be harvested. DWS will consider the study outcome for the allocation of further water. This will Eastern serve to protect the interest of: Wellfield from the Limpopo - Downstream South African users. Alluvial - Zimbabwean users. Aquifer between the Sand - Mozambiquan users and the exposure of Mozambique to Limpopo River flood events. River confluence and the Compliance to WUL and Environmental procedures and conditions. eastern extent of the farm
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REPORT NO 20MC-MMSEZ-BIOD-03
Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation Malala Hoek 20 Mm3/a and the uptake off Limpopo flood water to the foreseen extend of 180 – 400 Mm3/a approximately at the Sand River confluence pertaining to yield capacity. Perspective: Scientific proven resource availability. Possible Limitations due to 19.5 7 As part of the hydrological study as described above, a climatological study will be required to Global Warming determine: - The anticipated impact on rainfall over the catchment area. - The anticipated impact on run-off. - The anticipated impact on yield at the proposed points of abstraction. Using water from the 26 4 In accordance with available researched proposed Eastern (Limpopo) volumes from this resource: Alluvial - Proper consideration of technical- and economic feasibility. Aquifer - Design the required infrastructure according to functional requirements, applicable standards, guidelines and procedures. - Obtain the required approvals, wayleaves and servitudes as may be applicable. - Construction according to design. - Establishment of operational structure including the measurement, monitoring and recording of the required parameters, system operational requirements and operational structure. Compliance to WUL and Environmental procedures and conditions.
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation Using Water from the 26 4 In accordance with available researched volumes from this resource: proposed Off-Channel - Proper consideration of technical- and economic feasibility. Storage Dams - Design the required infrastructure according to functional requirements, applicable standards, in the Sand River: guidelines and procedures. - Obtain the required approvals, wayleaves and servitudes as may be applicable. Taking 180 - 400 Mm3/a - Construction according to design. floodwater - Establishment of operational structure including the measurement, monitoring and recording from the Limpopo River for off of the required parameters, system operational requirements and operational structure. channel Compliance to WUL and Environmental procedures and conditions. storage. Seen from the perspective of insufficient infrastructure development, management and / or compliance. On-Site Distribution 26 4 In accordance with available researched volumes from this resource: Infrastructure on the Northern - Proper consideration of technical- and economic feasibility. Site: Construction of various - Design the required infrastructure according to functional requirements, applicable standards, elements of guidelines and procedures. water supply, - storage and - - Obtain the required approvals, wayleaves and servitudes as may be applicable. distribution network linking - Construction according to design. the - Establishment of operational structure including the measurement, monitoring and recording various resources to the farm of the required parameters, system operational requirements and operational structure. Antonvilla 7 MT, constituting Compliance to WUL and Environmental procedures and conditions. the
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation Northern Site. Seen from the perspective of insufficient infrastructure development, management and / or compliance. On-Site Distribution 26 4 In accordance with available researched volumes from this resource: Infrastructure on the - Proper consideration of technical- and economic feasibility. Southern Site: - Design the required infrastructure according to functional requirements, applicable standards, Construction of various guidelines and procedures. elements of - Obtain the required approvals, wayleaves and servitudes as may be applicable. water supply, - storage and - - Construction according to design. distribution network linking - Establishment of operational structure including the measurement, monitoring and recording the of the required parameters, system operational requirements and operational structure. various resources to the Compliance to WUL and Environmental procedures and conditions. group of farms constituting the Southern Site. Seen from the perspective of insufficient infrastructure development, management and / or compliance.
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation Effluent Quality: 26 6 Clear effluent quality objectives based upon the required DWS standards will be defined and Effect on water quality arising incorporated in the various MOU's to be develop with the various investors. Strict compliance from the monitoring. envisaged water use. Seen from a perspective that: - Anticipated final effluent volumes are not estimated yet. - The exact quality of input water is not yet known. - The effect on the water due to the various possible industrial processes is not defined yet. - The objective to limit water demand through the re-is of water is stated by the investors as one of their project objectives. 1. Alternatives: No alternatives have been assessed; the study area has been assessed as per the layout of the Master Plan. 2. No-go option: No details of what would happen if the development of the MMSEZ does not occur.
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation 3. Cumulative Impacts: Cumulative impacts include the mining in the surrounding area. Quantification of regional cumulative impacts could not be completed and included in the Flora and Fauna Impact Assessment Report. 4. Suitability of Mitigation Measures: Significance rating with mitigation measures are generally low. Mitigation measures include the recommendation of a Geo-hydrological assessment. According to the study there is no direct access to any sustainable water resources sources, apart from groundwater. It is not clear (based on the details provided) on how the Geo-hydrological assessment will considerably reduce the negative impacts. A number of these measures are recommendations which the outcome would result in obtaining the mitigation measures. This Impacts Assessment is a supporting assessment with regards to the Biodiversity strategy rather than the main documents which are the Flora and Fauna. Thus input from this document was more for the Cumulative impacts. However, based on the report, caution should be taken to not remove vegetation and cause harm to the biodiversity when the project cannot source the water resources required for the project to continue. 5. Monitoring and Management: Assessment highlights the need for a Monitoring and Implementation Plan. Freshwater Construction Site clearance and Major (negative) Minor (negative) Design the footprint of the infrastructure so as not to fall within the pans and drainage lines or Impact construction of man-made their buffers. Assessment structures within the Musina- Makhado SEZ wetland The following should be adhered to: habitat and river catchment - Construction should take place during the dry season to minimise runoff; - Ensure construction activities are limited to the project footprint and that no vehicles are allowed to drive indiscriminately around the proposed Project area; - Sequential removal of the vegetation should take place (not all vegetation immediately); - Revegetate the construction footprint and vehicular pathways as soon as possible; - Storm water should be diverted from construction activities and managed in such a manner to disperse runoff and prevent the concentration of storm water flow; - Implement and maintain an alien vegetation management programme. This must be put in place so as to prevent further encroachment by invasive species as a result of disturbance to the surrounding terrestrial zones; and - Active rehabilitation, re-sloping, and re-vegetation of disturbed areas immediately after construction. Stockpiling and storage of Minor Negligible - Revegetate the construction footprint and vehicular pathways as soon as possible; construction materials (Negative) (negative)
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation - Ensure all stockpiles are within the construction footprint and ensure vehicles remain on demarcated roads; - Storm water should be diverted from construction activities and managed in such a manner to disperse runoff and prevent the concentration of storm water flow; - Construction should take place during the dry season to minimise runoff; and ▪ Sequential removal of the vegetation should take place (not all vegetation immediately). Operation Activity and Interactions: Major Minor - Appropriate storm water and wastewater systems must be in place; Surface operation activities (Negative) (Negative) - Incidents of erosion should be remedied as soon as possible; - Any pollutants should be removed to reduce contamination of the water quality. The contaminated material should then be discarded at the correct facility; - Leak detection of the industrial plant pipelines must be done on a regular basis; - Limit the footprint area of the operational activities to what is essential to minimise impacts as a result of any potential vegetation clearing and compaction of soils (all areas but critically so in freshwater areas); - All areas of increased ecological sensitivity should be designated as “No-Go” areas and be off limits to all unauthorised vehicles and personnel; - No vehicles or heavy machinery may be allowed to drive indiscriminately within any freshwater areas and their associated zones of regulation. All vehicles must remain on demarcated roads; - All vehicles must be regularly inspected for hydrocarbon leaks; - Re-fuelling must take place on a sealed surface area away from freshwater features to prevent ingress of hydrocarbons into topsoil; - All hydrocarbon spills should be immediately cleaned up and treated accordingly; - Appropriate sanitary facilities must be provided for the duration of the operational activities and all waste must be removed to an appropriate waste facility;
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation - Permit only essential personnel within the various zones of regulation/buffers for all freshwater features identified. Decommissioning Decommissioning of all Minor (negative) Negligible Limit the footprint area of the decommissioning and rehabilitation activities to what is essential; infrastructure (negative) - Wherever possible, restrict decommissioning activities to the drier winter months to avoid sedimentation of the freshwater resources further downstream; - No material may be dumped or stockpiled within any wetland areas or within 100m in the vicinity of the proposed decommissioning footprint; - Re-fueling must take place at a diesel facility on a sealed and bunded surface area away from wetlands to prevent ingress of hydrocarbons into topsoil; - All existing litter, debris should be removed from the freshwater systems and littering should be prohibited on an ongoing basis; - All spills from machinery should be immediately cleaned up and treated accordingly; - Appropriate sanitary facilities must be provided for the duration of the rehabilitation activities and all waste must be removed to an appropriate waste facility; - Waste generated from decommissioning activities must be disposed of in accordance with waste regulations; and - Any industrial pollutants should be removed and discarded at the correct facility. Rehabilitation measures and Minor negative Minor negative Limit the footprint area of the decommissioning and rehabilitation activities to what is absolutely site access essential to minimise impacts as a result of vegetation clearing and compaction of soils (all areas but critically so in wetland areas); - All soils compacted as a result of decommissioning activities should be ripped/scarified (<300mm) and profiled; - Wherever possible, restrict decommissioning activities to the drier winter months to avoid sedimentation of the freshwater resources further downstream;
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation - An AIP management plan to be implemented and managed for the life of the proposed decommissioning, rehabilitation, closure and post-closure phases; - As much vegetation growth as possible should be promoted within the proposed development area during all phases. In order to protect soils, vegetation clearance should be kept to a minimum; - All areas where active erosion is observed should be ripped, re-profiled and seeded with indigenous grasses; - No vehicles or heavy machinery may be allowed to drive indiscriminately within any wetland areas and their associated zones of regulation. All vehicles must remain on demarcated roads and within the project area footprint; - All vehicles must be regularly inspected for leaks; - Re-fueling must take place at a diesel facility on a sealed and bunded surface area away from wetlands to prevent ingress of hydrocarbons into topsoil; - All existing litter, debris should be removed from the freshwater systems and littering should be prohibited on an ongoing basis; - All spills from machinery should be immediately cleaned up and treated accordingly; - The road servitude and conveyor have affected the integrity of the wetlands resulting in a loss of habitat and downstream surface water recharge. Rehabilitation during the decommissioning and closure phase should focus on the rehabilitation of these areas. Management in this regard would include removal of the structures, re-profiling of the bed and marginal zones to restore the geomorphological and hydrological integrity and ripping and re-seeding with indigenous wetland grass species. - All incidents of erosion should be remedied and AIPs removed, as in the operational phase; and
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REPORT NO 20MC-MMSEZ-BIOD-03
Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation - Any industrial pollutants should be removed and discarded at the correct facility as in the operational phase. 1. Alternatives: No alternatives have been assessed; the study area has been assessed as per the layout of the Master Plan. 2. Cumulative Impacts. 3. Suitability of Mitigation Measures: Mitigation measures provided ensure that no infrastructure occurs in the pans and their buffers. The buffer area has been increased to reduce the impacts on these area. 4. Monitoring and Management
Climate Change Operation greenhouse gas emissions High (Negative) High (Negative) It is proposed that the environmental authorisations for the individual plants in the SEZ specify that the maximum emission intensities for the plants to be built is as would be required by the science-based target trajectories for 2030. This recommendation is based on the required decarbonisation rate for the global economy as well as the assumption that the new plants will not be retrofitted during the first 10 years of operation.
