001 Fuleni DRAFT EIR.pdf

Viewer
Transcript

Mining Right Application KZN30/5/1/2/2/10060 MR In terms of Section 22 of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) Environmental Authorisation Application DC 28/0035/2013: KZN/EIA/0001371/2013 in terms of the Environmental Impact Assessment Regulations of 2010

FULENI ANTHRACITE PROJECT Draft Environmental Impact Report

IBUTHO COAL (PTY) LTD

May 2015

Compiled by: Jacana Environmentals cc PO Box 31675, Superbia, 0759

PROJECT DETAILS

Name of Project

Fuleni Anthracite Project

Reference Numbers

DMR Ref: KZN 30/5/1/2/2/10060 MR DAEA Ref: DC 28/0035/2013: KZN/EIA/0001371/2013

Name of Applicant

Ibutho Coal (Pty) Ltd

Representative

Mr Johan van den Berg

Designation

Company Director

Physical address

18 Bolton Road, Parkwood, Gauteng

Postal Address

PO Box 411333, Craighall, 2024

Telephone

082 857 0742

Facsimile

086 774 3512

E-mail

[email protected]

Environmental Assessment Practitioner

Jacana Environmentals cc

Responsible person

Marietjie Eksteen

Physical address

7 Landdros Mare Street, Polokwane

Postal Address

PO Box 31675, Superbia, 0759

Telephone

015 291 4015

Facsimile

086 668 4015

E-mail

[email protected]

i|Page

TABLE OF CONTENT _Toc419892743

1

PROJECT BACKGROUND ............................................................................................................ 1

1.1

INTRODUCTION ...........................................................................................................................................1

1.2 1.2.1 1.2.2 1.2.3 1.2.4 1.2.5 1.2.6 1.2.6.1 1.2.6.2 1.2.6.3

PROJECT LOCATION .....................................................................................................................................1 Surface Ownership ............................................................................................................................................. 3 Traditional Authority ......................................................................................................................................... 6 Institutional Arrangements ................................................................................................................................ 8 Land Claims ........................................................................................................................................................ 8 Exploration Right Applicant – Umbono CBM Somkhele .................................................................................... 8 Relevant Government Departments, Agencies and Institutions ....................................................................... 9 Provincial and Local Government Departments ................................................................................................ 9 Agencies and Institutions ................................................................................................................................... 9 Landowner / Traditional Authority .................................................................................................................... 9

1.3 1.3.1.1 1.3.1.2 1.3.1.3 1.3.1.4 1.3.1.5 1.3.1.6 1.3.2

COMMUNITY DESCRIPTION ....................................................................................................................... 10 Ntuthunga 1 Community ................................................................................................................................. 13 Ntuthunga 2 Community ................................................................................................................................. 13 Novunula Community ...................................................................................................................................... 13 Ocilwane .......................................................................................................................................................... 13 Fuyeni .............................................................................................................................................................. 13 eMakhwezini .................................................................................................................................................... 14 Sensitive Receptors .......................................................................................................................................... 14

1.4

BRIEF PROJECT DESCRIPTION..................................................................................................................... 15

1.5 1.5.1 1.5.2 1.5.2.1 1.5.2.2 1.5.2.3 1.5.3 1.5.4

LEGAL FRAMEWORK .................................................................................................................................. 16 APPLICABLE LEGISLATION ................................................................................................................................ 16 APPROACH TO ENVIRONMENTAL AUTHORISATION AND STAKEHOLDER ENGAGEMENT ............................... 18 Mining Right Application ................................................................................................................................. 18 Application for Environmental Authorisation .................................................................................................. 19 Water Use Application ..................................................................................................................................... 19 Environmental Assessment Practitioner (EAP) ................................................................................................ 19 EIA REPORT FRAMEWORK ............................................................................................................................... 20

1.6 1.6.1 1.6.2 1.6.2.1 1.6.2.2 1.6.2.3

NEED AND DESIRABILITY OF THE PROJECT ................................................................................................. 25 Economic Benefits ........................................................................................................................................... 25 Social and Labour Plan ..................................................................................................................................... 26 Job Creation ..................................................................................................................................................... 26 Workforce Development ................................................................................................................................. 26 Community Development ................................................................................................................................ 27

2 DESCRIPTION OF THE BASELINE CULTURAL, SOCIO-ECONOMIC AND BIOPHYSICAL ENVIRONMENT ..............................................................................................................28 ii | P a g e

2.1

SPECIALIST TEAM....................................................................................................................................... 28

2.2 CULTURAL AND HERITAGE RESOURCES ..................................................................................................... 34 2.2.1 Archaeological Context of the Area ................................................................................................................. 34 2.2.1.1 The Stone Age .................................................................................................................................................. 34 2.2.1.1.1 Early Stone Age ....................................................................................................................................... 34 2.2.1.1.2 Middle Stone Age ................................................................................................................................... 34 2.2.1.1.3 The Late Stone Age ................................................................................................................................. 35 2.2.1.2 The Iron Age ..................................................................................................................................................... 36 2.2.2 Initial Assessment of Sites in the Area ............................................................................................................. 37 2.2.2.1 Places Associated with Oral Traditions or Living Heritage ............................................................................... 37 2.2.2.2 Landscapes and Natural Features .................................................................................................................... 37 2.2.2.2.1 Hluhluwe-iMfolozi Park .......................................................................................................................... 38 2.2.2.2.2 Mfolozi River........................................................................................................................................... 38 2.2.2.3 Traditional Burial Places .................................................................................................................................. 39 2.2.2.4 Archaeological Sites ......................................................................................................................................... 39 2.3 SOCIO-ECONOMIC ENVIRONMENT ............................................................................................................ 40 2.3.1 Policy and Planning .......................................................................................................................................... 40 2.3.1.1 KwaZulu Natal Provincial Growth and Economic Development Strategy, 2011 .............................................. 40 2.3.1.2 KZN Tourism Master Plan ................................................................................................................................ 41 2.3.1.3 KZN Spatial Development Framework, 2012 ................................................................................................... 43 2.3.1.4 uThungulu Spatial Development Framework, 2012 ........................................................................................ 46 2.3.1.5 Mfolozi Integrated Development Plan, 2014/2015 review ............................................................................. 47 2.3.2 Regional Social Environment ........................................................................................................................... 48 2.3.2.1 Settlements ...................................................................................................................................................... 48 2.3.2.1.1 Urban Settlements.................................................................................................................................. 48 2.3.2.1.2 Rural Settlements ................................................................................................................................... 48 2.3.2.1.3 Settlement Patterns ............................................................................................................................... 48 2.3.2.2 Land Use .......................................................................................................................................................... 48 2.3.2.3 Demographics .................................................................................................................................................. 50 2.3.2.3.1 The Poverty Index ................................................................................................................................... 50 2.3.2.3.2 Languages ............................................................................................................................................... 50 2.3.2.3.3 Literacy Rates and Education ................................................................................................................. 50 2.3.2.3.4 HIV/AIDS ................................................................................................................................................. 50 2.3.2.4 Basic Services and Housing .............................................................................................................................. 50 2.3.2.4.1 Community Facilities .............................................................................................................................. 50 2.3.2.4.2 Water and Sanitation.............................................................................................................................. 51 2.3.2.4.3 Energy ..................................................................................................................................................... 52 2.3.2.4.4 Housing ................................................................................................................................................... 53 2.3.2.4.5 Access to Refuse Disposal ....................................................................................................................... 54 2.3.2.4.6 Safety and Security ................................................................................................................................. 55 2.3.2.4.7 Access Roads .......................................................................................................................................... 55 2.3.2.4.8 Communication (Landline, Mobile, Post Services, E-mail and Internet) ................................................ 56 2.3.2.5 Economic Profile .............................................................................................................................................. 56 2.3.2.5.1 Household Incomes ................................................................................................................................ 56 2.3.2.5.2 Sectors of Employment and Sources of Income ..................................................................................... 56 2.3.2.5.3 GDP per Sector in Mfolozi ...................................................................................................................... 57 2.3.2.5.4 Nature of the Mfolozi Economy ............................................................................................................. 57 2.3.3 Local Social Environment (Community Analysis) ............................................................................................. 59

iii | P a g e

2.3.3.1 Demographics .................................................................................................................................................. 59 2.3.3.1.1 Population and Households.................................................................................................................... 59 2.3.3.1.2 Age of household heads ......................................................................................................................... 60 2.3.3.1.3 Marital Status ......................................................................................................................................... 61 2.3.3.1.4 Gender Analysis ...................................................................................................................................... 61 2.3.3.1.5 Language................................................................................................................................................. 61 2.3.3.1.6 Qualifications and Literacy ..................................................................................................................... 62 2.3.3.2 Economic Status............................................................................................................................................... 62 2.3.3.2.1 Employment ........................................................................................................................................... 62 2.3.3.2.2 Household Income and Expenditure ...................................................................................................... 63 2.3.3.2.3 Local Businesses ..................................................................................................................................... 64 2.3.3.3 Agricultural Activities ....................................................................................................................................... 65 2.3.3.3.1 Agriculture – Crop farming ..................................................................................................................... 65 2.3.3.3.2 Agriculture – Livestock ........................................................................................................................... 65 2.3.3.3.3 Agriculture – Hunting ............................................................................................................................. 66 2.3.3.3.4 Medicinal Plants ..................................................................................................................................... 67 2.3.3.4 Services and Infrastructure .............................................................................................................................. 68 2.3.3.4.1 Water and Sanitation.............................................................................................................................. 68 2.3.3.4.2 Energy ..................................................................................................................................................... 69 2.3.3.4.3 Health Services ....................................................................................................................................... 69 2.3.3.4.4 Schools .................................................................................................................................................... 70 2.3.3.5 Grave Sites ....................................................................................................................................................... 70 2.3.4 Project Affected Persons ................................................................................................................................. 71 2.3.4.1 Ocilwane .......................................................................................................................................................... 71 2.3.4.2 Novunula .......................................................................................................................................................... 72 2.3.4.3 Ntuthunga 1 ..................................................................................................................................................... 73 2.3.4.4 Ntuthunga 2 ..................................................................................................................................................... 74 2.4 BIOPHYSICAL ENVIRONMENT .................................................................................................................... 76 2.4.1 LANDSCAPE ...................................................................................................................................................... 76 2.4.2 Climatic Data .................................................................................................................................................... 78 2.4.2.1 Climate zone .................................................................................................................................................... 78 2.4.2.1.1 Mfolozi WMA.......................................................................................................................................... 78 2.4.2.1.2 Local catchment in relation to MRA area ............................................................................................... 78 2.4.2.2 Temperature .................................................................................................................................................... 79 2.4.2.2.1 Mfolozi WMA.......................................................................................................................................... 79 2.4.2.2.2 Local catchment in relation to MRA area ............................................................................................... 79 2.4.2.3 Winds ............................................................................................................................................................... 82 2.4.2.3.1 Atmospheric Stability ............................................................................................................................. 82 2.4.2.4 Mean Annual Precipitation (MAP) and Mean Monthly Rainfall ...................................................................... 84 2.4.2.4.1 Mfolozi WMA.......................................................................................................................................... 84 2.4.2.4.2 Local catchment in relation to MRA area ............................................................................................... 85 2.4.2.5 Mean Annual Runoff and Evaporation ............................................................................................................ 87 2.4.2.5.1 Mfolozi WMA.......................................................................................................................................... 87 2.4.2.5.2 Local catchment in relation to MRA area ............................................................................................... 89 2.4.3 Soils .................................................................................................................................................................. 90 2.4.3.1 Soil Form and Morphological Features ............................................................................................................ 90 2.4.3.2 Soil Fertility Status ........................................................................................................................................... 91 2.4.3.3 Soil Salinity Status ............................................................................................................................................ 92

iv | P a g e

2.4.3.4 Pedohydrology ................................................................................................................................................. 93 2.4.4 Land Capability and Land Use .......................................................................................................................... 95 2.4.4.1 Agricultural Potential linked to Land Capability .............................................................................................. 95 2.4.4.2 Potential Crop Yield and Grazing Capacity ....................................................................................................... 99 2.4.5 Biodiversity – flora ......................................................................................................................................... 102 2.4.5.1 Floral Description ........................................................................................................................................... 102 2.4.5.1.1 Biome, bioregion and vegetation type ................................................................................................. 102 2.4.5.1.2 Northern Zululand Sourveld ................................................................................................................. 103 2.4.5.1.3 Zululand Lowveld .................................................................................................................................. 104 2.4.5.1.4 Zululand Coastal Thornveld .................................................................................................................. 105 2.4.5.1.5 Subtropical Freshwater Wetlands ........................................................................................................ 106 2.4.5.2 Habitat Descriptions ...................................................................................................................................... 108 2.4.5.2.1 Habitat Unit 1: Rocky ridge areas ......................................................................................................... 108 2.4.5.2.2 Habitat Unit 2: Wetland and Riparian habitat ...................................................................................... 111 2.4.5.2.3 Habitat Unit 3: Savanna Woodland ...................................................................................................... 113 2.4.5.2.4 Habitat Unit 4: Transformed areas ....................................................................................................... 116 2.4.5.2.5 Vegetation Index Score......................................................................................................................... 119 2.4.5.2.6 Exotic and Invader Species ................................................................................................................... 120 2.4.5.2.7 Medicinal Plant Species ........................................................................................................................ 120 2.4.5.2.8 RDL and Protected Floral Species Assessment ..................................................................................... 123 2.4.5.3 Sensitivity Mapping........................................................................................................................................ 125 2.4.6 Biodiversity – Fauna ....................................................................................................................................... 126 2.4.6.1 Mammals ....................................................................................................................................................... 126 2.4.6.2 Avifauna ......................................................................................................................................................... 128 2.4.6.3 Reptiles .......................................................................................................................................................... 130 2.4.6.4 Amphibians .................................................................................................................................................... 131 2.4.6.5 Invertebrates ................................................................................................................................................. 132 2.4.6.6 Spiders and scorpions .................................................................................................................................... 134 2.4.6.7 Faunal Red Data Species Assessment ............................................................................................................ 134 2.4.7 Surface Water ................................................................................................................................................ 136 2.4.7.1 Locality and Background Information ............................................................................................................ 136 2.4.7.2 Ecoregion ....................................................................................................................................................... 137 2.4.7.3 Wetlands ........................................................................................................................................................ 138 2.4.7.3.1 General Importance with regards to Wetland and Watercourse Conservation .................................. 138 2.4.7.3.2 Importance according to the Kwa-Zulu Natal Freshwater Systematic Conservation Plan (2007) ........ 143 2.4.7.3.3 Wetland / Riparian System Characterisation ....................................................................................... 143 2.4.7.3.4 Wetland Assessment ............................................................................................................................ 145 2.4.7.4 Water Quality................................................................................................................................................. 147 2.4.7.4.1 Mfolozi WMA........................................................................................................................................ 147 2.4.7.4.2 Water quality upstream and downstream of the MRA area ................................................................ 149 2.4.7.4.3 Water quality in the MRA area ............................................................................................................. 152 2.4.7.4.4 Erosion and sediment load ................................................................................................................... 154 2.4.7.5 Aquatic Assessment and Monitoring ............................................................................................................. 155 2.4.7.5.1 Biomonitoring Results .......................................................................................................................... 156 2.4.7.5.2 Ecological Importance and Sensitivity (EIS) Assessment ...................................................................... 156 2.4.7.5.3 Summary and Conclusions.................................................................................................................... 157 2.4.7.6 Current Water Use and Sources .................................................................................................................... 159 2.4.7.6.1 Mfolozi WMA........................................................................................................................................ 159 2.4.7.6.2 Community Water Use ......................................................................................................................... 161

v|Page

2.4.7.7 Flood Peak Assessment .................................................................................................................................. 162 2.4.8 Groundwater ................................................................................................................................................. 164 2.4.8.1 Hydrocensus .................................................................................................................................................. 164 2.4.8.2 Groundwater Flow Evaluation ....................................................................................................................... 165 2.4.8.2.1 Depth to water level ............................................................................................................................. 165 2.4.8.2.2 Flow gradients ...................................................................................................................................... 167 2.4.8.2.3 Aquifer types and yield ......................................................................................................................... 167 2.4.8.2.4 Aquifer transmissivity and storativity ................................................................................................... 169 2.4.8.2.5 Aquifer recharge and discharge rates .................................................................................................. 170 2.4.8.2.6 Direction and rate of groundwater movement in potentially impacted areas .................................... 170 2.4.8.3 Groundwater Quality Evaluation ................................................................................................................... 171 2.4.8.3.1 Hydrocensus boreholes ........................................................................................................................ 171 2.4.8.3.2 New monitoring boreholes ................................................................................................................... 178 2.4.9 Air Quality ...................................................................................................................................................... 182 2.4.9.1 Baseline Air Quality ........................................................................................................................................ 182 2.4.9.1.1 Agriculture ............................................................................................................................................ 182 2.4.9.1.2 Vehicles................................................................................................................................................. 182 2.4.9.1.3 Domestic fuel burning .......................................................................................................................... 183 2.4.9.1.4 Fugitive emissions from mining operations ......................................................................................... 183 2.4.9.1.5 Veld fires ............................................................................................................................................... 183 2.4.10 Ambient Noise ............................................................................................................................................... 185 2.4.10.1Ambient Noise Conditions ............................................................................................................................. 185 2.4.10.1.1 Summary of the residual sound pressure level measurements ........................................................... 185 2.4.10.1.2 Determination of night-time noise levels ............................................................................................. 185 2.4.10.2Noise Climate related to Road Traffic ........................................................................................................... 185 2.4.10.3Noise Climate related to Railway Traffic ....................................................................................................... 187 2.4.10.4Prevailing Noise Climate ................................................................................................................................ 188 2.5 2.5.1 2.5.1.1 2.5.1.2 2.5.1.3 2.5.2 2.5.2.1 2.5.2.2 2.5.2.3 2.5.2.4 2.5.2.5 2.5.2.6

ENVIRONMENTAL ASPECTS THAT MAY REQUIRE PROTECTION ............................................................... 191 Formally and Informally Protected Areas ...................................................................................................... 191 National Parks and Nature Reserves ............................................................................................................. 191 iMfolozi Wilderness Area ............................................................................................................................... 192 iSimangaliso Wetland Park and World Heritage Site ..................................................................................... 193 NATIONAL AND PROVINCIAL CONSERVATION INITIATIVES AND STRATEGIES............................................... 195 National List of Threatened Terrestrial Ecosystems for South Africa (2011) ................................................. 195 National Protected Areas Expansion Strategy, 2010 (NPAES) ....................................................................... 195 KwaZulu-Natal Systematic Conservation Plan, 2005 ..................................................................................... 196 KwaZulu Natal Terrestrial Biodiversity Priority Areas .................................................................................... 197 Important Bird Areas (IBA)............................................................................................................................. 198 Importance According to the Mining and Biodiversity Guideline (2012) ...................................................... 198

3

PROPOSED MINING OPERATION ....................................................................................... 200

3.1

MINERAL TO BE MINED ........................................................................................................................... 200

3.2

EXTENT OF THE OPERATION .................................................................................................................... 201

3.3 3.3.1

IMPLEMENTATION SCHEDULE ................................................................................................................. 204 Phase 1 Development .................................................................................................................................... 204

vi | P a g e

3.3.2 3.3.3 3.3.4

Phase 2 Development .................................................................................................................................... 204 Phase 3 Development .................................................................................................................................... 206 Phase 4 Development .................................................................................................................................... 206

3.4 3.4.1 3.4.1.1 3.4.1.2 3.4.2

MINING OPERATIONS .............................................................................................................................. 208 Methodology ................................................................................................................................................. 208 Open Pit Mining ............................................................................................................................................. 208 Underground Mining ..................................................................................................................................... 209 Mining Schedule ............................................................................................................................................ 210

3.5

COAL PROCESSING (BENEFICIATION) ....................................................................................................... 211

3.6 3.6.1 3.6.2 3.6.3

MATERIALS HANDLING REQUIREMENTS .................................................................................................. 214 Run of Mine (ROM) Area ............................................................................................................................... 214 Discards Stockpile .......................................................................................................................................... 214 Product Stockpiles and Handling ................................................................................................................... 214

3.7 3.7.1 3.7.2 3.7.2.1 3.7.2.2 3.7.3 3.7.3.1 3.7.3.2 3.7.3.3 3.7.3.4

INFRASTRUCTURE .................................................................................................................................... 215 Buildings......................................................................................................................................................... 215 Roads ............................................................................................................................................................. 216 Access Roads .................................................................................................................................................. 216 Road Diversions ............................................................................................................................................. 217 Storm Water Management ............................................................................................................................ 218 Separation of Clean and Dirty Water ............................................................................................................. 218 River Diversions ............................................................................................................................................. 218 Pollution Control Dams .................................................................................................................................. 218 Silt Traps ........................................................................................................................................................ 218

3.8

BULK POWER SUPPLY .............................................................................................................................. 219

3.9 BULK WATER SUPPLY .............................................................................................................................. 220 3.9.1 Water Requirements ..................................................................................................................................... 220 3.9.1.1 Potable Water ................................................................................................................................................ 220 3.9.1.2 Non-Potable Water ........................................................................................................................................ 220 3.9.1.2.1 Process water ....................................................................................................................................... 220 3.9.1.2.2 Dust suppression .................................................................................................................................. 220 3.9.1.2.3 Underground mining ............................................................................................................................ 220 3.9.2 Water Balance................................................................................................................................................ 221 3.9.3 Water Sources................................................................................................................................................ 223 3.10 MINE RESIDUE MANAGEMENT ................................................................................................................ 223 3.10.1 Mining Waste ................................................................................................................................................. 223 3.10.2 Non-Mining Waste ......................................................................................................................................... 224 3.10.2.1Sewage .......................................................................................................................................................... 224 3.10.2.2General and Hazardous Waste ...................................................................................................................... 224 3.11 WORKFORCE ........................................................................................................................................... 225 3.11.1 Human Resource Development Programmes ............................................................................................... 227 3.11.2 Housing and Housing Services ....................................................................................................................... 227 3.11.2.1Construction Phase ....................................................................................................................................... 227

vii | P a g e

3.11.2.2Operational Phase ......................................................................................................................................... 227 3.11.3 Local Economic Development (LED) .............................................................................................................. 227 3.11.4 Health Services and Facilities ......................................................................................................................... 228 3.11.5 Education ....................................................................................................................................................... 228

4

DESCRIPTION OF POTENTIAL IMPACTS ASSOCIATED WITH ACTIVITY .............. 229 SOILS, LAND USE AND LAND CAPABILITY ................................................................................................. 229 Impact on Soil Environment........................................................................................................................... 229 Possible Changes in the Chemical Composition of the Soils of the Area owing to Leachate from Stockpiled Soils ................................................................................................................................................................ 232 4.1.2.1 Loss of Communal Agricultural Land ............................................................................................................. 233 4.1.3 Risk of Soil Erosion in the Post-Mining Landscape......................................................................................... 234 4.1.4 Post Mining Land Capability .......................................................................................................................... 234 4.1.5 Conclusions .................................................................................................................................................... 236

4.1 4.1.1 4.1.2

4.2 4.2.1 4.2.2 4.2.3 4.2.4

BIODIVERSITY – FLORAL .......................................................................................................................... 237 Impact On Floral Habitat ................................................................................................................................ 237 Impact on Floral Diversity .............................................................................................................................. 237 Impact on Floral Species of Conservation Concern ....................................................................................... 238 Conclusions .................................................................................................................................................... 238

4.3 4.3.1 4.3.2 4.3.3 4.3.4

BIODIVERSITY – FAUNAL ......................................................................................................................... 239 Impact on Faunal Habitat .............................................................................................................................. 239 Impact on Faunal Diversity ............................................................................................................................ 239 Impact on Faunal Species of Conservation Concern ...................................................................................... 239 Conclusions .................................................................................................................................................... 240

4.4 4.4.1 4.4.1.1 4.4.1.2 4.4.1.3 4.4.1.4 4.4.2 4.4.2.1 4.4.2.2 4.4.2.3 4.4.2.4 4.4.2.5 4.4.3 4.4.4 4.4.4.1 4.4.4.2 4.4.4.3 4.4.5 4.4.5.1 4.4.5.2 4.4.5.3

SURFACE WATER ..................................................................................................................................... 241 Wetland and Riparion Impact Assessment .................................................................................................... 241 Loss of Wetland and Riparian Habitat and Ecological Structure.................................................................... 241 Changes to Wetland Ecological and Socio-Cultural Service Provision ........................................................... 241 Impacts on Wetland Hydrological Function and Sediment Balance .............................................................. 242 Conclusions .................................................................................................................................................... 242 Aquatic Impact Assessment ........................................................................................................................... 243 Loss of Instream Flow .................................................................................................................................... 243 Impacts on Water Quality .............................................................................................................................. 244 Loss of Aquatic Habitat .................................................................................................................................. 246 Loss of Aquatic Biodiversity and Sensitive Taxa............................................................................................. 247 Summary ........................................................................................................................................................ 248 Impedance of Watercources and Flood-lines ................................................................................................ 249 Impacts on Quantity ...................................................................................................................................... 253 Impact on mean annual runoff (MAR) to the Mfolozi River .......................................................................... 253 Change to peak flow rates in the Mfolozi River and its affected tributaries during flood conditions ........... 253 Drying up of tributaries and establishment of new watercourse due to canalization .................................. 254 Impacts on Quality ......................................................................................................................................... 254 Increased sediment load in the Mfolozi River and its affected tributaries .................................................... 255 Impaired water quality due to pollutants in runoff ....................................................................................... 255 Impaired water quality due to hydrocarbon product spills ........................................................................... 256

viii | P a g e

4.4.5.4 4.4.6 4.4.6.1 4.4.6.2 4.4.6.3 4.4.7 4.4.7.1 4.4.7.2 4.4.7.3 4.4.7.4

Impact of groundwater interaction on surface water sources ...................................................................... 256 Impacts associated with the supply dam on the Mvamanzi River ................................................................. 256 Impact on surface water quantity ................................................................................................................. 256 Impact on the hydrological system and river dynamics, including surface water quality ............................. 257 Impact associated with potential dam breakage ........................................................................................... 257 Impacts on Sensitive Environmental Receptors ............................................................................................ 258 Mvamanzi Pan ............................................................................................................................................... 258 Lake St Lucia................................................................................................................................................... 259 iSimangaliso Wetland Park ............................................................................................................................ 259 The HiP ........................................................................................................................................................... 259

4.5 GROUNDWATER ...................................................................................................................................... 260 4.5.1 Groundwater Impact Modelling .................................................................................................................... 260 4.5.1.1 Potential Source Areas ................................................................................................................................... 261 4.5.1.2 Hydrostatic Units (Pathway) .......................................................................................................................... 261 4.5.1.2.1 Weathered Zone Aquifer ...................................................................................................................... 262 4.5.1.2.2 Deep Secondary Aquifer ....................................................................................................................... 262 4.5.1.2.3 Primary Alluvial Aquifer along the Mfolozi River .................................................................................. 263 4.5.1.3 Receptors ....................................................................................................................................................... 264 4.5.1.3.1 Groundwater Users .............................................................................................................................. 264 4.5.1.3.2 The Surface Water Environment .......................................................................................................... 264 4.5.1.4 Numerical Flow and Mass Transport Modelling ............................................................................................ 264 4.5.2 Groundwater Level Impacts ........................................................................................................................... 265 4.5.2.1 Simulated Groundwater Level Impacts at mine closure ................................................................................ 265 4.5.2.2 Groundwater Level Impacts 50 years post closure ........................................................................................ 266 4.5.3 Impact on Groundwater Quality .................................................................................................................... 267 4.5.3.1 The potential for acid rock drainage (ARD) or poor quality leachates .......................................................... 267 4.5.3.1.1 Acid-Base Accounting ........................................................................................................................... 267 4.5.3.1.2 Leaching Tests ...................................................................................................................................... 268 4.5.3.2 Groundwater quality at closure ..................................................................................................................... 269 4.5.3.3 Groundwater quality 100 years post closure ................................................................................................. 270 4.5.4 Residual Groundwater Impacts ..................................................................................................................... 271 4.6 AIR QUALITY ............................................................................................................................................ 274 4.6.1 Impact Assessment ........................................................................................................................................ 274 4.6.1.1 Construction Phase ........................................................................................................................................ 274 4.6.1.2 Operational Phase ......................................................................................................................................... 275 4.6.1.2.1 Stage 1 – Active pit mining ................................................................................................................... 275 4.6.1.2.2 Stage 2 – Transport of material ............................................................................................................ 275 4.6.1.2.3 Stage 3 – Beneficiation plant ................................................................................................................ 276 4.6.1.2.4 Stage 4 – Stockpiling of overburden and product ................................................................................ 276 4.6.1.3 Rehabilitation Phase ...................................................................................................................................... 276 4.6.2 Possible Mitigation Measures ........................................................................................................................ 277 4.6.3 Modelling Results .......................................................................................................................................... 278 4.6.3.1 Methane ........................................................................................................................................................ 278 4.6.3.2 Particulate Matter ......................................................................................................................................... 279 4.6.3.3 Heavy Metal Exposure ................................................................................................................................... 284 4.6.4 Conclusions .................................................................................................................................................... 285 4.7

AMBIENT NOISE ...................................................................................................................................... 287

ix | P a g e

4.7.1 4.7.1.1 4.7.1.2 4.7.2 4.7.2.1 4.7.2.2 4.7.2.3 4.7.2.4 4.7.2.5 4.7.2.6 4.7.2.7 4.7.3 4.7.3.1 4.7.3.2 4.7.4

Construction Phase ........................................................................................................................................ 287 Sources of Noise ............................................................................................................................................ 287 Noise Impact .................................................................................................................................................. 288 Operational Phase ......................................................................................................................................... 289 Noise Zones of the Mine ................................................................................................................................ 289 Calculation of Noise Footprint for the Various Elements of the Mining Operation ...................................... 290 Noise Climate and Noise Impact of the Internal Mine Traffic ....................................................................... 291 Mine Generated Traffic (External to Mine Property) .................................................................................... 291 Impact on the HiP and iMfolozi Wilderness Area .......................................................................................... 292 Impact on the Sompoho and Obuka Nature Reserves................................................................................... 293 Mine Access Road .......................................................................................................................................... 293 Mitigation Measures ...................................................................................................................................... 293 Construction Phase ........................................................................................................................................ 293 Operational Phase ......................................................................................................................................... 294 Conclusions and Recommendations .............................................................................................................. 297

4.8 BLASTING AND VIBRATION ...................................................................................................................... 299 4.8.1 typical Issues of concern ................................................................................................................................ 299 4.8.1.1 Ground vibration............................................................................................................................................ 299 4.8.1.2 Air blast .......................................................................................................................................................... 300 4.8.1.3 Fly rock ........................................................................................................................................................... 300 4.8.1.4 Noxious Fumes ............................................................................................................................................... 301 4.8.1.5 Vibration impact on provincial and national roads ....................................................................................... 303 4.8.1.6 Cracking of houses and consequent devaluation .......................................................................................... 303 4.8.1.7 Blast operations impacts on farm animals and wild life ................................................................................ 303 4.8.2 Impact Assessment ........................................................................................................................................ 307 4.8.2.1 Ground Vibration ........................................................................................................................................... 307 4.8.2.1.1 Ground Vibration and human perception ............................................................................................ 309 4.8.2.1.2 Vibration impact on roads .................................................................................................................... 310 4.8.2.1.3 Potential that vibration will upset adjacent communities ................................................................... 310 4.8.2.1.4 Cracking of houses and consequent devaluation ................................................................................. 311 4.8.2.2 Air Blast .......................................................................................................................................................... 311 4.8.2.3 Fly-rock Modelling Results and Impact of fly rock ......................................................................................... 312 4.8.2.4 Noxious fumes Influence Results ................................................................................................................... 315 4.8.2.5 Water well influence ...................................................................................................................................... 315 4.8.2.6 Blast operations impacts on farm animals and wild life ................................................................................ 316 4.8.3 Impact Significance ........................................................................................................................................ 319 4.8.4 Recommendations ......................................................................................................................................... 319 4.9 4.9.1 4.9.1.1 4.9.1.2 4.9.1.3 4.9.1.4 4.9.1.5 4.9.1.6 4.9.1.7

TRAFFIC IMPACT ASSESSMENT ................................................................................................................ 320 Impact Assessment AND mITIGATION ........................................................................................................... 320 Impact on Pedestrians ................................................................................................................................... 320 On-Site Pedestrian Activity ............................................................................................................................ 320 Impact of Dust ............................................................................................................................................... 321 Impact of Noise .............................................................................................................................................. 321 Impact on Other Road Users .......................................................................................................................... 321 Impact on Animals ......................................................................................................................................... 321 Impact on Deviation of D873 and L1791 for Open Pit 2 ................................................................................ 322

4.11

VISUAL AND AESTHETIC ........................................................................................................................... 323

x|Page

4.11.1 Visual Exposure and Visibility ........................................................................................................................ 323 4.11.1.1Viewshed Analysis ......................................................................................................................................... 323 4.11.1.2Receptors ...................................................................................................................................................... 324 4.11.1.3Key observation points .................................................................................................................................. 327 4.11.2 Night Time Lighting ........................................................................................................................................ 333 4.11.3 Visual Impacts ................................................................................................................................................ 335 4.11.3.1Impact on Landscape Character and Sense of Place ..................................................................................... 335 4.11.3.2Visual Intrusion and VAC impacts ................................................................................................................. 335 4.11.3.3Visual Exposure and Visibility Impacts .......................................................................................................... 336 4.11.3.4Impacts due to Night Time Lighting .............................................................................................................. 337 4.11.3.5Impact Summary ........................................................................................................................................... 337 4.11.3.6Cumulative Impacts ....................................................................................................................................... 338 4.11.3.7Residual Impacts ........................................................................................................................................... 339 4.12 IMPACT ON THE HIP AND IMFOLOZI WILDERNESS AREA ......................................................................... 339 4.12.1 Disturbances and impacts to wildlife through mining associated activities .................................................. 339 4.12.1.1Elephants ....................................................................................................................................................... 340 4.12.1.2Vultures ......................................................................................................................................................... 341 4.12.1.3Crocodiles ...................................................................................................................................................... 342 4.12.1.4Dispersing and foraging carnivores ............................................................................................................... 343 4.12.1.5Rhinos ............................................................................................................................................................ 343 4.12.2 Light and dust pollution ................................................................................................................................. 343 4.12.3 Other threats to the HiP and iMfolozi Wilderness area ................................................................................ 344 4.12.3.1Run away fires ............................................................................................................................................... 344 4.12.3.2Wilderness status and experience ................................................................................................................ 344 4.12.3.3Tourism ......................................................................................................................................................... 346 4.12.3.4Security concerns and poaching.................................................................................................................... 347 4.13

CULTURAL AND HERITAGE RESOURCES ................................................................................................... 347

4.14 4.14.1 4.14.2 4.14.3 4.14.4

SOCIO- ECONOMIC ASPECTS .................................................................................................................... 348 Background .................................................................................................................................................... 349 Impacts and Mitigation .................................................................................................................................. 350 Social Management Strategies ...................................................................................................................... 354 Conclusions .................................................................................................................................................... 356

4.15 4.15.1 4.15.2 4.15.3 4.15.4

CUMULATIVE IMPACTS ............................................................................................................................ 357 Cumulative Socio-Cultural Impact Mapping .................................................................................................. 359 Cumulative Impact Mapping for Wilderness Resources and the HiP ............................................................ 359 Cumulative Biophysical Impact Mapping....................................................................................................... 361 Mapping of Cumulative Displacement Zone .................................................................................................. 362

4.16 DISPLACEMENT OF HOUSEHOLDS AND COMMUNITY ASSETS AND FACILITIES ........................................ 364 4.16.1 Year 1 – 5 Development / Impacts ................................................................................................................ 364 4.16.1.1Impact – No Mitigation ................................................................................................................................. 364 4.16.1.2Application of the Avoidance Principle ......................................................................................................... 364 4.16.2 Year 6 – 10 Development / Impacts .............................................................................................................. 367 4.16.2.1Impact – No Mitigation ................................................................................................................................. 367 4.16.2.2Application of the Avoidance Principle ......................................................................................................... 367 4.16.3 Year 11 – 15 Development / Impacts ............................................................................................................ 369

xi | P a g e

4.16.3.1Impact – No Mitigation ................................................................................................................................. 369 4.16.3.2Application of the Avoidance Principle ......................................................................................................... 369 4.16.4 Displace Summary ......................................................................................................................................... 370 4.17

QUANTIFICATION OF IMPACT ON DIRECTLY AFFECTED PERSONS ............................................................ 371

5 ASSESSMENT AND EVALUATION OF POTENTIAL IMPACTS INCLUDING MITIGATION MEASURES ...................................................................................................................... 372 5.1 5.1.1 5.1.1.1 5.1.1.2 5.1.1.3 5.1.1.4 5.1.1.5 5.1.1.6 5.1.1.7 5.1.1.8 5.1.2 5.1.2.1 5.1.2.2 5.1.2.3

RISK ASSESSMENT CRITERIA .................................................................................................................... 372 IMPACT SIGNIFICANCE ................................................................................................................................... 372 Nature and Status .......................................................................................................................................... 372 Spatial Extent ................................................................................................................................................. 372 Duration ......................................................................................................................................................... 372 Probability ...................................................................................................................................................... 373 Intensity ......................................................................................................................................................... 373 Ranking, Weighting and Scaling ..................................................................................................................... 373 Impact significance without mitigation (WOM) ............................................................................................ 374 Effect of Significance on Decision‐makings ................................................................................................... 374 Mitigation ...................................................................................................................................................... 375 Impact significance with mitigation measures (WM) .................................................................................... 376 Mitigation Efficiency (ME) ............................................................................................................................. 376 Significance Following Mitigation (SFM) ........................................................................................................ 376

5.2

ENVIRONMENTAL IMPACT RISK MATRIX ................................................................................................. 377

5.3

SOCIAL IMPACT RISK MATRIX .................................................................................................................. 384

6

COMPARATIVE ASSESSMENT OF LAND USE AND DEVELOPMENT ALTERNATIVES389

6.1 6.1.1 6.1.1.1 6.1.1.2 6.1.2 6.1.3 6.1.3.1 6.1.3.2 6.1.4 6.1.4.1 6.1.4.2 6.1.4.3

LAND USE ALTERNATIVES ........................................................................................................................ 389 Status Quo ..................................................................................................................................................... 390 Subsistence farming ....................................................................................................................................... 390 Local Businesses ............................................................................................................................................. 390 Commercial Farming / Forestry ..................................................................................................................... 390 TOURISM ........................................................................................................................................................ 391 Local tourism ................................................................................................................................................. 391 HiP and iMfolozi Wilderness Area ................................................................................................................. 391 Conservation .................................................................................................................................................. 392 Potential Expansion of the HiP ...................................................................................................................... 392 Impact on animal species............................................................................................................................... 393 Increased Poaching ........................................................................................................................................ 394

6.2

MACRO-ECONOMIC IMPACT ANALYSIS ................................................................................................... 394

6.3

POTENTIAL FOR CO-EXISTENCE ................................................................................................................ 397

6.4 6.4.1

DEVELOPMENT ALTERNATIVES ................................................................................................................ 398 Mine Site location .......................................................................................................................................... 398

xii | P a g e

6.4.2 6.4.3 6.4.4 6.4.5 6.4.6 6.4.7 6.4.7.1 6.4.7.2

7

Mining Methodology ..................................................................................................................................... 398 Location of Fuleni CHPP ................................................................................................................................. 398 Product Haulage / Mine Access Route ........................................................................................................... 399 Water Sources................................................................................................................................................ 402 STOCKPILE PLACEMENT ................................................................................................................................. 403 Mine Residue Management ........................................................................................................................... 405 Slurry Management ....................................................................................................................................... 405 Discard Management ..................................................................................................................................... 405

LIST OF SIGNIFICANT IMPACTS AND MITIGATION MEASURES .............................. 406 CONCERNS RAISED BY IAPS ..................................................................................................................... 406 Stakeholder Comments ................................................................................................................................. 406 Comments by Government Departments ..................................................................................................... 406 Comments by Environmental and Community Advocacy Groups, NGO’s and Environmental Concerned Groups ........................................................................................................................................................... 407 7.1.1.3 Comments by the affected and neighbouring communities ......................................................................... 407 7.1.1.4 Objections ...................................................................................................................................................... 408 7.1.2 Perceptions of Community based on the Social Survey ................................................................................ 408

7.1 7.1.1 7.1.1.1 7.1.1.2

7.2

ENVIRONMENTAL IMPACTS AND MITIGATION ........................................................................................ 411

7.3 7.3.1

SOCIAL IMPACTS AND MITIGATION ......................................................................................................... 432 Social Management Strategies ...................................................................................................................... 436

8

STAKEHOLDER ENGAGEMENT ........................................................................................... 438

8.1

OBJECTIVES OF PUBLIC PARTICIPATION ................................................................................................... 438

8.2

PRINCIPLES OF PUBLIC PARTICIPATION ................................................................................................... 438

8.3

METHODS OF PUBLIC PARTICIPATION ..................................................................................................... 438

8.4

PUBLIC PARTICIPATION PROCESS FOLLOWED .......................................................................................... 439

8.5

REGISTER OF INTERESTED AND AFFECTED PARTIES (IAPS) (ANNEX-1.3)................................................... 439

8.6 8.6.1 8.6.2 8.6.3

PROJECT NOTIFICATIONS (ANNEX-1.4 & 1.5) ........................................................................................... 440 Public Participation Notifications................................................................................................................... 440 Advertisements and On-site Notifications (ANNEX-1.6 & 1.7) ...................................................................... 440 Establishment / Communication of Change .................................................................................................. 441

8.7 8.7.1 8.7.2 8.7.3 8.7.4

INFORMATION DISTRIBUTED ................................................................................................................... 441 Background Information Document (ANNEX-1.4) ......................................................................................... 441 Non-Technical Summary of the Scoping Report (ANNEX-1.8) ....................................................................... 442 Information Booklets (ANNEX-1.9) ................................................................................................................ 442 Posters (ANNEX-1.10) .................................................................................................................................... 442

8.8 8.8.1

IAP ENGAGEMENT AND MEETINGS (ANNEX-1.11 TO 1.19) ...................................................................... 442 Government Authority Engagement (ANNEX-1.11) ...................................................................................... 442

xiii | P a g e

8.8.2 8.8.3 8.8.4 8.8.5 8.8.6 8.8.7 8.8.8 8.8.9 8.8.10 8.8.11 8.8.12

Ezemvelo KZN Wildlife Engagement (ANNEX-1.12) ....................................................................................... 444 isiMangaliso Wetland Park Engagement (ANNEX-1.13) ................................................................................ 445 Ingonyama Trust Engagement (ANNEX-1.14) ................................................................................................ 445 Mhlana Traditional Council Engagement (ANNEX-1.15) ................................................................................ 445 Fuleni Mining Forum Engagement (Annex-1.16) ........................................................................................... 446 Broader Community Engagement (Annex-1.17) ............................................................................................ 447 One-on-one Engagement (ANNEX-1.18) ........................................................................................................ 448 Other Engagements with Environmental NGO’s (ANNEX-1.19) .................................................................... 448 Exploration Right Applicant – Umbono CBM Somkhele (ANNEX-1.20) ......................................................... 449 General IAP Engagement (ANNEX-1.21) ........................................................................................................ 449 Public Open Day ............................................................................................................................................. 450

IAP COMMENTS, SUGGESTIONS AND CONCERNS .................................................................................... 450 Scoping Report, Commenting Period and Comments and Response Report (ANNEX-1.22 & 1.23) ............. 450 Availability of the EIR/EMPr Report ............................................................................................................... 451 IAP Comments, Suggestions and Concerns (ANNEX-1.22 & 1.23) ................................................................. 451 Comments made by Government Departments ........................................................................................... 451 Comments made by Environmental and Community Advocacy Groups, NGO’s and Environmental Concerned Groups ........................................................................................................................................................... 452 8.9.3.3 Comments made by the affected and neighbouring communities ............................................................... 453 8.9.3.4 Objections (ANNEX-A23) ................................................................................................................................ 453

8.9 8.9.1 8.9.2 8.9.3 8.9.3.1 8.9.3.2

9

ADEQUACY OF PREDICTIVE METHODS AND KNOWLEDGE GAPS .......................... 454

10

ENVIRONMENTAL STATEMENT ......................................................................................... 457

11

TECHNICAL SUPPORT AND REFERENCES ....................................................................... 458

LIST OF TABLES Table 1: Surface ownership................................................................................................................................................ 3 Table 2: Activity-based legal requirement assessment for the Fuleni Anthracite Project............................................... 21 Table 3: Qualification and professional registrations and affiliations of EIA specialists .................................................. 29 Table 4: Community facilities........................................................................................................................................... 51 Table 5: Sources of water (Mfolozi Municipality Census 2011) ....................................................................................... 51 Table 6: Water Supply Backlog in uThungulu District ...................................................................................................... 52 Table 7: Energy for lighting (uThungulu) ......................................................................................................................... 52 Table 8: Formal and Informal Dwellings (2007) ............................................................................................................... 53 Table 9: Mfolozi Housing Project Plan for Wards affected by proposed mine ................................................................ 54 Table 10: Refuse Removal ................................................................................................................................................ 54 Table 11: Census 2011 refuse removal for Mfolozi Municipality .................................................................................... 54 Table 12: Household Access to Communication Devices ................................................................................................ 56 Table 13: GVA per Capita per municipality, R per person, 2005 values, 2005 to 2010 ................................................... 56 Table 14: Mfolozi Local Municipality, Gross value added at basic prices, R millions, constant 2005 prices ................... 57 Table 15: Mbonambi Local Municipality, Gross value added at basic prices, % Compounded Growth over 5 years, 1995 to 2010 ..................................................................................................................................................................... 57 Table 16: Mean Monthly Rainfall Distribution of Site Rainfall (Zone W2F) ..................................................................... 85 Table 17: Mean Monthly Quaternary Rainfall (mm) ........................................................................................................ 86

xiv | P a g e

Table 18: Mfolozi River Naturalised Runoff ..................................................................................................................... 87 Table 19: Monthly Evaporation Distribution (Symons Pan) ............................................................................................. 88 Table 20: Catchment Data (from WR2005)...................................................................................................................... 89 Table 21: Simulated Average Naturalized Monthly Runoff for Quaternary Catchment W23A ....................................... 89 Table 22: Monthly Evaporation Distribution (Symons Pan) ............................................................................................. 89 Table 23: Total hectares that each of the soil forms encountered in the study area comprise ...................................... 96 Table 24: Predicted crop yield for the soils encountered on the surveyed area ........................................................... 101 Table 25: Dominant and typical floristic species of Zululand Coastal Thornveld (Mucina & Rutherford, 2006) ........... 105 Table 26: Dominant species encountered in the Rocky ridge habitat unit ................................................................... 110 Table 27: Dominant species encountered in the Wetland and Riparian habitat unit ................................................... 112 Table 28: Dominant species encountered in the Savanna Woodland areas ................................................................. 115 Table 29: Dominant species encountered in the Transformed habitat unit................................................................... 118 Table 30: Vegetation Index Score ................................................................................................................................... 119 Table 31: Dominant exotic vegetation species identified during the assessment ......................................................... 121 Table 32: Traditional medicinal plants identified during the field assessment. Medicinal applications and application methods are also presented (van Wyk, et al., 1997; van Wyk and Gericke, 2000; van Wyk and Wink, 2004; van Wyk et el., 2009) .................................................................................................................................................... 121 Table 33: PRECIS RDL plant list (Raimondo et al., 2009; SANBI, 2015) ........................................................................... 123 Table 34: POC calculated for floral species of concern ................................................................................................... 123 Table 35: Mammal species evidence and visually observed within the mining footprint area ...................................... 126 Table 36: Mammal species expected within the mining footprint area and surrounding region .................................. 127 Table 37: Avifauna species recorded during the survey including IUCN RDL status ...................................................... 128 Table 38: National Birdlife South Africa RDL avifauna species status with a POC of more than 60% ............................ 130 Table 39: Reptile species recorded during the survey .................................................................................................... 131 Table 40: Reptile species expected to reside in this region with a threatened status which has a POC of more than 60% ............................................................................................................................................................................... 131 Table 41: Amphibian species identified within the mining footprint area ..................................................................... 132 Table 42: General results from the invertebrate collection and observation during the field assessments conducted 132 Table 43: Araneae species recorded during the survey .................................................................................................. 134 Table 44: Threatened faunal species with a 60% or greater Probability of Occurrence (POC) ...................................... 135 Table 45: Red Data Sensitivity Index Score calculated for the mining footprint area .................................................... 135 Table 46: Classification for the Rivers (Olliset al., 2013)................................................................................................. 144 Table 47: Classification for the Drainage Lines (Riparian and non-Riparian) (Olliset al., 2013)..................................... 144 Table 48: Classification for the valley head seepage wetlands (Olliset al., 2013) .......................................................... 144 Table 49: Summary of wetland assessment result and assigned REC ........................................................................... 145 Table 50: Water quality results upstream and downstream of the MRA area .............................................................. 150 Table 51: Water quality measured in Lake St Lucia ....................................................................................................... 151 Table 52: Water quality results for the MRA area ......................................................................................................... 153 Table 53: Co-ordinates of biomonitoring reference sites .............................................................................................. 155 Table 54: Results of EIS assessment for Mfolozi and Mvamanzi River systems ............................................................ 157 Table 55: Summary of aquatic assessment and monitoring results .............................................................................. 158 Table 56: Land Use Data from WR2005 ......................................................................................................................... 159 Table 57: Water Use and Provisional Water Balance .................................................................................................... 160 3 Table 58: Zululand DM: Mfolozi catchment water balance inclusive of ecological requirements (million m /a) ....... 160 Table 59: Aquifer parameters of monitoring boreholes ................................................................................................ 169 Table 60: Groundwater qualities in the hydrocensus boreholes compared to drinking water standards (SANS241:2011) ............................................................................................................................................................................... 173 Table 61: Groundwater qualities in the HiP hydrocensus points................................................................................... 175 Table 62: Groundwater qualities in the new monitoring boreholes compared to drinking water standards ............... 179

xv | P a g e

Table 63: Measures residual noise levels (2013) ........................................................................................................... 186 Table 64: Typical maximum noise levels for operational conditions along the railway line ......................................... 188 Table 65: Existing noise climate adjacent to main roads (2013).................................................................................... 190 Table 66: Various wilderness zones of the HiP explained (HiP Management Plan, 2011) ............................................. 192 Table 67: A summary of the areas to be impacted by mining activities ........................................................................ 231 Table 68: Summary of impact significance on floral resources ..................................................................................... 238 Table 69: Summary of impact significance on faunal resources .................................................................................... 240 Table 70: Summary of impact significance on wetland and riparian resources ............................................................ 243 Table 71: Summary of impact significance on the Mvamanzi and Mfolozi Rivers ......................................................... 248 Table 72: Total reduction in runoff downstream of the Fuleni Anthracite Project ....................................................... 253 Table 73: Estimated reduction on Mfolozi river runoff at Lake St Lucia ........................................................................ 259 Table 74: Results of ABA tests ....................................................................................................................................... 268 Table 75: Results of leaching tests on coal and overburden ......................................................................................... 269 Table 76: Summary of time to decant (years) ............................................................................................................... 272 Table 77: Groundwater seepage calculations ................................................................................................................ 273 Table 78: Dispersion Results from AERMOD – Worst Case Scenario.............................................................................. 280 Table 79: Dispersion Results from AERMOD – Best Available Technology Scenario ...................................................... 280 Table 80: Heavy Metal Analysis of Coal Sample ............................................................................................................ 284 Table 81: Environmental Rating Table (dust levels) ....................................................................................................... 286 Table 82: Predicted ambient noise levels at given offsets from some specific construction activities ......................... 288 Table 83: Comparison of noise footprint of the various noise zones under different meteorological conditions (unmitigated) ......................................................................................................................................................... 290 Table 84: Maximum bypass noise level of a truck at given offsets from road (unmitigated) ........................................ 291 Table 85: Noise climate adjacent to roads during the mine’s operational phase: background traffic + mine generated traffic (year 2013) .................................................................................................................................................. 292 Table 86: Noise impact on the HiP and Wilderness Area .............................................................................................. 292 Table 87: Comparison of noise footprint of the various noise zones under atmospheric inversion conditions (mitigated and unmitigated).................................................................................................................................................... 296 Table 88: Water boreholes that may be impacted by blasting ...................................................................................... 315 Table 89: Expected air blast levels in dB and kilopascal’s for short distance increments ............................................. 316 Table 90: Visibility classes ............................................................................................................................................... 323 Table 91: A summary of the results obtained from the assessment of visual impacts on the HIP ................................ 338 Table 92: A summary of the results obtained from the assessment of visual impacts on the region surrounding the Mining Footprint Area (excluding the HiP) ............................................................................................................ 338 Table 93: Social impacts associated with Fuleni Anthracite Project .............................................................................. 350 Table 94: Data sets and information considered during cumulative impact assessment ............................................. 358 Table 95: Displacement summary before and after mitigation (avoidance) ................................................................. 370 Table 96: Monetary quantification of impact on directly affected persons .................................................................. 371 Table 97: Viability of alternative land uses .................................................................................................................... 389 Table 98: Comparison of the local economic activities baseline and estimated negative impact of the proposed mine (2015 prices) .......................................................................................................................................................... 395

LIST OF FIGURES Figure 1: Municipal and Ward boundaries ........................................................................................................................ 1 Figure 2: Locality map ........................................................................................................................................................ 2 Figure 3: Fuleni Anthracite Project location in relation to protected conservation areas ................................................ 4

xvi | P a g e

Figure 4: Fuleni Anthracite Project MRA area .................................................................................................................... 5 Figure 5: Traditional Authority Structure (Development Unlimited, 2015) ....................................................................... 6 Figure 6: Mhlana Traditional Authority jurisdiction........................................................................................................... 7 Figure 7: Access road communities ................................................................................................................................. 11 Figure 8: Community map ............................................................................................................................................... 12 Figure 9: Sensitive receptors............................................................................................................................................ 14 Figure 10: Mfolozi Local Municipality population density ............................................................................................... 49 Figure 11: Mfolozi Local Municipality land use map ........................................................................................................ 49 Figure 12: Sanitation types .............................................................................................................................................. 52 Figure 13: Type of Dwelling ............................................................................................................................................. 53 Figure 14: Mfolozi Local Municipality Transport Network .............................................................................................. 55 Figure 15: Topography of the area ................................................................................................................................... 76 Figure 16: Landscape character within the MRA and surrounds ...................................................................................... 77 Figure 17: Topography of Fuleni Anthracite Project MRA area ....................................................................................... 77 Figure 18: Mfolozi Basin Climate Classification ............................................................................................................... 78 Figure 19: Koppen Climate Classification ......................................................................................................................... 79 Figure 20: Mean Annual Maximum Temperature ........................................................................................................... 80 Figure 21: Mean Annual Minimum Temperature ............................................................................................................ 80 Figure 22: Mean Annual Maximum Temperature of Fuleni Anthracite Project MRA area ............................................. 81 Figure 23: Mean Annual Minimum Temperature of Fuleni Anthracite Project MRA area .............................................. 81 Figure 24: Riverview wind roses ...................................................................................................................................... 83 Figure 25: Atmospheric stability classes .......................................................................................................................... 84 Figure 26: Mean Annual Precipitation ............................................................................................................................. 85 Figure 27: Mean Annual Precipitation of Fuleni Anthracite Project MRA area ............................................................... 86 Figure 28: Mean Monthly Precipitation as a % of the distribution .................................................................................. 86 Figure 29: Mean Monthly Precipitation in mm ................................................................................................................ 87 Figure 30: Mean Annual Evaporation .............................................................................................................................. 88 Figure 31: Major soil forms of the Fuleni Anthracite Project area .................................................................................. 92 Figure 32: Soils indicating hydromorphic characteristics ................................................................................................ 95 Figure 33: Land capability classes of the Fuleni Anthracite Project area ......................................................................... 97 Figure 34: Current land use in the Fuleni Anthracite Project area .................................................................................. 98 Figure 35: Sensitivity map pertaining to crop production potential of the area ............................................................. 98 Figure 36: Grazing capacity of each soil type for the surveyed area (large stock unit) ................................................. 100 Figure 37: Vegetation types associated with the MRA area (Scott-Shaw & Escott, 2011) ............................................ 102 Figure 38: Habitat Units within the mining footprint area ............................................................................................. 108 Figure 39: The Rocky ridge habitat unit .......................................................................................................................... 109 Figure 40: The Mfolozi River (left) and Mvamanzi River (right) and associated riparian habitat ................................... 111 Figure 41: Ephemeral drainage lines with established riparian zone (left) and with riparian zone absent (right) ........ 111 Figure 42: Representative photograph of the Savanna Woodland habitat unit ............................................................ 114 Figure 43: Representative photograph of the Transformed habitat unit ....................................................................... 117 Figure 44: Floral Sensitivity Map .................................................................................................................................... 126 Figure 45: Quaternary Catchment Areas ....................................................................................................................... 136 Figure 46: NFEPA wetland types within the Fuleni Anthracite Project MRA area ......................................................... 140 Figure 47: Wetland conditions as defined by the NFEPA wetland map ........................................................................ 141 Figure 48: Ranks according to general importance ....................................................................................................... 141 Figure 49: Wetlands indicated to be of importance towards biodiversity conservation (0 = no importance) .............. 142 Figure 50: FEPA wetlands indicated for the Fuleni Anthracite Project MRA area (1 = FEPA wetland) .......................... 142 Figure 51: Wetlands and riparian areas associated with the mining footprint area ..................................................... 143 Figure 52: Wetland PES .................................................................................................................................................. 145

xvii | P a g e

Figure 53: Wetland Ecoservices ..................................................................................................................................... 146 Figure 54: Wetland EIS ................................................................................................................................................... 146 Figure 55: DWS monitoring points evaluated as part of the water quality assessment (WSM Leshika, 2015) ............. 148 Figure 56: Water quality monitoring points within the MRA area ................................................................................ 152 Figure 57: Aquatic ecological assessment points........................................................................................................... 155 Figure 58: Major and Minor Drainage Lines .................................................................................................................. 162 Figure 59: Flood-lines in the western section of the Fuleni Anthracite Project mining area ........................................ 163 Figure 60: Flood-lines in the eastern section of the Fuleni Anthracite Project mining area ......................................... 163 Figure 61: Position of hydrocensus boreholes ............................................................................................................... 164 Figure 62: Thematic water level map for the proposed Fuleni Anthracite Project area ............................................... 166 Figure 63: Bayesian water levels in the Fuleni Anthracite Project mining area............................................................. 167 Figure 64: Distribution of hydrocensus localities with water quality information ........................................................ 171 Figure 65: Expanded Durov diagram of hydrocensus groundwater qualities ................................................................ 177 Figure 66: Stiff diagrams of hydrocensus groundwater qualities .................................................................................. 178 Figure 67: Position of new monitoring boreholes ......................................................................................................... 179 Figure 69: Stiff diagrams of monitoring boreholes groundwater qualities.................................................................... 181 Figure 68: Expanded Durov diagram of monitoring boreholes groundwater qualities ................................................. 181 Figure 70: Ambient noise monitoring sites .................................................................................................................... 187 Figure 71: Protected areas in vicinity of the proposed Fuleni Anthracite Project ......................................................... 191 Figure 72: iMfolozi Wilderness Area and Zonation ........................................................................................................ 193 Figure 73: iSimangaliso Wetland Park: Zone of influence (buffer zone) ........................................................................ 194 Figure 74: Threatened terrestrial ecosystems ............................................................................................................... 195 Figure 75: NPAES Focus Areas ....................................................................................................................................... 196 Figure 76: KZN Terrestrial Biodiversity Priority Areas .................................................................................................... 197 Figure 77: Important Bird Areas (IBA) ............................................................................................................................ 198 Figure 78: Importance in terms of the Mining and Biodiversity Guidelines (2012) ....................................................... 199 Figure 79: Simplified geological map (1:250 000 scale) of the proposed Fuleni Anthracite Project area ..................... 200 Figure 80: Layout plan in relation to nearby communities ............................................................................................ 202 Figure 81: Layout Plan for Fuleni Anthracite Project (Prodelko, 2014) ......................................................................... 203 Figure 82: Phase 1 development ................................................................................................................................... 205 Figure 83: Phase 2 development .................................................................................................................................... 205 Figure 84: Phase 3 development .................................................................................................................................... 206 Figure 85: Phase 1, 2 and 3 developments ..................................................................................................................... 207 Figure 86: Phase 4 development .................................................................................................................................... 207 Figure 87: Typical benches in open pit mining ............................................................................................................... 208 Figure 88: Typical view of an open pit coal mine............................................................................................................ 209 Figure 89: Typical bord-and-pillar mining panel layout .................................................................................................. 209 Figure 90: Fuleni CHPP Process Flow Diagram ............................................................................................................... 212 Figure 91: Fuleni Anthracite Project plant layout .......................................................................................................... 213 Figure 92: Mfolozi Local Municipality Transport Network ............................................................................................ 216 Figure 93: Selected Mine Access Route (Route 5) ......................................................................................................... 217 Figure 94: Water balance flow diagram ......................................................................................................................... 222 Figure 95: Workforce requirement and ramp-up .......................................................................................................... 225 Figure 96: Breakdown of Operational Staff, first 10 years............................................................................................. 226 Figure 97: Workforce Source Area ................................................................................................................................. 226 Figure 98: Position of the mining areas and related infrastructure transposed on a soil map and digital elevation model ..................................................................................................................................................................... 229 Figure 99: Erodibility factor for the soils in the mining footprint area .......................................................................... 235 Figure 100: Areas that will exhibit a high erosion risk in the post-mining landscape.................................................... 235

xviii | P a g e

Figure 101: Impedance of water courses and floodlines at Pits 1 & 2 ........................................................................... 250 Figure 102: Impedance of water courses and floodlines at Pits 3 & 4 and the CHPP .................................................... 251 Figure 103: Impedance of water courses and floodlines at Pits 4, 5 & 6 ....................................................................... 252 Figure 104: Extent of the dam breakage floodline and SEF flood level ......................................................................... 258 Figure 105: Catchment divide between quarternary catchments W23A and W21L ..................................................... 259 Figure 106: Conceptual representation of the aquifers in the Fuleni Anthracite Project area ..................................... 263 Figure 107: Simulated cone of depression at mine closure with hydrocensus borehole positions .............................. 265 Figure 108: Simulated drawdown at 50 years post-closure .......................................................................................... 266 Figure 109: Simulated TDS source concentration contours at mine closure ................................................................. 270 Figure 110: Simulated TDS concentration contours 100 years after mine closure ....................................................... 271 Figure 111: Potential decant point positions ................................................................................................................. 272 Figure 112: Methane emissions predicted based on the production rate provided for the LOM (m³ methane per ton) ............................................................................................................................................................................... 279 Figure 113: Isopleth plot showing particulate impacts associated with construction for a daily averaging period (Standard 75µg/m³) ............................................................................................................................................... 281 Figure 114: Isopleth plot showing particulate impacts associated with construction for an annual averaging period (Standard 40µg/m³) ............................................................................................................................................... 282 Figure 115: Isopleth plot showing Particulate impacts associated with no mitigation for a daily averaging period (Standard 75µg/m³) ............................................................................................................................................... 282 Figure 116: Isopleth plot showing Particulate impacts associated with operations for a daily averaging period (Standard 75µg/m³) ............................................................................................................................................... 283 Figure 117: Isopleth plot showing particulate impacts associated with operations for an annual averaging period (Standard 40µg/m³) ............................................................................................................................................... 283 Figure 118: Noise profile for the Fuleni Anthracite Project (unmitigated) .................................................................... 291 Figure 119: Noise profile for the Fuleni Anthracite Project without and with mitigation (35dBA) ............................... 296 Figure 120: Maximum charge yield of 6 mm/s and 12.5 mm/s ground vibration level around the mine areas ........... 308 Figure 121: Medium charge yield of 6 mm/s and 12.5 mm/s ground vibration level around the mine areas .............. 309 Figure 122: The effect of ground vibration with human perception and vibration limits ............................................. 310 Figure 123: Air blast influence from maximum charge for Pit Area 5 & 6 ...................................................................... 312 Figure 124: Air blast influence from maximum charge for Pit Area 5 & 6 ...................................................................... 313 Figure 125: Predicted Fly rock ........................................................................................................................................ 314 Figure 126: Predicted Fly rock zone areas ...................................................................................................................... 314 Figure 127: Water boreholes that may be impacted by blasting ................................................................................... 315 Figure 128: Sensitive river area ...................................................................................................................................... 317 Figure 129: Sensitive Raptor area ................................................................................................................................... 318 Figure 130: Road deviations associated with Open Pit 2 ............................................................................................... 322 Figure 131: Open Pit viewshed map .............................................................................................................................. 325 Figure 132: Plant and discards stockpile viewshed map................................................................................................ 325 Figure 133: Overburden and topsoil stockpiles viewshed map ..................................................................................... 326 Figure 134: Combined viewshed map for full LOM footprint ........................................................................................ 326 Figure 135: Visual receptors .......................................................................................................................................... 328 Figure 136: Receptor locations overlaid onto the combined viewshed map ................................................................ 328 Figure 137: Visual simulation of the view from the Ocilwane community .................................................................... 329 Figure 138: Visual simulation of the view from the Ntuthunga 1 community .............................................................. 330 Figure 139: Visual simulation of the view from the Novunula community ................................................................... 331 Figure 140: Visual simulation of the view from the HiP Wilderness Area ..................................................................... 332 Figure 141: View of Somkhele Mine .............................................................................................................................. 334 Figure 142: Cumulative socio-cultural impact map ....................................................................................................... 360 Figure 143: Cumulative Impact Map for Wilderness Resources and the HiP ................................................................ 361

xix | P a g e

Figure 144: Cumulative Biophysical Impact Map ........................................................................................................... 362 Figure 145: Cumulative Displacement Zone Map .......................................................................................................... 363 Figure 146: Phase 1 Displacement Zone ......................................................................................................................... 365 Figure 147: Phase 1 Access Road Displacement ............................................................................................................. 365 Figure 148: Proposed mitigation of Phase 1 (avoidance) ............................................................................................... 366 Figure 149: Proposed mitigation of Phase 1 Access Road (avoidance) .......................................................................... 366 Figure 150: Phase 2 Displacement Zone ......................................................................................................................... 368 Figure 151: Proposed mitigation of Phase 2 (avoidance) ............................................................................................... 368 Figure 152: Phase 3 Displacement Zone ........................................................................................................................ 369 Figure 153: Proposed mitigation of Phase 3 (avoidance) .............................................................................................. 370 Figure 154: Map showing ground-truthed geographical possibilities for protected area expansion (iMfolozi Valley Project Area) (EKZN) .............................................................................................................................................. 393 Figure 155: Alternative locations investigated for the Fuleni CHPP .............................................................................. 399 Figure 156: Alternative routes for product haulage ...................................................................................................... 400 Figure 157: Selected Mine Access Route (Route 5) ....................................................................................................... 402 Figure 158: Opencast pits and stockpiles in relation to the adjacent communities ...................................................... 404 Figure 159: Public Participation Process ......................................................................................................................... 439

xx | P a g e

1 PROJECT BACKGROUND 1.1

INTRODUCTION

Ibutho Coal (Pty) Ltd (Ibutho) has submitted a Mining Right Application (MRA) for coal on a portion of the farm Fuleni Reserve No. 14375 in Northern KwaZulu-Natal to the Department of Mineral Resources (DMR). This MRA was preceded by a Prospecting Right {Ref No. KZN311PR}. Ibutho is an active mineral prospector in the KwaZulu-Natal region who founded the company in 2006 with a vision to create economic upliftment in communities through responsible mining development. The majority of Ibutho’s directors and shareholders are black entrepreneurs with a wealth of mining experience. The proposed Fuleni Anthracite Project comprises a 44.9% Black Economic Empowerment (BEE) shareholding, of which at least 5% free carry share equity is offered to a community shareholding trust.

1.2

PROJECT LOCATION

Fuleni Anthracite Project is situated on Portion 1 (Remaining Extent) of the farm Fuleni Reserve No. 14375 in Northern KwaZulu-Natal, approximately 45 km north-west of the town of Richards Bay (Figure 2). The MRA area is situated within the Mfolozi Local Municipality (Ward 13) of the uThungulu District Municipality.

Figure 1: Municipal and Ward boundaries

1|Page

Figure 2: Locality map

2|Page

The nearest urban settlement is Kwambonambi, 30 km from the site. The district has within its boundaries the large industrial towns of Richards Bay and Empangeni, both home to skills and expertise in the mining industry which is just 55 km from the site. A number of communities are located within and adjacent to the Fuleni Anthracite Project area. The majority of residents at the proposed mine site are scattered rural settlements with low population density and low skill level. The Fuleni Anthracite Project is bordered by the Mfolozi River to the north, the Richards Bay railway line to the south and Hluhluwe-iMfolozi Park (HiP) to the north-west. The existing Somkhele Mine is located to the north-east of the Fuleni Anthracite Project. Two Community Nature Reserves were recently declared directly to the west of the MRA area, in the Ntambanana Local Municipality, namely:  

Somopho Community Nature Reserve on a portion of Portion 1 of Fuleni Reserve No. 14375 Obuka Community Nature Reserve on a portion of Reserve No. 11 No. 15831

Ezemvelo KZN Wildlife was assigned as the Management Authority of the two community nature reserves.

1.2.1 SURFACE OWNERSHIP The registered description associated with the MRA is listed in Table 1 below and covers 14,615 ha of the farm Fuleni Reserve No. 14375. An official survey of the area of the farm Fuleni Reserve No. 14375 covered by the MRA is shown in Figure 4. Note the remainder of farm Fuleni Reserve No. 14375 to the west, which is excluded from the MRA. Table 1: Surface ownership Farm Name

Farm no.

Reg Div

Portion

Title deed nr

Extent (ha)

Surface owner

Fuleni Reserve

14375

KT

0

G26/1962 T64294/2000

14,615

Ingonyama Trust

The Ingonyama Trust, governed by the Ingonyama Trust Board (ITB) and established and regulated by the KwaZulu-Natal Ingonyama Trust Act No. 3 of 1994 (as amended), is the legal landowner of approximately 2.8 million hectares of land in KwaZulu-Natal (South Africa) including the farm Fuleni Reserve No. 14375 where the proposed Fuleni Anthracite Project is located. His Majesty, the King, is the sole Trustee of the Trust.

3|Page

Figure 3: Fuleni Anthracite Project location in relation to protected conservation areas

4|Page

Hluhluwe-Umfolozi Park

Remainder of Fuleni Reserve 14375

Prospecting right KZN311PR Fuleni Reserve 14375

Figure 4: Fuleni Anthracite Project MRA area

5|Page

1.2.2 TRADITIONAL AUTHORITY The Traditional Authority of the project area is known as Mhlana Traditional Authority; and is headed by iNkosi Ntemba Mthethwa, of the Abathethwa tribe. Due to ill-health and old age, iNkosi Mthethwa has appointed his son (Mbusowabathethwa Mthethwa) as his right hand man and representative at almost all his engagements where he cannot be available. In terms of Government Gazette GK295-27.02.59 // GL161-11.02.72 the area depicted in Figure 6 falls under the Mhlana Traditional Authority jurisdiction, with a total extent of 51,918 ha. The Traditional Authority structure is depicted in the following organogram:

Figure 5: Traditional Authority Structure (Development Unlimited, 2015)

6|Page

Figure 6: Mhlana Traditional Authority jurisdiction

7|Page

1.2.3 INSTITUTIONAL ARRANGEMENTS The ITB is responsible for administering all land falling within its jurisdiction and control for the “material benefit and social well-being of the individual members of the communities and tribes living on Ingonyama land”. The Act states that “any land or real right therein of which the ownership immediately prior to the date of commencement of this Act vested in or had been acquired by the Government of KwaZulu shall hereby vest in and be transferred to and shall be held in trust by the Ingonyama as trustee of the Ingonyama Trust referred to in section 2(1) for and on behalf of the members of tribes and communities and the residents referred to in section 2(2).” The ITB head office is located in Pietermaritzburg (KwaZulu-Natal). Some of the key functions of the ITB include: 

    

Providing assistance and advice to communities on land related issues and possible joint venture schemes in furtherance of BEE and mining charter requirements, forestry privatization and tourism related projects. Ensuring that rural communities achieve fair deals from entrepreneurs and developers. Ensuring that land is made available for community care projects. Ensuring that land is made available for rural housing development purposes. Providing policy inputs in respect of rural housing, townships, commercial land and Integrated Development Plans (IDPs). Assessment, decision-making and management of the land for development purposes, primarily through the granting of formal leases upon application.

Whilst the Ingonyama Trust owns the land, the Mfolozi Local Municipality (LM) is responsible for the provision and management of many facilities. This is for both private landholders and Ingonyama Trust lessees within the municipality. The municipality is the principal authority in the municipal area, responsible for the provision and management of many services, including basic water, sanitation and energy supply. There is a split of function between the uThungulu District and Mfolozi Local Municipalities. The district is responsible for electrical, health, water and sanitation and abattoirs, whilst the Mfolozi LM handles all other local authority functions at some level.

1.2.4 LAND CLAIMS The Department of Rural Development and Land Reform was engaged to determine whether there are any land claims on the property. A response was received from the Department on 6 August 2014 indicating according to their records there are no claim for restitution in terms of the Restitution of Land Rights Act (Act 22 of 1994) on the property Fuleni Reserve No. 14375 KT. Please refer to ANNEX-1.2 for a copy of the letter.

1.2.5 EXPLORATION RIGHT APPLICANT – UMBONO CBM SOMKHELE Umbono CBM Somkhele has submitted an application for an Exploration Right to explore for Coal-Bed Methane Gas on the property Fuleni Reserve, and other properties. The Petroleum Resources Agency of 8|Page

South Africa (PASA) was contacted to obtain the details of the Exploration Right Applicant. They confirmed that the applicant is Umbono CBM Somkhele, but indicated that the application has been abandoned. This was subsequently confirmed by Umbono – see ANNEX-1.20 for correspondence.

1.2.6 RELEVANT GOVERNMENT DEPARTMENTS, AGENCIES AND INSTITUTIONS The relevant Government Departments, agencies and institutions responsible for various aspects of the environment, land and infrastructure which may be affected by the proposed Fuleni Anthracite Project include: 1.2.6.1 Provincial and Local Government Departments             

Kwazulu-Natal Department of Mineral Resources Kwazulu-Natal Department of Economic Development and Tourism (KZNDEDT) Kwazulu-Natal Department of Water and Sanitation (DWS) Kwazulu-Natal Department of Agriculture, Forestry and Fisheries (DAFF) Kwazulu-Natal Department of Agriculture and Rural Development (DARD) Kwazulu-Natal Department of Rural Development and Land Reform: Regional Land Claims Commission Kwazulu-Natal Department of Human Settlements Kwazulu-Natal Department of Cooperative Governance and Traditional Affairs Kwazulu-Natal Department of Education Kwazulu-Natal Department of Transport Kwazulu-Natal Department of Health Uthungulu District Municipality Mfolozi Local Municipality

1.2.6.2 Agencies and Institutions        

Ezemvelo KZN Wildlife South African National Parks Agency (SANParks) iSimangaliso Wetland Park Authority South African Heritage Resource Agency (SAHRA) Amafa (Heritage) aKwaZulu-Natali Heritage Council (AMAFA) South African National Roads Agency (SANRAL) ESKOM Transnet

1.2.6.3 Landowner / Traditional Authority  

Ingonyama Trust Board Mhlana Traditional Authority

9|Page

1.3

COMMUNITY DESCRIPTION

Abathethwa are part of the original Nguni people, whose modern identity dates back some 700 years. They are among the original Nguni groups who left the Great Lakes in Central Africa between 200AD and 1200AD. On arrival in Southern Africa, they settled around modern-day Swaziland, mainly on the Lubombo Mountains, before leaving in the 17th century to settle in Natal, in the Zululand region. This tribe is currently located south of the lower Mfolozi River in the northeastern part of the present-day province of KwaZulu-Natal (Development Unlimited, 2015). As a tribe, Abathethwa are descendants of iNkosi Jobe and his son Dingiswayo; and they became prominent in the first two decades of the 19th century, by absorbing small local lineages and by engaging in conflicts with neighbouring chieftaincies, such as the Qwabes to the south and the Ndwandwes to the northwest. iNkosi Dingiswayo was killed in a battle with the Ndwandwes in 1817 (Development Unlimited, 2015). The present day Abathethwa, under the leadership of iNkosi Ntemba Mthethwa are direct descendants of iNkosi Sokwethsatha, who was born in 1850 and died in 1907. iNkosi Sokwetshatha was the founder of the present day Mhlana Traditional Authority (Development Unlimited, 2015). The cultural beliefs and practices of Abathethwa people are similar to those practiced by most Zulu tribes, and hinge on the following: Language: The language of the Abathethwa people is "isiZulu", which is part of the Nguni subgroup. Zulu is the most widely spoken language in South Africa, where it is an official language; and notably the only spoken language in the project area. Although some of the people within the Mhlana Traditional Authority area can also speak other languages like English and Sesotho, their proficiency in these languages is somehow limited. Clothing: Like most tribes found in the KwaZulu-Natal province, and particularly in the heart of the Zululand region, the Abathethwa are Zulus by birth, language and practice. Like all true Zulus in the province (and mostly in Zululand), the Abathethwa wear a variety of attire, both traditional for ceremonial or cultural occasions, and modern westernized clothing for everyday use. The women dress differently depending on whether they are single, engaged, or married. Religion: Most of the people in this area are Christian. Some of the most common churches to which they belong are African Initiated Churches, especially the Zion Christian Church and United African Apostolic Church, although membership of major European Churches, such as the Dutch Reformed, Anglican and Catholic Churches is also common. Nevertheless, many of the people retain their traditional pre-Christian belief system of ancestor worship in parallel with their Christianity. This is mostly common among members of the Nazareth Baptist Church (commonly known as Shembe). Beliefs: Traditionally, the Zulu recognize several elements to be present in a human being: the physical body (umzimba); the breath or life force (umoya); and the "shadow," prestige, or personality (isithunzi). Once the umoya leaves the body, the isithunzi may live on as an ancestral spirit (idlozi) only if certain conditions were met in life. Behaving with ubuntu, or showing respect and generosity towards others, enhances one's moral standing or prestige in the community, one's isithunzi. By contrast, acting in a negative way towards others can reduce the isithunzi, and it is possible for the isithunzi to fade away completely. In order to appeal to the spirit world, a diviner (sangoma) must invoke the ancestors through divination processes to determine the problem. Then, a herbalist (inyanga) prepares a mixture (muthi) to 10 | P a g e

be consumed in order to influence the ancestors. As such, diviners and herbalists play an important part in the daily lives of the Zulu people. Christianity had difficulty gaining a foothold among the Zulu people, and when it did it was in a syncretic fashion. Isaiah Shembe, considered the Zulu Messiah, presented a form of Christianity (the Nazareth Baptist Church) which incorporated traditional customs. The location of the communities residing on the MRA area in relation to the proposed mining and infrastructure areas is shown in Figure 8. The communities that reside on the MRA area include the following:      

Ntuthunga 1 Ntuthunga 2 Novunula Ocilwane Fuyeni eMakhwezini

The proposed access road will be mostly located on existing roads the currently pass through existing rural villages. A new section will need to be constructed passing through Mendu (Enhlabosini) and Ocilwane Community.

