Proposed establishment of a quarry in the Ngquza Hill...
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Proposed establishment of a quarry in the Ngquza Hill Local
Municipality, Eastern Cape
Final Environmental Impact Report and
Environmental Management Programme Report
SLR Project No.: 723.19083.00003
Report No.: 5
April 2017
South African National Roads Agency SOC Ltd
Proposed establishment of a quarry in the Ngquza Hill Local
Municipality, Eastern Cape
Final Environmental Impact Report and
Environmental Management Programme Report
SLR Project No.: 723.19083.00003
Report No.: 5
April 2017
South African National Roads Agency SOC Ltd
ENVIRONMENTAL IMPACT ASSESSMENT REPORT
AND
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL
ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL
MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN
TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES
DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).
NAME OF APPLICANT: South African National Roads Agency SOC Ltd (SANRAL)
TEL NO: +27 41 398 3215
FAX NO: +27 41 492 0200
POSTAL ADDRESS: 20 Shoreward Drive (Adjacent Bay West Mall Entrance 4a),
Bay West, Port Elizabeth, 6025.
PHYSICAL ADDRESS: 20 Shoreward Drive (Adjacent Bay West Mall Entrance 4a),
Bay West, Port Elizabeth, 6025.
FILE REFERENCE NUMBER SAMRAD: EC 30/5/1/3/3/2/1/00066 BPEM
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EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER
NAME: Mr Fuad Fredericks
RESPONSIBILITY ON PROJECT: Project management and quality control
QUALIFICATIONS: M.Sc. (Botany), HDE
PROFESSIONAL
REGISTRATION: Pr.Sci.Nat., CEAPSA
EXPERIENCE IN YEARS: 17
EXPERIENCE:
Fuad Fredericks has been involved in environmental consulting
since 1999 and is currently a Director of SLR Consulting (South
Africa) (Pty) Ltd. He has experience in a wide range of
environmental disciplines, including Environmental Impact
Assessments, Environmental Management Programmes,
Environmental Monitoring and Auditing, Environmental
Education and Public Consultation. He has been responsible for
management and quality control of environmental assessments
dealing with a number of highly complex and controversial
projects, such as the proposed toll roads on the national routes
in the Western Cape and the proposed toll road between the
Eastern Cape and KwaZulu-Natal. He also has extensive
experience in the environmental assessment, monitoring and
auditing of projects related to railway facilities, landfill sites,
wastewater treatment facilities, and water and sewage pipelines.
NAME: Nicholas Arnott
RESPONSIBILITY ON PROJECT: Project consultant and report writing
QUALIFICATIONS: B.Sc. Hons (Earth and Geographical Science)
PROFESSIONAL
REGISTRATION: Pr.Sci.Nat.
EXPERIENCE IN YEARS: 10
EXPERIENCE:
Nicholas Arnott has worked as an environmental assessment
practitioner since 2006 and has been involved in a number of
projects covering a range of environmental disciplines, including
Basic Assessments, Environmental Impact Assessments and
Environmental Management Programmes. He has gained
experience in a wide range of projects relating to mining,
infrastructure projects (e.g. roads), housing and industrial
developments.
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EXECUTIVE SUMMARY
1. INTRODUCTION
This Executive Summary provides a comprehensive synopsis of the Final Environmental Impact Report
(EIR) and Environmental Management Programme Report (EMPR) prepared as part of the Scoping and
Environmental Impact Assessment (EIA) process that has been undertaken for the proposal by the South
African National Roads Agency SOC Ltd (SANRAL) to develop a quarry within the Ngquza Hill Local
Municipality in the Eastern Cape Province (see Figure 1). The proposed quarry would act as a local source
of the necessary materials for construction of the Mthentu and Msikaba river bridges and other required
works on the N2 Wild Coast Toll Highway.
1.1 PURPOSE OF THIS REPORT
This report summarises the Scoping and EIA process undertaken, provides an overview of the proposed project,
describes the affected environment, presents the findings of the specialist studies and provides an assessment of the
potential impacts of the proposed project. It should be noted that all substantive changes to the draft report are
underlined and in a different font (Times New Roman) to the rest of the text.
This report is submitted to the Department of Mineral Resources (DMR) for consideration as part of the Application for
Environmental Authorisation in terms of Chapter 5 of the National Environmental Management Act, 1998 (No. 107 of
1998) (NEMA), as amended.
1.2 PROJECT BACKGROUND
SANRAL has commenced with preparations for construction of the greenfields sections of the N2 Wild Coast
Toll Highway project. Such preparations include the identification of potential quarry site locations for the
sourcing of the necessary construction materials for the Mthentu and Msikaba river bridges and other
required works on the N2 Wild Coast Toll Highway. Based on the outcomes of preliminary geotechnical
investigations, a suitable site for the establishment of a quarry has been identified within the Ngquza Hill
Local Municipality in the Eastern Cape Province. Accordingly, SANRAL is now proposing to establish a
quarry at this site.
On 5 September 2016, SANRAL lodged an application for Environmental Authorisation with the DMR in
terms of Section 24 of NEMA, as amended. The application was accepted by DMR on 10 October 2016.
1.3 LEGISLATIVE FRAMEWORK
In terms of the Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002) (MPRDA), a
Mining Right must be issued prior to the commencement of any quarrying activities. In terms of Section 106
of the MPRDA, SANRAL is exempted from applying for a Mining Right for the purposes of sourcing road
building material. However, SANRAL is still required to submit the relevant environmental reports in terms of
Chapter 5 of the NEMA to obtain an environmental authorisation.
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Figure 1: Regional setting of the proposed quarry site.
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The EIA Regulations 2014 promulgated in terms of Chapter 5 of the NEMA, and published in Government
Notice (GN) No. R982 (as amended), provides for the control of certain listed activities. The proposed
project triggers various activities contained in Listing Notices 1, 2 and 3 (as amended), thus a full Scoping
and EIA process must be undertaken in order for the DMR to consider an application for environmental
authorisation1.
In terms of the National Water Act, 1998 (No. 36 of 1998) (NWA), a Water Use Licence Application for the
following water use activities, at a minimum, would be required for the proposed quarry:
• Section 21(c) - Impeding and diverting the flow of water in a watercourse; and
• Section 21(i) - Altering the bed, banks, course or characteristics of a watercourse.
It is noted that in terms of the General Authorisation (GA) Regulations (GN No. 509 of 26 August 2016),
SANRAL would not be required to apply for a WULA for the proposed access road over the KwaDlambu
River, as it would be authorised under the GA, subject to compliance with the necessary conditions.
Furthermore, the Contractor(s) to be appointed for the operation of the quarry would be responsible for
determining suitable water sources and obtaining any permits, licence and/or authorisations which may
also be applicable for the abstraction of water from these sources, as appropriate.
The proposed quarry will also require authorisation in terms of the National Heritage Resources Act, 1999
(No. 25 of 1999) (NHRA). The NHRA stipulates that no person may disturb any grave or burial ground
older than 60 years without a permit. Human remains that are less than 60 years old are subject to
provisions of the Human Tissue Act, 1983 (No. 65 of 1983) and any other applicable local regulations.
The relocation of graves would require a permit issued by the Eastern Cape Provincial Heritage
Resources Authority (ECPHRA).
2. EIA PROCESS
2.1 SCOPING PHASE
The Scoping Phase complied with the requirements of NEMA and the EIA Regulations 2014, as set out in
GN No. R982 (as amended). This involved a process of notifying Interested and Affected Parties (I&APs)
of the proposed project and EIA process in order to ensure that all potential key environmental impacts,
including those requiring further investigation, were identified.
The Scoping Report, which was prepared in compliance with Appendix 2 of the EIA Regulations 2014,
was accepted by DMR on 14 December 2016. DMR’s acceptance of the Scoping Report stated that the
next phase of the EIA may proceed as outlined in the Plan of Study for EIA, which was appended to the
Scoping Report.
2.2 EIA PHASE
2.2.1 Specialist studies
Three specialist studies were undertaken to address following aspects: (1) potential impacts on terrestrial
and freshwater ecosystems; (2) potential blasting impacts; and (3) potential impacts on cultural heritage
1 Subsequent to the distribution of the Draft EIA and EMPR Report for comment, the EIA Regulations 2014,
Listing Notices 1, 2 and 3 were amended by GN No. R.326, R.327, R.325, and R.324 of 7 April 2017,
respectively. These amendments have been duly taken into account in the compilation of this final report.
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resources. The specialist studies involved the gathering of data relevant to identifying and assessing
environmental impacts that may occur as a result of the proposed project. These impacts were then
assessed according to pre-defined rating scales. Specialists also recommended appropriate mitigation or
optimisation measures to minimise potential negative impacts or enhance potential benefits, respectively.
2.2.2 Integration and Assessment
The EIR and EMPR has been prepared in compliance with Appendix 3 of the EIA Regulations 2014. The specialist
assessments and other relevant information have been integrated into the report. The Draft EIR and EMPR was
distributed for a 30-day comment period from 17 March to 19 April 2017 (taking into account the three public
holidays during this period) in order to provide I&APs with an opportunity to comment on any aspect of the
proposed project and the findings of the EIA process. One verbal and two written submissions were received during
the review and comment period.
The following steps are envisaged for the remainder of the EIA process:
• After the Minister of Mineral Resources (or delegated authority) has reached a decision, all I&APs
on the project database will be notified of the outcome of the application and the reasons for the
decision; and
• A statutory appeal period in terms of the National Appeal Regulations (GN No. R993) will follow the
issuing of the decision.
3. PROPOSED PROJECT DESCRIPTION
As noted above, SANRAL is proposing to establish a quarry to provide the necessary materials for the
construction of the Mthentu and Msikaba river bridges and other works on the N2 Wild Coast Toll
Highway. Based on the initial results of preliminary geotechnical investigations, a suitable site for the
establishment of a quarry has been identified within the Ngquza Hill Local Municipality in the Eastern
Cape Province.
The proposed project would entail the establishment of a quarry, various associated stockpiles, a
contractor’s camp and an access road (see Figure 2). The total footprint of the area to be developed is
anticipated to be approximately 50 ha, with the proposed quarry being about 25 ha in extent.
The following key facilities associated with the contractor’s camp are currently planned:
• Offices;
• Ablution facilities;
• Workshop;
• Stores;
• Fuel storage;
• Concrete batching; and
• Crushing and processing plant.
The paragraphs overleaf provide a more detailed description of the proposed operations.
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Figure 2: Site plan of the proposed quarry.
CRUSHING PLANT
PRIMARY QUARRY
PRIMARY STOCKPILE
AREA
CONTRACTOR
CAMP
SECONDARY QUARRY
SECONDARY STOCKPILE
BACKUP
STOCKPILE
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3.1 QUARRY LAYOUT AND DEVELOPMENT
The proposed quarry could be either operated by a single operator or two operators simultaneously, thus
the site layout has been designed to make provision for two separate quarrying areas (Primary Quarry
and Secondary Quarry) that could be worked independently of each other. In the scenario that two
operators are involved, the Primary Quarry area would be worked by one operator along the east-west
face and the second operator would independently work the Secondary Quarry along the south-north
face.
The excavated material from each quarry area would then be processed by the crushing plant located on
the site. The processed material would be stockpiled and then loaded onto haul vehicles for transport to
the construction sites. Material that is not suitable for use in the construction works would be stockpiled
separately for use in the reshaping of the site during rehabilitation. Where two operators are involved at
the site, each operator would be responsible for the rehabilitation of their respective operational areas
(i.e. the separate Primary and Secondary quarry areas), as well as their portion of the overall site.
3.2 WASTE MANAGEMENT
Domestic waste generated during the course of the quarry operations would be collected and stored in
suitable receptacles on-site for collection and disposal at an appropriately licensed municipal waste site
or acceptable disposal facility.
3.3 WATER MANAGEMENT
It is anticipated that water would be required for dust suppression (on stockpiles and the access road)
and ancillary activities associated with the quarry operations (e.g. washing of vehicles and equipment).
The proposed source(s) and anticipated volumes required for the proposed project are not known at this
stage. The Contractor(s) to be appointed for the operation of the quarry would be responsible for
determining suitable water sources and obtaining any permits, licence and/or authorisations which may
also be applicable for the abstraction of water from these sources, as appropriate.
3.4 TRANSPORT
It is proposed that an access road would be established to link the proposed quarry site with the Holy
Cross - Mkambati Road. The proposed access road would cross a watercourse. The project engineer has
recommended that the proposed water crossing be a low-level river crossing structure comprising five
box culverts and positioned at the centre of the river. It was further recommended that the road section
located to the east of the river crossing be surfaced with concrete, while the road section to the west of
the river could be a gravel surface. The proposed access road would facilitate the transport of material by
truck from the site to the bridge construction and other areas.
4. AFFECTED ENVIRONMENT
4.1 BIOPHYSICAL ENVIRONMENT
The topography of the broader study area is very rugged and mountainous with deep and steep-sided
river valleys. The proposed quarry site itself is positioned on a hill and is bounded by two watercourses to
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the west, south and east of the site perimeter. The majority of the rivers in the region are considered to
have a high Ecological Importance and Sensitivity.
The natural vegetation of the study area is mapped as Ngongoni Veld, which is considered to be a
“Vulnerable” vegetation type. The proposed quarry site is located within an area identified as a terrestrial
“Critical Biodiversity Area (CBA) 2” and an aquatic “CBA2 estuary” in terms of the Eastern Cape
Biodiversity Conservation Plan Mapping.
Eight plant species of conservation concern were considered to potentially occur within the study area. Of
the eight species identified, two were confirmed to be present within the proposed quarry site, namely
Hypoxis hemerocallidea (Declining status) and Senecio umgeniensis (Threatened status), while further
verification is required to confirm the presence of a third species, Helichrysum cf. pannosum (Endangered
status). With respect to fauna, two mammal species (Cape Clawless Otter and Reddish-grey Musk
Shrew), three bird species (African Marsh-Harrier, Black Harrier and Black-Winged Lapwing) and twelve
endemic or near-endemic reptile species are thought to potentially occur within the project area.
4.2 CULTURAL HERITAGE ENVIRONMENT
Later Iron Age and two Early Iron Age sites have been historically identified in the broader study area.
From a cultural perspective, social capital is held in homesteads and graves, with grave sites often
associated with abandoned homesteads. The heritage specialist did not identify any archaeological sites
within the footprint of the proposed project and associated access road. However, a grave associated
with an old abandoned homestead was located in the eastern section of the project footprint.
4.3 SOCIO-ECONOMIC ENVIRONMENT
The Ngquza Hill Local Municipality (LM) is bordered by the Bizana LM to the north, the Port St John’s LM
to the south and the Ntabankulu LM to the northwest. The total population of the Ngquza Hill LM is
278 481, which is 20.4% of the total population of the O.R. Tambo District Municipality. Scattered rural
subsistence settlements predominate with some villages being fairly inaccessible. Approximately 95% of
the population of the municipality is recorded as living in traditional dwellings. The vast majority of the
population are not considered economically active (91 793 people) with only 18 524 people being
employed (Stats SA, 2011).
The proposed quarry site is largely undeveloped and sparsely populated with small dwellings (generally
comprising one to four structures). The remaining open areas are used for limited subsistence farming or
grazing. Road infrastructure in the area is poorly developed.
5. IMPACT ASSESSMENT CONCLUSIONS
A summary of the assessment of potential environmental impacts associated with the proposed project
activities and No-Go Alternative is provided in Table 5.1.
The majority of the impacts associated with the establishment and operation of the proposed quarry
would be largely localised, of long-term duration and of low intensity, and are considered to be of LOW
significance after mitigation. Key mitigation includes ensuring that the area of disturbance is limited to
what is absolutely necessary for the proposed operation, a detailed stormwater management plan is
developed and implemented, on-site pollution prevention measures are implemented and any complaints
received from third parties are addressed in accordance with a formal complaints procedure.
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One of the key issues associated with the proposed quarry operation relates to the loss of vegetation and
the related impacts on fauna and associated biodiversity. All vegetation within the quarry footprint would
be lost during the course of the operations. Approximately 22 ha of Degraded Primary Grassland and 29
ha of Secondary Grassland (of the ‘Vulnerable’ Ngongoni vegetation type) would be lost. Furthermore,
conservation-important plant species may be destroyed/damaged if measures are not taken to preserve
these plants. The loss of Ngongoni Veld and conservation-important species is considered to be a high
intensity impact, localised over the duration of the proposed quarry operations. As the loss of Ngongoni
Veld due to quarry establishment is accommodated in the approved Biodiversity Offset Report for the N2
Wild Coast Toll Highway (Botha & Brownlie, 2015), the requisite biodiversity offset would compensate for
the loss of the vegetation type. The residual impact is assessed to be of MEDIUM to HIGH significance.
With respect to noise impacts, it is anticipated that the proposed quarry would exceed the SANS
guidelines with respect to increasing ambient background noise levels in excess of 3 to 5 dBA. However,
as it is recommended that the homesteads closest to the quarry operations (i.e. within the project footprint
and associated 600m blast zone – see below) should be relocated, the closest receptors would be
located further away from noise sources associated with the proposed operations. The residual noise
impact of the proposed project is deemed to be of local extent, long-term duration, medium intensity and
MEDIUM significance.
The relocation of a single unmarked grave site located within the project footprint will be required, as well
as any graves which may be associated with homesteads to be relocated in the adjacent area. As human
remains have high heritage significance for their social value, the potential permanent, localised impact is
assessed to be of high intensity. By ensuring that all applicable legislative requirements, guidelines and
regulations applicable to the removal of human remains are implemented for the relocation of graves, it is
anticipated that the residual impact would be of MEDIUM significance.
Where basting activities associated with the proposed quarry operations lead to the damage of third party
property or injury of people or animals, the impact would be of high intensity at a local level and endure in
the medium term and is deemed to be of medium significance without mitigation. The blasting specialist
has indicated that the human response to the modelled ground vibration levels would be at an
“unpleasant” level up to 592 m of the boundary of the quarry footprint. Consequently, it is recommended
that the relocation of households within 600 m of the quarry boundary be considered. By relocating third-
parties outside of the project footprint and the blasting zone (a distance of 600 m, as recommended by
the blasting specialist), the significance of the residual impact would reduce to LOW.
Not going ahead with the proposed quarry operations (No-Go Alternative) would result in the
maintenance of the status quo. No change to the current impacts experienced on the site would be
expected for terrestrial and freshwater ecosystems, ambient air quality, noise, heritage and cultural
resources, traffic and land uses. Furthermore, NO IMPACT with respect to blasting hazards and the influx
of job seekers would be anticipated. However, not proceeding with the proposed project would result in
the loss of direct and indirect socio-economic benefits of the proposed project and lost economic
opportunities related to costs already incurred in the initial planning phase. This is considered to be of
HIGH significance.
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Table 5.1: Summary of the significance of the potential impacts associated with the proposed
mining operations and No-Go Alternative.
Potential impact
Significance
Without
mitigation
With mitigation
POTENTIAL BIOPHYSICAL IMPACTS
Soil and land capability M L
Fauna and Flora Loss of vegetation H M - H
Loss of fauna and alteration of habitats L L
Hydrology (Surface Water) M L - M
Air Quality L L
Noise M M
POTENTIAL SOCIO-ECONOMIC IMPACTS
Heritage and Cultural Resources Unmarked grave site H M
Archaeological sites M L
Impacts on roads by project-related traffic M – H L - M
Blasting Hazards M L
Land Use L L
Creation of employment and business opportunities L (+ve) L (+ve)
Influx of job seekers to the area M L
NO-GO ALTERNATIVE
No-Go Alternative Soil and land capability L N/A
Fauna and Flora L N/A
Hydrology (Surface Water) L N/A
Air Quality
NO CHANGE TO CURRENT
IMPACTS
Noise
Heritage and Cultural Resources
Impacts on traffic
Land Use
Blasting Hazards NO IMPACT
Influx of job seekers
Lost Economic Opportunities H N/A
VH=Very High H=High M=Medium L=Low VL=Very low Insig =
insignificant
N/A=
Not applicable
5.1 REASONED OPINION OF ENVIRONMENTAL ASSESSMENT PRACTITIONER
The key principles of sustainability, including ecological integrity, economic efficiency, and equity and
social justice, are integrated below as part of the supporting rationale for recommending an opinion on
whether the proposed project should or should not be approved.
• Ecological integrity2
The potential disturbance of Ngongoni Veld and associated biodiversity is considered to be of high
intensity as all vegetation (and associated available habitat) within the quarry footprint would be
lost during the course of quarry operations. The area of disturbance (approximately 70 ha including
the proposed project footprint and associated access road) is considered to be relatively
substantial in comparison to the remaining intact area of this ‘Vulnerable’ vegetation type.
Furthermore, there are numerous conservation-important species present within the grassland
2 Ecological integrity is the abundance and diversity of organisms at all levels, and the ecological patterns, processes and structural
attributes responsible for that biological diversity and for ecosystem resilience.
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ecosystem at the site which may be destroyed/damaged if measures are not taken to preserve
these plants. By undertaking a plant search and rescue operation prior to the clearing of the site,
the impact on conservation-important species would be mitigated.
As the loss of Ngongoni Veld due to quarry establishment is accommodated in the approved
Biodiversity Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015), the loss of
the vegetation type within the project footprint would be compensated for and the overall
significance of the project impact on the conservation status of the vegetation type would be
reduced.
• Economic efficiency
The area surrounding the proposed quarry site is generally undeveloped with very limited socio-
economic opportunities. The proposed project would create local employment and business
opportunities. These potential benefits to the local economy would extend over the operational
lifespan of the proposed project. It is anticipated that a large number of the low- and semi-skilled
employment opportunities could be sourced from the local labour force, especially during the site
establishment phase. In terms of business opportunities for local companies, contract procurement
requirements would create business opportunities for the regional and local economy. A
percentage of the monthly wage bill earned by permanent staff would be spent in the regional and
local economy, which would benefit local businesses.
In light of the above, the proposed project is considered to be economically efficient, as it would
provide an opportunity to utilise natural resources within the Eastern Cape with associated socio-
economic benefits. With the recommended enhancement measures, any possible negative impact
associated with inward migration would be further reduced.
• Equity and social justice
While the proposed project would require the relocation of people residing within the project
footprint and the associated blasting zone (600m from the boundary of the quarry footprint), the
relocation would be undertaken by the appointed land management specialist in accordance with
the requirements of, amongst others, the Constitution of South Africa Act, 1996 (Act No. 108 of
1996) and the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996), as
applicable. These legislative provisions ensure, amongst others, that directly affected parties
receive fair and equitable treatment and that no person shall be worse off when compared to their
current situation.
It is the opinion of SLR that, in terms of the sustainability criteria described above and the nature and
extent of the proposed quarry activities, the generally LOW to MEDIUM significance residual impacts
should support a positive decision being made by the Minister of Mineral Resources (or delegated
authority) in this regard.
5.2 RECOMMENDATIONS
It is recommended that the following conditions should be included in the Environmental Authorisation
(EA), if a decision to grant an EA is issued:
• An Environmental Management Programme (EMP) for the construction and operational phases
must be implemented for the duration of the proposed project (refer to the EMP attached as
Appendix 6).
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• Ensure that the existing Biodiversity Offset Agreement for the N2 Wild Coast Toll Highway, which
accommodates the potential loss of primary Ngongoni Veld due to stockpiling and/or the
establishment of borrow pits/quarries, is implemented effectively.
• A protected plant survey must be undertaken within the primary terrestrial Ngongoni grassland
within the project footprint, in order to confirm the presence and abundance of threatened and
protected plant species. This survey must be undertaken by a suitably qualified botanist, prior to
the commencement of construction, during the summer growing season (between November and
March). The protected plant survey must be used to develop a detailed protected plant rescue and
translocation protocol for threatened and protected plants (based on the preliminary guidelines
provided in Section 5.4 of the specialist terrestrial ecological report, attached as Appendix 4.1).
• Undertake a Baseline Water Quality Monitoring Survey prior to the commencement of construction
activities in order to collect baseline data for the monitoring of water quality impacts associated with
construction and operation of the quarry.
• Develop a detailed Stormwater Management Plan that describes how the design measures of
surface and near-surface water management facilities will be designed, constructed and operated
so that contaminated water is kept separate from clean water run-off through a system of berms,
channels, trenches, flood and erosion protection measures.
• Relocate all households within the quarry footprint and 600 m from the quarry boundary.
• Monitor ground vibration and air blast to ensure that the generated levels of ground vibration and
air blast comply with recommendations. The monitoring of ground vibration must qualify the
expected ground vibration and air blast levels and assist in mitigating these aspects properly. Ten
monitoring positions have been proposed by the blasting specialist (see Figure 18 and Table 17 of
Appendix 4.3).
• Develop a comprehensive Rehabilitation and Closure Plan prior to the decommissioning and
closure of the proposed quarry operation.
