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ENVIRONMENTAL MANAGEMENT FRAMEWORK DESIRED STATE OF ENVIRONMENT REPORT FOR VHEMBE DISTRICT, LIMPOPO Prepared by: Mr Victor Mongwe Director: Environmental Impact Regulation

ENVIRONMENTAL MANAGEMENT FRAMEWORK DESIRED …Environmental Management Framework (EMF) for Vhembe District, Limpopo – Desired State of Environment 8 1.0 Chapter One – Introduction

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Page 1: ENVIRONMENTAL MANAGEMENT FRAMEWORK DESIRED …Environmental Management Framework (EMF) for Vhembe District, Limpopo – Desired State of Environment 8 1.0 Chapter One – Introduction

ENVIRONMENTAL MANAGEMENT FRAMEWORK

DESIRED STATE OF ENVIRONMENT

REPORT

FOR

VHEMBE DISTRICT, LIMPOPO

Prepared by:

Mr Victor Mongwe

Director: Environmental Impact Regulation

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Title and Report Approval Page

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Report Amendments Page

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Table of Contents

Title and Report Approval Page ............................................................ 1

Report Amendments Page ................................................................... 2

Table of Contents ............................................................................. 3

List of Acronyms .............................................................................. 6

Executive Summary .......................................................................... 7

1.0 Chapter One – Introduction .......................................................... 8

1.1 Project Background .................................................................. 8

1.2 EMF Study Area ....................................................................... 8

1.3 Vhembe District Boundaries ........................................................ 8

1.4 EMF Objectives ....................................................................... 8

1.5 EMF Development Approach and Methodology .................................. 8

1.6 Establishing a Desired State ........................................................ 8

1.7 Assumptions, Limitations and Gaps ............................................... 8

2.0 Chapter Two – Management Priorities ............................................. 9

2.1 Vison for Vhembe District ......................................................... 9

2.1.1 Vhembe District ................................................................. 9

2.2 Environment Feature – Based Management Priorities ....................... 9

2.2.1 Topography ...................................................................... 9

2.2.2 Climate ........................................................................... 9

2.2.3 Soils and Agricultural Potential ............................................... 9

2.2.4 Geology and Mineral Resources ............................................... 9

2.2.5 Ecology and Bio-Diversity ...................................................... 9

2.2.6 Conservation, Wildlife and Nature Reserves ................................ 9

2.2.7 Surface Water Resources and Management ................................. 9

2.2.8 Geohydrology and Underground Water Resource .......................... 9

2.2.9 Air Quality and Climate Change .............................................. 9

2.2.10 Energy Use ..................................................................... 10

2.2.11 Waste Management ........................................................... 10

2.2.12 Heritage, Cultural and Archaeological Aspects ........................... 10

2.3 Socio-Economic Development Trends and Pressures ...................... 11

2.3.1 Provincial Planning Framework ............................................. 11

2.3.2 Limpopo Provincial Growth and Development Strategy ................. 11

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2.3.3 Local Planning Framework ................................................... 11

2.3.4 Threats to the Environment ................................................. 11

2.4 Planning and Development Opportunities and Constraints ............... 11

2.4.1 Development Opportunities ................................................. 11

2.4.2 District and Local Municipality Competitive Advantage ................. 11

2.4.3 Environmental Opportunities for Development........................... 11

2.4.4 Development Constraints .................................................... 11

2.5 Future Planned Management Priorities ....................................... 11

3.0 Chapter Two – Sensitivity Analysis for Vhembe District ..................... 12

3.1 Determining Sensitivity and Constraint Zones per Environment Feature

12

3.1.1 Topography .................................................................... 12

3.1.2 Climate ......................................................................... 12

3.1.3 Soils and Agricultural Potential ............................................. 12

3.1.4 Geology and Mineral Resources ............................................. 12

3.1.5 Ecology and Bio-Diversity .................................................... 12

3.1.6 Conservation, Wildlife and Nature Reserves .............................. 12

3.1.7 Surface Water Resources and Management ............................... 12

3.1.8 Geohydrology and Underground Water Resource ........................ 12

3.1.9 Air Quality and Climate Change ............................................ 12

3.1.10 Energy Use ..................................................................... 18

3.1.11 Waste Management ........................................................... 18

3.1.12 Heritage, Cultural and Archaeological Aspects ........................... 18

3.2 Socio-Economic Development Trends and Pressures ...................... 18

3.2.1 ...................................................................................... 18