Figure 7: Access road communities

Apart from the affected communities, the project area is surrounded by a number of other rural villages, more than 2 km from the mining footprint. These adjacent communities will not be directly affected by the mine development. 11 | P a g e

Figure 8: Community map

12 | P a g e

1.3.1.1 Ntuthunga 1 Community The village of Ntuthunga 1 is situated approximately 34 km west of Kwambonambi. The village (which is one of the areas that will be directly affected by the proposed Fuleni Anthracite Project) is situated in the southern part of the proposed mining area; and is led by Induna B.M. Mthethwa (a member of the Mhlana Traditional Authority council), and by councilor JM Ndimande of Ward 13 of the Mfolozi Local Municipality (a member of council and ward councilor under Mfolozi Local Municipality, in Kwambonambi). There are approximately 314 households in the area. The community of Ntuthunga 1 has been living in this area since the early sixties. 1.3.1.2 Ntuthunga 2 Community The village of Ntuthunga 2 is situated approximately 36 km west of Kwambonambi and about 2 km north of Ntuthunga 1. Similar to all villages in KwaZulu-Natal in general, and to Ntuthunga 1 in particular, the village is traditionally led by Induna N. Mthethwa (a member of the Mhlana Traditional Authority council), and by councilor JM Ndimande of Ward 13 of the Mfolozi Local Municipality (a member of council and ward councilor under Mfolozi Local Municipality, in Kwambonambi). There are approximately 255 households in the area. Similar to Ntuthunga 1, the community of Ntuthunga 2 has been living in this area since the early sixties. 1.3.1.3 Novunula Community The village of Novunula is situated approximately 38 km north of Kwambonambi. The HiP borders the village to the west, and the Mfolozi River to the north. The village is led by Induna M. Mdletshe (a member of the Mhlana Traditional Authority council), and by councilor JM Ndimande of Ward 13 of the Mfolozi Local Municipality (a member of council and ward councilor under Mfolozi Local Municipality, in Kwambonambi). There are approximately 186 households in the village. The community of Novunula has been living in this area since the early 19th century. 1.3.1.4 Ocilwane Ocilwane is situated approximately 36 km north of Kwambonambi, and is the most central village in relation to the proposed mining area. The village is traditionally led by Induna T. Mthethwa of the Mhlana Traditional Authority, and by councilor JM Ndimande of Ward 13 of the Mfolozi Local Municipality (a member of council and ward councilor under Mfolozi Local Municipality, in Kwambonambi). The village constitutes approximately 243 households. The community of Ocilwane has been living in this area since the early eighties, following resettlement from the Empangeni area. 1.3.1.5 Fuyeni The Fuyeni community is situated to the south of the mining footprint area and approximately 23 km northeast of Kwambonambi. The village is traditionally led by Induna T. Mthethwa of the Mhlana Traditional Authority, and in Ward 12 of the Mfolozi Local Municipality (a member of council and ward councilor under Mfolozi Local Municipality, in Kwambonambi). The village constitutes approximately 267 households.

13 | P a g e

1.3.1.6 eMakhwezini The eMakhwezini community is situated to the south of the mining footprint area and approximately 20 km north-east of Kwambonambi. The village is traditionally led by Induna T. Mthethwa of the Mhlana Traditional Authority, and in Ward 12 of the Mfolozi Local Municipality (a member of council and ward councilor under Mfolozi Local Municipality, in Kwambonambi). The village constitutes approximately 1068 households.

1.3.2 SENSITIVE RECEPTORS The following sensitive receptors have been identified as shown in :       

Residential areas (houses) Small businesses Schools Clinics Households Associated Graves Communal Graveyards Conservation areas

Figure 9: Sensitive receptors

14 | P a g e

1.4

BRIEF PROJECT DESCRIPTION

The potential for both opencast and underground mining has been identified and the estimated Life of Mine (LOM) for the Fuleni Anthracite Project is 32 years with a mineable resource of 35.7 Mt Run-of-Mine (ROM) for the opencast production and 1.8 Mt for underground production. The process design allows for the production of a primary Anthracite product suitable for the export and inland market and a lower grade middling product for the thermal market. The envisaged mining method for the opencast area is a conventional drill and blast operation with truck and shovel load and haul. Underground mining operations will commence from year 18 to the end of the mining schedule. Access will be from selected positions in the open pits and the coal will be mined through the typical bord-and-pillar methodology. A single production section is planned for all underground mining. After underground activities have been completed, the access to the underground areas will be closed with the final rehabilitation of the open pit. The proposed infrastructure to be developed includes         

Topsoil and overburden stockpiles; Haul roads and/or conveyor systems for ROM transport; ROM handling facility; Coal Handling Processing Plant (CHPP) with associated stockpiles; Pollution control dams; Temporary discard facility; Raw water storage facility(ies) and distribution systems; Access road to mine and for product transport; and Auxiliary infrastructure including workshops and stores, offices and change houses, sewage treatment plant, main electrical power supply and security fencing.

The washed coal will be transported via road to either a nearby siding on the Swaziland-Richards Bay railway line or directly to the Richards Bay Coal Terminal (RBCT) for export. The final discard material from the plant will be disposed of in the mined-out open pits. In the event that these pits are unavailable due to existing mining activities, the discard material will be placed on a temporary surface discards stockpile, from where it will be reclaimed and dumped into the mined-out open pits towards the end of the mine life as part of the rehabilitation of the mining site.

15 | P a g e

LEGAL FRAMEWORK

1.5

1.5.1 APPLICABLE LEGISLATION The legal frameworks within which the mining development, transport options and associated infrastructure aspects operate is complex and include many acts, associated regulations, standards, principle, guidelines, conventions and treaties on an international, national, provincial and local level. The main legal frameworks that require compliance in terms of Environmental and Water Use Authorisation are:   

Act No. 28 of 2002: Mineral and Petroleum Resources Development Act (MPRDA), as amended Act No. 107 of 1998: National Environmental Management Act (NEMA), as amended Act No. 36 of 1998: National Water Act (NWA), as amended

Other legislative frameworks applicable to the Fuleni Anthracite Project include:                             

Act No. 108 of 1996: The Constitution of South Africa Act No. 25 of 1999: National Heritage Resources Act (NHRA) Act No. 49 of 1999: World Heritage Convention Act Act No. 10 of 2004: NEMA: Biodiversity Act (NEMBA) Act No. 43 of 1983: Conservation of Agricultural Resources Act (CARA) Act No. 84 of 1998: National Forests Act (NFA) Act No. 39 of 2004: National Environmental Management: Air Quality Act (AQA) Act No. 57 of 2003: National Environmental Management: Protected Areas Act Act No. 59 of 2008: National Environmental Management: Waste Act (NEMWA) Act No. 101 of 1998: National Veld and Forest Fire Act Act No. 15 of 1973: Hazardous Substances Act GN No. R.527 of 23 April 2004: Mineral and Petroleum Resources Development Regulations GN No. 704 of 4 June 1999: Regulation on use of water for mining and related activities aimed at the protection of water resources GN No. R. 544-546 of 18 June 2010 and R. 922-923 of 2013: NEMA: EIA Regulations GN No. 718 of 3 July 2009 and R. 921 of 2013: NEMWA: Waste Management Activities GN No. 248 of 31 March 2010: AQA: Atmospheric Emissions Activities GN No. R.152 of 2007: NEMBA: Threatened or Protected Species (TOPS) Regulations Act No. 125 of 1991: Physical Planning Act Act No. 117 of 1998: Municipal Structures Act Act No. 32 of 2000: Municipal Systems Act Act No. 67 of 1995: Development Facilitation Act (DFA) Act No. 6 of 2008: KwaZulu-Natal Planning and Development Act Act No. 5 of 1999: KwaZulu-Natal Nature Conservation Management Act Act No. 4 of 2008: KwaZulu-Natal Heritage Act (KZNHA) Act No. 12 of 1996: KwaZulu-Natal Cemeteries and Crematoria Act Act No. 2 of 2005: KwaZulu-Natal Cemeteries and Crematoria Amendment Act Act No. 31 of 1996: Interim Protection of Informal Land Rights Act No. 11 of 2004: Communal Land Rights Act No. 41 of 2003: Traditional Leadership and Governance Framework Act 16 | P a g e

                

Act No. 2 of 2000: Promotion of Access to Information Act Act No. 3 of 2000: Promotion of Administrative Justice Act No. 67 of 1995: Development Facilitation Act Act No. 75 of 1997: Basic Conditions of Employment Act Act No. 66 of 1995: The Labour Relations Act Act No. 4 of 2000: Promotion of Equality and Prevention of Unfair Discrimination Act Act No. 85 of 1993: Occupational Health and Safety Act Act No. 53 of 2003: Broad Based Black Economic Empowerment Act Act No. 9 of 1972: National Road Safety Act Act No. 93 of 1996: National Road Traffic Act Act No. 19 of 1998: Prevention of Illegal Eviction from and Unlawful Occupation of Land Act Act No. 3 of 1996: Restitution of Land Rights Act No. 112 of 1991: Amendment of the Upgrading of Land Tenure Rights Act No. 5 of 2005: KwaZulu-Natal Traditional Leadership and Governance – PG 6460/16-01-2006 Act No. 3 of 2003: KwaZulu-Natal Land Administration – PG 6470/16-03-2006 Act No. 11 of 1992: KwaZulu Land Affairs Act No. 3 of 1994: The KwaZulu-Natal Ingonyama Trust Act

Strategies, guidelines and other documents of importance to this project (list not exhaustive) are:                    

National Protected Areas Expansion Strategy, 2010 (NPAES) National List of Threatened Terrestrial Ecosystems for South Africa, 2011 National Biodiversity Assessment, 2011 (NBA) Biodiversity Policy and Strategy for South Africa: Strategy on Buffer Zones for National Parks published under General Notice 106 in Government Gazette 35020 of 8 February 2012 The Mining and Biodiversity Guideline: Mainstreaming Biodiversity into the Mining Sector, 2013 Implementation Manual for Freshwater Ecosystem Priority Areas, 2011 KwaZulu-Natal Systematic Conservation Plan, 2005 KwaZulu-Natal Terrestrial Conservation Plan Integrated Management Plan: Hluhluwe-iMfolozi Park, South Africa: EKZN, 2011 iSimangaliso Wetland Park: Integrated Management Plan (2011-2016) Good Practice Guidance for Mining and Biodiversity: International Council on Mining and Metals. Convention on Biological Diversity (1995) World Summit for Sustainable Development (2002) KZN Provincial Notice No. 194 of 28 November 2013 KZN Municipal Notice No. 42 of 12 June 2014 KwaZulu Natal Provincial Growth and Economic Development Strategy, 2011 KZN Tourism Master Plan KZN Spatial Development Framework, 2012 UThungulu Spatial Development Framework, 2012 Mfolozi Integrated Development Plan, 2014/2015 review

17 | P a g e

1.5.2 APPROACH TO ENGAGEMENT

ENVIRONMENTAL

AUTHORISATION

AND

STAKEHOLDER

Every applicant who applies for a mining right in terms of Section 22 of the MPRDA must conduct an Environmental Impact Assessment (EIA) and submit an Environmental Management Programme (EMP) for approval to the DMR. The MPRDA allows 180 days (6 months) for this process to be completed. Although the MPRDA governs environmental management in the mining sector, a number of the ancillary activities required for mining operations (such as the construction of pipelines and roads and the clearance of land) trigger the requirement for an Environmental Authorisation under the NEMA EIA Regulations GN Nos. R. 544-546 of 2010 and R. 922-923 of 2013. In addition, many activities will also trigger the requirement for water use authorisation in terms of Section 21 of the NWA, including (for example) taking water from a water resource, storing of water and disposing of waste in a manner that may detrimentally impact on a water resource. Refer to Table 2 for a list of the listed activities and water uses applicable to the Fuleni Anthracite Project. It is important to note that the MPRDA and NEMA processes for the Fuleni Anthracite Project are performed in parallel and that an integrated Scoping Report, EIA and EMP will be submitted for the purpose of both applications. The public participation (stakeholder engagement) required in terms of the MPRDA and the NEMA will also be conducted in parallel. Given that no time frames are specified in the NEMA 2010 Regulations for the Environmental Authorisation process, the timeframes stipulated in the MPRDA and directed by the DMR will be applicable. It is important to note that the applications for Environmental Authorisation for the Fuleni Anthracite Project were submitted prior to 8 December 2014 when the One Environmental System came into force. In accordance with the transitional arrangements, this application will therefore be concluded in terms of the previous MPRDA and NEMA regulations, as if these have not been repealed. 1.5.2.1 Mining Right Application Ibutho applied for a MRA in terms of section 22(1) of the MPRDA on 29 August 2013, which was accepted by the DMR on 27 January 2014. The dates for submission of the integrated Scoping Report and EIR / EMPr directed by the acceptance letter from the DMR {Ref: KZN 30/5/1/2/1/10045 MR} were as follow:  

Submission of Scoping Report Submission of EIR / EMPr

: :

6 March 2014 16 October 2014

The required Scoping report was submitted to the DMR on 6 March 2014. Due to the amount of comments and objections received from the Interested and Affected Parties (IAPs) and the communities, as well as the rejection of the final Scoping Report by the (then) Department of Economic Development, Tourism and Environmental Affairs (EDTEA) on 15 September 2014, the deadline for the submission of the EIR / EMPr was not achievable. The DMR was approached in this regard (on 16 September 2014), requesting for extension for the submission of the EIR / EMPr. The said extension request was denied by the DMR. As the prevailing prospecting right is still valid until 6 December 2015, Ibutho made the decision to retract the existing MR 18 | P a g e

application {Ref: KZN 30/5/1/2/1/10045 MR} and resubmitted an application for a mining right on 3 November 2014. The new application was accepted by the DMR on 16 January 2015 {Ref: KZN 30/5/1/2/2/10060 MR}, stipulating the following dates for submission of the integrated Scoping Report and EIR / EMPr:  

Submission of Scoping Report Submission of EIR / EMPr

: :

26 February 2015 22 May 2015

1.5.2.2 Application for Environmental Authorisation The application for Environmental Authorisation in terms of NEMA was submitted to the (then) Department of Agriculture and Environmental Affairs (DAEA) on 8 October 2013 and acknowledged by the Department on 11 December 2013 {DAEA Ref: DC 28/0035/2013: KZN/EIA/0001371/2013}. The draft Scoping report was submitted to the DAEA on 5 March 2014, followed by a final Scoping Report submitted on 8 July 2014. The Scoping Report has gone through three versions due to extensive comments received from both stakeholders and authorities. For the sake of clarification those versions are:   

Version 1: Draft Scoping Report made available to IAPs on 7 March 2014 Version 2: Final Scoping Report made available to IAPs on 10 July 2014 Version 3: Amendment to the Final Scoping Report made available to IAPs on 2 March 2015

The amended Final Scoping Report was accepted by KZN Department of Economic Development and Environmetal Affairs (KZNDED) on 14 April 2015. 1.5.2.3 Water Use Application Application to the Department of Water and Sanitation (DWS) for an Integrated Water Use Licence (IWUL) will be made once the mining and infrastructure have been finalized and the required specialist studies conducted.

1.5.3 ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) The coordination and management of the EIA process is being undertaken by an Independent Environmental Assessor, namely Jacana Environmentals cc (Jacana) with appointed specialists providing the required specialist inputs and administrative support. Marietjie Eksteen is the Managing Director of the consulting firm Jacana Environmentals cc, an environmental consulting firm based in Polokwane. She is an environmental scientist with 24 years experience, her main fields of expertise being water quality management, mine water management, environmental legal compliance and project management. Ms Eksteen is a registered Professional Environmental Scientist (Pr.Sci.Nat.) at the South African Council for Natural Scientific Professions – Registration No. 400090/02. Since establishing Jacana Environmentals in 2006, she has been involved in a variety of mine-related environmental projects serving clients such as Coal of Africa Limited, BHP Billiton Energy Coal SA, Xstrata 19 | P a g e

Coal SA and Optimum Coal. Prior to 2006 she was employed by Pulles Howard & De Lange Inc as an environmental consultant for 2 years. Before consulting, Ms Eksteen was employed by BHP Billiton as a mine environmental manager at their operations in Mpumalanga, as well as the Department of Water Affairs where she was appointed as a water quality specialist for the mining industry. Her career started off as a geophysicist at Genmin in 1990. Ms Eksteen obtained a Master degree in Exploration Geophysics (MSc) from the University of Pretoria in 1993.

1.5.4 EIA REPORT FRAMEWORK The following reference documents were consulted to compile this report: 



MPRDA EIA Requirements: o Regulation 49 of GN No R.527 of 23 April 2004: Mineral and Petroleum Resources Development Regulations o DMR Guideline and Template for the compilation of an EIA and EMP NEMA EIA Requirements: o Regulation 28 of GN No R.543 of 18 June 2010: Environmental Impact Assessment Regulations

20 | P a g e

Table 2: Activity-based legal requirement assessment for the Fuleni Anthracite Project ACTIVITY

MPRDA

NEMA

NWA

Mining Operation - Opencast pits 1-6 - Underground mining

Mining Right Application

GNR545 – A15: Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more. GNR546 – A14: The clearance of an area of 5 hectares or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation outside urban areas. GNR545 – A5: The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply.

S21(c)&(i) – Impeding / altering of water courses S21(g) – Dust suppression

-

In-pit / underground water management {sumps / pumping} Storm water management {river diversions / berms}

CHPP and Infrastructure Areas - Access / haul roads

-

Stream crossings {bridges, pipelines roads}

S21(j) – Dewatering of pits S21(g) – Disposing of waste / water containing waste GNR544 – A11: The construction of (i) canals; (ii) channels; (iii) bridges; (iv) dams; (v) weirs; (vi) bulk storm water outlet structures; (vii) marinas; (viii) jetties exceeding 50 square metres in size; (ix) slipways exceeding 50 square metres in size; (x) buildings exceeding 50 square metres in size; or (xi) infrastructure or structures covering 50 square metres or more, where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line.

S21(c)&(i) – Impeding / altering of water courses

GNR544 – A22: The construction of a road, outside urban areas, (i) with a reserve wider than 13.5 meters or, (ii) where no reserve exists where the road is wider than 8 metres, or (iii) for which an environmental authorisation was obtained for the route determination in terms of activity 5 in Government Notice 387 of 2006 or activity 18 in Notice 545 of 2010. GNR544 – A11: The construction of (i) canals; (ii) channels; (iii) bridges; (iv) dams; (v) weirs; (vi) bulk storm water outlet structures; (vii) marinas; (viii) jetties exceeding 50 square metres in size; (ix) slipways exceeding 50 square metres in size; (x) buildings exceeding 50 square metres in size; or (xi) infrastructure or structures covering 50 square metres or more, where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line. GN544 – A18: The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock from (i) a watercourse; (ii) the sea;

S21(g) – Dust suppression

S21(c)&(i) – Impeding / altering of water courses

21 | P a g e

ACTIVITY

-

Infrastructure area, workshops

-

Plant stockpiles

-

Clean water storage tanks

-

Dirty water dams

MPRDA

NEMA (iii) the seashore; (iv) the littoral active zone, an estuary or a distance of 100 metres inland of the high-water mark of the sea or an estuary, whichever distance is the greater. GNR545 – A15: Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more. GNR546 – A14: The clearance of an area of 5 hectares or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation outside urban areas. GNR545 – A5: The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply. GNR546 – A1: The construction of billboards exceeding 18 square metres in size outside urban or mining areas or outside industrial complexes in areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve. GNR546 – A3: The construction of masts or towers of any material or type used for telecommunication broadcasting or radio transmission purposes where the mast: (a) is to be placed on a site not previously used for this purpose, and (b) will exceed 15 metres in height, but excluding attachments to existing buildings and masts on rooftops in areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core areas of a biosphere reserve. GNR545 – A5: The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply. GNR544 – A12: The construction of facilities or infrastructure for the offstream storage of water, including dams and reservoirs, with a combined capacity of 50000 cubic metres or more. GNR546 – A2: The construction of reservoirs for bulk water supply with a capacity of more than 250 cubic meters in areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve. GNR544 – A12: The construction of facilities or infrastructure for the off-

NWA

S21(g) – Disposing of waste / water containing waste

S21(g) – Disposing of waste / water containing waste

S21(b) – Storage of water

S21(g) – Disposing of waste / water containing waste

22 | P a g e

ACTIVITY -

MPRDA

Bulk hydrocarbon facilities

- Sewage treatment plant Conveyance / transport of ROM & product on site - Haul / service roads

-

{River crossings / culverts}

Bulk Water Supply - Bulk water dam

Mine residue management - Overburden stockpiles

NEMA

NWA

stream storage of water, including dams and reservoirs, with a combined capacity of 50000 cubic metres or more. GN545 – A3: The construction of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of more than 500 cubic metres. S21(g) – Disposing of waste / water containing waste GNR544 – A22: The construction of a road, outside urban areas, (i) with a reserve wider than 13.5 meters or, (ii) where no reserve exists where the road is wider than 8 metres, or (iii) for which an environmental authorisation was obtained for the route determination in terms of activity 5 in Government Notice 387 of 2006 or activity 18 in Notice 545 of 2010. GNR544 – A11: The construction of (i) canals; (ii) channels; (iii) bridges; (iv) dams; (v) weirs; (vi) bulk storm water outlet structures; (vii) marinas; (viii) jetties exceeding 50 square metres in size; (ix) slipways exceeding 50 square metres in size; (x) buildings exceeding 50 square metres in size; or (xi) infrastructure or structures covering 50 square metres or more, where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line.

S21(g) – Dust suppression

GNR545 – A19: The construction of a dam, where the highest part of the dam wall, as measured from the outside toe of the wall to the highest part of the wall, is 5 metres or higher or where the high-water mark of the dam covers an area of 10 hectares or more. GNR544 – A9: The construction of facilities or infrastructure exceeding 1000 metres in length for the bulk transportation of water, sewage or storm water - (i) with an internal diameter of 0,36 metres or more; or (ii) with a peak throughput of 120 litres per second or more, excluding where: a. such facilities or infrastructure are for bulk transportation of water, sewage or storm water or storm water drainage inside a road reserve; or b. where such construction will occur within urban areas but further than 32 metres from a watercourse, measured from the edge of the watercourse. GNR544 – A11: The construction of (i) canals; (ii) channels; (iii) bridges; (iv) dams; (v) weirs; (vi) bulk storm water outlet structures; (vii) marinas; (viii) jetties exceeding 50 square metres in size; (ix) slipways exceeding 50 square metres in size; (x) buildings exceeding 50 square metres in size; or (xi) infrastructure or structures covering 50 square metres or more, where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line.

S21(a) – Water abstraction S21(b) – Water storage S21(c)&(i) – Impeding / altering of water courses

GNR545 – A15: Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional

S21(g) – Disposing of waste / water containing waste

S21(c)&(i) – Impeding / altering of water courses

S21(c)&(i) – Impeding / altering of water courses

S21(c)&(i) – Impeding / altering of water courses

23 | P a g e

ACTIVITY -

Discards stockpile

MPRDA

NEMA

NWA

use where the total area to be transformed is 20 hectares or more. GNR546 – A14: The clearance of an area of 5 hectares or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation outside urban areas.

- In-pit disposal / rehabilitation - General / hazardous waste Transport of product - Product haulage road

-

Bulk power / electrical reticulation - Construction / operational power

S21(g) – Disposing of waste / water containing waste N/A – off-site disposal GNR544 – A22: The construction of a road, outside urban areas, (i) with a reserve wider than 13.5 meters or, (ii) where no reserve exists where the road is wider than 8 metres, or (iii) for which an environmental authorisation was obtained for the route determination in terms of activity 5 in Government Notice 387 of 2006 or activity 18 in Notice 545 of 2010. GNR544 – A47: The widening of a road by more than 6 metres, or the lengthening of a road by more than 1 kilometre - (i) where the existing reserve is wider than 13,5 meters; or (ii) where no reserve exists, where the existing road is wider than 8 metres – excluding widening or lengthening occurring inside urban areas. GN544 – A11: The construction of (i) canals; (ii) channels; (iii) bridges; (iv) dams; (v) weirs; (vi) bulk storm water outlet structures; (vii) marinas; (viii) jetties exceeding 50 square metres in size; (ix) slipways exceeding 50 square metres in size; (x) buildings exceeding 50 square metres in size; or (xi) infrastructure or structures covering 50 square metres or more, where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line. GN544 – A18: The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock from (i) a watercourse; (ii) the sea; (iii) the seashore; (iv) the littoral active zone, an estuary or a distance of 100 metres inland of the high-water mark of the sea or an estuary, whichever distance is the greater. GN544 – A10: The construction of facilities or infrastructure for the transmission and distribution of electricity - (i) outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts; or (ii) inside urban areas or industrial complexes with a capacity of 275 kilovolts or more.

S21(c)&(i) – Impeding / altering of water courses

S21(c)&(i) – Impeding / altering of water courses

S21(c)&(i) – impeding / altering of water courses (To be confirmed)

24 | P a g e

NEED AND DESIRABILITY OF THE PROJECT

1.6

According to the KwaZulu-Natal Planning Commission’s Vision 2030, KwaZulu-Natal will be a prosperous province with a healthy, secure and skilled population acting as a gateway to Africa and the world. Ibutho works closely with provincial government structures to make sure that the proposed mining activities complement the long-term vision of the KZN Planning Commission. The Commission developed specific strategic goals and Ibutho committed and aligned the Fuleni Anthracite Project to these goals:       

Job creation; Human resource development; Human and community development; Strategic infrastructure; Environmental sustainability; Governance and policy; and Spatial equity.

1.6.1 ECONOMIC BENEFITS Anthracite is a carbon-rich, high quality coal whose key application is as a carbon feedstock (reductant), replacing coke in metallurgical processing industries, with a notable increase in the intensity of anthracite use i.e. as a substitute for coke in ferroalloy smelting activities. Other uses of anthracite include:    

A smokeless fuel for domestic heating and similar processes, typically in urban areas where pollution restrictions apply; Pulverised fuel for power generation in the older type coal burning utilities, especially in Europe; and The manufacture of carbon-rich products, such as Soderberg electrodes and carbon blocks. Anthracite competes with bituminous coals, chars and cokes as a reductant in the metallurgical industry, particularly in the production of ferroalloys. It also makes an ideal blend with high volatile matter thermal coal.

The quality of the Fuleni primary product should be well accepted by overseas customers in India, Middle East, Europe and China. The steel and ferroalloy industries (FeCr and FeMn) are key consumers of anthracite products, with Xstrata and Samancor as dominant players in the South African ferrochrome market. The secondary product is a thermal coal and will be typically accepted by Eskom. Ibutho Coal aims to developing new customers for Anthracite and Thermal Coal in the overseas and local markets. The Fuleni Anthracite Project will develop a high quality mineral resource with an estimated LOM of 32 years which has the potential for huge economic benefits on local, provincial and national level in terms of employment and the contribution to the GDP.

25 | P a g e

In addition to the quantifiable economic benefits that will result from this development, there are also a number of benefits that are not measurable in the same way, but that should be considered. These benefits could include: 







 

Technology: Technology used on the mine will work towards improving knowledge on available technologies and skills in using such technology. This may enable local communities to run their own successful businesses in the future. Skills development: Local communities who may not have any marketable skills other than a basic education will be able to acquire skills through employment on the mine. This benefit will be least for those who work as employees. However, those who work in other roles may take on leadership positions or acquire technical skills in their roles. Asset base: The capital expenditure outlaid into the land in the area will result in an asset base upon which future development can occur. In addition to this, the asset base adds value to the municipality itself and provides a starting point for future developments. Local procurement and SMME opportunities: Local communities will be provided with opportunities and capacity to participate in contracts that would become available during the construction and operational phases. Equity participation of local communities. Equal employment opportunities and training and skills development opportunities associated with the mine will improve.

1.6.2 SOCIAL AND LABOUR PLAN Ibutho is committed to optimize opportunities in the local communities through the implementation of the Social and Labour Plan (SLP). The SLP implementation will commence once a decision has been made by the Department of Mineral Resources on the granting of the Mining Right. 1.6.2.1 Job Creation The Fuleni Anthracite Project will create 200 permanent job opportunities at commencement, ramping up to 363 job opportunities within the first 5 years of mining with an opportunity to create more than 400 opportunities once production reaches steady state. Ibutho has set a target to ensure that at least half of these opportunities are allocated to the local communities. 1.6.2.2 Workforce Development As part of the SLP, Ibutho plans to implement a comprehensive workforce development plan through adult basic education and training, core business training, artisan training, learnerships, bursaries and internships programmes. These will be supported by career-path planning and mentorship. Ibutho has committed these programmes over the first 5 years of mining with a total value of R 6.6 million: 

 

Core business and Artisan Training – creating an opportunity for 59 candidates to complete various training courses in Machine Operation, Truck Driving, Health and Safety, Human Resources, Mechanics, Electricians, Fitting and Turning. To make available 31 learnership opportunities in Engineering, Artisans, Machine Operation. To establish career-path plans for those candidates showing promise to fast track their development and facilitate promotions. 26 | P a g e

 

To make available 22 bursaries in Mining, Mechanical & Electrical Engineering, Financial, Human Resources and Geology study areas. To make available 7 internship opportunities in Mechanical & Electrical Technicians, Health and Safety and Financial positions.

1.6.2.3 Community Development To further support local communities, Ibutho is proposing Community Development Projects focused on Education and Small business development. Ibutho proposes the implementation of the following projects over the first 5 years of mining with a total value of R 2 million: 





School Needs Project in the schools located in Ocilwane, Novunula, Ntuthunga 1 and Ntuthunga 2, two (2) secondary and four (4) primary schools. The project will focus on key needs in each school, which will be identified in consultation with the school management and the Department of Education. Enterprise Development Project amongst local business people focusing on the establishment, training and mentoring of local companies in personnel transport, security, protective clothing, and catering. Unlocking Agricultural Potential amongst the local communities. This project will commence its first phase in the 5 year term, which will focus on planning agriculture interventions and organizing and training of local farmers to provide inputs and benefit from interventions to be implemented during the life of mine.

27 | P a g e

2 DESCRIPTION OF THE BASELINE CULTURAL, SOCIO-ECONOMIC AND BIOPHYSICAL ENVIRONMENT A number of specialist studies were performed for the Fuleni Anthracite Project, in line with the Plan of study presented in the Amendment to the Final Scoping Report accepted by KZNDED on 14 April 2015. NOTE: This EIA Report is a summary of the information provided in the specialist reports only and should be read in conjunction with the specialist reports.

2.1

SPECIALIST TEAM

The specialist team that has been appointed to assist Jacana Environmentals with the EIA is: 

Soil and land use capacity

Rossouw Associates



Biodiversity / Aquatic systems

Scientific Aquatic Services



Surface water

WSM Leshika Consulting (Pty) Ltd



Groundwater

Groundwater Complete



Air Quality

Royal Haskoning DHV



Noise

Jongens Keet Associates



Blasting and Vibration

Blasting Management & Consulting



Traffic Impact Assessment

Arup (Pty) Ltd



Heritage

eThembeni Cultural Heritage



Visual

Scientific Aquatic Services



Wilderness Risk Assessment

Scientific Aquatic Services



Social / Household Surveys

Development Unlimited



Health Impact Assessment

Occupational Care SA



Social Impact Assessment

Naledi Development Restructured (Pty) Ltd



Socio- and Macro-Economic

Graham Muller Associates



Sensitivity Mapping

Scientific Aquatic Services

Their qualification and professional registrations and affiliations are provided in Table 3.

28 | P a g e

Table 3: Qualification and professional registrations and affiliations of EIA specialists Aspect

Soils, land use & land capability

Biodiversity impact assessment Wilderness Assessment Sensitivity Mapping

Firm

Rossouw Associates

Scientific Aquatic Services

Specialists

Qualification

Professional registrations and affiliations

MSc Agriculture Soil Science

Pr.Sci.Nat. - SACNASP Reg No. 400194/12. Member of Soil Science Society of South Africa (SSSSA), South African Soil Surveyors Organisation (SASSO) and South African Wetland Society (SAWS).

Stephen van Staden

BSc (Hons) Zoology MSc Environmental Management

Pr.Sci.Nat. - SACNASP Reg No. 400134/05. Registered by the SA RHP as an accredited aquatic biomonitoring specialist. Member of the Gauteng Wetland Forum and South African Soil Surveyors Association (SASSO). 11 years of experience in ecology.

Christopher Hooton

National Diploma: Nature Conservation BTech Nature Conservation

Experience in environmental enforcement with GDARD as well as customs officials. Extensive experience in large mammal and carnivore research and management across south Africa and especially the Phinda Game reserve.

Emile van der Westhuizen

B.Sc. Environmental Management and Botany B.Sc. Hons Plant Science

Cand.Sci.Nat. - SACNASP Reg No. 100008/15. Extensive experience (more than 8 years) in botanical ecological assessments throughout Southern, Central, East and West Africa. Senior consultant, project manager and reviewer.

National Diploma in Nature Conservation

Timbavati Private Nature Reserve: Ground Hornbill Monitoring and monitoring project on nesting sites of White Backed Vultures on the reserve by using game census data and visiting the sites to determine if the nesting sites where still active or not. Agriculture Research Council: Vegetation Condition Assessments. Hennie is a keen birder and was a member of the Limpopo Falconers club (2007-2012) where he rehabilitated several raptors and also actively hunted with them.

PS Rossouw

Hennie de Beer

29 | P a g e

Aspect

Firm

Specialists

Qualification

Professional registrations and affiliations

M.Sc. Botany

Pr.Sci.Nat. - SACNASP Reg No. 400229/11. International Affiliation for Impact Assessments (IAIA). Botanical Society of SA member. Western Cape Wetlands Forum member.

Michelle de Klerk

B.Sc. Landscape Architecture B.Sc. Botany B.Sc. Hons Plant Science

Pr.Sci.Nat. - SACNASP REG.NO: 400003/15 Botanical Society of South Africa (BotSoc). South African Council for the Landscape Architectural Profession (SACLAP). 6 Years experience in the fields of landscape architecture, environmental management visual impact assessments and botany.

Dionne Crafford

B.Sc Ecology B.Sc (Hons) Zoology M.Sc Parasitology

Pr.Sci.Nat.

Rand Afrikaans University, BSc (Hons) Geology

A decade of proven experience in GIS and database management.

Anna Jansen van Vuuren

M Eng (Civil Engineering)

ECSA: Professional Engineer No 770359 (registered 21 November 1977) (Registration renewed for further 5 years from Feb 2013). SAICE: Member of the SA Institution of Civil Engineers: No 010181 (registered 14 April 1978). Fellow of SAICE 16 August 2002.

Rian Coetzee

N Dip (Civil Engineering)

-

Gerhard Steenekamp

MSc Geohydrology / Hydrology

Pr.Sci.Nat. - SACNASP Reg No. 400385/04.

Elida Boshoff

MSc Geohydrology

Pr.Sci.Nat. - SACNASP Reg No. 400286/14.

Paul Naude

BSc (Hons) M.Sc. Mol. Phylogenetics)

Pr.Sci.Nat. - SACNASP Reg No. 400130/10.

Natasha van de Haar

Jilleen Payne (South GIS)

Surface water impact assessment

Groundwater impact assessment

WSM Leshika Consulting Pty Ltd

Groundwater Complete

30 | P a g e

Aspect

Air quality impact assessment

Firm

Specialists

Qualification

Professional registrations and affiliations

Stuart Thompson

BSc (Hons) Applied Environmental Science

Society South African Geographers. South African Geophysical Association, M07/007. National Association for Clean Air. Air Pollution Information Network - Africa, Life time Membership. Astronomical Society for SA, Committee Member, THO003.

Lodewyk Jansen

BSc (Hons) Environmental Management

South African Society of Atmospheric Sciences National Association for Clean Air.

PhD (Toxicology)

Pr.Sci.Nat. - SACNASP Reg No. 400126/07 National Association for Clean Air. Air Pollution Information Network - Africa, Life time Membership.

Derek Cosijn

BSc (Civil Eng) 1967 Diploma in Town Planning 1974

Engineering Council of South Africa: Professional Engineer No 720347 (registered 17 April 1972). SA Institution of Civil Engineers (SAICE): Member No 8527. SAICE: Fellow 5 October 2000. Southern African Acoustics Institute Member 12 May 2004. Certified Environmental Assessment Practitioner of South Africa. 15 July 2002.

Erica Cosijn

MA, Post Grad Dipl Info Sci DPhil

Member Association for Computing Machinery Associate Member Acoustical Society of America

Danie Zeeman

1985 - 1987 Diploma: Explosives Technology, Technikon Pretoria 1990 - 1992 BA Degree, University Of Pretoria 1994 National Higher Diploma: Explosives Technology, Technikon Pretoria

International Society of Explosives Engineers.

Royal Haskoning DHV

Raylene Watson

Noise impact assessment

Blasting and Vibration Study

Jongens Keet Associates

Blasting Management & Consulting

31 | P a g e

Aspect

Firm

Specialists

Qualification

Professional registrations and affiliations

2000 Advanced Certificate in Blasting, Technikon SA

Traffic Impact Assessment

Heritage and cultural impact assessment

Visual Impact Assessment

Social / Household Surveys

Mohamed Kajee

BSc (Civil Eng)

ECSA Member Number 20075024 SAICE Corporate Member Number 207035

Naeem Hassen

BSc (Civil Eng)

ECSA Member Number 201350101 SAICE Member Number 20121494

Len van Schalkwyk

MA Archaeology

Association of Southern African Professional Archaeologists (ASAPA). ASAPA Council Member - Cultural Resources Management Portfolio (CRM): 2011-2013. ASAPA CRM Section - listed as Principal Investigator. Amafa aKwaZulu-Natali accredited heritage practitioner. South African Heritage Resources Agency’s Archaeological Permit Advisory Committee (2004). South African member of International Scientific Committee for Archaeological Management, elected by ICOMOS-SA Executive (1999 – 2000. Provincial Representative: South African World Heritage Convention Committee (1998 - 2000). Southern African Museums Association (1984 -1999).

Elizabeth Wahl

BA (Hons)

Professional member of ASAPA (Reg No 173).

Michelle de Klerk

B.Sc. Landscape Architecture B.Sc. Botany B.Sc. Hons Plant Science

Botanical Society of South Africa (BotSoc). South African Council for the Landscape Architectural Profession (SACLAP). 6 Years experience in the fields of landscape architecture, environmental management visual impact assessments and botany.

Lebo Mokoatsi

BA (Economics & Public Administration) Secondary Teachers Diploma (Mathematics & Physical Science)

-

Arup (Pty) Ltd

eThembeni Cultural Heritage

Scientific Aquatic Services

Development Unlimited cc

32 | P a g e

Aspect

Health Impact Assessment

Socio- and macro-economic impact assessment

Social Impact Assessment

Firm

Specialists

Qualification

Professional registrations and affiliations

Piet Marais

MSc (Occupational Physiology)

Registered Occupational Hygienist (SAIOH) Reg No. 0297. Founder members of the Occupational Hygiene Association of SA (OHASA). President of the Southern African Institute for Occupational Hygiene (SAIOH)

Christine de Klerk

BSc Physiology, Occupational Hygiene

SAIOH Registered Occupational Hygiene Assistant {Reg No. 0965}

Graham Muller

MA from London School of Economics, CIMA ACMA, CGMA

Economic Society of South Africa. Chartered Institute of Management Accountants.

Luke Muller

MCom, UKZN

Andrew McGill

BCom Economics & Finance, UKZN

Richard Gevers

BCom UKZN, CIMA AD DIP

Lizinda Dickson

BA (Geography) BA (Hons) Environmental Management M Inst Agrar Environment and Society

International Association for Impact Assessment.

Carien Joubert

PhD Social and Behavioural Sciences

-

Fransis de la Rosa

Diploma in Tourism Diploma in Environmental Management

-

William Nkuna

Diploma in Human Resource Development and Management

-

Occupational Care SA

Graham Muller Associates

Naledi Development Restructured

33 | P a g e

CULTURAL AND HERITAGE RESOURCES

2.2

Heritage assessments typically consider the following wide range of heritage resource types:          

Places, buildings, structures and equipment; Places associated with oral traditions or living heritage; Landscapes and natural features; Traditional burial places; Ecofacts; Geological sites of scientific or cultural importance; Archaeological sites; Historical settlements and townscapes; Public monuments and memorials; and Battlefields.

2.2.1 ARCHAEOLOGICAL CONTEXT OF THE AREA In archaeological terms South Africa’s prehistory has been divided into a series of phases based on broad patterns of technology. The primary distinction is between a reliance on chipped and flaked stone implements (the Stone Age), the ability to work iron (the Iron Age) and the Colonial Period, characterised by the advent of writing and in southern Africa primarily associated with the first European travellers (Mitchell 2002). Spanning a large proportion of human history, the Stone Age in Southern Africa is further divided into the Early Stone Age, or Paleolithic Period (about 2 500 000–150 000 years ago), the Middle Stone Age, or Mesolithic Period (about 500 000–30 000 years ago), and the Late Stone Age, or Neolithic Period (about 30 000–2 000 years ago). The simple stone tools found with australopithecine fossil bones fall into the earliest part of the Early Stone Age. 2.2.1.1 The Stone Age 2.2.1.1.1 Early Stone Age

Most Early Stone Age sites in South Africa can probably be connected with the hominin species known as Homo erectus. Simply modified stones, hand axes, scraping tools, and other bifacial artifacts had a wide variety of purposes, including butchering animal carcasses, scraping hides, and digging for plant foods. Most South African archaeological sites from this period are the remains of open camps, often by the sides of rivers and lakes, although some are rock shelters, such as Montagu Cave in the Cape region. 2.2.1.1.2 Middle Stone Age

The long episode of cultural and physical evolution gave way to a period of more rapid change about 120 000 years ago. Hand axes and large bifacial stone tools were replaced by stone flakes and blades that were fashioned into scrapers, spear points, and parts for hafted, composite implements. This technological stage, now known as the Middle Stone Age, is represented by numerous sites in South Africa. Open camps and rock overhangs were used for shelter. Day-to-day debris has survived to provide some evidence of early ways of life, although plant foods have rarely been preserved. Middle Stone Age bands 34 | P a g e

hunted medium-sized and large prey, including antelope and zebra, although they tended to avoid the largest and most dangerous animals, such as the elephant and the rhinoceros. They also ate seabirds and marine mammals that could be found along the shore and sometimes collected tortoises and ostrich eggs in large quantities. The Middle Stone Age is perhaps most significant as the time period during which the first modern humans, Homo sapiens sapiens, emerged between 120 000 and 30 000 years ago. The Klasies River cave complex, located on the southern Cape coast contains the oldest remains of anatomically modern humans in the world, dating to around 110 000 years ago (Singer & Wymer 1982; Rightmire & Deacon 1991). Humans were anatomically modern by 110 000 years ago but only developed into culturally modern behaving humans between 80 000 and 70 000 years ago, during cultural phases known as the Still Bay and Howieson’s Poort time periods or stone tool traditions. 2.2.1.1.3 The Late Stone Age

Basic toolmaking techniques began to undergo additional change about 40 000 years ago. Small finely worked stone implements known as microliths became more common, while the heavier scrapers and points of the Middle Stone Age appeared less frequently. Archaeologists refer to this technological stage as the Later Stone Age or LSA, which can be divided into four broad temporal units directly associated with climatic, technological and subsistence changes (Deacon 1984):    

Late Pleistocene microlithic assemblages (40‐12 000 years ago); Terminal Pleistocene / early Holocene non‐microlithic (macrolithic) assemblages (12‐8 000 years ago); Holocene microlithic assemblages (8 000 years ago to the Colonial Period); and Holocene assemblages with pottery (2 000 years ago to the Historic Period) closely associated with the arrival of pastoralist communities into South Africa (Mitchell 1997; 2002).

Animals were trapped and hunted with spears and arrows on which were mounted well-crafted stone blades. Bands moved with the seasons as they followed game into higher lands in the spring and early summer months, when plant foods could also be found. When available, rock overhangs became shelters; otherwise, windbreaks were built. Shellfish, crayfish, seals, and seabirds were also important sources of food, as were fish caught on lines, with spears, in traps, and possibly with nets. Elements of material culture characteristic of the LSA that reflect cultural modernity have been summarised as follows (Deacon 1984):     

Symbolic and representational art (paintings and engravings); Items of personal adornment such as decorated ostrich eggshell, decorated bone tools and beads, pendants and amulets of ostrich eggshell, marine and freshwater shells; Specialized hunting and fishing equipment in the form of bows and arrows, fish hooks and sinkers; A greater variety of specialized tools including bone needles and awls and bone skin-working tools; Specialized food gathering tools and containers such as bored stone digging stick weights, carrying bags of leather and netting, ostrich eggshell water containers, tortoiseshell bowls and scoops and later pottery and stone bowls;

35 | P a g e

  

Formal burial of the dead in graves, sometimes covered with painted stones or grindstones and accompanied by grave goods; The miniaturization of selected stone tools linked to the practice of hafting for composite tools production; and A characteristic range of specialized tools designed for making some of the items listed above.

2.2.1.2 The Iron Age Archaeological evidence shows that Bantu-speaking agriculturists first settled in southern Africa around AD 300. Bantu-speakers originated in the vicinity of modem Cameroon from where they began to move eastwards and southwards, sometime after 400 BC, skirting around the equatorial forest. An extremely rapid spread throughout much of sub-equatorial Africa followed: dating shows that the earliest communities in Tanzania and South Africa are separated in time by only 200 years, despite the 3 000 km distance between the two regions. It seems likely that the speed of the spread was a consequence of agriculturists deliberately seeking iron ore sources and particular combinations of soil and climate suitable for the cultivation of their crops. The earliest agricultural sites in KwaZulu-Natal date to between AD 400 and 550. All are situated close to sources of iron ore, and within 15 km of the coast. Current evidence suggests it may have been too dry further inland at this time for successful cultivation. From 650 onwards, however, climatic conditions improved and agriculturists expanded into the valleys of KwaZulu-Natal, where they settled close to rivers in savanna or bushveld environments. There is a considerable body of information available about these early agriculturists. Seed remains show that they cultivated finger millet, bulrush millet, sorghum and probably the African melon. It seems likely that they also planted African groundnuts and cowpeas, though direct evidence for these plants is lacking from the earlier periods. Faunal remains indicate that they kept sheep, cattle, goats, chickens and dogs, with cattle and sheep providing most of the meat. Men hunted, perhaps with dogs, but hunted animals made only a limited contribution to the diet in the region. Metal production was a key activity since it provided the tools of cultivation and hunting. The evidence indicates that people who worked metal lived in almost every village, even those that were considerable distances from ore sources. Large-scale excavations in recent years have provided data indicating that first-millennium agriculturist society was patrilineal and that men used cattle as bridewealth in exchange for wives. On a political level, society was organised into chiefdoms that, in our region, may have had up to three hierarchical levels. The villages of chiefs tended to be larger than others, with several livestock enclosures, and some were occupied continuously for lengthy periods. Social forces of the time resulted in the concentration of unusual items on these sites. These include artefacts that originated from great distances, ivory items (which as early as AD 700 appear to have been a symbol of chieftainship), and initiation paraphernalia. This particular way of life came to an end around AD 1000, for reasons that we do not yet fully understand. There was a radical change in the decorative style of agriculturist ceramics at this time, while the preferred village locations of the last four centuries were abandoned in favour of sites along the coastal littoral. In general, sites dating to between 1050 and 1250 are smaller than most earlier agriculturist settlements. It is 36 | P a g e

tempting to see in this change the origin of the Nguni settlement pattern. Indeed, some archaeologists have suggested that the changes were a result of the movement into the region of people who were directly ancestral to the Nguni-speakers of today. Others prefer to see the change as the product of social and cultural restructuring within resident agriculturist communities. Whatever the case, it seems likely that this new pattern of settlement was in some way influenced by a changing climate, for there is evidence of increasing aridity from about AD 900. A new pattern of economic inter-dependence evolved that is substantially different from that of earlier centuries, and is one that continued into the colonial period nearly 500 years later.

2.2.2 INITIAL ASSESSMENT OF SITES IN THE AREA Heritage impact assessments (HIA) at past and current mining activities, such as those at the adjacent Somkhele Mine, and literature and database reviews indicate that the following heritage resource types are likely to be present in the Fuleni Anthracite Project MRA area and will require mitigation before and possibly during mining operations: 2.2.2.1 Places Associated with Oral Traditions or Living Heritage Communal areas in southern Africa typically include places (such as mountains, river pools and forests) that are associated with cultural tradition; oral history; performance; ritual; popular memory; traditional skills and techniques; indigenous knowledge systems; and the holistic approach to nature, society and social relationships. Such places may be known to and utilised by entire communities, or only certain individuals, such as traditional healers. They may be visited regularly or only periodically, and their heritage significance could vary from low to high along a local to a national scale. Extensive developments such as mining activities potentially damage or destroy such places, with little or no opportunities for restitution and concomitant community disruption. Accordingly, it is imperative that alteration to such places is avoided by changing the development footprint if necessary, or negotiating appropriate offsets with affected communities. 2.2.2.2 Landscapes and Natural Features The project area is largely undeveloped and rural with low-density dispersed settlements and associated subsistence agriculture. Dwellings are grouped as small family-sized homesteads located in undulating terrain. Visual impacts would result from the construction, operation and closure phase of the proposed project. Specifically, impacts would result from the discard dump, open cast pits and ancillary surface infrastructure being seen from sensitive viewpoints (especially tourists) and the negative effects (relating primarily to visibility and visual absorption capability) on the scenic quality and sense of place of the landscape of the proposed site. At least two main areas in the vicinity of the project are considered to be sensitive landscapes and are described below. 37 | P a g e

2.2.2.2.1 Hluhluwe-iMfolozi Park

The HiP, formerly known as Hluhluwe–Umfolozi Game Reserve, is the oldest proclaimed natural park in Africa and lies west of the project area. It consists of 960 km² (96 000 ha) of hilly topography located 280 km north of Durban in central Zululand, KwaZulu-Natal and is known for its rich wildlife and conservation efforts. The park is the only state-run conservation area in KwaZulu-Natal where all the big five game animals occur. Due to conservation efforts, the park now has the largest population of white rhino in the world. The HiP was originally three separate reserves that joined under its current title in 1989. Throughout the park there are many signs of Stone Age archaeological sites. The area was originally a royal hunting ground for the Zulu kingdom, but was established as a park in 1895. The Umfolozi and Hluhluwe reserves were established primarily to protect the white rhinoceros, then on the endangered species list. The area has always been a haven for animals as tsetse flies carrying the nagana disease are common, which protected the area from hunters in the colonial era. However, as the Zululand areas was settled by European farmers the game was blamed for the prevalence of the tsetse fly and the reserves became experimental areas in the efforts to eradicate the fly. Farmers called for the slaughter of game and about 100 000 animals were killed in the reserve before the introduction of DDT spraying in 1945 solved the problem. However, white rhinoceros were not targeted and today a population of about 1000 is maintained. Potential impacts of mining on the park are likely to be indirect, including visual and noise pollution, and could affect its aesthetic and economic heritage significance negatively for the duration of construction and operation of the mine. 2.2.2.2.2 Mfolozi River

The Mfolozi River lies adjacent to the mining site and is formed by the confluence of the Black (Imfolozi emnyama) and White Mfolozi (Imfolozi emhlope) Rivers near the southeastern boundary of the HiP. The isiZulu name imFolozi is generally considered to describe the zigzag course followed by both tributaries, though other explanations have been given. The river flows in an easterly direction to the Indian Ocean at Maphelana, a coastal resort just south of the St Lucia River mouth. It originally meandered over the Monzi Flats, where it split into numerous slowflowing channels before entering the St. Lucia Estuary at Honeymoon Bend. The slow-moving water and reed beds in channels operated as a natural filtering system that removed silt from the Mfolozi floodwaters and created a rich habitat for numerous species. During the 1950s, the Umfolozi Landowners Association contained and artificially channeled the river through the Monzi Flats to develop sugarcane farms. The new Mfolozi canal resulted in the unfiltered water depositing its silt load after entering the slower moving St. Lucia Estuary. This caused the estuary mouth to rapidly silt up. There had only been one record of this occurring until that time, during the sustained drought during the 1930s. The government started a costly dredging operation in the estuary mouth area, but it proved ineffective. After years of dredging, the next plan was to prevent the Mfolozi River from entering the St Lucia estuary. The Mfolozi River was canalized straight out to sea at Maphelana. The impact of this decision continues; the silt plume from the river is often blown by strong south winds as far north as Sodwana Bay, 100 km 38 | P a g e

away. The changes threaten the coral reefs, which provide fish habitat and protect the shore. In addition, it jeopardizes the associated good snorkeling available at Cape Vidal, part of iSimangaliso Wetland Park, a UNESCO World Heritage Site. Potential impacts of mining on the river are likely to be direct and indirect and could affect its aesthetic, scientific (including biodiversity and ecology) and economic (including drinking and irrigation) heritage significance negatively for the duration of construction and operation of the mine and beyond. 2.2.2.3 Traditional Burial Places Numerous traditional burial places are known to occur within and adjacent to the project area. Such burials comprise one or more ancestral graves, typically located within or close to homestead precincts, rather than in formal cemeteries managed by a local authority. Graves usually comprise stone-packed mounds, with or without a headstone, although older graves may be less readily identifiable due to the deflation of the mound and scattering of the stone covering. All human remains have high heritage significance at all levels due to their spiritual, social and cultural values and may not be altered in any way without the permission of the next-of-kin and a permit from Amafa aKwaZulu-Natali, the Provincial Heritage Resources Authority. Potential impacts on traditional burial places range from indirect (next-of-kin cannot access graves during mining activities for health and safety reasons) to direct alteration or destruction. 2.2.2.4 Archaeological Sites Numerous archaeological sites are known to occur close to the project area (for example Anderson 1998, 1999; Hall 1981). Iron Age and historical sites are common in valley bottoms, on hill slopes and the tops of hills, ridges and spurs. If undisturbed, archaeological may have medium to high heritage significance for their historical and scientific values at various levels. Potential impacts on archaeological sites usually comprise alteration or destruction of the resource. Appropriate mitigation for sites with low heritage significance may be limited to basic recording and application for a destruction permit from Amafa; whereas more significant sites may require extensive recording, artefact sampling and/or excavation, all of which actions would require a permit from Amafa.

39 | P a g e

SOCIO-ECONOMIC ENVIRONMENT

2.3

The proposed mine is located in Mfolozi Local Municipality and uThungulu District Municipality in KwaZuluNatal. It is located on the northern boundary of the municipality with the Mfolozi River limiting linkages to the neighbouring municipality to the north. The proposed mine is on land owned by the Ingonyama Trust, on Mhlana Traditional Authority land.

2.3.1 POLICY AND PLANNING 2.3.1.1 KwaZulu Natal Provincial Growth and Economic Development Strategy, 2011 The 2011 KwaZulu-Natal Provincial Growth and Development Strategy (KZN PGDS) bolsters the Province’s commitment to achieving the vision of KwaZulu-Natal (KZN) as a “Prosperous Province with a healthy, secure and skilled population, acting as a gateway to Africa and the world”. The PGDS aims to build this gateway by growing the economy for the development and the improvement of the quality of life of all people living in the Province. The purpose of the 2011 KZN PGDS is to:  

 

Be the primary growth and development strategy for KwaZulu-Natal to 2030; Mobilise and synchronise strategic plans and investment priorities in all spheres of government, state owned entities, business, higher education institutions, labour, civil society and all other social partners in order to achieve the desired growth and development goals, objectives and outcomes; Spatially contextualise and prioritise interventions so as to achieve greater spatial equity; and Develop clearly defined institutional arrangements that ensure decisive leadership, robust management, thorough implementation and ongoing review of the growth and development plan.

The provincial, national and global policy framework, namely the six (6) Provincial Priorities, the twelve (12) National Outcomes, the New Growth Path, the National Planning Commission’s Diagnostic Report (NPC) and the Millennium Development Goals (MDGs) provides the backdrop to the 2011 KZN PGDS. These policies collectively together with the Situational Overview Report and the Strategic Analysis provide the foundation for the 2011 KZN PGDS and set the scene for the Province to build on these key priorities in developing its own growth and development trajectory. The 2011 KZN PGDS has devised a strong platform for a series of interventions to ensure that growth and development is oriented to its people and that a sustainable transformative agenda is prioritised. Significant milestones need to be achieved to address inherited social and spatial inequities which continue to inhibit the creation of safe, healthy and sustainable living environments. It is imperative that the institutional and governance framework also embraces thistransformative agenda by doing business differently - being developmental, competent, caring and facilitating – to ensure equitable, accessible and qualitative provision of services and infrastructure to all the people of this Province.

40 | P a g e

In attempting to address the challenges of the Province and embrace the policy intentions, the following principles were developed to facilitate overall guidance in the development of the 2011 KZN PGDS Strategic Framework, namely:        

Grow the economy to achieve shared growth; Harness the Province’s assets and endowments; Develop the Province’s greatest asset, its human capital; Harmonise environmental integrity and human and social development with economic development; Government must be developmental, competent, caring and facilitating; Private Sector must grow a shared economy to provide employment; Organised Labour must protect workers from exploitation while promoting labour productivity; and Civil Society must be responsible for shaping its own destiny.

For the 2011 KZN PGDS to deliver on shared growth and integrated, sustainable development through its interventions, all spheres of government must commit to the following:     

The implementation of catalytic projects and interventions; Effective participation in the institutional implementation framework; The incorporation of the strategic goals and objectives in their priorities and programmes; The reporting of progress; and The provision and allocation of the required support and resources.

2.3.1.2 KZN Tourism Master Plan The development of the KwaZulu-Natal Tourism Master Plan (KZNTMP) derives its mandate from theWhite Paper on the Development and Promotion of Tourism in KwaZulu-Natal of 2008, which stipulatesthat one of roles of the Provincial Government is to develop a Master Plan for tourism. The plan sets out the key strategic objectives and how to achieve these objectives for the province ensuringalignment to the National Tourism Sector Strategy (NTSS), a blueprint for the tourism sector withinSouth Africa and the Provincial Growth and Development Plan which clearly sets out economic growthtargets for KwaZulu-Natal leading to 2030. The development of the KZNTMP has been strategically undertakenand coordinated through active involvement and participation of various industry stakeholders. The KZNTMP sets a 2030 vision for tourism and further outlines specific key actions for the achievement of the set objectives, which includesincreasing the tourism GDP levels, increase of tourism employment in the province, and ensuring growth in levels of foreign and domesticvisitor arrivals to the province. The KZNTMP is premised on four main strategic clusters, namely: Policy, Strategy, Governance, Research & Knowledge Management, Monitoring & Evaluation; Planning and Product Development; People in Tourism and Marketing. The aim of these clusters is to providepolicy direction for tourism within the province; to prioritise and focus product planning and development to grow visitor numbers; topromote tourism awareness and understanding and also to ensure tourism growth and development in order to grow visitor numbers witha distinct emphasis on domestic tourism. 41 | P a g e

The KZN Tourism Master Plan is aligned to:    

The National Tourism Sector Strategy (NTSS). The National Growth Path. The National Development Plan. The Provincial Economic & Spatial objectives.

The following objectives have been set:          

Increase the tourism GDP levels; Grow the levels of all foreign visitor arrivals to the province; Grow the levels of domestic visitor arrivals to the province; Increase tourism employment in the province; Improve the geographic spread of tourism within the province; Ensure that Durban becomes/remains THE place to holiday for South Africansand other key markets; Improve overall visitor service and satisfaction levels throughout the province inall areas in which a visitor is serviced (i.e. beyond the recognised tourism plant to include retail, banking, toll roads etc.; Achieve significant transformation in the sector; Grow the events and meetings incentives and exhibitions sector (MICE) as a keyand important market area for the province; and Improve other niche tourism experiences for which the province has potentialand develop these markets.

The planning and product development strategy is based on strategic focus areas in terms of the core tourism experiences. Theprimary focus area is the Durban beach experience, and priority will be given in all planning and product development to improvingthe actual, and perceptions of, this experience. All other areas of focus are secondary. This does not mean that activities and attention will not occur from the outset to develop these areas, but when decisions regarding resource allocation options are considered forcompeting priorities, the priority will, in the initial years, be the beach experience in Durban. The secondary areas are:     

iSimangaliso WHS, Lubombo TFCA and Elephant Coast for wildlife experiences Ukhahlamba Drakensberg WHS/Maloti Drakensberg TFCA and Pietermaritzburg & Midlands – for scenic experiences Heritage Tourism – for overall experience uniqueness North Coast – beach experience South Coast – beach experience

42 | P a g e

2.3.1.3 KZN Spatial Development Framework, 2012

The Fuleni Anthracite Project area falls within identified areas of Economic Support and Social Need: 



Areas of Economic Support: number of regions resembled areas of good economic potential in more than just one of the key provincial economic sectors. Due to the fact that these areas represent a larger distribution across the entire province than the core areas of economic value adding, these zones are considered important areas of Economic Support. Typical interventions in these areas would include economic prioritisation of development, labour force interventions (e.g. skills development), key economic infrastructure investment and area promotion. Areas of High Social Need: The highest ranges of combined social need when considering the population density, dependency ratio as the provincial index of multiple deprivation is illustrated by this category of high social need. These areas broadly represents the areas where the most 43 | P a g e

intensive social interventions area required and this categorsy is further overlayed above all other categories to provide a spatial reference to the types of interventions which might be pursued towards addressing the concentrated social need within these areas. As example where high social need is identified within an area earmarked as areas of Economic Support, this firstly provides a reference to the fact that social conditions of communities will need to be addressed in line with economic development in the area. The project area is neighboured to the north by Biodiversity priority areas and to the south by further Areas of Economic support.

44 | P a g e

In promoting growth and development within the uThungulu District as well assupporting the proposed spatial structure and areas in need of intervention, the following provincial catalytic projects are envisaged within the district:        

Passenger Cruise Terminal Industrial Development Zone (IDZ) P700 Road Linkage Industrial Support Services (Empangeni) Eco, Battlefields & Cultural Heritage Tourism Routes Urban Regeneration Industrial Regeneration Small Town Regeneration 45 | P a g e

         

Regional Airports Innovation Hub Rural Service Centers ECD Centre Development Centres for the Disabled & Senior Citizens Substance abuse Rehabilitation Centres Rural Arts Centres Cultural Villages School Greening Rural Waste Management Units

2.3.1.4 uThungulu Spatial Development Framework, 2012

46 | P a g e

Spatial intervention areas refer to specific areas where deliberate actions from either the district municipality or any other tier of government can improve on a situation that prevails in the said area. Importantly, spatial intervention areas are identified and have to be benchmarked against anacceptable standard. The identification of spatial intervention areas can beconsidered as a step towards achieving a desired spatial pattern. The consolidated Spatial Development Framework for the uThungulu District elaborated on the following:           

Primary and Secondary Nodes Corridors and Focus Areas Ongoye Triangle Agricultural Focus Areas Multi-Sectoral Activity Corridor Agricultural Activity Corridor Recreational Focus Areas (Beach Related) P700 Tourism Focus R66 Tourism Route R66 Extensions King Shaka Tourism Route

2.3.1.5 Mfolozi Integrated Development Plan, 2014/2015 review The main challenges for the Municipality as per the situationalanalysis in this IDP relate to lack and or poor infrastructure services i.e. water, electricity, roads, socio economic spatial and housing issues as well as the issues around social facilities and services. The Municipalities strategic goals to mitigate the above challenges are stated as:               

Promoting good governance and institutional transformation Providing social and economic infrastructure Eradicate basic services backlog water, sanitation, electricity, waste removal Improving quality of life for our citizens Fighting poverty and underdevelopment Promote & Stimulating Economic Growth & Urban renewal Enhancing Revenue and financial viability Promoting safety and security Partnership against HIV and AIDS Enhancing public participation on matters of Government Environment Sustainability Providing sustainable human settlement Industrial regeneration Isithebe Organizational development and capacity building Creating enabling environment for investment and jobcreation

The Mfolozi IDP is currently under review. 47 | P a g e

2.3.2 REGIONAL SOCIAL ENVIRONMENT 2.3.2.1 Settlements 2.3.2.1.1 Urban Settlements

The district has within its boundaries the large industrial towns of Richards Bay and Empangeni, both home to skills and expertise in the mining industry which is just 55 km from the site. The nearest urban settlement within the Mfolozi Municipality is Kwambonambi, 30 km from the Fuleni Anthracite Project area. 2.3.2.1.2 Rural Settlements

The majority of residents in the municipality and at the proposed mine site are scattered rural settlements with low population density and low skill levels. 2.3.2.1.3 Settlement Patterns

As indicated on the map below there is a large amount of vacant land (previously not developed due to a Dept. of Agriculture cattle policy in the ward) where much of the mine is proposed; however, there are a number of households in the immediate vicinity. The population near the proposed mine site also has significantly more females than males possibly due to migrant labour patterns. The topography of North Western Mfolozi has many steep hills and valleys with many sparsely located homesteads and villages. This poses a challenge to service delivery and infrastructure investment. It can be extremely costly and time consuming to deliver basic services to these residents. Mfolozi Municipality is home to the poorest of the poor, which is evident by the fact that about 52 190 of the people within the municipality have no income. The population settlement trend is that people are generally settled in Traditional Authority areas and there is a high level of absentee household members who are migrant workers. A mine in the area would help address this imbalance. The area along the N2 in the Municipality is characterized by commercial agricultural/plantations and small game reserves. 2.3.2.2 Land Use In the municipality as a whole there are six land tenure categories:      

Kwambonambi – proclaimed urban settlement within the centre of the municipality Sobukwe – informal settlement, Privately owned land around Kwambonambi Lake Teza– formal conservation area under Ezemvelo KZN wildlife management The Ingonyama Trust land – east and west of the privately owned land Proclaimed mine lease

48 | P a g e

Figure 10: Mfolozi Local Municipality population density

Figure 11: Mfolozi Local Municipality land use map

49 | P a g e

2.3.2.3 Demographics The Mfolozi Municipality’s population has risen by 13% between the two censuses (2001 & 2011) and now is approximately 122 889 and 25 584 households with an average size of 5 make this up. 47% of these are men (Census, 2011). 22% of households have a member who has temporarily left the municipality for work purposes. Most of the population is exceptionally young with 48% under the age of 19 and 68% under 30. This poses serious challenges for development in the district and for the types of jobs that the mine will be able to offer. Interestingly during the 2005-2011 period where Mfolozi’s population was growing, uThungulu’s population of which Mfolozi is a part was shrinking. In 2009 56% of households were pensioner headed in Mfolozi Municipality. This is up from 22.3% in 2007, a worrying increase. The dependency ratio was above 50% in the settlements near the proposed mining area in Ward 13. 2.3.2.3.1 The Poverty Index

The municipal poverty index found that the households in the north-west corner of the local municipality, adjacent to where the proposed mine is located were the poorest residents of the entire municipality with the least economic activity occurring in this area. 2.3.2.3.2 Languages

The vast majority of residents of the municipality and all residents in the area surrounding the proposed mine site are isiZulu speakers. 2.3.2.3.3 Literacy Rates and Education

Since the municipality has such a young population, education levels are expected to be low. Only 6.77% of adults had some form of tertiary education (Census, 2011), however 87% had received some form of ordinary schooling and only 143 persons had no schooling at all. Literacy rates for the uThungulu District as a whole are at 60%, which is lower than the provincial and national averages. 2.3.2.3.4 HIV/AIDS

The incidence of HIV/Aids in the Mfolozi Municipality has reached its highest level in 2004 (Global Insight) and now sits at approximately 12% of the Mfolozi population. HIV/AIDS affects productivity, dependency ratios and company costs for developers in the area. According to the Municipal IDP “The impact of HIV/Aids is very serious issue and should be incorporated into whatever strategies or developments are undertaken in an area.” 2.3.2.4 Basic Services and Housing 2.3.2.4.1 Community Facilities

GIS data from the Mfolozi Municipal IDP gives us insight into community facilities in the municipality and near the proposed mine site. 50 | P a g e

Table 4: Community facilities Facility Cemeteries

Crèches

Municipal Assessment Lacking in some areas Good access for coastal TA but not for the Mhlana TA Good throughout municipality

Schools

Good throughout municipality

Tribal Courts

Community Halls Clinic Pension Payouts Sports Facilities

Some areas are well served but not all Some gap in the North West areas of the Mhlana TA Good throughout municipality Poor in the North West of the Mhlana TA

Located near Mine 4, but quite a drive for some residents More than 60 minutes from mining area 5 near mining effected communities A primary and high school within mining effected communities Ocilwane Hall within mining effected communities Ocilwane Clinic within mining effected communities 3 within mining effected communities 1 Facility up to 90 minutes from mining effected communities

2.3.2.4.2 Water and Sanitation

uThungulu District Municipality (UDM), in terms of the Water Services Act, is the Water Services Authority in respect of its area of jurisdiction, apart from the City of uMhlathuze. The latest UDM WSDP was completed in 2009. However, it is currently under review. The table below indicates the sources of water within the Mfolozi Municipality it indicates that about 64.7% of the population accesses potable water. Water supply backlogs in 2001 when the District was created stood at 81%. Table 5: Sources of water (Mfolozi Municipality Census 2011) SOURCE Regional Water Scheme (operated by Municipality or other water services provided) Borehole Spring Rain water tank Dam/pool/stagnant water River/stream Water vendor Water tanker Other TOTAL

HOUSEHOLD NUMBERS

%

16 549

64.7%

3 127 298 472 880 1 607 276 1 807 567 25 583

12.2% 1.2% 1.8% 3.4% 6.3% 1.1% 7.1% 2.2% 100%

51 | P a g e

Figure 12: Sanitation types Table 6: Water Supply Backlog in uThungulu District

Municipality

Mfolozi Uthungulu

2009 / 2010 Estimated number of house- holds 20,615 115,046

Households with water 13,087 67,727

Households without water 7,528 47,319

2011/ 2012 % backlog 37 % 41 %

Estimated cost per capita including VAT (Rand) 2,703 5,042

Estimated capital cost including VAT (Rands) 288,737,860 3,335,205,595

Note: Number of households and backlogs based on 2001 Stats and 2009 WSDP. Source: WSDP Review 2011

As evident from the above table, Mfolozi Municipality has a water-provisioning backlog of 37%. Additionally Mfolozi Municipality has a sanitation-provisioning backlog of 49%, which is less than the 55% backlog in the uThungulu District Municipal area. 2.3.2.4.3 Energy

Eskom, the national electricity supplier, supplies electricity in bulk to areas within the Mfolozi Municipal Area. Table 7: Energy for lighting (uThungulu) Energy Source: Lighting Electricity Gas Paraffin Candles Solar Other TOTAL

Census 2001 50.2% 1.1% 1.1% 46.4% 0.5% 0.7% 100.0%

Community Survey 2007 69.8% 0.0% 2.0% 27.7% 0.0% 0.5% 100.0%

52 | P a g e

Between 2001 and 2007, there has been a significant increase in the use of electricity as a source for lighting, i.e. from 50.2% to 69.8%. Further, and not unexpected, there has also been a dramatic decrease in the use of candles for lighting purposes, i.e. from 46.4% in 2001 to 27.7% in 2007. 2.3.2.4.4 Housing Table 8: Formal and Informal Dwellings (2007) Statistical Source Census 2001 Community Survey 2007

% Formal Dwellings 53.6 55.6

% Informal Dwellings 4.6 11.1

The 2011 census survey indicates that 65% of the population of Mfolozi Municipality has access to formal dwelling. The backlog is 27% in terms of access to formal structures.

Figure 13: Type of Dwelling

53 | P a g e

The following table depicts the Mfolozi Housing Project Plan for the proposed mining area: Table 9: Mfolozi Housing Project Plan for Wards affected by proposed mine NUMBER OF HOUSING UNITS

PROJECT PROGRESS

Mvamanzi Rural Housing Project

1000

Stage 01 Approved

Ward 12

Nomuwa/Makhwezini Rural Housing Project

1000

Project Packaging Stage 01

Ward 13

Ocilwane Rural Housing Project

1000

Project Packaging Stage 01

Ward 15

Phathane Rural Housing Projects

1000

DOHS Agreed to fund this from 2012/2013 Financial Year

WARD

PROJECT NAME

Ward 10

BUDGET As per Current Subsidy and or amended as per the applicable annual escalation As per Current Subsidy and or amended as per the applicable annual escalation As per Current Subsidy and or amended as per the applicable annual escalation

2.3.2.4.5 Access to Refuse Disposal Table 10: Refuse Removal Refuse Removal Removed by Local Authority at least once a week Removed by Local Authority less often Communal Refuse Dump Own Refuse Dump No Rubbish Disposal Not Applicable TOTAL

Census 2001 6.80% 2.30% 4.10% 71.00% 15.80% 0.00% 100.00%

Community Survey 2007 7.30% 1.30% 6.60% 76.10% 8.20% 0.60% 100.00%

The percentage of households who have their own refuse dumps have increased from 71% to 76.1% between 2001 and 2007. The uThungulu QOLS provides the following insights into refuse removal in the Mfolozi Municipal area: Table 11: Census 2011 refuse removal for Mfolozi Municipality REFUSE REMOVAL

Census 2011

Removed by local authority/private company once a week

1 837

Removed by local authority/private company less often Communal refuse dump Own refuse dump No rubbish disposal Other Unspecified Not applicable

435 556 20 536 2 068 153 25 585

Source: StatsSA Census 2001 & Community Survey 2007

54 | P a g e

The concerning fact from the above table is the high percentage of households in the Mfolozi Local Municipality (as well as the district) that burn/bury household refuse near their properties or have their own refuse dumps. This would be the case for all the households affected by the mining process. 2.3.2.4.6 Safety and Security

Revived Crime Awareness Campaigns, through the Community Policing Forums with co-operation of the local SAPS and the Regional Security Cluster, are being undertaken. 2.3.2.4.7 Access Roads

There are two main roads servicing the Fuleni Project area:  

National Road N2; and Provincial Road P425.

There are several secondary Provincial Roads that link the N2 and Road P425 to the Fuleni Project site.

Figure 14: Mfolozi Local Municipality Transport Network

55 | P a g e

2.3.2.4.8 Communication (Landline, Mobile, Post Services, E-mail and Internet) Table 12: Household Access to Communication Devices Household Access to Communication Devices Access to Radio Access to Landline Telephone Access to Cellphone Access to Computer Access to Internet

Census 2001 68.70% 7.90% 21.50% 1.80% 0.00%

Community Survey 2007 66.60% 2.90% 71.70% 3.10% 0.90%

2.3.2.5 Economic Profile 2.3.2.5.1 Household Incomes

Other than one small formal town most of Mfolozi Municipality is rural and associated with a lack of development, poverty and poor service provision. The economy of Mfolozi makes up 12% of the economy of uThungulu Mfolozi is the 3rd largest in the district being exceeded by uMhlathuze and Umlalazi. The Table Below indicates that the per capita GVA of the Mfolozi Municipality is the second highest in the district. Table 13: GVA per Capita per municipality, R per person, 2005 values, 2005 to 2010 Year Mfolozi Local Municipality uMhlathuze Local Municipality Ntambanana Local Municipality Umlalazi Local Municipality Mthonjaneni Local Municipality Nkandla Local Municipality Uthungulu Total

2005 14642 40281 8111 9360 10402 3505 19608

2006 15883 40744 8741 10391 10399 3759 20474

2007 17572 41869 9489 11589 10628 4071 21711

2008 19168 41749 10286 12759 10989 4372 22487

2009 19074 37926 10326 12693 10436 4499 21159

2010 19589 39364 10476 13006 10553 4571 21889

Source: Quantec, 2012

Mfolozi municipality is home to the poorest of the poor, which is evident in the average annual household income, which is R4,800 to R9,600 (compared to an average annual household income of R19,200 to R38,400 in the eThekwini Metro). 2.3.2.5.2 Sectors of Employment and Sources of Income

The Gross Value Added or GDP of the economic sectors in Mfolozi LM show that the manufacturing sector is by far the largest and has also increased at the fastest rate (from 26,9% in 1995 to 34,1% in 2010. This can be seen in the table below. The second and third largest sectors in the municipality are transport and the retail, wholesale and trade sectors. The finance and business services sector and the agricultural and forestry sectors follow as the fourth and fifth largest sectors. 56 | P a g e

Table 14: Mfolozi Local Municipality, Gross value added at basic prices, R millions, constant 2005 prices Year 0: Total PA: Agriculture, forestry and fishing [SIC: 1] PB: Mining and quarrying [SIC: 2] SC: Manufacturing [SIC: 3] SD: Electricity, gas and water [SIC: 4] SE: Construction [SIC: 5] TF: Wholesale and retail trade, catering and accommodation [SIC: 6] TG: Transport, storage and communication [SIC: 7] TH: Finance, insurance, real estate and business services [SIC: 8] TI: Community, social and personal services [SIC: 92, 95-6, 99, 0] TJ: General government [SIC: 91, 94]

1995 1061.3 151.1 137.5 285.9 21 48.5 128.5 117.8 102.2 23.6 45.2

2000 1230.8 214.1 242.5 262.1 17.5 31 121.8 119.7 104.5 42.8 74.8

2005 1661.9 222.9 200.2 455 24.8 48.8 212.4 221.4 152.6 47.5 76.4

2010 2373.5 224.2 132.2 808.3 37.4 86.9 348.2 371.5 247.7 43.7 73.3

2.3.2.5.3 GDP per Sector in Mfolozi Table 15: Mbonambi Local Municipality, Gross value added at basic prices, % Compounded Growth over 5 years, 1995 to 2010 Year 0: Total PA: Agriculture, forestry and fishing [SIC: 1] PB: Mining and quarrying [SIC: 2] SC: Manufacturing [SIC: 3] SD: Electricity, gas and water [SIC: 4] SE: Construction [SIC: 5] TF: Wholesale and retail trade, catering and accommodation [SIC: 6] TG: Transport, storage and communication [SIC: 7] TH: Finance, insurance, real estate and business services [SIC: 8] TI: Community, social and personal services [SIC: 92, 95-6, 99, 0] TJ: General government [SIC: 91, 94]

1995 to 2000 3 7.2 12 -1.7 -3.6 -8.6

2000 to 2005 6.2 0.8 -3.8 11.7 7.2 9.5

2005 to 2010 7.4 0.1 -8 12.2 8.5 12.3

-1.1

11.8

10.4

0.3 0.5 12.7 10.6

13.1 7.9 2.1 0.4

10.9 10.2 -1.7 -0.8

Some of the sectors experienced negative growth rates in the 1995 to 2000 period such as manufacturing, electricity and construction. This however changed later so that only the mining sector experienced a decline in the 2000 to 2010 period in the municipality. 2.3.2.5.4 Nature of the Mfolozi Economy

Mfolozi is in close proximity to the City of Richards Bay, which includes an industrial area that consists of heavy industry, shipping and logistics and manufacturing. Richards Bay provides many jobs to residents from nearby municipalities. The levels of unemployment in the district as a whole and in Mfolozi are high and there are very few employment opportunities for locals to work near their homes. The majority of people in the municipality do not have any income and a large portion of those earning enjoy incomes in the range of R800 – R2500 per month. 57 | P a g e

Agricultural Sector: The forestry and timber sectors are currently the major economic sectors in the area. Despite the fact that some areas in Mfolozi have a decent agricultural potential, land in the Ingonyama Trust areas such as where the mine is proposed are not farmed to the extent that they could be. They are mainly used at a subsistence or traditional agricultural level. Agriculture is regarded as a potential growth sector and as a means of alleviating poverty. The lowest earners tend to be involved in agricultural activities. Tourism Sector: Whilst there is no current tourism in the mining area and very little in the local municipality as a whole, there is a lot of potential. With the Hluhluwe-iMfolozi Nature Reserve adjacent to the site and a steady stream of tourists travelling up the N2 the opportunities are vast and need to be explored. Local Business Sector at Mfolozi: There are a few small to medium size businesses operating in the town of Mbonambi. A survey of some of the commercial businesses showed that a substantial number of SMMEs are engaged in the manufacturing sector and in industries such as carpentry, sewing, baking. Transport Sector: The area of Mfolozi is well serviced with the N2 National Road and several primary roads traversing the local municipality. However, the local road network is problematic, the road infrastructure needs to be upgraded and certain roads need to be constructed. The lack of adequate roads also has implications for access to transport, local economic development opportunities, access to education, and the like. The need for new mining roads could greatly improve access to certain rural areas. Mining Developments in the Region: Other than the Somkhele Mine located to the north of the site on the northern bank of the Mfolozi River, there is limited mining nearby. Currently Tronox and Richards Bay Minerals operate dune mining on the coastal strip of the district.

