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BASIC ASSESSMENT REPORT

and

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT SUBMITTED FOR ENVIRONMENTAL AUTHORISATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (NEMA) IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY A MINING PERMIT APPLICATION IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA).

DMR Reference Number: (WC) 30/5/1/3/2/ 10161MP Type of application: Application for a mining permit Applicant: Tip Trans Resources (Pty) Ltd Property: Remainder of the farm Langeberg 188, Vredenburg Magisterial District Local authority: Saldanha Bay Municipality Date: 7 March 2018

Remainder of the farm Langeberg 188: Basic Assessment Report and EMPr

Tip Trans Resources (Pty) Ltd 2

IMPORTANT NOTICE

In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”. Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment. In terms of section 16(3)(b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of section 17 (1) (c) the competent Authority must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the competent authority to the submission of applications. It is therefore an instruction that the prescribed reports required in respect of applications for an environmental authorisation for listed activities triggered by an application for a right or a permit are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the Environmental Authorisation being refused. It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the Report, in the order, and under the provided headings as set out below, and ensure that the report is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.



THE OBJECTIVE OF THE BASIC ASSESSMENT PROCESS (As described in Appendix 1 of the EIA Regulations, 2014)

The objective of the basic assessment process is to, through a consultative process─ (a) determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context; (b) identify the alternatives considered, including the activity, location, and technology alternatives; (c) describe the need and desirability of the proposed alternatives, (d) through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage , and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to determine:

(i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and (ii) the degree to which these impacts—

(aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be managed, avoided or mitigated;

(e) through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity to—

(i) identify and motivate a preferred site, activity and technology alternative; (ii) identify suitable measures to manage, avoid or mitigate identified impacts; and (iii) identify residual risks that need to be managed and monitored.

NOTE ON THE SCOPE AND CONTENT OF BASIC ASSESSMENT REPORTS AND THE CONTENTS OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

The scope and content of Basic Assessment Reports and the contents of Environmental Management Programmes are specified in Appendix 1 and Appendix 4 of the Environmental Impact Assessment Regulations, 2014 (as amended). Where relevant, extracts from the EIA Regulations, 2014 are shown in italics below each heading in this report. Note: The amendments of the EIA Regulations, 2014 commenced on 7 April 2017. These were published in the following government notices:

GN R326 – Amendments to the Environmental Impact Assessment Regulations, 2014

GN R327 – Amendment of Listing Notice 1 of 2014





BAR & EMPr

TABLE OF CONTENTS 1. CONTACT PERSON & CORRESPONDENCE ADDRESS ................................................. 7

1.1 Details of the Environmental Assessment Practitioner .................................................. 7 1.2 The expertise of the EAP, including a curriculum vitae ................................................. 7 1.3 RECENT CONTRACTS ............................................................................................... 8

2. LOCATION OF THE ACTIVITY ........................................................................................... 9 3. PLANS .............................................................................................................................. 10 4. DESCRIPTION OF THE PROPOSED ACTIVITIES ........................................................... 13

4.1 The scope of the proposed activities .......................................................................... 13 5. POLICY & LEGISLATIVE CONTEXT ................................................................................ 14 6. NEED & DESIRABILITY OF THE PROPOSED ACTIVITIES ............................................. 16 7. A MOTIVATION FOR THE PREFERRED SITE, ACTIVITY & ALTERNATIVE .................. 21 8. PUBLIC PARTICIPATION PROCESS ............................................................................... 22

8.1 Details of the public participation process ................................................................... 22 8.2 Summary of the issues raised by interested & affected parties ................................... 22

9. PROCESS TO REACH THE PROPOSED PREFERRED ALTERNATIVE......................... 23 9.1 Details of the alternatives considered ......................................................................... 23 9.2 The environmental attributes associated with the alternatives (i.e. the Baseline Environment) ........................................................................................................................ 26 9.3 The impacts and risks identified for each alternative .................................................. 32 9.4 The method used in determining significance of potential impacts ............................. 34 9.5 The positive & negative impacts that the proposed activity and alternatives will have 36 9.6 The possible mitigation measures that could be applied ............................................. 36 9.7 The outcome of the site selection matrix .................................................................... 36 9.8 Motivation where no alternatives were considered ..................................................... 36 9.9 Concluding statement on alternatives ......................................................................... 36

10. SPECIALIST FINDINGS ................................................................................................ 38 10.1 Soil and agricultural potential...................................................................................... 38 10.2 Groundwater .............................................................................................................. 38 10.3 Heritage resources ..................................................................................................... 39

11. ENVIRONMENTAL IMPACT ASSESSMENT................................................................. 40 11.1 Soil and agricultural potential...................................................................................... 40 11.2 Water resources ......................................................................................................... 41 11.3 Biodiversity ................................................................................................................. 43 11.4 Dust............................................................................................................................ 44 11.5 Noise .......................................................................................................................... 44 11.6 Solid waste ................................................................................................................. 45 11.7 Heritage Resources .................................................................................................... 46 11.8 Socio-economic .......................................................................................................... 49 11.9 Cumulative impacts .................................................................................................... 50

12. “NO GO” ALTERNATIVE ............................................................................................... 51 12.1 Socio-economic .......................................................................................................... 51

13. ENVIRONMENTAL IMPACT STATEMENT ................................................................... 52 13.1 Summary of the key findings of the environmental impact assessment ...................... 52 13.2 Final site map ............................................................................................................. 53 13.3 Summary of the positive and negative impacts and risks ............................................ 53 13.4 Proposed impact management objectives and outcomes ........................................... 53 13.5 Proposed conditions of authorisation .......................................................................... 54 13.6 Assumptions, uncertainties and gaps in knowledge .................................................... 54 13.7 Reasoned opinion of the EAP..................................................................................... 55



13.8 Period for which the environmental authorisation is required ...................................... 55 13.9 Undertaking by the EAP ............................................................................................. 55

14. FINANCIAL PROVISION ............................................................................................... 56 15. ANY OTHER SPECIFIC INFORMATION ....................................................................... 56 16. EMPr: INTRODUCTION ................................................................................................ 57

16.1 Details and expertise of the EAP ................................................................................ 57 16.2 Description of the aspects of the activity that are covered by the EMPr ...................... 57 16.3 Site map ..................................................................................................................... 57

17. IMPACT MANAGEMENT OBJECTIVES ........................................................................ 57 17.1 Closure and environmental objectives ........................................................................ 57 17.2 Closure ....................................................................................................................... 58 17.3 Impact management outcomes .................................................................................. 58

18. IMPACT MANAGEMENT ACTIONS .............................................................................. 59 18.1 Introduction ................................................................................................................ 59 18.2 Responsibility ............................................................................................................. 59 18.3 Demarcation of the mining area .................................................................................. 59 18.4 Community relations ................................................................................................... 59 18.5 Topsoil ....................................................................................................................... 59 18.6 Mining depth ............................................................................................................... 60 18.7 Rehabilitation and storm water control ........................................................................ 60 18.8 Control of invasive alien vegetation ............................................................................ 61 18.9 Protection of animal life .............................................................................................. 61 18.10 Illegal Dumping of Rubble ....................................................................................... 61 18.11 Dust ........................................................................................................................ 62 18.12 Noise ...................................................................................................................... 62 18.13 Maintenance and fuel.............................................................................................. 62 18.14 Solid Waste Management ....................................................................................... 63 18.15 Effluents.................................................................................................................. 63 18.16 Toilets ..................................................................................................................... 63 18.17 Road Safety and Access ......................................................................................... 63 18.18 Heritage Resources ................................................................................................ 64 18.19 Environmental Related Emergencies and Remediation .......................................... 64

19. MONITORING & REPORTING ...................................................................................... 66 19.1 Introduction ................................................................................................................ 66 19.2 Dust............................................................................................................................ 66

20. ENVIRONMENTAL AWARENESS PLAN ...................................................................... 67 21. UNDERTAKING BY THE EAP ....................................................................................... 68 LIST OF FIGURES

Figure 1: Locality plan .............................................................................................................. 10 Figure 2: Plan of the land ......................................................................................................... 11 Figure 3: Mining layout plan...................................................................................................... 12 Figure 4: Critical Biodiversity Areas (CBA) map of the area. ..................................................... 28



LIST OF TABLES

Table 1: Comment – response summary table ......................................................................... 23 Table 2: Key Statistics 2011 for the Saldanha Bay Municipal area ........................................... 29 Table 3: Potential impacts and risks associated with the preferred alternative .......................... 32 Table 4: Potential impacts and risks associated with the “no-go” alternative ............................. 33 Table 5: Nature and type of impact ........................................................................................... 34 Table 6: Criteria for the assessment of impacts ........................................................................ 34 Table 7: Significance rating ...................................................................................................... 35 Table 8: Probability, confidence, reversibility and irreplaceability .............................................. 35 Table 9: Soil and agricultural potential: summary of impact assessment .................................. 40 Table 10: Water resources: summary of impact assessment .................................................... 42 Table 11: Biodiversity: summary of impact assessment ............................................................ 43 Table 12: Dust: summary of impact assessment ...................................................................... 44 Table 13: Noise: summary of impact assessment ..................................................................... 45 Table 14: Solid waste: summary of impact assessment ............................................................ 45 Table 15: Archaeological Resources: summary of impact assessment ..................................... 47 Table 16: Palaeontological Resources: summary of impact assessment .................................. 47 Table 17: Cultural landscape: summary of impact assessment ................................................ 47 Table 18: Socio-economic: summary of impact assessment ..................................................... 49 Table 19: Socio-economic: summary of assessment of the “no go” alternative ......................... 51 Table 20: Comparative assessment of alternatives .................................................................. 52 Table 21: Itemisation of the quantum of the financial provision ................................................. 56 Table 22: Acceptable dust fall rates .......................................................................................... 66

LIST OF APPENDICES Appendix 1: Public participation report

Appendix 2: Specialist agricultural impact assessment

Appendix 3: Specialist groundwater assessment

Appendix 4a: Heritage impact assessment

Appendix 4b: Palaeontological assessment

Appendix 5: Environmental awareness handout



PART A: BASIC ASSESSMENT REPORT

1. CONTACT PERSON & CORRESPONDENCE ADDRESS

1.1 Details of the Environmental Assessment Practitioner

ITEM CONTACT DETAILS

Name of the EAP: Barry Wiesner

Company: Amathemba Environmental Management Consulting CC

Postal address: 24 Hiddingh Road, Bergvliet, 7945

Mobile no: 082 463 6221

Fax no: 086 672 7238

E-mail: [email protected]

Web site: www.amathemba.com

1.2 The expertise of the EAP, including a curriculum vitae

A summarised CV of the EAP (including qualifications and past experience) is provided below: EDUCATION M. Phil (Environmental Management) University of Cape Town 2001 B.Th UNISA 1995 H.D.E. (Sec) University of Cape Town 1987 B.A (Engeo & Archaeology) University of Cape Town 1986 PROFESSIONAL EXPERIENCE Barry completed a MPHIL in Environmental Management at the University of Cape Town. Barry

also has read a BA majoring in Archaeology and Environmental and Geographical Science and

has a Higher Diploma in Education (HDE) from the University of Cape Town. He also has a

Bachelor of Theology from the University of South Africa. Barry is a Green Star SA Accredited

Professional and is a member of the International Association of Impact Assessment (IAIAsa).

Barry has extensive site experience working as an Environmental Control Officer at major

construction sites and in conducting Environmental Audits, EIAs, BARs and the compilation of

numerous Environmental Management Programmes (EMP) over the last twelve years. Barry

has recently and is still currently involved as ECO with three 75 MW static Solar farms and two

144MW Wind Energy Facilities.

mailto:[email protected]

http://www.klipberg.co.za/



1.3 RECENT CONTRACTS

Khobab and Loeriesfontein Wind Energy Facilities

Lesedi, Letsasti and Jasper 75MW Solar Farms

Environmental Audits and EIA for Mothae Diamond mine, Lesotho

WACS ECO for South Africa Landing

Solar and wind farm renewable energy EIAs

SMART Living Handbook for City of Cape Town

A review of the Construction Environmental Management Plan (CEMP) for the Coega

Development Corporation in Port Elizabeth

EMP for Umhlanga Ridge New Town Centre

Scoping Report and the EIA for the establishment of Caledon Flight Park.

Welbeloond commercial, retail, industrial and Residential development, Cape Town

Environmental Control Officer supervision and auditing of large construction sites

(including One and Only Hotel and Spa, Grand West Casino, Worcester Casino,

Tygerfalls, Cape Gate, and the Helderberg Coastal Sewer.

PROFESSSIONAL AFFILIATIONS

Member of the International Association for Impact Assessment (IAIAsa)

Accredited Professional with the Green Building Council of South Africa



2. LOCATION OF THE ACTIVITY Full particulars of the applicant:

ITEM CONTACT DETAILS

Name of the Applicant: Tip Trans Resources (Pty) Ltd

Tel no: 021 971 1404

Fax no: 086 762 5875

Cellular no: 082 553 3240

Contact person: Pieter Visser

E-mail address: [email protected]

Postal address: PO Box 272, Moorreesburg, 7310

Physical address: Klipheuwel Park, Malmesbury Road (R302), Klipheuwel

Registered description of the land:

Registered Property Name: Remainder of the farm Langeberg 188

Local Authority: Saldanha Bay Municipality

Magisterial District: Vredenburg Magisterial District

Extent of the property: 618 hectares

Extent of mining permit application area:

5 hectares

Landowner: Eye of the Public Advertising CC

Address: Anyskop Farm, West Coast Road (R27) Vredenburg, 7380

LPI 21-digit codes: C04600000000018800000

Distance and direction from the nearest town

14km south-east of Vredenburg. 2.5km east of the R27 (West Coast Road)

mailto:[email protected]



3. PLANS The location of the farm is shown in Figure 1, the plan of the land in Figure 2 and the mining layout plan in Figure 3.

