BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).
NAME OF APPLICANT: Pan African Mineral Development Company (Pty) Limited
TEL NO: 011 201 8121
FAX NO: 011 201 8112 POSTAL ADDRESS: PO Box 786141, Sandton, 2146 PHYSICAL ADDRESS: Upper Grayston Office Park, Block C, Ann Crescent Street, Strathavon, Sandton
FILE REFERENCE NUMBER SAMRAD: NC30/5/1/1/2/12103PR
IMPORTANT NOTICE In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”.
Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment.
In terms of section 16(3)(b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of section 17 (1) (c) the competent Authority must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the competent authority to the submission of applications.
It is therefore an instruction that the prescribed reports required in respect of applications for an environmental authorisation for listed activities triggered by an application for a right or a permit are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the Environmental Authorisation being refused.
It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the Report, in the order, and under the provided headings as set out below, and ensure that the report
is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.
OBJECTIVE OF THE BASIC ASSESSMENT PROCESS The objective of the basic assessment process is to, through a consultative process─ (a) determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context;
(b) identify the alternatives considered, including the activity, location, and technology alternatives;
(c) describe the need and desirability of the proposed alternatives,
(d) through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage , and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to determine:
(i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and (ii) the degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be managed, avoided or mitigated; (e) through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity to— (i) identify and motivate a preferred site, activity and technology alternative; (ii) identify suitable measures to manage, avoid or mitigate identified impacts; and (iii) identify residual risks that need to be managed and monitored.
PART A SCOPE OF ASSSSMENT AND BASIC ASSESSMENT REPORT
1. Contact Person and correspondence address a) Details of the EAP
Prime Resources (Pty) Ltd EAP: - Jonathan van de Wouw
Prime Resources has affiliations- / is registered Professional affiliation / registration: with: SACNASP, ECSA and SAIMM
Contact person (if different from N/A EAP):
Company: Prime Resources (PTY) Ltd
The Workshop, No. 70 – 7th Ave, Parktown Physical address: North, 2193
Postal address: PO Box 2316, Parklands
Postal code: 2121 Cell: 072 602 3164
Telephone: 011 447 4888 Fax: 086 604 2219
E-mail: [email protected] b) Expertise of the EAP i) The qualifications of the EAP (with evidence)
Prime Resources is a specialist Environmental Consulting Firm providing environmental and related services, which was established in 2003. Prime Resources was founded by Peter Theron (PrEng, SAIMM), the Managing Director and Principal Environmental Consultant of the firm, who has a GDE Environmental Engineering from the University of Witwatersrand and over 30 years’ experience in the field of environmental science and engineering.
Jonathan van de Wouw, a Principal Environmental Scientist and Project Manager, has a BSc(Hons) Microbiology and Biotechnology (cum laude) from the University of Witwatersrand and 10 years’ experience in the field of environmental science.
Amanda Tresise (Pr.Sci.Nat, Environmental Science), a Senior Environmental Scientist, has a M.Sc. (Zoology) and a M.Sc. (Environmental Management) from the University of Johannesburg and six years’ experience in the field of environmental science.
Louise Jones, an Environmental Scientist, has a M.Sc. (Environmental Science) from the University of Witwatersrand and five years’ experience in the field of environmental science.
Bronwyn Grover, an Environmental Scientist and Geochemist, has a PhD (Environmental Analytical Chemistry) from the University of Witwatersrand and two years’ experience in the field of environmental science and geochemistry.
Key Prime Resources Personnel CVs are attached as Appendix 1.1. ii) Summary of the EAP’s past experience (in carrying out the Environmental Impact
Assessment procedure)
The EAP’s past experience is fully described in the Prime Resources Company Profile (attached as Appendix 1.2) when read together with the personnel CVs in Appendix 1.1.
2. Location of the overall activity
FARM NO PTN NO PROPERTY OWNER TITLE DEED NO 21 DIGIT CODE DESCRITPTION 1 Farm 703 Portion 31 (Vooruitzicht) Olivier Business Trust T1746/2015 C04100000000070300031 2 Farm 703 Portion 32 (Haakdoom) du Plessis Hendrik Stephanus T1404/1987 C04100000000070300032 3 Farm 703 Portion 41 (Rosebank) Welkom Boerdery Trust T759/2006 C04100000000070300041 4 Farm 703 Portion 42 (Sirocco) Eltin Trust T2005/2014 C04100000000070300042 5 Farm 703 Portion 43 (Eersbegint) Saltrim Ranches (Pty) Ltd T2297/2006 C04100000000070300043 6 Farm 703 Portion 49 (Mollers Ville) Mollersville Boerdery Trust T2757/1994 C04100000000070300049 7 Farm 703 Portion 50 (Sterkstroom) AGW & BES du Plooy Testamentere Trust T3465/2011 C04100000000070300050 8 Farm 703 Portion 59 (Mirage) Welkom Boerdery Trust T759/2006 C04100000000070300059 9 Farm 703 Portion 60 (Stillewoning) van der Walt Johannes Lodewikus T2842/1995 C04100000000070300060 10 Farm 703 Portion 75 Karlsruhe Trust T1160/2008 C04100000000070300075 11 Farm 703 Portion 103 (Avontuur) G C Olivier Boerdery Pty Ltd T1480/1979 C04100000000070300103 12 Farm 703 Portion 108 (Tevrede) Plessis Fransonette Du T654/1987 C04100000000070300108 13 Farm 703 Portion 114 (Caledonia Gravenhage) Hauman Testamentere Trust T529/2008 C04100000000070300114 14 Farm 709 Remainder Saltrim Ranches (Pty) Ltd T2297/2006 C04100000000070900000 15 Farm 709 Portion 1 Saltrim Ranches (Pty) Ltd T3181/2017 C04100000000070900001 16 Farm 710 Remainder Roelof Jacobus Willem du Plooy Trust T1955/2011 C04100000000071000000 17 Farm 710 Portion 1 Welkom Boerdery Trust T759/2006 C04100000000071000001
See table above for details of the farm names entailed in Farm Name this application.
Application area (Ha) The prospecting area is 41894.1306 hectares in extent
The prospecting area is situated within the Joe Morolong Magisterial district Local Municipality and the Magisterial District of John Taolo Gaetsewe, Northern Cape Province.
Distance and direction from The proposed prospecting area is located approximately nearest town 57 km north east of Kuruman.
21 digit Surveyor General Code for See table above for the Surveyor General Code for each farm each farm portion portion.
a) Locality map (show nearest town, scale not smaller than 1:250000)
Figure 1: Locality map
3. Description of the scope of the proposed overall activity (provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000 that shows the location, and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site)
Figure 2: Preliminary drill hole locations
a) Listed and specified activities
AERIAL WASTE APPLICABLE EXTENT OF LISTED MASNAGEMENT NAME OF ACTIVITY LISTING NOTICE THE ACTIVITY ACTIVITY AUTHORISATION
Prospecting Right Application (without bulk sampling): 41 894 ha X GN 983 Activity 20: N/A
Phase 1 (Non-invasive): 41 894 ha Not listed N/A - Literature Review / Desktop studies / Geological monitoring Phase 2 (Insignificantly invasive): 41 894 ha Not listed N/A - Soil Sampling - Geochemical & Geophysical Surveys - Laboratory testing and analysis of samples Phases 3 – Drilling Programme (invasive) (based on initial drilling 5 holes – additional sites may be identified during Phases 1 and 2 above) 2 - Access track to drill sites. Where possible available access tracks 8000 m X GN 983 Activity 27: N/A will be used. Potentially new access tracks may be required. (this trigger assumes - A realistic estimate is creation of access tracks of +/- 2 km from that collectively all the an existing track. In order to avoid triggering listed activities activities required will requiring a full EIA, any new track will be less than 4 m wide. require an area 2 - Demarcation of drill pad (20 m x 20 m) per pad (x5 pads) 2000 m greater than 1 ha of N/A 2 clearing of indigenous - Implement percussion drilling followed by diamond drilling 2000 m vegetation) N/A 2 - Stores / ablution / security required for drilling 2000 m N/A 2 - A camp site for the drillers (10 m x 10 m) which will include: 500 m o a temporary storage shed o a water tanker o chemical toilets o a mobile diesel bowser o a caravan to house the drillers 2 - Core shed for cutting and processing drilling core (30 m x 30 m) 900 m Not listed N/A - Sampling to be performed in an accredited laboratory N/A Not listed N/A
AERIAL WASTE APPLICABLE EXTENT OF LISTED MASNAGEMENT NAME OF ACTIVITY LISTING NOTICE THE ACTIVITY ACTIVITY AUTHORISATION
- Drilling water will be obtained from existing boreholes in the N/A Not listed N/A area in line with authorized abstraction rates and volumes, no boreholes should be drilled to avoid triggering a water use. The estimated use of water per day is 5 000 liters per diamond drill rig
Phase 4 (Non-invasive): - Completion of economic study. 41 894 ha Not listed N/A - Preparation of mining right application plant
b) Description of the activities to be undertaken (describe Methodology or technology to be employed, including the type of commodity to be prospected/mined and for a linear activity, a description of the route of the activity)
Pan African Mineral Development (Pty) Ltd (PAMDC) has submitted an application for a Prospecting Right for Diamonds, Gold, Manganese, Iron, Lead, Zinc, Nickel, Limestone, Platinum Group Metals, Uranium and Copper to the Department of Mineral Resources on 29 November 2017. The application covers portions of various farms within the Joe Morolong Local Municipality in the Northern Cape Province. The Prospecting Right Area (PRA) is located approximately 57 km north east of Kuruman (refer to Figure 1). A preliminary indication of the preliminary drill hole areas within the PRA is also provided (refer to Figure 2). However, the final location and number of exploration boreholes will be determined once the desktop studies and geophysical surveys have been completed.
The overall objective of the prospecting program is to identify the nature and extent of the target mineralisation which can potentially be economically mined in future. The prospecting activities will take place in the form of both non-invasive and invasive prospecting activities. The table below provides an indication of the anticipated activities and time frames for the implementation of the prospecting program. The timeframes are based on the assumption that the Prospecting Right is granted in 2018. The program is not rigid however, as the implementation of each phase of work is dependent on the results of the preceding phase. Results may therefore require changes and adaptations to aspects of the program as it advances.
PHASE ACTIVITY TIMEFRAME YEAR
Literature review and desktop Phase 1 studies 12 Months 2018-2019 Geological modelling
Soil sampling Phase 2 Geochemical & geophysical 12 Months 2019-2020 surveys DrillingLaboratory and testingsampling and activities analysis Phase 3 Preof samples-feasibility study 24 Months 2021-2022 Infill drilling
Bankable feasibility study / Phase 4 12 Months 2022-2023 mining rights
Non-Invasive Activities
Desktop Studies - The geological literature review and desktop studies will involve assessing all available geological literature with respect to the prospecting area. The available information will be evaluated in terms of developing a detail geological model for each mineral captured as part of the application.
Geological modelling and surface mapping during phase 1 and 2 of the prospecting period - Surface mapping will involve a geologist visiting the various farms and mapping geological features. Grab and soil sampling - The grab and soil samples will be used to identify Nickel and Copper anomalies. Grab sampling and soil sampling surveys will be designed in accordance with the findings of the desktop studies. Soil samples could be taken at a 500 m interval which will result in the collection of 10 000 samples. Such a soil sample entails a geologist walking the area with a soil auger. The impacts of this activity are insignificant and hence regarded as non-invasive.
Aeromagnetic and ground magnetic surveys - High Resolution Aeromagnetic surveys will be carried on the application area. A height of 150 ±15 m above the ground with 1 km line spacing along an East- Westerly direction will be maintained. An external company will be utilised to conduct the aeromagnetic surveys. A minimum of 10 km flight line will be maintained. Flights will only occur during daylight hours.
Ground magnetic surveys will be carried out with a line spacing of 1 km resulting in a 456-line km. This involves laying cables on the ground. Once the survey is completed the cables are removed.
Invasive Activities - Drilling Activities
The main invasive activity during the prospecting period will be the drilling of boreholes. Currently it is expected that drilling of core (diamond) drill holes will be performed. The final positioning of the proposed boreholes will be determined by the results of the non-invasive desktop studies completed in phase 1 of the prospecting program – at present, five potential drill sites have been indicated, however, it is acknowledged that alternate or additional sites may be selected once the outcomes of the non- invasive phase have been analysed.
Prospecting activities within the PRA will comprise drill hole areas, driller’s camps and access tracks (not more than 4 m wide). These areas will be demarcated and the vegetation in these areas cleared using a bulldozer. Each drill site will be confined to an area of approximately 20 x 20 m. The area will be temporarily fenced off as and when drilling is occurring.
It is the intention to use two drill rigs for the operation. In addition to the drill rig present at a drill site there will be:
a temporary storage shed a water tanker chemical toilets a mobile diesel bowser a caravan to house the drillers
At this early stage it is expected that 3 boreholes will be drilled at a depth of 300 m. Casing is to be inserted through the weathered zone into solid bedrock. The total metres budgeted for at this stage will be 7500 m. Cores will be sampled at 1 m intervals resulting in 7500 samples. On completion of the pre- feasibility study, and depending on the results thereof, infill drilling will take place and 2 boreholes will be drilled at a depth of approximately 300 m below surface on the proposed prospecting area. Drilling water will be obtained from existing boreholes in the area in line with authorised abstraction rates and volumes for those boreholes. The estimated use of water per day is 5 000 litres per diamond drill rig.
A plastic lining will be placed under the drill rig and in the small sump (1 x 1 m3) required for the drilling operation. The mobile diesel bowser will obtain diesel from the nearest diesel service station and
will also be located on the plastic lining. The plastic lining must be laid in such a manner that potential hydrocarbon spills will not flow off it due to gravity or other forces, and contaminate the adjacent soil. The purpose of the plastic lining is to ensure that there is no surface impact from the drilling program in the form of hydrocarbon spills on the soil. Furthermore, drilling activities presently utilise biodegradable and environmentally acceptable drill fluids.
On the completion of drilling activities each borehole will be plugged or properly covered, to prevent animals and people from injuring themselves. The cleared areas will be allowed to revegetate naturally.
All core assays will be submitted to an accredited laboratory for analysis. Sampling and Analysis - Samples from the boreholes will be taken to identify the properties for the minerals applied for. A total of 1500 samples will be budgeted for. Sampling expenses include assay costs, mineralogical costs and other metallurgical tests to determine the grades and ore characteristics essential to identify the suitability of the reserves for future mining. Sampling and analysis will be undertaken by an accredited professional laboratory.