58 | P a g e

2.3.3 LOCAL SOCIAL ENVIRONMENT (COMMUNITY ANALYSIS) 2.3.3.1 Demographics 2.3.3.1.1 Population and Households

The graph below depicts the total population of the surveyed households:

The table and graph below show the number of people per household: Total males:

2175

Total females:

2240

Did not respond:

0

Total Number of Persons:

4415

Average males:

4.0

Average females:

4.1

Average family size:

8.3

Average family size:

8.3

Averagae females:

4.1

Average males:

4.0 0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0

59 | P a g e

The statistics below indicate Household Heads that reside in the house and statistics relating to the period that they have lived there Always lived in this house:

500

88%

NOT always lived in this house:

3

1%

Did not respond:

64

11%

Average period:

31

Years

Longest period:

63

Years

Shortest period:

4

Years

Did not respond:

0

0%

Analysis/interpretation: The average family for this area compares favorably with other similar areas within the province of KwaZulu-Natal. The periods that the household heads have lived in their homes indicates that this is a stable community with a strong family leadership. 2.3.3.1.2 Age of household heads

Average age of the Household Head

0%

10%

20%

30%

40%

50%

60%

0 - 18 19 - 20 21 - 25 26 - 39 40 - 65 66 +

Did not respond:

Average age of the Household Head

0 - 18

3

1%

19 - 20

3

1%

21 - 25

23

4%

26 - 39

100

18%

40 - 65

279

49%

66 +

123

22%

Did not respond:

0

0%

Analysis / Interpretation: The average age of the household heads is a good indication of a normal community. 60 | P a g e

2.3.3.1.3 Marital Status 0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

Marital Status of Households

Married: Co-Habiting: Widow: Divorced: Single with Dependents: Did not respond:

Analysis/interpretation: A marital status of 44% being legally married is good for a peri-rural area. 2.3.3.1.4 Gender Analysis

Gender of total Gender of population household head

0%

10%

20%

30%

40%

50%

60%

70%

80%

Male: Female: Did not respond:

Males: Females: Did not respond:

Analysis / Interpretation: Most of the households are headed by females, while the total population has almost the same number of males and females, although the number of females is marginally higher than that of males. 2.3.3.1.5 Language

The language of the Abathethwa people is "isiZulu", which is part of the Nguni subgroup. Zulu is the most widely spoken language in South Africa, where it is an official language; and notably the main spoken language in the project area. However, some of the people within the Mhlana Traditional Authority area (notably the younger generation who are still schooling or just left school) can also speak other languages like English and Sesotho (by virtue of them being exposed to these languages at school or institutions of higher learning, although their proficiency in these languages is somehow limited.

61 | P a g e

2.3.3.1.6 Qualifications and Literacy 0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

Literacy

Read easily: Read with difficulty: Cannot read: Did not respond:

Analysis / Interpretation: Literacy levels within this community are excellent. 2.3.3.2 Economic Status 2.3.3.2.1 Employment

The graphs below depict the employment levels in the community, as well as the employment types available in the area.

Household Head Employment Status

0%

10%

30%

40%

50%

60%

70%

80%

90%

60%

70%

Employed: Self-Employed: Unemployed: Did not respond:

0% Household Head Employment Type

20%

10%

20%

30%

40%

50%

Informal - Self employed: Informal - Employed by others: Formal - Self-employed: Formal - Employed by others: Employed by Gvt / State: Pensions / Grants: Other: Number of HH with NIL income: Did not respond:

62 | P a g e

Analysis / interpretation: The employment statistics are not encouraging as 81% of household heads are unemployed, with 62% of all households dependent on pensions or government grants for an income. This is indicative of a community that is heavily affected by poverty. 2.3.3.2.2 Household Income and Expenditure

Below are graphs / tables displaying the following:

Monthly Income Statistics

    

Total household income Comment on poverty levels / indigent households Expenditure groups Household Assets Savings

Minimum family Total Income: Maximum family Total Income: Average family Total Income: Average other family members: Average Spouse / Partner:

Monthly Income Statistics

Average HH Head:

R 790.34

Average Spouse / Partner:

R 409.50

Average other family members:

R 380.51

Average family Total Income:

R 1 582.59

Maximum family Total Income:

R 27 000.00

Minimum family Total Income:

R 300.00

Number of Families with NIL income:

116

Did not respond:

0

R 30 000.00

R 25 000.00

R 20 000.00

R 15 000.00

R 10 000.00

R 5 000.00

R 0.00

Average HH Head:

63 | P a g e

Ability to save money

0%

10%

20%

30%

40%

50%

60%

70%

80%

Yes: No: Did not respond:

Analysis / interpretation: The total average household income per month is approximately R 1580, with the maximum possible (combined) income being in the region of R27 000 per month. Of the total 567 households surveyed, 116 do not earn an income at all. This constitutes approximately 20.4% of the households. 2.3.3.2.3 Local Businesses 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0%

Local Business Profile

Informal (Small shops):

84.4%

Larger (Formal shops)

0.3%

Bottle Store / Shebeen:

0.2%

Brick making:

7.0%

Sand mining: Other:

8.2% 0.0%

Analysis / interpretation: Most of the businesses found in the project area are informal, mostly in the transport and retail sectors. Between 80% and 90% of the people are involved (in one way or another) in the informal business practices.

64 | P a g e

2.3.3.3 Agricultural Activities 2.3.3.3.1 Agriculture – Crop farming

Crops most commonly grown

0%

10%

20%

30%

40%

50%

60%

70%

Maize: Sorghum:

Vegetables: Other:

Analysis / interpretation: Just over 60% of the households plant vegetables, and about 40% of the population plant maize. Less than 10% of the households plant sorghum. This shows that communities here are mostly dependent on subsistence crop farming for their livelihood. 2.3.3.3.2 Agriculture – Livestock

The graphs / table below reflect the prevalent situationin terms of agricultural practices with regards the following:    

Livestock Type Number Distance of grazing areas from home

Livestock ownership

Pigs: Chickens: Sheep: Donkeys: Goats: Cattle: 0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

65 | P a g e

Total Livestock Numbers

Distance to grazing (km)

Cattle:

2465

Goats:

3560

Donkeys:

15

Sheep:

81

Chickens:

5282

Pigs:

27

Furthest:

10

km

Closest:

1

km

Average:

7.0

km

Analysis / interpretation: It would appear that most of the families who own livestock are more inclined to goats and chicken farming than any other type of livestock because almost 60% of livestock are goats, while just over 60% are chickens. Just above 50% of livestock are cattle. With regards to distance from home to grazing areas, an average subsistence farmer travels approximately 7 km on a daily basis. 2.3.3.3.3 Agriculture – Hunting

The graphs below present data relating to:   

Hunting Means of hunting Hunting areas

Means of hunting

Family members that partake in hunting activities

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

Do hunt: Do not hunt: Did not respond:

Traps / snares: Firearms: Hunting Sticks: Dogs: 0.0%

10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0%

66 | P a g e

Area's within which hunting takes place

Efuyeni: Egqumeni: Mawuza: Ocilwane Hill: 0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

Analysis / interpretation: Hunting in the area is not a very popular hobby. About 10% of the population does practice hunting, and they mostly use dogs for hunting purposes. The most common hunting area is Mawuza. 2.3.3.3.4 Medicinal Plants

Households that harvest medicinal plants

The graphs below are indicative of households that harvest plants for medicinal purposes, and the areas where these plants are harvested from.

Sometimes: No: Yes:

Location of harvesting

0%

5%

10%

15%

20%

25%

30%

35%

Egqumeni: Mawuza:

Ntuthunga 2: Ocilwane Hill: Bush: Yard: 0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

Analysis / interpretation: About 30% of the population does harvest plants for medicinal purposes, and they mostly do so from their own backyards. This is no surprise as most of the households have a lot of indigenous plants right in their own backyards. Although plant harvesting does take place, it seldom happens in the bush. This is good for the environment, as less harm is being done to the biodiversity.

67 | P a g e

2.3.3.4 Services and Infrastructure 2.3.3.4.1 Water and Sanitation

The graphs below depict the current scenario with respect to water supply type, water source and the type of sanitation system. 0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

Water source

Spring, river or dam: Boreholes: Stand-pipes (Communal) : Tap in yard: Tap in dwelling: Truck: Commute to collect: Did not respond:

Place of water collection

0%

10%

15%

20%

25%

Nkolokotho: Mfolozi River: Mbukwini dam: Supplied by Uthungulu: Did not respond:

0% Type of satitation used

5%

10%

20%

30%

40%

50%

60%

70%

Bush: Pit Latrine: Septic tank - flush: VIP: Flush (Reticulated): Other (Specify): Did not respond:

Analysis / interpretation: While most people (constituting about 40% of the population) have got taps in the yard for water collection purposes, it is quite disturbing to note that about 35% of the population in this area still relies on rivers and dams for water collection purposes. The main source of water from a river is the Nkolokotho River. With regards to sanitation, it is encouraging to note that approximately 60% of the population has proper VIP toilet systems, and that about 10% still rely on ordinary pit latrines. Only a few people/communities still go to the bush to relieve themselves. 68 | P a g e

2.3.3.4.2 Energy

Energy resource for cooking Energy resource for heating

Energy resource for lighting

The graph below shows the various sources of energy that are commonly used by the people in the area. Did not respond: Combinations of above: Candle: Wood: Gas: Paraffin: Electricity: Did not respond: Combinations of above: Dung: Wood: Gas: Paraffin: Electricity: Did not respond: Other: Dung: Wood: Gas: Paraffin: Electricity: 0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

Analysis / interpretation: For cooking, heating and lighting purposes, the majority of the population uses electricity (although it is not clear whether it is a solar generated or Eskom generated electricity). Those that utilize wood, harvest it from the Ezigqulweni forest. 2.3.3.4.3 Health Services 0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

Medical Service Usage

Mobile clinic: Permanent clinic (5km radius): Private Doctor: Hospital: Traditional healer: Other: Did not respond:

69 | P a g e

Distances to a hospital

Furthest distance:

300

Km

Shortest distance:

1

Km

Average distance:

14

Km

Analysis / interpretation: Due to the Ocilwane clinic (which is within a 5 km radius of each of the villages) being the only clinic servicing the four villages in the project area, a mobile clinic seems to be the most likeable alternative as it cuts on the travelling costs for patients. About 60% of the population uses this service. 2.3.3.4.4 Schools

There are a number of schools surrounding the project area, as follows: 

 



Ocilwane: o Elangeni Secondary School: 12 Educators, 451 Learners o Ocilwane Primary School: 11 Educators, 322 Learners Novunula o Novunula Primary School: 6 Educators, 189 Learners Ntuthunga 1 o Ezigqizweni Secondary School: 13 Educators, 335 Learners o Nthuthunga Primary School: 11 Educators, 422 Learners Ntuthunga 2 o Siyokomana Primary School: 13 Educators, 301 Learners

2.3.3.5 Grave Sites Number of grave sites out of 567 households surveyed: A

B

C

D

E

F

Graves in yard

Graves in cemetery

Graves elsewhere

Total responses received

Total not responded

Total No of households in area (D+E)

No

60

311

55

426

141

567

%

10.6%

54.8%

9.7%

75.1%

24.9%

100%

Analysis / interpretation: The majority (about 55%) of the people in these communities use cemeteries to bury their dead. Only a 10.6% of the respondents bury their loved ones in the yard. A minimal 9.7% of the respondents have graves outside of where they live, while 24.9% did not respond. This implies that whether the people bury in the yard or in the cemetery, the impact of any potential relocations (due to mining activities) would still be huge because many individual graves and cemeteries would have to be moved as well.

70 | P a g e

2.3.4 PROJECT AFFECTED PERSONS 2.3.4.1 Ocilwane

Settlement: Ocilwane is situated approximately 36 km north of Kwambonambi, and is the most central village in relation to the proposed mining area. The village is traditionally led by Induna T. Mthethwa of the MhlanaTraditional Authority, and by councilor JM Ndimande of Ward 13 of the Mfolozi Local Municipality (in Kwambonambi). The village constitutes approximately 230 households. The community of Ocilwane has been living in this area since the early eighties, being resettled to this area from the Empangeni area. Schools: There are 2 schools in the area, comprising one primary school (Ocilwane Primary School) with approximately 322 learners and 11 educators and one high school (Elangeni Senior Secondary School) with approximately 451 learners and 12 educators. The high school also accommodates learners from Novunula and Ntuthunga 2 areas. Clinics: The Ocilwane clinic services the area and is located close to the schools. Business: There are small-scale businesses found in the area, mostly in the retail and transport sectors. Places of worship: There also are a handful of Churches in the area, with most community members following the Nazareth Baptist Church, while a small minority belongs to traditional western churches such as the Catholic, Methodist and Anglican churches. Burial groups: There is no formal communal graveyard within the Ocilwane community. People opt to bury their loved ones within the yard or specific sacred area on the property. 71 | P a g e

Agriculture: Ocilwane practices livestock farming with many households having a livestock kraal within the yard. Grazing takes place to the north-west of the village. There are arable fields towards the Mfolozi River, but there are a number of vegetable gardening taking place next to houses and their yards. 2.3.4.2 Novunula

Settlement: The village of Novunula is situated approximately 38 km north of Kwambonambi. The HiP borders the village to the west, and the Mfolozi River border the village to the north. The village is led by Induna M. Mdletshe (a member of the Mhlana Traditional Authority council), and by councilor J.M. Ndimande of Ward 13 of the Mfolozi Local Municipality. There are approximately 186 households in the village. The community of Novunula has been living in this area since the early 19th century. Schools: There is only one primaryschool (Novunula Primary School) with approximately 189 learners and 6 educators in the area. For high school education, learners have to attend either the Ntuthunga 1 (15 km away) or Ocilwane High Schools (4 km away). Clinics: There is no clinic in the village. The Ocilwane clinic is servicing the area of Novunula. Business: Like in all the other villages in the rural areas of KwaZulu-Natal, there are small-scale businesses found in the area, mostly in the retail and transport sectors. 72 | P a g e

Places of worship: The majority of the residents here are followers of the Nazareth Baptist Church (commonly known as Shembe), and they attend their worship services mostly on Saturdays. Their places of worship are clearly marked with white stones arranged in a circular manner in the open veld. There are however a few other places of worship such as the traditional western churches like the Catholic, Methodist and Anglican churches. Burial grounds: Novunula have one (1) community graveyard to the north-east of the village, families also bury their deceased inside their yards. Agriculture: Novunula primarily practice livestock farming with only a very few arable plots along the tributaries of the Mfolozi River. Rivers are utilized for livestock watering. 2.3.4.3 Ntuthunga 1

Settlement: The village of Ntuthunga 1 is situated approximately 34 km west of Kwambonambi. The village (which is one of the areas that will be directly affected by the proposed Fuleni mine) is situated in the southern part of the proposed mining area; and is led by Induna B.M. Mthethwa (a member of the Mhlana Traditional Authority council), and by councilor Ndimande of Ward 13 of the Mfolozi Local Municipality (a member of council and ward councilor under Mfolozi Local Municipality, in Kwambonambi). There are approximately 314 households in the area. The community of Ntuthunga 1 has been living in this area since the early sixties. 73 | P a g e

Schools: There are 2 schools in the area, comprising one primary school (Nthuthunga Primary School) with approximately 422 learners and 11 educators and one high school (Ezigqizweni High School) with approximately 335 learners and 13 educators. Clinics: There is no clinic in the area, but the community is serviced by a Mobile Clinic unit or they have the option to commute to Ocilwane clinic for health purposes. Business: There are small-scale businesses found in the area, mostly in the retail and transport sectors. Places of worship: There are also a handful of Churches in the area, with most community members following the Nazareth Baptist Church (Shembe), while a small minority belongs to traditional western churches such as the Catholic, Methodist and Anglican churches. Burial grounds: Ntuthunga 1 have three (3) community graveyards to the north, east and south-west of the village, families also bury their deceased inside their yards. Agriculture: Ntuthunga 1 primarily practice livestock farming with only a very few arable plots along the tributaries of the Ntutunga River. A livestock watering dam is located to the north-west of the village, capturing water from a tributary of the Ntutunga River. 2.3.4.4 Ntuthunga 2

74 | P a g e

Settlement: The village of Ntuthunga 2 is situated approximately 36 km west of Kwambonambi and about 2 km north of Ntuthunga 1. Similar to all villages in KwaZulu-Natal in general, and to Ntuthunga 1 in particular, the village is traditionally led by Induna N. Mthethwa (a member of the MhlanaTraditional Authority council), and by councilor JM Ndimande of Ward 13 of the Mfolozi Local Municipality (in Kwambonambi). There are approximately 255 households in the area. Similar to Ntuthunga 1, the community of Ntuthunga 2 has been living in this area since the early sixties. Schools: There is only one primary school (Siyokomana Primary School) with approximately 301 learners and 13 educators servicing the area. For high school education, learners from this area have to attend school either in Ntuthunga 1 (2 km away) or in Ocilwane (12 km away), as these are the only villages in the area that have high schools. Clinics: There is no clinic in the area, but the community is serviced by a Mobile Clinic unit or they have the option to use the Ocilwane clinic for their health requirements. Business: Similar to other areas, there are a few small-scale businesses found in the area, mostly in the retail and transport sectors. Places of worship: There are a handful of places of worshiplike the Nazareth Baptist Church, and other traditional western churches such as the Catholic, Methodist and Anglican churches in the area. Burial grounds: Ntuthunga 2 have a formal community graveyard to the north of the village, families also bury their deceased inside their yards. Agriculture: Ntuthunga 2 primarily practice livestock farming with a few arable / vegetable gardens either inside or next to their yard or towards the Ntutunga River.

75 | P a g e

2.4

BIOPHYSICAL ENVIRONMENT

2.4.1 LANDSCAPE The MRA area is characterised by rolling and undulating hills interspersed by wide, low valleys, including level areas such as associated with the Mfolozi River in the northeast of the mining footprint area (Figure 15).

Figure 15: Topography of the area

When viewed in its totality, the landscape associated with the MRA area and its surroundings exhibits a common, discernible pattern, is considered to have broadly similar landform, soil, vegetation and settlement configurations, and thus is considered to comprise a single landscape character type. This landscape character type thus includes both natural areas and settlements and can be described as traditional, rural, undulating woodland. The highest points in and around the MRA area include peaks at around 350m, while the lower portions of the areas are between 0 to 5m above sea level. Higher run-offs can be expected from the mountainous areas than from the drier plains. The mountain flanks are characterized by numerous incised streams. The general elevation in the region of the proposed development is shown in Figure 17.

76 | P a g e

Figure 16: Landscape character within the MRA and surrounds

Figure 17: Topography of Fuleni Anthracite Project MRA area

77 | P a g e

2.4.2 CLIMATIC DATA 2.4.2.1 Climate zone 2.4.2.1.1 Mfolozi WMA

The Mfolozi secondary catchment area is characterized by Warm-temperate climate conditions as classified by the 2012 CSIR Köppen-Geiger map for South Africa (Conradie and Kumirai, 2012). The climate for the region varies from warm summers with dry winters (Cwa&Cwb) in the north west of the catchment area near the towns of Vryheid and Emondlo; to warm and humid conditions (Cfb) near the middle of the catchment area; to hot and humid conditions (Cfa) towards the mid to lower parts of the catchment area in the south east near the site as shown in Figure 18 below.

Figure 18: Mfolozi Basin Climate Classification

2.4.2.1.2 Local catchment in relation to MRA area

Based on the Köppen-Geiger classification for South Africa (Conradie and Kumirai, 2012), the mining area is located in the climatic zone designated as ‘Warm Temperate Hot Dry Summer’ (Csa), shown in Figure 19. This climate is characterized by relatively high temperatures and evenly distributed precipitation throughout the year. In summer, these regions are largely under the influence of moist, maritime airflow from the western side of the subtropical anti-cyclonic cells over low-latitude ocean waters. Temperatures are high and can lead to warm, oppressive nights. Summers are usually somewhat wetter than winters, 78 | P a g e

with much of the rainfall coming from convectional thunderstorm activity; tropical cyclones also enhance warm-season rainfall in some regions. The coldest month is usually quite mild, although frosts are not uncommon, and winter precipitation is derived primarily from frontal cyclones along the polar front. The warmest and wettest months, on average, are between December and March and the coolest and driest months, on average, are between May and August.

Figure 19: Koppen Climate Classification

2.4.2.2 Temperature 2.4.2.2.1 Mfolozi WMA

The Department of Agriculture’s “Agricultural Geo-referenced Information System” (AGIS) hosts a wide spectrum of spatial information maps for public use. Figure 20 and Figure 21 indicate the maximum and minimum annual temperature for the region that was obtained from their natural resources atlas on climate. Mean minimum temperatures for the region ranges from 0°C to more than 8°C and the mean maximum temperatures ranges from 25°C to 33°C with some parts even reaching a mean maximum of 35°C. 2.4.2.2.2 Local catchment in relation to MRA area

The mean maximum temperatures ranges from 29°C to 33°C and the mean minimum temperatures for the site are more than 8°C as shown in Figure 22 and Figure 23 respectively. 79 | P a g e

Figure 20: Mean Annual Maximum Temperature

Figure 21: Mean Annual Minimum Temperature

80 | P a g e

Figure 22: Mean Annual Maximum Temperature of Fuleni Anthracite Project MRA area

Figure 23: Mean Annual Minimum Temperature of Fuleni Anthracite Project MRA area

81 | P a g e

2.4.2.3 Winds The meteorological data was gathered from the South African Weather Services’ Riverview Station (28°26’39.12’’S; 32°10’54.84’’E). The station recorded hourly data for the following parameters from 2010 to the end of 2012. Figure 24 illustrate the series of annual and seasonal wind roses (2010-2012) that was recorded at the SAWS Riverview station. The percentage of calm conditions recorded at the station is low (19.9%), indicating that the annual wind speed at the site is substantial (2.15 m/s). The dominant wind direction through the year blows from two directions, majority from the north north-east (17%) and from the southwest (13%). The strongest winds also blow from the south-west. The wind patterns from 2010 to 2012 do not change and the same is the case for the seasonal wind pattern. 2.4.2.3.1 Atmospheric Stability

Atmospheric stability is commonly categorised into six stability classes these are briefly described in the table in Figure 25. The atmospheric boundary layer is usually unstable during the day due to turbulence caused by the sun's heating effect on the earth's surface. The depth of this mixing layer depends mainly on the amount of solar radiation, increasing in size gradually from sunrise to reach a maximum at about 5-6 hours after sunrise. The degree of thermal turbulence is increased on clear warm days with light winds. During the night-time a stable layer, with limited vertical mixing, exists. During windy and/or cloudy conditions, the atmosphere is normally neutral. Based on the graphs presented in Figure 25 it can be seen that the region is subject to high winds (blowing from the south-west) and day and night-time cloud formations, these conditions (Class D) is classified as Neutral conditions and occurs for 27.4% (2010-2012). The second highest stability class for the region is Unstable conditions, where the wind speeds are lower (moderate wind speed blowing from the north-east) overcast conditions occur during the daytime, this occurs only for 12.5% (2010-2012).

82 | P a g e

Figure 24: Riverview wind roses

83 | P a g e

Figure 25: Atmospheric stability classes

2.4.2.4 Mean Annual Precipitation (MAP) and Mean Monthly Rainfall 2.4.2.4.1 Mfolozi WMA

The average MAP for the whole of the Mfolozi River basin is 803 mm/annum with a maximum value of 1 055 mm/annum in the mountainous area (upstream quaternary catchment W22E) and a minimum value of 708 mm/annum (inland quaternary catchment W21F, some 40 km south of Vryheid) (Middleton and Bailey, 2009). The general trend is that the rainfall decreases moving inland, with some high-lying areas receiving more rainfall. Rainfall distributions are influenced by the topographic features in the area. The precipitation range is shown in Figure 26. Note that the region is also within the impact zone of tropical cyclones occurring in the Indian Ocean which may cause high-intensity rainfalls leading to peak runoff events. The most notable of these was the cyclone Domoina of January/February 1984, the only known cyclone to date which penetrated inland and caused extreme rainfall (up to 924 mm in the upper Black Mfolozi River, DWA 1985) with resultant severe flooding. 84 | P a g e

Figure 26: Mean Annual Precipitation

2.4.2.4.2 Local catchment in relation to MRA area

The Fuleni Anthracite Project is located within quaternary catchment W23A, as defined in the WR2005 Study (Middleton and Bailey, 2009). The project falls within a hot and humid climatic zone with a mean annual precipitation (MAP) for the quaternary catchment W23A of 833mm. The MAP range is shown in Figure 27. The quaternary catchment is located in Rainfall Zone W2F. The mean monthly precipitation values are given in Table 16. The maximum monthly rainfall of 12.82% occurs in February and the lowest of 3.71% in August. The monthly distribution pattern of rainfall in the quaternary catchment is shown in Figure 28. Table 16: Mean Monthly Rainfall Distribution of Site Rainfall (Zone W2F) Mean Monthly Precipitation (% Distribution)

Rainfall Zone

OCT

NOV

DEC

JAN

FEB

MAR

APR

MAY

JUN

JUL

AUG

SEP

W2F

9.24

10.41

10.44

11.96

12.82

12.61

7.25

5.64

4.43

4.16

3.71

6.50

(Source: Middleton, B.J. and A.K. Bailey (2009). Water Resources of South Africa, 2005 Study.WRC Rep No TT381. Pretoria)

85 | P a g e

Figure 27: Mean Annual Precipitation of Fuleni Anthracite Project MRA area

Mean Monthly Precipitation (% Distribution) 14.00 12.00 10.00 8.00 6.00 4.00 2.00 0.00 OCT

NOV

DEC

JAN

FEB

MAR

APR

MAY

JUN

JUL

AUG

SEP

Mean Monthly Precipitation (% Distribution) Figure 28: Mean Monthly Precipitation as a % of the distribution

The absolute monthly rainfall (% distribution x MAP) of the quaternary catchment is shown in Table 17. The average rainfall for the catchment was determined and the maximum rainfall of 107mm occurs in February and the lowest of 31mm in August. The data in the table is shown in the bar chart below (Figure 29). Table 17: Mean Monthly Quaternary Rainfall (mm) Quaternary Catchment

Mean Annual Precipitation (mm)

Rainfall Zone

OCT

NOV

DEC

JAN

FEB

MAR

APR

MAY

JUN

JUL

AUG

SEP

W23A

833

W2F

77

87

87

100

107

105

60

47

37

35

31

54

Mean Monthly Precipitation (mm)

(Source: Middleton, B.J. and A.K. Bailey (2009). Water Resources of South Africa, 2005 Study.WRC Rep No TT381. Pretoria)

86 | P a g e

Mean Monthly Precipitation (mm) 150 100 50 0 OCT

NOV

DEC

JAN

FEB

MAR

APR

MAY

JUN

JUL

AUG

SEP

Mean Monthly Precipitation (mm) Figure 29: Mean Monthly Precipitation in mm

2.4.2.5 Mean Annual Runoff and Evaporation 2.4.2.5.1 Mfolozi WMA

The naturalized runoff in the Mfolozi River at the outlet of quaternary catchment W23A which is located just downstream of the site, have been compiled from data in WR2005 and the resultant MAR is 794 million m3/a as shown in Table 18. The naturalized unit runoff based on the net catchment area of 9 254 km2 at the outlet of quaternary catchment area W23A amounts to 85.8 mm. Note that this unit runoff for the Mfolozi River is based on naturalised conditions, i.e. it excludes any abstractions or other water uses, i.e. by afforestation. Table 18: Mfolozi River Naturalised Runoff Quaternary Catchment W21A W21B W21C W21D W21E W21F W21G W21H W21J W21K W21L W22A W22B W22C W22D W22E W22F W22G W22H W22J W22K W22L W23A Total Net Catchment 2 Area (km )

Net Catchment 2 Area (km ) 340 580 370 469 416 243 563 433 530 797 533 239 332 186 197 385 312 249 306 605 476 279 414

Lower Mfolozi

9 254

Total MAR (million m /a)

River(s)

White Mfolozi

Black Mfolozi

3

Naturalized MAR 3 (million m /a) 34.51 42.60 22.63 28.30 26.62 12.68 33.52 32.05 47.01 75.33 49.45 39.45 32.92 17.72 12.01 69.05 21.42 23.19 24.93 44.44 42.26 24.71 37.20

Naturalized MAR (mm/a) 101.48 73.45 61.16 60.34 63.99 52.17 59.54 74.02 88.71 94.52 92.78 165.06 99.15 95.24 60.97 179.35 68.64 93.12 81.46 73.45 88.78 88.58 89.85

794.0

-

87 | P a g e

Mean Annual Evaporation (MAE) varies from 1 400 mm/a for quaternaries W21L and W23A which are closest to the coast, to 1 500 mm/a for the mountainous areas. Except for quaternary catchment 23A which is in Evaporation Zone 22C, the upstream catchments are all within evaporation Zone 22B. The monthly evaporation pattern (as percentages of the total) is given in Table 19 below. The range of MAE is also shown in Figure 30. Table 19: Monthly Evaporation Distribution (Symons Pan) Month Evaporation (%) October 10.66 November 9.75 December 10.78 January 10.63 February 8.84 March 8.76 April 6.67 May 6.03 June 5.16 July 5.63 August 7.90 September 9.19 Source: WR90, evaporation zone 22B, based on data from the Vryheid station

Figure 30: Mean Annual Evaporation

88 | P a g e

2.4.2.5.2 Local catchment in relation to MRA area

The catchment hydrological data of this summer rainfall region are summarized in Table 20 below. Runoff data were generated on a quaternary catchment area scale in the WRSM2000 model, an enhanced version of the original Pitman rainfall-runoff model, since there are no reliable long term measured flow data. Note that the present MAR in the Mfolozi River is not reflected in the table since it shows the naturalized runoff generated within the catchment. To obtain the present runoff, all surface water uses in the catchment area must be subtracted. Table 20: Catchment Data (from WR2005)

Quaternary catchment

Net area 2 (km ) A

Mean Annual Precipitation (mm) MAP

Mean Annual Runoff (mm) MAR

Mean Annual (gross) Evaporation (mm) MAE (Zone 1B)

Irrigation area (ha)

Forest area (ha)

W23A

414

833

89.85

1400

0

0

The mean monthly naturalized runoff data for the catchment W23A, is shown in Table 21. Mean Annual Evaporation (MAE) for the MRA area varies between 1300mm and 1400mm. The monthly evaporation pattern (as percentages of the total) is given in

Table 22. Table 21: Simulated Average Naturalized Monthly Runoff for Quaternary Catchment W23A

Quaternary Catchment

Area (km2)

W23A

414

Mean Monthly Natural Runoff (mm) OCT

NOV

DEC

JAN

FEB

MAR

APR

MAY

JUN

JUL

AUG

SEP

Mean Annual Natural Runoff (mm)

6.81

5.75

4.75

5.98

10.39

13.03

9.07

7.32

6.20

7.15

5.12

8.28

89.85

Table 22: Monthly Evaporation Distribution (Symons Pan) Month November December January February March April May June July August September October

Evaporation (%) 10.24 11.71 12.46 10.73 10.13 7.12 5.63 4.40 4.67 6.10 7.59 9.22

Source: WR90, evaporation zone 22C, based on data from the Charters Creek station

89 | P a g e

2.4.3 SOILS 2.4.3.1 Soil Form and Morphological Features Figure 31 illustrates the major soil forms found in the surveyed area. The following soil forms were identified: 









The Arcadia soil form (Ar) comprises a vertic A-horizon that overlies unspecified material. The vertic A-horizon has strongly developed structure and exhibits clearly visible, regularly occurring slickensides in some part of the horizon or in the transition to an underlying layer. The horizon has a high clay content, is dominated by smectite clay minerals and possess the capacity to swell and shrink markedly in response to moisture changes. Swell-shrink potential is manifested typically by the formation of conspicuous vertical cracks in the dry state and the presence, at some depth, of slickensides (polished or grooved glide planes produced by internal movement). The lower lying (adjacent stream flow channels and preferential water flow channels) soils of the Arcadia soil are deep (in many cases more than two meters deep) and underlain by saprolitic material that is derived from what seems to be dolerite and sandstone. In the higher lying areas these soils overlie hard rock and ranges in depth from 25 cm to 50 cm. Note: Where the soil form is indicated with Ar on the soil map, the soil is deeper than 50 cm and where the soil is grouped with shallower soils, for instance Gs/Ar which indicates an area where a Glenrosa and Arcadia soil form complex are encountered, the Arcadia soil is shallower than 50 cm. The Glenrosa soil form (Gs) comprises an orthic A-horizon overlying a lithocutanic B-horizon. The lithocutanic B-horizon is a pedologically young horizon where clay illuviation has occurred. Soil depth ranges from 10 to 50 cm. In many cases the A-horizon of the Glenrosa soil form exhibits blocky structure, but no slickensides, pressure faces or cracking as is associated with the vertic Ahorizon. It is possible that these soils will, over hundreds or thousands of years, weather to become soils of the Arcadia soil form. The Mispah soil form (Ms) comprises an orthic A-horizon that overlies hard rock. These soils are mostly found between rock outcrops and soils of the Glenrosa soil form. Note: The soils of the Mispah soil form are grouped with sois of the Glenrosa soils form (Ms/Gs) and rock outcrops (R/Ms or R/Gs/Ms) on the soil map because no clear pattern in the occurrence of these soils where noticed. These areas are shallow and sometimes described as soil/rock complexes. The Clovelly soil form (Cv) comprises an orthic A-horizon that overlies a yellow brown apedal Bhorizon and unspecified material. The yellow brown apedal B-horizon has macroscopically weakly developed structure or is altogether without structure and reflects weathering under well drained, oxidised conditions. The clay fraction is dominated by non-swelling 1:1 clay minerals. The yellow colour that is encountered in these soils is attributed to Al substituted goethite dominating the iron oxide fraction. These soils range in depth from 60 to 150 cm. The soils marked Cv on the soil map are deeper and exhibits crusting on the soil surface. This area is extremely hard and water infiltration is slow. These soils are situated towards the Mfolozi River and the influence of windblown or washed in sand is evident. The Tukulu soil form (Tu) comprises an orthic A-horizon that overlies a neocutanic B-horizon and a horizon that exhibits signs of wetness. The neocutanic B-horizon is characterised by colour variation due to clay movement and accumulation and exhibits an apedal or weakly developed structure. Unspecified material with signs of wetness is a lower profile horizon that has suffered the effects of 90 | P a g e

 

intermittent or prolonged saturation with water. Signs of wetness are ascribed to conditions of reduction that leads to iron movement. Iron mobilises, moving from areas of reduction to precipitate in pockets that exhibit a higher state of oxidation. This leads to a bleached colouration in the soil matrix which is referred to as signs of wetness. The soils of the area are very sandy in nature and the accumulation of Fe at a depth of approximately 60 cm is diffuse in nature. This is typical of low clay content soils. A case can be made for rather classifying these soils as that of the Pinedine soil form (orthic A/yellow brown apedal B/unspecified material with signs of wetness) as the colour variation is not pronounce. It was decided the Tukulu soil form communicates the essence of these soils more clearly as these soils exhibit more pronounce colour variation and clay illuviation than any of the other soils encountered on the site. These soils border the floodplain of the Mfolozi River and are therefore pedologically younger soils. It is very possible that material will be deposited onto these soils when the Mfolozi River is in flood. In fact, sandy material has been deposited onto the Arcadia soil forms found just north of these soils. The Oakleaf soil form (Oa) comprises an orthic A-horizon that overlies a neocutanic B-horizon and unspecified material. These soils are encountered towards the Mfolozi River in the less steep areas. The Dundee soil form (Du) comprises an orthic A-horizon that overlies stratified alluvium. The latter horizon shows stratification which is the result of alluvial or colluvial deposition. In the case of the mining and infrastructure footprint area, these soils fall in the floodplain of the Mfolozi River. Note: The material found adjacent and in the Mfolozi River is marked alluvial sand owing to an orthic A-hirozon not being present.

2.4.3.2 Soil Fertility Status The soils of the area predominantly show alkaline or near neutral pH values. This is to be expected in an area where dolerite is the dominant parent material. Especially the vertic A-horizon is known to exhibit slightly alkaline pH values and contains, in many (also in the investigated area) limestone nodules. The phosphate for all the soil form is low and should be in the order of 20 mg/kg (Bray 1) for adequate crop nutrition. The phosphate values are even low in the Tukulu soil form which are used for vegetable production and should have been fertilised - the vegetable garden is sponsored by the Department of Agriculture. The cation exchange capacity (CEC) of the Tukulu soil form is, however, high enough for adequate nutrient retention. As expected, the Arcadia soil form exhibits the highest CEC while the more sandy soils exhibit relatively low CEC values. Organic matter content is low in all the soils, except the Arcadia soil form. Of concern is the extremely high Cl level in soil samples taken from an Arcadia soil which occurs in one of the stream flow channels. In fact, elevated levels of Cl are found in all soil samples and may be owing to mist or wind being blown in from the sea – although the ocean is quite some distance from the site. Adequate levels of K and Ca are encountered in most soil samples. Any deficiencies in soil fertility status can easily be rectified through the application of soil ameliorants. The more important factor to consider is therefore the soil salinity status.

91 | P a g e

Figure 31: Major soil forms of the Fuleni Anthracite Project area

2.4.3.3 Soil Salinity Status The presence of excessive amounts of exchangeable sodium and magnesium reverses the process of aggregation and causes soil aggregates to disperse into individual soil particles. Soils with an exchangeable sodium percentage (ESP) of approximately six and higher is regarded as sodic soils. The Oakleaf soil form falls into this category. Although samples of the crusted Clovelly soil form were not collected it can be assumed that this soil would also exhibit high levels of exchangeable Na, thus leading to soil particle dispersion and crusting. The sodium adsorption ration (SAR) is the ratio of sodium to calcium and magnesium. Sodium can lead to soil dispersion and this hampers water infiltration. Internationally, a SAR value of six is accepted as a level above which soil permeability and structural stability may be negatively affected. Some researchers, however, suggest that soil dispersion may occur at levels as low as three. The effects of high SAR values are more dramatic at low electrical conductivity (EC) levels and one method of overcoming the detrimental effects of high SAR is to increase the EC of the soil solution. This can be achieved by either adding gypsum or lime. The level at which the increasing EC nullifies the SAR is called the threshold electrolyte concentration. The SAR values for the soils are relatively low, with the values calculated for one of the Arcadia soil forms (taken from an area near the Ntuntuga River) and the subsoil of the Oakleaf soil form being the exception. The SAR values for all these samples are high. It would therefore seem that the soils of the Oakleaf soil form and at least some of the soils of the Arcadia soil form are sodic in nature 92 | P a g e

2.4.3.4 Pedohydrology Figure 32 show the soils which exhibit hydromorphic characteristics. The soils of the surveyed area, specifically the soils of the Mispah, Glenrosa, shallow Arcadia, crusted and shallow Clovelly soil forms and the soil rock complexes, are mainly discharge soils. Meaning that these contribute minimally, if at all, to underground aquifers which might be located in the phreatic zone. These soils are mainly associated with the higher lying areas, with the exception of the Clovelly soils, and steep slopes. After a rainfall event, water infiltration in the vertic A-horizon will be very high. Water will rush into the cracks encountered on the surface of these soils at a rate that could be as high as 10 m/day (measured as saturated hydraulic conductivity). As soon as the soils become moist, the smectite clay minerals will start to swell and the cracks will close. In the moist and wet state these soils exhibit a very low infiltration capacity and a saturated hydraulic conductivity that may be as low as a few mm/day. In this state water rushes from the soil surface as surface runoff. The soil specialist concluded that surface run-off, especially during high intensity rainfall events in the case of the Mispah/Glenrosa soils and during both high and low intensity rainfall events for the shallow Arcadia soils, is the dominant mechanism of water flow in this area. Thus, surface runoff from the soils of the Arcadia soil form, as well as the Mispah, Glenrosa and shallow Clovelly soil form remain the main contributor to water in the ephemeral streams and the more significant rivers such as the Mfolozi. The surface runoff water follows the path of least resistance towards lower lying areas. These are areas where the landscape converge. Erosion resulted in the formation of many of the ephemeral stream flow channels encountered on site and the lateral and proximal headcuts which are located in the headwaters of the ephemeral water courses keep eating away at the landscape. The higher lying soils are very susceptible to erosion for the following reasons:  The soil exhibit a high Na content which leads to the dispersion of both 2:1 and 1:1 clay mineral phases;  The soils of the Arcadia soil form exhibit strongly developed structured and are, in most cases, situated in areas of steep slope.  The soils exhibit, in certain areas, a low organic C content and a high clay and silt content;  The volume and velocity of surface runoff are high in the area. The high run-off rates of the area is the reason that only the soils close to the Mfolozi river exhibit hydromorphic characteristics (Figure 32). These soils are situated in lower lying areas where water can accumulate. Seasonal to permanent water tables are not encountered in the higher lying soils, including the soils of the numerous ephemeral stream flow channels. Temporary wetland plant species were identified in the lower lying watercourses by the biodiversity specialists, although these show no signs of hydromorphism. Apart from the presence of riparian habitat that may or may not be present, no delineation criteria or guidelines currently exists to demarcate watercourses that are regarded as natural channels with regular or intermittent flow that lack wetland indicators. These drainage lines can be indistinct in nature and commonly represent the origins of the drainage network. Headwater drainage lines that only carry storm flow are ephemeral in nature and form part of first-order and even second-order streams of rivers, located at the source of drainage line networks. These drainage 93 | P a g e

lines are never or very seldom in connection with the zone of saturation and they consequently never have base flow and are unlikely to support wetland conditions (DWAF 2005). The Practical Field Procedure for Delineation of Wetlands and Riparian Areas document describes A section headwater channels as (DWAF 2005): “…headward channels that are situated well above the zone of saturation at its highest level and because the channel bed is never in contact with the zone of saturation, these channels do not carry baseflow. They do however carry storm runoff during fairly high rainfall events but the flow is of short duration because there is no baseflow component. The A sections are the least sensitive watercourses in terms of impacts on water yield from the catchment. They are situated in the unsaturated zone and in this respect their position in the landscape is little different from non-riparian hillslope positions." It can be argued that these drainage lines or watercourses should still be regarded as important landscape features based on international literature:  The role and functions of headwater streams within catchments and their linkages with downstream aquatic systems are not thoroughly understood (Gomi et al., 2002). Recent research, however, ascribes increasing importance to these systems regarding catchment and water resource management (Berner et al., 2008).  Headwater drainage lines are crucial systems for nutrient dynamics as a link between hillslopes and downstream watercourses (Gomi et al., 2002).  They are directly linked to downstream aquatic systems and have a direct bearing on the health and functioning of larger aquatic systems, especially regarding water quality of downstream aquatic systems (Gomi et al., 2002; Dodds and Oaks, 2008).  Seasonal streams and wetlands are usually linked to the larger network through groundwater even when they have no visible overland connections.  The large spatial extent of headwater channels in the total catchment area make these systems important sources of sediment, water, nutrients and organic matter for downstream systems (Gomi et al., 2002). The more sandy soils found towards the Mfolzi River act as conduit for water flow when water flow is saturated. Water will infiltrate these soils at a relatively high rate and may even contribute to a water table. The water table may be found not to be very deep close to the Mfolozi River. These soils are recharge soils and could feed into an underground water table, as well as the Mfolozi River. These soils are not conducive to the unsaturated flow of water and exhibits a poor water holding capacity.

94 | P a g e

Figure 32: Soils indicating hydromorphic characteristics

2.4.4 LAND CAPABILITY AND LAND USE 2.4.4.1 Agricultural Potential linked to Land Capability Table 23 summarises the land capability of each major soil group, as well as the area that each group comprises. The land capability is illustrated in Figure 33. The only high potential arable land is that of the Tukulu soil form. These soils are deep and although sandy, exhibit a fluctuating water table at a depth of approximately 60 cm. The latter is ideal for vegetable production. The area marked high potential arable land on the map in Figure 33 was, at the time of the site visit, under cultivation. Figure 34 shows the current land use. Figure 35 illustrates the sensitive areas of the site. The map, however, pertains to crop production only.

95 | P a g e

Table 23: Total hectares that each of the soil forms encountered in the study area comprise Abbreviation

Soil form

Area (Ha)

Land Capability

Land Use

Alluvial Sand

Alluvial Sand

64.06905

Riparian

Grazing

Du

Dundee

12.045746

Tu

Tukulu

3.866707

*Ar

Arcadia*

689.178686

Wetland Arable (high potential) Grazing

Wetland/Grazing Vegetable production Grazing

Gs

Glenrosa

96.518607

Grazing

Grazing

Cv (Crusted)

Clovelly (crusted)

29.090275

Grazing

Oa

Oaklands

18.991948

Grazing Arable (medium potential)

56.63111

Grazing

Grazing

182.046474

Grazing

Grazing

Maize/Grazing

Ms / Gs

Glenrosa/shallow Clovelly complex Mispah/Glenrosa complex

Cv (Shallow)

Shallow Clovelly

8.000296

Grazing

Grazing

R / Ms

Rock/Mispah complex

10.04558

Grazing

Cv

Clovelly

23.014784

Ar (Shallow)

Shallow Arcadia Rock/Mispah?Glenrosa complex Mispah/Glenrosa/shallow Arcadia complex

12.135248 488.482141

Grazing Arable (medium potential) Grazing Grazing

Grazing

Grazing

Grazing

Grazing

Grazing

Grazing

Grazing

Gs / Cv (Shallow)

R / Ms / Gs Ms / Gs / Ar (Shallow) Gs / Ar (Shallow)

Glenrosa/shallow Arcadia

Soil Rock Complex

Soil Rock Complex

1271.70282 374.77902 2.139553

Maize/Grazing Grazing

* Associated with stream flow channels (watercourses), but does not exhibit hydromorphic characteristics.

Many attempts have been made to establish crops in other areas and relics of cultivated land are encountered in the areas marked Clovelly (crusted), Oakleaf, Clovelly and Arcadia soil forms on the soil map. Figure 34 illustrate these areas. In the case of the Arcadia soil form, for instance, cultivation was attempted near the western border of the surveyed area, close to the Ntutunga River. These areas are deemed to be of low agricultural potential. The soil is high in clay content and swells when wet, but cracks when dry. Root pruning is therefore a problem, as is the high levels of Cl and Na in the soil samples taken from the area where cultivation was attempted. The crusting encountered on some of the soils of the Clovelly soil forms will hamper root development and inhibits water infiltration. Water ponds on the surface of these soils while the subsoil is dry. Soils of the Oakleaf soil form exhibits near sodic characteristics and the soils of the Clovelly soil which does not exhibit crusting are very sandy, exhibits a poor nutrient holding capacity and shows no sign of a fluctuating water table within the top 150 cm. These soils area at best of medium potential arable land. The majority of the area therefore represent grazing land and is currently used as such. The only soils that exhibit so-called hydromorphic characteristics are that of the Dundee soil form and the alluvial sand found in the Mfolozi River. Many stream flow channels were encountered on site, but these are all lined by soils of the Arcadia soil form. The Arcadia soil form is not a wetland soil. These streams are therefore ephemeral streams and represent watercourses with a distinct channel that is continuous, contains regular or intermittent surface flows, and supports woody riparian habitat along its banks. These watercourses lack base flow and wetland features as they only support surface flow for a short period of 96 | P a g e

time after sufficient rainfall events. When considering whether or not a soil of the Arcadia soil form show signs of wetness, the material underlying the vertic A-horizon is examined as the vertic A-horizon can mask mottling (when temporary wet, but not when seasonally or permanently wet) and other morphological features which are indicative of wetland system. No signs of wetness were encountered in any of the Arcadia soil forms. Note: This is not to say that these systems will not be regarded as riparian or wetland areas from a vegetative and biodiversity perspective. Merely that these soils exhibit no hydromorphic character. Many of the stream flow channels where the Arcadia soil form dominate represents proximal or lateral headcuts. It would seem that these systems are continuously eroding the landscape and migrating towards the higher lying areas.

Figure 33: Land capability classes of the Fuleni Anthracite Project area

97 | P a g e

Figure 34: Current land use in the Fuleni Anthracite Project area

Figure 35: Sensitivity map pertaining to crop production potential of the area

98 | P a g e

Many attempts have been made to establish crops in other areas and relics of cultivated land are encountered in the areas marked Clovelly (crusted), Oakleaf, Clovelly and Arcadia soil forms on the soil map. In the case of the latter, cultivation was attempted near the western border of the surveyed area, close to the Nthuthunga River. These areas are deemed to be of low agricultural potential. In the case of the Arcadia soil form, the soils are high in clay and swells when wet, but cracks when dry. Root pruning is therefore a problem, as is the high levels of Cl and Na in the soil samples taken from the area where cultivation was attempted. The crusting encountered on some of the soils of the Clovelly soil forms will hamper root development and inhibits water infiltration. Water ponds on the surface of these soils while the subsoil is dry. Soils of the Oakleaf soil form exhibits sodic characteristics and the soils of the Clovelly soil which does not exhibit crusting are very sandy, exhibit a poor nutrient holding capacity and shows no sign of a fluctuating water table within the top 150 cm. The only soils that exhibit so-called hydromorphic characteristics are that of the Dundee soil form and the alluvial sand found in the Mfolozi River. Many stream flow channels were encountered on site, but these are all lined by soils of the Arcadia soil form. The Arcadia soil form is not a wetland soil. These streams are therefore ephemeral streams and represent watercourses with a distinct channel that is continuous, contains regular or intermittent surface flows, and supports woody riparian habitat along its banks. These watercourses lack base flow and wetland features as they only support surface flow for a short period of time after sufficient rainfall events. When considering whether or not a soil of the Arcadia soil form show signs of wetness, the material underlying the vertic A-horizon is examined as the vertic A-horizon masks mottling and other morphological features which are indicative of wetland system. No signs of wetness were encountered in any of the Arcadia soil forms. Note: This is not to say that these systems will not be regarded as wetland areas from a vegetative and biodiversity perspective. Merely that these soils exhibit no hydromorphic character. Many of the stream flow channels where the Arcadia soil form dominate represents proximal or lateral head-cuts. It would seem that these systems are continuously eroding the landscape and migrating towards the higher lying areas. The majority of the area therefore represents grazing land and is currently used as such. This holds true for the areas which were not surveyed but which are envisaged to be impacted by infrastructure and mining as well. 2.4.4.2 Potential Crop Yield and Grazing Capacity The surveyed area predominantly falls into the UVa5a and, to a lesser extent, Ua6 and VWa3 bioresource units (refer to Appendix A of ANNEX-2 for details) (Department of Agriculture, Environmental Affairs and Rural Development, Province of KwaZulu Natal). These bioresource units fall into a climatic zone that is described as moderately restricted to crop production due to low temperatures, frost and/or moisture stress. Suitable crops may be grown at risk of some yield loss. The area is dominated by shallow soils, duplex soils and soils of moderate to poor drainage. Soil erosion is a concern. Maize and cabbage area most commonly planted crops in the area. Table 24 summarises the expected crop yields for cabbage and maize. Figure 36 illustrates the grazing capacity of each soil group in the surveyed area. The bioresource data do not specify expected yields for cabbage. During the site visit it was noted that the cabbage are planted during fall and winter. It is not certain whether planting is again done during 99 | P a g e

August and September, although one can assume that this is the case as cabbage seems to be a staple food in the area. Approximately 30 000 plants of one of the so-called big headed cabbage cultivars (currently planted on site) can be grown on the Tukulu soils. At the time of inspection, the cabbage plants showed no signs of nutrient deficiencies and or severe attack by disease or insects. These soils should yield high cabbage plants in excess of 2.5 kg per head. The Tukulu soils have a fluctuating water table at a depth of 60 cm. The plants, therefore, have no shortage of water. The same degree of wetness is not encountered in the soils of the Clovelly and Oakleaf soil forms. Cabbage plants will suffer from drought in these soils if not irrigated. Currently the area is not irrigated. In addition, these soils vary in soil depth and the salinity of the soils and surface water could be problematic if irrigation was to be practiced. The maize yields and grazing capacity in Table 24 are taken from the Bioresource data in Appendix A of ANNEX-2. At the time of the site visit, the maize plants were already harvested. The Bioresource data for the area do not identify the Tukulu soil form. The data was therefore sourced from a soil that most closely resemble the Tukulu soil form. For details regarding the potential crop yields for numerous other crops, the climatic conditions of the area and veld data, the reader is referred to the Bioresource data for the area attached as Appendix A of ANNEX-2.

Figure 36: Grazing capacity of each soil type for the surveyed area (large stock unit)

100 | P a g e

Table 24: Predicted crop yield for the soils encountered on the surveyed area Crop yield (ton/hectare/annum) Grazing capacity (hectare/animal unit)

Area

Cabbage (one of the big headed cultivars)

Maize (Dry land – planted October)

Maize (Irrigated – planted April)

Maize (Irrigated – planted October)

Alluvial Sand

64,06905

-

-

-

-

2.7

Riparian zone of the Mfolozi river

Dundee

12,045746

-

-

-

-

2.7

Seasonal to permanent zone of wetland area

Tukulu

3,866707

75

5.9

5.1

5.9

2.7

High potential arable land

Soil form

Comments

1. Very high erosion risk owing to low organic C content, strongly developed structure, swell and shrink nature and high dispersive clay content (high Na levels on exchange compex) 2. High salinity status 1. Shallow soil, mostly situated in steep sloping areas, not ploughable 2. Rocky soils

Arcadia*

689.178686

-

-

-

-

3.1 (steep slopes > 13%) 2.8 (less steep slopes <13 %)

Glenrosa

96,518607

-

-

-

-

3.7 (steep slopes, > 13 %) 3.3 (less steep slopes < 13 %)

Clovelly (crusted)

29,090275

-

-

-

-

>3.3 (where not crusted; crusted patches has no grazing capacity)

Oakleaf

18,991948

40

1.3

5.9

5.1

2.7

Medium potential arable land

56,63111

-

-

-

-

3.3

Shallow soil, mostly situated in steep sloping areas, not ploughable

182,046474

-

-

-

-

2.7 - 3.3

Shallow Clovelly

8,000296

-

-

-

-

2.7

Rock/Mispah complex

10,04558

-

-

-

-

>3.7

Clovelly

23,014784

40

1.3

5.9

5.1

2.7

Shallow Arcadia

12,135248

-

-

-

Rock/Mispah/ Glenrosa complex Mispah/Glenrosa/ shallow Arcadia Glenrosa/ shallow Arcadia

488.482141

-

-

-

-

>3.7

-

-

-

-

3.7

--

-

-

-

3.7

Soil Rock Complex

2,139553

-

-

-

-

>10

Glenrosa/ shallow Clovelly complex Mispah/Glenrosa complex

1271.70282 374.77902

3.7

High salinity levels led to severe surface crusting

Shallow soil, mostly situated in steep sloping areas, not ploughable Shallow soil, mostly situated in steep sloping areas, not ploughable 1. Very shallow soils, mostly situated in steep sloping areas, not ploughable 2. Rocky areas

1. Shallow soil, mostly situated in steep sloping areas, not ploughable 2. Rocky areas Shallow soil, mostly situated in steep sloping areas, not ploughable Shallow soil, mostly situated in steep sloping areas, not ploughable Shallow soil, mostly situated in steep sloping areas, not ploughable Shallow soils found in between rock outcrops

101 | P a g e

2.4.5 BIODIVERSITY – FLORA 2.4.5.1 Floral Description 2.4.5.1.1 Biome, bioregion and vegetation type

Biomes are broad ecological units that represent major life zones extending over large natural areas (Rutherford 1997). The MRA area falls within the Savanna Biome (Mucina and Rutherford, 2006). Biomes are further divided into bioregions, which are spatial terrestrial units possessing similar biotic and physical features, and processes at a regional scale. The MRA area is situated within the Lowveld Bioregion (Mucina & Rutherford, 2006). While biomes and bioregions are valuable as they describe broad ecological patterns, they provide limited information on the actual species that are expected to be found in an area. Knowing which vegetation type an area belongs to provides an indication of the floral composition that would be found if the assessment site was in a pristine condition, which can then be compared to the observed floral list and so give an accurate and timely description of the ecological integrity of the assessment site. When the boundary of the focus mining rights area is superimposed on the vegetation types of the surrounding area it can be seen that it falls within the Northern Zululand Sourveld, the Zululand Coastal Thornveld, Zululand Lowveld and Subtropical Freshwater Wetland vegetation types (Scott-Shaw & Escott, 2011).

Figure 37: Vegetation types associated with the MRA area (Scott-Shaw & Escott, 2011)

102 | P a g e

2.4.5.1.2 Northern Zululand Sourveld

Northern Zululand Sourveld occurs within the KwaZulu-Natal Province and in Swaziland. It extends from the Lusthof area in Swaziland southwards with scattered patches in northern Zululand in the surrounds of Hlomohlomo, east of Louwsburg, Nongoma and the vicinity of Ulundi including Nkandla. In the HluhluweiMfolozi Park it occurs at highest altitudes in the park. Altitude mainly 450-900m (Mucina & Rutherford, 2006). The Northern Zululand Sourveld is considered vulnerable with a conservation target of 19%. Only 4% is statutorily conserved, mainly in the HiP and Ithala Game Reserve. Some 22% has already been transformed, mainly by cultivation and plantations. Erosion is generally moderate to high (Mucina & Rutherford, 2006). In terms of recent vegetation classifications, the assessed area occurs within the Northern Zululand Sourveld vegetation type (Mucina & Rutherford, 2006). The dominant structural vegetation type is wooded grassland, in places pure sour grasslands and rarely also dense bushveld thickets. Terrain is mainly low, undulating mountains, sometimes highly dissected, and also some moderately undulating plains and hills. Key indicator species of this vegetation type include {*(d) = dominant species}:   

   



  

Small trees: Acacia sieberiana var. woodii (d), A. natalitia, A. nilotica, A. tortilis subsp. heteracantha, Plectroniella armata; Tall shrubs: Gardenia volkensii, Gnidia caffra, G. kraussiana; Low shrubs: Agathisanthemum bojeri, Chaetacanthus burchellii, Crassandra fruticulosa, C. greenstockii, Diospyros galpinii, Phyllanthus glaucophylla, Ruellia cordata, Syncolostemon argenteus, Tetraselago natalensis; Succulent shrubs: Aloe vanbalenii; Woody climber: Cryptolepis oblongifolia; Herbaceous climbers: Cyphostemma schlechteri; Graminoids: Eragrostis curvula (d), Hyparrhenia hirta (d), Microchloa caffra (d), Themeda triandra (d), Tristachya leucothrix (d), Alloteropsis semialata subsp. semialata, Digitaria argyrograpta, D. tricholaenoides, Diheteropogon amplectens, Elionurus muticus, Loudetia simplex, Trachypogon spicatus; Herbs: Alepidea longifolia, Argyrolobium adscendens, Aster bakerianus, Berkheya speciosa, Chascanum hederaceum, Crabbea hirsuta, Gazania krebsiana subsp. serrulata, Gerbera ambigua, Helichrysum mixtum, H. nudifolium var. pilosellum, Hemizygia pretoriae subsp. pretoriae, Hermannia grandistipula, Hypericum aethiopicum, Lichtensteinia interrupta, Pimpinella caffra, Senecio glaberrimus, S. latifoius, Stachys nigricans, Vernonia galpinii, V. oligocephala; Geophytic herbs: Hypoxis hemerocallidea, Pachycarpus concolor; Succulent herbs: Aloe minima, A. parvibracteata, Senecio oxyriifolius; Geoxylic suffrutex: Salacia kraussii.

103 | P a g e

2.4.5.1.3 Zululand Lowveld

Zululand Lowveld occurs within the KwaZulu-Natal Province, Swaziland and the Mpumalanga Province. The main extent of the vegetation type is from around Big Bend south to Mkuze, Hluhluwe and Ulundi to just north of the Ongoye Forest. An isolated patch is also found on the Swaziland-Mpumalanga border. Altitude is about 50m reaching 450m in places (Mucina & Rutherford, 2006). The Zululand Lowveld is considered Vulnerable with a conservation target of 19%. Some 11% of the vegetation type is statutorily conserved, mainly in the HiP and Phongolapoort Nature Reserve. Almost 1% is protected in the private Masibekela Wetland. Much of the area between Magudu, Mkuze and Nongoma is managed as private game farms and lodges. About 26% of the area has been transformed, mostly by cultivation. Erosion is variable from low to high (Mucina & Rutherford, 2006). The Zululand Lowveld vegetation type occurs on extensive flat or only slightly undulating landscapes supporting a complex of various bushveld units ranging from dense thickets of Dichrostachys cinerea and Acacia species, through park-like savanna with flat-topped A. tortilis to tree dominated woodland with broad leaved open bushveld with Sclerocarya birrea subsp. caffra and A. nigrescens. Tall grassveld types with sparsely scattered solitary trees and shrubs form a mosaic with the typical savannah thornveld, bushveld and thicket patches. Key indicator species of this vegetation type include {*(d) = dominant species}:  

 



   

Tall trees: Acacia burkei (d), A. nigrescens (d), Sclerocarya birrea subsp. caffra (d); Small trees: Acacia tortilis subsp. heteracantha (d), A. gerrardii, A. natalitia, A. nilotica, A. senegal var. rostrata, A. welwitschii subsp. welwitschii, Boscia albitrunca, Combretum apiculatum, C. molle, Ozoroa paniculosa, Phoenix reclinata, Schotia brachypetala, Spirostachys africana, Teclea gerrardii, Ziziphus mucronata; Succulent trees: Aloe marlothii subsp. marlothii, Euphorbia grandidens, E. ingens; Tall shrubs: Dichrostachys cinerea (d), Euclea divinorum (d), Coptosperma supra-axillare, Crotalaria monteiroi, Euclea crispa subsp. crispa, E. schimperi, Galpinia transvaalica, Gardenia volkensii, Gymnosporia maranguensis, G. senegalensis, Jatropha zeyheri, Lycium acutifolium, Olea europaea subsp. africana, Tarchonanthus parvicapitulatus, Tephrosia polystachya, Triumfetta pilosa var. tomentosa; Low shrubs: Barleria obtusa, Crossandra greenstockii, Felicia muricata, Gymnosporia heterophylla, Indigofera trita subsp. subulata, Justicia flava, J. protracta subsp. protracta, Malhania didyma, Orthosiphon serratus, Pearsonia sessilifolia, Ruellia cordata, Sida serratifolia, Tetraselago natalensis; Succulent shrubs: Euphorbia grandicornis, E. trichadenia, E. vandermerwei; Soft shrub: Pavonia columella; Herbaceous climbers: Fockea angustifolia; Graminoids: Dactyloctenium austral (d), Enteropogon monostachus (d), Eragrostis capensis (d), E. curvula (d), E. racemosa (d), Heteropogon contortus (d), Panicum maximum (d), Sporobolus pyramidalis (d), Themeda triandra (d), Aristida bipartata, A. congesta, Bothriochloa insculpta, Chloris mossambicensis, Cymbopogon caesius, Digitaria natalensis, Leptochloa eleusine, Panicum deustum, Schizachyrium sanguineum, Setaria incrassata, Sporobolus nitens, Trachypogon spicatus, Tristachya leucothrix; 104 | P a g e





Herbs: Acrotome hispida, Argyrolobium rupestre, Aspilia mossambicensis, Chamaecrista biensis, C. mimosoides, Corchorus asplenifolius, Felicia massamedensis, Gerbera ambigua, Helichrysum rugulosum, Hibiscus pusillus, Kohautia virgata, Lotononis eriantha, Senecio latifolius, Stachys aethiopica, Tragia meyeriana, Vernonia capensis; Succulent herb: Aloe parvibracteata.

2.4.5.1.4 Zululand Coastal Thornveld

Zululand Coastal Thornveld is distributed in the KwaZulu-Natal Province, immediately west of Mtubatuba (in the north) and Empangeni (in the south) bisected by the Mfolozi River, extending westwards for 10 to 20 km. It prefers an altitude ranging from 40 to 300 m (Mucina & Rutherford, 2006). It is formally classified as an Endangered vegetation type that has no statutorily conserved areas. It has a provincial conservation target of 19%. It is highly transformed (58%), mostly by cultivation. This is highpotential agricultural land, which is already been much transformed to sugar cane. Most of the area is communal land. Large areas close to towns are becoming an urban sprawl. Very little of the natural plant communities remains intact. Heavy grazing has depleted the grassland and wood harvesting has depleted the bush clumps, reducing them to only the resistant and less useful species. Stunted forms of many of the woody species invade the grasslands in many places. Currently it is rare to find a site still with its natural plant composition. Themeda triandra, a ‘decreaser species’, has declined to critically low levels. Alien plant invasions are a threat, with Chromolaena odorata being the most problematic. Erosion is low to moderate (Mucina & Rutherford, 2006). Zululand Coastal Thornveld occurs in wooded grasslands dominated by Themeda triandra. The bush clumps are a strong feature and are more numerous on deeper soils, with Phoenix reclinata and Gymnosporia senegalensis usually dominant. These plant communities are species-rich relative to the surrounding vegetation units. They grade into dense Acacia woodlands on dry slopes and riverine bushland thickets and Lowveld Riverine Forest in valley bottoms (Mucina & Rutherford, 2006). Table 25: Dominant and typical floristic species of Zululand Coastal Thornveld (Mucina & Rutherford, 2006) Grass species Eragrostis capensis (d) Panicum maximum (d) Sporobolus pyramidalis (d) Themeda triandra (d) Tristachya leucothrix (d) Aristida congesta Eragrostis curvula E. racemosa Heteropogon contortus Hyparrhenia hirta Schizachyrium sanguineum Setaria sphacelata Trachypogon spicatus

Forb species Rhynchosia minima R. totta Berkheya setifera B. specoisa Centella asiatica Eriosema cordatum E. distinctum Gerbera viridifolia Helichrysum nudifolium var. pilosellum Hypericum aethiopicum Indigofera hilaris I. sanguinea Pentanisia prunelloides Ruellia patula Senecio erubescens S. inornatus Spermacoce natalensis Vernonia oligocephala

Tree/Shrub Species Acacia natalitia A. nilotica Phoenix reclinata Euphorbia tirucalli (d) E. ingens Diospyros lycioides subsp. Sericea (d) Euclea divinorum (d) Gymnosporia senegalensis (d) Abutilon angulatum Clutia abyssinica Euclea schimperi Gymnosporia buxifolia Acalypha peduncularis Clutia cordata Sida cordifolia S. dregei Thunbergia atriplicifolia

105 | P a g e

Grass species

Forb species Vigna unguiculata Hypoxis rigidula Pelargonium luridum

Tree/Shrub Species

*(d) – Dominant species for the vegetation type 2.4.5.1.5 Subtropical Freshwater Wetlands

Subtropical Freshwater Wetlands is distributed in KwaZulu-Natal, Mpumalanga, Gauteng, North West, Limpopo and Eastern Cape Provinces, as well as in Swaziland, where it occurs in Wetlands embedded within the Albany Thicket Biome, the Coastal Belt from Transkei as far as Maputaland as well as those Lowveld and the Central Bushveld regions. It prefers an altitude ranging from 0 to 1 400 m (Mucina & Rutherford, 2006). Subtropical Freshwater Wetlands falls within a mainly seasonal, summer-rainfall region, in the Lowveld and Central Bushveld, and to a lesser extent also nonseasonal climate characterized by high precipitation, in the Albany region and Eastern Cape and KwaZulu-Natal coastal belts. It occurs in a mean annual precipitation (MAP) between 454 mm and 963 mm. Subtropical and tropical temperature regimes are prevalent in winter and summer, with temperatures ranging from 18.0ºC (Central Bushveld) to 22.0ºC (Makatini Flats). Occurrence of frost is limited to the southernmost localities (Mucina & Rutherford, 2006). The preference geology is waterlogged, clayey soils of Champange and Arcadia forms, containing certain levels of decaying organic matter, especially in very productive reed beds. These wetlands are mostly underlain by Cenozoic alluvium, less so by the Karoo Supergroup volcanic rocks and sediments, as well as by the Cretaceous (and younger coastal) sediments if the Zululand and Maputaland Groups. Waterlogged habitats with water regularly, form columns of variable depth. The highest water levels are found in summer, during periods of maximum seasonal rainfall (Mucina & Rutherford, 2006). It is formally classified as a Least threatened vegetation type that is 40 to 50% statutorily conserved (provincial conservation target is 24%) in areas such as the Great St Lucia Wetland Park, Kruger National Park, Ndumo Game Reserve, Tembe Elephant Park as well as Nhlabane, Nylsvley, Mkombo, Sileza and Richards Bay Nature Reserve. A further 10% enjoys protection in a number of private game farms and other reserves in the Limpopo, Mpumalanga and KwaZulu-Natal Provinces. So far only about 4% has been transformed (largely for cultivation), but the pressure of local grazing and urban sprawl will result in the demise of many subtropical freshwater habitats. Disturbance leads to invasion of alien plants such as Lantana camara, Chromolaena discolor and Melia azedarach on the edges of wetlands and aquatic weeds such as Eichhornia crassipes, Pistia stratiotes and Salvinia molesta in water bodies. (Mucina & Rutherford, 2006). Subtropical Freshwater Wetlands occurs on a flat topography supporting low bed dominated by reeds, sedges and rushes, waterlogged meadows dominated by grasses. It is typically found along edges of often seasonal pools in aeolian depressions as well as fringing alluvial backwater pans or artificial dams (Mucina & Rutherford, 2006). Important Taxa Marshes {*(d) = dominant species}:  

Small trees: Hyphaene coriacea (d), Phoenix reclinata (d) Graminoids: Chloris vigata (d), Cynodon dactylon (d), Cyperus articulates (d), Dactyloctenium aegyptium (d), Diplachne fusca (d), Echinocloa pyramidalis (d), Fimbristylis obtusifolia (d), 106 | P a g e



    



Hemarthria altissima (d), Imperata cylindrical (d), Ischaemum arcuatum (d), Leersia hexandra (d), Pycreus mundii (d), Sporobolus nitens (d), S. smutsii (d), Urochloa stolonifera (d), Bolboschoenus glaucus, Courtoisia cyperiodes, Cyperus alopecuroides, C. pectinatus, Digitaria natalensis, Echinocloa stagnina, Eragrostis chapelieri, E. lappula, Eriochloa meyeriana, Fimbristylus bisumbellata, Fuirena ecklonii, Oxyxaryum cubense, Paspalidium obtusifolium, Paspalum commersonii, Pycreus pelophilus, P. polystachyos, Scleria poiformis, Sporobolus consimilis Herbs: Pentodon pentandrus (d), Persicaria senegalensis (d), Burmannia madagascariensis, Centella coriacea, Commelina diffusa, Convolvulus mauritanicus, Desmodium dregeanum, Eclipta prostrate, Epaltes gariepina, Eriocaulon abyssinicum, Ethulia conyzoides, Glinus lotoides, Hydrocotyle ranunculoides, Ludwigia adscendens subsp. Diffusa, L. leptocarpa, L. octovalvis, L. palustris, Neptunia oleracea, Persicaria attenuate subsp. Africana, P. hystricula, Rorippa madagascariensis, Sium repandum, Vahlia capensis Geophytic Herbs: Eulophia angolensis, Zeuxine Africana Succulent Herb: Salicornia pachystachya Semiparasitic Herb: Buchnera longespicata Aquatic Herb: Bergia salaria, Lagarosiphon cripus Lakes and Ponds o Graminoids: Eleocharis dulcis o Aquatic Herbs: Azolla pinnata var. Africana (d), Ceratophyllum demersum (d), Lemna minor (d), Nymphaea nouchali var. caerulea (d), Pistia stratiotes (d), Wolffia arrhiza (d), Aponogeton desetorum, A. natalensis, A. rehmannii, Ceraphyllum muricatum, Mersilea macrocarpa, Najas marina subsp. delilei, N. pectinata, Nymphides indica subsp. occidentalis, N. rautanenii, Ottelia exserta, Potamogeton cripus, P. pectinatus, P. schweinfurthii, Spirodela polyrhiza, A. punctate, Trapa natans var. bispinosa o Carnivorous Herbs: Utricularia gibba subsp. exoleta, U. inflexa, U. subulata o Geophytic Herb: Crinum paludosum Reeds and sedge beds o Megagraminoids: Cladium mariscus subsp. jamaicense (d), Cyperus papyrus (d), Pragmites australis (d), P. mauritianus (d), Schoenoplectus corymbosus (d), S. scirpoideus (d), Typha capensis (d). o Graminoids: Cyperus fastigiatus (d), C. difformis, C. digitatus, C. latifolius, C. sexangularis, Fuirena ciliaris

Biogeographically Important Taxa 





Streambanks o Herbs: Floscopa glomerata, Ipomoea aquatic o Geophytic Herb: Bolbitis heudelotii Lakes and ponds o Aquatic Herbs: Brasenia schreberi, Ceratopteris cornuta, Wolffia globosa, Wolffiella welwitschii o Herbs: Hygrophila schulli, Limnophyton obtusifolius, Marsilea apposita, M. coromandelina, M. minuta, M. villifolia Reed and segde beds o Graminoids: Cyperus dives, C. properus, C. prolifer 107 | P a g e

Endemic Taxa Marshes  

Graminoid: Cyperus sensilis Lakes and ponds o Geophytic Herbs: Crinum campanulatum o Aquatic herbs: Isoetes wormaldii, Wolffiella denticulata

2.4.5.2 Habitat Descriptions Four main habitat units were identified during the assessment, namely:    

Rocky ridges; Wetland and riparian habitat; Savanna Woodland habitat; and Transformed habitat.

Figure 38 depicts the habitat units identified during the site assessment in relation to the mining footprint area. 2.4.5.2.1 Habitat Unit 1: Rocky ridge areas

The Rocky ridge habitat unit occurs in sections along the Mfolozi River and in the north-eastern section of the mining footprint area. Figure 39 presents typical rocky ridge habitat present in the mining footprint area.

Figure 38: Habitat Units within the mining footprint area

108 | P a g e

Figure 39: The Rocky ridge habitat unit

Dominant taller woody species occurring within this habitat unit include Combretum molle, C. apiculatum, C. Dombeya rotundifolia, Ozoroa paniculosa, Peltophorum africanum, Schotia brachypetala and Pappea capensis, while the shrub layer was characterised by Euclea divinorum, Diospyros galpinii, Gardenia volkensii. Olea europaea subsp. africana and Gymnosporia heterophylla. Succulent species included Euphorbia tirucalli, Euphorbia ingens, Aloe marlothii and A. vanbalenii. Species such as Diheteropogon amplectens, Loudetia simplex, Heteropogon contortus, Cynodon dactylon, Tristachya leucothrix and Elionurus muticus dominate the graminoid layer. The vegetation composition in these areas is typical of rocky outcrops and ridges in the Zululand Lowveld and Northern Zululand Sourveld vegetation types. Alien species diversity and abundance was generally low, however around homesteads and kraal areas, species such as Zinnia peruviana, Opuntia ficus-indica, Cereus jamacaru and Tagetes minuta were abundant. In addition, disturbed areas were also severely invaded by indigenous species such as Dichrostachys cinerea and Euphorbia tirucalli, often forming dense, impenetrable stands. Table 26 lists the dominant floral species found within this habitat unit during the site assessment. The Rocky ridge habitat unit has general high ecological functionality and overall high levels of habitat integrity, especially in the north of the mining footprint area adjacent to the Mfolozi River and is in a relatively undisturbed condition, apart from areas where existing homesteads and kraals are situated. Furthermore, two species protected by the National Forest Act (Act 84 of 1998), namely Sclerocarya birrea subsp caffra and Boscia albitrunca and one species protected under the Kwazulu-Natal Nature Conservation Management Amendment Act (1999) namely Huernia hystrix, are present in this habitat unit. The above-mentioned botanical aspects of the Rocky ridge habitat indicate that this habitat type is of increased ecological sensitivity and conservation value. The Rocky ridge habitat unit provides niche habitat for a high diversity of floral and faunal species and contributes towards faunal migratory connectivity within the area. Thus, the Rocky ridge habitat unit is considered to be of high ecological sensitivity, and any impacts from the proposed mining activities and associated infrastructure are anticipated to be significant. 109 | P a g e

Table 26: Dominant species encountered in the Rocky ridge habitat unit Grass species Aristida congesta subsp barbicollis Aristida congesta subsp congesta Artistida bipartita Cymbopogon plurinodes

English names Spreading Three-awn Tassel Three-awn Rolling Grass Narrow-leaved Turpentine Grass Couch Grass Broad-leaved Bluestem (Narrow) Curly Leaf Weeping Love Grass Heart-seed Love Grass Wire Grass Spear Grass Common Thatching Grass Common Russet Grass Bristle-leaved Red Top Natal Red Top Guinea Grass Red Autumn Grass Red Grass Hairy Trident Grass

Forb species Argyrolobium adscendens *Bidens pilosa Chamaecrista biensis *Sesbania punicea *Tagetes minuta *Zinnia peruviana Asclepias fruticosa Asparagus natalensis Commelina africana Commelina erecta *Datura stramonium Hermannia grandistipula Ipomoea crassipes Kohautia virgata Lotononis eriantha Senecio glaberrimus *Solanum mauritianum Vernonia oligocephala

Cynodon dactylon Diheteropogon amplectens Eragrostis chloromelas Eragrostis curvula Eragrostis capensis Elionurus muticus Heteropogon contortus Hyparrhenia hirta Loudetia simplex Melinis nerviglumis Melinis repens Panicum maximum Schizachyrium sanguineum Themeda triandra Tristachya leucothrix Tree/Shrub species English names Succulent species Acacia karroo Sweet Thorn Aloe marlothii Acacia sieberiana Paperbark Thorn Aloe vanbalenii Berchemia zeyheri Red Ivory *Cereus jamacaru Boscia albitrunca Shepherds-tree Euphorbia ingens Brachylaena ilicifolia Small-leaf Silver-oak Euphorbia tirucalli Combretum apiculatum Red Bushwillow Combretum molle Velvet Bushwillow Huernia hystrix Commiphora Common Corkwood pyracanthoides Sickle-bush Kalanchoe rotundifolia Dichrostachys cinerea Dwarf Hairy Star-apple *Opuntia ficus-indica Diospyros galpinii Common Dombeya Dombeya rotundifolia Magic Guarri Euclea divinorum Bushveld Gardenia Gardenia volkensii Angle-stem Spikethorn Gymnosporia heterophylla Seringa/ Persian Lilac *Melia azederach Olea europaea subsp. Wild Olive africana Ozoroa paniculosa Resin-tree Pappea capensis Jacket-plum Pavetta edentula Gland-leaf Brides-bush Peltophorum africanum African-wattle Plectroniella armata False Turkey-berry Sclerocarya birrea subsp Marula caffra Schotia brachypetala Weeping Boer-bean Ziziphus mucronata Buffalo-thorn Alien species are indicated with an asterisk (*) and protected species are in bold font.

English names Common Blackjack Red Sesbania Tall Khaki Weed Redstar Zinnia Swan Plant Yellow Commelina Blue Commelina Common Thorn Apple Yellow Granny Bonnets Leafy-flowered Ipomoea Russet Lotononis Bugweed Bicoloured-leaved Vernonia

English names Mountain Aloe Van Balen’s Aloe Queen of the night Common Tree Euphorbia Pencil Plant/ Rubberhedge Euphorbia Porcupine Huernia/ Toad Plant Common Kalanchoe Sweet Prickly Pear

110 | P a g e

2.4.5.2.2 Habitat Unit 2: Wetland and Riparian habitat

Several types of wetlands are present on the mining footprint area; which were delineated and are discussed in detail within the wetland assessment section (ANNEX-3). This habitat unit is characterised by perennial rivers, ephemeral drainage lines and valley head seepage areas.

Figure 40: The Mfolozi River (left) and Mvamanzi River (right) and associated riparian habitat

The rivers assessed (Mfolozi River and Mvamanzi River) were defined as perennial systems containing riparian habitat due to the presence of alluvial soils and the presence of vegetation with a composition and physical structure, distinct from adjacent areas. The Mvamanzi River also forms a large floodplain where it enters Mfolozi River. Many smaller drainage lines within the mining footprint area also display these characteristics and were therefore also defined as systems with riparian habitat. The catchment of some of the drainage lines are however smaller and did not allow for the establishment of the defined riparian habitat characteristics and were therefore considered non-riparian ephemeral drainage lines.

