MINING APPLICATION FOR BORROW PIT SITES LOCATED … Green Mining Application PdL120... · EOH...

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MINING APPLICATION FOR BORROW PIT SITES LOCATED BETWEEN NCGOBO AND MTHATHA, EASTERN CAPE PROVINCE, SOUTH AFRICA DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT DMR REF: EC30/5/1/3/3/2/1/00063EM Prepared for: Prepared for: JG Africa (Pty) Ltd On behalf of: South African National Roads Agency Ltd (SANRAL) Prepared by: EOH Coastal & Environmental Services EAST LONDON 25 Tecoma Street, Berea East London, 5214 043 726 7809 Also in Grahamstown, Port Elizabeth, Cape Town, Johannesburg and Maputo www.cesnet.co.za February 2017

Transcript of MINING APPLICATION FOR BORROW PIT SITES LOCATED … Green Mining Application PdL120... · EOH...

Page 1: MINING APPLICATION FOR BORROW PIT SITES LOCATED … Green Mining Application PdL120... · EOH Coastal & Environmental Services 1 Jeffares & Green R61 Mining Application 1. INTRODUCTION

MINING APPLICATION FOR BORROW PIT SITES LOCATED BETWEEN NCGOBO AND MTHATHA, EASTERN CAPE PROVINCE, SOUTH AFRICA

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

DMR REF: EC30/5/1/3/3/2/1/00063EM

Prepared for:

Prepared for:

JG Africa (Pty) Ltd

On behalf of:

South African National Roads Agency Ltd

(SANRAL)

Prepared by:

EOH Coastal & Environmental Services EAST LONDON

25 Tecoma Street, Berea East London, 5214

043 726 7809 Also in Grahamstown, Port Elizabeth, Cape Town, Johannesburg and Maputo

www.cesnet.co.za

February 2017

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This Report should be cited as follows: EOH Coastal & Environmental Services, February 2017: Mining Application for Borrow Pit Sites Between Mthatha and Ngcobo: Draft Environmental Impact Assessment Report, EOH, East London.

REVISIONS TRACKING TABLE

EOH Coastal and Environmental Services

Report Title: Mining Application for Borrow Pit Sites Between Mthatha and Ngcobo: Draft Environmental Impact Assessment Report

Report Version: Draft Project Number: 120

Name Responsibility Signature Date

Peter De Lacy Report Writer

February 2017

Dr Alan Carter

Reviewer

February 2017

Copyright

This document contains intellectual property and proprietary information that is protected by copyright in favour of Coastal & Environmental Services (Pty) Ltd. and the specialist consultants. The document may therefore not be reproduced, used or distributed to any

third party without the prior written consent of Coastal & Environmental Services. Although this document is prepared exclusively for submission to the Department of Mineral Resources, Coastal & Environmental Services (Pty) Ltd retains ownership of the

intellectual property and proprietary information contained herein, which is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of

South Africa.

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TABLE OF CONTENTS 1. INTRODUCTION ..................................................................................................................... 1

1.1 Background to the Study ................................................................................................. 1 1.2 Environmental Authorisation in South Africa .................................................................... 1 1.3 The Environmental Impact Assessment Process ............................................................. 2 1.4 Scoping Phase ................................................................................................................ 1 1.5 The Environmental Impact Assessment Phase ................................................................ 1 1.6 Mining Right Application .................................................................................................. 2 1.7 Nature and Structure of this Report ................................................................................. 2 1.8 Assumptions and Limitations ........................................................................................... 2 1.9 Details and Expertise of the Environmental Assessment Practitioner .............................. 3

1.9.1 Details of the EAP........................................................................................................ 3 1.9.2 Expertise of the study team ......................................................................................... 3

2. LOCATION OF ACTIVITY ...................................................................................................... 5 2.1 Property Locality .............................................................................................................. 5

3. PROJECT DESCRIPTION ...................................................................................................... 8 3.1 Description of Proposed Activity ...................................................................................... 8 3.2 Listed activities triggered ............................................................................................... 12

4. RELEVANT LEGISLATION .................................................................................................. 13 4.1 Relevant Legislation and Guidelines used in the Compilation of this Environmental Impact Assessment Report ....................................................................................................... 13 4.2 Relevant policy .............................................................................................................. 14

4.2.1 National Policy ........................................................................................................... 14 4.2.2 Provincial Policy ........................................................................................................ 14

4.3 Municipal by-laws and planning ..................................................................................... 15 4.3.1 The KSD LM IDP (2013/2014) ................................................................................... 15

5. PROJECT NEED & DESIRABILITY ..................................................................................... 16 6. PROJECT ALTERNATIVES ................................................................................................. 17

6.1 Reasonable and Feasible Alternatives ........................................................................... 17 6.2 Fundamental Alternatives .............................................................................................. 17 6.3 Incremental Alternatives ................................................................................................ 17 6.4 No-Go development ...................................................................................................... 17 6.5 Analysis of alternatives .................................................................................................. 18

7. PUBLIC PARTICIPATION .................................................................................................... 23 7.1 Notification of Interested and Affected Parties ............................................................... 23

7.1.1 Public Participation .................................................................................................... 23 7.1.2 Newspaper advertisement ......................................................................................... 23 7.1.3 On-site Notice ............................................................................................................ 23 7.1.4 Stakeholders and I&APs ............................................................................................ 23 7.1.5 Background information document ............................................................................ 24 7.1.6 Proof of notification .................................................................................................... 24 7.1.7 Issues raised by stakeholders/ I&APs ........................................................................ 24

8. DESCRIPTION OF THE ENVIRONMENT ............................................................................. 25 8.1 The Bio-Physical Environment ....................................................................................... 25

8.1.1 Current land use ........................................................................................................ 25 8.1.2 Climate ...................................................................................................................... 27 8.1.3 Topography ............................................................................................................... 27 8.1.4 Geology and soils ...................................................................................................... 29 8.1.5 Rivers and wetlands .................................................................................................. 31 8.1.6 Vegetation ................................................................................................................. 33

8.2 Conservation and spatial planning tools ........................................................................ 35 8.2.1 NEMBA – Threatened Ecosystems ............................................................................ 35 8.2.2 Eastern Cape Biodiversity Conservation Plan ............................................................ 37

8.3 Socio-Economic Profile.................................................................................................. 42 8.3.1 Population ................................................................................................................. 42 8.3.2 Employment ............................................................................................................... 42

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8.3.3 Education .................................................................................................................. 42 9. APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMENT .................................... 43

9.1 General Impact Assessment .......................................................................................... 43 9.2 Specialist Impact Assessments ..................................................................................... 43 9.3 Methodology for Assessing Impacts and Alternatives .................................................... 43

9.3.1 Description of criteria ................................................................................................. 44 10. KEY FINDINGS OF THE SPECIALIST STUDIES ................................................................. 47

10.1 Specialist studies ........................................................................................................... 47 10.1.1 Paleontological Impact Assessment ....................................................................... 47 10.1.2 Heritage Impact Assessment ................................................................................. 47

11. IMPACT ASSESSMENT ....................................................................................................... 49 11.1 Possible Environmental Issues and Impacts .................................................................. 49

11.1.1 General Impact Assessment .................................................................................. 49 11.1.2 Specialist Impact Assessment ............................................................................... 50

12. IMPACT STATEMENT .......................................................................................................... 55 12.1 Environmental impact statement .................................................................................... 55

12.1.1 Comparative assessment of impacts ..................................................................... 56 12.2 Overall site sensitivity .................................................................................................... 57 12.3 Consideration of alternatives ......................................................................................... 58

12.3.1 Location alternatives .............................................................................................. 58 12.3.2 Technology alternatives ......................................................................................... 58 12.3.3 Layout alternatives ................................................................................................. 58

13. CONCLUSION, EAP OPINION AND RECOMMENDATIONS .............................................. 59 13.1 Description of the proposed activity ............................................................................... 59 13.2 Assumptions, uncertainties and gaps ............................................................................ 60 13.3 Opinion of the EAP ........................................................................................................ 60 13.4 Recommendations of the EAP ....................................................................................... 60

13.4.1 Recommended mitigation measures ...................................................................... 61 13.5 Declaration by the EAP.................................................................................................. 64

14. ADDITIONAL INFORMATION .............................................................................................. 65 14.1 Financial provisions for rehabilitation ............................................................................. 65

15. REFERENCES...................................................................................................................... 66 16. APPENDICES ....................................................................................................................... 67

16.1 Appendix A: Public participation documents .................................................................. 67 16.2 Appendix B .................................................................................................................. 102

16.2.1 Impact assessment .............................................................................................. 102 16.3 APPENDIX C: Specialist Volume ................................................................................. 108 16.4 Appendix D: Environmental Management Programme ................................................ 109

LIST OF FIGURES

Figure 1.1 The EIA process. ................................................................................................................................... 3 Figure 2.1. Locality map of the three SANRAL Borrow pit sites between Engcobo and Mthatha, Eastern

Cape. ................................................................................................................................................................. 7 Figure 3.1 Proposed layout of Borrow Pit 1 .......................................................................................................... 10 Figure 3.3 Proposed layout of Borrow Pit 3 .......................................................................................................... 11 Figure 8.1: Land use for BP01 and surrounding areas........................................................................................ 25 Figure 8.2: Land use for BP02 and surrounding areas........................................................................................ 26 Figure 8.3: Land use for BP03 and surrounding areas........................................................................................ 26 Figure 8.4: Topography for BP01 and surrounding areas. .................................................................................. 27 Figure 8.5: Topography for BP02 and surrounding areas. .................................................................................. 28 Figure 8.6: Topography for BP03 and surrounding areas. .................................................................................. 28 Figure 8.7: Geology for BP01 and surrounding areas. ........................................................................................ 29 Figure 8.8: Geology for BP02 and surrounding areas. ........................................................................................ 30 Figure 8.9: Geology for BP03 and surrounding areas. ........................................................................................ 30 Figure 8.10: Surface hydrology for BP01 and surrounding areas. ..................................................................... 31 Figure 8.11: Surface hydrology for BP02 and surrounding areas. ..................................................................... 32 Figure 8.12: Surface hydrology for BP03 and surrounding areas. ..................................................................... 32

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Figure 8.13: Vegetation for BP01 and surrounding areas (Mucina & Rutherford, 2014). ................................. 33 Figure 8.14: Vegetation for BP02 and surrounding areas (Mucina & Rutherford, 2014). ................................. 34 Figure 8.15: Vegetation for BP03 and surrounding areas (Mucina & Rutherford, 2014). ................................. 34 Figure 8.16: NEMBA Threatened Ecosystems for BP01 and surrounding areas. ............................................. 36 Figure 8.17: NEMBA Threatened Ecosystems for BP02 and surrounding areas. ............................................. 36 Figure 8.18: NEMBA Threatened Ecosystems for BP03 and surrounding areas. ............................................. 37 Figure 8.19: ECBCP for BP01 and surrounding areas. ....................................................................................... 38 Figure 8.20: ECBCP for BP02 and surrounding areas. ....................................................................................... 39 Figure 8.21: ECBCP for BP03 and surrounding areas. ....................................................................................... 39 Figure 8.22: ECBCP Aquatic for BP01 and surrounding areas. ......................................................................... 40 Figure 8.23: ECBCP Aquatic for BP02 and surrounding areas. ......................................................................... 41 Figure 8.24: ECBCP for BP03 and surrounding areas. ....................................................................................... 41 Figure 8.14. Employment figures for the KSDLM (StatsSA, 2011). .................................................................... 42 Figure 12.1 Sensitivity map of the study area. ..................................................................................................... 58

LIST OF PLATES Plate 6.1: Preferred layout alternative for borrow Pit 1 (heritage sites indicated by the red circle) .................. 22 Plate 6.1 cont.: Preferred layout alternative for borrow Pit 2 (heritage sites indicated by the red circle) ........ 22

LIST OF TABLES Table 2.1: Property details ....................................................................................................................................... 5 Table 2.2: Coordinates of the corner points of the three borrow pit sites. ........................................................... 5 Table 3.1: Size of mining activities within each of the borrow pits. ....................................................................... 8 Table 3.2: Listed activities triggered by the proposed three Borrow pits ............................................................ 12 Table 4.1: Environmental legislation considered in the preparation of this Environmental Impact Assessment

Report. ............................................................................................................................................................ 13 Table 6.1: The alternatives considered for the proposed 3 Borrow Pits. ........................................................... 19 Table 9.1: Significance Rating Table .................................................................................................................... 44 Table 9.2 Impact Severity Rating .......................................................................................................................... 45 Table 9.3 Overall Significance Rating ................................................................................................................... 45 Table 11.1 Summary of the issues identified and their applicability in each phase. ......................................... 50 Table 11.2. Summary of all General and Specialist Impacts. ............................................................................. 52 Table 12.1 High impacts identified for the proposed dolerite quarry. ................................................................. 55 Table 12.2 Comparative Assessment of General Impacts occurring in all phases for the proposed borrow pits

(+ = beneficial impact) ................................................................................................................................... 56 Table 12.3 Comparative Assessment of Heritage Impacts occurring in all phases for the proposed borrow

pits (+ = beneficial impact)............................................................................................................................. 57 Table 12.5 Impacts associated with the No-go alternative. ................................................................................. 57

LIST OF ACRONYMS

BID: Background Information Document

CBA: Critical Biodiversity Areas

CITES: Committee for International Trade in Endangered Species

DEA: Department of Environmental Affairs

DWS: Department of Water and Sanitation

EAP:

Environmental Assessment Practitioner

EO Environmental Officer

EM Environmental Manager

EIA: Environmental Impact Assessment

EIR: Environmental Impact Report

EMPr: Environmental Management Programme

GNR: Government Notice Regulation

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ha: Hectare

I&APs: Interested and Affected Parties

IDP: Integrated Development Plan

NEMA: National Environmental Management Act 107 of 1998 as amended

NFEPA National Freshwater Ecosystem Priority Area

PoS: Plan of Study

PAES Protected Areas Expansion Strategy

PPP: Public Participation Process

RDB: Red Data Book

SAHRA South African Heritage Resources Agency

SANBI South African National Biodiversity Institute

SCC: Species of Conservation Concern

ToR: Terms of Reference

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1. INTRODUCTION

1.1 Background to the Study The South African National Roads Agency Soc. Ltd. (SANRAL) will be making various safety improvements on Sections 6 & 7 of the R61 National Route between All Saints (km 68.50) and Baziya (km 12.00) outside Mthatha in the Eastern Cape Province. Three (3) Borrow Pit sites are required to supply the necessary material for the regravelling of roads, maintenance of existing culverts and where required, the installation of stormwater infrastructure on certain municipal gravel roads. This all forms part of the Rural Roads Regravelling Programme. Three existing borrow pits have been identified as potential sources of gravel wearing course material approximately 60 km south-west of Mthatha in the King Sabata Dalindyebo Local Municipality (KSDLM), Eastern Cape. In terms of Section 106 of the Mineral and Petroleum Resources Development Act (MPRDA No. 28 of 2002;) SANRAL is exempted from the application for a Mining Permit for the mining sites but is not exempted from the application for environmental authorisation. EOH has been appointed by SANRAL as the EAP to undertake the EIA for the proposed borrow pits.