3.3 Planning and Development Opportunities and Constraints ............... 18

3.3.1 ...................................................................................... 18

3.4 Environmental Constraint Zones ............................................... 18

4.0 Chapter Five – Public Participation Process .................................... 19

4.1 Approach to Stakeholder Engagement .......................................... 19

4.2 Advertisements ..................................................................... 19

4.3 Consultation Meetings and Workshops .......................................... 19

4.4 Summary of Issues Raised ......................................................... 19

4.5 EMF Implications ................................................................... 19

4.6 Review of the Draft Desired State of Environment Report .................. 19

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4.7 Final Desired State of Environment Report .................................... 19

5.0 Chapter Five – Environmental Management Zones ............................ 20

5.1 Biophysical Environment ........................................................ 20

5.1.1 Topography .................................................................... 20

5.1.2 Climate ......................................................................... 20

5.1.3 Soils and Agricultural Potential ............................................. 20

5.1.4 Geology and Mineral Resources ............................................. 20

5.1.5 Ecology and Bio-Diversity .................................................... 20

5.1.6 Conservation, Wildlife and Nature Reserves .............................. 20

5.1.7 Surface Water Resources and Management ............................... 21

5.1.8 Geohydrology and Underground Water Resource ........................ 21

5.1.9 Air Quality and Climate Change ............................................ 21

5.1.10 Energy Use ..................................................................... 26

5.1.11 Waste Management ........................................................... 26

5.1.12 Heritage, Cultural and Archaeological Aspects ........................... 26

5.2 Socio-Economic Environment and Development Trends .................. 26

5.2.1 Infrastructure .................................................................. 26

5.2.2 Economic Sectors ............................................................. 26

5.3 Planning and Development ...................................................... 26

5.3.1 Settlement Patterns .......................................................... 26

5.3.2 Land-Use and Ownership ..................................................... 26

5.3.3 Planned Development Nodes ................................................ 26

6.0 References ............................................................................ 27

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List of Acronyms

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Executive Summary

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1.0 Chapter One – Introduction

1.1 Project Background

1.2 EMF Study Area

1.3 Vhembe District Boundaries

1.4 EMF Objectives

1.5 EMF Development Approach and Methodology

1.6 Establishing a Desired State

1.7 Assumptions, Limitations and Gaps

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2.0 Chapter Two – Management Priorities

2.1 Vison for Vhembe District

2.1.1 Vhembe District

2.2 Environment Feature – Based Management Priorities

2.2.1 Topography

2.2.2 Climate

2.2.3 Soils and Agricultural Potential

2.2.3.1 Soil

2.2.3.2 Agricultural Potential

2.2.4 Geology and Mineral Resources

2.2.4.1 Geology

2.2.4.2 Mineral Resource

2.2.5 Ecology and Bio-Diversity

2.2.5.1 Flora

2.2.5.2 Fauna

2.2.6 Conservation, Wildlife and Nature Reserves

2.2.7 Surface Water Resources and Management

2.2.8 Geohydrology and Underground Water Resource

2.2.9 Air Quality and Climate Change

2.2.9.1 Air Quality

Findings of the Status Quo Report

The following key findings were identified during the status quo assessment.

• The prevailing wind field near Tshipise is from the south-east, but an east-west pattern was

recorded at the Thohoyando weather station. The variability in wind field across the DM is

likely related to the large topographic formations resulting in localised wind fields.

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• The status of active monitoring locations managed by the DM is uncertain and atmospheric

pollutant concentrations are therefore also unknown.

• The identified emission sources included:

o Industrial, mining, and commercial operations

o Waste management facilities

o Road traffic

o Domestic fuel burning

o Biomass burning

o Agricultural activities

• The main pollutants of concern identified in the DM are mainly criteria pollutants

(Particulates (TSP; PM10 and PM2.5); sulfur dioxide (SO2); oxides of nitrogen (NOx); and carbon

monoxide (CO)). Hydrocarbons, Volatile Organic Compounds (VOCs) and sulfur trioxide are

smaller contributors.

• In terms of emissions of criteria pollutants the top sources contributing to ambient

concentration were domestic fuel burning; mining; or, road traffic, depending on the

pollutant considered.

Management Priorities

Based on the findings of the status quo assessment of air quality within the VDM, the following

management priorities were identified.