1. Alternatives: No alternatives have been assessed; the study area has been assessed as per the layout of the Master Plan. 2. Cumulative Impacts: 3. Suitability of Mitigation Measures: Impact Assessment Study highlights other potential impacts on the SEZ which includes Risks which are associated with the core operations of the SEZ, these were heat stress (High risk), water stress (High risk) and Disaster Risk - Flash Floods (Medium Risk), Disaster Risks -Droughts (High risk) , Regulatory obligations (High risk). The study also identified risks associated with the value chain, these included Disrupted Supply Chain (High risk) and Regulatory obligations (High risk). Those associated with Social and Environmental related risks included; Ecosystem vulnerability (medium risk), Community vulnerability (High Risk), heat stress (High risk), in-migration (High risk), water supply (high risk).
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Assessment Phase During Impact Identified Rating Prior to Rating Post Proposed Mitigation Measure Project Mitigation Mitigation -According to this Assessment the Ferrochrome, Ferromanganese and Lime plants are above the suggested 2030 emission intensities. The Proposed mitigation measures include changes in the current design processes that would reduce the emission intensities in line with both the local and global climate commitments.
4. Monitoring and Management:
Air Quality Assessment
1. Alternatives: No alternatives have been assessed; the study area has been assessed as per the layout of the Master Plan. 2. Cumulative Impacts: Increase in air pollutant concentrations and dustfall rates as a result of the existing activities and the proposed MMSEZ activities in the area. Other impact is the reduction in ambient air quality due to additional industrial and transport operations and fuel burning if there is an establishment of new residential settlements. 3. Suitability of Mitigation Measures: According to the Air Quality Impact Assessment, design mitigation for a number of the earmarked activities are unknown (AirShed, 2019). There was insufficient data to quantify domestic waste handling, refractories production (assuming refractory bricks), Sewage treatment plant and Water treatment plant. Study identifies only impacts for the Construction and Operation and not the decommissioning phase thus mitigation measures for decommissioning have not been provided. 4. Monitoring and Management
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Need of biodiversity offsets for the MMSEZ:
• The proposed MMSEZ will result in the removal of large areas of vegetation and thus loss of habitat, these all affect
negatively on biodiversity. The Flora and Fauna Impact Assessment found the negative impacts associated with the proposed MMSEZ to be Medium-High, thus there is a need for a biodiversity offset.
ASSESSMENT OF RESIDUAL IMPACTS
The residual impacts associated with the MMSEZ study area were assessed in the Fauna and Flora Study. This assessment considered the “Extent”, “Duration”, “Intensity”, “Probability” and the “Nature” of the impacts on the Biodiversity pattern, the Biodiversity process and Ecosystem services. A full description on the methodology and significance rating are provided in the report (Digby Wells, 2019). Table 9.2 summarizes relevant impacts and residual significance as presented in the report.
Table 9.2: Residual Impacts associated with the proposed MMSEZ project relevant to biodiversity offsetting. Impact Identified Residual Significance Rating Comment
1 Direct and permanent loss of Moderate/Medium Negative Impacted area is larger than that approximately 4755 ha of natural estimated in this assessment but it is habitat. Including plant and anticipated that this will still remain animal SSC. Moderate negative.
2 Loss of ecological services provided Moderate/Medium Negative - by areas of high sensitivity including the wetlands, riparian habitat, pans and woodland areas. 3 Indirect impacts due to industrial Minor/Medium Negative - activities occurring within a largely natural landscape. 4 Air pollution and waste generation Minor/Medium Negative -
5 Proliferation of AIP species in Minor/Medium Negative - areas disturbed by operation activities.
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6 Site clearance and construction of Minor/Medium Negative man-made structures within the Musina-Makhado SEZ wetland habitat and river catchment
7 Surface operation activities on Minor/Medium Negative - freshwater resources
8 Impact of Rehabilitation Minor/Medium Negative - measures and site access on water resources during decommissioning of SEZ
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BIODIVERSITY STRATEGY FOR THE MMSEZ
SETTING BIODIVERSITY OFFSET GOALS AND OBJECTIVES
The success of biodiversity offsetting is highly debatable due to its success rate and what can be achieved, and the uncertainties associated with the MMSEZ makes the task even greater. Therefore, biodiversity offsets are not prescribed for projects with very high significant rating when mitigation measures have been accounted for. Even with those with moderate to high significant rating, all possible measures should be taken to ensure that the residual impacts are kept minimal. A precautionary approach needs to be applied, to ensure that the desired goals and outcomes for the biodiversity offset are higher than what has been indicated by the various specialist studies to compensate for the unknowns, as well as the fact that biodiversity offsetting is still in its infancy and their outcome cannot be adequately projected.
BIODIVERSITY OFFSET REQUIREMENTS
Application of Condition 1 for the no net loss:1. 1. Loss of the Musina Mopani vegetation, using the footprint of the infrastructure thus size (ha). 2. Decrease in the quality of the wetlands a. No certainty as this is just an estimate based on current information available and taking precautions. ▪ This will be dependent on the Final Layout, ▪ The extent of impact for example pollution as a result of the various emissions from the ear marked development is unknown, and the level of damage to the surrounding habitats is unknown. 3. Loss of Key Plant Species 4. Loss of Protected Tree Species 5. Loss of Key Faunal Species 6. Loss of Species of Conservation 7. Loss of Ecosystem Services
Application of Condition 2 for the no net loss: 1. Erosion Control
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2. Rehabilitation a. Already disturbed areas i. Re-introducing species that have been lost in the area ii. Improving the condition of the site depending on the cause of the disturbance iii. Grazing had an influence on the area, and thus the change in the land use will alleviate this impact. b. Of the areas that will be impacted by the proposed infrastructure on the conservation area 3. Management of Alien Invasive Species and Bush Encroachment a. Alien invasive species were already present on the project area thus the removal of these species and their management will improve the condition of the site. b. Alien invasive species are one of the biggest threats to biodiversity. c. Management of bush encroachment on site. 4. Storm Management on the project area 5. Protection of wetlands which are a sensitive habitat that requires protection
Table 10.1: Guidelines of appropriate offset ratios based on the impacted biodiversity feature provided by (DEA, 2017). Feature Basic offset ratio and specific Adjustments to size and/ or number requirements of the offset of offsets Composite biodiversity attributes Areas of irreplaceable Areas of irreplaceable biodiversity are not impacted by the proposed MMSEZ biodiversity Areas of composite Impact to areas of composite biodiversity significance has been avoided in this biodiversity significance project such as the CBA area and the wetlands have also been avoided. recognised in approved biodiversity policy, bioregional, biodiversity or spatial conservation plans Ecosystem status (using Offset requirements will need to be adjusted for the habitat condition, where poor most up-to-date and reliable condition relative to the receiving area will be given an adjustment ration of 0.5X biodiversity information, and and where the habitat condition is pristine relative to the receiving area will be applying all relevant adjusted at 2X, whilst similar conditions will be 1X. criteria for listing threat status (e.g. criteria
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established in GN 1002 see DEA, 2011)11. Species threat status (using Four protected tree species occur in the project area, covering a large area. It is most up-to-date and reliable suggested that due to the occurrence of these trees throughout the project area biodiversity information). and the large amount that may be lost due to their removal from the study area. Special habitats. Special habitats in the MMSEZ includes the Riparian vegetation sub-unit. Buffer areas have been added to this vegetation to avoid and minimise impact on this vegetation. Biodiversity process Important ecological, The MMSEZ study area does not transverse Important ecological, corridors (e.g. linking Corridors or areas important for ecological functioning areas. There is no need mountains to coast, along to increase the offset. gradients, linking protected areas or other priority areas for biodiversity) or areas important for ecological functioning. Ecosystem services Areas that provide Ecosystem services currently provided by the proposed MMSEZ study area have ecological goods and been considered in the calculation of the offset area. To ensure that the offset services of high value to area compensates for the ecosystem services currently provided by the proposed communities or society as a MMSEZ study area, rehabilitation of degraded sites of the proposed biodiversity whole, and on which there is offset have been considered. a high level of dependence.