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TABLE OF CONTENTS
DOCUMENT INFORMATION......................................................................................................................... i
EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER ...................................................... ii
EXECUTIVE SUMMARY .............................................................................................................................. iii
TABLE OF CONTENTS ............................................................................................................................. xiv
ACRONYMS AND ABBREVIATIONS ......................................................................................................... xx
PART A - FINAL ENVIRONMENTAL IMPACT REPORT
1. CONTACT PERSON AND CORRESPONDENCE ADDRESS........................................................... 1
1.1. DETAILS OF THE EAP WHO PREPARED THE REPORT ..................................................... 1
1.2. EXPERTISE OF THE EAP ....................................................................................................... 1
2. DESCRIPTION OF THE PROPERTY ................................................................................................. 1
3. LOCALITY MAP .................................................................................................................................. 2
4. DESCRIPTION OF THE SCOPE OF THE PROPOSED OVERALL ACTIVITY ................................. 2
4.1. LISTED AND SPECIFIED ACTIVITIES .................................................................................... 2
4.2. DESCRIPTION OF THE ACTIVITIES TO BE UNDERTAKEN ................................................. 6
4.2.1. PROJECT OVERVIEW ................................................................................................ 6
4.2.2. QUARRY LAYOUT AND DEVELOPMENT ................................................................. 6
4.2.3. WASTE MANAGEMENT .............................................................................................. 8
4.2.4. WATER MANAGEMENT ............................................................................................. 8
4.2.5. TRANSPORT ............................................................................................................... 8
5. POLICY AND LEGISLATIVE CONTEXT ............................................................................................ 8
5.1. LEGISLATIVE REQUIREMENTS ............................................................................................. 8
5.1.1. OVERVIEW OF THE “ONE ENVIRONMENTAL SYSTEM” ........................................ 8
5.1.2. MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002
(MPRDA) ...................................................................................................................... 8
5.1.3. NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (NEMA) ........................ 9
5.1.4. NATIONAL WATER ACT, 1998 (NWA) ....................................................................... 9
5.1.5. NATIONAL HERITAGE RESOURCES ACT, 1999 (NHRA) ...................................... 10
5.1.6. NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT, 2004
(NEM:BA) ................................................................................................................... 11
5.2. GUIDELINES AND POLICIES ................................................................................................ 11
6. NEED AND DESIRABILITY OF THE PROPOSED PROJECT......................................................... 12
7. MOTIVATION FOR THE PREFERRED DEVELOPMENT FOOTPRINT WITHIN THE
APPROVED SITE INCLUDING THE PROCESS FOLLOWED TO DEFINE THE PREFERRED
DEVELOPMENT ALTERNATIVES ................................................................................................... 13
7.1. DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED ....................................... 13
7.1.1. PROPERTY ON WHICH OR LOCATION WHERE IT IS PROPOSED TO
UNDERTAKE THE ACTIVITY.................................................................................... 13
7.1.2. TYPE OF ACTIVITY TO BE UNDERTAKEN ............................................................. 16
7.1.3. DESIGN OR LAYOUT OF THE ACTIVITY ................................................................ 16
7.1.4. TECHNOLOGY TO BE USED IN THE ACTIVITY ..................................................... 16
7.1.5. OPERATIONAL ASPECTS OF THE ACTIVITY ........................................................ 17
7.1.6. OPTION OF NOT IMPLEMENTING THE ACTIVITY ................................................. 17
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7.2. DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED ................................ 17
7.2.1. SCOPING PHASE ..................................................................................................... 17
7.2.2. SUMMARY OF ISSUES RAISED BY I&APS ............................................................. 20
8. THE ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE DEVELOPMENT
FOOTPRINT ALTERNATIVES ......................................................................................................... 25
8.1. BASELINE ENVIRONMENT ................................................................................................... 25
8.1.1. CLIMATE .................................................................................................................... 25
8.1.2. TOPOGRAPHY .......................................................................................................... 25
8.1.3. GEOLOGY AND SOILS ............................................................................................. 25
8.1.4. BIODIVERSITY .......................................................................................................... 26
8.1.5. CULTURAL/HERITAGE ENVIRONMENT ................................................................. 31
8.1.6. REGIONAL SOCIO-ECONOMIC ENVIRONMENT ................................................... 32
8.1.7. CURRENT LAND USES ............................................................................................ 32
8.2. IMPACTS AND RISKS IDENTIFIED INCLUDING THE NATURE, SIGNIFICANCE,
CONSEQUENCE, EXTENT, DURATION AND PROBABILITY OF THE IMPACTS .............. 34
8.2.1. POTENTIAL BIOPHYSICAL IMPACTS ..................................................................... 34
8.2.2. POTENTIAL SOCIO-ECONOMIC IMPACTS ............................................................ 43
8.2.3. NO-GO ALTERNATIVE ............................................................................................. 50
8.3. METHODOLOGY USED IN DETERMINING AND RANKING THE NATURE,
SIGNIFICANCE, CONSEQUENCES, EXTENT, DURATION AND PROBABILITY OF
POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS ...................................................... 51
8.3.1. EXTENT ..................................................................................................................... 53
8.3.2. DURATION................................................................................................................. 53
8.3.3. INTENSITY................................................................................................................. 53
8.3.4. SIGNIFICANCE .......................................................................................................... 54
8.3.5. STATUS OF IMPACT ................................................................................................ 54
8.3.6. PROBABILITY ............................................................................................................ 55
8.3.7. DEGREE OF CONFIDENCE ..................................................................................... 55
8.3.8. LOSS OF RESOURCES ............................................................................................ 55
8.3.9. DEGREE TO WHICH IMPACT CAN BE MITIGATED ............................................... 55
8.3.10. REVERSIBILITY OF AN IMPACT .............................................................................. 55
8.4. THE POSITIVE AND NEGATIVE IMPACTS THAT THE PROPOSED ACTIVITY (IN
TERMS OF THE INITIAL SITE LAYOUT) AND ALTERNATIVES WILL HAVE ON THE
ENVIRONMENT AND THE COMMUNITY THAT MAY BE AFFECTED ................................ 56
8.5. THE POSSIBLE MITIGATION MEASURES THAT COULD BE APPLIED AND THE
LEVEL OF RISK...................................................................................................................... 56
8.6. MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED........................... 56
8.7. STATEMENT MOTIVATING THE ALTERNATIVE DEVELOPMENT LOCATION
WITHIN THE OVERALL SITE ................................................................................................ 56
9. FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND
RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED
SITE................................................................................................................................................... 57
9.1. ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND
RISK ........................................................................................................................................ 58
9.2. SUMMARY OF SPECIALIST REPORTS ............................................................................... 61
10. ENVIRONMENTAL IMPACT STATEMENT ...................................................................................... 63
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10.1. SUMMARY OF THE KEY FINDINGS OF THE ENVIRONMENTAL IMPACT
ASSESSMENT........................................................................................................................ 63
10.2. FINAL SITE MAP .................................................................................................................... 63
10.3. SUMMARY OF THE POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS OF THE
PROPOSED ACTIVITY AND IDENTIFIED ALTERNATIVES ................................................ 64
11. PROPOSED IMPACT MANAGEMENT OBJECTIVES AND THE IMPACT MANAGEMENT
OUTCOMES FOR INCLUSION IN THE EMPR ................................................................................ 65
12. FINAL PROPOSED ALTERNATIVES ............................................................................................... 65
13. ASPECTS FOR INCLUSION AS CONDITIONS OF AUTHORISATION .......................................... 65
14. DESCRIPTION OF ANY ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE ........ 65
14.1. REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY SHOULD OR
SHOULD NOT BE AUTHORISED .......................................................................................... 65
14.2. REASONS WHY THE ACTIVITY SHOULD BE AUTHORISED OR NOT .............................. 67
14.3. CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION ............................... 67
14.3.1. SPECIFIC CONDITIONS TO BE INCLUDED INTO THE COMPILATION AND
APPROVAL OF EMPR .............................................................................................. 67
14.3.2. REHABILITATION REQUIREMENTS ....................................................................... 67
14.3.3. PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS
REQUIRED ................................................................................................................ 68
15. UNDERTAKING ................................................................................................................................ 68
16. FINANCIAL PROVISION .................................................................................................................. 68
16.1. EXPLAIN HOW THE AFORESAID AMOUNT WAS DERIVED .............................................. 68
16.2. CONFIRM THAT THIS AMOUNT CAN BE PROVIDED FOR FROM OPERATING
EXPENDITURE....................................................................................................................... 68
17. DEVIATIONS FROM THE APPROVED SCOPING REPORT AND PLAN OF STUDY ................... 69
17.1. DEVIATIONS FROM THE METHODOLOGY USED IN DETERMINING THE
SIGNIFICANCE OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS ..................... 69
17.2. MOTIVATION FOR THE DEVIATION .................................................................................... 69
18. OTHER INFORMATION REQUIRED BY THE COMPETENT AUTHORITY .................................... 69
18.1. IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY AFFECTED
PERSON ................................................................................................................................. 69
18.2. IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF THE
NATIONAL HERITAGE RESOURCES ACT .......................................................................... 69
19. OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT ........ 69
PART B - FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
1. FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT .............................................. 1
1.1. DETAILS OF THE EAP ............................................................................................................. 1
2. DESCRIPTION OF THE ASPECTS OF THE ACTIVITY .................................................................... 1
3. COMPOSITE MAP .............................................................................................................................. 1
4. DESCRIPTION OF IMPACT MANAGEMENT OBJECTIVES............................................................. 1
4.1. DETERMINATION OF CLOSURE OBJECTIVES .................................................................... 1
4.2. THE PROCESS FOR MANAGING ANY ENVIRONMENTAL DAMAGE, POLLUTION,
PUMPING AND TREATMENT OF EXTRANEOUS WATER OR ECOLOGICAL
DEGRADATION AS A RESULT OF UNDERTAKING A LISTED ACTIVITY ........................... 2
4.3. POTENTIAL RISK OF ACID MINE DRAINAGE ....................................................................... 2
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4.3.1. INDICATE WHETHER OR NOT THE MINING CAN RESULT IN ACID MINE
DRAINAGE................................................................................................................... 2
4.3.2. STEPS TAKEN TO INVESTIGATE, ASSESS, AND EVALUATE THE IMPACT
OF ACID MINE DRAINAGE ......................................................................................... 2
4.3.3. ENGINEERING OR MINE DESIGN SOLUTIONS TO BE IMPLEMENTED TO
AVOID OR REMEDY ACID MINE DRAINAGE ............................................................ 3
4.3.4. MEASURES THAT WILL BE PUT IN PLACE TO REMEDY ANY RESIDUAL
OR CUMULATIVE IMPACT THAT MAY RESULT FROM ACID MINE
DRAINAGE................................................................................................................... 3
4.4. VOLUMES AND RATE OF WATER USE REQUIRED FOR THE MINING, TRENCHING
OR BULK SAMPLING OPERATION ........................................................................................ 3
4.5. HAS A WATER USE LICENCE HAS BEEN APPLIED FOR? .................................................. 3
4.6. IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES ......................................... 4
4.7. IMPACT MANAGEMENT OUTCOMES .................................................................................... 7
4.8. IMPACT MANAGEMENT ACTIONS......................................................................................... 8
5. FINANCIAL PROVISION .................................................................................................................. 10
5.1. DETERMINATION OF THE AMOUNT OF FINANCIAL PROVISION .................................... 10
5.1.1. DESCRIBE THE CLOSURE OBJECTIVES AND THE EXTENT TO WHICH
THEY HAVE BEEN ALIGNED TO THE BASELINE ENVIRONMENT
DESCRIBED UNDER REGULATION 22 (2) (D) ....................................................... 10
5.1.2. CONFIRM SPECIFICALLY THAT THE ENVIRONMENTAL OBJECTIVES IN
RELATION TO CLOSURE HAVE BEEN CONSULTED WITH LANDOWNER
AND INTERESTED AND AFFECTED PARTIES....................................................... 10
5.1.3. PROVIDE A REHABILITATION PLAN THAT DESCRIBES AND SHOWS THE
SCALE AND AERIAL EXTENT OF THE MAIN MINING ACTIVITIES,
INCLUDING THE ANTICIPATED MINING AREA AT THE TIME OF CLOSURE ..... 10
5.1.4. COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE
OBJECTIVES ............................................................................................................. 10
5.1.5. CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION
REQUIRED TO MANAGE AND REHABILITATE THE ENVIRONMENT IN
ACCORDANCE WITH THE APPLICABLE GUIDELINE ........................................... 11
5.1.6. CONFIRM THAT THE FINANCIAL PROVISION WILL BE PROVIDED AS
DETERMINED ........................................................................................................... 11
6. MECHANISMS FOR MONITORING COMPLIANCE WITH AND PERFORMANCE
ASSESSMENT AGAINST THE ENVIRONMENTAL MANAGEMENT PROGRAMME AND
REPORTING ..................................................................................................................................... 12
6.1. INDICATE THE FREQUENCY OF THE SUBMISSION OF THE PERFORMANCE
ASSESSMENT REPORT ....................................................................................................... 15
7. ENVIRONMENTAL AWARENESS PLAN ......................................................................................... 15
7.1. MANNER IN WHICH THE APPLICANT INTENDS TO INFORM HIS OR HER
EMPLOYEES OF ANY ENVIRONMENTAL RISK WHICH MAY RESULT FROM THEIR
WORK ..................................................................................................................................... 15
7.2. MANNER IN WHICH RISKS WILL BE DEALT WITH IN ORDER TO AVOID
POLLUTION OR THE DEGRADATION OF THE ENVIRONMENT ....................................... 15
8. SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY ................................ 15
9. UNDERTAKING ................................................................................................................................ 15
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List of Appendices
Appendix 1: CVs and Proof of Registration of the EAP
Appendix 2: DMR Acceptance of the Scoping Report
Appendix 3: Public Participation Process
Appendix 3.1: I&AP Database
Appendix 3.2: I&AP Notification letters
Appendix 3.3: I&AP Correspondence
Appendix 3.4: Comments and Responses Report
Appendix 4: Specialist Reports
Appendix 4.1: Terrestrial and Aquatic Ecosystems
Appendix 4.2: Blasting Impact
Appendix 4.3: Cultural Heritage
Appendix 5: Undertaking
Appendix 6: EMP
List of Figures
FIGURE 3-1: REGIONAL SETTING OF THE PROPOSED QUARRY SITE ................................................................ 3
FIGURE 4-1: SITE PLAN OF THE PROPOSED QUARRY. ......................................................................................... 7
FIGURE 7-1: GOOGLE EARTH IMAGE OF THE IDENTIFIED ALTERNATIVE SITES FOR THE PROPOSED
QUARRY (THE PREFERRED ALTERNATIVE IS SHADED RED). ...................................................... 15
FIGURE 8-1: CRITICAL BIODIVERSITY AREAS IN THE BROADER STUDY AREA. THE PROPOSED QUARRY
LOCATION IS INDICATED AS A BLUE DOT (SOURCE: SANBI BIODIVERSITY GIS, 2016). ............ 27
FIGURE 8-2: IDENTIFIED VEGETATION COMMUNITIES WITHIN THE STUDY AREA. ......................................... 28
FIGURE 8-3: MAPPED WATERCOURSE UNITS WITHIN 500 M OF THE PROPOSED QUARRY FOOTPRINT
AREA. ................................................................................................................................................... 30
FIGURE 8-4: IDENTIFIED SCHOOLS, POLICE STATIONS AND HEALTH CARE FACILITIES WITHIN THE
BROADER STUDY AREA. ................................................................................................................... 33
List of Tables
TABLE 4-1: LIST OF ACTIVITIES/INFRASTRUCTURE ASSOCIATED WITH THE PROPOSED PROJECT ........... 4
TABLE 5-1: LIST OF POSSIBLE WATER USE ACTIVITIES IN TERMS OF THE NWA. ......................................... 10
TABLE 5-2: GUIDELINES AND POLICIES RELEVANT TO THE PROPOSED PROJECT. .................................... 12
TABLE 7-1: POTENTIAL ALTERNATIVE QUARRY SITES INITIALLY INVESTIGATED FOR DEVELOPMENT
(THE PREFERRED SITE IS SHADED). ............................................................................................... 13
TABLE 8-1: ASSESSMENT OF THE POTENTIAL IMPACT ON SOIL AND LAND CAPABILITY. ........................... 35
TABLE 8-2: ASSESSMENT OF THE POTENTIAL IMPACT ASSOCIATED WITH THE LOSS OF VEGETATION. 37
TABLE 8-3: ASSESSMENT OF THE POTENTIAL IMPACT ASSOCIATED WITH THE LOSS OF FAUNA AND
ALTERATION OF FAUNAL HABITAT. ................................................................................................. 38
TABLE 8-4: ASSESSMENT OF THE POTENTIAL IMPACTS ON SURFACE WATER FEATURES. ...................... 40
TABLE 8-5: ASSESSMENT OF THE POTENTIAL IMPACTS ON AIR QUALITY. ................................................... 41
TABLE 8-6: ASSESSMENT OF THE POTENTIAL IMPACTS ON AMBIENT NOISE LEVELS. ............................... 42
TABLE 8-7: ASSESSMENT OF THE POTENTIAL IMPACT ON HERITAGE RESOURCES. .................................. 43
TABLE 8-8: ASSESSMENT OF THE POTENTIAL IMPACT ON ROAD TRAFFIC. ................................................. 45
TABLE 8-9: ASSESSMENT OF THE POTENTIAL BLASTING IMPACTS. .............................................................. 47
TABLE 8-10: ASSESSMENT OF THE POTENTIAL IMPACT ON LAND USE. .......................................................... 48
TABLE 8-11: ASSESSMENT OF THE POTENTIAL SOCIAL IMPACT RELATED TO EMPLOYMENT AND THE
CREATION OF BUSINESS OPPORTUNITIES DURING OPERATION. .............................................. 49
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TABLE 8-12: ASSESSMENT OF THE POTENTIAL SOCIAL IMPACT RELATED TO THE INFLUX OF
OPERATION WORKERS. .................................................................................................................... 50
TABLE 8-13: ASSESSMENT OF THE POTENTIAL IMPACTS RELATED TO THE NO-GO ALTERNATIVE. ........... 51
TABLE 10-1: SUMMARY OF THE SIGNIFICANCE OF THE POTENTIAL IMPACTS ASSOCIATED WITH THE
PROPOSED QUARRY OPERATIONS AND NO-GO ALTERNATIVE. ................................................. 63
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ACRONYMS AND ABBREVIATIONS
Below a list of acronyms and abbreviations used in this report.
Acronyms / Abbreviations
Meaning
CBA Critical Biodiversity Area
DMR Department of Mineral Resources
DWS Department of Water and Sanitation
EAP Environmental Assessment Practitioner
ECPHRA Eastern Cape Provincial Heritage Resources Authority
EIR Environmental Impact Report
EMP Environmental Management Programme
EMPR Environmental Management Programme Report
GN Government Notice
I&AP Interested and Affected Party
IEM Integrated Environmental Management
MPRDA Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002)
NEMA National Environmental Management Act, 1998 (No. 107 of 1998)
NEM:BA National Environmental Management: Biodiversity Act, 2004 (No. 10 of 2004)
NWA National Water Act, 1998 (No. 36 of 1998)
SANRAL South African National Roads Agency SOC Ltd
SLR SLR Consulting (South Africa) (Pty) Ltd
PART A
FINAL ENVIRONMENTAL IMPACT REPORT
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1. CONTACT PERSON AND CORRESPONDENCE ADDRESS
1.1. DETAILS OF THE EAP WHO PREPARED THE REPORT
The contact details of the Environmental Assessment Practitioner (EAP) who prepared this Final
Environmental Impact Report (EIR) and Environmental Management Programme Report (EMPR) are
provided below.
Neither SLR Consulting (South Africa) (Pty) Ltd (SLR) nor any of the specialists involved in the
environmental assessment process have any interest in the proposed project other than fair remuneration
for consulting services rendered as part of the environmental assessment process.
EAP: SLR Consulting (South Africa) (Pty) Ltd
Contact Person: Fuad Fredericks
Postal Address PO Box 10145
Caledon Square Postal Code: 7905
Telephone 021 461 1118 Cell: -
E-mail: [email protected] Fax: 021 461 1120
1.2. EXPERTISE OF THE EAP
The expertise of the individuals who were involved in the preparation of this Final EIR and EMPR are
provided on Page ii. The relevant curricula vitae and proof of registrations of the EAP are provided in
Appendix 1.
2. DESCRIPTION OF THE PROPERTY
The South African National Roads Agency SOC Ltd (SANRAL) is proposing to develop a quarry within
the Ngquza Hill Local Municipality in the Eastern Cape Province. Details regarding the location of the
proposed quarry are provided below.
Farm Name Un-alienated state land. Corner of property point co-ordinates
A 31° 11' 43.09" S 29° 49' 3.78" E
B 31° 11' 43.89" S 29° 49' 9.42" E
C 31° 11' 47.18" S 29° 49' 14.08" E
D 31° 12' 7.31" S 29° 49' 31.33" E
E 31° 12' 11.95" S 29° 49' 27.92" E
F 31° 12' 12.98" S 29° 49' 26.70" E
G 31° 12' 13.22" S 29° 49' 24.32" E
H 31° 12' 12.95" S 29° 49' 21.18" E
I 31° 12' 12.37" S 29° 49' 18.14" E
J 31° 12' 12.22" S 29° 49' 15.30" E
K 31° 12' 12.81" S 29° 49' 12.03" E
L 31° 12' 14.95" S 29° 49' 9.81" E
M 31° 12' 9.51" S 29° 49' 5.33" E
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N 31° 12' 3.62" S 29° 49' 1.00" E
Corner of property point co-ordinates
O 31° 12' 0.07" S 29° 48' 59.92" E
P 31° 11' 57.32" S 29° 49' 3.34" E
Q 31° 11' 52.72" S 29° 49' 3.46" E
R 31° 11' 48.23" S 29° 49' 2.20" E
Application area (ha) 50 hectares (ha)
Magisterial district Flagstaff
Tribal Authority Sipaqeni Traditional Authority
Distance and direction from nearest town
Flagstaff (located approximately 34 km to the north-west) is the nearest town.
21 digit Surveyor General Code for each farm portion
Not applicable.
3. LOCALITY MAP
The regional setting of the study area indicating the locality of the proposed quarry site is provided in
Figure 3-1 overleaf.
4. DESCRIPTION OF THE SCOPE OF THE PROPOSED OVERALL
ACTIVITY
Provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000 that shows the location,
and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site.
SANRAL has commenced with preparations for construction of the greenfields sections of the N2 Wild
Coast Toll Highway project. Such preparations include the identification of potential quarry site locations
for the sourcing of the necessary construction materials for the Mthentu and Msikaba river bridges and
other required works on the N2 Wild Coast Toll Highway. Based on the outcomes of preliminary
geotechnical investigations, a suitable site for the establishment of a quarry has been identified within the
Ngquza Hill Local Municipality in the Eastern Cape Province. Accordingly, SANRAL is now proposing to
establish a quarry at this site. A description of the proposed quarry and associated activities is provided in
Section 4.2 below.
4.1. LISTED AND SPECIFIED ACTIVITIES
The EIA Regulations 2014 promulgated in terms of Chapter 5 of National Environmental Management Act
(NEMA), 1998 (Act 107 of 1998), and published in Government Notice (GN) No. R982, provides for the
control of certain listed activities1. These activities are listed in GN No. R983 (Listing Notice 1), R984
(Listing Notice 2) and R985 (Listing Notice 3) of 4 December 2014, and are prohibited until Environmental
Authorisation has been obtained from the competent authority. The Minister of Mineral Resources
remains responsible for the granting of Environmental Authorisation for Mining Right Applications in terms
of NEMA. Such Environmental Authorisation, which may be granted subject to conditions, will only be
considered once there has been compliance with GN No. R982 (as amended).
1 Subsequent to the distribution of the Draft EIA and EMPR Report for comment, the EIA Regulations 2014, Listing
Notices 1, 2 and 3 were amended by GN No. R.326, R.327, R 325, and R.324 of 7 April 2017, respectively. These
amendments have been duly taken into account in the compilation of this final report.
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Figure 3-1: Regional setting of the proposed quarry site.
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GN No. R982 (as amended) sets out the procedures and documentation that need to be complied with
when applying for Environmental Authorisation. A Basic Assessment process must be applied to an
application if the authorisation applied for is in respect of an activity(ies) listed in Listing Notice 1 and / or
3 (as amended) and a Scoping and Environmental Impact Assessment (EIA) process must be applied to an
application if the authorisation applied for is in respect of an activity(ies) listed in Listing Notice 2 (as
amended).
The proposed project triggers various activities contained in Listing Notices 1, 2 and 3, as amended (see
Table 4-1), thus a full Scoping and EIA process must be undertaken in order for the Department of
Mineral Resources (DMR) to consider the application in terms of NEMA and make a decision as to
whether to grant or refuse Environmental Authorisation. Where applicable, the listed activities described in
Table 4-1 have been updated to incorporate the amendments included in GN No. R.327, R. 325, and R.324 of 7
April 2017.
Table 4-1: List of activities/infrastructure associated with the proposed project
NAME OF ACTIVITY
APPROXIMATE AERIAL EXTENT OF THE ACTIVITY
LISTED ACTIVITY NUMBER AND LISTING NOTICE, AS AMENDED
Construction of proposed access road to the quarry site.
“The development of -
(ii) infrastructure or structures with a physical footprint of 100 square
metres or more; where such development occurs -
(a) within a watercourse…”
Greater than
100 m2
GNR 983 (Activity 12
of Listing Notice 1)
“The development of a road wider than 4 metres with a reserve
less than 13.5 metres:
(a) In Eastern Cape:
ii. Within critical biodiversity areas identified in bioregional
plans… ”
Approximately
0.4 ha
GNR 985 (Activity 4 of
Listing Notice 3)
“The development of -
(ii) infrastructure or structures with a physical footprint of 10 square
metres or more;
where such development occurs -
(a) within a watercourse…
(a) In Eastern Cape:
i. Outside urban areas, in:
(ff) Critical biodiversity areas or ecosystem service
areas as identified in systematic biodiversity
plans adopted by the competent authority or in
bioregional plans… ”
Greater than
100 m2
GNR 985 (Activity 14
of Listing Notice 3)
Fuel storage.
“The development of facilities or infrastructure, for the storage, or
for the storage and handling, of a dangerous good, where such
storage occurs in containers with a combined capacity of 80 cubic
metres or more but not exceeding 500 cubic metres.”
Approximately 2 ha
GNR 983 (Activity 14
of Listing Notice 1)
“The development of facilities or infrastructure for the storage, or
storage and handling of a dangerous good, where such storage
occurs in containers with a combined capacity of 30 but not
exceeding 80 cubic metres:
(a) In Eastern Cape:
i. Outside urban areas, in:
(ee) Critical biodiversity areas as identified in systematic
GNR 985 (Activity 10
of Listing Notice 3)
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NAME OF ACTIVITY
APPROXIMATE AERIAL EXTENT OF THE ACTIVITY
LISTED ACTIVITY NUMBER AND LISTING NOTICE, AS AMENDED
biodiversity plans adopted by the competent authority or
in bioregional plans;
(ii) Areas on the watercourse side of the development
setback line or within 100 metres from the edge of a
watercourse where no such setback line has been
determined…”
Establishment of the contractor’s camp and stockpiles.
“The infilling or depositing of any material of more than 10 cubic
metres into, or the dredging, excavation, removal or moving of soil,
sand, shells, shell grit, pebbles or rock of more than 10 cubic metres
from -
(i) a watercourse…”
Approximately 2 ha GNR 983 (Activity 19
of Listing Notice 1)
Site clearance for the establishment of the proposed quarry
and associated infrastructure.
“The clearance of an area of 20 hectares or more of indigenous
vegetation…” 50 ha
GNR 983 (Activity 15
of Listing Notice 2)
“The clearance of an area of 300 square metres or more of
indigenous vegetation…
(a) In Eastern Cape:
ii. Within critical biodiversity areas identified in bioregional
plans… ”
GNR 985 (Activity 12
of Listing Notice 3)
Operation of the proposed quarry.
“Any activity including the operation of that activity which requires a
mining right as contemplated in Section 22 of the Mineral and
Petroleum Resources Development Act, 2002 (No. 28 of 2002),
including –
(a) associated infrastructure, structures and earthworks, directly related
to the extraction of a mineral resource; or
(b) the primary processing of a mineral resource including winning,
extraction, classifying, concentrating, crushing, screening or
washing;…”
50 ha GNR 984 (Activity 17
Listing Notice 2)
Decommissioning of the mining activities following the
completion of mine operations.