• Limited good-quality meteorological data restricts the understanding of pollutant dispersion

potential.

• Limited ambient air pollutant concentrations are publically available. Network maintenance

and data distribution are additional limitations within the DM.

• The existing information lacks detail, for example: the location of some facilities and their

operational status). The AEL status of some facilities is also unknown in that some facilities

that require an AEL to operate may not have a valid certificate. Similarly the status of smaller

industries, schools and hospitals that operate boilers (or other controlled emitter

combustion sources) is unknown.

• Air Quality Management capacity (especially human and financial resources) within the

Province and VDM was identified in the gap and problem analysis phase of the Limpopo

AQMP (2013), and in the Vhembe AQMP (2015). It is assumed that this is still a management

priority.

2.2.9.2 Climate Change

2.2.10 Energy Use

2.2.11 Waste Management

2.2.12 Heritage, Cultural and Archaeological Aspects

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2.3 Socio-Economic Development Trends and Pressures

2.3.1 Provincial Planning Framework

2.3.2 Limpopo Provincial Growth and Development Strategy

2.3.3 Local Planning Framework

2.3.4 Threats to the Environment

2.4 Planning and Development Opportunities and Constraints

2.4.1 Development Opportunities

2.4.2 District and Local Municipality Competitive Advantage

2.4.3 Environmental Opportunities for Development

2.4.4 Development Constraints

2.5 Future Planned Management Priorities

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3.0 Chapter Two – Sensitivity Analysis for Vhembe District

3.1 Determining Sensitivity and Constraint Zones per Environment Feature

3.1.1 Topography

3.1.2 Climate

3.1.3 Soils and Agricultural Potential

3.1.3.1 Soil

3.1.3.2 Agricultural Potential

3.1.4 Geology and Mineral Resources

3.1.4.1 Geology

3.1.4.2 Mineral Resource

3.1.5 Ecology and Bio-Diversity

3.1.5.1 Flora

3.1.5.2 Fauna

3.1.6 Conservation, Wildlife and Nature Reserves

3.1.7 Surface Water Resources and Management

3.1.8 Geohydrology and Underground Water Resource

3.1.9 Air Quality and Climate Change

3.1.9.1 Air Quality

The definition of constraint zones for air quality focussed on the impact of air quality (especially

degraded air quality) on human health (Table 1). Areas where air quality is already known to be

compromised, or suspected to be compromise based on existing air pollution sources, were

considered to have a higher sensitivity rating; accompanied with recommendations regarding

development of activities resulting in atmospheric emissions in the area. Areas where the air quality

is known, or assumed, to be good were assigned a lower sensitivity rating. Protected areas were

given a high sensitivity rating.

Table 1: Sensitivity rating for the definition of constraint zones from an air quality perspective

Sensitivity rating Numeric

rating Description AQ Description

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Restricted 1 Constraints exit against the activities associated with the environmental feature.

All formal protected areas (conservation areas) including a surrounding 5 km constraint zone, in order to protect air quality..

Low 2

The inherent feature status and sensitivity is already significantly degraded. Environmental goods and services are depleted / compromised. Any significant environmental-development change will not influence the current status.

Air quality is not degraded leaving capacity for development of activities that release atmospheric pollutants.

Medium 3

The inherent feature status and sensitivity will be moderately influenced by a significant environmental-development change.

Based on available information air quality is compliant with national standards. However, there is a moderate level of uncertainty with regards to extent of emissions and impact footprint. The areas considered to be knowledge gaps.

High 4

Environmental-development change may influence the current status of the feature, either negatively or positively. Feature offers intact environmental goods and services/ supports environmental goods and services offered by other features. Feature may be afforded legal protection status.

Area of degraded air quality. Development within separation distance should be preceded by baseline air quality assessment.

Very High 5

Environmental-development change will significantly influence the feature, either negatively or positively. Feature offers critical environmental goods and services. Features afforded legal protection status.

Area of poor air quality where further development of facilities emitting air pollutants would have cumulative impact on human health. Development within the area should be avoided until management of the area can show significant improvements in air quality.

Assumptions and limitations

The following assumptions and limitations apply to the definition of constraint zones from an air

quality perspective:

• Sensitivity rating of constraint zones was based on the impact of degraded air quality

(primarily) on human health as does the National Environmental Management: Air Quality

Act (NEM:AQA).

• Sensitivity rating of constraint zones was based on the best available information regarding

the ambient air quality across the district.