Table 10.2: Determining the adjustment factor/multiplier to determine the biodiversity offset area required for the MMSEZ study area. Biodiversity Risk and Condition of Biodiversity Total Rationale Offset Areas uncertainties the Habitat Priority Option 1: 2X 0.5 1X 1X 1. A number of risks and South Site uncertainties are MMSEZ associated with the MMSEZ SEZ such as the impact of Gas Emissions (climate change) on Biodiversity, the impact of the air
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quality on the Biodiversity and the Groundwater 2. Condition of the Habitat is better in the offset area, as it includes an Area that has been mapped as HIGH sensitive (Digby Wells, 2019) and is found within the CBA area. 3. According to the Limpopo Conservation Plan this area is not in a CBA area (Desmet, 2013) Option 2: 2X 0.5 1X 1X 1. A number of risks and North Site of uncertainties are MMSEZ associated with the MMSEZ SEZ such as the impact of Gas Emissions (climate change) on Biodiversity, the impact of the air quality on the Biodiversity and the Groundwater 2. Condition of the Habitat is anticipated to better in the offset area, as Option 2 is found in a CBA 1 and CBA 2 area. The impacted areas will be used for the North Site MMSEZ, whilst
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the HIGH sensitive areas will be used for the offset. 3. According to the Limpopo Conservation Plan this area is not in a CBA area (Desmet, 2013) Option 3 2X 2x 1X 4X 1. A number of risks and uncertainties are associated with the MMSEZ SEZ such as the impact of Gas Emissions (climate change) on Biodiversity, the impact of the air quality on the Biodiversity and the Groundwater 2. Condition of the Habitat is unknown, thus a precautionary multiplier has been used. 3. According to the Limpopo Conservation Plan this area is not in a CBA area (Desmet, 2013)
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Table 10.3: Determining the adjustment factor/multiplier to determine the biodiversity offset area required for the MMSEZ study area. Impacted Proposed Offset Ratio Basic Adjustment Biodiversity Rationale Area by MMSEZ (ecosystem) offset factor offset the residual ratio Required(ha) proposed footprint MMSEZ (Ha) Musina 6181 0 - - 1 x Option 1: - MEDIUM sensitivity Mopane (Option Option 2: - Footprint is an over Bushveld 1 and Option 3: estimation as some of the 2) infrastructure in the sensitive - 4 x area will be moved to this (Option vegetation type and project 3) layout has not yet been updated. The footprint of some infrastructure is to be confirmed o Total Area of SEZ: 8761 (ha) o Area of Conservation area including CBA 2 area and Limpopo Ridge Area in the Northern Section of the project boundary: 2422,8 o Wetlands (Digby Wells, 2019): ~1230 ha for the 17 delineated pans, two of these pans do not occur within the project area. A 500 cautionary buffer has been added to these wetlands.
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o Riparian Vegetation Digby Wells, 2019): 155 (ha)
- Ecosystem Status is Least Threatened - Conservation Target is 19%, thus no basic offset ratio is required. - Large Area of Protected Tree Species - Habitat for Faunal SCC - Regional extent of this vegetation type
Limpopo Limpopo Ridge Bushveld has been delineated as HIGH Sensitivity, development in this area has been Ridge avoided thus no offsetting of this vegetation type is required. Bushveld
Riparian The Riparian vegetation has been delineated as HIGH Sensitivity, development in this area has been Vegetation avoided thus no offsetting of this vegetation type is required.
WETLAND OFFSET REQUIREMENTS
To calculate the wetland offset for the MMSEZ development project the Wetland guideline was used (Macfarlane et al., 2014). The aim of the guideline is to provide guidance for wetland offsets where “wetland offsets required as part of water use authorization processes (e.g. in an application for a Water Use Licence under the National Water Act) where wetland offsets are significant to achieving water resource objectives, including both National Water Resource Management and Water Resource Quality Objectives, through their use to ensure sustainable ecosystem functioning and use at a catchment level.”
With the use of the Freshwater Impact Assessment and Flora and Faunal Assessment by Digby Wells (2019) the Wetland Functionality Targets, Ecosystem Services Targets and Species conservation
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Targets could be calculated. The calculations were done using the Wetland Offsets Calculator Revised version 5.
A total of 17 pans were delineated in the Freshwater assessment (Digby Wells, 2019) (Figure 10.1). The artificial impoundments and drainage lines were not included as the guidelines does not provide details on how their offset should be calculated. In total 15 pans were assessed, Pan 10 and 11 have been excluded from the study area due to these falling outside the project boundary and being more than 500 m from the project boundary.
Figure 10.1 Pans delineated by the Freshwater Assessment for the proposed SEZ project area (Digby Wells, 2019). A 500 m buffer has been added to each pan.
WETLAND FUNCTIONALITY TARGET
Most of the wetlands were found to be largely natural (PES B) and two were unmodified natural (PES A) wetlands (Digby Wells, 2019). The Wetland functionality target considers the difference in the condition
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REPORT NO 20MC-MMSEZ-BIOD-03 and area of the wetland before and post development. It is expected that the condition of these wetlands would decrees, even though no wetland loss is anticipated.
ECOSYSTEM CONSERVATION
To determine the Importance weighting for the Regional and National Conservation Context the CBA according to the regional Limpopo Conservation Plan (2013) was used. The various pans fell in CBA 2, ESA 1 and ONA shown in Figure 10.2, the respective weighting for these categories are shown in Table 10.4. To determine the Ecosystem Status, the Threat status and Protection status weightings were determined by assessing the vegetation type according to the National Vegetation Map (Musina and Rutherford, 2012). Most of the pans occurred in the Musina Mopane Bushvelds, whilst only one occurred in the Limpopo Ridge Bushveld. According to Musina and Rutherford (2012) both these vegetation types are least threatened and poorly protected (Digby Wells, 2019).
Local Site Attributes included importance of the biota found in these pans, the land use around the wetlands (51m buffer) and the connection of the pans to other water resources, this was informed by the Wetland Impact Assessment , Flora and Fauna Assessment and desktop assessment (Digby Wells, 2020). Macroinvertebrate taxa were found in two of the four assessed pans (Digby Wells, 2019). The macroinvertebrate taxa that was found to occur in the pans were indicative that the pans can support a fairly high degree of biodiversity (Digby Wells, 2019). All pans were assessed to have a high Ecological Importance and Sensitivity (EIS) value (Digby Wells, 2019). Surrounding land use varied between the livestock and the game farms thus having a different score (Digby Wells, 2019).
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Figure 10.2: Critical Biodiversity Areas of the pans delineated as per the Freshwater Assessment (Digby Wells, 2019) for the proposed SEZ project area (Limpopo Conservation Plan, 2013).
Figure 10.3: Pans occurring on the SEZ fall within the Musina Mopane Bushvelds and Limpopo Ridge Bushveld according to the National Vegetation Map (Mucina and Rutherford, 2012).
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The freshwater assessment states that there are limited mitigation measures that can be implemented during the construction and operation phase of the SEZ developmental project (Digby Wells, 2019). Table 10.4 calculations have been based on the wetlands being protected and thus the change would be a result of indirect impacts.
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Table 10.4: Variables used to Calculate the Wetland Offset. Offset No of Area (ha) Wet- Wetland Regional and National Ecosystem Ecosystem Status Local Site Attributes (Weighting) Species Calculati Pans Health functionality Conservation Context Conservation Conserv on No. Category Target (Impact Targets ation (PES) Assessment) Impact Target Assessment Change in CBA Importance Threat Protection Importance Buffer Connection Functional Value weighting of Level of Biota (20%) (10%) (%) CBA (70%) 1 2 0,37 A 86 ESA1 0.75 0,36 1 1 0.7 0.2 0.075 N/A 2 3 0,20 B 72 CBA2 1 0.16 1 1 0.7 0.1 0.075 N/A 3 8 0,53 B 72 ESA1 0.75 0.43 1 1 0.7 0.1 0.075 N/A 4 1 0,03 B 72 ONA 0.5 0.024 1 1 0.7 0.1 0.075 N/A
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10.5.1 SPECIES OF CONSERVATION TARGET
Historical records showed that a number of SCC of flora and Fauna to potentially occur on the SEZ during the desktop assessment , these with the SCC found during the site visit for the Flora and Fauna Assessment and the Freshwater assessment (Digby Wells, 2019) have been included in the assessment of SCC targets as part of the Wetland Offset calculations. The Flora and Fauna Assessment (Digby Wells, 2019) states that the construction phase without mitigation measures will result in the SEZ having a major impact on the loss of both floral and faunal SCC. In the Freshwater Assessment the loss of SCC was not assessed on its own and from the report there were no SCC that were highlighted or flagged as potentially occurring on in the pans nor as having a moderate or high negative impact rating.