Figure 1: Locality plan

The Remainder of the farm Langeberg 188 is located approximately 14km south-east of Vredenburg, 2.5km east of the R27 (West Coast Road).



Figure 2: Plan of the land



Figure 3: Mining layout plan



4. DESCRIPTION OF THE PROPOSED ACTIVITIES

4.1 The scope of the proposed activities

4.1.1 Listed and specified activities applied for

Listing Notice

Activity no. Description

LN1 21 Any activity including the operation of that activity which requires a mining permit in terms of section 27 of the MPRDA, 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.

LN1 22 The decommissioning of any activity requiring - (i) a closure certificate in terms of section 43 of the MPRDA; or (ii) a mining permit 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.

LN1 28 Commercial or industrial developments where such land was used for agriculture on or after 01 April 1998 and where such development: (ii) will occur outside an urban area, where the total land to be developed is bigger than 1 hectare.

4.1.2 Description of the activities to be undertaken

The sand and calcrete will be used for road construction projects. The site is located in totally transformed land (see Figures 2 and 3).

The proposed mining sequence is as follows:

The mining permit area will be divided into 8 mining blocks. The mining blocks will vary in extent from 0.5 hectares to 0.8 hectares.

Only one block at a time will be mined.

Overburden clearing and stockpiling of topsoil.

Loading of sand and weathered calcrete into trucks using an excavator.

The average estimated depth of the proposed excavation is approximately 3 metres below surface.

Recording volumes in trucks.

Final rehabilitation of slopes to not more than 1:3. Levelling the final floor, replacing topsoil, stabilising the soil surface and rehabilitating the area so that it can continue to be used for agricultural purposes.



5. POLICY & LEGISLATIVE CONTEXT Applicable legislation, policies, plans, guidelines, spatial tools and municipal IDPs that are applicable

Reference where applicable

How the proposed activity complies with and responds to the policy and legislative context

National Environmental Management Act (NEMA), 1998 (Act No. 107 of 1998).

This BAR and EMPr. The application for environmental authorisation, the compilation of this Basic Assessment Report and the Public Participation Process are required in terms of NEMA.

EIA Regulations, 2014 (GN R324 – R327)

This BAR and EMPr. The listed activities that are triggered determine the Environmental Authorisation (EA) application process to be followed.

National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004)

Section 9.2.6 Section 11.3

There are no Critical Biodiversity Areas on the site.

National Environmental Management: Air Quality Act, 2004 (Act 39 of 2004). National Dust Control Regulations in GN R827 of 1 November 2013

Section 11.4 Section 18.11 Section 19.2

Dust control measures are included in the EMPr

Mineral and Petroleum Resources Development Act, 2008 (Act 28 of 2002)

Section 4 An application for a mining permit in terms of section 27 was submitted to the DMR. This determines that the DMR is the Competent Authority (CA) for this NEMA application.

Mine Health and Safety Act, 1996 (Act 29 of 1996)

Section 11.4 and 11.5 The objects of the MHSA are to protect the health & safety of mine workers. All mining activities described in this report must comply with the MHSA.

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

Section 11.7 A full HIA has been undertaken.

Promotion of Administrative Justice Act, 2000 (Act 3 of 2000)

Decision by the Competent Authority

Gives effect to section 33 of the Constitution that requires that “Everyone has the right to administrative action that is lawful, reasonable and procedurally fair”

Land Use Planning Act, 2014 (Act 3 of 2014) (LUPA)

Section 6 Consent use in terms of the Saldanha Bay Municipal Planning By-Law, 2015 is required to permit mining on properties that are zoned for Agricultural purposes (AG)

Saldanha Bay Municipality – Integrated Development Plan (IDP)

Section 6 The “Need & Desirability” of the project is described with respect to the IDP.



Saldanha Bay Municipality – Spatial Development Framework.

Section 6 The “Need & Desirability” of the project is described with respect to the SDF.

DEA and DEA&DP Guidelines e.g. Need & Desirability, Public Participation, Using Specialists and Alternatives.

This BAR and EMPr The relevant DEA and DEA&DP guidelines were used to compile this report, conduct the Public Participation Process (PPP) process and to guide specialist input.



6. NEED & DESIRABILITY OF THE PROPOSED ACTIVITIES The “Need & Desirability“ of the project is described by answering the same questions that are required by the Western Cape Provincial Department of Environmental Affairs & Development Planning (DEA&DP). Q1. Is the activity permitted in terms of the property’s existing land use rights?

Yes No

Explain: The property is zoned for Agricultural purposes by the Saldanha Bay Municipality. Land use approval from the Saldanha Bay Municipality (SBM) is required to allow sand and calcrete mining on the properties.

Q2. Will the activity be in line with the following? (a) Provincial Spatial Development Framework (PSDF)? Yes No

Explain: The PSDF (2014) promotes sustainable farming and mining (i.e. activities that generate positive socio-economic returns and do not pose significant risks to the environment). The applicable policy is listed below. Policy R3: Safeguard the Western Cape’s Agricultural and Mineral Resources and manage their sustainable use: 1. Record unique and high potential agricultural land in municipal SDFs, demarcate urban edges to protect these assets, and adopt and apply policies to protect this resource. Response The Agricultural Impact Assessment conducted by Soil Scientist Johann Lanz confirmed that the site does not consist of unique and high potential agricultural land. 2. Record the location of mineral deposits and known reserves of construction materials in municipal SDFs, and introduce and apply land use policies that reserve these assets for possible use (subject to environmental authorization). Response The 2017 draft Saldanha Bay SDF includes a description of some mineral deposits (e.g. phosphate) but fails to provide for construction materials in the municipal area. 3. Use transformed areas first for new farming and mining ventures. Response The proposed mining permit area is located on transformed land. (b) Urban edge / Edge of built environment? Yes No

Explain: The property is located outside the urban edge. The area will be rehabilitated so that it can continue to be used for agricultural purposes. The proposed small-scale mining project will have no impact on the urban edge. (c ) Integrated Development Plan (IDP) of the Municipality Yes No

Explain: The Mission of the SBM Municipality as described in the 2017-2022 IDP is as follows:



The following mission statement has been adopted by the Council to guide the actions of the Municipality, spell out its overall goal, provide a path, and guide decision-making. It serves to provide the framework or context within which the Council’s strategies are formulated. SBM is a caring institution that excels through:

Accelerated economic growth for community prosperity.

Establishment of high quality and sustainable services.

Commitment to responsive and transparent governance.

The creation of a safe and healthy environment.

Long term financial sustainability.

The provision of sand and weathered calcrete by Tip Trans Resources (Pty) Ltd will utilise the riches of the land in a sustainable manner, because the land will continue to be used for agricultural purposes after the sand and calcrete has been mined and the land has been rehabilitated. (d) Spatial Development Plan / Structure Plan of the Municipality

Yes No

Explain: The Draft SBM Spatial Development Framework 2018-2023 includes directives for mining. Chapter 11 describes the application of the “Bioregional Planning Model” to the SBM Municipal area. For core agricultural areas it is stated that mining and mineral extraction could be allowed: Where mining rights exist and mining would result in transformation of remnant natural vegetation that is categorised as a Critical Biodiversity Area or as Critically Endangered or Endangered, every effort should be made to consider compensation or land swaps to avoid transforming this vegetation. Where such transformation cannot be prevented, stringent rehabilitation measures, monitoring and auditing should be essential, and the objective of rehabilitation should be to restore natural veld of the affected area. The professional input of a specialist ecologist or botanist with local knowledge and experience should be required in this regard. The applicable policies relevant to this application are:

Prohibit transformation of those areas of buffer which are situated in key ecological/evolutionary process areas, or in sensitive and/or dynamic environments, and/or which provide connectivity between protected or threatened ecosystems within the municipal boundary to similar systems beyond the municipal boundary.

Allow low impact activities only.

Protect the distinctive landscape character of the area.

Promote sustainable use and sound management of natural resources.

Promote sustainable use of agricultural land in the Conservation-Agriculture Buffer area.

Prospecting or mining to be granted in certain conditions.

Promote efficient use of water resources and safeguard those ecosystems which regulate water yield and quality (wetlands, riparian systems, floodplains).

Promote restoration (preferably), or rehabilitation, of degraded or disturbed areas.

Promote eradication of alien invasive species.

Promote awareness of the significance and uniqueness of natural vegetation and ecosystems of the area amongst local landowners and communities, visitors and tourists.

The policies for mining are listed in Chapter 12.5.2 of the SDF, i.e.:

P51: Extractive industrial activities should be in harmony with the ecological systems, respecting the processes that control the functioning of these elements.

P52: Any negative impacts associated with extractive industrial activities must be affectively mitigated.

P53 Buffer areas should surround extractive industrial areas that are located in close proximity of core urban areas in order to mitigate visual and environmental impacts.

P54 The location of mining activities needs to be carefully considered relative to the location of other comparable resources, infrastructure availability and environmental sensitivity.



The SDF Strategies for implementing the above policies are:

S59 Undertake a Strategic Environmental Assessment (SEA) of resources to determine the potential impacts of extractive industries on the natural environment, relative to the location thereof.

S60 Mining areas should be fully rehabilitated, as per minimum statutory requirements, once the extraction of mining resources ceases.

S61 Mining areas should, wherever possible, be located close to core urban areas/ transport routes and existing infrastructure to ensure maximum economic sustainability.

(e ) Environmental Management Framework (EMF) adopted by the DEA&DP

Yes N/A No

Explain: There is no approved EMF adopted by the DEA&DP for this area

Q3. Is the proposed land use considered within the timeframe intended by the existing approved Spatial Development Framework (SDF)?

Yes….. No

Explain: Sand and calcrete mining and subsequent agricultural land use is consistent with the SBM SDF. There are no specified time frames.

Q4. Should development of the area concerned in terms of this land use (associated with the activity being applied for) occur here at this point in time?

Yes….. No

Explain: Building sand and calcrete is urgently needed for construction and development, particularly with regards to road construction. This site is conveniently located to provide sand and calcrete for road construction projects in the area.

Q5. . Does the community/area need the activity and the associated land use concerned (is it a societal priority)?

Yes….. No

Explain: Building sand is a basic material that is needed for construction and development, and calcrete is used for road construction. This is currently urgently needed in the area. If the sand and calcrete is not obtained from this site it will still need to be obtained from somewhere else. The local community has not raised any concerns.

Q6. Are the necessary services with adequate capacity currently available (at the time of application), or must additional capacity be created to cater for the development?

Yes…..N/A No

Explain: No municipal services are required at all for this proposed small-scale mining project.

Q7. Is this development provided for in the infrastructure planning of the municipality

Yes…..N/A No

Explain: The municipality does not need to provide any services.

Q8. Is this project part of a national programme to address Yes….. No



an issue of national concern or importance?

Explain: No, it is only a mining permit application. However, it will support construction and development projects in the Saldanha Municipal area.

Q9. Do location factors favour this land use (associated with the activity applied for) at this place?

Yes….. No

Explain: The resources on this farm are favourably positioned to supply the market in the Saldanha Municipality area. Specifically a number of road upgrade projects are proposed in the vicinity.

Q10. Will the activity or the land use associated with the activity applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)?

Yes….. No

Explain: The area is not located within a Critical Biodiversity Area (CBA).The activity will take place on previously transformed land. The Heritage Impact Assessment revealed a single LSA archaeological site of medium heritage significance that would be destroyed during the mining process. Mitigation could be easily accomplished and this is described in this BAR & EMP.

Q11. Will the development impact on people’s health and wellbeing (e.g. in terms of noise, odours, visual character and sense of place, etc)?

Yes….. No

Explain: There will be noise and dust impacts occurring over a short term duration and limited extent duration the operational life of the mine. Once the area has been rehabilitated the area will continue to be used for agricultural purposes and will fit in with the existing rural character and sense of place.

Q12 Will the proposed activity or the land use associated with the activity applied for, result in unacceptable opportunity costs?

Yes….. No

Explain: There will be no unacceptable opportunity costs.

Q13 Are there any cumulative impacts (positive and negative) of the proposed land use associated with the activity applied for, be?

Yes….. No

Explain: There will be no significant cumulative impacts.

Q14. Is the development the best practicable environmental option for this land/site?

Yes….. No

Explain: The area is currently not being used for intensive agriculture. The proposed mining is not a development, but should rather be considered as a temporary land use. The area will be rehabilitated so that it can continue to be used for grazing.



Q15. What will the benefits be to society in general and to the local communities?

Yes….. No

Explain: Building sand and calcrete will be provided for construction and development projects.

Q16 Any other need and desirability considerations related to the proposed activity?

Yes….. No

None

Q17. Please describe how the general objectives of Integrated Environmental Management as set out in section 23 of NEMA have been taken into account:

Explain: The principles of Integrated Environmental Management (EIM) as set out in s23 of NEMA have been considered in this environmental assessment and EMPr. Potential impacts on the environment, socio-economic conditions, and cultural heritage have been assessed, and steps have been taken to mitigate negative impacts, and enhance positive impacts. Adequate and appropriate opportunity has been provided for public participation. Environmental attributes have been considered, and environmental management practices have been identified and established to ensure that the proposed activities would proceed in accordance with the principles of IEM.

