ASH DISPOSAL FACILITY SCOPING REPORT

ASH DISPOSAL FACILITY SCOPING REPORT

ESKOM ARNOT POWER STATION

This document contains information proprietary to Environmental Impact Management Services (Pty) Ltd. and

as such should be treated as confidential unless specifically identified as a public document by law. The

document may not be copied, reproduced, or used for any manner without prior written consent from EIMS.

Copyright is specifically reserved.

DOCUMENT DETAILS

EIMS REFERENCE: 1140

DOCUMENT TITLE: ARNOT ASH DISPOSAL FACILITY SCOPING REPORT

DOCUMENT CONTROL

NAME SIGNATURE DATE

COMPILED:

John von Mayer 2018/07/06

CHECKED:

Brian Whitfield 2018/07/06

AUTHORIZED:

Liam Whitlow 2018/07/06

REVISION AND AMENDMENTS

REVISION DATE: REV # DESCRIPTION

2018/07/06 ORIGINAL DOCUMENT Ash Disposal Facility Scoping Report

1140 Arnot Ash Disposal Facility Project 1

Table of Contents 1 Introduction .................................................................................................................................... 8

1.1 Project Review ........................................................................................................................ 9

1.1.1 Proposed Infrastructure .................................................................................................. 9

1.1.2 Proposed Site .................................................................................................................. 9

1.1.3 Requirement for an EIA ................................................................................................... 9

1.2 Purpose of Scoping Report.................................................................................................... 13

1.3 Details of EAP ........................................................................................................................ 13

1.3.1 Expertise of The EAP ..................................................................................................... 13

1.3.2 Summary of EAP Curriculum Vitae ................................................................................ 13

1.4 Specialist Consultants ........................................................................................................... 14

1.5 Details of the Applicant ......................................................................................................... 15

2 Project Description ........................................................................................................................ 16

2.1 Location ................................................................................................................................. 16

2.1.1 Regional Setting ............................................................................................................ 16

2.1.2 Property Description ..................................................................................................... 16

2.1.3 Locality Map .................................................................................................................. 17

2.2 Description of Activity ........................................................................................................... 17

2.2.1 Need and Desirability of the Project ............................................................................. 17

2.2.2 Period for Which Authorization Is Required ................................................................. 25

2.2.3 Description of Proposed Project ................................................................................... 25

2.3 Alternatives ........................................................................................................................... 28

2.3.1 No Go Alternative ......................................................................................................... 28

2.3.2 Location Alternatives .................................................................................................... 29

2.3.3 Technology Alternatives ............................................................................................... 33

2.3.4 Actvity Alternatives ....................................................................................................... 33

3 Policy and Legislative Requirements ............................................................................................. 34

3.1 Applicable Environmental Legislation ................................................................................... 34

3.2 Applicable National Legislation ............................................................................................. 35

3.2.1 National Waste Act ....................................................................................................... 35

3.2.2 National Environmental Management Act ................................................................... 36

3.2.3 National Water Act ....................................................................................................... 44

3.2.4 National Environmental Management: Air Quality Act ................................................ 46

3.2.5 National Environmental Management: Biodiversity Act .............................................. 46


3.2.6 National Environmental Management: Protected Areas Act ....................................... 47

3.2.7 National Heritage Resources Act .................................................................................. 47

3.2.8 National Conservation Act ............................................................................................ 47

3.2.9 Constitution of South Africa .......................................................................................... 48

3.2.10 Minerals And Petroleum Resources Development Act (Act No. 28 Of 2002) ............... 48

3.3 Other Applicable Acts, Policies and Programmes ................................................................. 48

3.4 Proposed Legislation ............................................................................................................. 49

4 Public Participation Process (PPP) ................................................................................................ 50

4.1 Authority Consultation .......................................................................................................... 50

4.2 Stakeholder Engagement ...................................................................................................... 50

4.3 Methodology ......................................................................................................................... 52

4.3.1 Identification of I&APs .................................................................................................. 52

4.3.2 Affected Landowners .................................................................................................... 52

4.3.3 Authorities and Organs Of State ................................................................................... 52

4.3.4 Initial Notification of I&APs ........................................................................................... 53

4.3.5 Scoping Report Review ................................................................................................. 54

4.3.6 Public Meeting and Open Day....................................................................................... 55

5 Description of Receiving Environment .......................................................................................... 56

5.1 Climate .................................................................................................................................. 56

5.2 Geology and Topogrpahy ...................................................................................................... 56

5.2.1 Geology ......................................................................................................................... 56

5.2.2 Topography ................................................................................................................... 59

5.3 Land Use and Land Cover ...................................................................................................... 59

5.4 Ecology .................................................................................................................................. 61

5.4.1 Flora .............................................................................................................................. 61

5.4.2 Terrestrial Fauna ........................................................................................................... 62

5.4.3 Birds .............................................................................................................................. 64

5.4.4 Aspect Management Plans For The Area ...................................................................... 64

5.4.5 Key Sensitivities ............................................................................................................. 68

5.5 Heritage and Paleontology.................................................................................................... 71


5.6 Soils ....................................................................................................................................... 73


5.7 Rivers and wetlands .............................................................................................................. 74


5.7.1 Rivers ............................................................................................................................. 74

5.7.2 Wetlands ....................................................................................................................... 76


5.8 Groundwater ......................................................................................................................... 79


5.9 Air Quality ............................................................................................................................. 82


6 Environmental Impact Assessment ............................................................................................... 86

6.1 Approach and Methodology ................................................................................................. 86

6.1.1 Method of Assessing Impacts ....................................................................................... 86

6.1.2 Determination of Environmental Risk ........................................................................... 86

6.1.3 Impact Prioritisation ..................................................................................................... 89

6.2 Identification of Impacts ....................................................................................................... 91

6.3 Description and assessment of impacts................................................................................ 92

6.3.1 Preliminary Impacts on Ecology .................................................................................... 92

6.3.2 Preliminary Impacts on Geohydrology.......................................................................... 97

6.3.3 Preliminary Impacts on Hydrology ................................................................................ 98

6.3.4 Preliminary Impacts on Wetland Aquatic Ecology ...................................................... 101

6.3.5 Preliminary Impacts on Soils and Agricultural Potential ............................................. 105

6.3.6 Preliminary Impacts on Air Quality ............................................................................. 106

6.3.7 Preliminary Impacts on Archaeology and Palaentology ............................................. 108

6.3.8 Preliminary Visual Impacts .......................................................................................... 109

6.4 Consolidated Sensitivity Map .............................................................................................. 111

6.5 Assumptions, Limitations and Gaps in Knowledge ............................................................. cxiii

7 Project Alternatives ..................................................................................................................... 115

7.1 Alternative Assessment ...................................................................................................... 115

8 Plan of study for EIA .................................................................................................................... 121

8.1 Alternatives to be Considered in EIA .................................................................................. 121

8.1.1 No Go Alternative ....................................................................................................... 121

8.1.2 Siting Alternative ......................................................................................................... 121

8.2 Description of Impacts to be Assessed in EIA ..................................................................... 121

8.3 Description of Specialist Studies ......................................................................................... 121

8.3.1 Ecology ........................................................................................................................ 121

8.3.2 Hydrology .................................................................................................................... 123


8.3.3 Aquatic Ecology (Wetlands) ........................................................................................ 123

8.3.4 Geohydrology .............................................................................................................. 123

8.3.5 Heritage And Fossils .................................................................................................... 124

8.3.6 Visual ........................................................................................................................... 124

8.3.7 Air Quality ................................................................................................................... 124

8.3.8 Noise ........................................................................................................................... 125

8.3.9 Traffic .......................................................................................................................... 125

8.4 Environmental Impact Assessment process ....................................................................... 125

8.4.1 Method Of Assessing Impact Significance .................................................................. 125

8.4.2 Evaluation Of Impacts and Mitigation Measures ........................................................ 130

8.4.3 Public Consultation Process in Environmental Assessment ....................................... 130

8.4.4 Consultation Process With Competent Authority ...................................................... 131

8.4.5 Description of EIA Tasks .............................................................................................. 131

9 Undertaking of the Environmental Assessment Practitioner ..................................................... 133

9.1 Undertakings regarding corrections of information ........................................................... 133

9.2 Undertaking regarding level of agreement ......................................................................... 133

10 References .................................................................................................................................. 134

List of Figures

Figure 1: Locality Map indicating two alternative sites nominated for consideration in scoping ........................ 26

Figure 2: Flow diagram of the screening process. ................................................................................................ 29

Figure 3: Illustration of GIS Mapping Methodology ............................................................................................. 30

Figure 4: Final screened 80ha alternatives ........................................................................................................... 31

Figure 5: Final screened 80ha alternatives ........................................................................................................... 32

Figure 6: Geological Map ...................................................................................................................................... 57

Figure 7: Topographical Map ................................................................................................................................ 58

Figure 8: Land cover of the study area (areas within 5km of Arnot Power Station) ............................................ 60

Figure 9: Parts of the study are in different categories of the MBCP. .................................................................. 66

Figure 10: Parts of the study area in different categories of the MBSP. .............................................................. 67

Figure 11: Location of sensitive habitats within the study area. .......................................................................... 70

Figure 12: Potential heritage resources in the study area.................................................................................... 73

Figure 13: Map indicating the study area in relation to the River NFEPAs ........................................................... 75

Figure 14: Desktop wetland extent within the primary study area (120 Ha) ....................................................... 76


Figure 15: Desktop wetland extent within the secondary study area (1km radius) ............................................. 76

Figure 16: Map indicating the study area in relation to the NFEPA wetland types .............................................. 77

Figure 17: Sensitivity map of the watercourses associated with the study area ................................................. 78

Figure 18: Hydrocensus borehole map ................................................................................................................. 81

Figure 19: Diurnal wind roses ............................................................................................................................... 83

Figure 20: Seasonal wind roses ............................................................................................................................ 83

Figure 21: Location of sensitive receptors and potential 120ha ash disposal facility sites (1 km buffer) assessed

for the scoping phase. .................................................................................................................................. 85

Figure 22: Combined sensitivity map ................................................................................................................. 112

Figure 23: Map showing position of raw water pipeline and new position for Site Alternative 2 within 1km buffer

zone............................................................................................................................................................ 119

Figure 24: Map showing proposed site (and assoicated 1km buffer zone) to be considered for detailed

assessment in the EIA phase. ..................................................................................................................... 120

List of Tables

Table 1: Content of this Scoping Report in terms of NEMA and Appendix 2 of the EIA Regulations of December

2014 ............................................................................................................................................................. 10

Table 2: List of specialists appointed to the project ............................................................................................. 14

Table 3: Applicant details ..................................................................................................................................... 15

Table 4: List of affected properties for each alternative ...................................................................................... 16

Table 5: Needs and desirability analysis for the Arnot ADF .................................................................................. 17

Table 6: Applicable legislation .............................................................................................................................. 34

Table 7: NEMWA Listed Activities......................................................................................................................... 36

Table 8: NEMA Listed Activities ............................................................................................................................ 37

Table 9: Identified water uses. ............................................................................................................................. 45

Table 10: Summary of policies and programmes ................................................................................................. 48

Table 11: Conservation status of different vegetation types occurring in the study area. .................................. 62

Table 12: Mammal species of conservation concern with a likelihood of occurring in the study area................ 63

Table 13: Amphibian species of conservation concern with a likelihood of occurring in the study area............. 63

Table 14: Reptile species of conservation concern with a likelihood of occurring in the study area. .................. 63

Table 15: Mean monthly and annual precipitation, evaporation and runoff for quaternary catchment B12B ... 74

Table 16: Criteria for determining impact consequence ...................................................................................... 86

Table 17: Probability scoring ................................................................................................................................ 87

Table 18: Determination of Environmental Risk ................................................................................................... 88

Table 19: Significance classes ............................................................................................................................... 88

Table 20: Criteria for determining prioritisation .................................................................................................. 89

Table 21: Determination of prioritisation factor .................................................................................................. 90


Table 22: Final Environmental significance rating ................................................................................................ 90

Table 23: Site Alternative Assessment................................................................................................................ 115

Table 24: Criteria for determining impact consequence .................................................................................... 125

Table 25: Probability scoring .............................................................................................................................. 127

Table 26: Determination of Environmental Risk ................................................................................................. 127

Table 27: Significance classes ............................................................................................................................. 128

Table 28: Criteria for determining prioritisation ................................................................................................ 128

Table 29: Determination of prioritisation factor ................................................................................................ 129

Table 30: Final Environmental significance rating .............................................................................................. 129

Appendices

Appendix A: EAP CV

Appendix B: PUBLIC PARTICIPATION INFORMATION

Appendix C: RECORDS OF AUTHORITY CONSULTATION

Appendix D: GROUNDWATER ASSESSMENT

Appendix E: SURFACE WATER ASSESSMENT

Appendix F: WETLAND ASSESSMENT

Appendix G: VISUAL ASSESSMENT

Appendix H: ECOLOGY ASSESSMENT

Appendix I: HERITAGE ASSESSMENT

Appendix J: SOIL ASSESSMENT

Appendix K: AIR QUALITY ASSESSMENT

Appendix L: SITE SELECTION STUDY


Abbreviations ADF : Ash Disposal Facility

CMA : Catchment Management Agency

DEA : Department of Environmental Affairs

DMR : Department of Mineral Resources

DWA : Department: Water Affairs

DWS : Department of Water Affairs and Sanitation

EIA : Environmental Impact Assessment

EIMS : Environmental Impact Management Services

ELWU : Existing Lawful Water Use

EMPR : Environmental Management Programme Report

ESA : Early Stone Age

GA : General Authorisation

GHG : Greenhouse Gas

GN : Government Notice

HIA : Heritage Impact Assessment

I&AP : Interested & Affected Party

IBA : Important Bird Area

MAE : Mean Annual Evaporation

mamsl : metres above mean sea level

MAP : Mean Annual Precipitation

MAR : Mean Annual Runoff

MCM : Million cubic metres

MPRDA : Minerals and Petroleum Resources Development Act, 2002

NEM:WA : National Environmental Management: Waste Amendment Act, 2008

NEMA : National Environmental Management Act, 2002

NEMA : National Environmental Management Act

NGDB : National Groundwater Database

NHRA : National Heritage Resources Act

NWA : National Water Act, 1998

RoM : Run of Mine

SAHRA : South African Heritage Resources Agency

WUL : Water Use Licence


1 INTRODUCTION

Arnot Power Station is a coal fired power station owned by Eskom Holdings SOC and makes use of wet process

ashing to dispose of its ash waste. Arnot Power Station’s first ash facility was commissioned in 1971. All ash

produced by Arnot Power Station is pumped, in the form of a slurry, to 3 existing ash disposal facilities.

Arnot’s ash dams are situated approximately 1.5 km to the South-East of the Power Station in the Rietkuilspruit

valley. The whole ash dam complex, including penstock 5 (the silt trap) and the low-level ash water return dams,

covers approximately 200 hectares.

Two streams were diverted to enable Arnot to ash at the current location. It was necessary to construct the

stream diversion in order to keep the toe of the ash dam above the natural ground water table, thus keeping

the toe as dry as possible and to construct the ash dam on good stable founding material. The three current ash

dams have a remaining storage of ± 33 million m3 as of 23 September 2012.

Arnot Power Station uses a wet system for the ashing of the boiler plant. The ashing is conducted in 24-hour

cycles. During the day, the plant is dusted to remove fine ash for the building of the day walls and at night the

coarse ash is sent to the ash dam for the night paddocks. The ash is pumped to the ash dam from the station.

There are four ash pipelines leaving the station to the ash dam and the deposition of the ash depends on the

day plan of the operator. The ash is left to settle and the excess water (Ash Water Return) drained to the silt

trap dam to let the finer particle settle before it is pumped back to the station.

The current Ash Disposal Facility (ADF) at Arnot Power Station has been providing disposal services since the

establishment of the station. This ash disposal facility is facing some operational challenges, which need to be

addressed. The ash complex was designed to operate until the original end of the station life, which was 2021.

This date has been revised to 2032. An ash dam capacity study was compiled, and it revealed that the rate of

rise of the ash dam complex will be more than 4m by the year 2026. The main reason that Arnot Power Station

is in need of a new ash dam is to reduce this rate of rise to an acceptable rate, thus, it was recommended that

the new ash facility be commissioned. A wet ash disposal facility with appropriate barrier systems and a slurry

system pipework and pumping systems is required. The location of the new ash disposal facility will be based on

the least cost solution, within the constraints of the environmental law and regulations. The study area was

identified based on a 5km proximity from the edge of the Arnot power station.

Arnot Power Station requires a new ash disposal facility with the capacity to store all the ash it produces as part

of its operation until the end of station life, 2032. If the end of station life is extended, the new ash complex

must be able to be expanded to provide for this. This must be done in an environmentally friendly manner. The

proposed project is for a wet ash dam and associated infrastructure. The nature and extent of Ash Disposal

Facility, as well as potential environmental impacts associated with the construction, operation and

decommissioning of a facility of this nature are assessed in this Scoping Report. This Scoping Report consists of

the following sections:

• Chapter 1 provides background to the proposed project and associated infrastructure, and the

environmental impact assessment.

• Chapter 2 describes project details as well as the site selection process for the project.

• Chapter 3 provides the legal framework

• Chapter 4 outlines the public participation process which was followed during the Scoping Phase.

• Chapter 5 describes the existing biophysical and socio-economic environment affected by the proposed

project.

• Chapter 6 provides the description of the potential environmental issues and potential impacts

identified to be associated with the project, including potential cumulative impacts.

• Chapter 7 presents the outcomes of the alternative assessment.


• Chapter 8 presents the conclusions of the scoping evaluation and Plan of Study for the EIA

• Chapter 9 contains the EAP undertaken regarding the information provided in the report.

• Chapter 10 provides a list of all references used in this report.

1.1 PROJECT REVIEW

1.1.1 PROPOSED INFRASTRUCTURE

The aim of this proposed project is to provide Arnot Power Station with the additional capacity to dispose all of

the ash it produces as part of its operation from 2026 until the end of station life in 2032. The project will deliver

a wet ashing facility of up to 120ha in size with required liners and the required slurry system pipework and

pumping systems and supporting infrastructure.

This includes the building of:

• Access roads for operations and maintenance. Drainage channels for clean and dirty water. Ash Water

Return Dams;

• Construction of the New Ash Disposal Facility including its lining;

• Drainage channels for clean and dirty water;

• Ash Water Return Dams;

• Pipelines for transportation of wet ash and water to and from the ash disposal facility;

• Pumping capacity; and

• Sanitation services and offices.

A proposed infrastructure layout map will be included in the EIA report once the conceptual design work is

completed.

1.1.2 PROPOSED SITE

The New Ash Disposal Facility is required to be located at a suitable position which should take into consideration

the following aspects:

• The pumping constraints of the current ash plant;

• The location of the current Ash Water Return high level dams;

• Be the least cost solution within the constraints of the environmental law and regulations; and

• Be located within a 5km radius from the Arnot power station

A site selection study was completed, and the results of this assessment are included in Section 2. Several

suitable sites were identified as alternatives for assessment in the EIA. More detail on the site is included in

Section 2 of this EIA report.

1.1.3 REQUIREMENT FOR AN EIA

In terms of the Environmental Impact Assessment (EIA) Regulations (2014) and the National Environmental

Management Waste Act (Act 59 of 2008), Eskom Holdings SOC Limited requires authorisation from the National

Department of Environmental Affairs (DEA) for the undertaking of the proposed project. In order to obtain an

environmental authorisation and the relevant waste management license for this project, comprehensive,

independent environmental studies must be undertaken in accordance with the EIA Regulations. An EIA is a

legislative tool that is used to ensure that potential impacts that may occur due to the proposed development


are identified before execution, and can therefore either be avoided or mitigated (minimised). In South African

legislation the environment includes social, economic and bio-physical aspects and the EIA must assess these

equitably.

In terms of sections 24 and 24D of NEMA, as read with Government Notices R982, R983, R984 and R985, a

Scoping and EIA process is required for the proposed project. Certain listed activities require environmental

authorisation and a waste management license before they can proceed. In terms of Sections 24 and 24D of

NEMA, as read with Government Notices R983, R984 and R985, a Scoping and EIA process is required for the

proposed project. An integrated application for authorisation and waste licence will be submitted to DEA.

The NEMA is national legislation that provides for the authorisation of certain controlled activities known as

“listed activities”. In terms of Section 24(1) of NEMA, the potential impact on the environment associated with

these listed activities must be considered, investigated, assessed and reported on to the competent authority

(the decision-maker) charged by NEMA with the granting of the relevant environmental authorisation. The

National Department of Environmental Affairs (DEA) is the competent authority for this project.

The proposed ash dump facility will be a “wet ashing” facility. A Water Use Licence is therefore required to be

obtained for the project. The Water Use Licence Application (WULA) will be made in terms of Section 40 of the

National Water Act, Act 36 of 1998 (NWA). The WULA objective is to obtain the water use authorisation and

ensure that project complies with the requirements of the NWA and all other relevant water related legislation,

as well as Eskom’s Policies. The WULA process will run roughly parallel to the integrated EIA application process

and the two processes will inform one another.

Table 1: Content of this Scoping Report in terms of NEMA and Appendix 2 of the EIA Regulations of December 2014

A scoping report must contain all the information that is necessary for a proper understanding of the nature of

issues identified during scoping, ad must include -

(a) details of— (i) the EAP who prepared the report; and

(ii) the expertise of the EAP to carry out scoping procedures

Section 1.3

(b) the location of the activity, including: (i) the 21-digit Surveyor General code of each cadastral land parcel; (ii) where available, the physical address and farm name; (iii) where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties on which the activity is to be undertaken; (iv) coordinates of the activity on the property or properties; (v) a map at an appropriate scale of the property on which the activity is to be undertaken clearly indicating the location of the activity on the property or properties;

or, if it is— (aa) a linear activity, a description and coordinates of the route of the activity and a map at an appropriate scale clearly indicating the route of the activity; (bb) an ocean-based activity, the coordinates within which the activity is to be undertaken and a map at an appropriate scale clearly indicating the area within which the activity is to be undertaken; or

Section 2.1.2


(cc) on land where the property has not been defined, the coordinates within which the activity is to be undertaken and a map at an appropriate scale clearly indicating the area within which the activity is to be undertaken;

on condition that, where coordinates are provided, it is provided in degrees, minutes and seconds using the Hartebeesthoek 94; WGS84 co-ordinate system;

(c) a description of the proposed activity, including: (i) all listed and specified activities triggered and being applied for; (ii) the project type; (iii) a description of the activities to be undertaken and for a linear activity, a description of the route of the activity; and (iv) the sector classification of the activity as identified in the national electronic register;

Section 3

(d) the need and desirability for the proposed activity; Section 2.2

(e) The activity context and environmental factors, including: (i) an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to the activity and have been considered in the preparation of the scoping report; and

(ii) how the proposed activity complies with and responds to the legislation and policy context, plans, guidelines, tools frameworks and instruments;

Section 3

(f) the process followed to reach the proposed preferred site including:

(i) details of the sites considered, including maps and coordinates; (ii) details of the public participation process undertaken at each of the sites in terms of regulation 44 of these Regulations, including copies of the supporting documents and inputs; (iii) a summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated into the scoping document, or the reasons for not including them; (iv) the environmental attributes associated with the sites identified focusing on the geographical, physical, biological, social, economic and cultural aspects; (v) the impacts identified including the significance, probability and duration of the impacts; (vi) the methodology used in determining the significance of potential environmental impacts and risks; (vii) description of the advantages and disadvantages that the proposed activity and alternatives will have on the environment and on the community that may be affected; (viii) the possible mitigation measure that could be applied and level of residual risk; (ix) the outcome of the site selection matrix;

Section 2.3


(x) if no alternatives sites were investigation, the motivation for not considering; alternative sites; and (xi) a statement motivating the preferred site;

(g) a map of the site considered for the development of the

activity and the location of the property on the site;

Figure 1

(h) the period for which the environmental authorisation is

required and the date on which the activity is concluded, and the

post construction monitoring requirements finalised;

Section 8

(i) where applicable, any specific information required by the

competent authority;

N/A

(j) a plan of study for undertaking the environmental impact assessment process to be undertaken on the preferred site, including: (i) a description of the alternatives to be considered and assessed, including the option of not proceeding with the activity; (ii) a description of the aspects to be assessed as part of the environmental impact assessment process; (iii) aspects to be assessed by specialists; (iv) a description of the proposed method of assessing the environmental aspects including a description of the proposed method of assessing alternatives including alternatives to be assessed by specialists; (v) a description of the proposed method of assessing significance; (vi) an indication of the stages at which the competent authority will be consulted; (vii) particulars of the public participation process that will be conducted during the environmental impact assessment process; and

(viii) a description of the tasks that will be undertaken as part of the environmental impact assessment process;

Section 7

(k) an undertaking under oath or affirmation by the EAP in relation to the level of agreement between the EAP and interested and affected parties on the plan of study for undertaking the environmental impact assessment; and

Chapter 8

(l) any other matter required in terms of sections 24(4)(a) and (b) of the Act.

None required at this stage

The need to comply with the requirements of the EIA Regulations ensures that decision-makers are provided

the opportunity to consider the potential environmental impacts of a project early in the project development

process, and assess if environmental impacts can be avoided, minimised or mitigated to acceptable levels.

Comprehensive, independent environmental studies are required to be undertaken in accordance with the EIA

Regulations to provide the competent authority with sufficient information in order for an informed decision to

be taken regarding the project.


1.2 PURPOSE OF SCOPING REPORT

Scoping is an important part of the EIA process, as it helps to ensure that the impact assessment is appropriately

focussed. The purpose of the scoping process, through a consultative process, is to:

• Identify the policies and legislation that are relevant to the activity;

• To motivate the need and desirability of the proposed activity, including the need and desirability of

the activity in the context of the preferred location;

• To identify and confirm the preferred activity and technology alternative through an impact and risk

assessment and ranking;

• To identify and confirm the preferred site, through a detailed site selection process, which includes an

impact and risk assessment process including cumulative impacts and a ranking process of all the

identified alternatives focusing on the geographical, physical, biological, social, economic, and cultural

aspects of the environment;

• To identify the key issues to be addressed in the assessment phase;

• To engage with stakeholders at an early stage of the development so that they may contribute their

views with regards to the proposed project;

• To agree on the level of assessment to be undertaken, including the methodology to be applied, the

expertise required, as well as the extent of further consultation to be undertaken to determine the

impacts and risks the activity will impose on the preferred site through the life of the activity, including

the nature, significance, consequence, extent, duration and probability of the impacts to inform the

location of the development footprint within the preferred site;

• To identify potential impacts and suitable measures to avoid, manage, or mitigate identified impacts

and to determine the extent of the residual risks that need to be managed and monitored; and

• To describe the plan of study for the EIA.

1.3 DETAILS OF EAP

1.3.1 EXPERTISE OF THE EAP

Environmental Impact Management Services (Pty) Ltd (EIMS) has been appointed by Eskom to act as the

Independent Environmental Assessment Practitioner (EAP) and to assist in preparing and submitting the EA

application, Scoping and EIA Reports, and undertaking a Public Participation Process (PPP) in support of the

application for Environmental Authorization, WUL and WML.

1.3.2 SUMMARY OF EAP CURRICULUM VITAE

EIMS is a private and independent environmental management-consulting firm that was founded in 1993. EIMS

has in excess of 20 years’ experience in conducting EIAs, including many EIA’s for mines and mining related

projects. Please refer to the EIMS website (www.eims.co.za) for examples of EIA documentation currently

available. The EAP’s responsible for preparing this Scoping Report are Mr Bongani Khupe (Project Manager) and

Mr John von Mayer (Senior Consultant). Brief details of their expertise and experience are presented below.

John von Mayer is a registered Professional Natural Scientist who holds a Bachelor of Science Honours degree

and has over 9 years’ experience in the environmental field. His main focus is on environmental impact

assessments, environmental management programmes, environmental compliance and monitoring, the

identification of environmental management solutions and mitigation/risk minimising measures as well as

providing technical input for projects in the environmental management field. He has been involved as an EAP

in a number of large-scale infrastructure projects and EIAs throughout South Africa.


Mr. Bongani Khupe is a registered Professional Natural Scientist who holds a Bachelor of Science Honours

degree and has more than 10 years’ experience in the environmental field. His key focus is on environmental

impact assessments, environmental permitting, public participation, environmental management plans and

programmes, strategic environmental advice, rehabilitation advice and monitoring, environmental compliance

advice and monitoring as well as providing technical input for projects in the environmental management field.

He has been involved as an EAP in several infrastructure projects and other EIAs across the country. He is a

trained Environmental Auditor and his training included all aspects of Environmental Auditing as well as EMS

auditing in terms of ISO14001. Mr Khupe is therefore registered as an Associate Environmental Auditor with the

Institute of Environmental Management and Assessment (IEMA).

1.4 SPECIALIST CONSULTANTS

A number of specialist studies were undertaken to address the key issues that required further investigation.

The specialist studies involved the gathering of data relevant to identifying and assessing environmental impacts

that may occur as a result of the proposed project. These impacts were then assessed according to pre-defined

rating scales (see Section 7 for the impact rating methodology). Specialists also recommended appropriate

mitigation/management measures to minimise potential negative impacts or enhance potential benefits,

respectively. The specialists appointed for the proposed Arnot Ash Disposal Facility project are indicated in Table

2.

Table 2: List of specialists appointed to the project

Component Company Responsible

Engineering Design BEAL

Waste Classification Specialists GCS WATER AND ENVIRONMENT

Terrestrial Ecology Specialists DAVID HOARE CONSULTING

Wetland and Aquatic Ecology ECOTONE FRESHWATER CONSULTANTS

Ground and Surface Water GCS WATER AND ENVIRONMENT

Heritage PGS HERITAGE

Air Quality AIRSHED

Visual Impact NEWTOWN LANDSCAPE ARCHITECTS

Agricultural THE BIODIVERSITY COMPANY

Noise (EIA Phase Only) ENVIRO ACOUSTIC RESEARCH

Geotechnical Study (EIA Phase only) BEAL

Traffic Impact Assessment (EIA Phase only) BEAL


1.5 DETAILS OF THE APPLICANT

The details of the applicant are given in Table 3.