The Wetland offset calculator guideline requires that the species assessed are those which will be potential moderately or highly negatively impacted by the proposed project. Our evaluation of the desktop SCC and those which were recorded during the two assessments were found to not fit this criterion (Table 10.5, Table 10.6, Table 10.7, Table 10.8 and Table 10.9). Below is a short description of these species noting their conservation status, reasons for their need to be conserved, the likelihood of their likely occurrence in the pans and their dependance on the pans thus motivating the need or lack thereof to be assessed as part of the Wetland Functional Targets.
10.5.2 BOTANICAL SCC
According to the Freshwater Assessment Vegetation at the pans varied depending on the condition of the pans, several of the these were bare having little vegetation , whilst those with vegetation had grass species and shrubs, with no Species of Conservation Concern (SCC) recorded.
Table 10.5: Tree Species of Conservation Concern on proposed SEZ project area. Family Scientific Conservation Basis of their Freshwater Comment Name Status conservation Assessment, Flora (Common Status and Fauna Name) Assessment and Protected Trees Assessment
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BRASSICACEAE Boscia • National • Threats to • Found in the • The albitrunca Forest Act this surrounding occurrence (Shepherd’s 1998: species areas of the of this tree trees) Protected include pans. species Tree increased near the pressure pans does on not warrant harvesting this species of to be part of branches this during assessment drought as it is not a conditions wetland (Alias et al., species and 2003). does not • This depend on species the wetland. may have been placed on this list as it was not adequately protected in other legislation, when there were reasons to.
MALVACEAE Adansonia • National • According • Freshwater – digitata Forest Act to the NFA, Assessment (Baobab) (NFA) 1998: This (Digby Wells, Protected species 2019) states Tree may have that the • LEMA been species was Schedule 12 placed on Found in the this list as it surrounding
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was not areas of the adequately drainage lines protected and not the in other pans. Thus, legislation species will not when there be assessed. were reasons to. • Threats include climate change which has resulted in the decline in its populations (Sanchez et al., 2011).
10.5.3 FISH SCC
The Freshwater assessment report found no fish species in the project area, but historical records show that a single SCC may occur in the region (QDS 2229DB).
Table 10.6 Fish Species of Conservation Concern on proposed SEZ project area. Scientific Conservation Basis of their Freshwater Assessment Comment Name Status conservation Status (Digby, 2019) (Common)
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Oreochromis • Red List: • Threats to this • According to the • Due to the mossambicus Threatened species include other Freshwater Assessment, nature of the in its native invasive and historical data showed pans, range problematic species the possible occurrence drainage (Darwall et al., such as the Nile of this species in the Sand areas and 2009). Tilapia (Oreochromis River. watercourses • Vulnerable niloticus) which • However, site visit , this species showing a hybridizes with it, illustrated the is not a target decreasing loss of genetic unlikelihood of fish and thus has trend (IUCN, diversity and species occurring in the not been 2019) disease such as study area due to the assessed. Pansteatitis (Bills, conditions of the 2019; Huchzermeyer watercourses and et al., 2017; Zengeya drainage lines. et al., 2013; Darwall • The assessment found no et al., 2009). fish species in the pans.
10.5.4 AVIFAUNAL SCC
The Fauna and Flora assessment report states that of the 13 SCC bird species that may occur in the study area, two of the these have wetlands as preferred habitat (Digby Wells, 2019). Ciconia nigra and Leptoptilos crumeniferus use wetlands for foraging and habitat respectively (Digby Wells, 2019).
Table 10.7: Bird Species of Conservation Concern on proposed SEZ project area. Scientific Name Conservation Basis of their Flora and Fauna Comment (Common Status conservation Assessment (Digby, Name) Status 2019) Ciconia nigra Red Data List: - • Historical record • Pans may not Vulnerable (Taylor shows that it occurs support their ideal et al., 2015) in the region and habitat for foraging may use wetlands for as no fish were found foraging. in the pans. But other food sources such as insects and frogs may be found in the pans.
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• Their dependence is expected to be low negative due to the nature of the pans. • These two species did not fit the criteria to be assessed as part of the Species Conservation Target.
Leptoptilos Red Data List: • Historical record crumeniferus Near Threatened shows that it occurs (Marabou stork (Taylor et al., in the region and is) 2015) wetlands are a preferred habitat.
10.5.5 HERPETOFAUNA SCC
The Fauna and Flora assessment (Digby Wells, 2019) reported none of the species found during the site visit were species of conservation concern but the desktop assessment showed that historical data shows that two SCC may occur in the region.
Table 10.8: Herpetofauna Species of Conservation Concern that occur in the region of the SEZ project area.
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Scientific Conservation Status Basis of their Flora and Fauna Comment Name conservation Status Assessment (Digby, (Common 2019) Name) Crocodylus • Red List • Decline of • Of the reptiles found • Will not be niloticus (Nile Vulnerable population and on the project are, found in these Crocodile) (SARCA, 2014) habitat quality and non were species of pans as this is quantity (Bate et SCC. not a suitable al., 2014) habitat. • Main threat to this species is the degradation of aquatic habitat (Bate et al., 2014).
10.5.6 MAMMAL SCC
Mammal species (Three large mammal SCC and a bat SCC) may occur in the region (Digby Wells, 2019). Wetlands may support these mammals (if they do occur in the project area) at certain periods, the impact to these species may be low due to other water resources nearby such as the artificial impoundments. According to the Freshwater Assessment the Game farm only has two pans whilst the other farms with many pans are livestock farms (Digby Wells, 2019).
Table 10.9: Herpetofauna Species of Conservation Concern that occur in the region of the SEZ project area. Scientific Name Conservation Basis of their Flora and Fauna Comment (Common Name) Status conservation Status Assessment (Digby Wells, 2019) and Freshwater Assessment (Digby Wells, 2019) Equus quagga • Near • Threats relevant • Large mammals • These species burchelliii (Zebra) Threatened, to this region such as Giraffe are are large and showing a includes changes restricted to the occupy a larger decreasing in land use to game farm due to the area trend (IUCN, livestock farming, fencing 2020) hunting and
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increase in • Artificial • The pans are drought impoundment has ephemeral. conditions (King been constructed • Thus, the and Moehlman, (are observed) to negative 2016). provide water impact to these Giraffa • Tops NEM:BA • Decline in resources for game species camelopardalis Protected population and and livestock. because of the (Giraffe) • Vulnerable, habitat quality. • Sensitivity map of loss of these showing a • Threats relevant the Freshwater pans is decreasing to this region Assessment Report expected to be trend (IUCN, includes changes shows that only two low negative. 2020) in land use for of the pans occurs • Thus, these human on the game farm. three species development, • The Delineated pans have not been habitat loss and are about 0,37 ha. added as illegal hunting • The pan is Species and (Muller et al., ephemeral in nature Conservation 2018). target in this Panthera pardus • Tops NEM:BA • Decline in assessment. (Leopard) Protected population • Red data List of because of Mammals factors such as Vulnerable habitat (Friedman and fragmentation Daly, 2004) and the decline in • Vulnerable, prey base (Stein showing a et al., 2020; decreasing Swanepoel et al. trend (IUCN, 2016). 2020) • Threats are mainly a result of anthropogenic impacts such as land use conversion, trophy hunting and retaliatory killings (Stein et
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al., 2020; Swanepoel et al. 2016). Myotis tricolor • Red data List of • A 2016 Red data • Project area has • Bat species Temminck’s hairy Mammals List Assessment natural habitat which use wetlands bat Near shows that the may provide suitable for foraging.
Threatened species is now foraging habitat for The pans may (Friedman and Least Concern bats. provide insects Daly, 2004) (Monadjem et al., for bats. 2016). • Due to the species no longer being a SCC and the loss of the pans will not have a moderate or high impact, this species has not been added as a target species.
IDENTIFICATION OF POTENTIAL OFFSET AREAS
The choice of offset area and activity will be constrained by land and resource availability. The following potential offset areas for the MMSEZ were considered:
10.6.1 SITE OPTION 1: OFFSETTING ON THE SOUTHERN SECTION OF THE MMSEZ STUDY AREA
Onsite – Using information provided above about 2093 ha of the MMSEZ on site vegetation would not be disturbed and has been earmarked for environmental conservation, this includes portions of four farm potions namely 526, 580,584,585. It is estimated that about 6181 ha may be impacted by the proposed project area after mitigation measures have been put in place, this is just over triple the environmental conservation area. Figure 10.4 shows the boundary of the proposed Site option1 offset area. Two vegetation types occur in this area namely the Limpopo Ridge Bushveld and the Musina Mopane Bushveld, which the latter is the target vegetation type required for the biodiversity offset area. It is
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REPORT NO 20MC-MMSEZ-BIOD-03 expected that due to its proximity to the impacted area these two sections share similar vegetation communities and provides habitat to similar if not the same species.