Q18. Please describe how the principles of environmental management as set out in section 2 of NEMA have been taken into account:

Explain: In accordance with the s2 NEMA Principles this assessment has placed people and their needs at the forefront of its concern. The importance of sustainable development, in terms of social, environmental and economic factors has been carefully considered. The participation of all potential interested and affected parties has been encouraged. The social, economic and environmental impacts of activities, including disadvantages and benefits, have been considered, assessed and evaluated. Recommendations made are considered to be appropriate in the light of this consideration and assessment. The applicant is aware that the costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or health effects must be paid for by those harming the environment.



7. A MOTIVATION FOR THE PREFERRED SITE, ACTIVITY & ALTERNATIVE

The Tip Trans Cape Group operates a number of sand and gravel mines in the Swartland and City of Cape Town areas. The Group supplies materials to the construction industry and requires viable mineral resources in order to sustain its business. The Managing Director of Tip Trans has identified the Saldanha Bay – Vredenburg region as an area with an increasing demand for construction materials. The increased construction and development activities are associated with the designation of the Saldanha Bay Industrial Development Zone (SBIDZ) in 2013. In addition, the Western Cape Government is currently undertaking road network improvements required to support economic development in the Saldanha Bay Municipal Area as part of a Strategic Integrated Project (SIP5: Saldanha-Northern Cape Development Corridor project). Tip Trans Resources (Pty) Ltd evaluated a number of alternative sites in the Vredenburg area. Many of these alternatives were rejected at an early stage due to the identification of potential fatal flaws e.g. the mineral resources did not comply with customer specifications or the site was located in an environmentally sensitive area. This site was selected because of its location close to the R27 (West Coast Road) in an area where a number of road upgrading projects are planned. A soil survey was conducted over a large area on the farm and this was used to optimise the selection of this mining permit area. The mining permit area was also selected because it is located on transformed farm land and is not located in a Critical Biodiversity Area. Furthermore the site is in a rural area and so the proposed mining activities will not disturb any local communities. The site will be rehabilitated so that it can continue to be used for agricultural purposes. The “preferred alternative” takes into account location alternatives, activity alternatives, layout alternatives, technology alternatives and operational alternatives.



8. PUBLIC PARTICIPATION PROCESS

8.1 Details of the public participation process

The public participation process has been conducted according to the requirements as prescribed in Regulations 40 to 44 of the EIA Regulations, 2014. Full details of the public participation process conducted including copies of all supporting documents (e.g. the information provided to interested & affected parties and the comments received) are included in Appendix 1.

The landowner (Mr Gavin Stigling of the Eye of the Public Advertising CC) provided written consent for the applications and the proposed activities on 4 September 2017. Notices and a Background Information Document (BID) were e-mailed on 25 October 2017 to the authorities, the landowner and neighbours. Hard copies of the notice and BID were posted to the authorities and the other neighbours on 25 October 2017. A bilingual notice (English and Afrikaans) was placed in the Weslander of 25 October 2017. A site notice was placed at the entrance to the site on 24 October 2017.

8.2 Summary of the issues raised by interested & affected parties

The issues and concerns that were raised during the public participation process to date, as well as the responses to these issues are summarised in Table 1, below:

NAME ISSUES AND CONCERNS RESPONSE

LAND OWNER

Gavin Stigling (Eye of the Public Advertising)

The land owner provided consent for the application in a letter dated 28 October 2016

Noted

NEIGHBOURING LAND OWNERS:

West Coast Fossil Park Trust Farm 1223

E-Mail comment 25 October 2017 Registered as IAP

Noted

Joachim Paulus Bester RE Portion 7 of farm 185

No comment submitted Noted.

Barend Johannes Pieterse Trustees

Remainder of farm 187

No comment submitted Noted

Trans African Murals (Pty) Ltd Portion 7 of farm 188


WARD COUNCILLOR

(Ward 5)


AUTHORITIES:

Heritage Western Cape Letter dated 6 December 2017 in response



NAME ISSUES AND CONCERNS RESPONSE

to the NID. You are hereby notified that, since there is reason to believe that the proposed sand mining activities on farm Langberg 188, Vredenberg, will impact on heritage resources, HWC requires that a heritage Impact Assessment (HIA) that satisfies the provisions of section 38 (3) of the NHRA be submitted. The following specialist studies are required:

Paleontological;

Archaeological Impact Assessment;

The HIA must incorporate: o the comments of relevant

conservation bodies, relevant interested and affected parties and the municipality must be requested and included in the HIA where provided. Proof of these requests must be supplied.

A HIA has been compiled by ASHA Consulting and is included as an Appendix in the BAR. A palaeontological assessment has be compiled by Graham Avery and included as an appendix in the BAR. The specialist studies are included in the HIA Consultation with registered heritage conservation bodies and the municipality is in progress. Interested and affected parties will also be able to comment on the HIA which is included in the BAR.

DEA&DP No comment submitted

Noted.

DMR Acceptance of application 2 February 2018

Noted.

Cape Nature No comment submitted Noted

Department of Agriculture Western Cape


Department of Water & Sanitation (DWS)

No comment submitted. Noted

Saldanha Bay Municipality

No comment submitted. Noted

OTHER IAPs:

West Coast Bird Club (Keith Harrison)

E-mail dated 27 November 2017 Registered as IAP

Noted

Cape West Biosphere Reserve


Iziko Museums of South Africa


Adelaide Ruiters Mining & Exploration (Pty) Ltd

E-mail dated 26 October 2017 Registered as IAP

Noted

Table 1: Comment – response summary table

9. PROCESS TO REACH THE PROPOSED PREFERRED ALTERNATIVE

9.1 Details of the alternatives considered

(Note: “Alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to:



(a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity (“the no-go alternative”).

9.1.1 Location or site alternatives

The Tip Trans Cape Group operates a number of sand and gravel mines in the Swartland and City of Cape Town areas. The Group supplies materials to the construction industry and requires viable mineral resources in order to sustain its business. The Managing Director of Tip Trans has identified the Saldanha Bay – Vredenburg region as an area with an increasing demand for construction materials. The increased construction and development activities are associated with the designation of the Saldanha Bay Industrial Development Zone (SBIDZ) in 2013. In addition, the Western Cape Government is currently undertaking road network improvements required to support economic development in the Saldanha Bay Municipal Area as part of a Strategic Integrated Project (SIP5: Saldanha-Northern Cape Development Corridor project). Tip Trans Resources (Pty) Ltd evaluated a number of alternative sites in the Vredenburg area. Many of these alternatives were rejected at an early stage due to the identification of potential fatal flaws e.g. the mineral resources did not comply with customer specifications or the site was located in an environmentally sensitive area. This site was selected because of its location close to the R27 (West Coast Road) in an area where a number of road upgrading projects are planned. A soil survey was conducted over a large area on the farm and this was used to optimise the selection of this mining permit area. The mining permit area was also selected because it is located on transformed farm land and is not located in a Critical Biodiversity Area. Furthermore the site is in a rural area and so the proposed mining activities will not disturb any local communities.

9.1.2 Activity alternatives

The core business of Tip Trans Resources is to provide construction materials and so when an area is investigated the primary focus is to evaluate the viability of mining the mineral resource from a financial, technical and environmental point of view. Tip Trans Resources is not the land owner, so it would not be realistic for Tip Trans Resources to propose another type of activity on the land e.g. for housing or commercial or industrial activities. The holder of a mining permit is required to rehabilitate the environment affected by mining to its natural state or to another predetermined land use. The mining activity takes place over a relatively short time period, so the selection of the best post-mining long term land use is an important consideration. In the case of this application the best post-mining land use alternative is for agricultural purposes.



9.1.3 Design or layout alternatives

The design or layout of a mining project is determined by the shape, position and orientation of the mineral resource. There would be two feasible ways of mining this resource. It could be mined from west to east or from east to west. In this instance it is better to mine and rehabilitate the area sequentially in mining blocks from the west towards the east, as this minimises the disturbance to the mining blocks once they have been rehabilitated. The significance of the environmental impacts associated with different possible design or layout alternatives would be very similar, therefore layout alternatives are not considered any further.

9.1.4 Technology alternatives

The technology used in a mining project is determined by the shape, position and orientation of the mineral resource e.g. if a mineral deposit is situated below the surface then an underground mining method would be appropriate. For surface sand and calcrete mining in the Western Cape essentially two alternative mining methods are used. Where the mineral resources occur below the current land surface (e.g. in the hillwash sand deposits in the Malmesbury area) then an excavator is used to reach down and mine the sand and calcrete. In the Philippi and Macassar Dunes area, a front end loader is used to mine the sand. An excavator will be used for this project. The significance of the environmental impacts associated with different possible technology alternatives would be very similar, therefore technology alternatives are not considered any further.

9.1.5 Operational alternatives

From an operational point of view it could be possible to mine this mineral resource on a continuous basis (i.e. by using a double shift over 24 hours). The reality is that there would be additional health & safety considerations (e.g. requiring extra lighting at night). Mining operations will therefore take place during normal working hours only.

9.1.6 The “no-go” alternative

The assessment of alternatives must at all times include the “no-go” option as a baseline against which all other alternatives must be measured. The “no go” alternative is therefore assessed together with the preferred alternative.



9.2 The environmental attributes associated with the alternatives (i.e. the Baseline Environment)

(The description of the baseline environment should focus on the geographical, physical, biological, social, economic, heritage and cultural aspects)

9.2.1 Geographical

The proposed mining permit area is located 14km south-east of Vredenburg and 2.5km east of the R27 (West Coast Road) on the Remainder of the farm Langeberg 188 (also known as Anyskop Farm). Access to the mining permit area from the R27 (West Coast Road) is via a private farm road. The proposed mining permit area is situated in the south-east corner of the property. The site is situated at an elevation of approximately 23 metres above sea level and has a gentle slope towards the south.

9.2.2 Climate

Vredenburg normally receives about 240 mm of rain per year and because it receives most of its rainfall during winter it has a Mediterranean climate. It receives the lowest rainfall (1mm) in February and the highest (45mm) in June. The monthly distribution of average daily maximum temperatures shows that the average midday temperatures for Vredenburg range from 16.5°C in July to 25.6°C in February. The region is the coldest during July when the mercury drops to 8°C on average during the night. Climate information obtained from http://www.saexplorer.co.za As is to be expected, the prevailing wind patterns in the application area reflect those of the South Western Cape; that is south-easterly during summer and north-westerly during the winter months. The preparation and clearing of areas for mining, sand and calcrete mining and the transport of sand and calcrete could all result in dust, particularly in the drier summer months. Appropriate mitigation measures are required.

9.2.3 Soil

A specialist assessment of the impact of sand and calcrete mining on the agricultural potential of the land was prepared by Johann Lanz and is included as Appendix 2. The underlying geology of the area is mainly Quaternary limestone and calcrete of the Langebaan Formation and quartz sand of the Springfontyn Formation. The soils are generally deep to shallow, grey regic sands overlying calcrete. They have a slightly darker topsoil horizon underlain by bleached light coloured sand, and are predominantly of the Fernwood soil form, as classified by the South African soil classification system. Most are underlain by calcrete but in some places the sand is underlain directly by clay. The soils are limited by the low clay content and leaching of the upper soil horizons and therefore have a low water and nutrient holding capacity. As a result they have a low to medium agricultural potential, and are rated as >3 - ≤5 out of 10 according to the system used by Western Cape soil scientists. The site is classified on AGIS as land capability class III, suggesting that it is suitable for cultivation.

http://www.saexplorer.co.za/



9.2.4 Geology

Quartzitic sandy soils of the Springfontyn Formation cover the area, whilst calcrete of the Langebaan Formation underlies this at a shallow depth, often outcropping on surface. A comprehensive description of the geology is provided in the specialist Palaeontological Assessment Report prepared by Dr Graham Avery (see Appendix 4b).

9.2.5 Surface and groundwater resources

The property is situated within the G10M Quaternary Catchment area which falls under the Department of Water & Sanitation’s Berg Water Management Area. There are no dams, rivers or wetlands in the proposed mining area. The area is very sandy with weathered calcrete and any storm water run-off from the mining permit area will quickly drain into the sand. No wetland units or wetland clusters are present on or near the site. A specialist assessment of the potential impact of the sand and calcrete mining on groundwater was prepared by GEOSS and is included as Appendix 3. The proposed mine overlies an intergranular aquifer with an average borehole yield of 0.0 – 0.1 L/s and an electrical conductivity (EC) for the regional aquifer underlying the site has been classified as “poor” with an EC of 300 – 1 000 mS/m. These classifications of both expected yield and groundwater quality are based on a 1:500 000 scale map. Due to this regional scale of these maps these classifications are regarded as guidelines only. During the hydrocensus (i.e. field work), groundwater levels and quality was assessed and it was established that the groundwater level is generally 4.8 m below ground level (mbgl) and quality is ‘average to poor’ – primarily used for small scale irrigation and livestock watering. Calcrete is significantly deeper for this site than to the south of the site where the calcrete depth is on average 0.95 m below ground level (mbgl). On this site no calcrete was found to a depth of 4.7 m, although it could occur in lenses at shallower depth. No groundwater was intersected during hand augering to depth ranges of 3.7 – 4. 7 m, even above the impermeable clay layer. The area falls within a part of the Saldanha Subterranean Government Water Control Area. Utmost caution must thus be applied so as not too detrimentally impact both the shallow and deep aquifers.