Figure 41: Ephemeral drainage lines with established riparian zone (left) and with riparian zone absent (right)

Artificial impoundments were encountered within smaller drainage lines, most likely created as an effort to retain water for as long as possible for the purpose of water provision for livestock. This has led to the formation of piospheres, where trampling by livestock creates locally denuded areas around such impoundments, which has resulted in severe encroachment by invasive floral species such as Dichrostachys cinerea. Several of these artificial impoundments hold water throughout the year and the presence of water for prolonged periods of the year has resulted in the formation of wetland characteristics as defined by the NWA. 111 | P a g e

In terms of distinct wetland vegetation, the riparian zone of the Mfolozi and Mvamanzi Rivers and some of the larger ephemeral drainage lines was defined by the presence of large Ficus sycamorus trees. These trees were absent from the smaller ephemeral drainage lines. Furthermore, the permanent zones of the perennial systems were characterized by Phragmites mauritianum and Typha capensis. The ephemeral drainage lines were also associated with distinct species, although these species are not necessarily associated with wetland conditions. The vegetation around the majority of ephemeral drainage lines was characterised by dense thickets of Spirostachys africana, Mimusops obovata, Schotia brachypetala, S. capitata and various Acacia species. The vegetation of the weakly developed drainage lines was similar to the Savanna Woodland habitat unit with no distinct riparian or wetland vegetation present. The vegetation associated with the valley head seep wetlands was similar to the surrounding a terrestrial vegetation, except for Cyperus sexangularis and C. fastigiatus, among other species, which do not occur in the surrounding terrestrial areas. In some of the wetlands, Ficus sycomorus, which is associated with the riparian zones of the Mvamanzi and Mfolozi systems, was also present. Thus, the vegetation composition was distinct from surrounding terrestrial areas and considered to be representative of true wetland conditions. Within the majority of these wetlands, cultivation of several crops was encountered, which has led to the transformation of the floral community in isolated areas. Table 27 lists the dominant floral species found within this habitat unit during the site assessment. Table 27: Dominant species encountered in the Wetland and Riparian habitat unit Grass/Sedge/Reed species Aristida congesta subsp congesta Artistida bipartita Bothriochloa insculpta Cyperus sexangularis Cyperus fastigiatus Cynodon dactylon Digitaria natalensis Eragrostis chloromelas Eragrostis curvula Hyparrhenia hirta Hyparrhenia tamba Imperata cylindrica Phragmites mauritianum Panicum maximum Setaria incrassata Setaria sphacelata Sporobolus nitens Sporobolus pyramidalis Themeda triandra Typha capensis

English names Spreading Three-awn

Tree/Shrub species Acacia karroo Acacia sieberiana Acacia burkei Acacia nilotica Dichrostachys cinerea Diospyros galpinii Ficus sycamorus

Rolling Grass Pinhole Grass

Couch Grass Natal Crabgrass (Narrow) Curly-leaf Weeping Love Grass Common Thatching Grass Blue Thatching Grass Cottonwool Grass Guinea Grass Vlei Bristle Grass Golden Bristle Grass Curly-leaved Dropseed Catstail Dropseed Red Grass Bulrush

Forb species *Sesbania punicea Commelina africana Commelina erecta Gerbera ambigua Helichrysum rugulosum Helichrysum nudifolium var. pilosellum Ipomoea crassipes

English names Red Sesbania Yellow Commelina Blue Commelina Pink and White Gerbera Hottentot’s Tea Leavy-flowered Ipomoea

Senecio glaberrimus *Solanum mauritianum

Bugweed

English names

Succulent species

English names

Sweet Thorn Paperback Thorn Black-monkey Thorn Scented-pod Thorn Sickle-bush Dwarf Hairy Star-apple Sycamore Fig

*Opuntia ficus-indica

Sweet Prickly Pear

112 | P a g e

Gymnosporia heterophylla Angle-stem Spikethorn Mimusops obovata Forest Red-milkwood Sideroxylon inerme White-milkwood *Melia azederach Seringa/ Persian Lilac Pavetta lanceolata African Wattle Phoenix reclinata Wild Date Palm Sclerocarya birrea subsp Marula caffra Schotia brachypetala Weeping Boer-bean Schotia capitata Dwarf Boer-bean Spirostachys africana Tamboti Ziziphus mucronata Buffalo-thorn Alien species are indicated with an asterisk (*) and protected species are in bold font.

The perennial systems (Mfolozi and Mvamanzi Rivers) and some of the ephemeral systems (especially in the western sections of the mining footprint area) with strongly developed riparian zones are characterised by high ecological functionality and overall high levels of habitat integrity. Other ephemeral systems, especially towards the east of the mining footprint area, are more transformed. In terms of RDL and protected floral species, two species protected by the National Forest Act (1998), namely Sclerocarya birrea subsp caffra and Sideroxylon inerme are present in this habitat unit especially within the dense thickets associated with the riparian zones of the ephemeral systems. The wetland and riparian habitat unit provides niche habitat for a high diversity of floral and faunal species and acts as a very important network of migratory corridors for faunal species. Thus, this habitat unit is considered to be sensitive. As such, any impacts on the wetland and riparian systems associated with the mining footprint area are likely to be significant on a local and regional scale. 2.4.5.2.3 Habitat Unit 3: Savanna Woodland

The Savanna Woodland habitat unit covered the majority of the mining footprint area and was encountered on the lower lying sections of the mining footprint area. Toward the west of the mining footprint area, the landscape became more undulating, with low, rolling hills dominating the landscape. Sections of this habitat unit are more ecologically intact, especially toward the western boundary of the mining footprint area. In the eastern sections of the mining footprint area, villages, roads and grazing pressure by livestock have transformed the vegetation structure of this habitat unit, although not to such a degree that it is unrecognisable as Savannah Woodland.

113 | P a g e

Figure 42: Representative photograph of the Savanna Woodland habitat unit

The tall woody layer of this habitat unit was dominated by various Acacia species such as A. tortilis subsp. heteracantha, A. sieberiana var. woodii and A. nilotica, while the shrub layer was characterised by A. tortilis, Euclea divinorum, E. crispa subsp. crispa, Diospyros galpinii and Gymnosporia heterophylla. Succulent species included Aloe marlothii and Huernia hystrix. The graminoid layer was dominated by Themeda triandra, Eragrostis curvula, E. chloromelas, Hyparrhenia hirta, Heteropogon contortus, Cynodon dactylon, Tristachya leucothrix and Digitaria natalensis. The vegetation composition in these areas is best described as a combination of the Zululand Lowveld and Northern Zululand Sourveld vegetation types, as these two vegetation types form an ecotone within the mining footprint area. As with the rocky ridges, alien species diversity and abundance was low in the more natural areas, while species such as Pennisetum clandestinum, Melia azederach, Zinnia peruviana, Opuntia ficus-indica, Cereus jamacaru and Tagetes minuta were abundant around homesteads and kraal areas. Overgrazed and disturbed areas were severely invaded by indigenous species such as Dichrostachys cinerea and Acacia tortilis often forming dense, impenetrable stands. Table 28 lists the dominant floral species found within this habitat unit during the site assessment.

114 | P a g e

Table 28: Dominant species encountered in the Savanna Woodland areas Grass species Aristdia congesta subsp barbicollis Aristida congesta subsp congesta Artistida bipartita Bothriochloa insculpta Cymbopogon plurinodes Cynodon dactylon Diheteropogon amplectens Eragrostis chloromelas Eragrostis curvula Heteropogon contortus Hyparrhenia hirta Loudetia simplex Melinis nerviglumis Melinis repens Panicum maximum *Pennisetum clandestinum Setaria incrassata Sporobolus nitens Themeda triandra Tristachya leucothrix Tree/Shrub species Acacia karroo Acacia sieberiana Acacia burkei Acacia nilotica Acacia tortilis Acacia senegal var. rostrata Acacia welwitschii subsp. welwitschii *Agave sisalana Berchemia zeyheri Boscia albitrunca Brachylaena ilicifolia Combretum apiculatum Combretum molle Commiphora pyracanthoides Dichrostachys cinerea Diospyros galpinii Dombeya rotundifolia Euclea divinorum Gardenia volkensii Gymnosporia heterophylla *Melia azederach Olea europaea subsp. africana Ozoroa paniculosa Pappea capensis

English names Spreading Three-awn Tassel Three-awn Rolling Grass Pinhole Grass Narrow-leaved Turpentine Grass Broad-leaved Bluestem (Narrow) Curly Leaf Weeping Love Grass Spear Grass Common Thatching Grass Common Russet Grass Bristle-leaved Red Top Natal Red Top Guinea Grass Kikuyu Grass Vlei Bristle Grass Curly-leaved Dropseed Red Grass Hairy Trident Grass English names Sweet Thorn Paperback Thorn Black-monkey Thorn Scented-pod Thorn Umbrella Thorn Bushy Three-hook Thorn

Forb species Argyrolobium adscendens *Bidens pilosa Chamaecrista biensis *Sesbania punicea *Tagetes minuta *Zinnia peruviana Asclepias fruticosa Asparagus natalensis Commelina africana Commelina erecta *Datura stramonium Hermannia grandistipula Helichrysum rugulosum Ipomoea crassipes

English names

Kohautia virgata Lotononis eriantha Senecio glaberrimus *Solanum mauritianum Vernonia oligocephala

Leavy-flowered Ipomoea

Red Sesbania Tall Khaki Weed Redstar Zinnia Swan Plant Yellow Commelina Blue Commelina Common Thorn Apple Yellow Granny Bonnets

Russet Lotononis Bugweed Bicoloured-leaved Vernonia

Succulent species Aloe marlothii Aloe vanbalenii Aloe greatheadii *Cereus jamacaru Euphorbia ingens Euphorbia tirucalli Huernia hystrix

Sisal Red Ivory Shepherds-tree Small-leaf Silver Oak Red Bushwillow Velvet Bushwillow Common Corkwood Sickle-bush Dwarf Hairy Star-apple Common Dombeya Magic Guarri Bushveld Gardenia Angle-stem Spikethorn Seringa/ Persian Lilac

Common Blackjack

*Opuntia ficus-indica

English names Mountain Aloe Van Balen’s Aloe Spotted Aloe Queen of the night Common Tree Euphorbia Pencil Plant/ Rubber hedge Euphorbia Porcupine Huernia/ Toad Plant Sweet Pricky Pear

Wild Olive Resin-tree Jacket-plum

115 | P a g e

Pavetta lanceolata Pavetta edentula Peltophorum africanum

Weeping Brides-bush Gland-leaf Brides-bush African Wattle/ Weeping Wattle False Turkey-berry Marula

Plectroniella armata Sclerocarya birrea subsp caffra Schotia brachypetala Weeping Boer-bean Spirostachys africana Tamboti Tetraselago natalensis Ziziphus mucronata Buffalo-thorn Alien species are indicated with an asterisk (*) and protected species are in bold font.

Towards the western sections of the mining footprint area, the Savanna Woodland habitat unit is ecologically intact and characterised by overall high levels of habitat integrity. Towards the east, where existing informal sand mines, homesteads and kraals are situated and livestock grazing is more intensive, ecological function and vegetation structure is more transformed, although still recognisable as Savanna Woodland. In terms of protected species, two tree species protected by the National Forest Act (1998), namely Sclerocarya birrea subsp caffra and Boscia albitrunca were scattered throughout this habitat unit, although they were more abundant in the more ecologically intact areas. One species protected under the Kwazulu-Natal Nature Conservation Management Amendment Act (1999) namely Huernia hystrix is present in this habitat unit in the less transformed areas. The above characteristics indicate that the ecological sensitivity and conservation value of the less transformed areas of the habitat unit is of increased ecological significance. As mentioned, the more transformed areas of the habitat unit, while not as ecologically intact, are still moderately representative of the vegetation types they are situated in. Thus, the Savanna Woodland habitat unit is considered to be of high ecological sensitivity, and impacts from the proposed mining activities and associated infrastructure are likely to be significant. 2.4.5.2.4 Habitat Unit 4: Transformed areas

The Transformed habitat unit was encountered where villages, roads, subsistence agriculture and trampling and grazing pressure by livestock have transformed the vegetation structure to such a degree that it is no longer representative of the vegetation types in which this habitat unit occurs.

116 | P a g e

Figure 43: Representative photograph of the Transformed habitat unit

The floral composition of this habitat unit can be described as relict Northern Zululand Sourveld and Zululand Lowveld vegetation, which has been severely transformed by anthropogenic activities. The tall woody layer of this habitat unit was dominated by Schotia brachypetala, Acacia tortilis subsp. heteracantha, A. sieberiana var. woodii and A. nilotica, while the shrub layer was characterised by Dichrostachys cinerea, E. crispa subsp. crispa and Gymnosporia heterophylla. Succulent species included Aloe marlothii, A. vanbelanii, Euphorbia tirucalli and Huernia hystrix. The graminoid layer was dominated by pioneer and sub-climax grass species such as Hyparrhenia hirta, Cynodon dactylon, Aristida congesta subsp. congesta and A. congesta subsp. barbicollis. Alien species were more abundant in this habitat unit, with species such as Pennisetum clandestinum, Melia azederach, Zinnia peruviana, Opuntia ficus-indica, Cereus jamacaru and Tagetes minuta especially dominant. Overgrazed and disturbed areas were severely invaded by indigenous species such as Dichrostachys cinerea and Acacia tortilis and were characterised by denuded areas of bare soil.

Table 29 lists the dominant floral species found within this habitat unit during the site assessment.

117 | P a g e

Table 29: Dominant species encountered in the Transformed habitat unit Grass species Aristdia congesta subsp barbicollis Aristida congesta subsp congesta Artistida bipartita Bothriochloa insculpta Cymbopogon plurinodes

English names Spreading Three-awn Tassel Three-awn Rolling Grass Narrow-leaved Turpentine Grass Couch Grass (Narrow) Curly Leaf Weeping Love Grass Spear Grass Common Thatching Grass Bristle-leaved Red Top Natal Red Top Guinea Grass Kikuyu Grass

Forb species *Bidens pilosa *Sesbania punicea *Tagetes minuta *Zinnia peruviana Asclepias fruticosa Asparagus natalensis Commelina africana Commelina erecta *Datura stramonium Ipomoea crassipes

Cynodon dactylon Eragrostis chloromelas Eragrostis curvula Heteropogon contortus *Solanum mauritianum Hyparrhenia hirta Vernonia oligocephala Melinis nerviglumis Melinis repens Panicum maximum *Pennisetum clandestinum Setaria incrassata Vlei Bristle Grass Tree/Shrub species English names Succulent species Acacia karroo Sweet thorn Aloe marlothii Acacia sieberiana Paperbark Thorn Aloe vanbalenii Acacia burkei Black-monkey Thorn Aloe greatheadii Acacia nilotica Scented-pot Thorn *Cereus jamacaru Acacia tortilis Umbrella Thorn Euphorbia tirucalli Acacia senegal var. Bushy Three-hook Thorn rostrata Huernia hystrix *Agave sisalana Sisal Boscia albitrunca Shepherds-tree *Opuntia ficus-indica Dichrostachys cinerea Sickle-bush Dombeya rotundifolia Common Dombeya Euclea crispa subsp. crispa Blue Guarri Gardenia volkensii Bushveld Gardenia Gymnosporia heterophylla Angle-stem Spikethorn *Melia azederach Seringa/ Persian Lilac *Nerium oleander Oleander Peltophorum africanum African Wattle Plectroniella armata False Turkey-berry *Senna didymobotrya Peanut Butter Senna Sclerocarya birrea subsp Marula caffra Schotia brachypetala Weeping Boer-bean Spirostachys africana Tamboti Ziziphus mucronata Buffalo-thorn Alien species are indicated with an asterisk (*) and protected species are in bold font.

English names Common Blackjack Red Sesbania Tall Khaki Weed Redstar Zinnia Swan Plant Yellow Commelina Blue Commelina Common Thorn-Apple Leavy-flowered Ipomoea Bugweed Bicoloured-leaved Venonia

English names Moutain Aloe Van Balen’s Aloe Spotted Aloe Queen of the night Pencil Plant/ Rubberhedge Euphorbia Porcupine Huernia/ Toad Plant Sweet Prickly Pear

Although the Transformed habitat unit still contains species associated with the vegetation types it is situated in, the vegetation structure and floral community composition is, in most cases, completely transformed. Two tree species protected by the National Forest Act (1998), namely Sclerocarya birrea subsp caffra and Boscia albitrunca were scattered throughout this habitat unit, especially along roads and

118 | P a g e

closer to homesteads. Another species, which is protected under the Kwazulu-Natal Nature Conservation Management Amendment Act (1999) is also scattered throughout the habitat unit, namely Huernia hystrix. Although this habitat unit is considered to be of low ecological sensitivity, edge effects from mining activities are deemed likely to have a detrimental impact on the surrounding more sensitive habitat units. 2.4.5.2.5 Vegetation Index Score

The information gathered during the assessment of the mining footprint area was used to determine the Vegetation Index Score (VIS) - see ANNEX-3 for methodology and calculations. Due to variation between the different habitat units within the site, all habitat units were assessed separately. The perennial rivers, ephemeral systems with established riparian zones and ephemeral systems with weakly developed or no riparian zones were also assessed separately in order to provide an accurate assessment of the ecological integrity of each feature group. Table 30 lists the results of the assessment of each habitat unit. Table 30: Vegetation Index Score Habitat unit

Score

Class

Rocky ridges

21

B – Largely natural with few modifications

Perennial rivers (Mfolozi and Mvamanzi Rivers)

19

B – Largely natural

Ephemeral streams with established riparian zones

18

B/C – Largely natural/Moderately modified

18

B/C – Largely natural/Moderately modified

Ephemeral streams with weakly developed or no riparian zones Valley Head Seepage Wetlands

15

C – Moderately modified

Savanna Woodland

19

B – Largely natural

Transformed areas

8

E – The loss of natural habitat extensive

Motivation Rocky areas mostly undisturbed, intact, high ecological functionality, low levels of alien floral invasion place this habitat unit within Class B VIS. Well established riparian zones with isolated areas of disturbance, low levels of alien floral invasion and high levels of indigenous species recruitment places this habitat unit within Class B VIS. Established riparian zones with isolated areas of disturbance, low to moderate levels of alien floral invasion and high levels of indigenous species recruitment places this habitat unit between Class B and C VIS. Isolated areas of disturbance, low to moderate levels of alien floral invasion and high levels of indigenous species recruitment places this habitat unit between Class B and C VIS. Some evidence of subsistence agriculture, overgrazing and alien plant species invasion was noted, although overall functioning is still largely intact, placing the valley head seepage wetlands within a Class C VIS. General low levels of disturbance and alien floral invasion, high levels of indigenous species recruitment and intact vegetation structure place this habitat unit within Class B VIS. High levels of disturbance and alien floral recruitment and large areas of denuded soils place this habitat unit within Class E VIS.

119 | P a g e

2.4.5.2.6 Exotic and Invader Species

Alien invaders are plants that are of exotic origin and are invading previously pristine areas or ecological niches (Henderson, 2001). Not all weeds are exotic in origin but, as these exotic plant species have very limited natural “check” mechanisms within the natural environment, they are often the most opportunistic and aggressively growing species within the ecosystem. Therefore, they are often the most dominant and noticeable within an area. Disturbances of the ground through trampling, excavations or landscaping often leads to the dominance of exotic pioneer species that rapidly dominate the area. Under natural conditions, these pioneer species are overtaken by sub-climax and climax species through natural veld succession. This process, however, takes many years to occur, with the natural vegetation never reaching the balanced, pristine species composition prior to the disturbance. There are many species of indigenous pioneer plants, but very few indigenous species can out-compete their more aggressively growing exotic counterparts. Alien vegetation invasion causes degradation of the ecological integrity of an area, causing (Henderson, 2001):     

A decline in species diversity; Local extinction of indigenous species; Ecological imbalance; Decreased productivity of grazing pastures; and Increased agricultural input costs.

During the floral study of the mining footprint area, all exotic and weed, species were identified and are listed in Table 31. From the table it is clear that a moderate diversity of alien species is present within the mining footprint area, especially within the transformed areas. Any additional impacts associated with mining and associated infrastructure are likely to increase levels of alien floral invasion as levels of habitat disturbance will increase, which is especially significant considering the adjacent HiP and downstream iSimangaliso Wetland Park and World Heritage Site (HiP, 2011). 2.4.5.2.7 Medicinal Plant Species

Medicinal plant species are not necessarily indigenous species, with many of them regarded as alien invasive weeds. Most of the medicinal species are commonly occurring species and are not confined to the mining footprint area. Table 32 presents a list of plant species with traditional medicinal value, plant parts traditionally used and their main applications, which were identified during the field assessment. A moderate to high diversity of medicinal species is present, and it is highly likely that the local communities rely on these medicinal species as relatively few medical facilities are present in the local area. In addition, three medicinal tree species, namely Sclerocarya birrea subsp caffra, Sideroxylon inerme and Boscia albitrunca, are protected under the NFA (1998). Thus, any detrimental impact on the medicinal species associated with the mining footprint area is likely to have a significant impact on people relying on such species for medicinal use.

120 | P a g e

Table 31: Dominant exotic vegetation species identified during the assessment Species

English name

Origin

Trees/ shrubs Agave sisalana Cereus jamacaru Melia azedarach Nerium oleander Solanum mauritianum

Sisal Queen of the night Syringa Oleander Bugweed

Central America South America India Mediterranean South America

2 1 3 1 1

HU 3, 4 HU 1, 3, 4 HU 3, 4 HU 4 HU 3, 4

Opuntia ficus-indica Forbs Bidens pilosa Datura ferox Senna didymobotrya Sesbania bispinosa

Prickly pear

Mexico

1

HU 1, 2, 3, 4

Common blackjack Large thorn-apple Peanut butter cassia Spiny sesbania

South America Eurasia Tropical Africa Asia, North Africa

N/A 1 3 N/A

HU 1, 2, 3, 4 HU 3, 4 HU 4 HU 1, 3, 4

Tagetes minuta Taraxicum officinale Zinnia peruviana Grass Pennisetum clandestinum

Tall khaki weed Common dandelion Redstar zinnia

South America Europe South America

N/A N/A N/A

HU 1, 2, 3, 4 HU 2,3,4 HU 3, 4

Kikuyu

East Africa

   

Category*

2

Habitat unit

HU 3, 4

Category 1 – Declared weeds. Prohibited plants, which must be controlled or eradicated. Category 2 – Declared invader plants with a value. “Invaders” with certain useful qualities (i.e. commercial). Only allowed in controlled, demarcated areas. Category 3 – Mostly ornamental plants. Alien plants presently growing in, or having escaped from, areas such as gardens, but are proven invaders. No further planting or trade in propagative material is allowed (Henderson, 2001). HU 1 - Rocky ridge; HU 2 – Wetland and Riparian habitat; HU 3 – Savanna Woodland; HU 4 - Transformed areas

Table 32: Traditional medicinal plants identified during the field assessment. Medicinal applications and application methods are also presented (van Wyk, et al., 1997; van Wyk and Gericke, 2000; van Wyk and Wink, 2004; van Wyk et el., 2009) Species

Name

Plant parts used

Medicinal uses

Acacia karroo

Sweet thorn

Remedy for diarrhoea and dysentery.

Acacia sieberiana var. woodii

Paperbark

Bark, leaves and gum Leaves, bark and resin

Acacia nilotica

Scented pod acacia

Various parts

Aloe greatheadii var davyana Aloe marlothii

Spotted Aloe

Stems and leaves

Mountain aloe Milkweed

Leaves and roots

Asclepias fruticosa

Leaves, sometimes roots

Leaf, bark and resin are used as an astringent for colds/chest problems, diarrhoea, haemorrhage and eye inflammation. Gum used as glue. A decoction of the bark taken as a cough remedy. Other parts of the tree are used to treat eye diseases, or as a tranquillizer and even as an aphrodisiac. A root extract is used in the treatment of tuberculosis, impotence, diarrhoea, haemorrhages, toothache, dysentery and gonorrhoea. Extracts made from the leaves are used in the treatment of menstrual problems, eye infections, sores (specifically those caused by leprosy), ulcers, indigestion and haemorrhage. Decoction of powdered stems and leaf bases is taken orally twice a day after delivery to cleanse the system. Leaf and root decoctions used for roundworm infestations, stomach problems and horse sickness. Used as snuff to treat headaches and tuberculosis.

121 | P a g e

Species

Name

Plant parts used

Medicinal uses

Boscia albitrunca

Shepherd’s tree

Brak, roots, leaves

Commiphora pyracanthoides Dichrostachys cinerea

Common corkwood Sickle bush

Gum

Datura stramonium

Thornapple

The root is pounded to make porridge. It is commonly used as a substitute for coffee or chicory. The root is also used to make a beer and to treat haemorrhoids. The leaves are nutritious and are often browsed by cattle. An infusion of the leaves is used to treat eye infections in cattle. Gum boiled in water to form a soap for washing clothes, and the resin from the stem is used as a hair straightener. Root infusions have been used to treat body pain, backache, toothache, elephantiasis, syphilis, leprosy and as a styptic, diuretic, purgative and aphrodisiac. Generally as asthma treatment and pain reduction.

Dombeya rotundifolia

Wild pear

Euphorbia ingens

Sap

Euclea divinorum

Tree euphorbia Rubber hedge euphorbia Magic guarri

Mimisops obovata

Red milkwood

Bark and roots

Olea europaea subsp africana

Wild olive

Spirostachys africana

Tamboti

Dried leaves, sometimes stem and bark Latex, bark

Schotia brachypetala

Weeping boer bean

Bark and roots

Sideroxylon inerme

White miklwood Marula

Roots and bark

Tagetes minuta

Tall khaki bush

Leaves, flowers

Vernonia oligocephala

Groenamara

Leaves and twigs

Ziziphus mucronata

Buffalo thorn

Roots, bark or leaves used separately or in combination

Euphorbia tirucalli

Sclerocarya birrea subsp. caffra

Root and often stems bark, leaves and pods Leaves and rarely the green fruit Mainly bark, sometimes roots

Sap Twigs, roots

Bark, roots and leaves

Infusions are used orally or as enemas to treat internal ulcers, haemorrhoids, diarrhoea and stomach problems. If correctly applied it can be medicinally used as a purgative or for the treatment of ulcers. Regarded as a cure for sexual impotence and an antidote for snakebite. Frayed ends of twigs are used as toothbrushes and branches are good to put out veld fires with. The roots are used medicinally for the treatment of toothache, headache, convulsions, diarrhoea, infertility, bilharzia and as a purgative Decoctions prepared for treatment of gonorrhea and schistosomiasis The main use of the plant is as a hypotensive to lower blood pressure and to enhance renal function. A drop of the fresh latex is applied to a painful tooth as painkiller. The bark is used to treat stomach pains but large dosages will cause damage to the internal organs. Used to treat heartburn and hangovers. Bark and root mixtures are used to strengthen the body and purify the blood, to treat nervous heart conditions and diarrhoea, as well as for facial saunas. Used to cure broken bones, to treat fevers, to dispel bad dreams, and to treat gall sickness in stock Diarrhoea, dysentery and unspecific stomach problems are treated with the bark. Also used as a general tonic, in combatting fever and in the treatment of malaria. The repellent properties of essential oil have been known for a long time and were found to be effective in preventing sheep from becoming infected with blow-fly larvae. Many gardeners use warm water extracts of the fresh plant to keep roses and other garden plants free from insects and fungal diseases. The essential oil is used in perfumery and as a flavourant in food, beverages and tobacco. Infusions are taken as stomach bitters to treat abdominal pain and colic. Warm bark infusions (sometimes together with roots or leaves added) are used as expectorants (also as emetics) in cough and chest problems, while root infusions are a popular remedy for diarrhoea and dysentery. Decoctions of roots and leaves (or chewed leaves) are applied externally to boils, sores and glandular swellings, to promote healing and as an analgesic.

122 | P a g e

2.4.5.2.8 RDL and Protected Floral Species Assessment

An assessment considering the presence of any plant species of concern, as well as suitable habitat to support any such species, was undertaken. The complete PRECIS (Pretoria Computer Information Systems) red data plant lists for the grid references 2831BD, 2831DB and 2832AC) were acquired from SANBI (Raimondo et al., 2009; SANBI (2015)), EKZN (2000) and the KwaZulu-Natal Nature Conservation Management Amentment Act (1999). The following red data and protected species were listed for the area. Table 33: PRECIS RDL plant list (Raimondo et al., 2009; SANBI, 2015) Family

Species

English name

Threat status

Growth forms

Rare

Herb

NT

Shrub, tree

Rare

Dwarf shrub

NT

Shrub, tree

NT

Geophyte

Declining

Geophyte

QDS 2831BD ACANTHACEAE CELASTRACEAE MALVACEAE

Salpinctium natalense (C.B.Clarke) T.J.Edwards Elaeodendron transvaalense (Burtt Davy) R.H.Archer

Bushveld Saffron

Melhania polygama I.Verd.

QDS 2831DB CELASTRACEAE

Elaeodendron transvaalense (Burtt Davy) R.H.Archer

Bushveld Saffron

QDS 2832AC AMARYLLIDACEAE

Crinum acaule Baker

AMARYLLIDACEAE

Crinum stuhlmannii Baker

APOCYNACEAE

Pachycarpus concolor E.Mey. subsp. arenicola Goyder

VU

[No lifeform defined]

ASPHODELACEAE

Kniphofia littoralis Codd

NT

Herb

HYPOXIDACEAE

Hypoxis hemerocallidea Fisch., C.A.Mey. & Avé-Lall.

Star flower/ Yellow Star

Declining

Geophyte

ORCHIDACEAE

Eulophia speciosa (R.Br. ex Lindl.) Bolus

Large Yellow Eulophia

Declining

PASSIFLORACEAE

Adenia gummifera (Harv.) Harms var. gummifera

Monkey Rope

Declining

Candy-striped Crinum

Geophyte, herb, succulent Climber, succulent

NT: Near Threatened, VU: Vulnerable

The Probability of Occurrence (POC) of each of the species listed above, along with known RDL and protected species for the area according to EKZN (2000) and the KwaZulu-Natal Nature Conservation Management Amendment Act (1999) was calculated (Table 34) with reference to habitat suitability found during the assessment of the mining footprint area. Table 34: POC calculated for floral species of concern Species Salpinctium natalense

English name

Habitat Savanna, in partially shaded sites on the margins of acacia scrub. Known from one site within HiP nature reserve.

POC 0%

Elaeodendron transvaalense

Bushveld Saffron

Savanna or bushveld, from open woodland to thickets, often on termite mounds.

75%

Grassy hill slopes in Savanna.

65%

Melhania polygama

Motivation Highly unlikely to occur as this species is only known from one location in the HiP. Suitable habitat and within distribution range. Suitable habitat, especially in western parts of mining footprint area and within distribution range.

123 | P a g e

Species Crinum acaule

English name

Crinum stuhlmannii

Candy-striped Crinum

Pachycarpus concolor subsp. arenicola Kniphofia littoralis

Hypoxis hemerocallidea

Star flower/ Yellow Star

Eulophia speciosa

Large Yellow Eulophia

Bowiea volubilis

Climbing Onion

Bulbine inflata Haworthia limifolia

Fairies Washboard

Searsia kwazuluana Streptocarpus primulifolius

Cape Primrose

Warburgia salutaris

Pepper-bark Tree

Adenia gummifera

Monkey Rope

Habitat Eastern Maputaland and KwaZulu-Natal north of the Umfolozi River to southern Mozambique. Coastal grassland on arid, sandy flats. Indian Ocean Coastal Belt, Savanna. Scattered in grassland, bushveld and on sandy soils at low altitudes, in deep sand in lowveld bushveld. Grassy vegetation on stabilized dunes within 20 km of the coast.

POC 0%

Motivation Not within distribution range.

5%

Marginal habitat available, in extremities of distribution range.

0%

Not within distribution range.

St Lucia to Port Shepstone. Coastal grassland. Moist depressions, not usually in permanently waterlogged soils, 5-200 m. Occurs in a wide range of habitats, including sandy hills on the margins of dune forests, open, rocky grassland, dry, stony, grassy slopes, mountain slopes and plateaus. Appears to be drought and fire tolerant. Occupies various habitats including sand dunes, bushveld, thornveld and montane grasslands. Low and medium altitudes, usually along mountain ranges and in thickly vegetated river valleys, often under bush clumps and in boulder screes, sometimes found scrambling at the margins of karroid, succulent bush in the Eastern Cape. Occurs in bushy kloofs at the coast and inland in KwaZulu-Natal. In Gauteng, Mpumalanga and North West Province it is often found in open woodland or on steep rocky hills usually in well-shaded situations. Tolerates wet and dry conditions, growing predominantly in summer rainfall areas with an annual rainfall of 200-800 mm. Terrestrial. Not in distribution range.

0%

Not within distribution range.

80%

Suitable habitat, especially in western parts of mining footprint area and within distribution range. Suitable habitat present and within distribution range. Suitable habitat present in rocky ridges and within distribution range.

From Hectorspruit, Barberton and Mtubatuba through the Swaziland Lebombo Mountains. Probably Mozambique. Elevated grasslands along the tops of hills and ridges, often camouflaged amongst small stones and clumps of grass. Indian Ocean Coastal Belt. Sandy coastal grasslands as well as stony hilltop grasslands and woodlands. Forest. Restricted to Natal Group and Msikaba Formation sandstones, in shaded areas in forested ravines and scarp forest. Forest, Savanna.Variable, including coastal, riverine, dune and montane forest as well as open woodland and thickets.

5%

Forested ravines, forest patches and forest margins, forest scrub, miombo woodland, savanna, dune forest, on stony slopes, termitaria and littoral bush, 0-1 800 m.

15%

60%

70%

0%

5%

0%

5%

Not within distribution range. Marginal habitat available, in extremities of distribution range.

Marginal habitat available, in extremities of distribution range. No suitable habitat available. Suitable habitat available in the far easte of the MRA, in extremities of distribution range. Marginal habitat available, in extremities of distribution range.

124 | P a g e

From the above assessment, it is clear that several of the RDL and protected floral species listed for the region have a moderate to high probability of occurring within the mining footprint area, especially within the Rocky Ridge and Savanna Woodland habitat units. Furthermore, three protected tree species, namely Sclerocarya birrea subsp caffra, Sideroxylon inerme and Boscia albitrunca, were encountered which are listed as being ‘protected’ by the National Forest Act (1998). In terms of this act, protected tree species may not be cut, disturbed, damaged or destroyed and their products may not be possessed, collected, removed, transported, exported, donated, purchased or sold except under licence granted by the Department of Water Affairs (DWA) (or a delegated authority). Huernia hystrix, which is protected under the Kwazulu-Natal Nature Conservation Management Amendment Act (1999) is also present in the mining footprint area. Thus, the Rocky Ridge, intact Savanna Woodland and Wetland and Riparian habitat units are considered to be of high sensitivity in terms of RDL and protected floral species conservation. Impacts from the proposed mining activities and associated infrastructure are deemed highly likely to have a significant impact on RDL and protected floral species and habitat. 2.4.5.3 Sensitivity Mapping Figure 44 conceptually illustrates the areas considered to be of increased ecological sensitivity in relation to the proposed project. The areas are depicted according to their sensitivity in terms of faunal and floral habitat integrity and their suitability to provide habitat to faunal and floral communities. The wetland and riparian habitat unit provides niche habitat for a high diversity of floral and faunal species and acts as a very important network of migratory corridors for faunal species. Thus, this habitat unit is considered to be highly sensitive. As such, any impacts on the wetland and riparian systems associated with the mining footprint area are likely to be significant on a local and regional scale. The Rocky Ridge habitat unit provides niche habitat for a high diversity of floral and faunal species and contributes towards faunal migratory connectivity within the area and is also considered to be of high sensitivity. The ecological sensitivity and conservation value of the Savanna Woodland unit is of increased ecological significance and of high sensitivity. As mentioned, the more transformed areas of the habitat unit, while not as ecologically intact, are still moderately representative of the vegetation types they are situated in, and as such, these areas are deemed to be of moderate ecological sensitivity. Although the Transformed habitat unit is considered to be of low ecological sensitivity, edge effects from mining activities are deemed likely to have a detrimental impact on the surrounding more sensitive habitat units.

125 | P a g e

Figure 44: Floral Sensitivity Map

2.4.6 BIODIVERSITY – FAUNA 2.4.6.1 Mammals During the field assessment several mammal species were either directly or indirectly observed, namely Lepus saxatilis (Scrub Hare), Cynictis penicillata (Yellow Mongoose), Sylvicapra grimmia (Common Duiker), Crocidura mariquensis (Swamp musk shrew), Raphicerus campestris (Steenbok), Ichneumia albicauda (White tailed Mongoose), Crocuta crocuta (Spotted Hyena) and Lemniscomys rosalia (Single-striped mouse), as indicated in Table 35. According to the KZNCMAA (1999), HiP (2011) and the IUCN (2015) the above mentioned species are all considered to be non-threatened mammal species, except for Crocuta crocuta (Spotted Hyena), which is protected under the NEMBA. Table 35: Mammal species evidence and visually observed within the mining footprint area Scientific Name

Common Name

KZN Status

IUCN Status

Lepus saxatilis Cynictis penicillata Sylvicapra grimmia Crocuta crocuta Canis adustus Crocidura mariquensis

Scrub Hare Yellow Mongoose Common Duiker Spotted Hyena Side striped Jackal Swamp musk shrew

LC LC LC LC LC LC

LC LC LC LC LC LC

Raphicerus campestris

Steenbok

LC

LC

NEMBA

Protected

126 | P a g e

Scientific Name

Common Name

Ichneumia albicauda Lemniscomys rosalia

White tailed Mongoose Single-striped mouse

KZN Status

IUCN Status

LC LC

LC LC

NEMBA

LC = Least Concern

Spoor and dung encountered indicate the presence of several additional mammal species that also reside, forage or utilise the mining footprint area as a migratory corridor, especially smaller mammal species. Other mammal species which may utilise the mining footprint area and may be found in the surrounding areas are Galerella sanguine (Slender Mongoose), Caracal caracal (Caracal), Leptailurus serval (Serval), Potamochoerus larvatus (Bushpig) and Hystrix africaeaustralis (South African Porcupine). In terms of conservation the above mentioned mammal species are considered Least Concern by the KZNCMAA (1999), HiP (2011) and the IUCN (2015). Livestock such as goats and cattle were also noted within the mining footprint area. Table 36: Mammal species expected within the mining footprint area and surrounding region Scientific Name Raphicerus campestris Tragelaphus Scriptus Tragelaphus strepsiceros Canis mesomelas Cercopithecus Aethiops Caracal Caracal Leptailurus Serval Atilax paludinosus Cynictis penicillata Galerella sanguinea Ichneumia albicauda Mungos Mungo Hystrix africaeaustralis Otolemur crassicaudatus Dendromus melanotis Rhabdomys Pumilio Myosorex Sclateri Aonyx capensis Lutra maculicollis Rousettus aegyptiacus Potamochoerus larvatus Thryonomys swinderianus Genetta Tigrina

Common Name Steenbok Bushbuck Kudu Black-backed Jackal Vervet Monkey Caracal Serval Water Mongoose Yellow Mongoose Slender Mongoose White-tailed Mongoose Banded Mongoose Porcupine Thick-tailed Bushbaby Grey Climbing Mouse Striped Mouse Sclater's Tiny Mouse Shrew Cape Clawless Otter Spotted-necked Otter Egyptian Fruit Bat Bushpig Greater Cane Rat Large-spotted Genet

KZN Status LC LC LC LC LC LC LC LC LC LC LC LC LC LC LC LC THR THR THR LC LC LC LC

IUCN Status LC LC LC LC LC LC LC LC LC LC LC LC LC LC LC LC NT LC LC LC LC LC LC

LC = Least Concern; NT = Near Threatened; THR = Threatened and thus protected according to KZN Wildlife

Crocuta crocuta (Spotted Hyena), which is protected under the NEMBA was positively identified within the mining footprint area. None of the listed threatened species included in the KZNCMAA (1999) were identified within the mining footprint area. One endemic and/or threatened mammal species which may have the potential to occur in the area is the Myosorex sclateri (Sclater's Forest Shrew). This species is considered to be protected by the KZNCMAA (1999) and is endemic to the region. Furthermore, Aonyx capensis (Cape Clawless Otter) and Lutra maculicollis (Spotted-necked Otter) which are both listed as Threatened in KZN, also have a high probability of occurring, especially in and around the Mfolozi and Mvamanzi Rivers. The likelihood of other threatened mammal species being encountered within the mining footprint area is considered to be high due to the close proximity to the HiP. 127 | P a g e

From the results above, it is clear that the mining footprint area is important in terms of RDL and protected mammal conservation, especially the Mfolozi and Mvamanzi Rivers, the intact Savanna Woodland areas and the ephemeral drainage features which provide migratory corridors for mammal species moving through the mining footprint area. Consideration needs to be given to the possible impacts that the blasting and ground vibrations from mining activities may have on the elephant populations within the surrounding areas of the HiP. Elephants, in conjunction with the infrasonic calls, also emit ground waves in conjunction with these infrasonic waves. These ground waves are a replica of the infrasonic call, and are sent as seismic waves, which are able to travel through the ground more than 1.5 times further than the infrasound in air (between 16.0 to 32.0 km) (Shepard, 2003). These ground vibrations have multiple uses, from greeting fellow herd members, warning of danger to finding mates during breeding season (O'Connell-Rodwell, 2007; O'Connell-Rodwellet al., 2007; Wregeet al., 2010). Although there is limited data available to indicate the exact responses elephants have to blasting and foreign ground vibrations, it is likely that the mining activities will disturb the elephant populations in the surrounding HiP to a degree. Elephants in close proximity to the mine will likely selectively avoid the areas of the HiP near to mining activities, thus impacting upon elephant populations throughout the HiP through knock on effects of resource and space utilisation of displaced herds. Thus, it is likely that the proposed mining development will have a significant impact on not just elephant populations but overall mammal conservation in the region. 2.4.6.2 Avifauna The mining footprint area falls in the Moist Savannah Bird Habitat Biome of Southern Africa (Sinclair et al., 2002), which is considered to be prime bird habitat. Avifaunal surveys were conducted across the entire mining footprint area and all avifauna species seen or heard during the time of the field assessment were recorded. Table 37 lists all the avifaunal species identified during the assessment as well as their current IUCN status. The complete list of RDL avifaunal species occurring within the region is included in Appendix B of ANNEX-3 and complete lists of avifaunal species expected for the QDS 2527AC, 2527CA and 2527CB (South African Bird Atlas Project 2) are included in Appendix C1, C2 and C3, respectively. The mining footprint area falls within the HiP IBA (SA 060) (Birdlife South Africa, 2015). This IBA is relatively large and well conserved andseveral large raptor species are known to breed in these areas. RDL birds within this IBA area may utilise the mining footprint area for foraging purposes, especially where untransformed habitat is present. The most important RDL avifaunal species present in this IBA are listed by Birdlife SA and were included in the RDSIS calculations for the mining footprint area (Table 45). Table 37: Avifauna species recorded during the survey including IUCN RDL status Scientific Name

Common Name

IUCN Status

Merops pusillus

EuropeanLittle Bee-eater

LC

Turtur chalcospilos

Emerald-spotted Wood Dove

LC

Gyps coprotheres

Cape Vulture

VU

Vidua chalybeate

Village Indigobird

LC

Numida meleagris

Helmeted Guineafowl

LC

128 | P a g e

Scientific Name

Common Name

IUCN Status

Calendulauda sabota

Sabota Lark

LC

Prina subflava

Tawny Flanked Prina

LC

Spilopelia senegalensis

Laughing dove

LC

Ciconia episcopus

Woolly-necked Stork

LC

Aquila verreauxii

Verraux’s Eagle

LC

Urocolius indicus

Red faced mouse bird

LC

Hirundo albigularis

White throated Swallow

LC

Milvus aegyptius

Yellow-billed Kite

LC

Buphagus erythrorhynchus

Red-billed Oxpecker

LC

Phoeniculus purpureus

Green Wood Hoopoe

LC

Cuculus solitaries

Red-chested Cuckoo

LC

Terpsiphone viridis

African Paradise Flycatcher

LC

Vidua funereal

Dusky indigobird

LC

Gyps africanus

White-backed Vulture

EN

Anhinga rufa

African Darter

LC

Pternistisswainsonii

Swansons Spurfowl

LC

Streptopelia capicola

Cape Turtle Dove

LC

Circaetus cinereus

Brown Snake-eagle

LC

Lamprotornis nitens

Glossy Starling

LC

Falco biarmicus

Lanner falcon

LC

Melaenornis pammelaina

Southern Black Flycather

LC

Pycononotus tricolor

Darked Capped BulBul

LC

Vanellus armatus

Blacksmith Lapwing

LC

Lanius collaris

Common Fiscal

LC

Bubulcus ibis

Western Cattle Egret

LC

Euplectes afer

Yellow-crowned Bishop

LC

Alopochen aegyptiaca

Egyptian Goose

LC

Circaetus pectoralis

Black Chested Snake Eagle

LC

Bostrychia hagedash

Hadeda ibis

LC

Euplectes albonotatus

White Winged Widowbird

LC

Ploceus velatus

Southern Masked Weaver

LC

LC = Least Concern, NYBA = Not yet been assessed by the IUCN.

Four threatened RDL avifaunal species, namely Gypscoprotheres (Cape Vulture), Buphagus erythrorhynchus (Red-billed Oxpecker), Gyps africanus (White-backed Vulture) and Ciconia episcopus (Woolly-necked Stork) were identified within the mining footprint area during the site survey. These species were observed foraging within the mining footprint area. The likelihood that other RDL avifauna species identified and listed in the HiP IBA (SA 060) will be present on the mining footprint area is high. Bird species, along with all other fauna, in the park are protected and in the case of highly mobile bird species are likely to fly outside of the park boundaries. Threatened avifaunal species which have the potential to occur in the mining footprint area for foraging purposes but also possibly for breeding purposes, are indicated in Table 38. These avifaunal species have been compared to species known to occur within the IBA of the Hluhluwe area (BLSA, 2015).

129 | P a g e

Table 38: National Birdlife South Africa RDL avifauna species status with a POC of more than 60% National status NT

IUCN status LC

White-backed Vulture

VU

EN

100

Ciconia episcopus

Woolly-necked Stork

NT

LC

100

Aquila rapax

Tawny Eagle

VU

LC

75

Leptoptilos crumeniferus

Marabou Stork

NT

LC

75

Terathopius ecaudatus

Bateleur

NT

VU

70

Bucorvus leadbeateri

Southern Ground-hornbill

VU

VU

65

Neotis denhami

Denham's Bustard

NT

VU

65

Scotopelia peli

Pel’s Fishing Owl

THR

LC

64

Ephippiorhynchus senegalensis

Saddle-billed Stork

EN

LC

62

Trigonoceps occipitalis

White-headed Vulture

VU

VU

80

Circaetus fasciolatus

Southern Banded Snake-Eagle

VU

NT

80

Falco peregrinus

Peregrine Falcon

VU

LC

70

Polemaetus bellicosus

Martial Eagle

VU

NT

70

Sagittarius serpentarius

Secretary bird

NT

VU

75

Gyps coprotheres

Cape Vulture

VU

VU

100

Scientific Name

Common Name

Buphagus erythrorhynchus

Red-billed Oxpecker

Gyps africanus

POC % 100

VU = Vulnerable, NT = Near threatened, R = Rare, EN = Endangered, LC = Least Concerned.

From the above, it is clear that the mining footprint area provides habitat for a number of common and threatened avifaunal species. Furthermore, it is known that vultures are sensitive to acoustic disturbances (Bridgeford and Bridgeford, 2003) and therefore it is likely that mining activities could result in impacts on vulture populations within and around the mining footprint area. Impacts from blasting as well as other noises may result in nearby vultures abandoning their nests as well as non-breeding vultures avoiding the mining footprint and surrounding areas, including the areas of the HiP where noise disturbances area high. Overall avifaunal species are highly mobile and will utilise the mining footprint area both for foraging and breeding purposes throughout the year. Even though there is sufficient suitable habitat for avifaunal species in the areas surrounding the mining footprint area, these areas will most likely already inhabited by other avifaunal species and it is uncertain if these areas will be able to provide sufficient resources for species displaced by the mining activities. Within the MRA area itself, significant impacts on RDL avifaunal species and habitat will occur should the proposed mining development be approved. 2.4.6.3 Reptiles The reptile ecoregion for the mining footprint area falls is the Bushveld ecoregion (Alexander and Marais, 2008) which is situated in the lowveld northern region andstretches down the east coast of South Africa. Three reptile species were positively identified during the assessment, namely Naja mossambica (Mozambique Spitting Cobra), Varanus albigularis (Rock Monitor) and Trachylepis striata (Striped Skink). A shed skin from an unidentified snake species was also recorded during the assessment. Other reptile species expected to occur within the mining footprint area are Chamaeleo dilepis (Flap necked chameleon), Philothamnus natalensis (Natal Green Snake), Bitis arietans (Puff Adder), Agama atra (Southern Rock Agama) and Dispholidus typas (Boomslang). None of the above reptile species are considered to be threatened by the KZNCMAA (1999), HiP (2011) or the IUCN (2015). The complete list of threatened or RDL reptile species occurring within the KZN Province is included in Appendix A and C2 of ANNEX-3. 130 | P a g e

Table 39: Reptile species recorded during the survey Scientific Name

Common Name

National Status

IUCN Status

Trachylepis striata

Eastern Striped skink

LC

LC

Naja mossambica

Mozambique Spitting Cobra

LC

LC

Varanus albigularis

Rock Monitor

LC

LC

LC = Least Concern.

No RDL reptile species were identified within the mining footprint area. However, two protected reptile species, namely Python natalensis (Southern African Python) and Bradypodion setaroi (Setaro's Dwarf Chameleon) have been identified as RDL species which have a high probability to occur within the mining footprint area. These species are not listed by the IUCN but are considered threatened within the KZN Province (EKZN, 2000). These species are most likely to be restricted to areas within the vicinity of the Rocky Ridge, Riparian and Wetland habitat units within the mining footprint area. Although no Crocodylus niloticus (Nile Crocodile) were observed in the river systems within and alongside the MRA area, they cannot be excluded from the assessment. Individuals occur outside of the HiP will invariably be weary and remain hidden from easy observation. The river systems and pans within the HiP have a large population of Crocodylus niloticus, with many of these populations being located within the areas that are likely to be impacted by the mine. Furthermore, it has been noted that crocodiles are sensitive to ground vibrations, and it is likely that blasting and general mining activities may induce increased stress levels within the surrounding C. niloticus populations, both within and outside of the HiP. These increased levels could result in a decrease in breeding success as well as stress induced mortalities within the crocodile population of the HiP (Watson, 1990). Table 40: Reptile species expected to reside in this region with a threatened status which has a POC of more than 60% Scientific Name

Common Name

Regional status

IUCN Status

POC

Bradypodion setaroi

Setaro's Dwarf Chameleon

THR

NYBA

63%

Python natalensis

Southern AfricanPython

THR

NYBA

66%

THR = Threatened according to KZNwildlife and regional government, NYBA = Not yet been assessed by the IUCN (2014).

Thus, due to the close proximity to the HiP and the high likelihood of RDL reptile species occurring in the mining footprint area, impacts from the proposed mining activities and associated infrastructure are likely to have a significant impact on reptile conservation. 2.4.6.4 Amphibians According to du Preez & Carruthers (2009) the habitat associated with the mining footprint area is associated with low levels of amphibian endemism. Amphibian species encountered duringthe field assessment were Afrana angolensis (Common river frog) and Amietophrynus gutturalis (Guttural toad). These species are considered common to the region and of Least Concern (IUCN 2015). It is expected that the majority of amphibian specieslikely to occur on the mining footprint area are inhabitants of the Wetland and Riparian habitat unit.

131 | P a g e

Other common species which may occur in the mining footprint area include Ptychadena anchietae (Plain Grass Frog), Xenopus laevis (Common platanna), Cacosternum boettgeri (Common Caco), Schismaderma carens (Red toad), Tomopterna cryptotis (Tremolo sand frog), Kassina senegalensis (Bubbling kassina), Tomopterna natalensis (Natal sand frog), Tomopterna krugerensis (Knocking sand frog) and Ptychadena mossambica (Striped grass frog), none of which are considered to be threatened by the KZNCMAA (1999), HiP (2011) or the IUCN (2015). A list of protected amphibian species known to occur within the region is included in Appendix A and C3 of ANNEX-3. Table 41: Amphibian species identified within the mining footprint area Scientific names

Common name

IUCN Status

Amietophrynus gutturalis

Guttural toad

LC

Afrana angolensis

Common river frog

LC

LC = Least concern.

Although no RDL or threatened amphibian species were identified or are expected to be found within the mining footprint area, impacts from the proposed mining activities and associated infrastructure are likely to impact on amphibian diversity and abundance, especially within the riparian and wetland habitat areas. Thus the proposed development is deemed likely to pose a conservation threat to amphibian species within the mining footprint area. 2.4.6.5 Invertebrates Invertebrate habitat types in Southern Africa are divided into five major regions. The mining footprint area falls within the bushveld vegetation distribution area, which is known to contain a high invertebrate diversity. The species assemblages are generally subtropical species whose presence in Southern Africa reflects a southern extension of a range that is primarily Afrotropical (Picker et al, 2004). The invertebrate assessment conducted was a general assessment with the purpose of identifying common species and taxa in the mining footprint area. As such, the invertebrate assessment is not an indication of the complete invertebrate diversity potential of the proposed development site and surrounding area. A representation of commonly encountered families in the Insecta class that were observed during the assessment is listed in Table 42, with selected species recorded. A list of RDL invertebrate species known to occur within the region is included in Appendix A, C4 and E of ANNEX-3. Table 42: General results from the invertebrate collection and observation during the field assessments conducted Insects

Comments

Order: Lepidoptera (Butterflies & Moths) Family: Nymphalidae Subfamily: Danainae Danaus chrysippus aegyptius (African monarch) Subfamily: Nimphalinae Junonia hierta (Yellow pansy) Colias electo electo (African clouded yellow) Byblia ilythia (Spotted joker) Colotis euippe (Smoky orange tip) Family: Pieridae Eurema hecabe (Common grass Yellow) Beleonis creona (African Common White)

These are all commonly occurring species typical of the locality and habitat Visual observations

Visual observations

Visual observations

132 | P a g e

Insects

Comments

Family: Saturniidae Bunaea alcinoe (Emperor moth)

Visual observations

Order: Orthoptera (Grasshoppers, Crickets & Locusts)

These are all commonly occurring species typical of the locality and habitat

Family: Anostostomatidae Onosandrus sp Family: Gryllidae Gryllus bimaculatus (Common garden cricket) Acanthogryllus fortipes (Juvenile brown cricket) Family: Tettigoniidae Conocephalus caudalis(Meadow Katydid) Family: Acrididae Cannula gracilis(Grass mimicking Grasshopper) Order: Hymenoptera & Isoptera (Ants, Bees, Termites & Wasps) Camponotus maculatus (Spotted sugar ant) Polyrhachis gagates (Ants) Family: Apidae Apis mellifera scutellata (African honey bee) Family: Vespidae Vespula germanica (Hornet wasps) Family: Termitidae Odontotermes latericus (Harvester Termites) Order: Coleoptera (Beetles) Family: Coccinellidae Hippodamia variegata (Spotted amber lady) Cheilomenes lunata (Lunate ladybug) Family: Geotruidae Geotrupes egeriei (Earth-boring dung beetles) Thermophilum ruficornis (Two spotted ground beetle) Gymnochila varia (Gnawing beetle) Class: Gastropoda (Snail) Family: Achatinidae Archachatina sp (Land Snail)

Visual observations Visual observations Visual observations (see photos) Visual observations (see photo) These are all commonly occurring species typical of the locality and habitat Visual observations

Visual observations Visual observations These are all commonly occurring species typical of the locality and habitat Visual observations

Visual observations

Visual observations

Order: Spirobolida (Millipede) Family: Pachybolidae Centrobolus sp (Fire millipede)

Visual observations

Order: Phasmatodea (Stick insects)

These are all commonly occurring species typical of the locality and habitat

Family: Heteronemiidae Maransis rufolineatus (Grass stick insect)

Visual observations

Order: Neuroptera (Antlions)

These are all commonly occurring species typical of the locality and habitat

Family: Myreleontidae Brachyplectron sp (Antlion)

Visual observations

Order: Mantodea (Mantids)

These are all commonly occurring species typical of the locality and habitat

Family: Mantidae Sphodromantis lineola (African Praying mantis)

Visual observations

Two invertebrate species which are of conservation interest, namely Archachatina sp. (Land Snail) and Centrobolus sp. (Fire milipede) were identified in the mining footprint area (EKZN, 2000). Three additional mollusks are of interest. Chlamydephorus burnupi (Burnup’s Hunter Slug) and Chlamydephorus dimidius 133 | P a g e

(Snake Skin Hunter Slug) have been listed in the protected indigenous animals listed in Schedule 5 of the KwaZulu-Natal Nature Conservation Management Act (Act No 5 of 1999). Laevicaulis haroldi (Caterpillar Slug) has been listed in the specially protected indigenous animals listed in Schedule 4 of the KZNCMAA (1999). According to the IUCN, (2015) these three species are all threatened. Thus, the mining footprint area provides habitat for a number of common and threatened/protected invertebrate species and it is likely that the proposed mining development will have a significant impact on invertebrate conservation in the region should it be approved. 2.4.6.6 Spiders and scorpions No threatened spider or scorpion species are listed in the KZNCMAA (1999). Trapdoor and Baboon spiders are listed as threatened throughout South Africa (Dippenaar-Schoeman, 2002). Table 43 lists arachnid species identified during the site visit, namely Olurunia ocellata (Grass funnel-web

spider), Harpactira gigas (Common baboon spider), Hadogenes sp. (Flat rock Scorpion) and Pseudolychas sp. (Thick tailed Scorpion). The latter species was noted within the Rocky Outcrop Habitat Unit. The above mentioned species, excluding H. gigas (Common baboon spider) and Hadogenes sp. (Flat rock Scorpion) are non-threatened species. However, H. gigas and Hadogenes sp. are protected by the NEMBA, and Hadogenes sp. is also considered threatened within KZN (EKZN 2000). These RDL scorpion and spider species are restricted to the Rocky Ridge and the intact Savanna Woodland habitat units. Table 43: Araneae species recorded during the survey Scientific Name

Common Name

National status

IUCN status

Harpactira sp

Common baboon spider

THR

NYBA

Hadogenes sp

Flat rock Scorpion

THR

NYBA

Pseudolychas sp

Thick tailed Scorpion

LC

NYBA

Olurunia ocellata

Grass funnel-web spider

LC

LC

LC = Least Concern, NYBA = Not yet been assessed by the IUCN, THR = Threatened according to KZNwildlife and regional government.

From the results above, it is clear that the mining footprint area is important in terms of RDL and protected arachnid conservation, especially the intact Savanna Woodland areas and the Rocky Ridges. Thus, it is likely that the proposed mining development will have a significant impact on arachnid conservation in the region should it be approved. 2.4.6.7 Faunal Red Data Species Assessment Several RDL faunal species were identified during the site survey. These species scored 100% POC. Faunal species that were assessed during the calculation of the RDSIS for the site are included in Appendix 7 of ANNEX-3. Each species distribution range, habitat suitability and food availability were taken into account during the RDSIS calculation. Twenty nine (29) RDL threatened species were found to have a 60% or greaterprobability of occurring in the mining footprint area and are presented in Table 44.

134 | P a g e

Table 44: Threatened faunal species with a 60% or greater Probability of Occurrence (POC) Species

Common Name

National status

IUCN status

POC

Buphagus erythrorhynchus

Red-billed Oxpecker

NT

LC

100

Gyps africanus

White-backed Vulture

VU

EN

100

Ciconia episcopus

Woolly-necked Stork

NT

LC

100

Aquila rapax

Tawny Eagle

VU

LC

75

Leptoptilos crumeniferus

Marabou Stork

NT

LC

75

Terathopius ecaudatus

Bateleur

NT

VU

70

Bucorvus leadbeateri

Southern Ground-hornbill

VU

VU

65

Neotis denhami

Denham's Bustard

NT

VU

65

Scotopelia peli

Pel’s Fishing Owl

THR

LC

64

Ephippiorhynchus senegalensis

Saddle-billed Stork

EN

LC

62

Trigonoceps occipitalis

White-headed Vulture

VU

VU

80

Circaetus fasciolatus

Southern Banded Snake-Eagle

VU

NT

80

Falco peregrinus

Peregrine Falcon

VU

LC

70

Polemaetus bellicosus

Martial Eagle

VU

NT

70

Lutra maculicollis

Spotted-necked Otter

THR

LC

65

Aonyx capensis

African Clawless Otter

THR

LC

68

Myosorex sclateri

Sclater's Tiny Mouse Shrew

THR

NT

66

Sagittarius serpentarius

Secretary bird

NT

VU

75

Chlamydephorus burnupi

Burnup’s Hunter Slug

THR

VU

67

Chlamydephorus dimidiu

Snake Skin Hunter Slug

THR

VU

63

Laevicaulis haroldi

Caterpillar Slug

THR

EN

65

Gyps coprotheres

Cape Vulture

VU

VU

100

Archachatina sp

Land Snail

THR

NYBA

100

Centrobolus inscriptus

Fire milipede

THR

NYBA

100

Bradypodion setaroi

Setaro's Dwarf Chameleon

THR

NYBA

62

Scelotes fitzsimonsi

Skink

THR

NYBA

63

Python natalensis

Southern African Python

THR

NYBA

66

Hadogenes sp

Flat rock Scorpion

THR

NYBA

100

Harpactira gigas

Common baboon spider

THR

NYBA

100

LC = Least Concerned, EN = Endangered, VU = Vulnerable, THR = Threatened according to KZNwildlife and regional government, NYBA = Not yet been assessed by the IUCN (2014).

The species presented in Table 44 were then used to calculate the RDSIS for the mining footprint area, the results of which are presented in Table 45. Table 45: Red Data Sensitivity Index Score calculated for the mining footprint area

Red Data Sensitivity Index Score Average Total Species Score Average Threatened Taxa Score Average (Ave TSS + Ave TT/2) % Species greater than 60% POC RDSIS of Site

75 77 76 35% 56

135 | P a g e

The RDSIS assessment of the mining footprint area provided a moderately highscore of 56%, indicating a moderate to high importance in terms of RDL faunal species conservation within the region. Thus, the proposed mining development poses a significant threat to RDL and protected faunal species conservation, especially in the Mfolozi and Mvamanzi Rivers and ephemeral drainage features, the intact Savanna Woodland areas and the Rocky Ridge areas. Even if mining activities are limited to transformed areas, edge effects and general impacts associated with mining are likely to affect local and regional RDL and protected faunal communities.

2.4.7 SURFACE WATER 2.4.7.1 Locality and Background Information The MRA area is located within the Pongola to Mzimkule Water Management Area (WMA) as newly demarcated by the DWS, within secondary catchment area W2 which encompasses the Mfolozi River Basin (ref: National Water Resources Strategy-2). Note that the previous demarcation of the WMA covered a smaller area, viz. from the Usutu to the Mhlatuze River. The MRA area is located within quaternary catchments W21L, the W12G and the W23A as shown in Figure 45; however, the mining footprint area is wholly situated in the W23A and W21L and W12G is thus outside of any surface runoff impact area. The Mfolozi River downstream of the HiP is the receiving water body for outflows from the mining area.

Figure 45: Quaternary Catchment Areas

The streams in the vicinity of the mining area generally drain to the east directly towards the Mfolozi River, or in a south-eastwards direction towards the Mvamanzi River, a tributary of the Mfolozi River. To the north the perennial Ntutunga River flows into the Mvamanzi River. A well defined wetland, the Mvanzi Pan, 136 | P a g e

occurs on the Mvamanzi River’s floodplain close to the Mfolozi River on the north eastern border of the MRA area. The quaternary catchment bordering to the southwest on the MRA area, W12G, is within the Mhlatuze River catchment area, which is not affected by the proposed development. The Mhlatuze River Basin provides most of the water used in Richards Bay and surrounding urban and industrial complexes (the “City of uMhlatuze”), through the Mhlatuze Water utility company. No surface water sources will be disturbed in the Mhlatuze River catchment by mining activities. 2.4.7.2 Ecoregion The MRA area falls within the Lowveld and the North Eastern Uplands Ecoregion and is located within the W21L, the W12G and the W23A quaternary catchments. However, the Fuleni Anthracite Project footprint area is located within the North Eastern Uplands Ecoregion only and is located within the W23A quaternary catchment. Studies undertaken by the Institute for Water Quality Studies assessed all quaternary catchments as part of the Resource Directed Measures for Protection of Water Resources. In these assessments, the Ecological Importance and Sensitivity (EIS), Present Ecological Management Class (PEMC) and Desired Ecological Management Class (DEMC) were defined and serve as a useful guideline in determining the importance and sensitivity of aquatic ecosystems, prior to assessment or as part of a desktop assessment. This database was searched for the catchment of concern in order to define the EIS, PEMC and DEMC. The results of the assessment are summarised in the table below. Catchment

Resource

EIS

PESC

DEMC

W23A

Mfolozi

VERY HIGH

CLASS A

A: Highly Sensitive System

According to the ecological importance classification for the quaternary catchment, the system can be classified as a Highly Sensitive system which, in its present state, can be considered a Class A (unmodified, natural) stream. The points below summarise the impacts on the aquatic resources in the quaternary catchment W23A (Kleynhans 1999):      

The aquatic resources within this quaternary catchment have been marginally affected by bed modification. Marginal flow modifications occur within the quaternary catchment. Impacts as a result of introduced aquatic biota are very low. Impact as a result of inundation is very low. Riparian zones and stream bank conditions are considered to be moderately impacted apon by goats and human activity. Very few impacts have been created as a result of water quality modification.

137 | P a g e

In terms of ecological functions, importance and sensitivity, the following points summarise the conditions in this catchment:    

     

The riverine systems in this catchment have a very high diversity of habitat types which include wetlands and pans. The quaternary catchment has a moderate importance in terms of conservation and natural areas with special mention of flood plain lakes. Species within the quaternary catchment have a moderate intolerance to changes in flow and flow related water quality with special mention of invertebrate species. The quaternary catchment is regarded as having a very high importance for rare and endangered species conservation with special mention of Hippopotamus amphibious (Hippopotamus), Crocodylinae (Crocodiles), Brycinus lateralis (Striped Robber) and Clarias theodorae (Snake Catfish). The quaternary catchment is considered of very high importance in terms of provision of migration routes for species in the in-stream and riparian environments. The quaternary catchment has a very high importance in terms of providing refugia for aquatic community members within lakes and river channels. The quaternary catchment can be considered to have a high sensitivity to changes in water quality as re-aeration of the system is poor. The quaternary catchment can be considered to have a moderate sensitivity to changes in water flow with special mention of lakes. The quaternary catchment is of very high importance in terms of species richness with riparian zones, lakes and floodplains providing habitat to a large number of species, specifically bird species. The quaternary catchment is of moderate importance in terms of endemic and isolated species with special mention of Barbus natalensis (Scaly).

2.4.7.3 Wetlands 2.4.7.3.1 General Importance with regards to Wetland and Watercourse Conservation

The SANBI Wetland Inventory (2006) and National Freshwater Ecosystem Priority Areas (NFEPA) (2011), databases was consulted to define the aquatic ecology of the wetland or river systems close to or within the MRA area that may be of ecological importance. Aspects applicable to the MRA area and surroundings are discussed below: 

    

The MRA area falls within the Pongola to Mzimkule WMA (previously the Usuthu to Mhlathuze WMA). Each Water Management Area is divided into several sub-Water Management Areas (subWMA), where catchment or watershed is defined as a topographically defined area which is drained by a stream or river network. The subWMA indicated for the MRA area is the Mfolozi subWMA. The subWMA is not regarded important in terms of fish sanctuaries, rehabilitation or corridors. The subWMA is not considered important in terms of translocation and relocation zones for fish. The Mfolozi River extends along the northern border of the MRA area and tributaries of the river are located to the north of the MRA and mining footprint areas. The Mfolozi River is a perennial river classified as a Class A (unmodified, natural) river. It is indicated as a free flowing river and is classified as a flagship river and FEPA river. The Mvamazi River extends along the eastern border of the MRA area and tributaries of the river are located within the eastern portion of the MRA and mining footprint areas. 138 | P a g e

  



 

 

 

The Mvamanzi River is a perennial river classified as a Class A (unmodified, natural) river. It is not indicated as a free flowing river and is not classified as a flagship river or a FEPA River. Tributaries of the White Mfolozi River are located within the western portion of the MRA area. The White Mfolozi River is a perennial river classified as a Class A (unmodified, natural) river. It is not indicated as a free flowing river and is not classified as a flagship river; however, the White Mfolozi River is classified as a FEPA River. River FEPAs achieve biodiversity targets for river ecosystems and threatened fish species, and were identified in rivers that are currently in a good condition (A or B ecological category). Their FEPA status indicates that they should remain in a good condition in order to contribute to national biodiversity goals and support sustainable use of water resources. Although FEPA status applies to the actual river reach within a sub-quaternary catchment. The surrounding land and smaller stream networks within the sub-quaternary catchment need to be managed in a way that maintains the good condition (A or B ecological category) of the river reach. Tributaries of the Nseleni River are located within the southern portion of the MRA area. The Nseleni River is a perennial river classified as a Class A (unmodified, natural) river. It is not indicated as a free flowing river and is not classified as a flagship river; however, the Nseleni River is located within an Upstream WMA. Upstream WMA are sub-quaternary catchments in which human activities need to be managed to prevent degradation of downstream river FEPAs and Fish Support Areas. A wetland cluster area is located within the southern portion of the mining rights area. Wetland clusters are groups of wetlands embedded in a relatively natural landscape. This allows for important ecological processes such as migration of frogs and insects between wetlands. In many areas of the country, wetland clusters no longer exist because the surrounding land has become too fragmented by human impacts. Numerous wetland features are associated with the mining rights area. However, for the purpose of this assessment only the wetland features associated with the MRA area are discussed. All wetland features associated with the MRA area are indicated as valley floor wetlands.

139 | P a g e

Figure 46: NFEPA wetland types within the Fuleni Anthracite Project MRA area





The conditions of wetland features within the MRA area is depicted in Figure 47 and includes: o Category AB (Percentage natural land cover >75%). Includes wetland features to the north east and to the south of the MRA area. o Category C (Percentage natural land cover between 25% and 75%). Includes wetland features to the north east and to the north of the MRA area. o Category Z3 (Percentage natural land cover <25%). Includes a wetland feature to the west of the MRA area. The wetlands within the MRA area was ranked according to general importance depicted in Figure 48. o Rank 2 – Wetlands with a sub-quaternary catchment recognised by experts at the regional review workshops as containing wetlands that are good, intact examples from which to choose.

140 | P a g e

Figure 47: Wetland conditions as defined by the NFEPA wetland map

Figure 48: Ranks according to general importance

141 | P a g e



The wetland features within the MRA area are not considered important with regards the conservation of biodiversity. Expertid = 0; No importance

Figure 49: Wetlands indicated to be of importance towards biodiversity conservation (0 = no importance)



Wetland features to the south of the MRA area are indicated to be FEPA wetlands. {Wetfepa = 0: Not a wetland FEPA; Wetfepa = 1: Wetland FEPA}

Figure 50: FEPA wetlands indicated for the Fuleni Anthracite Project MRA area (1 = FEPA wetland)

142 | P a g e

  

The wetland features located within the MRA area are not shown to have sighting or breeding areas for cranes. The wetland features are not indicated as RAMSAR wetlands. The wetland features are not indicated to fall within 500m of an IUCN threatened frog point locality.

2.4.7.3.2 Importance according to the Kwa-Zulu Natal Freshwater Systematic Conservation Plan (2007)

The Kwa-Zulu Natal Freshwater Systematic Conservation Plan (2007) was consulted in order to determine whether any freshwater conservation areas will be affected by the proposed mining development. According to the database, a formally conserved freshwater catchment is located on the western boundary of the mining footprint area within the HiP. Furthermore, a freshwater catchment earmarked for conservation is located partially within the mining footprint areas in the east around the Mvamanzi system. Areas earmarked for conservation are optimal biodiversity areas required to meet biodiversity targets. 2.4.7.3.3 Wetland / Riparian System Characterisation

Wetland features within the mining footprint area were categorised with the use of the Classification System for Wetlands and other Aquatic Ecosystems in South Africa (Olliset al, 2013). From the field assessment it can be concluded that three main feature groups are present within the mining footprint area, namely valley head seeps, rivers (Mfolozi River, Mvamanzi River) and smaller drainage lines. Within the area several artificial earth dams were also observed, some of which are perennial with others that only seasonally or ephemerally hold surface water and support vegetation adapted to life in saturated soils. The results of the classification of these systems are illustrated in Table 46 to Table 48.

Figure 51: Wetlands and riparian areas associated with the mining footprint area

143 | P a g e

Table 46: Classification for the Rivers (Olliset al., 2013)

Level 1: System An ecosystem that has no existing connection to the ocean but which is inundated or saturated with water, either permanently or periodically.

Level 2: Regional Setting

Level 3: Landscape unit

The mining footprint area falls within the North Eastern Uplands and Lowveld Ecoregions and Lowveld Group 11 wetland vegetation (NFEPA WetVeg).

Valley floor: The base of a valley, situated between two distinct valley side slopes, where alluvial or fluvial processes typically dominate.

Level 4: Hydrogeomorphic (HGM) unit Longitudinal HGM Type zonation / landform Channel (river, including Lowland River: the banks): an open low-gradient, conduit with clearly defined alluvial fine-bed margins that (i) channels, which continuously or periodically may be confined, contains flowing water, or but (ii) forms a connecting link fullydeveloped betweentwo water bodies. meandering Dominant water sources pattern within a include concentrated distinct floodplain surface flow from develops in upstreamchannels and unconfined tributaries, diffuse surface reacheswhere flow or interflow, and/or there is increased groundwater flow. silt content in bed or banks.

Table 47: Classification for the Drainage Lines (Riparian and non-Riparian) (Olliset al., 2013)

Level 1: System

An ecosystem that has no existing connection to the ocean but which is inundated or saturated with water, either permanently or periodically.

Level 2: Regional Setting

Level 3: Landscape unit

The mining footprint area falls within the North Eastern Uplands and Lowveld Ecoregions and Lowveld Group 11 wetland vegetation (NFEPA WetVeg).

Plain: An extensive area of low relief characterised by relatively level, gently undulating or uniformly sloping land.

Level 4: Hydrogeomorphic (HGM) unit Longitudinal zonation / HGM Type landform / Inflow drainage Channelled valley bottom N/A wetland: a valley bottom wetland with a river channel running through it.

Table 48: Classification for the valley head seepage wetlands (Olliset al., 2013)

Level 1: System

An ecosystem that has no existing connection to the ocean but which is inundated or saturated with water, either permanently or periodically.

Level 2: Regional Setting

Level 3: Landscape unit

The mining footprint area falls within the North Eastern Uplands and Lowveld Ecoregions and Lowveld Group 11 wetland vegetation (NFEPA WetVeg).

Plain: An extensive area of low relief characterised by relatively level, gently undulating or uniformly sloping land.

Level 4: Hydrogeomorphic (HGM) unit Longitudinal zonation / HGM Type landform / Inflow drainage Valleyhead seep: a gentlyN/A sloping, typically concave wetland area located on a valley floor at the head of a drainage line, with water inputs mainly from subsurface flow (although there is usually also a convergence of diffuse overland water flow in these areas during and after rainfall events).

144 | P a g e

2.4.7.3.4 Wetland Assessment

SAS (2015) assessed the wetland features within the mining footprint in terms of the following:   

Present Ecological State (PES) Wetland Function and Service Provision Ecological Importance and Sensitivity (EIS)

From this SAS assigned a Recommended Ecological Class (REC) for the different wetland features. The results of the wetland assessment is provided in Table 49 and illustrated in Figure 52 to Figure 54. For the detail assessment, the reader is referred to ANNEX-3. Table 49: Summary of wetland assessment result and assigned REC Wetland Feature Mfolozi River Mvamanzi River Ephemeral Drainage Lines with Riparian Zone Ephemeral Drainage Lines without Riparian Zone Valley Head Seep Wetlands

Function & Service Provision High High

PES Class

EIS Class

REC Class

A/B A/B

A A

A A

Medium-High

B

A

B

Intermediate

B/C

B

B/C

Medium High

C

B

C

Figure 52: Wetland PES

145 | P a g e

Figure 53: Wetland Ecoservices

Figure 54: Wetland EIS

146 | P a g e

2.4.7.4 Water Quality 2.4.7.4.1 Mfolozi WMA

According to DWA’s Internal Strategic Perspective Document (DWA, 2004), the Mfolozi catchment is one of the few areas in the Usutu to Mhlathuze WMA in which there is a definite and serious water quality problem, as opposed to mostly potential problems in other catchments of the WMA (Primary Catchment W). Details in the document are summarised below: 





Municipal return flows from Vryheid (284 km upstream of the Fuleni Site) and settlements on State Land upstream of the Klipfontein Dam result in unacceptable poor water quality in the Dam. Eutrophication is a serious problem with the likelihood of toxic blooms threatening both human health and the ecology of the dam and the river. The Municipality has plans, but no funds, to build a facility to resolve this problem. Coal mining in the upper reaches of the catchment also impacts severely on the water quality. Leaching from the mostly abandoned coal mines in the upper catchment area decreases the pH and increases salinity. This is a problem throughout much of the northern and north-western sections of the WMA. Agricultural pollution occurs where runoff from fertilized fields transport pollutants to streams. This is prevalent in the cultivated sugar cane of the Mfolozi Flats.

The ISP study concluded as follows: 



Non-point source pollution needs to be assessed and strategies developed to curb this. This requires national, WMA and catchment level approaches to over-irrigation and excessive fertilisation. Mine licensing, operation and closure policies need to be very carefully considered and tightly managed. Staff and resources need to be allocated to achieve this.

In a publication prepared by CPH Water for a DWA/DFID Strategic Environmental Assessment in August 2002, on water quality issues in the whole of the WMA, more details of the extent and severity of water pollution are given. Coal mining in the upper reaches of the catchments is identified as causing high levels of sulphate, abnormal pH and high metal concentrations. Agricultural activities lead to high concentration of salts, nutrients, sediment, pesticides and herbicides. In addition, subsistence agriculture in many rural areas exacerbates the water quality problems with poor land management practices and over-grazing (13% of the catchment is classified as degraded, Grenfell and Ellery, 2009) leading to erosion and sedimentation of rivers. The identified problem of high E. coli counts in rural areas, ascribed to “little or no means” of water purification or sanitation is identified as leading to diseases, such as cholera. Lastly, industrial discharge cause polluted effluent which lead to acidification, salinization and may include high heavy metal content. The Bivane, Pongola, Manzane, Mkhuze and Mhlatuze Rivers (all outside of the Mfolozi Basin) are specifically mentioned in the study as experiencing pollution problems. The severe contamination of the Coastal Aquifer in the Richards Bay area is also highlighted. The White Mfolozi River catchment from below the confluence with the Sandspruit up to the confluence with the Black Mfolozi (quaternary catchments W21D to W21L) is also identified as a high-risk health area.

147 | P a g e

WSM Leshika (2015) did an evaluation of the current water quality conditions as part of the surface water impact assessment (ANNEX-4). Refer to Figure 55 that indicates the monitoring points evaluated during this assessment. WSM Leshika concluded that:    

Ten years later an evaluation of current conditions indicates that some of the ISP conclusions are no longer applicable. From historical data it appears that the highly polluted downstream effect may be dissipated over 18 km, if not less. the serious pollution due to mining in this Mfolozi Catchment, described in the ISP, has been substantially reduced since as early as 1997 and do not accurately reflect the current situation. Newer mines, developed since 2000 and complying with the legal requirements, should have less impact on surface water quality during its lifespan and also after closure, which is evident from the results downstream of more recent mines.

Figure 55: DWS monitoring points evaluated as part of the water quality assessment (WSM Leshika, 2015)

The reader is referred to Section 3.2.7 of ANNEX-3 for the full water quality assessment.