Figure 10.4: Proposed Site Option 1 occurs primarily the southern portion and a small portion in the northern portion of the MMSEZ study area.
The pros of offsetting on the MMSEZ study include:
1. The Area has a CBA 2 area and has areas with intact vegetation that has been mapped as HIGH sensitive. Thus the area is better than the area that will be lost. 2. The Biodiversity offset is onsite thus issues regarding distance are not applicable. 3. The option is cost effective and buy in from the landowner has already been obtained. Thus issues of securing land are not applicable.
The cons of offsetting on the MMSEZ study include:
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1. The concern about this option is that the processes occurring in the SEZ may also result in poor conditions of the surrounding areas. Thus, it is not only a matter of area, but ecological processes that were occurring in the original area, the functioning and ecosystem services. It is anticipated that rectification through rehabilitation, control of alien invasive species, storm management of the area would be implemented to mitigate these impacts. 2. The proposed site for the biodiversity offset is less than one third of the area that will be lost as a result of the proposed MMSEZ, thus in terms of size it would not meet the requirements. 3. Thus it is anticipated that this would reduce the negative impacts associated with the project but it would not be sufficient as the only offsetting site due to the following
Summary: Description of Site Option 1 Property Information Farm Area Portion (Ha) 580 663 584 630 585 535 526 396
Current Land use: (see map above 6.2) Availability of Land: Area has been secured Vegetation Type: Limpopo Ridge Bushveld (SVmp 2) Musina Mopane Bushveld (SVmp 1) (see map above 5.4) CBA: CBA 2 (see map above 7.1.1) Distance to Study Site 0 km Distance to Protected Area 0 km to Avarel Private Nature Reserve Wetland Offsetting: Four of the delineated pans classified as Category B are found in this area. Since the loss of the pans will be avoided and impact minimised, it is expected that with the mitigation measures put in place, that the rehabilitation and protection of these 4 pans will compensate for the residual impacts. Biodiversity Offsetting About 2093 ha is available for the offset once mitigation measures have been implemented. Due to the proximity (being onsite) and the area being of better of higher sensitivity (including CBA 2 area ) thus
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better condition, it is anticipated that this conservation area will be beneficial to key biodiversity species and the intact vegetation.
10.6.2 SITE OPTION 2: OFFSETTING ON THE NORTH SITE OF THE MMSEZ
The North Site of the MMSEZ (Antonvilla) is approximately 3900 ha. The proposed development on this site is about 375 ha. This Site Option 2 is proposed for the offsetting of the North Site and for the South Site MMSEZ. According to the Record decision for the North Site MMSEZ, a biodiversity offset is not a requirement, but it has been proposed that a certain portion of the remaining area to also account for the offsetting of the North Site. The South African Protected Areas Data shows that the Baobab Tree Reserve occurs at the boundary of the North Site. Other Protected Areas in the surrounding area included the Honnet Nature Reserve and the Nwanedi Nature Reserve. The NPAES Focus Area occurs within the proposed North Site Area. Two vegetation types occur in this area namely the Limpopo Ridge Bushveld and the Musina Mopane Bushveld. A large portion of the area is the Limpopo ridge area (2437 ha) whilst the target vegetation type, the Musina Mopane Bushveld is about 1462 ha. Thus this area will not be enough for the proposed Biodiversity offset as it does not meet the requirements.
Figure 10.5: South African Protected Areas and NPAES Focus Area occurring in the surrounding areas of the North Site MMSEZ.
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Figure 10.6 South African Protected Areas and NPAES Focus Area occurring in the surrounding areas of the North Site MMSEZ
Figure 10.7: South African Protected Areas and NPAES Focus Area occurring in the surrounding areas of the North Site MMSEZ
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Figure 10.8: NFEPA Rivers and Wetlands occurring the North Site MMSEZ
The pros of offsetting on the North Site of the MMSEZ study include:
1. The Area is a CBA 1 and CBA 2 area. 2. Aerial imagery of this area shows that is a potential for HIGH sensitive areas especially on the ridges, and near the river, protection of this area would be good for conservation. 3. Vegetation types occurring on the Site area are the targeted vegetation types. 4. Site occurs near the Baobab Tree Reserve and a focus area occurs in this site areas. 5. A large area, about 3625 ha will not be used by the development thus could be used as an offsetting area 6. The option is cost effective and buy in from the landowner has already been obtained. Thus issues of securing land are not applicable.
The cons of offsetting on the North Site MMSEZ study include:
1. North Site occurs much further from the site.
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2. The area not used by the development would need to consider both the residual impacts from the activities associated with the North Site and the South Site MMSEZ. Thus the available area is not yet clear as the Ecological Impact Assessment for the North Site is not yet available. 3. The Site does not have any wetlands or pans thus would not be able to compensate for the residual impacts on wetlands. 4. The area does not have sufficient area of the Musina Mopane Bushveld vegetation.
Summary Description of Site Option 2: North Site MMSEZ Property Information Farm Portion Area (Ha) Portion 1 of the farm 3900 Antonvilla 7 MT
+
Current Land use: Agricultural zone. Has been previously used for mining. Area has disturbed areas due to the mining and old infrastructure. Vegetation Type: Limpopo Ridge Bushveld (SVmp 2) Musina Mopane Bushveld (SVmp 1) (see map above 5.4) CBA: CBA 2 (see map above) Distance to Protected Area and 0 km to the Baobab Tree Reserve and the Blouberg Langjan Focus NPAES Focus Area Area occurs in the project area. Wetland Offsetting: No wetlands occur on this Site thus wetland offsetting would not be achieved. Biodiversity Offsetting About 3625 ha is available for the offset, but only 1462 ha is the Musina Mopane Bushveld.
10.6.3 OPTION 3: OFFSETTING ON A 3RD PARTY SITE NEARBY
Site Option three is found close to the MMSEZ study area, it has a large area of the targeted vegetation type (Musina Mopane Vegetation). Other features are shown in the two maps below, which include the occurrence of two NFEPA wetlands (Figure 10.9).
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Figure 10.9: Site Option three, showing Farm portion numbers, vegetation types, and proximity to MMSEZ study area , protected areas and Focus area.
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Figure 10.10: CBA areas , NFEPA rivers and wetlands found in Site Option 3 area.
The pros of offsetting on Option 3 Site of the MMSEZ study include:
1. Large area of the targeted vegetation type (Musina Mopane Vegetation). 2. Site occurs near protected areas and a focus area. 3. Could be used to expand the Avarel Private Nature Reserve 4. Site has two wetlands and a river crosses the site 5. Includes the Limpopo Ridge Bushveld, thus this would be a net gain with regards to the biodiversity offset requirements.
The cons of offsetting on the North Site MMSEZ study include:
1. Option will be costly as the site area needs to be secured. 2. Landowners of the area site area are unknown at the present stage. 3. Land might not be available
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4. The Site does not have any wetlands or pans thus would not be able to compensate for the residual impacts on wetlands. 5. Area is largely classified at Other Natural Areas (ONA), rehabilitation is not guaranteed that targets will be reached. Thus a higher adjustment factor will be required for this Site.
Summary Description of Site Option 3: Large Musina Mopane Vegetation Property Information Farm Portion Area (Ha) 516 827 569 857 147 345 148 933 149 808 154 5001 1/157 354
Availability of Land Unknown. More research and public participation would need to take place to determine if the area is available to be used as a conservation area. Vegetation Type: Limpopo Ridge Bushveld (SVmp 2) and Musina Mopane Bushveld (SVmp 1) (see map above) CBA: CBA 2 (see map above) Distance to Study Site Approximately 7 km Distance to Protected Area and 0 km to Avarel Private Nature Reserve. Other Protected areas NPAES Focus Area and focus areas nearby. Wetland Offsetting: Two wetlands occur on this Site thus wetland offsetting may be achieved. Biodiversity Offsetting About 9768 ha is available for the offset once mitigation measures have been implemented. Large portion of this area is the Musina Mopane Bushveld Vegetation.
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SUMMARY ON OFFSET SITE
- Restoration takes time and huge capital investment, thus more effort would be required for Option 3, whilst it would not be certain that the Biodiversity objectives will be met. Compared to the other two areas more effort would be required. - Option 2 and Option 3 occur in a Focus Area, meaning that it is targeted for conservation. - Overall Biodiversity offset target might be met if a combination of Site Option 1 and Site Option 2 are used together, even though Site Option 2 is much further away. - All the site options inhabit the targeted vegetation type.
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MANAGEMENT, MONITORING AND EVALUATION SYSTEMS
STAKEHOLDER ENGAGEMENT PROCESS FOR PROPOSED OFFSET SITE
The identification and evaluation of potential offset sites in this report considered two options: • Portions of land currently owned by MMSEZ and earmarked for offsetting or conservation. • Portions of land currently owned by the State or individuals that is deemed potentially suitable for offsetting.
Hence, a stakeholder engagement process is necessary for the MMSEZ to identify, evaluate and acquire potential offset sites in addition to the portions of land earmarked for offsetting or conservation. This section describes the stakeholder engagement model to be utilized by MMSEZ in identifying, evaluating, and acquiring additional offset sites.