1.2 Environmental Authorisation in South Africa The primary legislation regulating Environmental Impact Assessments (EIA) within South Africa is the National Environmental Management Act (NEMA, Act 107 of 1998). NEMA makes provision for the Minister of Environmental Affairs to identify activities which may not commence prior to authorisation from either the Minister or the provincial Member of the Executive Council (MEC). In addition to this, NEMA also provided for the formulation of regulations in respect of such authorisations. The EIA Regulations (2014) allow for a Basic Assessment process for activities with limited environmental impact (listed in GNR. 983 and 985, 2014) and a more rigorous two-tiered approach for activities with potentially greater environmental impact (listed in GNR. 984, 2014). This two-tiered approach includes both a Scoping and EIA process (Figure 1.1). The proposed borrow pits requires a Full Scoping and EIR due to the following triggers:

Government Notice

Activity Number

Activity Description Relevance to this project

GNR 984 17

Any activity including the operation of

that activity which requires a mining

right as contemplated in Section 22

of the MPRDA (2002), including

associated infrastructure, structures

and earthworks, directly related to

the extraction of a mineral resource,

including activities for which an

exemption has been issued in terms

of Section 106 of the MPRDA.

The project involves the

development of 3 Borrow

Pit sites, the size of which

exceed the threshold for a

mining permit, of 5ha.

GNR 984 21

Any activity including the operation of

that activity associated with the

primary processing of a mineral

resource including winning,

reduction, extraction, classifying,

concentrating, crushing, screening

The activity includes the

processing of mineral

resources, specifically

extraction, crushing and

screening.

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Government Notice

Activity Number

Activity Description Relevance to this project

and washing but excluding the

smelting, beneficiation, refining,

calcining or gasification of the

mineral resource.

In terms of the EIA Regulations (2014), the competent authority for assessing applications for authorisation of these triggers is the Department of Mineral Resources (DMR). After obtaining an Environmental Authorisation (EA) from the DMR, SANRAL may commence with mining after submission of an EMPr and financial provision for rehabilitation to DMR as regulated by the Minerals & Petroleum Resources Development Act (MPRDA, Act 28 of 2002).

1.3 The Environmental Impact Assessment Process The EIA process is guided by regulations made in terms of Chapter 5 of NEMA, published as Government Notice No R 982 in Government Gazette No 38282 of 8 December 2014. The regulations set out the procedures and criteria for the submission, processing and consideration of decisions on applications for environmental authorisation.

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Figure 1.1 The EIA process.

Contextualise Proposed Development

Pre-Application Planning

Adopt the Scoping & Environmental Impact Assessment Process

Submit Application to Relevant Authority

Conduct Public Participation Process

Scoping Report and Plan of Study for the EIA

Public Review of Scoping Report and Plan of Study of the EIA

Authority Review of Scoping

Report and Plan of Study of the EIA

Accept

Request Amendments

Conduct Environmental Impact Assessment. Compile EIR and EMPr

Public Review of EIR and EMPr

Authority Review of EIR and EMPr

Accept

Request

Amendments

Issue Environmental Authorisation and notify applicant

of conditions and appeal provisions

Notify I&APs of Environmental Authorisation and appeal provisions

Consider Appeals if any

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1.4 Scoping Phase A detailed description of the Scoping Phase for the proposed borrow pits and the outcomes thereof is included in: “Mining Application for Borrow Pit Sites Between Mthatha and Ngcobo: Final Scoping Report, EOH, East London”. A Plan of Study (PoS) for the detailed EIA phase was submitted to the Department of Mineral Resources (DMR) together with the Final Scoping Report (FSR), in fulfilment of Appendix 2 in GNR 982 of the EIA Regulations (2014). The PoS and FSR was accepted by DMR on 7 February 2017.

1.5 The Environmental Impact Assessment Phase The Environmental Impact Assessment (EIA) is a comprehensive evaluation and study phase that addresses all the issues raised in the Scoping Phase. It is a substantial phase that has seven key objectives:

Describe the biophysical and socio-economic environment that is likely to be affected by the proposed borrow pits.

Assess the significance of impacts that may occur from the proposed borrow pits.

Assess the alternatives proposed during the Scoping Phase.

Provide details of mitigation measures and management recommendations to reduce the significance of impacts.

Provide a framework for the development of the Environmental Management Programme (EMPr).

Continue with the public participation process. This EIA phase includes the following steps: 1. Specialist studies

Specialist studies are undertaken to provide a detailed and thorough examination of key issues and environmental impacts. Specialists gather relevant data to identify and assess environmental impacts that might occur on the specific component of the environment that they are studying (for instance waste management, air quality, noise, vegetation, water quality, pollution, waste management). Once completed, these studies are synthesised in, and presented in full as appendices to the Environmental Impact Report (EIR).

2. The Public Participation Process The public participation process (PPP) initiated at the beginning of the Scoping Phase continues into the EIA Phase. Once again the PPP provides a platform from which all I&APs are able to voice their concerns and raise issues regarding the project.

3. Assessment of the Significance of Impacts

It is necessary to determine the significance, or seriousness, of any impacts on the natural or social environment. It is common practice in the EIA Phase to use a significance rating scale that determines the spatial and temporal extent, and the severity and certainty of any impact occurring, including impacts relating to any project alternatives. This allows the overall significance of an impact or benefit to be determined. The overall intent of undertaking a significance assessment is to provide the competent authority with information on the potential environmental impacts and benefits, thus allowing them to make an informed, balanced and fair decision.

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4. Mitigation Measures and Recommendations

Critical to any EIA is the recommendation of practical and reasonable mitigation measures and recommendations. These recommendations relate to the actions that are needed in order to avoid, minimise or offset any negative impacts from the borrow pits.

5. Planning input

An effective EIA process should actively engage and contribute to the project planning process so as to mitigate environmental impacts through improved design and layout.

6. Environmental Impact Report

The above-mentioned tasks are synthesised in the EIR. This will allow the assessment of the relationship of environmental impacts to project actions, as well as to assess the overall significance of these impacts. The EIR will also provide sufficient information to allow the competent authority to make an informed decision.

1.6 Mining Right Application SANRAL is exempted from the application for a Mining Right for the borrow pits, but is not exempted from the application for Environmental Authorisation for the borrow pits. The borrow pits require an application for environmental authorisation in terms of NEMA (Act 107 of 1998) and in terms of the MPRDA (No. 28 of 2002). An application for environmental authorisation was submitted to DMR (DMR Ref. no.: EC30/5/1/3/3/2/1/00063EM).

1.7 Nature and Structure of this Report This EIR fulfils the requirement of the EIA Regulations (2014) for the documentation of the EIR phase. The structure of this report is based on APPENDIX 3 of GNR No. 982, of the EIA Regulations (2014), which clearly specifies the required content of an Environmental Impact Assessment Report.

1.8 Assumptions and Limitations This EIR is based on currently available information and, as a result, the following limitations and assumptions are implicit:

The report is based on project information provided by the client.

Descriptions of the natural and social environments are based on limited fieldwork, relevant specialist studies and available literature.

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1.9 Details and Expertise of the Environmental Assessment Practitioner In fulfilment of the above-mentioned legislative requirement the details of the Environmental Assessment Practitioner (EAP) who prepared the report as well as the expertise of the individual members of the study team are provided below. 1.9.1 Details of the EAP EOH was established in 1990 as a specialist environmental consulting company and has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, State of Environment Reporting (SOER), Integrated Waste Management Plans (IWMP), EMPs, Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the EIA and Strategic Environmental Assessment (SEA) processes. 1.9.2 Expertise of the study team Dr Alan Carter (EAP) Alan is the executive of the CES East London Office. He holds a PhD in Marine Biology and is a certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years’ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP). He is also registered as an EAP by the Environmental Assessment Practitioners of South Africa (EAPSA). Mr Peter De Lacy Peter holds a BSc with majors in Environmental Science and Zoology, as well as a BSc (Hons) in Environmental Science both from Rhodes University. Peter's honours dissertation looked at the growth rate of indigenous street and garden trees and it has subsequently been published in the South African Journal of Botany. His MSc (Environmental Science) thesis was done through Rhodes University and is currently being examined. It looked at the woody species composition and congregant appreciation of the cultural and spiritual services provided by sacred areas in Grahamstown. He has an academic background in a range of fields including Urban Ecology and Forestry, Rehabilitation and Disturbance Ecology, Statistics, Environmental Impact Assessment, and Community-Based Natural Resource Management.

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include – (a) Details of– (i) The EAP who prepared the report; and (ii) The expertise of the EAP, including a curriculum vitae.

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2. LOCATION OF ACTIVITY

2.1 Property Locality Three (3) Borrow Pit sites are required to supply the necessary material for the regravelling of roads, maintenance of existing culverts and where required the installation of stormwater infrastructure on certain municipal gravel roads. This all forms part of the Rural Roads Regravelling Programme. The three borrow pits are all located within the King Sabata Dalindyebo Local Municipality (KSD LM), Wards 17 & 31. Figures 2.2-2.4 show aerial images of each Borrow Pit. Property details and the SG code of the affected farms are illustrated in Table 2.1 below. Coordinates of the corner points of each of the proposed borrow pits are illustrated in Table 2.2. Table 2.1: Property details Borrow Pit 01 Erf 1218 (C11000180000121800000)

Allotment Area Xongora Town (C110018)

Borrow Pit 02 Erf 1105 (C11000180000110500000)

Erf 425 (C11000180000042500000)

Allotment Area Xongora Town (C1100018)

Borrow Pit 03 Allotment Area Sikebeni Town (C1100012)

Table 2.2: Coordinates of the corner points of the three borrow pit sites.

Corner #

Latitude (S) (DDMMSS) Longitude (E) (DDMMSS)

Borrow Pit 01

1 31° 41’ 16.53” S 28° 29’ 42.54” E

2 31° 41’ 15.81” S 28° 29’ 45.66” E

3 31° 41’ 16.08” S 28° 29’ 45.94” E

4 31° 41’ 15.31” S 28° 29’ 49.43” E

5 31° 41’ 17.19” S 28° 29’ 50.00” E

6 31° 41’ 18.89” S 28° 29’ 42.38” E

Borrow Pit 02

1 31° 42’ 47.89” S 28° 26’ 42.42” E

2 31° 42’ 45.12” S 28° 26’ 43.94” E

3 31° 42’ 45.82” S 28° 26’ 48.39” E

4 31° 42’ 49.71” S 28° 26’ 51.26” E

5 31° 42’ 51.55” S 28° 26’ 47.82” E

6 31° 42’ 49.29” S 28° 26’ 46.08” E

Borrow Pit 03

1 31° 38’ 20.20” S 28° 34’ 37.98” E

2 31° 38’ 17.16” S 28° 34’ 42.09” E

3 31° 38’ 23.42” S 28° 34’ 48.37” E

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

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 terms of (i) and (ii) is not available, the

coordinates of the boundary of the property or properties; c) A plan which locates the proposed activity or activities applied for at an

appropriate scale

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4 31° 38’ 27.09” S 28° 34’ 43.74” E

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Figure 2.1. Locality map of the three SANRAL Borrow pit sites between Engcobo and Mthatha, Eastern Cape.

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3. PROJECT DESCRIPTION

3.1 Description of Proposed Activity Jeffares and Green (Pty) Ltd were appointed by SANRAL (South African National Roads Agency Soc. Ltd.) to undertake the design, contract documentation and construction monitoring for the regravelling of roads, maintenance to existing culverts and where required the installation of stormwater infrastructure on certain municipal gravel roads. This all forms part of the Rural Roads Regravelling Programme. Three (3) Borrow Pit sites are required to supply the necessary material for road regravelling. Three suitable sites have been identified between All Saints and Baziya approximately 60 km south-west of Mthatha in the King Sabata Dalindyebo Local Municipality (KSDLM), Eastern Cape. Table 3.1: Size of mining activities within each of the borrow pits.

Activity Area (hectare)

Borrow Pit 01

Mining area 0.36

Material stockpile 0.39

Crushing and screening area 0.04

Topsoil stockpile 0.05

Borrow Pit 2

Mining area 0.90

Material stockpile 0.41

Crushing and screening area 0.04

Topsoil stockpile 0.04

Borrow Pit 3

Mining area 1.4

Material stockpile 0.38

Crushing and screening area 0.04

Topsoil stockpile 0.23

Figure 3.1, 3.2 and 3.3 represent the proposed mining plans for the borrow pits. The direction of mining, mining area, location of stockpiles, processing areas, and proposed fence line are all indicated on these plans. The mining plans also illustrate how the proposed layouts avoid heritage sensitive sites.

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include -

d) A description of the scope of the proposed activity, including – (i) All listed and specified activities triggered and being applied for; (ii) A description of the associated structures and infrastructure related to the

development.

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Figure 3.1 Proposed layout of Borrow Pit 1

Figure 3.2 Proposed layout of Borrow Pit 2

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Figure 3.3 Proposed layout of Borrow Pit 3

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3.2 Listed activities triggered The proposed borrow pits triggers the need for a Full Scoping and EIA process under the NEMA Regulations (2014) in terms of Listing Notices 1 and 2 and published in Government Notices No. R. 983 and R. 984 respectively. The listed activities that have been applied for are provided in Table 3.3 below. Table 3.2: Listed activities triggered by the proposed three Borrow pits

Government Notice

Activity Number

Activity Description Relevance to this project

GNR 983 22(i)

The decommissioning of any activity

requiring (i) a closure certificate in

terms of Section 43 of the MPRDA

(2002).

Decommissioning of the

three Borrow Pits once

mining is complete will

require a closure

certificate.

GNR 983 27

The clearance of an area of 1

hectare or more, but less than 20

hectares of indigenous vegetation.

The Borrow Pit sites may

require clearance of more

than 1 hectare of

indigenous vegetation.

GNR 984 17

Any activity including the operation of

that activity which requires a mining

right as contemplated in Section 22

of the MPRDA (2002) including

associated infrastructure, structures

and earthworks, directly related to

the extraction of a mineral resource,

including activities for which an

exemption has been issued in terms

of Section 106 of the MPRDA.

The Borrow Pits will be

used for mining material to

be used in road

construction (approximately

5 ha in size total).

Any activity which requires a mining right, including activities for which an exemption has been issued, require that an application for environmental authorisation be submitted to DMR.

GNR 984 21

Any activity including the operation of

that activity associated with the

primary processing of a mineral

resource including winning,

reduction, extraction, classifying,

concentrating, crushing, screening

and washing.

Material will be crushed

and screened onsite.

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4. RELEVANT LEGISLATION

4.1 Relevant Legislation and Guidelines used in the Compilation of this Environmental Impact Assessment Report The table below (Table 4.1) summarises the legislation and policy guidelines that are relevant to the proposed 3 Borrow Pits. Table 4.1: Environmental legislation considered in the preparation of this Environmental Impact Assessment Report.

Title of Environmental Legislation, Policy or

Guideline Implications for the proposed borrow pits

Constitution Act (108 of 1996)

Obligation to ensure that the 3 Borrow Pit sites will not result in pollution and ecological degradation; and

Obligation to ensure that the proposed Borrow Pits are ecologically sustainable, while demonstrating economic and social development.

National Environmental Management Act (NEMA) (107 of 1998)

The developer must be mindful of the principles, broad liability and implications associated with NEMA and must eliminate or mitigate any potential impacts.

The developer must also be mindful of the principles, broad liability and implications of causing damage to the environment.

The developer must also comply with the EIA Regulations (2014) in the terms of the Act which specifies when an environmental authorisation is required and the nature of the EIA process.