Since the exploration program is results driven, updated final drill position plans and drill information will be submitted to DMR at the end of the program.
c) Policy and legislative context HOW DOES THIS DEVELOPMENT COMPLIY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT The Mineral and Petroleum Resources Development Act, No. 28 of An integrated application in 2002 (MPRDA) is the key legislation governing mining activities within terms of the MPRDA and An application for a Prospecting Right was South Africa. It details the requirements and processes which need to be NEMA is being undertaken. submitted to the DMR on 29 November 2017, followed and adhered to by mining companies. The Department of Mineral The NEMA process for the through the SAMRAD online system (accepted on Resources (DMR) is the competent authority that deals with all mining proposed project is described 13 December 2017). related applications. below. The National Environmental Management Act, No. 107 of 1998 (NEMA) is enabling legislation intended to provide a framework for integrating environmental management into all developmental activities to promote co-operative environmental governance with regard to decision An application for Environmental Authorisation in making by state organs on matters affecting the environment. terms of NEMA was submitted together with the Prospecting Right application to the DMR on 29 The Environmental impact Assessment (EIA) Regulations of GNR982, This Basic Assessment November 2017 for the NEMA listed activities December 2014 as amended in 2017 serve to regulate the procedure and Report (BAR) and triggered by the proposed project (accepted on 13 criteria for submitting, processing and considering decisions for applications Environmental Management December 2017). for Environmental Authorisation. These Regulations provide details on the Programme (EMP) has been process to be followed for the consultation of stakeholders and IAPs, the prepared to meet the According to the EIA Regulations (2014) the identification of the Competent Authority, and the various timeframes and requirements of the EIA following is to be submitted in support of the application requirements for Environmental Authorisation. A further three Regulations (GNR982 of application for Environmental Authorisation: Regulations, GNR983, GNR984, and GNR985 (all of 2014 as amended in 2014). 2017), provide lists of activities for which Environmental Authorisation, BAR / EMP (this document) together with the either in the form of a Basic Assessment or Scoping and EIA is required Refer to Section 3(a) for the results of consultation with Interested and before the activity can commence. listed activities applicable to Affected Parties (IAPs) and State Departments, the proposed project. which must be submitted to the DMR within 90 Since the enactment of the “One Environmental System” on 8 December days (by 5 April 2018). 2014, the Environmental Authorisation process in terms of the NEMA must be followed for any mining activities requiring a right or permit in terms of the MPRDA to fulfil the requirements of Section 5A(a) of the Act. In instances where Environmental Authorisation is required for a mining project, the DMR is identified as the Competent Authority. The National Environmental Management Air Quality Act, No. 39 of 2004 (NEMAQA) has placed the responsibility for air quality management No listed activities in terms of the NEMAQA are on local authorities that will be tasked with baseline characterisation, Refer to Section 5(a) where triggered by the proposed project. Therefore, no management and operation of ambient monitoring networks, licensing of the current air quality in the AEL is required. project area is characterised. listed activities, and emissions reduction strategies. GN893 of 2013 provides Activities associated with the proposed project are the list of activities in terms of Section 21(1)(a) for which licensing is unlikely to result in exceedances in the air quality required in terms of Chapter 5 of the Act. This notice further establishes HOW DOES THIS DEVELOPMENT COMPLIY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT minimum emission standards for the listed activities. standards. The ambient air quality standards (GN1210 of 2009) were determined based on international best practice for PM10 (particulates with an aerodynamic diameter of 10 micron), dust-fall, sulphur dioxide (SO2), nitrogen dioxide (NO2), ozone (O3), carbon monoxide (CO), lead (Pb), benzene and recently PM2.5. The PM2.5 standards were published in GN486 of 2012. Section 32 of NEMAQA allows for the promulgation of measures to control and monitor dust. The National Dust Control Regulations (GNR827 of 2013) prescribe general measures for the control of dust in all areas, including residential and light commercial areas. The purpose of the National Environmental Management: Biodiversity The PRA and preliminary drill hole areas fall within Act, No. 10 of 2004 (NEMBA) is to provide for the management and the three different vegetation types namely Kathu conservation of South Africa’s biodiversity within the framework of the Bushveld, Molopo Bushveld and Southern Kalahari NEMA. This includes, among others, the protection of species and Mekgacha, all of these ecosystems are listed as ecosystems. Least Threatened. Section 52 of the Act provides for listing of threatened or protected However, there is a Critical Biodiversity Area ecosystems, in one of four categories: Critically Endangered (CR), (CBA), which is considered well protected and Endangered (EN), Vulnerable (VU) or Protected. The main purpose of listing within an area earmarked for protected area threatened ecosystems is to reduce the rate of ecosystem and species expansion, and an Ecological Support Area (ESA) extinction and includes the prevention of further degradation and loss of located within the PRA, both associated with the structure, function and composition of threatened ecosystems. Threatened Kuruman River. These areas are of moderate terrestrial ecosystems have been delineated based on the South African Refer to Section 5(a) where biodiversity value and are therefore at risk from Vegetation Map, national forest types and priority areas identified in a the current biodiversity in mining. provincial systematic biodiversity plan. the project area is characterised. The preliminary drill hole area (number 4 - refer Chapter 4, Part 2 of the Act provides for listing of species as threatened or to Figure 2) on Portion 50 of the Farm protected. If a species is listed as threatened, it should be further classified Gravenhage 703 is the only preliminary drill hole as critically endangered, endangered or vulnerable (GNR151 of 2007). The area located within the CBA. Should it be Act also defines restricted activities in relation to a specimen of a listed determined that prospecting activities will take threatened or protected species (GNR152 of 2007). place within this drill hole area (or any alternative drill hole areas identified within the CBA or ESA in the future), the area to be cleared must be limited to less than 300 m2, roads must be less than 4 m wide and dangerous goods stored must be less than 30 m3 to prevent triggering a listed activity in terms of GNR985 of 2014. Alternatively, a suitable alternate location for exploration must be
HOW DOES THIS DEVELOPMENT COMPLIY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT identified. Species of conservation concern likely to occur within the PRA are the Camel Thorn, Shepherds Tree, Ground Pangolin, African Wild Cat, Tawny Eagle, Secretary Bird, Rock Monitor, Giant Bullfrog, Horned Baboon Spider and the Starburst Baboon Spider. Permits may be required as per NEMBA in the unlikely event that species of conservation concern are identified and require relocation, should avoidance not be possible. The National Environmental Management Waste Act, No. 59 of 2008 (NEMWA) serves to reform the laws regulating waste management in order to protect public and environmental health by providing measures for the prevention of pollution and ecological degradation and to provide defining No listed activities in terms of the NEMWA are requirements for the licensing and control of waste management activities. triggered by the proposed project. Therefore, no GN921 of 2013 provides definitions for activities which require a waste Waste Management Licence (WML) is required. management licence and identifies the relevant environmental N/A Activities associated with the proposed project are authorisations which are further required for said activities. unlikely to result in exceedances in the thresholds The storage of waste above the specific thresholds (in excess of 100 m3 of for waste storage. general waste or 80 m3 of hazardous waste) triggers a Category C activity which requires registration in terms of- and compliance with the National Norms and Standards for the Storage of Waste (GN926 of 2013). The National Heritage Resources Act, No. 25 of 1999 (NHRA) serves to protect and manage South African heritage and cultural resources, which include places, buildings, structures and equipment of cultural significance, historical settlements and townscapes, archaeological and paleontological sites, graves and burial grounds. The Act protects any heritage resources from damage by developments by stipulating in Section 38 that any person Refer to Section 5(a) where None of the listed activities in terms of the NHRA intending on undertaking any form of development which involves the the current heritage are triggered by the proposed project as the activities listed below must, at the earliest stage of initiation, notify the landscape in the project area prospecting activities will not transform the South African Heritage Resources Association (SAHRA) specifically the is characterised. character of the site. Northern Cape Heritage Resources Authority: A. the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length; B. the construction of a bridge or similar structure exceeding 50 m in HOW DOES THIS DEVELOPMENT COMPLIY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT length; C. any development or other activity which will change the character of a site— i. exceeding 5 000 m2 in extent; or ii. involving three or more existing erven or subdivisions thereof; or iii. involving three or more erven or divisions thereof which have been consolidated within the past five years; or iv. the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority; D. the re-zoning of a site exceeding 10 000 m2 in extent; or E. Any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority. The only watercourses within the PRA are the Kuruman River and associated wetlands as well as depression-, unchannelled valley bottom-, valley head seep-, flat- and floodplain wetlands scattered throughout the PRA. The National Water Act, No. 36 of 1998 (NWA) regulates all matters Refer to Section 5(a) where The preliminary drill hole areas are not in relating to inland water resources. It thus operates as a management the current water resources proximity to the Kuruman River or any wetlands instrument with the lead authority being the DWS. This Act provides in the project area are with the exception of a portion of the proposed mechanisms for the prevention of the pollution of water resources to characterised. drill hole area (number 4) on Portion 50 of the support the management of water as a renewable resource. Section 21 of Farm Gravenhage 703, which is located within the the Act lists water uses for which authorisation is required from the DWS. It has been included as a 500 m buffer of a wetland. commitment in the EMP Regulation GN704 of 1999 provides regulations for the use of water for No listed activities in terms of the NWA are (Section 4 - Part B of this mining and related activities and is aimed to further protect water triggered by the proposed project, assuming no document) that no resources. These regulations describe how mining activities should be prospecting activities will take place within 500 m prospecting activities must managed to protect water resources. The Act thus plays a crucial role in the of a wetland as recommended. mining process as many mining-related activities use water as listed in take place within 500 m of a Section 21, thereby requiring approval from DWS. wetland. Drilling water will be obtained from existing boreholes in the area in line with authorized abstraction rates and volumes for the existing boreholes. No boreholes will be drilled to avoid triggering a water use. Therefore, no Water Use Licence (WUL) is
HOW DOES THIS DEVELOPMENT COMPLIY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT required. The Mine Health and Safety Act, No. 29 of 1996 (MHSA) and the Regulations thereto provide for protection of the health and safety of staff and other persons at mines and, for that purpose to promote a culture of health and safety; to provide for the enforcement of health and safety measures; to provide for appropriate systems of employee, employer and A commitment to abide by State participation in health and safety matters; to establish representative the Act and Regulations has The Applicant will ensure that operations are in tripartite institutions to review legislation, promote health and enhance been included in the EMP line with the requirements of the Act and properly targeted research; to provide for effective monitoring systems and (Section 4 - Part B of this Regulations. inspections, investigations and inquiries to improve health and safety; to document). promote training and human resources development; to regulate employers' and staff' duties to identify hazards and eliminate, control and minimise the risk to health and safety; to entrench the right to refuse to work in dangerous conditions; and to give effect to the public international law obligations of the Republic relating to mining health and safety. The Integrated Development Plan (IDP) of the Joe Morolong Local Municipality (2017/2018) provides the regional socio-economic context of the project area. The IDP states that the Joe Morolong Local Municipality has a total surface area of 20 172 km2 that accommodates a population of 89 377 (as per Census 2011). There are 146 villages and 2 small towns in the district surrounded by privately owned commercial farms and government farms. There are Tribal authorities in the municipal jurisdiction with 8 Paramount Chiefs. The IDP includes Key Performance Areas (KPAs) Refer to the social baseline for the wards and for the municipality which cover 1) Basic Service Delivery, in Section 5(a). This has also 2) Local Economic Development (LED), 3) Municipal Transformation and been taken into The IDP has been taken into account in Organizational Development, 4) Municipal Finances and Financial Viability, consideration in determining determining the need and desirability of the and 5) Good Governance and Community participation. Ward specific KPAs of the need and desirability project. focus on KPA 1 and 2; municipal KPAS include KPAs 3, 4 and 5. Agriculture, of the project, refer to mining and community services are the primary economic sectors. Most of Section 3(d). the municipal service projects implemented within the area in the past two years were funded through government grants and Social Labour Plan (SLP) money from the mining houses. There are 12 740 economically active people in the municipality (employed or unemployed but seeking work). Poverty alleviation projects in the past two years were implemented in 15 villages, employing 224 people. Groundwater is a major source of water and factors affecting the quality include agricultural activities and environmental issues. The municipality embarked on refurbishing the current water HOW DOES THIS DEVELOPMENT COMPLIY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT infrastructure. The project is not yet finalized. There are 11423 households that are below the RDP standard for sanitation. Approximately 95% of the roads in the municipality are gravel roads, funding for road construction used to be sourced from SLP projects, however the IDP states that due to unfavourable economic conditions in the mining sector, no allocation will be received from the mines for road construction for the 2017-18 Financial Year. The Northern Cape Provincial Spatial Development Framework (PSDF) (2012) provides the framework for building a prosperous, From the PSDF Composite Spatial Vision, the sustainable growing provincial economy to eradicate poverty and improve PAMDC PRA falls within an area classified as social development. The PAMDC PRA falls within the Joe Morolong Local This has been taken into agriculture according to the spatial planning Municipality and the Magisterial District of John Taolo Gaetsewe. Kuruman is consideration in determining categories and a mining focus area according to the administrative capital of the John Taolo Gaetsewe District Municipality the need and desirability of the industrial areas spatial vision. The mining and this area is referred to as the Kalahari ‘macro-region’. The Gamagara the project, refer Section focus area is aligned with the planned prospecting corridor comprises the mining belt of the John Taolo Gaetsewe and Siyanda 3(d). activities. districts and runs from Lime Acres and Danielskuil to Hotazel in the north. The corridor focuses on the mining of iron ore and manganese.
d) Need and desirability of the proposed activities (motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location)
Need
The prospecting activities being applied for are required in order to investigate the presence of suitable mineralisation and, if so, whether this mineralisation can be economically and feasibly mined in future which, in turn, presents various socio-economic benefits to the region.
Desirability
Previous prospecting activities undertaken over the PRA have intersected significant zones of manganese mineralisation with high-grade levels.
From the PSDF, the PAMDC PRA falls within an area classified as agriculture according to the spatial planning categories and a mining focus area according to the industrial areas spatial vision. The mining focus area is aligned with the planned prospecting activities and prospecting activities can be conducted concurrently with existing agricultural land uses.
Access to the area is good, consisting of paved main roads and secondary gravel roads.
The preliminary drill hole areas, with the exception of drill hole area 4 on Portion 50 of the Farm Gravenhage 703, are not in proximity to any sensitive environmental features, therefore, limiting the potential for negative environmental impacts.
The preliminary drill hole areas are not in proximity to any communities or residences, therefore, limiting the potential for negative social impacts.