• The best available information regarding the location and operation of the large stationary

sources (such as industrial, mining, or domestic fuel burning) was used.

• In the absence of potential impact areas for all known atmospheric sources, internationally

accepted separation distances were used as conservative estimates of AQ impact footprint.

• In areas where there is a large uncertainty about air quality but where no large continuous

sources (such as industrial, mining, or domestic fuel burning) exist, it was assumed that the

air quality is likely to be good and a lower sensitivity rating was assigned.

Methodology

A total of 101 industrial, mining, and commercial operations were identified within the Vhembe DM.

However the location of only 9 operations could be verified. In order to estimate the impact of the

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atmospheric emissions from these operations internationally recognised separation distances were

used as indicative impact areas. Separation distances are used as an international best practice in

planning of new developments. These are (Wickham, 2012):

• simple to use by all parties (applicants, consultants, authorities, and general public);

• transparent because these are reproducible and consistent across all new developments of

the same type; and,

• generally more conservative than specific atmospheric dispersion modelling exercises.

On this basis, and for the high level assessment of constraint zones for an Environmental

Management Framework, it was decided that using separation distances would be an appropriate

method. Separation distances are used to include: to avoid locating incompatible activities adjacent

to each other; to minimise sensitivity issues; and to manage risk (Wickham, 2012).

We referred to the Auckland Council separation distances (Wickham, 2012) as they summarised

validated separations distances defined for the: Auckland Regional Plan: Air, Land, and Water (first

choice); South Australia Environmental Protection Agency (second choice); as well as Victoria, West

Australia and Tasmanian Environmental Protection Agencies. The separation distances used for the

VDM for constraint zones around facilities are given in Table 2. Where separation distances varied or

varied based on facility size, the most conservative value was used. All constraint zones around

facilities were given a sensitivity score of ‘high’. The constraint zone based on dispersion modelling

was joined with the constraint zones defined for the industrial, mining, and commercial operations.

No weighting was applied.

The Auckland Council also defined Constraint zones were also defined for residential areas. These

are considered to be reverse sensitivity areas where the separation distances are considered in

order to protect the residential communities from atmospheric and nuisance pollutants, especially

sensitive land-uses including schools, hospitals, parks, etc. The 500 m separation distance was

applied to all identified residential areas in the categories formal residential, informal residential,

and tradition residential, as defined in the StatsSA Census 2011 spatial data. In South Africa, and in

the VDM, residential areas can be a significant source of atmospheric pollutants through the

combustion of coal, wood, paraffin, liquid petroleum gas, and other biomass, the use of the

separation distance as constraint zone will also protect against developments that may add

significantly to the already potentially compromised air quality in these areas. In the informal and

traditional residential areas domestic fuel burning is likely to be used extensively, under the

assumption that household income and electricity supply rates are lower. However, population

density, as an indicator of density of domestic fuel burning use and number of people potentially

exposed to elevated pollutant concentrations, differs between these two residential area types.

Informal residential areas are likely to have higher population density and as a result the sensitivity

rating in these areas was given as ‘high’. In traditional residential areas, population density is lower

and domestic fuel burning sources are likely to be wider spread, therefore a sensitivity rating of

‘medium’ was applied to these areas.

In formal residential areas the use of domestic fuel burning is likely to be lower or less frequent, and

air quality is likely to be in compliance with the National Ambient Air Quality Standards1 (NAAQS).

Formal residential areas defined in the StatsSA 2011 Census data included some low-income

residential areas (identified by small buildings on small properties, separated by unpaved roads) in

which domestic fuel burning use will be similar to informal and traditional residential areas. Air

1 National Ambient Air Quality Standards exist for criteria pollutants

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quality is potentially degraded in these areas and a ‘high’ sensitivity rating was applied to all formal

residential areas.

Table 2: Separation distances used as constraint zones around existing facilities

Type of facility Separation

distance (m) Source

Mining 2 000 Tasmanian EPA for blasting (2011)

Bricks 500 South Australia EPA (2007) [for ceramics works]

Incinerator 1 000 South Australia EPA (2007)

Small boiler 300 South Australia EPA (2007) [>5MW]

Sawmill / wood processing 1 500 West Australian EPA (2005)

Abattoir 1 000 West Australian EPA (2015)

Residential areas 500 Wickham (2012)

Constraint zones around protected conservation areas were also considered. Since there are no

benchmarks for quantifying the impact of air pollutants on South African vegetation types it was

assumed that a conservative approach should be taken. A separation distance of 5 km around

protected areas was applied in order to facilitate the protection of air quality within protected areas.