Mineral and Petroleum Resources Development Act (Act No. 28 of 2002)

The purpose of the Act is to regulate the prospecting for and the optimal exploitation, processing and utilization of minerals; to regulate the orderly utilization and the rehabilitation of the surface of land during and after prospecting and mining operations; and to provide for matters connected therewith.

SANRAL is exempted from the application for a Mining Permit/Right, but is not exempted from an application for Environmental Authorisation and EMPr.

Any activities requiring extraction of material for construction purposes will require the submission of an application to DMR for Environmental Authorisation and mining authorisation.

National Environmental Management: Waste Act (59 of 2008)

The proponent must ensure that all activities associated with the project address waste related matters in compliance with the requirements of the Act.

National Water Act (36 of 1998)

Appropriate measures must be taken to prevent the pollution of watercourses.

Riparian zones must be protected.

Any mining activity that takes place within a watercourse or within 500 m of a wetland will require a water use licence (section 21(c) and (i) of the National Water Act).

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

e) A description of the policy and legislative context within which the development is located and an explanation of how the proposed development complies with and

responds to the legislation and policy context.

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Title of Environmental Legislation, Policy or

Guideline Implications for the proposed borrow pits

National Heritage Resources Act (Act No. 25 of 1999)

The Act requires all developers (including mines), to undertake cultural heritage studies for any development exceeding 5000 m2 in size. It also provides guidelines for impact assessment studies to be undertaken whenever cultural resources may be destroyed by development activities.

ECPHRA/ SAHRA needs to be informed of the project.

Should heritage resources be identified during mining, appropriate measures must be undertaken to involve ECPHRA/ SAHRA and to protect these resources.

Mine Health and Safety Act (Act No. 29 of 1996)

The key objectives of the Act are to provide for the health and safety of persons at work and in connection with the use of plants and machinery.

This Act will be applicable during all phases of the project and therefore necessary measures should be taken to ensure compliance.

Air Quality Act (Act No. 39 of 2004)

The purpose of this Act is to provide for national norms and standards regulating air quality monitoring, management and control.

This Act will be applicable during all phases of the project. The necessary measures must be taken to ensure compliance.

National Environmental Management: Biodiversity Act (Act No. 10 of 2004)

Threatened or Protected Species List: • Identifying any protected animal and plant that will be

impacted and remove to a safe natural area.

Alien and invasive Species list: • If any declared weed and/or invader species listed in terms of

this Act is present on site, it must be removed.

4.2 Relevant policy 4.2.1 National Policy The National Development Plan (NDP) (also referred to as Vision 2030) is a detailed plan produced by the National Planning Commission in 2011 that is aimed at reducing and eliminating poverty in South Africa by 2030. The NDP represents a new approach by Government to promote sustainable and inclusive development in South Africa, promoting a decent standard of living for all, and includes key focus areas, such as improvement of roads and transport facilities. 4.2.2 Provincial Policy The Eastern Cape Vision 2030 Provincial Development Plan sets out nine key challenges that need to be addressed in the Eastern Cape. The challenge relevant to the proposed project has been extracted below: (3) Infrastructure is poorly located, under-maintained and insufficient to foster higher growth and spatial transformation.

The road network is severely stressed and deteriorating. “…Because there are existing plans for the major arterial routes in the province, the programme will focus on building feeder and secondary roads, particularly rural and access roads, to ensure that no village is without a well-maintained connection to national roads and service centres by 2030.”

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4.3 Municipal by-laws and planning 4.3.1 The KSD LM IDP (2013/2014) The KSD LM IDP highlights the fact that there are serious road infrastructure challenges in the KSDLM. Some of the issues mentioned are that roads are in a poor condition and existing roads are not safe.

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5. PROJECT NEED & DESIRABILITY Three existing borrow pits have been identified as potential sources of gravel wearing course material. These borrow pits are currently unlicensed and consist of a mixture of sandstone and weathered shale. The need and desirability of this project is supported by National, Provincial and Municipal policy documents.

The road upgrade speaks directly to the National Development Plan for 2030. The vision statement of the NDP specifically mentions transport and improvement of roads.

The Eastern Cape Vision 2030 Provincial Development Plan (PDP) emphasises the challenge of road networks in the Eastern Cape and explains that roads are severely stressed and deteriorating. The PDP continues to explain that there are existing plans for the major arterial routes in the province and focus should be given to the construction of feeder and secondary roads. This is to ensure that no village is without a well-maintained connection to national roads.

The KSDLM IDP (2013/2014) highlights the need for an improvement in the safety and condition of roads in the local municipality.

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

f) A motivation for the need and desirability for the proposed development including the need and desirability of the activity in the context of the preferred location.

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6. PROJECT ALTERNATIVES One of the objectives of an EIA is to investigate alternatives to the proposed project. There are two types of alternatives: Fundamental Alternatives and Incremental Alternatives.

6.1 Reasonable and Feasible Alternatives Alternatives should include consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The no-go alternative must also in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. “Alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to; -

a) the property on which or location where it is proposed to undertake the activity. b) the type of activity to be undertaken. c) the design or layout of the activity. d) the option of not implementing the activity.

6.2 Fundamental Alternatives Fundamental alternatives are developments that are totally different from the proposed project description and usually include the following:

Alternative property or location where it is proposed to undertake the activity.

Alternative type of activity to be undertaken.

Alternative technology to be used in the activity.

6.3 Incremental Alternatives Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. There are several incremental alternatives that can be considered, including:

Alternative design or layout of the activity.

Alternative technology to be used in the activity.

Alternative operational aspects of the activity

6.4 No-Go development The EIA process is obligated to assess the status quo (i.e. the “No-Go” option). The No-Go alternative provides the assessment with a baseline against which predicted impacts resulting from the proposed development may be compared. A ‘’No-Go” alternative has been assessed for the proposed quarry.

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

(g) A motivation for the preferred development footprint within the approved site; (h) A full description of the process followed to reach the proposed development

footprint within the approved site, including – (i) Details of the development footprint alternatives considered;

(ix) If no alternative development locations for the activity were investigated, the motivation for not considering such; and

(x) A concluding statement indicating the preferred alternative development location within the approved site.

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6.5 Analysis of alternatives Table 6.1 illustrates the methodology used to assess the identified alternatives. The table assesses the advantages and disadvantages, and provides further comments on the selected alternatives. It should be noted that the assessment of alternatives does not consider those alternatives that are not deemed to be either reasonable or feasible.

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Table 6.1: The alternatives considered for the proposed 3 Borrow Pits.

Alternative level Alternatives Advantages Disadvantages Reasonable and feasible

Further assessment

Comment

Property or location (Fundamental location alternative)

Alternative location 1 - Current proposed site for each Borrow Pit (preferred alternative).

The geology of the proposed three sites are ideal for the material required.

A portion of each site has already been impacted by mining activities.

Each site is located in close proximity to the road portion that will be upgraded.

Loss of rural grazing/ agricultural land.

Removal of approximately 8 hectares of indigenous vegetation cumulatively for the three sites.

YES YES The main determining factors for selecting the proposed location were:- Appropriate

geology of the area.

A portion of each site has already been impacted by mining activities.

Location of the site relative to the road upgrade site.

Alternative location 2 – None identified.

N/A N/A N/A N/A Alternative locations for the proposed three Borrow Pits are limited and probably not reasonable or feasible due to inappropriate geology.

The appropriate geology was considered a critical aspect.

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Alternative level Alternatives Advantages Disadvantages Reasonable and feasible

Further assessment

Comment

No alternative location will be assessed for each site in the impact assessment.

Type of technology This refers to the fundamental technology options required to operate each of the three Borrow pits.

Alternative technology 1 – Crushing and screening area on site (preferred alternative)

Time effective, i.e. shorter time required for processing material and delivering it to the required site for use

Cost effective

Increase in noise levels on site and possible disturbance to surrounding areas.

Dust disturbance to the surrounding areas especially during windy conditions.

YES YES This is the preferred and most feasible mining method.

Alternative technology 2 – Crushing and screening area offsite

Less noise and dust generated on site.

Higher cost to have a crushing and screening area offsite.

Materials will have to be transported from the borrow pit sites to be processed.

YES NO This mining method will not be assessed further in the impact assessment process due to the high costs involved in transporting material to an offsite crusher.

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Alternative level Alternatives Advantages Disadvantages Reasonable and feasible

Further assessment

Comment

Layout alternative Incremental alternative.

Alternative layout 1 – Current proposed layout (preferred alternative). Plate 6.1

The proposed layouts for all of the borrow pits avoid sensitive areas, both inside and outside the mining areas.

Smaller mining area available.

YES YES This is the preferred layout and will be assessed further in the impact assessment. The proposed layout has been subjected to environmental screening.

No-go option This refers to the current status quo and the risks and impacts associated with it.

Current land use of the proposed site is rural grazing and agricultural/cultivated land.

- Area will not be disturbed by mining operations

- Less damage to the environment

- Less job creation. - Area will suffer

extensive erosion due to grazing.

YES YES Will be assessed further in the impact assessment process.

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Plate 6.1: Preferred layout alternative for borrow Pit 1 (heritage sites indicated by the red circle)

Plate 6.1 cont.: Preferred layout alternative for borrow Pit 2 (heritage sites indicated by the red circle)

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7. PUBLIC PARTICIPATION

7.1 Notification of Interested and Affected Parties 7.1.1 Public Participation Public consultation is a legal requirement throughout the EIA process. The proponent is required to conduct public consultation throughout the Scoping and EIR phase. Formal EIA documents are required to be made available for public review and comment by the proponent, these include the Project Brief, Scoping Report and Terms of Reference for the EIA, the draft and final EIA reports and the decision of the Competent Authority. The method of public consultation to be used depends largely on the location of the development and the level of education of those being impacted on by the project. Required means of public consultation include:

Site notice/s;

Newspaper advertisements;

Letter of Notification to affected landowner(s), stakeholders and registered I&APs;

Background Information Document (BID) distribution;

Focus group site meeting (Attendance register and meeting minutes);

Authority and Stakeholder engagement (DMR, DEA, DEDEAT, DWS). 7.1.2 Newspaper advertisement The borrow pit EIA was advertised in the Daily Dispatch on 14 July 2016. This advert included notification that an application for environmental approval would be lodged with DMR, the release of the Draft Scoping Report for public review and of the date, time and location of the public meetings. The advert provided detail regarding the proposed borrow pits and provided Interested and Affected Parties with an opportunity to register and comment on the Draft Scoping Report (Refer to Appendix A). 7.1.3 On-site Notice Notice boards were placed near each of the borrow pit sites (Refer to Appendix A). 7.1.4 Stakeholders and I&APs During the EIA for the proposed borrow pits certain stakeholders were identified based on their potential interest in the project. These stakeholders were contacted via e-mail or telephone for comment and were sent a Letter of Notification (LoN) and Background Information Document (BID). A full list of stakeholders and I&APs registered to date is available in Appendix A. Any new I&APs that register during the EIR phase will be added to this list. No comments were received on the draft Scoping Report. The Final Scoping Report was submitted to DMR on 22 September 2016 and was accepted by DMR on 7 February 2017.

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

h) A full description of the process followed to reach the proposed development footprint within the approved site, including – (ii) Details of the public participation process undertaken in terms of regulation 41

of the 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, or the reasons for not including them.

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7.1.5 Background information document A BID was distributed for the proposed borrow pits (Appendix A). 7.1.6 Proof of notification Letters of Notification were emailed/posted to stakeholders and I&APs during the EIA process (Refer to Appendix A). Stakeholders and I&APs were notified via email/registered mail/ telephonically about the proposed borrow pits as well as of the availability of the draft Scoping Report for review (Appendix A). Stakeholders and I&APs will be notified once the draft EIR is available for review. 7.1.7 Issues raised by stakeholders/ I&APs The Issues and Response Trail is updated throughout the EIA process and will include all comments received until submission of the final EIR to the competent authority. EOH held a public meeting during the EIA for the proposed borrow pits. The proposed borrow pits were discussed in these meetings and issues were raised and documented. The attendance registers for the public meeting is provided in Appendix A.

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8. DESCRIPTION OF THE ENVIRONMENT

8.1 The Bio-Physical Environment 8.1.1 Current land use BP01 falls within degraded: unimproved grassland. The area is currently grazed on by community livestock such as cattle, goats and sheep (Figure 8.1).

Figure 8.1: Land use for BP01 and surrounding areas. BP02 is currently also grazed on by community livestock such as cattle, goats and sheep with scattered residences surrounding the site and also falls within degraded: unimproved grassland (Figure 8.2). BP03 falls within unimproved grassland closely surrounded by forest plantations (Figure 8.3).

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

h) A full description of the process followed to reach the proposed development footprint within the approved site, including–

(iv) The environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic,

heritage and cultural aspects;

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Figure 8.2: Land use for BP02 and surrounding areas.

Figure 8.3: Land use for BP03 and surrounding areas.

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8.1.2 Climate BP01 is located approximately 28 west of Mthatha in the Eastern Cape while BP02 is located 33km west and BP03 is located 18km west of Mthatha. All 3 sites are located in close proximity of each other. Mthatha normally receives about 556 mm of rain per year, with most rainfall occurring mainly during summer. It receives the lowest rainfall (6 mm) in June and the highest (87 mm) in March. The average midday temperatures for Mthatha range from 19.4°C in July to 25.8°C in February. The region is the coldest during July when the mercury drops to 5.8°C on average during the night. 8.1.3 Topography The topography of the area surrounding all three Borrow Pit sites is characterised by gently undulating hills. BP01 is flat with a gentle slope downwards to the northwest. Elevations range from 920 to 945 meters above sea level (masl; Figure 8.4).

Figure 8.4: Topography for BP01 and surrounding areas. BP02 gently slopes towards to the north. Elevations range from 950 to 980 meters above sea level (masl; Figure 8.5). BP03 is located on a low hill. Elevations range from 1005 to 1020 meters above sea level (masl; Figure 8.6).

A

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Figure 8.5: Topography for BP02 and surrounding areas.

Figure 8.6: Topography for BP03 and surrounding areas.

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8.1.4 Geology and soils The area surrounding the both BP01 & BP02 is characterised by mudstones and sandstones of the Tarkastad Subgroup (Beaufort Group) (Figure 8.7 & 8.8). According to AGIS online (http://www.agis.agric.za/) all 3 Borrow Pit sites consists of soils with minimal development, usually shallow soils, on hard or weathering rock. BP03 not only contains rock form the Tarkastad Subgroup but also rock from a dolerite dyke intrusion located in the south-eastern sections of the site (Figure 8.9).

Figure 8.7: Geology for BP01 and surrounding areas.

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Figure 8.8: Geology for BP02 and surrounding areas.

Figure 8.9: Geology for BP03 and surrounding areas.

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8.1.5 Rivers and wetlands A NFEPA wetland is located within 500 metres of BP01. The topography of the area (Figure 8.4) illustrates that due to the drainage in the area this wetland will not be impacted by the proposed borrow pit. There is also an existing road between the proposed borrow area and wetland. There are no watercourses identified within 50 metres of BP01 (Figure 8.10). BP02 is located within 50 metres of a tributary that feeds the Kucanco River. The borrow pit is not located within 500 metres of any wetlands (Figure 8.11). The site will require stormwater management to minimise the risk of sedimentation and erosion into this system. There are no watercourses or wetlands located within 50 metres of the proposed BP3 (Figure 8.12).

Figure 8.10: Surface hydrology for BP01 and surrounding areas.

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Figure 8.11: Surface hydrology for BP02 and surrounding areas.

Figure 8.12: Surface hydrology for BP03 and surrounding areas.