“The decommissioning of any activity requiring -
(i) a closure certificate in terms of section 43 of the Mineral and
Petroleum Resources Development Act, 2002 (No. 28 of
2002); or
(ii) a …mining right… where the throughput of the activity has
reduced by 90% or more over a period of 5 years excluding
where the competent authority has in writing agreed that such
reduction in throughput does not constitute closure.”
50 ha GNR 983 (Activity 22
of Listing Notice 1)
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4.2. DESCRIPTION OF THE ACTIVITIES TO BE UNDERTAKEN Describe methodology or technology to be employed, including the type of commodity to be prospected/mined and for a
linear activity, a description of the route of the activity. Including associated structures and infrastructure.
4.2.1. PROJECT OVERVIEW
As noted above, SANRAL is proposing to establish a quarry to provide the necessary construction
materials for the Mthentu and Msikaba river bridges and other works on the N2 Wild Coast Toll Highway.
The proposed project would entail the establishment of a quarry, various associated stockpiles, a
contractor’s camp and an access road (see Figure 4-1). The total footprint of the area to be developed is
anticipated to be approximately 50 ha, with the proposed quarry being about 25 ha in extent.
The following key facilities associated with the contractor’s camp are currently planned:
• Offices:
• Ablution facilities;
• Workshop;
• Stores;
• Fuel storage;
• Concrete batching; and;
• Crushing and processing plant.
In addition to the required road within the confines of the quarry site, the proposed access road would link
the quarry to the Holy Cross – Mkambati road situated on the south-eastern boundary of the site.
4.2.2. QUARRY LAYOUT AND DEVELOPMENT
The proposed quarry could be either operated by a single operator or two operators simultaneously, thus
the site layout has been designed to make provision for two separate quarrying areas (Primary Quarry
and Secondary Quarry) that could be worked independently of each other. In the scenario that two
operators are involved, the Primary Quarry area would be worked by one operator along the east-west
face and the second operator would independently work the Secondary Quarry along the south-north
face.
The excavated material from each quarry area would then be processed by the crushing plant located on
the site. The processed material would be stockpiled and then loaded onto haul vehicles for transport to
the bridge construction and other sites. Material that is not suitable for use in the construction of the
bridges or other works would be stockpiled separately for use in the reshaping of the site during
rehabilitation. Where two operators are involved at the site, each operator would be responsible for the
rehabilitation of their respective operational areas (i.e. the separate Primary and Secondary quarry areas,
respectively), as well as their portion of the overall site.
Vegetation would be cleared from the site as the quarry is developed, with any seed-bearing material to
be kept separate for use during rehabilitation or preferably mulched into the topsoil. Topsoil would, where
possible, be stripped to an appropriate depth and stockpiled separately from other soil layers in piles not
exceeding 2 m in height.
To minimise any impacts on the surrounding land, the extent of the area disturbed during the operations
would be limited as far as possible. In this regard, the quarry and associated activities and infrastructure
would be carefully planned to ensure that the footprint is kept to a minimum and remains within the
confines of the site.
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Figure 4-1: Site plan of the proposed quarry.
CRUSHING PLANT
PRIMARY QUARRY
PRIMARY STOCKPILE
AREA
CONTRACTOR
CAMP
SECONDARY QUARRY
SECONDARY STOCKPILE
BACKUP
STOCKPILE
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4.2.3. WASTE MANAGEMENT
Domestic waste generated during the course of the quarry operations would be collected and stored in
suitable receptacles on-site for collection and disposal at an appropriately licensed municipal waste site
or acceptable disposal facility.
4.2.4. WATER MANAGEMENT
It is anticipated that water would be required for dust suppression (on stockpiles and the access road)
and ancillary activities associated with the quarry operations (e.g. washing of vehicles and equipment).
The proposed source(s) and anticipated volumes required for the proposed project are not known at this
stage. The Contractor(s) to be appointed for the operation of the quarry would be responsible for
determining suitable water sources and obtaining any permits, licence and/or authorisations which may
also be applicable for the abstraction of water from these sources, as appropriate.
4.2.5. TRANSPORT
As mentioned above, it is proposed that an access road would be established to link the proposed quarry
site with the Holy Cross - Mkambati Road. The proposed access road would cross a watercourse. The
project engineer has recommended that the proposed water crossing be a low-level river crossing
structure comprising five box culverts and positioned at the centre of the river. It was further
recommended that the road section located to the east of the river crossing be surfaced with concrete,
while the road section to the west of the river could be a gravel surface. The proposed access road would
facilitate the transport of material by truck from the site to the bridge construction and other areas.
5. POLICY AND LEGISLATIVE CONTEXT
An overview of the key legislative requirements applicable to the proposed project is provided below.
5.1. LEGISLATIVE REQUIREMENTS
5.1.1. OVERVIEW OF THE “ONE ENVIRONMENTAL SYSTEM”
The “One Environmental System” commenced on 8 December 2014, removing the environmental
regulation of prospecting, mining, exploration and production and related activities from the Mineral and
Petroleum Resources Development Act, 2002 (No. 28 of 2002) (MPRDA) and transferring it to NEMA.
Under the “One Environmental System”, the Minister of Mineral Resources (or delegated authority) is the
competent authority responsible for issuing Environmental Authorisations in terms of NEMA for mining
and petroleum related activities. The Minister of Environmental Affairs, however, remains the appeal
authority for these authorisations.
5.1.2. MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA)
In terms of the MPRDA, a Mining Right must be obtained prior to the commencement of any mining
activities.
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A requirement for obtaining a Mining Right is that an applicant must submit an application in terms of
Section 22(1) of the MPRDA to the Regional Manager, who must accept the application within 14 days if,
inter alia, no other person holds a Prospecting Right, Mining Right, Mining Permit or Retention Permit for
the same mineral and land. If the application for a Mining Right is accepted, the Regional Manager must
request that the applicant comply with Chapter 5 of NEMA with regards to consultation and reporting (see
Section 5.1.3 below).
It is noted that in terms of Section 106 of the MPRDA, SANRAL is exempted from applying for a Mining
Right to develop a quarry for the purposes of sourcing road building material. However, SANRAL is still
required to obtain Environmental Authorisation in terms of NEMA. In this regard, SANRAL lodged an
Application for Environmental Authorisation with the DMR on 5 September 2016. DMR accepted the
application on 10 October 2016 (see Appendix 2).
5.1.3. NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (NEMA)
Section 2 of NEMA sets out a range of environmental principles that are to be applied by all organs of
state when taking decisions that significantly affect the environment. Included amongst the key principles
is that all development must be socially, economically and environmentally sustainable and that
environmental management must place people and their needs at the forefront of its concern, and serve
their physical, psychological, developmental, cultural and social interests equitably. NEMA also provides
for the participation of Interested and Affected Parties (I&APs) and stipulates that decisions must take into
account the interests, needs and values of all I&APs.
Chapter 5 of NEMA outlines the general objectives and implementation of Integrated Environmental
Management (IEM), which provides a framework for the integration of environmental issues into the
planning, design, decision-making and implementation of plans and development proposals. Section 24
provides a framework for granting of Environmental Authorisations. In order to give effect to the general
objectives of IEM, the potential impacts on the environment of listed activities must be considered,
investigated, assessed and reported on to the competent authority. Section 24(4) provides the minimum
requirements for procedures for the investigation, assessment and communication of the potential impact
of activities. A summary of the EIA Regulations 2014, as amended, and an outline of the identified listed
activities which are triggered in terms of these regulations are provided in Section 4.1 above.
5.1.4. NATIONAL WATER ACT, 1998 (NWA)
The National Water Act, 1998 (No. 36 of 1998) (NWA) provides a legal framework for the effective and
sustainable management of water resources4 in South Africa. It serves to protect, use, develop,
conserve, manage and control water resources as a whole, promoting the integrated management of
water resources with the participation of all stakeholders. In terms of this Act, all water resources are the
property of the State and the Scoping and EIA process is used as a fundamental management tool.
A Water Use Licence is required for any new water use that is not listed in Schedule 1 or that is not
covered by a General Authorisation. Water uses that may require Water Use Licensing or General
Authorisation are listed in Table 5-1. A Water Use Licence Application (WULA) would need to be
submitted to the Department of Water and Sanitation (DWS) Eastern Cape Regional Office for approval, if
these activities are not considered to be Generally Authorised.
4 A water resource includes a watercourse, surface water, estuary or aquifer, and, where relevant, its bed and banks. A
watercourse means a river or spring; a natural channel in which water flows regularly or intermittently; a wetland, lake or dam, into which or from which water flows; and any collection of water that the Minister may declare to be a watercourse.
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The terrestrial and aquatic ecosystems specialist deems that a WULA for the water use activities
specified in Table 5-1 below, at a minimum, would be required for the proposed quarry as the risk of
altering the characteristics of downstream watercourses may be deemed Moderate (even with
appropriate mitigation) according to the DWS Risk Matrix/Assessment method applied to the project.
In terms of the recent General Authorisation (GA) Regulations (GN No. 509 of 26 August 2016),
published in terms of Section 39 of the NWA for Section 21(c) and/or (i) water use, a number of activities
are Generally Authorised for State Owned Companies (SOC’s) and institutions. These activities are then
subject only to compliance with the conditions of the GA, including “all maintenance of bridges over rivers,
streams and wetlands and the new construction of bridges done according to the SANRAL Drainage
Manual or similar norms and standards”. Thus, it is deemed that SANRAL would not be required to apply
for a WULA for the proposed access road over the KwaDlambu River, as it would be authorised under the
GA, subject to compliance with the necessary conditions.
Furthermore, as mentioned in Section 4.2.4 above, the Contractor(s) to be appointed for the operation of
the quarry would be responsible for determining suitable water sources and obtaining any permits, licence
and/or authorisations which may also be applicable for the abstraction of water from these sources, as
appropriate.
Table 5-1: List of possible water use activities in terms of the NWA.
Water
Use No. Water Use Description
Description of the water use in relation to the proposed
project
21(c) Impeding and diverting the flow of
water in a watercourse
The establishment of the proposed quarry may impact on water
resources within the project site and surrounds. In addition, the
proposed access road would pass through a watercourse
located on the eastern boundary of the site. These project
components may require the impeding of water and / or altering
of the bed and banks of the watercourse. 21(i)
Altering the bed, banks, course or
characteristics of a watercourse
5.1.5. NATIONAL HERITAGE RESOURCES ACT, 1999 (NHRA)
Section 38(1) of the National Heritage Resources Act (NHRA) (No. 25 of 1999) lists development
activities that would require authorisation by the responsible heritage resources authority. The activity
applicable to the proposed project is the following:
“(c) Any development or other activity which will change the character of a site: (i) exceeding
5 000 m2 in extent.”
The NHRA requires that a person who intends to undertake a listed activity must notify the relevant
heritage authority at the very earliest stages of initiating such a development. The relevant heritage
authority would then, in turn, notify the person whether a Heritage Impact Assessment Report should be
submitted. However, according to Section 38(8) of the NHRA, a separate report would not be necessary
if an evaluation of the impact of such development on heritage resources is required in terms of any other
applicable legislation. The decision-making authority should, however, ensure that the heritage evaluation
fulfils the requirements of the NHRA and take into account in its decision-making any comments and
recommendations made by the relevant heritage resources authority.
In terms of Section 34(1) of the Act, no person may, without a permit issued by the responsible heritage
resources authority, alter or demolish any structure or part of a structure which is older than 60 years.
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Also, in terms of Section 35(4) of the Act, no person may, without a permit issued by the responsible
heritage resources authority, destroy, damage, excavate, alter or remove from its original position, or
collect, any archaeological material or object.
Furthermore, some grave sites are associated with existing residences within the proposed quarry site. In
terms of Section 36(3) of the Act, no person may, without a permit issued by the responsible heritage
resources authority, destroy, damage, alter, exhume or remove from its original position or otherwise
disturb any grave or burial ground older than 60 years, which is situated outside a formal cemetery
administered by a local authority. Human remains that are less than 60 years old are subject to provisions
of the Human Tissue Act 1983 (No. 65 of 1983) and any other applicable local regulations.
The specialist heritage study has been undertaken in compliance with the NHRA as required and will be
lodged with the Eastern Cape Provincial Heritage Resources Authority (ECPHRA) as the competent
heritage authority.
5.1.6. NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT, 2004
(NEM:BA)
The National Environmental Management: Biodiversity Act, 2004 (No. 10 of 2004) (NEM:BA) provides for
the management and conservation of South Africa’s biodiversity and the protection of species and
ecosystems that warrant national protection.
NEM:BA regulates the carrying out of restricted activities that may harm listed threatened or protected
species or activities that encourage the spread of alien or invasive species subject to a permit. The list of
restricted activities relate to the keeping, moving, having in possession, importing, exporting and selling of
species. NEM:BA also makes provision for the publication of bioregional plans and the listing of
ecosystems and species that are threatened or in need of protection. Threatened or Protected Species
Regulations (2007), Guidelines for the Determination of Bioregions and the Preparation and Publication of
Bioregional Plans (2009) and a National List of Ecosystems that are Threatened and in Need of
Protection (2011) have been promulgated in terms of NEM:BA.
Within the published bioregional (spatial) plans, terrestrial and aquatic features that are critical for
conserving biodiversity and maintaining ecosystem functioning are indicated as Critical Biodiversity Areas
(CBAs). Bioregional plans thus provide the guidelines for avoiding the loss or degradation of natural
habitat in CBAs with the aim of informing EIA processes and land-use planning (including Environmental
Management Frameworks (EMFs), Spatial Development Frameworks (SDFs), and Integrated
Development Plans (IDPs)). CBAs mapped in terms of the Eastern Cape Biodiversity Conservation Plan
are discussed in Section 8.1.4.
5.2. GUIDELINES AND POLICIES
The guidelines and policies listed in Table 5-2 have been taken into account during the Scoping and EIA
process.
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Table 5-2: Guidelines and policies relevant to the proposed project.
Guideline Governing
body Applicability
Scoping, Integrated Environmental Management,
Information Series 2 (2002) DEA
This guideline was consulted to obtain
guidance on how to implement scoping.
Stakeholder Engagement, Integrated Environmental
Management, Information Series 3 (2002) DEA
These public participation guidelines
were consulted to ensure that an
adequate public participation process
was undertaken. IEM Guideline Series (Guideline 7): Public participation in
the EIA process (2012)
Specialist Studies, Integrated Environmental Management, Information Series 4 (2002)
DEA
This guideline was consulted to ensure
adequate development of terms of
reference for specialist studies.
Impact significance, Integrated Environmental
Management, Information Series 5 (2002) DEA
This guideline was consulted to inform
the assessment of significance of
impacts of the proposed project.
Cumulative Effects Assessment, Integrated
Environmental Management, Information Series 7 (2004) DEA
This guideline was consulted to inform the consideration of potential
cumulative effects of the proposed
project.
Criteria for determining Alternatives in EIA, Integrated
Environmental Management, Information Series 11
(2004)
DEA This guideline was consulted to inform
the consideration of alternatives.
Environmental Management Plans, Integrated
Environmental Management, Information Series 12
(2004)
DEA
This guideline was consulted to ensure
that the Environmental Management
Programme (EMPR) has been
adequately compiled.
IEM Guideline Series (Guideline 9): Guideline on Need
and Desirability (2014) DEA
This guideline was consulted to inform
the need and desirability aspects of the proposed project.
6. NEED AND DESIRABILITY OF THE PROPOSED PROJECT Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location
As noted previously, the proposed quarry is required for the sourcing of materials to facilitate the
construction of the Mthentu and Msikaba river bridges and other works associated with the proposed N2
Wild Coast Toll Highway. The rationale for the N2 Wild Coast Toll Highway project is to provide an
improved, shorter and safer road link between the Eastern Cape/Western Cape and KwaZulu-Natal and
is considered of strategic importance to the region and the country as a whole. Given that large volumes
of construction materials would be required for the project, the development of a local source for this
material is considered to be highly beneficial.
It is deemed that obtaining the required quality of material from commercial sources would be expensive,
as the closest commercial sources are located a considerable distance (up to 200 km away) from the
bridge construction areas. Substantial cost savings would accrue to the project by eliminating the cost of
transportation of large volumes of material from existing commercial sources. Added advantages for the
establishment of a local source of material include avoiding negative impacts on road safety of the
surrounding road network by the presence of haul vehicles and reducing air pollution emissions from haul
trucks by reducing haul distances.
On completion of the N2 Wild Coast Highway construction, it is possible that the local community may
take ownership of the quarry site. The final use of the quarry site, and the related closure objectives, will
be determined in consultation with the local communities via the SANRAL-appointed land management
specialist.
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7. MOTIVATION FOR THE PREFERRED DEVELOPMENT
FOOTPRINT WITHIN THE APPROVED SITE INCLUDING THE
PROCESS FOLLOWED TO DEFINE THE PREFERRED
DEVELOPMENT ALTERNATIVES
7.1. DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED
7.1.1. PROPERTY ON WHICH OR LOCATION WHERE IT IS PROPOSED TO
UNDERTAKE THE ACTIVITY
According to the design engineer, the primary rationale behind the selection of the preferred site
alternative relate to the area available to establish the proposed quarry, topography, level of existing
development, and availability and quantity of suitable material. The locality of the identified alternative
quarry sites which were investigated by the design engineer are illustrated in Figure 7-1 overleaf.
The preferred site alternative is considered to be sufficiently large to allow for the stockpiling of material,
as well as the establishment of the contractor’s camp and placement of crushing equipment (previous
experience has shown that for a project of this nature, an area in excess of 40 ha is required). Secondly,
the site has a topography suitable for quarry development and is relatively undeveloped (in comparison to
other potential quarry sites identified). Lastly, the laboratory test results undertaken have indicated that
the Dwyka Formation tillite underlying the site is considered suitable for use as fine and coarse concrete
aggregate. The rationale for the exclusion of other possible alternative sites which were investigated is
provided in Table 7-1.
Table 7-1: Potential alternative quarry sites initially investigated for development (the
preferred site is shaded).
Site Material
Source
Latitude Longitude Suitability
SQ1 Dwyka
Formation
Tillite
31°11'51.06"S 29°49'7.83"E This site is considered to be the most suitable for the
following reasons:
• The site is relatively undeveloped;
• There is a large enough area to undertake the
proposed quarry operations;
• There is sufficient quantities of unweathered
rock available;
• The site is relatively close to both bridge
construction sites (within 15km) and other
works.
SQ2 Dwyka
Formation
Tillite
31°12'7.36"S 29°47'31.91"E While the site is possibly suitable (given it is located
close to both bridge construction sites and suitable
material is present) it is currently not preferred due
to:
• Insufficient space to incorporate all activities
associated with the quarry operations; and
• The topography of the site would make
quarrying difficult and costly.
However, it is possible that SANRAL may wish to
establish an additional quarry at this site in the
future. A separate environmental authorisation
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Site Material
Source
Latitude Longitude Suitability
process will then be undertaken in this regard.
NQ6 Dwyka
Formation
Tillite
31° 4'22.59"S 29°57'0.32"E Establishing a quarry on this site is not considered
feasible due to:
• Space constrains; and
• Close proximity to a school.
Flagstaff Karoo
Dolerite
31° 4'9.83"S 29°32'56.11"E Establishing a quarry on this site is not considered
possible due to:
• The large haul distance to the bridge
construction sites (greater than 50 km); and
• An Eskom substation has recently been
constructed on the site.
Holy Cross Karoo
Dolerite
31° 7'22.47"S 29°34'26.45"E Establishing a quarry on this site is not considered
possible due to:
• The large haul distance to the bridge
construction sites (greater than 50 km); and
• An extensive layer (30 m deep) of poor quality
overburden overlaying the required source
materials.
Mtonjeni Msikaba
Formation
Sandstone
31°13'15.42"S 29°51'35.17"E The availability of suitable materials has not yet been
confirmed at this site. Thus, the site cannot be
considered at this stage.
Mtentu
South
Approach
Msikaba
Formation
Sandstone
31°11'18.67"S 29°55'43.85"E Establishing a quarry on this site is not considered
possible as the quality of the source material is sub-
standard.
Mtentu North
Approach
Msikaba
Formation
Sandstone
31° 9'57.51"S 29°56'7.58"E Establishing a quarry on this site is not considered
possible as the quality of the source material is sub-
standard.
Msikaba
South
Approach
Msikaba
Formation
Sandstone
31°17'49.64"S 29°47'24.30"E Establishing a quarry on this site is not considered
possible as the quality of the source material is sub-
standard and not available in sufficient quantities.
Msikaba
North
Approach
Msikaba
Formation
Sandstone
31°17'18.08"S 29°48'4.60"E Establishing a quarry on this site is not considered
possible as the quality of the source material is sub-
standard.
Mahana Msikaba
Formation
Sandstone
31° 9'29.55"S 30° 1'32.15"E Establishing a quarry on this site is not considered
possible as the quality of the source material is sub-
standard.
Makwateni Msikaba
Formation
Sandstone
31° 7'47.62"S 29°59'34.91"E Establishing a quarry on this site is not considered
possible as the quality of the source material is sub-
standard.
Mpetsheni Karoo
Dolerite
31° 0'20.30"S 29°48'15.82"E Establishing a quarry on this site is not considered
possible due to:
• The presence of excessive overburden; and
• The quantity of available material is inadequate.
Telawayeka Dwyka
Formation
Tillite
31°18'9.49"S 29°44'44.71"E Establishing a quarry on this site is not considered
possible as the local communities denied access to
the site for physical testing.
Mtontsasa Karoo
Dolerite
31°13'32.40"S 29°41'24.05"E The availability of suitable materials has not yet been
confirmed at this site. Thus, the site cannot be
considered at this stage.
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Figure 7-1: Google Earth Image of the identified alternative sites for the proposed quarry (the preferred alternative is shaded red).
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7.1.2. TYPE OF ACTIVITY TO BE UNDERTAKEN
No alternatives pertaining to the type of activity to be undertaken have been considered for the proposed
project.
7.1.3. DESIGN OR LAYOUT OF THE ACTIVITY
The preferred layout of the proposed quarry site has been informed by the outcomes of the public
participation process and site sensitivity investigations undertaken as part of the Scoping Process.
Based on the original layout presented in the Scoping Report, the terrestrial and freshwater ecosystems
specialist recommended that the quarry layout should be revised in order to take into account the location
and extent of the proposed aquatic buffer zones associated with wetlands and riparian areas located on
the site. The specialist recommended a variable aquatic buffer zone width of between 18 m and 40 m,
based on the sensitivity of each receiving watercourse. The recommendations of the specialist have been
taken into consideration by the project engineer and the layout of the proposed quarry has been revised
accordingly (refer to Figure 4-1).
With respect to the proposed access road crossing over the KwaDlambu River, three possible
configurations of the low-level crossing structure were designed by the project engineer:
• a 3-cell structure with each cell measuring 3.6m wide x 3.6m high and a total length of 10.8 m;
• a 4-cell structure with each cell measuring 3.0m wide x 3.0m high and a total length of 12 m; and
• a 5-cell structure with each cell measuring 5.0m wide x 2.0m high and a total length of 25 m.
The project engineer has indicated that the 3-cell and 4-cell structures would require large quantities of fill
and excavation at the approach roads leading to the river. However, the 5-cell structure can be designed
as a culvert under fill or as a low-level river crossing and would therefore require the least amount of cut
and fill at the approach road sites.
The terrestrial and freshwater ecosystems specialist noted that the 3-cell structure would be narrower
than the active channel of the river. Thus, it is anticipated that this structure would concentrate flows and
increased flow velocities within the river channel. This may result in scouring and possible long-term
channel incision. Furthermore, the 3-cell structure would require infilling of the river to elevate the road
infrastructure well above the high-water mark. Similar impacts are anticipated from the 4-cell structure,
albeit of less intensity. As the 5-cell structure would span the entire width of the active channel, it would
maintain spread flows, channel width and limit the risk of scouring below the structure. In light of the
engineering and environmental suitability highlighted above, the 5-cell structure is the preferred road
crossing structure for the proposed project.
7.1.4. TECHNOLOGY TO BE USED IN THE ACTIVITY
No other alternatives pertaining to alternative technologies to be used in the operation of the proposed
quarry have been considered for the proposed project.
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7.1.5. OPERATIONAL ASPECTS OF THE ACTIVITY
As noted in Section 4.2.2 above, the proposed quarry could be either operated by a single operator or two
operators simultaneously. Accordingly, the site layout has been designed to make provision for two
separate quarrying areas (Primary Quarry and Secondary Quarry) that could be worked independently of
each other. The nature of the potential impacts associated with the proposed project are not anticipated
to be materially different should the quarry be operated by a single operator or by two operators
simultaneously. Where two operators are involved at the site, each operator would be responsible for the
rehabilitation of the area they operated in (i.e. the separate Primary and Secondary quarry areas), as well
as their portion of the overall site.
7.1.6. OPTION OF NOT IMPLEMENTING THE ACTIVITY
The option of not implementing the activity is referred to as the No-Go alternative. In this scenario, the
potential impacts assessed in Section 8.2 would not materialise. The implications of the No-Go alternative
would also include, amongst others, the following:
• The direct economic benefits associated with the quarry operation for sourcing of material for the
construction of the bridges and other works associated with the N2 Wild Coast Toll Highway would
be lost. Furthermore, any possible indirect economic benefits of the quarry operation (related to
the procurement of goods and services and the spending power of employees) would also be lost;
and
• In the event that construction materials would have to be obtained from commercial sources, there
would be other potential negative impacts associated with the movement of heavy haul vehicles
over large distances on the surrounding provincial and national road network (e.g. damage to roads
from heavy loads, road safety and air pollution).
The No-Go alternative is assessed in detail in Section 8 of the report.
7.2. DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED
Describe the process undertaken to consult interested and affected parties including public meetings and one on one
consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public
meetings. Information to be provided to affected parties must include sufficient detail of the intended operation to enable
them to assess what impact the activities will have on them or on the use of their land.
7.2.1. SCOPING PHASE
The Scoping Phase (including the compilation of the Scoping Report) complied with the requirements of
NEMA and the EIA Regulations 2014, as set out in GN No. R982 (as amended). This involved a process of
notifying I&APs of the proposed project and EIA process in order to ensure that all potential key
environmental impacts, including those requiring further investigation, were identified.
The Scoping Phase also included a pre-application public participation process. Although this is not a
legislated requirement of the EIA Regulations 2014, it provided an opportunity to notify I&APs of the
proposed project and to raise any initial issues or concerns regarding the proposed quarrying activities.