Table 3: Applicant details

Project Application: Eskom Holdings SOC Ltd

Registration no: 6603060573081

Responsible Person: Ms Deidre Herbst (Eskom Environmental Manager)

Physical address: Megawatt Park, Maxwell Drive, Sunninghill, Sandton, Johannesburg, 2157

Postal address: PO Box 1091, Johannesburg, 2000

Email: [email protected]


2 PROJECT DESCRIPTION

2.1 LOCATION

2.1.1 REGIONAL SETTING

The two alternative sites (Site Alternative 1 and 2), are located south of Rietkruil in the Mpumalanga province.

The general topography of the three sites slope in a northerly direction towards the Perennial Rietkuilspruit

River. The Perennial Rietkuilspruit River flows in a westerly direction and flows within the 1km buffer zones of

Alternative 1 and 2. Several other non-perennial rivers are located within and surrounding the 1km buffer zones

as well as small isolated dams/pans.

The project is located in the Eastern Highveld Grassland vegetation unit. This vegetation unit is characterised by

lightly to moderately undulating plains which includes some low hills, pan depressions and rocky outcrops. The

vegetation is short dense grassland dominated by a highveld grass composition (Mucina, L. & Rutherford, M.C.

(eds), 2006). The sites are underlain by the Ecca Formation of the Karoo Supergroup. The formation consists of

shale, shaly sandstone, grit, sandstone and conglomerate. Coal occurs in places near the base and top of the

Formation.

The landuse within the region consists of farmsteads that are spread out through the site and surroundings and

a more formal residential area associated with town of Arnot / Rietkuil. The agricultural activities are a

combination of open grassland (grazing veld) and crop production (maize) and are mostly located towards the

east of the R104.

There are coal mining activities within the study area and includes the existing Eskom Arnot Power Station,

Boschmanspoort Mine, Kwagga Coal Mine Zevenfontein Coal Mine, Amstaerdam and Rietkuil Coal Mine. The

Pullenshope Coal Mine and Eskom Hendrina Power Station are located outside the study area, approximately

15km from Site Alternative 2. The mining activities are all located to the west of the R104, except for the Eskom

Arnot Power Station which is located to the north of the project site and east of the R104.

2.1.2 PROPERTY DESCRIPTION

Two alternative sites have been identified for investigation in Scoping, one site will be taken into the EIA phase

for detailed investigation. Table 4 below lists the farm portions potentially affected by each alternative.

Table 4: List of affected properties for each alternative

Potentially Affected Farm Portions

Alternative

1

Schoonoord 164 IS: 28/164, 22/164, 6/164, 10/164, 19/164, 9/164, 5/164, 4/164, 3/164, 1/164, 11/164; and

Rietkuil 491 JS: 3/491, 27/491.

Alternative

2

Schoonoord 164 IS: 28/164, 22/164, 10/164;

Rietkuil 491 JS: 27/491, 32/491, RE/24/491;

Nooitgedacht 493 JS: 9/493, 4/493; and

Vlakfontein 166 IS: 1/166, 2/166, 5/166, 6/166, 15/166, 166.


2.1.3 LOCALITY MAP

Figure 1 overleaf indicates the locality of the two 120ha alternative sites proposed for the Arnot Ash Disposal

Facility project. It is expected that minor adjustments to the site locations may still occur prior to the start of the

EIA, therefore each site also includes a 1km buffer zone area. Specialists were asked to consider the entire area

for each site, including the buffer zone, when investigating the sites.

2.2 DESCRIPTION OF ACTIVITY

2.2.1 NEED AND DESIRABILITY OF THE PROJECT

The ash complex was designed to operate until the original end of the station life in 2021. This date has been

revised to 2032. An ashing capacity study showed that the rate of rise of the ashing complex will be more than

4m by the year 2026. Arnot is in need of a new ashing facilities in order to reduce this rate of rise to an acceptable

rate. It was recommended that the new facility should be 80ha – 120ha in size in order to provide Arnot Power

Station with the capacity to dispose all of the ash it produces as part of its operation from 2026 until the end of

station life in 2032.

If Eskom is to meet its mandate and commitment to supply the ever-increasing needs of end-users in South

Africa, one of Eskom’s options is to extend the life of its infrastructure of generation capacity and transmission

and distribution powerlines. This expansion includes not only the building new power stations but also

expanding and upgrading existing power stations to ensure that the operating life of the power stations can be

extended. Table 5 present the needs and desirability analysis undertaken for the Arnot ADF project.

Table 5: Needs and desirability analysis for the Arnot ADF

Ref # Question Answer

1 Securing ecological sustainable development and use of natural resources

1.1 How were the ecological integrity considerations considered in terms of: Threatened Ecosystems, Sensitive and vulnerable ecosystems, Critical Biodiversity Areas, Ecological Support Systems, Conservation Targets, Ecological drivers of the ecosystem, Environmental Management Framework, Spatial Development Framework (SDF) and global and international responsibilities.

The following specialist studies are being conducted:

• Biodiversity and wetland study;

• Hydrological;

• Hydrogeological study;

• Soil study;

• Traffic study (EIA only)

• Noise study (EIA only)

• Geotechnical study;

• Heritage and paleontological study.;

• Wetlands Study; and

• Visual Study.

The conclusions of these studies, and the identified impacts and mitigation measures stemming there from will be included in the EIA and EMPr. The need of the project in terms of the Nkangala District Municipal SDF will also be further considered in the EIA and EMPr.

1.2 How will this project disturb or enhance ecosystems and / or result in the loss or protection of biological diversity? What measures were explored to avoid these negative impacts, and where these negative impacts could not be avoided altogether, what measures were explored to minimise and remedy the impacts? What measures were explored to enhance positive impacts?

Refer to baseline ecological information in Section 5, and the impact assessment and mitigation measures in Section 6 of this Scoping Report. These sections will be further expanded in the EIA and EMPr, with the addition of specialist studies.


1.3 How will this development pollute and / or degrade the biophysical environment? What measures were explored to either avoid these impacts, and where impacts could not be avoided altogether, what measures were explored to minimise and remedy the impacts? What measures were explored to enhance positive impacts?

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

Refer to Section 2 of this Scoping Report. This aspect will be further explored in the EIA and EMPr

1.5 How will this project disturb or enhance landscapes and / or sites that constitute the nation’s cultural heritage? What measures were explored to firstly avoid these impacts, and where impacts could not be avoided altogether, what measures were explored to minimise and remedy the impacts? What measures were explored to enhance positive impacts?

A Heritage and paleontological specialist has been appointed to conduct a Phase 1 Heritage impact assessment and a paleontological study, the results of this study will be made available in the EIA and EMPr.

1.6 How will this project use and / or impact on non-renewable natural resources? What measures were explored to ensure responsible and equitable use of the resources? How have the consequences of the depletion of the non-renewable natural resources been considered? What measures were explored to firstly avoid these impacts, and where impacts could not be avoided altogether, what measures were explored to minimise and remedy the impacts? What measures were explored to enhance positive impacts?

Refer to the impact assessment and mitigation methods in Section 6 of this Scoping Report. Apart from soil / farmlands, no non-renewable resource will be directly depleted as a result of the project.

1.7 How will this project use and / or impact on renewable natural resources and the ecosystem of which they are part? Will the use of the resources and / or impacts on the ecosystem jeopardize the integrity of the resource and / or system taking into account carrying capacity restrictions, limits of acceptable change, and thresholds? What measures were explored to firstly avoid the use of resources, or if avoidance is not possible, to minimise the use of resources? What measures were taken to ensure responsible and equitable use of the resources? What measures were explored to enhance positive impacts?

Refer to the impact assessment and mitigation methods in Section 6 of this Scoping Report.

1.7.1 Does the proposed project exacerbate the increased dependency on increased use of resources to maintain economic growth or does it reduce resource dependency (i.e. de-materialised growth)?

The power station is existing. The project will allow the power station to extend its operational lifespan.


1.7.2 Does the proposed use of natural resources constitute the best use thereof? Is the use justifiable when considering intra- and intergenerational equity, and are there more important priorities for which the resources should be used?

The power station is existing. The project will allow the power station to extend its operational lifespan. There will be some impacts on natural resources. Refer to the impact assessment and mitigation methods in Section 6 of this Scoping Report.

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

The power station is existing. The project will allow the power station to extend its operational lifespan which would reduce dependency on resources associated with a new coal-fired power station however the dependency on resources associated with the existing power station would continue for at least another 15 years.

1.8 How were a risk-averse and cautious approach applied in terms of ecological impacts:

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

In terms of the ecological impacts, the current knowledge gaps include:

• Detailed and site-specific background information regarding some of the environmental aspects is not yet available however, the outstanding information will be generated through the identified specialist studies identified in Section 9.

• While the expected potentially significant impacts have been preliminarily identified as part of this Scoping Process, the impacts on all environmental aspects will be explored in more detail and quantified wherever possible during the EIA Phase.

• The mitigation measures associated with the impacts need to still be determined.

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

The level of risk is low as previous specialist studies have been conducted in the areas surrounding the proposed project location, and therefore some information is already available.

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

A prefeasibility study was conducted to take a least risk approach in selecting suitable site for consideration in the scoping and EIA process

1.9 How will the ecological impacts resulting from this development impact on people’s environmental right in terms following?

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

Refer to the impact assessment and mitigation measures in Section 6 in this Scoping Report. This aspect will be further explored in the EIA and EMPr.

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

1.10 Describe the linkages and dependencies between human wellbeing, livelihoods and

Refer to the impact assessment and mitigation measures in Section 6 in this Scoping Report.


ecosystem services applicable to the area in question and how the development’s ecological impacts will result in socio-economic impacts (e.g. on livelihoods, loss of heritage site, opportunity costs, etc.)?

This aspect will be further explored in the EIA and EMPr.

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

Refer to the impact assessment and mitigation measures in Section 6 in this Scoping Report. This aspect will be further explored in the EIA and EMPr.

1.12 Considering the need to secure ecological integrity and a healthy biophysical environment, describe how the alternatives identified (in terms of all the different elements of the development and all the different impacts being proposed), resulted in the selection of the “best practicable environmental option” in terms of ecological considerations?

Refer to Section 7, details of the alternatives considered, and Section 5 the advantages and disadvantages of the proposed activity, of this Scoping Report. This aspect will be further explored in the EIA and EMPr.

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

Refer to Section 9 of this Scoping Report. This aspect will be further explored in the EIA and EMPr

2 Promoting justifiable economic and social development

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

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

The Steve Tshwete Local Municipality Integrated Development Plan (IDP) for the period of 2017 – 2022 describes the largest employing industries in Steve Tshwete as trade (including industries such as tourism), community/government services and mining. The unemployment rate for 2015 was 21%.

The proposed ADF will extend the lifespan of the power station, thus allowing Eskom to continue supplying jobs at that power station for a longer time period. The surrounding communities will also continue to benefit through direct and indirect income; as well as the power station’s use of local contractors and suppliers.

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

The power station will make use of labourers from the local community as far as possible.

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

Refer to the baseline environment in Section 5 of this Scoping Report.

2.1.4 Municipal Economic Development Strategy ("LED Strategy").

The proposed project will promote and support the sustainability of existing business; and assist in increasing local beneficiation and shared economic growth, through extending the life of the power station.

2.2 Considering the socio-economic context, what will the socio-economic impacts be of the development (and its separate

Refer to the impact assessment and mitigation measures in Section 6 in this Scoping Report.


elements/aspects), and specifically also on the socio-economic objectives of the area?


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

The proposed project will increase the lifespan of the power station - this will complement the local socio-economic initiatives identified for the area.

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

Refer to the proposed public participation process in Section 4 of this Scoping Report. This aspect will be further explored in the EIA and EMPr.

2.4 Will the development result in equitable (intra- and inter-generational) impact distribution, in the short- and long term? Will the impact be socially and economically sustainable in the short- and long-term?

Refer to the impact assessment and mitigation measures in Section 6 of this Scoping Report. This aspect will be further explored in the EIA and EMPr.

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

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

Refer to Section 2 and Section 7, details of alternatives considered in this Scoping Report.

2.5.2 Reduce the need for transport of people and goods.

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

2.5.4 Compliment other uses in the area, Refer to item 1.3 of this table (above).

2.5.5 Be in line with the planning for the area. Refer to item 2.2.1 of this table (above).

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

Not applicable.

2.5.7 Optimise the use of existing resources and infrastructure,

Refer to Chapter 2 of this scoping report

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

2.5.9 Discourage "urban sprawl" and contribute to compaction / densification.

The proposed project will result in the continued employment of workers. Influx of additional workers to the area as a direct result of the proposed project is not anticipated.

2.5.10 Contribute to the correction of the historically distorted spatial patterns of settlements and to the optimum use of existing infrastructure in excess of current needs,

Refer to items 2.5.7 – 2.5.9 of this table (above).

2.5.11 Encourage environmentally sustainable land development practices and processes

The proposed end land use will be developed in order to be environmentally sustainable in the long term.

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

Refer to item 1.7.3 of this table (above).


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

The proposed project will allow the power station to continue contributing to the local, regional and national Gross Domestic Product (GDPs), and also on the local communities through continued employment of employees and local contractors, as well as other influences that the power station has on local communities in the area.

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

Refer to impact assessment and mitigation measures in Section 6 of this Scoping Report.

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

The proposed project will ensure continued employment in the region.

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

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

Refer to Section 6.2 of this scoping report

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

The level of risk is low as the project is not expected to have far reaching impacts on socio-economic conditions.

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

The EIA and impact assessment methodology implements a risk averse approach to addressing and mitigating any potential impacts.

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

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


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


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


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


2.10 What measures were taken to pursue environmental justice so that adverse environmental impacts shall not be distributed in such a manner as to unfairly discriminate against any person, particularly vulnerable and disadvantaged persons (who are the

Refer to the impact assessment and mitigation measures in Section 6 of this Scoping Report.


beneficiaries and is the development located appropriately)? Considering the need for social equity and justice, do the alternatives identified, allow the "best practicable environmental option" to be selected, or is there a need for other alternatives to be considered?

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

By conducting a Scoping and EIA Process, the applicant ensures that equitable access has been considered. Refer to the impact assessment and mitigation measures in Section 6 of this Scoping Report. This aspect will be further explored in the EIA and EMPr.

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

Refer to the impact assessment and mitigation measures in Section 6 of this Scoping Report. The EIA and EMPr will specify timeframes within which mitigation measures must be implemented.

2.13 What measures were taken to:

2.13.1 Ensure the participation of all interested and affected parties.

Refer to Section 4 of this Scoping Report, describing the public participation process to be implemented for the proposed project.

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

Refer to Section 4 of this Scoping Report, describing the public participation process to be implemented for the proposed project. The advertisement and site notice will be made available in English and Afrikaans to assist in understanding of the project. Public meetings are also planned to be held in the scoping and EIA phases of the project.

2.13.3 Ensure participation by vulnerable and disadvantaged persons,

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

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

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

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

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

Refer to Section 4 of this Scoping Report, describing the public participation process to be implemented for the proposed project. This aspect will be further explored in the EIA and EMPr.

2.15 What measures have been taken to ensure that current and / or future workers will be

Workers will be educated on a regular basis as to the environmental risks that may occur


informed of work that potentially might be harmful to human health or the environment or of dangers associated with the work, and what measures have been taken to ensure that the right of workers to refuse such work will be respected and protected?

within their work environment, adequate measures have been taken to ensure that the appropriate personal protective equipment is issued to workers based on the areas that they work and the requirements of their job.

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

2.16.1 The number of temporary versus permanent jobs that will be created.

It is not anticipated that any new jobs will be created during operation; rather, existing jobs will be maintained for a longer period of time. Some jobs will be created during construction – more detail will be provided in the EIA phase.

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

2.16.3 The distance from where labourers will have to travel.

2.16.4 The location of jobs opportunities versus the location of impacts.

It is not anticipated that any new jobs will be created during operation; rather, existing jobs will be maintained for a longer period of time. Some jobs will be created during construction – more detail will be provided in the EIA phase.

2.16.5 The opportunity costs in terms of job creation.

2.17 What measures were taken to ensure:

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

The Scoping and EIA Process requires governmental departments to communicate regarding any application. In addition, all relevant departments will be notified of the project by the EAP. 2.17.2 That actual or potential conflicts of interest

between organs of state were resolved through conflict resolution procedures.

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

Refer to Section 4 of this Scoping Report, describing the public participation process to be implemented for the proposed project.

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

Refer to the impact assessment and mitigation measures in Section 6 of the Scoping Report. This aspect will be further explored in the EIA and EMPr.

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

The EIA EMPR will include reasonable, feasible

and achievable mitigation measures in this

regard.

2.21 Considering the need to secure ecological integrity and a healthy bio-physical environment, describe how the alternatives identified (in terms of all the different elements of the development and all the different impacts being proposed), resulted in the selection of the best practicable environmental option in terms of socio-economic considerations?

Refer to Section 2 and Section 7, description of the process followed to reach the proposed preferred site, of the Scoping Report. This aspect will be further explored in the EIA and EMPr.


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


2.2.2 PERIOD FOR WHICH AUTHORIZATION IS REQUIRED

The ash complex was designed to operate until the original end of the station life in 2021. This date has been

revised to 2032. Therefore, the authorisation will be required until 2032.

2.2.3 DESCRIPTION OF PROPOSED PROJECT

The coal-fired power generation process produces large quantities of ash, which is disposed of in ash dumps and

dams. Eskom uses coal of a low grade (called middlings coal) which produces a larger mass of ash during

combustion. The higher-grade coal in South Africa predominantly serves the export market. Eskom uses either

wet or dry methods of ash disposal. Both utilise effluent water or wastewater, which is the end product of the

cascading water re-use process. Wet ash disposal, utilized at the Arnot site, entails the hydraulic conveyance of

ash, while dry ash disposal entails the conveyance of partially moistened ash on conveyer belts. The proposed

facility will be a wet ashing facility.

The proposed Ash Disposal Facility will also have the following associated infrastructure:

• Access roads for operations and maintenance;

• Drainage channels for clean and dirty water;

• Ash Water Return Dams;

• Lining for the New Ash Disposal Facility;

• Emergency ash offloading area;

• Pipelines for transportation of wet ash and water to and from the ash disposal facility;

• Pumping capacity;

• Sanitation services and Offices;

• Storm Water Drainage and Groundwater Monitoring Boreholes; and

• Fencing and access control.


Figure 1: Locality Map indicating two alternative sites nominated for consideration in scoping


2.2.3.1 INTERNAL AND EXTERNAL ACCESS ROADS

Access roads will be established, initially to allow for construction vehicles, but some of these roads may be

retained, but reduced, post construction to allow for maintenance of the facility. The location of these access

roads has not yet been determined and will form part of the next phase of assessment.

2.2.3.2 CLEAN AND DIRTY WATER SYSTEM (ASH WATER RETURN DAMS AND TRENCHES / DRAINS)

A clean and dirty water separation system will be designed for the facility. Dirty storm water from the facility

will be collected and channelled to a dirty water return dam, from where it will be pumped for re-use. The

capacity requirements will be determined by an engineering investigation that will be undertaken during the EIA

phase. Clean water cut-off canals/trenches/drains will be established to divert clean water back into the natural

environment.

2.2.3.3 ASH WATER RETURN DAMS

A wet-ashing system is utilized at Arnot power station. The new ash disposal facility will utilise effluent water or

wastewater, which is the end product of the cascading water re-use process. Wet ash disposal entails the

hydraulic conveyance of ash and an ash water return dam is therefore required for this purpose. More detailed

specifications will be provided in the EIA report.

2.2.3.4 LINING FOR THE NEW ASH DISPOSAL FACILITY

Coal ash is considered a pollutant to ground water. The Department of Water and Sanitation (DWS) does not

allow storage of this bi-product without ensuring the area is protected against contaminated water seepage into

the environment. A durable composite liner system will be designed that will ensure the safety of the

surrounding ground water. More detailed specifications will be provided in the EIA report. A suite of regulations

as well as norms and standards, aimed at the classification and disposal of waste, was published in Government

Notice No. R.6349, R.63510 and R.63611 under Section 63 of the NEM:WA (2008). The aforementioned

regulations as well as norms and standards informed the classification and assessment of the ash (i.e. waste) to

determine the mandatory method of disposal. In accordance with the provisions of Government Notice No.

R.635 the proposed Continuous ADF facility will include an appropriate barrier system.

2.2.3.5 EMERGENCY ASH OFFLOADING AREA

This is a concrete slab area that is used to accommodate ash that has been offloaded in case of an emergency.

The current ash disposal facility has an existing emergency ash offloading area of 900m2; this needs to be

extended by 4680m2 to a total area of 5580m2.

2.2.3.6 PIPELINES

A network of pipelines will be installed to, amongst others: transport water to and from the return water dam

and the power station; transport potable water; transport water for dust suppression; and to transport water

collected from the waste facility to the return water dam.

2.2.3.7 FENCING AND ACCESS CONTROL

It is envisaged that fencing will be required for security reasons. In order to ensure controlled access and to

prevent illegal dumping, the site will require access control through a security guard. This person will also

contribute to site safety.

2.2.3.8 STORM WATER DRAINAGE AND GROUNDWATER MONITORING BOREHOLES

As part of the site design, ongoing monitoring of the site storm water drainage features will be undertaken, and

additional groundwater monitoring boreholes will be installed for monitoring. As part of the conceptual designs

a storm water management plan will be developed to ensure that storm water is adequately addressed

2.2.3.9 FOOTPRINT AND LIFESPAN

The ashing facility will cover an area of up to 120ha and is expected to allow operation of the power station for

at least another 15 years or until the power station is decommissioned.


2.2.3.10 CONSTRUCTION, OPERATION, REHABILITATION AND DECOMMISSIONING

Once authorized the detailed design phase will commence. This is expected to take 6 months. The construction

phase is then expected to take 2 years to complete.

The operating life of the ash disposal facility will be approximately 15 years. During operations ash will be mixed

with water, stored in dams and ultimately transported via pipelines to the approved facility. Management

activities at the facility will include dust suppression and, once a stable stack has been reached, re-vegetation of

the stable areas can commence.

During closure the proposed ash disposal facility will be capped and rehabilitated. Some re-vegetation will be

undertaken over the life of the facility. More detailed information on the capping and closure of the facility will

be generated in the EIA phase of the project. The ash dump will be rehabilitated progressively. Areas where final

shaping and levelling of the ash have been completed are topsoiled immediately and rehabilitated as soon as

possible. The ash dump will be covered daily with a layer of soil/sandy material while the final rehabilitation

cover consists of topsoil material with seeding for grass and the manual planting of trees.

Detailed specifications for the above infrastructure has not been determined at this stage because it is

dependent on the site that is finally chosen for the establishment of the ash disposal facility as well as the

conceptual design which is currently being completed. More detail will be included in the EIA phase report.

2.3 ALTERNATIVES

The identification of alternatives is a key aspect of the success of the EIA process. All reasonable and feasible

alternatives must be identified and assessed to determine the most suitable alternatives for the proposed

project. There are however some significant constraints that have to be taken into account when identifying

alternatives for a project of this scope. Such constraints include financial, social, and environment related issues.

Alternatives can typically be identified according to:

• Activity alternatives;

• Location alternatives;

• Design and layout alternatives;

• Technological alternatives;

• The No-Action alternative (No-Go).

For any alternative to be considered feasible such an alternative must meet the need and purposes of the

development proposal without presenting significantly high associated impacts. The remainder of this section

briefly describes the alternatives which were considered viable and feasible for this project as well as reasons

why some will not be assessed in the EIA Phase.

Alternatives can also be distinguished into discrete or incremental alternatives. Discrete alternatives are overall

development options, which are typically identified during the pre-feasibility, feasibility and or scoping phases

of the EIA process. Incremental alternatives typically arise during the EIA process and are usually suggested as a

means of addressing identified impacts. These alternatives are closely linked to the identification of mitigation

measures and are not specifically identified as distinct alternatives.

2.3.1 NO GO ALTERNATIVE

The National Integrated Resource Plan 2016 (IRP) developed by the Department of Energy has identified the

need for power generation from coal as part of the technology mix for power generation in the country in the

next 20 years. In order for the Arnot power station to continue to produce power, a new ashing facility is

required to provide additional capacity. The 'do nothing' option will not address this need and will result in

reduced power generation activities at the power station and a reduction in the power stations lifespan.

This alternative will imply that no ash dump facility is constructed, and that the environment remains unchanged

and unaltered. This alternative will be investigated further in the EIA phase.


2.3.2 LOCATION ALTERNATIVES

In order to identify a potential site for the proposed facility a screening and site selection exercise was conducted

which culminated in the compilation of a site Selection Report (Appendix L). This screening study was completed

in February 2018. This site selection exercise was initially based on a GIS mapping process in order select sites

for further consideration in an EIA process. All the specialist input layers were combined into the sensitivity

analysis. Engineering and other site selection constraints are then overlaid to indicate preliminary suitable sites.

Further refinement to the potential suitable sites was done in order to determine:

• Feasible alternative sites to be investigated in more detail (5 sites)

• Preferred alternative sites for investigation in the Scoping Phase (3 sites)

Figure 2 below gives a graphic representation of the steps that we followed during the screening/site selection

process that was followed to identify the 3 preferred alternative sites being considered in this report.

Figure 2: Flow diagram of the screening process.

The sensitivity mapping approach is based on a desktop study and GIS study with numerus specialist inputs. The

GIS was tasked with identifying suitable sites of up to 120 hectares in extent. The sensitivity mapping process is

described by the flow diagram below:


Figure 3: Illustration of GIS Mapping Methodology

The following eight environmental constraints were mapped with the input from the various specialists.

• Air quality in the study area and distance from receptors;

• Aquatic sensitivity in the study area;

• Ecological sensitivity in the study area;

• Heritage and palaeontological sensitivities in the study area;

• Sensitive hydrological features in the study area;

• Surface hydrology and related formal protected areas within study area; and

• Areas preferred from a visual perspective within the study area;

Based on the environmental sensitivity mapping approximately 15 potential sites were identified. However,

after considering information on existing Eskom infrastructure this number was reduced to 6. Once information

was obtained from DMR regarding undermining in the study area, this reduced the number of least risk sites

from 6 to 5.

A site visit with the specialist team and engineers to the remaining five: “least-risk” sites was conducted on 23

November 2016. The five sites were ground-truthed by the specialist team consisting of the ecologist,

hydrologist, groundwater specialist, the engineering and design team and the geotechnical engineers as well as

two representatives from EIMS. The remaining specialist input was based on desktop assessments of the sites.


Based on the space requirements, several 80ha and 120 sites were identified for screening. The combined results

from the environmental and engineering constraints mapping reduced the number of preferred 80ha sites to six

(6) and the number of preferred 120ha sites to three (3). These sites were identified as being of least risk for the

development of the ash disposal facility. Potential alternative sites were further refined based on a desktop

study in order to identify screened alternatives which are to be further assessed by specialists on-site.

Figure 4: Final screened 80ha alternatives


Figure 5: Final screened 80ha alternatives

Placement of ash waste into existing surface excavations is also not considered a viable option due to the fact

that the ash waste will most probably become water logged and saturated. The resultant mix of material will

have a very low shear strength and will be highly unstable.

These alternatives are discussed in more detail within this scoping report. Site Alternative 1 (120ha option) and

Site Alternative 2 (120ha option) were nominated as the most preferred options for consideration in a scoping

and EIA process. The main reasons for the rankings are listed below:

• Potential undermining at Alternative 4 (80ha site) and Alternative 3 (120ha site) could be a fatal flaw

and should be investigated if this option is considered further (or alternatively these sites should be

excluded going forward);

• A portion of the 1km radius for Site Alternative 3 (120ha option) and Alternative 4 (80ha option) is

situated within a Freshwater Ecosystem Priority Area and a highly significant aquatic biodiversity sub-

catchment based on the Mpumalanga Biodiversity Conservation Plan. This alternative has the highest

extent of temporal/seasonal and seasonal/permanent wetland areas;

• Site Alternative 4 (80ha) has the highest extent of temporary / seasonal and seasonal / permeant

wetland areas. Alternative 4 has a higher landcover associated with grassland when compared to the

other alternatives. Furthermore, this alternative is situated more than 3km from the existing Arnot ash

disposal facility will require more extensive supporting infrastructure which may have a greater impact

on the surrounding wetland areas.

• Alternative 3 and 4 (both 80ha and 120ha options) is situated upstream of the Grootpan, Leeuwpan,

Rietpan, Klippan and Blinkpan. Any spillages originating from the Alternative 4 would have a negative

effect on the downstream pans;


• All sites have wetland features within the 1 km buffer zone however Site Alternative 3 (80ha) also

contains wetland features within the current proposed ash disposal facility footprint area;

• Topographical arrangements at Site Alternative 3 (80ha) indicate a single low point (valley) which can

be beneficial to drainage but due to the upstream collection of water it is not recommended as large

water diversion structures will be required to eliminate the risk of water collecting to the east of the

proposed facility;

• Site Alternative 2 is located close to the existing ash disposal facility, therefore consolidating impacts

within a single area within the broad study area; and

• A large proportion of Site Alternative 2 is already transformed by cultivation.

2.3.3 TECHNOLOGY ALTERNATIVES

The main technology alternative that could be implemented is dry ashing as opposed to the wet ashing facility

currently proposed. Dry ash disposal entails the conveyance of partially moistened ash on conveyer belts.

However, this option is not considered feasible for the Arnot power station. The New Ash Disposal Facility must

take into consideration the pumping constraints of the current ash plant. Existing wet ashing infrastructure

already exists for the power station and there are already three existing wet ash facilities at the power station.