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8.1.6 Vegetation Mucina and Rutherford (2012) have developed the National Vegetation map as part of a South African National Biodiversity Institute (SANBI) funded project: “to provide floristically based vegetation units of South Africa, Lesotho and Swaziland at a greater level of detail than had been available before.” The map was developed using a wealth of data from several contributors and has resulted in the best national vegetation map to date, the previous being that of Adcocks developed over 50 years ago. This map forms the base of finer scale bioregional plans such as Sub-tropical Thicket Ecosystem Plan (STEP). The map and accompanying book describe each vegetation type in detail, along with the most important species including endemic species and those that are biogeographically important and is the most comprehensive data for vegetation types in South Africa. Mucina and Rutherford (2012) define the vegetation type that occurs within the BP01 as both Drakensberg Foothill Moist Grassland and Mthatha Moist Grassland (Figure 8.13). The area within the proposed borrow pit layout is already impacted and so the vegetation within the area is is not pristine. Only Drakensberg Foothill Moist Grassland occurs within BP02 & BP03 (Figure 8.14 & 8.15).

Figure 8.13: Vegetation for BP01 and surrounding areas (Mucina & Rutherford, 2014).

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Figure 8.14: Vegetation for BP02 and surrounding areas (Mucina & Rutherford, 2014).

Figure 8.15: Vegetation for BP03 and surrounding areas (Mucina & Rutherford, 2014).

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Both these vegetation types are classified as a Sub-escarpment Grassland, which is a subdivision of the Grassland Biome of South Africa. These grassland types are associated with the foothills of the Drakensberg region & Northern Escarpment. Drakensberg Foothill Moist Grassland This vegetation type is found on the broad arc of the Drakensberg piedmonts covering the surroundings of Mt. Fletcher, Ugie, Maclear and Elliot in the Eastern Cape Province between elevations of 880 – 1860masl. The vegetation occurs on moderately rolling and mountainous landscapes that is incised by river gorges of drier vegetation types and forests. The grassland is forb-rich and dominated by short bunch grasses like Themeda triandra and Tristachya leucothrix. The vegetation type is considered as LEAST THREATENED by SANBI while only 2-3% are statutorily conserved. Up to 20% has already been transformed for cultivation, plantations and urban sprawl. Alien woody species like Rubus, Acacia dealbata and Solanum muaritanum may become invasive in places. Erosion is considered as low to very low. Mthatha Moist Grassland This vegetation type is found on the plains between Mthatha and Butterworth parallel to the coastline and excluding river valleys that intrude landwards. It occurs on undulating plains and hills supporting species-poor, sour wiry grassland with Eragrostis plana and Sporobolus africana. Themeda triandra tend to dominate. This vegetation type is considered at ENDANGERED by SANBI.

8.2 Conservation and spatial planning tools 8.2.1 NEMBA – Threatened Ecosystems The National Environmental Management Biodiversity Act (NEMBA; No. 10 of 2004) identified on a national scale a list of threatened terrestrial ecosystems with an exceptionally high conservation value (GN. R. 1002; 2011) that requires preserving. NEMBA classifies Mthatha Moist Grassland (See Section 8.1.6) as an endangered ecosystem and recommends that an EIA be conducted for areas larger that 300m2 found within the proposed development site that has not been irreversibly lost. Figure 8.16 below indicates threatened ecosystems as identified by NEMBA found at BP01. No threatened ecosystems were identified at either BP02 or BP03 (Figure 8.17 & 8.18).

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Figure 8.16: NEMBA Threatened Ecosystems for BP01 and surrounding areas.

Figure 8.17: NEMBA Threatened Ecosystems for BP02 and surrounding areas.

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Figure 8.18: NEMBA Threatened Ecosystems for BP03 and surrounding areas. 8.2.2 Eastern Cape Biodiversity Conservation Plan The Eastern Cape Biodiversity Conservation Plan (ECBCP) is a first attempt at detailed, low-level conservation mapping for land-use planning purposes. Specifically, the aims of the Plan were to map critical biodiversity areas through a systematic conservation planning process. The current biodiversity plan includes the mapping of priority aquatic features, land-use pressures, and critical biodiversity areas which develops guidelines for land and resource-use planning and decision-making. The ECBCP maps critical biodiversity areas (CBAs) based on extensive biological data and input from key stakeholders. Critical Biodiversity Areas (CBA 1 and 2), as defined by the ECBCP, form the foundation areas where conservation is priority. These areas provide essential ecosystem services. CBA Areas provide the spatial framework for future spatial development planning, particularly indicating those areas where development needs to be avoided or at best, carefully managed. The ECBCP, although mapped at a finer scale than the National Spatial Biodiversity Assessment (Driver et al., 2005) is still, for the large part, inaccurate and "course". Therefore it is imperative that the status of the environment, for any proposed development MUST first be verified before the management recommendations associated with the ECBCP are considered (Berliner and Desmet, 2007). The ECBCP has been adopted by the provincial department of Economic Development, Environmental Affairs and Tourism (DEDEAT) as a strategic biodiversity plan for the Eastern Cape.

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Figure 8.19 identifies the following critical biodiversity areas occurring within BP01:

Classification Recommended land use

CBA2 Near Natural Landscapes

Maintain biodiversity in near natural state with minimal loss of ecosystem integrity. No transformation of natural habitat should be permitted.

No CBA areas were identified at either BP02 or BP03 (Figure 8.20 & 8.21).

Figure 8.19: ECBCP for BP01 and surrounding areas.

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Figure 8.20: ECBCP for BP02 and surrounding areas.

Figure 8.21: ECBCP for BP03 and surrounding areas.

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Figure 8.24 identifies the following critical biodiversity areas occurring within BP03:

Classification Recommended transformation threshold

CBA2 Important sub-catchments, Primary catchment management areas

Less than 15 % of total area of sub-quaternary catchment.

No Aquatic CBA areas were identified at either BP01 or BP02 (Figure 8.22 & 8.23).

Figure 8.22: ECBCP Aquatic for BP01 and surrounding areas.

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Figure 8.23: ECBCP Aquatic for BP02 and surrounding areas.

Figure 8.24: ECBCP for BP03 and surrounding areas.

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8.3 Socio-Economic Profile All 3 Borrow Pit sites fall within the King Sabata Dalindyebo Local Municiplity (KSD LM) in the OR Tambo District Municipality (ORT DM). The KSDLM covers an area of approximately 3,028 km2. 8.3.1 Population According to StatsSA (2011) the total population in the KSDLM is 451,710 and comprises mainly black African people of which the majority is Xhosa speaking. 53.9% of the population is female. The average household size is 4 people and 57.3% of the households are female headed. 8.3.2 Employment According to StatsSA (2011), of the 95,577 economically active (employed or unemployed and looking for work) people in the municipality, 38.3% are unemployed. The youth unemployment rate is 48.3% and 16.7% of the population receive no income.

Figure 8.14. Employment figures for the KSDLM (StatsSA, 2011). 8.3.3 Education According to StatsSA (2011) 28.7% of the population aged over 20 years and older have no form of education. 48 % of the population have reached some primary education level. Only 1.1% of the population have received Higher Education.

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9. APPROACH TO THE ENVIRONMENTAL IMPACT ASSESSMENT In line with the above-mentioned legislative requirement, this chapter of the EIR details the approach to the EIA phase of the proposed borrow pits with a particular focus on the methodology that was used when determining the significance of potential environmental impacts. PLEASE NOTE THAT DURING THE PUBLIC PARTICIPATION THE COMMUNITY WOULD NOT ALLOW BORROW PIT TWO TO GO AHEAD. FOR THIS REASON IT WILL NOT BE ASSESSED FURTHER IN THE IMPACT ASSESSMENT.

9.1 General Impact Assessment A general impact assessment was conducted based on site visits and information relating to the planning and design, construction, operation and decommissioning/closure of the proposed borrow pits.

9.2 Specialist Impact Assessments A series of specialist studies were conducted during the EIA for the proposed borrow pits. These specialist studies included the proposed borrow pit sites in their assessment. The outcomes will be summarised in this EIR. Specialist studies that will be incorporated in this EIR:

Paleontological Impact Assessment

Heritage Impact Assessment

9.3 Methodology for Assessing Impacts and Alternatives Introduction Identified impacts will be assessed against the following criteria:

Temporal scale

Spatial scale

Risk or likelihood

Degree of confidence or certainty

Severity or benefits

Significance The relationship of the issue to the temporal scale, spatial scale and the severity are combined to describe the overall importance rating, namely the significance of the assessed impact.

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

(h) A full description of the process followed to reach the proposed development footprint within the approved site, including: (vi) the methodology used in determining and ranking the nature, significance,

consequences, extent, duration and probability of potential environmental impacts and risks.

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9.3.1 Description of criteria Table 9.1: Significance Rating Table

Significance Rating Table

Temporal Scale (The duration of the impact)

Short term Less than 5 years (Many construction phase impacts are of a short duration).

Medium term Between 5 and 20 years.

Long term Between 20 and 40 years (From a human perspective almost permanent).

Permanent Over 40 years or resulting in a permanent and lasting change that will always be there.

Spatial Scale (The area in which any impact will have an affect)

Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area.

Study area The proposed site and its immediate environs.

Municipal Impacts affect the local municipality(s), or any towns within them.

Regional Impacts affect the wider district municipality or the province as a whole.

National Impacts affect the entire country.

International/Global Impacts affect other countries or have a global influence.

Likelihood (The confidence with which one has predicted the significance of an impact)

Definite More than 90% sure of a particular fact. Should have substantial supportive data.

Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring.

Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring.

Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

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Table 9.2 Impact Severity Rating

Impact severity (The severity of negative impacts, or how beneficial positive impacts would be on a particular affected system or affected party)

Very severe Very beneficial

An irreversible and permanent change to the affected system(s) or party(ies) which cannot be mitigated. For example the permanent loss of land.

A permanent and very substantial benefit to the affected system(s) or party(ies), with no real alternative to achieving this benefit. For example the vast improvement of sewage effluent quality.

Severe Beneficial

Long term impacts on the affected system(s) or party(ies) that could be mitigated. However, this mitigation would be difficult, expensive or time consuming, or some combination of these. For example, the clearing of forest vegetation.

A long term impact and substantial benefit to the affected system(s) or party(ies). Alternative ways of achieving this benefit would be difficult, expensive or time consuming, or some combination of these. For example an increase in the local economy.

Moderately severe Moderately beneficial

Medium to long term impacts on the affected system(s) or party (ies), which could be mitigated. For example constructing a sewage treatment facility where there was vegetation with a low conservation value.

A medium to long term impact of real benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are equally difficult, expensive and time consuming (or some combination of these), as achieving them in this way. For example a ‘slight’ improvement in sewage effluent quality.

Slight Slightly beneficial

Medium or short term impacts on the affected system(s) or party(ies). Mitigation is very easy, cheap, less time consuming or not necessary. For example a temporary fluctuation in the water table due to water abstraction.

A short to medium term impact and negligible benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are easier, cheaper and quicker, or some combination of these.

No effect Don’t know/Can’t know

The system(s) or party(ies) is not affected by the proposed development.

In certain cases it may not be possible to determine the severity of an impact.

Table 9.3 Overall Significance Rating

Overall Significance (The combination of all the above criteria as an overall significance)

VERY HIGH NEGATIVE VERY BENEFICIAL

These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services, would be regarded by the affected parties as resulting in benefits with VERY HIGH significance.

HIGH NEGATIVE BENEFICIAL

These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating of HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as people growing crops in the soil) would be HIGH.

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MODERATE NEGATIVE SOME BENEFITS

These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant.

LOW NEGATIVE FEW BENEFITS

These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Example: The temporary changes in the water table of a wetland habitat, as these systems are adapted to fluctuating water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits of LOW significance to people who live some distance away.

NO SIGNIFICANCE

There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective, but is of NO significance in the overall context.

DON’T KNOW

In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people’s psychological perspective of the environment.

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10. KEY FINDINGS OF THE SPECIALIST STUDIES

The following discussion summarises the key findings of the specialist studies. Full reports have been attached in Appendix C of the EIR. The relevant impacts and mitigation measures from these specialist studies have been included in the Impact Assessment of this report.

10.1 Specialist studies The following Specialist Studies have been completed for the EIA Phase:

Paleontological Impact Assessment: Dr Gideon Groenewald from Umlando

Heritage Impact Assessment: Mr Gavin Anderson from Umlando The layout of the borrow pits ensured that sensitive areas identified by these reports were avoided. 10.1.1 Paleontological Impact Assessment Paleontological Specialist Dr Gideon Groenewald, from Umlando, was appointed to conduct a paleontological specialist report. Recommendations All the mitigation measures provided below are to be implemented in the Planning and Design, Construction and Operation Phases of the proposed borrow pits.

The EAP and ECO must be informed of the fact that a Very High Palaeontological Sensitivity was allocated to all three the proposed sites for the development and due to highly weathered state of the rocks, no fossils were recorded during the Phase 1 field investigation.

A suitably qualified palaeontologist must be appointed to inspect all areas where excavation of deeper than 1,5m is made into sediments of the Burgersdorp Formation. A protocol for the chance find of fossils must be developed and discussed with the contractor on site.

A permit must be obtained by SANRAL and the palaeontologist to inspect all excavations of deeper than 1.5 m.

A protocol for the chance find of fossils must be developed and discussed with the contractor onsite.

10.1.2 Heritage Impact Assessment Heritage Specialist Mr Gavin Anderson, from Umlando, was appointed to conduct a heritage specialist report. Recommendations Borrow Pit 1 The following recommendations were made by the Heritage Specialist for Borrow Pit 1:

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include – (k) A summary of the findings and recommendations of any specialist report complying

with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final assessment report.

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A 20 m must be placed between the edge of identified graves sites and any development.

A visible fence/barrier must be erected around graves at a distance of 5 m.

If any graves/heritage features are damaged during construction then construction must stop immediately.

Any damage to heritage features must be reported to the EM, Heritage Specialist and SAHRA/ECPHRA.

It was stated by the Heritage Specialist that heritage features may be a fatal flaw for this borrow pit. The design of the borrow pit was then altered to avoid these sensitive sites. Borrow Pit 2 The following recommendations were made by the Heritage Specialist for Borrow Pit 2:

The two possible headstones should be treated as graves until proven otherwise.

A 20 m must be placed between the edge of identified graves sites and any development.

A visible fence/barrier must be erected around graves at a distance of 5 m. Borrow Pit 3 No sensitive features or artefacts were noted at Borrow Pit 3.

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11. IMPACT ASSESSMENT

11.1 Possible Environmental Issues and Impacts The impact assessment for the proposed borrow pits were conducted in two parts:

General Impact Assessment

Specialist Impact Assessment The general impact assessment and specialist impact assessments were combined into one table per phase and a detailed assessment of all impacts and mitigation measures is available in Appendix B. 11.1.1 General Impact Assessment The general impact assessment identified and assessed impacts across four phases of borrow pit development:

Planning & Design Phase

Construction Phase

Operational or Mining Phase

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

h) A full description of the process followed to reach the proposed development footprint within the approved site, including –

(v) The impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts –

Can be reversed;

May cause irreplaceable loss of resources; and

Can be avoided, managed or mitigated; (vii) Positive and negative impacts that the proposed activity and alternatives will

have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;

i) A full description of the process undertaken to identify, assess and rank the impacts that the activity and associated structures and infrastructure will impose on the preferred location through the life of the activity, including –

A description of all environmental issues and risks that were identified during the environmental impact process; and

An assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures.