Should prospecting activities indicate that mining in the area is feasible it will contribute in alleviating unemployment in the area. Poverty alleviation in the area is needed as the official unemployment rate of the District Municipality is 29.7%, and the youth unemployment rate is 37.2%. e) Motivation for the overall preferred site, activities and technology alternative
The site has been selected for its potential geological features in terms of mineralisation. No alternative site locations were therefore assessed as the preliminary drill hole areas are based on the expected mineral resources located within that area, however, alternative sites may be determined once the desktop studies and geophysical surveys have been completed and the exact position and number of target drill sites are confirmed. The preliminary drill hole areas, with the exception of the drill hole area on Portion 50 of the Farm Gravenhage 703, are not in proximity to any sensitive environmental features, therefore, limiting the potential negative environmental impacts. The footprint of activities will be kept to a minimum, and disturbed areas are to be utilised where possible, minimising the environmental impact. It is however recommended that prospecting activities within the CBA, ESA and within 500 m of any wetlands be avoided. The preliminary drill hole areas are also not in proximity to any communities or residences, therefore, limiting the potential negative social impacts. f) Full description of the process followed to reach the proposed preferred alternatives within the site (NB!! – this section is about the determination of the specific site layout and the location of infrastructure and activities on site, having taken into consideration the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout) i) Details of the development footprint alternatives considered (with reference to the site plan provided and the location of the individual activities on site, provide details of the alternatives considered with respect to: (a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity)
The site has been selected for its potential geological features in terms of mineralisation. The type of activity is limited based on the geology but this activity is in line with the development plans, the alternative to which would be agriculture but this is not the business interest of the applicant. The layout at present has preliminarily identified five potential sites in order to characterise the mineralisation, however, the non-invasive prospecting (desktop studies and geophysical surveys) will identify additional or alternative candidate drill sites and thus this BAR takes into consideration the full extent of the applied for area. The technology involved in prospecting is limited to tried and tested drilling techniques being percussion and diamond drilling. Other techniques (such as trenching for example) are not suitable for the minerals being prospected for. Prospecting site alternatives are limited to the location of the mineral resources. Therefore, the sites of the proposed drill holes are based on the potential for high grade minerals to be present in these areas. However, alternative sites may be determined once the desktop studies and geophysical surveys have been completed. There are no alternatives to the type of activity (prospecting activities) as prospecting is required to characterise the mineral resources in the area. If the project does not go ahead, the area will likely not be developed for mining in future. Alternative development may be possible, but the Applicant is unaware of any such proposals at present.
4. Details of the Public Participation Process followed (describe the process undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless
of whether or not they attended public meetings. (Information to be provided to affected parties must include sufficient detail of the intended operation to enable them to assess what impact the activities will have on them or on the use of their land)
The public participation process followed met the requirements of Chapter 6 of the NEMA EIA Regulations, GNR982 of 2014.
Landowner Notification
The current landowners of the farm portions subject to the Prospecting Right Application were initially contacted telephonically and then provided with written notification via email of the project on 22 February 2018 (refer to Appendix 2.1).
Media Notice
A media notice (in English) was published in Kalahari Bulletin on 22 February 2018 and media notices in English and Tswana were published in Kathu Gazette on 23 February 2018, providing a brief project description, legislative requirements, the process to be followed to register as an Interested and Affected Party (IAP), availability and location of the BAR / EMP, and contact details of the EAP for more information (attached as Appendix 2.2).
Site Notices
Site notices (in English and Tswana) were posted up on site and at conspicuous locations within the surrounding communities on 23 February 2018, providing a brief project description, legislative requirements, the process to be followed to register as an IAP, availability and location of the BAR / EMP, and contact details of the EAP for more information (attached as Appendix 2.3).
IAP Registration
An IAP register was opened including representatives from all of the relevant State Departments, as well as landowners and any IAPs requesting to register (attached as Appendix 2.4).
Commenting Period
The BAR / EMP was made available for comment to State Departments (including the Competent Authority) via email or hard copy, as requested, and placed within the public domain on the Prime Resources website (www.resources.co.za), for a 30 day period (23 February 2018 to 26 March 2018). Proof of distribution will be included as an appendix in the final documentation to be submitted to the DMR for consideration.
Comments and Response Report
A Comments and Response Report will be compiled as part of the public participation process - refer to the table in Section i below. Copies of comments and responses received will be included as an appendix in the final documentation to be submitted to the DMR for consideration.
i) Summary of issues raised by IAPS (complete the table summarising comments and issues raised, and reaction to those responses)
INTERESTED AND AFFECTED PARTIES DATE ISSUES RAISED EAPS RESPONSE TO ISSUES AS SECTION AND COMMENTS MANDATED BY THE APPLICANT PARAGRAPH LIST THE NAMES OF PERSONS RECEIVED REFERENCE IN THIS CONSULTED IN THIS COLUMN, AND REPORT WHERE THE MARK WITH AN X WHERE THOSE WHO ISSUES AND OR MUST BE CONSULTED WERE IN FACT RESPONSE WERE CONSULTED INCORPORATED AFFECTED PARTIES
Landowner/s X
Olivier Business Trust X du Plessis Hendrik Stephanus X Welkom Boerdery Trust X Eltin Trust X Saltrim Ranches (Pty) Ltd X Mollersville Boerdery Trust X AGW & BES du Plooy Testamentere Trust X van der Walt Johannes X Lodewikus No issues and concerns have been raised to date. Any issues and concerns raised during the public participation process will be Karlsruhe Trust X responded to and proposed alternatives and mitigation measures assessed where applicable. G C Olivier Boerdery Pty Ltd X du Plessis Fransonette X Hauman Testamentere Trust X Roelof Jacobus Willem du Plooy Trust X Lawful occupier/s of the land du Plessis Hendrik Stephanus X Eltin Trust X AGW & BES du Plooy Testamentere Trust X Welkom Boerdery Trust X van der Walt Johannes X Lodewikus G C Olivier Boerdery Pty Ltd X du Plessis Fransonette X Roelof Jacobus Willem du Plooy Trust X Landowners or lawful occupiers X on adjacent properties Site notices were posted up on site and at conspicuous locations within the surrounding X communities. Municipal councillor X Ms Keemenao Julia Katong (Ward 4, Joe Morolong Local X Municipality) Municipality X
Joe Morolong Local Municipality X Mr Teise (Director Planning and Development, John Taolo X Gaetsewe District Municipality) Organs of state (Responsible for infrastructure that may be X affected Roads Department, Eskom, Telkom, DWA Mr Moses Mahunonyane (Director Institutional Establishment, Northern Cape X Department of Water and Sanitation) Ms Lerato Mokhoantle (Assistant Director Lower Vaal (Environmental Manager), X Northern Cape Department of Water and Sanitation) Communities X
Media notice published in English and Tswana. Distribution X of notice includes nearby towns, villages and mines. Dept. Land Affairs X Mr WVD Mothibi (Head of Department. Northern Cape X Department: Agriculture, Land Reform and Rural Development) Mr Leon Terblanche (Director of Sustainable Development, Northern Cape Department: X Agriculture, Land Reform and Rural Development) Traditional Leaders N/A Dept. Environmental Affairs X Mrs van Olmen Phillips (Director of Environmental Policy, Planning and Coordination; X Northern Cape Provincial Department: Environment and Nature Conservation) Other Competent Authorities X affected Mr Ntsundeni Ravhugoni (Head of Mine Environmental X Management, Department of Mineral Resources) Ms Raisibe Sekepane (Environmental Manager, Department of Mineral X Resources (Mine Environmental Management)) Khuthala Dlamini (Land Use Officer, Department of X Agriculture, Fisheries and Forestry) Northern Cape Department: Co- X operative Governance, Human Settlements and Traditional Affairs OTHER AFFECTED PARTIES Mr William Symington (Agri Northern Cape) INTERESTED PARTIES
5. The environmental attributes associated with the alternatives (the environmental attributes described must include socio-economic, social, heritage, cultural, geographical, physical and biological aspects)
The description below is applicable to the entire PRA and therefore applicable to the preliminary drill hole sites and any alternative sites which may be identified in future. a) Baseline environment i) Air Quality In accordance with Section 15(2) of the NEM:AQA, the Northern Cape Department of Environment and Nature Conservation developed an Air Quality Management Plan (AQMP). The following information was obtained from the AQMP for the Northern Cape: Air Quality Baseline Assessment Report developed by uMoya-NILU (Final, December 2017).
The Northern Cape is generally hot and dry. Maximum summer temperatures often exceed 40°C. During winter, the average daytime temperatures are mild and night time temperatures may drop below 0°C. There are four climatic zones in the Northern Cape: hot desert, cold semi-arid, cold desert and hot semi- arid. Kuruman (the closest town to the project area) is classed as a cold semi-arid area. Average rainfall is 457 mm at Kuruman and evaporation levels exceed annual rainfall. Wind direction near Kuruman is predominantly northwest through to north-northeast, and from the southeast to east-southeast.
The main sources of air pollution in the Northern Cape are biomass burning and mining, followed by industry and motor vehicles. Biomass burning is a major contributor of carbon monoxide (CO) whereas mining contributes particulate matter (PM10, PM2.5) and total suspended particles (TSP). Long range atmospheric transport of air pollutants from the industrialised Highveld and biomass burning in southern and central Africa may influence ambient air quality over parts of the Northern Cape. Emissions within the Northern Cape in 2015 are summarised in Table 1.
Table 1: Estimated emissions (tons/annum) during 2015 in the Northern Cape (uMoya-NILU, 2017)
PM10 PM2.5 TSP SO2 NOX CO VOC Industrial sources 1452 133 289 333 79 24 Mining 32248 22315 61453 Residential fuels 42 2 6 315 Biomass burning 15978 695 3917 115525 Motor vehicles 517 253 6574 15433 3067 Airports 3 11 9988 158 Total 34259 22315 77564 1242 10841 141340 3249
Continuous ambient air quality monitoring in the Northern Cape is conducted by the South African Weather Service (SAWS) at the Hantam National Botanical Garden near Nieuwoudtville. Ambient air quality monitoring is also conducted by the Department of Environment and Nature Conservation using passive sampling to measure SO2, NO2 and O3 at 15 sites around the province, i.e. three sites each in Kimberley, Upington, De Aar and Kuruman and three sites in the Namakwa DM around Okiep and Springbok. Monthly sampling has been conducted for different periods at different sites. The monitoring at Kuruman took place during December 2014 – November 2015 at three sites (taxi rank, Bankhara, Seoding). Results for the monitoring of NO2 and SO2 at Kuruman compared to National Ambient Air Quality Standards (NAAQS) are summarised in Table 2. The NO2 and SO2 concentrations are below NAAQS. The elevated NO2 concentrations at the taxi rank were attributed to vehicle emissions. In terms of O3 monitoring, the averages are compared monthly with the 8 hour NAAQS of 120 ug/m3. Kuruman levels were below 100 ug/m3 with peaks (50 – 100 ug/m3) in February 2015 and November 2015.
Table 2: Air quality monitoring results in Kuruman, Dec 2014 - Nov 2015 (uMoya-NILU, 2017)
3 3 MONITORING SITE AVERAGE NO2 (UG/M ) AVERAGE SO2 (UG/M ) Taxi rank 8.5 2.0 Bankhara 3.7 1.0 Seoding 4.2 1.9 500 (10 min) 200 (1 hour) 350 (1 hour) NAAQS (averaging period) 40 (1 year) 125 (24 hours) 50 (1 year) ii) Palaeontology, Heritage and Geology The following information was obtained from
J. Almond and John Pether (2009). Palaeontological Heritage of the Northern Cape, SAHRA Palaeotechnical Report J van Schalkwyk (2010). Heritage impact assessment for the Proposed Gravenhage Manganese Project, John Taolo Gaetsewe District Municipality, Northern Cape Province
There are no UNESCO World Heritage Sites in the vicinity of the project area. The SAHRIS Palaeontology (fossil) sensitivity map was used in determining the requirements for the level of study required for the region (refer to Figure 3). The map indicates that the area is of moderate sensitivity, aside from the Kuruman River which has a high sensitivity (no prospecting will take place within the river or within 500 m of the wetland associated with the river).
The climatic conditions (semi-arid to arid) of the Northern Cape are ideal for the exposure of fresh, unweathered rocks at surface and fossils related to them. The Northern Cape spans a wide range of geology.
On a regional scale, the project area is located on the relatively young Kalahari Group. Rock types of the Kalahari include fluvial gravels, sands, lacustrine and pan mudrocks, evaporites, aeolian sands, pedocretes. Due to the arid conditions, which began approximately 15 million years ago (Miocene Epoch), the region only has sparse fossilised areas and these areas are usually ancient pans, lakes and river systems. Late Cretaceous to Paleogene fluvial and lacustrine sediments towards the base of the succession contain such fossils, but these fossils are rarely exposed. Arid-adapted fossils include land snails, ostrich eggs, plant root casts as well as pockets of lake sediments with molluscs, diatoms and freshwater stromatolites. The palaeontological significance of the Kalahari Group is low, in terms of a recommended
action for projects in the region, the SAHRA Palaeotechnical Report recommends that no action is required, however any fossil finds should be reported.
As per the 2622 geological map (Figure 4), the PRA is underlain by Transvaal, Waterberg and Karoo Systems. Transvaal andesitic lavas lie to the east of the PRA. The lavas are of moderate paleontological significance/vulnerability. Quartzite and shales of the Waterberg system occur near the centre of the PRA. The Waterberg Group is not referred to in Palaeontological Heritage of the Northern Cape, but it is assumed to have the same significance as the Olifantshoek Supergroup, which is low. Shale and tillites (Dwyka series) of the Karoo occur to the west. The vulnerability of the Dwyka series is low.
A heritage impact assessment was undertaken in August 2010 by J van Schalkwyk specifically looking at Portion 114 of the Farm Gravenhage 703 (the northern farm in the PRA). The study included a regional overview of the area which is referred to below.
Occupation of the region took place during the Early Stone Age and centres in the areas where there are hills, e.g. to the east and south (in the vicinity of Kathu). Later Stone Age sites are less obvious but occur in the larger region, with Cape Coastal pottery in the period 100 BC to AD 1900.
Tswana-speaking people were the earliest that settled in the region to the north and west of Kuruman. With the annexation of the Tswana areas by the British in 1885, a number of reserves were set up for people to stay in. In 1895 the Tswana-speakers rose up in resistance to the British authority as represented by the government of the Cape Colony, their land was taken away, divided up into farms and given out to white farmers to settle on.
Early explorers, hunters, traders and missionaries travelled through the area on their way to Kuruman on what became known as “Missionary Road”.
The study concluded that there were no sites of cultural significance or graves on farm portion 114.
From the above, the overall cultural and archaeological sensitivity of the PRA is low, with the exception of the Kuruman River itself, which does not form part of the exploration target sites.