148 | P a g e

2.4.7.4.2 Water quality upstream and downstream of the MRA area

Data from current DWS water quality stations in the vicinity of the MRA area was evaluated, the following available monitoring sites (Figure 55): 



Upstream – o Black Umfolozi River: W2H025 and W2H002 o White Umfolozi River: W2H027 Downstream – o Mfolozi River: W2H010 and W2H032

The results are provided in Table 50. Note: Values marked in red indicate constituent values, similarly coloured in the columns to the left, which are exceeding the guideline values. Values marked in green indicate compliance to the guideline values, where applicable. The domestic water use guidelines are exceeded for calcium, chloride, magnesium and TDS/EC in the lower river reach. The results of the soil assessment (Rossouw Associates, 2015) indicate that high values of calcium, magnesium and sodium are present in soil samples of the Arcadia, Oakleaf Dundee and Glenrosa forms. These forms occur as single units over 40% of the approximate 3 500 ha sampled. They also manifest in complex units with other soil forms so thus occur over a relatively large area. The high concentration in surface water of the constituents listed can thus be ascribed to naturally occurring elements. Sulphate concentration, which is normally an indicator of coal mine impact, is well within the acceptable within the target domestic range at all the monitoring points. The aquatic water guidelines are exceeded for ammonia, nitrogen and phosphorous which indicate a measure of eutrophication. Information on the water quality in Lake St Lucia at the estuary is shown in Table 51. DWS sampled the water from October 1973 to May 1996 (Station W3R002Q04). As could be expected, the water is saline with high levels of sodium and chloride. Note also the high levels of almost all constituents, including sulphate at a median value of 2 490 mg/ℓ.

149 | P a g e

Table 50: Water quality results upstream and downstream of the MRA area SA Domestic Water Guidelines

Black Mfolozi R W2H025Q01 Constituent

Symbol

Measurement unit

90th Median Percentile

White Mfolozi R

W2H002Q01

W2H027Q01

Lower Mfolozi R W2H010Q01

W2H032Q01

Median

90th Percentile

Median

90th Percentile

Median

90th Percentile

Median

90th Percentile

SA Aquatic Ecosystems Water Guidelines

Target Range

CEV / acceptable

AEV / not acceptable

unit

< 1.0 < 32

1.0 - 10.00 32 - 80

> 10 < 80

mg/l

100 - 600 1 - 1.5# 30 - 100 6 - 10 50 -100 100 - 400

>600*** > 1.5 < 100 > 10 > 100 > 400

μg/l

mg/l

< 100 <1 < 30 <6 < 50 < 100

mg/l

< 200

200 - 400

> 400

μg/l

dependant on natural background

unit

Target Range

CEV / acceptable

AEV / not acceptable

<7

7 - 15

15 - 100

Inorganic constituents μg/l

Ammonia Calcium** Chloride (Domestic) / Chlorine (Aquatic) Fluoride Magnesium Nitrate Potassium Sodium

NH4 Ca

mgN/l mg/l

0.04 27.1

0.16 32.2

0.045 24.6

0.041 37

0.05 23.5

0.36 28.9

0.05 25

0.15 42.2

0.044 15.3

0.115 24.3

mg/l N

Cl F Mg NO2+NO3(N) K Na

mg/l mg/l mg/l mgN/l mg/l mg/l

47.6 0.445 14.3 0.53 2.6 33.7

57.4 0.75 21.3 0.8 3.71 43.4

50.3 0.41 16.4 0.33 1.46 35.8

74.5 0.49 25.7 0.71 2.1 52.3

33.8 0.42 15.7 0.1 1.82 27.3

44.6 0.64 21.4 0.58 4.11 40.7

57.1 0.41 18.4 0.12 1.82 46.7

116 0.6 35.2 0.6 2.66 79

70.3 0.26 12.2 0.231 3.25 58.4

99.9 0.378 17 0.407 4.12 81.5

mg/l

Sulphate

SO4

mg/l

33.8

72

37.4

76.2

27.7

53.9

16.6

33.4

15.3

28.9

Inorganic Total Nitrogen (should be average monthly summer concentration based on weekly samples) N

mgN/l

0.57

0.96

0.375

0.751

0.15

0.94

0.17

0.75

0.275

0.522

n.a.

mg/l

<0.5

0.5 - 2.5

>2.5

Phosphorus(inorganic) (should be average monthly summer concentration based on weekly samples) P

mgP/l

0.19

0.87

0.0905

0.351

0.051

0.4

0.098

0.77

0.021

0.049

n.a.

mg/l

<0.005

0.005 - 0.025

>0.025

mg/l

mg/l mg/l mg/l N mg/l

μg/l

Chlorine not measured <750 750 - 1500 1500 -2 540

Physical Properties

pH

Total Dissolved Salts Electrical Conductivity

pH

TDS EC

-

mg/l mS/m

7.7

264 42.8

7.96

369 54.4

7.7

278 43.8

8.17

400 58.4

7.77

263 37.2

8.3

361 44.1

7.81

333 46

8.4

584 83

7.9

306 48.9

8.26

437 65.9

6.0 - 9.0

mg/l

mS/m

< 450 <70

4 - 6 and 9 - 11 < 4 and > 11

450 - 2 000 70 - 300

> 2 000 > 300

variance should be less than 5% of natural background variance should be less than 5% of natural background

** No health effects - scaling problems and lathering of soap impaired at higher values *** Increased corrosion rates and salty taste at high levels but at values >1 200 fatalities may occur in infants (dehydration) # Threshold for marked dental mottling

150 | P a g e

Table 51: Water quality measured in Lake St Lucia SA Domestic Water Guidelines

CLASS

Lake St Lucia Estuary

SA Aquatic Ecosystems Water Guidelines

1

2

3

Target Range

CEV

AEV

1

2

3

unit

Target Range

CEV

AEV

μ g/l

<7

15

100

W3R002Q04 Constituent

Symbol

Median

90th 10th Percentile Percentile

Max

Min

unit

-

0.60 1 760.00 22 100.00 2.72 2 750.00 69.90 993.00 12 200.00 14 000.00

0.02 33.10 869.00 0.05 61.10 0.02 20.70 501.00 80.20

μ g/l

-

0.262

0.003

Inorganic constituents

Ammonia Calcium Chloride Fluoride Magnesium Nitrate Potassium Sodium Sulphate

NH4 Ca Cl F Mg NO2+NO3(N) K Na SO4

Phosphate

PO4

0.11 0.33 386.00 466.00 18 600.00 20 900.00 1.00 2.08 1 230.00 1 400.00 0.02 0.11 379.00 448.00 10 300.00 11 500.00 2 490.00 2 900.00 0.026

0.061

mg/l mg/l mg/l mg/l mgN/l mg/l mg/l mg/l

< 1000 < 32 < 100 <1 < 30 <6 < 50 < 100 < 200

2000 - 10000 > 10000 <1200 3.5 - 4.0 100 - 200 10 - 20 100 - 400 1000 - 5000 600 - 1000

mg/l mg/l > 100 < 400 > 20 > 400 > 5000 > 1000

mg/l

μ g/l

<0.2 <750

0.35 5 1500 2540

μ g/l

dependant on natural background

μ g/l

less than 5% variance of natural background less than 15% variance from background

Physical Properties

pH

pH

Total Dissolved Salts Total Alkalinity Electrical Conductivity

TDS TAL EC

7.72

8.25

33 800.00 37 400.00

7.17

8.52

2.11

5 240.00

47 500.00

1 730.00

< 4 and > 6.0 - 9.0 4 - 6 and 9 - 11 11

mg/l

< 450

2000 - 3000

> 3 000

mg/l

4 720.00

5 240.00

-

5 440.00

324.00

mS/m

151 | P a g e

2.4.7.4.3 Water quality in the MRA area

Figure 56 shows the provisionally identified long-term water quality monitoring points, designated “S”. During the team site visit conducted on 31 July 2013, samples were only collected at one of the “S” localities, with the other sites being dry. However, three sites were accessed where water were either flowing, or ponded in small dams. These are designated as “T” sites. On 16 June 2014 another set of three samples were collected: these were designated “FUL” sites. Note that the positions of FUL1 and T01 coincide, as well as those of FUL3 and T10. FUL2 was taken at a new position on the Mfolozi River, 2.6 km upstream of FUL1. The results of the water quality tests for the samples collected are shown in Table 52.

Figure 56: Water quality monitoring points within the MRA area

The test results show that the water, though largely natural, is not pristine. The best quality was sampled at the Mfolozi River (T01, FUL01 and FUL02). The two samples collected downstream of Ntuthunga Village (S01 and T08) exceeded drinking water limits of chloride, magnesium and sodium. This can be ascribed to the sodic nature of the naturally occurring soils which have a high sodium content, as described in the specialist report on soils (Rossouw and Ass, 2014). One of the soil samples that were collected on site measured concentrations of 6 672 mg/l Cl and 317 mg/l Na (water soluble fraction). In addition, the same sample contained 1 103 mg/l water soluble SO4.

152 | P a g e

Table 52: Water quality results for the MRA area Sampling date

31-May-13

31-May-13

31-May-13

16-Jun-14

31-May-13

Same locality Constituent

Symbol

Measurement Unit

16-Jun-14 16-Jun-14

SA Domestic Water Guidelines

SA Aquatic Ecosystems Water Guidelines

Same locality

SO1

T08

T01

FUL1

T10

FUL3

FUL2

unit

<0.003 0.406 25.7

<0.003 0.264 36.9

<0.003 0.067 23

<0.003 0.027 29.5

<0.003 0.116 95.1

<0.003 6.58 90.7

<0.003 0.049 30.2

mg/l N

2792 <0.001 1.59

1268 <0.001 0.633

32.1 <0.001 0.351

37.9 <0.001 0.176

410 <0.001 0.711

552 <0.001 0.542

39.7 <0.001 0.178

mg/l

<0.003 <0.004 146 <0.001 1850 189 <0.002 0.746

<0.003 <0.004 106 <0.001 714 69.2 <0.002 0.226

<0.003 <0.004 16.6 <0.001 29.2 16.1 <0.002 0.25

<0.003 <0.004 21.2 <0.001 44 13.9 <0.002 0.289

<0.003 <0.004 105 0.308 374 39.2 <0.002 0.708

<0.003 <0.004 116 0.838 542 21.2 <0.002 0.353

<0.003 <0.004 21.2 <0.001 43.8 15.4 <0.002 0.306

mg N/l

1.152

0.49

0.317

0.316

0.824

6.933

0.355

mg P/l

0.011

0.027

0.017

<0.008

0.092

0.028

<0.008

8.79

8.96

8.49

8.43

8.12

7.94

8.49

875

406

31.5

46.3

227

311

46.7

Target CEV / AEV / not Range/ Ideal acceptable acceptable

unit

Target Range / Ideal

CEV / Acceptable

AEV / Not acceptable

<0.03 ^ <7

0.03 -0.07 7 - 15

>0.07 15 - 100

Inorganic constituents

Aluminium Ammonia Calcium Chloride (Domestic) / Chlorine (Aquatic) Copper Fluoride

Al NH4 Ca

mg/l

Cl Cu F

mg/l

Iron Lead Magnesium Manganese Sodium Sulphate Zinc Nitrate

Fe Pb Mg Mn Na SO4 Zn NO2+NO3(N)

mg/l

Inorganic Total Nitrogen (should be average monthly summer concentration based on weekly samples) N Total Phosphorus (inorganic) (should be average monthly summer concentration based on weekly samples) P

mg/l mg/l

mg/l mg/l

mg/l mg/l mg/l mg/l mg/l mg/l

mg/l mg/l mg/l mg/l mg/l

μg/l mg/l mg/l mg/l mg/l N mg/l mg/l N

< 0.15 < 1.0 < 32

0.15 - 0.5 1.0 - 10.00 32 - 80

>>0.5 > 10 < 80

mg Al3/l

< 100 <1 <1

100 - 600 1 - 30 1 - 1.5#

>600*** > 30**** > 1.5

μg/l

< 0.1 < 10 < 30 < 0.05 < 100 < 200 < 10 <6

0.1 - 30 < 10 30 - 100 0.05 - 5## 100 - 400 200 - 400 10 - 50 6 - 10

>30 < 10 < 100 >5 >400 > 400 > 50 > 10

μg/l

μg/l μg/l

μg/l μg/l

Chlorine not measured <0.8^^ 0.8 - 1.5 1.5 -4.6 <750 750 - 1500 1500 -2 540 variance should be less than 10% of natural background <0.5 0.5 - 1.0 1.0 - 7 <180

180 - 370

370 - 1300

Dependant on natural background μg/mg

<2

2- 5

5 - 30

n.a.

mg N/l

<0.5

0.5 - 2.5

>2.5

n.a.

μg P/l

<0.005^^^

0.005 - 0.025

>0.025

Physical Properties

pH

pH

Total Dissolved Solids and TDS Electrical Conductivity EC

mg/l

mS/m

6.0 - 9.0 mg/l

** No health effects - scaling problems and lathering of soap impaired at higher values *** Increased corrosion rates and salty taste at high levels BUT >1 200 fatalities may occur in infants (dehydration) **** Acute poisoning at levels >200 # Threshold for marked dental mottling

mS/m

< 450 <70

4 - 6 and 9 11 < 4 and > 11 450 - 2 000 70 - 300

> 2 000 > 300

variance should be less than 5% of natural background μg/l

less than 15% variance from background

## Unacceptable aesthetic effects ^ For pH<6.5 ^^ For medium water hardness ^^^ TWQ range to be based on case studies and site conditions

153 | P a g e

Sample T10, collected along the road further away from habitation tested marginally better in terms of drinking water limits. The results of long term monitoring by DWS on the Mfolozi River (W2H010 and W2H032) compared well to those of the river samples T01, FUL01 and FUL02, with the values almost within drinking water target range. 2.4.7.4.4 Erosion and sediment load

Sediment transport in rivers and streams is a function of the following:  

The availability of sediment The capacity of stream flow to suspend and transport sediment

The availability of sediment depends on the land cover and land-use practises in the catchment area. Intensive grazing in the rolling hill topographical areas, coupled to deforestation that has takenplace over the years, lead to increased risk of local erosion. During high rainfall events, the streams and rivers have a higher transport capacity. Loosened sediment is then suspended and transported. The streams also exert a scour action at obstructions such as bridge piers and the outside of river bends and material will be transported until the carrying capacity is reduced (i.e. widening of riverflow reduces velocity, which typically occurs in wetlands or upper reaches of impoundments). Grenfell and Ellery (2009) found that precipitation in the catchment varies considerably in terms of quantity and timing – more variable than many other parts of the world. The seasonal runoff was thus also found to be variable, with the coefficient in variation extremely high. Since sediment transport is related to flow rate and velocity (if transportable sediment is available), the sediment load is not constant and was found to be highest in November and December. In the months of highest runoffs, the load is lower because the availability of sediment is less, with loosened sediment transported at the onset of the rain season. Sediment transport in the Mfolozi River is thus highly variable on a monthly timescale and on the droughtflood cycle in the long term. The Fuleni Anthracite Project falls within a region that is at risk of very high local erosion. The designs of surface water control systems should thus cater for increased sediment in runoff from disturbed areas by providing storage capacity in dams, and measures to clean dams when required. Also refer to Section 2.4.3.

154 | P a g e

2.4.7.5 Aquatic Assessment and Monitoring The aquatic assessment included a survey of general habitat integrity, habitat conditions for aquatic macroinvertebrates and aquatic macro-invertebrate community integrity. The protocols of applying the indices were strictly adhered to and all work was performed by a South African River Health Program (SA RHP) accredited assessor or under supervision of such an assessor. The reader is referred to ANNEX-3 which describes the assessment protocols and results in detail. Three aquatic ecological assessment point were identified which were used to define the Present Ecological State (PES) of the riverine features in the vicinity of the MRA area. Assessments were performed over two seasons, in autumn (April 2013), spring (October2013) and winter (June 2014). Assessments were thus performed at times when predominantly low and moderately high flows were experienced. The position of the points and reference site is presented in Table 53 and displayed in Figure 57. Table 53: Co-ordinates of biomonitoring reference sites

Site

GPS co-ordinates

Description

South

East

FUL1*

Site downstream on the Mfolozi River.

S 28°23’46.94’’

E 32°00’06.76’’

FUL2

Site upstream on the Mfolozi River to act as reference site for purposes of spatial comparison.

S28°22'46.88"

E31°59'49.44"

Located on the upper Mvamanzi River, atributary of the Umfolozi River.

S 28°25’58.13’’

E 32°59’28.04’’

FUL3**

* Previously FM1; ** Previously FM2

Figure 57: Aquatic ecological assessment points

155 | P a g e

2.4.7.5.1 Biomonitoring Results

The results of the aquatic assessment performed by SAS (ANNEX-3) correlates with the existing data available for the system from the DWS RQIS PESEIS database which indicates that the system has very low levels of aquatic biodiversity. Mfolozi River system 



 





The SASS data indicates that the aquatic macro-invertebrate community of the Mfolozi system prior to mining supports an aquatic community of limited abundance and diversity when compared to the reference score for a pristine Lowveld Lower Aquatic Ecoregion stream; As observed in the IHAS index this limited community diversity can be ascribed to natural limitations posed in the system by the lack of suitable habitat and cover for aquatic macroinvertebrates; It must however be noted that the conditions in the system are natural and limited impact on the aquatic ecosystem is deemed likely; It can therefore be concluded that the macro-invertebrate community of the system shows high levels of variability while still showing low levels of community diversity due to natural constraints in the system; Future SASS5 and ASPT results should be monitored and any alterations in the scores should be identified, with particular reference to potential seasonal/annual variations in SASS score which seem relatively stable in the data collected to date scores; and Streamflow reduction activities, water contamination, habitat destruction and in-stream habitat changes associated with the proposed mining activity will have a significant effect on the aquatic community within the system. Such potential impacts should be mitigated and close monitoring of trends must take place.

Mvamanzi River system 

 

 

SASS data indicates that the aquatic macro-invertebrate community has suffered a significant loss in integrity throughout the area when compared to the reference score for a pristine North Eastern Uplands ecoregion stream; SASS scores ranging between class E (severely impaired classification) according to the Dickens and Graham (2001) and class E/F according to the Dallas (2007) were reported; Flow and inadequate habitat within the system are likely to pose significant limitations on the diversity, abundance and sensitivity of the aquatic community of the system, with additional potential impact from rural settlements and livestock access to the site; The overall ASPT score indicates the absence of more sensitive taxa currently in the area; and Water quality is likely to be an additional limiting factor shaping the aquatic community within the system.

2.4.7.5.2 Ecological Importance and Sensitivity (EIS) Assessment

The EIS method was applied in order to ascertain the current sensitivity and importance of the two systems. The results of the assessment are presented in Table 54.

156 | P a g e

Table 54: Results of EIS assessment for Mfolozi and Mvamanzi River systems Biotic Determinants Rare and endangered biota Unique biota Intolerant biota Species/taxon richness

Umfolozi River

Mvamanzi River

4 0 2 1

4 0 2 1

2 2 2 2 2 4 2.1 High

3 1 3 1 1 4 2.0 High

Aquatic Habitat Determinants Diversity of aquatic habitat types or features Refuge value of habitat type Sensitivity of habitat to flow changes Sensitivity of flow-related water quality changes Migration route/corridor for instream and riparian biota Nature Reserves, Natural Heritage sites, Natural areas, PNEs RATING AVERAGE EIS CATEGORY

The EIS assessment analysis of the Mfolozi River provided a score of 2.1 which is regarded as indicating that a system is highly important and sensitive. The increased importance and sensitivity of the river is mainly as a result of the presence of protected semi aquatic species utilising the system and the system being located next to a park of national importance. The system has some importance with regards to use as a migration corridor, and the provision of refugia for species relying on the system. The system has some diversity of habitat features. The system is considered moderately sensitive to alterations in flow and flow-related water quality changes with year round water required in the system. The EIS assessment analysis of the Mvamanzi River provided a score of 2.0 which is regarded as borderline between moderate and highly important and sensitive. The increased importance and sensitivity of the stream is mainly as a result of the presence of protected species (waterfowl) utilising the system and the system being located in close proximity to a park of national importance. The system has some importance habitat diversity, and the provision of refugia for species relying on the system. The system has some diversity of habitat features. The system is considered moderately sensitive to alterations in flow. 2.4.7.5.3 Summary and Conclusions

A summary of the aquatic assessment and monitoring results is provided in Table 55. Based on the findings of this assessment it is evident that despite the limited community diversity the aquatic resources of the area are of high aquatic EIS. This is largely due to the project area being located adjacent to a conservation area (HiP) of national importance and is located upstream of the Isimangaliso Wetland Park. The potential for post-closure impacts on water quality are of concern. Unless it is considered economically feasible to treat and/or contain all potential sources of contaminated water which may affect the receiving environment post-closure indefinitely to pre-mining water quality standards in such a way as to support the post closure land use, the project is regarded as posing a very high long term impact on the region. Extensive mitigation will further be required during the construction and operational phases of the project to ensure that no impact takes place beyond the surface infrastructure footprint and an acceptable zone of edge effects. In this regard particular mention is made of the management of surface water and the dirty water area of the mine footprint.

157 | P a g e

Strict monitoring throughout the life of the mine and post-closure is required in order to ensure the health and functioning of the terrestrial, wetland and aquatic ecosystems is retained, and monitoring data must be utilised to proactively manage any identified emerging issues in a well-managed and overseen Biodiversity Action Plan (BAP). The rehabilitation of the infrastructure at closure of the mine must take place in such a way as to ensure that the post closure land use objectives are met. The wetland and aquatic resources will need to be rehabilitated in such a way as to support the larger wetland systems at the same level as those evident in the pre-mining condition. In order to meet this objective rehabilitation will need to be well planned and a suitably qualified ecologist must form part of the management team through the entire life cycle of the project and to guide the rehabilitation and closure objectives of the mine. Table 55: Summary of aquatic assessment and monitoring results Site Variable

Survey

Umfolozi River (FUL1 and FUL2)

Mvamanzi River (FUL3)

VEGRAI

Autumn/spring 2013

B/C

C

IHIA

Autumn/spring 2013

B

C

MIRAI

Combined

B

C

FRAI

Combined

D

D

Umfolozi River

Mvamanzi River

Variable

Survey FUL1

SASS (Dickens and Graham 2001)

SASS (Dickens and Graham 2001)

SASS (Dallas 2007)

FUL2

FUL3

Autumn 2013

E

E

Spring 2013

E

E

Winter 2014

E

E

Not assessed

Autumn 2013

Inadequate

Inadequate

Spring 2013

Inadequate

Inadequate

Winter 2014

Inadequate

Inadequate

Not assessed

Autumn 2013

D

E/F

Spring 2013

C

E/F

Winter 2014

A*

E/F

Not assessed

Class 1 Class 3 (No Statistically significant acute (Acute toxicity) toxicity) * High Dallas (2007) classification resulting from a very high ASPT score whilst SASS score remained low. Dickens and Graham (2001) classification considered to be more representative.

Toxicity testing

Winter 2014

158 | P a g e

2.4.7.6 Current Water Use and Sources 2.4.7.6.1 Mfolozi WMA

The Mfolozi River Basin is, after the Tugela River Basin, the second largest river basin in KwaZulu Natal. The total Secondary Catchment W2 catchment has a land area of 10 008 km2 to the river’s sea outlet. The Mfolozi River (also known as Umfolozi, uMfolozi or iMfolozi) consist of two main tributaries, the Black (Imfoloziemnyama) and White (Imfoloziemhlope) Mfolozi, both of which rise on the eastern escarpment of the Drakensberg Mountain range. The rivers flow eastward across the Zululand coastal plain and then converges to become the lower Mfolozi River that passes through the Mfolozi Flats before it reaches the Indian Ocean. The isiZulu name iMfolozi is generally considered to describe the zigzag course followed by both tributaries. According to DWA’s Internal Strategic Perspective, or ISP Report (DWA, 2004), the Mfolozi River catchment consists mostly of tribal land, with the main activity being cattle farming. There is a limited amount of afforestation in the catchment compared to the total area of the catchment (approximately 435 km 2). This is situated mostly in the upper reaches of the catchment near Vryheid, in the vicinity of Nongoma, and near the coast. There is a significant area under irrigation in the catchment, estimated at about 72 km2, with 65 km2 dryland sugarcane near the coast. Table 56 summarizes land use data obtained from WR2005. The afforested area is similar to the ISP data, while the total irrigated area of some 16 km2 is only about a quarter of the value given in the ISP document. This may be ascribed to the fact that most irrigation is opportunistic since its cultivation depends on the availability of run-of-river abstraction. Note that in hydrological terms, alien vegetation is also deemed to be a “water user” and its use is considered in river flow and dam yield modeling. Table 56: Land Use Data from WR2005 Tertiary Catchment W21 W22 W23 TOTAL

2

Forestry (km ) 117 103 214 434

2

Alien Vegetation (km ) 33.2 19.1 26.6 78.9

2

Irrigated Area (km ) 0.52 15.28 0 15.8

The water resources of the Mfolozi catchment are mostly undeveloped. The most significant development is the Klipfontein Dam which is situated in the upper reaches of the White Mfolozi River. There is an allocation to irrigators downstream of the dam, but very little of this allocation is currently utilized, as is evident from recent satellite images. A total of 18 million m3/a is transferred out of the River Basin from the lower reach of the Mfolozi River to Richards Bay Minerals. The ISP (2004) study found that (theoretically) the catchment as a whole is stressed and the water balance is minus 19 million m3/a as shown in Table 57. However, because the ecological Reserve is not currently being supplied and not accounted for in the calculations, the stressed situation is under-estimated. Once the comprehensive Reserve is determined, operating rules will need to be formulated in order to ensure 159 | P a g e

that it is met with the minimum reduction in allocations to existing lawful users and the minimum socioeconomic impacts. The water balance (Table 58) for the Mfolozi River included in the Zululand DM Water Services Development Plan (WSDP) (2013) lists the balance at minus 47 million m3/a, inclusive of the ecological reserve, river losses and others as described in the footnote. Table 57: Water Use and Provisional Water Balance

Water Resources (million m3 /a) Natural Resource Surface Water Ground Water Irrigation 36 5 5

Usable Return Flow Total Local Yield Urban Mining and Bulk 4 1 51

Water Requirments/allocations (million m3/a) Irrigation Urban Rural Mining and Bulk Afforestation Total Local Need Transfers Out 23 12 11 4 2 52 18 Reconcilliation of allocation and available water (million m 3 /a) Local Yield Tranfers In Total Local Needs Transfers Out 51 0 51 52 18

Total 70

Grand Total 70

Balance -19

3

Table 58: Zululand DM: Mfolozi catchment water balance inclusive of ecological requirements (million m /a)

Natural Resource

Available water

Usable return flow

Surface water

36

Groundwater Irrigation Urban Mining & Bulk Supply

5 5 4 1 51 0 51 51 12 11 4 2 80 18 98 -47

Total local yield* Transfers in Total available

Consumer groups Water requirements Total Local Requirements Transfers out Total Used Balance

Irrigation Urban** Rural** Mining & Bulk Industrial*** Afforestation****

Source:ZDM, WSDP (2013) * Includes allowance for impacts of the ecological component of the Reserve, river losses, alien vegetation water use, rain-fed agriculture and urban run-off on yield ** Includes allowance for basic human needs component of the Reserve (25/ℓ/c/d) ***Mining and bulk industrial water uses that are not part of the urban system **** Afforestation quantities refer to the impact on yield only

160 | P a g e

2.4.7.6.2 Community Water Use

From the above it is clear that water resource development (in the form of storage dams) would be required to fulfil the reasonable needs of all users at acceptable levels of risk of failure of supply, unless a new external source can provide in the demand. Mhlathuze Water’s area of supply covers some 37,000 km² stretching from the Thukela River in the south and up the east coast to the Mozambique and Swaziland borders, in the north-west the supply area reaches up to Paul Pietersburg and include Vryheid. Within this region, Mhlathuze Water has built and operates an inter-basin transfer, major water treatment plants, an offshore waste water disposal pipeline and it operates treatment and sewerage plants on an agency basis for local municipalities (Source: Mhlatuze Water web site). The MRA area is within the Local Mfolozi Municipality which is part of the uThungulu District Municipality (DM). The uThungulu DM is the Water Service Authority and Water Service Provider in terms of the Municipal Structures Act, Schedule 84(1)(b) and the Water Services Authority Act 108 of 1997. According to information in the WSDP (2009) of the DM, they have a household water service backlog of 47% and will develop new schemes to supply 60ℓ/cap/day. The IDP (May 2011) of the Mfolozi Local Municipality (recently renamed the Mbonambi LM) refers to a study of 2007 (“Quality of Life Survey”) which found that 48% of inhabitants use borehole water, 42% has access to piped water and the balance use rainwater, surface water in streams or rivers or water supplied by vendors. From the groundwater survey (Groundwater Complete, 2015) it was found that groundwater is probably used on site for human consumption from only three boreholes included in the hydro-census. Cattle are dependent on surface water. In addition to water in the Mfolozi River and wetlands, a number of small impoundments have been created which provides water to cattle. Rudimentary sanitation facilities (VIP or other forms of pit latrines) are provided at homesteads and evidence was found of human faeces in stream beds. The major drinking water supplies are provided by tankers which fill small reservoirs where water is collected by the villagers, or piped to standpipes in denser developments. The closest bulk piping infrastructure shown in available literature appeared in DWA’s Reconciliation Strategy document of the uThungulu District Municipality (DWA, 2011) is as follows: Water is taken from Nzesi River from where it is pumped northwards to the Nseleni Water Treatment Plant. From Nseleni WTW a pipeline deliver water to Kwambonambi. No details are shown of further bulk water reticulation. Kwambonambi is about 20 km south of the mining area. A major user of water in the catchment is the operational Somkhele Mine only 5 km across the Mfolozi River. Somkhele has a license to abstract 750 000 m3 per annum from the Mfolozi River, which is deemed sufficient for all planned future operations.

161 | P a g e

2.4.7.7 Flood Peak Assessment Figure 58 shows the major and minor drainage lines within the vicinity of the proposed project and also shows the general flow direction of the minor drainage system. Since the NWA identifies a stream as a feature where water flows, albeit intermittently, all identifiable drainage lines are shown.

Figure 58: Major and Minor Drainage Lines

Hydraulic modeling of the Mfolozi River and its tributaries was performed by means of the HEC-RAS program. The associated 1:100-year flood levels are shown on Figure 59 and Figure 60. Thereader is referred to Section 4 of the surface water specialist report (ANNEX-4) that describes the mthdology and calcultations in detail.

162 | P a g e

Figure 59: Flood-lines in the western section of the Fuleni Anthracite Project mining area

V W

Figure 60: Flood-lines in the eastern section of the Fuleni Anthracite Project mining area

163 | P a g e

2.4.8 GROUNDWATER 2.4.8.1 Hydrocensus A hydrocensus survey was conducted by Aquatico in May 2013. A total of 52 boreholes were recorded of which 3 provide groundwater in taps for drinking water purposes (FUL17, 21 and 48). The remainder of the localities recorded represents exploration boreholes drilled by the mine. Five additional borehole localities were recorded during a follow-up survey in June 2014 (HIP 01 to HIP 05), located in HiP. The follow-up survey was done to record boreholes that may represent the primary alluvial aquifer along the rivers. No boreholes were recorded closer than 500 meters from the rivers and therefore these boreholes are not representative of the primary alluvial aquifer. The positions of boreholes recorded during the hydrocensus survey are presented on the map in Figure 61. No springs were recorded during the hydrocensus.

Figure 61: Position of hydrocensus boreholes

164 | P a g e

The potential radius of influence on the groundwater regime around a coal mine in Karoo sediments is usually accepted as 1 km. This is subjective, because the radius of influence depends strongly on geological structures such as faults and dykes (preferred groundwater flow paths), groundwater gradients, nearby mining operations and the presence of other groundwater production boreholes or dewatering from mining in the area. Experience from other coal mines in similar Karoo-type aquifer conditions has, however, indicated that the influences of open pit and underground coal mining activities on the regional groundwater level are usually not very extensive and usually limited to as little as 0.2 km. Different types of groundwater information were obtained for a total of 52 points during the groundwater user survey and hydrocensus conducted in the Fuleni Anthracite Project area. No yields of the recorded boreholes were noted. Yields of newly monitoring boreholes will be determined with the aid of pump tests. 2.4.8.2 Groundwater Flow Evaluation 2.4.8.2.1 Depth to water level

Groundwater levels in the Fuleni Anthracite Project area were measured during the hydrocensus survey and in the new monitoring boreholes. Water level depths for the mining area are shown as a thematic map in Figure 62. Water levels recorded during the hydrocensus and in the new monitoring boreholes vary between 7 and 55 mbs. The groundwater levels measured during the hydrocensus surveys and in new monitoring boreholes were used as calibration points for the numerical groundwater model to verify the conceptual model and construction thereof. The highest static water level elevations are approximately 80 mamsl and occur in the topographically higher region towards the north-west of the mining area (Figure 63). The lowest static water level elevations where no impact from abstraction occurs are at approximately 10 mamsl in the downstream direction of the mining areas. The groundwater flow direction in the proposed mining areas mostly varies but is generally towards the east. Seen in the light of water level differences because of recharge effects, filtering and processing of water levels is required to remove water levels considered anomalous high or low. The final interpolated potentiometric surface of the water levels is thus bound to contain local over- or under estimations of the actual water levels but it will be representative of the general regional trend of the static groundwater level. The natural interpolated groundwater level contours (without impacts from mining / other) were estimated through Bayesian interpolation and are presented in Figure 63 as a contour map. The directions of groundwater flow are indicated in Figure 63 with the use of arrows and will always be perpendicular to the groundwater level contours.

165 | P a g e

In Karoo-type sediments like those underlying the proposed mining areas, it is generally accepted that the majority of groundwater flow occurs through the bedding plane fractures between the different sedimentary units.

Figure 62: Thematic water level map for the proposed Fuleni Anthracite Project area

166 | P a g e

Figure 63: Bayesian water levels in the Fuleni Anthracite Project mining area

2.4.8.2.2 Flow gradients

On the relatively steeper sloping hillocks where groundwater gradients are higher, groundwater seepage rates are correspondingly higher. Seepage rates on the other hand are much lower in the flat plateaus and valley bottoms. Average groundwater gradients were calculated from the water level elevation data. groundwater gradient is approximately:     

The general

Pit 1 & UG1 = 4%; Pit2 & UG2 = 8%; Pit3 & UG3 = 4%; Pit4 = 3.6%; and Pit 5, Pit6 and UG4 = 4.6%

2.4.8.2.3 Aquifer types and yield

From drilling results of the new monitoring boreholes, three possible aquifer types have been found present in the MRA area. For the purpose of this study an aquifer is defined as a geological formation or group of formations that can yield groundwater in economically useable quantities. According to this definition of an aquifer, only the weathered-fresh interface or fractures in the hard rocks below the weathered zone could be defined as aquifers. By another definition, an aquifer is a geological formation or group of formations that can yield groundwater in economical exploitable quantities. 167 | P a g e

The first aquifer system that occurs widely in Karoo sediments in South Africa is a shallow aquifer that occurs in the transitional soil and weathered bedrock zone or sub-outcrop horizon. This aquifer generally has a low yield with phreatic water levels sometimes occurring on un-weathered bedrock or clayey layers. Yields in this aquifer are low (generally less than 0.3 l/s) and the aquifer is not usable as a groundwater supply source on a continuous basis. Where consideration of the shallow aquifer system becomes important is during seepage estimations into open pit voids and mass transport simulations from mineinduced contamination sources because a lateral seepage component in the shallow water table zone in the weathered zone often occurs. According to the Parsons Classification system, the aquifer is usually regarded as a minor or even a non-aquifer system. In the Fuleni Anthracite Project area, no clear evidence was found of widespread occurrence of this aquifer type. No shallow boreholes or wells were recorded that would typically indicate the presence of this aquifer. Groundwater levels are deeper than 7 meters below surface, which is below the level where this aquifer is generally developed. The second aquifer system, and dominating one in the Fuleni Anthracite Project area, is the fractured Karoo rock-type aquifer where groundwater yields, although more heterogeneous, can be higher than the weathered zone aquifer. This aquifer system usually displays semi-confined or confined characteristics with piezometric heads often higher than the water-bearing fracture position. The aquifer forms in transmissive fractures in the consolidated and almost impervious bedrock. The fractures may occur in any of the coexisting host rocks due to different tectonic, structural and depositional processes. A third aquifer system that is present in the area is the primary alluvium aquifer developed in some areas in the immediate vicinity of the Mfolozi River and other major river systems in the Fuleni Anthracite Project area. Very little information is available for this aquifer and information is mainly provided from our conceptual understanding of the groundwater system and studies of comparative aquifer systems. No direct measurements of characteristics such as thickness, yield, hydraulic parameters etc were made. Conceptually, this aquifer is mostly recharged by the river and occurs in alluvial deposits as well as the weathered bedrock below and directly adjacent to the river. Where present, the aquifer is expected to be generally higher yielding than the secondary aquifers but sustainability depends directly on pulse-like recharge during times when sizeable flow occurs in the river. When flow in the river ceases, subsurface flow continues where alluvial deposits occur and where bedrock below the river is weathered and porous. The storage is however expected to be limited in the alluvium aquifer due to the limited extent of the aquifer. Due to the close interrelation between the alluvial aquifer and the river, the water quality in the aquifer is expected to closely resemble that of the water in the river itself. During the study it transpired that the HiP utilized groundwater from boreholes at/near the river when there was no flow in the river. We expected that the boreholes tapped the alluvial aquifer and hoped to gain information on the properties of the primary aquifer. The boreholes were visited in June 2014 (HIP0105). Water levels were measured and the water was sampled and analyzed for inorganic content. Conclusions drawn from the assessment are summarized as follows:  

The boreholes are not situated near the Mfolozi River and therefore do not intersect the alluvial aquifer – at least not as primary source. The boreholes are situated more than 500 meters from the rivers.

168 | P a g e

 

The groundwater qualities in these boreholes are similar to the qualities in the secondary fractured rock aquifer. To conclude, there is still no site specific information on the primary alluvial aquifer.

Pump tests were performed on all the new monitoring boreholes where a sufficient water column was present, whether groundwater was intersected during drilling or not. These pump tests were performed using a low yield (± 0.1 l/s) pump with the main aim of determining the transmissivity and storage characteristics of the solid geological formation – the so-called aquifer matrix. These low rate pump tests are performed instead of the more commonly used slug tests because of the much improved accuracy obtained with the pump tests, resulting in much more reliable aquifer parameters calculated from the tests. 2.4.8.2.4 Aquifer transmissivity and storativity

Aquifer transmissivity is defined as a measure of the amount of water that could be transmitted horizontally through a unit width of aquifer by the full-saturated thickness of the aquifer under a hydraulic gradient of 1. Transmissivity is the product of the aquifer thickness and the hydraulic conductivity of the aquifer, usually expressed as m2/day (Length2/Time). Storativity (or the storage coefficient) is the volume of water that a permeable unit will absorb or expel from storage per unit surface area per unit change in piezometric head. Storativity (a dimensionless quantity) cannot be measured with a high degree of accuracy in slug tests or even in conventional pumping tests. It has been calculated by numerous different methods with the results published widely and a value of 0.002 to 0.01 is taken as representative for the Karoo Supergroup sediments. The storage coefficient values calculated from the Fuleni Anthracite Projectpump tests proved to be exactly in this order of magnitude. Table 59: Aquifer parameters of monitoring boreholes

Borehole

Drawdown

Recovery

Tf

Tm

Unit

2

m /d

2

Sf

m /d

FBH03

0.6

0.1

0.009

FBH04

NA

0.2

FBH06

0.5

FBH07

NA

FBH08 Harmonic Mean

Sm

Tf

Tm

2

m /d

m /d

0.003

1.5

0.2

NA

0.003

1.4

0.1

0.1

0.005

0.009

4.9

NA

0.2

NA

0.004

2.9

0.2

NA

NA

NA

NA

3.9

NA

0.5

0.1

0.006

0.004

2.3

0.2

2

Note: Tf – Transmissivity at the start of the test, usually fracture dominated flow. Tm – Transmissivity at the end of the test, usually matrix dominated flow. Sf – Storativity at the start of the test, usually fracture dominated flow. Sm – Storativity at the end of the test, usually matrix dominated flow. NA – not accurately determinable by the specific method or test or unrealistic result.

Because aquifer hydraulic parameters (like most geological parameters) usually display a log-normal distribution it is an accepted approach to calculate the harmonic mean in preference to the arithmetic mean. These values have been calculated in Table 59 and it follows that the representative transmissivity 169 | P a g e

of the aquifer matrix (between fracture zones) in the proposed Fuleni Anthracite Projectmining area can vary between 0.1 and 0.2 with an average of 0.1 m2/d. These transmissivities calculate to a representative hydraulic conductivity of 0.005 m/d for the mining area. The representative transmissivity of the fractures in the area was in the order of 2.3 m2/day with a maximum of 5 m2/day. 2.4.8.2.5 Aquifer recharge and discharge rates

Effective recharge in the project area is estimated between 2 and 6 % of MAP. Based on this estimate the average rechargeto the entire Fuleni Anthracite Project model area (MAP = 800 mm) can vary between approximately 3 180 m3/d (1 160 000 m3/y) to 9 550 m3/d (3 490 000 m3/y). 2.4.8.2.6 Direction and rate of groundwater movement in potentially impacted areas

The pre-mining groundwater contours have been presented in Figure 63. These contours represent steady state conditions without impacts from sources or actions other than natural conditions like rivers, natural spring discharges, pans or wetland recharge areas. A large number of man-made actions could impact on the groundwater regime; including the aquifer structure, flow paths and directions, storage, discharges and recharge. Possible impacts relevant to the proposed project are discussed briefly below: Aquifer structure, flow paths and directions: During active mining and thereafter, the voids created by mining (opencast and underground) will impact on the natural groundwater movement. Mine voids destroy the in situ aquifer structures and could be compared to areas of very high (even infinitely high) transmissivity and also high storativity. Because groundwater will follow the route of least resistance, groundwater will prefer to move through the mined-out areas. Even after the mine has been closed and the mine voids have been backfilled, the transmissivity and storativity remain higher than the pre-mining natural aquifer(s). Because the Karoo rocks where mining will take place have relatively low transmissivity values, impacts on the natural flow pattern in the Fuleni Anthracite Project region are expected to be only noticeable in the immediate vicinity of the operations. The extent of the impact depends mostly on the transmissivity of the in situ aquifer material. Karoo type formations in the coal mining environment generally do not have very high in situtransmissivities, but this will be confirmed from the pump test results. Aquifer discharge: A mining and processing operation may impact significantly on the discharge of an aquifer in different ways. If mining occurs and mine dewatering is required, the natural aquifer discharge will decrease by the volume of groundwater removed by dewatering. Aquifer discharge may also increase with the use of return water dam, slurry and other dams through leakage of water to the subsurface, especially if water is imported to the project from other sources. Other factors that may decrease the aquifer discharge are compacted surfaces, haul roads and concrete surfaces that prevent infiltration to the aquifer and decrease groundwater discharge, although increasing surface runoff. After mine closure, however, recharge will be higher to the area and after the mine has filled up, the discharge to surface will also be higher than before the disruption by mining. Aquifer recharge: All the aspects mentioned under aquifer discharge apply to aquifer recharge. Opencast and bord-&-pillar mining usually causes an increase in aquifer recharge percentage.

170 | P a g e

2.4.8.3 Groundwater Quality Evaluation 2.4.8.3.1 Hydrocensus boreholes

During the hydrocensus several groundwater samples were taken for quality analysis. Eighteen localities were analysed. These localities were selected to give a good distribution of points over the proposed mining area. A map showing the distribution of the hydrocensus borehole positions where groundwater quality information is available is presented in Figure 64.

Figure 64: Distribution of hydrocensus localities with water quality information

171 | P a g e

The groundwater quality data of the hydrocensus points was interpreted with the aid of diagnostic chemical diagrams and by comparing the inorganic concentrations with the South African Drinking Water Guidelines for Domestic Use. The first step in the water quality interpretation was to classify the groundwater quality. The classification was based on the following:  

the spatial distribution of the monitoring points, and the proximity of the monitoring points to certain known pollution sources that are expected to impact on the groundwater and / or surface water in the downstream flow direction.

The four main factors usually influencing groundwater quality are:    

annual recharge to the groundwater system; type of bedrock where ion exchange may impact on the hydrogeochemistry; flow dynamics within the aquifer(s), determining the water age; and source(s) of pollution with their associated leachates or contaminant streams.

Where no specific source of groundwater pollution is present upstream of the borehole, only the other three factors play a role. Water qualities are compared to the SANS241:2011 standards for drinking water. SANS 241:2011 Class 1 Recommended

Class 2 Maximum

0 - 0.3

0.3 - 0.5

> 0.5

Calcium

No Guide

No Guide

No Guide

Chloride

0 - 300

300 - 600

> 600

Fluoride

0 – 1.5

0 – 1.5

>1.5

2

2

>2

Magnesium

No Guide

No Guide

No Guide

Manganese

0 - 0.5

0.5 – 1

>1

Nitrate

0 - 11

11 - 20

> 20

pH

5 - 9.7

9.7 - 10

< 5, > 10

No Guide

No Guide

No Guide

Sodium

0 - 200

200 - 400

> 400

Sulphate

0 - 500

500 - 600

> 600

TDS

0 - 1200

1200 - 2400

> 2400

Chemical Parameter Aluminium

Iron

Potassium

Class 0 Ideal mg/l

172 | P a g e

Table 60: Groundwater qualities in the hydrocensus boreholes compared to drinking water standards (SANS241:2011) FUL03

FUL04

FUL09

FUL12

FUL17

FUL18

FUL21

FUL26

FUL33

FUL34

FUL35

FUL37

FUL44

FUL48

FUL50

FUL53

FUL55

Aluminium

0.017

<0.003

<0.003

0.028

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

0.81

0.012

<0.003

<0.003

<0.003

0.825

<0.003

Calcium

24

112

80.1

3.93

24.7

8

25.9

20.4

46.6

12.8

2.19

152

43.4

25.5

23.2

21.3

34.7

Chloride

158

222

504

204

84.1

340

83.9

207

170

38.6

50.2

2846

434

84.6

2855

186

1387

Fluoride

1.81

0.546

0.728

0.952

0.455

1.89

0.486

0.952

0.444

0.489

0.998

1.55

0.389

0.474

1.06

2.53

4.06

Iron

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

2.08

0.139

<0.003

<0.003

<0.003

<0.003

9.81

<0.003

Magnesium

12.9

120

171

1.06

24.6

0.247

26.2

16.5

28.6

11.8

2.11

129

10.8

25.7

119

23.5

14.7

Manganese

0.007

0.012

0.363

<0.001

<0.001

<0.001

<0.001

<0.001

0.103

0.153

<0.001

0.429

<0.001

<0.001

<0.001

0.437

<0.001

Nitrate

0.418

9.22

1.35

0.188

0.185

0.134

0.182

0.477

0.154

0.117

8

0.269

0.613

0.183

0.444

0.091

0.144

pH

7.6

7.42

7.39

9.3

8.23

8.8

8.18

8.32

7.62

8.05

10

8.18

7.56

8.19

8.91

6.87

8.06

Potassium

3

2.29

3.51

9.31

5.25

2.18

5.66

3.52

4.62

4.92

13.2

17.7

2.62

4.87

12.1

8.43

8.08

Sodium

136

114

309

131

73.5

307

74

277

238

70.3

110

1620

326

82.7

1894

257

920

Sulphate

6.54

72.5

73.5

0.358

25.4

237

24.7

46.8

10.1

<0.04

7.55

48.8

121

24.4

202

<0.04

<0.04

TDS

476

959

1696

380

345

916

343

817

798

290

338

5305

1021

356

5466

809

2547

173 | P a g e

Groundwater qualities measured in the hydrocensus boreholes are not of good quality and the chemical elements often exceed ideal and maximum permissible limits for drinking water. The TDS is a measure of inorganic salts dissolved in the water. At high concentrations the overall salinity can have adverse health effects on the groundwater users if used for drinking water. Elevated TDS concentrations are observed especially in the boreholes to the south of the proposed mining area. The maximum permissible limits for drinking water were exceeded in 5 boreholes. The measured TDS concentrations varied from 290 to 5470 mg/l. Groundwater pH under natural conditions is affected by the geology and geochemistry of the host rocks. At very low pH levels dissolved toxic metal ions are present which can lead to severe health problems if consumed. At low pH levels (less than ± 4.5) the water will have a sourly taste. At high pH levels there is a health hazard due to the de-protonated species. Water which has a high pH will have a soapy taste. The pH in the hydrocensus boreholes varies from 6.87 to 10. Overall basic pH conditions exist in the Fuleni Anthracite Projectarea. The pH value in FUL35 is on the boundary between ideal and maximum permissible limits. Calcium and magnesium are usually coexisting cations in natural groundwater. These two elements are the main cations responsible for the hardness in water when bound with the bicarbonate anion. The major effect of high concentrations is scaling problems in especially heating appliances. These two elements will have no or little effect in terms of health on the consumer. Magnesium can lead to diarrhea in some users. For the SANS241:2011 standards no guides are provided for the magnesium and calcium concentrations, but these two elements will however be discussed in this report. The magnesium and calcium concentrations in all of the boreholes are low. No guide for magnesium exists in the SANS241:2011 drinking water guidelines. Sodium is an alkali metal and when reacting with water it forms highly soluble, positively charged sodium ions. At high concentrations the water will have a salty taste and can lead to the disturbance of the electrolyte balance in the human body. Sodium concentrations in the hydrocensus boreholes are high, exceeding ideal limits for drinking water in 6 boreholes and the maximum permissible limits in 5 boreholes. The sodium concentration in the hydrocensus boreholes varies from 70 to 1895 mg/l. Chloride concentration at high concentration will give a very salty taste to the water. Nausea and disturbance of the electrolyte balance can occur which can eventually lead to dehydration. The chloride concentration exceeds ideal limits for drinking water in 5 boreholes and maximum permissible limits also in 5 boreholes. Chloride concentrations vary from 50 to 2855 mg/l. The elevated salt concentrations are most likely to be as a result of salt spray from the Indian Ocean. The distribution of the salt content is dependent on several factors of which the most important is paleo- and current wind directions, storms and other climate factors. The direct impact of salt spray will be deposition of salt on the ground and thus result in elevated salt content recharge to the aquifers, (Van Wyk, 1963). The main effects of aluminium are aesthetic and currently no adverse impacts on health have been confirmed. The maximum permissible limits for aluminium in drinking water have been exceeded in 2 boreholes. Fluoride at high concentrations can cause severe tooth damage and even skeletal fluorosis. Fluoride concentrations exceed maximum permissible limits for drinking water in 6 of the hydrocensus boreholes. The fluoride concentrations vary from 0.38 to 4.9 mg/l. 174 | P a g e

Elevated iron concentration mostly has aesthetic impacts but can also at very high concentrations have an effect on the health of users. The maximum permissible limits for iron concentrations in terms of drinking water have been exceeded in 3 of the hydrocensus boreholes. No mining or other activities are present in the area and the groundwater therefore exists under steady state conditions. The relatively poor groundwater quality (high sodium/chloride content) in some of the boreholes is therefore a result of natural causes (Van Wyk, 1963). The main reason for the domination of chloride and sodium is considered to be salt spray from the nearby ocean. Onshore winds carry salt spray inland and the (sea) salt is deposited through different processes. The deposited salt concentration will be highest at the coast and decrease inland but the position and gradient of deposition depend on various factors of which wind, climate and humidity are the most important. The deposited salt causes salinization of soil and surface water, which is in turn leached into groundwater and ends up in surface run-off. Apart from the salt sea spray contribution, the low aquifer properties and compartmentalization due to dolerite dyke and sill intrusions are expected to contribute to the elevated inorganic salinity in some areas. In the majority of the samples where high salinities occur, the dominant ions are sodium and chloride but fluoride are also elevated, confirming the salt spray origin of the salinity. It should be noted that the water quality of the drinking water (FUL17, FUL21 and FUL48) is good with all chemical parameters within ideal limits for drinking water. Table 61: Groundwater qualities in the HiP hydrocensus points Constituent

HIP 01

HIP 02

HIP 03

HIP 05

Aluminium

<0.003

<0.003

<0.003

<0.003

Calcium

63

165

221

21

Chloride

340

1563

2107

349

Fluoride

0.373

0.435

0.546

4.9

Iron

<0.003

<0.003

0.259

3.9

Magnesium

56

152

202

18

Manganese

<0.001

0.437

<0.001

<0.001

Nitrate

3.3

0.444

0.421

0.455

pH

7.2

7.5

7.0

7.4

0.784

10

23

6.1

Sodium

202

661

854

241

Sulphate

24.1

63.3

87.1

36.8

TDS

935

2902

3807

808

Potassium

The boreholes recorded during the second hydrocensus (HIP01-HIP05) display similar qualities and types of groundwater than the boreholes recorded during the first hydrocensus. The second survey was specifically conducted to see if there are any boreholes within close proximity to the rivers that may represent the primary alluvial aquifer. However, the closest borehole to the river was HIP02, situated 580 meters from the closest river. The 5 boreholes located during the second hydrocensus do not represent the alluvial aquifer. 175 | P a g e

One of the most appropriate ways to interpret the type of water at a sampling point is to assess the plot position of the water quality on different analytical diagrams like a Piper, expanded Durov and Stiff diagrams. Of these three types, the expanded Durov Diagram probably gives the most holistic water quality signature. The characteristics of the different fields will be discussed briefly:   

 

  



Field 1: Fresh, very clean recently recharged groundwater with HCO3- and CO32- dominated ions. Field 2: Field 2 represents fresh, clean, relatively young groundwater that has started to undergo Mg ion exchange, often found in dolomitic terrain. Field 3: This field indicates fresh, clean, relatively young groundwater that has undergone Na ion exchange (sometimes in Na-enriched granites or other felsic rocks) or because of contamination effects from a source rich in Na. Field 4: Fresh, recently recharged groundwater with HCO3- and CO32- dominated ions that has been in contact with a source of SO4 contamination or that has moved through SO4 enriched bedrock. Field 5: Groundwater that is usually a mix of different types – either clean water from fields 1 and 2 that has undergone SO4 and NaCl mixing/contamination or old stagnant NaCl dominated water that has mixed with clean water. Field 6: Groundwater from field 5 that has been contact with a source rich in Na or old stagnant NaCl dominated water that resides in Na rich host rock/material. Field 7: Water rarely plots in this field that indicates NO3 or Cl enrichment or dissolution. Field 8: Groundwater that is usually a mix of different types – either clean water from fields 1 and 2 that has undergone SO4, but especially Cl mixing/contamination or old stagnant NaCl dominated water that has mixed with water richer in Mg. Field 9: Old or stagnant water that has reached the end of the geohydrological cycle (deserts, salty pans etc) or water that has moved a long time and/or distance through the aquifer or on surface and has undergone significant ion exchange because of the long distance or residence time in the aquifer. Mg

Expanded Durov Diagram

Ca T.Alk

Anions: HCO3SO4 Cl + NO3

SO4

Na+K

1

2

3

4

5

6

7

8

9

Cl+NO3

Cations:

Ca

Mg Na + K

176 | P a g e

Another way of presenting the signature or water type distribution in an area is by means of Stiff diagrams. These diagrams plot the equivalent concentrations of the major cations and anions on a horizontal scale on opposite sides of a vertical axis. The plot point on each parameter is linked to the adjacent one resulting in a polygon around the cation and anion axes. The result is a small figure/diagram of which the geometry typifies the groundwater composition at the point. Groundwater with similar major ion ratios will show the same geometry. Ambient groundwater qualities in the same aquifer type and water polluted by the same source will for example display similar geometries. The expanded Durov diagram and stiff diagrams indicates a very prominent domination of sodium on the cation side. The anion side is dominated by bi-carbonate alkalinity or chloride (Figure 65 and Figure 66). In summary:    

  

Groundwater in the hydrocensus boreholes generally does not display good quality. Several chemical parameters exceed the ideal and maximum permissible limits for drinking water. Elevated chloride and sodium concentrations are observed in the groundwater. This high sodium and chloride salinity is considered to be the direct impact of salt spray from the ocean. The deposition of transport salt (in sea spray) on the land surface, plant foliation and surface water leads to a relatively saline soils, surface water and groundwater environment in spite of high rainfall and aquifer recharge. The ambient groundwater quality varies significantly due to aquifer heterogeneity. The groundwater used for drinking water purposes does however display good qualities and is suitable for human consumption. The stiff and expanded Durov diagrams indicate clear domination of sodium cations and either bicarbonate alkalinity or chloride anion domination.

Expanded Durov Diagram Mg

HIP 05 HIP 03 HIP 02 HIP 01 FUL55 Ca T.Alk

Na+K

FUL53 FUL50 FUL48 FUL44 FUL37 FUL35 FUL34 FUL33

SO4

FUL26 FUL21 FUL18 FUL17 FUL12

Cl+NO3

Figure 65: Expanded Durov diagram of hydrocensus groundwater qualities

177 | P a g e

STIFF Diagrams FUL12 Na+K

FUL17

20130529 - 00h00

Cl+NO3

Na+K

20130529 - 00h00

FUL18 Cl+NO3

Na+K

20130529 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

100

100

100

100

100

m eq/l

FUL21 Na+K

m eq/l

FUL26

20130529 - 00h00

Cl+NO3

Na+K

20130529 - 00h00

m eq/l

100

FUL33 Cl+NO3

Na+K

20130529 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

100

100

100

100

100

m eq/l

FUL34 Na+K

m eq/l

FUL35

20130529 - 00h00

Cl+NO3

Na+K

20130529 - 00h00

m eq/l

100

FUL37 Cl+NO3

Na+K

20130529 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

100

100

100

100

100

m eq/l

m eq/l

m eq/l

100

STIFF Diagrams FUL44 Na+K

FUL48

20130529 - 00h00

Cl+NO3

Na+K

20130529 - 00h00

FUL50 Cl+NO3

Na+K

20130529 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

100

100

100

100

100

m eq/l

FUL53 Na+K

m eq/l

FUL55

20130529 - 00h00

Cl+NO3

Na+K

20130529 - 00h00

m eq/l

100

HIP 01 Cl+NO3

Na+K

20140605 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

100

100

100

100

100

m eq/l

HIP 02 Na+K

m eq/l

HIP 03

20140605 - 00h00

Cl+NO3

Na+K

20140605 - 00h00

m eq/l

100

HIP 05 Cl+NO3

Na+K

20140605 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

100

100

100

100

100

m eq/l

m eq/l

m eq/l

100

Figure 66: Stiff diagrams of hydrocensus groundwater qualities

2.4.8.3.2 New monitoring boreholes

Eight new monitoring boreholes were drilled within the proposed Fuleni Anthracite Project area. All eight of these boreholes have been sampled and analysed. A map indicating the distribution of the new monitoring boreholes, where groundwater quality information is available, is presented in Figure 67. 178 | P a g e

Figure 67: Position of new monitoring boreholes

Once again the groundwater quality data of the monitoring points was interpreted with the aid of diagnostic chemical diagrams and by comparing the inorganic concentrations with the South African Drinking Water Guidelines for Domestic Use. Table 62: Groundwater qualities in the new monitoring boreholes compared to drinking water standards FBH03

FBH06

FBH08

FBH04

FBH05

FBH02

FBH01

FBH07

Aluminium

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

Calcium

56.4

125

106

121

134

86.7

267

39.3

Chloride

360

683

692

739

700

1682

5713

201

Fluoride

3.5

0.524

0.694

0.555

0.433

3.06

0.773

0.836

Iron

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

<0.003

Magnesium

47.8

91.2

242

107

104

59.5

495

53

Manganese

<0.001

0.246

0.051

0.617

0.781

0.016

<0.001

0.006

Nitrate

0.359

0.302

4.26

0.468

0.406

0.252

0.188

14.3

pH

7.6

7.29

7.42

7.29

7.37

7.61

7.24

7.4

Potassium

2.18

8.65

2.83

10.7

16.7

6.91

21

1.48

Sodium

387

607

438

612

558

1173

2498

283

Sulphate

37.8

8.84

118

140

155

2.2

312

80.5

TDS

1345

2051

2168

2172

2083

3261

9661

1089

179 | P a g e

Groundwater qualities measured in the new monitoring boreholes are of poor quality and the chemical elements often exceed ideal and maximum permissible limits for drinking water. Elevated TDS concentrations are observed in all the boreholes. The ideal limits for drinking water were exceeded in five boreholes and the maximum permissible exceeded in 2 boreholes. The measured TDS concentrations varied from 1089 to a very high 9661 mg/l. The pH in the monitoring boreholes varies from 7.24 to 7.6. Overall near neutral pH conditions exist in the Fuleni Anthracite Project area. All pH levels are within ideal limits for drinking water. The magnesium and calcium concentrations in all of the boreholes are low. No guide for magnesium exists in the SANS241:2011 drinking water guidelines. Sodium concentrations in the monitoring boreholes are high, exceeding ideal limits for drinking water in 2 boreholes and the maximum permissible limits in the other 6 boreholes. The sodium concentration in the monitoring boreholes varies from 280 to 2500 mg/l. The chloride concentration in the monitoring boreholes is once again elevated. The chloride concentration exceeds ideal limits for drinking water in FBH03 and maximum permissible limits also in 6 of the other monitoring boreholes. Chloride concentrations vary from 200 to 5713 mg/l. Fluoride concentrations exceed maximum permissible limits for drinking water in FBH03 and FBH02. The fluoride concentrations vary from 0.43 to 3.5 mg/l. The expanded Durov diagram and stiff diagrams indicates a very prominent domination of sodium on the cation side. The anion side is dominated by bi-carbonate alkalinity or chloride (Figure 68 and Figure 69). In summary:       

Groundwater in the monitoring boreholes does not display good qualities, Several chemical parameters exceed the ideal and maximum permissible limits for drinking water, The most notable are the domination of the macro element content by sodium and chloride. The direct impact of salt spray from the ocean is considered to be the cause of the salinity in the aquifers. The stiff and expanded Durov diagrams indicate clear domination of sodium cations and either bicarbonate alkalinity or chloride anion domination. Although the groundwater qualities are generally poor, they represent natural qualities and not groundwater affected by contamination sources. These qualities thus represent the baseline from which any project will depart and against which any impact should be measured.

180 | P a g e

Expanded Durov Diagram Mg

Ca T.Alk

FBH08

Na+K

FBH07 FBH06 FBH05 FBH04 FBH03 FBH02 FBH01

SO4

Cl+NO3

Figure 68: Expanded Durov diagram of monitoring boreholes groundwater qualities

STIFF Diagrams FBH01 Na+K

20131218 - 00h00

FBH02 Cl+NO3

Na+K

20131218 - 00h00

FBH03 Cl+NO3

Na+K

20131218 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

180

180

180

180

180

meq/l

FBH04 Na+K

20131218 - 00h00

meq/l

FBH05 Cl+NO3

Na+K

20131218 - 00h00

meq/l

180

FBH06 Cl+NO3

Na+K

20131218 - 00h00

Cl+NO3

Ca

Alk

Ca

Alk

Ca

Alk

Mg

SO4

Mg

SO4

Mg

SO4

180

180

180

180

180

meq/l

FBH07 Na+K

20131218 - 00h00

meq/l

Cl+NO3

Na+K

20131218 - 00h00

Alk

Ca

Alk

Mg

SO4

Mg

SO4

180

180

meq/l

180

Cl+NO3

Ca

180

meq/l

FBH08

meq/l

180

Figure 69: Stiff diagrams of monitoring boreholes groundwater qualities

181 | P a g e

2.4.9 AIR QUALITY 2.4.9.1 Baseline Air Quality The Fuleni Anthracite Project is located in rural areas where the population density is very low. There are no large industries or activities in the surrounding region, expect for the Somkhele Mine located 10 km to the north-east of the beneficiation plant area. The vegetation in the mining rights area of CoAL is located within the coast-hinderland bushveld, consisting out of grasslands and bushveld. The site is also closely related to the Natal Lowveld. Based on the site visit and 1:50 000 topographical map the following sources of air pollution have been identified:     

Agricultural activities; Vehicle entrainment and exhaust gas emissions; Domestic fuel burning; Fugitive emissions from mining operations; and Veld Fires.

A qualitative discussion on each of these source types is provided in the subsections which follow. 2.4.9.1.1 Agriculture

Agricultural activity can be considered a significant contributor to particulate emissions, although harvesting and other activities associated with field preparation are seasonally based. The majority of the agricultural activities are however on small scale and and are likely to only have a very small localised effect. 2.4.9.1.2 Vehicles

The force of the wheels of vehicles travelling on unpaved roadways causes the pulverisation of surface material. Particles are lifted and dropped from the rotating wheels, and the road surface is exposed to strong air currents in turbulent shear with the surface. The turbulent wake behind the vehicle continues to act on the road surface after the vehicle has passed. The quantity of dust emissions from unpaved roads varies linearly with the volume of traffic (USEPA, 1996). Due to the nature of both industrial and agricultural activity, road networks can often be of a temporary nature, and are thus unpaved. An extensive unpaved road network exists in the area and the proposed rout options are in the majority unpaved and only some sections will be paved on the commencement of the project. Exhaust tailpipe emissions from vehicles is a significant source of particulate emissions and can be grouped into primary and secondary pollutants. Primary pollutants which are CO2, CO, hydrocarbons, SO2, NOX, particulates and lead are those emitted directly into the atmosphere and secondary pollutants which are nitrogen dioxide, ozone which is a photochemical oxidant, hydrocarbons, sulphuric acid, sulphates, nitric acid and nitrate aerosol are those formed in the atmosphere as a result of chemical reactions. Toxic hydrocarbons include acetylaldehyde, benzene and formaldehyde, carbon particles, sulphates, aldehydes, alkanes, and alkenes.

182 | P a g e

2.4.9.1.3 Domestic fuel burning

It is anticipated that certain low income households in the area are likely to use wood and electricity for space heating and/or cooking purpose. The problems facing South Africa around the impact of air pollution generated indoors as a result of the use of wood are not unique. Similar problems are reported around the world in poor communities which either lack access to electricity or lack the means to fully utilise the available supply of electricity (Van Horen et al. 1992). Globally, almost 3 billion people rely on biomass (wood, charcoal, crop residues, and dung) as their primary source of domestic energy. Exposure to indoor air pollution (IAP) from the combustion of solid fuels is an important cause of morbidity and mortality in developing countries. Biomass and coal smoke contain a large number of pollutants and known health hazards, including particulate matter, carbon monoxide, nitrogen dioxide, sulphur oxides (mainly from coal), formaldehyde, and polycyclic organic matter, including carcinogens such as benzo[a]pyrene (Ezzati and Kammen, 2002). Monitoring of pollution and personal exposures in biomass-burning households has shown concentrations are many times higher than those in industrialized countries. The latest South African National Ambient Air Quality Standards, for instance, required the daily average concentration of PM10 (particulate matter < 10µm in diameter) to be < 180 µg/m3 (annual average < 60 µg/m3). In contrast, a typical 24-hr average concentration of PM10 in homes using biofuels may range from 200 to 5000 µg/m3 or more throughout the year, depending on the type of fuel, stove, and housing. Concentration levels, of course, depend on where and when monitoring takes place, because significant temporal and spatial variations may occur within a house. Field measurements, for example, recorded peak concentrations of 50000 µg/m3 in the immediate vicinity of the fire, with concentrations falling significantly with increasing distance from the fire. Overall, it has been estimated that approximately 80% of total global exposure to airborne particulate matter occurs indoors in developing nations. Levels of CO and other pollutants also often exceed international guidelines (Ezzati and Kammen, 2002). 2.4.9.1.4 Fugitive emissions from mining operations

Potential sources of fugitive dust emissions (PM10 and DUST) are released from these sources; material handling operations, vehicle entrainment by haul vehicles, windblown dust from tailings dams and oxides of nitrogen (NOX) and carbon monoxide (CO) which are produced during mining operations. Fugitive dust emissions released during mining operations are generally only of concern within 3 - 5 km of the mine boundary. The only mine in the region is the open cast coal mine on the opposite side of the Mfolozi River. The emissions from this site can blow over into the MRA area of the Fuleni Anthracite Project. 2.4.9.1.5 Veld fires

A veld fire is a large-scale natural combustion process that consumes various ages, sizes, and types of flora growing outdoors in a geographical area. Consequently, veld fires are potential sources of large amounts of air pollutants that should be considered when attempting to relate emissions to air quality. The size and intensity, even the occurrence, of veld fires depend directly on such variables as meteorological conditions, the species of vegetation involved and their moisture content, and the weight of consumable fuel per hectare (available fuel loading).

183 | P a g e

Once a fire begins, the dry combustible material is consumed first. If the energy released is large and of sufficient duration, the drying of green, live material occurs, with subsequent burning of this material as well. Under suitable environmental and fuel conditions, this process may initiate a chain reaction that results in a widespread conflagration. It has been hypothesized, but not proven, that the nature and amounts of air pollutant emissions are directly related to the intensity and direction (relative to the wind) of the veld fire, and are indirectly related to the rate at which the fire spreads. The factors that affect the rate of spread are (1) weather (wind velocity, ambient temperature, relative humidity); (2) fuels (fuel type, fuel bed array, moisture content, fuel size); and (3) topography (slope and profile). However, logistical problems (such as size of the burning area) and difficulties in safely situating personnel and equipment close to the fire have prevented the collection of any reliable emissions data on actual veld fires, so that it is not possible to verify or disprove the hypothesis. The major pollutants from veld burning are particulate matter, carbon monoxide, and volatile organics. Nitrogen oxides are emitted at rates of from 1 to 4 g/kg burned, depending on combustion temperatures. Emissions of sulphur oxides are negligible (USEPA, 1996). A study of biomass burning in the African savannah estimated that the annual flux of particulate carbon into the atmosphere is estimated to be of the order of 8 Tg C, which rivals particulate carbon emissions from anthropogenic activities in temperate regions (Cachier et al, 1995).

184 | P a g e

2.4.10 AMBIENT NOISE 2.4.10.1 Ambient Noise Conditions Noise measurements to establish current ambient noise conditions were taken at five (5) sites on Thursday 27 June 2013 from 09h00 to 12h00. The sound pressure level (SPL) (noise) measurements were taken in accordance with the requirements of the South African National Standard SANS 10103:2008, The Measurement and Rating of Environmental Noise with Respect to Annoyance and Speech Communication. For all measurements taken to establish the ambient noise levels, the equivalent noise level (LAeq), the maximum sound pressure level (LAmax) and the minimum sound pressure level (LAmin) during that measurement period were recorded. The frequency weighting setting was set on “A” and the time weighting setting of the meters were set on Impulse (I). Measurement periods of a minimum of 10 minutes were used. In addition, the variation in instantaneous sound pressure level (SPL) over a short period was also measured at some of the Sites. For these latter measurements the time weighting setting of the meter was also set on Impulse (I). 2.4.10.1.1 Summary of the residual sound pressure level measurements

The results of the residual noise condition measurement survey are summarised in Table 63. The equivalent sound pressure (noise) level (LAeq), the maximum sound pressure level (LAmax) and the minimum sound pressure level (LAmin) are indicated. Note that the equivalent sound pressure (noise) level may, in layman’s terms, be taken to be the average noise level over the given period. This “average” is also referred to as the residual noise level (excluding the impacting noise under investigation) or the ambient noise level (if the impacting noise under investigation is included). 2.4.10.1.2 Determination of night-time noise levels

No 10 minute to 15 minute measurements were taken during the night-time period. The typical night-time noise conditions were established from the minimums recorded during the daytime measurements, from measurements immediately north of the planned mine in the vicinity of the Somkhele Mine, in other similar areas, from the traffic noise calculations and from auditory observations in the respective areas. 2.4.10.2 Noise Climate related to Road Traffic In order to complement the short-term noise measurements, the existing 24-hour residual noise levels related to the average daily traffic (ADT) flows on a number of main and secondary roads through the area and the roads directly affected by the Fuleni Anthracite Project were calculated. There are several main roads servicing the study area:      

National Road N2. Provincial Road P425. Provincial Road P494 (this road is to be upgraded as the new mine access). It is aligned through the northern sector of the study area. Road P499. Road D873 (near Richards Bay railway line). Road D873 (near planned Fuleni Anthracite Project). 185 | P a g e

Table 63: Measures residual noise levels (2013) Measured Sound Pressure (Noise) Level (dBA) Site No

Location Description

GPS Co-ordinates

Daytime Period

Night-time Period

LAeq

Lmax

Lmin

LAeq

Lmax

1

Off the main gravel road in Velongezinyo, just north of the radio mast.

-28.4109S 31.9897E

35.7

56.6

25.7

<30

-

2

In the river valley, approximately 550m south-east of the nearest village.

-28.4378S 31.9324E

42.2

59.9

22.7

<30

-

3

Next to the gravel road, immediately south-east of Mgilane Hill, which forms the south-eastern corner of the Hluhluwe-iMfolozi Park

-28.4097S 31.96253E

36.0

61.9

18.7

<30

-

4

At a borrow site next to the main gravel road, at the northern side of Ocilwana.

-28.4066S 31.98222E

47.8

70.6

29.8

<30

-

5

Just south of a small group of homesteads, approximately 870m west of the main gravel road.

-28.4231S 31.9809E

37.3

57.0

20.7

<30

-

(i)

Lmin

Notes: The typical night-time noise conditions were established from the minimums recorded during the daytime measurements, from measurements in similar areas, from the road traffic noise calculations and from auditory observations in the respective areas.

186 | P a g e

Figure 70: Ambient noise monitoring sites

These calculated noise values provide an accurate base for the SANS 10103 descriptors. The noise levels generated from the traffic on these roads were calculated using the South African National Standard SANS 10210, Calculating and Predicting Road Traffic Noise. Typical situations were used for the calculation site. The Year 2013 traffic data were used as the baseline for the calculations. The noise levels at various offsets from the relevant road centre-lines were established and are summarised in Table 65. The noise levels given are for generalised and the unmitigated conditions. There will be greater attenuation than shown with distance where there are houses, other buildings and terrain restraints in the intervening ground between the source and the receiver point. 2.4.10.3 Noise Climate related to Railway Traffic There are two railway lines in the area: 



The Ermelo to Richard’s Bay line (Richards’s Bay Coal Line): This railway line is aligned in a northwest to south-east direction through the southern sector of the MRA area. There are at present, on average, 38 trains (freight) per day on this line. Richards Bay to Swaziland line: There are at present, on average, 13 trains (freight) per day on this line.

There is no commuter service on these lines. Data were obtained from Transnet. With the pass-by of each train there will be a fluctuation in sound pressure level ranging from the normal background noise for the area (residual noise level) to a maximum as the train passes and then reducing again to the residual level as the train moves away from the receiver point. The approximate maximum noise levels that will be experienced with the pass-by of a typical freight train at various offsets from the 187 | P a g e

railway line and for various typical cross-section types are given in Table 64. These values were measured by Jongens Keet Associates, as well as from Nelson (1987) and UK Department of Transport (1995). Note that the noise levels for the sections at-grade and the sections on fill are the same. The values given are the unmitigated noise levels. Table 64: Typical maximum noise levels for operational conditions along the railway line Maximum Pass-by Noise Level (LAmax) (dBA) Offset (m)

At-grade/Fill Section

Cutting Section 3m Depth

7m Depth

25

93,3

81,5

77,9

50

88,3

75,7

71,1

100

82,2

69,3

64,3

200

75,6

62,6

57,4

300

71,9

58,9

53,4

500

66,5

53,5

48,0

The operations of the trains have the potential to adversely influence the noise climate of the areas along the railway corridor to a larger or lesser extent for significant distances from the tracks. The propagated noise will be attenuated with distance from the source, the nature of the ground cover on the intervening ground, and from screening by the natural topography and buildings. The wheel-rail generated noise is enhanced where the train is travelling on elevated structure. The character (qualitative aspect) of the railway operational noise will have many facets. The component of noise that will predominate at maximum operating speed will be the wheel-rail interaction noise. The noise from diesel locomotives will be much higher than that from electric locomotives. The noise from the locomotives will be slightly louder than that from the wagons. With the pass-by of each train, the perceived noise at any one receiver point within the area of influence of the train will fluctuate relatively rapidly from the normal background (ambient) noise level of the area to peak at the maximum, will then fall slightly once the locomotives have passed the closest point to the receiver to remain fairly constant at this level until the whole train has passed by the near-ground and then will fall back to the area’s ambient level as the train moves into the far distance. This whole cycle can take place over a period of several minutes. The noise of the braking systems may sometimes be audible. There will possibly be some “flange squeal” (rail-wheel interaction) heard in areas where there are tight-radius track curves. There will also be mechanical banging sounds from the wagon couplings when the trains slow down or accelerate. It is normally mandatory that a train sounds a warning horn at at-grade crossings with roads. Noise from these horn soundings can be as loud as 105dBA at 30 metres and 84dBA at 350 metres from the train. 2.4.10.4 Prevailing Noise Climate In overview, the existing situation with respect to the existing noise climate in the study area was found to be as follows: 

The main sources of noise in the area are from: 188 | P a g e

o o



 







Traffic on the main roads. The Ermelo to Richard’s Bay railway line (Richards’s Bay Coal Line), and the Richards Bay to Swaziland railway line. o The Somkhele Mine to the north of the proposed Fuleni Mine. o General farming activities (not major source of noise). The main noise sensitive receptors in the study area are: o Numerous farmhouses and farm labourer residences to the east of Road P425 (east of the proposed mining area). o Residential urban area of KwaMbonambi. o Rural residential dwellings either in a scattered pattern or clustered into small villages. o Various schools in the study area. o HiP and Wilderness Area. The areas relatively far from the main roads and the other mentioned major noise sources are generally very quiet. Most of the core study area, namely where the mine will be developed comprises scattered rural residential dwellings and agricultural land. It has a typical rural noise climate. Ideally the ambient noise levels for a rural area should not exceed 45dBA during the daytime period (06h00 to 22h00) and 35dBA during the night-time period (22h00 to 06h00). The noise climate of the villages (areas where there is a high concentration of dwellings) can generally be said to have a suburban residential character. Ideally the ambient noise levels for a suburban residential area should not exceed 50dBA during the daytime period (06h00 to 22h00) and 40dBA during the night-time period (22h00 to 06h00). The minor provincial roads that penetrate the study area carry small volumes of traffic and the impact of traffic noise from these facilities is minimal. However many of the roads and many vehicles are in poor repair resulting in a louder than normal noise generation from the road environment. The noise climate close to National Road N2 and Road P425 (Route R102) is severely degraded and adjacent to the following roads for the distances shown from the road the noise levels exceed acceptable residential living conditions as specified in SANS 10103 (using the night-time standards of 35dBA LReq,n as the indicator for rural residential areas and 40dBA LReq,n as the indicator for suburban residential areas): Road National Road N2 Provincial Road P425 (Route R102) Road P499 Road P494 Road D873 (R) Road D873 (M)



Rural residential 1850m 900m 45m 250m 250m

Suburban residential 1000m 400m 15m 80m 20m 100m

The Ermelo to Richard’s Bay railway line (Richards’s Bay Coal Line) carries at present, on average, 38 trains (freight) per day. The Richards Bay to Swaziland line carries at present, on average, 13 trains (freight) per day. These have only a minor influence on the general noise climate of the area, except at noise sensitive sites very close to the railway line with the pass-by of a train.

189 | P a g e

Table 65: Existing noise climate adjacent to main roads (2013)

Noise Climate Alongside the Main Roads at Given Offset from Centreline (SANS 10103 Indicator) (dBA) Road 25m Offset Ld

Ln

Ldn

50m Offset Ld

Ln

Ldn

100m Offset

250m Offset

500m Offset

1000m Offset

1500m Offset

2000m Offset

2500m Offset

3000m Offset

4000m Offset

Ld

Ld

Ld

Ld

Ld

Ld

Ld

Ld

Ld

Ln

Ldn

Ln

Ldn

Ln

Ldn

Ln

Ldn

Ln

Ldn

Ln

Ldn

Ln

Ldn

Ln

Ldn

Ln

Ldn

N2

65.1 58.5 66.6 602.0 55.5 63.5 58.8 52.8 60.3 54.4 47.9 55.9 50.6 44.1 52.1 46.1 39.6 47.6 43.1 36.6 44.6 40.8 34.3 42.3 39.0 32.4 40.5 37.5 30.9 38.9 35.0 28.5 36.5

P425

59.9 53.4 61.4 56.9 50.3 58.3 53.7 47.2 55.2 49.3 42.7 50.7 45.5 38.9 47.0 41.0 34.4 42.4 38.0 31.4 39.4 35.7 29.1 37.2 33.8 27.3 35.3 32.3 25.8 33.8 29.9 23.3 31.4

P494

50.8 44.3 52.3 47.7 41.2 49.2 44.6 38.0 46.1 40.1 33.6 41.6 40.1 33.6 41.6 31.8 25.3 33.3 28.8 22.3 30.3 26.5 20.0 28.0 24.7 18.2 26.2 23.2 16.7 24.7 20.8 14.2 22.2

P499

44.0 37.5 45.5 40.9 34.4 42.4 37.8 31.2 39.2 33.3 26.8 34.8 29.5 23.0 31.0 25.0 18.5 26.5 22.0 15.5 23.5 19.7 13.2 21.2 17.9 11.4 19.4 16.4

D873R 39.9 33.3 41.4 36.8 30.3 38.3 33.6 27.1 35.1 29.2 22.7 30.7 25.4 18.9 26.9 20.9 14.4 22.4 17.9 11.4 19.4 15.6

9.1 17.1 13.8

7.2 15.3 12.3

9.8 17.9 14.0

7.4 15.4

5.7 13.7

3.3 11.3

9.8

D873M 52.4 45.8 53.8 49.3 42.7 50.7 46.1 39.6 47.6 41.7 35.1 43.2 37.9 31.4 39.4 33.4 26.8 34.9 30.4 23.8 31.9 28.1 21.5 29.6 26.3 19.7 27.7 24.7 18.2 26.2 22.3 15.8 23.8

     

N2 P425 P494 P499 D873R D873M

-` -

National Road N2 Provincial Road P425 (Route R102). Provincial Road P494 to be upgraded as the new mine access route. Road P499. Road D873 (south-west of planned Fuleni Mine near Richards Bay railway line). Road D873 (near planned Fuleni Mine).