(j) An assessment of each identified potentially significant impact and risk, including –

Cumulative impacts;

The nature, significance and consequences of the impact and risk;

The extent and duration of the impact and risk;

The probability of the impact and risk occurring;

The degree to which the impact and risk can be reversed;

The degree to which the impact and risk may cause irreplaceable loss of resources;

The degree to which the impact and risk can be mitigated.

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Decommissioning/Closure Phase Issues identified were not covered in the specialist studies such as:

Waste management

Borrow pit design

Sanitation

Hazardous substances

Dust and noise issues

Socio-economic impacts

General construction impacts

Stormwater management

Visual impacts

11.1.2 Specialist Impact Assessment The specialist impact assessment covered issues identified by the following specialist studies:

Paleontological Impact Assessment

Heritage Impact Assessment

Summary of findings The various issues and impacts that were identified are summarised in table 11.1 and 11.2 below. Table 11.1 Summary of the issues identified and their applicability in each phase. Theme Applicability to phase

Planning and Design

Construction Operation (Mining)

Decommissioning/ Closure

GENERAL IMPACTS

Compliance with relevant policy and legislation

YES Failure to comply with relevant policies and legal obligations.

N/A YES Failure to comply with relevant policies and legal obligations.

N/A

Design of the borrow pits

YES Inappropriate borrow pit design

N/A N/A N/A

Topography YES Failure to plan for the disturbance to the topography

N/A N/A N/A

Stormwater YES Inappropriate stormwater design

N/A YES Inadequate strormwater control

N/A

Socio-economic YES Loss of agricultural land

YES Temporary job creation

YES Job creation

N/A

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Theme Applicability to phase

Planning and Design

Construction Operation (Mining)

Decommissioning/ Closure

Impact on natural flora

YES Poor planning for the removal of SCC

YES

Loss of SCC

Inadequate rehabilitation

YES

Loss of SCC

Inadequate rehabilitation

Encroachment of mining activities into surrounding areas

N/A

Inadequate rehabilitation

N/A YES Inadequate rehabilitation allowing for the spread of alien vegetation

YES Inadequate rehabilitation allowing for the spread of alien vegetation

N/A

Visual intrusion N/A YES Visual intrusion as a result of construction activity

YES Visual intrusion associated with mining activities

N/A

Sanitation N/A YES Inappropriate siting and servicing of sanitation facilities

YES Inappropriate siting and servicing of sanitation facilities

N/A

Demarcation of borrow pit sites

N/A YES Inadequate demarcation and fencing off of the borrow pits

YES Encroachment of mining activities outside demarcated area

N/A

Waste management

N/A YES Littering on site

YES Littering on site

N/A

Hazardous substances

N/A N/A YES Spillage of hazardous substances

N/A

Dust control N/A N/A YES Dust nuisance from mining activities

N/A

Noise N/A N/A YES Increase in noise as a result of mining activities

N/A

Final rehabilitation and

N/A N/A N/A YES

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Theme Applicability to phase

Planning and Design

Construction Operation (Mining)

Decommissioning/ Closure

decommissioning Failure to decommission and rehabilitate properly

Closure N/A N/A N/A YES Failure to comply with closure requirements

HERITAGE IMPACTS

Impact on sites of archaeological and cultural significance

YES Poor planning and consideration of the identified heritage sites

YES

Accidental damage to already identified heritage features.

Potential unidentified heritage features may be uncovered and damaged

YES Damage to potential heritage features

N/A

Impacts on sites of paleontological significance

YES Poor planning and consideration of the identified paleontological sites

YES Accidental damage to paleontologically sensitive sites

YES Damage to potential paleontological sites

N/A

Table 11.2. Summary of all General and Specialist Impacts. Theme Description of impact

Planning and Design Phase

GENERAL IMPACTS

Compliance with relevant environmental legislation and policy

During the planning and design phase failure to comply with existing policies and legal obligations could lead to the project conflicting with local, provincial and national policies, legislation etc. This could result in legal non-compliance, fines, overall project failure or delays in mining activity and undue disturbance to the natural environment.

Design of the borrow pits During the planning and design phase an inappropriately designed borrow pit could lead to subsidence, face collapses, erosion and stormwater issues (during mining).

Disturbance to the topography of the study area

During the planning and design phase failure to plan for the permanent disturbance to the topography of the borrow pit sites (as a result of mining) could result in safety hazards, erosion and stormwater issues.

Stormwater During the planning and design phase inappropriate stormwater design may lead to an increase in surface soil erosion and subsequently sedimentation of the surrounding rivers and streams.

Socio-economic During the planning and design phase, failure to come to an agreement with the relevant land users (regarding loss of the available agricultural land) of the borrow pit sites could lead to dissatisfaction from the current land users.

Impact on natural flora During the planning and design phase the poor planning for the removal of sensitive vegetation could result in the permanent loss of unidentified SCC.

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Theme Description of impact

HERITAGE and PALEONTOLOGICAL

Impact on sites of archaeological and cultural significance

During the planning and design phase, poor planning and consideration of the identified heritage sites could result in the loss of sites of archaeological and cultural significance.

Impacts on sites of paleontological significance

During the planning and design phase, poor planning and consideration of the identified sensitive paleontological sites could result in the loss significant fossils.

Construction Phase

GENERAL IMPACTS

Visual intrusion associated with the establishment of the borrow pit sites

During the construction phase construction activity and the presence and use of large machinery on site and along access roads will result in a visual disturbance of the landscape.

Sanitation facilities During the construction phase inappropriate siting and servicing of sanitation facilities could result in contamination of surface and ground water.

Demarcation of the borrow pit sites

During the construction phase inadequate demarcation and fencing off of the borrow pit site could lead to unnecessary environmental disturbance.

Socio-economic During the construction phase temporary jobs will be created which will benefit the local workforce.

Waste management During construction, littering on site may attract vermin, detract from the visual appeal of the area and pollute the surrounding areas.

Impact on natural flora During the construction phase construction activity may result in the permanent loss of unidentified SCC.

Inadequate rehabilitation During the construction phase inadequate rehabilitation may lead to the permanent loss of sensitive ecosystems as well as allow the spread of alien invasive vegetation.

HERITAGE and PALEONTOLOGICAL

Impact on sites of archaeological and cultural significance

During the construction phase there could be accidental damage to already identified heritage features.

During the construction phase potential unidentified heritage features may be uncovered and damaged.

Impacts on sites of paleontological significance

During the construction phase there could be accidental damage to identified paleontologically sensitive sites.

Operation (Mining) Phase

GENERAL IMPACTS

Compliance with relevant environmental legislation and policy

During the operational (mining) phase failure to comply with existing policies and legal obligations could lead to the project conflicting with local, provincial and national policies, legislation etc. This could result in legal non-compliance, fines, overall project failure or delays in mining activity and undue disturbance to the natural environment.

Visual intrusion associated with mining activities

During the operational (mining) phase the mining activities could result in a negative impact on the aesthetic value of the study area and immediate surrounds.

Sanitation facilities During the operational (mining) phase inappropriate siting and servicing of sanitation facilities could result in contamination of surface and ground water.

Demarcation of borrow pit site During the operational (mining) phase encroachment of mining activities onto areas outside the borrow pit footprint could result in unnecessary environmental disturbance.

Storm water During the operational (mining) phase inadequate stormwater control could result in soil erosion and impact surface water quality.

Spillage of hazardous substances

During the operational (mining) phase spillage of any hazardous substances such as fuel, chemicals, etc. could result in ground and surface water contamination.

Dust control During the operational (mining) phase dust (generated from mining activities and from vehicles traveling on dirt roads) could be a nuisance during windy conditions.

Noise During the operational (mining) phase mining activities and movement of heavy vehicles could result in an increase in ambient noise levels on site and on surrounding properties.

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Theme Description of impact

Waste management During operation (mining) littering on site may attract vermin, detract from the visual appeal of the area and pollute the surrounding areas.

Socio-economic During the operational phase jobs will be created which will benefit the local workforce.

Impact on natural flora During the operational phase mining activity may result in the permanent loss of unidentified SCC.

During the operational (mining) phase encroachment of mining activities into surrounding areas may cause unnecessary harm to sensitive faunal and floral species.

Inadequate rehabilitation During the operational (mining) phase inadequate rehabilitation may lead to the permanent loss of sensitive vegetation as well as allow the spread of alien invasive vegetation.

HERITAGE and PALEONTOLOGICAL

Identification of archaeological and sites of cultural significance

During the operational (mining) phase sites of archaeological or cultural significance might be uncovered and damaged

Impacts on sites of paleontological significance

During the operational (mining) phase sites of palaeontological significance might be uncovered and damaged.

Decommissioning/Closure Phase

GENERAL IMPACTS

Final rehabilitation and decommissioning

During the decommissioning phase failure to decommission and rehabilitate the mining site properly could result in soil erosion, storm water issues, safety risks and invasion of alien plant species.

Closure During the decommissioning phase failure to comply with the closure requirements could result in unnecessary environmental degradation and failure to obtain a closure certificate from DMR.

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12. IMPACT STATEMENT

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include: (l) An environmental impact statement which contains –

(i) A summary of the key findings of the environmental impact assessment; (ii) A map at an appropriate scale which superimposes the proposed activity and its

associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers; and

(iii) A summary of the positive and negative impacts and risks of the proposed activity and identified alternatives;

(n) The final proposed alternatives which respond to the impact management measures,

avoidance, and mitigation measures identified throughout the assessment;

In line with the above-mentioned legislative requirement, this chapter of the EIR provides an Environmental Impact Statement which summarises the environmental impact assessment findings. This chapter of the EIR also includes a sensitivity map and a summary of the alternatives investigated.

12.1 Environmental impact statement The HIGH negative impacts that were identified are summarised in Table 12.1 below. These impacts can all be reduced through the recommended mitigation measures to LOW or MODERATE post-mitigation impacts. Table 12.1 High impacts identified for the proposed dolerite quarry. Theme Description of impact

Planning and Design Phase

GENERAL IMPACTS

Compliance with relevant environmental legislation and policy

During the planning and design phase failure to comply with existing policies and legal obligations could lead to the project conflicting with local, provincial and national policies, legislation etc. This could result in legal non-compliance, fines, overall project failure or delays in mining activity and undue disturbance to the natural environment.

Design of the borrow pits During the planning and design phase an inappropriately designed borrow pit could lead to subsidence, face collapses, erosion and stormwater issues (during mining).

Stormwater During the planning and design phase inappropriate stormwater design may lead to an increase in surface soil erosion and subsequently sedimentation of the surrounding rivers and streams.

HERITAGE and PALEONTOLOGICAL

Impact on sites of archaeological and cultural significance

During the planning and design phase, poor planning and consideration of the identified heritage sites could result in the loss of sites of archaeological and cultural significance.

Impacts on sites of paleontological significance

During the planning and design phase, poor planning and consideration of the identified sensitive paleontological sites could result in the loss significant fossils.

Construction Phase

GENERAL IMPACTS

Demarcation of the borrow pit sites

During the construction phase inadequate demarcation and fencing off of the borrow pit site could lead to unnecessary environmental disturbance.

HERITAGE and PALEONTOLOGICAL

Impact on sites of archaeological and cultural significance

During the construction phase there could be accidental damage to already identified heritage features.

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Theme Description of impact

Impacts on sites of paleontological significance

During the construction phase there could be accidental damage to identified paleontologically sensitive sites.

Operation (Mining) Phase

GENERAL IMPACTS

Compliance with relevant environmental legislation and policy

During the operational (mining) phase failure to comply with existing policies and legal obligations could lead to the project conflicting with local, provincial and national policies, legislation etc. This could result in legal non-compliance, fines, overall project failure or delays in mining activity and undue disturbance to the natural environment.

Demarcation of borrow pit site During the operational (mining) phase encroachment of mining activities onto areas outside the borrow pit footprint could result in unnecessary environmental disturbance.

Impact on natural flora During the operational (mining) phase encroachment of mining activities into surrounding areas may cause unnecessary harm to sensitive faunal and floral species.

HERITAGE and PALEONTOLOGICAL

Identification of archaeological and sites of cultural significance

During the operational (mining) phase sites of archaeological or cultural significance might be uncovered and damaged

Impacts on sites of paleontological significance

During the operational (mining) phase sites of palaeontological significance might be uncovered and damaged.

Decommissioning/Closure Phase

GENERAL IMPACTS

Final rehabilitation and decommissioning

During the decommissioning phase failure to decommission and rehabilitate the mining site properly could result in soil erosion, storm water issues, safety risks and invasion of alien plant species.

Closure During the decommissioning phase failure to comply with the closure requirements could result in unnecessary environmental degradation and failure to obtain a closure certificate from DMR.

12.1.1 Comparative assessment of impacts Below is an assessment of the impacts in terms of the number of impacts identified for each phase. The breakdown of the impact assessments in Table 12.2 to 12.5 below provides insight into the key issues of all phases (including the no-go option) of the proposed borrow pits. GENERAL IMPACT ASSESSMENT An analysis of the distribution of General impacts identified indicates that the bulk of the mitigation effort should be placed on the Planning and Design and Operation or Mining Phase. The HIGH impacts identified in the planning and design phase and operation phase relate to compliance with legislation, borrow pit design, stormwater infrastructure design, demarcation of site, impacts on natural flora and heritage and palaeontological impacts. Both HIGH and MODERATE identified impacts can be significantly reduced through the recommended mitigation measures resulting in predominantly LOW post-mitigation impacts. Two impacts were identified as being positive impacts. These impacts related to the socio-economic benefit of the proposed borrow pits in terms of job creation. Table 12.2 Comparative Assessment of General Impacts occurring in all phases for the proposed borrow pits (+ = beneficial impact)

PRE-MITIGATION POST-MITIGATION

LOW MODERATE HIGH VERY HIGH

LOW MODERATE HIGH VERY HIGH

Planning & Design 0 3 3 0 6 0 0 0

Construction 1 4(+1) 1 0 6 +1 0 0

Operation 1 8(+1) 3 0 12 +1 0 0

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Decommissioning 0 0 2 0 2 0 0 0

TOTAL 2 15(+2) 9 0 26 (+2) 0 0

HERITAGE AND PALEOTOLOGICAL IMPACT ASSESSMENT The Heritage and Paleontological Impact Assessment identified impacts in the Planning and Design, Construction and Operation or Mining Phases. Both HIGH and MODERATE identified impacts can be significantly reduced through the recommended mitigation measures resulting in predominantly LOW post-mitigation impacts. Table 12.3 Comparative Assessment of Heritage Impacts occurring in all phases for the proposed borrow pits (+ = beneficial impact)

PRE-MITIGATION POST-MITIGATION

LOW MODERATE HIGH VERY HIGH

LOW MODERATE HIGH VERY HIGH

Planning & Design 0 0 2 0 2 0 0 0

Construction 0 1 2 0 3 0 0 0

Operation 0 1 1 0 2 0 0 0

Decommissioning 0 0 0 0 0 0 0 0

TOTAL 0 2 5 0 7 0 0 0

NO-GO IMPACT ASSESSMENT The negative impacts identified when assessing the NO-GO alternative related to communities in the project area. Socio-economic development in the study area would also be inhibited. Positive impacts identified from the NO-GO alternative relate to the preservation of the existing vegetation and wildlife and agricultural/grazing land if the development does not go ahead. Table 12.5 Impacts associated with the No-go alternative.