Any proposed development within a protected area should be thoroughly investigated to ensure

that the cumulative effect will not significantly degrade the air quality. A sensitivity rating of

‘‘restricted’ was assigned to these areas.

Sensitivity rating to all feature-type constraint areas defined above are summarised in Table 3.

Table 3: Air quality sensitivity ratings for constraint zones

Feature type Sensitivity rating

Areas of potential non-compliance with NAAQS(a) Very High

Industry, Mining, Commercial operations High

Traditional residential areas Medium

Formal and Informal residential areas High

Protected areas (except mountain catchments) Restricted

Notes: (a) simulated using dispersion modelling for the Limpopo AQMP (2013)

Results

The resultant constraint zones based on the above methodology are shown in the following figures:

Figure 1- for industrial, mining, and commercial operations; Figure 2 – for residential areas; and,

Figure 3 – for protected / conservation areas.

During the sensitivity analysis of the district, the following constraint zones were identified:

• areas where non-compliance with NAAQS may already occur (with a high confidence);

• areas around industrial, mining, and commercial operations that result in atmospheric

pollution;

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• low-income areas (such as informal and traditional residential areas) where domestic fuel

burning is likely to be extensive and have low-level (breathing zone) impacts over extended

time periods; and,

• ecologically sensitive areas (protected areas) where no benchmarks for assessing impact,

result in a high degree of uncertainty with regards to the air quality

Figure 1: Air Quality Constraint zones around industrial, mining, and, commercial operations

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Figure 2: Air Quality Constraint zones associated with residential areas

Figure 3: Air Quality Constraint zones associated with conservation areas

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3.1.9.2 Climate Change

3.1.10 Energy Use

3.1.11 Waste Management

3.1.12 Heritage, Cultural and Archaeological Aspects

3.2 Socio-Economic Development Trends and Pressures

3.2.1

3.3 Planning and Development Opportunities and Constraints

3.3.1

3.4 Environmental Constraint Zones

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4.0 Chapter Five – Public Participation Process

4.1 Approach to Stakeholder Engagement

4.2 Advertisements

4.3 Consultation Meetings and Workshops

4.4 Summary of Issues Raised

4.5 EMF Implications

4.6 Review of the Draft Desired State of Environment Report

4.7 Final Desired State of Environment Report

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5.0 Chapter Five – Environmental Management Zones

Each work stream must cover:

• Delineating Environmental Management zones

• Managing conflicts between Development and Environmental Features

• Mapping Environmental Management Zones

5.1 Biophysical Environment

5.1.1 Topography

5.1.2 Climate

5.1.3 Soils and Agricultural Potential

5.1.3.1 Soil

5.1.3.2 Agricultural Potential

5.1.4 Geology and Mineral Resources

5.1.4.1 Geology

5.1.4.2 Mineral Resource

5.1.5 Ecology and Bio-Diversity

5.1.5.1 Flora

5.1.5.2 Fauna

5.1.6 Conservation, Wildlife and Nature Reserves

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5.1.7 Surface Water Resources and Management

5.1.8 Geohydrology and Underground Water Resource

5.1.9 Air Quality and Climate Change

5.1.9.1 Air Quality

Air quality management aims to improve air quality in areas where it is poor (in non-compliance with

NAAQS) and sustain air quality where it is good (low air pollution levels well within the NAAQSs). The

selection of management zones are therefore aimed to focus on areas with potentially poor air

quality and areas where, due to urbanization for example, the air quality may deteriorate due to

increases in air pollution sources (such as traffic, small boiler operations, new industries and mines).

Delineation of management zones

The air quality management zones were divided into three categories:

1. Priority Air Quality Management zones – areas with poor or potentially poor air quality.

These areas require a better understanding on the significance of current air pollution levels

by means of ambient monitoring, comprehensive emissions inventory of all pollution

sources and proactive improvement strategies to reduce air pollution levels (specifically

PM10). These include sensitivity ratings of High.

2. Sustainable Air Quality Management zones – areas with acceptable air quality but the

potential to be affected by future growth/ development. These include sensitivity ratings of

Medium.