Figure 3: Palaeosensitivity map (SAHRIS, 2017)
Figure 4: Geological map
iii) Noise The area in which prospecting activities will take place is assumed to be relatively secluded with low levels of noise typical to rural farming activities (mainly cattle farming). The typical noise rating in the area is expected to be that of rural districts. According to SANS 10103:2008, the continuous noise rating level for rural districts is between 25 dB(A) at night to 45 dB(A) during the day. iv) Surface Water The following information was obtained from:
Water Research Commission. The South African Mine Water Atlas (WRC Project No. K5/2234/3) Department of Water and Sanitation. 2014. A Desktop Assessment of the Present Ecological State, Ecological Importance and Ecological Sensitivity (PESEIS) per Sub Quaternary Reaches for Secondary Catchments in South Africa MS Basson and JD Rossouw, 2003. Lower Vaal Water Management Area: Overview of Water Resources Availability and Utilisation. The online DWS Resource Quality Information Services (RQIS) (http://www.dwa.gov.za/iwqs/)
Catchment Description and Surface Water Resources
The project area is located in quaternary catchment D41M, within the Lower Vaal River Water Management Area (WMA) (refer to Figure 5) and Drainage Basin D (Orange River basin). The Lower Vaal WMA is located downstream of the Bloemhof Dam and upstream of Douglas Weir. It extends to the headwaters of the Harts, Molopo and Kuruman River in the north and the Vaal River Downstream of Bloemhof in the south. The Lower Vaal WMA covers a catchment area of 51,543 km2.
The Kuruman River flows to the north-west through the quaternary catchment where it joins the Mosahaweng River to the northern edge of the quaternary catchment. The Kuruman River flows in a western direction until confluence with the Molopo River. The Molopo River drains into the Orange River near the Augrabies Falls National Park.
The Kuruman River is classified as a Freshwater Ecosystem Priority Area (FEPA) River. The river has the following characteristics:
Class B largely natural Class F Lowland River River order number 4 River Condition is B Largely Natural with few modifications (Considered intact and able to contribute towards river ecosystem biodiversity targets).
River Health
The Kuruman River in the D41M quaternary catchment is considered to be in largely a natural state with few modifications (as per PESEIS 2013), with mining in the area posing a moderate risk to surface water resources.
The Present Ecological State (PES) was assessed by experts during the 2013 Desktop Assessment by the DWS. The PES category of the Kuruman River in the D41M catchment was category B (refer to Figure 6). A category B river is one which is only slightly modified; a small change in natural habitats may have taken place. However, the ecosystem functions are essentially unchanged. The Kuruman River is modified in terms of flow regime and pollution is limited to sediment
The Ecological Importance (EI) of an aquatic ecosystem indicates its importance to the maintenance of biological diversity and ecological functioning on local and wider scales. Ecological Sensitivity (ES) indicates the ecosystem’s ability to resist disturbance and its capability to recover from disturbance once it has occurred. The EI of the Kuruman River in the project area was rated as moderate (refer to Figure 7). The ES in terms of sensitivity to modified flow and water level changes was determined to be low and in terms of riparian, wetland and instream vertebrates and vegetation, the sensitivity was found to be very low (refer to Figure 8). The mean ES was determined to be very low.
Surface Water Flow and Quality
There are no DWS flow and water quality monitoring points in the D41M catchment. There was an upstream site in a tributary of the Kuruman River at the Tsnineg Eye that was analysed periodically between 1988 and 1996. During this time, water was of general good quality with pH averaging 8.1, low sulphate concentrations (less than 20 mg/L) but the water could be considered borderline hard with significant calcium (> 90 mg/L), magnesium (approximately 50 mg/L) and alkalinity levels (>390 mg/L). Following convergence with the Moshaweng River, there were two monitoring stations. Resource quality data (as per RQIS) for these sites was last measured in 1988.
Mean Annual Rainfall and Ecological Reserve
The Lower Vaal WMA can be subdivided into three sub-catchments; Harts, Vaal downstream of Bloemhof and Molopo. The Kuruman River and the D41M quaternary catchment are located within the Molopo sub- area. Due to the low rainfall, flat topography and sandy soils over much of the WMA, little usable surface runoff is generated in the water management area. The runoff is highly variable and intermittent. Although occasional runoff occurs in the upper reaches of the Molopo River, no record exists of flow having reached the Orange River (according to the Overview of Water Resources Availability and Utilisation, 2003). The estimated runoff for the Molopo sub area is 197 million m3/a. The ecological reserve, the amount of water needed to maintain the PES category B rating of the river, is 29 million m3/a.
Figure 5: Water Management Area (WMA) and quaternary catchment map
Figure 6: PES category of rivers surrounding the project area (PESEIS, 2013)
Figure 7: Ecological importance (EI) of rivers surrounding the project area (PESEIS, 2013)
Figure 8: Ecological sensitivity of rivers surrounding the project area (PESEIS, 2013)
v) Groundwater The following information was obtained from
Water Research Commission. The South African Mine Water Atlas (WRC Project No. K5/2234/3) Development of Internal Strategic Perspectives (ISP): Groundwater Overview for the Lower Vaal Catchment Management Area (prepared for Directorate Water Resource Planning, 2003) Internal Strategic Perspectives (ISP) for the Lower Vaal Management Area (WMA No 10, 2004) The online DWS Resource Quality Information Services (RQIS) (http://www.dwa.gov.za/iwqs/) MS Basson and JD Rossouw, 2003. Lower Vaal Water Management Area: Overview of Water Resources Availability and Utilisation.
Aquifer systems
In general, there are 4 major aquifer systems in the Vaal WMA:
Karst aquifers with borehole yields >5.0 l/s, supporting fresh dolomite springs Intergranular and fractured aquifers with boreholes yields between 0.1 and 2.0 l/s Fractured aquifers with borehole yields between 0.1 and 2.0 l/s, highly variable water quality Intergranular/ alluvial aquifers with borehole yields between 0.1 and 2.0 l/s, multi layered aquifer systems (fresh upper aquifers, underlain by brackish to hyper saline groundwater).
The Mine Atlas rates the aquifer vulnerability of the Lower Kuruman River (close to Van Zylsrus-Askham area) as 3.2 (high) due to its good fresh water quality (<70 mS/m) and high yields (2.0 to 5.0 l/s), however nearer to the project area the risk is considered moderate (rated between 2 and 3).
Most of the groundwater abstraction that takes place in the Molopo sub-area (which includes the D41M catchment) is in the vicinity of dry sandy riverbeds. A substantial part of the recharge of groundwater is also assumed to be from these watercourses.
To the south of the project area in quaternary catchment D41L, an extensive dolomitic aquifer is hosted in the Ghaap Plateau dolomites.
Groundwater Use in the Region
As per the ISP, almost every farm in the Lower Vaal WMA is dependent on groundwater supply for domestic use and stock watering. There are no abstraction volumes available but in terms of quantities of water, stock farming has a relatively small influence on the regional groundwater resource. Several local municipalities are dependent on groundwater as a source of bulk supply, aquifers exploited are generally hosted in dolomites and weathered fractured crystalline rocks. As the 2011 Census, 15.6% of households in the local municipality rely on borehole water.
Groundwater Quality
There is a large amount of groundwater data available for the Lower Vaal WMA. There are over 13000 borehole locations in Region D that have data available via the DWS Resource Quality Information Services (RQIS). Boreholes in the project area that are included in the database are shown in Figure 9.
Note that most of the sampling took place in 1993 and there is no indication as to whether these boreholes still exist and are currently being used. The groundwater in the region is generally of good quality. There were a few exceedances in the qualities relative to the SANS 241-1:2015 drinking water guidelines. The water appears to be saline in some cases with high Cl and Na concentrations. Poorer groundwater is a natural feature of the western portion of the Lower Vaal WMA within the Kalahari group primary (sand/gravel) aquifers and clay formations. The relatively high nitrate-nitrite concentrations could be attributed to the agricultural activities in the region. Agricultural activities are a source of diffuse water contamination. The contribution of each farm on a local scale is often small but the cumulative contribution can be significant.
Figure 9: Boreholes with available data in the National Groundwater Database
5 vi) Socio Economic The following information was obtained from the 2017/2018 Integrated Development Plan of the Joe Morolong Local Municipality (adopted by the Council on 30 March 2017) as well Census 2011 data and Community Survey 2016 data, provided by Statistics South Africa (Stats SA).
Provincial context
The Northern Cape is the largest of the South African provinces, covering an area of 372 889 km2. The province is also the least populous of the country’s provinces, with a total population of only 1 193 780 (Community Survey 2016). Only 2.1% of the country’s total households reside in the Northern Cape.
The capital city of the province is Kimberley. Other important towns include Upington, Springbok, Kuruman and De Aar.
Mining and agriculture are the primary economic sectors of the province. There are alluvial diamonds, iron ore, copper, asbestos, manganese, fluorspar, semi-precious stones and marble resources which have been mined in the region.
The province has fertile agricultural land in the Orange River Valley where grapes and fruit are cultivated intensively. Sheep farming takes place in the interior Karoo. Wheat, fruit, peanuts, maize and cotton are also produced at the Vaalharts Irrigation Scheme near Warrenton.
The Northern Cape is subdivided into five district municipalities: Francis Baard, John Taolo Gaetsewe, Namakwa, Pixley Ka Seme and ZF Mgcawu. The PRA is located in the John Taolo Gaetsewe District Municipality.
Regional context
The John Taolo Gaetsewe District Municipality (previously Kgalagadi) is located to the north east of the province and borders Botswana. It is comprised of three local municipalities: Gamagara, Ga-Segonyana and Joe Morolong. Joe Morolong is the largest of these municipalities in terms of area.
There are 186 towns and settlements, of which the majority (approximately 80%) are villages.
The District has an established rail network from Sishen South and between Black Rock and Dibeng. It is characterised by a mixture of land uses, of which agriculture and mining are dominant.
The population of the District Municipality was 242 264 (Community Survey 2016), of which 63.3% were aged between 15 and 64 years and 31.9% of the population was under the age of 15. The official unemployment rate of the District Municipality is 29.7%, while the youth unemployment rate is 37.2%.
Local context
The prospecting area is situated within the Joe Morolong Local Municipality (JMLM), Ward 4.
JMLM is mostly rural, with virgin land surface comprising about 60% of the surface. Agriculture, mining and community services are the primary economic sectors. JMLM has three main nodes where relatively higher economic activity takes place, namely Vanzylsrus, Hotazel and Blackrock. Mining is the predominant economic activity in Hotazel and Blackrock. Vanzylsrus operates as service centre for the surrounding area.
According to 2011 Census data, there are 12 740 people that are economically active (employed or unemployed but looking for work), and of these, 38.6% are unemployed. Of the 6 323 economically active youth (15–34 years) in the area, 49.5% are unemployed.
According to the 2011 Census, JMLM has a total population of 89 530 people. The majority of the population in the municipality are black African (96.4%), 2.0% are coloured, with the other population groups making up the remaining 1.6%.
Setswana is the most prevalent language spoken in the community with 90.1% of people listing it as their first language. Afrikaans and English are the first languages of 3.6% and 1.9% of the population respectively.
Of the population aged 20 years and older, 5.2% have completed primary school, 27.8% have some secondary education, 13.4% have completed matric, 4.1% have some form of higher education and 22.9% have no form of schooling.
There are 168 schools, 4 police stations, 24 clinics and 3 community health centres located in JMLM. There is no hospital in JMLM. According to the IDP, there are 23 707 households with a population growth of - 0.9%. The average household size is 3.4 persons per household.
JMLM does not own any land in their jurisdiction. Most of the land either belongs to the state or falls under the jurisdiction of the Tribal leaders.
AS per the IDP, JMLM itself is not responsible for the implementation of electrification projects. The Municipality acts as a project coordinator for projects implemented by ESKOM and Department of Energy. Within JMLM, 81.8% of households have access electricity and use it for lighting while 16.1% still use candles for lighting. Wood is used for heating in 51.2% and for cooking in 39.3% of households.
Currently, most of the communities within JMLM receive water for free. Of all households, only 6.6% have access to piped water either in their dwelling or in the yard. As per the 2011 Census, 71.7% sourced water from a water services provider (municipality or other), 15.6% used borehole water and 5.8% received water via a water truck. Vanzylsrus and Hotazel are the only areas that have water borne system in JMLM. According to the IDP, there are 24 villages that are without access to piped water. They receive water by means of truck delivery or through a windmill equipped with a tap. The IDP identified the following as challenges to the provision of water:
Community disruptions caused some projects to lag the programme of works Vandalism of infrastructure equipment Insufficient funding Illegal water connections
Due to the shortage or lack of water supply, JMLM is unable to provide adequate sanitation to their communities. The majority of the population uses pit toilets (40.3% with ventilation and 36.7% without ventilation), 10.3% of the population have no access to toilet facilities and 6% are connected to a sewerage system.
7 JMLM collects refuse in Hotazel and Vanzylsrus, serving 1 144 households in the two areas. According to the 2011 Census, this service is provided for 6.1% of households, while 79.8% of households provide their own refuse dump and 11.4% do not have access to rubbish disposal.
JMLM conducts Environmental Awareness campaigns in all of the wards annually. The communities are given information on issues that need to be taken care of in their respective environmental areas. The most challenging issue of environmental management in JMLM is veld fires and to minimize that the municipality has entered into an agreement with Working on Fire through Expanded Public Works Programme.
From telephonic conversations with the landowners, the majority of the farms are used for cattle farming with some small scale game farming. Of the 17 farm portions making up the PRA, there are there are houses on 7 of the farms and the landowners generally reside on these properties. vii) Soil Information for this section has been sourced from:
The Soil and Terrain (SOTER) database developed by ISRIC World Soil Information M.V. Fey (2010). A short guide to the soils of South Africa, their distribution and correlation with World Reference Base soil groups. 19th World Congress of Soil Science, Soil Solutions for a Changing World.
The Soil and Terrain (SOTER) database developed by ISRIC World Soil Information provide data on key soil and terrain properties. According to the database, the project region is dominated ferralic arenosols (refer to Figure 10). Arenosols develop during the weathering of quartz-rich material. The soils have a loamy sand or coarse-grained texture and occur at a depth of at least 50 cm from the surface. The soil typically has less than 35% rock fragments by volume. The soil type is generally suitable for extensive stock grazing but could be used for arable crops if well irrigated.
Quartz and feldspars are the dominant minerals in arenosols with lesser micas, pyroxenes, amphiboles, olivines, and heavy minerals (such as zircon, garnet, tourmaline, etc). Arenosols generally lack structure, they are not sticky when wet and loose grains when dry. A cemented layer may occur at some depths.
Arenosols is a World Reference Base soil type, in terms of South African classification, arenosols would classify as ‘plinthic’, ‘oxidic’ or ‘cumulic’ soil groups. As per the distribution of these soil types, oxidic and cumulic soils are known to occur in the project region, with oxidic soils generally being in greater abundance (refer to Figure 11). Cumilic soils are generally young soils with an orthic topsoil but weakly developed subsoil and formed in colluvial, alluvial or aeolian environments. Oxidic soils are generally iron enriched through weathering with an orthic topsoil layer.