The stakeholder engagement platforms for this task should include meetings, workshops, phone calls, emails etc. Relevant stakeholders must be identified and engaged once a potentially suitable offset site has been identified and selected. The relevant stakeholders would typically include the landowner(s) and occupant(s), nearby landowner(s) and occupant(s), communities, Non-Governmental Organizations, trade organizations, local and provincial government etc.
The role and responsibility of each stakeholder must be defined to ensure that all relevant stakeholders participate accordingly on the task to ensure successful implementation.
A four-phased approach to stakeholder engagement management as shown in Figure 11.1 is recommended for adoption.
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Stakeholder Engagement Management
Who are your stakeholders? Who is important? • Development of a list of everyone who can • Determine which stakeholders to affect or is affected by Identify the project. spend more time • Stakeholders are both managing internal or external • Establish the Analyse stakeholders’ power and interest
Stakeholder Engagement Management
Engage How will you manage your stakeholders? How will you engage your Plan • Determine which stakeholders? stakeholders to spend • Choose the most efficient more time managing and effective engagement • Develop approach for each communication plan stakeholder group • Identify strategies
Source: Stakeholder Management https://www.stakeholdermap.com/stakeholder-management.html. Figure 11.1: Stakeholder engagement management • Phase One is stakeholder identification, where a comprehensive list of the all the stakeholders that need to be engaged is developed.
• Phase Two involves the analysis of stakeholders to determine the stakeholders that must be invited for public consultation workshop, and those that will be engaged via other platforms.
• Phase Three involves planning the communication strategy and materials to be presented via various stakeholder engagement platforms.
• Phase Four involves engaging the stakeholders through the suitable platforms identified.
In analyzing the identified stakeholders, these should be mapped and grouped according to the power or influence they have on other stakeholders and the task, as well as their interest in the overall Project (Figure 11.2).
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Figure 11.2: Stakeholder analysis and classification based on influence
ROLES AND RESPONSIBILITIES FOR OFFSET IMPLEMENTATION
It is the responsibility of MMSEZ to commission an offset management team or service provider to oversee the implementation and continuous management of the offset strategy. The team should be led by a Biodiversity Offset Manager with the necessary expertise to manage the execution of the biodiversity offset strategy; and may consist of Site Coordinator(s), Conservation Officer(s), Field Ranger(s), Field Intern(s) etc. as required. The Biodiversity Offset Manager should report directly to the Executive in charge of Infrastructure Development at MMSEZ (or similar role).
All aspects of the offset implementation, including offset risk assessment, offset monitoring, and reporting will be undertaken by the offset management team. A requirement for submission of quarterly offset report to MMSEZ and annual offset report to the Competent Environmental Authority should be instituted.
OFFSET ENFORCEMENT
To ensure that the objectives of the Biodiversity offset strategy are met, enforcement plays an important role as it ensures that all that had been planned is carried out this included monitoring , management and auditing of the offset area.
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OFFSET MONITORING AND EVALUATION
Monitoring and Evaluation are the primary mechanisms to assess whether the offset is meeting its targets over various spatial and functional scales. Monitoring and evaluation should be considered a key component of offset implementation and receive adequate attention in the offset budgeting process.
Monitoring activities should be planned and instituted as part of the offset implementation plan. For example, monitoring activities should be instituted to examine whether the significant environmental impacts occur as predicted or to establish whether mitigation measures are effective as anticipated. Indicators should be determined as part of the implementation plan and should include a measure of variables over time used to measure achievement of objectives. These indicators should be specific, measurable, achievable, relevant, and timely.
Effective monitoring requires quarterly or annual performance reports on the implementation of the set targets and objectives. These performance reports must include the extent to which the target or plan has been implemented during the period, new initiatives and protocols undertaken during the reporting period, gaps and challenges encountered during the reporting period.
AUDITING AND VERIFICATION
In the case of the biodiversity offset for the MMSEZ, auditing and verification must involve reviewing, inspecting, testing, checking, establishing, and documenting that the planned and projected biodiversity outcomes of the offset have been achieved. Verification may be undertaken by MMSEZ, however, a second party (service provider) or a third party (an independent institution) verification process will instil credibility in the process.
OFFSET AREA PROCLAMATION
The proclamation of the MMSEZ offset site(s) as nature reserve(s) in terms of Protected Areas Act No. 57 of 2003 section 23(1) is recommended.
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MECHANISM FOR FUNDING THE OFFSET
The funding mechanism for the MMSEZ offset should be based on strategic costing and planning (ongoing as at the time of report compilation) to determine where the financial resources to meet the projected costs will come from, and how they will be managed. The assessment of revenue options represents a key step in the implementation of the offset strategy. Several types of mechanisms are possible, including endowments, sinking funds, revolving (recurrent) funds or a combination approach.
11.7.1 FUNDING OPTIONS
Long-term financing options to be considered by MMSEZ are briefly discussed.
1. Standard annual project financing can be used to provide consistent funding over a specific time to implement offset management activities. 2. An endowment is a fund where the financial assets, or capital, of the fund are invested to earn income (interest) and only that income is used to finance agreed-upon activities. Investments may include bonds, private bank accounts, real estate, etc. Although there are different types of endowments, they are generally thought of as permanently invested resources that generate funds on a continuing basis. 3. Sinking funds are designed to disburse their entire principal and investment income over a fixed period until the value of the fund sinks to zero. When sinking funds are set up for relatively short terms, they operate more like typical project financing. However, many sinking funds are established to address longer term funding goals and usually operate for a relatively long period.
11.7.2 FUNDING INSTRUMENTS
11.7.2.1 CONSERVATION TRUST FUND
A conservation trust fund (CTF) is a funded, tax-exempt organisation to support specific conservation activities in perpetuity, such as the offset activities proposed for the MMSEZ. CTFs are private, legally independent institutions that provides sustainable financing for biodiversity conservation. The funds can be derived from one or more of the funding options described in Section 11.7.1. A CTF can directly finance operations of an offset, provide direct payments to support offset management and provide finance for all the cost of implementing and managing the biodiversity offset.
The establishment of a CTF for the MMSEZ offset activities prior to commencement of construction activities at the MMSEZ sites will ensure that sufficient funds are available for the activities and that the
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REPORT NO 20MC-MMSEZ-BIOD-03 funds are kept and managed in a separate instrument from the financial and operational mechanisms of the MMSEZ.
The costs associated with all MMSEZ offset activities, which should be kept in a trust, are classified under the following:
• Programme costs: these are the costs associated with undertaking the offset activities themselves. • Operating costs: these are the costs associated with administering and managing the offset. • Monitoring and Evaluation costs: these are the costs of auditing and checking whether the offset is achieving its objectives. • Future costs: these considers potential increases in costs over time, inflation and assess risk factors that will lead to unanticipated expenditures to ensure that sufficient funds are available in the future to manage the activities.
Trust Fund Governance The establishment of the CTF should be structured within the legal and institutional context in which the MMSEZ was established. The following governance issues should be considered:
• The CTF should be a legally created entity, governed by an independent board of trustees. • The board should have fiduciary responsibility for the funds held and managed by the trust. • The board should be responsible for overseeing the offset management team or service provider to manage the implementation of the offset strategy. • The board raises and manages long-term financing for biodiversity conservation and / or protected areas. • The CTF’s management should generally create an investment policy and spending rules to determine how money will be managed and to create constraints on its use. • Securing the support of stakeholders, including national, provincial, and local governments and communities, in the development of the trust fund is vital. Given the role a conservation trust fund play in supporting conservation activities in an offset, it will be important to ensure stakeholder support for the fund and its objectives.
11.7.2.2 BIODIVERSITY OFFSET AGREEMENT
A biodiversity offset agreement can also be regarded as a viable instrument for funding offset activities. These agreements are often undertaken between project proponents, organs of state, established
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REPORT NO 20MC-MMSEZ-BIOD-03 conservation entities and/or heritage sites (which the project will have a direct impact on due to proximity), and other affected entities and communities. The agreement typically details the type, scale and function of various activities, projects, rehabilitation efforts and commitments to be observed over the life of the project to ensure that the effect of the project impacts are adequately addressed.
It is not apparent if a biodiversity offset agreement would suffice as a funding instrument or guarantee for the MMSEZ offset activities, hence an evaluation of this instrument should be investigated.
COMMUNITY INVOLVEMENT AND RESEARCH
It is suggested that to even uplift the community, the community may be encouraged to be part of restoration programmes. Funding would need to be included which will consider the monitoring of the site that would need to occur, due to it being estimated to take several years, monitoring and studies should take place. There should also be a buy in from nearby academia, fostering research into documenting the success of the area to be able to determine if really there is an improvement in the area.
BUILDING SUSTAINABILITY AND SOCIETAL BENEFITS INTO THE OFFSET
FUNDING PROGRAMME
A vital consideration for offset planning is that successful offset implementation requires the development of a revenue generating strategy that can ensure long-term offset financing and the nearby communities and the society can derive benefits from. Ideally, the project developer will provide sufficient funds to create a funding mechanism, such as a conservation trust fund, which can generate long-term revenues needed to support offset activities and ensure nearby communities derive benefit from. The offset programme must consider sustainable options that can generate additional benefits for nearby communities and the society at large.