PRE-MITIGATION POST-MITIGATION

LOW MODERATE HIGH VERY HIGH

LOW MODERATE HIGH VERY HIGH

TOTAL +1 1(+1) 1 0 +1 1(+1) 1 0

12.2 Overall site sensitivity The entire site has been assessed by various specialists, and this information has been analysed spatially and then used to inform the most environmentally acceptable layout for the borrow pits. This layout will be based on an overall sight rate of LOW sensitivity with small localised areas of HIGH sensitivity surrounding the borrow pits (Figure 12.1 below). The final layout will be based on the sensitivity map and impacts and mitigation measures identified throughout the process.

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Figure 12.1 Sensitivity map of the study area. No areas of high sensitivity were identified with borrow pit 3.

12.3 Consideration of alternatives Chapter 6 provides a detailed comparison of alternatives for the proposed borrow pits. It should be noted that the assessment of alternatives does not consider those alternatives that are not deemed to be either reasonable or feasible. 12.3.1 Location alternatives The current locations (preferred alternative) is the only alternative assessed in the impact assessment process. Alternative locations for the proposed borrow pits are limited and probably not reasonable or feasible due to inappropriate geology (critical aspect). Due to the fact that the community would sign the landowner agreement for borrow pit 2, it was no longer considered in the impact assessment process. 12.3.2 Technology alternatives The technology alternatives considered in Chapter 6 are a crushing and screening area on site (preferred) and a crushing and screening area offsite (not feasible). Only the former is assessed in the impact assessment as the latter is not considered to be economically viable. 12.3.3 Layout alternatives The current layout (preferred alternative) is the only layout alternative assessed in the impact assessment. The proposed layout has been subjected to environmental screening and is based on ideal geological conditions and a lower heritage sensitivity.

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13. CONCLUSION, EAP OPINION AND RECOMMENDATIONS In line with the above-mentioned legislative requirement, this Chapter of the EIR provides the recommended mitigation measures, uncertainties or gaps in knowledge, the EAP’s opinion as to whether or not the activity should be authorised and the reason(s) for this opinion as well as an undertaking by the EAP.

13.1 Description of the proposed activity Jeffares and Green (Pty) Ltd were appointed by SANRAL (South African National Roads Agency Soc. Ltd.) to undertake the design, contract documentation and construction monitoring for the regravelling of roads, maintenance to existing culverts and where required the installation of stormwater infrastructure on certain municipal gravel roads. This all forms part of the Rural Roads Regravelling Programme. Three (3) Borrow Pit sites are required to supply the necessary material for road regravelling. Three suitable sites have been identified between All Saints and Baziya approximately 60 km south-west of Mthatha in the King Sabata Dalindyebo Local Municipality (KSDLM), Eastern Cape. The proposed borrow pits consists of the following components:

Mining area

Material Stockpile

Crushing and screening area

Topsoil stockpile

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include –

(m) Based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation;

(o) Any aspects which were conditional to the findings of the assessment either by the EAP or specialist which are to be included as conditions of authorisation.

(p) A description of any assumptions, uncertainties and gaps in knowledge which relate to the assessment and mitigation measures proposed;

(q) A reasoned opinion as to whether the proposed activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation;

(r) Where the proposed activity does not include operational aspects, the period for which the environmental authorisation is required and the date on which the activity will be concluded and the post construction monitoring requirements finalised;

(s) An undertaking under oath or affirmation by the EAP in relation to:

The correctness of the information provided in the reports;

The inclusion of comments and inputs from stakeholders and I&APs;

The inclusion of inputs and recommendations from the specialist reports where relevant; and

Any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties;

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13.2 Assumptions, uncertainties and gaps The following assumptions have been made during the EIA process:

The information provided by SANRAL and their respective consultants (JG Afrika) is assumed to be correct.

The layout provided by JG Afrika is preliminary, and might undergo changes in response to the recommendations contained in this report.

13.3 Opinion of the EAP Although a number of impacts are associated with the proposed borrow pits and associated infrastructure, it is the professional opinion of EOH and the specialists that:

The vast majority of environmental impacts identified can be adequately mitigated to reduce the impacts to an acceptable level, provided mitigation measures recommended in this report are implemented and maintained throughout the life of the project.

The implementation of mitigation measures and recommendations must be consistently monitored by a fulltime onsite Environmental Manager (EM) during construction/operation.

Annual environmental audits must be conducted by an independent Environmental Officer (EO) on an annual basis. These audits must be submitted to DMR for review.

The recommendations made by all specialists and the EAP in the EMPr (Appendix D) must be implemented.

The information in the report is sufficient to allow DMR to make an informed decision. It is the opinion of EOH that NO FATAL FLAWS are associated with the proposed borrow pits 1 and 3. Although no environmental fatal flaw exists with borrow pit 2, the community would not sign the landowner agreement and therefore it will no longer be considered.

13.4 Recommendations of the EAP It is the opinion of EOH that the proposed borrow pits should be approved provided that appropriate mitigation measures are implemented and that the EMPr is implemented, maintained and adapted to incorporate relevant legislation, standard requirements and audit reporting, throughout the life of the borrow pits. The mitigation measures for all impacts identified in the EIA are provided in the detailed impact assessment in Appendix B and have been incorporated into the EMPr (Appendix D). The EMPr must be implemented by the relevant parties during all phases of development of the project i.e. Planning & Design, Construction, Operational (or Mining) and Closure/Decommissioning phase. Inclusions, additions and adaptations of the EMPr, as well as all final plan drawings and maps must be submitted to DMR (Port Elizabeth) for final approval.

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13.4.1 Recommended mitigation measures Theme Mitigation measure

Planning and Design Phase

GENERAL

Compliance with relevant environmental legislation and policy

All relevant legislation and policy must be consulted and the proponent must ensure that the project is compliant with such legislation and policy.

These should include (but are not restricted to): MPRDA, NEMA, Local and District Spatial Development Frameworks, Eastern Cape Biodiversity Conservation Plan (ECBCP), Local Municipal bylaws.

Design of the borrow pits The borrow pit must be designed by an appropriately qualified engineer.

Disturbance to the topography of the study area

During the planning and design phase an appropriate mining rehabilitation and closure plan must be developed.

Stormwater Appropriate stormwater structures must be designed and implemented.

All stormwater structures must be designed in line with SANRAL and DWS requirements.

Socio-economic The proponent must ensure that an agreement is reached between SANRAL and the current land users prior to any construction or mining activity taking place on site.

Impact on natural flora The mining area must be surveyed prior to topsoil removal in order to locate SCC and transplant them into the neighbouring undeveloped environment.

A Plant Rescue & Protection Plan must be implemented and managed by a vegetation specialist familiar with the site in consultation with the appointed EM.

The prescribed financial provision for rehabilitation (based on the quantum calculation for rehabilitation) must be submitted to DMR.

HERITAGE and PALEONTOLOGICAL

Impact on sites of archaeological and cultural significance

All access roads, construction activity and planned mining activities must avoid the identified heritage sites.

Community approval must be obtained for having the borrow pits near identified heritage sites.

Impacts on sites of paleontological significance

• A suitably qualified palaeontological specialist must be appointed to inspect all areas where excavations of deeper than 1.5 m are made.

• A permit must be obtained by SANRAL and the palaeontologist to inspect all excavations of deeper than 1.5 m.

A protocol for the chance find of fossils must be developed and discussed with the contractor onsite.

Construction Phase

GENERAL

Visual intrusion associated with the establishment of the borrow pit sites

All construction activity should take place during daylight working hours (i.e. 7 – 5pm).

All construction activity and equipment must be limited to the demarcated areas.

Sanitation facilities Sanitation facilities must NOT be located within 50m of any water resources or water drainage areas.

Sanitation facilities must be located within the borrow pit footprint.

The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.

Demarcation of borrow pit sites The boundaries of the borrow pit site must be adequately demarcated to restrict construction and other (eating, washing and ablution) activities. All plant, equipment and other materials must remain within the demarcated boundaries.

The site must be access controlled with security monitoring movements

Socio-economic No mitigation measure.

Waste management Ensure there are sufficient containers for collecting waste.

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Theme Mitigation measure

No waste must be buried on site.

Waste must be collected on a regular basis and disposed of at a licensed landfill site.

Impact on natural flora All SCC impacted by construction activities must be conserved and rescued.

Inadequate rehabilitation A Rehabilitation Management Plan must be implemented.

An Alien Removal Plan must be implemented and run during the construction phase.

HERITAGE and Paleontological

Impact on sites of archaeological and cultural significance

If any graves/heritage features are damaged during construction then construction must stop immediately.

Any damage to heritage features must be reported to the EM, Heritage Specialist and SAHRA.

If human graves are uncovered during construction then all activity must stop immediately.

The police and ECPHRA must to be notified immediately. If any other archaeological artefacts are uncovered during

construction then construction must stop and these should be reported to the EM, Heritage Specialist and SAHRA/ECPHRA immediately.

Impacts on sites of paleontological significance

A suitably qualified paleontological specialist must be appointed to inspect all areas where excavation of deeper than 1.5 m is made.

A protocol for the chance find of fossils must be developed and discussed with the contractor onsite.

Operation Phase

GENERAL

Compliance with relevant environmental legislation and policy

The proponent must ensure that mining is compliant with the relevant legislation and policy.

These should include (but are not restricted to): MPRDA, NEMA, Local and District Spatial Development Frameworks, Eastern Cape Biodiversity Conservation Plan (ECBCP), Local Municipal bylaws.

Visual intrusion associated with mining activities

Mining activities should only take place during normal work hours (7am to 5pm).

Mining activities must be limited to the designated area and not encroach into surrounding areas.

Sanitation facilities Sanitation facilities must be located more than 50m from any water resources or water drainage areas.

Sanitation facilities must be located within the borrow pit footprint.

The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.

Demarcation of borrow pit site The boundaries of the borrow pit site must be adequately demarcated to restrict mining and other (eating, washing and ablution) activities. All plant, equipment and other materials must remain within the demarcated boundaries.

The site must be access controlled with security monitoring movements

Storm water Water runoff must be controlled and the stormwater management plan implemented.

Spillage of hazardous substances

All oils, fuel and other maintenance equipment and supplies must be stored in a secure area with a compacted surface.

Spill kits must be kept on-site and maintained and stored more than 50 m away from any water course.

Dust control During windy periods un-surfaced and un-vegetated areas should be dampened down.

Vegetation should be retained where possible as this will reduce dust travel.

Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas.

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Theme Mitigation measure

A speed limit of 30km/h must not be exceeded on dirt roads.

Any complaints or claims emanating from the lack of dust control must be attended to immediately.

Noise Drilling, blasting and movement of heavy machinery should be limited to normal working hours (7 AM to 5 PM).

Ensure there is a facility for nearby residents to make complaints. These must be addressed and recorded.

Waste management Sufficient waste containers must be available.

No waste must be buried on site.

Waste must be collected on a regular basis and disposed of at a licensed landfill site.

Socio-economic No mitigation measures.

Impact on natural flora

All SCC impacted by mining activities must be conserved and rescued.

The mining area must be clearly demarcated/ fenced in. No mining activity must extend beyond the demarcated area.

Inadequate rehabilitation A Rehabilitation Management Plan must be implemented.

An Alien Removal Plan must be implemented and run during the operational phase.

HERITAGE and PALEONTOLOGICAL

Identification of archaeological and sites of cultural significance

If human graves are uncovered during mining then all activity must stop immediately.

The police and ECPHRA must to be notified immediately. If any other archaeological artefacts are uncovered during mining

activity then mining must stop and these should be reported to the EM, Heritage Specialist and SAHRA/ECPHRA immediately.

Impacts on sites of paleontological significance

• A suitably qualified paleontological specialist must be appointed to inspect all areas where excavation of deeper than 1.5 m is made.

A protocol for the chance find of fossils must be developed and discussed with the contractor onsite.

Decommissioning/Closure Phase

GENERAL

Final rehabilitation and decommissioning

All infrastructure, equipment, machinery and other items used during the mining period must be removed from the site.

Waste material of any description, including receptacles, scrap, rubble and tyres, must be removed entirely from the mining area and disposed of at a recognized landfill facility. No waste must be buried or burned on the site.

The borrow pits, access roads, storm water control areas and any other affected areas must be rehabilitated.

The site must be covered with locally occurring grass and shaped/ levelled correctly.

All exposed areas must be re-vegetated where possible.

Mining areas must be inspected weekly for soil stability until rehabilitation is complete.

Alien invasive plant species must be eradicated until rehabilitation is complete.

The closed borrow pits must pose no safety risks.

Rehabilitation must be completed in such a manner that the land can be optimally used post-mining.

Final rehabilitation must be completed within a period specified by the Regional Manager (DMR).

Closure Closure must comply with the MPRDA (Act 28 of 2002), NEMA (Act 107 of 1998) and the NEMA Regulations (2014) requirements for mine closure.

A closure plan must be compiled using the guidelines described in Appendix 5 of the NEMA Regulations (2014) and submitted to DMR.

A closure certificate must be obtained from the Minister of Mineral Resources.

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13.5 Declaration by the EAP I, _____________________________ declare that:

I act as the independent environmental practitioner in this application;

I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

I declare that there are no circumstances that may compromise my objectivity in performing such work;

I have expertise in conducting environmental impact assessments, including knowledge of the Act, regulations and any guidelines that have relevance to the proposed activity;

I will comply with the Act, Regulations and all other applicable legislation;

I have no, and will not engage in, conflicting interests in the undertaking of the activity;

I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;

All the particulars furnished by me in this report are true and correct; and

I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.

Signature of the specialist:

Name of company (if applicable):

Date:

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14. ADDITIONAL INFORMATION

14.1 Financial provisions for rehabilitation SANRAL are required to submit an undertaking and commitment to rehabilitation. This includes a quantum calculation for financial provision for rehabilitation (based on the DMR “Guideline Document for the Evaluation of the Quantum of Closure-Related Financial Provision provided by a mine”, 2005). This financial provision will be submitted with the final EIR to DMR.

In terms of APPENDIX 3(3) of the EIA Regulations (2014), an Environmental Impact Assessment Report must include – (t) Where applicable, details of any financial provisions for the rehabilitation, closure

and ongoing post decommissioning management of negative environmental impacts;

(u) An indication of any deviation from the approved scoping report, including the plan of study, including-

Any deviation from the methodology used in determining the significance of potential environmental impacts and risks;

And a motivation for the deviation. (v) Any specific information that may be required by the competent authority; (w) Any other matters required in terms of section 24(4)(a) and (b) of the Act.

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15. REFERENCES AGIS online (www.agis.agric.za/agisweb/agis.html). Conservation and Agricultural Resources Act (No. 43 of 1983). Constitution Act (No. 108 of 1996). Eastern Cape Vision 2030 Provincial Development Plan. Hazardous Substances Act (No. 15 of 1973). Integrated Development Plan (2013/2014). KSD Local Municipality. Mineral and Petroleum Resources Development Act (No. 28 of 2002). Mucina, L. & Rutherford, M.C. (eds). 2006. The vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria. NPC National Development Plan 2030. National Environmental Management Act (No. 107 of 1998). National Environmental Management: Air Quality Act (No. 39 of 2004). National Environmental Management: Biodiversity Act (No. 10 of 2004). National Environmental Management: Protected Areas Act (No. 57 of 2003). National Environmental Management: Waste Management Act (No. 59 of 2008). National Forests Act (No. 84 of 1998). National Heritage Resource Act (No. 25 of 1999). National Water Act (No. 36 of 1998). Occupational Health and Safety Act (No. 85 of 1993). StatsSA (http://www.statssa.gov.za/).