The soils within the PRA region can be broadly categorised into groupings associated with the different types of vegetation. (Mucina and Rutherford, 2006). The Kathu Bushveld and the Molopo Bushveld vegetation types (the dominant indigenous vegetation types in the PRA) are hosted on aeolian red sand, surface calcrete and deep (>1.2m) sandy soils of Hutton and Clovelly soil forms. The Southern Kalahari Mekgacha vegetation type is found the Kuruman River and is hosted on prevalently sandy Kalahari sediments that cover the Precambrian metamorphic crust of the area. The substrate of the dry riverbeds is silty, sandy and rocky, poorly drained and can be rich in nutrients. The banks of the dry rivers can cut into
calcrete and silcrete, and in places also ferricretes. In some areas steep vertical cliffs a few meters high may develop.
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Figure 10: Soil types in the project area
Figure 11: Oxidic soil distribution is highest in the Northern Cape (from Fey, 2010)
11 viii) Terrestrial Ecology The project area falls within the Savanna Biome, within the Eastern Kalahari Bushveld Bioregion and the Inland Saline Vegetation Bioregion. Three vegetation types occur within the project area, namely the Molopo Bushveld, Kathu Bushveld and Southern Kalahari Mekgacha vegetation types which are all listed as Least Threatened in terms of Section 52 of NEMBA (refer to Figure 12).
The ecosystem protection level indicates whether ecosystems are adequately protected or under- protected. The assessment of the ecosystem protection level is evaluated as the proportion of each vegetation type protected relative to the biodiversity target. Ecosystem types are categorized as not protected, poorly protected, moderately protected or well protected, based on the proportion of each ecosystem type that occurs within a protected area recognized in the Protected Areas Act. The Ecosystem protection levels of the Molopo Bushveld, Kathu Bushveld and Southern Kalahari Mekgacha ecosystems are poorly protected (less than 50% of the biodiversity target is met is met in formal protected areas), not protected (less than 5% of the biodiversity target is met is met in formal protected areas) and moderately protected (less than 100% of the biodiversity target is met in formal protected areas) (refer to Figure 13).
According to the Northern Cape Critical Biodiversity Areas assessment (2016), the portion of the PRA that falls over the Kuruman River, which is classified as a FEPA river, is considered to be a CBA One (Natural landscape). Associated with this area is also a CBA Two (Near-natural landscape) and an Ecological Support Area (ESA) (Functional landscape) (where the river provides ecosystem functions and landscape linkages for this arid region). These areas are of conservation importance. CBA’ are terrestrial and aquatic features in the landscape that are critical for retaining biodiversity and supporting continued ecosystem functioning and services. CBA’s 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. Ecological support areas (ESA’s) 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.
According to the Mining and Biodiversity Guidelines (2013), the south west portion of the PRA falls within an area considered to be of Highest Biodiversity Importance and Moderate Biodiversity Importance (refer to Figure 15). Areas of Highest Biodiversity Importance are areas where mining is not legally prohibited, but where there is a very high risk from mining due to their potential biodiversity significance and importance to ecosystem services (e.g. water flow regulation and water provisioning). Areas of Moderate Biodiversity Importance include ESAs, vulnerable ecosystems as well as focus areas for protected area expansion. These areas are of moderate biodiversity value and therefore are at a moderate risk from mining.
Species Composition
The project area falls within the Molopo Bushveld, Kathu Bushveld and Southern Kalahari Mekgacha vegetation type classifications (Mucina & Rutherford, 2006).
The Molopo Bushveld vegetation type is characterised by open woodland to a closed shrubland with the trees Acacia erioloba (Camel Thorn) and Boscia albitrunca (Shepherds Tree) and shrubs Lycium cinereum, Lycium hirustum and Rhigozum trichotomum. The grass layer is usually fairly open.
The Kathu Bushveld vegetation type has medium-tall tree layer with the trees Acacia erioloba (Camel Thorn) and Boscia albitrunca (Shepherds Tree) as prominent trees interspersed with Schmidtia spp. and Stipagrostis spp. The shrub layer is generally most important with A.mellifera, Diospyros lycioides and Lycium hirustum. The grass layer is variable in cover.
The Southern Kalahari Mekgacha vegetation type has sparse, patchy grasslands, sedgelands and low herblands dominated by grasses such as Panicum, Eragrostis, Enneapogon, Targus, Chloris and Cenchrus on the bottom of mostly dry riverbeds. Low shrublands are found with patches of taller shrubland on the banks of the river. Relatively tall Acacia erioloba trees can form a dominant belt along the river.
Species of Conservation Concern
Floral species of conservation concern (SCC) likely to occur in the PRA include Acacia erioloba (Camel Thorn) and Boscia albitrunca (Shepherds Tree) which are classified as of least concern.
It can be expected that faunal species of conservation importance do occur on the site including mammals (Ground Pangolin and African Wild Cat), birds (Tawny Eagle and Secretary Bird), reptiles (Rock Monitor) and amphibians (Giant Bullfrog). Invertebrates of conservation importance such as the Horned Baboon Spider and the Starburst Baboon Spider are also likely to occur within the PRA.
Environmental Sensitivity
The Kathu Bushveld, Southern Kalahari Mekgacha and Molopo Bushveld ecosystem types are considered to be Least Threatened. According to the Northern Cape Critical Biodiversity Areas assessment (2016), ESA and CBAs are present within the project area and these areas are of conservation importance. The depression wetlands (endorheic pans) within the PRA are considered to be sensitive habitats in terms of species diversity and as potential linkage points on migratory routes during seasonal rainfall periods.
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Figure 12: Vegetation Types/ Ecosystems associated with the project area
Figure 13: Ecosystem Protection Levels associated with the project area
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Figure 14: Northern Cape Critical Biodiversity Areas occurring in the project area
Figure 15: Mining and Biodiversity Guideline classification of the project area
17 ix) Wetlands The wetlands and associated 500 m wetland buffer occurring over the entire PRA are shown in Figure 16 below. Wetlands identified within the greater PRA include depression-, unchannelled valley bottom-, valleyhead seep-, flat- and floodplain wetlands. The wetlands have a PES equivalent that is natural or good and the NFEPA condition is classified as AB (intact wetland), with the percentage of natural land cover > 75%. The depression wetlands (endorheic pans) within the PRA are considered to be sensitive habitats in terms of species diversity and as potential linkage points on migratory routes during seasonal rainfall periods.
According to the National Freshwater Ecosystem Priority Area (NFEPA) database (desktop study), no wetlands were identified within the indicative preliminary drill hole areas (refer to Figure 17 to Figure 21). Area 4 does however fall within the 500m wetland buffer of the floodplain wetland associated with the Kuruman River.
If any additional target sites are identified, the location of the wetlands and associated buffers must be taken into account and avoided.
Figure 16: Wetlands associated with the PRA
Figure 17: Wetlands associated with Farm 703 Portions 103, 108, 114 and proposed drill area 1
Figure 18: Wetlands associated with Farm 703 Portions 32, 59, 60, 103, 108 and the proposed drill area 2
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Figure 19: Wetlands associated with Farm 703 Portions 31, 32, 41, 50, 59, 108, Farm 710 Portions RE and 1 and the proposed drill area 3
Figure 20: Wetlands associated with the Farm 703 Portions 31, 43, 49, 50, Farm 709 Portions RE and 1, Farm 710 Portions RE and 1 and the proposed drill area 4
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Figure 21: Wetlands associated with the Farm 703 Portions 42, 43, 75, Farm 709 Portions RE and 1 and the proposed drill area 5
b) Description of the current land uses
Land use is defined as the operations that are occurring on land, as carried out by humans, with the intention to obtain products and/or benefits through using land resources. Land use therefore refers to the purpose the land serves, such as recreation, natural or agriculture. From Google Earth aerial photography, the land use associated with the PRA is largely natural/ open space that is used for cattle farming/ grazing with some game farming (refer to Figure 22).
Land cover is defined as the physical coverage on the earth’s surface, such as the vegetation (natural or cultivated) or man-made constructions (buildings, etc.) which occur on the earth surface. Land cover data for the proposed project area was obtained from the SANBI GIS Land Cover Map 2015. The land cover associated with the proposed PRA is classified as low shrubland with some grassland and thicket/bush. There are also some homesteads/ dwellings and roads within the PRA (refer to Figure 23).
Figure 22: Land Uses associated with the project area
Figure 23: Land Cover associated with the project area
c) Description of specific environmental features and infrastructure on the site
The Kathu Bushveld, Southern Kalahari Mekgacha and Molopo Bushveld ecosystem types are considered to be Least Threatened. According to the Northern Cape Critical Biodiversity Areas assessment (2016), ESA and CBAs are present within the project area and these areas are of conservation importance. The Kuruman River and its associated floodplain wetland run through the south west portion of the PRA. The depression wetlands (endorheic pans) within the PRA are considered to be sensitive habitats in terms of species diversity and as potential linkage points on migratory routes during seasonal rainfall periods.
In terms of infrastructure, the R380 road runs along the Kuruman River and the north western side of the PRA. There are also some homesteads/ dwellings and gravel roads within the PRA. d) Environmental and current land use map (show all environmental, and current land use features)
Figure 24: Environmental and current land use map
6. Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts (provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability, and duration of the impacts. Please indicate the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and can be avoided, managed or mitigated)
The potential impacts of the planned invasive prospecting activities (drilling) are listed below. Non-invasive prospecting activities are not expected to result in any environmental or socio-economic impacts.
Vegetation clearing for drill hole areas and access tracks as well as minor earth moving activities may result in the following impacts:
Dust generated from activities. Damage to buried archaeological or paleontological resources of significance.
Leaks from vehicles and machinery on site, inadequate hydrocarbon handling and storage, inadequate waste management and spills from ablutions may result in the following impact:
Contamination of soil.
The presence of vehicles and machinery as well as personnel on site for drilling activities may result in the following impacts:
Noise. Compaction of soil and subsequent negative impact on vegetation re-establishment. Disturbance of flora and fauna.
Refer to Section 6(g) below for an indication of the significance of the potential impacts and extent to which they can be avoided, managed or mitigated.
Refer to Appendix 3 for a detailed assessment of the significance of the potential impacts considering their magnitude, scale, duration and probability; as well as the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and extent to which they can be avoided, managed or mitigated. a) Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks (describe how the significance, probability, and duration of the aforesaid identified impacts that were identified through the consultation process was determined in order to decide the extent to which the initial site layout needs revision) The Prime Resources impact ranking tool is a quantitative manner of investigating, assessing and evaluating the potential impacts / risks resulting from the activities associated with the proposed activity on the receiving environment; i.e. the biophysical, socio-economic and cultural heritage environment.
The methodology encompasses an assessment of the nature, extent, duration, probability and significance of the identified potential environmental, social and cultural impacts of the mining operation, including the cumulative environmental impacts. The significance of both positive and negative potential impacts will be determined through the evaluation of impact consequence and likelihood of occurrence.
The following risk assessment model has been used for determination of the significance of impacts.
SIGNIFICANCE = (MAGNITUDE + DURATION + SCALE) X PROBABILITY
The maximum potential value for significance of an impact is 100 points. Impacts can therefore be rated as high, medium or low significance on the following basis:
High environmental significance 60 – 100 points Medium environmental significance 30 – 59 points Low environmental significance 0 – 29 points
MAGNITUDE (M) DURATION (D) 10 – Very high (or unknown) 5 – Permanent 8 – High 4 – Long-term (ceases at the end of operation) 6 – Moderate 3 – Medium-term (2-4 years) 4 – Low 2 – Short-term (0-1 years) 2 – Minor 1 – Immediate SCALE (S) PROBABILITY (P) 5 – International 5 – Definite (or unknown) 4 – National 4 – High probability 3 – Regional 3 – Medium probability 2 – Local 2 – Low probability 1 – Site 1 – Improbable 0 – None 0 – None b) The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected (provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)
The drill hole site selection is based on the location of the mineral resources. Preliminary drill sites have been identified however additional and alternative locations may come to light post the Phase 1 activities. No concerns have been raised as yet but any are raised during public participation process will be included and evaluated in this section of the final report. c) The possible mitigation measures that could be applied and the level of risk (with regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/ discussion of the mitigations or site layout alternatives
available to accommodate or address their concerns, together with an assessment of the impacts or risks associated with the mitigation or alternatives considered)
PROPOSED ALTERNATIVE / ISSUE / CONCERN RAISED RESPONSE MITIGATION AND ASSESSMENT THEREOF No issues and concerns have been raised to date. Any issues and concerns raised during the public participation process will be responded to and proposed alternatives and mitigation measures assessed where applicable. d) Motivation where no alternative sites were considered
No alternative site locations were assessed to date as the preliminary drill hole areas are based on the expected mineral resources located within that area. Additional and alternative locations within the total PRA may come to light post the Phase 1 activities. e) Statement motivating the alternative development location within the overall site (provide a statement motivating the final site layout that is proposed)
No concerns have been raised as yet but any are raised during public participation process will be included and evaluated in this section of the final report.
The preliminary drill hole areas are not in proximity to any communities or residences, therefore, limiting the potential negative social impacts. The proposed drill hole areas, with the exception of the drill hole area on Portion 50 of the Farm Gravenhage 703, are also not in proximity to any sensitive environmental features, therefore, limiting the potential negative environmental impacts. Therefore, most of the preliminary drill hole areas do not require alternative development locations within the overall site. However, should it be determined that prospecting activities will take place within the drill hole area on Portion 50 of the Farm Gravenhage 703, it is recommended that the 500 m buffer of the wetland associated with the Kuruman River be excluded from the drill hole area.
Additional and alternative locations within the total PRA may come to light post the Phase 1 activities. f) Full description of the process undertaken to identify, assess and rank the impacts and risks the activity will impose on the preferred site (in respect of the final site layout plan) through the life of the activity. (Including (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures)
5 The potential impacts which may arise as a result of the planned exploration drilling activities are considered typical of these activities and were determined by considering the nature of the activity, the equipment and materials utilised, the type of waste generated, common incidents which lead to impacts, and the known timeframes and the proximity in relation to the environmental features of the site. The Prime Resources (Pty) Ltd Impact Assessment Methodology and rationale (described in Section 6[a]) above was used to assess the significance of the potential impacts. Refer to Section 6 above for the list of potential impacts identified, and refer to Appendix 3 for the detailed assessment of their significance and the extent to which they can be mitigated.
g) Assessment of each identified potentially significant impact and risk (this section of the report must consider all the known typical impacts of each of the activities including those that could or should have been identified by knowledgeable persons and not only those that were raised by registered interested and affected parties - the supporting impact assessment conducted by the EAP must be attached as an appendix)
The potential impacts of the planned invasive prospecting activities (drilling) have been assessed and summarised in the table below, non-invasive prospecting activities are not expected to result in any environmental or socio-economic impacts. The supporting impact assessment conducted by Prime Resources is attached as Appendix 3.