9.2.6 Biodiversity

Historically, the proposed mining site was covered by Saldanha Flats Strandveld (FS3). This is described as “sclerophyllous shrublands built of a sparse emergent and moderately tall shrub layer with an open succulent shrub layer forming the undergrowth. With conspicuous displays of geophytes and annual herbaceous flora in spring” The site has been previously transformed by agricultural activities and although some natural rehabilitation has taken place, the vegetation on site has a low species diversity and the site is considered to still be severely degraded. The site has not been mapped as a Critical Biodiversity Area (CBA) or an Ecological Support Area (ESA).



The proposed mining permit area has been transformed for agricultural purposes. It was previously ploughed and cultivated and is currently used for the grazing. Historical aerial photographs are included in the Heritage Impact Assessment (see Appendix 4a).

Figure 4: Critical Biodiversity Areas (CBA) map of the area.

There is a 25m buffer between the mining permit area and the northern boundary of the farm. (see Figure 4). No significant impacts on natural vegetation are anticipated.

9.2.7 Socio-economic

Saldanha Bay Municipality is a local municipality situated along the West Coast. As of 2011 it had a population of 99 193. Its municipality code is WC014. The municipality covers a total area of 2 015 square kilometres which includes the West Coast Peninsula (also known as the Vredenburg Peninsula) and stretches southeast to include the West Coast National Park and the area around Hopefield. According to the 2011 census the municipality has a population of 99 193 people in 28 835 households. Of this population, 55.8% describe themselves as "Coloured", 24.5% as "Black African", and 18.0% as "White". The first language of 72.5% of the population is Afrikaans, while 16.4% speak Xhosa, 6.6% speak English and 1.2% speak Sotho. Vredenburg is the transportation and commercial hub of the West Coast area and the administrative centre of the municipality. According to the 2011 census Vredenburg has a population of 38 382.



The key statistics provided by Stats SA for the Saldanha Bay Municipal Area based on the statistics from the 2011 Census are shown in the following table:

Table 2: Key Statistics 2011 for the Saldanha Bay Municipal area

Total population 99 193

Young (0-14) 25.3%

Working Age (15-64) 69.5%

Elderly (65+) 5.2%

Dependency ratio 44

Sex ratio 99.2

Growth rate 3.45% (2001-2011)

Population density 49 persons/km2

Unemployment rate 23.4%

Youth unemployment rate 30.4%

No schooling aged 20+ 2.4%

Higher education aged 20+ 9.3%

Matric aged 20+ 28.4%

Number of households 28 835

Number of Agricultural households 1 116

Average household size 3.2

Female headed households 30.4%

Formal dwellings 81.7%

Housing owned/paying off 62.1%

Flush toilet connected to sewerage 92.5%

Weekly refuse removal 96.6%

Piped water inside dwelling 80.2%

Electricity for lighting 97%

The largest sectors within the municipality are manufacturing, transport and communication, wholesale and retail, as well as agriculture and fishing. Future development is anticipated for the Saldanha-Vredenburg region as it is noted as a "Regional Centre", situated as it is around one of the largest natural harbours in the world. The port is expected to generate much activity and smaller scale downstream industries. An Industrial Development Zone (IDZ) has been proclaimed to attract industries to the area.



However, as has been seen with the initial establishment of large-scale industries, such as Saldanha Steel, Namaqua Sands, Duferco and others, a much higher growth rate was predicted than actually occurred. Workers from outside the region are attracted by job prospects, and have taken many of the employment opportunities.

9.2.8 Heritage and cultural aspects

In response to the NID that was submitted by Dr Jayson Orton of ASHA Consulting, Heritage Western Cape requires that a Heritage Impact Assessment (HIA) be submitted and that Paleontological and Archaeological specialist studies were required. Furthermore the HIA is to incorporate the comments of relevant heritage conservation bodies, relevant interested and affected parties and the municipality. Dr Jayson Orton compiled the HIA (see Appendix 4a) and the Palaeontological Assessment was compiled by Dr Graham Avery (see Appendix 4b).

The broader area around Langebaan, Saldanha Bay and the Vredenburg Peninsula contains some highly significant archaeological sites. The majority, however, are focused along the shoreline where marine resources served as a steady food supply. However, one important archaeological site has been located inland. This was in a large deflation hollow on a low hill called Anyskop within the West Coast Fossil Park (WCFP) boundary (about 1.3 km north of the proposed mining permit area). No archaeological resources were located in the study area. Although just one fossil (a snail) was seen during an earlier field survey in the area. The cultural landscape is also considered to be a heritage resource with the West Coast Fossil Park, a National Heritage Site, being an important component of it. The proposed sand and calcrete mine is located in a palaeontologically-sensitive region of potentially fossiliferous sediments underlain by bedrock of the Cape Granite Suite, which outcrops in the region but is not palaeontologically relevant in this instance. The proposed sand mine will focus on sediments from the Langebaan Formation of the Sandveld Group and will reach a depth of up to 3 m, which is above the water table. There is the potential for significant palaeontological remains to be found within the site during mining. The findings and proposed mitigation measures are discussed in more detail in the Impact Assessment section of this report (Section 11).

9.2.9 Land uses and planning considerations

The property is zoned for agricultural purposes by the Saldanha Bay Municipality. Tip Trans Resources (Pty) Ltd should ensure that the required land use approvals are in place. The policies for mining are listed in Chapter 12.5.2 of the Saldanha Bay Spatial Development Framework (SDF), i.e.:

P51: Extractive industrial activities should be in harmony with the ecological systems, respecting the processes that control the functioning of these elements.

P52: Any negative impacts associated with extractive industrial activities must be affectively mitigated.

P53 Buffer areas should surround extractive industrial areas that are located in close proximity of core urban areas in order to mitigate visual and environmental impacts.

P54 The location of mining activities needs to be carefully considered relative to the location of other comparable resources, infrastructure availability and environmental sensitivity.



9.2.10 Description of specific environmental features and infrastructure on the site.

Specific environmental features have already been described above.

9.2.11 Environmental sensitivity and current land use map

See Figures 2, 3 and 4.



9.3 The impacts and risks identified for each alternative

(including the nature, significance, consequence, extent, duration and probability of the of the impacts, including the degree to which the impacts:- (aa) can be reversed, (bb) may cause irreplaceable loss of resources and (cc) can be avoided or mitigated) (DMR: 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) The potential impacts and risks associated with each alternative are described in the following tables. The full assessment is provided in Section 11 of this report.

Table 3: Potential impacts and risks associated with the preferred alternative

Aspect Potential Impacts

Biodiversity The proposed mining permit area is situated on transformed land and will have no impact on natural vegetation. Smaller animals will move away when mining operations are in progress.

Water resources The proposed mine will have no significant impact on surface water. The planned mining depth of 3 m will not negatively impact groundwater, however it is recommended that excavations do not pass the lower weathered calcrete zone if this zone occurs at a shallower depth than that.

Soil and agricultural potential When the sand and calcrete has been removed the area will be rehabilitated to that it can continue to be used for agricultural purposes (i.e. grazing).

Noise and dust An excavator will be used to excavate the material and to load trucks. Noise and dust impacts will be largely restricted to the site. The mine will operate during working hours only.

Socio-economic The proposed mine will not have a negative impact on any agricultural activity on the property or on adjacent properties. The mine will provide limited employment and the aim is to use the sand and calcrete for road construction projects in the Saldanha Bay municipal area.

Cultural and heritage resources No archaeological resources were located in the study area. Although just one fossil (a snail) was seen during an earlier field survey in the area. The West Coast Fossil Park is located to the north of the mining permit area. There is the potential for significant palaeontological remains to be found within the site during mining.



The potential impacts and risks associated with the “no-go” alternative are shown in the following table:

Table 4: Potential impacts and risks associated with the “no-go” alternative

Aspect Potential Impacts

Flora and fauna No change

Water resources No change.

Soil and agricultural potential No change

Noise and dust No change

Socio-economic Tip Trans Resources (Pty) Ltd will forgo an opportunity to create employment and generate an income from this project. Transport is a major component of the cost of low value bulk commodities like sand and calcrete. Increased transport costs for material obtained from further away will add to the total cost which will ultimately be paid by consumers.

Cultural and heritage resources No change.



9.4 The method used in determining significance of potential impacts

The method used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks associated with the alternatives is provided in the following tables:

Table 5: Nature and type of impact

Nature and type of impact Description

Positive An impact that is considered to represent an improvement to the baseline conditions or represents a positive change

Negative An impact that is considered to represent an adverse change from the baseline or introduces a new negative factor

Direct Impacts that result from the direct interaction between a planned project activity and the receiving environment / receptors

Indirect Impacts that result from other activities that could take place as a consequence of the project (e.g. an influx of work seekers)

Cumulative Impacts that act together with other impacts (including those from concurrent or planned future third party activities) to affect the same resources and / or receptors as the project

Table 6: Criteria for the assessment of impacts

Criteria Rating

Description

Spatial extent of impact

National Impacts that affect nationally important environmental resources or affect an area that is nationally important / or have macro-economic consequences

Regional

Impacts that affect regionally important environmental resources or are experienced on a regional scale as determined by administrative boundaries or habitat type / ecosystems

Local Within 2 km of the site

Site specific On site or within 100 m of the site boundary

Consequence of impact (magnitude / severity)

High Natural and/ or social functions and/ or processes are severely altered

Medium Natural and/ or social functions and/ or processes are notably altered

Low Natural and/ or social functions and/ or processes are slightly altered

Very Low Natural and/ or social functions and/ or processes are negligibly altered

Zero Natural and/ or social functions and/ or processes remain unaltered

Duration of impact

Temporary Impacts of short duration and intermittent and/or occasional

Short term During the construction period

Medium term During part or all of the operational phase

Long term Beyond the operational phase, but not permanently

Permanent Mitigation will not occur in such a way or in such a time span that the impact can be considered transient (irreversible)



Table 7: Significance rating

Significance rating

Description

High High consequence with a regional extent and long term duration.

High consequence with either a regional extent and medium term duration or a

local extent and long term duration.

Medium consequence with a regional extent and long term duration.

Medium High consequence with a local extent and medium term duration.

High consequence with a regional extent and short term duration or a site specific

extent and long term duration.

High consequence with either a local extent and short term duration or a site

specific extent and medium term duration.

Medium consequence with any combination of extent and duration except site

specific and short term or regional and long term.

Low consequence with a regional extent and long term duration.

Low High consequence with a site specific extent and short term duration.

Medium consequence with a site specific extent and short term duration.

Low consequence with any combination of extent and duration except site specific

and short term.

Very low consequence with a regional extent and long term duration.

Very low Low consequence with a site specific extent and short term duration.

Very low consequence with any combination of extent and duration except regional

and long term.

Neutral Zero consequence with any combination of extent and duration.

Table 8: Probability, confidence, reversibility and irreplaceability

Criteria Rating

Description

Probability

Definite >90% likelihood of the impact occurring

Probable 70% – 90% likelihood of the impact occurring

Possible 40% – 70% likelihood of the impact occurring

Unlikely <40% likelihood of the impact occurring

Confidence

Certain Wealth of information on and sound understanding of the environmental factors potentially affecting the impact

Sure Reasonable amount of useful information on and relatively sound understanding of the environmental factors potentially influencing the impact.

Unsure Limited useful information on and understanding of the environmental factors potentially influencing this impact

Reversibility Reversible

The impact is reversible within 2 years after the cause or stress is removed.

Irreversible The activity will lead to an impact that is in all practical terms permanent.

Irreplaceability Replaceable The resources lost can be replaced to a certain degree

Irreplaceable The activity will lead to a permanent loss of resources



9.5 The positive & negative impacts that the proposed activity and alternatives will have

(The positive and negative impacts that the proposed activity and alternatives will have on the environment and the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects) (DMR: Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)

See Section 9.3 of this report.

9.6 The possible mitigation measures that could be applied

(The possible mitigation measures that could be applied and the level of residual risk) See the environmental impact assessment in Section 11 of this report.

9.7 The outcome of the site selection matrix

See Figure 2 and Figure 3.

9.8 Motivation where no alternatives were considered

(If no alternatives, including alternative locations for the activity were investigated, the motivation for not considering such)

Alternatives were considered.

9.9 Concluding statement on alternatives

(a concluding statement indicating the preferred alternatives, including preferred location of the activity)

The Tip Trans Cape Group operates a number of sand and gravel mines in the Swartland and City of Cape Town areas. The Group supplies materials to the construction industry and requires viable mineral resources in order to sustain its business. The Managing Director of Tip Trans has identified the Saldanha Bay – Vredenburg region as an area with an increasing demand for construction materials. The increased construction and development activities are associated with the designation of the Saldanha Bay Industrial Development Zone (SBIDZ) in 2013. In addition, the Western Cape Government is currently undertaking road network improvements required to support economic development in the Saldanha Bay Municipal Area as part of a Strategic Integrated Project (SIP5: Saldanha-Northern Cape Development Corridor project). Tip Trans Resources (Pty) Ltd evaluated a number of alternative sites in the Vredenburg area. Many of these alternatives were rejected at an early stage due to the identification of potential fatal flaws e.g. the mineral resources did not comply with customer specifications or the site was located in an environmentally sensitive area. This site was selected because of its location close to the R27 (West Coast Road) in an area where a number of road upgrading projects are planned. A soil survey was conducted over a large area on the farm and this was used to optimise the selection of this mining permit area.