Wet ashing technology is therefore the only feasible alternative from a technical and financial perspective.

Several other alternatives exist for ash disposal. The two main alternative options identified are:

• Underground backfill; and

• The expansion of existing ash disposal facilities.

These were both ruled out during feasibility studies. However, the opportunity for modular design and

expansion to accommodate future technological advances for the ash dump is being considered. Further detail

will be provided in the EIA report.

Furthermore there are two operational alternatives in terms of how the ADF is operated. These include:

• Parallel operation; and

• Series operation.

The parallel option involves operating the new ADF at the same time as the existing ADF. This may allow for a

slightly smaller footprint for the new ADF. Serial operation involves decommissioning of the current ADF first

and then operating the new ADF only once the existing ADF has been decommissioned. This will require a slightly

larger site for the new ADF but is much easier to operate since only one ADF will be operational at a time. Eskom

has conducted a pre-feasibility assessment on both options and series operation was nominated as the only

feasible option for operation of the ADF from a technical feasibility perspective.

2.3.4 ACTVITY ALTERNATIVES

No activity alternatives have considered. The ashing facility is required at the existing Arnot power station. The

current Ash disposal facility at Arnot Power Station has been providing disposal services since the establishment

of the station. This ash disposal site is facing challenges, which need to be addressed. The only way these

challenges can be addressed is for a new ash disposal facility to be constructed in the vicinity of the power

station. No other reasonable and feasible activity alternatives exist.


3 POLICY AND LEGISLATIVE REQUIREMENTS

3.1 APPLICABLE ENVIRONMENTAL LEGISLATION

A summary of the applicable legislation guiding the requirement to conduct this Environmental Application

process is provided in Table 6 below. The sections below furthermore provide an overview of the governing

legislation identified which relate to the proposed project.

Table 6: Applicable legislation

Applicable Legislation and

Guidelines

Reference Where Applied

Relevant Authority

How does this Development Comply with and Respond to the Legislation and Policy

Context

CONSTITUTION OF THE REPUBLIC OF SOUTH AFRICA, Act 108 of 1996

This act is generally applied throughout the S&EIR process

All government departments

The constitution of any country is the supreme law of that country. The Bill of Rights in chapter 2 section 24 of the Constitution of South Africa Act (Act 108 of 1996) makes provisions for environmental issues and declares that: “Everyone has the right to an environment that is not harmful to their health or well-being.

NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT (ACT 59 of 2008)

A waste license is required for the construction of the ash disposal facility. Several Category B Listed Activities are triggered by the project.

Hazardous Waste – National DEA

Other – Provincial Government

An integrated application for Environmental Authorisation and Waste Management Licence is being applied for.

NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA) (ACT 107 of 1998)

Various GN 983, 984 and 985 Listed Activities are triggered. This entire report is prepared as part of the Application for Environmental Authorisation under the NEMA.

National DEA In terms of the National Environmental Management Act an Application for Environmental Authorisation subject to a Scoping and EIA Process is being applied for.

THE NATIONAL WATER ACT, 1998 (ACT 36 of 1998) (NWA)

There are several potential water uses that will require licensing under the NWA.

Department of Water and Sanitation

A Water Use License Application is being applied for. This is a separate process to the EIA however some parts of the process will be integrated into the EIA.

NATIONAL HERITAGE RESOURCE ACT (ACT 25 of 1999)

Provides for the protection of all archaeological and palaeontological sites that may be affected by the project.

South African Heritage Resources Agency (SAHRA)

A heritage assessment has been undertaken as part of the Scoping Process to identify heritage sites


NATIONAL ENVIRONMENTAL MANAGEMENT: PROTECTED AREAS ACT (ACT 57 of 2003)

Provides for the protection of Protected Areas

DEA An ecological study has been undertaken as part of the Scoping Phase.

NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT (ACT 10 of 2004)

Under this Act, a permit would be required for any activity which is of a nature that may negatively impact on the survival of a listed protected species.

National DEA An ecological study has been undertaken as part of the Scoping Phase. As such the potentially occurrence of critically endangered, endangered, vulnerable, and protected species and the potential for them to be affected has been considered.

A permit may be required should any listed plant species on site be disturbed or destroyed as a result of the proposed development.

HAZARDOUS SUBSTANCES Act (Act No. 15 of 1973)

This Act regulates the control of substances that may cause injury, or ill health, or death due to their toxic, corrosive, irritant, strongly sensitising, or inflammable nature.

Department of Health

The use, conveyance, or storage of any hazardous substance is prohibited without an appropriate license being in force.

3.2 APPLICABLE NATIONAL LEGISLATION

The legal framework within which the proposed application operates is governed by many acts, regulations,

standards, guidelines and treaties on an international, national, provincial and local level. Legislation applicable

to the project includes the following.

3.2.1 NATIONAL WASTE ACT

On 2 June 2014 the National Environmental Management: Waste Amendment Act came into force. Waste is

accordingly no longer governed by the MPRDA but is subject to all the provisions of the National Environmental

Management: Waste Act, 2008 (NEMWA).

Section 16 of the NEMWA must also be considered which states as follows:

1. “A holder of waste must, within the holder’s power, take all reasonable measures to-

a. avoid the generation of waste and where such generation cannot be avoided, to minimise the toxicity and amounts of waste that are generated;

b. reduce, re-use, recycle and recover waste;

c. where waste must be disposed of, ensure that the waste is treated and disposed of in an environmentally sound manner;

d. manage the waste in such a manner that it does not endanger health or the environment or cause a nuisance through noise, odour, or visual impacts;

e. prevent any employee or any person under his or her supervision from contravening the Act; and

f. prevent the waste from being used for unauthorised purposes.”


These general principles of responsible waste management will be incorporated into the requirements of the

EMPR to be implemented for this project.

In July 2009 the NEM:WA was promulgated, and amongst others makes provision for licensing and management

of waste disposal facilities. The Minister of the Department of Water and Environmental Affairs, under Section

19 (1) of the NEM:WA, has published a list of waste management activities, which has or is likely to have, a

detrimental effect on the environment in GNR 718 of 3 July 2009. The schedule has listed activities in two

different categories:

For Category “A” activities: a person who wishes to commence, undertake or conduct an activity listed under

this Category, must conduct a Basic Assessment, as stipulated in the EIA regulations under section 24 (5) of the

NEMA as part of a Waste Management Licence Application.

For Category “B” activities: a person who wishes to commence, undertake or conduct an activity listed under

this Category, must conduct a S&EIR process, as stipulated in the EIA regulations under section 24(5) of the

NEMA as part of a Waste Management Licence Application.

The activities of the project that require a waste management license in terms of these regulations are listed in

Table 7. It should be noted that the activities listed for the project fall within Category B and will therefore

require a full Scoping and EIA process be undertaken for the licensing of the proposed project.

Table 7: NEMWA Listed Activities

Notice and Activity No Listed Activity Description of listed activity as per

detailed project description

GN 921, 29 August 2013, Category B, Activity 7

The disposal of any quantity of hazardous waste to land

The proposed project is an ash disposal facility. The ash produced through the power generation process is considered to be hazardous.

GN 921, 29 August 2013, Category B, Activity 10

The construction of facilities for a waste management activity listed in Category B of this schedule (not in isolation to associated activity).

The proposed project is an ash disposal facility. The ash produced through the power generation process is considered to be hazardous.

Coal ash is considered a pollutant to ground water, the Department of Water and Sanitation (DWS) does not

allow storage of this bi-product without ensuring the area is protected against contaminated water seepage into

the environment. A suite of regulations as well as norms and standards, aimed at the classification and disposal

of waste, was published in Government Notice No. R.6349, R.63510 and R.63611 under the Section 73 of the

NEM:WA (2008). The aforementioned regulations as well as norms and standards informed the classification

and assessment of the ash (i.e. waste) to determine the mandatory method of disposal. In accordance with the

provisions of Government Notice No. R.635 the proposed Continuous ADF facility will include an appropriate

barrier system.

3.2.2 NATIONAL ENVIRONMENTAL MANAGEMENT ACT

The National Environmental Management Act (Act No. 107 of 1998) as amended (NEMA), aims to protect the

environment, and stipulates that developments must be socially, environmentally and economically sustainable,

and that disturbances and pollution of the environment must be avoided, minimised and remedied. The Act also

provides for the equitable access to environmental resources, to meet basic human needs. Decisions on the

environment must be taken in an open and transparent manner, and resources must be held in trust for the

public and protected as such. NEMA also makes provision for the cost of remedying pollution, and all such costs

shall be paid by the polluter.


Section 24 (2) in NEMA (1998) provides for activities which may have a detrimental effect on the environment

and may not commence without environmental authorisation (EA) from the competent authority. In Section 24

(4 & 5) provision is made for the Regulations which stipulate the minimum procedures for the issuing of and

monitoring compliance with EA’s. Section 24 (8), states that authorisations or permits obtained under any other

law for an activity listed or specified in terms of this Act does not absolve the applicant from obtaining

authorisation under this Act.

In accordance with Section 24 of the NEMA, the Minister has published (in GN R. 983, 984, and 985) a list of

activities that require EA prior to commencement of these activities. In this regard it provides a list of the specific

activities extracted from the Regulations which the proposed project may potentially trigger, and which

consequently have been applied for in this application for EA.

A Scoping and EIA process is reserved for activities which have the potential to result in significant impacts which

are complex to assess. Scoping and EIA accordingly provides a mechanism for the comprehensive assessment of

activities that are likely to have more significant environmental impacts.

This section provides a brief overview of EIA Regulations and their application to this project. NEMA is national

legislation that provides for the authorisation of certain controlled activities known as “listed activities”. In terms

of Section 24(1) of NEMA, the potential impact on the environment associated with these listed activities must

be considered, investigated, assessed and reported on to the competent authority (the decision-maker) charged

by NEMA with granting of the relevant environmental authorisation. Eskom is the applicant and the project

requires licensing for hazardous waste activities, therefore in terms of Section 24C (2) (d) (iii) of the NEMA (1998)

and Section 43 (1) (a)(c) of the NEMWA ((2008) the National Department of Environmental Affairs (DEA) is the

competent authority.

The Scoping and EIA for the proposed project is being undertaken in accordance with the EIA Regulations

published in Government Notice 38282 of 8 December 2014, in terms of Section 24(5) of the National

Environmental Management Act (NEMA; Act No 107 of 1998). This process is being undertaken in support of

the application for Authorisation in terms of NEMA, as well as in support of the application for a waste license

in terms of the requirements of the NEM: Waste Act (Act No. 59 of 1998).

Table 8: NEMA Listed Activities

Activity No

Aerial Extent of Activity (Ha or

m2)

Applicable Listing Notice

Listed Activity Description Description of listed activity as per detailed project description

9 Linear Activity 983 The development of infrastructure exceeding 1000 metres in length for the bulk transportation of water or storm water—

(i) with an internal diameter of 0,36 metres or more; or

(ii) with a peak throughput of 120 litres per second or more;

excluding where—

(a) such infrastructure is for bulk transportation of water or storm water or storm water drainage inside a road reserve; or

Construction of drainage channels and return water facilities.

Construction of pipelines for the transportation of the ash slurry and return water.

Length TBC in EIA phase.


(b) where such development will occur within an urban area.

10 Design to be confirmed in EIA phase

983 "The development of infrastructure exceeding 1000 metres in length for the bulk transportation of water or storm water-

(i) with an internal diameter of 0,36 metres or more; or

(ii) with a peak throughput of 120 litres per second or more;

excluding where-

(a) such infrastructure is for bulk transportation of water or storm water drainage inside a road reserve; or

(b) where such development will occur within an urban area."

Construction of drainage channels and return water facilities.

Construction of pipelines for the transportation of the ash slurry and return water.

Length TBC in EIA phase.


983 The development of—

(i) canals exceeding 100 square metres in size;

(ii) channels exceeding 100 square metres in size;

(iii) bridges exceeding 100 square metres in size;

(iv) dams, where the dam, including infrastructure and water surface area, exceeds 100 square metres in size;

(v) weirs, where the weir, including infrastructure and water surface area, exceeds 100 square metres in size;

(vi) bulk storm water outlet structures exceeding 100 square metres in size;

(vii) marinas exceeding 100 square metres in size;

(viii) jetties exceeding 100 square metres in size;

(ix) slipways exceeding 100 square metres in size;

(x) buildings exceeding 100 square metres in size;

Construction of infrastructure within 32 metres of a watercourse.


(xi) boardwalks exceeding 100 square metres in size; or

(xii) infrastructure or structures with a physical footprint of 100 square metres or more;

where such development occurs—

(a) within a watercourse;

(b) in front of a development setback; or

(c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse; —

excluding—

(aa) the development of infrastructure or structures within existing ports or harbours that will not increase the development footprint of the port or harbour;

(bb) where such development activities are related to the development of a port or harbour, in which case activity 26 in Listing Notice 2 of 2014 applies;

(cc) activities listed in activity 14 in Listing Notice 2 of 2014 or activity 14 in Listing Notice 3 of 2014, in which case that activity applies;

(dd) where such development occurs within an urban area; or

(ee) where such development occurs within existing roads or road reserves.


983 The development of facilities or infrastructure for the off-stream storage of water, including dams and reservoirs, with a combined capacity of 50000 cubic metres or more, unless such storage falls

An ash water return dam will be constructed as part of the project. The combined capacity of the ash water return dams will be confirmed in the EIA phase.


within the ambit of activity 16 in Listing Notice 2 of 2014.


983 The development of facilities or infrastructure, for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 cubic metres or more but not exceeding 500 cubic metres.

Potential storage of chemicals – quantities TBC in EIA phase

19 Linear Activity 983 The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 cubic metres from—

(i) a watercourse;

(ii) the seashore; or

(iii) the littoral active zone, an estuary or a distance of 100 metres inland of the high-water mark of the sea or an estuary, whichever distance is the greater—

but excluding where such infilling, depositing, dredging, excavation, removal or moving—

(a) will occur behind a development setback;

(b) is for maintenance purposes undertaken in accordance with a maintenance management plan; or

(c) falls within the ambit of activity 21 in this Notice, in which case that activity applies.

Construction of infrastructure across watercourses or wetlands may be required.

A Pollution Control Dam (PCD) will be constructed. The size will be confirmed in the EIA phase. Boundaries of the adjacent wetlands in relation to the proposed layout are unknown at this stage.

24 Linear activity.

The length of new roads required will be confirmed in EIA phase.

983 The development of—

(i) A road for which an environmental authorisation was obtained for the rote determination in terms of activity 5 in Government notice 387 of 2008 or activity 18 in

The construction of access roads for the construction and or long-term servicing of all planned infrastructure for the project will be required.


Government Notice 545 of 2010; or

(ii) a road with a reserve wider than 13,5 meters, or where no reserve exists where the road is wider than 8 metres;

but excluding—

(a) roads which are identified and included in activity 27 in Listing Notice 2 of 2014; or

(b) roads where the entire road falls within an urban area.

25 Design to be confirmed in EIA phase.

983 The development and related operation of facilities or infrastructure for the treatment of effluent, wastewater or sewage with a daily throughput capacity of more than 2000 cubic metres but less than 15000 cubic metres.

Potential treatment of water in the PCD

27 TBC 983 "The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation, except where such clearance of indigenous vegetation is required for-

(i) the undertaking of a linear activity; or

(ii) maintenance purposes undertaken in accordance with a maintenance management plan."

Clearance of vegetation for construction of PCD and new access road – condition of vegetation to be confirmed in EIA phase.

34 TBC 983 "The expansion or changes to existing facilities for any process or activity where such expansion or changes will result in the need for a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the release of emissions or pollution, excluding-

(i.) where the facility, process or activity is included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental

NEMWA listed activities


Management: Waste Act, 2008 applies; or

(ii.) the expansion of or changes to existing facilities for the treatment of effluent, wastewater or sewage where the capacity will be increased by less than 15 000 cubic metres per day."


983 "The widening of a road by more than 6 metres, or the lengthening of a road by more than 1 kilometre-

(i) where the existing reserve is wider than 13,5 meters; or

(ii) where no reserve exists, where the existing road is wider than 8 metres;

excluding where widening or lengthening occur inside urban areas."

Size of road to be confirmed in EIA phase

7 Linear activity 984 The development and related operation of facilities or infrastructure for the bulk transportation of dangerous goods─

(ii) in liquid form, outside an industrial complex, using pipelines, exceeding 1000 metres in length, with a throughput capacity of more than 50 cubic metres per day;

Pipelines will be required for transportation of wet ash and water to and from the ash disposal facility

The ash and ash water may be classified as dangerous goods.

The length of the pipelines is not likely to exceed 1000m but this will be confirmed in the EIA phase.

15 The ashing facility will be approximately 70ha

984 The clearance of an area of 20 hectares or more of indigenous vegetation, excluding where such clearance of indigenous vegetation is required for—

(i) the undertaking of a linear activity; or

(ii) maintenance purposes undertaken in accordance with a maintenance management plan.

Up to 120 hectares of vegetation will need to be cleared for the ash disposal facility.


984 The development of a dam where the highest part of the dam wall, as measured from the outside toe of the wall to the highest part

A return water dam will be constructed for the project. The highest part of the dam


of the wall, is 5 metres or higher or where the high-water mark of the dam covers an area of 10 hectares or more.

wall will be confirmed in the EIA phase.

By the time the EIA phase commences it will be confirmed if the dam wall will be less than 5 m or cover less than 10 ha.

2 Exact extent of CBA areas affected to be confirmed n EIA phase.

985 The development of reservoirs for bulk water supply with a capacity of more than 250 cubic metres.

f. Mpumalanga

(dd) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans.

Parts of site fall potentially fall within CBA areas identified in the Mpumalanga Biodiversity Sector Plan.

4 Linear activity.

The length of new roads required will be confirmed in EIA phase. The extent of CBA areas affected to be confirmed n EIA phase.

985 The development of a road wider than 4 metres with a reserve less than 13,5 metres.

f. Mpumalanga

(ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans.

The construction of access roads for the construction and or long-term servicing of all planned infrastructure for the project will be required. Parts of site fall potentially fall within CBA areas identified in the Mpumalanga Biodiversity Sector Plan.


985 The development of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres.

f. Mpumalanga




985 1. The development of—

(iv) dams, where the dam, including infrastructure and water surface area exceeds 10 square metres in size;



where such development occurs—

(f) Mpumalanga:

ii. Outside urban areas, in:

(ff) Critical biodiversity areas or ecosystem service areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans;


985 The widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre.

(a) Mpumalanga::

ii. Outside urban areas, in:



3.2.3 NATIONAL WATER ACT

The National Water Act, 1998 (Act 36 of 1998) (NWA) makes provision for two types of application for water use

licences, namely individual applications and compulsory applications. The NWA also provides that the

responsible authority may require an assessment by the applicant of the likely effect of the proposed licence on

the resource quality, and that such assessment be subject to the EIA regulations. A person may use water, if the

use is-

• permissible as a continuation of an existing lawful water use (ELWU);

• permissible in terms of a general authorisation (GA);

• permissible under Schedule 1; or

• authorised by a licence (i.e.: a Water Use Licence (WUL).

The NWA defines 11 water uses. A water use may only be undertaken if authorised. Water users are required to

register certain water uses that actually took place on the date of registration, irrespective of whether the use

was lawful or not.

Section 21 of the National Water Act 1998 lists the following 11 water uses which can only be legally undertaken

through the water use authorisation issued by the Department of Water and Sanitation (DWS):

(a) taking water from a water resource;

(b) storing water;

(c) impeding or diverting the flow of water in a watercourse;

(d) engaging in a stream flow reduction activity contemplated in section 36;

(e) engaging in a controlled activity identified as such in section 37(1) or declared under section 38(1);


(f) discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduits;

(g) disposing of waste in a manner which may detrimentally impact on a water resource;

(h) disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process;

(i) altering the bed, banks, course or characteristics of a watercourse;

(j) removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity or for the safety of people; and

(k) using water for recreational purposes.

Table 9: Identified water uses.

Applicable Legislation and Guidelines Description of activity

Section 21 (a) Taking water from a water resource

Borehole water abstraction during construction / operation

Section 21 (b) Storing of water

To be confirmed

Section 21 (c) Impeding or diverting the flow of water in a water course.

Linear infrastructure (roads, pipelines, and conveyor belts) crossing

streams and streams associated with wetlands (culverts, causeways,

bridges).

Section 21 (d) Engaging in a stream flow reduction activity contemplated in Section 36 of the Act.

To be confirmed.

Section 21 (f) Discharging waste or water containing waste into a water resource.

To be confirmed.

Section 21 (g) Disposing of waste in a manner which may impact on a water resource.

Storage of contaminated water in a pollution control dam / balancing

dam / evaporation dam.

Section 21 (h) Disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process.

To be confirmed


Section 21 (i) Altering the bed, banks, course, or characteristics of a watercourse. This includes altering the course of a watercourse (previously referred to as a river diversion).

Linear infrastructure (roads, pipelines, power lines, and conveyor belts)

crossing streams and streams associated with wetlands (culverts,

causeways, bridges).

Section 21 (j) Removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity, or for the safety of people.

To be confirmed

3.2.4 NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT

The National Environmental Management: Air Quality Act (NEMAQA) is the main legislative tool for the

management of air pollution and related activities. The Object of the Act is:

a) to protect the environment by providing reasonable measures for-

i. the protection and enhancement of the quality of air in the republic;

ii. the prevention of air pollution and ecological degradation; and

iii. securing ecologically sustainable development while promoting justifiable economic and social development; and

b) Generally, to give effect to Section 24(b) of the constitution in order to enhance the quality of ambient air for the sake of securing an environment that is not harmful to the health and wellbeing of people.

Section 21 of the NEMAQA allows that the Minister to publish a list of activities which may result in atmospheric

emissions and which may have a significant detrimental effect on the environment. The NEMAQA further

requires that no person may, without a provisional atmospheric emissions licence or an atmospheric emissions

licence conduct an activity which is listed in accordance with Section 21.

3.2.5 NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT

The National Environmental Management: Biodiversity Act (Act 10 of 2004)(NEMBA), ‘provides for: the

management and conservation of South Africa’s biodiversity within the framework of the NEMA; the protection

of species and ecosystems that warrant national protection; the sustainable use of indigenous biological

resources; the fair and equitable sharing of benefits arising from bio-prospecting involving indigenous biological

resources; the establishment and functions of a South African National Biodiversity Institute (SANBI); and for

matters conducted therewith”.

In terms of the Biodiversity Act, the applicant has a responsibility for:

• The conservation of endangered ecosystems and restriction of activities according to the categorization

of the area (not just by listed activity as specified in the EIA regulations);

• Promote the application of appropriate environmental management tools in order to ensure integrated

environmental management of activities thereby ensuring that all development within the area are in

line with ecological sustainable development and protection of biodiversity; and

• Limit further loss of biodiversity and conserve endangered ecosystems.


Regulations published under the NEMBA also provide a list of protected species, according to the Act (GN R. 151

dated 23 February 2007, as amended in GN R. 1187 dated 14 December 2007). Section 57 of NEMBA identifies

restricted activities involving threatened or protected species. Restricted activities include the gathering,

collecting, cutting, uprooting, damaging or destroy a listed species.

3.2.6 NATIONAL ENVIRONMENTAL MANAGEMENT: PROTECTED AREAS ACT

The National Environmental Management: Protected Areas Act (Act 57 of 2003) serves to: “provide for the

protection and conservation of ecologically viable areas representative of South Africa’s biological biodiversity

and its natural landscapes and seascape; for the establishment of a national register of all national, provincial

and local protected areas; for the management of those areas in accordance with national norms and standards;

for intergovernmental co-operation and public consultation in matters concerning protected areas; for the

continued existence, governance and functions of South African National Parks; and for matters in connection

therewith.

The objectives of this Act are –

a) to provide, within the framework of the national legislation, including the National Environmental Management Act, for the declaration and management of protected areas;

b) to provide for co-operation governance in the declaration and management of protected areas;

c) to effect a national system of protected areas in South Africa as part of a strategy to manage and conserve its biodiversity;

d) to provide for a diverse and representative network of protected areas on state land, private land, communal land and marine water;

e) to promote sustainable utilisation of protected areas for the benefit of people, in a manner that would preserve the ecological character of such areas;

f) to promote participation of local communities in the management of protected areas, when appropriate; and

g) to provide for the continued existence of South African National Parks.

3.2.7 NATIONAL HERITAGE RESOURCES ACT

The National Heritage Resources Act (NHRA) stipulates that cultural heritage resources may not be disturbed

without authorization from the relevant heritage authority. Section 34(1) of the NHRA states that, “no person

may alter or demolish any structure or part of a structure which is older than 60 years without a permit issued

by the relevant provincial heritage resources authority…”

The NEMA 23(2)(b) states that an integrated environmental management plan should, “…identify, predict and

evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage”.

A study of subsections (23)(2)(d), (29)(1)(d), (32)(2)(d) and (34)(b) and their requirements reveals the

compulsory inclusion of the identification of cultural resources, the evaluation of the impacts of the proposed

activity on these resources, the identification of alternatives and the management procedures for such cultural

resources for each of the documents noted in the Environmental Regulations. A further important aspect to be

taken account of in the Regulations under NEMA is the Specialist Report requirements laid down in Section 33

(Fourie, 2008b).

In accordance with the legislative requirements and EIA rating criteria, the regulations of the South African

Heritage Resources Agency (SAHRA) and Association of Southern African Professional Archaeologists (ASAPA)

have also been incorporated to ensure that a comprehensive and legally compatible heritage impact report is

compiled.

3.2.8 NATIONAL CONSERVATION ACT

The Environment Conservation Act (Act 73 of 1989) (ECA) was, prior to the promulgation of the NEMA, the

backbone of environmental legislation in South Africa. To date the majority of the ECA has been repealed by


various other Acts, however Section 25 of the Act and the Noise Regulations (GN R. 154 of 1992) promulgated

under this section are still in effect. These regulations serve to control noise and general prohibitions relating to

noise impact and nuisance.

3.2.9 CONSTITUTION OF SOUTH AFRICA

Section 24 of the Constitution states that everyone has the right to an environment that is not harmful to their

health or well-being; and to have the environment protected, for the benefit of present and future generations,

through reasonable legislative and other measures that:

• Prevent pollution and ecological degradation;

• Promote conservation; and

• Secure ecologically sustainable development and use of natural resources while promoting justifiable

economic and social development.

The public’s right to be involved in decisions that may affect them is enshrined in the South African Constitution.

Section 57(1) of the new Constitution provides that: “The National Assembly may (b) make rules and orders

concerning its business, with due regard to representative and participatory democracy, accountability,

transparency and public involvement”.

This provision, along with several others gave rise to many new trends in South African legislation. In

environmental legislation, the idea of public participation (or stakeholder engagement) features strongly and

especially the National Environmental Management Act (Act No. 107 of 1998 - NEMA) and the recent regulations

passed under the auspices of this Act makes very strict provisions for public participation in environmental

decision-making.

Public participation can be defined as “a process leading to a joint effort by stakeholders, technical specialists,

the authorities and the proponent who work together to produce better decisions than if they had acted

independently" (Greyling, 1999, p. 20). From this definition, it can be seen that the input of the public is regarded

as very important indeed.

3.2.10 MINERALS AND PETROLEUM RESOURCES DEVELOPMENT ACT (ACT NO. 28 OF 2002)

A mining permit or mining right may be required where a mineral in question is to be mined (e.g. materials from

a borrow pit) in accordance with the provisions of the Act. Requirements for Environmental Management

Programmes and Environmental Management Plans are set out in S39 of the Act. As no borrow pits are expected

to be required for the construction of the facility, no mining permit or right is required to be obtained.

3.3 OTHER APPLICABLE ACTS, POLICIES AND PROGRAMMES

A summary of other applicable acts, policies and programmes is provided in Table 10.

Table 10: Summary of policies and programmes

Policy/Programme Objectives

WHITE PAPER ENERGY POLICY This policy aims to clarify government policy regarding the supply and consumption of energy for the next decade. It promotes the development of underdeveloped systems in certain areas and demonstrates a resolve to bring about extensive change in several areas. The White paper provides an overview of the of the energy sectors contribution to the GDP, employment, taxes and the balance of payments.

Part 3 and Part 4 of the policy contain sections involving the management of the environment.


Sections 8.1, 8.3 and 8.4 focus on Integrated energy planning, energy efficiency and environment, health and safety respectively.

INTEGRATED ENVIRONMENTAL MANAGEMENT INFORMATION GUIDELINE SERIES:

• GUIDELINE 4: STRATEGIC ENVIRONMENTAL ASSESSMENT.

• GUIDELINE 7: PUBLIC PARTICIPATION.

GUIDELINE 9: NEED AND DESIRABILITY.

Department of Environmental Affairs developed these guidelines as a tool to assist with the various environmental aspects of a development.

MUNICIPAL IDP AND SDF DOCUMENTS Integrated Development Plans and Spatial Development Frameworks of the local municipality are reviewed and presented as part of the scoping and EIA reports.

BEST PRACTISE GUIDELINE (G1) STORMWATER MANAGEMENT DWS2006

Provides guidelines to the management of stormwater.

SOUTH AFRICAN WATER QUALITY GUIDELINES

Provides water quality guidelines.

SANS 10210: CALCULATING AND PREDICTING ROAD TRAFFIC NOISE

Provides guidelines for traffic noise levels.

SOUTH AFRICAN NATIONAL STANDARD (SANS) 69

Framework for setting and implementing national ambient air quality standards.

NATIONAL VELD AND FOREST FIRE ACT (ACT 101 OF 1998)

While no permitting or licensing requirements arise from this legislation, this act will find application during the operational phase of the project in terms of fire prevention and management.