The noise descriptors used are those prescribed in SANS 10103:2008, namely:   

Daytime equivalent continuous rating (noise) level (L Req,d) (Ld used in Table), namely for the period from 06h00 to 22h00). Night-time equivalent continuous rating (noise) level (L Req,n) (Ln used in Table), namely for the period from 22h00 to 06h00). Day-night equivalent continuous rating (noise) level (L R,dn) (Ldn used in Table), namely for the 24 hour period from 06h00 to 06h00).

Traffic data were obtained from the KwaZulu Natal Department of Transport and Mikros Traffic Monitoring (Pty) Ltd.

190 | P a g e

ENVIRONMENTAL ASPECTS THAT MAY REQUIRE PROTECTION

2.5

2.5.1 FORMALLY AND INFORMALLY PROTECTED AREAS 2.5.1.1 National Parks and Nature Reserves The recently completed National Biodiversity Assessment (NBA, 2011) provides an assessment of South Africa’s biodiversity and ecosystems, including headline indicators and national maps for the terrestrial, freshwater, estuarine and marine environments. The NBA 2011 was led by the South African National Biodiversity Institute (SANBI) in partnership with a range of organisations, including the DEA, CSIR and SanParks. It follows on from the National Spatial Biodiversity Assessment 2004, broadening the scope of the assessment to include key thematic issues as well as a spatial assessment. The NBA 2011 includes a summary of spatial biodiversity priority areas that have been identified through systematic biodiversity plans at national, provincial and local levels (SANBI BGIS). According to the NBA (2011), the MRA area is not located within either a formal or informal protected area or within a national park. However, the MRA area borders on the formally protected Hluhluwe-iMfolozi Park (HiP) while the Fundimvelo Nature Reserve lies approximately 10 km to the west (Figure 71). Three Community Nature Reserves were recently declared directly to the west of the MRA area, in the Ntambanana Local Municipality (KZN Municipal Notice No. 42 of 12 June 2014), namely:   

Somopho Community Nature Reserve on a portion of Portion 1 of Fuleni Reserve No. 14375 Obuka Community Nature Reserve on a portion of Reserve No. 11 No. 15831 Mandlakazi Community Nature Reserve on a portion of Portion 11 of Reserve No. 12 No. 15832

Figure 71: Protected areas in vicinity of the proposed Fuleni Anthracite Project

191 | P a g e

2.5.1.2 iMfolozi Wilderness Area Wilderness in iMfolozi was demarcated in 1957 and first protected as a wilderness area in 1959 by Board resolution of the then Natal Parks Board. It has increased in size from 12 150 hectares to about 32 000 hectares between 1959 and 2002 (EKZN, 2014). Between 2006 and 2009, a zonation, management and monitoring system was researched and applied to the iMfolfozi Wilderness Area so that it met with the most recent and internationally accepted scientific standards for wilderness management. This management system was included in the Management Plan for the HiP, which was subjected to rigorous public participation process and signed by the MEC (Ezemvelo KZN Wildlife, 2014). As such the iMfolozi Wilderness Area is protected as such under section 41(2) (g) of the Protected Areas Act, and with this in place, it is possible to seek direct designation under section 26 of the Protected Areas Act and IUCN 1b category recognition (EKZN, 2014). The iMfolozi Wilderness Area is of national and possibly even international importance as it is used as an example of wilderness and the management thereof (Paul Cryer, African Conservation Trust, personal communication, 2014). Table 66 below provides a description of the wilderness zones that are within influence range of the proposed Fuleni Anthracite Project. The exact location of the various zones as well as the location of the proposed mine can be seen in Figure 72 below (HiP Management Plan, EKZN, 2011). Table 66: Various wilderness zones of the HiP explained (HiP Management Plan, 2011) Zone/ Condition Class

General Description

Pristine Wilderness

Area is characterised by essentially unmodified natural environment of fairly large size. Interaction between users is very low, and evidence of other users is minimal. The area is managed to be essentially free from evidence of human-induced restrictions and controls. Motorised use not permitted.

Primitive Wilderness

Extremely high probability of experiencing isolation from the sights and sounds of humans, independence, closeness to nature, tranquillity and selfreliance through the application of woodsman and outdoor skills in an environment that offers a high degree of challenge and risk.

Semi Primitive Wilderness

Area is characterized by a predominantly natural or natural appearing environment of moderate to large size, interaction between users is low, but there is often evidence of other users. The area is managed such that minimum on-site controls and restrictions may be present, but are subtle. Motorised use is not permitted.

Specific Description in the Context of Hluhluwe-iMfolozi Park An un-modified area in the most remote parts of the wilderness area. No human impacted paths are visible. Camping techniques should be the least invasive to wildlife. Only primitive campsites are present and these should not be immediately visible. Groups are restricted such that encounters would be exceptional. Human habitation within or outside the Park is barely, if ever, visible. An un-modified area usually not on the periphery of the wilderness area. Semipermanent fly-camps may be present. There is no sign of impacted human paths outside the fly-camps. Groups are restricted such that encounters would be exceptional. Human habitation within or outside the Park is seldom visible. An un-modified area usually on the periphery of the wilderness area. Impacted human paths are visible and semipermanent base camps may be present. Although encounters are minimised and group sizes restricted, other people may well be in the area. The area will commonly have views, which would include human habitation outside the wilderness area or Park.

192 | P a g e

Figure 72: iMfolozi Wilderness Area and Zonation

2.5.1.3 iSimangaliso Wetland Park and World Heritage Site The iSimangaliso Wetland Park and World Heritage Site (WHS) is situated downstream of the proposed Fuleni Anthracite Project. The Park’s Zone of Influence is indicated in Figure 73. In addition, five sub-zones for the terrestrial and aquatic environments have been defined:   



Sub-zone 1: 10 m wide strip of land, 5 m either side of the Park boundary, in which no development is permitted (save for necessary access points, fencing and management roads). Sub-zone 2: a larger area extending inland for the full length of the Park and delineated on the basis of watersheds and view sheds. Sub-zone 3: rivers (including their catchments) that enter the Park, defined as a 30 m strip from the riverbank either side of the river. Recognising the strategic importance of rivers, iSimangaliso needs to have influence from where the rivers enter the Park to as far upstream as impacts can be experienced by the Park, i.e. potentially to source. Here, the provisions of the Reserve (water quality and quantity) for each river, once determined by the Department of Water Affairs, are critically important to being able to control negative impacts on the Park that relate to rivers. Sub-zone 4: 10 km buffer zone set by 2010 EIA Regulations. Certain activities that fall outside the Park require environmental authorisation prior to their commencement because they fall within the buffer area (defined as the area extending 10 km from the proclaimed boundary of a world heritage site). This is in addition to any activities triggered by a development in its own right.

193 | P a g e



Sub-zone 5: littoral zone south of the Park. This refers to the area of coastline just south of the southern Park boundary in terms of the National Environmental Management: Integrated Coastal Management Act, 2008.

Of these, Sub-zone 3 would be applicable to the Fuleni Anthracite Project.

Figure 73: iSimangaliso Wetland Park: Zone of influence (buffer zone)

194 | P a g e

2.5.2 NATIONAL AND PROVINCIAL CONSERVATION INITIATIVES AND STRATEGIES 2.5.2.1 National List of Threatened Terrestrial Ecosystems for South Africa (2011) The National Environmetal Management Biodiversity Act (Act 10 of 2004) provides for listing of threatened or protected ecosystems, in one of four categories: critically endangered, endangered, vulnerable or protected. Threatened ecosystems are listed in order to reduce the rate of ecosystem and species extinction by preventing further degradation and loss of structure, function and composition of threatened ecosystems. The purpose of listing protected ecosystems is primarily to conserve sites of exceptionally high conservation value (SANBI, BGIS). According to the National List of Threatened Terrestrial Ecosystems (2011) the mining rights area covers a small area of the remaining extent of the vulnerable Eastern Scarp Forest vegetation at its western edge. This vegetation type has undergone ecosystem degradation and a loss of integrity (Figure 74).

Figure 74: Threatened terrestrial ecosystems

2.5.2.2 National Protected Areas Expansion Strategy, 2010 (NPAES) The goal of the National Protected Area Expansion Strategy (NPAES) is to achieve cost effective protected area expansion for ecological sustainability and adaptation to climate change. The NPAES sets targets for protected area expansion, provides maps of the most important areas for protected area expansion, and makes recommendations on mechanisms for protected area expansion. It deals with land-based and marine protected areas across all of South Africa’s territory (SANBI BGIS). 195 | P a g e

According to the NPAES, the mining footprint area is not located within a NPAES protected area (formal or informal). However, a NPAES focus area is located within the western portion of the MRA area (Figure 75). NPAES Focus Areas are focus areas for land-based protected area expansion. Focus areas are large, intact and unfragmented areas of high importance for biodiversity representation and ecological persistence, suitable for the creation or expansion of large protected areas.

Figure 75: NPAES Focus Areas

2.5.2.3 KwaZulu-Natal Systematic Conservation Plan, 2005 In order to appropriately monitor development and derive useful conservation plans, we need appropriate measures of the state of the landscape and extent of transformation. The KZN Land Cover Dataset is a single, contiguous land-cover dataset covering the entire KZN Province that has been generated from multidate SPOT2/4 imagery acquired primarily in 2005, and represents the final 2005 KZN Province Land-Cover product. According to the KZN Land Cover Dataset the land cover of the MRA area is a combination of urban areas, rural dwellings, woodland, grassland, dense bush, bushland, grassland/bushclump mix, degraded grassland, wetlands, dams and freshwater systems (SANBI BGIS).

196 | P a g e

2.5.2.4 KwaZulu Natal Terrestrial Biodiversity Priority Areas According to the KwaZulu-Natal Terrestrial Conservation Plan (Figure 76) the MRA area contains areas specified as Biodiversity Priority Areas 1 (Critical Biodiversity Areas (CBAs) 1 Mandatory) and Biodiversity Priority Areas 3 (CBA 3 Optimal) (SANBI, BGIS). The CBA 1 Mandatory areas are based on the C-Plan Irreplaceability analyses. Identified as having an Irreplaceability value of 1, these planning units represent the only localities for which the conservation targets for one or more of the biodiversity features contained within can be achieved i.e. there are no alternative sites available. CBA3 Optimal areas reflect the negotiable sites with an Irreplaceability score of less than 0.8. Even though these areas may display a lower Irreplaceability value it must be noted that these areas, together with CBA 1s and CBA 2s, collectively reflect the minimal reserve design required to meet the Systematic Conservation Plans targets and as such, they are also regarded as CBA areas. Biodiversity areas not highlighted in MINSET are not open for wholesale development. Important species are still located within them and should be accounted for in the EIA process. They are not highlighted as the MINSET highlights the 'choice' areas from a biodiversity point of view only. Should one or more of the CBA2 and CBA3 sites be utilised for development, it is obvious that the target for whatever feature(s) where located within that PU will no longer be met. Ideally, MINSET would have to be re-run to calculate the next optimal solution, the new PUs being 'extracted' from the currently blank/un-defined areas.

Figure 76: KZN Terrestrial Biodiversity Priority Areas

197 | P a g e

2.5.2.5 Important Bird Areas (IBA) The mining footprint area falls within the Hluhluwe–Umfolozi Park IBA (SA 060) (Figure 77). This IBA is relatively large and well conserved and several large raptor species are known to breed in these areas. RDL birds within this IBA area may utilise the mining footprint area for foraging purposes, especially where untransformed habitat is present.

Figure 77: Important Bird Areas (IBA)

2.5.2.6 Importance According to the Mining and Biodiversity Guideline (2012) The Mining and Biodiversity Guideline (2012) provides explicit direction in terms of where mining-related impacts are legally prohibited, where biodiversity priority areas may present high risks for mining projects, and where biodiversity may limit the potential for mining. The guideline distinguishes between four categories of biodiversity priority areas in relation to their importance from a biodiversity and ecosystem service point of view as well as the implications for mining. These categories include: Legally Protected Areas, Highest Biodiversity Importance, High Biodiversity Importance and Moderate Biodiversity Importance (SANBI, BGIS). According to the Mining and Biodiversity Guideline the majority of the mining footprint area falls within an area considered to be of Highest Biodiversity Importance. Highest Biodiversity Importance areas include areas where mining is not legally prohibited, but where there is a very high risk that due to their potential biodiversity significance and importance to ecosystem services (e.g. water flow regulation and water provisioning) that mining projects will be significantly constrained or may not receive necessary authorisations. 198 | P a g e

Areas within the remainder of the mining footprint area fall within isolated areas considered to be of High Biodiversity Importance (Figure 78). High Biodiversity Importance areas include protected area buffer (including buffers around National Parks, World Heritage Sites and Nature Reserves), Transfrontier conservation Areas (remaining areas outside of formally proclaimed protected areas), other identified priorities from provincial spatial biodiversity plans and high water yield areas, amongst others. These areas are important for conserving biodiversity, for supporting or buffering other biodiversity priority areas, for maintaining important ecosystem services for particular communities or the country as a whole. An environmental impact assessment should include an assessment of optimum, sustainable land use for a particular area and will determine the significance of the impact on biodiversity. Mining options may be limited in these areas, and red flags for mining projects are possible. Authorisations may set limits and specify biodiversity offsets that would be written into licence agreements and/or authorisations.

Figure 78: Importance in terms of the Mining and Biodiversity Guidelines (2012)

199 | P a g e

3 PROPOSED MINING OPERATION 3.1

MINERAL TO BE MINED

The Fuleni Anthracite Project area is underlain predominantly by rocks of the Karoo Supergroup. The coal measures occur approximately 100 meters above the base of the Emakwezini Formation. Karoo dolerites intrude the stratigraphic sequence and dykes and sills are common in the area. Four coal seams exist in the area of the proposed Fuleni Anthracite Project; Lower, Main, Upper Seam 1 and Upper Seam 2 (also known as A, B, C and D coal zones). The B-zone or Main seam is generally the only seam of economical importance and has an average thickness of 10 to 11 meters.

Figure 79: Simplified geological map (1:250 000 scale) of the proposed Fuleni Anthracite Project area

200 | P a g e

3.2

EXTENT OF THE OPERATION

The proposed Fuleni Anthracite Project is essentially an opencast mine, with some underground potential towards the south of the open pit areas. The MRA area constitute 14 615 ha; however the actual development footprint covers an area of only 1 750 ha for mining and infrastructure development. The development footprint (orange shaded area) in relation to the full MRA area is shown below.

The intention is to maintain a constant product stream and first develop the opencast Pits 1, 2 and 3 simultaneously, followed by underground mining via portals to be developed at the headwalls of these pits. Pits 4, 5 and 6 will follow. Associated infrastructure including roads, stockpiles and plant is mainly situated towards the south of the open pit workings and includes:         

Topsoil and overburden stockpiles; Haul roads and/or conveyor systems for ROM transport; ROM handling facility; Coal Handling Processing Plant (CHPP) with associated stockpiles; Pollution control dams; Temporary discard facility; Raw water storage facility(ies) and distribution systems; Access road to mine and for product transport; and Auxiliary infrastructure including workshops and stores, offices and change houses, sewage treatment plant, main electrical power supply and security fencing.

The washed coal will be transported via road to either a nearby siding on the Swaziland-Richards Bay railway line or directly to the Richards Bay Coal Terminal (RBCT) for export. The Fuleni Anthracite Project layout plan is shown in Figure 80 and Figure 81 overleaf. 201 | P a g e

Figure 80: Layout plan in relation to nearby communities

202 | P a g e

Figure 81: Layout Plan for Fuleni Anthracite Project (Prodelko, 2014)

203 | P a g e

IMPLEMENTATION SCHEDULE

3.3

The project will be implemented in four (4) phases:    

Phase 1: Development of Open Pits 2 & 3 with associated infrastructure Phase 2: Continuous development of Phase 1 and the addition of Open Pit 1 with associated infrastructure Phase 3: Continuous development of Phases 1 & 2 and the addition of Open Pits 4, 5 & 6 with associated infrastructure Phase 4: Continuous development of Phases 1, 2 & 3, and the addition of Underground Workings

3.3.1 PHASE 1 DEVELOPMENT Phase 1 involves the planned development of 2 open pits and 11 associated stockpiles, a processing plant, haul roads, access roads, road deviations, electricity supply, water supply and management. Refer to Figure 82. The Phase 1 development takes place near the Ocilwane and Novunula communities. The development of Phase 1 will commence in year 1.

3.3.2 PHASE 2 DEVELOPMENT Phase 2 involves additional planned development of 1 open pit and 6 additional associated stockpiles, haul roads, electricity supply, water supply and management. Refer to Figure 83. The Phase 2 development takes place near the Ocilwane and Ntuthunga 2 communities. The development of Phase 2 will commence in year 6.

204 | P a g e

Figure 82: Phase 1 development

Figure 83: Phase 2 development

205 | P a g e

3.3.3 PHASE 3 DEVELOPMENT Phase 3 involves the continuation of Phases 1 & 2 with the additional planned development of 3 open pits and 4 additional associated stockpiles, haul roads, electricity supply, water supply and management. Refer to Figure 84. The Phase 3 development takes place near the Ocilwane and Ntuthunga 1. The development of Phase 3 will commence in year 11.

Figure 84: Phase 3 development

3.3.4 PHASE 4 DEVELOPMENT Phase 4 involves the continuation of Phases 1, 2 & 3 with the additional underground workings and associated stockpiles, haul roads, electricity supply, water supply and management. Refer to Figure 86. The Phase 4 development takes place near the Ocilwane, Ntuthunga 1 and Ntuthunga 2 communities. The development of Phase 4 will commence in year 16.

206 | P a g e

Figure 85: Phase 1, 2 and 3 developments

Figure 86: Phase 4 development

207 | P a g e

3.4

MINING OPERATIONS

The potential for both opencast and underground mining has been identified and the estimated Life of Mine (LOM) for the Fuleni Anthracite Project is 32 years with a mineable resource of 35.7 Mt Run-of-Mine (ROM) for the opencast production and 1.8 Mt for underground production. The process design allows for the production of a primary anthracite product suitable for the export and inland market and a lower grade middling product for the thermal market. The two types of coal products targeted by the open pit and underground mining are shown in the table below. The products are essentially determined based on size and ash content. Product Anthracite coal Thermal coal

Product Tonnes 14.2 5.2

Opencast 13.4 4.9

Underground 0.9 0.3

3.4.1 METHODOLOGY 3.4.1.1 Open Pit Mining The envisaged mining method for this operation is a conventional drill and blast operation with truck and shovel load and haul. Figure 87 is a graphical representation of the typical high wall design in a bench based mining operation as planned at the Fuleni Anthracite Project.

Figure 87: Typical benches in open pit mining

208 | P a g e

Figure 88: Typical view of an open pit coal mine

3.4.1.2 Underground Mining Underground mining will be done from year 15 to the end of the mining schedule. Access will be from selected positions in the open pits. After underground activities have been completed, the access will be closed with the final rehabilitation of the open pit. A single production section is planned for all underground mining. The following figure illustrates a typical bord-and-pillar layout for an underground coal mining operation.

Figure 89: Typical bord-and-pillar mining panel layout

209 | P a g e

3.4.2 MINING SCHEDULE The anthracite product tonnes will be delivered at a rate of 0.5 Mt per year. The secondary thermal coal product will be delivered at a rate of 0.15 Mt per year. Illustrated in the figures below are the ROM and anthracite product production profiles over the life of mine.

Fuleni: LOM Schedule ROM tonnes 1 800 000 1 600 000 1 400 000 1 200 000

Tonnes

1 000 000 800 000 600 000 400 000 200 000

OPEN CAST

2048

2046

2044

2042

2040

2038

2036

2034

2032

2030

2028

2026

2024

2022

2020

2018

2016

2014

-

UNDERGROUND

Fuleni: LOM Schedule Product tonnes 600 000

400 000 300 000 200 000 100 000

OPEN CAST

2048

2046

2044

2042

2040

2038

2036

2034

2032

2030

2028

2026

2024

2022

2020

2018

2016

2014

ROM Tonnes

500 000

UNDERGROUND

210 | P a g e

COAL PROCESSING (BENEFICIATION)

3.5

The Fuleni Coal Handling Process Plant (CHPP) will treat an average of 1.5 Mt per annum of ROM coal. In order to achieve this, the Fuleni CHPP is designed to treat ROM coal at a rate of 250 tonnes per hour for a minimum of 500 hours on coal per month. This is achieved with a key compliment of approximately 60 people, from the managerial, operational and engineering functions. The CHPP will be manned for operations on a 24 hour per day, 7 days per week basis, with the exclusion of statutory public holidays. The process design allows for the production of a primary anthracite product suitable for the export and inland market and a lower grade middling product for the thermal market. Refer to Figure 90 for the process flow diagram for the Fuleni CHPP. In order to achieve the required product specifications, the ROM coal is subjected to double stage crushing, which will reduce the ROM top size from approximately 600mm to below 50mm. This material is sized into coarse (+15mm) and fine (-15mm) fractions and fed to a double stage dense medium separation (wash) process. The high gravity separation will take place first to remove the large discard content, followed by the low gravity separation into anthracite and middlings products. A spiral plant will upgrade the fine material to produce two products in the size fraction from 150μm to 1mm for inclusion into the primary and secondary products respectively. The final discard material from the plant will be disposed of in mined-out open pits. In the event that these pits are unavailable due to existing mining activities, the discard material will be placed on a temporary discards stockpile, in horizontal compacted layers. From here it will be reclaimed and dumped into the mined-out open pits towards the end of the mine life. The ultrafine discard material (slimes) is thickened in the thickener from where the clear water thickener overflow is re-circulated for reuse in the process plant and the thickened slurry or underflow is pumped to a filter press. The filtrate water from the filter press is re-circulated to the clarified water tank and the filter cake is discarded with the final coarse discard. The plant will thus have a closed water circuit in order to minimise the environmental impact as far as possible. The proposed CHPP will consist of the following main areas:            

Run of Mine (ROM) reception area; Crushing and Screening; Coarse Coal High- and Low Gravity Dense Medium Cyclone Plants; Fine Coal High- and Low Gravity Dense Medium Cyclone Plants; Fine Coal Spiral Plant; Thickening of Ultrafine Material; Plate and Frame Filter Press; Magnetite Storage and Feeding; Discard Bin Area; Product Screening and Stockpiling; Make-up Water Handling System; and Electrical Power and Control System.

211 | P a g e

Figure 90: Fuleni CHPP Process Flow Diagram

212 | P a g e

Figure 91: Fuleni Anthracite Project plant layout

213 | P a g e

3.6

MATERIALS HANDLING REQUIREMENTS

3.6.1 RUN OF MINE (ROM) AREA The ROM enters the beneficiation plant from the west and provision is made for the temporary storage of such ROM from up to 3 pits, allowing for some blending before being loaded into the primary crusher. The maximum floor slope on this platform is 5%, with a minimum of 1%. The platform area space available for such stockpiles is some 9,000 m2 in extent, which implies a maximum stockpile volume of some 24,000 m3.

3.6.2 DISCARDS STOCKPILE No permanent discards stockpile is envisaged and only sufficient temporary stockpile area is proposed to the north of the beneficiation area. Once sufficient capacity is available in the pits, this discards stockpile will be transferred back into the pits. The discards stockpile is situated to the north of the beneficiation area. The area to be prepared to accommodate this stockpile is large enough to accommodate some 900,000 tonnes of discards (+/- 18 months of peak production). The floor of the discards stockpile will be prepared to ensure that all moisture released from the discards as well as rain falling on the discards area is captured without polluting any sub-strata and channelled to Pollution Control Dams (PCDs). This preparation comprises of an impervious clay layer over which are placed filter drains covered by a graded gravel layer to protect the clay layer and filters from mechanical damage. Toe drains at the edges of the defined area are provided to collect dirty water from the filter drains as well as from surface water run-off directly from the discards. All run-off created by rainfall falling on the discards stockpile is to be collected in toe drains situated on the periphery of the stockpile. Some of the peripheral drains feed by gravity to PCD B, and the rest feed via the dirty water drainage channels through the plant site to PCD A.

3.6.3 PRODUCT STOCKPILES AND HANDLING The Product handling area accommodates four product stockpiles and sufficient traffic turning circle and working space for the loading equipment and product haulage vehicles, with a centrally located parking area. The maximum floor slope on this platform is 2%, with a minimum of 1%.

214 | P a g e

3.7

INFRASTRUCTURE

3.7.1 BUILDINGS The anticipated building requirements are indicated in the table below. These requirements are based on staff required over the production period for permanent employees and sub-contractors. Office Facilities Administration and Staff Offices Reception area 1 x filing Room 1 x Storage room for Training and Administration 1 x meeting room 2 x Environmental Control Offices 1 x Training Room 1 x Control Room 2 x Ablution Facilities for Male and female 1 x kitchen Ablution Facilities for Production Staff Ablution Facility for 45 users Locker Rooms for 160 lockers Ancillary buildings Clock Room Lamp Room for 50 units Tuck Shop Laundry Security Building Weigh-bridge Control room Workshops and Stores Explosive Magazine Room Field Offices 3 x Site Office Buildings Summary Total area for Administration and Staff offices Total Area for Ablution Facilities Total Area for Ancillary Buildings Total Area for Field Offices Total Infrastructure excluding Plant

2

m 215 10 10 10 60 20 60 10 30 12 120 120 9 16 20 18 20 10 120 100 30 437 240 313 30 1020

215 | P a g e

3.7.2 ROADS 3.7.2.1 Access Roads There are two main roads servicing the Fuleni Anthracite Project area:  

National Road N2; and Provincial Road P425.

There are several secondary Provincial Roads that link the N2 and Road P425 to the Fuleni Anthracite Project site.

Figure 92: Mfolozi Local Municipality Transport Network

The washed coal will be transported via road to the Richards Bay Coal Terminal (RBCT) for export. The thermal coal will be sold locally, however investigation to optimise revenue for this is still being pursued. A feasibility study has identified 6 alternatives for access to and from site and for product hauling. Route 5 was selected for reasons provided in Section 6.4.4. Route 5 follows the N2 National Road from the Kwambonambi off-ramp northward for a distance of approximately 15.63 km to an existing off-ramp located approximately 1.6 km south of the bridge of the N2 over the Mfolozi River. From the off-ramp the route turns westward towards the mine site. This section of the road will be approximately 20.87 km long and have a gravel surface, of which 15.70 km will be constructed by upgrading existing gravel roads and approximately 5.17 km will be constructed as a new road. The entire length of the road is sparsely populated, with a section of approximately 2 km that is somewhat more densely populated.

216 | P a g e

Figure 93: Selected Mine Access Route (Route 5)

The roads that will be used as the access route to and from the mine will need to be upgraded. The construction of roads will involve:  

Upgrading of existing gravel access roads: All roads will have a gravel wearing course. Appurtenant storm water handling measures: It is proposed that culverts at stream crossings and other storm water infrastructure along the haul road routes be designed for a recurrence interval of 1 in 50 years

The road upgrade / construction will commence in Phase 1 of the development (Year 1). 3.7.2.2 Road Diversions Existing provincial gravel roads will be affected by two opencast pits (O/C2 and O/C6). These roads will have to be diverted and/or replaced to ensure continual access to the communities.

217 | P a g e

3.7.3 STORM WATER MANAGEMENT 3.7.3.1 Separation of Clean and Dirty Water It is proposed to separate the clean and dirty water by constructing a system of clean and dirty water channels within the plant layout area. The plant and discards stockpile area will be delineated into dirty clean water areas as defined by the catchments of each type of run-off. The clean water channels will discharge into natural tributaries after necessary energy dissipating measures in order to mitigate soil erosion. The dirty water channels will discharge into the Pollution Control Dams (PCDs), from which the water will be reused. 3.7.3.2 River Diversions Several diverging streams exist within the defined opencast pit limits. Appropriate water management in line with the environmental requirements for regulatory approval will have to be implemented and managed throughout the life of the operation. Clean runoff will need to be diverted around the open pits for discharge into natural tributaries. 3.7.3.3 Pollution Control Dams Dirty storm water runoff and seepage from the plant and discards stockpile area will be directed along dirty water drains towards two PCDs situated to the east and the south-west of the plant footprint. The dams will be designed for the 1:50 year flood event, with preliminary capacity requirements estimated at some 49,200 m3 for PCD A and 15,620 m3 for PCD B. The dirty water in these dams will be recycled as primary sources for all process water and dust suppression requirements. 3.7.3.4 Silt Traps Silt traps will be constructed where the dirty water drains enter the PCDs. These silt traps will be sized to ensure that they can be cleaned out using mechanical equipment such as a small front end loader and labour without damaging their structural integrity.

218 | P a g e

3.8

BULK POWER SUPPLY

The power demand for the Fuleni Anthracite Project is anticipated at 3.6 MW of power on average, and 5.5 MW at peak periods as summarised below. Open Pit Energy Mega Watt Hour/Month Average Power Mega Watt Peak Power Mega Watt Underground Energy Mega Watt Hour/Month Average Power Mega Watt Peak Power Mega Watt Plant Energy Mega Watt Hour/Month Average Power Mega Watt Peak Power Mega Watt Lighting, Workshops and Offices Energy Mega Watt Hour/Month Average Power Mega Watt Peak Power Mega Watt Pumps Energy Mega Watt Hour/Month Average Power Mega Watt Peak Power Mega Watt Water Treatment Works and Sewage Treatment Plant Energy Mega Watt Hour/Month Average Power Mega Watt Peak Power Mega Watt Total Power Energy Mega Watt Hour/Month Average Power Mega Watt Peak Power Mega Watt

9.6 0.013 0.020 760 1.583 2.400 1296 1.8 2.8 48 0.067 0.10 48 0.067 0.10 28.8 0.04 0.06 2190 3.6 5.5

The long term power supply has been applied for with Eskom. Should the mine become operational before this supply has been secured and/or power infrastructure is in place, power will be supplied via the use of diesel-fired generators.

219 | P a g e

3.9

BULK WATER SUPPLY

3.9.1 WATER REQUIREMENTS 3.9.1.1 Potable Water The potable requirement at the plant area has been determined for use at the washrooms and kitchen/ablution facilities at the various buildings only. The total average potable demand for the mine has been determined at about 113 kl/d with a peak day demand of some 121 kl/d. The proposed source of supply is a supply dam to be constructed on the stream due south of the plant area. The water is to be pumped via a raw water pipeline to a package type Water Treatment Works (WTW) situated south east of the plant area. A package type water treatment works, housed in a container is proposed. The water losses at this WTW are expected to approximate 10% on average, hence implying an average raw water requirement to the plant of about 131 kl/d. This WTW and chlorination facility will maintain a full supply level in a 200 kl covered reservoir, adjacent to the WTW. 3.9.1.2 Non-Potable Water Non-potable comprises of make-up water for the process plant and dust suppression water. 3.9.1.2.1 Process water

The demand for processing, excluding dust suppression outside the plant, has been determined to range between 21 kl/day and 126 kl/day, with an average of 76 kl/day. 3.9.1.2.2 Dust suppression

Dust suppression needs to be implemented on the haul roads as well as the gravelled section of the access road to Richards Bay. Further dust suppression will be required on the temporary discards stockpile, ROM stockpiles as well as the open pits. The requirement for the open pits will be supplied from rainwater stored inside the pits. The total demand for dust suppression will vary between 0 kl/day and 2 520 kl/day with an average of 2 072 kl/day over the LOM. The areas requiring dust suppression applications are the haul roads on the mine site, the graveled section of the product transport route to Richards Bay (Access road), the plant area, the Discards stockpile area and the ROM stockpiles. The dust suppression requirements on the plant itself are included in the water requirements for the plant as such water is applied as part of the beneficiation process and are therefore not included in this demand. 3.9.1.2.3 Underground mining

Once this activity commences, the total water requirements for the underground mining operations have been determined to vary from a minimum of 33 kl/d to a maximum of 337 kl/d with an average requirement of some 335 kl/d over the period that underground operations take place.

220 | P a g e

3.9.2 WATER BALANCE Water Balance and Design Capacities Element

Potable Demands

Raw Water demands

Total Water

Dirty water Generation

River flows and Dams

Sub Element

Units

Potable Water Supply

kl/d

121

113

Water Treatment Works

kl/d

121

113

Potable Reservoir

kl

250

Pipeline to Potable reticulation

kl/d

363

113

Plant requirements

kl/d

126

76

Dust Suppression

kl/d

2 526

2 072

P/Station from S/Dam to WTW

kl/d

2 863

1 546

Pipeline from S/Dam to WTW

kl/d

2 863

1 546

Pipeline from WTW to Polcon Dam A

kl/d

2 742

1 433

P/Station from Polcon A to Plant

kl/d

2 953

664

P/Line from Polcon A to Plant

kl/d

2 941

664

P/station from Polcon B to Plant

kl/d

2 988

278

Pipeline from Polcon B to Plant

kl/d

3 008

278

Dust Suppression Abstraction Points

kl/d

2 526

2 072

Total Water Demand

kl/d

3 126

2 547

Inflows to Polcon A (excl. S/W)

kl/d

408

197

S/W to Polcon A

kl/d

Inflows to Polcon B (excl. S/W)

kl/d

S/W to Polcon B

kl/d

STP to Polcon A

kl/d

103

96

Total generated (excl S/W)

kl/d

486

364

Total generated (incl S/W)

kl/d

943

Run-off into Supply Dam

kl/d

27 596

Environmental release from S/Dam

kl/d

290

Spillage from S/Dam

kl/d

24 688

Supply Dam Start Capacity

kl

705 901

Silt load in S/Dam

kl

Spillage from Polcon A

1 in

Polcon A Capacity

kl

Spillage from Polcon B

1 in

Polcon B Capacity

kl

Total Mine requirements General

Total evaporation losses Total system abstraction

Design Capacity

Average (LOM)

472 104

62 214

294 604 59 49 173 322 15 620

kl/d

2 600

1 600

3

0.58

3

0.39

3

0.98

Mm /a Mm /a Mm /a

221 | P a g e

Figure 94: Water balance flow diagram

222 | P a g e

3.9.3 WATER SOURCES The following water sources have been investigated:   





Direct abstraction from the Mfolozi River: The Mfolozi River is a water-stressed river and it is unlikely that the DWA will grant a permit to abstract water directly from the river. Boreholes: From the various geotechnical investigations it was shown that there is little likelihood of finding sufficient underground water for the mine. Off-channel storage from the Mfolozi River: Off-channel storage utilising flood water from the Mfolozi River. A desktop study revealed that the topography of the area did not lend itself to any viable or economical solution using this idea. Supply dam on the Mvamanzi River: The Mvamanzi River, which passes about 1 km south of the plant area and flows into the Mfolozi River, appears to be a viable source if some storage is provided. The position of the Supply Dam is shown in Figure 81. In addition to the above, an additional source of water is the rainfall falling on the site, together with the re-use of water draining from the site. Treated sewage effluent will also be recycled via the Polcon Dams. Such rainfall and recycled water has been adopted for purposes of this report to be a source of water.

Two meetings were held with the DWS, one with the National Office in Pretoria on 17 July 2013 and one with the Durban Regional Office on 12 November 2013. DWS sees the in-stream storage dam on the Mvamanzi River as a viable option, provided that the siltation could be managed. They also reiterated that the impact on the downstream users and the Ecological Reserve will need to be determined (removal of surface runoff from the system) prior to a final decision. The water balance determined that the supply dam needs to be able to provide an average of 600 000 kl/annum (1 600 kl/day) for the LOM. This yield can be achieved by the provision of a dam with an initial storage capacity of 705 901 kl. The dam was therefore designed with a full supply capacity of 705 901 kl. It was determined that this capacity will reduce to 411 297 kl at the end of LOM as a result of siltation.

3.10 MINE RESIDUE MANAGEMENT 3.10.1 MINING WASTE The final discard material from the plant will be disposed of in mined-out open pits. No permanent discards stockpile is envisaged and only sufficient temporary stockpile area is proposed to the north of the beneficiation area. Once sufficient capacity is available in the pits, this discards stockpile will be transferred back into the pits. The discards stockpile is situated to the north of the beneficiation area. The area to be prepared to accommodate this stockpile is large enough to accommodate some 900,000 tonnes of discards (+/- 18 months of peak production). The ultrafine discard material (slimes) is thickened in the thickener from where the clear water thickener overflow is re-circulated for reuse into the process plant and the thickened slurry or underflow is pumped to a filter press. The filtrate water is re-circulated to the thickener feed well and the filter cake is discarded via the final discard conveyor belt. The plant will thus have a closed water circuit in order to minimise the environmental impact as far as possible.

223 | P a g e

3.10.2 NON-MINING WASTE 3.10.2.1 Sewage The only sewage expected to be generated on the mine is from the ablution facilities and wash-rooms at the plant area. The sewage treatment plant will be fed by gravity from the various ablution facilities and wash-rooms in the plant area. The treated sewage will be discharged into the dirty water drains that feed into PCD A. The sewage outflow is estimated at an average of 96 kl/day with a maximum expected of 103 kl/day. The proposed sewage treatment works is to be of a semi-package plant design and will require a control building of some 10 square metres in area to house nominal water testing equipment, control equipment and an office for the operator. The processes included in the proposed plant are:      

Primary settling Anaerobic digestion Aerobic digestion Final settling Disinfection Sludge dewatering (volute hydrator)

The treatment plant shall be relatively easy to operate and shall have low operating and energy requirements. The treated effluent shall comply with the general limit as set out in the Water Resources Management Act, 2004 (Act No. 25 of 2004). This type of plant has previously been approved by DWA and has been utilised on several mines in the past with great success. 3.10.2.2 General and Hazardous Waste Upon approval of the project, a dedicated, approved (registered) waste contractor will be appointed by the mine to manage the non-mining waste generation and safe disposal thereof. The following waste types will be generated during the course of the project:          

Domestic waste Hazardous waste, including used oil/diesel/greases Fluorescent tubes Glass and plastics Chemicals Medical waste Scrap metal Building rubble (construction & demolition activities) Used tyres Old explosives

224 | P a g e

The different waste streams will be segregated and disposed of in appropriate designated receptacles. All waste will be disposed off-site at approved landfill sites. No landfill site will be established on the Fuleni Anthracite Project site. The closest waste facility suitably registered to accept all types of waste that may be generated at the mine is situated in Richards Bay. It is therefore proposed that refuse is collected in Waste Tech type containers on site and delivered to this dump site on a fortnightly basis, using a crane truck. It is estimated that the total volume of refuse accumulating at the mine should not exceed 3 m 3/week. It is proposed that and area of some 10 m2 be allocated at the plant area for the collection of refuse and temporary storage of hydrocarbon contaminated waste.

3.11 WORKFORCE There will be contractor workforce required for the first two years in support of constructing infrastructure for the mine development. Operational staff requirement and ramp-up is indicated in the figure below:

Figure 95: Workforce requirement and ramp-up

225 | P a g e

Figure 96: Breakdown of Operational Staff, first 10 years

Senior Management includes the Mine Manager, other legal compliant appointments (i.e. Safety) and Professional staff (i.e. Finance, Geology, etc). Middle Management includes the Department / Section Managers (i.e. Plant Manager). Junior Management include as the Supervisors in the Production, Engineering, Processing and Support Departments. Core skills positions primarily consist of artisans, operators, Clerks, admin and other supporting staff positions. Ibutho Coal has made a commitment to ensure that at least half of the employment opportunities are sourced from the local communities.

Figure 97: Workforce Source Area

226 | P a g e

3.11.1 HUMAN RESOURCE DEVELOPMENT PROGRAMMES Ibutho Coal has committed to the following programmes over the first 5 years of mining with a total value of R6.6 million: 

   

Core business and Artisan Training – creating an opportunity for 59 candidates to complete various training courses in Machine Operation, Truck Driving, Health and Safety, Human Resources, Mechanics, Electricians, Fitting and Turning. To make available 31 learnership opportunities in Engineering, Artisans, and Machine Operation. To establish career-path plans for those candidates showing promise to fast track their development and facilitate promotions. To make available 22 bursaries in Mining, Mechanical & Electrical Engineering, Financial, Human Resources and Geology study areas. To make available 7 internship opportunities in Mechanical & Electrical Technicians, Health and Safety and Financial positions.

3.11.2 HOUSING AND HOUSING SERVICES The following accommodation arrangements are assumed for this study: 3.11.2.1 Construction Phase The Construction Phase non-local temporary workforce will be accommodated in a contractors’ workforce camp on site as part of the infrastructure development. The Construction Phase local temporary workforce will be sourced from surrounding communities and where existing accommodation exist and will be brought to site daily as per shift roster. 3.11.2.2 Operational Phase The Operational Phase non-local permanent workforce will be housed in formalised towns close to the mine area such as Empangeni, Kwambonambi, Mtubatuba and Richards Bay. Ibutho Coal has committed to work closely with the District and Local Municipalities to facilitate access to housing for their staff. The Operational Phase local permanent workforce will be sourced from surrounding communities and where existing accommodation exist and will be brought to site daily as per shift roster. These workers will also qualify for a housing subsidy to upgrade his/her existing accommodation situation.

3.11.3 LOCAL ECONOMIC DEVELOPMENT (LED) Ibutho Coal has proposed the implementation of the following projects over the first 5 years of mining with a total value of R2million: 



School Needs Project in the schools located in Ocilwane, Novunula, Ntuthunga 1 and Ntuthunga 2, two (2) secondary and four (4) primary schools. The project will focus on key needs in each school, which will be identified in consultation with the school management. Enterprise Development Project amongst local business people focusing on the establishment, training and mentoring of local companies in personnel transport, security, protective clothing, and catering. 227 | P a g e



Unlocking Agricultural Potential amongst the local communities. This project will commence its first phase in the 5 year term, which will focus on planning agriculture interventions and organizing and training of local farmers to provide inputs and benefit from interventions to be implemented during the life of mine.

3.11.4 HEALTH SERVICES AND FACILITIES The Health Services currently provided by the Ocilwane Clinic has been assessed. It is anticipated that the current level of service, allocated resources and capacity will not be adequate for the mine workforce. In preliminary discussions it was agreed with the Department of Health that further discussions and planning around Health Services will be explored with a focus on the possible upgrading of the Ocilwane Clinic to provide medical services to both the local communities and the mine workforce, as well as the establishment of an Emergency Medical Services depot.

3.11.5 EDUCATION The majority of the workforce will utilise local schools in the surrounding communities. These schools will be supported through the LED Programme. The capacity and level of education of these schools will be monitored in cooperation with the Local and District Circuit to identify potential problems at an early stage. The balance of the workforce will utilise education facilities in established towns such as Empangeni and Richards Bay.

228 | P a g e

4 DESCRIPTION ACTIVITY 4.1

OF

POTENTIAL

IMPACTS

ASSOCIATED

WITH

SOILS, LAND USE AND LAND CAPABILITY

4.1.1 IMPACT ON SOIL ENVIRONMENT Figure 98 illustrates the position of the proposed opencast and underground mining areas, as well as the area earmarked for mining related infrastructure in relation to the soil forms encountered on the surveyed area. The information is transposed onto a digital elevation model of the area.

Figure 98: Position of the mining areas and related infrastructure transposed on a soil map and digital elevation model

All of the soil groups that are to be impacted by open cast mining fall into the grazing land capability, with the exception of the soils of the Clovelly soil form. Approximately 1 ha of a stockpile is envisaged to cover the soils of the Clovelly soil form. The latter is of medium agricultural potential. The area currently used for vegetable production (Tukulu soil form) will not be directly impacted. The impact of the mining activities, from an agricultural perspective, is therefore not as pronounced as it is from a hydropedological perspective. The most significant impact in the area is on the soils of the deep Arcadia soil form. These soils are not wetland soils but are found in and around stream channels and preferential water flow channels. The hydropedological functioning of the soils will be severely impacted.

229 | P a g e

The nature of the impact of opencast mining on the soil include the stripping and stockpiling of topsoil (consisting of A and B soil horizons) and the construction of facilities such as discard dumps, overburden stockpiles, pollution and run-off control dams and any other possible footprint structures. Heavy machinery traffic on the soil surface and possible chemical pollution of soil through polluted water or certain geological materials could constitute further impacts on soil. The latter may especially be the case where coaliferous material is being stockpiled. Stripping and stockpiling of topsoil will result in: 

     

Loss of the original spatial distribution of natural soil forms and horizon sequences which cannot be reconstructed similarly during rehabilitation, especially in an area dominated by swelling and shrinking soils. Loss of natural topography and drainage pattern. Loss of original soil depth and soil volume. Loss of original fertility and organic carbon content. Soil compaction from heavy machinery traffic during earthworks and rehabilitation will adversely affect effective soil depth, structure and density, thus influencing the pedohydrology of the area Exposure of soils to weathering, compaction, erosion, and chemical alteration of nutrients, particularly nitrogen. Exposure of the soils to acidic, neutral or alkaline mine drainage that may be high in sulphates and heavy metals.

Underground mining could result in subsidence. This is the process through which the earth’s surface lowers owing to the collapse of bedrock and unconsolidated materials (sand, gravel, salt, and clay) into underground mined areas. Subsistence could also occur where material settling occurs in the case of filled opencast pits. Two types of subsidence are identified: i) sinkhole or pit and ii) sag or through. Pit subsidence results in an abrupt sinking of the earth’s surface to form circular and steep sided craters. These areas usually do not fill with water as the water drains to deeper lying strata. Sag subsidence is a more gradual settling of the soil service and may also happen in open-cast areas that have been rehabilitated. Usually sag subsidence is associated with pillar crushing or deeper mines. These areas can hold water if the post mining or post subsidence topography lends itself thereto, as in the case of deeper soils of the Arcadia soil form. Water will seep into these areas if the subsidence intersects the water table or if surface runoff is high. Acid, neutral or alkaline mine drainage becomes an issue as pyrite, contained in coalliferous spoil, oxidises. The mine drainage can be a source of salinity, but is more often rich in heavy metals and sulphate. Very little can be done to combat subsidence in the mining environment. It is therefore evident that both underground and opencast mining could severely impact the hydropedological functioning of the area and therefore the quality and volume of water that flows towards the catchments situated towards the east of the site. Heavy machinery traffic on the soil surface during and after mining, as well during construction of infrastructure, can lead to compaction and this could adversely affect the land capability of the area. Fine sand and silt are more prone to compaction. The lower lying soils of the area exhibit a sandy texture while the higher lying soils, especially of the Arcadia soil form, are high in clay content. Compaction and hardsetting of the Arcadia soil form are definite concerns. These soils are difficult to stockpile and tend to cement if the stockpile is not kept moist. Compaction and hard setting hampers root growth and root development. Surface runoff increases, but the area already exhibits high surfacerunoff rates. 230 | P a g e

Erosion of the Arcadia soil forms during and after mining is a major concern. These soils tend, as mentioned, to cement when stockpiled and these stockpiles could easily erode. The areas where soils of Arcadia soil form are present are already eroding as is evident by the many proximal and lateral head cuts found throughout the site. Heavy machinery traffic could exacerbate this process. If not kept moist while stockpiled and placed correctly during rehabilitation these will be the first soils to erode. Erosion of rehabilitated areas will lead to soil loss and impact the land capability of the area adversely. If hard setting occurs, sheet erosion could be a significant concern on the site. In areas such as this where steep slopes dominate, erosion may occur even if hardsetting does not. Table 67 summarises the hectares of each soil form that will be impacted by mining and correlates it with land capability. Table 67: A summary of the areas to be impacted by mining activities Infrastructure

Soil Form

Land Capability

Area (Ha)

Discard Dump

Ms / Gs / Ar (Shallow)

Grazing

5.691785

Discard Dump

R / Ms / Gs

Grazing

6.752934

New Roads

Ar

Grazing

4.164173

New Roads

Ar

Grazing

0.151245

New Roads

Ar (Shallow)

Grazing

0.710765

New Roads

Cv (Crusted)

Grazing

0.0844

New Roads

Gs

Grazing

0.686226

New Roads

Gs / Ar (Shallow)

Grazing

4.136216

New Roads

Gs / Cv (Shallow)

Grazing

0.882468

New Roads

Ms / Gs

Grazing

0.072164

New Roads

Ms / Gs / Ar (Shallow)

Grazing

13.05899

New Roads

R / Ms

Grazing

0.081515

New Roads

R / Ms / Gs

Grazing

2.025795

Opencast Pit

Ar

Grazing

64.542628

Opencast Pit

Ar

Grazing

2.641047

Opencast Pit

Ar (Shallow)

Grazing

5.781527

Opencast Pit

Cv (Crusted)

Grazing

21.419813

Opencast Pit

Gs

Grazing

49.878953

Opencast Pit

Gs / Ar (Shallow)

Grazing

15.382692

Opencast Pit

Gs / Cv (Shallow)

Grazing

14.53059

Opencast Pit

Ms / Gs

Grazing

29.703499

Opencast Pit

Ms / Gs / Ar (Shallow)

Grazing

148.90411

Opencast Pit

R / Ms / Gs

Grazing

0.159872

Opencast Pit

Soil Rock Complex

Grazing

0.840113

Plant

Ms / Gs / Ar (Shallow)

Grazing

6.302412

Plant

R / Ms / Gs

Grazing

6.343088

Pollution Control Dam

Ar

Grazing

1.037141

Pollution Control Dam

Ms / Gs / Ar (Shallow)

Grazing

0.221885

Stockpiles

Ar

Grazing

68.430226

Stockpiles

Ar

Grazing

0.371352

Stockpiles

Ar (Shallow)

Grazing

1.383895

Stockpiles

Cv

Arable

1.089069

Stockpiles

Cv (Crusted)

Grazing

1.47313

231 | P a g e

Infrastructure

Soil Form

Land Capability

Area (Ha)

Stockpiles

Gs

Grazing

13.081922

Stockpiles

Gs / Ar (Shallow)

Grazing

91.962086

Stockpiles

Gs / Cv (Shallow)

Grazing

16.822314

Stockpiles

Ms / Gs

Grazing

3.004689

Stockpiles

Ms / Gs / Ar (Shallow)

Grazing

376.032409

Stockpiles

R / Ms

Grazing

0.662194

Stockpiles

R / Ms / Gs

Grazing

74.087602

Underground Mining

Ar

Grazing

5.513682

Underground Mining

Ar

Grazing

2.641047

Underground Mining

Ar

Grazing

0.327391

Underground Mining

Cv

Arable

0.022041

Underground Mining

Cv (Shallow)

Grazing

0.006433

Underground Mining

Gs

Grazing

9.910809

Underground Mining

Gs / Ar (Shallow)

Grazing

16.316223

Underground Mining

Ms / Gs

Grazing

23.265627

Underground Mining

Ms / Gs / Ar (Shallow)

Grazing

79.859111

Underground Mining

R / Ms / Gs

Grazing

3.463023

The nature of the impact of stockpiling of coal and discard dumps, the construction of plants, roads, pollution control dams and related infrastructure entails covering large areas of soil leading to a loss in agricultural land use and land capability. These areas may also lead to acid, neutral or alkaline mine water which could be high in sulphates and heavy metals to leach into the soils underlying and surrounding the stockpiles, discard dumps and pollution control dams. This may especially be the case if the linings become perforated and leak. Compaction of the soils of these areas is a further concern and post mining land capability of the area may be permanently altered.

4.1.2 POSSIBLE CHANGES IN THE CHEMICAL COMPOSITION OF THE SOILS OF THE AREA OWING TO LEACHATE FROM STOCKPILED SOILS The soils of the area exhibit high levels of Na and especially Cl. Many of the soils, especially the soils of the Arcadia soil form that is encountered along the ephemeral watercourses are sodic in nature. Stripping and stockpiling of these soils could lead to a release of the salts as rainwater percolates through the stockpiles as explained in detail in the soil specialist impact report and which is not repeated here (ANNEX-2). The soil specialist concluded that seepage water from stockpiled soil could significantly increase the salt content of the underlying and surrounding soil material. In addition, high levels of Na and especially Cl could leach to lower lying areas and enter the Mfolozi, Mvamanzi and Ntutunga river systems. The majority of the seepage water from the stockpiled soil will, however, through overland flow towards the ephemeral streamflow channels and Mfolozi, Mvamanzi and Ntutunga river systems, thereby increasing the salt load in these systems. Water decanting from the mined pits post-mining could similarly effect the soil environment and pose threats to water quality in the Mfolozi, Mvamanzi and Ntutunga river systems Soils that occur in seasonal or permanent wetland systems (as those indicated in Figure 32) can significantly buffer chemical changes. Some of these processes include:

232 | P a g e







Denitrificaion and the mobilisation of Fe, Mn and Al: Rainwater manifests as surface run-off on the majority of the soils of the area. It is transported to the wetland system through a network of ephemeral watercourses (associated with soils of the Arcadia soil form). The water enters the soil towards the lower lying areas, especially where the soils of the Arcadia soil form transitions to more sandy alluvial soils. The rate of flow is dependent on the slope of the area, the hydraulic properties of the soil, the transpiration rate of plants growing in the area and the rainfall. As the water passes through the soil, it becomes anoxic, meaning that none of the oxygen molecules in solution can accept any more electrons during the process of reduction. Nitrate therefore acts as the next electron acceptor and transforms to nitrite after which Mn (III) transforms to Mn (II) and nitrite transform to N2 gas. The latter is called denitrification and is a very effective means to remove nitrogen compounds from solution. The following element to reduce is Fe (III) resulting in the formation of Fe (II). Both Mn (II) and Fe (II) are soluble and contribute to the elevated levels of Mn and Fe that are usually seen in wetland systems. Aluminium is often associated with Mn and Fe mineral phases and may be solubilised by the abovementioned processes. In addition, the dissolution of Al mineral phases under anoxic conditions may be driven by mineral equilibrium reactions, especially under acidic soil pH conditions. Metal removal under aerobic conditions: Aeration of reduced water (i.e. where water daylights or passes over turbulent flow channels) will lead to the precipitation of many of the cationic heavy metal compounds. Water pH affects the kinetics of these reactions significantly. For instance, where oxygen demand is not a factor, the rate of abiotic Fe oxidation slows a hundred fold for every one unit drop in pH. Sulphate reduction: Water that flows through an anaerobic environment that contains an organic substrate can be affected by bacterial sulphate reduction. Bacteria oxidise organic matter through the use of sulphate as the terminal electron sink. Hydrogen sulphide is released at acidic and neutral pH conditions. Under alkaline conditions HS- or S2- becomes the dominant species. The bacteria require the presence of low molecular weight organic compounds, a pH above four and the absence of oxidising agents such as O2, Fe3+ and Mn4+. Bacterial sulphate reduction also affects the metal content of the water as metal-sulphide precipitates are formed. The latter process is governed by the solubility product of the metal-sulphide compound, the water pH and the concentrations of the reactants. Generally speaking, CuS, PbS, ZnS and CdS are the first precipitates to form. FeS is one of the last phases to precipitate and MnS only forms when the concentrations of other heavy metal elements are below 1 mg/l. The implication hereof is that even if mine water enters the wetland system, the sulphate and heavy metals could be removed from solution by wetland processes.

However, the fact that the majority of the soils of the area do not show any signs of prolonged wetness increases the risk water high in potentially hazardous elements (i.e. water leaching from stockpiles or decanting the pits) poses to the environment as a whole. 4.1.2.1 Loss of Communal Agricultural Land The areas to be directly impacted by mining and related infrastructure predominantly fall into the grazing land capability class. The community uses the land for extensive grazing and community gardens (subsistence farming). Mining will result in the community losing their grazing land and a number of subsistence garden plots. Refer to the Resettlement, Compensation and Mitigation Strategy (ANNEX-18).

233 | P a g e

4.1.3 RISK OF SOIL EROSION IN THE POST-MINING LANDSCAPE Usually, the main aim of the rehabilitation process (from an agricultural perspective) is to create a post mining landscape that has the same land capability (or as close to as possible) as the pre-mining landscape. In this case the majority of the soils that will be impacted if mining is to be allowed in the area falls into the grazing land capability. The standard approach when attempting to meet this aim (when dealing with the open-cast pits and excavated areas) is to work towards completing the following main objectives:  

Fill the open pits and other excavated areas in such a manner that the original soil horizon sequence is restored; Shape the rehabilitated areas to resemble (more or less) the pre-mining topography.

If these are the main objectives to be followed when dealing with rehabilitation of the open pits and excavated areas, large scale erosion of the in-filled areas will occur where the slope is steeper than eight percent. Figure 99 summarises the erodibility of the soils of the area (determined from the Wischmeier, Johnson and Cross (1971) nomograph). Figure 100 illustrates the areas that will be prone to severe erosion in the post mining landscape. It must be kept in mind that the Wischmeier, Johnson and Cross (1971) nomograph does not take the effect of the chemistry of the soils on erosion potential into consideration. The soils of area are high in Na which is known to disperse both 1:1 and 2:1 clay mineral phases, thus leading to an increased risk of soil erosion. The Wischmeier, Johnson and Cross (1971) nomograph underestimates the erosion risk of the soils of the area, but is still a valuable tool to determine the approximate slopesat which erosion of stockpiled and in-filled soils will occur. The dark areas on the map in Figure 100 must therefore be seen as areas of high risk in terms of soil erosion while the light areas are less prone (but not immune) to soil erosion. Of significance is that a number of stockpiles and overburden stockpiles will be situated in these zones of high erosion risk. It can be assumed with confidence that erosion and material loss of the stockpiles will be severe where the slopes are steeper than eight percent. It is doubtful that this can be mitigated. The objectives of the rehabilitation plan will have to be carefully formulated for the open-cast and excavated areas that fall into the high risk zone (where the slope is greater than eight percent). It is advised that the main objective of the rehabilitation plan for the areas that fall into the high risk erosion zone should be to combat soil erosion instead of simply filling the open pits with material and shaping the landscape.

4.1.4 POST MINING LAND CAPABILITY It is doubtful that the areas will ever function in the same manner as is presently the case from a hydropedological perspective. If traditional approached are followed, one can assume that the rehabilitated land will exhibit a much higher infiltration and percolation rate than is presently the case. Rehabilitated land tend to be rather permeable and large volumes of water that currently manifests as surface runoff will end up in the open pits – even after infilling. Hard-setting and crusting are significant concerns and the post-mining landscape will quickly erode. As indicated above, an alternative to the traditional approach to rehabilitation is to rather aim to combat soil erosion as opposed to recreating the original topography – especially in areas where the slope is steeper than eight percent. To do this a network of constructed wetland system (stabilised using gabions, swales and berms) in the areas where the open pits are to be filled in could be attempted. This will 234 | P a g e

minimise erosion, ensure that water is kept in the vadose zone, lead to plant species diversity and restore some sort of grazing capacity to the land.

Figure 99: Erodibility factor for the soils in the mining footprint area

Figure 100: Areas that will exhibit a high erosion risk in the post-mining landscape

235 | P a g e

4.1.5 CONCLUSIONS The following can be concluded: 















The mining footprint area comprise of mostly shallow soils that exhibit a poor infiltration capacity and therefore act as discharge soils, meaning that surface runoff after a rainfall event is pronounce. The higher lying areas comprise soils of the Mispah, Glenrosa and shallow Arcadia soil forms, while stream flow channels and preferential water flow channels are bordered by soils of the deeper Arcadia soil form. Close to the Mfolozi River and therefore comprising the lower lying areas, soils of the Tukulu, Oakleaf, Clovelly, Alluvial Sand and Dundee are encountered. The soils of the Tukulu soil form comprise the only high potential arable land (3.8 ha) while the alluvial sands and soils of the Dundee soil form comprise soils that exhibit hydromorphic features (76.6 ha). Approximately 42 ha of soils comprising the Clovelly and Oakleaf soil forms are of low to medium potential agricultural potential. The remainder of the site falls into the grazing land capability class. A stockpile will impact approximately one hectare of the low to medium agricultural potential Clovelly soils while the high agricultural potential Tukulu soils are not directly impacted by mining activities. The areas to be directly impacted by mining and related infrastructure predominantly fall into the grazing land capability class. The community uses the land for extensive grazing and community gardens (subsistence farming). Mining will result in the community losing their grazing land and a number of subsistence garden plots. The area is prone to severe soil erosion. Most of the ephemeral watercourses are the result of soil erosion. Numerous headcut, donga and erosion channels can be seen on site, especially in the higher lying areas. A significant impact of mining in the area will be on the hydropedological functioning of the area. Mining will result in the loss of soil form distribution which drives the hydropedological processes of the area. Soil erosion will most probably be the greatest threat to the functioning of the post-mining landscape in terms of ecology, land capability and hydropedodology, especially in areas where the slope is steeper than eight percent. These areas are marked as high risk zones. Instead of simply rehabilitating towards a scenario where spoil and soil material are back-filled to represent the current topography, the in-filled open pit areas should be shaped in such a way that a network of depression will form constructed wetlands which is stabilised using gabions, swales and berms. This will lower the risk of erosion in a highly dispersive environment, lead to plant species diversity and return the land to some degree of grazing land capability. In addition, the wetlands can be constructed in such a manner that a degree of sulphate and heavy metal sequestration will occur. These systems cannot, however, sequester Na and Cl. Pollution emanating from the mining areas and stockpiles could severely influence the chemistry of the soils of the area. Sodium and Cl have been found to be high in most soil samples (saturated paste extract). One can except that these elements will leach from stockpiled soils. Stockpiling should therefore occur for as short a time period as possible. If this is not possible, it is proposed that the stockpiles be covered with geotextiles to limit rainwater infiltration and salt leaching from the stockpiled material. This may be very expensive and will negatively impact on the fertility and microbiological activity of soils. Some of the plant seeds in these soils may also not survive such a storing practice. Correct fertilisation and seeding of the soils in the post mining landscape will therefore be important. An alternatively to covering the soils with a geotextile, is to cover it with a 236 | P a g e

layer of soil that is not high in Na and Cl. Vegetation should be encouraged to grow in this soils layer.

BIODIVERSITY – FLORAL

4.2

4.2.1 IMPACT ON FLORAL HABITAT Placement of infrastructure and mining activities within intact floral habitat in areas such as the savanna woodland habitat, wetland areas and rocky ridges is highly likely to have a detrimental impact on floral habitat conservation. The focus area is associated with Critical Biodiversity Areas (KZN C-Plan 2010) and vegetation types which are classified as vulnerable and endangered. Furthermore, the baseline floral assessment confirmed the presence and habitat integrity of these areas. The focus area is also situated adjacent to the HiP and sections of the focus area are earmarked for expansion of the HiP (NPAES 2010). The data gathered during the baseline floral ecological assessment indicate that the savannah woodland, rocky ridges and wetland areas are of high sensitivity in terms of ecological functioning and floral habitat integrity. Activities which are likely to negatively affect the floral habitat integrity in the mining footprint area include, but are not limited to, the following:      

Placement of mining infrastructure within sensitive floral habitat; Destruction of floral habitat during construction and operational activities; Dust generated by mining activities; Alien floral invasion and erosion in disturbed areas; Dewatering and pollution of watercourses leading to altered riparian and wetland floral habitat; Increased human populations in the area leading to greater pressure on natural floral habitat.

4.2.2 IMPACT ON FLORAL DIVERSITY Placement of infrastructure, construction of the mineand mining activities within intact floral habitat in areas such as the savanna woodland habitat, wetland areas and rocky ridges is highly likely to have a detrimental impact on floral diversity. Furthermore, during the baseline floral assessment a high diversity of floral species was recorded in the mining footprint area, especially within the savannah woodland, rocky ridges and wetland areas, which are of high sensitivity in terms of ecological functioning and floral habitat integrity. Activities which are likely to negatively affect the floral diversity include, but are not limited to, the following:     

Placement of mining infrastructure within sensitive floral habitat; Destruction of floral habitat during construction and operational activities; Dust generated by mining activities leading to altered floral species diversity; Alien floral invasion and erosion in disturbed areas; Dewatering and pollution of watercourses leading to altered riparian and wetland floral communities.

237 | P a g e

4.2.3 IMPACT ON FLORAL SPECIES OF CONSERVATION CONCERN Placement of infrastructure, construction of the mine and mining activities are highly likely to have a high impact on floral species of conservation concern such as Sclerocarya birrea subsp. caffra, Sideroxylon inerme and Huernia hystrix, among others. Furthermore, the mining footprint area is highly likely to harbour additional protected species. A high diversity of medicinal species were also encountered which are important to the rural communities residing in and around the focus area. Activities which are likely to negatively affect the flora of conservation concern within and around the mining footprint area include, but are not limited to, the following:      

Placement of mining infrastructure within sensitive floral habitat; Destruction of floral habitat during construction and operational activities; Dust generated by mining activities leading to altered floral species diversity; Alien floral invasion and erosion in disturbed areas; Increased harvesting pressure on protected and medicinal floral communities; Dewatering and pollution of watercourses leading to altered riparian and wetland floral communities.

4.2.4 CONCLUSIONS From the results of the floral impact assessment (ANNEX-3) it is evident that prior to mitigation all impacts on the receiving floral environment are very high in the construction and decommissioning and closure phases and high in the operational phase. Mitigation measures available will have limited ability to minimise the impacts on the receiving floral environment and impact significance remains medium high to high after mitigation. Table 68: Summary of impact significance on floral resources Construction Phase Impact Unmanaged 1: Impact on habitat for floral species Very High 2: Impact on floral diversity Very High 3: Impact on species of conservation concern Very High Operational Phase Impact Unmanaged 1: Impact on habitat for floral species High 2: Impact on floral diversity High 3: Impact on species of conservation concern High Decommissioning and Closure Phase Impact Unmanaged 1: Impact on habitat for floral species Very High 2: Impact on floral diversity Very High 3: Impact on species of conservation concern Very High Summary Very High

Managed High High High Managed Medium High Medium High Medium High Managed Medium High Medium High Medium High Medium High

238 | P a g e

BIODIVERSITY – FAUNAL

4.3

4.3.1 IMPACT ON FAUNAL HABITAT Placement of infrastructure and mining activities within sensitive faunal habitat such as the savanna woodland habitat, wetland areas and rocky ridges is highly likely to have a detrimental impact on faunal habitat and migratory corridors. Several protected faunal species, along with a high diversity of more common faunal species, rely on these habitat types for foraging, migratory and breeding purposes. The data gathered during the baseline faunal ecological assessment indicate that the mining footprint area is of high sensitivity in terms of ecological functioning and faunal habitat integrity. Activities which are likely to negatively affect the faunal habitat integrity of the mining footprint area include, but are not limited to, the following:      

Placement of mining infrastructure within sensitive faunal habitat; Destruction of faunal habitat during construction and operational activities; Dust generated by mining activities; Alien floral invasion and erosion in disturbed areas; Dewatering and pollution of watercourses leading to altered riparian and wetland faunal habitat; Increased human populations in the area leading to greater pressure on natural faunal habitat.

4.3.2 IMPACT ON FAUNAL DIVERSITY Mining construction and mining activities within the focus area is highly likely to have a detrimental impact on faunal diversity, which was determined to be high during the baseline faunal assessments, especially within the savannah woodland, rocky ridges and riparian and wetland areas, which are of high sensitivity in terms of ecological functioning and faunal habitat integrity. Activities which are likely to negatively affect the faunal diversity of the mining footprint area include, but are not limited to, the following:      

Placement of mining infrastructure within sensitive faunal habitat; Destruction of faunal habitat during construction and operational activities; Collision of mining vehicles with faunal species; Trapping and poaching of faunal species; Alien floral invasion and erosion in disturbed areas; Dewatering and pollution of watercourses leading to altered riparian and wetland faunal communities.

4.3.3 IMPACT ON FAUNAL SPECIES OF CONSERVATION CONCERN Placement of infrastructure, construction of the mineand mining activities are highly likely to have a negative impact on faunal species of conservation concern such as Crocuta crocuta, Harpactira gigas and Ciconia episcopus, among others. Furthermore, the mining footprint area is highly likely to harbour additional protected species and is also situated adjacent to the HiP. Furthermore, impacts such as blasting and vibrations are likely to affect species sensitive to vibration within the HiP such as elephants and 239 | P a g e

vultures. There is also the likelihood of an increased risk to rhino populations in the park due to the increase in human activity should the mine be approved. Activities which are likely to negatively affect fauna of conservation concern within and around the focus area include, but are not limited to, the following:      

Placement of mining infrastructure within sensitive faunal habitat; Destruction of faunal habitat during construction and operational activities; Blasting and vibrations from mining; Alien floral invasion and erosion in disturbed areas; Increased harvesting pressure on protected faunal communities; Increased risk of poaching and trapping.

4.3.4 CONCLUSIONS From the results of the faunal impact assessment (ANNEX-3) it is evident that prior to mitigation all impacts on the receiving faunal environment are very high in the construction and decommissioning and closure phases and high in the operational phase. Mitigation measures available will have limited ability to minimise the impacts on the receiving faunal environment and impact significance remains medium high to high after mitigation. Table 69: Summary of impact significance on faunal resources Construction Phase Impact Unmanaged 1: Impact on habitat for faunal species Very High 2: Impact on faunal diversity Very High 3: Impact on species of conservation concern Very High Operational Phase Impact Unmanaged 1: Impact on habitat for faunal species Very High 2: Impact on faunal diversity High 3: Impact on species of conservation concern Very High Decommissioning and Closure Phase Impact Unmanaged 1: Impact on habitat for faunal species Very High 2: Impact on faunal diversity Very High 3: Impact on species of conservation concern Very High Summary Very High

Managed High High High Managed Medium High Medium High Medium High Managed Medium High Medium High Medium High Medium High

240 | P a g e

SURFACE WATER

4.4

The surface water impacts of the project can be divided into into the following aspects, namely:       

Impact on wetlands and the riparian zone Impact on the aquatic environment Impeding on water resources and flood-lines Impacts on surface water quantity Impacts on surface water quality Impacts associated with the supply dam on the Mvamanzi River Downstream impacts

It must be kept in mind that water quality is naturally linked to water quantity due to the fact that changes in water quantity are likely to affect the dilution of pollutants.

4.4.1 WETLAND AND RIPARION IMPACT ASSESSMENT 4.4.1.1 Loss of Wetland and Riparian Habitat and Ecological Structure Construction related activities that will be undertaken, such as the removal of the topsoil and construction of mining infrastructure, will lead to destruction of habitat and overall loss of wetland habitat and ecological structure. Impacts on the wetlands will lead to a loss of migratory routes for faunal species. All these activities will result in permanent impact on the wetland features and will most likely extend to downstream/downgradient areas; however, based on the results of the surface water assessment (WSM, 2015) the impact will not be a far down as the iSimangaliso Wetland Park. Operational activities will likely result in the contamination of wetland soils and water, which will lead to the alteration or loss of habitat for wetland-associated floral and faunal species. Activities which are likely to negatively affect wetland and riparian systems within and around the mining footprint area include, but are not limited to, the following:      

Placement of mining infrastructure within wetlands and riparian areas; Destruction of wetland and riparian habitat during construction and operational activities; Dewatering; Discharge and/or spills and seepage from mining infrastructure; Diversion of surface water systems; Construction of dam in the Mvamanzi system.

4.4.1.2 Changes to Wetland Ecological and Socio-Cultural Service Provision Construction related activities that will be undertaken, such as the removal of the topsoil and construction of mining infrastructure, will lead to destruction of habitat and overall loss of wetland and riparian ecological and sociocultural service provision such as cultural value, biodiversity maintenance and nutrient and toxicant assimilation. Operational activities will likely result in the contamination of wetland soils and water, which will lead to the alteration or loss of wetland and riparian ecological and socio-cultural service provision. 241 | P a g e

Activities which are likely to negatively affect wetland and riparian systems within and around the mining footprint area include, but are not limited to, the following:      

Placement of mining infrastructure within wetlands and riparian areas; Destruction of wetland and riparian habitat during construction and operational activities; Dewatering; Discharge and/or spillage and seepage from mining infrastructure; Diversion of surface water systems; Construction of dam in the Mvamanzi system.

4.4.1.3 Impacts on Wetland Hydrological Function and Sediment Balance Mining and construction activities that will be undertaken, such as the removal of the topsoil and construction of mining infrastructure, will lead to disturbances of wetland hydrological function and sediment balance. Furthermore, as the systems are interconnected, any impacts are likely to affect the entire system. All these activities will result in permanent impact on the wetland features; however based on the results of the surface water assessment (WSM, 2015) no impact on the iSimangaliso wetland Park is deemed likely. Activities which are likely to negatively affect wetland and riparian systems within and around the mining footprint area include, but are not limited to, the following:      

Placement of mining infrastructure within wetlands and riparian areas; Destruction of wetland and riparian habitat during construction and operational activities; Dewatering; Discharge and/or spills and seepage from mining infrastructure; Diversion of surface water systems; Construction of dam in the Mvamanzi system.

The above activities are highly likely to have a significant detrimental impact on wetland and riparian habitat within and around the mining footprint area and also downstream. 4.4.1.4 Conclusions From the results of the wetland and riparian impact assessment (ANNEX-3) it is evident that prior to mitigation all impacts on the wetland and riparian systems are very high throughout all phases. Mitigation measures available will have limited ability to minimise the impacts on the receiving faunal environment and impact significance remains high after mitigation.

242 | P a g e

Table 70: Summary of impact significance on wetland and riparian resources Construction Phase Impact 1: Loss of wetland and riparian habitat and ecological structure 2: Changes to wetland ecological and socio-cultural service provision 3: Impacts on wetland hydrological function and sediment balance Operational Phase Impact 1: Loss of wetland and riparian habitat and ecological structure 2: Changes to wetland ecological and socio-cultural service provision 3: Impacts on wetland hydrological function and sediment balance Decommissioning and Closure Phase Impact 1: Loss of wetland and riparian habitat and ecological structure 2: Changes to wetland ecological and socio-cultural service provision 3: Impacts on wetland hydrological function and sediment balance Summary

Unmanaged Very High Very High Very High

Managed High High High

Unmanaged Very High Very High Very High

Managed Medium High Medium High Medium High

Unmanaged Very High Very High Very High Very High

Managed High High High High

4.4.2 AQUATIC IMPACT ASSESSMENT Quaternary catchment W23A is classified as a Highly Sensitive system considered to be in largely natural condition. The general area is indeed largely unimpacted, with agricultural activities such as livestock farming and rural settlements currently the only potential sources of negative impact. The aquatic resources in the local area assessed are of high ecological importance and sensitivity largely due to supporting protected species and the proximity to the HiP. The proposed development of the Fuleni Anthracite Project will have a high impact on the Mvamanzi River and a moderately high negative effect on the aquatic resources of the Mfolozi River. Mitigation measures available will have limited ability to minimise the impacts on the Mvamanzi River and mitigation is deemed unlikely to alter the significance of impact on the Mfolozi River from the pre mitigation conditions in any way leading to a change in impact significance although the overall magnitude of the impact will be reduced to some degree. 4.4.2.1 Loss of Instream Flow Impacts on reduced instream flow will in turn affect aquatic refugia, loss of flow dependant taxa along with deterioration in water quality. In terms of aquatic and riparian zone ecology relating to the MRA area, the Mfolozi River (aquatic assessment sites FUL1 and FUL2) is most significant. However, other drainage lines should also be taken into account when planning of the proposed mine takes place. In addition the Mvamanzi River, represented by aquatic assessment site FUL3, may also be impacted on and needs to be closely monitored. However, without impact from any mining activities the tributary already experiences seasonal no-flow conditions with associated negative impacts on water quality (increased salt levels). It is expected that activity proposed to take place within the MRA area may cause significant change to flows in the Mvamanzi River River and to a lesser extent the Mfolozi River. Factors which may play a role are indicated below: 

Construction of a dam in the Mvamanzi River for raw water supply to the mine;

243 | P a g e









Change in surface coverage. Development of the mining rights area will change the surface coverage in some areas from vegetated soil to buildings, hardened gravel roads, paved areas (parking), and compacted earth; Impacts of opencast pit mining would lower instream flow in the receiving environment and may lead to catchment yield changes due to a cone of dewatering formed by open pits close to the Mfolozi River; Separation and management of clean and dirty water and capture of run-off and capture of rainfall in the ‘dirty’ area would lower instream flow in the receiving environment and reduce catchment yield; Canalisation of run-off. Intercepting run-off around mining activities and infrastructure could reduce the amount of time that water would take to reach the Mfolozi River. This is likely to occur due to the decreased friction on the water associated with concentrated flow in a concrete-lined canal as opposed to sheet flow on a hill slopes, and the consequently higher flow velocities and shortened peak flows and reduced streamflow regulation in the system.

The above factors are likely to lead to altered riverine recharge flood peaks and a general loss of runoff volumes successfully reaching the Mfolozi River system as well as the other drainage systems in the area. This in turn may lead to the loss of aquatic biota such as fish and aquatic macro-invertebrates which rely on the presence of surface water. It must however be noted that the loss of catchment yield in the Mfolozi River due to the proposed mining activity is low (WSM, 2015) Aspects of instream flow affected Construction

Operational Loss of instream surface and base flow

Decommissioning and Closure Loss of instream surface and base flow

Loss of streamflow regulation and stream recharge

Loss of streamflow regulation and stream recharge

Loss of streamflow regulation and stream recharge

Loss of aquatic habitats and refugia for aquatic macro-invertebrates and fish

Loss of aquatic habitats and refugia for aquatic macro-invertebrates and fish

Loss of aquatic habitats and refugia for aquatic macro-invertebrates and fish

Increased moisture stress on riparian vegetation

Increased moisture stress on riparian vegetation

Increased moisture stress on riparian vegetation

Loss of instream surface and base flow

4.4.2.2 Impacts on Water Quality The Mfolozi River (sites FUL1 and FUL2) is the most significant aquatic system linked to the MRA area which may be impacted on and requires the most attention when considering impacts on reduced water quality and the impact it may have on the aquatic community. However the Mvamanzi River represented by site FUL3 will also be impacted and although the significance of this system on a regional is lower than the Mfolozi River impacts on water quality affecting the Mvamanzi River have the potential to significantly affect the water quality within this system and in particular the lower areas in the system which are of high ecological significance. As mentioned in the aquatic ecological baseline study the Mvamanzi River system already appears to be suffering water quality fluctuations resulting from seasonal flow rate changes and salinisation.

244 | P a g e

Consequently current analyses of biota specific water quality indicated very high salt loads in the tributary at site FUL3 and are deemed likely to constrain the aquatic community in the system. 