The mining permit area was also selected because it is located on transformed farm land and is not located in a Critical Biodiversity Area. Furthermore the site is in a rural area and so the proposed mining activities will not disturb any local communities. The site will be rehabilitated so that it can continue to be used for agricultural purposes. The “preferred alternative” takes into account location alternatives, activity alternatives, layout alternatives, technology alternatives and operational alternatives.



10. SPECIALIST FINDINGS (a summary of the findings and impact management measures identified in any specialist report complying with Appendix 6 to these Regulations) and an indication as to how these findings and recommendations have been included in the final report)

10.1 Soil and agricultural potential

The assessment of the impact on the agricultural potential of the land (see Appendix 2) has found that there are adequate reserves of sand on site for mining and rehabilitation. Soils are sandy and the agricultural potential across the site is low to medium. The potential impact of mining on the land is to reduce its agricultural potential by way of eight different identified mechanisms: 1. Loss of agricultural land for duration of mining 2. Reduction in soil depth 3. Impaired soil drainage 4. Loss of topsoil and fertility during mining and stockpiling 5. Erosion of returned topsoil after rehabilitation 6. The creation of steep slopes and uneven surfaces 7. Alien vegetation encroachment 8. Soil contamination from fuel spills Mitigation measures and a rehabilitation plan are provided. With mitigation, the reduction in agricultural potential is assessed as having low significance. Without mitigation it is assessed as having medium significance. Mining of this site can proceed, subject to the recommended mitigation measures provided. If these measures are followed and effectively implemented, the agricultural potential of the land can be successfully rehabilitated and it can be utilised at the same level of production (perennial pasture) as the pre-mining agricultural land use. These findings and recommendations have been included in the environmental impact assessment and EMPr.

10.2 Groundwater

A specialist groundwater impact assessment was compiled by GEOSS (see Appendix 3). The planned mining depth of 3 m will not negatively impact groundwater, however it is highly recommended that excavations do not pass the lower weathered calcrete zone if this zone occurs at a shallower depth than that. The following measures are recommended to ensure that successful rehabilitation results during and after the sand and calcrete mining operations and that unnecessary impacts to groundwater through negligence are avoided.

During the rainfall season erosion rates increase, and extra caution must be used to not exacerbate this during the mining process.

The strips of soil that are removed should be done so at right angles to the slope, as this will slow down surface runoff and help to prevent erosion.

Rehabilitation by replacing topsoil on the stripped land should take place before the next strip is opened and mined.

All machinery must be in excellent condition and there must be no oil/fuel leaks whatsoever from equipment.

If a spill does occur, it must be immediately reported to the relevant authorities and immediately remediated.



A short report (with photographs) should be completed prior to and on completion of the mining to the relevant authorities by an Environmental Control Officer (ECO).

In order to avoid impacting on infiltration, groundwater recharge and flow, the Department of Water and Sanitation (DWS) generally stipulates that sand mining not be allowed within 1.5 m of the shallow groundwater level. The proposed mining depth of 3 m falls within this requirement, however if the lower weathered calcrete layer is intersected before this, excavation should stop.

As the area is within a Subterranean Government Water Control Area, utmost care needs to be taken when an activity takes place that could affect groundwater. In this area quality is an issue and a buffer zone of at least 2 m must be left above the water table.

10.3 Heritage resources

A full Heritage Impact Assessment (HIA) was undertaken, this is included in Appendices 4a and 4b.

The archaeological resources are deemed to have very low cultural significance for their scientific value. The palaeontological resources of the region (including the entire WCFP as a single site) are deemed to have high cultural significance for their scientific value. Although one cannot predict what might be found in the study area, it is clear that the possibility exists to find anything with cultural significance ranging from very low to very high. The agricultural/rural cultural landscape is considered to have low significance for its aesthetic and historical values because of the great degree of transformation that it has undergone in recent years. The largely subsurface palaeontological landscape, however, is considered to have high cultural significance for its scientific value. The only heritage resources relevant to the present project are:

Potential buried palaeontological resources that might be graded anywhere between Grade IIIC and Grade II, although a higher grade (II or IIIA) is far less likely than a lower one (IIIB or IIIC); and

The regional palaeontological cultural landscape which is considered to be worthy of at least Grade IIIA (although individual exposures such as Langebaanweg are clearly worthy of higher grades).

The proposed site Pit#2 DMR 10161 MP is close to and lithologically essentially similar to Approved Pit #1 DMR 10122MP (Avery 2016); the palaeontological potential of each is almost certainly similar, if not identical. With respect to Pit#2 DMR 10161MP, the greater depth of Springfontyn Formation sand reported from a test hole (GEOSS 2018) may increase the potential for encountering preserved Middle Pleistocene stone artefacts and/or fossil bones, particularly if the surface of the Langebaan Formation there was less affected by erosion.



11. ENVIRONMENTAL IMPACT ASSESSMENT (As prescribed in Appendix 1 of the EIA Regulations, 2014: A full description of the process undertaken to identify, assess and rank the impacts and risks the activity will impose on the preferred location through the life of the activity, Including- (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures)

An assessment of each potentially significant impact and risk (including- (i) cumulative impacts, (ii) the nature, significance and consequence of the impact and risk, (iii) the extent and duration of the impact and risk occurring, (iv) the probability of the impact and risk occurring, (v) the degree to which the impact and risk can be reversed, (vi) the degree to which the impact and risk may cause irreplaceable loss of resources, and (vii) the degree to which the impact and risk can be avoided, managed or mitigated) A full description and assessment of the environmental impacts and risks associated with the “preferred alternative” is provided below:

11.1 Soil and agricultural potential

Introduction Topsoil is a valuable and essential resource for rehabilitation and it should therefore be managed carefully to conserve and maintain it throughout the stockpiling and rehabilitation processes. Potential impacts The potential impact of mining on the land is to reduce its agricultural potential by way of eight different identified mechanisms:

1. Loss of agricultural land for duration of mining 2. Reduction in soil depth 3. Impaired soil drainage 4. Loss of topsoil and fertility during mining and stockpiling 5. Erosion of returned topsoil after rehabilitation 6. The creation of steep slopes and uneven surfaces 7. Alien vegetation encroachment 8. Soil contamination from fuel spills

Table 9: Soil and agricultural potential: summary of impact assessment

Potential impacts on soil & agric. potential:

Nature of impact: Negative and direct

Extent of impact: Site specific

Consequence of impact: Medium

Duration of impact: Medium term

Probability of occurrence: Definite

Confidence: Certain

Degree to which the impact can be reversed: Reversible

Degree to which the impact may cause irreplaceable loss of resources:

Replaceable

Significance rating of impact prior to mitigation (Neutral, Very Low, Low, Medium, or High)

Medium

Significance rating of impact after mitigation (Neutral, Very Low, Low, Medium, or High)

Low



Discussion The topsoil will be pre-stripped and stockpiled for replacement on the land directly after sand and calcrete mining has been completed in each mining block. The highest risk of rehabilitation failure is as a result of erosion of and / or loss of topsoil. Erosion of topsoil can occur both as a result of stripping and stockpiling, as well as after topsoil spreading. These aspects must therefore be well managed in order for rehabilitation to be successful. Proposed mitigation measures The proposed mitigation measures to avoid or minimise the impact of the project on soils and the agricultural potential of the land are listed below:

The upper 50 cm of the soil must be stripped and stockpiled before mining. Mining can then be done down to the clay layer (or other depth limiting layer).

Topsoil is a valuable and essential resource for rehabilitation and it should therefore be managed carefully to conserve and maintain it throughout the stockpiling and rehabilitation processes.

Topsoil stripping, stockpiling and re-spreading must be done in a systematic way. The mining plan should be such that topsoil is stockpiled for the minimum possible time by rehabilitating different mining blocks progressively as the mining process continues.

Topsoil stockpiles should be protected against losses by water and wind erosion. Stockpiles should be positioned so as not to be vulnerable to erosion. The establishment of plants (weeds or a cover crop) on the stockpiles will help to prevent erosion.

To ensure minimum impact on drainage, it is important that no depressions are left in the mining floor. A surface slope (even if minimal) must be maintained across the mining floor in the drainage direction, so that all excavations are free draining.

After mining, any steep slopes at the edges of excavations, must be reduced to a minimum and profiled to blend with the surrounding topography.

The stockpiled topsoil must then be evenly spread over the entire mining area, so that there is a depth of 50cm of sandy topsoil above the underlying clay or other depth limiting layer. The depth should be monitored during spreading to ensure that coverage is adequate and even.

Topsoil spreading should only be done at a time of year when vegetation cover can be established as quickly as possible afterwards, so that erosion of returned topsoil by both rain and wind, before vegetation is established, is minimised. The best time of year is at the end of the rainy season, when there is moisture in the soil for vegetation establishment and the risk of heavy rainfall events is minimal.

A cover crop must be planted and established immediately after spreading of topsoil, to stabilise the soil and protect it from erosion. The cover crop should be fertilized for optimum production. It is important that rehabilitation is taken up to the point of cover crop stabilisation. Rehabilitation cannot be considered to be complete until the first cover crop is well established.

The rehabilitated area must be monitored for erosion, and appropriately stabilised if any erosion occurs.

On-going alien vegetation control must keep the area free of alien vegetation after mining.

11.2 Water resources

Introduction There are no rivers, streams or wetlands in the mining permit area. The mining permit area overlies an intergranular aquifer (Langebaan Road Aquifer). The area is also part of the Saldanha Subterranean Government Water Control Area. Utmost caution must thus be applied so as not too detrimentally impact both the shallow and deep aquifers.



Potential impacts Potential impacts of a sand and calcrete mining operation on water resources could include soil erosion, ponding of water or pollution from hydrocarbon spills.

Table 10: Water resources: summary of impact assessment

Potential impacts on water resources:



Consequence of impact: Low

Duration of impact: Temporary

Probability of occurrence: Unlikely

Confidence: Sure



Replaceable


Low


Very low

Discussion No groundwater resources will be used by this mining operation. Data gathered during the augering indicates that the calcrete layer is deeper than 4.73 m, however shallower lenses could be found between sampling sites. Groundwater level from boreholes close by indicates that the groundwater is beneath the calcrete layer with an average depth of 4.84 mbgl. This shallow groundwater is of poor quality and with low flow rates. Although the proposed area is part of the Saldanha Subterranean Government Water Control Area, impact to the uppermost shallow aquifer will be negligible and to the deeper aquifer will be highly unlikely. The planned mining depth of 3 m will not be detrimental to the groundwater. Proposed mitigation measures The following measures should be applied:

During the rainfall season erosion rates increase, and extra caution must be used to not exacerbate this during the mining process.

The strips of soil that are removed should be done so at right angles to the slope, as this will slow down surface runoff and help to prevent erosion.

Rehabilitation by replacing topsoil on the stripped land should take place before the next strip is opened and mined.

All machinery must be in excellent condition and there must be no oil/fuel leaks whatsoever from equipment.

If a spill does occur, it must be immediately reported to the relevant authorities and immediately remediated.

A short report (with photographs) should be completed prior to and on completion of the mining to the relevant authorities by an Environmental Control Officer (ECO).

In order to avoid impacting on infiltration, groundwater recharge and flow, the Department of Water and Sanitation (DWS) generally stipulates that sand mining not be allowed within 1.5 m of the shallow groundwater level. The proposed mining depth of 3 m falls within this requirement, however if the lower weathered calcrete layer is intersected before this, excavation should stop.

As the area is within a Subterranean Government Water Control Area, utmost care needs to be taken when an activity takes place that could affect groundwater. In this area quality is an issue and a buffer zone of at least 2 m must be left above the water table.



11.3 Biodiversity

Introduction The proposed mining permit area was selected in transformed farm land in order to avoid potential impacts on biodiversity. Potential impacts There will be no impacts on natural vegetation as the site is situated on transformed agricultural land. The disturbance of the land will make the area susceptible to invasion by alien vegetation. There is, however natural vegetation mapped in the vicinity. The closest natural vegetation north of the mining permit area is some 25m away. The noise and vibration caused by the earthmoving equipment will disturb smaller animals (e.g. snakes and moles). These will move away whilst operations are in progress.

Table 11: Biodiversity: summary of impact assessment

Potential impacts on biodiversity:

Nature of impact: Negative and indirect




Probability of occurrence: Possible

Confidence: Sure



Replaceable


Low


Very low

Discussion Significant potential impacts on biodiversity have been avoided through the site selection process. Proposed mitigation measures The proposed mitigation measures to further avoid or minimise the impact of the project on biodiversity are listed below:

If any animals are encountered during the mining operations they must not be killed or injured, but rather removed from the site (by a suitably trained nature conservation officer, if necessary).

Invasive alien vegetation must be controlled within the mining permit area.

The buffers will be maintained between the mining area and any natural vegetation.



11.4 Dust

Introduction Windblown dust is a standard aspect that needs to be assessed for mining projects. Potential impacts Windblown dust may occur during all phases of the project (e.g. clearing, mining, loading and rehabilitation). Impacts may be aggravated during high wind conditions.