• Offset activities should contribute to ecotourism and agroforestry in a manner as to ensure that communities and businesses derive benefit from it over time. • Offset activities should engender a local or regional improvement in ecosystem services, by providing means to ensure protection of ecological function, reduce local business risk, and engender economic benefits for communities.
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BIODIVERSITY OFFSET FINANCIAL PROVISION
The identification and evaluation of potential offset sites in this report considered two options: • Portions of land currently owned by MMSEZ and earmarked for offsetting or conservation. • Portions of land currently owned by the State or individuals that is deemed potentially suitable for offsetting.
In quantifying the projected cost of acquiring, securing, rehabilitating, and managing the offset site(s), one scenario is presented as follows: • Projected cost of acquiring, securing, rehabilitating, and managing the offset site(s) (if half of the land area required for offset is already owned by MMSEZ and earmarked for offsetting or conservation)
The financial provision accounts for the first year of implementation as well as a subsequent recurring year for the life of the main project components (estimated at 30 years). It is anticipated that the implementation and management of the offset activities will exceed this projected 30 years.
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Table 12.1: Projected cost of acquiring, securing, rehabilitating and managing the offset site(s) (if half of the land area required for offset is already owned by MMSEZ and earmarked for offsetting or conservation)
Financial provision to secure and manage biodiversity offset A: Estimated cost of acquiring and securing offset land Anticipated cost of offset (R) Anticipated cost of offset (R) Ecosystem type Average cost of land in the vegetation type (R/ha) Offset area (ha) (1st year/Once Off Cost) (2nd year / recurring annual cost) (name) 30 000.00 2 6 181.00 77 262 500.00 - (name) ------Land survey costs 1 500 000.00 - Legal transaction costs (e.g. lodging notarial deeds, gazetting, advertisements, or legal notices) 6 181 000.00 - Costs of fencing, equipment, infrastructure needed to implement offset 6 597 400.00 - Other (e.g.: Signage, compensation of affected parties) 500 000.00 - Total cost 92 040 900.00 - B: Estimated cost of offset establishment Anticipated cost of offset (R) Anticipated cost of offset (R) Item Area, number, or extent (1st year/Once Off Cost) (2nd year / recurring annual cost) Costs of any permits, authorizations triggered by offset WULA 350 000.00 - activities (e.g. rehabilitation works) Costs of fencing, equipment, infrastructure needed to - - - implement offset Cost of relocating and transplanting protected trees ~6181 hectare 5 000 000.00 - Other (e.g. signage, compensation of affected parties) - - Total cost 5 350 000.00 - C: Estimated cost of intensive initial management
2 https://www.foodformzansi.co.za/after-17-year-wait-limpopo-farmer-finally-gets-his-land-from-government/ https://www.businesslive.co.za/bd/national/2020-01-19-state-drags-its-feet-over-land-sale-to-limpopo-farmer/
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For each ecosystem type and for offset area as a whole Anticipated cost of offset (R) Anticipated cost of offset (R) Item Area, number, or extent (1st year/Once Off Cost) (2nd year / recurring annual cost) Rehabilitation of eroded areas or physical / structural 309.05 463 575.00 416 625.00 rehabilitation work Intensive clearing of dense infestations of invasive alien 618.10 1 545 250 154 525.00 species Costs of any permits, authorizations triggered by offset - - - activities (e.g. rehabilitation works) Total cost 2 008 825.00 664 457.50 D: Estimated cost of annual management For each ecosystem type and for offset area over the required timeframe, considering escalation/inflation Anticipated cost of offset (R) Anticipated cost of offset (R) Item Area, number, or extent (1st year/Once Off Cost) (2nd year / recurring annual cost) Fire management 61.81 1 545 250.00 1 699 775.00 61.81 Erosion management 309 050.00 339 955.00 Alien and invasive species control/ management 61.81 1 545 250.00 1 699 775.00 61.81 Faunal management 772 625.00 849 887.50 Total cost 4 172 175.00 4 589 392.50 E: Other costs For each offset area Anticipated cost of offset (R) Anticipated cost of offset (R) Item (1st year/Once Off Cost) (2nd year / recurring annual cost) Administrative costs 1 236 200.00 1 359 820.00 Risk/premium insurance 1 112 580.00 1 223 838.00 Human resources costs 1 250 000.00 1 375 000.00 Infrastructure development and maintenance 1 000 000.00 100 000.00 Road and trail maintenance 250 000.00 275 000.00 Operational / running costs 500 000.00 550 000.00
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Monitoring and auditing costs - 500 000.00 General projects - - Total cost 5 348 780.00 5 383 658.00
Total cost of offsets 108 920 680.00 10 637 508.00
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RECOMMENDATIONS
The biodiversity offset strategy for the MMSEZ is based on the ecosystem approach to biodiversity management. This approach promotes the integrated management of land, water, and natural resources to achieve optimal conservation and sustainable use of biodiversity. It is aimed at strengthening co- operation between various parties towards the conservation and sustainable development of the MMSEZ Site. It is also aimed at maintaining the integrity of the site and ensuring that the negative impacts of development are avoided, minimised, or remedied in the pursuit of sustainable development, and as a last resort, offsets are implemented. Several recommendation and action point have been provided throughout this document; however, the following are worthy of note:
- This report has clearly identified the avoid, mitigate, rehabilitate hierarchy for every biodiversity feature found on site. A strict adherence is recommended. - Clearance of vegetation is not recommended until the mechanisms of the biodiversity offset have been fully put in place. - Clearance of vegetation should not occur until it is evident that the minimal requirements required for the operation of a SEZ are first met, these include but not limited to: o Water requirements ▪ It has not yet been finalised where the water to fulfil the requirements for the SEZ will be obtained. This is crucial as it might be a determining factor whether this SEZ will be successful. ▪ An updated hydrological Assessment has been suggested in the EIR since information from the Water report is still in draft phase and as suggested by the EIR, should the information change significantly, this might also affect the results of the Offset report. - Clearance of vegetation is too high of a risk if the proposed activities (e.g. Lime plant, coke plant) has not been finalised and granted authorisation to proceed. o Thus clearance of vegetation should only occur where it is necessary, meaning no clearance should occur until the proposed activity for that particular area/zone within the MMSEZ has already been ground truth, and appropriate EIA and BA assessment has been conducted. The removal of the vegetation would thus decrease the impacts associated with the proposed activity thus they magnitude may not be realised. Removal
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of the vegetation would also indirectly put pressure on a development to go through as not there would be a need to utilise the space. o Areas with high sensitivity should not be disturbed (as per the Fauna and Flora Assessment) These areas will be cordoned, and a buffer area included to ensure that nearby activities do not impact these areas. o As per the Freshwater Assessment, no activities should occur in the wetland area and a buffer area of 51 m was deemed sufficient by the wetland specialist. It is the recommendation of this strategic report that this should be increased to 500m to ensure that the surrounding vegetation and more area around these wetlands are protected, so that it decreases the chances of pollution, soil erosion and other impacts associated with the construction and operation of the MMSEZ. This will also try to minimise the loss of ecosystem services and good provided by the wetland and riparian area. o Based on the Polluter Principle, should the activities not take place after removal of vegetation, with accompanying loss of vegetation habitat, fragmentation, loss of biodiversity, the “polluter” would still be required to manage and remedy this damage through the biodiversity offset, which all of this would not be sustainable development. - This document is written in a manner to ensure it continued use as a working document, due to the fact that currently, there is incomplete knowledge and information on the scope and nature (technology option) of the industrial activities anticipated (Also, there are still outstanding reports that will feed into this strategy that need to be taken into consideration prior to agreements and finalisation of the offset area). This ensures that the document can be continually updated with new information and to ensure that the activities that are granted permission are within the estimates that are presented and compensated in the offset.
The biodiversity offset study was commissioned to assess the impacts of the MMSEZ by following the offset hierarchy: “avoid”, “mitigate”, “rehabilitate” and “offset” options. The study sought to evaluate options and opportunities for offsetting biodiversity features that would otherwise be impacted (upon exhaustion of the “avoid”, “mitigate”, and “rehabilitate” options).
It is yet to be fully ascertained how direct and residual cumulative impacts within the region will affect the immediate environment since the nature and extent of these impacts have not been quantified or
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REPORT NO 20MC-MMSEZ-BIOD-03 assessed. Additionally, it is yet to be fully ascertained how the impacts of each individual constituent of the MMSEZ will affect the immediate environment.
Considering the complex nature of biodiversity offset programmes and their desired targets in terms of conservation, ecological status, and functionality, as well as the extent of the impacts and size of the area required for offsetting, it remains uncertain whether the MMSEZ offset programme will meet its desired objectives of achieving “net gain”. Important to note, is that, while selected activities or ecosystem services (such as translocating of trees, SCC search and rescue programmes), can be replicated and established successfully (with a good probability for success, if implemented appropriately); many ecological values, functionalities and intact ecosystems are very difficult to create with current knowledge and expertise. Added to the uncertainty are the gaps and limitations identified in this report, and without further investigation to evaluate and eliminate these issues, the certainty of achieving “net gain” for the offset programme cannot be assured.