Increased sediment load: Increased erosion of disturbed surfaces means that the run-off contains a higher silt or sediment load are likely to contaminate the Mfolozi River as well as the Mvamanzi River system. The current natural state of the MRA area, the vegetation cover causes friction to rainfall run-off which reduces flow velocities and consequently shear forces between the water and the ground surface, resulting in the ground surface remaining intact and not being eroded away. If for any reason the ground surface is disturbed and the flow velocities are increased then there is potential for significantly increased erosion to occur. Increased sediment load contains suspended solids. If there are too many suspended solids in the water this can negatively affect biological life and affect refugia in the Mfolozi River system. The following activities are likely to cause an increase in movement of sediment loads, or directly increase erosion: o Stripping (vegetation clearance) of mining areas prior to excavation of pits and stockpiles areas; o Construction of hard-standing areas that increase run-off volumes, including roads, buildings and paved areas; o Canalisation of run-off, particularly if canals do not discharge directly into the Mfolozi River; and o Construction activities that loosen the ground surface. Impaired water quality due to pollutants released from processing plant: Wastewater from the coal ore beneficiation process would contain pollutants in excess of the target water quality ranges for the water uses of the receiving water body. The potential release of wastewater would thus impact negatively on the surface water quality. A further consideration is the run-off of pollutants from the process plant area following rainfall, due to the activities within that area. Impaired water quality due to pollutants in run-off from stockpiles: It is likely that run-off from the stockpiles will have a different chemical composition to natural run-off. In this event it is best practice to keep ‘dirty’ water from stockpile run-off separate from ‘clean’ water from natural runoff. Impaired water quality due to pollutants in water released from open pits: Overflow of water (decant), whether surface or ground, from the pits could release pollutants to the surface water environment if geochemical testing indicates a possible acid mine drainage or other water quality issue. Impaired water quality due to petrochemical spills: Fuel or oil spills from vehicles could contaminate surface water resources. Leakages, spills or run-off from vehicle wash bays, workshop facilities, fuel depots or storage facilities of potentially polluting substances could contaminate surface water resources. Heavy metal contamination: Increase in metal concentrations is commonly associated with tillage and blasting of the upper crust of the earth’s surface. This releases metals into the associated surface and ground water systems. Under alkaline conditions, most of the metals remain biologically unavailable, however in the presence of acid mine drainage the metal-speciation changes and they become available. This may alter the species composition of the aquatic biota inhabiting the surrounding rivers especially downstream of the proposed development. This is particularly significant due to the presence of the WHS downstream of the site which plays host to a diversity of species such as waterfowl and crocodile as well as predatory fish species known to be affected by bioaccumulation and biomagnification. 245 | P a g e

Aspects of instream water quality affected Construction

Operational

Decommissioning and Closure

Impact on riparian vegetation structures due to impaired water quality

Impact on riparian vegetation structures due to impaired water quality

Impact on riparian vegetation structure due to impaired water quality

Build-up of contaminants in sediments leading to the creation of a sediment sink and chronic source of potential water contamination

Build-up of contaminants in sediments leading to the creation of a sediment sink and chronic source of potential water contamination

Latent release of contaminants in sediments leading to the formation of an ongoing source of potential water contamination

Impacts on groundwater quality which could manifest in surface water sources

Impacts on groundwater quality which could manifest in surface water sources

Potential bioaccumulation and biomagnification in fauna located in the Mfolozi River system

Potential bioaccumulation and biomagnification in fauna located in the Mfolozi River system

4.4.2.3 Loss of Aquatic Habitat Habitat transformation and destruction is the alteration of a natural habitat to the point that it is rendered unfit to support species dependent upon it as their home territory. Loss or transformation of habitat may cause a reduction of biodiversity, due to organisms previously using the area being displaced or destroyed. Globally modification of habitats for agriculture is the chief cause of such habitat loss. Habitat destruction is presently ranked as the most significant cause of species population decrease and ultimately species extinction worldwide. Additional causes of habitat destruction include surface mining, deforestation, slashand-burn practices, urban development, water pollution, introduction of alien species, over grazing and over harvesting of resources such as fishing. Riverine systems and particularly temporary riverine systems or river systems that have very low flows as part of their annual hydrological cycles are particularly susceptible to changes in habitat condition. The proposed mining activity of the proposed Fuleni Anthracite Project has the potential to lead to habitat loss and/or alteration of the aquatic and riparian resources on the mining rights area, with special reference to the smaller tributaries exemplified by site FUL3 as well as the loss of refugia within the Mfolozi River system. Aspects of instream habitat affected Construction

Operational

Decommissioning and Closure

Erosion and incision of riparian zone

Erosion and incision of riparian zone

Erosion and incision of riparian zone

Altered wetting patterns leading to impacts on riparian zone continuity

Altered wetting patterns leading to impacts on riparian zone continuity

Altered wetting patterns leading to impacts on riparian zone continuity

Loss of low flow refugia

Loss of low flow refugia

Loss of low flow refugia

Altered substrate conditions from sandy conditions to more muddy conditions

Altered substrate conditions from sandy conditions to more muddy conditions

Altered substrate conditions from sandy conditions to more muddy conditions

Altered depth and flow regimes in the major drainage systems

Altered depth and flow regimes in the major drainage systems

Alien vegetation proliferation

Alien vegetation proliferation

Alien vegetation proliferation

246 | P a g e

4.4.2.4 Loss of Aquatic Biodiversity and Sensitive Taxa Loss or a decrease of aquatic biodiversity and sensitive taxa is largely driven by impacts stressed by instream flow, altered water quality and habitat loss. The aquatic resources in the area do not however support, or potentially support, an aquatic community of significant diversity and sensitivity in the immediate area. The monitoring of aquatic communities such as macro-invertebrates and fish within aquatic systems vary over season and other factors such as weather play a vital role when field studies are conducted. It is thus crucial to implement a regular monitoring strategy which will increase the data set and understanding of the aquatic community within the surrounding aquatic systems linked in the vicinity of the proposed mining area. It is recommended that a biannual high flow (summer) and low flow (winter) biomonitoring strategy be implemented as part of the ongoing monitoring program with an initial quarterly assessment prior to major construction in the area. The planned mining activities of the proposed Fuleni Anthracite Project have the potential to lead to a loss of aquatic biodiversity due to all the project aspects mentioned above since impacts on instream flow, water quality and habitat will all affect species diversity and especially more sensitive taxa and species of conservation concern. Aspects of aquatic biodiversity affected Construction Sedimentation and loss of natural substrates

Operational Sedimentation and loss of natural substrates

Decommissioning and Closure Sedimentation and loss of natural substrates

Altered stream channel forms

Altered stream channel forms

Altered stream channel forms

Increased turbidity of water

Increased turbidity of water

Loss of refugia

Loss of refugia

Loss of refugia

Deterioration in water quality with special mention of impacts from, heavy metals and salinisation

Deterioration in water quality

Deterioration in water quality with special mention of impacts from, heavy metals, AMD And salinisation

Eutrophication of the aquatic ecosystems

Loss of flow sensitive macroinvertebrates and fish

Eutrophication of the aquatic ecosystems

Loss of flow sensitive macroinvertebrates and fish

Loss of water quality sensitive macroinvertebrates and fish

Loss of flow sensitive macroinvertebrates and fish

Loss of water quality sensitive macroinvertebrates and fish

Loss of riparian vegetation species

Loss of water quality sensitive macroinvertebrates and fish

Loss of riparian vegetation species

Loss of riparian vegetation species

Loss of sensitive species and species of conservation concern in the Mvamanzi river as well as the downstream areas of the Mfolozi River

Loss of sensitive species and species of conservation concern in the Mvamanzi river as well as the downstream areas of the Mfolozi River

Loss of sensitive species and species of conservation concern in the Mvamanzi river as well as the downstream areas of the Mfolozi River

247 | P a g e

4.4.2.5 Summary The aquatic impact study (ANNEX-3) identified that the aquatic resources in the local area assessed are of high ecological importance and sensitivity largely due to supporting protected species and the proximity to the HiP. In addition the significance of impacts on the downstream iSimangaliso Wetland Park had to be considered. Mitigation measures available will limit the impact on the aquatic biota within and reliant on the systems. Prior to mitigation the impact on the Mvamanzi River is considered high while the impact on the Mfolozi River is considered Medium high. With mitigation the impact on the Mvamanzi River is considered moderately high while the impact on the Mfolozi River is considered moderately low. Table 71 summarises the aquatic impact assessment on the Mvamanzi River and the Mfolozi River including the downstream areas and including potential impact on iSimangaliso Wetland Park. From the results of the assessment it is evident that prior to mitigation all impacts on the Mvamanzi River are high. Even with mitigation impacts on the Mvamanzi River will remain high with the only impact reduced to medium high levels being the impact on species diversity and species of conservation concern. From the results of the assessment it is evident that prior to mitigation all impacts on the Mfolozi River are medium high. Even with mitigation impacts on the instream flow as well as water quality of the Mfolozi River will remain moderately high with the impacts on habitat and species diversity and species of conservation concern will be reduced to medium high levels. Table 71: Summary of impact significance on the Mvamanzi and Mfolozi Rivers

No

Impact

Unmanaged

Managed

Mvamanzi River 1

Loss of instream flow

High

High

2

Impacts on water quality

High

High

3

Loss of Aquatic habitat

High

High

4

Loss of Aquatic Biodiversity and sensitive taxa

High

Medium - High

SUMMARY

High

High

Mfolozi River 1

Loss of instream flow

Medium - High

Medium - High

2

Impacts on water quality

Medium - High

Medium - High

3

Loss of Aquatic habitat

Medium - High

Medium - Low

4

Loss of Aquatic Biodiversity and sensitive taxa

Medium - High

Medium - Low

SUMMARY

Medium - High

Medium

248 | P a g e

4.4.3 IMPEDANCE OF WATERCOURCES AND FLOOD-LINES The following generic impact types are based on the prescribed buffer zones as delineated by floodlines or prescribed distances:  



Impact A: The footprint of the proposed opencast mining activity intersects the 1:50 year floodline which requires mitigation in order to safeguard the mine. Impact B: The proposed mining infrastructure layout may cause an obstruction to the natural drainage regime of a particular stream or river, which in turn could eliminate the contribution of that stream or river to the larger drainage system further downstream. Impact C: The footprint of the proposed mining facilities (e.g. plant, ponds, residue deposits and other) intersects the 1:100 year floodline. More detailed studies of the underlying strata are required to determine the possible impacts that the activities will have on the receiving water body, including sub-soil strata, to determine suitable mitigation measures.

249 | P a g e

Figure 101: Impedance of water courses and floodlines at Pits 1 & 2

250 | P a g e

Figure 102: Impedance of water courses and floodlines at Pits 3 & 4 and the CHPP

251 | P a g e

Figure 103: Impedance of water courses and floodlines at Pits 4, 5 & 6

252 | P a g e

4.4.4 IMPACTS ON QUANTITY 4.4.4.1 Impact on mean annual runoff (MAR) to the Mfolozi River Mean annual runoff (MAR) from the Project site into the Mfolozi River via its affected tributaries is anticipated to be primarily affected by the following: 



Direct rainfall in the opencast pits. Rain falling directly into the pits will collect in a sump at the bottom of the pit/s and thus be polluted. This water may be recycled for use, or be evaporated in dirty water dams, thereby decreasing the MAR of the river. Concentration of flow when runoff is intercepted by canals. The canal system will intercept run-off that would otherwise have flowed naturally over the ground surface until reaching a defined watercourse. Vegetation and surface topography, particularly in flatter areas, would in the natural state have encouraged interception and infiltration. Once water has been intercepted by a canal however, no further interception or infiltration is likely until the canal discharges the flow into a watercourse. There is thus likely to be a marginal increase in MAR resulting from the construction of the canal system.

The total cumulative impact of the proposed mining infrastructure on runoff is shown in Table 72. The mining footpring will cause a small reduction in annual runoff of 1.26% of the MAR of the quaternary catchment W23A, or in broader terms an extremely low reduction of 0.06% of the MAR of the Mfolozi River catchment area. The total reduction in runoff is based on the worst case scenario at the end of the LOM, assuming that no rehabilitation of the pits has been done and the overburden dumps and plant areas retain polluted runoff. Table 72: Total reduction in runoff downstream of the Fuleni Anthracite Project

Description

Affected area (ha)

Discards

11.7

Pits

356.9

Roads

153.8

Total for site

522.4

Quaternary catchment area W23A (ha)

Mfolozi catchment area (ha)

% of quaternary catchment W23A

% of Mfolozi catchment area

41 400

925 400

1.26%

0.056%

Note: Based on worst case scenario with no rehabilitation in place.

4.4.4.2 Change to peak flow rates in the Mfolozi River and its affected tributaries during flood conditions A substantial increase to the peak flow of flood events in the Mfolozi River and its major tributaries could cause erosion and change in channel character and dimensions, destroy riverine vegetation, alter bed roughness and cause eroded sediment to be deposited downstream. However, it is expected that the project activities will cause a slight change to peak flows in the Mfolozi River and its major affected tributaries downstream of the mining footprint area, due to the following factors:

253 | P a g e



 

Change in surface coverage. Development of the mining footprint area will change the surface coverage in some areas from vegetated soil to buildings, hardened gravel roads, paved areas (parking), and compacted earth. These new surface types will allow considerably less infiltration into the ground (typically 0-20%) than the natural surface (typically 60-70%), resulting in more surface runoff following storms and consequently higher peak flow rates. Capture of Run-off. Capture of runoff in the form of an impoundment or in the pits would lower peak flow rates. Canalisation of runoff. Intercepting runoff from the hill-slopes above the open pits and canalising the flow could reduce the amount of time that water would take to reach the Mfolozi River. This is due to the decreased friction on the water associated with concentrated flow in a concrete-lined canal as opposed to sheet flow on the hill slopes. In technical terms, the time of concentration would be reduced and reducing the time of concentration results in higher peak flow rates. This effect is dependent on the design of the canal system, as increasing the length of flow paths, and implementing other detention measures, could negate this effect.

4.4.4.3 Drying up of tributaries and establishment of new watercourse due to canalization A cut-off canal system is required to separate unpolluted (‘clean’) and polluted (‘dirty’) water, which is a positive intervention. However, intercepting the tributaries that flow from the water divide across the mining areas, and redirecting them via canals around the pits, will starve those same watercourses of water along their reach between the point of interception and the discharge of the canals into the same river course. It is probable that in many instances the canals may discharge into a different watercourse which will have a more serious effect on the impacted streams. Furthermore, if the canals only extend as far as to route water around the outer edge of the opencast pits, then concentrated volumes of water will be discharged at point locations on the hill slopes. Also, the soils most susceptible for erosion are those where sandy topsoil overlies structured sub-soils. When considered together, this information suggests that the soils on the hill slopes are particularly prone to erosion. Hence rather than dispersing out over the surface, the concentrated flow at the canal discharge points would erode gulleys into the soil and carry silt into the Mfolozi River and its affected tributaries, impacting on water quality.

4.4.5 IMPACTS ON QUALITY The philosophy supporting the impact section on water quality is that if all constituents in the cumulative discharge from the project site are within the applicable target water quality ranges, then the project activities will not contribute significantly to an unacceptable cumulative impact. The converse of this statement is not necessarily true, as different activities within the catchment may discharge different pollutants at different concentrations, and the dilution effect may mean that a constituent that is out of the target water quality range in the cumulative discharge from the project site is within the target water quality range when the discharge is combined with the Mfolozi River flow itself. However the Precautionary Principle requires that a conservative approach be taken, in this case to account for possible discharge of pollutants by future activities in the river catchment, and therefore the dilution effect of the Mfolozi River cannot be relied upon. 254 | P a g e

4.4.5.1 Increased sediment load in the Mfolozi River and its affected tributaries In the natural state of the project site vegetation cover reduces flow velocities and concomitant erosion – a stable state has normally been reached. If for any reason flow velocities are increased, there is potential for increased erosion to occur.Increased erosion means that the runoff contains a higher silt or sediment load, which is discharged to the Mfolozi River. A component of this sediment load is particles fine enough to remain in suspension, ‘clouding’ or ‘muddying’ the water. The extent of this effect can be quantified by measuring the suspended solids in the water – high concentrations can negatively affect biological life. In addition, a changed sediment load could have similar morphological effects to the river as changing peak flow rates, such as changes in channel character or dimensions and changes to bed roughness. All of these changes could potentially affect biological life. The following activities are likely to cause an increase in flow velocities, or directly increase erosion:    

Stripping (vegetation clearance) of mining areas prior to excavation of pits; Construction of hard-standing areas that increase runoff volumes, including roads, buildings and paved areas; Canalisation of run-off, particularly if canals do not discharge directly into the Mfolozi River; and Construction activities that loosen the ground surface.

Furthermore, if runoff from the stockpiles is uncontrolled, such runoff would likely contain a high sediment load due to the fine particles in the waste product resulting from the ore crushing process. It can thus be stated that without any mitigation measures, the sediment load in the Mfolozi River and its affected major tributaries will increase as a result of mining activities. 4.4.5.2 Impaired water quality due to pollutants in runoff The water chemistry modifications due to the coal mining activities generally follow three common trends; downstream water becomes more saline, the pH of the water becomes more acidic and the water also develops a strongly modified ionic composition. Wastewater from the coal ore beneficiation process would contain pollutants in excess of the target water quality ranges for the water uses of the receiving water body and discharge of this would impact negatively on the surface water quality. A further consideration is the runoff of pollutants from the process plant area following rainfall, due to the activities within that area. Overflow of water (decant) from the pits, whether into surface or groundwater, could release pollutants to the surface water environment if geochemical testing indicates a possible acid mine drainage or other water quality issue. However, the groundwater assessment (Groundwater Complete, 2015) has found that although the coal and anthracite seams have potential for generating acid, the overburden and interburden layers (to be used in rehabilitation) is non-acid generating. Therefore it was concluded that the potential for acid generation post-closure is generally low, also since the majority of acid-forming material will have been removed. When water levels have recovered after mine closure, the mine should investigate the need for management measures to deal with poor quality water, if it occurs.

255 | P a g e

4.4.5.3 Impaired water quality due to hydrocarbon product spills Leakages, spills (petrol, diesel, oils/lubricants) or runoff from vehicle wash bays, workshop facilities, fuel depots or storage facilities of potentially polluting substances has the potential to contaminate surface water resources. Coal mining, especially strip mining, affects the area that is being mined. Characteristically, the material closest to the coal is acidic. After the mining is completed, the land will remain barren unless special precautions are taken to ensure that proper topsoil is used when the area is replanted. Materials other than coal are also brought to the surface in the coal mining process, and these are left as solid wastes. As the coal itself is washed, more waste material is left. 4.4.5.4 Impact of groundwater interaction on surface water sources From the perspective of the groundwater specialist (ANNEX-5), the drainage areas in the MRA area are mostly characterised as non-perennial, losing streams under steady state conditions. For groundwater to contribute to surface drainage or base flow to streams, the static water level of the aquifer needs to be at the same elevation or higher than the base of the stream. The measured static water levels in the Fuleni mining area vary between 7 and 55 mbs (meters below surface). Therefore base flow to the streams in the area is only expected for short periods after rainfall events. This water is then also referred to as ‘soil water’ rather than groundwater. Base flow may however occur to the larger rivers such as the Mfolozi, Ntutunga and Mvamanzi Rivers. The area is made up of a rather complex array of numerous structures such as dykes which can act as groundwater flow barriers or preferred flow paths along the dykes where fracturing occurred. For this reason it is difficult to determine where and if polluted flow from the mine will daylight in the rivers. According to numerical model simulations a groundwater pollution plume is expected to reach the position of the Ntutunga River 100 years post closure. All water levels measured during the study were well below the base of the rivers, therefore little or no impact is expected apart from temporary effects in extremely wet seasons. The aquifers (alluvial, weathered and deep secondary) are therefore expected to receive water from the streams, if/when run-off occurs. Furthermore, groundwater discharge as base flow from the aquifer(s) is not expected the reach the streams. The surface water environment is thus not expected to be receptors of groundwater contamination impact.

4.4.6 IMPACTS ASSOCIATED WITH THE SUPPLY DAM ON THE MVAMANZI RIVER 4.4.6.1 Impact on surface water quantity From the engineering data, the yield of the dam at 0.564 million m3 is 5.75% of the MAR at the dam site. The total system losses, ignoring the possibility that the seepage losses contribute to the groundwater source, and eventually to baseflow in the nearby Mvamanzi Pan and Mfolozi River, was calculated to be 1.02 million m3/a. This equals losses of 10.12% of the naturalised MAR at the dam site. Considering the impact on Catchment W23A, which has a MAR of 37.2 million m3/a, the reduction in runoff to the Mfolozi River amounts to losses of 2.74% of the quaternary catchment MAR. When the impact on

256 | P a g e

the Mfolozi River catchment is considered, which has a MAR of 794 million m3/a, the reduction in runoff amounts to losses of 0.13% of the Mfolozi River catchment MAR. 4.4.6.2 Impact on the hydrological system and river dynamics, including surface water quality The main hydraulic effect is the discharge of part of the Quaternary Catchment runoff to a stationary reservoir instead of a stream bed. Therefore, an instant change will start downstream; the downstream part of a stream dries partially or totally whenever the reservoir begins to accumulate water. During this temporary or periodically repeating time interval, the hydrological balance can collapse. However, after completion, environmental releases will be made and the dam spills on average 85% of the MAR. The wetland can thus be maintained. The construction period and first filling of the reservoir is the most crucial period. Special measures are required to assure continuation of a normal flow pattern to the wetland during construction. Such a requirement will lead to a slower filling of the reservoir than under conditions where all dam outlets can be closed off. Although after this process, the stream forms a new and healthy ecosystem in this part of it, there will be a permanent, though at this stage undefinable impact on the system due to the flow losses of 10% of the MAR. The impact of such a reduction is intensified in dry periods. 4.4.6.3 Impact associated with potential dam breakage The supply dam was designed by Prodelko which adopted the South African National Committee of Large Dams (SANCOLD) guidelines for their design. The guidelines provide a clear understanding of the hazard rating of the dam, which also prescribes the Recommended Design Flood (RDF) along with the Safety Evaluation Flood (SEF). In the event of dam failure the downstream section to the confluence of the Mfolozi River will be impacted on due to high flood water levels, high flow velocities and sediment settlement. Such an event may cause erosion of the downstream river, loss of riverine vegetation, loss of livestock and human lives. Preventative measures such as flood awareness and flood observation programs should be implemented. Figure 104 shows the extent of the Dam Break Floodline along with the SEF flood level, superimposed on the social mapping. No houses will be impacted in the event of a dam breakage. Operation and Maintenance (O&M) requirements of the dam should include the following but not limited to: 



The embankment dam should be inspected at regular intervals (as per DWA Dam safety office) for evidence of the development of unfavourable conditions. The downstream slope should be carefully inspected for indications of cracks, slides, sloughs, subsidence, and impairment of slope protection, springs, seeps, or boggy areas caused by seepage from the dam. The upstream slope of the embankment should be carefully inspected for adequate protection of the embankment. The maintenance of the embankments and spillway should consist of the removing of debris (upstream face), replacing disintegrated riprap, repairing eroded material, controlling undesirable vegetation and rodents. 257 | P a g e

Figure 104: Extent of the dam breakage floodline and SEF flood level

4.4.7 IMPACTS ON SENSITIVE ENVIRONMENTAL RECEPTORS 4.4.7.1 Mvamanzi Pan The construction of the dam will have both a negative and a positive impact on the downstream Mvamanzi Pan. During the construction phase of the dam, an increase in sediment load could be expected, although the construction will take place in the dry months of the year. The dam will also take a while to fill up to full supply level before it releases the naturalised mean annual runoff. It is envisaged that, except in dry periods, the water supply to the plant area will make use of water collected during storm events and not necessarily have a large impact on the MAR of the Mvamanzi River. The positive impact of the dam is that it will act as a sediment trap in a catchment area well-known for its high yielding sediment loading. The dam will have a low impact on water supply to the downstream Mvamanzi Pan provided that the required ecological releases from the dam are implemented.

258 | P a g e

4.4.7.2 Lake St Lucia The cumulative reduction of the MAR of the total Mfolozi River catchment area at the mouth of Lake St Lucia is shown in Table 73. This is considered negligible. Table 73: Estimated reduction on Mfolozi river runoff at Lake St Lucia Affected area (ha)

Description Discards

11.7

Pits

356.9

Roads

153.8

Total for site

522.4

Quaternary catchment area W23A (ha)

Mfolozi catchment area at Lake St Lucia (ha)

% of quaternary catchment W23A

% of Mfolozi catchment area at Lake St Lucia

41 400

1 000 800

1.23%

0.050%

Based on worst case scenario with no rehabilitation in place.

4.4.7.3 iSimangaliso Wetland Park From the results of the pollution study at other mines in the catchment, it was found that the impact of severe pollution was dissipated over a distance of 18 km. The distance from the eastern boundary of the Fuleni Anthracite Project to the N2 road is 24 km. From the N2 road to the estuary adds a distance of 40 km, thus a total of 64 km before any runoff from the MRA area will reach Lake St. Lucia, if the Mfolozi River is connected to the Lake. From the calculations above on impact on flow quantity, it was shown that the impact on the Mfolozi River and thus the on iSimangaliso is very low. 4.4.7.4 The HiP The HiP is located in the quaternary catchment W21L drainage system and the proposed mining footprint area in the W23A quaternary catchment. The quaternary water divide is shown in Figure 105. This means that water from the mining area’s drainage system would not have an impact on the HiP’s drainage system.

Figure 105: Catchment divide between quarternary catchments W23A and W21L

259 | P a g e

GROUNDWATER

4.5

4.5.1 GROUNDWATER IMPACT MODELLING For a negative groundwater quality impact to be registered the following three aspects should be present: Source to generate and emit contamination

Pathway along which contamination is transported

Receptor to receive contamination

A source area is defined as an area in which groundwater contamination is generated or released from as seepage or leachate. Source areas are subdivided into two main groups:  

Point source: The contamination can easily be traced back to the source and typically includes mining infrastructure such as tailings dams, discard dumps, pollution control dams, etc. Diffuse source: The exact source/s of the contamination is unknown, which is typically the case with contaminated surface runoff water.

In order for contamination to reach and eventually affect groundwater users, it needs to travel along a preferred pathway. Pumping tests were performed on purpose drilled groundwater monitoring boreholes and the data were evaluated with analytical software to determine aquifer parameters such as transmissivity. Aquifer transmissivity is an important parameter as it provides a measure of the amount of water or pollution that can be transmitted horizontally through a unit width of aquifer by the full-saturated thickness of the aquifer under a hydraulic gradient of 1. Pumping tests are used to calculate the aquifer transmissivity and the few tests in the Fuleni Anthracite Project region produced low transmissivities. Numerous dykes produce numerous flow boundaries and compartments, concluding that the aquifer host rock of the area is a poor pathway for flow and mass transport. Groundwater flow and contaminant transport within the aquifer depend directly on the hydraulic gradient. The groundwater hydraulic gradient is therefore another very important parameter in determining the effectiveness of the aquifer as a pathway for contamination. An average groundwater gradient of ± 3 to 8% was calculated for the mining area, which is relatively low and restricts the movement of groundwater and contamination through the aquifer system. The aquifer is therefore considered a poor pathway for contamination. Please note that areas of higher/lower transmissivities and gradients are likely to exist due to the extremely heterogeneous nature of the fractured rock environment. The extent of permeable/transmissive fractures is however generally limited. On a localized scale there may be higher flow rates but the regional rate is directly determined by the lowest permeability.

260 | P a g e

4.5.1.1 Potential Source Areas Many of the proposed activities may cause groundwater quality impacts to occur in the Fuleni Anthracite Project area. The proposed infrastructure to be developed includes:         

Topsoil and overburden stockpiles (dry source); Haul roads and/or conveyor systems for ROM transport (dry source); ROM handling facility (dry source); Coal Handling Processing Plant (CHPP) with associated stockpiles (dry source); Pollution control dams (wet source); Temporary discard facility (dry source); Raw water storage facility(ies) and distribution systems (wet source); Access road to mine and for product transport (dry source); and Auxiliary infrastructure including workshops and stores, offices and change houses, sewage treatment plant, main electrical power supply and security fencing (dry source).

Some of the sources listed above represent structures or activities that have an effect on groundwater quality due to infiltration of poor quality water/effluent – the so-called wet sources, or due to poor quality leachate generated through dry hazardous material – the dry sources. Wet sources can include storm water control dams, pollution control dams and other effluent containment facilities that are unlined or where liners have failed. These structures can result in mounding of the water levels as a result of artificial recharge to the aquifer. Elevated water elevations result in an increase in flow gradients which means higher flow rates. Dry sources include discard rock dumps, ROM handling facility, stockpile areas, etc. For dry facilities impact on the groundwater only occurs through leachate formation from surface. Impact thus only occurs as a result of rainfall recharge or when water is introduced in some form where leachate can form that seeps to the groundwater regime. The artificial recharge and mounding concept does not come into play with dry sources and therefore the intensity and rate of transport of contamination is far less significant than at wet sources. 4.5.1.2 Hydrostatic Units (Pathway) Aquifer types and characteristics in the Fuleni Anthracite Project area have been described in Section 2.4.8 above. Distinction between aquifers is generally based on the type of porosity in the aquifer, i.e. a primary aquifer formed by primary pore porosity or secondary aquifer formed due to secondary porosity. Secondary porosity, reflecting development of open space and voids with potential groundwater storage and aquifer development in an otherwise impermeable rock, occurs in the presence of weathering and/or fracturing of the rock mass. From studying numerous borehole logs and aquifer test results it followed that the aquifers are comprised of the typical secondary fractured rock type with fissures and fractures facilitating groundwater flow and mass transport. The majority of these water-bearing fissures occurred close to the weathered-fresh rock interface.

261 | P a g e

The most important characteristics for the weathered zone aquifer, the deep, secondary aquifer and the primary alluvial aquifer are discussed below. These three aquifers have been recognized and characterized in the Fuleni Anthracite Project region. The different types of aquifer porosity are illustrated below.

4.5.1.2.1 Weathered Zone Aquifer

Aquifer development and areas of highest permeability in the weathered zone aquifer correlate with the depth and degree of weathering of the bedrock as well as soil development and characteristics. This aquifer also occurs along the courses of the surface drainage features with limited aquifer development in bedrock outcrop areas where little or no weathering occurs. The shallow, weathered zone aquifer is developed to a limited extent in the Fuleni Anthracite Project area. According to the Parsons Classification system, the aquifer is usually regarded as a minor or even a nonaquifer system. Although groundwater seepage does occur in the weathered zone, the yields are very low and this zone cannot really be defined as an ‘aquifer’ according to the true meaning of the term. The main value and function of the shallow weathered zone ‘aquifer’ lies in the storage and transfer of moisture from rainfall to soil (laterally), vegetation (upwards) and the deeper aquifer (downwards). 4.5.1.2.2 Deep Secondary Aquifer

The second aquifer system is the fractured Karoo rock-type aquifer that is considered the main aquifer in the Fuleni Anthracite Project area. Groundwater yields, although more heterogeneous, can be higher than the weathered zone aquifer. This aquifer system usually displays semi-confined or confined characteristics with piezometric heads often significantly higher than the water-bearing fracture position. The aquifer forms in transmissive fractures in the consolidated and mostly impervious bedrock. The fractures may occur in any of the co-existing host rocks due to different tectonic, structural and depositional processes. The main characteristics of the deep aquifer are summarized below: 

The aquifer is developed in fractures (secondary porosity) from around near surface to more than 100 mbs. 262 | P a g e

     

Fracturing occurs in all rock typesbut are mostly located on the contacts of intrusive dolerite dykes or sills and in fault zones, although the latter are not well developed in the study area. Effective porosity is very low – estimated to be in the order of 5%. Yields are generally very low and vary from zero to 2 l/s. Water quality in the deep aquifer is generally very poor: Na-Cl dominant with elevated salinity. Where no secondary porosity is present the transmissivity is estimated at approximately 0.1 m2/d for the matrix and around 5 m2/d for the fractures. The storativity is difficult to determine accurately but is estimated to be between 0.0001 for fractures and 0.01 for thesedimentary rock matrix (Bredenkampet al., 1995).

4.5.1.2.3 Primary Alluvial Aquifer along the Mfolozi River

No direct information was obtained for the primary aquifer along the Mfolozi River. The primary alluvium aquifer is expected to be developed in some areas in the immediate vicinity of the Mfolozi River and other major river systems in the Fuleni Anthracite Project area. This aquifer is mostly recharged by the river and occurs in alluvial deposits as well as the weathered bedrock below and directly adjacent to the river. No information can be provided in terms of aquifer storage, yield, conductivity, water levels or even water quality. The relationship between the alluvial aquifer and the weathered zone aquifer (where present) and the secondary fractured rock aquifer could also not be established in the area. The 5 boreholes recorded during the second hydrocensus are not situated near the Mfolozi River and therefore do not intersect the alluvial aquifer. The hydrocensus was specifically performed to find boreholes that could represent the alluvial aquifer, but no such boreholes could be found.

Figure 106: Conceptual representation of the aquifers in the Fuleni Anthracite Project area

Please note that the above is only a conceptual representation of the aquifer systems in the area. Since no drilling was conducted during the groundwater study the relationships between the different aquifers and aquifer connectivity could not be established for the area.

263 | P a g e

4.5.1.3 Receptors Receptors refer to all groundwater users or other receptors within the immediate vicinity of the mining and/or processing activities. Two potential receptors are recognized in the Fuleni Anthracite Project area, namely:  

Direct users (humans) that utilize groundwater through boreholes as a source of water for domestic use, livestock supply, irrigation etc.; and The receiving surface water environment that can receive groundwater through base flow to rivers and streams.

4.5.1.3.1 Groundwater Users

A user survey was conducted and three active groundwater users were recorded within the mining footprint area. One of these localities, FUL17, is situated within the mining boundary of one of the proposed pits. Therefore, this borehole will be mined away during the mining process. FUL21 is also situated close to the proposed mining area and it is expected that the water level in this borehole may be influenced by mining. Therefore, the groundwater users of these two boreholes will have to be compensated by the mine for their loss. 4.5.1.3.2 The Surface Water Environment

The drainage areas in the Fuleni Anthracite Project area are mostly characterised as non-perennial, losing streams under steady state conditions. For groundwater to contribute to surface drainage or base flow to streams, the static water level of the aquifer needs to be at the same elevation or higher than the base of the stream. The measured static water levels in the Fuleni Anthracite Project area vary between 7 and 55mbs. Therefore base flow to the streams in the area is only expected for short periods after rainfall events. This water is then also referred to as ‘soil water’ rather than groundwater. Base flow may however occur to the larger rivers such as the Mfolozi, Ntuthunga and Mvamanzi Rivers. The area is made up of a rather complex array of numerous structures such as dykes which can act as groundwater flow barriers or preferred flow paths along the dykes where fracturing occurred. For this reason it is difficult to determine where and if polluted flow from the mine will daylight in the rivers. According to numerical model simulations a groundwater pollution plume is expected to reach the position of the Ntuthunga River 100 years post closure. All water levels measured during the groundwater study were well below the base of the rivers, therefore little or no impact is expected apart from temporary effects in extremely wet seasons. The aquifers (alluvial, weathered and deep secondary) are therefore expected to receive water from the streams if/when run-off occurs and that the streams do not receive groundwater discharge as base flow from the aquifer(s). The surface water environment is thus not expected to be receptors of groundwater contamination impact. 4.5.1.4 Numerical Flow and Mass Transport Modelling Numerical flow and mass transport groundwater models were constructed to simulate current aquifer conditions and impacts and to provide a tool for evaluation of different management options for the future. The reader is referred to the groundwater impact assessment (ANNEX-5) for more detail.

264 | P a g e

4.5.2 GROUNDWATER LEVEL IMPACTS 4.5.2.1 Simulated Groundwater Level Impacts at mine closure

Figure 107: Simulated cone of depression at mine closure with hydrocensus borehole positions

The cones of depression, or drawdown, caused by mine dewatering are given in Figure 107. According to the model simulations a maximum possible drawdown of more than 100 meters can be expected in Pit 4. The simulated drawdown in Pit 3 is deeper simply because the difference in thickness between the static water level and coal floor elevation is greater than in the other pits. The user boreholes located during the hydrocensus are also included in Figure 107. The extent of the cone of depression at mine closure is not expected to exceed 700 meters from the mining boundaries. The simulated depression cone is considered to be a worst case scenario. There are, however, factors like zones of higher transmissivity along which the cone of depression can extent further. Also clear in Figure 107 is the compartments formed by the structural geology. This is caused by dykes acting as flow barriers and the fractured zone along the dykes acting as preferred flow paths. The positions of the 3 drinking water localities are indicated in Figure 107. As is clear from the figure it is possiblethat FUL21 may be influenced by drawdown from mine dewatering. Drawdown at FUL21 can be as high as to 20 meters. Should this be the case, the mine should provide an alternative source to replace the loss. FUL17 will be mined away at Pit2 and the same applies to this source of water.

265 | P a g e

4.5.2.2 Groundwater Level Impacts 50 years post closure

Figure 108: Simulated drawdown at 50 years post-closure

Figure 108 indicates the simulated water levels 50 years post-closure. The groundwater level has not yet recovered in all the areas. At Pits 1, 3 and 4 the water level still needs to recover up to 16 meters to be as close as possible to the pre-mining water levels. The extent of the cone is still not expected to exceed more than 700m from the void boundaries. The extent of the cone is somewhat larger, since the voids remain groundwater sinks and over time the gradient decreases but the extent increases. At 100 years postclosure the water level is estimated to have recovered completely. Summary:     

Groundwater level impacts are expected to be more severe in Pits 1, 3 and 4. Due to the cone of depression created by mine dewatering, the natural flow directions of the groundwater will be influenced. Until a new groundwater level equilibrium has been reached, groundwater will move radially inwards towards the pits. The overall maximum cone of depression is not expected to extend more than 700 m from the mining pits. Drawdown at FUL21 can be as high as to 20 meters. Should this be the case, the mine should provide an alternative source to replace the loss. FUL17 will be mined away at Pit2 and the same applies to this source of water.

266 | P a g e

4.5.3 IMPACT ON GROUNDWATER QUALITY 4.5.3.1 The potential for acid rock drainage (ARD) or poor quality leachates 4.5.3.1.1 Acid-Base Accounting

Acid-base accounting (ABA) is done to determine the acid generating and neutralizing potential of a mine by completely oxidizing the coal and overburden samples after which their initial and final pH values are compared. ABA was done in the proposed Fuleni Anthracite Project area. The following criteria were used on the ABA test data to assess the potential for each of the samples to generate ARD: 



The difference between the acid-neutralising potential and acid-generating potential is known as the net-neutralising potential (NNP = NP – AP). Therefore, whenever the NNP is a negative value the acid potential exceeds the base potential, suggesting that water leaching through this material will tend to turn acidic. Any sample with NNP < 20 is potentially acid-generating, while any sample with NNP > -20 might not generate acid. NNP < 0

Potentially acid forming

NNP > 0

Non-acid forming

The ratio of NP:AP is termed the Net Potential Ratio (NPR). ARD screening criteria based on NPR and sulphur % are

Type I

Potentially acid forming

Total Sulphur> 0,25 % and AGP:GNP ratio 1:1 or less

Type II

Intermediate

Total Sulphur> 0,25 % and AGP:GNP ratio 1:3 or less

Type III

Non-acid forming

Total Sulphur> 0,25 % and AGP:GNP ratio 1:3 or greater

Note:

AGP - Acid generation potential (kg CaCO3/tonne), GNP - Gross neutralisation potential (kg CaCO3/tonne), NNP - Nett neutralisation potential (kg CaCO3/tonne), OB – Overburden.

The results of the ABA tests are provided in Table 74. Fourteen samples were collected for the tests. The samples consisted of material from the B seam lower, upper and anthracite seam itself as well as the interburden material between the seams and the overburden material above the seams.   

Of the 14 samples, two samples from the anthracite seam indicated a potential for generating acid water. Two samples taken from the B upper seam showed intermediate potential for generating acid. The remaining ten samples showed to be non-acid generating.

The conclusion can therefore be made that the coal and anthracite seams can have potential for generating acid but that the overburden and inter-burden (between different coal layers) material, eventually used for rehabilitation, is non-acid generating. Therefore, the potential for acid generation post-closure is generally low since the acid forming material will be removed. Studies at the nearby Somkhele Anthracite Mine also indicating the potential of acid-generation by the coal and anthracite seams itself, but indicated that the in-

267 | P a g e

pit water after rehabilitation is expected to be neutral in pH. No decrease is groundwater qualities when compared to natural qualities are expected post-closure (GCS, 2002). Table 74: Results of ABA tests

Acid – Base Accounting Modified Sobek (EPA-600)

GT 1-4 BI

GT 2-3 BI

GT 1-4 BU

GT 2-3 BU

GT 3-2 BU

GT1-4 BB

GT 2-3 BB

2819

2820

2821

2822

2823

2824

2825

Paste pH

8.9

8.8

8.4

8.2

8.6

8.7

8.8

Total Sulphur (%) (LECO)

0.07

0.12

0.43

0.25

0.34

0.19

0.37

Acid Potential (AP) (kg/t)

2.19

3.75

13.4

7.81

10.6

5.94

12

Neutralization Potential (NP)

18

5.7

112

25

12

170

11

Nett Neutralization Potential (NNP)

16

1.95

99

18

1.14

164

-1.04

Neutralising Potential Ratio (NPR) (NP : AP)

8.2

1.52

8.34

3.25

1.11

29

0.91

Rock Type

III

III

II

III

II

III

I

GT 3-2 BB

GT 1-4 BHW

GT 1-4 BHW

GT 2-3 BHW

GT 3-2 BHWB (Hanging Wall)

GT 3-2 B Inter

GT 3-2 B Inter

2826

2827

2827 D

2828

2829

2830

2830 D

Paste pH

8.3

8.7

8.6

8.9

8.6

8.5

8.5

Total Sulphur (%) (LECO)

0.46

0.02

0.02

0.02

0.07

0.12

0.12

Acid Potential (AP) (kg/t)

14

0.63

0.63

0.63

2.19

3.75

3.75

Neutralization Potential (NP)

8.42

33

33

8.67

5.7

6.81

4.58

Nett Neutralization Potential (NNP)

-5.96

33

32

8.04

3.51

3.06

0.83

Neutralising Potential Ratio (NPR) (NP : AP)

0.59

53

53

14

2.6

1.82

1.22

I

III

III

III

III

III

III

Sample Number

Acid – Base Accounting Modified Sobek (EPA-600) Sample Number

Rock Type Note:

BB BI BU B-Inter B-HW

= B Seam Anthracite; = B lower seam; = B upper seam; = interburden / waste rock between seams; = overburden / waste rock above seams.

4.5.3.1.2 Leaching Tests

In basic terms a leaching test involves the percolation of a liquid through a finely crushed rock sample after which the leachate retrieved from the sample (extract) is analysed to determine what chemical changes have occurred. Different liquids are used for different purposes and numerous documented leach procedures exist. For the Fuleni Anthracite Project samples the so-called distilled Water Leach was used. The distilled water leach is considered a realistic scenario that can materialize in the Fuleni Anthracite Project area. The rainfall in the region is not acidic and the quality of the rain water is very similar to that of distilled water. 268 | P a g e

The results of the leaching tests are provided in Table 75 and are compared against the water quality objectives as stated in the SANS 241:2011 guidelines. Parameters highlighted with red are those that exceed the guideline concentrations. The Aluminium content of the leachate exceeds the guideline concentration of 0.5 mg/l in all samples but three. Sulphate data from the leaching tests indicates that sulphate remains low and well within guidelines. Elevated sulphate is associated with acid generation. Therefore, acid generation from leaching is not expected in the Fuleni Anthracite Project area. Table 75: Results of leaching tests on coal and overburden Chemical Parameter

Al

Class 0

Ideal

0 - 0.3

Class 1

Recommend

0.3 0.5

Class 2

Maximum

> 0.5

Ca No Guide No Guide No Guide

Fe 2 2 >2

Mg

Mn

No Guide No Guide No Guide

0.5 – 1

0 - 0.5

>1

K

Na

No Guide No Guide No Guide

0200 200 400

Cl

SO4

N

F

0 - 300

0 - 500

0 - 11

0 – 1.5

300 600

500 600

11 - 20

0 – 1.5

> 400

> 600

> 600

> 20

>1.5

GT 1-4 BI

0.907

2

0.164

2

<0.025

2.5

30

<5

8

<0.2

0.4

GT 2-3 BI

0.725

<2

0.159

<2

<0.025

<1.0

15

<5

15

<0.2

0.7

GT 1-4 BU

0.199

13

<0.025

3

<0.025

<1.0

10

<5

22

<0.2

<0.2

GT 2-3 BU

0.213

20

0.04

3

0.036

2.5

12

<5

29

<0.2

<0.2

GT 3-2 BU

0.985

7

0.356

2

<0.025

1.1

9

<5

<5

<0.2

<0.2

GT1-4 BB

0.262

9

0.073

4

<0.025

1.7

17

<5

17

<0.2

0.2

GT 2-3 BB

1.2

3

0.132

<2

<0.025

<1.0

20

<5

<5

<0.2

<0.2

GT 3-2 BB

0.754

14

0.137

6

<0.025

2.7

20

<5

57

<0.2

0.3

GT 1-4 BHW

1.74

6

0.747

2

0.028

4.7

14

<5

9

<0.2

0.3

GT 2-3 BHW

3.13

4

2.23

<2

0.073

5.3

18

5

24

<0.2

0.4

GT 3-2 BHWB (Hanging Wall)

2.97

3

0.493

3

0.043

4.2

20

5

22

<0.2

0.2

GT 3-2 B - Inter

1.85

3

0.928

<2

<0.025

1.9

25

<5

35

<0.2

0.9

4.5.3.2 Groundwater quality at closure Figure 109 indicates that contamination at mine closure will start to spread away from the mine at mine closure since the water levels can start to recover in down-gradient areas. A Total Dissolved Solids (TDS) concentration of 100 was applied to the potential source areas, representing 100% of the source concentration. The exact TDS concentration at the end of mining is unknown. The TDS will be the highest at the source and will decrease away from the source as the contamination plume moves. The plume from the plant, discard dump and pollution control dams will dilute as time progress since the source is removed after mine closure. The remainder of the two localities used for drinking water, FUL21 and FUL48, is not expected to be impacted on at mine closure by contamination from the mine.

269 | P a g e

Figure 109: Simulated TDS source concentration contours at mine closure

4.5.3.3 Groundwater quality 100 years post closure The plumes will extend a maximum distance of approximately 500m from the pits and sources. Simulated groundwater quality impacts revealed that the two remaining borehole localities used for drinking water purposes, FUL21 and FUL48, will not be affected in terms of pollution at 100 years post closure (Figure 110). The pollution plume along dykes extends further due to fracturing along the dykes which is known as preferred flow paths. The plume from Pit4 migrating south is expected to reach the Ntuthunga River at 100 years post-closure and is expected to reach the position of the river. It was concluded that the deep, secondary aquifer does not contribute to base flow to the rivers on a continuous basis. Poor water quality in the aquifer is thus not expected to have a measurable effect on water quality in the river. When it reaches the position of the river, the plume has also diluted significantly and effects are not expected to be measurable, especially given the relatively saline baseline groundwater conditions. It should be noted that plume movement from the rehabilitated opencast areas can be contained or reduced to a large extent. This can be achieved by leaving a deeper void (at least 15-20 meters below surface) at the decant point and pumping at a rate that keeps the water level down below the surface. The same can be achieved by a dewatering borehole drilled or built into the backfill material at the decant point. 270 | P a g e

Figure 110: Simulated TDS concentration contours 100 years after mine closure

4.5.4 RESIDUAL GROUNDWATER IMPACTS The following possible impacts are generally associated with closure of coal mining projects:   

Deterioration of groundwater quality within the back-filled opencast mine workings due to acid rock drainage reactions. Downstream movement of a deeper groundwater pollution plume. Opencast pits could decant into the shallow aquifer or on surface at the lowest surface elevations intersected by the pits.

During decommissioning, and for a certain time after closure, the geohydrological environment will dynamically attain a new equilibrium after the dewatering effects of the open pits and underground. The time it will take the mining voids to decant were calculated with the use of volume/recharge calculations and are given in Table 77. The potential decanting points with decanting elevation in the mine blocks are presented in Figure 111. It should be noted that the underground mining areas will be accessed from selected positions in the opencast pits. Therefore the underground and opencast areas will be connected. After underground activities has ceased the underground areas will be closed before rehabilitation of the opencast can start. The assumption is however made that recharge to the opencast pits will also contribute to the filling of the underground voids. Therefore, the void volumes and recharge rates of the opencast and underground are combined to determine the time to decant. 271 | P a g e

Table 76: Summary of time to decant (years)

Best Case Most probable Worst Case

Pit1 & UG1 158 106 53

Pit2 & UG2 105 66 33

Pit3 & UG3 176 115 58

Pit4 129 86 43

Pit5 & UG4.1 111 75 39

Pit6 & UG4.2 109 73 37

*Notes: Best Case- 30% Porosity, 65% extraction ratio, 1% recharge to UG, 10% recharge to OC. Most probable- 25% Porosity, 62.5% extraction ratio, 1.5% recharge to UG, 12.5% recharge to OC. Worst Case- 20% Porosity, 60% extraction ratio, 2.5% recharge to UG, 20% recharge to OC.

The time to decant in the mining areas varies from 66 to 115 years after closure in the most probable case. For the worst case scenario decant will occur between 33 and 58 years and best case scenario will occur between 105 and 176 years after closure. It is accepted best practice in the coal mining environment that carbonaceous material be backfilled at the bottom of the opencast pit. The aim with this practice is to have the carbonaceous material covered with water as soon as possible when the water level in the pit starts to recover. When covered with water, acidbase reactions in the carbonaceous material are minimized since the majority of these reactions require oxygen, i.e. oxidation reactions. When water covers the carbonaceous matter and causes a reducing environment, the acid-mine-drainage group of reactions diminishes and results in a much improved water quality compared to the oxidation environment.

Figure 111: Potential decant point positions

272 | P a g e

Table 77: Groundwater seepage calculations Pit1 & UG1 OC MAP (mm/a)

Pit2 & UG2

UG

OC

800

Area (m2)

541000

OC

800 300050

Decant elevation (mamsl)

UG

Pit3 & UG3

598280

46

UG 800

3351480

558970

65

Pit4 OC

Pit5 & UG4.1 OC

800 829870

90

264800

UG

Pit6 & UG4.2 OC

800 35020

65

UG 800

70530

121330

76

10490 84

3

Recharge (m /day) 1% UG, 10% OC

119

7

131

73

123

18

58

8

2

27

0.2

1.5% UG, 12.5% OC

148

10

164

110

153

2.5% UG, 20% OC

237

16

262

184

245

27

73

10

2

33

0.3

45

116

15

4

53

1

22564700

715080

24350170

799860

28304950

829870

9144280

925910

149910

3516770

21620

4512940

429048

4870034

479916

5660990

497922

1828856

185182

89946

703354

12972

5641175

446925

6087543

499913

7076238

518669

2286070

231478

93694

879193

13513

6769410

464802

7305051

519909

8491485

539416

2743284

277773

97442

1055031

14053

3

Void Volumes (m ) Total Void volume 20% porosity OC, 60 % extraction ratio UG 25% porosity OC, 62.5 % extraction ratio UG 30% porosity OC, 65 % extraction ratio UG Time to fill, most probable (years)

106

66

115

86

75

73

*Notes: OC = Opencast; UG = Underground.

273 | P a g e

AIR QUALITY

4.6

4.6.1 IMPACT ASSESSMENT 4.6.1.1 Construction Phase Heavy construction is a source of dust emissions that may have substantial temporary impact on local air quality. Buildings and roads construction are two examples of construction activities with high emissions potential. Emissions during the construction of a building or road can be associated with land clearing, drilling and blasting, ground excavation, cut and fill operations and construction of a particular facility itself. Dust emissions often vary substantially from day to day, depending on the level of activity, the specific operations, and the prevailing meteorological conditions. A large portion of the emissions results from equipment traffic over temporary roads at the construction site. The temporary nature of construction differentiates it from other fugitive dust sources as to estimation and control of emissions. Construction consists of a series of different operations, each with its own duration and potential for dust generation. In other words, emissions from any single construction site can be expected (1) to have a definable beginning and an end and (2) to vary substantially over different phases of the construction process. This is in contrast to most other fugitive dust sources, where emissions are either relatively steady or follow a discernible annual cycle. Furthermore, there is often a need to estimate areawide construction emissions, without regard to the actual plans of any individual construction project. The quantity of dust emissions from construction operations is proportional to the area of land being worked and to the level of construction activity. By analogy to the parameter dependence observed for other similar fugitive dust sources, one can expect emissions from heavy construction operations to be positively correlated with the silt content of the soil (that is, particles smaller than 75 micrometers *μm+ in diameter), as well as with the speed and weight of the average vehicle, and to be negatively correlated with the soil moisture content. The identified sources of airborne pollution from this phase of development are:  

General construction of roads and beneficiation plant (including all infrastructure); and The preparations of each opencast pit mine.

It is of the opinion of Royal Haskoning DHV that the general construction emission calculations be based on the US EPA AP-42 Chapter 13 Section 2.3 “Heavy Construction Operations” emission factor. The preparation of each coal mining pit is a combination of different factors and will occur on different scheduled timeframes. It is likely that the preparation of a pit will be conducted while other pits are active and some being rehabilitated or the activity in the pit has changed to underground mining. The emission inventory calculates the emission factors so to include the time variation of the activities. The sources listed below are included in the emission rate calculation for the preparation of each pit:     

Earth Clearing; Grading and Scraping; Un/loading of material; Wind Erosion; and Vehicle Generated Dust. 274 | P a g e

The emission calculations for each emission factor are based on either the US EPA AP-42 or Australian Government National Pollution Inventory Manual for Mining (NPI). The list of scenarios for the Construction phase is presented in section 7.1.1 of the specialist report (ANNEX-6). 4.6.1.2 Operational Phase The operational phase will commence after the pit preparation is complete. The emission inventory is calculated accordingly the possible hourly emission rate per mining pit based on each specific timeframes. The beneficiation plant’s emission inventory and calculations is presented separately from the mining activities. However the hourly emission rates will be dependant on the mining activity of the mine. It should be noted that due to the variability of the mining pits during the lifetime of the project the transfer of material to the beneficiation plant and to the market will also be calculated separately. Thus, the Operational Phase is divided into different stages:    

Stage 1 – Active pit mining Stage 2 – Transport of material Stage 3 – Beneficiation plant Stage 4 – Stockpiling of overburden and product

4.6.1.2.1 Stage 1 – Active pit mining

The emission inventory at each mining pit will consist out of the following emission sources:       

Drilling of holes for explosives; Blasting of overburden and coal; Dragline mining method; Bulldozing of overburden and coal in mining pit; Loading of Hauling vehicles inside mining pit; Wheel generated dust from vehicles and machinery active in mining pit and service roads; and Wind erosion of exposed ground inside the mining pit.

The emission calculations for each emission factor are based on either the US EPA AP-42 or Australian Government National Pollution Inventory Manual for Mining (NPI). The list of scenarios for the active mining stage is presented in section 7.3.4 of the specialist report (ANNEX-6). The major sources identified during the mining at each pit are the transfer of material onto hauling trucks, dragline mining and wind erosion on exposed ground. 4.6.1.2.2 Stage 2 – Transport of material

The emission inventory for the transfer of material from each mining pit to the beneficiation plant to the market consists out of the following emission sources:  

Wheel generated dust from hauling and general vehicles travelling on service roads to and from the plant and travelling to market; and Wind erosion on unpaved roads.

275 | P a g e

The emission calculations for each emission factor are based on either the US EPA AP-42 or Australian Government National Pollution Inventory Manual for Mining (NPI). The list of scenarios for the transport stage is presented in section 7.3.4 of the specialist report (ANNEX-6). The main sources identified are the wheel generated dust from heavy hauling trucks and from wind erosion on unpaved roads. 4.6.1.2.3 Stage 3 – Beneficiation plant

The emission inventory for the beneficiation plant consists out of the following emission sources:      

Unloading of hauling vehicles at plant; Wheel generated dust from vehicles and machinery operational at plant; Crushing and Screening of coal; Material handling at stockpiles; Stockpiling of waste rock and product; and Wind erosion over the plant area.

The emission calculations for each emission factor are based on either the US EPA AP-42 or Australian Government National Pollution Inventory Manual for Mining (NPI). The list of scenarios for the beneficiation stage is presented in section 7.3.4 of the specialist report (ANNEX-6). The main sources identified to emit pollutants to the atmosphere are wind erosion on stockpiles and ground surface area of plant, crushing and screening and material handling (unloading of hauling trucks). 4.6.1.2.4 Stage 4 – Stockpiling of overburden and product

The emission inventory for the stockpiling of overburden consists out of the following emission sources:   

Unloading of hauling vehicles at location; Wheel generated dust from vehicles and machinery operational on and at the location; and Wind erosion from overburden stockpile.

It should be noted, that this stage focuses on the storing of overburden and the building of the overburden stockpile. This does not include the removal of overburden for the rehabilitation process for each inactive mining pit. The emission calculations for each emission factor are based on either the US EPA AP-42 or Australian Government National Pollution Inventory Manual for Mining (NPI). The list of scenarios for the stockpiling of overburden stage is presented in section 7.3.4 of the specialist report (ANNEX-6). The main sources identified to emit pollutants to the atmosphere are wind erosion and material handling (unloading of hauling trucks). 4.6.1.3 Rehabilitation Phase The rehabilitation of the mining pits will commence when there are no further plans to mine at the site. The rehabilitation phase entails that backfilling of the mining shafts and open pit area starts and active 276 | P a g e

mitigation and rehabilitation measures are in place. There is however emission generation related to the rehabilitation phase, namely:   

Material handling (loading and unloading of hauling vehicles); Wheel generated dust from hauling vehicles (travelling from stockpile to open pit area); and Wind erosion.

The different mitigation measures (as discussed further in Section 8) are applied to the modelling simulations and the best possible measure decided on.

4.6.2 POSSIBLE MITIGATION MEASURES There are a wide range of mitigation measures that can be implemented at mining operations, however each mining operation is different as each climate is also different. The table below list the activities recommended for as mitigation measure(s) that can be introduced for the Fuleni Anthracite Project to effectively control air pollution:

Activity

Mitigation Measures

Vehicle wind and wheel dust

Set the speed limit for hauling vehicles and vehicles in general to as low a speed possible and enforce the speed limits specified. The higher the speed the more dust will be generated. It is recommended the speed limit be set to 40km/h and less. Include speed-bumps to control the speed limits, also include a program of wet-suppression of the unpaved roads with major vehicle activity. The wetsuppression can be of typical grey water from the mine or the water can contain a chemical that will increase the dust trapping capability once sprayed over a surface. Limit the load size of the vehicles to ensure the wind in transit does not pick up more dust that need be. This option is the most expensive and unlikely mitigation measure – pave all major hauling routes and ensure the road surface is kept clean from any silt or gravel. It is however recommended that the main access road to the mine be paved. All trucks leaving the site should be cleaned of excess dust, either through washing or air curtain, and all trailers should be covered to prevent dust when product is transported out of the mine area.

Blasting Transportation Mining

Blasting should only be undertaken when wind speeds are below 12km/h (light breeze) All trucks leaving the site should be covered to ensure dust is not generated from the product being transported. Limit the area of operation to what is absolutely necessary.

Emission reduction efficiency (%) ~65%

~90% ~85%

~84% ~90% Variable

277 | P a g e

Activity

Stockpiles

Crushing and Screening Air Quality Management Program

Mitigation Measures Rehabilitation should be performed on an on-going basis. During the pre-mining preparation of the area, ensure that only the bare minimum amount of vegetation is removed from the site. It is recommended that the natural vegetation, as far as possible, be left undisturbed to ensure there is ample ground cover. Limit the height and slope of stockpiles to reduce wind entrainment. The ideal stockpile height is less than 3m with a slope no more than 30°. Ideally stockpiles should be fully enclosed, this is very unlikely to occur at the Fuleni Anthracite Project, due to limited land availability, and the maintenance of the stockpile, as well as the general vehicle traffic should be continuous. The stockpiles can be covered by large rock fragments to ensure there silt area that can be picked up by wind is reduced and kept to a minimum. Windshield (barriers) can be implemented on the slopes and surface of the stockpile, these barriers are typically large trees with good foliage coverage (the area of the mine and the soil characteristics cause the possibility of this option to relatively low). The substitute of the wind barriers is a wind shield made from a prose material (shade cover). It should be noted that the height of the wind shield will reduce the wind effect by 10x in distance. The original intention is for several smaller stockpiles to be in place, however this creates a canyon effect, where wind is forced through the gaps between, in the process increasing in speed. It is therefore recommended that larger lower stockpiles are created to reduce this effect. In effect to reduce the type of scenario shown below:

During the transport and processing of material, the material should be kept damp to ensure the dust does not escape during the processing. As material is trucked to the plant it is recommended all trucks are covered. The air quality management program needs to be developed which will provide the mine health, safety and environment person to report to the managers about the air quality impact the mine has on the surrounding environment. This AQMP should include monitoring schedules and can be used to determine if some mitigation measures are capable in reducing the emission effectively and to determine areas of concern.

Emission reduction efficiency (%) 30% ~ 95%

~60%

~60% Variable 27% ~ 41%

~50%

~80%

4.6.3 MODELLING RESULTS 4.6.3.1 Methane Coal bed methane which is released from the coal bed during normal mining operations as the gas is trapped within the layers of coal, is predicted to be a total of 84 074 306 m³ for the LOM (approximately 32 278 | P a g e

years). This is based on an average for the Tier 1 IPCC Emission Factor and is calculated based on the proposed production rate for the mine. Figure 112 below shows the projected methane emissions based on the coal production volumes for the life of mine, indicating the variability in the production rates, and methane production, due to the opening of various pits and underground sections of the mine. Due to this variability modelling of the methane production can not be accurately modelled, and therefore is calculated as a total over the LOM.

2014\Jan 2015\Mar 2016\May 2017\Jul 2018\Sep 2019\Nov 2021\Jan 2022\Mar 2023\May 2024\Jul 2025\Sep 2026\Nov 2028\Jan 2029\Mar 2030\May 2031\Jul 2032\Sep 2033\Nov 2035\Jan 2036\Mar 2037\May 2038\Jul 2039\Sep 2040\Nov 2042\Jan 2043\Mar 2044\May 2045\Jul 2046\Sep 2047\Nov 2049\Jan 2050\Mar 2051\May 2052\Jul 2053\Sep 2054\Nov

100 000 90 000 80 000 70 000 60 000 50 000 40 000 30 000 20 000 10 000 0

Figure 112: Methane emissions predicted based on the production rate provided for the LOM (m³ methane per ton)

4.6.3.2 Particulate Matter The dispersion of pollutants through the air was modelled with the AERMOD software. The physical environmental parameters, such as wind, temperature, humidity and rain, influence the concentrations over distance. The modelling software took all of these parameters into account in the primary Gaussian calculations, and a concentration value per pollutant was calculated at each of the grid points to be able to form isopleth images for graphical presentation of the typical plume dispersion in the region. The modelled results are presented in Table 78 and Table 79 to compare with the national standards. The concentrations depicted are all the second highest concentration calculated, as per statistical law. The different modelled scenarios are:  Construction phase – This phase focus on the pollutants generated during the construction phase.  Operational Mining – This phase addressed the pollutants from the mining activities (such as the ROM loading-transport-unloading, product transportation and averaged blasting events). For each of the modelling scenarios a Worst Case and Best Available Technology options were assessed. The Worst Case assumes that no mitigation measures will be undertaken as part of the mining operations and therefore this is the maximum expected result from the mine. The Best Available Technologies option assumes that all mitigation measures identified in Section 4.6.2 above are implemented and are operating optimally.

279 | P a g e

Table 78: Dispersion Results from AERMOD – Worst Case Scenario PM10 NAAQS (Standards) (2015) 24-hour Annual 3 3 75 µg/m 40 µg/m Construction Phase Maximum Beyond Fence line Mining Phase Maximum Beyond Fence line

PM2.5 NAAQS (Standards) (2016) 24-hour Annual 3 3 40 µg/m 20 µg/m

77.62 44.81

39.21 15.09

49.45 43.47

19.83 10.68

823.50 823.50

186.16 186.16

192.05 165.06

36.55 31.17

Table 79: Dispersion Results from AERMOD – Best Available Technology Scenario PM10 NAAQS (Standards) (2015) 24-hour Annual 3 3 75 µg/m 40 µg/m Construction Phase Maximum Beyond Fence line Mining Phase Maximum Beyond Fence line

PM2.5 NAAQS (Standards) (2016) 24-hour Annual 3 3 40 µg/m 20 µg/m

54.36 42.59

18.68 12.36

43.48 34.07

14.94 9.88

104.42 104.42

31.20 30.94

59.05 59.05

24.96 24.75

It should be noted that the legal standard for ambient air quality is taken beyond the Property Boundary (Fence Line), and not within the active mining area. Therefore the ambient standards only apply to exceedances beyond the fenceline. The Air Quality Legislation distinguishes between Ambient Air Pollution and Occupational Air Quality, which would be completed as part of the mines Health and Safety Plan. This results in the Fenceline concept where the ambient standards cover the air pollution beyond the site boundary and the occupational standards cover the air quality on site. Expected dust fallout during construction is predicted to be relatively low, and will not exceed the National Standards for ambient air quality (refer to Figure 113 and Figure 114). Occupational Health and Safety Standards for construction are very strict in terms of respirable dust, and therefore the construction team will need to ensure dust levels are kept to a minimum. Figure 115 provides modelled particulate emission plume for all sources under normal operating conditions if no mitigation whatsoever has been included or used. From this isopleth plot and from

280 | P a g e

Table 78 it is possible to note the exceedences to both the PM10 and PM2.5 standards. These exceedances indicate that mitigation will be required to reduce the air quality emissions in order to comply with National Standards. Isopleth plots for PM10 for the best case model runs have been provided in Figure 116 and Figure 117 to provide an indication as to the dispersion likely to occur at the site during the operational phase. These predictions show the effects that the mitigation measures will have on the air quality impacts associated with the mining operations. When using the Best Available Technologies and recommended mitigation measures, there is a significant decrease in the emissions from the proposed Fuleni Anthracite Project. The maximum concentration for the operational PM10 emissions is seen within in the HiP’s fenceline. This is due to the dispersion potential in the region and the design of the waste rock dumps and stockpiles of the project. The release height of dust from the stockpiles is at a greater height than before (higher that ground level) and the design of the slopes of the stockpiles impacts the wind profile. The wind liberates the dust from the source and carries it in the air with the wind. As the HiP is adjacent to the MRA area, the distance the dust must travel to fallout to the standard receptor height (1.5m above ground level), is within the HiP, resulting in exceedances within the reserve.

Figure 113: Isopleth plot showing particulate impacts associated with construction for a daily averaging period (Standard 75µg/m³)

281 | P a g e

Figure 114: Isopleth plot showing particulate impacts associated with construction for an annual averaging period (Standard 40µg/m³)

Figure 115: Isopleth plot showing Particulate impacts associated with no mitigation for a daily averaging period (Standard 75µg/m³)

282 | P a g e

Figure 116: Isopleth plot showing Particulate impacts associated with operations for a daily averaging period (Standard 75µg/m³)

Figure 117: Isopleth plot showing particulate impacts associated with operations for an annual averaging period (Standard 40µg/m³)

283 | P a g e

4.6.3.3 Heavy Metal Exposure A coal sample was collected from the Fuleni Anthracite Project site and submitted for heavy metal namlysis, since questions were raised about the make-up of the coal and possible dust that would be transported from the miing activities. Table 80 presents the percentage make-up of the coal sample. The highest percentage element found in the sample is Calcium (Ca), followed by Aluminium (Al) and Iron (Fe). No toxic heavy metal concentrations were found in the sample and the concentrations (percentage make-up) of the sample also indicates that there is no risk of exposure to harmful elements. These results provide an indication as to the chemical composition of the coal dust generated during the operational phase of the mining project. The major components of the coal sample are identified to include Aluminium (1.06 %), Calcium (1.99 %), and Iron (0.72 %). This combination of chemicals forms part of the Particulate Matter (dust) generated from the mine. The 24 Hour PM concentration has had the heavy metals included, and the chemical exposure of the heavy metals within the dust is then compared with the World Health Organisation Standards for 24 hour exposure. Where World Health Organisation standards exist, these have been provided for reference, showing that none of the metals identified, even during the worst case scenario, will exceed the WHO standards. Table 80: Heavy Metal Analysis of Coal Sample

Al

Aluminium

Percentage Composition (%) 1.06

B

Boron

0.00

0.01

100

Ba

Barium

0.02

0.14

5

Ca

Calcium

1.99

16.36

Cr

Chromium

0.00

0.00

1

Cu

Copper

0.00

0.01

10

Fe

Iron

0.72

5.93

300

K

Potassium

0.31

2.53

Li

Lithium

0.00

0.04

Mg

Magnesium

0.08

0.68

Mn

Manganese

0.05

0.43

Na

Sodium

0.05

0.45

Ni

Nickel

0.00

0.01

S

Sulphur

0.28

2.31

Sr

Strontium

0.02

0.13

Ti

Titanium

0.00

0.02

V

Vanadium

0.00

0.01

0.2

Zn

Zinc

0.01

0.05

50

Zr

Zirconium

0.00

0.01

Heavy Metals

Maximum 24 Hour Exposure

WHO 24 Hour Std.

8.75

50

8 0.15

284 | P a g e

4.6.4 CONCLUSIONS Royal Haskoning DHV concluded that there are direct and cumulative impacts on human and environmental health associated with the Fuleni Anthracite Project. The impacts result primarily from the dust emission sources such as stockpiles and haul roads, especially during the operational phase of each mining pit. The emissions of particulates from the Fuleni Anthracite Project will add to the existing particulate concentrations, particularly from the Somkhele Mine. Thus, the potential exists that the increase in ambient key pollutant concentrations can result in exceedance of the national ambient air quality standards at specific locations in and around the MRA area. Other indirect impacts may result from the emission of Greenhouse Gases such as methane (CH4) and carbon dioxide (CO2) from spontaneous combustion, should this occur. As dust (particulate matter) is the major airborne pollutant from mining activities, the impact as calculated in this document will be great on the Park and along the access routes. It is predicted that during the operational phase, mine operations will result in exceedances to the ambient standards within the HiP. The dispersion of airborne-pollutants will travel up and down the valley thus, funnelling and concentrating the dust to a specific and limited area. The cause of the high concentrations in, that is found in the park, is due to low speed wind that blows from south east over the mine opencast areas and stockpiles and into the park. Based on dispersion modelling of the proposed Fuleni Anthracite Project, exceedances to the 2015 are noted to occur for a daily averaging period for PM10, and the 2016 standards for PM2.5 for a daily and annual averaging period. These exceedances are noted both under a worst case scenario, where no mitigation is in place, as well as when mitigation is in place, based on the current Best Available Technology available for mines. It is therefore recommended that additional innovative engineering methods and designs be implemented to identify additional mitigation measures which may reduce particulate emissions. These processes of design must be done in combination and with the mine engineers to come up with a totally new concept of design to improve (reduce) the mitigation potential. It is unlikely that the available technology of mitigation measures are able to reduce the emission factors to an acceptable level, and it is unpractical to enclose all stockpiles and mining operations to ensure the dispersion of airborne pollutants will not venture into the park. Table 81 provides a summary of the results of the impact ratings.

285 | P a g e

Table 81: Environmental Rating Table (dust levels)

Scenario

Without mitigation

With mitigation

Impact Construction Phase - Transport of material - Pre-mining preparations - Construction of plant Operational Phase - Drilling & blasting - Transport - Stockpiling - Wind erosion Construction Phase - Transport of material - Pre-mining preparations - Construction of plant Operational Phase - Drilling & blasting - Transport - Stockpiling - Wind erosion

Rating of Impact Med/High Med Med Med Med/High Med/High Extreme High Med Low Low Low Med Med/High High

286 | P a g e

AMBIENT NOISE

4.7

4.7.1 CONSTRUCTION PHASE Construction will likely be carried out during the daytime only (07h00 to 18h00 or 20h00). It should however be noted that certain activities may occasionally extend into the late evening period, while others such as de-watering operations may need to take place over a 24-hour period. It is estimated that the development of the project will take place over a period of about 18 months to 24 months. 4.7.1.1 Sources of Noise The following, where relevant, are likely to be the main construction related sources of noise for the planned surface workings and related infrastructure of the mine:                  

Construction camp establishment (Site offices, workshops and accommodation). Removal and demolition of existing infrastructure that is no longer needed or needs to be replaced. Earthworks to remove topsoil and overburden at opencast pits. Activities related to the relocation of services. Excavation of heavy plant/building foundations and service trenches. Blasting may be required in places but in general pneumatic breakers will be used where rock is encountered. Erection of shuttering for concrete works. Fixing of steel reinforcing. Placing and vibration of concrete. Poker vibrators will be used. Stripping of shuttering after concrete pour. Erection of structural steelwork. Finishing operations on buildings. Cladding, services installation, etc. Installation of plant and equipment. General movement of heavy vehicles such as concrete delivery vehicles, mobile cranes, mechanical dumpers and water trucks (dust suppression) around the site. De-watering pumps. A 24-hour operation may sometimes be necessary. Road construction equipment. Scrapers, dozers, compactors, etc. (Construction of the internal road system, and access roads). Construction site fabrication workshops and plant maintenance workshops. Concrete batching plant. Construction material and equipment delivery vehicles.

Where relevant the main construction related sources of noise for the road construction will be similar. The level and character of the construction noise will be highly variable as different activities with different plant/equipment take place at different times, over different periods, in different combinations, in different sequences and on different parts of the construction site. Exact day-time period and night-time period continuous equivalent sound pressure levels are therefore not possible to calculate with certainty at this stage as the final construction site layout, work programme for the various components, work modus operandi and type of equipment have not been finalised.

287 | P a g e

Using baseline data from typical construction sites, the ambient noise conditions at various offsets from the following main construction activities are predicted:  

Noise from concrete batching plant. General concrete construction in the various proposed plant areas.

Table 82: Predicted ambient noise levels at given offsets from some specific construction activities

Sound pressure level at given offset(dBA) Equipment 500m

1000m

1500m

2000m

2500m

3000m

Concrete Batching Plant

53.6

46.0

41.1

37.5

34.7

32.3

Concreting Operations

57.2

49.1

43.9

40.1

37.1

34.6

4.7.1.2 Noise Impact The general nature of the noise impacts from the project construction sites is predicted to be as follows: 







Source noise levels from many of the construction activities will be high. Noise levels from all work areas will vary constantly and in many instances significantly over short periods during any day working period. Exact daytime period and night-time period continuous equivalent sound pressure levels are not possible to calculate with certainty at this stage as the final construction site layout, work programme for the various components, work modus operandi and type of equipment have not been finalised. Working on a worst case scenario basis, it is estimated that the ambient noise level from general construction activities could negatively affect noise sensitive sites within a distance of 1300 metres of the construction site. Refer to Table 82. Night-time construction could have a significant impact on noise sensitive sites within a radius of 3000 metres of the construction site. There are likely to be significant noise nuisance effects during the day from intermittent loud noises on people living in the area. If there is any night-time construction, fairly significant impacts will be experienced. It has been estimated that the construction activities at the mine site will on average generate no more than about 230 vehicle trips (two way trips) daily. The main percentage of the trips will be concentrated in the morning and evening peak periods. In general, the construction traffic will have a relatively minor effect on the noise climate alongside the main external roads in the area. Because of the character of the traffic (namely heavy vehicles), there is likely to be some noise nuisance factor with the passing of each vehicle at noise sensitive receptors along the access routes. This is particularly so at night with heavy delivery trucks.

The general nature of the noise impacts from road construction (internal roads and access road) activities is predicted to be as follows: 

The level and character of the construction noise will be highly variable as different activities with different plant/equipment take place at different times, over different periods, in different combinations, in different sequences and on different parts of the construction site.

288 | P a g e



As no specific construction details or possible locations of major ancillary activity sites are available at this stage, the anticipated noise from various types of construction activities cannot be calculated accurately. In general at this stage, it can be said that the typical noise levels of construction equipment at a distance of 50 metres lie in the range of 75 decibels (dBA) to 100dBA. Based on data from similar “linear” construction sites, a one-hour equivalent noise level of between 75dBA and 78dBA at a point 50 metres from the construction would be typical for the earthmoving phase.

It should be noted that higher ambient noise levels than recommended in SANS 10103 are normally accepted as being reasonable during the construction period, provided that the very noisy construction activities are limited to the daytime and that the contractor takes reasonable measures to limit noise from the work site. Note that it has been assumed that construction will generally take place from 06h00 to 18h00 with no activities (or at least no noisy construction activities) at night. The noise specialist concluded that the construction noise impact is not likely to be severe. There is however always the potential for impact at sites in the immediate vicinity of the construction activity.

4.7.2 OPERATIONAL PHASE In general, it is not anticipated that the noise levels from these existing sources will increase significantly in the future, with the exception of road traffic noise. The noise generated by the new mining operations, surface workings, the haul truck operation between the mine and the N2 Freeway/Richards Bay, and mine generated traffic will add to the noise climate prevailing in the area. 4.7.2.1 Noise Zones of the Mine The analysis of the noise impact of the operational phase of the project has focused individually on the following areas (noise zones), namely:    

The Opencast Pits: There are to be six separate opencast pits, numbered sequentially from north to south, namely Pits 1 to 6. The various stockpiles at each of the pits. The Coal Handling Processing Plant (CHPP). Surface infrastructure related to the underground mining, namely o Adits. o Vent shafts.

The following components of the new mining operation were also analysed:   

Pump stations in plant area for water reticulation and movable pumps in pits for dewatering. Wastewater treatment plant. Workshops.

In addition, the noise along the routes traversed by the coal product delivery trucks has been analysed. The reader is referred to ANNEX-7 for details on methodology and calculations/results.

289 | P a g e

4.7.2.2 Calculation of Noise Footprint for the Various Elements of the Mining Operation Several scenarios were calculated. High wind conditions as well as conditions where thermal inversions occur have been modelled. The latter were found to represent the worst condition. Table 83 shows a comparison of the various offsets of the 35dBA, 40dBA, 45dBA and 50dBA contours under high wind and inversion conditions (unmitigated). Table 83: Comparison of noise footprint of the various noise zones under different meteorological conditions (unmitigated) Mining Elements (Noise Zones) and Meteorological Conditions

Offset (m) 35dBA

40dBA

45dBA

50dBA

Process Plant

4100

2900

1950

1300

Open Cast Pits

5500

3800

2700

1800

Stockpiles

3100

2200

1400

950

Vent Shafts

1350

900

550

350

Adits

3100

2200

1400

950

Process Plant

4900

3400

2300

1500

Open Cast Pits

6600

4700

3200

2100

Stockpiles

3700

2500

1600

1000

Vent Shafts

1600

1000

600

350

Adits

3700

2500

1600

1000

Maximum Wind Factor

Inversion Conditions

The overall combined noise area of influence of all of the individual noise zones are shown on Figure 118. The 35dBA ambient noise contour demarcates the outer limit of influence according to SANS 10103, in this case the outer limits with temperature inversion conditions. There will, at times, be noises from the mine that will be heard well beyond the indicated positions of the respective 35dBA contours, specifically from single short-term events (such as blasting). Note that Figure 118 reflect a worst condition scenario (conservative, i.e. meteorological inversion conditions) approach (refer to Table 83). The noise levels given are for unmitigated conditions. In reality there will during many periods be greater attenuation with distance than shown where there are houses, other buildings, vegetation and terrain restraints (refer to Appendix C of ANNEX-7) in the intervening ground between the source and the receiver point. Due to the complexity of the mining schedule and the numerous permutations between the various mining operations over the life of the mine, each of the types of operation at the mine have initially been analysed separately. Therefore, cumulative effects between these operations have not been indicated in the noise impact assessment, but for some that have been addressed as case studies in Appendix F of ANNEX-7. Cumulative effects can only be shown for a specific scenario at a specific moment in time.