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The steps / tasks undertaken during the Scoping Phase are summarised in Box 7.1.
The Scoping Report was accepted by DMR on 14 December 2016 (see Appendix 2). DMR’s acceptance
of the Scoping Report stated that the next phase of the EIA may proceed as outlined in the Plan of Study
for EIA, which was appended to the Scoping Report.
Box: 7.1: Tasks undertaken during the Scoping Phase.
The Scoping Phase public participation process involved the following:
• An initial consultation meeting was held with Chief Khanyayo on 25 July 2016 to provide preliminary
background information regarding the proposed project and to confirm the preferred approach to be followed
for the public participation process going forward.
• Following the compilation of the Scoping Report, a formal notification letter was distributed to potential
Interested and Affected Parties (I&APs), a notice was erected on site and media advertisements were placed
in the Uvo Lwethu (previously known as The Fever) and The Daily Dispatch newspapers on 8 September
2016.
• The purpose of the notification letter, site notice, and newspaper advertisements was to convey information
on the proposed project, to invite I&APs to register on the project database and provide notice that the
Scoping Report was released for a 30-day review and comment period from 5 September to 6 October 2016.
Copies of the report were made available at the following locations:
o Flagstaff Public Library, Clubhouse, Flagstaff;
o The residence of Chief Khanyayo, Khanyayo Village;
o Cape Town offices of SLR; and
o On the SLR website (www.ccaenvironmental.co.za).
• A public meeting was held during the above-mentioned registration and comment period at the residence of
Chief Khanyayo, Khanyayo Village on 13 September 2016 at 11h00.
• A total of five written submissions were received during the above-mentioned review and comment period.
The submissions were collated and responded to in the Comments and Responses Report and attached to
the final Scoping Report which was submitted to the DMR for consideration and acceptance on 26
September 2016. A summary of the issues raised by I&APs is provided in Section 7.2.3.
• The Scoping Report was accepted by DMR on 14 December 2016 (see Appendix 2).
7.2.2. EIA PHASE
The Draft EIR and EMPR was distributed for a 30-day comment period from 17 March to 19 April 2017 (taking into
account the three public holidays during this period) in order to provide I&APs with an opportunity to comment on
any aspect of the proposed project and the findings of the EIA process. The public participation tasks undertaken
during this phase are summarised in Box 7.2 and all supporting information is presented in appendices to this report
(Appendix 3.1 to 3.4).
Box: 7.2: Tasks undertaken during the EIA Phase.
1. Draft EIR and EMPR availability
Copies of the Draft EIR and EMPR were made available at the following locations for the duration of the review and
comment period (17 March to 19 April 2017):
• Flagstaff Public Library, Clubhouse, Flagstaff;
• The residence of Chief Khanyayo, Khanyayo Village;
• Cape Town offices of SLR; and
• On the SLR website (www.slrconsulting.com).
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Box: 7.2: Tasks undertaken during the EIA Phase (continued).
2. I&AP notification
A notification of the availability of the Draft EIR and EMPR for review and comment was sent to all I&APs registered on the
project database via sms or email. The notification also informed them of where the report could be accessed and reviewed.
Copies of the report were also sent directly to the following key authorities (see Appendix 3.2 for letters and proof of
distribution):
No. Organisation Contact Person
1. Department of Agriculture, Forestry and Fisheries Ms G. Sgwabe
2. Department of Environmental Affairs: Biodiversity and Conservation Directorate Mr S. Tshitwamulomoni
3. Eastern Cape Department of Economic Development and Environmental Affairs Regional Director
4. Department of Rural Development and Land Reform Ms N. Tamba
5. Department of Roads and Public Works Mr K. Tyali
6. Department of Water and Sanitation Ms P. Makhanya
7. Eastern Cape Provincial Heritage Resources Authority Ms A. Maxonga
8. Eastern Cape Parks and Tourism Agency Ms B. Geach
9. Ngquza Hill Local Municipality Mr M. Fihlani
10. OR Tambo District Municipality Mr O. Hlazo
3. Comments received on the Draft EIR and EMPR
One verbal and two written submissions were received during the review and comment period. Comments
received from I&APs on the Draft EIR and EMPR have been collated into a Comments and Responses Report
and appended to this final report. An updated summary of the issues raised by the I&APs is provided in Section
7.2.3 overleaf (this includes correspondence from the Department of Water and Sanitation which was received
following the submission of the Final Scoping Report and prior to the release of the Draft EIR and EMPR for
comment).
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7.2.3. SUMMARY OF ISSUES RAISED BY I&APS
Interested and Affected Parties
Date Received Issues raised EAPs response to issues
Section of
report
Other Affected Parties
Mxolisi Magadikiti 13 September
2016
Construction vehicles driving past pedestrians walking alongside
the roads at high speed. This is dangerous and causes dust which
affects people’s eyes and health.
Measures to regulate vehicle usage on site, and in the surrounding
area, have been included in the Environmental Management
Programme (EMP) for the construction and operational phases. All
contractors appointed by SANRAL for the proposed project will be
required to comply with the recommendations of the EMP during the
construction and operational phases.
Appendix 6
Sonwabile Jama
Chief Khanyayo
Khanyayo
Traditional Council
13 September
2016
The Khanyaho Traditional Council is satisfied with the
environmental assessment and consultation process undertaken
thus far and have read, reviewed and understood the proposed
project description and the implications thereof for our community.
We hereby extend our support through this letter for the project
and officially indicate that we have no objection to the project in
principle. We also confirm that our no-objection applies to all
projects or activities to be implemented within the scope of the
project subject to certain conditions.
The letter of no-objection has been noted and acknowledged.
N/A
Mxolisi Magadikiti 13 September
2016
I would like to know what criteria SANRAL will be using to uplift the
local community from this project.
An assessment of the potential negative and positive impacts
associated with the proposed project, as appropriate, has been
provided in Section 8.2 of the EIR.
It is anticipated that appropriate targets for employment and training
of local persons from the local community would be incorporated into
the conditions of the contract to operate the proposed quarry.
Section 8.2
Simphiwe Kaqa 13 September
2016
I am not from the Khanyayo village, but I would like to see this
community uplifted socially and economically.
Mxolisi Magadikiti 13 September 2016
We would like to request that SANRAL take the youth and train them so that they are not excluded from the job opportunities
because of lack of experience and qualifications.
Dlamini Mbikwa 13 September
2016
The people are saying this project is only for the benefit of the
residents of the Khanyayo village but this meeting was advertised in the newspaper so anyone should be allowed to benefit from this project.
Mam’ Mthembu 13 September 2016
Thank you for clarifying that even though people will not be getting jobs today, there are such plans in the future for this community. But please do not delay!
These comments are noted.
N/A Simlindiwe 13 September
2016 We understand that this is the initial stage of this project, however please do not delay. Let us open that quarry because we need jobs.
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Date Received Issues raised EAPs response to issues
Section of
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Xolisile Skhonza 13 September 2016
We have heard that some homes will be relocated. We would like to get a clear understanding of which homes will be moved.
SANRAL has appointed a land management specialist which will undertake a separate process with the traditional council and
community in terms of the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996) and will liaise directly with the Department of Rural Development and Land Reform, as required in
this regard.
N/A
Sebitso Thoka, Department of Rural
Development and Land Reform
8 September 2016
Please note that the proposed development is governed by the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of
1996), and one of the apex requirements is that you should make an application to the Department of Rural Development and Land Reform (DRDLR) requesting disposal of land tenure rights since
the Minister; Hon G Nkwinti is the custodian. Such projects should benefit the land rights holders and the Government at large in fighting the triple challenges facing by our communities i.e.
unemployment, inequality and poverty. Having said that, please find the attached documents to familiarise yourself with and the requirements thereof. And please note that there is no prescribed
application form to be used, just draft a normal application on your company’s letterhead.
Sonwabile Jama
Chief Khanyayo
Khanyayo Traditional
Council
16 March 2017 The traditional council and the people of Khanyayo village would like to
make it clear that no construction shall commence before the following
conditions have been met:
1. People living on the proposed quarry area are to be relocated and
new houses are to be built for the affected families (dates of these
activities to be supplied to the traditional council)
2. Graves are to be relocated prior to any construction activities (dates
of these activities to be supplied to the traditional council)
3. A fence surrounding the quarry area is to be constructed as soon as
possible (dates to be supplied to the traditional council)
These comments are noted.
N/A
Charmaine Jasmin 19 April 2017 I would like to raise my OBJECTION in the manner in which SANRAL
has conducted itself with regard to the quarry. Whilst we have no
objection to the highway being built, we object to the manner in which
SANRAL started this EIA process from the onset!
This objection is noted.
N/A
Last year’s meeting (where SANRAL presented to the community a
notice for an EIA for the Quarry) we were lead to believe that it was a
meeting to let the community know what opportunities were available to
them, and not one to discuss the matter of the quarry! Not having been
aware that the quarry was going to be discussed, deprived us of the
opportunity to raise pertinent questions.
The purpose of the public meeting (held at the residence of Chief
Khanyayo, Khanyayo Village on 13 September 2016 at 11h00) during the
Scoping Phase was to, amongst others, convey information on the proposed
project, invite I&APs to register on the project database and provide notice
that the Scoping Report was released for a 30-day review and comment
period. The public meeting provided an additional opportunity for I&APs to
raise any queries or concerns they may have had regarding the proposed
project. I&APs were also invited to provide written submissions during the
review and comment periods for the Draft Scoping and Draft EIR and
EMPR reports.
Section 7.2.1
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Charmaine Jasmin 19 April 2017 What are SANRAL's plans around the management, ownership and
operations with regard to the quarry? Whether local business people
would be given an opportunity to participate in these ventures and be
empowered by the skills transfer that these opportunities bring, so once
the road is constructed, the quarry can continue operating?
Currently the access roads are being constructed, and we are of the
opinion that the allocation of work seems to be already predetermined!
It is anticipated that either one or two contractors would be appointed to
operate and manage the proposed quarry operations. The appropriate targets
for employment and training of local persons from the local community
would be incorporated into the conditions of the contract to operate the
proposed quarry. On completion of the N2 Wild Coast Toll Highway
construction, it is possible that the local community may take ownership of
the quarry site. The final use of the quarry site, and the related closure
objectives, will be determined in consultation with the local communities
via the SANRAL-appointed land management specialist.
Section 4.2.1
of EIR and
Section 4 of
the EMPR
Organs of State
M.R. Dinga
Deputy Director
(Acting): Forestry
Regulation and
Support Eastern
Cape
10 October 2016 I think it would have been appropriate to include the National
Forests Act, 1998 (No. 84 of 1998) (NFA) amongst the legislations
to be considered. The inclusion of the NFA in the legislation to be
considered is also supported by the mention of the possible
clearance of an area of 20 hectares or more of indigenous
vegetation. Nevertheless it is hoped that the impact and clearance
mentioned will not affect a natural forest because if that would be
the case, then NFA will have to be considered and be included in
the legislations that have been considered when the report was
being compiled. Lastly an authorisation from DAFF would have to
be applied for, in the normal procedure if the flora under
consideration is a natural forest.
The findings of the baseline specialist aquatic and terrestrial
ecosystems investigation indicated that there are no natural forest
areas located within the study area. Thus, it is deemed that no
authorisation from DAFF needs to be applied for.
Section 8.1
Mr Lonwabo Mini
Department of Water
and Sanitation
Mzimvubu to
Tsitsikamma Proto-
CMA
Water Use Catchment
Regulation
31 October 2016 The Department of Water and Sanitation has no objections to the
proposed activity provided the following are adhered to that:
1. Water abstraction from water courses or boreholes and Section 21
water uses need to be authorized by this Department,
3. All activities carried out should comply with the requirements of the
National Water Act (Act 36 of 1998) and other related legislation.
4. No prospecting mining activity should occur in close proximity to a
water resource or within the 1:100 year flood line.
The necessary water use authorisation requirements applicable to the
project are discussed in Section 5.1.4 above.
Section 5.1.4
5. Confine any polluted water systems away from the clean water
systems. Collect water arising within any dirty area, including water
seeping from mining operations, outcrops or any other activity, into
a dirty water system.
6. Design, construct, maintain and operate any dirty water system at the
mine or activity so that it is not likely to spill into any clean water
system more than once in 50 years.
7. Silt fences should be used to prevent soil eroding from nearby
It has been recommended that a detailed Stormwater Management Plan be
developed for the project. The Stormwater Management Plan must describe
how the design measures of surface and near-surface water management
facilities will be designed, constructed and operated so that contaminated
water is kept separate from clean water run-off through a system of berms,
channels, trenches, flood and erosion protection measures.
Section
8.2.1.3
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mining activities reaching watercourses.
5. Design, Construct, Maintain and Operate any dam or tailings dam
that forms part of a dirty water system to have a minimum freeboard
of 0.8 metres above full supply level.
The proposed project will not entail the construction of any dams. N/A
7. Solid waste should be disposed of at a licensed waste disposal site.
8. All procedures and equipment used must be in accordance with the
Occupational Health and Safety Act & Regulations of South Africa.
9. The developer must exercise suitable precautions with the storage,
handling and transport of all materials that could adversely affect the
environment. Such precautions may include the use of bund walls. If
pollution of any surface or groundwater occurs, it shall immediately
be reported to this Department and appropriate mitigation measures
must be employed.
10. Storage of material, chemicals, fuels, etc. must not pose a risk to the
surrounding environment and this includes surface and groundwater.
Such storage areas must be located outside the 1:100 year floodline
of any watercourse and must be fenced to prevent unauthorised
access into the area.
11. Temporary bund walls must also be constructed around chemical or
fuel storage areas to contain possible spillages. The floor and wall of
the bund area must be impervious to prevent infiltration of any
spilled/leaked fuel, oil or hazardous substance into the soil.
12. Within 6 months of the storage tanks ceasing to be functional for the
purpose for which they have been authorised, they must be removed
and the site including all associated infrastructure must be
rehabilitated.
13. Notwithstanding the above, the responsibility rests with the
applicant to identify any sources or potential sources of pollution
from his undertaking and to take appropriate measures to prevent
any pollution of the environment.
15. Chemical toilets should be:
o Placed outside areas susceptible to flooding.
o Maintained in a sound, clean sanitary condition free of insects,
overflowing, leakages and other harmful conditions.
o Not create public health hazard or nuisance.
o Waste water from chemical toilets should not be discharged to a
water resource. If not going to be used for a long time, empty
and keep clean.
The recommended environmental management measures to be
implemented during the construction and operational phases of the
proposed project are provided in the EMP (see Appendix 6).
Appendix 6
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S. Songca
Eastern Cape
Department of
Economic
Development,
Environmental Affairs
and Tourism
19 April 2017 The KwaDlambu is a very important tributary of the Msikaba River. It is
of note that there are various plant endemics which are found on the
banks of the KwaDlambu. Therefore, one must make sure that such plants
are not disturbed by quarry mining operations.
The aquatic and terrestrial ecology specialist has recommended that a
protected plant survey be undertaken in order to confirm the presence and
abundance of threatened and protected plant species. The survey would be
used to develop a detailed protected plant rescue and translocation protocol
for any threatened and protected species identified within the project
footprint.
Section
8.2.1.2
Notwithstanding the above, an alternative site suitable for this activity
might be useful.
The primary rationale for the selection of the preferred site alternative relate
to the area available to establish the proposed quarry, topography, level of
existing development, and availability and quantity of suitable material. The
rationale for the exclusion of other possible alternative sites which were
investigated is provided in Table 7 1.
Section 7.1.1
Mitigatory measures for avoiding impact on the wetland environment
must be employed.
The recommended mitigation measures for the identified impacts on
wetlands associated with the construction and operational phases of the
proposed project are provided in the EMP (see Appendix 6).
Appendix 6
It is necessary and important to properly describe anticipated changes
which might occur within the nearby homesteads of 600 m away from the
site as a result of quarry operation and evaluation of conflicts that could
arise during operation.
An assessment of the potential negative and positive impacts associated
with the proposed project, as appropriate, has been provided in Section 8.2
of the EIR. Section 8.2
No mining is allowed within 32m from the banks of the river, stream,
watercourse, wetland or any water body drainage without a permit.
The recommended aquatic buffer zones associated with wetlands and
riparian areas located on the site have been incorporated into the updated
layout plan for the project (refer to Section 71.3). The necessary water use
authorisation requirements applicable to the project are discussed in Section
5.1.4 above.
Sections 5.1.4
and 7.1.3
Soil erosion mitigation measures must be in place to avoid severe soil
erosion.
The recommended mitigation measures for soil-erosion related impacts
associated with the construction and operational phases of the proposed
project are provided in the EMP (see Appendix 6).
Appendix 6
Ngquza Hill Local municipality must be consulted about the proposed
development.
A copy of the Draft EIR and EMPR report was sent directly to the local
municipality.
Section 7.2.2
and
Appendix 3.2
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8. THE ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE
DEVELOPMENT FOOTPRINT ALTERNATIVES The environmental attributes associated with the alternatives described must include socio-economic, social, heritage, cultural, geographical, physical and biological aspects
8.1. BASELINE ENVIRONMENT
This section provides a general description of the key biophysical, cultural/heritage and socio-economic
characteristics of the study area.
8.1.1. CLIMATE
The climate of the broader region is influenced by the semi-permanent Indian high pressure cell that shifts
both in latitude and longitude. The northern part of the Eastern Cape experiences cool sub-tropical
conditions which vary between the coastal and inland environments. The temperatures experienced
inland tend to be more extreme when compared to the milder temperatures and higher rainfall of the
coastal areas. The region is predominantly a summer rainfall area with most rains occurring from October
to March.
8.1.2. TOPOGRAPHY
The topography of the broader region is very rugged and mountainous with deep and steep-sided river
valleys. The proposed quarry site itself is positioned on a hill and is bounded by two watercourses to the
west, south and east of the site perimeter.
8.1.3. GEOLOGY AND SOILS
The geology of the region is characterised by the Cape Super Group rocks that consist of sandstones,
shales and quartzites of Palaeozoic age. These rest unconformably upon older formations and are
followed by the Karoo Super Group rocks. The succession of the Cape Super Group rocks allows the
identification of three groups, namely the Witteberg Group – quartzites and subordinate shales, the
Bokkeveld Group – shales, flagstones and sandstones, and the Table Mountain Group – thick
unfossilised grits with scattered pebbles (CCA, 2009).
The sandstones of the Pondoland region are defined as generally white/sometimes reddish sandstones
stretching north-east from Port St Johns through “Natal” into “Zululand” and are correlated with the Table
Mountain Sandstone of the Cape. A wide terrace belt occurs along the Pondoland coast, stretching into
KwaZulu-Natal. The inland section of beds forms a flat plateau, while in the coastal section the
sandstones dip seawards beneath the Karoo beds, sometimes forming the actual shore. The Natal
Sandstones consist of a number of formations, with the Msikaba Formation being the most southerly,
stretching from Port St Johns to just north of Port Shepstone.
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8.1.4. BIODIVERSITY
8.1.4.1. Vegetation
There are three biomes located within the Ngquza Hill Local Municipality, namely Grassland, Indian
Ocean Coastal and the Savanna Biome. The natural vegetation within the study area is mapped as
Ngongoni Veld, which is considered to be a “Vulnerable” vegetation type in terms of the National List of
Ecosystems that are considered to be threatened and are in need of protection (the ‘National List’)5. The
study area is located within the vicinity of several rural dwellings typical of the area and it is anticipated
that the vegetation has been partially modified by grazing and other activities typically associated with
such settlements in the area.
Critical Biodiversity Areas (CBAs) mapped in terms of the Eastern Cape Biodiversity Conservation Plan
(ECBCP) mapping are presented in Figure 8-1 below. The proposed quarry site is located within an area
identified as terrestrial “Critical Biodiversity Area 2 (CBA)”. In terms of the Conservation Plan, the
preferred land use objective for “CBA 2” areas is to “maintain biodiversity in near natural state with
minimal loss of ecosystem integrity and no transformation of natural habitat should be permitted”.
From fieldwork undertaken by the aquatic and terrestrial ecology specialist, four vegetation communities
were identified within the study area (see Figure 8-2), namely:
• Terrestrial Ngongoni grassland which can be subdivided into:
a. Degraded Primary Grassland; and
b. Secondary Grassland.
• Small and localised areas of scrub, mostly comprised of alien species; and
• Small and localised transformed areas (homesteads and cultivated lands).
The Degraded Primary Grassland community is considered to have modest herbaceous and geophyte
diversity despite being subjected to various anthropogenic impacts. The dominant species is Aristida
junciformis subsp. junciformis (Ngongoni Grass) with other notable species including Moraea elliotii, a
single specimen of a Dierama sp. (not in flower and could only be identified to genus level) and the orchid
Eulophia hians var. hians. Additional specimens of this orchid species, as well as other species are
expected to still appear in the summer months after good rains.
The Secondary Grassland community contain numerous shallow rock exposures where the grass
Microchloa caffra and the bulbs Albuca setosa and Ornithogalum juncifolium were found. A small number
of Aloe maculata plants were also seen near one of the rock outcrops. The rock exposures generally
provide habitat for Brachystelma species, some of which are rare, but if these species are present, they
would only be seen during late summer.
Approximately four (4) specimens of a plant were observed that appeared to resemble Helichrysum
pannosum, which is an endangered species (Raimondo et al., 2009). However, the plants could not be
positively identified. One individual of the uncommon (previously considered Vulnerable but now listed as
Data Deficient) Senecio cf. umgeniensis was also observed.
Small and localised areas of scrub, mostly comprised of alien species were found outside the mapped
extent of grassland areas described above. This vegetation comprised the indigenous pioneer species
Maesa lanceolata and the alien species Acacia mearnsii, Caesalpinia decapetala, and Rubus cuneifolius.
5 Published in terms of Government Notice R.1002 of 9 December 2011.
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Figure 8-1: Critical Biodiversity Areas in the broader study area. The proposed quarry location is indicated as a blue dot (Source: SANBI
Biodiversity GIS, 2016).
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Figure 8-2: Identified vegetation communities within the study area.
The aquatic and terrestrial ecology specialist assessed the Degraded Primary Grassland vegetation to
have a “moderate” ecological sensitivity and importance, while the Secondary Grassland and Alien Scrub
vegetation communities were considered to be “low”. The transformed areas were assessed to be of
“very low” ecological sensitivity and importance.
Using available desktop information, the aquatic and terrestrial ecology specialist identified eight plant
species of conservation concern which were considered to potentially occur within the study area.
Species of conservation concern refer to species of flora (plants) and fauna (animals) that have a high
conservation importance in terms of preserving South Africa's high biological diversity and include
threatened species that have been classified as ‘at high risk of extinction in the wild’. Of the eight species
identified, two were confirmed to be present within the proposed quarry site, namely Hypoxis
hemerocallidea (Declining status) and Senecio umgeniensis (Threatened status), while further verification
is required to confirm the presence of a third species, Helichrysum cf. pannosum (Endangered status),
as the plant was not flowering at the time of the site visit. The remaining species of concern are
considered unlikely to be present on site given the lack of suitable habitat for these species.
8.1.4.2. Fauna
With respect to fauna, it should be noted that the broader region has not been extensively studied outside
of protected areas and is not known to exhibit many unique features. Available information indicates that
within protected areas there is high faunal biodiversity and numerous endemic species. Outside of these
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areas, the fauna is, in general, considered to be impoverished due to large-scale overgrazing and other
human-induced impacts associated with rural settlements.
Various fauna species of conservation concern that could potentially occur within the study area were
identified by the aquatic and terrestrial ecology specialist using desktop information (see Appendix 4.1).
With respect to mammal species, it is noted that the lack of species-specific habitat for most of the
identified species, and the proximity to human activities, greatly reduces the likelihood of their occurrence
at the site. The Cape Clawless Otter and the Reddish-grey Musk Shrew are the only important mammal
species considered likely to occur within the study area.
Three bird species of conservation concern were identified as potentially utilising the grassland and
wetland/riverine habitat at the site and surrounds, namely the African marsh-harrier (Circus ranivorus),
Black Harrier (Circus maurus), and Black-winged Lapwing (Vanellus melanopterus).
Twelve endemic or near-endemic reptile species of conservation concern were considered to be
potentially located within the study area, particularly in the more intact grassland and wetland/riverine
habitats. The site falls within the distributional range of four threatened reptiles, namely the Pondo Dwarf
Chameleon (Endangered), Kentani Dwarf Chameleon (Vulnerable), Kwa-Zulu Natal Black Snake (Near
Threatened) and the Variable Legless Skink (Endangered). From the site visit undertaken by the
specialist, only a single terrapin species was recorded in the KwaDlambu River.
No amphibian species of conservation concern are considered likely to be present at the site or within the
surrounding aquatic habitats due to the lack of suitable habitat provided for key species. Only a few
common stream frogs (such as the Clicking Stream frog) could be identified by the specialist through calls
within the watercourses adjacent to the site.
The aquatic and terrestrial ecology specialist noted that there is no known available information on
invertebrates for the study area to enable the assessment of potential occurrence for invertebrate
species.
8.1.4.3. Aquatic features
There are a number of important rivers in the broader region, in particular the Msikaba and Mthentu
rivers. These rivers are typically associated with deeply incised gorges.
In terms of the National Freshwater Ecosystem Priority Area (NFEPA) mapping for the area, the perennial
KwaDlambu River (a tributary of the Msikaba River) is the primary drainage feature in the catchment. It
has been classified as a “B” category (largely natural) river FEPA, with the catchment area highlighted as
an Upstream Management Area (UMA), which refers to sub-quaternary catchments in which human
activities need to be managed to prevent degradation of downstream river FEPAs and Fish Support
Areas. No wetland FEPAs have been classified within the study area, however, the wetland vegetation
group (the Sub-Escarpment Savanna group) is regarded as Endangered and generally “Hardly protected”
at a national level.
In terms of the ECBCP Mapping, the KwaDlambu River and its catchment area (which incorporates the
proposed quarry site) is located within an area designated as “aquatic CBA2 estuary”. In terms of the
ECBCP, the area represents critically important river sub-catchments in a near-natural state that are
considered critical catchment management areas for important downstream estuaries (i.e. the Msikaba
River Estuary in this case). According to the ECBCP land-use planning for CBA2 estuary catchments,
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focus is given to the management of Mean Annual Runoff (MAR) in order to sustain the functioning of
important downstream estuaries. The desired management objective for these aquatic CBAs should be to
limit the total transformation of these catchments to less than 15%, with any reduction in MAR limited to
less than 25%.