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16. APPENDICES

16.1 Appendix A: Public participation documents Newspaper advert:

Advert placed in the Daily Dispatch on 14 July 2016.

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Background Information Document:

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Notice board:

Sign placed at BP01 (31°41'18.12"S; 28°29'48.10"E)

Sign placed at BP02 (31°42'52.49"S; 28°26'48.75"E)

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Sign placed at BP03 (31°38'20.93"S; 28°34'47.96"E)

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Letter of notification:

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Public meeting agenda

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Proof of landowner consent

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Meeting minutes

East London

25 Tecoma Street, Berea East London, 5201 Tel: +27 (43) 726 7809; Fax: +27 (43) 726 8352 Email: [email protected]

Website: www.cesnet.co.za

HJT TRANSPORT MINING PERMIT- MEETING MINUTES

CLIENT JG Afrika

DATE 21 July 2016

VENUE Gubevu Village

TIME OF MEETING 10:00

MINUTES BY Thina Mgweba

CIRCULATION DATE 21 September 2016

ATTENDED BY

NAME ASSOCIATION EMAIL ADDRESS

Thina Mgweba EOH CES [email protected]

Peter De Lacy EOH CES [email protected]

Mike Potter JG Afrika [email protected]

Colin Armstrong Aveng Grinaker-LTA [email protected]

Phindile Herming Mqulo Gubevu Location [email protected]

S.B Mtirara Traditional Leader

L.Poto Cogta CDW Ludwepoto.cogta@gmail

L.Noki Gubevu Location

M.Sonamzi JG Afrika [email protected]

N.Luzwana Gubevu Location

N. Ndumndum Gubevu Location

N. Dondi Gubevu Location

X.Mbambisa Community Member

M. Goniwe Community Member

M.Sikoti Community Member

A.O Poto Community Member

N.Ngabom Community Member

Nikelwa Mqulo Community Member

Thobela Soyini Community Member

Mqulo Community Member

Noliviwe Ngabom Community Member

P. Maxaba Community Member

S.Nonstwabu Community Member

Olwethu Mdazuka Community Member

S. Tshokotsha Community Member

K. Nontswabu Community Member

M.Mqulo Community Member

H.Kulimashe Community Member

M. Pukaneko Community Member

D.Poto Community Member

S.Mqulo Community Member

Z.R. Picane Community Member

K.Naki Community Member

Mziwekhaya Nontswabu Community Member

Bongani Adonis Community Member

M. Nketyana Community Member

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T.Mzimni Community Member

K.Goniwe Community Member

N.Mbambisa Community Member

N.Lamani Community Member

Z.Dondi Community Member

Mcedisi Dondi Community Member

Siphamandla Mgweli Community Member

Anathi Dwenga Community Member

Busisiwe Community Member

Nosandla Community Member

W.M.Dondi Community Member

B.Mgweli Community Member

B.Mqulo Community Member

N.Adonis Community Member

A.Mgwali Community Member

APOLOGIES:

NONE

TEXT ACTION/REPLY

WELCOME AND INTRODUCTION

The Chief welcomed everybody to the meeting No action

INTRODUCTION

The attendees introduced themselves No action

PURPOSE OF THE DAY

Mr. Poto, the Community Development Worker (CDW) presented the purpose of the day, explaining the why the meeting was being held and the agenda for the meeting.

No action

EOH: EIA PROCESS PRESENTATION

Thina Mgweba explained who the applicant and EOH

were and what they do. She presented on the EIA

process and requirements as well as how the community

can get involved.

No action

JG AFRIKA ROAD PRESENTATION

Mike Potter explained the project in on the engineering

side where the road starts, where the quarry is and how

the project came about. He explained that the project

will not be a very labour intensive project but there will

be a few people needed for temporary employment.

These people will be employed through a labour desk

which must be developed by the community leaders.

Community Leaders (Traditional Leader, Councillor etc.) to formulate a labour desk.

QUESTIONS AND COMMENTS

A member of the community asked how the how long

will the EIA process will take and when the road upgrade

will take.

REPLY: JG Afrika replied that as soon as the EIA process is concluded the upgrade of the road will commence. EOH replied that the Scoping report is already finished and ready for public review and that application will be sent to the Department of Mineral Resources (DMR) in the next week. EOH further explained that they cannot specify exactly when the process will be finished as DMR is often not predictable on the timeframes they take to process applications.

A member of the community sought clarity on how long

the actual road upgrade will take when it starts.

REPLY: JG Afrika estimated that the project will be last for duration of approximately 3 months once the material

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is obtained.

A member of the community asked about how this road

was chosen as there are many other roads that also

need fixing.

REPLY: JG Afrika replied that they had no decision making as to which roads must be done. This was decided by the Local Municipality with discussion with the councillor and the community committee. He further explained that the budget is not up to JG Afrika is it money put aside by National Treasury. If there are more roads that the community may want fixed, they should contact the Municipality who can then source funding for the additional roads.

Another member of the community enquired about a

previous meeting they had with a lady representing the

contractor that had said a list of names for employment

must be populated.

REPLY: JG Afrika apologised for the premature consultation with regards to employment and reiterated that they will work through a labour desk formulated by the community from here on. The list may still be given to the labour desk for approval. Approximately 12 people are needed for the temporary jobs

A community member asked about the labour; what

type of people the contractor needs in terms of ages,

gender etc.

A member of the community stated that the trucks from

these developments damage the roads and that they

must fix the roads when that happens.

REPLY: Aveng Grinaker-LTA representing the contractor replied and said they will need approximately 12 people; 2 security guards (these can be old gentlemen and need not be certified/accredited), 4 flag people (these can be ladies of any age), 4 manual labourers (these need to be young men), 1 secretary (this needs to be an reasonably educated person of any age or gender), 1 brick layer (someone who has previous experience of brick laying) Aveng Grinaker emphasised that the subcontractor will employ these people through the labour desk. They will come and introduce the subcontractor in due course.

A community member asked What type of people are

required to form the labour desk/ committee, will they

get paid?

REPLY: JG Afrika There is no money set aside for the committee, this wil be on a voluntary basis for the community. The only people who will get paid will be the people employed by the contractor. JG Afrika also emphasised that there will be spinoffs to the community as there will be some people who might come into the community with the contractor who will need accommodation.

What are the hours and the rates of payment for the

workers?

REPLY: The security guards will work 24hrs a day 7 days a week split between the two. If 12 hours are too excessive this may be changed but will be finalised closer

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to the time. The official hours will be a nine hour day for the workers 5 days a week. The rates will be forwarded to the councillor from the contractor and the workers will be told the rates before they start working.

WAY FORWARD

The councillor proposed that a further meeting be held to

make up the committee/labour desk closer to the time of

commencement of the project. Furthermore, the

councillor proposed that the community lead by him can

in the meantime also contact the Municipality to further

ask whether the project can be expanded to other

access roads.

ACTION: Community to coordinate the setting up of a labour desk/committee

CLOSING

The councillor and headman passed a vote of thanks to

everybody and closed the meeting.

No action.

POST- MEETING ACTIVITIES

The headman signed the EIA application form and

received the scoping report for public review.

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Attendance Register

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Photos of the site meeting

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Proof of delivery of Draft Scoping Report to Community

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Notification of the availability of the Final Scoping Report for public review. Email notification:

SMS notification: This serves to notify you that the Final Scoping Report for three borrow pits between Mthatha and Ngcobo has been submitted to the Department of Mineral Resources. A hard copy has been made at our offices at 25 Tecoma Street, Berea. Please forward any comments to Mr Peter De Lacy - Tel: 043 726 7809; Fax: 043 726 8352; Email: [email protected]; PO Box 8145, Nahoon, East London, 5210. SMS Database: SMS notification went to the following contacts:

0736634061

0736714839

0731019766

0728280014

0818434885

0604699941

0635552636

0832101888

0769710249

0635485090

0739767254

0635485090

0782059279

0716159424

0782341789

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0787547739

0638590316

0738987069

0734715040

0786144086

0710676556

0737614996

0738141063

0784461446

0736864968

0710643171

0730267086

0710712963

0633278213

0782545705

0788579630

0832053577

0787151574

0767378377

0789206805

0737086939

0732578152

0732525168

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Delivery of Final Scoping Reports to DMR (Port Elizabeth):

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Interested and affected parties database:

Organisation/association Name/contact person Address e-mail Tel: Fax:

Identified Stakeholders

DWS Lizna Fourie (Licensing) [email protected] 043 701 0248

DWS Andiswa Mngxe [email protected]

DWS Mbikwana Mlondolozi [email protected]

DWS Nduna Mandisa [email protected]

ECPHRA (EC Heritage) Mr Sello Mokhanya No 74 Alexandra Road, King Williams Town

[email protected]

0436422811

0436422812

DEDEAT Qondile Paliso [email protected]

0475312287

DMR Deidre Thompson [email protected]

DMR Xolani Mchunu [email protected]

DMR Hloniphile Dlamini [email protected]

Department of Rural Development and Land Reform

B. Keikelame [email protected]

EC Dept of Rural Dev and Agrarian Reform

Patrick Futshane [email protected]

Dept. of Human Settlement Olona Njoteni (Regional Director)

Private Bag 5030 [email protected]

0475313511

KSD Municipality Mike Merry PO Box 44, Mthatha, 5100 [email protected]

0475014238

KSD Municipality Acting Municipal Manager

Mr Zolani.H. Mdikane PO Box 44, Mthatha, 5100 [email protected]

OR Tambo Municipality Mr. HT Hlazo [email protected]

0475016460

OR TDM Secretary Ayanda Wakana [email protected]

0475016460

Ward 17 Councillor Mtirara 083264340

Ward 31 Councillor Zimele 0736634061

I&AP Mr Nyingwa 0736714839

Headman Chief Vulisago 0731019766

Jeffares and Green Mike Potter [email protected]

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Jeffares and Green Duncan Murphy [email protected]

SANRAL Iqbal Hoosein [email protected]

Aneng Grinaker-LTA Colin Armstrong

[email protected]

0769021031

I&AP Semakaleng Llale [email protected]

Community Members Phindile Herming Mqulo [email protected]

0728280014

Community Members S.B Mtirara 0818434885

Community Members L.Poto [email protected]

0604699941

Community Members L.Naki 0635552636

JG Afrika M.Sonamzi [email protected]

0832101888

Community Members N.Luzwana 0769710249

Community Members N. Ndumndum

Community Members N. Dondi 0635485090

Community Members X.Mbambisa

Community Members M. Goniwe

Community Members M.Sikoti

Community Members A.O Poto 0739767254

Community Members N.Ngabom 0635485090

Community Members Nikelwa Mqulo 0782059279

Community Members Thobela Soyini

Community Members A. Mqulo 0716159424

Community Members Noliviwe Ngabom 0782341789

Community Members P. Maxaba 0787547739

Community Members S.Nonstwabu 0638590316

Community Members Olwethu Mdazuka 073898706

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9

Community Members S. Tshokotsha 0734715040

Community Members K. Nontswabu

Community Members M.Mqulo

Community Members H.Kulimashe 0786144086

Community Members M. Pukaneko

Community Members D.Poto 0710676556

Community Members S.Mqulo 0737614996

Community Members Z.R. Picane 0738141063

Community Members K.Naki 0784461446

Community Members Mziwekhaya Nontswabu 0736864968

Community Members Bongani Adonis 0710643171

Community Members M. Nketyana 0730267086

Community Members T.Mzimni 0710712963

Community Members K.Goniwe 0633278213

Community Members N.Mbambisa 0782545705

Community Members N.Lamani 0788579630

Community Members Z.Dondi

Community Members Mcedisi Dondi 0832053577

Community Members Siphamandla Mgweli 0787151574

Community Members Anathi Dwenga 0767378377

Community Members Busisiwe 0789206805

Community Members Nosandile 073708693

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Community Members W.M.Dondi 0732578152

Community Members B.Mgweli

Community Members B.Mqulo

Community Members N.Adonis 0732525168

Community Members A.Mgwali

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Proof of Application to SAHRIS Engcobo borrow pits Add new comment Subscribe to: This post 2 reads

CaseViews CaseHeader(active tab) LocationInfo Admin Images

Status: SUBMITTED HeritageAuthority(s):

ECPHRA Case Type:

Section 38 (1) - Decision from Heritage Authority required Development Type:

Borrow Pits ProposalDescription: Three Borow pits west of Umthatha, E. Cape Expanded_Motivation: Three existing borrow pits were identified as potential sources of gravel wearing course material. Borrow Pit 1 is situated alongside the Kwa-Saba access road and is approximately 8.5km from the intersection of the access road to Upper Centuli School and DR08282. It is proposed to use this source for the regravelling of the Kwa-Saba and Centuli Access Roads. Borrow Pit 2 is located 6.7km further down the Kwa-Saba access road towards DR08033 and it is proposed as only a back-up source. Borrow Pit 3 is 1.6km to the south-east of the end point of the road joining Sandleni with Sixhotyeni and is proposed for the regravelling of this road. All of these borrow pits are currently in the process of being licenced. The materials encountered in the borrow pits consists of a mixture of sandstone and weathered shale” (Jeffares & Green 2016 Preliminary Design report ApplicationDate: Monday, August 15, 2016 - 13:27 CaseID: 9997 Applicants: Coastal & Environmental Services - East London SANRAL Consultants/Experts: Gavin Anderson Gideon Groenewald OtherReferences: Heritage Reports: Engcobo borrow pits ReferenceList:

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16.2 Appendix B 16.2.1 Impact assessment Impacts associated with the planning and design phase of the proposed borrow pits.

ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

PLANNING & DESIGN PHASE

GENERAL IMPACTS

Compliance with relevant environmental legislation and policy

During the planning and design phase failure to comply with existing policies and legal obligations could lead to the project conflicting with local, provincial and national policies, legislation etc. This could result in legal non-compliance, fines, overall project failure or delays in mining activity and undue disturbance to the natural environment.

DIRECT CUMULATIVE

Localised Long-term Possible Severe HIGH NEGATIVE

All relevant legislation and policy must be consulted and the proponent must ensure that the project is compliant with such legislation and policy.

These should include (but are not restricted to): MPRDA, NEMA, Local and District Spatial Development Frameworks, Eastern Cape Biodiversity Conservation Plan (ECBCP), Local Municipal bylaws.

LOW NEGATIVE

Design of the borrow pits

During the planning and design phase an inappropriately designed borrow pit could lead to subsidence, face collapses, erosion and stormwater issues (during mining).

DIRECT Localised Long-term Possible Severe HIGH NEGATIVE

The borrow pit must be designed by an appropriately qualified engineer.

LOW NEGATIVE

Disturbance to the topography of the study area

During the planning and design phase failure to plan for the permanent disturbance to the topography of the borrow pit sites (as a result of mining) could result in safety hazards, erosion and stormwater issues.

DIRECT Localised Permanent Definite Moderately severe MODERATE NEGATIVE

During the planning and design phase an appropriate mining rehabilitation and closure plan must be developed.

LOW NEGATIVE

Stormwater During the planning and design phase inappropriate stormwater design may lead to an increase in surface soil erosion and subsequently sedimentation of the surrounding rivers and streams.