3. Air Quality Constraint zones – areas with potentially good air quality that needs to be

protected. These include sensitivity ratings of Restricted.

Managing conflicts between development and environmental features

• facilities already operational within protected area constraint zones

• mining exploration in protected area constraint zones

• access to and maintenance of infrastructure

• domestic fuel burning as country-wide concerns linked with complex issues such as poverty

and access to affordable housing and electricity

Mapped Air Quality Management Zones are provided in Figures 4 to 10.

• The Priority Air Quality Management zones are primarily the areas around existing sources

of air pollution (mining (including exploration), small boilers and domestic fuel burning) and

the likelihood for future growth in these residential areas (increase in traffic, more

commercial and industrial operations, and increase in domestic fuel burning). These Priority

Air Quality Management zones fall within three of the Local Municipalities (LM) namely

Musina-; Makhado- and Thulamela Local Municipality.

o The Musina LM Priority Air Quality Management zones were selected due to

existing mining operations. One is close to a Rural Settlement Cluster (Figure 5) and

falls within the Musina Mining Cluster earmarked for diamond mining development.

None of these AQM zones falls within sensitive floristic areas (Figure 6).

o One of the two Makhado LM Priority Air Quality Management zones is in a

Provincial Growth Point, a Mining Cluster (coal mining exploration) (Figure 7) and in

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a High floristic sensitive area. The second zone is within a Very High floristic sensitive

area (Figure 8).

o The one Thulamela LM Priority Air Quality Management zone, as shown in Figure 9,

is close economic growth points (Regional Market, Urban node and Industrial Agro

Processing) and the second one is in a High floristic sensitive area (Figure 10).

• The Sustainable Air Quality Management zones are the formal residential areas where

there is a potential for increase air pollution due to the likelihood that people may migrate

from the rural areas to formal residential areas (Figure 5, Figure 7 and Figure 9). The towns

of Musina and Makhado are classified as a priority growth points. These areas need to be

monitored through passive sampling campaigns (summer and winter) to determine the

baseline air quality levels.

• The Air Quality Constraint zones are the conservation areas where air quality is suspected

to be good and needs to be sustained. These are also areas where further industrial

development is not desired.

Figure 4: Air Quality Management Zones

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Figure 5: Air Quality Management Zones in Musina Local Municipality in relation to Economic Growth Areas

Figure 6: Air Quality Management Zones in Musina Local Municipality in relation to Ecological and Biodiversity Sensitive Areas

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Figure 7: Air Quality Management Zones in Makhado Local Municipality in relation to

Economic Growth Areas

Figure 8: Air Quality Management Zones in Makhado Local Municipality in relation to

Ecological and Biodiversity Sensitive Areas

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Figure 9: Air Quality Management Zones in Thulamela Local Municipality in relation to

Economic Growth Areas

Figure 10: Air Quality Management Zones in Thulamela Local Municipality in relation to

Ecological and Biodiversity Sensitive Areas

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5.1.9.2 Climate Change

5.1.10 Energy Use

5.1.11 Waste Management

5.1.12 Heritage, Cultural and Archaeological Aspects

5.2 Socio-Economic Environment and Development Trends

5.2.1 Infrastructure

5.2.2 Economic Sectors

5.3 Planning and Development

5.3.1 Settlement Patterns

5.3.2 Land-Use and Ownership

5.3.3 Planned Development Nodes

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6.0 References

South Australia EPA, (2007). Guidelines for Separation Distances, South Australia Environment

Protection Authority, December 2007. Available at:

http://www.epa.sa.gov.au/xstd_files/Industry/Guideline/sepguidepcd.pdf

Tasmania Planning Commission, (2011). Attenuation Distances and Air Quality Code (working draft) supplied in confidence to Auckland Council by Department of Primary Industries, Parks, Water and Environment, personal comm Mike Power July, 2012. West Australia EPA, (2005). Guidance for the Assessment of Environmental Factors (in accordance

with the Environmental Protection Act 1986) Separation Distances between Industrial and Sensitive

Land Uses No. 3, Western Australia Environmental Protection Authority, June 2005.

West Australia EPA, (2015). Draft Environmental Assessment Guideline for Separation Distances

between Industrial and Sensitive Land Uses, Western Australia Environmental Protection Authority,

September 2015.

Wickham, L., (2012). Separation Distances for Industry, A discussion document prepared for

Auckland Council, July 2012. Prepared by Emission Impossible Ltd.