3.4 PROPOSED LEGISLATION

Certain proposed legislation which may come into effect during of after the EIA process may have implications

for the Arnot ADF. These are described below”

Proposed Legislation Implications for project

NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT (ACT 59 of 2008)

Proposed regulations to exclude a waste stream or a portion of a waste stream from the definition of waste (January 2018)

List of waste stream or portion of waste stream excluded

from the definition of waste: according to the proposed

regulations ash from combustion and gasification processes

may be permitted to be used as backfill in old mine

workings. Considering the proximity to the mines in the area

it may be option to dump some of the ash in the old mine

voids (if feasible). This would affect future volumes required

to be catered for in the ADF.


4 PUBLIC PARTICIPATION PROCESS (PPP)

This section presents a summary of the various components pertaining to the Public Participation Process (PPP)

for the project. The Scoping Phase for the proposed Ash Disposal Facility at Arnot Power Station and associated

infrastructure has been undertaken in accordance with the EIA Regulations published in Government Notice

GN38282 of December 2014, in terms of Section 24(5) of NEMA (Act No. 107 of 1998 as amended). This chapter

serves to outline the Public Participation process that was undertaken.

4.1 AUTHORITY CONSULTATION

The National DEA is the competent authority for this application. A record of all authority consultation

undertaken is included within this Scoping report. Consultation with the regulating authorities (i.e. DEA and

Mpumalanga Department of Economic Development, Environment and Tourism) has continued throughout the

EIA process.

The following will be undertaken as part of this EIA process:

• Notification and Consultation with Organs of State that may have jurisdiction over the project, including

provincial and local government departments, and State-Owned Enterprises; and

• Provide an opportunity for DEA and Mpumalanga DEDET representatives to visit and inspect the

proposed site and the study area.

• Preliminary 30-day review period of the draft Scoping Report prior to submission of the application to

DEA;

• Submission of second draft Scoping Report to DEA for review and comment during the public review

period (30 days);

• Submission of final Scoping report to DEA for acceptance;

• Submission of the draft EIA Report to DEA for review and comment during the public review period (30

days);

• Submission of a final EIA Report to DEA following a public review period for the draft EIA (30 days);

A pre-application meeting was held with DEA on 25 October 2016 to discuss the timing constraints related to

the EIA process with DEA. EIMS highlighted that due to the time required to complete the detailed designs there

will be challenges in meeting the 106-day requirement to submit the EIA report. DEA recommended that where

possible due to the engineering constraints highlighted, the team can consider putting the Draft Scoping Report

out for a 30-day comment period before submitting an application to DEA so that any issues can be addressed

before the report is submitted to DEA. The scoping report will then subsequently be put out for another 30-day

review period once the application has been lodged with DEA.

4.2 STAKEHOLDER ENGAGEMENT

The public participation process has been undertaken in accordance with the requirements of the EIA

Regulations of December 2014. The PPP is a requirement of several pieces of South African Legislation and aims

to ensure that all relevant Interested and Affected Parties (I&APs) are consulted, involved and their comments

are taken into account, and a record of consultation included in the reports submitted to authorities. The PPP

ensures that stakeholders are provided the opportunity to be involved as part of a transparent process which

allows for a robust and comprehensive environmental study. The PPP for the proposed Arnot Ash Disposal

Facility project needs to be managed according to best practises in order to ensure and promote the following:

• Compliance with international best practice options;

• Compliance with national legislation;


• Establish and manage relationships with key stakeholder groups; and

• Encourage involvement and participation in the environmental study and authorisation/approval

process.

As such, the purpose of the PPP and stakeholder engagement process is to:

• Introduce the proposed project;

• Explain the environmental authorisations required;

• Explain the environmental studies to be undertaken (where applicable);

• Determine and record issues, concerns, suggestions, and objections to the project;

• Provide opportunity for input and gathering of local knowledge;

• Establish and formalise lines of communication between the I&AP’s and the project team;

• Identify all significant issues for the project; and

• Identify possible mitigation measures or environmental management plans to minimise and/or prevent

negative environmental impacts and maximize and/or promote positive environmental impacts

associated with the project.

EIMS intends to undertake a Stakeholder Engagement Process in order to satisfy the requirements for public

involvement in terms of the NEMA. The process that is to be followed will consist of the following key steps:

• A BID (this document) has been compiled;

• A Scoping Report will be compiled in order to provide a baseline for the receiving environment. The

Scoping Report will aim to present all information in a clear and understandable format and suitable

for easy interpretation by I&APs and authorities. The preliminary scoping report will be released for

public review for a 30-day period during the call to register. At this time there will be and initial

notification and call to register for I&AP’s through the following means: Newspaper Advertisements,

Site Notices, Registered Letters, E-mails and Faxes with an aim to inform all I&AP’s of the proposed

project and encourage comment and feedback to be incorporated into the Scoping and EIA Reports -

as well as to invite I&AP’s to register for further involvement on the process;

• The Scoping Report for public review will then be released for another 30-day review and comment

period once the EIA application has been submitted to DEA.

• The I&AP database will be updated on an ongoing basis throughout the consultation process;

• All comments received will be included in the final Scoping Report and forwarded to the DEA for

consideration;

• Upon receipt of the DEA’s acceptance of the Scoping Report, the EIA phase will commence.

• An EIA Report will then be compiled integrating all specialist studies and other relevant information

obtained during the PPP to date. The EIA Report will aim to present all information in a clear and

understandable format and suitable for easy interpretation by I&APs and authorities;

• The EIA Report (for public review) will be released for a 30-day review and comment period. All

comments received will be included in the final EIA Report and forwarded to the DEA for consideration;

• EIMS will continue with on-going consultation with I&AP’s during the entire process in order to provide

all I&AP’s with the opportunity to comment on the proposed project prior to submission of the Scoping

and EIA Reports to the Relevant Authorities and Government Departments.


• Once a decision on the project has been reached all I&APs will be notified of the departments’ decision

as well given the opportunity to appeal the decision.

4.3 METHODOLOGY

The PPP for the proposed Arnot Ash Disposal Facility project has been undertaken in accordance with the

requirements of the NEMA, in line with the principles of Integrated Environmental Management (IEM). IEM

implies an open and transparent participatory process, whereby stakeholders and other I&APs are afforded an

opportunity to comment on the project.

4.3.1 IDENTIFICATION OF I&APS

An initial I&AP database has been compiled from Windeed searches as well as information from previously

conducted EIA projects, particularly those that were in the vicinity of the proposed project. The I&AP database

includes amongst others landowners, organs of state, communities, regulatory authorities, and other specialist

interest groups. Below is a summary of the various entities identified and to be consulted with during scoping

and they include the following broad groups:

• Authorities, including ward councillors, etc.

• Key stakeholders, including:

o Land owners of the properties associated with the application.

o Owners and custodians of existing infrastructure within the study area.

o Adjacent land owners and land users.

o Surrounding communities.

o Non-Governmental Organisations (NGO’s).

• Potential sensitive receptors.

• I&APs who express an interest in the project.

These I&APs have been and will continue to be consulted throughout the EIA process of the proposed project.

Furthermore, all I&APs (including new I&APs and those who have already registered) are encouraged through

advertisements (newspaper and on-site notices), written correspondence, and consultation meetings to

participate in the process.

4.3.2 AFFECTED LANDOWNERS

All the affected properties were identified and included in the project database as pre-identified I&APs. All

landowners will be notified of the EIA process by means of a letter and Background Information Document (BID).

Site notices and posters will be placed within and around the study area and in public venues to ensure that

occupiers and other community members will be notified about the project.

4.3.3 AUTHORITIES AND ORGANS OF STATE

The following Government Authorities were notified of the proposed project:


• Nkangala District Municipality;

• Steve Tshwete Municipality;

• Mpumalanga Department of Economic Development, Environment and Tourism

• Mpumalanga Department of Labour;

• Mpumalanga Department of Mineral Resources;

• Mpumalanga Department of Social Development;

• Mpumalanga Department of Public Works and Infrastructure;

• Mpumalanga Department of Police, Roads and Transport;

• Department of Water and Sanitation;

• South African National Road Agency Limited

• Catchment Management Agency;

• National Department of Agriculture, Forestry and Fisheries;

• National Development Agency;

• National Commission on Restitution on Land Rights

• National Department of Rural Development;

• National Energy Regulator of South Africa (NERSA)

• Transnet.

4.3.4 INITIAL NOTIFICATION OF I&APS

The PPP commenced on the 13th July 2018 with an initial notification and call to register; and ended on the 13th

August 2018. Initial notification was given in the following manner:

4.3.4.1 REGISTERED LETTERS, FAXES AND EMAILS

Notification letters (English and Afrikaans,), faxes, and emails were distributed to all pre-identified key I&APs

including government organisations, landowners, NGOs, relevant municipalities, ward councillors, and other

organisations that might be affected.

The initial notification letter will include the following information:

• List of anticipated activities to be authorised;

• Scale and extent of activities to be authorised;

• Sufficient detail of the intended operation to enable I&APs to assess/surmise what potential impacts

the proposed activities may have on them or on the use of their land;

• The purpose of the proposed project;

• Details of the affected properties (including a locality map);

• Details of the NEMA regulations that must be adhered to;


• Date by which any request to register as an I&AP must be forwarded through to EIMS; and

• Contact details of the EAP.

In addition, a registration sheet/ questionnaire was included in the registered letters, emails and facsimiles to

landowners towards facilitating registration and soliciting input on local knowledge of the study area.

4.3.4.2 BACKGROUND INFORMATION DOCUMENT

A Background Information Document (BID) in English was prepared and distributed by post with the registered

letter and made available on the EIMS website (www.eims.co.za). The BID contains the following information:

• Project Name;

• Applicant name;

• Project location;

• Map of affected project area;

• Description of the application process;

• Information on document review;

• A detailed questionnaire;

• I&AP registration form; and

• Relevant EIMS contact person for the project.

4.3.4.3 NEWSPAPER ADVERTISEMENTS

Adverts and site notices will be placed during the scoping phase.

4.3.4.4 PRELIMINARY SCOPING REPORT

The preliminary scoping report will be released for comment along with the initial notification to I&APs.

4.3.5 SCOPING REPORT REVIEW

Notification regarding the availability of this Scoping Report for public review has been given in the following

manner:

• Registered letters with details on where the scoping report is available from, as well as the public review

comment period, were distributed to all registered I&APs (which includes key stakeholders and

landowners);

• Facsimile notifications with information similar the that in the registered letter described above, were

distributed to all registered I&APs; and

• Email notifications with a letter attachment containing the information described above were also

distributed to all registered I&APs.

The Scoping Report will be made available for public review from the 13h of July 2018 until the 13th of August

2018, for a 30-day comment period. As discussed in the pre-application meeting with DEA it was recommended

that, where possible due to the engineering constraints highlighted, the team can consider putting the Draft

Scoping Report out for a 30-day comment period along with the initial call to register, before submitting any

application to DEA so that any issues can be addressed prior to application submission. This is the current scoping

report review period. Hereafter the scoping report will be revised and a second Scoping Report (revised where

necessary) will be released along with submission of the EIA application form to the DEA. The 2nd draft scoping

report will also be released for another 30-day review period.


4.3.6 PUBLIC MEETING AND OPEN DAY

Details regarding the public meeting and open day will be included in the notification regarding the availability

of the scoping report for public review. The details include the date, time and venue for the meeting and open

day. The notifications are to be distributed via registered letter, facsimile, and email, all registered I&APs.

The public meeting attendance register, as well as the minutes of the public meeting will be included in the

Scoping Report submitted to the competent authority. I&APs who attend the meeting will be registered for the

project through the attendance register which will be available at the public meeting.


5 DESCRIPTION OF RECEIVING ENVIRONMENT

This chapter provides information about baseline environment for the proposed Ash Disposal Facility at Arnot.

Information in this section was sourced from the specialist scoping reports which are included as appendices to

this Scoping Report.

The site lies between 1 600 and 1 730 metres above sea level, with the highest point near the north-eastern

boundary. From the baseline 1:50 000 scale topo-cadastral map, the terrain falls gently to the south-west, with

slopes of between 2% and 5%. The area is drained by the Rietkuil Spruit and Bosman Spruit, which flow generally

from east to west.

5.1 CLIMATE

The climate of the study area (Koch, 1987) can be regarded as warm to mild, with rain in summer and dry winters.

The long-term average annual rainfall in this region is 720 mm, of which 610.79 mm, or 85%, falls from November

to April. The total annual evaporation is approximately 1 830 mm per year, peaking at approximately 6.4 mm

per day in December. The study area has warm summers and cold winters. Frost is a common phenomenon with

13-42 days of frost per year and the coldest periods (usually from June to August) are exacerbated by seasonal

aridity. The daily minima for the coldest months are below freezing. Rainfall is concentrated from November to

April, which constitutes the growing season for vegetation and plant species.

Temperatures vary from an average monthly maximum and minimum of 25.0ºC and 12.5ºC for January to 16.7ºC

and 0.2OC for July respectively. The extreme high temperature that has been recorded is 35.6oC and the extreme

low –11.1ºC. Frost occurs most years on around 25 days on average between mid-May and early September.

5.2 GEOLOGY AND TOPOGRPAHY

5.2.1 GEOLOGY

The sites are underlain by the Ecca Formation of the Karoo Supergroup. The formation consists of shale, shaly

sandstone, grit, sandstone and conglomerate. Coal occurs in places near the base and top of the Formation

(refer to Figure 6Error! Reference source not found.).


Figure 6: Geological Map


Figure 7: Topographical Map


5.2.2 TOPOGRAPHY

The study site is generally flat to gently undulating. The Rietkuilspruit and Bosman Spruit are the main drainage

systems in the study area, along with a number of smaller tributaries of the Klein Olifants River. There are no

significant hills or ridges in the study area.

The area varies in elevation from approximately 1580 to 1750 m above sea level with the highest point being in

the north-eastern part of the study area and the lowest point on the western boundary in the Rietkuilspruit. A

topographic map is provided in Figure 7.

5.3 LAND USE AND LAND COVER

It is not possible to provide a detailed land capability map, as the specific distribution within the study area must

be established by means of a more detailed survey, which will be conducted during the EIA/EMP phase of the

environmental study. However, it can be expected that, if the soil distribution from the land type survey

(Schoeman & Fitzpatrick, 1979) is found to occur, the prevailing land capability within the study area would be

approximately:

• Arable: + 60%

• Grazing: + 25%

• Wetland: + 10%

• Wilderness: <2%

Within the Arable class, it can be also expected that the land capability will vary and that certain soils will have

a higher potential for arable cultivation than others. However, it is common practice on the highveld that in most

cases, where the soil is deep enough and has favourable enough properties to cultivate, it is generally done. In

the vicinity of the study area, it can be predicted that grazing capacity will be relatively high, around 6-8 ha per

large stock unit (Schoeman & van der Walt, 2004). This classification does not apply to game farming, where

more detailed specialized knowledge is required, mainly in terms of relating plant species composition in both

the grass layer and woody layer to the requirements of various grazing and/or browsing species of game.

Arnot Power Station can be accessed via access roads westwards from the N11 (running from Middelburg to

Hendrina), northwards from the N4 (between Middelburg and Belfast) or eastwards from the R33 (between the

N4 and Carolina). There are various other main, district and farm roads passing through various parts of the

broad study area


Figure 8: Land cover of the study area (areas within 5km of Arnot Power Station)


5.4 ECOLOGY

5.4.1 FLORA

According to the most recent vegetation map of the country (Mucina & Rutherford 2006) the study area is

dominated by Eastern Highveld Grassland, with large pans being characterised by Eastern Temperate Freshwater

Wetlands (Mucina & Rutherford 2006). An indication of the regional vegetation types in relation to the study

area is shown in Figure 5. A brief description of each regional vegetation type that is likely to occur on site is

provided below. Full descriptions can be found in Mucina et al. (2005).

Eastern Highveld Grassland

This vegetation type is found in Mpumalanga and Gauteng Provinces: Plains between Belfast in the east and the

eastern side of Johannesburg in the west and extending southwards to Bethal, Ermelo and west of Piet Retief.

Altitude 1 520–1 780 m, but also as low as 1 300 m.

The vegetation landscape is usually location in a landscape of slightly to moderately undulating plains, including

some low hills and pan depressions. The vegetation is short dense grassland dominated by the usual highveld

grass composition (Aristida, Digitaria, Eragrostis, Themeda, Tristachya, etc.) with small, scattered rocky outcrops

with wiry, sour grasses and some woody species (Acacia caffra, Celtis africana, Diospyros lycioides subsp lycioi-

des, Parinari capensis, Protea caffra, P. welwitschii and Rhus magalismontanum).

Eastern Temperate Freshwater Wetlands

This vegetation types if found in the Northern Cape, Eastern Cape, Free State, North-West, Gauteng,

Mpumalanga and KwaZulu-Natal Provinces as well as in neighbouring Lesotho and Swaziland: Around water

bodies with stagnant water (lakes, pans, periodically flooded vleis, edges of calmly flowing rivers) and embedded

within the Grassland Biome. Altitude ranging from 750–2 000 m.

The vegetation features are flat landscapes or shallow depressions filled with (temporary) water bodies

supporting zoned systems of aquatic and hygrophilous vegetation of temporarily flooded grasslands and

ephemeral herblands.

The vegetation type is typically found on younger Pleistocene to recent sediments overlying fine-grained

sedimentary rocks of the Karoo Supergroup (on sediments of both Ecca and Beaufort Groups due to the large

extent of the area of occurrence) as well as of the much older dolomites of the Malmani Subgroup of the

Transvaal Supergroup in the northwest. Especially the areas built by Karoo Supergroup sediments are associated

with the occurrence of Jurassic Karoo dolerite dykes having a profound influence on run-off. Soils are peaty

(Champagne soil form) to vertic (Rensberg soil form). The vleis form where flow of water is impeded by

impermeable soils and/or by erosion resistant features, such as dolerite intrusions. Many vleis and pans of this

type of freshwater wetlands are inundated and/or saturated only during the summer rainfall season, and for

some months after this into the middle of the dry winter season, but they may remain saturated all year round.

Surface water inundation may be present at any point while the wetland is saturated and some plant species

will be present only under inundated conditions, or under permanently saturated conditions. The presence of

standing water should not be taken as a sign of permanent wet conditions.

Conservation status of vegetation types

Driver et al. (2005) classified regional vegetation types into ecosystem status on the basis of rates of

transformation and conservation (Table 1). The dominant vegetation types occurring in the study area (Eastern

Highveld Grassland) is classified as Endangered (Table 2). In this regional vegetation type, the amount of

transformation is relatively high, and less than 1% of the vegetation type is conserved (Table 2).

Eastern Highveld Grassland is listed as Vulnerable in the National List of Ecosystems that are Threatened and

need of protection (GN1002 of 2011), published under the National Environmental Management: Biodiversity

Act (Act No. 10, 2004).

Eastern Temperate Freshwater Wetlands vegetation type is classified as Least Threatened in the scientific

literature (Driver et al. 2005, Mucina et al. 2005) (Table 2) and is not listed in the National List of Ecosystems


that are Threatened and need of protection (GN1002 of 2011), published under the National Environmental

Management: Biodiversity Act (Act No. 10, 2004).

Table 11: Conservation status of different vegetation types occurring in the study area.

Vegetation Type Target

(%)

Conserved

(%)

Transformed

(%)

Conservation status

Driver et al. 2005 National

Environmental:

Biodiversity Act

Eastern Highveld

Grassland

24 0.3 44 Endangered Vulnerable

Eastern Temperate

Freshwater Wetlands

24 4.6 15 Least Threatened Not listed

There are four species listed as Vulnerable, two as Near Threatened and three as Declining that could occur in

the study area in habitats that may be present on site.

Gladiolus paludosus, listed as Vulnerable, is found in wetlands or marshes in high altitude grasslands from

Witbank to Lydenburg and southwards to Piet Retief and Wakkerstroom. It has been previously recorded just

north of Klippan and there is a possibility that suitable habitat may occur in other areas nearby.

Khadia carolinensis, listed as Vulnerable, is found in well-drained, sandy-loam soils among rock outcrops or at

the edge of sandstone sheets in the Carolina and Belfast region. It has been previously recorded close to Arnot

Power Station within the study area and there is a high probability of it occurring in the study area, if suitable

habitat occurs there.

Miraglossum davyi, listed as Vulnerable, is found in grassland in the area between Middelburg, Dullstroom and

Standerton. The study area is in the centre of this distribution range.

Bowiea volubilis var. volubilis, listed as Vulnerable, is found in low and medium altitudes in summer rainfall areas

and has a probability of occurring in the study area. The total distribution range of this widespread species (which

occurs throughout Africa) overlaps with the study area and suitable habitat possibly occurs on site.

Two species listed as Near Threatened could occur in the study area, one that is widely distributed (Merwilla

plumbea), and the other that occurs in habitat that is found in the study area (Gladiolus robertsoniae). These

two species also have a moderate probability of being found in the study area.

Three additional species of conservation concern, listed as Declining, have a high probability of occurring on site.

These species are Boophane disticha, Eucomis autumnalis and Hypoxis hemerocallidea, all three of which are

widespread plants.

One protected tree species could be found on site or nearby, namely Pittosporum viridiflorum.

5.4.2 TERRESTRIAL FAUNA

Mammals

A total of 118 mammal species have a geographical distribution that includes the general study area in which

the site is found (Friedmann & Daly 2004, Mills & Hes 1997). Fifteen of the species with a geographical

distribution that includes the site have been listed in the Red Data Book of the Mammals of South Africa

(Friedmann & Daly 2004). These species are as follows: Oribi, Cheetah, Brown Hyaena, Serval, Spotted-necked

Otter, Honey Badger, Percival's Short-eared Trident Bat, Natal long-fingered Bat, Temminck's Myotis,

Welwitsch’s Myotis, Rusty Pipistrelle, Blasius's Horseshoe Bat, Swinny's Horseshoe Bat, South African Hedgehog

and Temminck's Ground Pangolin.


Of the species currently listed as threatened or protected, those listed in Table 5.2 are considered to have a

medium to high probability of occurring on site and being potentially negatively affected by proposed activities

on site.

There are a number of bats that have a geographical distribution that includes the study area, some only

marginally. All these species depend on caves for roosting. They are therefore unlikely to be found on site other

than during foraging excursions, except at specific potential roosting sites. Activities on site are therefore highly

unlikely to have any negative effect on any of these species.

Table 12: Mammal species of conservation concern with a likelihood of occurring in the study area.

Scientific name Common name Status

Hyaena brunnea Brown hyaena Near Threatened, protected

Leptailurus serval Serval Near Threatened, protected

Hydrictus (Lutra) maculicollis Spotted-necked Otter Near Threatened, protected

Aterelix frontalis South African Hedgehog Near Threatened

Miniopterus natalensis Natal Long-fingered Bat Near Threatened

Amphibians

A total of 19 frog species have a geographical distribution that includes the general study area in which the site

is found (Du Preez & Carruthers 2009). Some of these species are only marginally present in the study area due

to the fact that their distribution range ends close to the study area. Of the frog species that could potentially

occur in the study area, none are listed in a threat category, but the Giant Bullfrog, previously listed as Near

Threatened, is protected.

The site contains habitat that is suitable for various frog species, although only one species of conservation

concern is likely to occur in the study area.

Table 13: Amphibian species of conservation concern with a likelihood of occurring in the study area.


Pyxicephalus adspersus Giant Bullfrog Protected

Reptiles

A total of 65 reptile species have a geographical distribution that includes the general study area in which the

site is found (Alexander & Marais 2007, Bates et al. 2014, Branch 1988, Marais 2004, Tolley & Burger 2007). Of

the reptile species that could potentially occur in the study area, Breyer's Long-tailed Seps, listed as Vulnerable,

and the Coppery Grass Lizard, Large-scaled Grass Lizard and Striped Harlequin Snake, all listed as Near

Threatened, have been listed in a threat category. The Coppery Grass Lizard (Chamaesaura aenea), listed as Near

Threatened, occurs in western Swaziland, Limpopo, Mpumalanga, Gauteng, KwaZulu-Natal (associated with the

Drakensberg), northeastern Free State.

There are therefore three reptile species of conservation concern that could potentially occur in the study area

and that may therefore be affected by the proposed project, as shown in Table 14.

Table 14: Reptile species of conservation concern with a likelihood of occurring in the study area.


Chamaesaura aenea Coppery Grass Lizard Near Threatened


Tetradactylus breyeri Breyer's Long-tailed Seps Vulnerable

Homoroselaps dorsalis Striped Harlequin Snake Near Threatened

5.4.3 BIRDS

A total of 320 bird species have a geographical distribution that includes the general study area in which the site

is found (Chittenden 2007). A total of 189 of these species have been recently recorded in the grid (SABAP2).

This includes a wide variety of species from different groups (see Appendix 3) and occurring in different types of

habitats. The habitat on site is only potentially suitable for a smaller number of these species and not all would

be expected to be found there.

A total of 27 of the bird species with a geographical distribution that includes the site are listed in "The 2015

Eskom Red Data Book of Birds of South Africa, Lesotho and Swaziland" (Taylor et al. 2015) and/or on the IUCN

Red List (www.iucnredlist.org). Twelve of these are listed as Near Threatened, nine as Vulnerable and six as

Endangered. The Endangered species are Ludwig's Bustard, Martial Eagle, African Marsh Harrier, Black Harrier,

Yellow-billed Stork and Cape Vulture. The Vulnerable species are Burchell's Courser, Verreaux's Eagle, Lanner

Falcon, African Grass Owl, Great White Pelican, Pink-backed Pelican, Secretarybird, Black Stork and Caspian Tern.

It is concluded that the site contains habitat that is suitable for various bird species of conservation concern.

Those that are potentially significantly vulnerable to proposed activities in the study area are as follows:

• African Marsh Harrier (EN),

• Yellow-billed Stork (EN),

• Burchell's Courser (VU),

• African Grass Owl (VU),

• Secretarybird (VU),

• Black Stork (VU),

• Maccoa Duck (NT),

• Red-footed Falcon (NT),

• Greater Painted Snipe (NT),

• Black-winged Pratincole (NT).

Important Bird Areas

The site does not fall within any Important Bird Area, as defined by BirdLife South Africa, but is in close proximity

to two of them. The closest IBA is 4 km to the north-east, the Steenkampsberg IBA. Further south, approximately

16 km away, is the Amersfoort-Bethal-Carolina IBA. The site is therefore wedged between two large IBAs.

5.4.4 ASPECT MANAGEMENT PLANS FOR THE AREA

There are two biodiversity management plans for Mpumalanga Province, the earlier version called the

Mpumalanga Biodiversity Conservation Plan (MBCP) and the more recent version called the Mpumalanga

Biodiversity Sector Plan.

The Mpumalanga Biodiversity Conservation Plan

The Mpumalanga Biodiversity Conservation Plan (MBCP) classifies the natural vegetation of the province

according to conservation value in decreasing value, as follows:

1. Protected


2. Irreplaceable

3. Highly significant

4. Important and necessary

5. Least concern

The two site options have different amounts of each conservation category within their broader borders.

According to the Mpumalanga Biodiversity Conservation Plan (MBCP), remaining areas of natural vegetation on

site within Alternative 1 are classified in all categories of the MBCP, except Protected, including a small area of

habitat classified as Irreplaceable (Figure 9). The areas of higher significance are scattered throughout the centre

of the Alternative 1 area and it may not be possible to avoid them by alternative placement of the infrastructure.

The remaining areas of natural vegetation on site within Alternative 2 are classified as Least Concern or No

natural habitat remaining.

Mpumalanga Biodiversity Sector Plan

The more recently compiled Mpumalanga Biodiversity Sector Plan (Mpumalanga Parks and Tourism Agency

2014) classifies the natural vegetation of the Province according to the following categories:

1. Protected Areas

2. Critical Biodiversity Areas

3. Other natural areas

4. Ecological Support Area

5. Modified.

According to this assessment, the study area contains areas within three categories, namely Modified Areas,

Other Natural Areas and Critical Biodiversity Areas (Figure 10). The most important CBA is associated with the

stream that runs across the northern parts of both site options. Another one is associated with the grasslands

around the pan that occurs in Alternative 2.


Figure 9: Parts of the study are in different categories of the MBCP.


Figure 10: Parts of the study area in different categories of the MBSP.


5.4.5 KEY SENSITIVITIES

There are features on site that need to be taken into account in order to evaluate sensitivity of the site and its

surroundings. These include the following:

1. Wetlands areas: There is a stream running through the study area and some small pans. The stream is

associated with a significant floodplain area. The pans sometimes have areas of grassland surrounding

them that forms part of the pan environment and may constitute a seepage area. The wetlands are

protected according to the National Water Act and constitute important ecological areas in terms of

hydrological processes and as refugia for species.

2. Natural vegetation: The major vegetation type of this region is Eastern Highveld Grassland, which is

listed as Endangered in the scientific literature and as Vulnerable according to the National List of

Ecosystems that are Threatened and need of protection (GN1002 of 2011), published under the

National Environmental Management: Biodiversity Act (Act No. 10, 2004). These remaining patches of

grassland have high conservation value.

Table 5: Sensitivity ratings for features in the study area and explanations for ratings assigned.

Feature Score Reason

Transformed areas

-1 These areas are already degraded, and the proposed project will not affect this current status. Over the long-term, there is the potential to rehabilitate following termination of the project, which could potentially improve the current status or at least be neutral.

Secondary areas

0 The project will not result in removal of vegetation, although some of the vegetation is considered to be secondary. This vegetation could potentially develop into something with biodiversity value over long periods of time, but this can also be achieved through rehabilitation after termination of the project and achieve the same end result. The project will therefore not affect the inherent feature status.

Natural areas in poor condition

0 The poor state of the vegetation means that it has already lost its intrinsic biodiversity value. The vegetation in these patches would require extensive rehabilitation efforts to improve it, which can also be achieved through rehabilitation after termination of the project and achieve the same end result. The project will therefore not affect the inherent feature status.

Secondary areas with important ecological functionality

+1 This relates primarily to wetland areas that were previously cultivated, but have since developed a secondary vegetation cover. The system still functions as a wetland, but has different species composition to what would be found in a natural wetland.