Table 12: Dust: summary of impact assessment

Potential windblown sand and dust impacts




Duration of impact: Short term


Confidence: Certain



Replaceable


Low


Very low

Discussion The size of the mining blocks are small in relation to the overall size of the property. Noise and Dust are Occupational Health and Safety issues for mine workers. These are controlled via the Mine Health and Safety Act, 1996 (Act 29 of 1996). The employer is required to:

supply all the necessary health and safety equipment to each employee;

provide regular health and safety training;

establish a system of medical surveillance;

conduct occupational hygiene measurements; and

assess and control risks. Proposed mitigation measures The proposed mitigation measures to avoid or minimise impacts related to windblown sand and dust are as follows:

Establish EMPr procedures to minimise the generation of dust (e.g. use of water cart, commercial dust binders on access tracks etc.).

Minimise size of areas to be cleared at any one time.

Rehabilitate and revegetate mining blocks as soon as mining is completed.

Ensure vehicles keep to the speed limit.

Reduce activities during very strong winds.

11.5 Noise

Introduction Noise is a standard aspect that is assessed for mining projects. Potential impacts Noise will be created by mining equipment (e.g. excavators and front end loaders) and vehicles.



Table 13: Noise: summary of impact assessment

Potential noise impacts:



Consequence of impact: Very low



Confidence: Certain



Not applicable


Very low


Very low

Discussion The size of the mining blocks are small in relation to the overall size of the property. Noise associated with the mining activity will not negatively impact on activities on any of the surrounding properties. Noise and Dust are Occupational Health and Safety issues for mine workers. These are controlled via the Mine Health and Safety Act, 1996 (Act 29 of 1996). The employer is required to:

supply all the necessary health and safety equipment to each employee;

provide regular health and safety training;

establish a system of medical surveillance;

conduct occupational hygiene measurements; and

assess and control risks. Proposed mitigation measures The proposed mitigation measures to avoid or minimise noise related impacts are as follows:

Ensure all equipment and vehicles are well maintained.

Restrict work to standard operating hours only.

11.6 Solid waste

Introduction Solid waste is not a significant aspect for this project, however this aspect is assessed for completeness. Potential impacts Potential impacts may be associated with litter left by mine workers or if empty containers are left on site.

Table 14: Solid waste: summary of impact assessment

Potential solid waste impacts:



Consequence of impact: Very low





Confidence: Sure



Not applicable


Very low


Very low

Discussion The mining activity itself will not generate any solid waste. It is possible that minor solid waste may be generated if equipment is serviced (e.g. containers for lubricants and hydraulic fluid or packaging for spare parts). The mine workers could potentially generate a small amount of solid waste (e.g. food wrapping paper and tins). Proposed mitigation measures The proposed mitigation measures to avoid or minimise impacts associated with solid waste are as follows:

Provide all workers with environmental awareness training.

Provide a bin at the temporary site office / container.

Regularly dispose of any solid waste at a municipal waste disposal site.

Ensure all workers comply with the requirements of the EMPr.

11.7 Heritage Resources

Introduction The HIA has focussed on archaeology and palaeontology as requested by HWC, although other aspects of heritage were also noted to be relevant to the broader area. The study revealed no significant archaeological material. Although just one fossil (a snail) of very low significance was seen in the study area, there is the potential for important fossils to be uncovered during the development but this potential reduces towards the north where the calcrete is far deeper, beyond the reach of mining. Occasional mineralised bones have already been noted in the existing mine but higher density finds can be very localised and cannot be predicted. Regular monitoring will be key to understanding the potential during the early stages of mining and planning the frequency of subsequent monitoring and any collection of fossils that may become necessary. The cultural landscape (including the palaeontological landscape) is also considered a heritage resource but impacts are expected to be insignificant. Potential impacts

Impacts to archaeological material are most likely to occur during the ‘construction’ phase of the mine when the topsoil is removed. It must be noted that because the calcrete dips down towards the north the chances of impacts diminish in that direction because it is likely that the calcrete will not even be intersected over large parts of the borrow pit. Impacts would be direct and negative because archaeological material would be physically damaged or destroyed. As a result of the low consequence the significance would be low before mitigation. Mitigation of such material is not feasible because of the likely low density and difficulty of finding it underground. The significance after mitigation thus remains low. There are no fatal flaws in terms of archaeology.



Impacts to palaeontological material are most likely to occur during the operational phase of the mine when calcrete is removed, although some fossils may also be located high enough to be impacted during the clearing of topsoil.

Table 15: Archaeological Resources: summary of impact assessment

Potential impacts on archaeological resources:




Duration of impact: Permanent


Confidence: Sure

Degree to which the impact can be reversed: Irreversible


Irreplaceable

Significance rating of impact prior to mitigation Low

Significance rating of impact after mitigation Low

Table 16: Palaeontological Resources: summary of impact assessment

Potential impacts on palaeontological resources:


Extent of impact: Site specific to regional


Duration of impact: Permanent


Confidence: Sure

Degree to which the impact can be reversed: Irreversible


Irreplaceable

Significance rating of impact prior to mitigation Medium to high

Significance rating of impact after mitigation Low

Table 17: Cultural landscape: summary of impact assessment

Potential impacts on the cultural landscape: Nature of impact: Negative and indirect





Confidence: Certain



Replaceable

Significance rating of impact prior to mitigation Low

Significance rating of impact after mitigation Very low

Discussion Impacts would be direct and negative because palaeontological material would be physically damaged or destroyed. As a result of the medium consequence and permanent duration the significance would be medium before mitigation should fossils of only very local importance be



found but potentially high before mitigation should fossils that are important at the regional level be found. With mitigation the significance would reduce to low because it is still likely that some fossils will be lost during mining. A positive aspect is that fossils not otherwise accessible to science may be revealed during the operational phase. There are no fatal flaws in terms of palaeontology. Cumulative impacts are difficult to rate because it is completely unknown what impacts would occur and similar activities are sporadic and widely scattered. It is possible, however, that cumulative impacts would be positive and of low-medium significance because any new fossils brought to light would contribute to the regional understanding of the deep past. Impacts to the cultural landscape would occur throughout the lifetime of the project. Impacts would be indirect (contextual) and negative because the landscape would be visually disturbed. Because the site is in a low-lying area and is screened from the WCFP the consequence of this impact is deemed to be very low. As a result of this, the site-specific extent and medium term duration of the impact, the overall significance rating is low before mitigation. After mitigation the rating would reduce to very low. There are no fatal flaws in terms of landscape impacts, especially given the already approved road and borrow pit that are currently under construction and being actively mined respectively. Cumulative impacts to the landscape are of relatively little significance in this instance because there will be very little physical alteration of the broader landscape compared to what has already happened: the area to the west is already highly degraded through industrial development, the huge berm surrounding the WCFP has created a significant unnatural aspect to the local landscape and an existing borrow pit and road project have resulted in visual degradation of the immediate context of the site. Proposed mitigation measures As the impacts to heritage resources are manageable and effective mitigation is readily accomplishable, it is recommended that the proposed mine be allowed to proceed but subject to the following conditions which should be included in the authorisation if the mining permit is granted:

Mining will provide an opportunity to assess the sub-surface palaeontological and archaeological potential and geology of the site.

All fossils are protected by law. Should anything of a palaeontological or archaeological nature be encountered on site by the Contractor (or any other party), e.g. bones, artefacts or wetland deposits, work is to be stopped in that area immediately, and the OM / Principal Agent notified. Failure to do so will result in a penalty and this must be carefully explained to workers during the Environmental Education Programme undertaken by the OM.

Mining should be monitored by a palaeontologist or archaeologist with appropriate palaeontological knowledge. This should start at the same time as mining and the subsequent frequency of this is to be worked out a priori with the contractor to minimize time spent on site.

A training session to familiarize contractor’s staff, including machine operators, has proved important at other sites in the Saldanha region and has led to more efficient recovery of scientifically important material with minimal or no delays; given the scale of mining a temporary shift of the operation a few metres until a find is assessed and removed should not be a problem.

Given the known palaeontological potential of the region, mitigationary action, beyond simple recording and recovery during monitoring, including the possibility of systematic excavations, while unlikely, may be necessary. In the event of palaeontological material being encountered, the OM will demarcate the area and notify the appointed specialist (palaeontologist/ archaeologist with appropriate experience) who will view the material and ascertain whether further study of the area is required.

Should the specialist confirm a genuine fossil or sub-fossil and recommend further study of the area, work in the applicable area is to cease until further notice while



arrangements are put in place. The appointed palaeontologist/ archaeologist will report finds to Heritage Western Cape (HWC).

The removal of discovered palaeontological or archaeological remains, by a contracted specialist shall be at the expense of Tip Trans Resources (Pty) Ltd.

11.8 Socio-economic

Introduction Building sand and calcrete are basic constructions material required for construction and development projects. Sand and calcrete are a low cost but high bulk materials. A significant proportion of the total cost of sand and calcrete is related to the transport distance from a mine to a development site. This site is very conveniently located to provide building sand and calcrete for projects in the Saldanha Bay and Vredenburg areas. The mining site is located in a rural area where it will not cause any disturbance or disruption to neighbouring communities. Potential impacts The mine will provide direct employment for mine workers and indirect employment for truck drivers who will transport the material to construction sites. The provision of construction material is Tip Trans Resources (Pty) Ltd’s core business. This project will secure mineral resources for Tip Trans Resources and help to sustain its business. The rehabilitation of the mining permit area will ensure that the land can still be used for agricultural purposes.

Table 18: Socio-economic: summary of impact assessment

Potential impacts on socio-economic environment:

Nature of impact: Positive – Direct and indirect

Extent of impact: Local to regional




Confidence: Certain

Degree to which the impact can be reversed: n/a


n/a


Medium (+ve)


Medium (+ve)

Discussion The sand and calcrete mining project will not only have a positive socio-economic impact during the life of the mine. Construction and development projects that make use of the sand and calcrete will have a long term positive socio-economic benefit for the region. Good housekeeping and compliance with the requirements of the EMPr are required to minimise any local short-term impacts on the neighbours. Proposed mitigation / enhancement measures

Ensure compliance with the requirements of the EMPr and the rehabilitation of the land.

Maintain normal working hours.

Ensure no dumping of rubble.

Maintain communications with I&APs and keep a “Complaints Register” on site.



11.9 Cumulative impacts

The potential degradation of agricultural land can be considered as the most important possible cumulative impact associated with the proposed mining operation. The impact of the proposed mining project on the soil and agricultural potential of the land has already been described, and so is not repeated again.



12. “NO GO” ALTERNATIVE The significance rating of the “no go” alternative is Neutral with respect to most of the key aspects that have been assessed for the “preferred” mining option. However if the “no go” alternative is to be considered as a realistic and feasible option then it is important to consider the impact of the “no-go” alternative on the socio-economic aspects.

12.1 Socio-economic

Introduction Tip Trans Resources (Pty) Ltd’s core business is the provision of construction material for construction and development projects. Potential impacts of the “no go” alternative The “no-go” alternative would mean that Tip Trans Resources will lose an economic opportunity as well as an opportunity to create employment. Construction projects in the area would still require building sand to be obtained from somewhere else. If the material was transported from a longer distance it would increase the cost. The increased cost would ultimately be passed on to the consumer.

Table 19: Socio-economic: summary of assessment of the “no go” alternative

Potential impacts on socio-economic environment:

Nature of impact: Negative

Extent of impact: Local


Duration of impact: Long term

Probability of occurrence: Probable

Confidence: Sure



Replaceable


Medium


Medium

Discussion The “no go” alternative will not have a positive impact on the socio-economic aspects for Tip Trans Resources, its employees or for construction projects in the area. Proposed mitigation / enhancement measures There are no mitigation or enhancement measures for the impact of the “no go” alternative on socio-economic conditions.



13. ENVIRONMENTAL IMPACT STATEMENT

13.1 Summary of the key findings of the environmental impact assessment

The significance ratings of impacts after mitigation on the key aspects of the “preferred alternative” and the “no-go” alternative are shown in the following table:

Table 20: Comparative assessment of alternatives

Aspects “preferred alternative”

“no-go alternative”

Soil and agricultural potential

Low Neutral

Water resources Very low Neutral

Biodiversity Very low Neutral

Dust Very low Neutral

Noise Very low Neutral

Solid waste Very low Neutral

Heritage resources

Archaeology

Palaeontology

Cultural landscape

Very low Neutral

Low Neutral

Very low Neutral

Socio-economic Medium (+ve) Medium (-ve)

The assessed impacts of the proposed mine are very low for most aspects apart from on the socio-economic aspects which is medium positive. The assessed impacts on the soil & agricultural and palaeontological aspects are both low (negative). These are therefore the key aspects that should be considered by decision makers. Key findings of the environmental impact assessment for the “preferred alternative” are summarised below:

Soil and agricultural potential: The property is zoned for agricultural purposes and therefore it is essential that the proposed mining operation does not result in degradation of the land with consequent negative impacts on the agricultural potential of the land. The EAP considers that this is the key aspect that should be closely monitored. The soil scientist has provided detailed mitigation and rehabilitation measures. With mitigation, the reduction in the agricultural potential is assessed as having a ‘low’ significance, but without mitigation it is assessed as having ‘medium’ significance. Water resources: The proposed mine will have a negligible impact on surface water resources. The planned mining depth of 3m should not negatively impact groundwater. Provided that the



applicant complies with the mitigation measures recommended by GEOSS and included in the EMPr, then the significance of the impacts on groundwater should be ‘very low’. Biodiversity: The proposed mining area has been specifically sited to avoid negative impacts on biodiversity. Provided that the applicant complies with the requirements of the EMPr then the significance of impacts on biodiversity should be ‘very low'. Dust, noise and waste: The proposed mining activity could potentially result in dust, noise and waste impacts. However, as long as the applicant complies with the requirements of the EMPr, then the significance of potential dust, noise and waste impacts should be ‘very low’. Heritage resources Providing that the mitigation measures are adhered to, the potential impact on archaeological resources will be ‘very low’. As there is a possibility of exposing fossils during mining, a professional palaeontologist should be appointed to inspect the mine pit at appropriate intervals. With this mitigation measure in place the significance of the impact will be ’low’ Socio-economic: The site is very conveniently located to provide building sand and calcrete to the Saldanha Bay and Vredenburg areas. It is considered that the long term socio-economic benefits of this project outweigh the negative impacts that will occur as the result of the proposed mining activities.