The quarry site itself is bounded by two watercourses, i.e. a small tributary of the KwaDlambu River to the
west and the KwaDlambu River itself to the south/east. Twenty-one definable watercourse units (i.e.
rivers and wetlands) were mapped within a 500 m radius of the quarry footprint area by the aquatic and
terrestrial ecology specialist. The individual watercourses (including seepage and valley bottom wetlands,
as well as channelled watercourses) are illustrated in Figure 8-3 below.
Figure 8-3: Mapped watercourse units within 500 m of the proposed quarry footprint area.
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The aquatic and terrestrial ecology specialist then undertook a qualitative screening assessment to
identify which of the identified watercourses are likely to be measurably negatively affected by the
proposed project and/or likely to trigger a water use as contemplated in terms of Section 21 (c) and (i) of
the NWA. From the screening assessment, the following aquatic features were considered for further
assessment:
• Three river units (C3-R01 KwaDlambu River, C1-R01 and C2-R01);
• One stream unit (C1-S01); and
• Five wetland units (C1-W01, C1-W02, C2-W01, C2-W04 and C3-W02).
The identified wetland and channelled rivers/streams were generally classified as seep (hillslope
seepage) wetlands located on hillsides/slopes, characterised mainly by subsurface flows and diffuse
water movement. The rivers and streams were classified according to the nature of flows and size of the
present active channel and were characterised as seasonal rivers (C1-R01 and C2-R01), a perennial
river (KwaDlambu River) and ephemeral stream (C1-S01).
The Present Ecological State (PES) for the identified wetland units was assessed to be “Moderately
Modified” (a “C” PES Ecological Category), with a moderate change in ecosystem processes and loss of
natural habitats having occurred but with the natural habitat remaining predominantly intact in most
instances. Existing impacts (such as poor land use management, soil erosion and establishment of alien
invasive plant species) on these wetlands have resulted in a moderate level of modification to wetland
condition, with wetland hydrology and vegetation showing the greatest level of modification.
The PES of the identified river/stream units were generally considered to be “Fair” to “Poor” (a “C” or “D”
PES) as a result of existing on-site impacts (including poor catchment management, alteration of flow
patterns leading to bed and bank erosion, livestock moving and grazing and establishment of alien
invasive plant species).
Owing to the small wetland size and significantly high level of ecosystem degradation that has already
occurred, the various wetlands were found to generally provide only low to moderate levels of ecosystem
goods and services. Overall, wetland C1-W01, C2-W01 and C2-W04 appear to be the most functionally
important wetlands at the site. The Ecological Importance and Sensitivity (EIS) of the various wetland
units were generally assessed as being of moderately low EIS (i.e. wetlands typically play a small/limited
functional role in the landscape). The identified river/stream units were assessed as being of low EIS with
the exception of the larger KwaDlambu River (C3-R01) which was assessed as being of moderate EIS.
8.1.5. CULTURAL/HERITAGE ENVIRONMENT
The cultural/heritage environment of the broader region may be considered an integral part of an
ethnographic landscape that has evolved over the last 1 000 years, due to extensive livestock
management within the context of low-density human settlement and subsistence agriculture. Social
capital is held in homesteads and graves, with grave sites often left at homestead sites which have since
been abandoned.
A few Later Iron Age and two Early Iron Age sites have been identified in the general area of the
Mkambati Nature Reserve (Granger and Feely, 1985; Feely, 1987). Charred remains of the rare
Mkambati palm nut, dating back almost 5 000 years, have been discovered in the area.
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The heritage specialist did not identify any archaeological sites within the footprint of the proposed project
and associated access road (see Appendix 4.2). However, a grave associated with an old abandoned
homestead was located in the eastern section of the footprint (GPS co-ordinates: S 31º 11’ 56.19”
E 29º 49’ 19.98). The unmarked grave is indicated by a raised soil heap and is approximately 2 m x 1.6 m
in extent. The grave appears to be older than 60 years old and is therefore protected in terms of the
NHRA.
Seven contemporary Mphondo homesteads were observed within the project footprint. While no obvious
graves were visible in the immediate environs of these homesteads, the specialists noted that grave sites
less than 60 years could potentially be associated with these dwellings. It is anticipated that, if present,
the exhumation and reburial of these graves will be addressed in conjunction with the homestead
relocation process to be undertaken by SANRAL’s land management service provider prior to the
establishment of the proposed quarry operations, with due consideration of applicable legislative and
approval requirements.
8.1.6. REGIONAL SOCIO-ECONOMIC ENVIRONMENT
The Eastern Cape is one of the poorer provinces in South Africa. Its economy has been characterised in
the province’s 2004-2014 Provincial Growth and Development Plan (PGDP) as having “extreme levels of
uneven development”. Spatially, it is the second-largest province, covering almost 14 % of the total
surface area of South Africa (CCA, 2009).
The annual average economic growth for the provincial economy over the last decade was 2.2 % against
the national average of 2.8 %. Farming is an important contributor to household livelihoods in the region,
but it is largely a subsistence activity. The region surrounding the proposed quarry site is considered to
be generally representative of the undeveloped rural hinterland of the province (particularly with reference
to the former Transkei and Ciskei homelands) and consists of weak subsistence agriculture and very
limited socio-economic growth.
The Ngquza Hill Local Municipality (LM) is bordered by the Bizana LM to the north, the Port St John’s LM
to the south and the Ntabankulu LM to the northwest. It comprises the magisterial areas of Lusikisiki and
Flagstaff. The total population of the Ngquza Hill LM is 278 481, which is 20.4% of the total population of
the O.R. Tambo District Municipality.
Scattered rural subsistence settlements predominate with some villages being fairly inaccessible.
Approximately 95% of the population of the municipality recorded as living in traditional dwellings. Given
the rural nature of the Ngquza Hill LM, the vast majority of the population are not considered economically
active (91 793 people) with only 18 524 people being employed (Stats SA, 2011).
8.1.7. CURRENT LAND USES
The proposed quarry site is largely undeveloped and sparsely populated with small dwellings (generally
comprising one to four structures) typically associated with the region. The remaining open areas are
typically used for limited subsistence farming or grazing. Road infrastructure in the area is poorly
developed and typically comprises unsurfaced roads. The identified schools, police stations and health
care facilities within the broader study area are illustrated in Figure 8-4.
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Figure 8-4: Identified schools, police stations and health care facilities within the broader study area.
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8.2. IMPACTS AND RISKS IDENTIFIED INCLUDING THE NATURE,
SIGNIFICANCE, CONSEQUENCE, EXTENT, DURATION AND PROBABILITY
OF THE IMPACTS
Provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken,
as informed by both the typical known impacts of such activities, and as informed by the consultations with affected
parties together with the significance, probability, and duration of the impacts. Please indicate the extent to which they can
be reversed, the extent to which they may cause irreplaceable loss of resources, and can be avoided, managed or
mitigated.
This section describes and assesses the significance of potential impacts associated with the proposed
project. All impacts are systematically assessed and presented according to predefined rating scales
(see Section 8.3 below). Mitigation or optimisation measures are proposed which could ameliorate the
negative impacts or enhance potential benefits, respectively. The status of all impacts should be
considered to be negative unless indicated otherwise. The significance of impacts without and with
mitigation is also assessed.
8.2.1. POTENTIAL BIOPHYSICAL IMPACTS
8.2.1.1. Soil and land capability
Description of impact
Topsoil is generally a resource of high value, containing a gene bank of seeds of indigenous species. A
loss of topsoil (through sterilisation, erosion or contamination) would generally result in a decrease in the
rehabilitation and future land use potential of any land that is disturbed.
Assessment
The aquatic and terrestrial ecology specialist has noted that there is evidence of existing soil erosion
impacts within the project footprint as a result of over-grazing and associated poor land use management
(see Appendix 4.1). Given the current rural land use of the site, no material pre-existing soil pollution
impacts have been identified on the site.
The anticipated direct impacts on soil resources include:
• Removal of topsoil and subsoil within the project footprint for the establishment of the proposed
quarry, access road and associated infrastructure; and
• Pollution of soil as a result of ad-hoc spills and point-source contaminants.
Indirect impacts include the compaction of soils through the movement of people and vehicles within the
project footprint. Increased runoff from these compacted surfaces may result in the erosion of soil
resources outside of the project footprint.
The physical disturbance of soils would predominately take place during establishment of the quarry and
associated infrastructure, as well as during the construction of the proposed access road. The presence
of construction vehicles and associated equipment also pose a risk of ad-hoc hydrocarbon spills in this
phase. During the operation of the quarry, following the removal of topsoil and subsoil from the quarry
footprint, no further physical disturbance of soil resources is anticipated. However, there is a risk of point-
source contamination from storage areas and stationary equipment, as well as ad-hoc spills from vehicles
traversing the site.
Given that there are limited pre-existing impacts on soil resources within the project footprint, the above-
mentioned impacts are considered to be of medium intensity and localised over the duration of the
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proposed quarry operations. The significance of this impact is deemed to be medium without mitigation.
However, it is anticipated that as part of the establishment of the proposed operations, topsoil and subsoil
would be removed and stockpiled for use during rehabilitation of the quarry. Furthermore, the
implementation of pollution-control measures throughout the project life-cycle would reduce the incidence
of ad-hoc and point-source contamination of soil resources. This would reduce the impact significance to
LOW (see Table 8-1).
Mitigation
The following mitigation measures are recommended:
• Limit the disturbance of soils to what is absolutely necessary for earthworks, on-going activities,
infrastructure footprints and use of vehicles.
• Provide adequate sanitary facilities for contractors for the life of the project. Waste from these
facilities must be disposed of and treated at an appropriate disposal facility.
• Conduct proper management of hazardous substances to avoid spillages during all the phases of
the project. If spills do occur and soils become contaminated, the appropriate remedial measures
should be identified in consultation with an appropriately qualified specialist. Where in-situ clean-up
and remediation of spill incidents is not possible, the polluted soils should be classified as wastes
and disposed of. After removal of the contaminated soils, the affected areas should be suitably
rehabilitated.
• The following mitigation measures are specific to soil stockpiles:
> Topsoil (top 300 – 400 mm) should be removed from areas to be disturbed within the project
footprint, including temporary activities and stockpiled separately from the subsoil for
rehabilitation purposes;
> Stockpiles should be demarcated to minimise the risk of disturbance and contamination;
> Stockpiles should not be compacted;
> Stockpiles should be monitored regularly to identify any alien invasive plants, which should
be removed when they germinate to prevent contamination of the seed bank; and
> Topsoil should be replaced after the subsoil has been replaced and compacted.
• As a general principle, storage areas and vehicle maintenance areas should be surfaced with
impermeable substrates and should have appropriate runoff containment measures, such as oil traps
or bunds, in place.
Table 8-1: Assessment of the potential impact on soil and land capability.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Medium Low
Significance Medium LOW
Status Negative Negative
Probability Definite Definite
Confidence High High
Nature of cumulative impact Other activities that may contribute to the cumulative impact on the
soils include over-grazing, and associated poor land-management
practices. The cumulative impact is considered to be of LOW to
MEDIUM significance depending on the total extent of these
impacts.
Degree to which impact can be reversed Partially reversible
Degree to which impact may cause
irreplaceable loss of resources
Medium
Degree to which impact can be
mitigated
Medium
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8.2.1.2. Fauna and Flora
Loss of vegetation
Description of impact
All vegetation within the proposed project footprint would either be stripped or disturbed during the course
of the proposed operations. Furthermore, there could be potential secondary impacts on flora (such as
change in species composition, reduction of total biomass and productivity) as a result of changes to
surface and groundwater quantity and quality, and changes in ambient air quality.
Assessment
The construction of the haul road and establishment of the quarry would necessitate clearing of
indigenous grassland vegetation within the development footprint. This would result in permanent loss of
the terrestrial grassland vegetation at the site.
The potential impacts on vegetation would be most significant in areas that are still largely natural and
which contain or support important flora. Approximately 55 ha of the Ngongoni Veld vegetation type would
be transformed. The aquatic and terrestrial ecology specialist has indicated that of the 55 ha,
approximately 4 ha has been completely transformed, while the remainder of the site comprises
Degraded Primary Grassland (22 ha) and Secondary Grassland (29 ha). In addition, the proposed access
road would have a footprint of approximately 14.7 ha, of which approximately 5.9 ha comprises an
existing dirt road.
In addition to the loss of the Ngongoni Veld Type, there are conservation-important plant species located
at the site (refer to Section 8.1.4.1) which may be destroyed/damaged if measures are not taken to
preserve these plants.
The loss of the Ngongoni Veld vegetation type and conservation-important plant species is considered to
be a high intensity impact, localised over the duration of the proposed quarry operations. The significance
of this impact is deemed high without mitigation. However, it is understood that the approved Biodiversity
Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015) makes provision for the loss
of Transkei Coastal Belt Dolerite & Shale Grassland (including Ngongoni Veld) due to stockpiling and/ or
the establishment of borrow pits/quarries to supply additional road material. Thus, it is anticipated that the
loss of Ngongoni Veld associated with the proposed project would be accommodated within the existing
Biodiversity Offset Agreement for the N2 Wild Coast Toll Highway. Accommodating the loss of Ngongoni
Veld within the existing Biodiversity Offset agreement, together with a plant search and rescue operation
prior to the commencement of site clearing, would slightly reduce the impact significance to MEDIUM to
HIGH (see Table 8-2).
Mitigation
The following mitigation measures are recommended:
• Undertake a protected plant survey within the primary terrestrial Ngongoni grassland within the
project footprint, in order to confirm the presence and abundance of threatened and protected plant
species. This survey must be undertaken by a suitably qualified botanist, prior to the
commencement of construction, during the summer growing season (between November and
March). The protected plant survey must be used to develop a detailed protected plant rescue and
translocation protocol for threatened and protected plants (based on the preliminary guidelines
provided in Section 5.4 of the specialist terrestrial ecological report, attached as Appendix 4.1).
• Ensure that the existing Biodiversity Offset Agreement for the N2 Wild Coast Toll Highway, which
accommodates the potential loss of Ngongoni Veld, is implemented effectively.
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• Demarcate the quarry site footprint prior to commencement of construction using appropriate
fencing material. Areas outside of the development footprint and operational area are to be
considered sensitive ‘No-Go’ areas.
• All disturbed terrestrial areas beyond the project footprint that are intentionally or accidentally
disturbed must be rehabilitated as per the rehabilitation guidelines included in the specialist
terrestrial ecological report (see Appendix 4.1).
• Implement measures to curb the spread of alien invasive species. In this regard post-construction
monitoring must be undertaken and any seedlings removed prior to establishment.
• Develop a comprehensive Rehabilitation and Closure Plan prior to the decommissioning and
closure of the proposed quarry operation.
Table 8-2: Assessment of the potential impact associated with the loss of vegetation. •
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity High Medium - High
Significance High MEDIUM - HIGH
Status Negative Negative
Probability Definite Definite
Confidence High High
Nature of cumulative impact Other activities that may contribute to the cumulative impact on flora
include over-grazing, and associated poor land-management
practices. The cumulative impact is considered to be of LOW to
MEDIUM significance depending on the total extent of these
impacts.
Degree to which impact can be reversed Partially reversible
Degree to which impact may cause
irreplaceable loss of resources
Medium
Degree to which impact can be
mitigated
Medium
Loss of fauna and alteration of faunal habitats
Description of impact
Faunal habitats may be lost through the clearing of vegetation, as well as alteration of habitat due to the
operation of the proposed quarry. Terrestrial faunal species may be directly impacted through direct
mortality of individuals or indirectly through disturbance from project activities, during the life of the
project.
Assessment
The clearance of vegetation within the project footprint reduces the availability of habitat and food sources
for local animals. In addition, the establishment of the quarry and increased anthropogenic activity in the
area would lead to other disturbance and restrict faunal movement between natural areas in the broader
area. Those species that cannot effectively vacate the area during development of the quarry may suffer
direct mortality during site clearing and earthworks. The majority of the larger faunal species occurring on
the site would be able to flee the site to similar habitat in the surrounding area. Smaller vertebrate
species (e.g. reptiles and small mammals) may, however, be directly impacted.
The establishment and operation of the quarry is likely to also result in the alteration of the ambient
environment through nuisance factors such as noise, vibrations and light pollution. Locally common
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species already occurring at the site are likely to be less sensitive to noise/light disturbance (due to the
proximity of the existing homesteads) and can probably become habituated to the operations located at
the site.
Assessment of the potential impact of direct mortality on faunal species was considered in light of
impacting on a species as a whole and not an individual animal. In order to accurately assess the
potential long-term impacts on a species as a whole, the possibility of impacting on species of
conservation concern was specifically considered. A number of species of conservation concern (Cape
Clawless Otter, Reddish-grey Musk Shrew, African Marsh-Harrier, Black Harrier, Black-Winged Lapwing
and twelve endemic or near-endemic reptile species) are thought to potentially occur in the area (refer to
Section 8.1.4.2). Based on the surrounding anthropogenic disturbance in the vicinity of the proposed
quarry site and the mobile nature of the identified species, it is not expected that these species of
conservation concern would be encountered in significant numbers on the proposed site. Thus, no long-
term impact from direct mortality of any species of conservation concern as a whole is expected.
No unique faunal habitats in relation to the larger area were identified on the proposed site, thus no long-
term impact on any other terrestrial faunal species that may occur on the site is expected. The potential
direct mortality of terrestrial faunal species of conservation concern is considered to be of local extent, of
long-term duration and of low intensity. Therefore the impact is rated to be of LOW significance without
and with mitigation (see Table 8-3).
Mitigation
The following mitigation measures are recommended:
• Limit the area of disturbance to what is absolutely necessary for the proposed operation.
• Ensure that every effort is made to save and relocate any amphibian, reptile, bird or mammal
encountered during site preparation that cannot flee of its own accord.
• Relocate these animals to a suitable area immediately outside the proposed project footprint, but
under no circumstance to an area further away.
Table 8-3: Assessment of the potential impact associated with the loss of fauna and alteration of
faunal habitat.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Low Low
Significance Low LOW
Status Negative Negative
Probability Probable Improbable
Confidence High High
Nature of cumulative impact Other activities that may contribute to the cumulative impact on
fauna include habitat disturbance through development, over-
grazing, and poor land-management practices. The cumulative impact is considered to be LOW.
Degree to which impact can be reversed Irreversible
Degree to which impact may cause
irreplaceable loss of resources
Low
Degree to which impact can be
mitigated
Very low
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8.2.1.3. Hydrology (Surface Water)
Description of impact
There are a number of surface water resources located within the vicinity of the proposed project
footprint. Several of these aquatic features were identified as surface water resources that would likely be
measurably affected by the proposed project. Such potential impacts include physical disturbance, flow
modification, erosion / sedimentation and alterations of water quality. Upon closure, the presence of the
quarry would also lead to a permanent change to the drainage patterns within the area.
Assessment
Following the completion of the Scoping Phase, the proposed site plan (refer to Figure 4-1) was revised
by the project engineer to incorporate aquatic buffer zones (ranging between 18 – 40m from the edge of
watercourses) as recommended by the aquatic and terrestrial ecology specialist. Thus, the establishment
of the quarry is unlikely to directly result in the destruction and or modification of the watercourses.
However, the construction of the proposed access road over the KwaDlambu River would likely lead to
the destruction and or modification of instream and riparian habitat at the proposed river crossing.
The aquatic and terrestrial ecology specialist noted that aquatic impacts can typically be grouped into
three categories: (i) the destruction and modification of aquatic habitat; (ii) flow modification and erosion /
sedimentation; and (iii) alteration of water quality. The potential impact of the proposed project for the
construction and operational phases with respect to these three categories has been assessed in detail in
the specialist report (see Appendix 4.2).
In summary, contamination, flow modification and related erosion / sedimentation impacts are likely to
arise but would be localised for the construction phase. Site clearing and earthworks upslope of the
identified watercourses would reduce groundcover and associated runoff infiltration rates would lead to
slightly increased peak discharges reaching these watercourses. During the operational phase, it is
expected that there would be increased water inputs to the downstream wetlands and streams/rivers due
to stormwater runoff. With respect to pollution, while the potential sources of contaminants would likely
be fewer than the construction phase, the poor management of sediment-laden stormwater generated by
the quarry site would be more significant.
Overall, the potential impacts of the project on surface water features is considered to be a localised,
long-term impact of medium intensity. The significance of the impacts is, therefore, assessed to be
medium before mitigation. With the implementation of mitigation, the intensity of the impacts would be
partially reduced and would be of LOW to MEDIUM significance (see Table 8-4).
Mitigation
The following mitigation measures are recommended:
• Undertake a Baseline Water Quality Monitoring Survey prior to the commencement of construction
activities in order to collect baseline data for the monitoring of water quality impacts linked to
construction and operation of the proposed quarry.
• Develop a detailed Stormwater Management Plan that describes how the design measures of
surface and near surface water management facilities will be designed, constructed and operated
so that contaminated water is kept separate from clean water run-off through a system of berms,
channels, trenches, flood and erosion protection measures.
• Prevent contaminated runoff emanating from the project site directly entering rivers / streams.
• Limit the areas of disturbance to what is absolutely necessary for earthworks, on-going activities,
infrastructure footprints and use of vehicles. No arbitrary movement of vehicles through wetland
areas should be permitted. Once the project design is finalised and the associated project footprint
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is determined, the area located outside of the site should be clearly demarcated and regarded as a
‘no-go’ area.
• Handle all hazardous chemicals (new and used), contaminated water, stockpiles, and general
waste in a manner that they do not contaminate surface water run-off or near surface water flow.
• Locate ablution facilities at least 32 m away from the river systems and wetland areas.
Table 8-4: Assessment of the potential impacts on surface water features.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Medium Low to Medium
Significance Medium LOW to MEDIUM
Status Negative Negative
Probability Probable Probable
Confidence High High
Nature of cumulative impact Poor land-management practices may contribute to the cumulative impact on surface water features. The cumulative impact is considered
to be of LOW to MEDIUM significance.
Degree to which impact can be reversed Irreversible
Degree to which impact may cause
irreplaceable loss of resources
Low
Degree to which impact can be
mitigated
Very low
8.2.1.4. Air Quality
Description of impact
The activities most likely to generate emissions during the construction phase include excavations,
earthworks, removal of spoil, storage of materials and vehicle movement on haulage routes and public
roads. For the operational phase, the main sources of particulate emissions would be blasting activities,
crushing and screening, material handling, vehicle entrainment of dust on unsurfaced haul roads, and
wind erosion on exposed areas. These emissions could have an impact on the air quality of the site and
surrounding areas and typically comprise the following elements (i) particulates less than 10 microns in
size, (ii) larger total suspended particulates that relate to dust fallout, and (iii) gas emissions, in particular
sulphur dioxide, oxides of nitrogen, carbon monoxide and Volatile Organic Compounds from vehicle
exhaust emissions. At certain concentrations, each of these contaminants can have health and/or
nuisance impacts.
Assessment
Existing emission sources that influence ambient air quality in the vicinity of the project site include
vehicle entrainment of dust on unsurfaced roads, subsistence agricultural activities, domestic fuel burning
and veld fires. The anticipated emissions as a result of the proposed project would likely contribute to the
current ambient air quality experienced in the area and lead to potential impacts on local communities,
primarily due to nuisance and aesthetic impacts associated with fugitive dust emissions. The extent of
emissions will vary substantially from day to day and will be dependent on the level of activity, the specific
operations being undertaken and the prevailing meteorological conditions.
The expected impact of emissions for the proposed quarry would be most significant in the immediate
vicinity of the operations. As the proposed project would require the relocation of third parties residing
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within the identified quarry site (and associated blasting zone), the intensity of air quality impacts would
be low in the long-term with an overall LOW significance without and with mitigation (see Table 8-5).
Mitigation
The following mitigation measures are recommended:
• Limit the areas of disturbance to what is absolutely necessary for earthworks, on-going activities,
infrastructure footprints and use of vehicles.
• Apply dust suppression on unpaved roads through chemical binding agents and/or water combined
with vehicle speed and volume controls, where possible.
• Install appropriate dust controls at the crushing and screening operation. Control measures should
aim to achieve a 50% control efficiency.
• Maintain all vehicles to achieve optimal exhaust emissions.
• Where complaints from third-parties are received, immediate steps should be taken to address the
issue (in accordance with a formal air quality complaints procedure).
Table 8-5: Assessment of the potential impacts on air quality.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Low Low
Significance Low LOW
Status Negative Negative
Probability Probable Probable
Confidence Medium Medium
Nature of cumulative impact Additional emissions from other vehicles could contribute to impacts
on the ambient air quality of the region.
Degree to which impact can be reversed Partially Reversible
Degree to which impact may cause
irreplaceable loss of resources
Low
Degree to which impact can be
mitigated
Very low
8.2.1.5. Noise
Description of impact
The establishment and operation of the proposed quarry will lead to the generation of noise. Two types of
noise-related impacts are distinguished: noise disturbance and noise nuisance. The former is noise that
can be registered as a discernible reading on a sound level meter and the latter, although it may not
register as a discernible reading, may cause nuisance because of its tonal character (e.g. distant
humming noises).
Assessment
The South African National Standard (SANS) guidelines for noise (SANS 10103, 2008) stipulates that
noise levels from a development that cause ambient background noise levels to increase in excess of 3 to
5 dBA will create a noise disturbance.
No quantification of the current ambient noise levels for the site were undertaken, however given the rural
nature of the site, it is assumed that the SANS limits for rural areas (45 dBA during the day and 35 dBA
during the night) would be applicable. The prevailing ambient noise levels surrounding the project
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footprint comprise a combination of domestic sources (i.e. residential homesteads) and linear noise
sources (e.g. roads).
The construction of the proposed access road, establishment and subsequent operation of the proposed
quarry would likely result in in the generation of disturbance (e.g. through blasting activities and operation
of crushing and screening equipment) and nuisance (e.g. movement of heavy vehicles) noise impacts, in
exceedances of the SANS guideline limit for rural areas when in close proximity to residential receptors.
However, as residents within the quarry footprint and associated blast zone would need to be relocated,
these receptors would be located further away from the potential noise sources associated with the
proposed operations.
It should also be noted that noise pollution (disturbance and nuisance) will have different impacts on
different receptors because some are very sensitive to noise and others are not. For example, workers do
not expect a noise free work environment and so they will be less sensitive to environmental noise
pollution at work. In contrast, neighbouring residents may be sensitive to additional noise and so any
change to ambient noise levels because of operation-related noise may have a negative impact on them
and their anticipated residential experience. The potential noise impact on the closest receptors is
deemed to be of local extent, long-term duration, medium intensity and overall MEDIUM significance
without and with mitigation (see Table 8-6).
Mitigation
The following mitigation measures are recommended:
• Maintain all vehicles and equipment to limit noise emissions.