Natural areas +1 Natural areas of grassland are considered to have high intrinsic biodiversity value. If there is any loss or degradation of this habitat, the natural vegetation is only replaceable over periods of time that exceed human life-spans, which means that it is essentially permanently lost if it is removed. This further highlights the high value of these area for biodiversity retention.

Wetlands and pans

+2 The wetlands and associated vegetation is ecologically sensitive and has high intrinsic biodiversity value. The system is interconnected in a way where any damage could lead to changes to the entire ecosystem and the way it functions, including to downstream areas.

Natural areas within regional vegetation types

+2 Only small fragments of these remain. Due to the listing of this regional vegetation type as Endangered, all remaining fragments are considered to have irreplaceable biodiversity value.


classified as Endangered or in CBA areas

A sensitivity map based on these scores is provided below (Figure 11).


Figure 11: Location of sensitive habitats within the study area.


5.5 HERITAGE AND PALEONTOLOGY

The province of Mpumalanga is known to be rich in archaeological sites that tell the story of humans and their

predecessors in the region going back some 1,7 million years (Delius & Hay, 2009). The pre-colonial period is

divided broadly into the Stone Age and the Iron Age (Refer to Figure 1 for a visual representation of the human

time line).

The Stone Age refers to the earliest people of South Africa who relied mainly on stone for their tools and were

hunter-gatherers. This period is divided into the Earlier, Middle and Later Stone Age:

• Earlier Stone Age: The period from ± 2.5 million yrs. - ± 250 000 yrs. ago. Acheulean stone tools are

dominant.

• Middle Stone Age: Various stone tool industries in SA dating from ± 250 000 yrs. – 40 000 yrs. before

present.

• Later Stone Age: The period from ± 40 000 yrs. before present to the period of contact with either Iron

Age farmers or European colonists. (Delius & Hay, 2009; Morris, 2008)

The archaeological literature does not contain much information on the Stone Age archaeology of this area,

since this period has not been researched extensively in Mpumalanga (Esterhuysen & Smith, 2007). However, it

is clear from the general archaeological record that the larger Mpumalanga region has been inhabited by

humans since Earlier Stone Age (ESA) times. Although no Stone Age sites are known from the immediate vicinity

of the study area, there are some sites recorded in the greater region (Esterhuysen & Smith, 2007). Examples of

such sites are noted below.

Stone Age Sites

An Earlier Stone Age site is located at Maleoskop near Groblersdal. Concentrations of ESA stone tools were

found in erosion gullies along the Rietspruit (Esterhuysen & Smith, 2007). Evidence for the Middle Stone Age

(MSA) period has been excavated from Bushman Rock Shelter, situated on the farm Klipfonteinhoek in the

Ohrigstad District. The MSA layers indicated that the cave was visited repeatedly over a long period, between

approximately 40 000 years ago and 27 000 Before Present (Esterhuysen & Smith, 2007). Two Later Stone Age

(LSA) sites were found at the farm Honingklip near Badplaas in the Carolina District, (Esterhuysen & Smith, 2007).

Early Iron Age

Early farming communities moved into the Mpumalanga area around AD 500. These early farmers used metal

tools and pottery and lived in fairly permanent agricultural villages. The most well-known EIA site in the area is

the Lydenburg Heads site in the Sterkstroom Valley.

Late Iron Age

Late Farmer societies developed extensive stone settlements around Lydenburg, Badfontein, Sekhukhuneland,

Roossenekal and Steelpoort (Delius & Hay, 2009). The greater Belfast area specifically, is known for its large

complexes of LIA stonewalling. Although there was some early research on the stone ruins in the general region

of the then-named eastern Transvaal, systematic investigation of the ruins only began in the last decade (Collett,

1982). Evers (1975) and Mason (1968) both undertook surveys of aerial photographs of the general area and

identified a vast number of such settlements between Lydenburg and Machadodorp. Evers noted that

settlements are not evenly distributed over the area, largely for topographical reasons (1975). These settlements

typically consisted of three interrelated elements: homesteads, with cattle kraals surrounded by enclosures for

human habitation; stone-edged paths or roadways, probably for movement of cattle; and stone terraces, for

agricultural cultivation. Most of the homesteads were built in symmetrical patterns, some of which were

reproduced in rock engravings found close to these settlements (Delius and Hay; 2009).

With regard to dating, the beginning of the Late Iron Age in this region is obscure. At the time of Evers’ article

there were no sites known that were intermediate in age between the Early Iron Age sites and the later stone-

walled sites. However, since elsewhere in the then-named Transvaal and Orange Free State, stone-walled

building appeared to start around A.D. 1450-1500, this was thought to be true in this region as well (Evers, 1975).


Rock Engravings

An article by Maggs (1995), explains that these agriculturist engravings are mainly dominated by depictions of

ground plans representing the shape of settlements people built and lived in. Virtually all known engraved sites

are in the vicinity of Late Iron Age settlements and it is now known that such engravings are much more common

than was previously thought. Fieldwork in several such regions has produced many formerly unrecorded sites

within the limited areas searched. Therefore, Maggs recommended that future fieldwork on the stone-built

settlements should incorporate an examination of neighbouring rock outcrops for possible engravings (ibid).

Maggs’ article highlights that such images may represent abstract or symbolic spatial arrangements reflecting

the cosmology of the society that made them. He uses an example taken from the Pedi, a northern Sotho group

linked geographically and culturally with the Mpumalanga engravings. Within this system, social and religious

structure was, and among many rural communities still is, clearly inseparable. Each member literally knows their

place within the homestead according to their age, sex and status (ibid).

The South African (Anglo-Boer) War

The area between Witbank and Ermelo major military activity during the latter part of the South African War.

The occupation of Pretoria on 5 June 1900, saw the retreat of Boer forces towards the eastern Transvaal

(Mpumalanga) and the intensification of the guerrilla warfare activities. Seeking to bring an end to the conflict

the British started an advance of the Boer forces from the west (Pretoria) and the south (Ermelo). In April 1901,

one of the British Columns under Major-General F.W. Kitchener started with a push from Lydenburg towards

the south over the Delagoa-Pretoria rail line in an attempt to capture the Boer forces under the command of

General Ben Viljoen. Between April and August of 1900 numerous skirmishes and engagements took place

between British forces (predominantly associated with the Western Australian 5th and 6th Contingents) and

retreating Boer commandos


The data analysis has enabled the identification of possible heritage sensitive areas that included:

• Dwellings

• Clusters of dwellings (homesteads and farmsteads);

• Archaeological Sensitive areas (based on historical descriptions);

• Structures.

Cemeteries and graves

Three cemeteries could be directly impacted by the proposed construction activities of the ADF but area situated

outside the proposed footprint areas and can be conserved with the necessary management measures. The

cemeteries have high heritage significance and are given a Grade 3A significance rating in accordance with the

system described in Section 3.1 of the Heritage Impact Assessment (Appendix I).

Heritage structures

Only a single farmstead is situated inside the buffer area of Alternative 2 and should not be directly impacted by

the development. The cluster that historically functioned as a single farmstead is protected under Section 34 of

the NHRA and has a medium heritage significance and given a grading of Generally protected B.


Figure 12: Potential heritage resources in the study area

5.6 SOILS

The project area is flat in relief with slopes of less than 4%. The land type data suggest that soils of the Hutton,

Glencoe, and Wasbank forms are present in the crest to midslope positions, with Longlands, Rensburg, and

Katspruit soil forms in the valley bottoms. The average land capability based on the land type data is that of a

class III (moderate cultivation). Class III land would pose moderate limitations to agriculture with some erosion

hazard and would require special conservation practice and tillage methods. The farming method for this

capability would require the rotation of crops and ley (50%).

The current land use seems to be croplands with some depressions in the areas. Alternative one shows lower

agricultural potential from the areal imagery and therefor from an agricultural perspective Alternative 1 is the

selected site. The land capability will need to be verified in the field.



Special care and erosion prevention measures must be taken when working in areas where naturally dispersive

soils occur.

5.7 RIVERS AND WETLANDS

5.7.1 RIVERS

The project site is located within the Olifants Water Management Area 4 (WMA 4) and within quaternary

catchment B12B. The Mean Annual Precipitation (MAP) calculated for this area is 699 mm while the Mean

Annual Evaporation (MAE) is 1552 mm and the Mean Annual Runoff (MAR) is 24.09 million m3/annum making

this a dry area. The preliminary flood plain of the tributaries surrounding the proposed ash disposal facility sites

was mapped out and is considered to be Highly Sensitive (+2) since it is prone to siltation and pollution which

could potentially arise from the proposed project. Slurry from the operations and spillages of hydrocarbons and

chemicals used by machinery and vehicles are possible sources of pollution in The Rietkuilspruit and its

tributaries, if due care is not taken. Refer to Table 15 for average climatic data for the area.

Table 15: Mean monthly and annual precipitation, evaporation and runoff for quaternary catchment B12B

A map indicating the study area in relation to the identified River National Freshwater Ecosystem Priority Areas

(NFEPAs) in provided in Figure 13.

Month Precipitation (mm) Evaporation (mm) Runoff (MCM)

Oct 73 167 0.74

Nov 115 158 2.34

Dec 120 175 3.80

Jan 122 171 5.13

Feb 89 142 4.69

Mar 80 140 2.86

Apr 41 108 1.85

May 15 91 0.92

Jun 8 74 0.61

Jul 6 81 0.47

Aug 7 107 0.37

Sep 23 139 0.32

Annual 699 1552 24.09


Figure 13: Map indicating the study area in relation to the River NFEPAs


5.7.2 WETLANDS

The extent of wetland areas (based on the desktop delineation) within the primary (120ha) and secondary (1km

radius) study areas are shown in Figure 14. Based on the desktop delineation, a higher wetland extent within

the primary study area was recorded at Alternative 1, with approximately 29.49 % of the area demarcated as a

wetland. Alternative 2 reflected a lower wetland extent, with approximately 8.86 % of the area demarcated as

wetlands. For the secondary study area Alternative 1 reflected less wetlands. However, based on the field

observations, the wetlands situated within the secondary study area of Alternative 2, were more degraded

compared to that of Alternative 1. This will be further assessed during the EIA phase of the study. A map

indicating the location of NFEPA wetlands in the study area is provided in Figure 16.

Figure 14: Desktop wetland extent within the primary study area (120 Ha)

In addition to the desktop delineation a Wetland Index (WI) was also modelled for study area. The WI (Figure

15) reflects the propensity of an area to express wetness based on topographical variation and augmented the

sensitivity analyses. The wetness index provides a suitable proxy for the determination of likely wetland areas

within the individual study areas. Based on the WI, Alternative 2 indicted the lowest proportion of

temporary/seasonal and permanent wetland areas.

Figure 15: Desktop wetland extent within the secondary study area (1km radius)


Figure 16: Map indicating the study area in relation to the NFEPA wetland types


Figure 17: Sensitivity map of the watercourses associated with the study area



The preliminary flood plain of the tributaries surrounding the two proposed ash disposal facility sites was

mapped out and is considered to be Highly Sensitive (+2) since it is prone to siltation and pollution which could

potentially arise from the proposed project (Figure 17). Slurry from the operations and spillages of hydrocarbons

and chemicals used by machinery and vehicles are possible sources of pollution in the Rietkuilspruit and its

tributaries, if due care is not taken.

The rationale applied with the aquatic/wetland sensitivity assessment is based on the premise that all

watercourses or potential watercourse areas are sensitive. The catchment size, slope and position in the

landscape predominantly determine the potential for water accumulation. Once accumulated, other factors

such as underlying geology and soil permeability also contribute towards the nature of particular wetness

expressed. The proposed activities may potentially have a significant negative influence on the current status of

the receiving instream environment if not adequately managed.

Both alternative sites fall within quaternary catchments B12B, in the Olifants Water Management Area (WMA).

The two main river systems that are associated with the proposed alternatives include the Rietkuilspruit (Alt2)

and the Klein-Olifants (Alt1). The Rietkuilspruit SQR fell within an overall E Present Ecological State (PES)

category, inferring a Seriously modified state, while the Klein-Olifants is less impacted, falling into a C PES

category, indicating a Moderately modified state. The WI was modelled for the study area. The WI reflects the

propensity of an area to express wetness based on topographical variation and formed the basis of the sensitivity

analyses. Based on the WI, Alternative indicted a lower proportion of temporary/seasonal and permanent

wetland areas when compared to Alternative 1.

Based on the desktop delineation, a higher wetland extent within the study area was recorded at Alternative 1,

while Alternative 2 indicated a higher wetland extent within the secondary study area (1 km radius). The PES of

the wetlands was not considered during the scoping assessment. The rationale applied with the aquatic/wetland

sensitivity assessment is based on the premise that all watercourses or potential watercourse areas are sensitive.

The catchment size, slope and position in the landscape determine the potential for water accumulation. Once

accumulated, other factors such as underlying geology and soil permeability also contribute towards the nature

of wetness expressed.

5.8 GROUNDWATER

According to the 1:500 000 hydrogeological map series 2526 Johannesburg (Barnard and Baran, 1999) the site

is underlain by an intergranular and fractured aquifer with an average borehole yield between 0.5 to 2l/s.

The aquifer vulnerability and classification maps of South Africa classify the underlying aquifer as a minor aquifer

which is the least vulnerable aquifer system. However, no municipal water or water supply dams are present in

the area, therefore the aquifer can be classified as a sole source aquifer system, based on the hydrocensus data

which indicated numerous production boreholes in the area investigated. According to Parsons and Conrad

(1998), a sole source aquifer system can be defined as an aquifer which is used to supply 50% or more domestic

water for a given area, and for which no alternative source is available should the aquifer be depleted.

Surface and groundwater quality monitoring was conducted by Fisuxolo Trading in June 2013. The project was

planned for three-year period incorporating surface and groundwater monitoring each quarter. The project was

interrupted in March 2014 and August 2015 for commercial reasons and resumed in May 2015 and April 2016.

The following was concluded in the quarterly report (up to July 2016): Surface and Groundwater Quality

Monitoring - Arnot Power Station: August 2016 – 3rd Quarter 2016.

• Surface water and groundwater samples were collected from: Nooitgedacht Spruit, Rietkuil Spruit,

power station area, coal stockyard area, ash water return dams, ashing area and ash dams, sewage

plant and the domestic waste site;

• Laboratory results indicated that the quality of water in the Arnot area is mixed. There are fluctuating

concentrations according to the SANS 241:2011 but all concentrations are in line with the Arnot WUL

and its amendment;


• The majority of samples are calcium dominant (Ca-HCO3 and Ca-SO4 type waters). Ca-HCO3 waters are

typical of shallow, fresh surface and groundwater typical of the Karoo aquifers, which are generally

shallow. The Ca-SO4 waters are typical of gypsum groundwater and mine drainage. Coal is associated

with small amounts of pyrite which when exposed to oxygen and water readily reacts to produce

elevated sulphate water;

• Water chemistry trends indicate fluctuating concentrations over time possibly as a result of seasonal

variations. High concentrations are observed in the dry season and lower concentrations in the wet

season;

• Water levels vary with seasons becoming shallow in the wet seasons and deeper in the dry season. Both

the chemical and water level fluctuations can be expected to persist and are considered normal;

As part of the overall monitoring done by Fisuxolo, a hydrocensus was carried out in July 2016 and the

results were submitted in August 2016. The following recommendations were made:

o The recommended remediation is cutting off the sources of the pollutants and, where ground

and water is already contaminated, neutralisation with a suitable buffer;

o Geophysics were recommended to trace the depth and lateral extent of the pollutants

followed by design of a detailed remediation plan;

o One of the reasons for pollution is the over use of water in the process. By reducing water

demand the pollution created by water leakage or spillage can be significantly reduced with

concomitant savings in water costs;

o Evaluate the objectives of the monitoring and discuss where the monitoring can be reduced

and optimised;

o Automatic monitoring is an option and can reduce costs without loss of accuracy;

o Recommendations for water management indicated by the chemistry results:

▪ Improve access to monitoring sites;

▪ Investigate reasons for contamination; and

▪ Use reasons to develop a mitigation strategy.

o Surface water and groundwater in the Arnot area has been recorded as polluted since the start

of monitoring. The last 2 monitoring phases do not indicate any improvement. Active

remediation is required.

During the hydrocensus, properties within a 2-5km radius of the site were visited. Details including water use

type, volumes, abstraction rates, water levels and co-ordinates were obtained where possible. The groundwater

abstracted from the majority of boreholes are used for domestic, garden irrigation and agricultural purposes.

The pH, EC and TDS values for all boreholes which were sampled for field parameters were compliant with the

SANS 241-1:2011 standards. In total, 12 hydrocensus boreholes were identified within the 1km radius

surrounding the two alternative sites. The groundwater abstracted from the majority of boreholes are used for

domestic, garden irrigation and agricultural stock watering purposes (cattle). The hydrocensus borehole map is

provided in Figure 18.


Figure 18: Hydrocensus borehole map



For Site Alternative 1 and 2 the risk of groundwater contamination due to shallow groundwater levels are

probable. For Site Alternative 1 the presence of four boreholes used for potable use increases the impact of

groundwater contamination as opposed to the two boreholes for Site Alternative 2.

5.9 AIR QUALITY

The Department of Environmental Affairs (DEA) operates a monitoring network over the Highveld region at the

residential areas of Hendrina (actual location in Kwazamokuhle, just northeast of Hendrina), Ermelo,

Middleburg, Secunda and eMalahleni. The closest monitoring station to the proposed operations is located at

Hendrina approximately 18 km southwest. The measured daily PM10 and PM2.5 ground level concentrations at

the DEA operated Hendrina monitoring station is within current NAAQS for the period 2016.

Eskom operates a monitoring station (Kwazamokuhle) less than 1km from the DEA operated Hendrina

monitoring station. Monitored data from this site is only available from October 2016 and measures 5

exceedances of the daily PM10 NAAQS and 2 exceedances of the daily PM2.5 NAAQS for the period October to

December 2016 (3-month period). Measured PM10 and PM2.5 thus potential exceeds daily NAAQS at this

monitoring site.

It should be noted that measured PM10 and PM2.5 concentrations at the DEA operated Hendrina and Eskom

operated Kwazamokuhle sites may be influenced by local sources of emissions and may not be representative

of ambient air quality at the proposed project site approximately 18 km to the northeast.

The period wind field and diurnal variability in the wind field are shown in Figure 19, while the seasonal variations

are shown in Figure 20. The wind regime for the area is dominated by easterly and northwesterly flow fields.

The northwesterly wind flow is more dominant during day-time conditions, with easterly wind flow more

dominant during the night. Calm conditions occurred for 11.2 % of the period summarised.

Seasonally, the wind flow pattern conforms to the period average wind flow pattern; however, some seasonal

variability in the wind fields. During summer easterly winds are more frequent than in other seasons, while winds

from the north-west occur more frequently in winter. Autumn has the highest frequency of calm periods (16%)

while spring shows an increased frequency of winds of speeds greater than 5 m/s.


Figure 19: Diurnal wind roses

Figure 20: Seasonal wind roses


Air temperature is important, both for determining the effect of plume buoyancy (the larger the temperature

difference between the emission plume and the ambient air, the higher the plume is able to rise), and

determining the development of the mixing and inversion layers.

Temperatures ranged between -3.0°C and 29.5°C. During the day, temperatures increase to reach maximum at

about 15:00 in the late afternoon. Ambient air temperature decreases to reach a minimum at between 06:00

and 07:00.

Existing sources of emission

The main existing sources of particulate emissions in the area are mining activities, agricultural activities and

vehicle entrainment.

Gaseous emissions (viz. SO2, CO, carbon dioxide (CO2), oxides of nitrogen (NOx) and hydrocarbons) will derive

from combustions sources such as vehicles and power station activity.

The main contribution from these sources can be summarised as follows:

• Power station operations near the project site (i.e. Arnot Power Station) will contribute to CO2, SO2, CO,

PM10, PM2.5 and NOx gaseous emissions. The existing ash facility at the power station will contribute to

particulate matter though windblown dust if the facility is not completely rehabilitated once the new

facility is operational.

• Numerous coal mines are located near the Arnot Power Station (particularly to the west of operations).

Particulate matter is the main pollutant of concern from mining operations deriving from materials

handling, vehicle entrainment and crushing activities.

• Agriculture (together with mining) is a dominant land-use within the surrounding area. Particulate

matter is the main pollutant of concern from agricultural activities as particulate emissions are deriving

from windblown dust, burning crop residue, and dust entrainment as a result of vehicles travelling along

dirt roads. In addition, pollen grains, mold spores and plant and insect parts from agricultural activities

all contribute to the particulate load (WHO, 2000).

• Biomass burning results in aerosols, black carbon and hydrocarbons. Biomass burning is also a

significant source of greenhouse gases, especially CO2 and methane (CH4), black carbon and

photochemical gases (NOx, CO and hydrocarbons) that lead to the production of tropospheric O3. The

extent of NOx emissions depends on combustion temperatures, with minor sulphur oxides being

released. Burning crop residue may be a significant source of atmospheric emissions within the area.

• Household fuel burning contributes to gaseous and particulate ambient concentrations. Coal burning

emits a large amount of gaseous and particulate pollutants including SO2, NO2, heavy metals, total and

respirable particulates including heavy metals and inorganic ash, carbon monoxide, polycyclic aromatic

hydrocarbons, and benzo(a)pyrene (EPA, 1996). Polyaromatic hydrocarbons are recognised as

carcinogens. Pollutants arising due to the combustion of wood include respirable particulates, SO2, NO2,

carbon monoxide, polycyclic aromatic hydrocarbons, particulate benzo(a)pyrene and formaldehyde

(EPA, 1996). The main pollutants emitted from the combustion of paraffin are NO2, particulates carbon

monoxide and polycyclic aromatic hydrocarbons (EPA, 2010).

• Vehicle tailpipe emissions can be significant sources of CO2, CO, hydrocarbons (HCs), SO2, NOx and

particulate matter.


The closest residential area to the proposed project is Rietkuil, immediately north of the existing Arnot

Power Station ash facility. Individual farmsteads also surround the project area. Due to the location of

sensitive receptors to the proposed project sites, both alternatives are likely to impact on the same number

of receptors so there is no clear preferable site in terms of sensitivities in general.


Figure 21: Location of sensitive receptors and potential 120ha ash disposal facility sites (1 km buffer) assessed

for the scoping phase.


6 ENVIRONMENTAL IMPACT ASSESSMENT

This section aims to identify and assess the potential environmental impacts associated with the proposed

activities. This impact assessment will be used to guide the identification and selection of preferred alternatives,

and management and mitigation measures, applicable to the proposed activity. Section 6.4 discussed the

selection of preferred alternatives in more detail.

6.1 APPROACH AND METHODOLOGY

This section presents the proposed approach to assessing the identified potential environmental impacts with

the aim of determining the relevant environmental significance.

6.1.1 METHOD OF ASSESSING IMPACTS

The impact assessment methodology is guided by the requirements of the NEMA EIA Regulations. The broad

approach to the significance rating methodology is to determine the environmental risk (ER) by considering the

consequence (C) of each impact (comprising Nature, Extent, Duration, Magnitude, and Reversibility) and relate

this to the probability/likelihood (P) of the impact occurring. This determines the environmental risk. In addition,

other factors, including cumulative impacts, public concern, and potential for irreplaceable loss of resources, are

used to determine a prioritisation factor (PF) which is applied to the ER to determine the overall significance (S).

6.1.2 DETERMINATION OF ENVIRONMENTAL RISK

The significance (S) of an impact is determined by applying a prioritisation factor (PF) to the environmental risk

(ER). The environmental risk is dependent on the consequence (C) of the particular impact and the probability

(P) of the impact occurring. Consequence is determined through the consideration of the Nature (N), Extent (E),

Duration (D), Magnitude (M), and reversibility (R) applicable to the specific impact.

For the purpose of this methodology the consequence of the impact is represented by:

C= (E+D+M+R) x N

4

Each individual aspect in the determination of the consequence is represented by a rating scale as defined in

Table 16.

Table 16: Criteria for determining impact consequence

Aspect Score Definition

Nature - 1 Likely to result in a negative/ detrimental impact

+1 Likely to result in a positive/ beneficial impact

Extent 1 Activity (i.e. limited to the area applicable to the specific activity)

2 Site (i.e. within the development property boundary),

3 Local (i.e. the area within 5 km of the site),

4 Regional (i.e. extends between 5 and 50 km from the site)

5 Provincial / National (i.e. extends beyond 50 km from the site)



Duration 1 Immediate (<1 year)

2 Short term (1-5 years),

3 Medium term (6-15 years),

4 Long term (the impact will cease after the operational life span of the

project),

5 Permanent (no mitigation measure of natural process will reduce the impact

after construction).

Magnitude/ Intensity 1 Minor (where the impact affects the environment in such a way that natural,

cultural and social functions and processes are not affected),

2 Low (where the impact affects the environment in such a way that natural,

cultural and social functions and processes are slightly affected),

3 Moderate (where the affected environment is altered but natural, cultural

and social functions and processes continue albeit in a modified way),

4 High (where natural, cultural or social functions or processes are altered to

the extent that it will temporarily cease), or

5 Very high / don’t know (where natural, cultural or social functions or

processes are altered to the extent that it will permanently cease).

Reversibility 1 Impact is reversible without any time and cost.

2 Impact is reversible without incurring significant time and cost.

3 Impact is reversible only by incurring significant time and cost.

4 Impact is reversible only by incurring prohibitively high time and cost.

5 Irreversible Impact

Once the C has been determined, the ER is determined in accordance with the standard risk assessment

relationship by multiplying the C and the P. Probability is rated/scored as per Table 17.

Table 17: Probability scoring


Pro

bab

ility

1 Improbable (the possibility of the impact materialising is very low as a result of design, historic

experience, or implementation of adequate corrective actions; <25%),

2 Low probability (there is a possibility that the impact will occur; >25% and <50%),

3 Medium probability (the impact may occur; >50% and <75%),

4 High probability (it is most likely that the impact will occur- > 75% probability), or

5 Definite (the impact will occur).

The result is a qualitative representation of relative ER associated with the impact. ER is therefore calculated as

follows:

ER= C x P

Table 18: Determination of Environmental Risk

Co

nse

qu

ence

5 5 10 15 20 25

4 4 8 12 16 20

3 3 6 9 12 15

2 2 4 6 8 10

1 1 2 3 4 5

1 2 3 4 5

Probability

The outcome of the environmental risk assessment will result in a range of scores, ranging from 1 through to 25.

These ER scores are then grouped into respective classes as described in Table 19.

Table 19: Significance classes

Environmental Risk Score

Value Description

< 9 Low (i.e. where this impact is unlikely to be a significant environmental risk),

≥9 <17 Medium (i.e. where the impact could have a significant environmental risk),

≥ 17 High (i.e. where the impact will have a significant environmental risk).


The impact ER will be determined for each impact without relevant management and mitigation measures (pre-

mitigation), as well as post implementation of relevant management and mitigation measures (post-mitigation).

This allows for a prediction in the degree to which the impact can be managed/mitigated.

6.1.3 IMPACT PRIORITISATION

In accordance with the requirements of Appendix 3(3)(j) of the NEMA 2014 EIA Regulations (GNR 982), and

further to the assessment criteria presented in the Section above it is necessary to assess each potentially

significant impact in terms of:

• Cumulative impacts; and

• The degree to which the impact may cause irreplaceable loss of resources.

In addition, it is important that the public opinion and sentiment regarding a prospective development and

consequent potential impacts is considered in the decision-making process.

In an effort to ensure that these factors are considered, an impact prioritisation factor (PF) will be applied to

each impact ER (post-mitigation). This prioritisation factor does not aim to detract from the risk ratings but

rather to focus the attention of the decision-making authority on the higher priority/significance issues and

impacts. The PF will be applied to the ER score based on the assumption that relevant suggested

management/mitigation impacts are implemented.

Table 20: Criteria for determining prioritisation

Public response

(PR)

Low (1) Issue not raised in public response.

Medium (2) Issue has received a meaningful and justifiable public response.

High (3) Issue has received an intense meaningful and justifiable public response.

Cumulative

Impact (CI)

Low (1) Considering the potential incremental, interactive, sequential, and

synergistic cumulative impacts, it is unlikely that the impact will result in

spatial and temporal cumulative change.

Medium (2) Considering the potential incremental, interactive, sequential, and

synergistic cumulative impacts, it is probable that the impact will result in


High (3) Considering the potential incremental, interactive, sequential, and

synergistic cumulative impacts, it is highly probable/definite that the

impact will result in spatial and temporal cumulative change.

Irreplaceable

loss of

resources (LR)

Low (1) Where the impact is unlikely to result in irreplaceable loss of resources.

Medium (2) Where the impact may result in the irreplaceable loss (cannot be replaced

or substituted) of resources but the value (services and/or functions) of

these resources is limited.


High (3) Where the impact may result in the irreplaceable loss of resources of high

value (services and/or functions).

The value for the final impact priority is represented as a single consolidated priority, determined as the sum of

each individual criteria represented in Table 20. The impact priority is therefore determined as follows:

Priority = PR + CI + LR

The result is a priority score which ranges from 3 to 9 and a consequent PF ranging from 1 to 2 (Refer to Table

21 ).

Table 21: Determination of prioritisation factor

Priority Ranking Prioritisation Factor

3 Low 1

4 Medium 1.17

5 Medium 1.33

6 Medium 1.5

7 Medium 1.67

8 Medium 1.83

9 High 2

In order to determine the final impact significance, the PF is multiplied by the ER of the post mitigation scoring.

The ultimate aim of the PF is to be able to increase the post mitigation environmental risk rating by a full ranking

class, if all the priority attributes are high (i.e. if an impact comes out with a medium environmental risk after

the conventional impact rating, but there is significant cumulative impact potential, significant public response,

and significant potential for irreplaceable loss of resources, then the net result would be to upscale the impact

to a high significance).