However, the establishment of detailed biodiversity offset implementation programme and biodiversity offset management and monitoring plan will strengthen the offset implementation process and further assist the MMSEZ in achieving a “net gain” offset target.
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REFERENCES
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DEA. (2015c). NEMAQA - National Atmospheric Emission Inventory System. Pretoria: Department of Environmental Affairs (Government Gazette). DEA. (2017). Draft National Biodiversity Offsets Policy. Pretoria, SA: Department of Environmental Affairs. Digby Wells. (2019). Fauna and Flora Impact Assessment – Environmental Impact Reporting Process for the Musina-Makhado Energy and Metallurgy Special Economic Zone Development. Digby Wells. Digby Wells. (2019). The Digby Wells Fresh Water Impact Report – Environmental Impact Reporting Process for the Musina-Makhado Energy and Metallurgy Special Economic Zone Development. Digby Wells. FFI. (2015). Biodiversity Offsets: Lesson Learnt from Policy and Practice – Country Summary Report, South Africa. Fauna and Flora International. Friedman, Y., and Daly, B. (2004). Red data book of the mammals of South Africa: a conservation assessment: CBSG southern Africa. Conservation Breeding Specialist Group (SSC/IUCN), Endangered Wildlife Trust, Saxonwold, South Africa. Huchzermeyer, K. D. A., Woodborne, S., Osthoff, G., Hugo, A., Hoffman, A. C., Kaiser, H., Steyl, J.C.A. & Myburgh, J. G. (2017). Pansteatitis in polluted Olifants River impoundments: nutritional perspectives on fish in a eutrophic lake, Lake Loskop, South Africa. Journal of fish diseases, 40(11), 1665-1680. King, S. R. B., & Moehlman, P. D. (2016). Equus quagga. IUCN Red List Threat Species. LEDET. (2013). Limpopo Conservation Plan Version 2 (C-Plan 2). Polokwane: Limpopo Department of Economic Development; Environment and Tourism. Macfarlane, D., Holness, S.D., von Hase, A., Brownlie, S. & Dini, J. (2014). Wetland offsets: a best- practice guideline for South Africa. pretoria, SA: South African National Biodiversity Institute and the Department of Water Affairs. Macfarlane, D., Holness, S.D., von Hase, A., Brownlie, S. & Dini, J., 2014. Wetland offsets: a best-practice guideline for South Africa. South African National Biodiversity Institute and the Department of Water Affairs. Pretoria. 69 pages. Monadjem, A., Taylor, P. J., & Schoeman, M. C. (2020). Bats of southern and central Africa: a biogeographic and taxonomic synthesis. Wits University Press. Mucina and Rutherford. (2006). The vegetation of South Africa, Lesotho and Swaziland. Strelizia 19. Pretoria South Africa: South African National Biodiversity Institute.
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Muller, Z., Bercovitch, F., Brand, R., Brown, D., Brown, M., Bolger, D., Carter, K., Deacon, F., Doherty, J.B., Fennessy, J. & Fennessy, S. (2018). Giraffa camelopardalis (amended version of 2016 assessment). The IUCN Red List of Threatened Species, 2016-3. Sanchez, A. C., Osborne, P. E., & Haq, N. (2011). Climate change and the African baobab (Adansonia digitata L.): the need for better conservation strategies. African Journal of Ecology, 49(2), 234- 245. Stein, A. B., Athreya, V., Gerngross, P., Balme, G., Henschel, P., Karanth, U., U., Miquelle, D., Rostro- Garcia, S., Kamler, J.F., Laguardia, A. & Khorozyan, I. (2020). Panthera pardus (amended version of 2019 assessment). IUCN Red List of Threatened Species, 2020, e- T15954A163991139. Swanepoel, L. H., Balme, G., Williams, S., Power, R. J., Snyman, A., Gaigher, I., Senekal, C., Martins, Q. & Child, M. (2016). A conservation assessment of Panthera pardus. The. Zengeya, T. A., Robertson, M. P., Booth, A. J., & Chimimba, C. T. (2013). Ecological niche modeling of the invasive potential of Nile tilapia Oreochromis niloticus in African river systems: concerns and implications for the conservation of indigenous congenerics. Biological Invasions, 15(7), 1507-1521. Herrmann, E., Milton, S., Seymour, C., & Alias, D. (2003). A Collation and Overview of Research Information on Combretum imberbe Warwa (Combretaceae) and Identification of Relevant Research Gaps to Inform Protection of the Species. Contract, 6(2003/089). NAPAES, 2016: Department of Environmental Affairs (2016) National Protected Areas Expansion Strategy for South Africa 2016. Department of Environmental Affairs, Pretoria, South Africa. NSBA, 2004: Rouget, M., Reyers, B., Jonas, Z., Desmet, P., Driver, A., Maze, K., ... & Rutherford, M. C. (2004). South African National Spatial Biodiversity Assessment 2004. Technical report. Volume 1: Terrestrial component. Macfarlane, D. M., & Bredin, I. P. (2017). Buffer Zone Guidelines for Rivers, Wetlands and Estuaries Buffer Zone Guidelines for Rivers, Wetlands and Estuaries. WRC Report No TT, 715(1), 17. Desmet, P. G., Holness, S., Skowno, A., & Egan, V. T. (2013). Limpopo Conservation Plan vol 2: Technical Report. Contract Number EDET/2216/2012. Report for Limpopo Department of Economic Development, Environment & Tourism (LEDET) by ECOSOL GIS. Limpopo Department of Economic Development, Environment and Tourism (LEDET) (2017). Vhembe district bioregional plan. Revision 4: Reviewed by the Review Panel for Bioregional Plans.
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Naledzi Environmental Consultants (NEC) (2020). Protected Tree Relocation MUSINA-MAKHADO SPECIAL ECONOMIC ZONE (MMSEZ) LIMPOPO PROVINCE Report. Sanchez, A. C., De Smedt, S., Haq, N., & Samson, R. (2011). Variation in baobab seedling morphology and its implications for selecting superior planting material. Scientia Horticulturae, 130(1), 109- 117. Alias, D., Milton, S., Herrmann, E., & Seymour, C. (2003). A collation and overview of research information on Boscia albitrunca (shepherd’s tree) and identification of relevant research gaps to inform protection of the species. Department of Water Affairs and Forestry.
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DETAILS OF THE AUTHORS
Biodiversity, Environmental and Strategy Team
Name Qualifications Experience Skills
Ayanda Zide Rhodes Ayanda Zide is a Natural Resources • Biodiversity studies University: Consultant in the Strategic and Natural • Ecological 2014 Resource Services Division at Mamadi assessments and Company. Her role includes • Environmental impact BSc (Hons) assessment Botany stakeholder’s engagement, and reporting on various studies in strategy • Environmental
development, biodiversity and ecology, management plans Rhodes feasibility and research studies etc. • GIS mapping University: In her previous role as an Environmental 2013 Consultant at EOH Coastal & BSc. Botany, Environmental Services, she was Microbiology involved in a number of projects such as and Chemistry renewable energy projects, mine closure projects, baseline assessments and ground truthing assessments. Most of her work involved conducting vegetation and impact assessments that guided proposed developments to reduce their impacts on sensitive vegetation.
As part of these surveys, she would identify and map the vegetation communities and areas of high sensitivity using GIS applications and write the reports. Her role also included liaising with clients, landowners, governmental departments, interested and affected parties and manage the stakeholder
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database. Her research interests lie in estuarine ecology, conservation biology, rehabilitation ecology, plant biotechnology, biological invasions and water research.
Mpho Over 10 years’ Mpho has extensive experience in • Biodiversity studies Ramalivhana experience conducting biodiversity studies, • Ecological • BSc Hons ecological assessments, environmental assessments Botany (Plant impact assessment, environmental • Environmental impact Ecology • BSc., management plans, environmental audit, assessment Ecology and environmental due diligence, land quality • Environmental Microbiology • Pr.Sci.Nat assessment, environmental site management plans (SACNASP) assessment, environmental compliance • Environmental audit monitoring, bio-monitoring of water • Biomonitoring resources and implementation of • Environmental environmental monitoring systems. monitoring systems
Mpho has worked with the South African National Biodiversity Institute and Limpopo Department of Economic, Environment and Tourism where his professional working career started.
Mpho is a member of the South African Council of Natural Scientific, Profession and South African Association of Botanists
Dr Ola 11 years’ Ola is an experienced in environmental, • Environmental Akinshipe experience natural resource and strategic assessments • PhD Chemical environmental specialist with projects • Strategy development Technology cutting across various industries in South • Implementation plan, (Pretoria) Africa, and beyond. These projects cut monitoring and across various public and private evaluation
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• MSc institutions, including mining and ore • Baseline Environmental handling, metal recovery, power assessments Technology generation, exploration, • Feasibility and (Pretoria) chemical/metallurgical, construction, clay research studies • BSc Hons. brick, transport, processing, waste • Impact assessments Environmental management and recycling. His typical • Health and Technology projects include baseline assessments, environmental risk • Pr.Sci.Nat impact assessments, health risk screening (SACNASP) screening, management planning, • Management climate change assessment. Ola has planning also worked on specialized environmental projects involving strategy development, baseline, and feasibility studies, country-wide chemical inventory, environmental and waste management strategies
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