• Document all noise complaints and ensure reasonable efforts are made to investigate and address
the area of concern. Options available for reducing noise impacts include but are not limited to:
> Changing operating hours;
> Equipping noise sources with silencers;
> Construction and/or maintenance of noise attenuation measures (e.g. noise berms and
placing noise sources sub surface); and
> Consulting a noise specialist for mitigation advice.
• Where necessary, use noise monitoring as part of the investigatory process into noise complaints
and assessment of the impact of mitigation and, if required, the alteration thereof.
Table 8-6: Assessment of the potential impacts on ambient noise levels.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Medium Medium
Significance Medium MEDIUM
Status Negative Negative
Probability Probable Probable
Confidence Medium Medium
Nature of cumulative impact The generation of additional noise could contribute to impacts on the ambient noise level experienced in proximity to the site.
Degree to which impact can be reversed Partially Reversible
Degree to which impact may cause
irreplaceable loss of resources
Low
Degree to which impact can be
mitigated
Very low
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8.2.2. POTENTIAL SOCIO-ECONOMIC IMPACTS
8.2.2.1. Heritage and Cultural Resources
Description of impact
The establishment of the proposed quarry and associated access road could disturb cultural heritage
material, including fossils and other archaeological material. During the course of the quarry operations,
it is also possible that undiscovered cultural heritage material could be unearthed.
Assessment
The cultural/heritage environment of the broader region is characterised by the low-density human
settlement and subsistence agriculture activities which have taken place over the last 1 000 years.
However, the site itself is not part of any known cultural landscape.
A single unmarked grave site was identified within the project footprint. The heritage specialist further
noted that additional grave sites (most probably younger than 60 years old) could potentially be
associated with the contemporary homesteads which would require relocation. The heritage specialist did
not identify any other archaeological sites within the footprint of the proposed project and associated
access road (see Appendix 4.2).
The identified grave site (as well as any other grave sites associated with the homesteads to be
relocated) would need to be relocated as it is situated within the project footprint. Since all human
remains have high heritage significance for their social value, the potential permanent, localised impact is
assessed to be of high intensity and significance. By ensuring that all applicable legislative requirements,
guidelines and regulations applicable to the removal of human remains are implemented for the relocation
of the grave site, it is anticipated that the significance of the potential impact would reduce to MEDIUM
(see Table 8-7).
It is possible that the construction of the proposed access road, or the operation of the quarry itself could
result in the alteration or destruction of archaeological material. The potential impact on archaeological
material is considered to be a localised, permanent impact of medium intensity. The significance of this
impact is, therefore, assessed to be medium before mitigation and LOW with mitigation (see Table 8-7).
Table 8-7: Assessment of the potential impact on heritage resources.
Rating criteria Without Mitigation With Mitigation
Impact on unmarked grave site
Extent Local Local
Duration Permanent Permanent
Intensity High Medium
Significance High MEDIUM
Status Negative Negative
Probability Definite Definite
Confidence High High
Impact on archaeological sites
Extent Local Local
Duration Permanent Permanent
Intensity Medium Low
Significance Medium LOW
Status Negative Negative
Probability Improbable Improbable
Confidence Medium to high Medium to high
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Nature of cumulative impact While the broader area is largely undeveloped, future development
within could result in a cumulative loss of heritage resources over
time.
Degree to which impact can be reversed Irreversible
Degree to which impact may cause
irreplaceable loss of resources
Medium to High
Degree to which impact can be
mitigated
Low
Mitigation
The following mitigation measures are recommended:
• Before relocation of the identified grave site (or any other grave sites older than 60 years) may occur,
the necessary permit application in terms of Section 36 of the NHRA must be followed in order to
obtain the required approval from the ECPHRA prior to the commencement of the proposed quarry
operations.
• The exhumation and reburial of any other grave sites younger than 60 years must be discussed with
the homestead occupants as part of the SANRAL land management process. The exhumation of
such sites must be undertaken by a local registered undertaker.
• Should any human remains be disturbed, exposed or uncovered during excavation, these must
immediately be reported to the South African Police Service and, if suspected that the remains are
older than 60 years, ECPHRA.
• Ensure that environmental induction/awareness courses for construction and quarry operation
personnel includes the relevant heritage-related aspects to enable personnel to participate effectively
in heritage resource management. A suitably experienced archaeologist should undertake induction
and training of the ECO and relevant site management personnel in the identification and
monitoring/recovery protocols for heritage resources (including marked and unmarked burial grounds
and graves) during the course of operations, as appropriate.
8.2.2.2. Impacts on roads by project-related traffic
Description of impact
The establishment and operation of the proposed quarry would result in an increase in traffic volumes on
the surrounding road network.
Assessment
Current traffic movement along the road network in proximity of the project site predominately consists of
pedestrian movement and privately owned vehicles. Due to the rural nature of the area, the current road
use frequency in the region is considered to be low.
The commencement of the proposed project would lead to an increase in traffic volumes within the
region, the majority of which would comprise heavy construction vehicles and trucks. During the
operational phase, haul trucks would be required to undertake regular trips to and from the site to
transport the quarried material.
Given the relatively low traffic volumes currently experienced within the surrounding road network it is
anticipated that sufficient reserve capacity within the road network would be available to accommodate
the additional project traffic. However, the increased movement of heavy vehicles presents a higher risk
for traffic-related safety incidents.
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The potential impact related to the movement of heavy vehicles is considered to be local to regional in
extent, long-term and of medium intensity. The significance of this potential impact is, therefore, assessed
to be medium to high before mitigation. With the implementation of mitigation, the intensity of the impact
would reduce and would be of LOW to MEDIUM significance (see Table 8-8).
Mitigation
The following mitigation measures are recommended:
• Ensure that all vehicles are road-worthy and drivers are qualified and made aware of the potential
road safety issues within the area and adhere to speed limits.
• Record and respond appropriately and without delay, to any complaints about usage of roads by
quarry vehicles.
Table 8-8: Assessment of the potential impact on road traffic.
Rating criteria Without Mitigation With Mitigation
Extent Local to Regional Local to Regional
Duration Long-term Long-term
Intensity Medium Low
Significance Medium to High LOW to MEDIUM
Status Negative Negative
Probability Definite Definite
Confidence High High
Nature of cumulative impact While the broader area is largely undeveloped, future development
within the region could result in a cumulative impact on road traffic.
Degree to which impact can be reversed Fully Reversible
Degree to which impact may cause
irreplaceable loss of resources
Low
Degree to which impact can be
mitigated
Medium
8.2.2.3. Blasting Hazards
Description of impact
Blasting activities have the potential to impact on people, animals and structures located in the vicinity of
the proposed quarry. Blast hazards include ground vibration, air blast, fly rock, blast fumes and dust.
Ground vibrations travel directly through the ground and have the potential to cause damage to
surrounding structures. Air blasts result from the pressure released during the blast resulting in an air
pressure pulse (wave), which travels away from the source and has the potential to damage surrounding
structures. Fly rock is the release of pieces of rock over a distance and can be harmful to people and
animals and damage structures and property. Blast fumes and dust, caused by the explosion, can be
considered significant nuisance factors. Ground vibrations and air blasts have the potential to cause
nuisance to people and animals even if blasts occur within legal limits.
Assessment
No blasting activities are anticipated during the construction of the proposed access road and
establishment of the quarry itself. The potential blasting impacts associated with the operation of the
proposed quarry were assessed in detail by the blasting specialist (see specialist report attached in
Appendix 4.3). The blasting specialist modelled the expected levels of ground vibration, air blast and fly
rock from the boundary of the proposed quarry and calculated the distances of influence on third parties
for each of the potential impacts.
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With respect to human perception of ground vibration, the modelled ground vibration levels showed that
‘intolerable’ levels would be experienced up to a distance of 258 m from the quarry boundary and
‘unpleasant’ levels could be anticipated up to 592 m. For this reason the blasting specialist has
recommended that the relocation of households within 600 m of the quarry boundary be considered. The
modelled levels of air blasts indicate that the current accepted limit of air blast (134 dB) would be
exceeded up to a distance of 333 m from the quarry boundary. There would be a high probability of
damage to public property and complaints as a result of air blast impacts within this area. The
occurrence of fly rock in any form will have a negative impact if found to travel outside the zone deemed
to be unsafe. The modelling undertaken by the blasting specialist noted that the minimum unsafe distance
for fly rock would be 206 m from the quarry boundary.
Should the basting activities lead to damage of third party property or injury of people or animals, the
impact would be of high intensity at a local level and endure in the medium term. Therefore, this impact is
assessed to be of medium significance without mitigation. By relocating third-parties outside of the
project footprint and the blasting zone (a distance of 600 m, as recommended by the blasting specialist),
the significance of this impact reduces to LOW with mitigation (see Table 8-9).
Mitigation
The following mitigation measures are recommended:
• Relocate all households within the quarry footprint and 600 m from the quarry boundary.
• Implement a monitoring programme for recording blasting operations. The following elements
should be part of such a monitoring program:
> Ground vibration and air blast results;
> Blast information summary;
> Meteorological information at time of the blast;
> Video recording of the blast; and
> Fly rock observations.
• Review the initial blast design and prepare a detailed blasting code of practice for the project. The
following blast designs are recommended:
> Blast initiation should be electronic;
> Blastholes should be 89 mm in diammeter;
> Stemming lengths must be at least 30 times the blasthole diameter (89 mm x 30 mm = 2.7 m);
and
> Use crushed aggregate as stemming material at 10 % of the blasthole diameter (7 - 12 mm).
• Monitor ground vibration and air blast to ensure that the generated levels of ground vibration and
air blast comply with recommendations. The monitoring of ground vibration must qualify the
expected ground vibration and air blast levels and assist in mitigating these aspects properly. Ten
monitoring positions are proposed by the blasting specialist (see Figure 18 and Table 17 of
Appendix 4.3).
• Undertake pre-blast photographic surveys of all structures up to 1000 m from the quarry area.
• Respond immediately to any blast-related complaints. These complaints and the follow-up actions
should be dated, documented and kept as records for the duration of the operation. Where proven
blast-related damage has been caused, appropriate compensation must be provided to affected
parties.
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Table 8-9: Assessment of the potential blasting impacts.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Medium Term Medium Term
Intensity High Medium
Significance Medium LOW
Status Negative Negative
Probability Highly Probable Highly Probable
Confidence High High
Nature of cumulative impact No other cumulative blasting impacts are anticipated.
Degree to which impact can be reversed Partially Reversible
Degree to which impact may cause
irreplaceable loss of resources
Medium
Degree to which impact can be
mitigated
Medium
8.2.2.4. Land use
Description of impact
In order to establish the proposed quarry, as well as to ensure the safety of people within the possible
blasting zone, individuals residing within these areas would be physically relocated. Members of the local
community would no longer be able to occupy homesteads located within these areas and conduct
subsistence farming within the remaining areas of the project site until rehabilitation of the site has been
completed.
Assessment
In addition to the scattered households within the project footprint and associated blasting zone, the site
is predominately utilised for limited subsistence agriculture and livestock grazing. As the proposed project
would require the relocation of homesteads, it is anticipated that the relocation process would also entail
the reallocation of associated arable land. The relocation process would be undertaken by SANRAL’s
land management service provider prior to the establishment of the proposed quarry operations. Prior to
the closure of the proposed operations, a rehabilitation and closure plan for the site would need to be
developed. This plan would consider the proposed future land use of the project site and ensure that
disturbed areas are suitably shaped and rehabilitated to facilitate this identified land use.
The potential impact is considered to be a localised, long-term impact of low intensity. The significance of
this impact is, therefore, assessed to be LOW before and after mitigation (see Table 8-10).
Mitigation
The following mitigation measures are recommended:
• Implement the commitments contained within the EMP with a view not only to prevent and/or
mitigate the various environmental and social impacts, but also to prevent negative impacts on
surrounding land uses.
• If a situation arises where any surrounding land use are negatively affected by the operations, the
quarry operator will immediately take steps to address the cause of the impacts.
• Incorporate measures to achieve the future land use plans for the project site during closure
planning.
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Table 8-10: Assessment of the potential impact on land use.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Low Low
Probability Probable Probable
Confidence High High
Significance Low LOW
Cumulative impact Low Low
Nature of Cumulative impact The establishment of additional projects in the area could impact on existing land
uses.
Degree to which impact can
be reversed
Partially Reversible
Degree to which impact may
cause irreplaceable loss of
resources
Low
Degree to which impact can
be mitigated / optimised
None
8.2.2.5. Creation of employment and business opportunities
Description of impact
The proposed development would create a number of local employment and business opportunities
during operation. In addition, there would be an opportunity for skills development and on-site training. It is anticipated that an increase in the number of income-earning people would also have a multiplier effect
on the trade of other goods and services in other sectors within the area.
Assessment The proposed project would create a limited number of employment opportunities during the site
establishment and operational phases. The majority of the low- and semi-skilled employment
opportunities are likely to benefit historically disadvantaged members of the community. The
implementation of a skills development and training programme would increase the number of skilled
local employment opportunities.
The benefits to the local economy would extend over the operational lifespan of the proposed project.
A percentage of the monthly wage bill earned by permanent staff would be spent in the regional and local
economy, which would benefit local businesses in the region.
The creation of employment and business opportunities during the site establishment and operational
phases is likely to result in a long-term, local impact of low intensity. The significance of this potential
impact is, therefore, assessed to be LOW (positive) before and after optimisation (see Table 8-11).
Optimisation
• The Applicant should, where reasonable and practical, implement a ‘locals first’ employment policy,
especially for semi- and low-skilled job categories, and appoint local contractors/sub-contractors
that are compliant with Black Economic Empowerment (BEE) criteria.
• A training and skills development programme for locals should be implemented during the first five
years of operation.
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Table 8-11: Assessment of the potential social impact related to employment and the creation
of business opportunities during operation.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Low Low
Probability Probable Definite
Confidence High High
Significance Low (positive) LOW (POSITIVE)
Cumulative impact Low (positive) Low (positive)
Nature of Cumulative impact Potential cumulative impacts linked to employment and business opportunities would
depend on other construction projects being implemented in the same timeframe.
Degree to which impact can
be reversed
Fully reversible
Degree to which impact may
cause irreplaceable loss of
resources
N/A
Degree to which impact can
be mitigated / optimised
Low
8.2.2.6. Influx of job seekers to the area
Description of impact
The establishment of the proposed project is likely to attract job seekers to the area during the operation
phase, which could pose a number of risks to the local community. While the presence of job seekers and
their families does not in itself constitute a social impact, the manner in which they conduct themselves
could affect the local community. In the case of local communities the most significant risks include:
• Impact on existing social networks and community structures.
• Pressure on local services, such as schools, clinics, etc.
• Competition for scarce jobs.
• Increase in incidences of crime.
• Increase in transmission of sexually transmitted diseases (STDs).
Assessment The potential risk posed by job seekers is considered to have a localised, long-term to permanent impact
of medium intensity for the community as a whole. The significance of this potential impact is, therefore,
assessed to be medium before mitigation. The implementation of a local employment strategy would
reduce these risks to a large extent. The effective implementation of the proposed mitigation measures
would reduce the potential social impact to LOW significance (see Table 8-12).
Mitigation
• A ‘locals first’ employment policy should be implemented.
• Monitoring of the implementation of the mitigation measures recommended for the proposed
project should be undertaken by the Environmental Monitoring Committee which has already been
established for the construction phase of the N2 Wild Coast Toll Highway.
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Table 8-12: Assessment of the potential social impact related to the influx of operation
workers.
Rating criteria Without Mitigation With Mitigation
Extent Local Local
Duration Long-term Long-term
Intensity Medium Low
Probability Probable Probable
Confidence High High
Significance Medium LOW
Cumulative impact Medium Medium
Nature of Cumulative impact The presence of labourers involved with other developments in the area may exacerbate the risks.
Degree to which impact can be reversed
Irreversible (in case of HIV/AIDs, unwanted pregnancies etc.)
Degree to which impact may cause irreplaceable loss of resources
Low
Degree to which impact can be mitigated / optimised
Low
8.2.3. NO-GO ALTERNATIVE
Description of impact
The no-go alternative would result in the maintenance of the status quo. While none of the impacts
associated with the proposed project (as described above) would occur, the implementation of the no-go
alternative would result in lost economic opportunities, such as:
• The direct economic benefits associated with the proposed project would be lost to the local and
regional economies;
• The possible indirect economic benefits derived from the procurement of goods and services and
the spending power of employees would also be lost; and
• Lost economic opportunities related to sunken costs (i.e. costs already incurred) of initial desktop
investigations and previous prospecting activities.
Assessment
With respect to the identified biophysical impacts described in Section 8.2.1 above, the no-go alternative
would result in the site remaining in its current state with no change to the current impacts on ambient air
quality or noise levels in the area. However, the current over-grazing and associated poor land use
management activities would likely continue for the foreseeable future. These activities would lead to
additional soil erosion impacts, sedimentation of surface water features and the related degradation of
natural vegetation and faunal habitats. The negative impacts would be of low intensity and highly
localised over the long-term. Thus, the potential negative impact of the no-go alternative on soil and land
capability, fauna and flora and hydrology is considered to be of LOW significance.
With respect to the potential socio-economic impacts described in Section 8.2.2, the status quo would
have NO IMPACT on heritage and cultural resources, traffic and existing land uses. Furthermore, there
would be no influx of job seekers and there would be no blasting impacts. However, the potential impact
related to the lost economic opportunities described above is considered to be of HIGH significance (see
Table 8-13).
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Table 8-13: Assessment of the potential impacts related to the No-Go alternative.
Rating criteria Without Mitigation
Air Quality, Noise, Heritage and Cultural Resources, Traffic, Blasting, Land Use and Influx of Job Seekers
Extent
NO IMPACT
Duration
Intensity
Significance
Status
Probability
Confidence
Soil and Land Capability, Fauna and Flora and Hydrology
Extent Local
Duration Long-term
Intensity Low
Significance LOW
Status Negative
Probability Probable
Confidence Low
Lost Economic Opportunities
Extent Regional
Duration Permanent
Intensity Medium
Significance Improbable
Status Low
Probability HIGH
Confidence Yes
Nature of cumulative impact Increased construction costs associated with the N2 Wild Coast Toll
Highway.
Degree to which impact can be reversed Reversible
Degree to which impact may cause
irreplaceable loss of resources
N/A
Degree to which impact can be
mitigated
N/A
8.3. METHODOLOGY USED IN DETERMINING AND RANKING THE NATURE,
SIGNIFICANCE, CONSEQUENCES, EXTENT, DURATION AND
PROBABILITY OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS
The assessment of potential environmental impacts will involve consideration of the following criteria:
• Extent of impact;
• Duration of impact;
• Intensity of impact;
• Status of impact;
• Probability of impact occurring;
• Significance of impact;
• Degree to which impact can be mitigated;
• Degree to which a resource is lost;
• Reversibility of impact;
• Nature of cumulative impacts; and
• Degree of confidence of assessment.
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In assigning significance ratings to potential impacts before and after mitigation, specialists are instructed
to follow the approach presented below:
1. The core criteria for determining significance ratings are “extent” (Section 8.3.1), “duration”
(Section 8.3.2) and “intensity” (Section 8.3.3). The preliminary significance ratings for combinations
of these three criteria are given in Section 8.3.4.
2. Additional criteria to be considered, which could “increase” the significance rating if deemed
justified by the specialist, with motivation, are the following:
• Permanent / irreversible impacts (as distinct from long-term, reversible impacts);
• Potentially substantial cumulative effects (see Item 9 below); and
• High level of risk or uncertainty, with potentially substantial negative consequences.
3. Additional criteria to be considered, which could “decrease” the significance rating if deemed
justified by the specialist, with motivation, is the following:
• Improbable impact, where confidence level in prediction is high.
4. The status of an impact is used to describe whether the impact will have a negative, positive or
neutral effect on the surrounding environment. An impact may therefore be negative, positive (or
referred to as a benefit) or neutral (Section 8.3.5).
5. Describe the impact in terms of the probability of the impact occurring (Section 8.3.6) and the
degree of confidence in the impact predictions, based on the availability of information and
specialist knowledge (Section 8.3.7).
6. Describe the degree to which a resource is impacted (Section 8.3.8);
7. When assigning significance ratings to impacts after mitigation, the specialist needs to:
• First, consider probable changes in intensity, extent and duration of the impact after
mitigation, assuming effective implementation of mitigation measures, leading to a revised
significance rating; and
• Then moderate the significance rating after taking into account the likelihood of proposed
mitigation measures being effectively implemented. Consider:
o Any potentially significant risks or uncertainties associated with the effectiveness of
mitigation measures;
o The technical and financial ability of the proponent to implement the measure; and
o The commitment of the proponent to implementing the measure, or guarantee over
time that the measures would be implemented.
8. Describe the degree to which an impact can be mitigated or enhanced (Section 8.3.9) and reversed
(Section 8.3.10)
9. The cumulative impacts of a project should also be considered. “Cumulative impacts” refer to the
impact of an activity that may become significant when added to the existing activities currently
taking place within the surrounding environment.
10. Where applicable, assess the degree to which an impact may cause irreplaceable loss of a
resource. A resource assists in the functioning of human or natural systems, i.e. specific minerals,
water, etc.
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The significance ratings are based on largely objective criteria and inform decision-making at a project
level as opposed to a local community level. In some instances, therefore, whilst the significance rating
of potential impacts might be “low” or “very low”, the importance of these impacts to local communities or
individuals might be extremely high. The importance which I&APs attach to impacts must be taken into
consideration, and recommendations should be made as to ways of avoiding or minimising these
negative impacts through project design, selection of appropriate alternatives and / or management.
The relationship between the significance ratings after mitigation and decision-making can be broadly
defined as follows:
Significance rating Effect on decision-making
INSIGNIFICANT; VERY LOW; LOW
Will not have an influence on the decision to proceed with the proposed project, provided
that recommended measures to mitigate negative impacts are implemented.
MEDIUM Should influence the decision to proceed with the proposed project, provided that
recommended measures to mitigate negative impacts are implemented.
HIGH; VERY HIGH Would strongly influence the decision to proceed with the proposed project.
8.3.1. EXTENT
“Extent” defines the physical extent or spatial scale of the impact.
Rating Description
LOCAL Extending only as far as the activity, limited to the site and its immediate surroundings. Specialist studies to specify extent.
REGIONAL Specialist studies to specify extent.
NATIONAL South Africa
INTERNATIONAL
8.3.2. DURATION
“Duration” gives an indication of how long the impact would occur.
Rating Description
SHORT-TERM 0 - 5 years
MEDIUM-TERM 6 - 15 years
LONG-TERM Where the impact will cease after the operational life of the activity, either because of natural
processes or by human intervention.
PERMANENT Where mitigation either by natural processes or by human intervention will not occur in such a
way or in such time span that the impact can be considered transient.
8.3.3. INTENSITY
“Intensity” establishes whether the impact would be destructive or benign.
Rating Description
ZERO TO VERY LOW Where the impact affects the environment in such a way that natural, cultural and social
functions and processes are not affected.
LOW Where the impact affects the environment in such a way that natural, cultural and social
functions and processes continue, albeit in a slightly modified way.
MEDIUM Where the affected environment is altered, but natural, cultural and social functions and
processes continue, albeit in a modified way.
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Rating Description
HIGH Where natural, cultural and social functions or processes are altered to the extent that it will
temporarily or permanently cease.
8.3.4. SIGNIFICANCE
“Significance” attempts to evaluate
the importance of a particular impact, and in doing so incorporates the
above three scales (i.e. extent, duration and intensity).
Rating Description
VERY HIGH Impacts could be EITHER:
of high intensity at a regional level and endure in the long term 6;
OR of high intensity at a national level in the medium term;
OR of medium intensity at a national level in the long-term.
HIGH Impacts could be EITHER:
of high intensity at a regional level and endure in the medium term;
OR of high intensity at a national level in the short term;
OR of medium intensity at a national level in the medium term;
OR of low intensity at a national level in the long term;
OR of high intensity at a local level in the long term;
OR of medium intensity at a regional level in the long term.
MEDIUM Impacts could be EITHER:
of high intensity at a local level and endure in the medium term;
OR of medium intensity at a regional level in the medium term;
OR of high intensity at a regional level in the short term;
OR of medium intensity at a national level in the short term;
OR of medium intensity at a local level in the long-term;
OR of low intensity at a national level in the medium term;
OR of low intensity at a regional level in the long term.
LOW Impacts could be EITHER
of low intensity at a regional level and endure in the medium term;
OR of low intensity at a national level in the short term;
OR of high intensity at a local level and endure in the short term;
OR of medium intensity at a regional level in the short term;
OR of low intensity at a local level in the long term;
OR of medium intensity at a local level and endure in the medium term.
VERY LOW Impacts could be EITHER
of low intensity at a local level and endure in the medium term;
OR of low intensity at a regional level and endure in the short term;
OR of low to medium intensity at a local level and endure in the short term.
INSIGNIFICANT Impacts with:
Zero to very low intensity with any combination of extent and duration.
UNKNOWN In certain cases it may not be possible to determine the significance of an impact.
8.3.5. STATUS OF IMPACT
The status of an impact is used to describe whether the impact would have a negative, positive or zero
effect on the affected environment. An impact may therefore be negative, positive (or referred to as a
benefit) or neutral.
6 For any impact that is considered to be “Permanent” apply the “Long-Term” rating.
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8.3.6. PROBABILITY
“Probability” describes the likelihood of the impact occurring.
Rating Description
IMPROBABLE Where the possibility of the impact to materialise is very low either because of design or
historic experience.
PROBABLE Where there is a distinct possibility that the impact will occur.
HIGHLY PROBABLE Where it is most likely that the impact will occur.
DEFINITE Where the impact will occur regardless of any prevention measures.
8.3.7. DEGREE OF CONFIDENCE
This indicates the degree of confidence in the impact predictions, based on the availability of information
and specialist knowledge.
Rating Description
HIGH Greater than 70% sure of impact prediction.
MEDIUM Between 35% and 70% sure of impact prediction.
LOW Less than 35% sure of impact prediction.
8.3.8. LOSS OF RESOURCES
“Loss of resource” refers to the degree to which a resource is permanently affected by the activity, i.e. the
degree to which a resource is irreplaceable.
Rating Description
LOW Where the activity results in a loss of a particular resource but where the natural, cultural
and social functions and processes are not affected.
MEDIUM Where the loss of a resource occurs, but natural, cultural and social functions and
processes continue, albeit in a modified way.
HIGH Where the activity results in an irreplaceable loss of a resource.
8.3.9. DEGREE TO WHICH IMPACT CAN BE MITIGATED
This indicates the degree to which an impact can be reduced.