Table 22: Final Environmental significance rating

Environmental Significance Rating

Value Description

< -10 Low negative (i.e. where this impact would not have a direct influence on the decision to

develop in the area).

≥ -10 < -20 Medium negative (i.e. where the impact could influence the decision to develop in the area).

≥ -20 High negative (i.e. where the impact must have an influence on the decision process to


0 No impact


< 10 Low positive (i.e. where this impact would not have a direct influence on the decision to


≥ 10 < 20 Medium positive (i.e. where the impact could influence the decision to develop in the area).

≥ 20 High positive (i.e. where the impact must have an influence on the decision process to


6.2 IDENTIFICATION OF IMPACTS

Potential environmental impacts were identified during the scoping process. These impacts were identified by

the EAP, the appointed specialists, as well as the public. Table 8 provides the list of potential impacts identified.

Table 8: Identified Environmental Impacts

ENVIRONMENTAL

ASPECT

POTENTIAL IMPACT

Biodiversity • Loss of habitat (Construction)

• Habitat fragmentation (Construction)

• Displacement of fauna (Construction & Operation)

• Blockage of seasonal dispersal (Construction & Operation)

• Direct Construction Impacts on flora

• Direct Construction Impacts on fauna

• Pollution of habitats (Construction and Operation)

• Blockage of seasonal dispersal (Operation)

• Introduction of alien plants (Operation)

Soils and Geology • Loss of agricultural land

• Wind erosion

• Water seepage

Geohydrology/

Groundwater

• Contamination of Groundwater (i.e. chemicals, fuel, waste, sedimentation)

Hydrology/ Surface

Water & Wetlands

• Increase sediment loads

• Spillage of oils, fuel and chemicals

• Contamination from leakage and spillage

• Impacts related to a decrease in surface water quality on wetlands and aquatic biota

• Impacts related to altered surface water hydrology on wetlands and aquatic biota

• Impacts related to erosion and sedimentation on wetlands and aquatic biota

• Aquatic habitat destruction and fragmentation.

Air Quality • Gases and particles from vehicle activity on-site (Construction and

operation)

• Wind erosion from ash disposal facility

• Particulates from rehabilitation of ash disposal facility

• Particulates from construction of progressing ash disposal facility site

Visual • Alteration of the visual quality and sense of place of the area

• Light pollution

• Improvement of the visual quality and sense of place of the area


Without proper mitigation measures and continual environmental management, most of the identified impacts

may potentially become cumulative, affecting areas outside of their originally identified zone of impact. The

potential cumulative impacts have been identified, evaluated, and mitigation measures suggested which will be

updated during the detailed EIA level investigation. The impact identification and calculation methodology

employed by all specialists incorporates cumulative impacts in a quantitative manner to determine the final

impact score and corresponding rating.

When considering cumulative impacts, it is vitally important to bear in mind the scale at which different impacts

occur. There is potential for a cumulative effect at a broad scale, such as regional deterioration of air quality, as

well as finer scale effects occurring in the area surrounding the activity. The main impacts which have a

cumulative effect on a regional scale are related to the transportation vectors that they act upon. For example,

air movement patterns result in localised air quality impacts having a cumulative effect on air quality in the

region. Similarly, water acts as a vector for distribution of impacts such as contamination across a much wider

area than the localised extent of the impacts source. At a finer scale, there are also impacts that have the

potential to result in a cumulative effect, although due to the smaller scale at which these operate, the

significance of the cumulative impact is lower in the broader context.

6.3 DESCRIPTION AND ASSESSMENT OF IMPACTS

The following potential impacts were identified during the scoping phase assessment. As a result of the scoping

phase assessment and the sensitivity mapping exercise, a preferred layout alternative will be identified and will

be assessed further in the EIA phase assessment. These preliminary impact calculations will be subject to

amendment based on the EIA phase assessment and the results of public consultation undertaken during the

EIA phase.

6.3.1 PRELIMINARY IMPACTS ON ECOLOGY

The following preliminary impacts on the ecological resources within the study area were identified and assessed

for the various project phases (planning and design, construction, operation, decommissioning, and

rehabilitation and closure). No impacts on the ecological receiving environment have been identified that will

occur during the Planning and Design Phase, Decommissioning Phase, and the Rehabilitation and Closure Phase.

Below are the construction and operational phase preliminary impacts on ecological resources identified during

scoping, as well as their impact rating.

A) Loss/ Destruction of Natural Habitat

The proposed activities on site will lead to localised damage to an estimated 120ha area. There will also be

damage to habitats associated with linear infrastructure between the power station and the ash heap.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final Significance

Loss/ Destruction of

Natural Habitat (Alternative

1)

Construction -18,75 -13,75 -18,33

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final Significance


Loss/ Destruction of

Natural Habitat (Alternative

2)

Construction -18,75 -13,75 -16,04

Proposed Preliminary Mitigation

Undertake activities in previously disturbed places and/or habitats with a lower sensitivity score.

B) Habitat Fragmentation and Edge Effects

Due to the existing fragmentation of natural habitat, limited fragmentation and edge effects are expected.

Impact Project Phase Pre-Mitigation

Score

Post-Mitigation

Score

Final Significance

Habitat Fragmentation and

Edge effects (Alternative 1)

Construction -20,00 -17,50 -20.42


Score

Post-Mitigation

Score

Final Significance

Habitat Fragmentation and

Edge effects (Alternative 2)

Construction -18,75 -16,25 -18,96


• Undertake activities in previously disturbed areas and/or habitats with lower sensitivity;

• Where possible locate activities on the boundaries of existing disturbance;

• Use existing access roads as much as possible; and

• Rehabilitate disturbed areas as soon as possible.

C) Displacement of Faunal Species

The proposed activities on site will lead to localised damage to habitat. There will also be damage to habitats

associated with linear infrastructure. The overall loss of habitat is, however, expected to be quite a small

proportion of the total habitat within the study area. Loss of faunal habitat will therefore be very low.


Score

Post-Mitigation

Score

Final Significance

Displacement of Faunal

Species (All alternatives)

Construction

Operation

-14.00 -13.00 -13.00



• Where possible undertake activities in previously disturbed places and/or habitats with a lower

sensitivity score; and


D) Blockage of Seasonal and Dispersal Movements

Proposed activities will result in insignificant loss of habitat, especially migration corridors. Habitat

fragmentation is also expected to be minimal.


Score

Post-Mitigation

Score

Final

Significance

Blockage of Seasonal and

Dispersal Movements (All

alternatives)

Construction

Operation

-10.50 -10.50 -10.50


• Where possible undertake activities in previously disturbed areas and/or habitats with lower sensitivity;

• Where possible locate activities on the boundaries of existing disturbance; and

• Use existing access roads as much as possible; and rehabilitate disturbed areas as soon as possible.

E) Flora Direct and Indirect Mortality

There are various plant species of concern that could potentially be affected by the proposed activities on site.

The exact location of these is unknown relative to the proposed siting of proposed activities and will be

determined in the EIA phase.


Score

Post-Mitigation Score Final

Significance

Flora Direct and Indirect

Mortality (Alternative 1)

Construction -14.00 -7.00 -10.50


Score

Post-Mitigation Score Final

Significance

Flora Direct and Indirect

Mortality (Alternative 2)

Construction -7.00 -3.50 -5.25


• Where possible, walk-through survey of local site prior to activity to be undertaken;

• Search and rescue of species of concern (if any);


• Obtain permits for any listed/protected species found on site;


• Where possible locate activities on the boundaries of existing disturbance; and use existing access roads

as much as possible.

F) Fauna Direct and Indirect Mortality

There are risks to fauna, for example illegal hunting/poaching as well as threats from movement of machinery.

During construction, relatively sedentary species may suffer direct mortality. The assessment is based on a

worst-case scenario affecting species of the highest conservation status and as such the final significance is

minimal.


Score

Post-Mitigation

Score

Final Significance

Fauna Direct and Indirect

Mortality (Alternative 1

and 2)



• Where possible undertake site-specific walk-through surveys for potential species of concern;


• Where possible locate activities on the boundaries of existing disturbance; and

• Use existing access roads as much as possible.

G) Pollution of Habitats

There is a possibility that activities could result in pollution being introduced into natural habitats.

Impact Project Phase Pre-Mitigation Score Post-Mitigation

Score

Final

Significance

Pollution of Habitats (All

alternatives)

Construction

-9.75 -9.75 -14.63


• Manage all waste sources emanating from proposed activities in line with legal requirements;

• As far as possible maintain minimum distances from aquatic and wetland habitats.as per legal

requirements;


and

• Compile a comprehensive storm-water management plan and pollution control plan.

H) Displacement of faunal species


Continued activities during operation will tend to keep sensitive fauna away.


Score

Post-Mitigation

Score

Final

Significance

Displacement of faunal

species (All Alternatives)

Operation

-8.50 -6.50 -6.50


• Wherever possible, use existing access roads and minimize creation of new tracks through natural

habitats; and


I) Blockage of seasonal and dispersal movements

Continued activities during operation will tend to keep sensitive fauna away, including from corridors.


Score

Post-Mitigation

Score

Final Significance

Blockage of seasonal and

dispersal movements (All

Alternatives)

Operation -6.50 -6.50 -8.67


• Undertake activities in previously disturbed areas and/or habitats with lower sensitivity;

• Locate activities on the boundaries of existing disturbance;

• Use existing access roads as much as possible; and


J) Introduction/ Invasion by Alien Species

Disturbing activities on site will favour alien plants in places. In most cases, it is in the interests of the landowner

to control infestations.


Score

Post-Mitigation

Score

Final Significance

Introduction/ Invasion by Alien

Species

Operation -14.00 -6.75 -10.13




• Where possible locate activities on the boundaries of existing disturbance;

• Use existing access roads as much as possible;

• Rehabilitate disturbed areas as soon as possible;

• Manage alien plants within close proximity to activities;

• Compile an alien plant management plan.

6.3.2 PRELIMINARY IMPACTS ON GEOHYDROLOGY

All geohydrological impacts are restricted to the operational phase of the project. Below are the operational

phase preliminary impacts on groundwater resources identified during scoping, as well as their impact rating.

A) Contamination of Groundwater due to shallow groundwater levels

The proposed activities on site will lead to localised damage to an estimated 120ha area. There will also be

damage to habitats associated with linear infrastructure between the power station and the ash heap. The depth

to groundwater is an important factor to consider when determining the impacts to groundwater from a

contamination perspective. A site associated with shallow water levels has a higher risk of contaminating the

groundwater environment. Water contained in the ash material during deposition can leach constituents from

the ash disposal facility and transport it to the surrounding environment. Additional water that is recharged from

rainfall will supplement the interstitial water and contribute to the leaching of elements. The water that migrates

through the facility can either seep out along the edge of the ash storage facility and enter the surrounding

environment as surface water or migrate vertically to the bottom of the disposal facility and enter the underlying

soil from where it can recharge and contaminate the aquifers. Mitigation would significantly reduce the potential

impact associated with contamination of groundwater.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final Significance

Contamination of

Groundwater due to

shallow groundwater levels

(Alternative 1 and 2)

Operation -14.00 -10.50 -14.00


• The mitigation measures would include lining the ash disposal facility (more details regarding the liner

will be provided in the EIA phase); and

• Mitigation measures would also include implementing a groundwater monitoring programme. This

would allow for the early detection of water quality deterioration associated with the site.

B) Contamination of Groundwater affecting sensitive receptors

Several boreholes are located within the 1km buffer zones for both site alternatives. There are four active

boreholes are present within the 1km buffer zone of Site Alternative 1 and two active abstraction boreholes

within the buffer zone of Site Alternative 2.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final Significance


Groundwater

Contamination Affecting

Sensitive receptors

(Alternative 1)

Operation -14.00 -10.50 -14.00

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final Significance

Groundwater

Contamination Affecting

Sensitive receptors

(Alternative 2)

Operation -10.50 -7.00 -9.33


• The mitigation measures would include monitoring of the boreholes on a frequent basis. Monitoring

boreholes would also be required between the source (ash disposal facility) and the receptor

(borehole).

• If it is determined that the borehole has been negatively affected due to the ash disposal facility, then

abstraction from the borehole must be revised in order to allow minimal drawdown.

• Mitigation measures would also include obtaining baseline water quality conditions from the river

downgradient and implementing a surface water monitoring programme. This would allow for the early

detection of water quality deterioration associated with the site.

• All clean and dirty surface water systems must be separated according to legislation and storm water

management must be in place to avoid contaminated surface runoff.

6.3.3 PRELIMINARY IMPACTS ON HYDROLOGY

The following preliminary impacts on the hydrological resources within the study area were identified and

assessed for the various project phases (planning and design, construction, operation, decommissioning, and

rehabilitation and closure). No impacts on hydrology have been identified that will occur during the Planning

and Design Phase. Below are the preliminary impacts on hydrological resources for the construction, operation,

and rehabilitation and closure phases identified during scoping, as well as their impact rating.

A) Increase sediment loads for Construction Phase

The removal of vegetation as well as the compaction of surfaces during construction will very likely result in

increased runoff and erosion from the site if not adequately mitigated. Runoff with higher sediment loads and

the higher flood peaks could thus report to The Rietkuilspruit and its tributaries. The magnitude of this potential

impact is, however, very small since it expected to be localised to the project site and nearby watercourse.


Impact Project

Phase

Pre-Mitigation

Score

Post-

Mitigation

Score

Final

Significance

Increase sediment loads

(Alternative 1)

Construction

-10.00 -4.00 -4.67

Impact Project

Phase

Pre-Mitigation

Score

Post-

Mitigation

Score

Final

Significance

Increase sediment loads

(Alternative 2)

Construction

-9.00 -3.50 -4.08


• Progressive rehabilitation of disturbed land should be carried out to minimize the amount of time that

bare soils are exposed to the erosive effects of rain and subsequent runoff;

• A starter embankment is recommended to prevent sediment runoff;

• Traffic and movement over stabilised areas should be controlled (minimised and kept to certain paths),

and damage to stabilised areas should be repaired timeously and maintained; and

• The total footprint area to be cleared for the proposed ash disposal facility should be kept to a minimum

by demarcating the construction areas and restricting removal of vegetation to these areas only.

B) Surface Water Contamination – oil, fuel or chemicals

Due poor storm water management during construction and operational phases, contamination of surface water

can occur.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Surface Water

Contamination

(Alternative 1)

Construction

-9.00 -3.75 -4.38

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


Surface Water

Contamination

(Alternative 2)

Construction

-8.00 -2.00 -2.33


• Oil recovered from servicing any vehicle or machinery on site should be collected, stored and disposed

of by accredited vendors for recycling.

C) Contamination from seepage, leakage and spillage

Contamination of surface water during operation of the facility due to ash seepage or oil spills.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Surface Water Contamination

(Alternative 1)

Operation -9.75 -4.00 -4.67

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


(Alternative 2)

Operation -8.25 -3.50 -4.08


• A detailed storm water management plan is recommended for the ash disposal facility with adherence

to the GN704;

• The engineering design team should ensure that seepage from the dump does not occur at the toe of

the dump;

• Vegetation should be planted on the Ash Disposal facility embankments to prevent erosion and silt

runoff; and

• A water quality monitoring plan should be produced and implemented to determine any changes in the

water quality.

D) Surface Water Contamination from seepage, leakage and spillage during decommissioning

Leakages/seepages and spillages can occur during the decommissioning phase of the proposed ash disposal

facility due to contaminated water seepage.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance



(All Alternatives)

Decommissioning -9.75 -4.00 -4.67

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


(All Alternatives)

Decommissioning -8.25 -3.50 -4.08


• The proposed ash disposal facility should be monitored and checked to ensure that no

leakages/seepages of contaminated water occur when the ash disposal facility is being?

decommissioned; and

• The water quality monitoring plan should continue during decommissioning activities to monitor any

deterioration of the water quality.

6.3.4 PRELIMINARY IMPACTS ON WETLAND AQUATIC ECOLOGY

The following preliminary impacts on the wetland aquatic ecology within the study area were identified and

assessed for the project. Below are the preliminary impacts on wetland aquatic ecology during the planning,

construction, operation, rehabilitation and closure phases, as well as the impact rating.

A) Impacts Related to a Decrease in Surface Water Quality on Wetland Function during construction

The main perceived impact related to surface water quality during construction pertains mainly to potential

hydrocarbon spills from construction equipment and machinery. Construction material, hydrocarbons (oil,

diesel, etc.), solvents and other pollutants spilling/leaking from construction machinery and equipment during

the construction phase may have a severe impact on the receiving aquatic environment.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


(Alternative 1)

Construction -12.00 -2.50 -3.33

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


(Alternative 2)

Construction -11.00 -2.50 -2.92



• Avoid, as far as reasonably possible, the placement of infrastructure within regulated areas of

watercourses.;

• No dumping of any building rubble, soil, litter, organic matter or chemical substances should occur

within watercourses. Dumping and temporary storage of the above should only occur at predetermined

and approved locations;

• No access is permitted within watercourses;

• In the case of dewatering of a construction site, water should be treated and all suspended particles

should be removed. Water removed from a construction site should not be released directly into a

watercourse. The discharge should occur onto a well vegetated area, which will help trap sediment and

contaminants; and

• Construction equipment should not be serviced or refuelled near (<100m) watercourses.

B) Impacts Related to a Decrease in Surface Water Quality during operation

The risk scores during the operation phase are higher since the probability of water quality related impacts on

aquatic ecology will be more pronounced, as seepage/leakage and aerial deposition from the ash disposal facility

may potentially occur.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


(Alternative 1)

Operation -15.00 -4.00 -5.33

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


(Alternative 2)

Operation -14.00 -4.00 -4.67


• Any water with a chemical signature different to that of the receiving aquatic environment should be

considered contaminated and should be isolated; and

• Ashing processes and activities should make a clear distinction between clean and contaminated water

and systems to deal with both should be in place.

C) Impacts Related to Altered Hydrology on Wetlands and Aquatic Biota

There will be complete loss of the hydrological function of the wetlands directly affected by the proposed

footprint. The proposed ash disposal facility will result in the localised reduction in catchment yield and

potentially result in the subsequent loss in hydrological contribution to the downslope watercourses. The

hydrological regime associated with the rivers/streams in the study area are characterised by peak flows during

the summer months and lower base flows during the winter months. The continuous ashing at the proposed ash


disposal facility may possibly result in lowered base flows in the receiving aquatic systems due to the loss of the

catchment area. Base flow is important as it defines habitat availability.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Altered hydrology (Alternative 1) Construction -14.00 -4.00 -6.00

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Altered hydrology (Alternative 2) Construction -13.00 -5.50 -6.67

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Altered hydrology (Alternative 1) Operation -16.00 -5.50 -8.25

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Altered hydrology (Alternative 2) Operation -15.00 -5.50 -7.33


• The stormwater design should consider the natural flood retention capacity provided by the soil

(including wetlands) within the footprint. The stormwater design should compensate for any loss in

natural flood retention, though carful placement of stormwater infrastructure, maximising onsite

(uncontaminated) infiltration and through the strategic placement of environmental infrastructure (i.e.

bioswales, berms, retention structures). The surface roughness of impermeable surfaces should also be

increases as much as possible to assist runoff energy dissipation.

• The extent of wetlands should be delineated prior to construction and the temporary access roads to

cross points should be designed to minimise soil compaction, thus not impeding the horizontal

movement of water through the soil;

• Reinstate hydrological functionality of affected systems after construction activity, as far as possible.

This will require rehabilitation of disturbed downslope areas where attention is paid to increase surface

roughness and energy dissipation.


D) Impacts Related to Erosion and Sedimentation on Wetlands and Aquatic Biota

Vegetation removal and the compaction of soil during construction and operation will result in increased surface

runoff and subsequently increase the erosion potential of the construction site. Furthermore, this may also have

an impact on the water quality via increased turbidity if not adequately managed.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Erosion and sedimentation

(Alternative 1 and 2)

Construction

and operation

-13.00 -3.50 -4.67


• Limit any disturbances to the smallest possible footprint.

• Erosion and silt control mechanisms must be in place prior to the onset of construction within any

watercourse. This includes the reduction of surface flow through the construction site. Silt fences or

hay bales need to be placed near the base of a slope in order to limit the amount of silt entering the

watercourse;

• Similarly, the erection of silt barriers along all the drainage lines must be undertaken to curb any

sediment and silt run-off in the preparation activities. Ideally, the amount of land that will be disturbed

should be kept to an absolute minimal;

• Non-erodible materials should be used for the construction of any berms, coffer dams or any other

isolation structures to be used within a flowing watercourse;

• Spoil stockpiles should be placed above the high-water mark in distinct piles and adequate erosion

measures need to be implemented in order to minimise and reduce erosion and siltation into the

watercourse;

• It is also recommended that construction activities should make use of the dry seasonal construction

window if feasible. This will further reduce the risk associated with erosion/siltation;

• Erosion control measures should be inspected regularly during the course of construction and

necessary repairs need to be carried out if any damage has occurred;

• Place access roads and infrastructure on natural topography and avoid side hill cuts and grades. Roads

should be designed with natural reclamation in mind;

• Design runoff control features to minimize soil erosion and avoid placement of infrastructure and sites

on unstable slopes and consider conditions that can cause slope instability, such as groundwater

aquifers, precipitation and slope angles.

E) Aquatic habitat destruction and fragmentation

The direct loss of wetland areas through clearing of riparian and wetland habitat will result in a complete, but

localised, loss of aquatic / wetland habitat. Aquatic habitat fragmentation may be the result of chemical (water

quality) or physical (hydrology, erosion and sedimentation) migration barriers.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance



(Alternative 1)

Construction -20.00 -17.50 -29.17

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


(Alternative 2)

Construction -18.75 -14.00 -21.00


• The footprint of the proposed facility should avoid as far as feasibly possible the placement of

infrastructure within watercourses. This will reduce the significance of the perceived impacts

substantially.

6.3.5 PRELIMINARY IMPACTS ON SOILS AND AGRICULTURAL POTENTIAL

The following preliminary impact on the soils and geology within the study area was identified and assessed for

the various project phases (planning and design, construction, operation, decommissioning, and rehabilitation

and closure). No impacts on soils and geology have been identified for the operation Phase.

Below are the preliminary impacts on soils and agricultural potential during the construction, operation, closure

and rehabilitation phases as well as the impact rating.

A) Loss of land capability

Land that could be used for cultivation is no longer available due to the establishment of the ADF.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Loss of land capability (All

Alternatives)

Planning -17.50 -4.00 -6.00

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


Alternatives)

Construction -20.00 -15.00 -27.50


Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


Alternatives)

Closure and

rehabilitation

-20.00 -8.25 -15.13


• Proper planning of project sequences;

• Topsoil stripping and stockpiling guidelines;

• Rehabilitation and monitoring plans;

• Ensure that, as far as possible, the ADF is situated on soils with low agricultural potential;

• Ensure proper storm water management designs are in place;

• Only the designated access routes are to be used to reduce any unnecessary compaction;

• If erosion occurs, corrective actions (erosion berms) must be taken to minimize any further erosion

from taking place;

• Topsoil is to be moved when the soil is dry, as to reduce compaction;

• The handling of the stripped topsoil will be minimized to ensure the soil's structure does not

deteriorate; and

• Compacted areas are to be ripped to loosen the soil structure and vegetation cover re-instated.

6.3.6 PRELIMINARY IMPACTS ON AIR QUALITY

The following preliminary impacts on the air quality within the study area were identified and assessed. Below

are the preliminary impacts on air quality are expected during the construction, operation and closure phases,

as well as the impact rating. No air quality impacts are expected during the planning or rehabilitation phases.

A) Degraded Ambient Air Quality during construction

The construction phase is relevant when the ash disposal facility is established as well as during continuous ash

disposal, as this would normally comprise a series of different operations including land clearing, topsoil

removal, road grading, material loading and hauling, stockpiling, compaction, etc. Each of these operations has

a distinct duration and potential for dust generation. It is anticipated that the extent of dust emissions would

vary substantially from day to day depending on the level of activity, the specific operations, and the prevailing

meteorological conditions. It is not anticipated that the various construction activities will result in higher off-

site impacts than the operational activities. The temporary nature of the construction activities, and the

likelihood that these activities will be localised and for small areas at a time, will reduce the potential for

significant off-site impacts.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Degraded air quality (All

Alternatives)




• Maintenance of vehicles and wet suppression or chemical treatment on unpaved road surfaces;

• Wet suppression on disturbed areas where feasible;

• Minimise extent of disturbed areas;

• Reduction of frequency of disturbance;

• Early re-vegetation; and

• Stabilisation (chemical, rock cladding or vegetative) of disturbed soil.

B) Degraded Ambient Air Quality during operation

Degraded ambient air quality during operation due to wind erosion. Dust will only be generated under conditions

of high wind speeds and from areas where the material is exposed and has dried out. A potentially significant

impacting source may be wind erosion from the ash dams during periods of high winds (>9m/s).

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


Alternatives)

Operation -10.50 -9.75 -13.00


• It is recommended that the sidewalls of the ash dams be vegetated. The vegetation cover should be

such to ensure at least 80% control efficiency. The top surface area should have 40% wet beach area (if

feasible and if wet deposition option is considered) and a water spraying system should be

implemented on the surface of the ash dam covering the outer perimeter of the dam, spraying water

when winds exceed 4 m/s.

C) Degraded Ambient Air Quality during closure

If rehabilitation is planned to occur continuously throughout the disposal of ash, dust may be generated from

the dried out exposed ash surfaces before it is covered with topsoil. Once vegetation is established the potential

for dust generation will reduce significantly. The tipping of topsoil and vehicle entrainment on associated

unpaved roads will also result in dust generation. It is assumed that all ash disposal activities will have ceased

during closure phase, when the power station has reached end of life. If most of the rehabilitation is undertaken

during the operations, the ash disposal facility should be almost completely rehabilitated by the closure phase.

The potential for impacts after closure will depend on the extent of continuous rehabilitation efforts on the ash

disposal facility.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


Alternatives)

Rehabilitation

and Closure

-7.50 -4.50 -6.00


• Ensure adequate cover of self-sustaining vegetation.


6.3.7 PRELIMINARY IMPACTS ON ARCHAEOLOGY AND PALAENTOLOGY

The following preliminary impacts on heritage and palaeontology within the study area were identified and

assessed. Below are the preliminary impacts. Impacts are only expected during the construction phase.

A) Destruction of Graves

Three cemeteries could be directly impacted by the proposed construction activities of the ADF but are situated

outside the proposed footprint areas and can be conserved with the necessary management measures. The

cemeteries have high heritage significance however none occur within the area proposed for Alternative 1.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Destruction of Graves (Alternative

1)


Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Destruction of Graves (Alternative

2)



• Demarcate the cemeteries inside the final development buffer as a no-go area during construction and

include a 50-meter buffer around the cemeteries.

B) Destruction of Historic Structures

Only one structure is situated inside the buffer area of Alternative 2 and should not be directly impacted by the

development. As no historic structures occur within the footprint of Alt1 site and buffer, no impacts are foreseen

for this Alternative. Or something like this wording.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Destruction of farmstead

(Alternative 1)


Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


Destruction of farmstead

(Alternative 2)



• Demarcate the site inside the final development buffer as a no-go area during construction and include

a 50 meter buffer around the cemetery.

• A single farmstead is situated inside the buffer area of Alternative 2 and should not be directly impacted

by the development. The cluster that historically functioned as a single farmstead is protected under

Section 34 of the NHRA and has a medium heritage significance and given a grading of Generally

protected B.

C) Destruction of Palaeontology

The palaeontological sensitivity of the area is rated as very high and will require a field assessment and finds

protocol as part of the EIA report.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Destruction of Graves (All

Alternatives)

Construction -12.00 -1.25 -1.88


• Mitigation depends on outcomes of EIA-phase field assessment but could include monitoring of

excavations during construction.

6.3.8 PRELIMINARY VISUAL IMPACTS

The proposed ADF will cause a partial loss of or alteration to key elements / features / characteristics of the

visual and landscape baseline including the introduction of project elements that may be prominent but may

not necessarily be considered to be substantially uncharacteristic when set within the attributes of the receiving

landscape. Visual impacts are only expected during construction and operation.

A) Impact on visual quality of study area during construction & decommissioning

Alteration to the visual quality of the study area due to the physical presence, scale and size of the ADF project

with a moderate impact on nearby residential / farmsteads and other public road (R104, local roads and farm

roads) view during construction and operation.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Visual Impact (All Alternatives) Construction &

closure

-11.00 -6.75 -10.13


• Earthworks should be executed in such a way that only the footprint and a small ‘construction buffer

zone’ around the proposed activities are exposed. In all other areas, the naturally occurring vegetation


and more importantly the indigenous vegetation should be retained, especially along the periphery of

the site.

• An ecological approach to rehabilitation and vegetative screening measures, as opposed to a

horticultural approach to landscaping should be adopted. For example, communities of indigenous

plants enhance biodiversity and blend well with existing vegetation. This approach can significantly

reduce long term costs as less maintenance would be required over conventional landscaping methods

as well as the introduced landscape being more sustainable.

• Should Site Alternative 2 be selected as the preferred site it is recommended that a row of trees

(vegetation screen) be planted along the R104 to screen the view from the R104 towards the ash

disposal facility. This will have a similar effect as the clump of trees located along the local road that

connects the R104 and Arnot / Rietkuil residential.

• Access and haul roads will require an effective dust suppression management programme.

• Paint any buildings and structures with colours that reflect and compliment the natural colours of the

surrounding landscape. To further reduce the potential of glare, the external surfaces of buildings and

structures should be articulated or textured to create interplay of light and shade.

B) Impact on visual quality of study area during operation

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance

Visual Impact (All Alternatives) Operation -18.75 -15.00 -22.50


• Install light fixtures that provide precisely directed illumination to reduce light “spillage” beyond the

immediate surrounds of the site.

• Avoid high pole top security lighting along the periphery of the site and use only lights that are activated

on illegal entry to the site.