13.2 Final site map

(a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers)

See Figures 2, 3 and 4.

13.3 Summary of the positive and negative impacts and risks

(a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives)

The assessed impacts and risks of the proposed mine are ‘very low’ for most aspects apart from on the soil & agricultural aspects and palaeontological (fossil) resources which are assessed to be ‘low’. The socio-economic aspects are considered to be ‘medium positive’. These are therefore the key aspects that should be considered by decision makers. The area will be rehabilitated so that it can continue to be used for agricultural land. The f inal landscape will blend in with the adjacent land.

13.4 Proposed impact management objectives and outcomes

(based on the assessment, and where applicable, impact management measures from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr)

The proposed impact management objectives and outcomes for the project are as follows: Objective 1: To ensure effective rehabilitation of the mining permit area. Outcomes:

The site is to be shaped and levelled to match the adjacent topography

Topsoil to be replaced over the mined areas.



Pasture grass is to be planted over the previously mined area. Objective 2: To minimise pollution or degradation of the environment. Outcomes:

Ensure that no fuel or oil spills occur in the mining area.

Ensure that no solid waste or rubble is dumped on the site.

Ensure that portable toilets are used. Objective 3: To minimise impacts on the community. Outcomes:

To ensure that workers remain within the mining permit area.

To operate during normal working hours only.

To minimise the generation of noise and dust.

To respond rapidly to any complaints received.

13.5 Proposed conditions of authorisation

(any aspects which were conditional to the findings of the assessment either by the EAP or specialist which are to be included as conditions of authorisation) The proposed conditions of authorisation are as follows:

All mining and rehabilitation to be conducted as per the approved EMPr.

Concurrent mining and rehabilitation must be done in the designated mining blocks.

The proposed mining area must be clearly demarcated with semi-permanent markers.

The upper 500mm of soil must be removed and stockpiled to be returned after mining by spreading evenly over the mined area.

Rehabilitation cannot be considered to be complete until the first cover crop is well established.

Control measures must be implemented to prevent pollution of any water resource by oil, grease, fuel or chemicals.

Eradicate all alien vegetation in the area during and regularly after mining.

Appropriate pollution prevention measures must be implemented to prevent dust and noise pollution.

Should any heritage remains be exposed during mining these must immediately be reported to Heritage Western Cape.

Environmental audit reports should be submitted every second year.

13.6 Assumptions, uncertainties and gaps in knowledge

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

Where relevant or applicable, each specialist provided details of knowledge gaps, assumptions and uncertainties encountered in compiling the required information. The overall confidence was provided in the impact assessment tables for each aspect that was assessed. In no case was the confidence level found to be ‘unsure’. Relevant knowledge gaps, assumptions and uncertainties are provided below. Soil & agricultural potential There are no important knowledge gaps, assumptions and uncertainties in the soil scientist’s report.



Heritage resources The heritage specialist considers that the proposed mine will not have a significant impact on heritage resources. Appropriate mitigation measures have been recommended and included in the EMPr. There is a possibility that the mine will excavate buried fossils. The appointment of a palaeontologist to monitor the site has been recommended.

13.7 Reasoned opinion of the EAP

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

13.7.1 Reasons why the activity should be authorised or not

This report provides an assessment of the environmental impacts associated with the proposed mining activities. The assessment has taken into account the comments provided by the relevant authorities and interested and affected parties to date. All interested and affected parties will be provided with a further 30 day period to comment on this report and the comments will be included with the final submission to the Competent Authority (i.e. the DMR). Specialist studies were was commissioned to assess the impact of the proposed mining activity on the soils & agricultural potential of the land, groundwater and heritage resources (including archaeological, palaeontological and the culture landscape) (see Appendices).

The “preferred alternative” takes into account location alternatives, activity alternatives, layout alternatives, technology alternatives and operational alternatives. The approach taken by the applicant is that it is preferable to avoid significant negative environmental impacts, wherever possible. The mining permit area is not located in a Crit ical Biodiversity Area (CBA). There are no wetlands, streams or rivers located within the mining permit area. It is the opinion of the Environmental Assessment Practitioner (EAP) that provided that the recommended mitigation measures are implemented and mining activities are managed in accordance with the stipulations of the Environmental Management Programme and in an environmentally sound manner, the potential negative impacts associated with the implementation of the preferred alternative can be reduced to acceptable levels. No negative impacts have been identified that are so severe as to prevent the proposed mining activity from taking place, and the activity has been assessed to have a positive socio-economic impact, especially in terms of the creation of employment and the provision of building sand and calcrete for construction and development projects in the Saldanha Bay and Vredenburg areas.

13.8 Period for which the environmental authorisation is required

The environmental authorisation is required for a five year period.

13.9 Undertaking by the EAP

It is confirmed that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the Basic Assessment Report (BAR) and the Environmental Management Programme report (EMPr).



14. FINANCIAL PROVISION (where applicable, details of any financial provisions for the rehabilitation, closure, and ongoing post decommissioning management of negative environmental impacts)

The Applicant is required to make the prescribed financial provision for the rehabilitation or management of negative environmental impacts. If the Applicant fails to rehabilitate or manage any negative impact on the environment, the DMR may, upon written notice to the Applicant, use all or part of the financial provision to rehabilitate or manage the negative environmental impact in question. The Applicant plans to mine one Mining Block at a time. An estimate of the financial provision required to rehabilitate one Mining Block is shown in the following table:

Table 21: Itemisation of the quantum of the financial provision

Item Unit rate Number of units/ hours /days

Amount in Rands

Shaping of the mine floor and edge (hours) R 300 32 R 9 600

Hauling and spreading of topsoil over mined areas (hours)

R 450 48 R 21 600

Seeding and planting / block R 6 000 1 R 6 000

Labour (days) R 600 10 R 6 000

Sub-total (1) R 43 200

10% Supervision fees R 4 320

Sub-total (2) R 47 520

14% VAT R 6 653

TOTAL R 54 173

say R 55 000

The quantum of the financial provision required is therefore: R55 000. The Applicant must annually update and review the quantum of the financial provision The Applicant undertakes to provide financial provision and a Bank Guarantee will be the method of providing for the financial provision.

15. ANY OTHER SPECIFIC INFORMATION (any specific information that may be required by the competent authority)

None requested.



PART B: ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPr)

16. EMPr: INTRODUCTION

16.1 Details and expertise of the EAP

The details and expertise of the EAP have been included in PART A, the Basic Assessment Report.

16.2 Description of the aspects of the activity that are covered by the EMPr

The aspects of the activity have been described in PART A, the Basic Assessment Report.

16.3 Site map

(a map at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoiding including buffers) A site map is included in the Basic Assessment Report (see Figures 2 and 3).

17. IMPACT MANAGEMENT OBJECTIVES

17.1 Closure and environmental objectives

The closure and environmental objectives have already been described in the BAR and are repeated below: Objective 1: To ensure effective rehabilitation of the mining permit area. Outcomes:

The site is to be shaped and levelled to match the adjacent topography.

Topsoil to be replaced over the mined areas.

Pasture grass is to be planted over the previously mined area. Objective 2: To minimise pollution or degradation of the environment. Outcomes:

Ensure that no fuel or oil spills occur in the mining area.

Ensure that no solid waste or rubble is dumped on the site.

Ensure that portable toilets are used. Objective 3: To minimise impacts on the community. Outcomes:

To ensure that workers remain within the mining permit area.

To operate during normal working hours only.

To minimise the generation of noise and dust.

To respond rapidly to any complaints received.



17.2 Closure

The decommissioning of the mine will require a closure certificate in terms of section 43 of the MPRDA. This is also Listed Activity 22 in Listing Notice 1 of the EIA Regulations, 2014. The contents of the closure plan are prescribed in Appendix 5 of the EIA Regulations, 2014 and must contain, inter alia:

The closure objectives;

The proposed mechanisms for monitoring compliance with and performance assessment against the closure plan;

The time periods within which the measures contemplated in the closure plan must be implemented;

The details of all public participation processes conducted; and

The details of any financial provision for the rehabilitation, closure and on-going post decommissioning management of negative environmental impacts.

17.3 Impact management outcomes

See Section 17.1 (above).



18. IMPACT MANAGEMENT ACTIONS (1(f) in Appendix 4 of the EIA Regulations, 2014: A description of proposed impact management actions)

18.1 Introduction

This section contains guidelines, operating procedures and rehabilitation/pollution control requirements which will be binding on the holder of the mining permit after the granting of the environmental authorisation and the approval of the Environmental Management Programme. It is essential that this portion be carefully studied, understood, implemented and adhered to at all time. The Applicant shall ensure that this Environmental Management Programme is provided to the Mine Manager and any other person or organisation who may work on the site. The Applicant shall ensure that any person or organisation that works on the site complies with the requirements of this Environmental Management Plan.

18.2 Responsibility

The affected environment shall be maintained in a stable condition that will not be detrimental to the safety and health of humans and animals and that will not pollute the environment or lead to the degradation thereof.

The environment affected by the mining operation shall be effectively rehabilitated, so that the land can be used for agricultural purposes.

It is the responsibility of the Applicant to ensure that the manager on the site and the employees are capable of complying with all the statutory requirements that must be met in order to mine, which includes the implementation of this EMPr.

Schedule Ongoing, throughout the life of the mine.

18.3 Demarcation of the mining area

The mining area is to be clearly demarcated by means of painted beacons at its corners. Mining operations will only take place within this demarcated area. Schedule Annual check to see that corner beacons are still in place.

18.4 Community relations

The Applicant shall erect and maintain a notice board at the entrance to the Mine. The notice board shall include contact details for complaints by the neighbours and members of the public. The Applicant shall keep a “Complaints Register” on site. The Register shall contain the contact details of the person who made the complaint, and information regarding the complaint itself. The Applicant shall respond to all complaints within seven days. Copies of all responses should be kept together with the Register. Schedule Ongoing, throughout the life of the mine.

18.5 Topsoil

As each mining block is cleared and prepared for mining, the topsoil shall be removed. The topsoil should be stockpiled on previously cleared and level ground. The stockpiles shall not be



higher than 2m in order to minimize compaction. The stockpiled topsoil must be protected from erosion. The Mine Manager must choose suitable locations for topsoil stockpiles. The topsoil stockpiles must be kept within the mining permit area. As mining progresses and land is made available for rehabilitation, then the topsoil shall be evenly spread over the land. Topsoil shall not be used for building or maintenance of access roads or for any purpose other than rehabilitating the land. Schedule Ongoing, throughout the life of the mine.

18.6 Mining depth

In order to protect the underlying groundwater, the estimated mining depth is 3m below surface. As soon as the lower weathered calcrete is encountered then mining should be stopped even if this occurs less than 3m below surface. Schedule Ongoing, throughout the life of the mine.

18.7 Rehabilitation and storm water control

Topsoil stripping, stockpiling and re-spreading must be done in a systematic way. The mining plan should be such that topsoil is stockpiled for the minimum possible time by rehabilitating different mining blocks progressively as the mining process continues. To ensure minimum impact on drainage, it is important that no depressions are left in the mining floor. A surface slope (even if minimal) must be maintained across the mining floor in the drainage direction, so that all excavations are free draining. The channelling of run-off below the mining areas, which could erode lands down-slope, must be controlled with an effective run-off control system using temporary bunds where necessary. After mining, any steep slopes at the edges of excavations must be reduced to a minimum and profiled to blend with the surrounding topography. The stockpiled topsoil must then be evenly spread over the entire mining area, so that there is a depth of 50cm of sandy topsoil above the underlying clay. The depth should be monitored during spreading to ensure that coverage is adequate and even. Topsoil spreading should be done at a time of year when vegetation cover can be established as quickly as possible afterwards, so that erosion of returned topsoil by both rain and wind, before vegetation is established, is minimised. The best time of year is at the end of the rainy season, when there is moisture in the soil for vegetation establishment and the risk of heavy rainfall events is minimal. A cover crop (pasture grass) must be planted and established immediately after spreading of topsoil, to stabilise the soil and protect it from erosion. The cover crop should be fertilized for optimum production. It is important that rehabilitation is taken up to the point of cover crop stabilisation. Rehabilitation cannot be considered to be complete until the first cover crop is well established.



The rehabilitated area must be monitored for erosion, and appropriately stabilised if any erosion occurs. Rehabilitation progress (with photographs) is to be documented in the required environmental audit reports. Schedule Ongoing, throughout the life of the mine. Progress to be reported in environmental audit reports.

18.8 Control of invasive alien vegetation

Disturbed areas are susceptible to invasion by alien Acacia spp. (i.e. Port Jackson or

Rooikrants). If the mined areas are rehabilitated back to land that is suitable for cultivation within a short period of time, it will be difficult for alien invasive vegetation to get established. The correct procedure for the removal of alien Acacia spp. is as follows:

1. Hand cut the stem as low as possible to ground level and apply herbicide immediately to the exposed stump, using a Garlon/diesel or Roundup/water mixture applied with a paintbrush/ Knapsack sprayer [mixture rate appr. 5% herbicide to 95% carrier agent].