PHASE SIGNIFICANCE ASPECTS IN WHICH SIGNIFICANCE NAME OF ACTIVITY POTENTIAL IMPACT IF NOT MITIGATION TYPE AFFECTED IMPACT IS IF MITIGATED MITIGATED ANTICIPATED Loss of vegetation (possible - Where possible available plant species of conservation access tracks will be used concern) from clearing or - Avoid all plant species of Low Low harvesting by personnel or conservation concern (in the uncontrolled fires set by unlikely event that they are - Clearing access track personnel present) by changing the and drill sites location of sites accordingly - Demarcation of drill prior to clearing pad - Areas to be cleared will be - Temporary camp site Operational limited to the minimum for the drillers Biodiversity (Phase 2 - extent possible - Temporary core yard Drilling) - Avoid clearing trees where for cutting and Loss of animal species as a possible processing drilling result of collisions with Low - No hunting and harvesting Low - Percussion drilling vehicles or hunting and of plants or animals must be followed by diamond trapping by personnel allowed drilling - No uncontrolled fires must be allowed - Intervening by planting indigenous vegetation in disturbed areas should PHASE SIGNIFICANCE ASPECTS IN WHICH SIGNIFICANCE NAME OF ACTIVITY POTENTIAL IMPACT IF NOT MITIGATION TYPE AFFECTED IMPACT IS IF MITIGATED MITIGATED ANTICIPATED natural revegetation prove unsuccessful - Maintaining equipment and machinery in good working Noise from drilling activities Noise; Socio- Low order Low may result in nuisance economic - Switching off equipment when not in use Damage to buried Heritage; - Implement a chance finds archaeological or or Socio- Low procedure as detailed in Low paleontological resources of economic Table 3 significance - Areas to be cleared will be limited to the minimum Air quality; Dust generated may result in extent possible Socio- Low Low nuisance impacts - Wet suppression must be economic implemented where dust plumes are noted - Implementing spill prevention measures such as handling and storing Heavy vehicles and machinery hydrocarbons on on site may result in potential impermeable surfaces Soil Low Low hydrocarbon leaks which may - Adequately maintaining in turn pollute the soil vehicles and machinery to prevent leaks - Cleaning any spills immediately Heavy vehicles and machinery - Minimising areas to be on site may result in soil disturbed by vehicle and compaction subsequently Soil Low machinery, Low impacting vegetation re- - Ripping and profiling establishment compacted soil Waste spills may result in - Cleaning any spills Stores and ablutions Soil Low Low pollution of soil immediately
PHASE SIGNIFICANCE ASPECTS IN WHICH SIGNIFICANCE NAME OF ACTIVITY POTENTIAL IMPACT IF NOT MITIGATION TYPE AFFECTED IMPACT IS IF MITIGATED MITIGATED ANTICIPATED - Implementing adequate waste management practices
5 h) Summary of specialist reports (this summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular form - attach copies of specialist reports as appendices)
SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION THAT HAVE BEEN OF REPORT WHERE LIST OF RECOMMENDATIONS OF SPECIALIST REPORTS INCLUDED IN THE EIA SPECIALIST STUDIES UNDERTAKEN REPORT RECOMMENDATIONS (Mark with an X where HAVE BEEN INCLUDED. applicable) N/A N/A N/A N/A
No specialist studies were commissioned considering the nature of the activities to be undertaken, the availability of suitable information from available resources and the sensitivity of the project area. Should the outcomes of the public participation process reveal the need for additional specialist studies, or should additional specialist studies be requested by the Competent Authority, these will be undertaken and the outcomes described herein.
7. Environmental impact statement a) Summary of the key findings of the environmental impact assessment
Potential impacts which cannot be adequately mitigated (i.e. those with a significance rating of Medium (significance value ≥ 31) or above after the implementation of mitigation measures), are considered key findings of the environmental impact assessment.
Due to the limited extent of the areas to be cleared, limited temporary infrastructure required, temporary nature of the activities, the fact that few residences are located within the PRA and the fact that the preliminary drill hole areas as well as any additional drill sites will seek to avoid activities in proximity to an sensitive environmental features, all of the potential impacts are considered to be of low significance before the implementation of mitigation measures. Therefore, none of the potential impacts are considered key findings.
Any recommended mitigation measures applicable to the preliminary drill hole areas will also be applicable to the additional drilling sites identified as a result of Phase 1 prospecting activities and will therefore still ensure that the significance of the potential impacts remains low by, for e.g. avoiding watercourses and wetlands and known sensitive environments. b) Final site map (provide a map at an appropriate scale which superimposes the proposed overall activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers)
Refer to Figure 25 for a composite map of the PRA and currently proposed drill hole areas. c) Summary of the positive and negative impacts and risks of the proposed activity and identified alternatives
Negative impacts
The potential impacts of the planned invasive prospecting activities (drilling) are listed below.
Vegetation clearing and minor earth moving activities for drill hole areas and access tracks may result in the following impacts:
Dust generated from activities. Damage to buried archaeological or paleontological resources of significance.
Leaks from vehicles and machinery on site, inadequate hydrocarbon handling and storage, inadequate waste management and spills from ablutions may result in the following impact:
Contamination of soil.
The presence of vehicles and machinery as well as personnel on site for drilling activities may result in the following impacts: Noise. Compaction of soil and subsequent negative impact on vegetation re-establishment. Disturbance of flora and fauna.
Positive impacts
The prospecting activities being applied for are required in order to investigate the presence of suitable mineralisation and, if so, whether this mineralisation can be economically and feasibly mined in future which, in turn, presents various socio-economic benefits to the region.
8. Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr (based on the assessment and where applicable the recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation)
Refer to Section 4 of the EMP (Part B of this document) for the proposed impact management objectives and the impact management outcomes.
9. Aspects for inclusion as conditions of Authorisation (any aspects which must be made conditions of the Environmental Authorisation)
The terms and conditions for surface access to the PRA between the Applicant and affected landowners must be finalised prior to the commencement of invasive prospecting activities. The commitments as per this EMP (Part B) must be adhered to. Rehabilitation and closure must be undertaken as per the Closure Plan (refer to Appendix 4).
10. Description of any assumptions, uncertainties and gaps in knowledge (which relate to the assessment and mitigation measures proposed)
Information to characterise the baseline environment was obtained from available desktop sources in the public domain. It is assumed that this information accurately reflects the current conditions of the PRA, aside from those aspects where information is outdated and is stated as such in the baseline description. It is, however, not considered that this data will alter the findings or outcomes of any potential impact identified nor the management measures proposed.
11. Reasoned opinion as to whether the proposed activity should or should not be authorised a) Reasons why the activity should be authorized or not
The findings of the impact assessment indicate that prospecting activities will not result in any significant social or environmental impacts. No fatal flaws were identified; therefore, no reasons why the activities should not be authorized were identified. b) Conditions that must be included in the authorisation
None aside from those listed under Section 9 above, as all the relevant aspects have been included as commitments in this EMP (Part B of this document) as well as within the Closure Plan (refer to Appendix 4). c) Period for which the Environmental Authorisation is required
The period for which authorisation is required will be from the year 2018 to the year 2023.
12. Undertaking (confirm that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the Basic assessment report and the Environmental Management Programme report)
The undertaking in the EMP is applicable to both the BAR (this section, Part A) and the EMP (Part B).
13. Financial Provision (state the amount that is required to both manage and rehabilitate the environment in respect of rehabilitation)
As per Regulation 6(3) of the NEMA Regulations on Financial Provision (GNR1147 of 2015) the determination of the quantum for rehabilitation-related financial provision has been included in the EMP (Part B - 5(a)(v)).
The total financial provision for the invasive prospecting activities proposed for the PAMDC Project, is therefore R 135,048 (value as per date of assessment - 2018). a) Explain how the aforesaid amount was derived
Regulation 6 of the NEMA Regulations on Financial Provision (GNR1147 of 2015) states that a holder must determine the financial provision through a detailed itemisation of all activities and costs required for final rehabilitation, decommissioning and closure of the operations.
The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using contractor rates to provide actual, present-day costs for decommissioning and rehabilitation. The rates utilised are based on contractor rates which have been escalated by Consumer Price Index (CPI) of 5.26% for 2017. Refer to Section 5(a)(v) in the EMP - Part B of this document for further information.
From the methodology for calculation of Financial Provision for a new development in the draft financial provisioning regulations (GNR1228 of 2017), the costing for final rehabilitation, decommissioning and closure, must reflect the total cost to remediate disturbances that will occur in Year O and must reflect
5 actual market related costs based on prevailing rates exclusive of VAT. The costing for residual environmental impacts which will occur in the future must reflect the Net Present Value (NPV) based on prevailing rates of future residual environmental impacts due to disturbance of Year O. This is the Year O cost for residual environmental impacts. Total 1 for final rehabilitation, decommissioning and mine closure and Total 2 for residual environmental impacts which may occur in the future are then added to obtain the Total Financial Provision. b) Confirm that this amount can be provided for from operating expenditure (confirm that the amount, is anticipated to be an operating cost and is provided for as such in the Mining work programme, Financial and Technical Competence Report or Prospecting Work Programme as the case may be)
Financial Provision is provided for as a regulatory cost, totalling R 100 000 (under the ongoing environmental cost and final rehabilitation cost category) in the Prospecting Work Programme.
14. Specific Information required by the Competent Authority a) Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998) the report must include the:- i) Impact on the socio-economic conditions of any directly affected person (provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as an appendix)
There are no communities in proximity to the PRA. The land is privately owned. There are currently no land claims lodged on the farm portions applicable to the PRA. The landowners would therefore be the only directly affected persons. It is required that a suitable agreement will be drawn up between the Applicant and the landowners for the activities.
Due to the fact that there are no communities in the vicinity of the PRA and limited residences present within the area, no social impacts are foreseen. ii) Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act (provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi)
and (vii) of that Act, attach the investigation report as an appendix and confirm that the applicable mitigation is reflected herein)
Sites of archaeological or or paleontological significance are unlikely to be present in the area. However, there is always a chance that buried artefacts may be unearthed during vegetation clearing and minor earth moving activities. The potential impact is only applicable during vegetation clearing and earth moving activities. The potential impact can be mitigated by implementing a chance finds procedure (as detailed in Table 3 in the EMP - Part B of this document) to prevent damage to buried resources which may be of significance, in the unlikely event that they are unearthed. The significance of the potential impact on buried artefacts is low prior to and after the implementation of the recommended mitigation measure. b) Other matters required in terms of sections 24(4)(a) and (b) of the Act (the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist)
Motivation for why alternatives were not considered has been included in Section 3(f). This BAR addresses the following requirements in terms of sections 24(4)(a) and (b) of the Act:
SECTION DESCRIPTION OF HOW THE CONTENTS OF NEMA ASPECT HAS BEEN ADDRESSED Section 24(4)(a) Procedures for the investigation, assessment and communication of the potential consequences or impacts of Refer to Section 6(a) for the 24(4)(a) activities on the environment – methodology used for the assessment must ensure, with respect to every of impacts. application for an environmental authorisation— The BAR / EMP will be made available to all the relevant organs of state: local and district municipality, Northern Cape Department of Environment and Coordination and cooperation between Nature Conservation; Northern Cape organs of state in the consideration of Department of Agriculture Land Reform 24(4)(a)(i) assessments where an activity falls under and Development; Department of the jurisdiction of more than one organ of Mineral Resources; Department of state; Water and Sanitation; Department of Agriculture, Fisheries and Forestry for comment during public participation processes. The DMR remains the Competent Authority. That the findings and recommendations The general objectives and the flowing from an investigation, the general principles of environmental 24(4)(a)(ii) objectives of integrated environmental management were addressed in the management laid down in this Act and the EMP - Part B of this document.
7 SECTION DESCRIPTION OF HOW THE CONTENTS OF NEMA ASPECT HAS BEEN ADDRESSED principles of environmental management set out in section 2 are taken into account in any decision made by an organ of state in relation to any proposed policy, programme, process, plan or project; That a description of the environment Refer to Section 5(a) for a detailed likely to be significantly affected by the 24(4)(a)(iii) description of the baseline environment proposed activity is contained in such likely to be affected by the project. application; Investigation of the potential consequences for or impacts on the Refer to Section 3(g) for the 24(4)(a)(iv) environment of the activity and assessment of the potential impacts. assessment of the significance of those potential consequences or impacts; and Public information and participation procedures which provide all interested and affected parties, including all organs of state in all spheres of government that Refer to Section 4 which details the 24(4)(a)(v) may have jurisdiction over any aspect of public participation process followed. the activity, with a reasonable opportunity to participate in those information and participation procedures; and Where environmental impact assessment has been identified as the environmental Basic Assessment has been identified instrument to be utilised in informing an 24(4)(A) as the environmental instrument application for environmental therefore (4)(b) is applicable. authorisation, subsection (4)(b) is applicable Section 24(4)(b) Must include, with respect to every 24(4)(b) application for an environmental authorisation and where applicable— Investigation of the potential consequences or impacts of the Motivation for why alternatives were alternatives to the activity on the not considered, as well as the options 24(4)(b)(i) environment and assessment of the of not implementing the activity have significance of those potential been addressed in Section 3(f). consequences or impacts, including the option of not implementing the activity; Mitigation measures for potential Investigation of mitigation measures to impacts have been identified. Refer to 24(4)(b)(ii) keep adverse consequences or impacts to Section 4 of the EMP - Part B of this a minimum; document. Investigation, assessment and evaluation of the impact of any proposed listed or The NHRA has been taken into account specified activity on any national estate (refer to Section 5(a)) where the referred to in section 3(2) of the National current heritage landscape in the 24(4)(b)(iii) Heritage Resources Act, 1999 (Act No. 25 project area is characterised) and the of 1999), excluding the national estate project does not trigger any activities contemplated in section 3(2)(i)(vi) and as listed therein (refer to Section 3(c)). (vii) of that Act; 24(4)(b)(iv) Reporting on gaps in knowledge, the The gaps have been identified. Refer to
SECTION DESCRIPTION OF HOW THE CONTENTS OF NEMA ASPECT HAS BEEN ADDRESSED adequacy of predictive methods and Section 10 of the EMP - Part B of this underlying assumptions, and uncertainties document. encountered in compiling the required information; Management and monitoring measures have been specified in the EMP - Part B Investigation and formulation of of this document. Implementation and arrangements for the monitoring and suitability of the EMP will be audited management of consequences for or every second year as required by 24(4)(b)(v) impacts on the environment, and the Regulation 55 of the MPRDA as well as assessment of the effectiveness of such per the frequency indicated in the arrangements after their implementation; Environmental Authorisation as per of Regulation 34 of the NEMA EIA Regulations, 2014. Consideration of environmental attributes identified in the compilation of information 24(4)(b)(vi) and maps contemplated in subsection (3); and Refer to Section 5(a) for maps The Minister, or an MEC with the indicating geographical areas, including concurrence of the Minister, may compile the sensitivity, extent, interrelationship information and maps that specify the and significance of such attributes attributes of the environment in particular informed by maps compiled by relevant 24(3) geographical areas, including the departments. sensitivity, extent, interrelationship and significance of such attributes which must be taken into account by every competent authority. Listed activities for the project have been identified. Refer to Section 3(a). Basic Assessment has been identified as the environmental instrument in terms of NEMA. An AEL is not required Provision for the adherence to as per NEMAQA. A WML is not required requirements that are prescribed in a as per NEMWA. Permits may be 24(4)(b)(vii) specific environmental management Act required as per NEMBA in the unlikely relevant to the listed or specified activity in event that species of conservation question. concern are identified and require relocation should avoidance through locating alternative drill sites not be possible. The area does not fall within a protected area as per NEMPAA. A WUL is not required in terms of NWA.