• Minimise the amount of light fixtures to the bare minimum, including security lighting.

• Wherever possible, lights should always be directed downwards so as to avoid illuminating the sky.

• Dust suppression techniques should be in place at all times during all phases of the project.

• Should Site Alternative 2 be selected as the preferred site it is recommended that a row of trees

(vegetation screen) be planted along the R104 to screen the view from the R104 towards the ash

disposal facility. This will have a similar effect as the clump of trees located along the local road that

connects the R104 and Arnot / Rietkuil residential.

C) Impact on visual quality of study area during closure

At Closure, the ash disposal facility will remain and therefore the environmental risk for unmitigated impact

will remain moderate, if the site is effectively managed and rehabilitated, the mitigated environmental risk

could be low.

Impact Project

Phase

Pre-Mitigation

Score

Post-Mitigation

Score

Final

Significance


Visual Impact (All Alternatives) Closure -11.25 -6.50 -7.50


• During and closure of the project, access and haul roads will require an effective dust suppression

management programme; and

• Ensure effective rehabilitation.

6.4 CONSOLIDATED SENSITIVITY MAP

Environmental sensitivity mapping provides a strategic overview of the environmental, cultural and social assets,

opportunities, and constraints in a defined spatial context. The sensitivity mapping technique integrates

numerous datasets (basemaps and shapefiles) into a single consolidated layer making use of Geographic

Information System (GIS) software and analysis tools. Environmental sensitivity mapping is a rapid and objective

method applied to identify areas which may be particularly sensitive to development based on environmental,

cultural and social sensitivity weightings – which is determined by specialists input within each respective field

based on aerial or ground-surveys. Environmental sensitivity is used to aid in decision-making during

consultation processes, forming a strategic part of Environmental Assessment processes.

A consolidated sensitivity map showing all identified sensitivities is provided in Figure 22. The only areas of very

high sensitivity identified are the wetland systems present at both sites. No absolute “no-go” areas were

identified. Several high sensitivity areas were however identified within both site alternative areas. These are

highly sensitive ecological areas as well as rivers and their associated buffer zones. Several potential heritage

sites and sensitive visual receptors were also identified within both site areas and their respective buffer zones.


Figure 22: Combined sensitivity map

1140 Arnot Ash Disposal Facility Project cxiii

6.5 ASSUMPTIONS, LIMITATIONS AND GAPS IN KNOWLEDGE

Certain assumptions, limitations, and uncertainties are associated with the Scoping Phase specialist studies.

These are detailed for each aspect below.

Ecology

• Red List species are, by their nature, usually very rare and difficult to locate. Compiling the list of species

that could potentially occur in an area is limited by the paucity of collection records that make it difficult

to predict whether a species may occur in an area or not. The methodology used in this assessment is

designed to reduce the risks of omitting any species, but it is always possible that a species that does

not occur on a list may be located in an area where it was not formerly known to exist.

• Lists of threatened, rare and sensitive species are dynamic in the sense that new information is

collected on a continuous basis, information does not necessarily become quickly available in the public

domain and important information is sometimes only available from obscure or restricted sources.

There is therefore the possibility that species of concern for the site have not been detected from

general literature sources. The latest available information was used for this assessment.

• Animal species, especially birds, are mostly highly mobile and often migrate seasonally. Any field

assessment of relatively short duration is therefore unlikely to record anything more than the most

common species that happen to be on site at the time of the survey. Such field surveys are generally a

poor reflection of the overall diversity of species that could potentially occur on site.

• This study excludes any assessment of invertebrates.

• This study does not constitute a formal wetland study. If any wetlands occur on site, their description

is in terms of them being unique habitats and/or containing a unique species composition, but does not

constitute a legally determined wetland boundary.

• It is difficult to accurately map secondary grasslands from aerial imagery and areas currently mapped

as natural may possibly be secondary. The only way to accurately map such degradation is through

extensive field-based surveys where plant species composition can be used to confirm whether an area

is secondary or not. The budget and timeframes associated with this assessment are inadequate for

undertaking such a detailed study. Uncertainty surrounding the location of secondary grasslands

therefore remains.

Hydrology

• The total assessment of all probable scenarios or circumstances that may exist for the study area was

not undertaken. No assumptions should be made, unless opinions are specifically indicated and

provided. Data presented may not explain all possible conditions that may exist given the nature of the

enquiry.

• The information presented only has reference to the investigated study area(s) and cannot be applied

to any other area without prior investigation.

• The risk assessment was limited to the spatial extent of wetlands on each alternative and within a 1km

radius thereof.

• The risk assessment focussed in the placement of the ash disposal facility footprint and a 1km radius

thereof. The alternative alignments of associated linear infrastructure were not considered within this

scoping assessment.

• The impact assessment was based on the desktop delineation of the study areas with a brief site

inspection, carried out in January 2017. The scoping phase field assessment focussed on landscape

1140 Arnot Ash Disposal Facility Project cxiv

features, the presence of surface water and obligate and facultative wetland plant species. The soil

profile was not assessed during the scoping phase and will be assessed in the EIA phase.

Geohydrology

• No detailed, intrusive investigations were conducted, therefore the aquifer conditions have not been

verified and only desktop information has been included.

• No geophysical investigations have been conducted therefore the geological conditions have not been

confirmed and only mapped from desktop information.

• Access to certain hydrocensus boreholes were not available therefore this information was excluded in

the report.

Agricultural Potential

• Public participation comments have not yet been received, so specific responses to soil-related issues

cannot be supplied. These will be addressed in the EIA phase, as and when required.

• This scoping level assessment was conducted as a desktop study exercise only, no detailed site

inspections were completed, however detailed site inspections will be undertaken during the EIA phase.

Air Quality

• No on-site meteorological data was available. Use was therefore made of modelled MM5

meteorological data for the period 2013-2015.

• Measured ambient data is not available at the proposed project site. The closest monitoring stations

operated by DEA (Hendrina) and Eskom (Kwazamokuhle) are located approximately 18 km southwest

of the site. The measured ambient air quality at these sites may thus not be representative of ambient

air quality at the proposed project site.

Visual

• The study uses the worst-case scenario in predicting impacts (day time and night time);

• It was assumed that all residential units, as per the site visit, topographic map and aerial photographs,

were occupied.

Heritage and Palaeontology

• It is necessary to realise that the heritage resources located during the fieldwork do not necessarily

represent all the possible heritage resources present within the area. Various factors account for this,

including the subterranean nature of some archaeological sites and the current dense vegetation cover.

As such, should any heritage features and/or objects not included in the present inventory be located

or observed, a heritage specialist must immediately be contacted.

• Such observed or located heritage features and/or objects may not be disturbed or removed in any way

until such time that the heritage specialist has been able to make an assessment as to the significance

of the site (or material) in question. This applies to graves and cemeteries as well. In the event that any

graves or burial places are located during the development, the procedures and requirements

pertaining to graves and burials will apply.


7 PROJECT ALTERNATIVES

Section 2.3 of this report focused on the various development alternatives (process, activity and location

alternatives) and describes the various alternatives considered as part of the Arnot ADF project as well as how

the two preferred location alternatives were arrived at for assessment in this Scoping report. This section

describes the pros and cons of various alternatives as well as nomination of a preferred site for detailed

assessment in the EIA phase of the project. A comparison of the various process, activity and technology

alternatives is presented in Section 2.3 of this scoping report.

7.1 ALTERNATIVE ASSESSMENT

Table 23: Site Alternative Assessment

Specialist

Study

Alternative 1 Alternative 2

Ecology Negotiable Preferred

According to the Mpumalanga Biodiversity Conservation Plan (MBCP), remaining areas of natural vegetation on site within Alternative 1 are classified in all categories of the MBCP, except Protected, including a small area of habitat classified as Irreplaceable. The areas of higher significance are scattered throughout the centre of the Alternative 1 area and it may not be possible to avoid them by alternative placement of the infrastructure. Alternative 1 represents the highest direct impact on natural habitats although Alternative 1 is less likely to cause habitat fragmentation.

According to the Mpumalanga Biodiversity Conservation Plan (MBCP), remaining areas of natural vegetation on site within Alternative 2 are classified as Least Concern or No natural habitat remaining. Alternative 2 will have an intermediate direct impact on natural habitats and habitat fragmentation. Alternative 1 is more likely to impact on flora species of concern than Alternative 2. Alternative 2 appears to be the more favoured option from an ecological perspective.

Soils Preferred Negotiable

Alternative one shows lower agricultural potential from the areal imagery and therefore from an agricultural perspective Alternative 1 is the selected preferred site.

Alternative 2 shows lower agricultural potential from the areal imagery and is therefore less preferred.

Wetlands and Aquatic

Ecology

Restricted Preferred

A higher wetland extent within the primary study area was recorded at Alternative 1, with approximately 29.49 % of the area demarcated as a wetland. For the secondary study area (1km buffer area), Alternative 1 reflected less wetlands. However, based on the field observations, the wetlands situated within the

Alternative 2 reflected a lower wetland extent, with approximately 8.86 % of the area demarcated as wetlands. Alternative 2 represents less wetland areas within the primary study area and is therefore considered the preferred alternative in terms of wetland /aquatic ecology. Furthermore, Alternative 2 is closer to the existing infrastructure. It follows that it


secondary study area of Alternative 2, were more degraded compared to that of Alternative 1.

will require linear infrastructure over a shorter distance and will decrease the number of possible contamination pathways compared to Alternative 1.

Surface Water Negotiable Preferred

Site Alternative 1 is considered less preferred due to its proximity to two pans which slightly increases its impact significance rating over that of Site Alternative 2.

Site Alternative 2 has lower significance ratings for all assessed impacts and is, therefore, considered more suitable for the proposed Ash Disposal Facility project

Ground Water Negotiable Preferred

Shallow groundwater levels were measured ranging from 2.27 to 13.24mbgl. Seven boreholes are located within the 1km buffer zone, however three boreholes, HBH14, HBH16 and HBH24 are not currently in use. Therefore only four abstraction boreholes are present within the 1km buffer zone

Shallow groundwater levels were measured ranging from 4.62 to 6.67mbgl. Five boreholes are located within the 1km buffer zone, however three boreholes, HBH9, HBH22 and HBH23 are not currently in use. Therefore only two boreholes are present within the 1km buffer zone. Alternative 2 is marginally ranked as the more suitable option according the due to having fewer boreholes in use and groundwater users within a 1km radius of the site.

Heritage Preferred Negotiable

Alternative 1 is slightly preferred although the detailed EIA phase fieldwork will confirm this. The reason is due to the slightly lower significance of potential heritage resources located at Site Alterative 1.

Alternative 2 is less preferred although the detailed EIA phase fieldwork will confirm this. The reason is due to the slightly higher significance of potential heritage resources located at Site Alterative 2.

Visual Negotiable Negotiable

Site Alternative 1 will be located along the R104 and the visual impact will be absorbed by the existing mining activities. Although the site will be seen by viewers travelling along the R104 these viewers will only be exposed to Site Alternative 1 for a short period of time. Other sensitive viewers will include the surrounding farmsteads. Views from these locations will be fore and middle – ground views and even though the viewers are exposed to mining activities it should be noted that the mining activities were limited to background views. The new facility will now be located

Site Alternative 2 will be located between the R104 and the Wonderfontein Road. The proposed alternative is located in an agricultural area and close to the existing ash disposal facility and the Eskom Arnot Power Station. The proposed alternative will therefore be absorbed by the existing mining activities. Motorist travelling on the R104 or the Wonderfontein Rd will be exposed to the new ash disposal facility for a short period of time and will most likely have the existing mining activities as backdrop. Other sensitive viewers will include the surrounding farmsteads. Views from these locations will be fore and middle – ground views and even though the viewers are exposed to mining activities it


closer to the viewers and will be more intrusive and visible. The proposed Site Alternative 1 will have a moderate environmental risk during the construction and decommissioning phases of the project. With successful mitigation measures this can however be reduced to a low. The overall significance during this period of the project will be moderate. During the operational period the visual significance will however be high. Mitigation measures will be difficult due to the extent and height of the ash disposal facility but it should also be noted that the proposed project will be located on an elevated area.

should be noted that the mining activities were limited to background views. The new facility will now be located closer to the viewers and will be more intrusive and visible. The proposed Site Alternative 2 will have a moderate environmental risk during the construction and decommissioning phases of the project. With successful mitigation measures this can however be reduced to a low. The overall significance during this period of the project will be moderate. During the operational period the visual significance will however be high. Mitigation measures will be difficult due to the extent and height of the ash disposal facility but it should also be noted that the proposed project will be located on an elevated area. Site Alternative 1 and Site Alternative 2 are very similar when compared.

Air Quality Negotiable Negotiable

The significance ranking of Alternative 1 and Alternative 2 will be similar as the impacts offsite will be comparable in magnitude and spatial distribution

The significance ranking of Alternative 1 and Alternative 2 will be similar as the impacts offsite will be comparable in magnitude and spatial distribution

Engineering & Design Preferred Fatally Flawed

Relatively sparse vegetation cover and undulating topography facilitating effective drainage but not jeopardising slope stability. A 132kV power line runs through the north-western corner of the site however the site can be shifted within the 1km buffer area to avoid the power line.

There is a 132kV power line that runs through the middle of the site which will need to be relocated. The topographical arrangement has a single high point in the centre of facility which pose potential challenges with effectively draining the facility. This could either require deep excavations with high volume earthworks or two separate drainage systems which will double the implementation cost as well as maintenance costs. An existing raw water pipeline route goes through the centre of the site for the proposed ADF. The new dams cannot be positioned above the existing pipe. This is considered a fatal flaw from a design perspective.

As can be seen from Table 23, Site Alternative 2 is preferred from an Ecological, Wetlands, Groundwater and

Surface Water perspective. Site Alternative 1 is marginally preferred from a heritage as well as a soils

perspective. Site Alternative 2 is therefore nominated as the preferred site. However it was brought to the

attention of the EAP that there are four(4) raw water pipelines that run through the middle of site Alternative

2. The existence of the raw water pipelines was only brought to the attention of the EAP during the scoping

phase studies for the two sites.


The location of the raw water pipelines is indicated in Error! Reference source not found. The pipeline runs in a s

ervitude that follows the existing 132kV power line route through a small section of Site Alternative 1 and

through the centre of Site Alternative 2. According to Eskom the pipeline could be relocated but at the cost of

hundreds of millions of rand. Additionally the 132kV power line that runs through the middle of the site would

need to be relocated. However the site can be relocated within the 1km buffer zone to avoid the pipeline

servitude. A specialist workshop was held on 19 June 2018 to nominate a new suitable position for the site within

the 1km buffer area of Site Alternative 2. The new position of Site Alternative 2 is indicated in Figure 23 and

Figure 24 below. It is proposed that this is the site considered for detailed assessment in the EIA phase. The

main advantages of shifting the site north to the position shown in Figure 23 and Figure 24 are listed below:

• The site avoids the raw water pipelines servitude that would otherwise fatally flaw the site;

• The site is relatively close to the Arnot power station;

• The average slope of the site is relatively low compared to other potential suitable sites within the 1km

buffer;

• Fewer contamination pathways exist from a wetlands perspective than other suitable site options

within the 1km buffer zone; and

• The site is located further from pans or wetlands than other suitable site options within the 1km buffer

zone.

• Due to the location of the raw water pipeline Site Alternative 2 is still nominated as the preferred

alternative for assessment in the EIA phase however the site should be shifted north to avoid the

pipeline servitude. The preferred site position for detailed assessment in the EIA phase is indicated in

Figure 24.


Figure 23: Map showing position of raw water pipeline and new position for Site Alternative 2 within 1km buffer zone.


Figure 24: Map showing proposed site (and assoicated 1km buffer zone) to be considered for detailed assessment in the EIA phase.


8 PLAN OF STUDY FOR EIA

The section below outlines the proposed plan of study which will be conducted for the various environmental

aspects during the EIA Phase. The plan of study has been compiled by the specialist consultants contracted to

the project with select input from EIMS. It is also important to note that the plan of study will also be guided by

comment obtained from I&APs and other stakeholders during the PPP.

8.1 ALTERNATIVES TO BE CONSIDERED IN EIA

The alternatives considered and discussed in the above chapter have culminated into the identification of two

development alternatives. These development alternatives are discussed below.

8.1.1 NO GO ALTERNATIVE

The National Integrated Resource Plan 2016 (IRP) developed by the Department of Energy has identified the

need for power generation from coal as part of the technology mix for power generation in the country in the

next 20 years. In order for the Arnot power station to continue to produce power, a new ashing facility is

required to provide additional capacity. The 'do nothing' option will not address this need and will result in

reduced power generation activities at the power station and a reduction in the power stations lifespan.

This alternative will imply that no ash dump facility is constructed, and that the environment remains unchanged

and unaltered. This alternative will be investigated further in the EIA phase.

8.1.2 SITING ALTERNATIVE

Site Alternative 2 is preferred, however, due to the location of the raw water pipelines which pass through the

centre of Site Alternative , Site Alternative has been shifted north within the assessed 1km buffer zone to

avoid the pipeline route.

8.2 DESCRIPTION OF IMPACTS TO BE ASSESSED IN EIA

The following aspects will be assessed further during the EIA phase investigation to be undertaken:

• Ecology;

• Hydrology;

• Wetlands;

• Heritage including Palaeontological Assessment

• Noise;

• Visual;

• Geohydrology; and

• Air Quality.

8.3 DESCRIPTION OF SPECIALIST STUDIES

8.3.1 ECOLOGY

The following assessments should be undertaken during the EIA phase in order to properly assess potential

impacts on the ecological receiving environment by the proposed activity:

• The study area includes a combination of natural areas, degraded areas, secondary vegetation and

transformed areas. For all areas within proximity to the proposed activities, a general habitat survey

should be undertaken to confirm the status of habitat and to characterise it in terms of condition and

species composition and cover.


• The potential presence of plant species of concern must be evaluated within the footprint of proposed

activities. There are various plant species of concern that have been evaluated as having a high

probability of occurring on site, namely the Vulnerable species, Gladiolus paludosus, Khadia

carolinensis, Miroglossum davyi and Bowiea volubilis subsp. volubilis, the Near Threatened species,

Merwilla plumbea and Gladiolus robertsoniae, the Declining plant species, Boophane disticha, Eucomis

autumnalis & Hypoxis hemerocallidea, and the protected species, Merwilla plumbea and Crinum

bulbispermum.

• The potential presence of protected trees on site must be evaluated. There is one protected tree

species that could potentially occur on site, depending on the habitat that is affected. Although the

probability of this species occurring on site is considered to be low, this should be confirmed in the

field.

• The presence of species of concern or habitats that are important for particular species of concern must

be evaluated during the EIA phase. Particular attention should be paid to those species classified as

threatened (VU, EN or CR), Near Threatened or Critically Rare and which have a high probability of

occurring on site or being affected by the proposed activities. There are various animal species currently

listed as threatened or protected that are considered to have a medium to high probability of occurring

on site, based on habitat suitability, including the Brown Hyaena (NT), Serval (NT), Spotted-necked

Otter (NT), the South African Hedgehog (NT), the Giant Bullfrog (protected), the Coppery Grass Lizard

(NT), Breyer's Long-tailed Seps (VU), the Striped Harlequin Snake (NT), the African Marsh Harrier (EN),

the Yellow-billed Stork (EN), Burchell's Courser (VU), the African Grass Owl (VU), the Secretarybird (VU),

the Black Stork (VU), the Maccoa Duck (NT), the Red-footed Falcon (NT), the Greater Painted Snipe (NT)

and the Black-winged Pratincole (NT).

• The potential presence of suitable habitat should be evaluated during field surveys.

• There is an extensive system of wetlands in the study area, including a range of different wetland

habitats. The general presence of wetland habitat within any area affected by the proposed activities

must be evaluated.

The following methodology is proposed in order to obtain the information required for assessing impacts on

specific features of concern:

• Habitat condition and status can be determined on the basis of a combination of visual surveys,

vegetation structure and species composition. The relative composition of the vegetation is a powerful

source of information for providing information on the status of vegetation. A general survey should be

undertaken in areas within proximity to proposed activities, ensuring that all affected areas are

covered. Plant species composition, relative cover and vegetation structure data should be collected at

selected sites in order to characterise habitats properly. Photographs will also be taken as a visual

reference. A floristic list will be compiled. Any unknown species will be identified using published field

guides, expert knowledge or via collection of appropriate plant material.

• A targeted survey for plant species of concern must be undertaken within the footprint and nearby

areas. Habitat requirements and flowering times of all species are relatively well-known but could vary

from published information. There is also the possibility that other species of concern could occur on

site that were not on any database, but that occur on site. A general flora survey should therefore be

included to ensure that no additional species of concern occur on site. For any species that are

encountered, the exact locality and number of individuals must be recorded. Photographs must be

taken to confirm the identity of the species. The survey will be a visual survey on foot, with the purpose

of identifying the flora of the site. The timing of the survey depends on the best time for detecting these

species.

• A targeted survey for protected trees must be undertaken within the footprint and nearby areas of all

proposed activities. It is crucial for this that the footprint is known. For this survey, the exact location

of each individual must be recorded.


• A habitat survey will be undertaken during mid- to late summer when the vegetation has grown

sufficiently to be able to assess habitat suitability for the various faunal species of concern that could

potentially occur on site. Attention will be paid to the suitability of habitat for foraging, roosting and

breeding. The intention is to make a more informed decision on the importance of the site for the

various faunal species of concern that could potentially occur on site. If any species of concern are seen

on site then GPS co-ordinates of individuals will be obtained, as well as observations on numbers and

behaviour.

• For any areas affected by the proposed activities, including access routes and downslope areas, a survey

must be undertaken of wetland habitats that could potentially be affected. These wetland areas should

be characterised in terms of species composition, habitat type, general condition and

sensitivity/vulnerability to damage by the proposed activities. Habitat mapping should be enhanced

during these field surveys.

• A list will be compiled of any alien plant species that occur in the general area. This includes any species

listed according to the Conservation of Agricultural Resources Act and the National Environmental

Management: Biodiversity Act.

8.3.2 HYDROLOGY

Following on from this desktop surface water scoping report, a detailed surface water assessment will be

undertaken for the EIA phase of the project. This will include the calculation of 1:50- and 1:100-year flood lines,

a conceptual storm water management plan, calculation of a static water balance, a water quality analysis and

recommendations for a water quality monitoring plan, a management plan and a risk and mitigation assessment

to build on from that contained within this document.

8.3.3 AQUATIC ECOLOGY (WETLANDS)

An aquatic ecology survey will be undertaken to ascertain the Present Ecological State (PES) and Ecological

Importance and Sensitivity (EIS) of the rivers and wetlands located within the preferred alternative. The Scope

of Work that will be encompassed to reach the objective is summarised and outlined below and the following

information will be generated in the form of a detailed freshwater ecology report.

• Rivers: Sites will be strategically chosen, and biomonitoring methodology will be applied to ascertain

the PES of the associated systems.

• Wetlands: Wetland delineation and mapping (1:10 000) of wetlands associated with the preferred

alternative for the proposed expansion of the Arnot Ash Disposal Facility, using DWAF (2005)

methodology. Generation of PES and EIS data for the wetlands using Wet-EcoServices (Kotze et al.,

2009) and Wet-Health (MacFarlane et al., 2009). Identification of current impacts, including point and

non-point source impacts.

Deliverables include an analysis of habitat biotopes, diatom-, macroinvertebrate- and fish community structures

and in situ water quality where applicable, an analysis of the PES and EIS of relevant wetlands, a wetland

delineation and application of relevant buffer zones to delineated wetlands, a detailed report on the status of

the surface water ecology and wetlands, Identification of current impacts on rivers and wetland systems,

including point and non-point source impacts, and an impact assessment with regards to impacts of the

proposed Arnot Ash Disposal Facility on the surrounding aquatic ecosystems.

8.3.4 GEOHYDROLOGY

The following Scope of Work applies for the detailed Phase II study:

• Geophysical investigation to site the monitoring borehole positions;

• Monitoring well drilling of four monitoring wells of a depth of 40m;

• Aquifer testing of the newly drilled monitoring wells;


• Water quality sampling of the four newly drilling monitoring wells;

• Geochemical Assessment and Waste Classification of the ash material;

o Whole rock analyses (including TC values for Waste Classification)

o Acid-rock drainage potential

o Leach tests (including LC values for Waste Classification)

• Waste Classification of the ash;

• Geochemical modelling;

• Groundwater contaminant transport modelling; and

• Risk Assessment and Reporting.

8.3.5 HERITAGE AND FOSSILS

The Heritage Impact Assessment (HIA) report to be compiled by PGS Heritage (PGS) for the proposed Arnot ADF

will assess the heritage resources found on site. This report will contain the applicable maps, tables and figures

as stipulated in the NHRA (no 25 of 1999), the National Environmental Management Act (NEMA) (no 107 of

1998) and the Minerals and Petroleum Resources Development Act (MPRDA) (28 of 2002). The HIA process

consists of three steps:

• Step I – Literature Review: The background information to the field survey leans greatly on the Heritage

Scoping Report completed by PGS for this site.

• Step II – Physical Survey: A physical survey was conducted on foot and by vehicle through the proposed

project area by heritage specialists, aimed at locating and documenting sites falling within and adjacent

to the proposed development footprint. – Completed during the Scoping Phase

• Step III – The final step involves the assessment of resources in terms of the heritage impact assessment

criteria and report writing, as well as mapping and constructive recommendations.

Management actions and recommended mitigation, which will result in a reduction in the impact on the sites,

will be included.

A full paleontological field survey will also be undertaken in the EIA phase.

8.3.6 VISUAL

During the Impact Assessment Phase, a detailed impact assessment will be done for the preferred Site

Alternative. This will include the viewshed analysis as well as the photo simulations. Any additional comments

received during the public participation will be addressed as well.

8.3.7 AIR QUALITY

The main aim of this investigation was to provide the basis for the air quality impact assessment plan to be

conducted for the proposed project. The following will be included in the impact assessment study:

• Compilation of an emissions inventory, comprising the identification and quantification of potential

sources of emissions due to the proposed project;

• Dispersion simulations of particulate matter from the proposed project for applicable averaging

periods;

• Evaluation of potential for human health and environmental impacts; and,

• Determination of environmental risk according to stipulated Impact Assessment methodology.


8.3.8 NOISE

A detailed noise study will form part of the EIA specialist studies. Sensitive receptors around project will be

identified and evaluated in the report with regards to possible impacts by the current activities. This will be

done by evaluating the impact on both day and night time activities that impacts on these receptors. This will

indicate the possible impact at each receptor point. Suitable mitigation measures should then be proposed for

each impact on the sensitive receptors. A monitoring program will be proposed to evaluate the effectiveness of

the mitigation measures for each receptor.

8.3.9 TRAFFIC

A detailed traffic study will form part of the EIA specialist studies. The study will:

• Determine the existing traffic flows on adjacent road network in order to quantify the regional traffic

assessment;

• Identify current routes ability to handle super and abnormal loads;

• Proposed road upgrading in the area;

• Public transport and pedestrian activities; and

• Access arrangements.

8.4 ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

8.4.1 METHOD OF ASSESSING IMPACT SIGNIFICANCE

Method of Assessing Impacts:

The impact assessment methodology is guided by the requirements of the NEMA EIA Regulations (2014). The

broad approach to the significance rating methodology is to determine the environmental risk (ER) by

considering the consequence (C) of each impact (comprising Nature, Extent, Duration, Magnitude, and

Reversibility) and relate this to the probability/likelihood (P) of the impact occurring. This determines the

environmental risk. In addition, other factors, including cumulative impacts, public concern, and potential for

irreplaceable loss of resources, are used to determine a prioritisation factor (PF) which is applied to the ER to

determine the overall significance (S).

Determination of Environmental Risk:

The significance (S) of an impact is determined by applying a prioritisation factor (PF) to the environmental risk

(ER).

The environmental risk is dependent on the consequence (C) of the particular impact and the probability (P) of

the impact occurring. Consequence is determined through the consideration of the Nature (N), Extent (E),

Duration (D), Magnitude (M), and reversibility (R) applicable to the specific impact.

For the purpose of this methodology the consequence of the impact is represented by:

C= (E+D+M+R) x N

4

Each individual aspect in the determination of the consequence is represented by a rating scale as defined in

Table 24.

Table 24: Criteria for determining impact consequence


Nature - 1 Likely to result in a negative/ detrimental impact



+1 Likely to result in a positive/ beneficial impact

Extent 1 Activity (i.e. limited to the area applicable to the specific activity)

2 Site (i.e. within the development property boundary),

3 Local (i.e. the area within 5 km of the site),

4 Regional (i.e. extends between 5 and 50 km from the site)

5 Provincial / National (i.e. extends beyond 50 km from the site)

Duration 1 Immediate (<1 year)

2 Short term (1-5 years),

3 Medium term (6-15 years),

4 Long term (the impact will cease after the operational life span of the project),

5 Permanent (no mitigation measure of natural process will reduce the impact after

construction).

Magnitude/

Intensity

1 Minor (where the impact affects the environment in such a way that natural, cultural

and social functions and processes are not affected),

2 Low (where the impact affects the environment in such a way that natural, cultural

and social functions and processes are slightly affected),

3 Moderate (where the affected environment is altered but natural, cultural and social

functions and processes continue albeit in a modified way),

4 High (where natural, cultural or social functions or processes are altered to the

extent that it will temporarily cease), or

5 Very high / don’t know (where natural, cultural or social functions or processes are

altered to the extent that it will permanently cease).

Reversibility 1 Impact is reversible without any time and cost.



2 Impact is reversible without incurring significant time and cost.

3 Impact is reversible only by incurring significant time and cost.

4 Impact is reversible only by incurring prohibitively high time and cost.

5 Irreversible Impact

Once the C has been determined, the ER is determined in accordance with the standard risk assessment

relationship by multiplying the C and the P. Probability is rated/scored as per Table 25.