2. Avoid herbicide drift onto other plants. 3. Dye can be added to above mixture to ensure that individual plants are not missed. 4. Hand cutting can be performed with tools, brushcutter or chainsaw. 5. Follow up annually by pulling out the alien invasive seedlings by hand or using a

“Treepopper”. 6. Take care not to damage indigenous vegetation by trampling or stacking alien vegetation

on top of it. If alien vegetation clearance is required it could be conducted by suitable contractors or, alternatively, if the company plans to employ its own workers to clear alien vegetation, then these workers should first receive training from an experienced Nature Conservator. Schedule Ongoing, throughout the life of the mine.

18.9 Protection of animal life

It is anticipated that the noise and general activity will keep the animal life away from the site while the mining is ongoing. However, if animals are encountered during the mining operations they must not be killed or injured. Any animals encountered during the mining operations should be taken to a Nature Reserve. If necessary, a suitable trained nature conservation official should be called in to remove dangerous animals (e.g. venomous snakes). Schedule Ongoing, throughout the life of the mine.

18.10 Illegal Dumping of Rubble

Access to the site will be controlled at all times. The public will not have access to the site. The Mine will not be used for the dumping of rubble. The environmental awareness training will ensure that all workers are aware of this commitment. Any vehicle that is caught illegally dumping rubble will be reported to the Saldanha Bay Municipality immediately. Schedule Ongoing, throughout the life of the mine.



18.11 Dust

During mining operations, all reasonable measures must be taken to minimise the generation of dust and to prevent windblown sand. These measures include:

Removal of vegetation shall be avoided until such time as soil stripping is required and similarly exposed surfaces (especially mined out areas) shall be rehabilitated or stabilised as soon as is practically possible.

Excavation, handling and transport of calcrete, sand and topsoil shall be avoided under high wind conditions or when a visible dust plume is present.

During high wind conditions, the Mine Manager will evaluate the situation and make recommendations as to whether dust-damping measures are adequate, or whether working will cease altogether until the wind speed drops to an acceptable level.

Where possible, soil stockpiles shall be located in sheltered areas where they are not exposed to the erosive effects of the wind. Where erosion of stockpiles becomes a problem, erosion control measures shall be implemented at the discretion of the Mine Manager.

Vehicle speeds shall not exceed 35 km/hour along the access road.

Appropriate dust suppression measures shall be used when dust generation is unavoidable, e.g. dampening with water, particularly during prolonged periods of dry weather in summer. Such measures could also include the use of temporary stabilising measures (e.g. chemical soil binders, straw, brush packs, chipping etc.).

Schedule Ongoing, throughout the life of the mine.

18.12 Noise

The Applicant will limit the noise levels on the site by taking the following measures:

Work will be restricted to the following operating hours: o 6:30 am to 5:00 pm Mondays to Fridays o 7:00 am to 2:00 pm Saturdays o Closed Sundays

Equipment will be regularly maintained.

Silencers will be installed and maintained on machinery, trucks and earth moving equipment.

No amplified music will be allowed on the site. Schedule Ongoing, throughout the life of the mine.

18.13 Maintenance and fuel

No workshop is planned for the site, however if emergency maintenance is required, Tip Trans Resources must ensure that no pollution occurs. When servicing equipment, drip trays shall be used to collect the waste oil, hydraulic fluid and other lubricants. Vehicles and equipment used in the mining operation must be adequately maintained so that no spillage of oil, diesel, petrol or hydraulic fluid occurs. Any hazardous substances such as detergents, fuels, oils etc. shall be securely stored at the Tip Trans depot at Klipheuwel Park (i.e. not on the mining permit site) The earth moving equipment will be re-fuelled using a diesel bowser. Drip trays are to be used when re-fuelling takes place to prevent any diesel spillage on the ground. All other vehicles (e.g. bakkies) will be refuelled at the depot or at a commercial garage.



Tip Trans Resources shall ensure that there is always a supply of absorbent material available to absorb / breakdown / encapsulate minor hydrocarbon spills. The quantity of such materials shall be able to handle a minimum of a 200 litre hydrocarbon spill. Used oil should be collected in a suitable container (e.g. 210 litre drums or a tank provided by the Rose Foundation). The container shall be kept in a protected and bunded area. When the container is almost full then this should be removed from the depot, either for resale or for recycling. (Oilkol collects used oil on behalf of the Rose Foundation and can be contacted at: 0860 107107). Any effluents or waste containing oil, grease or other industrial substances must be collected in a suitable container and removed from the depot, either for resale, recycling or for appropriate disposal at a recognised facility. Schedule Ongoing, throughout the life of the mine.

18.14 Solid Waste Management

An integrated waste management approach, which is based on waste minimisation and incorporates reduction, recycling, re-use and disposal, where appropriate, must be used. No on-site burying or dumping of any waste materials, litter or refuse shall occur. The Applicant will use vermin- and weather-proof bins with lids to store any solid waste. The lids shall be kept firmly on the bins at all times. Waste will be disposed at an approved waste disposal facility. Schedule Ongoing, throughout the life of the mine.

18.15 Effluents

Any effluents containing oil, grease or other industrial substances must be collected in a suitable receptacle and removed from the site, either for resale, recycling or for appropriate disposal at a recognised facility. Schedule On-going, throughout the life of the mine.

18.16 Toilets

Portable toilets will be used in the mining area. These facilities shall be maintained in a hygienic state and serviced regularly. The temporary/portable toilets shall be secured to the ground to prevent them toppling due to the wind or any other cause. Schedule Ongoing, throughout the life of the mine.

18.17 Road Safety and Access

The speed of all vehicles must be strictly controlled to avoid dangerous conditions or excessive dust. No vehicles should travel at more than 35 km/hour while driving along the access track. Schedule



Ongoing, throughout the life of the mine.

18.18 Heritage Resources

Contractors, staff and plant operators should be briefed about what to look out for with regard to heritage resources during clearing and mining operations.

All fossils are protected by law. Should anything of a palaeontological or archaeological nature be encountered on site by the Contractor (or any other party), e.g. bones, artefacts or wetland deposits, work is to be stopped in that area immediately, and the OM / Principal Agent notified. Failure to do so will result in a penalty and this must be carefully explained to workers during the Environmental Education Programme undertaken by the OM.

Mining should be monitored by a palaeontologist or archaeologist with appropriate palaeontological knowledge. This should start at the same time as mining and the subsequent frequency of this is to be worked out a priori with the contractor to minimize time spent on site.

A training session to familiarize contractor’s staff, including machine operators, has proved important at other sites in the Saldanha region and has led to more efficient recovery of scientifically important material with minimal or no delays; given the scale of mining a temporary shift of the operation a few metres until a find is assessed and removed should not be a problem.

Given the known palaeontological potential of the region, mitigationary action, beyond simple recording and recovery during monitoring, including the possibility of systematic excavations, while unlikely, may be necessary. In the event of palaeontological material being encountered, the OM will demarcate the area and notify the appointed specialist (palaeontologist/ archaeologist with appropriate experience) who will view the material and ascertain whether further study of the area is required.

Should the specialist confirm a genuine fossil or sub-fossil and recommend further study of the area, work in the applicable area is to cease until further notice while arrangements are put in place. The appointed palaeontologist/ archaeologist will report finds to Heritage Western Cape (HWC).

The removal of discovered palaeontological or archaeological remains, by a contracted specialist shall be at the expense of Tip Trans Resources (Pty) Ltd.

18.19 Environmental Related Emergencies and Remediation

The Applicant will operate on the principle that “prevention is better than cure” and so will institute procedures to reduce the risk of emergencies taking place. These will include ensuring that all contracts specify that the contractor is required to comply with all the environmental measures specified in this EMPr, environmental awareness training, on-going risk assessment and emergency preparedness. Emergency telephone numbers All employees shall have the telephone numbers of emergency services, including the local ambulance and firefighting service. All employees must be made aware of procedures to be followed during the environmental awareness training course. Fire The Applicant shall ensure that there is basic firefighting equipment available on Site at all times. This shall include at least two rubber beaters and at least one fire extinguisher. The Applicant shall advise the relevant authority of a fire as soon as one starts and shall not wait until the fire is out of control.



Hydrocarbon spills The Applicant shall ensure that all employees are aware of the procedures to be followed for dealing with hydrocarbon spills. The Applicant shall ensure that the necessary materials and equipment for dealing with hydrocarbon spills and leaks is available on Site at all times. The Applicant shall ensure that there is always a supply of absorbent material readily available to absorb/ breakdown and where possible is designed to encapsulate minor hydrocarbon spillage. The quantity of such materials shall be able to handle a minimum of 200 l of hydrocarbon liquid spill. There are a number of different products on the market, which can be used as absorbents and encapsulators of hydrocarbons. The following are examples of these products:

Spill-Sorb

Drizzit

Enretech

Peat Moss In the event of a significant hydrocarbon spill, the following procedure is required:

The source of the spillage shall be isolated

The spillage must be contained using sand berms, sandbags, pre-made booms, sawdust or absorbent materials.

The area shall be cordoned off, secured and made safe.

If a serious spill has occurred in a sensitive environment, then the Department of Environmental Affairs and Development Planning: Directorate Pollution & Waste Management must be notified (Telephone: 021 483 2798).

Treatment and remediation of spill areas shall be undertaken to the satisfaction of the Mine Manager. Remediation may include in-situ bioremediation using appropriate products (e.g. Enretech-1) and / or the removal of the spillage together with the contaminated soil and the disposal at a recognised waste disposal facility. Any contaminated spill kit cleaning materials must be disposed of at a hazardous waste disposal facility.



19. MONITORING & REPORTING

19.1 Introduction

Regular monitoring of the conditions of approval of the environmental authorisation and the environmental management procedures and mitigation measures in this EMPr shall be carried out by Tip Trans Resources. Tip Trans Resources will ensure that compliance with the conditions of the environmental authorisation and the EMPr are audited and that an environmental audit report is submitted to the competent authority (i.e. the DMR). The environmental audit report is required to contain the information set out in Appendix 7 of the EIA Regulations, 2014. Schedule The Mine Manager will monitor compliance with the conditions of the environmental authorisation and the EMPr on an on-going basis. The environmental audit report is to be prepared by an independent person with the relevant environmental auditing expertise every two years or more frequently if required to do so by the competent authority.

19.2 Dust

Tip Trans Resources (Pty) Ltd is aware that in the event of an instruction from the Saldanha Bay Municipality or the Air Quality Officer from the West Coast District Municipality that dust fall monitoring may be called for to determine the extent of dust and fugitive dust emissions from the premises. The National Dust Control Regulations, 2013 (GN R827 of 2013) provides the standards for acceptable dust fall rates. These are shown below in Table 20:

Table 22: Acceptable dust fall rates

Restriction Areas Dust fall rate (D) (mg/m2/day, 30-days average)

Permitted frequency of exceeding dust fall rate

Residential area D < 600 Two within a year, not sequential months

Non-residential area 600 < D < 1200 Two within a year, not sequential months

The method to be used for measuring dust fall rate and the guideline for locating sampling points shall be ASTM D1739:1970, or equivalent method recognised by an internationally recognised body.

In the event that dust fall monitoring is required then Tip Trans Resources (Pty) Ltd will contract a suitable air quality specialist to install sampling / monitoring points at appropriate locations on the property boundaries. If it is determined that the dust fall rate exceeds the Non-residential Standard then corrective action will be taken to ensure compliance.



20. ENVIRONMENTAL AWARENESS PLAN General environmental awareness will be fostered among the project's workforce to encourage the implementation of environmentally sound practices throughout its duration. This will ensures that environmental incidents are minimised and environmental compliance maximised. Environmental awareness will be fostered in the following manner:

Induction course for all workers on site, before commencing work on site.

Refresher courses as and when required

Toolbox talks at the start of a day when workers can be alerted to particular environmental concerns associated with their tasks for that day or the area/habitat in which they are working.

Displaying of information posters and other environmental awareness material. The aim of training is to enable a shared understanding and common vision of the environment, the impact of the mining operation on the environment (and why this is important) and the role of mining personnel in terms of environmental management and compliance. The induction course will consist of the following steps:

The first step will be a background discussion about the environment: what it consists of, and how we interact with it.

The second step will be a description of the components and phases of the mining operation.

The third step will be a general account of how the mining operation and its associated activities can affect the environment, giving rise to Environmental Impacts.

The fourth and most important step will be a discussion of what staff can do in order to help prevent the negative environmental impacts from degrading our environment and why the company is required to comply with the approved Environmental Management Programme.

An environmental awareness handout for mine workers is provided in Appendix 5.

Schedule Employees should be provided with environmental awareness training before mining operations start. All new employees should be provided with environmental awareness training.



21. UNDERTAKING BY THE EAP The Environmental Assessment Practitioner (EAP) herewith confirms a) the correctness of the information provided in the BAR and EMPr; b) the inclusion of comments and inputs from stakeholders and I&APs; c) the inclusion of inputs and recommendations from the specialist reports where relevant; d) any information provided by the EAP to interested and affected parties and any

responses by the EAP to comments or inputs made by interested and affected parties

Signature of the environmental assessment practitioner: Name: Barry Wiesner Name of company: Amathemba Environmental Management Consulting CC Date: 27 February 2018

Documents

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