Rating Description
NONE No change in impact after mitigation.
VERY LOW Where the significance rating stays the same, but where mitigation will reduce the
intensity of the impact.
LOW Where the significance rating drops by one level, after mitigation.
MEDIUM Where the significance rating drops by two to three levels, after mitigation.
HIGH Where the significance rating drops by more than three levels, after mitigation.
8.3.10. REVERSIBILITY OF AN IMPACT
This refers to the degree to which an impact can be reversed.
Rating Description
IRREVERSIBLE Where the impact is permanent.
PARTIALLY REVERSIBLE Where the impact can be partially reversed.
FULLY REVERSIBLE Where the impact can be completely reversed.
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8.4. THE POSITIVE AND NEGATIVE IMPACTS THAT THE PROPOSED
ACTIVITY (IN TERMS OF THE INITIAL SITE LAYOUT) AND ALTERNATIVES
WILL HAVE ON THE ENVIRONMENT AND THE COMMUNITY THAT MAY
BE AFFECTED
Refer to Section 8.2 for a discussion of the identified positive and negative impacts of the proposed
project.
8.5. THE POSSIBLE MITIGATION MEASURES THAT COULD BE APPLIED AND
THE LEVEL OF RISK
With regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/
discussion of the mitigations or site layout alternatives available to accommodate or address their concerns, together with
an assessment of the impacts or risks associated with the mitigation or alternatives considered.
The identified mitigation measures, together with an assessment of the impacts is provided in Section 8.2
above.
8.6. MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED
As noted in Section 7.1.1, various site alternatives were investigated by the design engineer. The
rationale for selecting the preferred site and exclusion of other possible alternative sites which were
investigated is provided in Table 7-1.
8.7. STATEMENT MOTIVATING THE ALTERNATIVE DEVELOPMENT
LOCATION WITHIN THE OVERALL SITE
The primary rationale for the selection of the preferred site alternative is provided in Section 7.1.1 and
relates to the area available to establish the proposed quarry, topography, level of existing development,
availability and quantity of suitable material.
The proposed project layout has been informed by the outcomes of the Scoping Process and has been
refined based on the baseline input provided by the terrestrial and freshwater ecosystems specialist (refer
to Section 7.1.3). In this regard the project layout has taken into account the recommended aquatic buffer
zones associated with wetlands and riparian areas located on the site.
Given the above, the proposed project layout provided in Figure 4-1 is deemed to be the preferred
alternative.
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9. FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO
IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE
ACTIVITY WILL IMPOSE ON THE PREFERRED SITE
Including (i) a description of all environmental issues and risks that were identified during the environmental impact
assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to
which the issue and risk could be avoided or addressed by the adoption of mitigation measures.
Refer to Section 8.2, which provides a detailed description of the environmental issues / risks that were
identified during the environmental impact assessment process and assessed in this EIR.
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9.1. ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK
ACTIVITY (e.g. excavations, blasting, stockpiles, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, roads, etc.)
POTENTIAL IMPACT (e.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc.)
ASPECTS AFFECTED
PHASE (e.g. Construction, commissioning, operational, decommissioning, closure)
SIGNIFICANCE (UNMITIGATED)
MITIGATION TYPE (modify, remedy, control, or stop through e.g. noise control measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc.)
Significance (mitigated)
Extent to which the impact can be avoided or addressed through the implementation of management measures
Civil works – related to infrastructure establishment
Site Establishment
Quarry Operation
Transport systems
Waste management
Rehabilitation
Maintenance and aftercare of rehabilitated areas
Loss of soil resources and land capability through pollution and physical disturbance
Soil and land capability
Construction Operation Decommissioning Closure
Medium • Restrict project footprint • Pollution prevention
measures • Stockpile topsoil
Low Can be managed/mitigated to acceptable levels
Earthworks - for all surface infrastructure
Site Establishment
Quarry Operation
Transport systems
Waste management
Rehabilitation
Maintenance and aftercare of rehabilitated areas
Loss of vegetation Terrestrial Biodiversity
Construction Operation Decommissioning
High • Implementation of the biodiversity offset
• Restrict project footprint • Rehabilitate disturbed
areas • Prevention of the killing of
animal species • Pollution prevention
measures • Prevention of the
disturbance of ecosystems
Medium to High Can be managed/mitigated to acceptable levels
Earthworks - for all surface infrastructure
Site Establishment
Quarry Operation
Transport systems
Rehabilitation
Maintenance and aftercare of rehabilitated areas
Loss of fauna and alteration of faunal habitats
Terrestrial Biodiversity
Construction Operation Decommissioning
Low Low Can be managed/mitigated to acceptable levels
Earthworks - for all surface infrastructure
Site Establishment
Quarry Operation
Transport systems
Physical disturbance and pollution of surface water resources
Surface water
Construction Operation Decommissioning Closure
Medium • Implement a monitoring programme
• Implement a stormwater management plan
• Implement emergency response procedure
Low to Medium Can be managed/mitigated to acceptable levels
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ACTIVITY (e.g. excavations, blasting, stockpiles, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, roads, etc.)
POTENTIAL IMPACT (e.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc.)
ASPECTS AFFECTED
PHASE (e.g. Construction, commissioning, operational, decommissioning, closure)
SIGNIFICANCE (UNMITIGATED)
MITIGATION TYPE (modify, remedy, control, or stop through e.g. noise control measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc.)
Significance (mitigated)
Extent to which the impact can be avoided or addressed through the implementation of management measures
Waste management
Rehabilitation
Maintenance and aftercare of rehabilitated areas
• Implementation and maintenance of licence requirements
• Pollution prevention measures
Earthworks - for all surface infrastructure
Site Establishment
Quarry Operation
Transport systems
Rehabilitation
Maintenance and aftercare of rehabilitated areas
Air quality Air Construction Operation Decommissioning Closure
Low • Restrict project footprint • Apply dust suppression
measures • Implementation of an air
quality complaints procedure
Low Can be managed/mitigated to acceptable levels
Earthworks - for all surface infrastructure
Site Establishment
Quarry operation
Transport systems
Noise pollution Noise Construction Operation Decommissioning
Medium • Maintenance of vehicles and equipment
• Implementation of a noise complaints procedure
Medium Can be managed/mitigated to acceptable levels
Earthworks - for all surface infrastructure
Site Establishment
Quarry operation
Transport systems Rehabilitation
Loss of heritage and cultural resources
Heritage and cultural resources
Construction Operation Decommissioning
Medium (for archaeological sites) to High (for graves)
• Exhume and relocate graves in accordance with the applicable legislation and procedures
• Where archaeological material is discovered, implement emergency response procedure
Low (for
archaeological
sites) to
Medium(for
graves)
Can be avoided
Transport system Traffic impact Traffic Construction Operation Decommissioning
Medium to High • Implementation of a traffic safety programme
• Implementation of a traffic complaints procedure
Low to Medium Can be managed/mitigated to acceptable levels
Quarry operation
Blasting impacts (fly rock, air blasts and ground vibrations)
Blasting Operation Medium • Relocate households outside of blasting zone
• Implementation of a blast management plan
• Pre-mining photographic crack survey
Low Can be managed/mitigated to acceptable levels
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ACTIVITY (e.g. excavations, blasting, stockpiles, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, roads, etc.)
POTENTIAL IMPACT (e.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc.)
ASPECTS AFFECTED
PHASE (e.g. Construction, commissioning, operational, decommissioning, closure)
SIGNIFICANCE (UNMITIGATED)
MITIGATION TYPE (modify, remedy, control, or stop through e.g. noise control measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc.)
Significance (mitigated)
Extent to which the impact can be avoided or addressed through the implementation of management measures
• Communication of planned blasting times with stakeholders
• Pre-blast warning • Monitoring blasts • Audit and review to adjust
blast design were necessary
• Investigate blast-related complaints
Loss of soil resources and land capability through pollution and physical disturbance
Quarry operation
Land use impact Land use Construction Operation Decommissioning
Low
• Implementation of EMP commitments
• Take necessary steps to prevent negative impact on surrounding land
• Closure planning to incorporate measures to achieve future land use plans
Low Can be managed/mitigated to acceptable levels
Establishment of the quarry Quarry operation
Creation of employment and business opportunities
Socio-economic
Construction Operation
Low positive • Hire people from closest communities
• Local procurement of goods and services
Low positive N/A
Establishment of the quarry
Presence of the quarry operation
Influx of job seekers to the area
Construction Operation Decommissioning
Medium • Employment and procurement opportunities provided to closest communities
• Monitor and prevent the development of informal settlements through the interaction with local authorities and law enforcement officials
Low Can be managed/mitigated to acceptable levels
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9.2. SUMMARY OF SPECIALIST REPORTS
This summary must be completed if any specialist reports informed the impact assessment and final site layout process
and must be in the following tabular form:
Attach copies of Specialist Reports as appendices
The following specialist studies have been undertaken and are attached in Appendix 4.
SPECIALIST STUDY SPECIALIST APPENDIX
Terrestrial and freshwater ecosystems Eco-Pulse Environmental Consulting Services 4.1
Blasting impact Blast Management and Consulting 4.2
Cultural heritage resources Active Heritage 4.3
LIST OF STUDIES UNDERTAKEN
RECOMMENDATIONS OF SPECIALIST REPORTS
SPECIALIST RECOMMENDATIONS THAT HAVE BEEN INCLUDED IN THE EIA REPORT (Mark with an X where applicable)
REFERENCE TO APPLICABLE SECTION OF REPORT WHERE SPECIALIST RECOMMENDATIONS HAVE BEEN INCLUDED.
Terrestrial and
freshwater
ecosystems
The aquatic and terrestrial ecology specialist
made several recommendations with regards to
mitigation for the proposed project. The
recommendations pertain to, inter alia, aquatic
buffer zones, demarcation of ‘no-go’ areas,
design of the proposed access road and
associated culverts, stormwater management
design, pollution prevention measures, erosion
control, alien invasive species monitoring and
control and monitoring and rehabilitation. See
Sections 4.5 and 5.3 of the specialist report for
more detail in this regard. It was further noted
that the loss of Ngongoni Veld associated with
the proposed project could be accommodated
within the existing Biodiversity Offset Agreement
for the N2 Wild Coast Toll Highway.
X Section 8.2.1.2 and
Section 8.2.1.3
Blasting The blasting specialist indicated that relocation
of households within 600 m from the pit
boundary should be considered.
The following blast designs were recommended:
• Blast initiation should be electronic;
• Blastholes should be 89 mm in diammeter;
• Stemming lengths must be at least 30
times the blasthole diameter (89 mm x
30 mm = 2.7 m); and
• Use crushed aggregate as stemming
material at 10 % of the blasthole diameter
(7 - 12 mm).
It was further recommended that a minimum
area of 206 m around a blast should be cleared
of people and animals before blasting. The final
blast designs should be used to determine the
X Section 8.2.2.3
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final decision on safe distance to evacuate
people and animals. Blasting should not take
place early in the morning, when there is a
possibility of atmospheric inversion, during
periods of poor visibility (e.g. fog or night), too
late in the afternoon during winter and when
wind is blowing strongly in the direction of
receptors.
The blasting specialist also recommended
various ground vibration and air blast levels
limits for blasting operations (see Table 20 of the
specialist report attached in Appendix 4.2).
Additional recommendations were made
pertaining to blasting times, undertaking
photographic surveys of all structures up to
1000 m from the quarry area and implementing
a ground vibration and air blast monitoring.
Cultural
heritage
resources
Before relocation of the identified grave site (or
any other grave sites older than 60 years) may
occur, the necessary permit application in terms
of Section 36 of the National Heritage
Resources Act, 1999 (No. 25 of 1999) (NHRA)
must be followed in order to obtain the required
approval from the Eastern Cape Heritage
Resources Agency (ECPHRA) prior to the
commencement of the proposed quarry
operations.
With respect to the contemporary homesteads
located within the project footprint, it was
recommended that these be evaluated by
SANRAL’s land management service provider
and should any graves be identified, then their
possible exhumation and reburial must be
discussed with the homestead occupants. As
these graves would most probably be younger
than 60 years old their exhumation would have
to be conducted by a local registered
undertaker.
Where palaeontological, archaeological, or
historical materials are uncovered during the
commencement of the proposed quarry
operations, the activities should cease
immediately pending an evaluation by the
heritage authorities.
X Section 8.2.2.1
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10. ENVIRONMENTAL IMPACT STATEMENT
10.1. SUMMARY OF THE KEY FINDINGS OF THE ENVIRONMENTAL IMPACT
ASSESSMENT
A summary of the assessment of potential environmental impacts associated with the proposed quarry
activities and No-Go Alternative is provided in Table 10-1 overleaf.
Table 10-1: Summary of the significance of the potential impacts associated with the proposed
quarry operations and No-Go Alternative.
Potential impact
Significance
Without
mitigation
With mitigation
POTENTIAL BIOPHYSICAL IMPACTS
Soil and land capability M L
Fauna and Flora Loss of vegetation H M - H
Loss of fauna and alteration of habitats L L
Hydrology (Surface Water) M L - M
Air Quality L L
Noise M M
POTENTIAL SOCIO-ECONOMIC IMPACTS
Heritage and Cultural Resources Unmarked grave site H M
Archaeological sites M L
Impacts on roads by project-related traffic M – H L - M
Blasting Hazards M L
Land Use L L
Creation of employment and business opportunities L (+ve) L (+ve)
Influx of job seekers to the area M L
NO-GO ALTERNATIVE
No-Go Alternative Soil and land capability L N/A
Fauna and Flora L N/A
Hydrology (Surface Water) L N/A
Air Quality
No change to current impacts.
Noise
Heritage and Cultural Resources
Impacts on traffic
Land Use
Blasting Hazards No impact.
Influx of job seekers
Lost Economic Opportunities H N/A
VH=Very High H=High M=Medium L=Low VL=Very low Insig =
insignificant
N/A=
Not applicable
10.2. FINAL SITE MAP
The final site map of the proposed quarry has been included as Figure 4-1.
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10.3. SUMMARY OF THE POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS
OF THE PROPOSED ACTIVITY AND IDENTIFIED ALTERNATIVES
The majority of the impacts associated with the establishment and operation of the proposed quarry
would be largely localised, of long-term duration and of low intensity, and are considered to be of LOW
significance after mitigation. Key mitigation includes ensuring that the area of disturbance is limited to
what is absolutely necessary for the proposed operation, a detailed stormwater management plan is
developed and implemented, on-site pollution prevention measures are implemented and any complaints
received from third-parties are addressed in accordance with a formal complaints procedure.
One of the key issues associated with the proposed quarry operation relates to the loss of vegetation and
the related impacts on fauna and associated biodiversity. All vegetation within the quarry footprint would
be lost during the course of the operations. Approximately 22 ha of Degraded Primary Grassland and 29
ha of Secondary Grassland (of the ‘Vulnerable’ Ngongoni vegetation type) would be lost. Furthermore,
conservation-important plant species may be destroyed/damaged if measures are not taken to preserve
these plants. The loss of Ngongoni Veld and conservation-important species is considered to be a high
intensity impact, localised over the duration of the proposed quarry operations. As the loss of Ngongoni
Veld due to quarry establishment is accommodated in the approved Biodiversity Offset Report for the N2
Wild Coast Toll Highway (Botha & Brownlie, 2015), the requisite biodiversity offset would compensate for
the loss of the vegetation type. The residual impact is assessed to be of MEDIUM to HIGH significance.
With respect to noise impacts, it is anticipated that the proposed quarry would exceed the SANS
guidelines with respect to increasing ambient background noise levels in excess of 3 to 5 dBA. However,
as it is recommended that the homesteads closest to the quarry operations (i.e. within the project footprint
and associated 600m blast zone – see below) should be relocated, the closest receptors would be
located further away from noise sources associated with the proposed operations. The residual noise
impact of the proposed project is deemed to be of local extent, long-term duration, medium intensity and
MEDIUM significance.
The relocation of a single unmarked grave site located within the project footprint will be required, as well
as any graves which may be associated with homesteads to be relocated in the adjacent area. As human
remains have high heritage significance for their social value, the potential permanent, localised impact is
assessed to be of high intensity. By ensuring that all applicable legislative requirements, guidelines and
regulations applicable to the removal of human remains are implemented for the relocation of graves, it is
anticipated that the residual impact would be of MEDIUM significance.
Where basting activities associated with the proposed quarry operations lead to the damage of third party
property or injury of people or animals, the impact would be of high intensity at a local level and endure in
the medium term and is deemed to be of medium significance without mitigation. The blasting specialist
has indicated that the human response to the modelled ground vibration levels would be at an
“unpleasant” level up to 592 m of the boundary of the quarry footprint. Consequently, it is recommended
that the relocation of households within 600 m of the quarry boundary be considered. By relocating third-
parties outside of the project footprint and the blasting zone (a distance of 600 m, as recommended by
the blasting specialist), the significance of the residual impact would reduce to LOW.
Not going ahead with the proposed quarry operations (No-Go Alternative) would result in the
maintenance of the status quo. No change to the current impacts on terrestrial and freshwater
ecosystems, ambient air quality, noise, heritage and cultural resources, traffic and land uses is
anticipated. Furthermore, there would be NO IMPACT with respect to blasting hazards and the influx of
job seekers. However, not proceeding with the proposed project would result in the loss of direct and
indirect socio-economic benefits of the proposed project and lost economic opportunities related to costs
already incurred in the initial planning phase. This is considered to be of HIGH significance.
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11. PROPOSED IMPACT MANAGEMENT OBJECTIVES AND THE
IMPACT MANAGEMENT OUTCOMES FOR INCLUSION IN THE
EMPR
The impact management objectives and outcomes for inclusion in the EMPR are detailed under the
mitigation measures listed in Section 8.2 above.
12. FINAL PROPOSED ALTERNATIVES
The final proposed preferred alternatives for the proposed project entail the site layout plan included in
Figure 4-1 and the overall project description provided in Section 4.
13. ASPECTS FOR INCLUSION AS CONDITIONS OF
AUTHORISATION
Recommendations for any aspects that must be made a condition of the Environmental Authorisation are
included in in Section 14.3 below.
14. DESCRIPTION OF ANY ASSUMPTIONS, UNCERTAINTIES AND
GAPS IN KNOWLEDGE
The EIA assumptions and limitations are listed below:
• The Scoping and EIA assumes that SLR has been provided with all relevant project information
and that it was correct and valid at the time it was provided.
• Specialists have been provided with all the relevant project information in order to produce
accurate and unbiased assessments.
• There will be no significant changes to the project description or surrounding environment between
the completion of the EIR and implementation of the proposed project that could substantially
influence findings, recommendations with respect to mitigation and management etc.
• The blasting assessment is based, to a large extent, on a generic description of the proposed
quarrying activities, as the specific details were not available at the time of writing the blasting
impact report (e.g. exact timing and duration of blasts, sound levels, etc.).
These assumptions and limitations, however, are not considered to have any negative implications in
terms of the credibility of the results of the EIA process.
14.1. REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY
SHOULD OR SHOULD NOT BE AUTHORISED
The key principles of sustainability, including ecological integrity, economic efficiency, and equity and
social justice, are integrated below as part of the supporting rationale for providing an opinion on whether
the proposed project should or should not be approved.
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• Ecological integrity7
The potential disturbance of Ngongoni Veld and associated biodiversity is considered to be of high
intensity as all vegetation (and associated available habitat) within the quarry footprint would be
lost during the course of quarry operations. The area of disturbance (approximately 70 ha including
the proposed project footprint and associated access road) is considered to be relatively
substantial in comparison to the remaining intact area of this ‘Vulnerable’ vegetation type.
Furthermore, there are numerous conservation-important species present within the grassland
ecosystem at the site which may be destroyed/damaged if measures are not taken to preserve
these plants. By undertaking a plant search and rescue operation prior to the clearing of the site,
the impact on conservation-important species would be mitigated.
As the loss of Ngongoni Veld due to quarry establishment is accommodated in the approved
Biodiversity Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015), the loss of
this vegetation type within the project footprint would be compensated for and the overall
significance of the project impact on the conservation status of the vegetation type would be
reduced.
• Economic efficiency
The area surrounding the proposed quarry site is generally undeveloped with very limited socio-
economic opportunities. The proposed project would create local employment and business
opportunities. These potential benefits to the local economy would extend over the operational
lifespan of the proposed project. It is anticipated that a large number of the low- and semi-skilled
employment opportunities could be sourced from the local labour force, especially during the site
establishment phase. In terms of business opportunities for local companies, contract procurement
requirements would create business opportunities for the regional and local economy. A
percentage of the monthly wage bill earned by permanent staff would be spent in the regional and
local economy, which would benefit local businesses.
In light of the above, the proposed project is considered to be economically efficient, as it would
provide an opportunity to utilise natural resources within the Eastern Cape with associated socio-
economic benefits. With the recommended enhancement measures, any possible negative impact
associated with inward migration would be further reduced.
• Equity and social justice
While the proposed project would require the relocation of people residing within the project
footprint and the associated blasting zone (600m from the boundary of the quarry footprint), the
relocation would be undertaken by the appointed land management specialist in accordance with
the requirements of, amongst others, the Constitution of South Africa Act, 1996 (Act No. 108 of
1996) and the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996), as
applicable. These legislative provisions ensure, amongst others, that directly affected parties
receive fair and equitable treatment and that no person shall be worse off when compared to their
current situation.
It is the opinion of SLR that, in terms of the sustainability criteria described above and the nature and
extent of the proposed quarry activities, the generally LOW to MEDIUM significance residual impacts
should support a positive decision being made by the Minister of Mineral Resources (or delegated
authority) in this regard.
7 Ecological integrity is the abundance and diversity of organisms at all levels, and the ecological patterns, processes and structural
attributes responsible for that biological diversity and for ecosystem resilience.
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14.2. REASONS WHY THE ACTIVITY SHOULD BE AUTHORISED OR NOT
See rationale provided in Section 14.1 above as to why the proposed activity may be authorised.
14.3. CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION
14.3.1. SPECIFIC CONDITIONS TO BE INCLUDED INTO THE COMPILATION AND
APPROVAL OF EMPR
The following specific conditions are recommended:
• Ensure that the existing Biodiversity Offset Agreement for the N2 Wild Coast Toll Highway, which
accommodates the potential loss of primary Ngongoni Veld due to stockpiling and/or the
establishment of borrow pits/quarries, is implemented effectively.
• A protected plant survey must be undertaken within the primary terrestrial Ngongoni grassland
within the project footprint, in order to confirm the presence and abundance of threatened and
protected plant species. This survey must be undertaken by a suitably qualified botanist, prior to
the commencement of construction, during the summer growing season (between November and
March). The protected plant survey must be used to develop a detailed protected plant rescue and
translocation protocol for threatened and protected plants (based on the preliminary guidelines
provided in Section 5.4 of the specialist terrestrial ecological report, attached as Appendix 4.1).
• Undertake a Baseline Water Quality Monitoring Survey prior to the commencement of construction
activities in order to collect baseline data for the monitoring of water quality impacts associated with
construction and operation of the quarry.
• Develop a detailed Stormwater Management Plan that describes how the design measures of
surface and near-surface water management facilities will be designed, constructed and operated
so that contaminated water is kept separate from clean water run-off through a system of berms,
channels, trenches, flood and erosion protection measures.
• Relocate all households within the quarry footprint and 600 m from the quarry boundary.
• Monitor ground vibration and air blast to ensure that the generated levels of ground vibration and
air blast comply with recommendations. The monitoring of ground vibration must qualify the
expected ground vibration and air blast levels and assist in mitigating these aspects properly. Ten
monitoring positions have been proposed by the blasting specialist (see Figure 18 and Table 17 of
Appendix 4.3).
• Develop a comprehensive Rehabilitation and Closure Plan prior to the decommissioning and
closure of the proposed quarry operation.
14.3.2. REHABILITATION REQUIREMENTS
Requirements for rehabilitation have been outlined in Sections 4.5.3 (rehabilitation guidelines for the
access road crossing the KwaDlambu River) and 5.3.3 (rehabilitation guidelines for terrestrial habitat) of
the aquatic and terrestrial ecology specialist report (see Appendix 4.1). Notwithstanding the above, given
the long-term nature of the proposed operations, it is further recommended that a comprehensive
Rehabilitation and Closure Plan be developed prior to the decommissioning and closure of the proposed
quarry operation.
In summary, during rehabilitation, the topography would be finished off so that the sides of the quarry
area are shaped in accordance with the recommendations of the project engineer and contoured to
prevent rapid runoff of water that could cause soil erosion.
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Shaping of the quarry would provide flowing curves that blend with the surrounding landscape in
preference to sharp angles. Topsoil and mulched vegetation stripped during site clearance would be
spread evenly across the quarry area as soon as possible after each phase of extraction, where
applicable. For revegetation of the site, the ideal species for seeding would be mat-forming or tufted
pioneer grasses that can become quickly established at the site to provide immediate cover in order to
stabilise soils and reduce erosion risk. The initial pioneer grass cover (annuals) would then be replaced
by subclimax and climax grass species naturally occurring at the site, such as Aristida junciformis subsp.
junciformis, which will typically outcompete pioneer grasses over time through natural successional
processes. Recommended pioneer grasses for attaining an initial cover at disturbed sites (based on the
climate and soil occurring at the site) may include Cynodon dactylon (Couch grass), Chloris gayana
(Rhodes grass), Eragrostis tef and Urochloa mosambicensis (Bushveld signal grass).
14.3.3. PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED
The period for which the Environmental Authorisation is required would be for the total estimated Life of
Mine for the operations (15 years).
15. UNDERTAKING
The undertaking by the EAP is included in Appendix 4 of the main report.
16. FINANCIAL PROVISION
16.1. EXPLAIN HOW THE AFORESAID AMOUNT WAS DERIVED
In terms of Section 24P of NEMA and associated regulations pertaining to the financial provision
(GN No. R1147), an applicant for Environmental Authorisation must, before the Minister of Mineral
Resources issues the Environmental Authorisation, comply with the prescribed financial provision for the
rehabilitation, closure and ongoing post-decommissioning management of negative environmental
impacts.
SANRAL would discuss and conclude the nature and quantum of the financial provision required for the
management and remediation of environmental damage with DMR. It is understood that in terms of the
agreement between SANRAL and DMR, it is anticipated that the contract for the proposed works would
include a 10% retention (up to a limit of R1 million) which is to be withheld until all work (inclusive of a
rehabilitation work set out in the EMP) has been completed to the satisfaction of the engineering team
and DMR.
16.2. CONFIRM THAT THIS AMOUNT CAN BE PROVIDED FOR FROM
OPERATING EXPENDITURE
The estimated cost for the proposed rehabilitation would be included in the operational expenditure
planned for the proposed quarry operations.