Table 25: Probability scoring

Pro

bab

ility

1 Improbable (the possibility of the impact materialising is very low as a result of design, historic

experience, or implementation of adequate corrective actions; <25%),

2 Low probability (there is a possibility that the impact will occur; >25% and <50%),

3 Medium probability (the impact may occur; >50% and <75%),

4 High probability (it is most likely that the impact will occur- > 75% probability), or

5 Definite (the impact will occur).

The result is a qualitative representation of relative ER associated with the impact. ER is therefore calculated as

follows:

ER= C x P

Table 26: Determination of Environmental Risk

Co

nse

qu

ence

5 5 10 15 20 25

4 4 8 12 16 20

3 3 6 9 12 15

2 2 4 6 8 10

1 1 2 3 4 5

1 2 3 4 5

Probability


The outcome of the environmental risk assessment will result in a range of scores, ranging from 1 through to 25.

These ER scores are then grouped into respective classes as described in Table 27.

Table 27: Significance classes

Environmental Risk Score

Value Description

< 9 Low (i.e. where this impact is unlikely to be a significant environmental risk),

≥9 <17 Medium (i.e. where the impact could have a significant environmental risk),

≥ 17 High (i.e. where the impact will have a significant environmental risk).

The impact ER will be determined for each impact without relevant management and mitigation measures (pre-

mitigation), as well as post implementation of relevant management and mitigation measures (post-mitigation).

This allows for a prediction in the degree to which the impact can be managed/mitigated.

Impact Prioritisation:

In accordance with the requirements of Appendix 3(3)(j) of the NEMA 2014 EIA Regulations (GNR 982), and

further to the assessment criteria presented in the Section above it is necessary to assess each potentially

significant impact in terms of:

• Cumulative impacts; and

• The degree to which the impact may cause irreplaceable loss of resources.

In addition, it is important that the public opinion and sentiment regarding a prospective development and

consequent potential impacts is considered in the decision-making process.

In an effort to ensure that these factors are considered, an impact prioritisation factor (PF) will be applied to

each impact ER (post-mitigation). This prioritisation factor does not aim to detract from the risk ratings but

rather to focus the attention of the decision-making authority on the higher priority/significance issues and

impacts. The PF will be applied to the ER score based on the assumption that relevant suggested

management/mitigation impacts are implemented.

Table 28: Criteria for determining prioritisation

Public response

(PR)

Low (1) Issue not raised in public response.

Medium (2) Issue has received a meaningful and justifiable public response.

High (3) Issue has received an intense meaningful and justifiable public response.

Cumulative

Impact (CI)

Low (1) Considering the potential incremental, interactive, sequential, and

synergistic cumulative impacts, it is unlikely that the impact will result in



Medium (2) Considering the potential incremental, interactive, sequential, and

synergistic cumulative impacts, it is probable that the impact will result in


High (3) Considering the potential incremental, interactive, sequential, and

synergistic cumulative impacts, it is highly probable/definite that the

impact will result in spatial and temporal cumulative change.

Irreplaceable

loss of

resources (LR)

Low (1) Where the impact is unlikely to result in irreplaceable loss of resources.

Medium (2) Where the impact may result in the irreplaceable loss (cannot be replaced

or substituted) of resources but the value (services and/or functions) of

these resources is limited.

High (3) Where the impact may result in the irreplaceable loss of resources of high

value (services and/or functions).

The value for the final impact priority is represented as a single consolidated priority, determined as the sum of

each individual criteria The impact priority is therefore determined as follows:

Priority = PR + CI + LR

The result is a priority score which ranges from 3 to 9 and a consequent PF ranging from 1 to 2 (Refer to Table

29).

Table 29: Determination of prioritisation factor

Priority Ranking Prioritisation Factor

3 Low 1

4 Medium 1.17

5 Medium 1.33

6 Medium 1.5

7 Medium 1.67

8 Medium 1.83

9 High 2

In order to determine the final impact significance, the PF is multiplied by the ER of the post mitigation scoring.

The ultimate aim of the PF is to be able to increase the post mitigation environmental risk rating by a full ranking

class, if all the priority attributes are high (i.e. if an impact comes out with a medium environmental risk after

the conventional impact rating, but there is significant cumulative impact potential, significant public response,

and significant potential for irreplaceable loss of resources, then the net result would be to upscale the impact

to a high significance).

Table 30: Final Environmental significance rating


Value Description



< -10 Low negative (i.e. where this impact would not have a direct influence on the decision to


≥ -10 < -20 Medium negative (i.e. where the impact could influence the decision to develop in the area).

≥ -20 High negative (i.e. where the impact must have an influence on the decision process to


0 No impact

< 10 Low positive (i.e. where this impact would not have a direct influence on the decision to


≥ 10 < 20 Medium positive (i.e. where the impact could influence the decision to develop in the area).

≥ 20 High positive (i.e. where the impact must have an influence on the decision process to


8.4.2 EVALUATION OF IMPACTS AND MITIGATION MEASURES

The significance of environmental impacts will be rated before and after the implementation of mitigation

measures. These mitigation measures may be existing measures or additional measures that may arise from the

impact assessment and specialist input. The impact rating system considers the confidence level that can be

placed on the successful implementation of the mitigation. The impact assessment methodology enables the

assessment of environmental issues including: the severity of impacts (including the nature of impacts and the

degree to which impacts may cause irreplaceable loss of resources), the extent of the impacts, the duration and

reversibility of impacts, the probability of the impact occurring, and the degree to which the impacts can be

mitigated.

The specialist studies will recommend practicable mitigation measures or management actions that effectively

minimise or eliminate negative impacts, enhance beneficial impacts, and assist project design. If appropriate,

the studies will differentiate between essential mitigation measures, which must be implemented and optional

mitigation measures, which are recommended (“nice-to-haves”).

8.4.3 PUBLIC CONSULTATION PROCESS IN ENVIRONMENTAL ASSESSMENT

An overview of the proposed public participation process to be followed for the EIA phase is provided below.

Forecast dates provided below may change as the project progresses but authority submission deadlines will be

strictly adhered to. The commenting periods that will be provided to an I&APs will be thirty (30) days long. Two

commenting periods will be provided during the project for the:

• One for the Scoping Report; and

• One for the EIA Report and EMPr.

Feedback from I&APs has been and will be solicited through the following means:

• Public meetings /Open Days;


• Advertisements;

• Site Notices and Posters;

• Registered Letters;

• Faxes and e-mails;

• Completion of the comment sheet/ questionnaires provided; and

• Any other communication with EIMS.

The public participation process was initiated on the 13th of July 2018 with an initial notification and call to

register. The initial 30 day commenting and review period of the Scoping Report will take place between the 13th

July 2018 and the 13th August 2018. Following this initial comment period a second scoping report will be made

available for public review for another 30 day period. All comments received during the initial call to register

and both Scoping Report comment periods will be included in the final Scoping Report submission to the

authorities.

The dates of the review and commenting period for the draft EIA report and associated EMPr will be determined

at a later date and communicated to all registered I&APs.

8.4.4 CONSULTATION PROCESS WITH COMPETENT AUTHORITY

The conditions of the scoping approval from the competent authority (if any) will be implemented through the

EIA process. A site visit and meeting with the competent authority shall be held, if requested. DEA will be invited

to all public-feedback meetings/ open days to be held. The EIA Report and EMPr will be submitted to DEA in

both draft and final formats.

8.4.5 DESCRIPTION OF EIA TASKS

The plan of study in terms of certain aspects is detailed in the above sections and is summarised below. The

following tasks will be undertaken as part of the EIA phase of the project:

• Specialist studies:

o Ecology;

o Hydrology;

o Geohydrology;

o Wetlands;

o Heritage (including Palaeontological Assessment);

o Noise;

o Visual;

o Traffic; and

o Air Quality.

• Public consultation:

o Notification regarding availability of EIA Report and EMPr.

o Public meeting or open day (EIA Phase).

• Authority consultation:

o Consultation with commenting authorities.


o Authorities meeting to provide authorities with project related information and obtain their

feedback (if requested).

• Document compilation:

o The EIA Report and EMPr will be compiled in line with the requirements of Appendix 3 and 4

of the EIA Regulations (2014).

o The EIA Report and EMPr will be made available for public comment for a period of 30 days.

The EIA Report and EMPr will be finalised and submitted to the competent authority.


9 UNDERTAKING OF THE ENVIRONMENTAL ASSESSMENT

PRACTITIONER

9.1 UNDERTAKINGS REGARDING CORRECTIONS OF INFORMATION

I _________________________ herewith undertake that the information provided in the foregoing report is

correct, and that the comments and inputs from stakeholders and Interested and Affected Parties have been

correctly recorded in the report.

Signature of the EAP

Date: 5 July 2018

9.2 UNDERTAKING REGARDING LEVEL OF AGREEMENT

I ___________________________________ herewith undertake that the information provided in the foregoing

report is correct, and that the level of agreement with Interested and Affected Parties and stakeholders has

been correctly recorded and reported herein.

Signature of the EAP

Date: 5 July 2018


10 REFERENCES

ABBEY, D., Ostro, B., & F, P. (1995). Chronic respiratory symptoms associated with estimated long-term ambient

concentrations of fine particulates less than 2.5 microns in aerodynamic diameter (PM2.5) and other air

pollutants. J Expo Anal Environ Epidemiol 5, 137–159.

AEPA South Australia. (2007). Guidelines for Seperation Distances. AEPA South Australia.

AGIS, 2007. Agricultural Geo-Referenced Information System, accessed from www.agis.agric.za on 2 December

2014.

Alade, O. L. (2009). Characteristics of particulate matter over the South African industrialised Highveld. MSc

dissertation. Faculty of Science, University of the Witwatersrand.

ALEXANDER, G. & MARAIS, J. 2007. A guide to the reptiles of southern Africa. Struik, Cape Town.

Barnard, H. C. and Baran, E. (1999). 2526 Johannesburg 1:500 000 Hydrogeological map series of the Republic

of South Africa

BARNES, K.N. (ed.) (2000) The Eskom Red Data Book of Birds of South Africa, Lesotho and Swaziland. Birdlife

South Africa, Johannesburg.

BATES, M.F., BRANCH, W.R., BAUER, A.M., BURGER, M., MARAIS, J., ALEXANDER, G.J. & DE VILLIERS, M.S. (eds).

2014 (reprint 2014). Atlas and Red List of the Reptiles of South Africa, Lesotho and Swaziland. Suricata 1. South

African National Biodiversity Institute, Pretoria.

BRANCH, W.R. (1988) South African Red Data Book—Reptiles and Amphibians. South African National Scientific

Programmes Report No. 151.

BROMILOW, C. 2010. Problem plants and alien weeds of South Africa. Briza, Pretoria.

CAMPBELL, PETA. date unknown. Rehabilitation recommendations after alien plant control and Wattle Control.

ARC-PPRI publication.

CEPA/FPAC Working Group. (1998). National Ambient Air Quality Objectives for Particulate Matter. Part 1:

Science Assessment Document. A Report by the Canadian Environmental Protection Agency (CEPA) Federal-

Provincial Advisory Committee (FPAC)on Air Quality Objectives and Guidelines.

CERC. (2004). ADMS Urban Training. Version 2. Unit A.

CHITTENDEN, H. 2007. Roberts bird guide: a comprehensive field guide to over 950 bird species in southern

Africa. John Voelcker Bird Book Fund, Cape Town.

CILLIERS, J.P. 2010. Phase 1 Archaeological Impact Assessment for Enpact Environmental Consultants concerning

the proposed Elandshoek township development on portions 2 and 6 of the farm Lindenau 303 JT and portion 2

of Berlin 466 JT, Mpumalanga Province. Kudzala Antiquity.

COLLETT, D.P. 1982. Excavations of Stone-Walled Ruin Types in the Badfontein Valley, Eastern Transvaal, South

Africa. The South African Archaeological Bulletin Vol. 37, No. 135 (Jun., 1982), pp. 34-43 Published by: South

African Archaeological Society. Article Stable URL: http://www.jstor.org/stable/3888578

CONANT, S. (1988). Saving Endangered Species by Translocation. Are we tinkering with evolution? BioScience,

38, 254-257.

CONSERVATION BIOLOGY INSTITUTE (2000). Review of potential edge effects on the San Fernando Valley

Spineflower (Chorizanthe parryi var. fernandina). Prepared for Ahmanson Land Company, West Covina,

California & Beveridge & Diamond, LLP, San Francisco, California.

Council for Geoscience (1986). 2528 Pretoria Geological map, 1:250 000.

Council for Geoscience (1986). 2628 East rand Geological map, 1:250 000.


Davidson, C. I., Phalen, R. F., & Solomon, P. A. (2005). Airborne Particulate Matter and Human Health: A Review.

Aerosol Science and Technology , Volume 39, Issue 8.

DEA. (2014). Regulations regarding Air Dispersion Modelling. Department of Environmental Affairs, Government

Gazette No. 37804, 11 July 2014.

DELIUS, P and Hay, M. 2009. Mpumalanga: An Illustrated History. The Highveld Press

DELIUS, Peter (ed). 2007. Mpumalanga: History and Heritage. University of Kwa-Zulu Natal Press.

DENT, M.C., LYNCH, S.D. & SCHULZE, R.E. 1989. Mapping mean annual and other rainfall statistics in southern

Africa. Department of Agricultural Engineering, University of Natal. ACRU Report No. 27. Massachusetts: Clark

University.

DEPARTMENT OF ENVIRONMENTAL AFFAIRS. DEA National Landcover (TIFF) [Raster] 2015. Available from the

Biodiversity GIS website, downloaded on 23 May 2016.

Department of Water and Sanitation (DWS) (2012). Aquifer Classification Map of South Africa.

Department of Water and Sanitation (DWS) (2013). Aquifer Vulnerability Map of South Africa.

Department of Water and Sanitation (DWS) (2013). Groundwater Resource Directed Measures (GRDM). Version

2.3.2.

Dockery, D. W., & Pope, C. A. (1994). Acute Respiratory Effects of Particulate Air Pollution. Annual Review of

Public Health, 15, 107 - 132.

DRIVER, A., MAZE, K., ROUGET, M., LOMBARD, A.T., NEL, J., TURPIE, J.K., COWLING, R.M., DESMET, P.,

GOODMAN, P., HARRIS, J., JONAS, Z., REYERS, B., SINK, K and STRAUSS, T. 2005. National Spatial Biodiversity

Assessment 2004: priorities for biodiversity conservation in South Africa. Strelitzia 17. South African National

Biodiversity Institute, Pretoria.

DU PREEZ, L. & CARRUTHERS, V. 2009. A complete guide to the frogs of southern Africa. Random House Struik,

Cape Town.

Ernst, W. (1981). Monitoring of particulate pollutants. In L. Steubing, & H.-J. Jager, Monitoring of Air Pollutants

by Plants: Methods and Problems. The Hague: Dr W Junk Publishers.

ESTERHUYSEN, A and Smith, J. 2007. Stories in Stone. Chapter 2 in Mpumalanga: History and Heritage. Evers,

T.M. 1975. Recent Iron Age Research In The Eastern Transvaal, South Africa. In The South African Archaeological

Bulletin, Vol. 30, No. 119/120 (Dec., 1975), pp. 71-83. South African Archaeological Society Stable URL:

http://www.jstor.org/stable/3888096 Accessed: 03/05/2012 08:54

FAIRBANKS, D.H.K., THOMPSON, M.W., VINK, D.E., NEWBY, T.S., VAN DEN BERG, H.M & EVERARD, D.A. 2000.

The South African Land-Cover Characteristics Database: a synopsis of the landscape. S.Afr.J.Science 96: 69-

82.Fourie, W. 2008a. Archaeological Impact Assessment: Northern Coal Portion 15 and 16 of the farm

Weltevreden 381 JT, Belfast, Mpumalanga. PGS.

FOURIE, W. 2008b. Archaeological Impact Assessments within South African Legislation. South African

Archaeological Bulletin 63 (187): 77–85, 2008

FOURIE, W. 2009. Arnot Colliery Mine Project of Exxaro On Portions 4 and 5 of the farm Mooifontein 448 JS and

Portions 3 And 4 of the farm Tweefontein 458 JS , District Middelburg, Mpumalanga

Fourie, W. 2016. Heritage Assessment - The Kwagga North Project, Optimum Coal, Arnot, Mpumalanga.

FRIEDMANN, Y. & DALY, B. (eds.) 2004. The Red Data Book of the Mammals of South Africa: A Conservation

Assessment: CBSG Southern Africa, Conservation Breeding Specialist Group (SSC/IUCN), Endangered Wildlife

Trust, South Africa.

GELBARD, J.L. & BELNAP, J. 2003. Roads as conduits for exotic plant invasions in a semiarid landscape.

Conservation Biology, 17(2), 420-432.


GERMISHUIZEN, G., MEYER, N.L., STEENKAMP, Y and KEITH, M. (eds.) (2006). A checklist of South African plants.

Southern African Botanical Diversity Network Report No. 41, SABONET, Pretoria.

Goldreich, Y., & Tyson, P. (1988). Diurnal and Inter-Diurnal Variations in Large-Scale Atmospheric Turbulence

over Southern Africa. South African Geographical Journal, 48-56.

Google Earth (2005). http://earth.google.com/. Google

Grantz, D. A., Garner, J. H., & Johnson, D. W. (2003). Ecological effects of particulate matter. Env. Int, 29 pp 213-

239.

GRIFFITH, B., SCOTT, J.M., CARPENTER, J.W. & REED, C. (1989). Translocation as a species conservation tool:

Status and strategy. Science, 245, 477 - 480.

HANSEN, M.J. & CLEVENGER, A.P. 2005. THE INFLUENCE OF DISTURBANCE AND HABITAT ON THE PRESENCE OF

NON-NATIVE PLANT SPECIES ALONG TRANSPORT CORRIDORS. BIOLOGICAL CONSERVATION, 125, 249-259.

Harmens, H., Mills, G., Hayes, F., Williams, P., & De Temmerman, L. (2005). Air Pollution and Vegetation. The

International Cooperative Programme on Effects of Air Pollution on Natural Vegetation and Crops Annual Report

2004/2005.

HENDERSON, L. 2001. Alien weeds and invasive plants. Agricultural Research Council.

HENNING, G.A., TERBLANCHE, R.F. and BALL, J.B. 2009. South African Red Data Book: butterflies. SANBI

Biodiversity Series 13. South African National Biodiversity Institute, Pretoria.

HENNING, S.F. & HENNING, G.A. 1989. South African Red Data Book - Butterflies. South African National Scientific

Programmes No. 158, Foundation for Research Development, CSIR, Pretoria.

Hirano, T., Kiyota, M., & Aiga, I. (1995). Physical effects of dust on leaf physiology of cucumber and kidney bean

plants. Environmental Pollution, 255–261.

HPA. (2011). Highveld Priority Area Air Quality Management Plan. Pretoria: Department of Environmental

Affairs, Chief Directorate: Air Quality Management.

HRUBA, F., Fabianova, E., Koppova, K., & Vandenberg, J. (2001). Childhood respiratory symptoms,hospital

admissions,and long-term exposure to airborne particulate matter. Journal of Exposure Analysis and

Environmental Epidemiology 11, 33–40.

IUCN (2001). IUCN Red Data List categories and criteria: Version 3.1. IUCN Species Survival Commission: Gland,

Switzerland.

IUCN 2014. The IUCN Red List of Threatened Species. Version 2014.3. <http://www.iucnredlist.org>.

Downloaded on 02 December 2014. [for details of threatened Mpumalanga invertebrates as at 2 December

2014 see http://www.iucnredlist.org/search/link/547d71ff-63b06a82]

JOOSTE, C.P. 2002. Anglo-Boer War Battles: The Battle Of Bergendal - The Last Pitched Battle Of The Anglo-Boer

War. Military History Journal Vol 12 No 4 - December

JOOSTE, C.P. 2008. Machadodorp tot en met dorpstigting in 1904 (Afrikaans), MA dissertation, University of

Pretoria, Pretoria, viewed 120501 http://upetd.up.ac.za/thesis/available/etd-11132008-124230

KITTO, J. 2012. Exxaro Paardeplaats Project Heritage Impact Assessment Report

KITTO, J. 2015. Proposed expansion of existing mining area into portion re of the farm Roetz 210 IS, Jagtlust

Colliery, near Carolina, Albert Luthuli Local Municipality, Gert Sibande District Municipality, Mpumalanga

Province .

MACVICAR, C. N., SCOTNEY, D. M. SKINNER, T. E. NIEHAUS, H. S. & LOUBSER, J. H., 1974. A classification of land

(climate, terrain form, soil) primarily for rainfed agriculture. S. Afr. J. Agric. Extension, 3(3): 1-4.

MAGGS, T. 1995. Neglected Rock Art: The Rock Engravings of Agriculturist Communities in South Africa Reviewed

work(s): Source: The South African Archaeological Bulletin, Vol. 50, No. 162 (Dec.), pp. 132-142 Published by:


South African Archaeological Society Stable URL: http://www.jstor.org/stable/3889062. Accessed: 01/05/2012

01:40

MARAIS, J. 2004. A complete guide to the snakes of southern Africa. Struik Publishers, Cape Town.

Mason, R.J. 1968. Transvaal and Natal Iron Age settlement revealed by aerial photography and excavation.

African Studies 27: 167-179.

MECENERO S., BALL J.B., EDGE D.A., HAMER M.L., HENNING G.A., KRÜGER M.A., PRINGLE E.L., TERBLANCHE R.F.

& WILLIAMS M.C. (eds) 2013. Conservation Assessment of Butterflies of South Africa, Lesotho and Swaziland:

Red List and Atlas. Saftronics (Pty) Ltd., Johannesburg & Animal Demography Unit, Cape Town. 676 pp.

MILLS, G. & HES, L. 1997. The complete book of southern African mammals. Struik Publishers, Cape Town.

MINTER, L.R., BURGER, M., HARRISON, J.A., BRAACK, H.H., BISHOP, P.J. and KLOEPFER, D. (eds.) 2004. Atlas and

Red Data Bookof the Frogs of South Africa, Lesotho and Swaziland. SI/MAB Series #9. Smithsonian Institution,

Washington, DC.

MONADJEM, A., TAYLOR, P.J., COTTERILL, E.P.D. & SCHOEMAN, M.C. 2010. Bats of southern and central Africa.

Wits University Press, Johannesburg.

Morris, D. 2008. Archaeological and Heritage Impact Assessment on Remainder of Carter Block 458, near Lime

Acres, Northern Cape. McGregor Museum.

MPUMALANGA TOURISM AND PARKS AGENCY. MBSP Terrestrial Assessment 2014 [Vector] 2014. Available from

the Biodiversity GIS website, downloaded on 06 February 2017.

MUCINA, L. AND RUTHERFORD, M.C. (editors) 2006. Vegetation map of South Africa, Lesotho and Swaziland: an

illustrated guide. Strelitzia 19, South African National Biodiversity Institute, Pretoria.

MUCINA, L., HOARE, D.B., Lotter, M.C., du Preez, J., Rutherford, M.C., Scott-Shaw, R., Bredenkamp, G.J., Powrie,

L.W., Scott, L., Camp, K.G.T., Cilliers, S.S., Bezuidenhous, H., Mostert. T.H., Siebert, S.S., Winter, P.J.D., Burrows,

J.E., Dobson, L., Ward, R.A., Stalmans, M., Oliver, E.G.H., Siebert, F., Schmidt, E., Kobisi, K. & Kose, K. 2006b.

Grassland Biome. In: MUCINA, L. & RUTHERFORD, M.C. (editors). The Vegetation of South Africa, Lesotho and

Swaziland. Strelitzia 19, South African National Biodiversity Institute, Pretoria.

MUCINA, L., RUTHERFORD, M.C. AND POWRIE, I.W. (editors) 2005. Vegetation map of South Africa, Lesotho and

Swaziland, 1:1 000 000 SCALE SHEET MAPS South African National Biodiversity Institute, Pretoria.

NAIDOO, G., & Chirkoot, D. (2004). The effects of coal dust on photosynthetic performance of the mangrove,

Avicennia marina in Richards Bay, South Africa. Environmental Pollution, 359–366.

PAKENHAM, T. 1979. The Boer War. Jonathan Ball Paperbacks. Johannesburg

PASSMORE, N.I. & CARRUTHERS, V.C. (1995) South African Frogs; a complete guide. Southern Book Publishers

and Witwatersrand University Press. Johannesburg.

PELSER, A. 2012. A report on a heritage assessment for the proposed Arnot-Gumeni 400 kv powerline project,

in the Middelburg/Belfast area, Mpumalanga Province

PISTORIUS, J. C. C. 2004. A Heritage Impact Assessment (HIA) study for the proposed New Optimum Colliery on

the farm Schoonoord 164IS in the Mpumalanga Province of South Africa

PISTORIUS, J. C. C. 2014. A phase I Heritage Impact Assessment (HIA) study for the consolidated Environmental

Management Programme report (consolidated EMPR) for Arnot Coal on the eastern highveld in the Mpumalanga

Province .

PISTORIUS, J. C. C. 2014. A revised phase I Heritage Impact Assessment (HIA) study for the proposed Rietvlei

open cast coal mining operation between Middelburg, Belfast and Stofberg in the Mpumalanga province of

South Africa.

Pope, C. (2000). Epidemiology of fine particulate air pollution and human health: biologic mechanisms and who’s

at risk? Environmental Health Perspectives, 713-723.


Pope, C., Burnett, R., Thun, M., Calle, E., Krewski, D., Ito, K., & Thurston, G. (2002). Lung cancer, cardiopulmonary

mortality, and long term exposure to fine particulate air pollution. . Journal of the American Medical Association,

1132-1141.

Republic of South Africa. National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008).

Ricks, G., & Williams, R. (1974). Effects of atmospheric pollution on deciduous woodland part 2: effects of

particulate matter upon stomatal diffusion resistance in leaves of Quercus petraes (Mattuschka) Leibl.

Environmental Pollution, 87–109.

ROYAL DE L’AFRIQUE CENTRALE, Ser. IN-8o 221: 1-472.

RSA National Geospatial Institute. 2529DC, DD, 2629BA, BB, 1:50 000 Topographical series.

RUTHERFORD, M.C. & WESTFALL, R.H. (1994). Biomes of southern Africa: an objective categorization. Memoirs

of the Botanical Survey of South Africa No. 63.

SAMWAYS, M.J. 2006. National Red List of South African Odonata. Odonatologica35(4): 341-368.

SAMWAYS, M.J. and TAYLOR, S. 2004. Impacts of alien invasive plants on Red-Listed South African dragonflies

(Odonata). South African Journal of Science 100: 78-80.

SHAO, Y. (2008). Physics ad Modelling of Wind Erosion. Atmospheric and Oceanographic Science Library, 2nd

Revised and Expanded Edition. Springer Science.

SNEERINGER, S. (2009). Does Animal Feeding Operation Pollution Hurt Public Health? A National Longitudinal

Study of Health Externalities Identified by Geographic Shifts in Livestock Production. American Journal of

Agricultural Economics, Vol. 91, No. 1, pp. 124-137.

South African Bureau of Standards (SABS) (2015). South African National Standard: Drinking Water Part 1:

Microbiological, physical, aesthetic and chemical determinants: SANS 241-1:2015 2nd Ed. ISBN 978-0-626-

29841-8

SPENCEr, S. (2001). Effects of coal dust on species composition of mosses and lichens in an arid environment.

Arid Environments 49, 843-853.

TARBOTON, W. and TARBOTON, M. 2002. A Fieldguide to the Dragonflies of South Africa. Published by the

authors, 95pp.

TARBOTON, W. and TARBOTON, M. 2005. A Fieldguide to the Damselflies of South Africa. Published by the

authors, 95pp.

TIWARY, A., & Colls, J. (2010). Air Pollution: Measurement, Modelling and Mitigation.

TOLLEY, K. & BURGER, M. 2007. Chameleons of southern Africa. Struik Publishers, Cape Town.

US EPA. (2006). AP 42, 5th Edition, Volume I, Chapter 13: Miscellaneous Sources, 13.2.4 Aggregate Handling and

Storage Piles.

VAN SCHALKWYK, J 2007. Heritage Impact Scoping Report for the Planned Hendrina-Marathon Power line,

Mpumalanga Province

VAN WYK, A.E. & SMITH, G.F. 2001. REGIONS OF FLORISTIC ENDEMISM IN SOUTHERN AFRICA. UMDAUS PRESS,

HATFIELD.

VEGTER. J. R. (1995). Groundwater Resources of the Republic of South Africa. Water Research Commission.

Department of Water Affairs and Forestry. Printpak Transvaal. South Africa.

VICTOR, J.E. & KEITH, M. 2004. THE ORANGE LIST: A SAFETY NET FOR BIODIVERSITY IN SOUTH AFRICA. SOUTH

AFRICAN JOURNAL OF SCIENCE 100: 139–141.

VICTOR, J.E. 2006. DATA DEFICIENT FLAGS FOR USE IN THE RED LIST OF SOUTH AFRICAN PLANTS. BOTHALIA 36,1:

85–86.

WERNER, K. 2000. The Tiger Beetles of Africa, Volumes 1 and 2, Taita Publishers.


WHISENANT, S.G. (1999). Repairing Damaged Wildlands: A process-orientated, landscape-scale approach.

Cambridge University Press. Cambridge

ZAR, J.H. 1996, Biostatistical Analysis, 3rd ed., Prentice-Hall, New Jersey.

Google Earth

GOOGLE EARTH. 6.0.12032 Beta.

Aerial depictions the Heritage Scoping Report are from Google Earth.

World Wide Web References:

www.angloboerwar.com

www.dwaf.gov.za/wfw/Control/docs/controltables.doc: The Working for Water Programme's website.

www.sahistory.org.za

www.sahra.org.za

www.wikipedia.org

http://www2.lib.uct.ac.za/mss/bccd/)

ASH DISPOSAL FACILITY SCOPING REPORT

Documents

Transcript of ASH DISPOSAL FACILITY SCOPING REPORT