9 PART B ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
1. Details of the EAP (confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A, section 1(a) herein as required)
The details and expertise of the EAP are already included in Part A, Section 1(a) herein as required. Key Prime Resources Personnel CVs are attached as Appendix 1.1. The Prime Resources Company Profile is attached as Appendix 1.2.
2. Description of the aspects of the activity (confirm that the requirement to describe the aspects of the activity that are covered by the draft environmental management programme is already included in PART A, section (1)(h) herein as required)
The aspects of the activity that are covered by the EMP are already included in detail in Part A, Section (1)(h) herein as required.
3. Composite map (provide a map at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that any areas that should be avoided, including buffers)
Refer to Figure 25 for a composite map which superimposes the PRA and preliminary drill hole areas on the environmental sensitivities identified.
Figure 25: Composite map indicating the buffer zones
4. Description of Impact management objectives including management statements a) Determination of closure objectives (ensure that the closure objectives are informed by the type of environment described)
The main objective will be to rehabilitate- and return the borehole drill areas, access tracks and any areas affected as a result of invasive prospecting activities (including temporary infrastructure) to resemble the surrounding landscape (natural/ open) with no remaining infrastructure or potential hazards to people or the environment.
Further environmental objectives include:
. Ensure that no temporary infrastructure is left on-site and ensure environmental and safety risks are minimised; . Rehabilitate areas disturbed by prospecting activities; . Rehabilitated areas must not pose a safety hazard to humans and animals; . Establish a self-sustaining and stable vegetation cover over the area disturbed by the prospecting activities; . Minimise the establishment of alien vegetation; . Ensure the rehabilitated landform is free draining; . Protect drainage lines and watercourses; and . Ensure adherence to local, provincial and national regulatory requirements.
The Closure Plan (Appendix 4) provides specific goals for each of the above-mentioned aspects to achieve the main closure objective. b) Volumes and rate of water use required for the operation
The estimated water use required per day is approximately 5 000 litres per diamond drill rig per day which equates to 10 000 litres per day. The Applicant will make use of water obtained from a legal source within the area. It is anticipated that that water will be obtained from existing boreholes in the area in line with authorised abstraction rates and volumes for the existing borehole and stored in a water tanker. c) Has a water use licence has been applied for?
A water use licence is not required for the project as:
The Applicant will make use of water obtained from a legal source and not commission a new abstraction point; No waste or water containing waste will be disposed in a manner which may result in pollution; No waste or water containing waste will be discharged into the environment; and No activities which may result in pollution will take place within a regulated area of a watercourse.
d) Impacts to be mitigated in their respective phases (measures to rehabilitate the environment affected by the undertaking of any listed activity)
SIZE AND COMPLIANCE TIME PERIOD FOR ACTIVITIES POTENTIAL IMPACT PHASE SCALE OF MITIGATION MEASURES WITH IMPLEMENTATION DISTURBANCE STANDARDS - Where possible available Permits may be access tracks will be used required as per - Access track - Avoid all plant species of NEMBA in the conservation concern (in unlikely event Loss of vegetation to drill sites the unlikely event that they that species of (possible plant species of - (length will are present) by changing conservation conservation concern) vary) the location of sites concern are from clearing or - Demarcation accordingly prior to clearing identified and harvesting by personnel of drill pad Areas to be cleared will be require relocation or uncontrolled fires set (20 m x 20 - m) per pad limited to the minimum should avoidance - Clearing access track by personnel (x5 pads) extent possible through locating and drill sites - A camp site - Avoid clearing trees alternative drill - Demarcation of drill for the - No harvesting of plants or sites not be pad drillers hunting and trapping of possible. - Temporary camp site Operational (10m x animals must be allowed Operational for the drillers (Phase 2 - 10m) - No uncontrolled fires must (Phase 2 - - Temporary core yard Loss of animal species as Drilling) - Core yard be allowed Drilling) for cutting and a result of collisions with for cutting - Intervening by planting processing drilling N/A vehicles or hunting and and indigenous vegetation in - Percussion drilling trapping by personnel processing disturbed areas should followed by diamond drilling (30 natural revegetation prove drilling m x 30 m) unsuccessful - Percussion Ambient noise drilling - Maintaining equipment and levels unlikely to followed by machinery in good working increase above Noise from drilling diamond order the typical rating activities may result in drilling (10 - Switching off equipment level for rural holes) when not in use districts (SANS 10103:2008) Damage to buried - Implement a chance finds In the unlikely archaeological or or procedure as detailed in event that SIZE AND COMPLIANCE TIME PERIOD FOR ACTIVITIES POTENTIAL IMPACT PHASE SCALE OF MITIGATION MEASURES WITH IMPLEMENTATION DISTURBANCE STANDARDS paleontological resources Table 3 artefacts are of significance unearthed they must be dealt with according to the provisions of the NHRA Dust generated likely to fall - Areas to be cleared will be below the limited to the minimum threshold as per Dust generated may extent possible the NEMAQA result nuisance impacts - Wet suppression must be National Dust implemented where dust Control plumes are noted Regulation Standards for residential areas - Implementing spill prevention measures such No activities as handling and storing must take place Heavy vehicles and hydrocarbons on within a machinery on site may impermeable surfaces regulated area of result in potential - Adequately maintaining a watercourse hydrocarbon leaks which vehicles and machinery to without may in turn pollute soil prevent leaks authorisation as - Cleaning any spills per NWA immediately Heavy vehicles and - Minimising areas to be machinery on site may disturbed by vehicle and result in soil compaction machinery, N/A subsequently impacting - Ripping and profiling vegetation re- compacted soil establishment - Cleaning any spills Waste spills may result in immediately Stores and ablutions N/A pollution of soil - Implementing adequate waste management
SIZE AND COMPLIANCE TIME PERIOD FOR ACTIVITIES POTENTIAL IMPACT PHASE SCALE OF MITIGATION MEASURES WITH IMPLEMENTATION DISTURBANCE STANDARDS practices
5 e) Impact management outcomes (a description of impact management outcomes, identifying the standard of impact management required for the aspects contemplated in paragraph)
PHASE IN ASPECTS WHICH IMPACT STANDARDS TO BE ACTIVITIES POTENTIAL IMPACT MITIGATION MEASURES AFFECTED IS ACHIEVED ANTICIPATED Loss of vegetation (possible - Where possible available access plant species of conservation tracks will be used concern) from clearing or - Avoid all plant species of harvesting by personnel or conservation concern (in the uncontrolled fires set by unlikely event that they are personnel present) by changing the Prevent loss of plant location of sites accordingly prior species of to clearing conservation - Areas to be cleared will be concern and limited to the minimum extent minimise - Clearing access track and Biodiversity possible disturbance to drill sites - Avoid clearing trees Loss of animal species as a habitat and fauna as - Demarcation of drill pad - No harvesting of plants or result of collisions with per the management - Temporary camp site for hunting and trapping of animals vehicles or hunting and Operational plan in Section 4(f) the drillers must be allowed trapping by personnel (Phase 2 - below - Temporary core yard for - No uncontrolled fires must be Drilling) cutting and processing allowed drilling - Intervening by planting - Percussion drilling followed indigenous vegetation in by diamond drilling disturbed areas should natural revegetation prove unsuccessful Avoid disturbance of surrounding residents by - Maintaining equipment and implementing Noise from drilling activities Noise; machinery in good working order measures as per the may result in nuisance Social - Switching off equipment when management plan in not in use Section 4(f) below; noise likely to be in line with standards
PHASE IN ASPECTS WHICH IMPACT STANDARDS TO BE ACTIVITIES POTENTIAL IMPACT MITIGATION MEASURES AFFECTED IS ACHIEVED ANTICIPATED (SANS 10103:2008) Prevent damage to archaeological resources by implementing measures as per the Damage to buried management plan in archaeological or or Heritage; - Implement a chance finds Section 4(f) below; paleontological resources of Social procedure as detailed in Table 3 in the unlikely event significance that artefacts are unearthed they must be dealt with according to the provisions of the NHRA Prevent excessive dust by implementing measures as per the - Areas to be cleared will be management plan in limited to the minimum extent Section 4(f) below; Dust generated may result in Air quality; possible dust generated likely nuisance impacts Social - Wet suppression must be to fall below the implemented where dust plumes threshold as per the are noted NEMAQA National Dust Control Regulation Standards for residential areas - Implementing spill prevention Prevent Soil; Heavy vehicles and machinery measures such as handling and contamination of Biodiversity; on site may result in potential storing hydrocarbons on soil by Surface water; hydrocarbon leaks which may impermeable surfaces implementing Wetlands; in turn pollute the soil - Adequately maintaining vehicles measures as per the Groundwater and machinery to prevent leaks management plan in
7 PHASE IN ASPECTS WHICH IMPACT STANDARDS TO BE ACTIVITIES POTENTIAL IMPACT MITIGATION MEASURES AFFECTED IS ACHIEVED ANTICIPATED - Cleaning any spills immediately Section 4(f) below Prevent or repair compaction of soil by implementing Heavy vehicles and machinery measures as per the - Minimising areas to be disturbed on site may result in soil management plan in by vehicle and machinery, compaction subsequently Soil Section 4(f) below to - Ripping and profiling compacted impacting vegetation re- ensure that there soil establishment are no negative impacts of vegetation re- establishment Prevent contamination of - Cleaning any spills immediately soil by Waste spills may result in Stores and ablutions Soil - Implementing adequate waste implementing pollution of soil management practices measures as per the management plan in Section 4(f) below
f) Impact management actions (a description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (c) and (d) will be achieved)
TIME PERIOD FOR MITIGATION COMPLIANCE WITH ACTIVITY POTENTIAL IMPACT IMPLEMENTATION TYPE STANDARDS
Loss of vegetation (possible - Where possible available access plant species of conservation tracks will be used concern) from clearing or - Avoid all plant species of harvesting by personnel or conservation concern (in the unlikely uncontrolled fires set by event that they are present) by personnel changing the location of sites Prevent loss of plant accordingly prior to clearing species of - Areas to be cleared will be limited to conservation concern the minimum extent possible and minimise - Avoid clearing trees disturbance to habitat - No harvesting of plants or hunting Loss of animal species as a result and fauna as per the and trapping of animals must be - Clearing access track and drill of collisions with vehicles or management plan in allowed sites hunting and trapping by Table 3 below - No uncontrolled fires must be - Demarcation of drill pad personnel allowed - Temporary camp site for the - Intervening by planting indigenous Operational (Phase 2 - drillers vegetation in disturbed areas should Drilling) - Temporary core yard for natural revegetation prove cutting and processing drilling unsuccessful - Percussion drilling followed by Avoid disturbance of diamond drilling surrounding residents by implementing - Maintaining equipment and measures as per the Noise from drilling activities may machinery in good working order management plan in result in nuisance to landowners - Switching off equipment when not in Table 3 below; noise use standards (SANS 10103:2008) must be met Prevent damage to Damage to buried archaeological - Implement a chance finds procedure archaeological or or paleontological resources of as detailed in Table 3 resources by significance implementing
9 TIME PERIOD FOR MITIGATION COMPLIANCE WITH ACTIVITY POTENTIAL IMPACT IMPLEMENTATION TYPE STANDARDS
measures as per the management plan in Table 3 below; in the unlikely event that artefacts are unearthed they must be dealt with according to the provisions of the NHRA Prevent excessive dust by implementing measures as per the - Areas to be cleared will be limited to management plan in the minimum extent possible Table 3 below; dust Dust generated may result in - Wet suppression must be generated likely to fall nuisance impacts implemented where dust plumes are below the threshold as noted per the NEMAQA National Dust Control Regulation Standards for residential areas - Implementing spill prevention measures such as handling and Prevent contamination Heavy vehicles and machinery storing hydrocarbons on soil by implementing on site may result in potential impermeable surfaces measures as per the hydrocarbon leaks which may in - Adequately maintaining vehicles and management plan in turn pollute soil machinery to prevent leaks Table 3 below - Cleaning any spills immediately Prevent or repair compaction of soil by implementing Heavy vehicles and machinery measures as per the on site may result in soil - Minimising areas to be disturbed by management plan in compaction subsequently vehicle and machinery, Table 3 below to impacting vegetation re- - Ripping and profiling compacted soil ensure that there are establishment no negative impacts of vegetation re- establishment
TIME PERIOD FOR MITIGATION COMPLIANCE WITH ACTIVITY POTENTIAL IMPACT IMPLEMENTATION TYPE STANDARDS
Prevent contamination of soil by - Cleaning any spills immediately Waste spills may result in implementing Stores and ablutions - Implementing adequate waste pollution of soil measures as per the management practices management plan in Table 3 below
The table below details the management plan to be implemented to manage the potential impacts of the proposed prospecting activities. An Environmental Control Officer (ECO) must be appointed to ensure that the various management measures detailed herein are implemented and that the necessary auditing and reporting is conducted.