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17. DEVIATIONS FROM THE APPROVED SCOPING REPORT AND
PLAN OF STUDY
17.1. DEVIATIONS FROM THE METHODOLOGY USED IN DETERMINING THE
SIGNIFICANCE OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS
This section is not applicable given that the impact assessment methodology used to determine the
significance of potential environmental impacts and risks in the EIR and EMP did not deviate from the
plan of study outlined in the Scoping Report.
17.2. MOTIVATION FOR THE DEVIATION
Not applicable.
18. OTHER INFORMATION REQUIRED BY THE COMPETENT
AUTHORITY
18.1. IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY
AFFECTED PERSON
The identified impacts on the socio-economic condition of directly affected persons and the proposed
mitigation measures to manage these impacts are provided in Section 8.2.2 above.
18.2. IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF
THE NATIONAL HERITAGE RESOURCES ACT
The identified potential impacts on cultural heritage resources and the proposed mitigation measures to
manage these impacts are provided in in Section 8.2.2.1 above.
19. OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A)
AND (B) OF THE ACT
No other matters are required in terms of Section 24(4)(A) and (B) of the Act.
PART B
FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME
REPORT
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1. FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME
REPORT
1.1. DETAILS OF THE EAP
Confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A as
required.
The contact details of the EAP who prepared this EIR and EMPR are provided in Section 1.1 of the EIR
(refer to Part A). The expertise of the individuals who prepared this EIR and EMPR are provided on
Page ii of Part A. The relevant curricula vitae and proof of registrations are provided in Appendix 1.
2. DESCRIPTION OF THE ASPECTS OF THE ACTIVITY
Description of the aspects of the activity. Confirm that the requirement to describe the aspects of the activity that are
covered by the environmental management programme is already included in PART A as required.
The description of the activities to be undertaken as part of the development of the proposed quarry is
included in Section 4 of the EIR.
3. COMPOSITE MAP
Provide a map (attached as an Appendix) at an appropriate scale which superimposes the proposed activity, its associated
structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be
avoided, including buffers.
A map showing the extent of the proposed quarry site, access road and associated infrastructure is
provided in Part A, Figure 4-1 of the EIR. The location of the identified vegetation communities and
protected plant species, as well as the identified surface water features and associated buffer areas, in
relation to the project footprint, are illustrated in Part A, Figures 8-2 and 8-3 of the EIR, respectively.
4. DESCRIPTION OF IMPACT MANAGEMENT OBJECTIVES
4.1. DETERMINATION OF CLOSURE OBJECTIVES
Ensure that the closure objectives are informed by the type of environment described.
The objectives for closure of the proposed quarry are to:
• Initiate a consultative process with the local community to identify and confirm a suitable end use
for the quarry, closer to the time of closure. It is currently proposed that the local community
would continue with the quarry operations following the completion of construction of the N2 Wild
Coast Toll Highway. The anticpated life of the quarry would be 15 years.
• Implement progressive rehabilitation, as far as possible, throughout the life of the quarry to reduce
the rehabilitation efforts required at the time of closure. These measures include:
o Rehabilitation and seeding / planting of areas where quarrying and surface activities
have ceased;
o Storing of sufficient quantities of topsoil (all available topsoil) for future rehabilitation
efforts;
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o Erosion prevention; and
o Stabilisation and re-shaping of eroded steep slopes on berms and stockpiles.
• Remove all product stockpiles.
• For all slopes:
o Investigate slope stability to determine the final safe / stable slope angle;
o The final profile of quarry slopes would depend on their overall stability, with due
consideration of factors such as pre-existing joints, fault patterns, and permeating ground
water (if any);
o Avoid long slopes, which could pose a safety hazard; and
o Seed slopes with mixed natural grass species as per the recommendations of the aquatic
and terrestrial ecology specialist.
• Discourage access to areas posing a safety hazard, in accordance with applicable legal and
regulatory requirements.
• Stabilise rehabilitated ground against wind and water erosion.
• Reduce residual impacts on surface water as well as landscape character.
• Establish self-sustaining natural vegetation cover on all disturbed areas.
4.2. THE PROCESS FOR MANAGING ANY ENVIRONMENTAL DAMAGE,
POLLUTION, PUMPING AND TREATMENT OF EXTRANEOUS WATER OR
ECOLOGICAL DEGRADATION AS A RESULT OF UNDERTAKING A
LISTED ACTIVITY
The mitigation measures outlined in Part A, Section 8.2 and in the Environmental Management
Programme (EMP) prepared for the construction and operational phases (see Appendix 6) have been
identified in order to manage and reduce impacts and prevent unnecessary damage to the environment
as a result of the proposed project. In the event that incidents that may result in environmental damage
occur, the emergency response procedure will be implemented to avoid pollution or degradation (see
Section 2.7 of the EMP). It is noted that due to the nature of the proposed quarry operations, the
“pumping and treatment of extraneous water“ is not required.
4.3. POTENTIAL RISK OF ACID MINE DRAINAGE
4.3.1. INDICATE WHETHER OR NOT THE MINING CAN RESULT IN ACID MINE
DRAINAGE
Not applicable. The proposed project does not include any activities which would result in acid mine
drainage.
4.3.2. STEPS TAKEN TO INVESTIGATE, ASSESS, AND EVALUATE THE IMPACT OF
ACID MINE DRAINAGE
Not applicable.
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4.3.3. ENGINEERING OR MINE DESIGN SOLUTIONS TO BE IMPLEMENTED TO AVOID
OR REMEDY ACID MINE DRAINAGE
Not applicable.
4.3.4. MEASURES THAT WILL BE PUT IN PLACE TO REMEDY ANY RESIDUAL OR
CUMULATIVE IMPACT THAT MAY RESULT FROM ACID MINE DRAINAGE
Not applicable.
4.4. VOLUMES AND RATE OF WATER USE REQUIRED FOR THE MINING,
TRENCHING OR BULK SAMPLING OPERATION
It is anticipated that a minimal volume of water would be required for the operation of the proposed quarry
(e.g. for dust suppression, potable water etc.). As noted in Part A, Section 4.2.4, water would be sourced
by the appointed contractor(s).
4.5. HAS A WATER USE LICENCE HAS BEEN APPLIED FOR?
The anticipated water use authorisation requirements of the proposed project are described in Part A,
Section 5.1.4 of the EIR. In this regard, a separate Water Use Licence Application will be submitted to
the Department of Water and Sanitation (DWS) Eastern Cape Regional Office for approval. Water
abstraction licensing / authorisation would need to be applied for / registered by the appointed
contactor(s).
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4.6. IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES
Measures to rehabilitate the environment affected by the undertaking of any listed activity
ACTIVITIES PHASE of operation in which activity will take place. State Planning and Design, Pre-Construction, Construction, Operational, Rehabilitation Closure.
SIZE AND SCALE OF DISTURBANCE Volumes, tonnages and hectares or m².
MITIGATION MEASURES Describe how each of the recommendations herein will remedy the cause of pollution or degradation and migration of pollutants.
COMPLIANCE WITH STANDARDS A description of how each of the recommendations herein will comply with any prescribed environmental management standards or practices that have been identified by Competent Authorities.
TIME PERIOD FOR IMPLEMENTATION Describe the time period when the measures in the environmental management programme must be implemented. Measures must be implemented when required. With regard to rehabilitation, specifically this must take place at the earliest opportunity.
Site selection and final
quarry layout
Planning and design Approximately 55 ha
for the proposed
quarry and 14.7 ha for
the proposed access
road
• The site layout plan has been amended based on
specialist recommendations in order to allow for
buffer areas between the quarry activities and
identified watercourses.
Specialist
recommendations (see
Appendix 4.1 to 4.3)
During EIA process
Site demarcation Pre-construction Individual footprints of
project components
• Demarcate the quarry site footprint using
appropriate fencing material.
• Areas outside of the development footprint and
operational area are to be considered sensitive ‘No-
Go’ areas.
Quarry plan and EMP
(see Sections 2.13.2
and 3.3 of the EMP
attached as Appendix 6)
During site establishment
Site clearance Site establishment
and access road
construction
Approximately 55 ha
for the proposed
quarry and 14.7 ha for
the proposed access
road
• Strip topsoil layer up to at least 300 mm where
possible and store separately.
• Keep seed-bearing material separate for use during
rehabilitation or preferably mulch vegetation into the
topsoil.
• Vegetation clearing shall take place in a phased
manner in order to retain vegetation cover for as
long as possible. This would reduce the size of
areas where dust can be generated and sediment
runoff may take place.
Quarry plan and EMP
(see Section 2.13.3 of
the EMP)
During site establishment
Stockpiling Operational Unknown at this stage,
but within the project
footprint
• Temporary stockpiling of excavated material shall
take place in demarcated areas.
• Stockpiles shall be positioned and sloped to create
the least visual impact and to reduce dust
generation.
Quarry plan and EMP
(see Section 3.3.2.4 of
the EMP)
During operational phase
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ACTIVITIES PHASE SIZE AND SCALE OF
DISTURBANCE
MITIGATION MEASURES COMPLIANCE WITH
STANDARDS
TIME PERIOD FOR
IMPLEMENTATION
Topsoil management Operational and
rehabilitation
Up to 300 mm depth
across the project
footprint
• Topsoil shall be stored separately and in stockpiles
not exceeding 2 m in height.
• Topsoil stockpiles shall be protected from erosion by
wind and rain by providing suitable stormwater and
cut off drains and/or by establishing suitable
temporary vegetation, if necessary.
• Topsoil stockpiles shall be monitored regularly to
identify and remove any alien plants.
Quarry plan and EMP
(see Sections 2.13.3.2
and 2.13.3.3 of the
EMP)
During site establishment and
operational phase
Blasting Operational Quarry footprint and
600 m blasting zone
• Relocate households outside of blasting zone. • Implementation of a blast management plan. • Pre-mining photographic crack survey. • Communication of planned blasting times with
stakeholders. • Pre-blast warning. • Monitoring blasts. • Audit and review to adjust blast design were
necessary. • Investigate blast-related complaints.
Quarry plan and EMP
(see Section 3.3.13.2 of
the EMP)
During operational phase
Transport Operational Unknown, but limited
to proposed access
roads and provincial
road network
• Vehicle movement shall be limited to defined tracks
and roads.
• Material from the quarry shall be appropriately
secured to ensure safe passage between
destinations.
• Movement of construction vehicles shall be limited
to daylight hours.
• Dangers associated with the movement of large
haulage vehicles shall be clearly sign-posted.
EMP (see Sections
2.13.1.1 and 3.3.11 of
the EMP)
During operational phase
Ablution facilities Operational Unknown at this stage,
but within the project
footprint
• The appointed contractor shall provide and maintain
adequate portable ablution facilities. These facilities
must be easily accessible and shall be secured in
order to prevent them from blowing over.
• Ablution facilities shall be located at least 32 m
away from the river systems and wetland areas.
• A suitable sub-contractor shall be appointed to
empty toilets on a regular basis.
EMP (see Section
2.13.1.2 of the EMP)
During operational phase
Refuelling and
maintenance
Operational Within project footprint • Should any refuelling of plant be required at the
quarry site, a drip tray shall be used.
• Ensure that there is always a supply of absorbent
material readily available in order to treat any minor
EMP (see Sections
2.13.5 and 3.3.3 of the
EMP)
During operational phase
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ACTIVITIES PHASE SIZE AND SCALE OF
DISTURBANCE
MITIGATION MEASURES COMPLIANCE WITH
STANDARDS
TIME PERIOD FOR
IMPLEMENTATION
hydrocarbon leaks or spills.
• Ensure that all vehicles and equipment are kept in
good working order and serviced regularly in order
to prevent hydrocarbon leaks.
Stormwater and soil
erosion
Operational and
rehabilitation
Within and downslope
of quarry footprint
• Develop a detailed Stormwater Management Plan
that describes the methodology for undertaking
construction of the stormwater infrastructure. The
stormwater plan should describe the design
measures surface and near surface water
management facilities will be designed, constructed
and operated so that contaminated water is kept
separate from clean water run-off through a system
of berms, channels, trenches, flood and erosion
protection measures.
• No stormwater run-off is to be routed directly to any
drainage lines.
EMP (see Sections
2.13.7 and 3.3.5 of the
EMP)
During operational phase and
rehabilitation
Changes to existing land
uses
Operational Within and in close
proximity to quarry
footprint
• Relocate all households within 600 m from the
quarry boundary outside of the project footprint and
assocaited blasting zone.
• Implement the EMP commitments with a view not
only to prevent and/or mitigate the various
environmental and social impacts, but also to
prevent negative impacts on surrounding land uses.
• If a situation arises where any surrounding land use
are negatively affected by the operations, the
contractor will immediately take steps to address the
cause of the impacts.
• Incorporate measures to achieve the future land use
plans for the project site during closure planning.
EMP (see Section 3.3.7
of the EMP)
During site establishment and
operational phase
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4.7. IMPACT MANAGEMENT OUTCOMES
A description of impact management outcomes, identifying the standard of impact management required.
ACTIVITY (e.g. excavations, blasting, stockpiles, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, roads, etc.)
POTENTIAL IMPACT (e.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc.)
ASPECTS AFFECTED
PHASE (e.g. Construction, commissioning, operational, decommissioning, closure)
SIGNIFICANCE (UNMITIGATED)
MITIGATION TYPE (modify, remedy, control, or stop through e.g. noise control measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc.)
Significance (mitigated)
Extent to which the impact can be avoided or addressed through the implementation of management measures
Refer to Part A, Section 9.1 of the EIR.
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4.8. IMPACT MANAGEMENT ACTIONS
A description of impact management actions, identifying the manner in which the impact management objectives and outcomes will be achieved.
ACTIVITY
(Whether listed or not listed e.g.
Excavations, blasting,
stockpiles, discard dumps or dams, loading, hauling and transport, water supply dams
and boreholes, accommodation, offices, ablution, stores, workshops, processing plant,
storm water control, berms, roads, pipelines, etc.).
POTENTIAL IMPACT
(E.g. Dust, noise, drainage surface disturbance, fly rock, surface water contamination,
groundwater contamination, air pollution etc.).
MITIGATION TYPE
(Modify, remedy, control, or stop through e.g. noise control measures, storm-water control, dust control,
rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc.).
TIME PERIOD FOR IMPLEMENTATION
(Describe the time period when the measures in the environmental management programme must be implemented. Measures must be
implemented when required. With regard to rehabilitation specifically this must take place at the earliest opportunity. State either: upon
cessation of the individual activity or upon the cessation of mining, bulk sampling or alluvial diamond prospecting as the case may be.)
COMPLIANCE WITH STANDARDS (A description of how each of the recommendations will comply with any prescribed environmental management standards or practices that have been identified by Competent Authorities.)
Site preparation (includes,
site demarcation, site
access, vegetation clearing
etc.)
Loss of natural vegetation
and faunal habitat due to
site clearing
As per measures included in the
table provided in Section 9.1 of
the EIR and the EMP attached as
Appendix 6.
At commencement of site establishment
and construction of access road EIR and EMP
Soil erosion
Excavation
Surface water
contamination
As per measures included in the
table provided in Section 9.1 of
the EIR and the EMP attached as
Appendix 6.
For the duration of operational phase EIR and EMP
Air Quality
Noise
Heritage / archaeology
Land use
Job creation
Blasting
Air Quality As per measures included in the
table provided in Section 9.1 of
the EIR and the EMP attached as
Appendix 6.
For the duration of operational phase EIR and EMP
Applicable norms and standards Noise
Land use
Storage of excavated
material (stockpiling etc.)
Air Quality As per measures included in the
table provided in Section 9.1 of
the EIR and the EMP attached as
Appendix 6.
For the duration of operational phase EIR and EMP
Soil pollution
Surface water
contamination
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ACTIVITY POTENTIAL IMPACT MITIGATION TYPE TIME PERIOD FOR IMPLEMENTATION COMPLIANCE WITH STANDARDS
Transport of resource
(loading, hauling, roads etc.)
Traffic safety and access As per measures included in the
table provided in Section 9.1 of
the EIR.
At commencement of site establishment
and for the duration of operational phase EIR and EMP
Air Quality
Rehabilitation and closure
(shaping, removal of
infrastructure, spreading of
topsoil etc.)
Unsuccessful rehabilitation
resulting in poor vegetation
cover, erosion, loss of
grazing and cultivation
potential etc.
As per measures included in the
table provided in Section 9.1 of
the EIR.
Immediately after completion of material
extraction and during final closure
activities
EIR and EMP
Approved Rehabilitation and
Closure Plan
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5. FINANCIAL PROVISION
5.1. DETERMINATION OF THE AMOUNT OF FINANCIAL PROVISION
5.1.1. DESCRIBE THE CLOSURE OBJECTIVES AND THE EXTENT TO WHICH THEY
HAVE BEEN ALIGNED TO THE BASELINE ENVIRONMENT DESCRIBED UNDER
REGULATION 22 (2) (D)
The objectives for closure of the proposed quarry are outlined in Section 4.1 above. The main closure
objective is to ensure that the quarry footprint would be shaped and rehabilitated in order to allow for the
establishment of natural vegetation over time or, where applicable, the facilitation of the end land use
identified for the site during detailed closure planning.
5.1.2. CONFIRM SPECIFICALLY THAT THE ENVIRONMENTAL OBJECTIVES IN
RELATION TO CLOSURE HAVE BEEN CONSULTED WITH LANDOWNER AND
INTERESTED AND AFFECTED PARTIES
Proof of consultation with I&APs is provided in Part A, Section 7.2 of the EIR. No specific comments
relating to the environmental objectives for closure have been received.
5.1.3. PROVIDE A REHABILITATION PLAN THAT DESCRIBES AND SHOWS THE
SCALE AND AERIAL EXTENT OF THE MAIN MINING ACTIVITIES, INCLUDING
THE ANTICIPATED MINING AREA AT THE TIME OF CLOSURE
Given the long-term nature of the proposed operations, it is recommended that a comprehensive
Rehabilitation and Closure Plan be developed prior to the decommissioning and closure of the proposed
quarry operation. The scale and aerial extent of the proposed quarry at closure is provided in Part A,
Figure 4-1 of the EIR.
Notwithstanding the above, the specific requirements for rehabilitation have been outlined in
Sections 4.5.3 (rehabilitation guidelines for the access road crossing the KwaDlambu River) and 5.3.3
(rehabilitation guidelines for terrestrial habitat) of the aquatic and terrestrial ecology specialist report (see
Appendix 4.1).
5.1.4. COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE
OBJECTIVES
The rehabilitation measures outlined in the aquatic and terrestrial ecology specialist report (as noted
above) are considered to be compatible with the closure objectives identified for the site.
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5.1.5. CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION
REQUIRED TO MANAGE AND REHABILITATE THE ENVIRONMENT IN
ACCORDANCE WITH THE APPLICABLE GUIDELINE
In terms of Section 24P of NEMA and associated regulations pertaining to the financial provision (GN No.
R1147), an applicant for Environmental Authorisation must, before the Minister of Mineral Resources
issues the Environmental Authorisation, comply with the prescribed financial provision for the
rehabilitation, closure and ongoing post decommissioning management of negative environmental
impacts.
SANRAL would discuss and conclude the nature and quantum of the financial provision required for the
management and remediation of environmental damage with DMR. It is understood that in terms of the
agreement between SANRAL and DMR, it is anticipated that the contract for the proposed works would
include a 10% retention (up to a limit of R 1 million) which is to be withheld until all work (inclusive of all
rehabilitation work set out in the EMP) has been completed to the satisfaction of the engineering team
and DMR.
5.1.6. CONFIRM THAT THE FINANCIAL PROVISION WILL BE PROVIDED AS
DETERMINED
The estimated cost for the proposed rehabilitation would be included in the operational expenditure
planned for the proposed quarry operations.
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6. MECHANISMS FOR MONITORING COMPLIANCE WITH AND PERFORMANCE ASSESSMENT
AGAINST THE ENVIRONMENTAL MANAGEMENT PROGRAMME AND REPORTING THEREON Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including a) Monitoring of Impact Management Actions; b) Monitoring and reporting frequency; c) Responsible persons; d) Time period for implementing impact management actions; and e) Mechanism for monitoring compliance.
The functional requirements for monitoring have been listed below with further details being provided in the EMP for the construction and operational phases (see
Appendix 6).
SOURCE ACTIVITY IMPACTS REQUIRING
MONITORING
PROGRAMMES
FUNCTIONAL REQUIREMENTS FOR
MONITORING
ROLES AND
RESPONSIBILITIES
(for the execution of the
monitoring programmes)
MONITORING AND REPORTING FREQUENCY
AND TIME PERIODS FOR IMPLEMENTING
IMPACT MANAGEMENT ACTIONS
Authorisation and
administration
Relevant
authorisations,
registrations and
permits are in place
• Ensure that all relevant authorisations and
permits have been obtained (e.g. Water Use
Authorisation, blasting etc.).
• Ensure that a copy of the EIR and EMP are
provided to all relevant stakeholders and kept
on-site.
Applicant Prior to site establishment
Site preparation Site establishment,
demarcation,
vegetation clearing, soil
erosion
• Site demarcation, fencing and identification of
no-go areas.
• Provision of appropriate ablution facilities and
eating areas.
• Vegetation and topsoil clearing.
• Soil erosion due to vegetation clearing.
ECO, Resident Engineer,
appointed Contractor,
Environmental Officer
(EO)
During site establishment
Daily monitoring by the Contractor’s designated
EO and monthly auditing by ECO
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SOURCE ACTIVITY IMPACTS REQUIRING
MONITORING
PROGRAMMES
FUNCTIONAL REQUIREMENTS FOR
MONITORING
ROLES AND
RESPONSIBILITIES
(for the execution of the
monitoring programmes)
MONITORING AND REPORTING FREQUENCY
AND TIME PERIODS FOR IMPLEMENTING
IMPACT MANAGEMENT ACTIONS
Excavation
Surface water
contamination • Maintain designated buffer areas from
identified surface water features (refer to
Figure 8-3 of the EIR).
• Prevent contaminated run-off from entering
surface water features.
• Maintenance of machinery and equipment,
refuelling, supply of absorbent material, leaks
and spills.
EO, ECO, Quarry
Operator and
Environmental Site
Officer (ESO)
Daily monitoring during operational phase (Quarry
Operator and ESO)
Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
ESO)
Dust
• Dust suppression measures.
• Securing of material loads during
transportation and compliance with speed
limits.
ECO, EO, and ESO Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
ESO)
Noise • Compliance with local by-laws and regulations
regarding the generation of noise and hours of
operation.
ECO, EO, and ESO Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
ESO)
Blasting • Monitor compliance with blast management plan.
• Audit and review to adjust blast design. • Investigate blast-related complaints.
Quarry Operator and
ESO
Operation (as required by ESO)
Heritage / archaeology • Notify the SAPS and ECPHRA or SAHRA
should human remains be uncovered.
ECO, EO, ESO Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
ESO)
Land use • Site to be rehabilitated in line with closure
objectives and in consultation with local
community.
Applicant and Quarry
Operator
During decommissioning and closure phase
Fire hazard • Avoid damage to surrounding private property
and infrastructure due to runaway fires by
ensuring that the necessary fire prevention
measures are in place.
ECO, EO, and ESO Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
ESO)
Storage of material
(stockpiling etc.)
Waste management • Avoid pollution from inappropriate solid waste
and wastewater management.
EO, ECO, Quarry
Operator and ESO
Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
Quarry Operator and ESO)
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SOURCE ACTIVITY IMPACTS REQUIRING
MONITORING
PROGRAMMES
FUNCTIONAL REQUIREMENTS FOR
MONITORING
ROLES AND
RESPONSIBILITIES
(for the execution of the
monitoring programmes)
MONITORING AND REPORTING FREQUENCY
AND TIME PERIODS FOR IMPLEMENTING
IMPACT MANAGEMENT ACTIONS
Dust from stockpiles • Appropriate storage of excavated material
stockpiles and dust suppression measures.
EO, ECO, Quarry
Operator and ESO
Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
Quarry Operator and ESO)
Loss or contamination
of topsoil
• Appropriate management and monitoring of
topsoil stockpiles.
EO, ECO, Quarry
Operator and ESO
Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
Quarry Operator and ESO)
Transport of resource
(loading, hauling,
roads etc.)
Traffic safety and
access
• Traffic safety measures linked to vehicle
speed, access route etc.
EO, ECO, Quarry
Operator and ESO
Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
Quarry Operator and ESO)
Loss of material from
haul vehicles
• Appropriately secure material loads to ensure
safe passage between destinations.
ECO, EO, and ESO Construction (daily monitoring by the EO and
monthly auditing by ECO) and Operation (daily by
ESO)
Rehabilitation and
closure
Rehabilitation success • Rehabilitation of quarry is to be undertaken in
a phased manner, wherever possible, and in
accordance with an approved rehabilitation
plan.
Applicant and Quarry
Operator
During decommissioning and closure phase
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6.1. INDICATE THE FREQUENCY OF THE SUBMISSION OF THE
PERFORMANCE ASSESSMENT REPORT
Performance Assessment Reports, as required by the NEMA EIA Regulations 2014, would be prepared
and submitted every two years to DMR or as often as requested by DMR.
In addition, the appointed ECO would undertake regular site audits during the site establishment /
construction phase (see Section 2.12 of the EMP). Copies of the site audits reports could be submitted to
DMR if requested.
7. ENVIRONMENTAL AWARENESS PLAN
7.1. MANNER IN WHICH THE APPLICANT INTENDS TO INFORM HIS OR HER
EMPLOYEES OF ANY ENVIRONMENTAL RISK WHICH MAY RESULT
FROM THEIR WORK
Before the commencement of any activities at the site, the appointed Contractor's site management staff
should attend an environmental awareness-training course (see Section 2.6 of the EMP for contents of
the training course).
7.2. MANNER IN WHICH RISKS WILL BE DEALT WITH IN ORDER TO AVOID
POLLUTION OR THE DEGRADATION OF THE ENVIRONMENT
Risks would be managed and environmental impacts prevented or minimised by the implementation of
the recommended mitigation measures and EMP (Appendix 6). SANRAL would be responsible for the
implementation of the required mitigation measures in order to avoid pollution or degradation of the
environment. Appropriate implementation of the recommended mitigation measures and EMP would be
monitored through regular site audits during site establishment and operation.
8. SPECIFIC INFORMATION REQUIRED BY THE COMPETENT
AUTHORITY
Among others, confirm that the financial provision will be reviewed annually
The financial provision as set out above would be reviewed on an annual basis or as requested by DMR.
9. UNDERTAKING
Refer to Appendix 6 of the main report.