DIRECT CUMULATIVE

Study area Long-term Probable Severe HIGH NEGATIVE

Appropriate stormwater structures must be designed and implemented.

All stormwater structures must be designed in line with SANRAL and DWS requirements.

LOW NEGATIVE

Socio-economic

During the planning and design phase, failure to come to an agreement with the relevant land users (regarding loss of the available agricultural land) of the borrow pit sites could lead to dissatisfaction from the current land users.

DIRECT CUMULATIVE

Localised Long-term Definite Moderately severe MODERATE NEGATIVE

The proponent must ensure that an agreement is reached between SANRAL and the current land users prior to any construction or mining activity taking place on site.

LOW NEGATIVE

Impact on natural flora

During the planning and design phase the poor planning for the removal of sensitive vegetation could result in the permanent loss of unidentified SCC.

DIRECT Localised Permanent Definite Severe MODERATE NEGATIVE

The mining area must be surveyed prior to topsoil removal in order to locate SCC and transplant them into the neighbouring undeveloped environment.

A Plant Rescue & Protection Plan must be implemented and managed by a vegetation specialist familiar with the site in consultation with the appointed EM.

The prescribed financial provision for rehabilitation (based on the quantum calculation for rehabilitation) must be submitted to DMR.

LOW NEGATIVE

HERITAGE and PALEONTOLOGICAL

Impact on sites of

During the planning and design phase, poor planning and

DIRECT INDIRECT

Localised Long-term Possible Moderately severe HIGH NEGATIVE

All access roads, construction activity and planned mining activities must

LOW NEGATIVE

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ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

archaeological and cultural significance

consideration of the identified heritage sites could result in the loss of sites of archaeological and cultural significance.

avoid the identified heritage sites.

Community approval must be obtained for having the borrow pits near identified heritage sites.

Impacts on sites of paleontological significance

During the planning and design phase, poor planning and consideration of the identified sensitive paleontological sites could result in the loss significant fossils.

DIRECT INDIRECT

Localised Long-term Possible Moderately severe HIGH NEGATIVE

• A suitably qualified palaeontological specialist must be appointed to inspect all areas where excavations of deeper than 1.5 m are made.

• A permit must be obtained by SANRAL and the palaeontologist to inspect all excavations of deeper than 1.5 m.

A protocol for the chance find of fossils must be developed and discussed with the contractor onsite.

LOW NEGATIVE

Impacts associated with the construction phase of the proposed borrow pits.

ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

CONSTRUCTION PHASE

GENERAL IMPACTS

Visual intrusion associated with the establishment of the borrow pit sites

During the construction phase construction activity and the presence and use of large machinery on site and along access roads will result in a visual disturbance of the landscape.

DIRECT CUMULATIVE

Localised Short-term Probable Moderately severe MODERATE NEGATIVE

All construction activity should take place during daylight working hours (i.e. 7 – 5pm).

All construction activity and equipment must be limited to the demarcated areas.

LOW NEGATIVE

Sanitation facilities

During the construction phase inappropriate siting and servicing of sanitation facilities could result in contamination of surface and ground water.

DIRECT Localised Medium-term Possible Severe MODERATE NEGATIVE

Sanitation facilities must NOT be located within 50m of any water resources or water drainage areas.

Sanitation facilities must be located within the borrow pit footprint.

The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.

LOW NEGATIVE

Demarcation of borrow pit sites

During the construction phase inadequate demarcation and fencing off of the borrow pit site could lead to unnecessary environmental disturbance.

DIRECT Localised Medium-term Possible Severe HIGH NEGATIVE

The boundaries of the borrow pit site must be adequately demarcated to restrict construction and other (eating, washing and ablution) activities. All plant, equipment and other materials must remain within the demarcated boundaries.

The site must be access controlled with security monitoring movements

LOW NEGATIVE

Socio-economic

During the construction phase temporary jobs will be created which will benefit the local workforce.

INDIRECT Study area Short-term Probable Moderately beneficial

SOME BENEFITS

No mitigation measure. SOME BENEFITS

Waste management

During construction, littering on site may attract vermin, detract from the visual appeal of the area and pollute the surrounding areas.

DIRECT Localised Medium-term Possible Moderately severe MODERATE NEGATIVE

Ensure there are sufficient containers for collecting waste.

No waste must be buried on site.

Waste must be collected on a regular basis and disposed of at a licensed landfill site.

LOW NEGATIVE

Impact on During the construction phase DIRECT Medium-term Localised Definite Severe LOW NEGATIVE All SCC impacted by construction LOW NEGATIVE

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ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

natural flora construction activity may result in the permanent loss of unidentified SCC.

activities must be conserved and rescued.

Inadequate rehabilitation

During the construction phase inadequate rehabilitation may lead to the permanent loss of sensitive ecosystems as well as allow the spread of alien invasive vegetation.

DIRECT INDIRECT

Long-term Localised Probable Moderately Severe MODERATE NEGATIVE

A Rehabilitation Management Plan must be implemented.

An Alien Removal Plan must be implemented and run during the construction phase.

LOW NEGATIVE

HERITAGE and PALEONTOLOGICAL

Impact on sites of archaeological and cultural significance

During the construction phase there could be accidental damage to already identified heritage features.

DIRECT

Medium-term Localised Possible Moderately severe HIGH NEGATIVE

If any graves/heritage features are damaged during construction then construction must stop immediately.

Any damage to heritage features must be reported to the EM, Heritage Specialist and SAHRA.

LOW NEGATIVE

During the construction phase potential unidentified heritage features may be uncovered and damaged.

DIRECT Medium-term Localised Possible Moderately severe MODERATE NEGATIVE

If human graves are uncovered during construction then all activity must stop immediately.

The police and ECPHRA must to be notified immediately.

If any other archaeological artefacts are uncovered during construction then construction must stop and these should be reported to the EM, Heritage Specialist and SAHRA/ECPHRA immediately.

LOW NEGATIVE

Impacts on sites of paleontological significance

During the construction phase there could be accidental damage to identified paleontologically sensitive sites.

DIRECT

Medium-term Localised Possible Moderately severe HIGH NEGATIVE

A suitably qualified paleontological specialist must be appointed to inspect all areas where excavation of deeper than 1.5 m is made.

A protocol for the chance find of fossils must be developed and discussed with the contractor onsite.

LOW NEGATIVE

Impacts associated with the operational (mining) phase of the proposed borrow pits.

ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

OPERATION PHASE

GENERAL IMPACTS

Compliance with relevant environmental legislation and policy

During the operational (mining) phase failure to comply with existing policies and legal obligations could lead to the project conflicting with local, provincial and national policies, legislation etc. This could result in legal non-compliance, fines, overall project failure or delays in mining activity and undue disturbance to the natural environment.

DIRECT CUMULATIVE

Localised Long-term Possible Severe HIGH NEGATIVE

The proponent must ensure that mining is compliant with the relevant legislation and policy.

These should include (but are not restricted to): MPRDA, NEMA, Local and District Spatial Development Frameworks, Eastern Cape Biodiversity Conservation Plan (ECBCP), Local Municipal bylaws.

LOW NEGATIVE

Visual intrusion associated with mining activities

During the operational (mining) phase the mining activities could result in a negative impact on the aesthetic value of the study area and immediate surrounds.

DIRECT CUMULATIVE

Study area Long-term Possible Moderately severe MODERATE NEGATIVE

Mining activities should only take place during normal work hours (7am to 5pm).

Mining activities must be limited to the designated area and not encroach into surrounding areas.

LOW NEGATIVE

Sanitation During the operational (mining) DIRECT Localised Medium-term Possible Severe MODERATE Sanitation facilities must be located LOW NEGATIVE

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ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

facilities phase inappropriate siting and servicing of sanitation facilities could result in contamination of surface and ground water.

NEGATIVE more than 50m from any water resources or water drainage areas.

Sanitation facilities must be located within the borrow pit footprint.

The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.

Demarcation of borrow pit site

During the operational (mining) phase encroachment of mining activities onto areas outside the borrow pit footprint could result in unnecessary environmental disturbance.

DIRECT Localised Medium-term Possible Severe HIGH NEGATIVE

The boundaries of the borrow pit site must be adequately demarcated to restrict mining and other (eating, washing and ablution) activities. All plant, equipment and other materials must remain within the demarcated boundaries.

The site must be access controlled with security monitoring movements

LOW NEGATIVE

Storm water During the operational (mining) phase inadequate stormwater control could result in soil erosion and impact surface water quality.

DIRECT CUMULATIVE

Localised Long-term Possible Moderately severe MODERATE NEGATIVE

Water runoff must be controlled and the stormwater management plan implemented.

LOW NEGATIVE

Spillage of hazardous substances

During the operational (mining) phase spillage of any hazardous substances such as fuel, chemicals, etc. could result in ground and surface water contamination.

DIRECT Localised Long-term Possible Moderately severe MODERATE NEGATIVE

All oils, fuel and other maintenance equipment and supplies must be stored in a secure area with a compacted surface.

Spill kits must be kept on-site and maintained and stored more than 50 m away from any water course.

LOW NEGATIVE

Dust control During the operational (mining) phase dust (generated from mining activities and from vehicles traveling on dirt roads) could be a nuisance during windy conditions.

DIRECT Study area Long-term Possible Moderately severe MODERATE NEGATIVE

During windy periods un-surfaced and un-vegetated areas should be dampened down.

Vegetation should be retained where possible as this will reduce dust travel.

Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas.

A speed limit of 30km/h must not be exceeded on dirt roads.

Any complaints or claims emanating from the lack of dust control must be attended to immediately.

LOW NEGATIVE

Noise During the operational (mining) phase mining activities and movement of heavy vehicles could result in an increase in ambient noise levels on site and on surrounding properties.

DIRECT Study area Long-term Probable Moderately severe MODERATE NEGATIVE

Drilling, blasting and movement of heavy machinery should be limited to normal working hours (7 AM to 5 PM).

Ensure there is a facility for nearby residents to make complaints. These must be addressed and recorded.

LOW NEGATIVE

Waste management

During operation (mining) littering on site may attract vermin, detract from the visual appeal of the area and pollute the surrounding areas.

DIRECT Localised Medium-term Possible Moderately severe MODERATE NEGATIVE

Sufficient waste containers must be available.

No waste must be buried on site.

Waste must be collected on a regular basis and disposed of at a licensed landfill site.

LOW NEGATIVE

Socio-economic

During the operational phase jobs will be created which will benefit the local workforce.

DIRECT Study area Long-term Probable Moderately beneficial

SOME BENEFITS

No mitigation measures. SOME BENEFITS

Impact on During the operational phase mining DIRECT Medium-term Localised Definite Severe LOW NEGATIVE All SCC impacted by mining activities LOW NEGATIVE

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ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

natural flora activity may result in the permanent loss of unidentified SCC.

must be conserved and rescued.

During the operational (mining) phase encroachment of mining activities into surrounding areas may cause unnecessary harm to sensitive faunal and floral species.

DIRECT Long-term Study area Possible Severe HIGH NEGATIVE

The mining area must be clearly demarcated/ fenced in. No mining activity must extend beyond the demarcated area.

LOW NEGATIVE

Inadequate rehabilitation

During the operational (mining) phase inadequate rehabilitation may lead to the permanent loss of sensitive vegetation as well as allow the spread of alien invasive vegetation.

DIRECT INDIRECT

Long-term Localised Probable Moderately Severe MODERATE NEGATIVE

A Rehabilitation Management Plan must be implemented.

An Alien Removal Plan must be implemented and run during the operational phase.

LOW NEGATIVE

HERITAGE and PALEONTOLOGICAL

Identification of archaeological and sites of cultural significance

During the operational (mining) phase sites of archaeological or cultural significance might be uncovered and damaged.

DIRECT Localised Long-term Possible Moderately severe MODERATE NEGATIVE

If human graves are uncovered during mining then all activity must stop immediately.

The police and ECPHRA must to be notified immediately.

If any other archaeological artefacts are uncovered during mining activity then mining must stop and these should be reported to the EM, Heritage Specialist and SAHRA/ECPHRA immediately.

LOW NEGATIVE

Impacts on sites of paleontological significance

During the operational (mining) phase sites of palaeontological significance might be uncovered and damaged.

DIRECT Localised Long-term Possible Moderately severe HIGH NEGATIVE

• A suitably qualified paleontological specialist must be appointed to inspect all areas where excavation of deeper than 1.5 m is made.

A protocol for the chance find of fossils must be developed and discussed with the contractor onsite.

LOW NEGATIVE

Impacts associated with the decommissioning/closure phase of the proposed borrow pits.

ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

DECOMMISSIONING PHASE

GENERAL IMPACTS

Final rehabilitation and decommissioning

During the decommissioning phase failure to decommission and rehabilitate the mining site properly could result in soil erosion, storm water issues, safety risks and invasion of alien plant species.

DIRECT Localised Long-term Possible Severe HIGH NEGATIVE

All infrastructure, equipment, machinery and other items used during the mining period must be removed from the site.

Waste material of any description, including receptacles, scrap, rubble and tyres, must be removed entirely from the mining area and disposed of at a recognized landfill facility. No waste must be buried or burned on the site.

The borrow pits, access roads, storm water control areas and any other affected areas must be rehabilitated.

The site must be covered with locally occurring grass and shaped/ levelled correctly.

All exposed areas must be re-vegetated where possible.

Mining areas must be inspected weekly

LOW NEGATIVE

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ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

for soil stability until rehabilitation is complete.

Alien invasive plant species must be eradicated until rehabilitation is complete.

The closed borrow pits must pose no safety risks.

Rehabilitation must be completed in such a manner that the land can be optimally used post-mining.

Final rehabilitation must be completed within a period specified by the Regional Manager (DMR).

Closure During the decommissioning phase failure to comply with the closure requirements could result in unnecessary environmental degradation and failure to obtain a closure certificate from DMR.

DIRECT Localised Long-term Possible Severe HIGH NEGATIVE

Closure must comply with the MPRDA (Act 28 of 2002), NEMA (Act 107 of 1998) and the NEMA Regulations (2014) requirements for mine closure.

A closure plan must be compiled using the guidelines described in Appendix 5 of the NEMA Regulations (2014) and submitted to DMR.

A closure certificate must be obtained from the Minister of Mineral Resources.

LOW NEGATIVE

No-go impacts associated with the proposed borrow pits.

ISSUE DESCRIPTION OF IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY / BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

NO-GO

Socio-economic benefits

If the project does not proceed then there will be a lack of job creation in the study area.

INDIRECT CUMULATIVE

Study Area Long-term Definite Moderately severe MODERATE NEGATIVE

No mitigation MODERATE NEGATIVE

No loss of vegetation

If the project does not proceed then vegetation that would otherwise be lost, during the construction and mining activity, would remain intact.

DIRECT Localised Long-term Definite Moderately Beneficial

SOME BENEFITS

No mitigation SOME BENEFITS

Current land use

If the project does not proceed there will be no change in the current land use of communal grazing, subsistence agriculture and grassland in the study area.

DIRECT Localised Long-term Definite Slightly beneficial FEW BENEFITS No mitigation FEW BENEFITS

Surrounding access road upgrade

If the project does not proceed then it will have negative implications for the access road upgrade (cost implications for purchasing road material, transport of material from far away to the road upgrade site, etc.).

DIRECT Regional Long-term Definite Severe HIGH NEGATIVE

No mitigation HIGH NEGATIVE

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16.3 APPENDIX C: Specialist Volume Heritage and Paleontologically Impact Assessment

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16.4 Appendix D: Environmental Management Programme