Table 3: Management plan
RESPONSIBLE MANAGEMENT AREA ASPECT MANAGEMENT MEASURE PARTY Environmental awareness training must be implemented as per the environmental Soil; awareness plan (as per Section 7 of the EMP Part B of this document) educating Biodiversity; personnel and contractors on how to interact with the environment and landowners. Surface water; As part of environmental awareness training, personnel and contractors must be Awareness Wetlands; ECO Groundwater; educated regarding the possible presence of subterranean archaeological and/or Heritage; paleontological sites, features or artefacts and be advised of the penalties associated Social with the unlawful removal of these artefacts, as set out in the NHRA as well as of this chance finds procedure. If any buried archaeological or palaeontological findings are discovered during clearing activities, the excavation must stop and the ECO must be notified immediately. The ECO ECO / SAHRA must then contact SAHRA to investigate the findings. The ECO must contact an archaeologist and/or palaeontologist, depending on the nature Chance finds procedure Heritage of the find, to assess the importance and rescue them if necessary (with the relevant ECO/ SAHRA permit). No work may be resumed in this area without the permission from the Archaeologist / ECO and SAHRA. Under no circumstances shall any artefacts be removed, destroyed or Palaeontologist interfered with.
11 RESPONSIBLE MANAGEMENT AREA ASPECT MANAGEMENT MEASURE PARTY Any mitigation or management measures recommended by the specialist, after assessment of the find, must be implemented. Air quality; Vegetation clearing must be limited to the smallest extent possible. Vegetation clearing Biodiversity; Where possible available access tracks must be used. Soil Dust Air quality Wet suppression must be implemented where dust plumes are noted. All topsoil removed during ground clearance must be separately stored at least 500 m from any watercourse. Topsoil clearing Soil When excavating separate pits for waste water, grease and oil polluted water, the topsoil and subsoil must be stored separately. The ECO needs to be educated with the prevalent species in the area (as per Section Floral species of 5a)viii) of the BAR - part A of this document) and should survey any sites before conservation concern clearance for the presence of any such species and make the necessary changes to the plan. Trapping of fauna No trapping or hunting of any faunal species must be allowed. Biodiversity Fires Uncontrolled fires must not be allowed. Natural revegetation will likely occur. Where drill sites have been denuded, the surface shall be ripped or ploughed. Access tracks shall be ripped or ploughed. Disturbed areas Rehabilitation must be inspected after a growing season has passed and should natural revegetation ECO prove unsuccessful areas must be revegetated using indigenous vegetation species. Handle and store hydrocarbons on impermeable surfaces. Hydrocarbons must be stored in a bunded area with a capacity to contain 110 % of the total volume stored. Implement systematic maintenance of all forms of equipment and vehicles to prevent Hydrocarbon leaks. management Refuel machinery and vehicles over drip trays. Conduct any machinery and vehicle maintenance on impermeable surfaces. Pits for waste water, grease and oil polluted water must be lined to prevent pollution. Soil The contents of the pit must be disposed of at a licensed disposal facility. Ensure that an adequate number of waste bins are available on site. Waste must be stored in a manner that it cannot be washed or blown into the environment. The active drill site must be cleaned daily and litter removed and deposited in the bins Waste management provided. No waste is permitted to be buried or burned on site. Waste must be collected and disposed of at a licensed disposal facility. Portable toilets are to be provided and maintained in a manner which prevents spills.
RESPONSIBLE MANAGEMENT AREA ASPECT MANAGEMENT MEASURE PARTY Under no circumstances may ablutions occur outside of the provided facilities. Clean any spills immediately according to the MSDS using spill kits which must be kept Spills on site. Soil; Minimise areas to be disturbed by vehicles and machinery. Compaction Biodiversity Rip and profile any areas of compacted soil. Surface water; The 500 m wetland buffer must be a no-go area in terms of prospecting activities No-go areas Wetlands personnel and contractors. Any drainage lines must also be avoided. Biodiversity The CBA and ESA areas must be avoided where possible. Air quality Low vehicle speeds must be enforced on unpaved surfaces to minimise dust.
Limit idling and switch off equipment when not in use. Vehicles and machinery Noise; Social Implement systematic maintenance of all forms of equipment and vehicles to minimise noise. Introduce a mechanism whereby complaints from landowners can be received and Complaints responded to. Social Agreements Adhere to agreements made with landowners. Health and safety Ensure that operations are in line with the requirements of the MHSA and Regulations.
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5. Financial Provision
a) Determination of the amount of Financial Provision
Section 24(P)(1) of NEMA states that an Applicant for an environmental authorisation relating to mining or related activities on a mining area must make the prescribed financial provision for the rehabilitation, management and closure of environmental impacts, before the Minister responsible for mineral resources issues the environmental authorisation.
In order to ensure that the Applicant provides sufficient funds for the total quantum to cover the rehabilitation, management and remediation of negative residual environmental impacts, the quantum for closure-related financial provision in terms of Regulation 4 of the NEMA Regulations on Financial Provision (GNR1147 of 2014) has been determined.
i) Describe the closure objectives and the extent to which they have been aligned to the baseline environment described under the Regulation
CLOSURE OBJECTIVES EXTENT TO WHICH ALIGNED TO BASELINE ENVIRONMENT The topography of rehabilitated drill sites will be shaped to ensure that the area is fee draining to represent the baseline Developing a landform that is state. free draining, with established, Natural revegetation will likely occur. self-sustaining vegetation Disturbed areas must be inspected after a growing season has passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species. Alien vegetation must be removed. Rehabilitate and return the drill Natural revegetation will likely occur. hole areas to a capability that is Disturbed areas must be inspected after a growing season has in line with the surrounding passed and should natural revegetation prove unsuccessful areas landscape. must be revegetated using indigenous vegetation species.
Rehabilitated areas do not pose a Backfilling of any excavations safety hazard to humans and No temporary infrastructure is to be left on-site. animals. All waste will be removed.
The Closure Plan has been prepared which further details the closure objectives, strategy, measures and relinquishment criteria; refer to Appendix 4.
ii) Confirm specifically that the environmental objectives in relation to closure have been consulted with landowner and interested and affected parties
The main objective will be to rehabilitate- and return the borehole drill areas, access tracks and any areas affected as a result of invasive prospecting activities (including temporary infrastructure) to resemble the surrounding landscape (natural/ open) with no remaining infrastructure or potential hazards to people or the environment.
Further environmental objectives include: . Ensure that no temporary infrastructure is left on-site and ensure environmental and safety risks are minimised; . Rehabilitate areas disturbed by prospecting activities; . Rehabilitated areas must not pose a safety hazard to humans and animals; . Establish a self-sustaining and stable vegetation cover over the area disturbed by the prospecting activities; . Minimise the establishment of alien vegetation; . Ensure the rehabilitated landform is free draining; . Protect drainage lines and watercourses; and . Ensure adherence to local, provincial and national regulatory requirements.
The above environmental objectives with regards to closure and rehabilitation have been incorporated into the BAR / EMP. The BAR/ EMP and the Closure Plan are available for comment during the period (23 February 2018 to 26 March 2018).
No issues and concerns have been raised to date. Any issues and concerns raised during the public participation process will be responded to and proposed alternatives and mitigation measures assessed where applicable and presented in the final BAR / EMP to be issued to the DMR.
iii) Provide a rehabilitation plan that describes and shows the scale and aerial extent of the main mining activities, including the anticipated mining area at the time of closure
The Closure Plan (Appendix 4) includes a rehabilitation plan.
iv) Explain why it can be confirmed that the rehabilitation plan is compatible with the closure objectives
The rehabilitation measures in the Closure Plan (Appendix 4) were compiled to meet the specific closure objectives as described in Section 5(a)(ii) above.
v) Calculate and state the quantum of the financial provision required to manage and rehabilitate the environment in accordance with the applicable guideline
The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using contractor rates to provide actual costs (contractor rates) for decommissioning and rehabilitation. The rates utilised are based on contractor rates which have been escalated by CPI of 5.26% for 2017. Refer to Section 5(a)(v) in the EMP - Part B of this document for further information.
From the methodology for calculation of Financial Provision for a new development in the draft financial provisioning regulations (GNR1228 of 2017), the costing for final rehabilitation, decommissioning and mine closure, must reflect the total cost to remediate disturbances that will occur in Year O and must reflect actual market related costs based on prevailing rates exclusive of VAT. The costing for residual
environmental impacts which will occur in the future must reflect the Net Present Value (NPV) based on prevailing rates of future residual environmental impacts due to disturbance of Year O. This is the Year O cost for residual environmental impacts. Total 1 for final rehabilitation, decommissioning and mine closure and Total 2 for residual environmental impacts which may occur in the future are then added to obtain the Total Financial Provision.
Identification of areas of disturbance - areas, volumes and lengths of possible disturbances and developments and each applicable closure component were identified and calculated using the proposed invasive prospecting plan. The closure plan currently includes the cost for the rehabilitation of the following: 5 drill pads (20m x 20m each, 2000 m2 in total) Storage area (2000 m2) Campsite (500 m2 ) Core shed (900 m2) Access tracks (3000 m2)
The total financial provision for the invasive prospecting activities proposed for the PAMDC Project, is therefore R 135,048 (value as per date of assessment - 2018). This amount comprises the financial provision for decommissioning and rehabilitation as well as the remediation of latent or residual environmental impacts. Refer to the Closure Plan (Appendix 4) for further detail.
vi) Confirm that the financial provision will be provided as determined
Financial provision will be provided for as determined through a financial vehicle as prescribed in the NEMA Financial Provision Regulations (GNR1147 of 2015) namely a financial guarantee alone or a financial guarantee for the financial provision for decommissioning and rehabilitation and a contribution to a trust fund to secure funds for remediation of latent or residual environmental impacts.
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6. Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including: a) Monitoring of impact management actions b) Monitoring and reporting frequency c) Responsible persons d) Time period for implementing impact management actions e) Mechanism for monitoring compliance
MONITORING AND REPORTING IMPACTS REQUIRING FUNCTIONAL REQUIREMENTS FOR ROLES AND RESPONSIBILITIES FREQUENCY AND TIME PERIODS SOURCE ACTIVITY MONITORING MONITORING FOR IMPLEMENTING IMPACT PROGRAMMES MANAGEMENT ACTIONS As no significant environmental or social impacts are expected to be Performance assessments of exerted as a result of the EMP in terms of the MPRDA To ensure compliance with the EMP Invasive prospecting the prospecting to be undertaken every two and to determine the continued activities - Phase 2 activities monitoring ECO years and environmental audits appropriateness and adequacy of drilling programmes have not of the EMP in terms of NEMA as the EMP been recommended. per the frequency stated in the Therefore, only Environmental Authorisation compliance with the EMP requires monitoring
a) Indicate the frequency of the submission of the performance assessment/ environmental audit report
MPRDA Regulation 55(1) (of the MPRDA Regulations GNR527 of 2004) stipulates the requirements for performance assessments of the EMP (in sub-regulation [3]) to be undertaken every two years, to ensure compliance with the EMP and to determine the continued appropriateness and adequacy of the EMP.
NEMA also makes provision for environmental audits of the EMP, as per Regulation 34 of the NEMA EIA Regulations (GNR982 of 2014), which must be conducted to determine whether the programme sufficiently provides for the avoidance, management and mitigation of environmental impacts. Regulation 35 of the NEMA EIA Regulations requires an Environmental Audit Report to be submitted to the Competent Authority at the frequency specified within the Environmental Authorisation. The Environmental Authorisation will also specify the frequency of updating the EMP and Closure Plan.
It is anticipated that the performance assessment report (as required by the MPRDA) and the Environmental Audit Report (as required by NEMA) will be submitted as a single report, at least once every two years. This report will meet the requirements of both sets of legislation.
7. Environmental Awareness Plan a) Manner in which the applicant intends to inform his or her employees of any environmental risk which may result from their work
All personnel (including permanent employees as well as contractors) will undergo environmental awareness training as per this Environmental Awareness Plan. Environmental awareness training will be conducted as part of induction prior to the commencement of work, and relevant aspects of the EMP should be extracted for use by contractors. The Environmental Awareness Plan also provides for periodic awareness training throughout operations. Adherence to the Environmental Awareness Plan as well as provision of periodic environmental awareness training will be monitored and enforced by the ECO throughout operations. The contents of the Environmental Awareness Plan are detailed below:
Objectives
All personnel must be made aware of the environmental management requirements; All personnel, as a minimum, will undergo general environmental awareness training, which will highlight the environmental responsibility of all personnel; and Those personnel whose functions may have a significant impact on the environment will receive the appropriate specialised training, so that they may perform their designated tasks adequately.
Training Requirements
The agenda for the environmental awareness course must consist of the following:
A definition of what the environment is; Environmental rights; Constitutional rights; NEMA, and the rights of a whistle blower; Why we must look after the environment; How we should look after the environment; Details of working areas; The possible presence of subterranean archaeological and/or paleontological sites, features or artefacts, the penalties associated with the unlawful removal of these artefacts, as set out in the NHRA as well as of the chance finds procedure as detailed in Table 3; Avoidance of streams, rivers and wetlands; Management of biodiversity including: o The importance of biodiversity; o The different habitats in the area; o Threatened, protected or otherwise sensitive species of plants and animals that must be avoided (namely the Camel Thorn, Shepherds Tree, Ground Pangolin, African Wild Cat, Tawny Eagle, Secretary Bird, Rock Monitor, Giant Bullfrog, Horned Baboon Spider and the Starburst Baboon Spider); o The habitats that the teams must avoid; o Reasoning why species should not be harvested or used as firewood; o Speeding and the impacts on biodiversity; o Alien invasive species; o Incentives for reporting any instances of speeding, harvesting, hunting and trapping etc; o Avoidance (and not destruction) of feared species such as snakes; and o Contacts for snake removals; Details regarding smoking and fires; Management of petrol, oil and diesel; Dust management; Ablution facilities; Waste management; Traffic and road safety; Emergency procedures and numbers; and Appropriate manner of interacting with neighbouring landowners and communities.
Frequency of Training
All new employees, as well as contractors, will be expected to undergo environmental awareness training as part of their induction. This induction will occur within the first two weeks of employment.
This programme will include any required competencies associated with that employee’s environmental management role, and the means and timeframe by which this competency is meant to be achieved.
Adherence to this programme will be monitored. The employee will be required to successfully complete the programme. b) Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment
The EMP details commitments in order to avoid pollution or the degradation of the environment. Compliance with the EMP commitments will form part of the contractors’ contract. Employees will also be briefed regarding the EMP commitments prior to the commencement of operations. The ECO will monitor that the commitments are being adhered to by the contractors and employees.
8. Specific information required by the Competent Authority (among others, confirm that the financial provision will be reviewed annually)
The Applicant commits to reviewing the Financial Provision on an annual basis as per the requirements of Section 24(P)(3) of NEMA, which states that every holder must annually assess his or her environmental liability and, if circumstances so require, must adjust his or her financial provision to the satisfaction of the Minister responsible for mineral resources.
In addition the Applicant commits to conduct EMP performance assessments as required in terms of Regulation 55 of the MPRDA on a biennial basis and external environmental audits of the EMP and Environmental Authorisation as per the NEMA EIA Regulations, 2014 according to the frequency indicated in the Environmental Authorisation.
The Competent Authority has not requested any specific information to date.
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