290 | P a g e

Figure 118: Noise profile for the Fuleni Anthracite Project (unmitigated)

4.7.2.3 Noise Climate and Noise Impact of the Internal Mine Traffic The noise generated by the movement of loaded articulated dump trucks (ADTs) between the mining areas and the CHPP will have a noise nuisance impact on noise sensitive receptors within two kilometres of the truck on an internal haul road especially at night. Refer to Table 84. Table 84: Maximum bypass noise level of a truck at given offsets from road (unmitigated)

Description 25m 57.7 81.5

Truck (empty) Truck (loaded)

Sound pressure level at given offset from Road (dBA) 50m 100m 200m 400m 600m 800m 1000m 51.6 45.4 39.0 32.4 28.4 75.4 69.2 62.9 56.5 52.5 49.7 47.4

2000m 39.8

4.7.2.4 Mine Generated Traffic (External to Mine Property) The mine is planned to eventually employ in the order of 400 people. The following maximum daily traffic generation (two-way vehicle trips) over the life of the mine is predicted:     

Cars (work trips) Buses (work trips) Taxis (work trips) Business trips Product export trucks

-

46 trips per day 16 trips per day 14 trips per day 60 trips per day 160 trips per day

291 | P a g e

It should be noted that the mine-generated traffic will be concentrated around the periods of shift changes at the mine. The details of the road traffic noise impact of the development are given in Appendix D of ANNEX-7. The noise impact along the main roads in the study area will be minimal, as shown in Table 85. Table 85: Noise climate adjacent to roads during the mine’s operational phase: background traffic + mine generated traffic (year 2013)

Road Road N2 Road P425 (R102) Road P494 Road P499 Road D873R Road D873M

Noise Climate Alongside Main Roads at 25m Offset from Centerline (SANS 10103 Indicator) (dBA) Background + Background Traffic Increase in Noise Level Operational Traffic 66.6 66.9 +0.3 61.4 62.4 +1.0 52.3 55.2 +2.9 45.5 45.5 0 41.4 41.4 0 53.8 53.8 0

The main impact will be a noise nuisance impact on a noise sensitive receptor with the bypass of each truck along the haul route (Roads N2, P425 and P494) for the product to Richards Bay. The maximum noise with the bypass of a truck (both loaded and empty) is given in Table 84 above. Where a new section of the access road is to built (not just an upgrading) there is likely to be a greater sensitivity to passing mine traffic due to the current relatively quieter noise climate. 4.7.2.5 Impact on the HiP and iMfolozi Wilderness Area The effect of noise from the Fuleni Anthracite Project on the HiP and iMfolozi Wilderness Area is an issue of great concern as it brings into contention two highly conflicting land-uses. A large frontage of the HiP will be exposed to the noise that will be generated from the mine, resulting in a wedge of the HiP’s land where the imposed noise levels from the mine will exceed desirable noise levels. The HiP and Wilderness Area could be adversely impacted for the distances as indicated in Table 86. Table 86: Noise impact on the HiP and Wilderness Area

Impact Distance from common boundary with mine

Without mitigation Daytime Night-time (>45dBA) (>35dBA) 3200m

6600m

With mitigation Daytime Night-time (>45dBA) (>35dBA) 2150m

4800m

The impact of noise on wildlife is not well-researched and reports are mainly of an anecdotal nature (Larkin, 1994). Furthermore, as each species has a unique auditory sensitivity, it is not feasible to extrapolate to animals any effects noise may have on human annoyance or health. In some cases, levels of noise judged intolerable by people do not bother animals. But in other cases, animals are adversely impacted by noise judged otherwise innocuous by people (DoD, 2005). Refer to Appendix E of ANNEX-7 for an approach to assessing the desirable maximum for the noise climate for the Wilderness Area of the HiP.

292 | P a g e

4.7.2.6 Impact on the Sompoho and Obuka Nature Reserves The 35dBA noise contour of the mine does not extend to either of these Nature Reserves and the impact on these areas will not be significant. 4.7.2.7 Mine Access Road JKA have undertaken a preliminary analysis of the potential impact of this new road and have established the position of the noise sensitive receptors (NSRs) and where noise attenuation barriers (earth berms) are likely to be needed. The base map used to establish the noise sensitive receptors was the latest Google Earth imagery (8 May 2014). The area is one of rapid residential development. The planned mine access road will have a significant impact on the population along its route between the mine and National Road N2. It was established that NSRs falling within a corridor approximately 460 metres wide (230 metres to the north and the south of the centreline of the new road) could be affected. This impact corridor is defined by the 45dBA Ldn noise contour. These contours are indicated in red in Figures D3 to D8 of Appendix D (ANNEX-7). It was then established where it was likely to need mitigating measures along the route. Earth berms of at least 3 metres average height will be required. For the position of these refer to Figures D9.1 to D9.4 (Appendix D of ANNEX-7) where the areas that may need berm mitigation treatment are indicated along the southern frontage and northern frontage of the mine access road. The following lengths of berm may be required:  

11 300 metres along the southern frontage of the road 8 800 metres along the northern frontage

This is a preliminary estimate giving only a rough indication of the extent of berm that will be necessary. Detailed design will have to be carried out with the detailed design of the road itself.

4.7.3 MITIGATION MEASURES Potential noise mitigation measures for the project were assessed. 4.7.3.1 Construction Phase The noise mitigation measures to be considered during the construction phase of the mine as well as the upgrading of the access road and internal haul roads are as follows:   



Construction site yards and other noisy fixed facilities should be located well away from noise sensitive areas adjacent to the development sites. All construction vehicles and equipment are to be kept in good repair. Where possible, stationary noisy equipment (for example compressors, pumps, pneumatic breakers,) should be encapsulated in acoustic covers, screens or sheds. Proper sound insulation can reduce noise by up to 20dBA. Portable acoustic shields should be used in the case where noisy equipment is not stationary (for example drills, angle grinders, chipping hammers, poker vibrators). Construction activities, and particularly the noisy ones, are to be contained to reasonable hours during the day and early evening.

293 | P a g e

   

With regard to unavoidable very noisy construction activities in the vicinity of noise sensitive areas, the mine should liaise with local residents on how best to minimise the impact. Machines in intermittent use should be shut down in the intervening periods between active working or throttled down to a minimum. In general, operations should meet the noise standard requirements of the Occupational Health and Safety Act (Act No 85 of 1993). Construction staff working in areas where the 8-hour ambient noise levels exceed 75dBA should wear ear protection equipment.

4.7.3.2 Operational Phase The following noise mitigation measures, which will need to be considered where appropriate, are indicators of what needs to be done to reduce or control the noise generated by the operations at the mine: 









The design of all major plant for the mine is to incorporate all the necessary acoustic design aspects required in order that the overall generated noise level from the new installation does not exceed a maximum equivalent continuous day/night rating level (LRdn), namely a noise level of 70dBA (just inside the property projection plane, namely the property boundary of the mine) as specified for industrial districts in SANS 10103. Notwithstanding this provision, the design is also to take into account the maximum allowable equivalent continuous day and night rating levels of the land use type of potentially impacted sites outside the Fuleni Anthracite Project property. Where the noise level at such an external site is presently lower than the maximum allowed, the maximum shall not be exceeded. Where the noise level at the external site is presently at or exceeds the maximum, the existing level shall not be increased by more than indicated as acceptable in SANS 10103. The proposed mine does not comply with these requirements and mitigation measures will have to be implemented. The latest technology incorporating maximum noise mitigation measures for components of the complex should be designed into the system. Ideally, plant and equipment should meet the following specification: the sound power level (LW) should be such that the sound pressure level (SPL – i.e. the noise level) measured at 1 metre from the surface of the given plant/equipment should not exceed 85dBA. When ordering plant and machinery, manufacturers should be requested to provide details of the sound power level. Where possible, those with the lowest sound power level (most quiet) should be selected. The design process is to consider, inter alia, the following aspects: o The position and orientation of buildings, plant and stockpiles on the site. o The design of the buildings to minimise the transmission of noise from the inside to the outdoors. o The insulation of particularly noisy plant and equipment. The stockpiles of spoil rock and overburden (berms) from the opencast pit excavations should, where possible, be used as interim or long-term noise attenuation barriers. Specifically such berms should be constructed (where necessary) around all six of the planned pits, and around the coal processing plant. It should be noted that the workings at stockpiles are, in themselves, also a contributing source of noise. It is therefore only dormant stockpiles that will be effective as a noise barrier. All plant, equipment and vehicles are to be kept in good repair. 294 | P a g e



Where possible, very noisy activities should not take place at night (between the hours of 20h00 to 06h00). Specifically, blasting should take place to a regular programme and should be restricted to the period between 08h00 and 16h00.

Specific recommendations to achieve noise levels in line with standards for rural residential living (nighttime conditions) in the residences surrounding the mine, as well as the schools in the area, are as follows: 



 



Use of low-noise generation plant and equipment. All vehicles should have engines and gearboxes encapsulated. Noise control measures on machinery should be agreed with the manufacturer. Encapsulation should achieve at least a 5dBA reduction. Where possible, stationary noisy equipment (for example compressors, pumps) should be encapsulated in buildings, acoustic covers, screens or sheds. Specifically, the processing plant and conveyor drives should be housed in buildings. Portable acoustic shields should be used in the case where noisy equipment is not stationary (for example drills, angle grinders, chipping hammers, poker vibrators). Acoustic insulation of houses and school classrooms such as double glazing and sealing of the roof eaves should be investigated further. Note that while it is possible to improve sound insulation of windows, this is only effective as long as windows stay closed. This implies that forced ventilation systems (either air conditioning or fans) should also be installed. No work on stockpiles at night in order to cut down on generated noise.

The following noise mitigation measures, which will need to be considered where appropriate, are indicators of what needs to be done to reduce or control the noise generated by the haul trucks:    

All vehicles to be kept in good repair. Regular maintenance of the road. Haul operations should be limited to between the hours of 06h00 to 20h00. Noise barriers may need to be built some residential areas along the external haul route. This aspect needs closer investigation.

It should be noted that any mitigation measures taken at the development sites at the mine and transport route will limit the impacts in the specific areas designed for, but will not necessarily contribute to improving the degraded noise climates in adjacent areas where there is already a problem. Table 87 gives an indication of the magnitude of improvement of the noise with the application of the mitigation measured recommended. Figure 119 compares the total area of influence (35dBA outer limit) of the development with and without mitigation.

295 | P a g e

Table 87: Comparison of noise footprint of the various noise zones under atmospheric inversion conditions (mitigated and unmitigated)

Mining Elements (Noise Zones) Unmitigated Conditions Process Plant Open Cast Pits Stockpiles Vent Shafts Adits Mitigated Conditions Process Plant Open Cast Pits Stockpiles Vent Shafts Adits

Offset (m) 35dBA

40dBA

45dBA

50dBA

4900 6600 3700 1600 3700

3400 4700 2500 1000 2500

2300 3200 1600 600 1600

1500 2100 1000 350 1000

2800 4800 2500 600 2500

1870 3300 1600 350 1600

1230 2150 1000 210 1020

760 1400 620 120 630

Figure 119: Noise profile for the Fuleni Anthracite Project without and with mitigation (35dBA)

296 | P a g e

4.7.4 CONCLUSIONS AND RECOMMENDATIONS The noise specialist concluded that: 









   

 

The existing noise climate in most of the study area is very quiet and is generally of a rural nature. The HiP to the west of the proposed mine is an unspoilt nature reserve. The areas to the north, east, south and south-west consist of scattered rural dwellings and small established villages. In these areas the main land-uses are residential and agricultural. The Somkhele Mine lies to the north of the proposed mine. The noise climate close to National Road N2 and Road P425 (Route R102) is severely degraded and adjacent to the following roads for the distances shown from the road the noise levels exceed acceptable residential living conditions as specified in SANS 10103. This situation will deteriorate as traffic volumes increase in the future. The minor provincial roads that penetrate the study area carry small volumes of traffic and the impact of traffic noise from these facilities is minimal. However many of the roads and many vehicles are in poor repair resulting in a louder than normal noise generation from the road environment. The development of the Fuleni Anthracite Project, together with the haul route to Road N2 will introduce very loud noise sources into the area and the size of the control 35dBA noise footprint (area of potential noise impact) will be extensive relative to the actual mining area. From a qualitative aspect, the development of the Fuleni Anthracite Project will bring about a significant change in the noise character of the area. There will be very loud and short term noises (for example blasting) from sections of the mine that will be heard at times well beyond the indicated positions of the respective 35dBA contours and the total 35dBA contour envelope of the operation. There are numerous rural residential and suburban residential noise sensitive receptors in the area that potentially will be impacted by the mine. The rural residential noise receptors are the residences and villages. All the rural residential noise sensitive receptors within the 35dBA contours are potentially affected. A suburban residential climate may be said to be present in some of the larger villages. All the residential noise sensitive receptors within the 40dBA contours are potentially affected. The noise climate of the HiP and Wilderness Area is very quiet and may be classified as that suitable for a wilderness area. Any manmade noise can be perceived as intrusive and unwanted sound in such areas. There are no specific noise standards for game parks and each instance must be classified according to its own characteristics and merits. The 35dBa noise contour of the mine does not extend to either the Somopho or Obuka Nature Reserves and these areas will not be significantly impacted. There are measures that can be introduced to mitigate some of the impact of the operational noise, but in general the development of the mine and operations along the haul route will alter the noise profile and character of the area significantly. Adverse noise conditions in the near field can be expected, especially at night. Therefore, the noise risk ratings remain high, even post mitigation.

297 | P a g e

The noise specialist recommended the following:  



 

 

The National Noise Control Regulations and SANS 10103:2008 should be used as the main guidelines for addressing any further issues related to the potential noise impact of this project. Various measures to reduce the potential noise impact from the operations at the mine and along the planned haul route are possible, and the mitigation measures indicated in Section 5 of ANNEX-7 need to be considered. The noise mitigation measures will need to be designed and/or checked by an acoustical engineer in order to optimise the design parameters and ensure that the cost/benefit of the measure is optimised. Once the actual noise profile of plant and equipment is known, the position of the noise contours should be checked. At commissioning of the mine, the noise footprint of each discrete element should be established by measurement in accordance with the relevant standards, namely SANS ISO 8297:1994 and SANS 10103. The character of the noise (qualitative aspect) should also be checked to ascertain whether there is any nuisance factor associated with the operations. Noise monitoring guidelines are to be prepared and implemented. With regard to wildlife, surveys need to set up to establish the vulnerability of any endangered species in the vicinity of the proposed mine site.

298 | P a g e

4.8

BLASTING AND VIBRATION

4.8.1 TYPICAL ISSUES OF CONCERN 4.8.1.1 Ground vibration Explosives are used to break rock through the shock waves and gasses yielded from the explosion. Ground vibration is a natural result from blasting activities. The far field vibrations are inevitable, but un-desirable by products of blasting operations. The shock wave energy that travels beyond the zone of rock breakage is wasted and could cause damage and annoyance. The level or intensity of these far field vibration is however dependant on various factors. Some of these factors can be controlled to yield accepted levels of ground vibration and still produce enough rock breakage energy. Ground vibration from blasting operations is measured in velocity and units applied are mm/s. Factors influencing ground vibration are the charge mass per delay, distance from the blast, the delay period and the geometry of the blast. These factors are controlled by planned design and proper blast preparation. Ground vibration limitations for infrastructure in the Fuleni Anthracite Project area are (BM&C, 2015): Structure / Installation National Roads/Tar Roads Electrical Lines Railway Transformers Water Wells Telecoms Tower Structures according to NHBRC guidelines – typical government built, schools clinics Rural building typically found in the project area and traditional mud houses

Vibration limit (mm/s) 150 75 150 25 50 50 USBM Criteria or 25 mm/s vibration limit 6 mm/s limit

A further aspect of ground vibration amplitude and frequency is the human perception. It should be realized that the legal limit for structures is significantly greater than the comfort zones for people. Humans and animals are sensitive to ground vibration and vibration of the structures. Research has shown that humans will respond to different levels of ground vibration and at different frequencies. Ground vibration is experienced as “Perceptible”, “Unpleasant” and “Intolerable” (only to name three of the five levels tested) at different vibration levels for different frequencies. This is indicative of the human’s perceptions on ground vibration and clearly indicates that humans are sensitive to ground vibration. Humans already perceive ground vibration levels of 4.5mm/s as unpleasant. Generally people also assume that any vibrations of the structure - windows or roofs rattling - will cause damage to the structure. Air blast also induces vibration of the structure and is the cause of nine out of ten complaints.

299 | P a g e

4.8.1.2 Air blast Air blast is an inaudible pressure wave. Air blast is the direct result from the blast process. Air blast is normally associated with frequency levels less than 20 Hz, which is the threshold for hearing. The three main causes of air blast can be described as the pressure pulse directly from the rock displacement, ground vibration causing pressure pulses some distance away from the blast and blast holes venting or blowing out during the detonation process. Air blast levels yielded may be influenced by external factors, wind strength, wind direction, meteorological conditions and topography. Air blast is measured in pressure (Pa) but normally converted to a dB scale for ease of interpretation. Air blast limitations on structures: The recommended limit for air blast currently applied in South Africa is 134dB. This is specifically pertaining to air blast or otherwise known as air-overpressure. This takes into consideration where general public is of concern. In case of schools and hospitals a recommended limit of 128 dB is applicable. Airoverpressure is pressure acting and should not be confused with sound that is within audible range (detected by the human ear). Damage Limits for Air Blast: Level >130 dB

Description Resonant response of large surfaces (roofs, ceilings). Complaints start.

150 dB 170 dB

Some windows break Most windows break

180 dB

Structural Damage

Considering the human perception and misunderstanding that could occur between ground vibration and air blast, generally it is recommended that blasting be done in such a way that air blast levels is kept below 120dB. In this way it is certain that fewer complaints will be received for blasting operations. The effects on structures that startled people are significantly less – thus no reason for complaining. It is the actual influence on structures like rattling of windows or doors or large roof surface’s that startle people. These effects are sometimes misjudged as ground vibration and considered as damaging to the structure. 4.8.1.3 Fly rock Blasting practices require some movement of rock to facilitate the excavation process. The extent of movement is dependent on the scale and type of operation. For example, blasting activities within large coal mines are designed to cast the blasted material much greater distances than practices in a quarrying or hard rock operations. This movement should be in the direction of the free face, and therefore the orientation of the blasting is important. Material or elements travelling outside of this expected range may be considered to be fly rock. Fly rock can be explained and defined in the following three categories: 

Throw - the planned forward movement of rock fragments that form the muck pile within the blast zone.

300 | P a g e





Fly rock - the undesired propulsion of rock fragments through the air or along the ground beyond the blast zone by the force of the explosion that is contained within the blast clearance (exclusion) zone. Fly rock using this definition, while undesirable, is only a safety hazard if a breach of the blast clearance (exclusion) zone occurs. Wild fly rock - the unexpected propulsion of rock fragments, when there is some abnormality in a blast or a rock mass, which travels beyond the blast clearance (exclusion) zone.

Figure below shows the schematic fly rock terminology

Fly rock from blasting can result from the following conditions:   

When burdens are too small rock elements can be propelled out of the free face area of the blast, When burdens are too large and movement of blast material is restricted and stemming length is not correct rock elements can be forced upwards creating a crater forming fly rock from this, If the stemming material is of proper quality or too little the stemming is ejected out of the blast hole and fly rock created.

Stemming of correct type and length is required to ensure that explosive energy is efficiently used to its maximum and to control fly rock. The occurrence of fly rock in any form will have a negative impact if found to travel outside the safe boundary. A general unsafe boundary is normally considered to be within a radius of 500 m. If a road, structure, people or animals are within the 500 m unsafe boundary of the blast, irrespective of the possibility of fly rock or not, precautions must always be taken to stop the traffic, remove people and / or animals for the duration of the blast. 4.8.1.4 Noxious Fumes Explosives are carefully engineered to yield the energy for the purpose it was designed. The chemical composition of commercial explosives currently used is required to be oxygen balanced. Oxygen balance refers to the stoichiometry of the chemical reaction and the nature of gases produced from the detonation of the explosives. The creation of poisonous fumes such as nitrous oxides and carbon monoxide are particular undesirable. These fumes present themselves as red brown cloud after the blast detonated. It has been reported that 10 ppm to 20 ppm has been mildly irritating. Exposure to 150 ppm or more (no time period given) has been reported to cause death from pulmonary edema. It has been predicted that 301 | P a g e

50% lethality would occur following exposure to 174 ppm for 1 hour. Anybody exposed must be taken to hospital for proper treatment. Factors contributing to undesirable fumes are typically: poor quality control on explosive manufacture, damage to explosive, lack of confinement, insufficient charge diameter, excessive sleep time, and specific types of ground can also contribute to fumes. Poor quality control on explosives will yield improper balance of the explosive product. This is typically in the form of too little or too much fuel oil or incorrect quantities of additives to the mixture. Improper quality will cause chemical breakdown of the explosives product that may result in poor performance. A “burning” may occur that increases the probability of fumes in the form of NO and NO2. Damage to explosives occurs when deep blast holes are charged from the top of the hole and literally fall into the hole and get damage at the bottom. The bottom is normally the point of initiation and damaged explosives will not initiate properly. A slow reaction to detonation is forced and again contributes negatively to the explosives performance and fume creating capability. Studies showed that inadvertent emulsion mixture with drill cuttings can also be a significant contributing factor to NOx production. The NO production from the detonation of emulsion equally mixed (by mass) with drill cuttings increased by a factor of 2.7 over that of emulsion alone. The corresponding NO 2 production increased by factor of 9 while detonation propagated at a steady Velocity of Detonation. Water also has visible effect on the generation of fumes from emulsion explosives. Tests have shown that the detonation velocity may not be influenced as much but the volumes of fumes generated were significantly higher. Further it is also known that for certain ground types, especially the oxidized type materials could have an advert effect on explosives as well. These ground materials types tends to react with the explosives and causes more than expected fumes. Drill diameter is also contributing factor to explosive performance and the subsequent generation of fumes. Explosives are diameter dependant for optimal performance. If diameter is too small for a specific product improper detonation will occur and may result in a burning of the product rather than detonation. This will have an adverse effect of more fumes created. Each explosive product has a critical diameter. It is the smallest diameter where failure to detonate properly occurs. ANFO blends are normally not good for small diameter blast holes and emulsion explosives can be used in the smaller diameter blast holes. Control actions on fumes will include the use of the proper quality explosives and proper loading conditions. Quality assurance will need to be achieved from the supplier with quality checks on explosives from time to time. Further action is to prevail from loading blast holes at long periods prior to blasting. Excessive sleeping of charged blast holes will add to fumes generation and should be prevented. Additional measures could include placing stemming plugs at the bottom of the hole and loading emulsion from the bottom up will excluded mixing of drill chippings with the explosives in initiation area. The checking of blast holes for water will ensure that charging crew charges blast hole from the bottom (which should be a standard practise) and displaces the water. This will also ensure proper initiation of the blast hole.

302 | P a g e

4.8.1.5 Vibration impact on provincial and national roads The influence of ground vibration on tarred roads are expected when levels is in the order of 150mm/s and greater. Or when there is actual movement of ground when blasting is done to close to the road or subsidence is caused due to blasting operations. Normally 100 blast hole diameters are a minimum distance between structure and blast hole to prevent any cracks being formed into the surrounds of a blast hole. Crack forming is not restricted to this distance. Improper timing arrangements may also cause excessive back break and cracks further than expected. Fact remain that blasting must be controlled in the vicinity of roads. Air blast does not have influence on air blast by virtue of the type of structure. There is no record of influence on gravel roads due to ground vibration. The only time damage can be induced is when blasting is done next to the road and there is movement of ground. Fly rock will have greater influence on the road as damage from falling debris may impact on the road surface if no control on fly rock is considered. 4.8.1.6 Cracking of houses and consequent devaluation Houses in general have cracks. It is reported that a house could develop up to 15 cracks a year. Ground vibration will be mostly responsible for cracks in structures if high enough and at continued high levels. The influences of environmental forces such as temperature, water, wind etc. are more reason for cracks that have developed. Visual results of actual damage due to blasting operations are limited. Observing cracks on a structure will certainly influence the value as structural damage has occurred. The presence of general vertical cracks or horizontal cracks that are found in all structures does not need to indicate devaluation due to blasting operations but rather devaluation due to construction, building material, age, standards of building applied. Proper building standards are not always applied or else stated was not always applied in the country side when houses were built. Thus damage in the form of cracks will be present. Exact costing of devaluation for normal cracks observed is difficult to estimate. A property valuator will be required for this and I do believe that property value will include the total property and not just the house alone. Mining operations may not have influence to change the status quo of any property. 4.8.1.7 Blast operations impacts on farm animals and wild life The information and proper study material of the occurrence of blasting operations near farming communities with various animals, wild life areas and wild life in general is limited in exact detail. Some work was done but much related to impact from air blast in nuclear blasts or bombs exploding. This was mainly indication of mid-air detonations occurring and the respective effect. There is not much research done in the field of farm animals or wild live in relation to blasting operations specifically with regards to social interaction defects or changes or the influence on wellbeing of animals. Cattle: Cattle seem to be very accommodating with regards to blasting operations. We have seen that for a first time blast, the blast will upset them. Reaction is shown in taking freight and running a short distance – maybe 10m to 20m – and then carries on grazing. Second blast they will only lift their heads and carry on grazing. Third blast no specific reaction was shown most of the time. Chickens: Chickens react to sudden noises. Chickens in a broiler will run into the opposite corner of the broiler than the noise source and actually trample each other to death. Chickens in a broiler are considered a problem when blasting is done in close proximity without specific mitigation measures.

303 | P a g e

House animals: Dogs are sensitive to vibration much more than humans and most probably all animals. Significant vibration levels will have them reacting in barking, getting anxious and possibly running away in opposite direction. One can relate to what typically happens when crackers are fired over Christmas and Guy faux days. Loud noises will certainly have an influence. Noise affects wildlife differently from humans and the effects of noise on wildlife vary from serious to nonexistent in different species and situations. Risk of hearing damage in wildlife is probably greater from exposure to nearby blast noise from bombs and large weapons than from long-lasting exposure to continuous noise or from muzzle blast of small arms fire. Direct physiological effects of noise on wildlife, if present, are difficult to measure in the field. Behavioural effects that might decrease chances of surviving and reproducing could include retreat from favourable habitat near noise sources and reduction of time spent feeding with resulting energy depletion. Serious effects such as decreased reproductive success have apparently been documented in some studies. Decreased responsiveness after repeated noises is frequently observed and usually attributed to habituation. Military and civilian blast noise had no unusual effects (beyond other human-generated noise) on wildlife in most studies, although hearing damage was not an issue in the situations studied and animals were often probably habituated to blasts. The Animal Research Centre at Onderstepoort, South Africa was contacted in the past for information as well but to no prevail as studies in this field does not exist at Onderstepoort. There has been claims in the past of farmers claiming that the reproductively of pigs were severely hampered due to mining operations but no scientific evidence were presented for this. No scientific evidence exists of deterioration of milk production. However previous projects done by BM&C in the vicinity of dairies, it was considered that it is possible that milk production will be hampered when blasting is done during the milking process. In this instance no blasting was allowed prior to milking time. Thus blasting was only done after the daily milking period. This instance the quarry where blasting was done was approximately 800m away from the dairy. Work done by Richmond, Damon, Fletcher, Bowen and White considered the effect of air blast on animals from air blast in specific conditions. Animals were tested in shock tubes as well as research from other encompassed into the report. In this research work that was done to define the influence of air blast pressure and the resulting effect on different types and size of animals. Mouse, rabbits, Guinea Pig, hamsters, rat, dog, goat, sheep, cat and cattle were the subjects of this research. The research concentrated on the effect of short duration and long duration pressure pulses, orientation of subject, reflected shock or not and investigated the effect with regards to lethality, lung injury and eardrum rupture. This work was basis for estimates of pressure and possible influence on humans and the required protection of humans in blast situations. Without going into all the detail of the report the following is a summary of the findings. Long duration and fast rising pressure pulses seem to have most influence on the wellbeing of animals. Long duration pressure pulses are also found in the blasting environment. Long duration pressure pulses are defined as pulses beyond 20 msec, and short duration as pulses having duration of less than 5 msec. Lungs are considered the critical organs in such a situation. The release of air bubbles from disrupted alveoli of the lungs into the vascular systems accounted for the rapid deaths. The degree of lung haemorrhage was related to the increase in lung weight and blast dosage. Smaller lung sizes were damaged easier. Larger animals showed threshold of petechial haemorrhage was near 10psi to 15psi (68.9476kPa to 103.421kPa) at long durations. Ear damage recorded in sheep showed 38% rupture were recorded at 21.4psi (147.548kPa) for long durations and severity of damage increased with the intensity of the blast. 304 | P a g e

There are various mines in South Africa and Botswana that has game reserve areas as part of mine property. For example, New Vaal Colliery has some small game and Debswana Orapa Diamond mine has a rather large area with various animals and specifically also rhino. No specific observations on the animals were done by the author at these mines, but it leads to that if these animals survive a certain habituation must occur. A further example is the Alkantpan test range in the Northern Cape where large calibre canons are tested. Small antelope like Springbok is also found on the test range. There is certainly enough evidence that co-existence is possible. Elephants: General literature search on possible influence of ground vibration and air blast from blasting operations on elephants and crocodiles showed no specific information. Work has been done on elephants with regards to responses on vibration stimuli in Etosha by O’Connell-Rodwell et al. Stimuli representing specific rumbles were played back and responses observed. Specific rumbles that will resemble specific warning or information were used. The levels of these signals were very low and confirming the elephants can feel very low levels. The study did show that responses from the elephants were observed. Though the signals were very low and range in specific frequency it was specific recordings of certain situations known to elephants – or otherwise said specific recognised signals. A study done by Peter H. Wrege et al investigated the response of forest elephants during oil exploration. No specific stimuli were provide other than the activities concerning the exploration project. This included road making, camp setups, clearing of bush and also seismic blasting. Equipment was setup to monitor the elephant responses during the process. Specific of interest was observation of elephant movements due to these actions. There was indication that the seismic detonations showed limited response from the elephants. The human activities seemed rather to have an influence causing elephants to remain from open areas in the forest. Activity increases at night were observed. The exploration activity however did not cause elephants to completely move away from the forest area. Crocodiles: Concern was expressed about the influence of blasting operations on the lively hood of crocodiles that may be found in the Mfolozi River. In order determine what the possible or the possibility of influence can be a literature search was done. This search involved search on the internet and communication to specialist in the field of crocodiles. In particular Mr. Xander Combrink was very helpful in this regard. There are various and in abundance of information on crocodiles but very little that really addresses the question of influence from blasting operations. In fact one report and court case was documented about blasting operations apparently contributing to the deaths of various crocodiles at a crocodile farm in KwaZulu Natal in 1989. The incident was followed by a court case between the farm owner and the blasting company doing blasting operations near the farm on the N2 national route. It is not the objective to give full details of the case but to highlight the fact that on a previous occasion a claim was made that the effects from blasting contributed to the deaths of multiple crocodiles. Main reasons given were stress caused by the blasting that contributed to this. There was unfortunately no specific data reported in this paper with the regards to recordings made or the specific influences. Comparisons were made doing analysis of blood samples from the stressed crocodile group and a group of crocodiles at the Natal University (considered the control due to apparent non-stressed). The crocodiles at the farm were inspected and factors were observed that could indicate signs of stress. Further to this autopsies were conducted and blood samples taken. These blood samples were the compared to the control group. It was also mention that possible other factors such an early winter and a virus could possibly have had influence on the stress of the crocodiles. A significant group of the crocodiles at the farm were imported from Namibia not too long before this incident. 305 | P a g e

The court case following the claim did however conclude that there was no clear evidence that the crocodiles died as a direct result from the blasting operations. There were no specific evidence of a relationship between the deaths and blasting. This confirms that there is still no real data that can indicate a relationship of ground vibration and air blast influence on crocodiles. It is know that crocodiles are using the lower jaw bone to feel vibration from fish when hunting and thus dependant on this for their survival. In light of not knowing of exact effects and no real data indicating contributing factors or discounting the effects of blasting operations. Further research also included studies that were conducted on the hearing capability of crocodiles and turtles. There are more specific data available on these subjects. The basic outcomes from these studies indicated the likelihood of turtles have hearing capability in frequency ranges of 100 Hz and 3000 Hz. Various aspects of the ear functions were tested. Pressure tested ranged between just less than -20 dB to greater than 30 dB. This is indicated as normal functioning of the turtle ear. This corresponds to pressure levels between 0.008 Pa and 302 Pa. Crocodiles have likelihood to have hearing capability ranging in frequency between 30 Hz and 5000 Hz. The tests conducted on the specific crocodiles indicated best sensitivity between 300 Hz and 2000 Hz. The intensities tested ranged between -60 dB and +40 dB. This corresponds to pressures in the order of 0.0001 Pa and 10 Pa. What is of importance from this data is the frequency range capability of crocodiles and turtles. Noise could be within the same range as that of crocodiles and turtles. Research work done in Canada on fish when blasting operations are done resulted in specific recommendations when blasting is done in water and close to water. This is the closest to a solution and in view of the lack of information with the already presented court case, the data from the Canadian study / recommendations is proposed. The specific report is also provided for perusal as an attachment to this report. There are specific recommendations that are highlighted in the recommendations that could be made applicable here:     

No explosive to be knowingly detonated within 500 m of any marine animal. The stemming of a blast hole must be done using angular gravel to have particle size of approximately 1/12 the size of blast hole diameter. No explosive to be detonated in or near fish habitat that produces and instantaneous pressure change of greater than 100 kPa. For confined explosives the distance between habitat and blast must be such not to exceed the 100 kPa overpressure. No explosives to be detonated or is likely to detonate that will produce vibration greater than 13 mm/s in a spawning bed during egg incubation. (For the sake of simplicity this will be used irrespective of spawning or not).

Considering the above summary the following will be important to consider.     

Location of crocodile concentrations and other aquatic life must be known. Air blast will have to be controlled in relation to the surroundings where crocodiles and aquatic life are found. The pressure levels of should not exceed 100 kPa at water’s edge. Ground vibration should not exceed 13 mm/s. Air blast frequency should be less than 30 Hz. 306 | P a g e

The levels of ground vibration can be managed by specific blast design that will contribute to lower levels. Ground vibration is likely to be transferred from solid to water but with reduction due to reflections of the shockwave on the interface between solid and water. Air blast on the other hand is less like to transfer to the water as a shockwave. The specific characteristics are rather an upward direction away from the ground and this will make it highly unlikely causing a significant pressure pulse in the water. Distance and location will be imperative in determining possible influences. Birdlife: Mining operations are not without having birds in the vicinity. Various types and sizes of birds may be expected. In order to evaluate the possible effects of mining operations on birds literature research had to be done. Specific literature to blast impact is limited but significant research was done on interaction between humans and different bird’s species in different parts of the world. Military activity influence was also considered by researchers and some data is available. In one case research was done that considered blasting effects on the behaviour and productivity of nesting Prairie Falcons. The Prairie Falcons is found in North America and is accepted to be comparable with local falcons and even kestrels though a bit bigger. Other birds that may be present are vultures which are significantly larger than falcons. It is certain the birds may differ in behaviour due to specie or size but the work done is a good baseline of what could be expected in relation to possible influences.

4.8.2 IMPACT ASSESSMENT 4.8.2.1 Ground Vibration The opencast operation was evaluated for expected levels of ground vibration from future blasting operations. Review of the site and the surrounding installations / houses / buildings showed that structures varied in distances from the opencast pit area. Houses and other structures are relatively well spread around the opencast areas. Higher concentrations are found next to Pit 1 & 2 and Pit 5 & 6. Pit 3 &4 showed the least number of house structures around the pit areas. The structures identified range in distance from very close to very far for all pit areas. The evaluation took mainly up to 3500 m from the mining areas into consideration. The distances between structures and pit areas is the main contributing factor to the levels of ground vibration expected and the subsequent possible influences. It is observed that for the different charge masses evaluated that levels of ground vibration will change as well. In view of the maximum charge specific attention will need to be given to specific areas. Figure 120 below shows the radius of 1025 m around the mining areas where 6 mm/s is expected measured and 655 m where 12.5 mm/s are expected. Review of the site and the structures it is certain the maximum ground vibration levels cannot be greater than 12.5 mm/s. There are structures that are better built and some that are of lesser quality integrity. Only a detail survey will pin point exactly what type of structure is found where. When considering human perception a better limit for future management of possible problems will be using a 6 mm/s limit. Figure 120 clearly indicates that there is a significant number of structures located within the range of 655m and thus where the 12.5 mm/s will be exceeded when maximum charge is considered. Structures in the area south of Pit 1 & 2, north of Pit 2 and south of Pit 6 is the highest concentration that will need to be considered. The influence from the medium charge is showing is significant reduction in influence sphere. Figure 121 shows an overview of structures that could be influenced. View of levels to 6 mm/s the greatest influence can be expected at Pit 1 & 2, Pit 5 & 6 on the western side and mainly Pit 6 on the south side. There are 307 | P a g e

lessstructures with the range of the 12.5 mm/s. Pit 4 & 5 showed limited influence. There are no houses in within the 6 mm/s and 12.5 mm/s vibration ranges. Reduction of the charge to at least the minimum required for a single overburden blast hole will have an added relieving effect but structures are located in such a way that influence will still be experienced. In view of the above it is believed that specific mitigations will be required to either reduce the pit areas or relocation of households. There are areas where blasting will be done that will have influence on structures.

Figure 120: Maximum charge yield of 6 mm/s and 12.5 mm/s ground vibration level around the mine areas

308 | P a g e

Figure 121: Medium charge yield of 6 mm/s and 12.5 mm/s ground vibration level around the mine areas

4.8.2.1.1 Ground Vibration and human perception

Considering the effect of ground vibration with regards to human perception, vibration levels calculated were applied to an average of 30 Hz frequency and plotted with expected human perceptions on the safe blasting criteria graph (Figure 122). The frequency range selected is the expected average range for frequencies that will be measured for ground vibration. Review of the maximum charge in relation to human perception it is seen that 3500 m from the blast people could possibly experience the ground vibration as “Perceptible”. At 1250 m the expected ground vibration levels are still less than the lower safe blasting limit – less than 6mm/s but will be experienced by people as “unpleasant”. At distance of 600m and closer there is strong indication that people will experience the ground vibration as “Intolerable”. Distances closer than 1025 m will exceed the minimum 6mm/s proposed safe limit for structures of lesser integrity. Figure 122 shows this effect of ground vibration with regards to human perception for maximum charge.

309 | P a g e

Fuleni Anthracite Coal Project Ground Vibration Limits & Human Perception Perceptible

Unpleasant

Intolerable

Vibration @30 Hz

1250m

600m

6mm/s Limit

12.5mm/s Limit

3500m

1000 Above Limit Zone

Ground Vibration (mm/s)

Intolerable

30Hz Vibration levels

100

12.5 10

600m

12.5 600m

Unpleasant

6

6 1250m

1250m

Perceptible

1

3500m

3500m

Safe Blasting Zone 0.1 1

10

100

Frequency (Hz)

Figure 122: The effect of ground vibration with human perception and vibration limits

4.8.2.1.2 Vibration impact on roads

There are no highways or nation provincial roads in vicinity of the project area to be considered. There are no tarred roads in the vicinity of the project area. There gravel roads that link the different villages. In two cases the roads are running cross the planned opencast areas. Two roads are crossing Pit 2 and one road is crossing Pit 6. These roads will require rerouting consideration. There also various smaller paths that are used by people and animals in the areas of the project. These routes are specifically of concern blasting is done. There may be people and animals on these routes and will require careful planning to main safe blasting radius. There are no roads located such that ground vibration levels would be of concern other than mention in this section for re-routing. 4.8.2.1.3 Potential that vibration will upset adjacent communities

Ground vibration and air blast generally upset people living in the vicinity of mining operations. There are communities, grazing areas and roads that are within the evaluated area of influence. There are structures in close proximity of most of the pit areas. Structures are in some cases right next to the pit area and in some cases within the pit areas. It is understood that communities are already complaining about damages due to the neighbouring mining operations. This makes the possibility that ground vibration from the project will be an added concern. Ground vibration levels at distances of 1025 m from the areas is expected to be within acceptable limits – 6 mm/s. Up to a distance of 1250 m people could experience levels of ground vibration as unpleasant. Due to the already sensitiveness of the people it is well expected that people will be upset about the levels of ground vibration at least up to a distance of 1250 m.

310 | P a g e

The importance of good public relations cannot be under stressed. People tend to react negatively on experiencing of effects from blasting such as ground vibration and air blast. Even at low levels when damage to structures is out of the question it may upset people. Proper and appropriate communication with neighbours about blasting, monitoring and actions done for proper control will be required. 4.8.2.1.4 Cracking of houses and consequent devaluation

The structures found in the areas of concern ranges from informal building style to brick and mortar structures. There are villages / groups of houses surrounding the different pit areas. A significant number of structures are found within 3500 m from the pit areas. Building style and materials will certainly contribute to additional cracking apart from influences such as blasting operations. The presence of general vertical cracks, horizontal and diagonal cracks that are found in all structures does not need to indicate devaluation due to blasting operations but rather devaluation due to construction, building material, age, standards of building applied. Thus damage in the form of cracks will be present. Exact costing of devaluation for normal cracks observed is difficult to estimate. Mining operations may not have influence to change the status quo of any property if correct precautions are considered. The proposed limits as applied in this document i.e. 6mm/s, 12.5mm/s and 25mm/s is considered sufficient to ensure that additional damage is not introduced to the different categories of structures. It is expected that, should levels of ground vibration be maintained within these limits, the possibility of inducing damage is limited. 4.8.2.2 Air Blast The prediction of air blast is subjective and is used to help identify critical points as best as possible. Actual blasting operation preparation plays a very significant part in the outcome of air blast levels. If care is not taken then this prediction could be rendered useless and not applicable. It is known that air blast is probably the aspect that contributes to complaints from neighbours more than ground vibration even at levels not range of causing damage. Review of the air blast levels shows trend of lesser influence than ground vibration. Structures within 200m from the pit boundaries are generally problematic and structures found up to 900m could experience levels of air blast that could contribute to complaints. Complaints from air blast are normally based on the actual effects that are experienced due to rattling of roof, windows, doors etc. These effects could startle people and raise concern of possible damage. The possible negative effects with regards to causing damages from air blast are expected to be less than that of ground vibration. It is maintained that if stemming control is not exercised this effect could be greater with greater range of complaints or damage. The pit areas with structures around are such that “free blasting” – meaning no controls on blast preparation – will not be possible. Review of maximum charge shows minimal structures included where levels are exceeding the current legal limit of 134 dB. Figure 123 shows the influence area for maximum charge evaluated and Figure 124 shows the influence area for Medium charge evaluated. Considering the maximum charge it is mainly structures around Pit 2 and the structures on the southern side of Pit 6 that are problematic. The 120 dB level stretches to a distance of 900 m and do include a significant quantity more structures.

311 | P a g e

The medium charge reduces the areas of influence but Pits 1& 2 remains with structures that will certainly be influenced. The structures at pit 6 on the southern corner are also included even with reduced charge. The location of these structures is such that possible influence is highly likely.

Figure 123: Air blast influence from maximum charge for Pit Area 5 & 6

4.8.2.3 Fly-rock Modelling Results and Impact of fly rock The blasting of overburden in the harder material than coal has high potential for elements to travel further when fly rock is considered. The fly rock prediction concentrated on the worst case option. Review of the factors that contribute to fly rock it is certain that if no stemming control is exerted there will be fly rock. A stemming length of 4.13m in the blast is expected to yield fly rock that could travel as far as 306m. The reduction of stemming length will certainly see fly rock travelling further. Figure 125 below shows the relationship burden or stemming length towards expected throw distance. Throw distance considered here on the same level as the free face. Landing level of elements lower than free face could see longer distances. Optimal throw distance is also observed at 45 degree angles of departure and at the elevated levels of blasting care must be taken on fly rock as travel distance may be further than anticipated.

312 | P a g e

Figure 124: Air blast influence from maximum charge for Pit Area 5 & 6

As can be seen from Figure 126 there are various receptors located at different points in relation to the pit areas. Pit area 1 & 2 shows houses on the southern side of the two pit areas and on the north eastern side of Pit 2. On the eastern side the Mfolozi River is just outside the 304 m mark. Pit 3 shows the road on the northern side to be within the 500 m exclusion zone. The game reserve fence is outside the 500 m mark. There are two water boreholes located at close proximity of Pit 3 & 4 that is also within the 306 m radius. Direct damage is not expected unless a pump or pump house etc. is erected at the borehole. Pit 6 has various houses that are at close proximity on the most southern corner of the pit. There are a significant number of houses that is included in the 306 m range and the 500 m range. The location of structures around the pit areas are a concern as blasting operations will not be possible as per current status and location of structures. Significant evacuation during blasting will have to be done. The location of some of these structures is also such that possible damages due to ground vibration and air blast will be possible.

313 | P a g e

Fuleni Anthracite Coal - Fly Rock Maximum Throw Distance vs Burden/Stemming Height 600

Planned Stemming Coal Fly Rock Calc

Planned Stemming OB Fly Rock Calc

OB Fly Rock Calc - ISEE

Coal Fly Rock Calc - ISEE

500

Throw Distance (m)

400

306

300 249 200

100

0 1

1.5

2

2.5

3

3.5

4

4.5

5

5.5

6

Burden / Stemming Length (m)

Figure 125: Predicted Fly rock

Figure 126: Predicted Fly rock zone areas

314 | P a g e

4.8.2.4 Noxious fumes Influence Results The occurrence of fumes in the form the NOx gaseous format is not a given and very dependent on various factors. However the occurrences of fumes should be closely monitored. It is not assumed that fume will travel to any part nearby but again if anybody is present in the path of cloud travel it could be problematic. 4.8.2.5 Water well influence Boreholes for water were evaluated for possible influence as well. There are various boreholes in the area. Five boreholes were identified that could possibly be influenced due to excessive ground vibration at minimum, medium or maximum charge. The expected levels of ground vibration are significantly greater than the limit applied for water boreholes. Table 88 shows the boreholes that are of concern and Figure 127 show the location of these water boreholes. These boreholes range from 25 m to 238 m from pit boundary. Table 88: Water boreholes that may be impacted by blasting Tag 126 127 128 129 132

Description Borehole (FUL33) Borehole (FUL44) Borehole (FUL21) Borehole (FUL26) Borehole (FUL50)

-Y 94820.84 93618.94 96367.19 95479.87 92226.70

-X -3144358.71 -3146016.18 -3143891.29 -3143937.29 -3146875.31

Specific Limit (mm/s) 50 50 50 50 50

Distance (m) 64 25 150 238 113

Figure 127: Water boreholes that may be impacted by blasting

315 | P a g e

4.8.2.6 Blast operations impacts on farm animals and wild life The area is characterised by hills and flat areas in between. There are no specific fenced grazing areas. There are fenced off small agricultural lands that area used. Cattle and goats can be expected to roam freely throughout the area. It may also be anticipated that cattle could be present from time to time at close proximity in the area. It is however considered important that the aspect of influence from blasting is addressed as well. The influence on productivity of animals over period of time due to blasting operations is not clearly defined and difficult to estimate. Social behaviour and change of social behaviour is unfortunately problematic. It is however the blasting specialist’s opinion that influence will be experienced when animals are located permanently in close proximity of blasting operations. At larger distances, estimated in the region of 500m and greater, cattle or game will get accustomed to the blasting and related noise. This is based in observations made personally when blasting is done and cattle are present. Review of the charging configurations and air blast levels expected it is clear that in order to induce lung / ear injury or death, animals will have to very close to the blast. This is excluding fright and secondary injury from flying debris. The blasting specialist indicated that cattle will get used to the blasting operations and fly rock may be the most likely cause of injury or death if not removed to safe distance. As an example review of the pressures required to cause lung damage in larger animals is at 10psi (68.59kPa) to 15psi (103.4kPa). This relates to air blast levels in the order of 190dB (L) and 195dB (L). Table 89 shows that it will be required that animals be on the blast and again showing that factors apart from air blast would cause death. Table 89 show air blast levels in dB and kPa at short increment distances from the blast based on the maximum charge used for the assessment. Table 89: Expected air blast levels in dB and kilopascal’s for short distance increments

Distance (m) 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0 50.0

Air Blast Pressure Levels for Maximum Charge in dB 174 167 163 160 157 156 154 153 151 150

Air Blast Pressure Levels for Maximum Charge in kPa 10.33 4.50 2.77 1.96 1.50 1.20 1.00 0.85 0.74 0.65

Considering the above information it is certain that injury to animals such as cattle / goats is highly unlikely due to the fact that cattle should never be allowed on top of a blast area. The effect from the blast itself is then more likely to be lethal. It is anticipated that the mining area will be fenced off and animals not be present inside the mining area and cleared to outside the exclusion zone for safe blasting. Based on the background information with regards to wildlife it is certain that there is uncertainty if ground vibration from blasting operations will contribute to deaths and if so at what levels. The same can be argued for air blast at distances further than what is normally considered safe from a blast operation. In 316 | P a g e

general there is indication that animals will habituate to the effects. Pressure levels from 124.9 dB air blast as calculated for maximum charge at the reserve fence 568 m from nearest pit - Pit 3& 4 – equals 35.2 Pa over pressure. This is significantly less where any injury is expected. Considering the possible influences that may exists from blasting operations on crocodiles and the Canadian guidelines are used, Pit 1 shows area of concern with regards to medium and maximum charge. These charges are likely to yield ground vibration levels greater than 13 mm/s at water’s edge. Due to uncertainty of existence of crocodiles or water life on this part of the Mfolozi River on the eastern side of Pit 1 it must be considered a sensitive area. Levels expected from the medium and maximum charge is expected to yield levels greater than the proposed 13 mm/s. The minimum charge shows expected levels less. The charge mass per delay to yield 13 mm/s over the distance of 310 m from Pit 1 to water’s edge is 423 kg. This charge mass is less than medium charge but greater than what is required for a single overburden blast hole charge. A single overburden charge calculated is 300 kg. Recommendation will then be that single blast hole detonation process will be required from blasting in pit 1. It is only this area of the river on the eastern side that is critical. Location of the river downstream and upstream is significantly further away. The air blast levels expected from 423 kg charge mass at 310 m is expected to yield 126 dB. This relates to 0.04 kPa over pressure. This level is not expected to lethal. Figure 128 below shows area of Mfolozi River that could possibly be influenced based on the expected ground vibration levels for medium and maximum charges.

Figure 128: Sensitive river area

It is very difficult to specifically ascertain whether there will be any influence without any direct investigating of the process. The sensitivity of the possible influences is understood but based on the effects such as ground vibration and air blast there is reason to believe that levels expected is less than 317 | P a g e

what will be required to induce injury of death. Social behaviour or changes of social behaviour in these circumstances are unknown at this stage. Review of data on blast effects on birdlife and specifically falcons there is guidelines on levels of air blast that could be problematic. Currently not known at time of this report is exact location or occurrence of any raptor colony in the area of the project. Based on the guidelines a sensitive area can be determined. This area is considered the area around the pit areas that could yield the same levels as measured by Holthuijzen. The research showed levels ranging between 129 dB to 146 dB for all the tests conducted. In this report a guideline of 129 dB is then accepted as baseline. Air blast levels calculated for the various charges indicate that the maximum charge evaluated could yield levels of 129 dB at a distance of 400 m. This distance decreases to approximately 300 m for medium charge and 150 m for the minimum charge. (Table 89). A buffer zone of 400 m can then be considered an acceptable distance from any breeding raptor. Figure 129 below shows the areas associated with the 400 m and 1000 m around the pit areas. It can be seen that if this taking as standard the identified area of 400 m falls well within the existing village areas and the 1000 m extends into the reserve area at POI 16. The possible existence of raptors nesting within these areas seems limited. There are no typical (known) nesting areas within this range.

Figure 129: Sensitive Raptor area

318 | P a g e

4.8.3 IMPACT SIGNIFICANCE

Nr

Impact

Construction Phase 1 None Operational Phase 1 Ground vibration Impact on houses 2 Ground vibration Impact on boreholes 3 Ground vibration Impact on roads 4 Air blast Impact on houses 5 Air blast Impact on boreholes 6 Air blast Impact on roads 7 Fly Rock Impact on houses 8 Fly Rock Impact on boreholes 9 Fly Rock Impact on roads 10 Impact of Fumes - Houses 11 Impact of Fumes - Boreholes 12 Impact of Fumes - Roads 13 Impact of Ground vibration - crocodiles 14 Impact of Air blast - crocodiles 15 Impact of Fly rock - crocodiles 16 Impact of Ground vibration - elephants 17 Impact of Air blast - elephants 18 Impact of Fly rock - elephants 19 Impact of Ground vibration - farm animals 20 Impact of Air blast - farm animals 21

Impact of Fly Rock - farm animals

Closure Phase 1 None

Impact Significance Without With mitigation mitigation Negligible

Negligible

Moderate Moderate Moderate Moderate Negligible Negligible Low Low Moderate Moderate Negligible Negligible Low Negligible Negligible Low Negligible Negligible Moderate Moderate

Low Low Low Low Negligible Negligible Low Low Low Low Negligible Negligible Low Negligible Negligible Low Negligible Negligible Low Low

Moderate

Low

Negligible

Negligible

4.8.4 RECOMMENDATIONS The location of the site and the current objections will require very detail best blasting practice program. A number of recommendations were made by the blasting specialist that must be incorporated into the Blasting Procedure – refer to Section 2.2.6 of the EMP.

319 | P a g e

TRAFFIC IMPACT ASSESSMENT

4.9

Arup (Pty) Ltd performed a detail Traffic Impact Assessment for the Fuleni Anthracite Project to determine the impact associated with the envisaged increase in traffic related to the project, as well as the construction of the new access road to the project site. They concluded that the proposed mine development will have minimal capacity impact on the surrounding road network. The mine development will however have significant impact on the following aspects:    

Pedestrian movement along the preferred “Route 5” Noise Impact Dust Impact Existing road users along D873 and L1791 as a result of the deviation for O/C2

The road improvements associated with the new access road will however have a positive impact on the safety along the route and in mitigating a number of the issues identified.

4.9.1 IMPACT ASSESSMENT AND MITIGATION 4.9.1.1 Impact on Pedestrians Significant pedestrian activity was observed along roads leading to the proposed development site. A significant proportion of the pedestrian consisted of scholars. It is anticipated that the increase in the mining traffic will have a negative impact on pedestrian activity along the new access road. In this regard, the following pedestrian safety measures are to be implemented to minimise and manage the impact:    



The road geometric upgrades that will be implemented along the new access road will improve safe stopping site distance. If the sections around the high pedestrian activity areas are paved then traffic calming measures in the form of speed humps should be implemented. The provision of traffic warning signs and decrease in speed limit for trucks over the affected sections to 40km/h. All trucks servicing the Fuleni Anthracite Project should be installed with tracking devices and the development management should employ an independent assessor monitor the speed over the affected sections and provide the controlling authorities with a detailed report at regular intervals. Provision of dedicated pedestrian footpaths in the high pedestrian areas that are physically separated from roadway (by barriers) and that have openings at selected locations and at formal pedestrian crossings.

4.9.1.2 On-Site Pedestrian Activity At this stage the on-site pedestrian activity has not been considered. It is recommended that prior to construction a Traffic Management Plan (TMP) should be prepared to address all on-site transportation activities (pedestrians, cars, trucks etc). This plan should address the following: 320 | P a g e

     

Pedestrian circulation Drop off and pick up location for staff shuttles Access control systems On-site vehicle circulation for trucks, cars etc Parking Areas Loading Areas

4.9.1.3 Impact of Dust The proposed mine will increase the traffic volumes along routes D873, D1587, P494, P425 and P389 and as such the amount of dust generated will increase. The increase dust will impact negatively on pedestrians and residents along the route. In this regard, the following suggested mitigating measures must be implemented by the mine:   

The provision of paved road surfaces in high pedestrian activity sections will reduce dust. If the busy pedestrian sections are not paved then regular routine road maintenance plan must be adhered to (as dictated by the daily traffic volumes) Reducing the speed limit over sections of the road where there is high pedestrian activity.

An alternate measure could be implemented but this must be approved by a pavement engineer. 4.9.1.4 Impact of Noise The increase in traffic along the new access road will increase the noise level along this route. It is recommended that the recommendation made by the specialist be adhered. 4.9.1.5 Impact on Other Road Users The increase in traffic along the access road will impact on the other road users in terms of road capacity and safety. Detailed analysis regarding capacity was undertaken and the results are shown in Sections 5 and 6 of the specialist report (ANNEX-15). It is therefore concluded that the proposed mine will have minimal impact on the capacity of the road network. Regarding the safety, as part of the development there will be road geometric improvements made to the road network. These upgrades are focused on improving the safety of the road and will hence have a positive impact on other road users. 4.9.1.6 Impact on Animals The increase in traffic along access road will impact on the safety of animals. upgrades will however improve the safety along this route.

The proposed geometric

It is however recommended that warning signs be placed along the route where there is high animal activity.

321 | P a g e

4.9.1.7 Impact on Deviation of D873 and L1791 for Open Pit 2 Open Pit 2 will result in the realignment of both D873 and L1791 (Figure 130). The net result is that commuters, and especially students travelling to the nearby school, along this road will now have to travel longer distance to circumnavigate Open Pit 2. In order to mitigate the impact of the deviation, one of the following mitigating measures is proposed: 

 

Option 1 – The mining of Pit 2 is sequenced in such a manner that the use of D873 and L1791 are maximised. This could include mining Pit 2 last and the area where the existing roads are located is mined at the latest feasible time. Once Pit 2 is completed then a safe route closer to the edge of the pit should be constructed. Option 2 – A more direct deviation route could be provided located between Pit 1 and Pit 2. This will link the residential node to the north with the school and southwards towards the N2. Option 3 – Pit 2 is mined in such a manner that L1791, which runs along the eastern side, is not affected. The deviation for D873 could occur.

In addition to the above, the following regarding pedestrians in this area, is recommended: 

Students walking along affected sections of D873 and L1791 should be provided with a footpath that circumnavigates close as safely possible around Pit 2. All the necessary safety measures should be put in place.

Figure 130: Road deviations associated with Open Pit 2

322 | P a g e

4.11 VISUAL AND AESTHETIC 4.11.1 VISUAL EXPOSURE AND VISIBILITY Visual exposure refers to the geographic area from which the proposed project will be visible and is defined by the degree of visibility of a proposed project from various receptors sites. Visibility, in turn, is determined by distance between the components of a proposed project and the viewer. Visual exposure is determined by the zone of visual influence or the “viewshed”. A viewshed is the topographically defined area that includes all the major observation sites from where the proposed development will be visible. The boundary of the viewshed tends to connect high points in the landscape through following ridgelines and demarcates the zone of visual influence. The zone of visual influence usually fades out beyond 5 km distance and the further away from an observer the project is, the less visible it would be. It is also important to note that the actual zone of visual influence of the proposed project is considered to be smaller than indicated because of screening by existing vegetation and infrastructure, which may partially or totally obscure a view. Visibility classes identified for the Fuleni Anthracite Project with reference to receptors within the region surrounding the mining footprint area are indicated in the table below. In addition to potential screening from existing vegetation and infrastructure, the undulating topography, which further contributes to a screening effect. The proposed mining activities and infrastructure is expected to be highly visible to receptors present within 3 km thereof as these areas fall within the high visibility zone and the proposed project will form part of the foreground – middleground of their viewing experience. The proposed project will be moderately visible to receptors within 3-6 km and marginally visible to receptors within 6-10 km of the mining footprint area, while further than 10 or 15 km from the project area, the infrastructure will fall within the “seldom seen” distance class and be hardly visible, unless pointed out. Table 90: Visibility classes

Class

Decription

Highly visible Moderately visible Marginally visible Hardly visible

Clearly noticeable within the observer’s viewframe 0 to 3 km Recognisable feature within observer’s viewframe 3 to 6 km Not particularly noticeable within observer’s viewframe 6 to 10 km Practically not visible unless pointed out to observer 10 to 1 5km+

The visibility classes associated with the HiP were calculated as highly visible within 0-5 km and moderately visible within 5-10 km, due to the high visual sensitivity of the HiP and Wilderness environment. 4.11.1.1 Viewshed Analysis The viewshed analysis calculates the geographical locations from where the proposed project might be visible. This potential visual exposure of the project has been modelled by creating a Digital Terrain Model (DTM) and applying a viewshed analysis using GIS software, whereby all areas with a line of sight towards the proposed project is indicated. It must be noted that the heights of existing infrastructure and vegetation are not included in the calculation of the viewshed and it is, therefore, important to bear in mind that the proposed development will not be visible from all points within the viewshed as views may be obstructed by visual elements and such intervening objects will modify the viewshed at ground level. 323 | P a g e

The viewsheds created by the proposed project infrastructure are illustrated in Figure 131 to Figure 134 below, with distance radii of 5 km also indicated. Figure 131 indicates the combined viewshed of the six proposed open pits only. Figure 132 shows the combined viewshed of all other infrastructure components, including the processing plant and the discards stockpile to the north of the plant. Figure 133 indicates the combined viewshed analysis of all the proposed overburden and topsoil stockpiles. The combined viewshed, including all proposed mining infrastructure with a vertical dimension, is indicated in Figure 134. From the viewshed analysis and through the breakdown of the various components, it is evident that the extent of the visual impact of the proposed project will be centred on the overburden stockpiles which will be visible from significant distances (up to 10 km) in all directions, including from within the HiP and from within Pristine, Primitive and Semi-Primitive Wilderness areas, and that these infrastructure components contribute the most to the combined viewshed. The opencast mining areas are of lowered visual significance, will be screened from view of within the HiP by the various overburden stockpiles, and may be partially or completely screened from some receptors further away from the mining footprint area by the stockpiles. The open pits will however be highly visible from settlements in the immediate vicinity of the mining footprint areas due to the close proximity and placement of several of the open pits on hillslopes. The plant area and associated infrastructure along with the discards stockpile will mainly be visible from the south. At a distance further than 10 km from the site activities, visual exposure and visibility is expected to decrease due to objects being difficult to distinguish from the background at such significant distances in an undulating landscape. 4.11.1.2 Receptors With reference to the mining footprint area, the main visual receptors include rural villages within the region as well as tourists and hikers within the southern portions of the HiP, the latter which is considered to be a valued landscape. Users associated with nature reserves are generally regarded as highly sensitive, with this sensitivity being applicable when viewpoints from within the nature reserve towards the affected environment are unobstructed. In this case, it is evident that the proposed project will be visible from the informal wilderness trails and camping locations, and possibly from the various trail camps (as well as base camps and satellite camps not indicated below) situated in this portion of the HiP. During passage through the landscape, certain activities or locations may be specifically associated with the experience and enjoyment of the landscape, such as the use of footpaths, tourist or scenic routes and associated viewpoints. Hikers within the HiP wilderness area generally follow animal trails and part of the attraction of this tourist activity and the purpose thereof is to experience nature without evidence of manmade intrusion. The proposed project and visibility of the topsoil and overburden stockpiles from this area may therefore possibly significantly detract from this experience for some users. It is however possible that existing vegetation will assist in partially screening the stockpiles from this area. Less sensitive receptors, who will be visually affected to a lesser degree, are likely to be people at their place of work or study or engaged in similar activity, whose attention may be focused on their work or activity and who therefore may be potentially less susceptible to changes in the view.

324 | P a g e

Figure 131: Open Pit viewshed map

Figure 132: Plant and discards stockpile viewshed map

325 | P a g e

Figure 133: Overburden and topsoil stockpiles viewshed map

Figure 134: Combined viewshed map for full LOM footprint

326 | P a g e

Due to the mining footprint area not being located on a tourist or main route it is unlikely that tourists or travellers will specifically utilise the smaller roads to and from the mining footprint area in the south, while people travelling on the main roads such as the N2 and the R615, will not be affected by the proposed development as it will not be visible from these locations. Three distance zones have been identified, based on visibility from travel routes and observation points. These have been determined through field verification:   

Foreground/Middleground – includes local and sub-regional areas visible from highways, rivers, or other viewing locations which are less than 5 km away. Background – includes distant sub-regional areas visible past the foreground-middleground zone and usually less than 15 km away. Seldom Seen – includes areas that are not part of the foreground-middle ground or the background and generally hidden from view, usually further than 15km away.

Figure 135 indicate the receptors located within 5 km, 10 km and 15 km of the infrastructure and mining operations. Figure 136 shows the receptor map overlain by the combined viewshed map. 4.11.1.3 Key observation points Key Observation Points (KOPs) were identified based on prominent viewpoints, where uninterrupted views of the proposed development may occur and at points where positive viewshed areas intersect with potential receptors. KOPs were further selected based on the location of viewing areas that would possibly exist after the mine has been constructed and are therefore mostly located outside of the mining footprint. The analysis was conducted by investigating the visual influence of proposed structures as per the available site layout. Major routes, such as the N2 and the R615, which carry large amounts of traffic, the railway to the south, as well as various smaller roads, were also considered during the assessment through its inclusion in the field assessment. It was found that the proposed project would not be visible from the railway, the N2 or the R615 due the distance of these routes from the proposed mining infrastructure and screening from surrounding topography. Visual simulations were rendered from at ten key locations and are shown in Figures 33 to 42 of the Visual Impact Assessment (ANNEX-9). All visual simulations are presented as the development is envisioned in its pre-mitigated state. With appropriate mitigation and management measures put in place as outlined at the end of this report, the visual impact may be reduced. Visual simulations from Ocilwane, Ntuthunga 1, Novunula and the HiP Wilderness area are presented below in Figure 137 to Figure 140.

327 | P a g e

Figure 135: Visual receptors

Figure 136: Receptor locations overlaid onto the combined viewshed map

328 | P a g e

processing plant

Figure 137: Visual simulation of the view from the Ocilwane community

329 | P a g e

Figure 138: Visual simulation of the view from the Ntuthunga 1 community

330 | P a g e

Figure 139: Visual simulation of the view from the Novunula community

331 | P a g e

Figure 140: Visual simulation of the view from the HiP Wilderness Area

332 | P a g e

4.11.2 NIGHT TIME LIGHTING In order to understand the potential visual impacts from night lighting, it is important to understand the existing lighting levels. The Institute of Lighting Engineers (ILP) (2011) identifies five environmental zones for exterior lighting control and with which to describe the lit situation of the landscape. These environmental zones are supported by design guidance for the reduction of light pollution, which can then inform proposed mitigation techniques. Where an area to be lit lies on the boundary of two zones the obtrusive light limitation values used should be those applicable to the most rigorous zone. Environmental Zone

Surrounding

Lighting Environment

E0

Protected

Dark

E1

Natural

Intrinsically Dark

E2

Rural

Low District Brightness

E3

Suburban

Medium District Brightness

E4

Urban

High District Brightness

Examples UNESCO Starlight Reserves, IDA Dark Sky Parks National Parks, Areas of Outstanding Natural Beauty etc Village or relatively dark outer suburban locations Small town centres or suburban locations Town/city centres with high levels of night-time activity

The HiP and the majority of the MRA area is generally free from the effects of night lighting sources, with low-level light sources predominantly coming from residential areas, with other current lighting sources in the region include the Somkhele mining operations and other residential/ tourism areas located further away. The lighting environment of the MRA area is consistent with Environmental Zone E1 – Intrinsically Dark Landscapes. Overall, there is little night-time lighting currently impacting on the MRA area, and the impact from the mining development and 24 hour mining operations is expected to be significant in such a rural area during night time hours. The ILP (2011) notes recommend that, in order to maintain the nighttime setting, lighting within the identified zone should have minimal illumination into the sky as well as to adjacent viewpoints. Two types of lighting are associated with the proposed project, namely stationary lighting sources and vehicle mounted lighting sources. Stationary lights facing upward are great contributors to light pollution and causes skyglow and glare, while light facing in a horizontal direction can be visible for long distances, lead to light trespass (light falling outside the desired area of illumination) and be disturbing to viewers and vehicles. Skyglow refers to the night-time brightening of skies, particularly over urban areas, caused by the scattering and redirecting of light in the atmosphere, by water droplets and dust in the air, back towards the ground. The stray light mostly comes from poorly designed and improperly aimed light, and from light reflected from over-lit areas. This effect is very noticeable at night and in the early morning at mining operations (ASSA, 2012). Lighting from vehicles within rural areas is expected be more intrusive than in urban settings and, therefore, will have a potentially greater impact due the open nature of the landscape and the general lack of existing ambient light. Vehicle-mounted lights or portable light towers are preferred over permanently mounted lighting for night-time maintenance activities, provided that it is aimed toward the ground to avoid causing glare and skyglow (BLM, 2013). 333 | P a g e

The proposed project is expected to contribute to the effects of artificial lighting in the region, particularly as a result of stationary lighting sources. Generally, the impacts of vehicle mounted lighting sources in rural areas will be confined to the local and sub-regional setting (up to 10km from the mining footprint area) due to the effects of distance and intervening topography, vegetation and structures which serve to restrict the potential impact on views from more distant regional points. During the field assessment, a photograph sequence was taken from the MRA area, toward Somkhlele Mine at a distance of approximately 6km, indicating the occurrence of light in the distance as night approaches (Figure 141). Within the existing landscape setting, it is evident that night time lighting will be visible over moderate distances (within the local and sub-regional setting), particularly where infrastructure and roads are positioned on higher lying areas. The light from Somkhele Mine contrast strongly with the surrounding lighting levels.

Figure 141: View of Somkhele Mine

334 | P a g e

4.11.3 VISUAL IMPACTS 4.11.3.1 Impact on Landscape Character and Sense of Place Development of the proposed mining project will bring about changes in the visual character of the mining footprint area and surrounding areas and also affect the sense of place associated within the larger region. The character of the landscape in the region of the development is currently dominated by low-density rural development and subsistence agriculture, with significant areas comprising natural vegetation, riparian areas and wetlands. The HiP located to the north and northwest of the mining footprint area also has a strong sense of place and contributes to the sense of place of the region. The area in the immediate vicinity to the north, south and west of the proposed Fuleni Anthracite Project has not previously been exposed to mining activities, with only the Somkhele Mine present to the northeast. The overall character of the landscape will therefore be altered by the proposed mining activities. Prior to mitigation measures being implemented, the impact on the overall visual character and sense of place of the HiP is considered to be High during the construction phase of the project, Very High during the operational phase and Medium-High during the decommissioning and closure phases. A change in landscape character and sense of place within the southern portions of the HiP, which has high visual sensitivity (Ezemvelo KZN Wildlife, 2011) will occur during the operational phase due to stockpiles being visible from the HiP. Such an impact is likely to commence from the construction phase until the end of the decommissioning and closure phases as the proposed project will change the land use of the region. Should mitigation measures such as the shaping and revegetating of stockpiles be successfully implemented all impact levels may be somewhat lowered though reducing the severity of the impact and decreasing the spatial scale thereof. The landscape character and sense of place of the region surrounding the mining footprint area to the northeast, east, west, south and southwest is considered to be moderate, and as such is indicated as being of moderate visual sensitivity and importance. The proposed mining activities are expected to impact on a large number of residents, particularly those residing in the immediate vicinity of the mining footprint area including the Ntuthunga 1 & 2, Ocilwane and Novunula communities. Through mitigation, the severity of the impact may be lowered, particularly during the construction and operational phase. The spatial scale of the impact is considered to only affect the local area (within 5km of the mining footprint area), while the duration of the impact is likely to be long-term if the impact is not suitably mitigated. Prior to management taking place, the overall impact significance on the visual character and sense of place of the area is considered to be High during the operational phase of the project, Medium-High during the construction phase and Medium-Low during the decommissioning and closure phases. Post mitigation, should management measures be effectively implemented, the overall impact significance during the construction and decommissioning phases may be lowered to Medium-High and Medium-Low levels. 4.11.3.2 Visual Intrusion and VAC impacts The altered visual environment during the various development phases of the proposed mining project may lead to unacceptable levels of visual intrusion, with high level of incompatibility with surrounding land uses 335 | P a g e

as well as visual contrast and discord between the mining footprint area and it surroundings. This in turn will negatively impact on the VAC (the ability of an area to visually absorb development) of the area. Prior to mitigation measures being implemented, the impact significance levels on the HiP are High during the construction phase, Very High during the operational phase and Medium-High during the decommissioning and closure phases. This is mainly due to the proposed project expecting to lead to a noticeable change within the southern portions of the HiP and being discordant with the natural surroundings associated with the HiP. This impact may be lowered to Medium-High and High levels through the implementation of mitigation measures such as shaping and revegetating of the stockpiles along the southern HiP boundary, however alteration of the ridgeline will still take place. The expected level of visual intrusion through the development of a mine, taking adjacent land uses such as the HiP into consideration, is considered to be high, although the VAC itself has been determined to be moderate. This is as a result of current site conditions in terms of topography and existing levels of vegetation cover, meaning that the area has some ability to absorb or conceal visual impacts. The VAC of the mining footprint area will however be lowered during the mining process, due to clearing of vegetation and alteration of landforms. During the construction and operational phases of the project, visual intrusion and loss of VAC on the surrounding areas will occur, while further loss of VAC may also take place during the closure and decommissioning phases. This rating may be lowered, although still having a Medium-High significance rating, during the construction and closure and decommissioning phases through suitable mitigation. The severity scale of the perceived impact is expected to be great prior to mitigation and to remain as such or slightly reduced once mitigation measures have been put in place. The duration of the impact, should mitigation measures not be implemented, may be long term, but should mitigation be effective and the recovery of the landscape be actively sought after closure and through concurrent rehabilitation, may be lowered. 4.11.3.3 Visual Exposure and Visibility Impacts This impact relates directly to the perception of sensitive visual receptors towards the project. Sensitive visual receptors primarily comprise of residents living within 5km of the mining area, as well as tourists and hikers within the southern portions of the HiP. Visual exposure will take place directly as a result of mining infrastructure being visible and indirectly through fugitive dust generated by construction and operation related activities, such as construction vehicles driving on dirt roads as well as blasting and earthwork activities which will alter the visual environment. In addition to mining infrastructure, impacts from clearing of vegetation, potential erosion as a result of bare soils, alteration of landforms and access road and mining construction activities will also create noticeable contrast in the landscape and will be visible to a number of receptors. Impacts on the HiP as a result of visual exposure and visibility are considered to be Very High during the construction and operational phases and High during the decommissioning and closure phases. This is due to the high probability of this impact from occurring, the high visual sensitivity of the HiP and the high severity should this impact occur. Visual exposure and visibility of mine stockpiles by tourists and hikers utilising the HiP may be lowered to Medium-High and High significance levels by implementing mitigation measured such as shaping and revegetating of the stockpiles located on the southern boundary of the HiP during all development phases. 336 | P a g e

In addition to tourists and hikers utilising the HiP to the north of the Mining Footprint Area, a number of sensitive visual receptors reside within close proximity of the mining footprint area, including receptors residing within the Ocilwane, Novunula and Ntuthunga 1 & 2 settlements. The sensitivity of the receiving environment surrounding the mining footprint area in terms of this impact is therefore considered to be high. Prior to mitigation this impact has High and Medium-High significant and some residents of the above-mentioned villages will defiitely be affected by the proposed project. Should mitigation measures be implemented, this impact is still highly likely to occur. 4.11.3.4 Impacts due to Night Time Lighting Lighting associated with the proposed project may be visible during both day and night, but is more likely to have a visual impact during the night time. Lighting may be visible for significant distances and indirect lighting impact, such as sky glow (the scattering of light in the sky) and glare may reduce the night sky quality at locations very distant from the light sources. Night time lighting as a result of the 24 hour operations associated with the proposed project may reduce the appearance of starry skies within the intrinsically dark landscape, with particular reference to viewpoints from within the HiP, where such night skies are valued as a tourist amenity. The impact on visual resources through light pollution, particularly at night, within the HiP is likely to definitely occur during all development phases. Due to the presence of the HiP adjacent to the proposed Fuleni Anthracite Project and the area being rural with a low lighting level, together with the possibility that skyglow and light trespass may reduce the visual quality of this environment, the landscape is considered to be visually highly sensitive and important. The severity of light pollution impacts on the HiP is high, with night lights, particularly at elevated locations, expected to be visible for significant distances. Should effective mitigation however take place and no lights be located on the stockpiles bordering the HiP and operational vehicles be restricted from driving in these areas during the night, this impact may be lowered to Medium-Low significance. The impact on other visual resources through light pollution, particularly at night, is Medium-High during all development phases, but during the construction and decommissioning and closure phases the effective implementation of mitigation measures pertaining to lighting may be reduced to Medium-Low significance level. The operational phase significance level will however remain Medium-High. 4.11.3.5 Impact Summary Based on the above assessment it is evident that there are four possible impacts that may affect the visual character of the subject property and impact on potential receptors and visually sensitive landscapes. Table 91 and Table 92 below summarise the findings of the impact assessment, indicating the significance of the various impacts before mitigation takes place and the likely impact if effective management and mitigation takes place, for the HiP and the area surrounding the Fuleni Anthracite Project (excluding the HiP) respectively.

337 | P a g e

Table 91: A summary of the results obtained from the assessment of visual impacts on the HIP Impact Construction Phase 1: Impact on landscape character and sense of place 2: Visual intrusion and VAC impacts 3: Visual exposure and visibility impacts 4: Impacts due to night time lighting Operational Phase 1: Impact on landscape character and sense of place 2: Visual intrusion and VAC impacts 3: Visual exposure and visibility impacts 4: Impacts due to night time lighting Closure and Decommissioning Phase 1: Impact on landscape character and sense of place 2: Visual intrusion and VAC impacts 3: Visual exposure and visibility impacts 4: Impacts due to night time lighting

Unmanaged

Managed

High High Very High Medium-High

Medium-High Medium-High Medium-High Medium-Low

Very High Very High Very High High

High High High Medium-Low

Medium-High Medium-High High Medium-High

Medium-Low Medium-High Medium-High Medium-Low

Table 92: A summary of the results obtained from the assessment of visual impacts on the region surrounding the Mining Footprint Area (excluding the HiP) Impact Construction Phase 1: Impact on landscape character and sense of place 2: Visual intrusion and VAC impacts 3: Visual exposure and visibility impacts 4: Impacts due to night time lighting Operational Phase 1: Impact on landscape character and sense of place 2: Visual intrusion and VAC impacts 3: Visual exposure and visibility impacts 4: Impacts due to night time lighting Closure and Decommissioning Phase 1: Impact on landscape character and sense of place 2: Visual intrusion and VAC impacts 3: Visual exposure and visibility impacts 4: Impacts due to night time lighting

Unmanaged

Managed

Medium-High Medium-High High Medium-High

Medium-Low Medium-High Medium-High Medium-Low

High High High Medium-High

Medium-High High Medium-High Medium-High

Medium-Low Medium-High Medium-High Medium-High

Medium-Low Medium-Low Medium-High Medium-High

4.11.3.6 Cumulative Impacts Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. Cumulative visual impacts resulting from landscape modifications as a result of the proposed project in conjunction with existing mining activity within the region (although limited to Somkhele Mine), is likely to be of some significance, even more so due to the fact that the proposed developments is placed largely within previously undisturbed areas. A mining project such as the Fuleni Anthracite Project, considering the proximity thereof to the HiP, will affect the way in which the landscape is experienced, both for residents living near the mining footprint area as well as for tourists and hikers within the HiP. The proposed project will be developed in phases, but 338 | P a g e

will cover a large footprint area. Cumulative visibility effects due to the combined effects of individual infrastructure components will therefore occur in different locations over a period of time and may cumulatively lead to an unacceptable level of visual impact. The cumulative impact of additional traffic will also occur and affect the sense of place of the MRA area and surrounds. 4.11.3.7 Residual Impacts It is possible that after all infrastructure have been removed from the mining footprint area, scarring of the terrain may remain present after closure. The possibility also exist that rehabilitation efforts, including revegetation of impacted areas may be unsuccessful, which will lead to a long term visual impact in the area, due to the size of the mining areas.

4.12 IMPACT ON THE HIP AND IMFOLOZI WILDERNESS AREA Cole (1990) and Roush (1995) noted that the ever increasing human population is the single greatest threat to wilderness areas, with human influences translating into varying levels of impacts. These impacts are dependent on the types of activities and the associated behaviour of these activities, as well as the frequency of the activities and the overall sensitivity of the receiving environment where these activities are occurring. Cryer (2009) and Cole (1990) described 2 categories of which human actions can affect wilderness:  

Impacts that hinder and disrupt the ecological integrity and functioning of the area; and Impacts that will affect and distort our human perception of what wilderness is meant to constitute.

4.12.1 DISTURBANCES AND IMPACTS TO WILDLIFE THROUGH MINING ASSOCIATED ACTIVITIES The construction and operation of the mine will result in an increase in ambient noise, from operational equipment, along with the issue of noise disturbance and seismic vibrations from general mine activities and blasting actions. In the Noise Impact Assessment it has noted that a large frontage of the Park will be exposed to noise that will be generated from the mine, resulting in a wedge of the Park’s land where the imposed noise levels from the mine will exceed desirable noise levels(Cosijn, 2014). Due to the proximity of the proposed mine to the HiP, it is considered likely that these activities will have an impact on the wildlife of the reserve. Animals rely on meaningful sounds for communication, navigation, avoiding danger and finding food against a background of noise (Federal Highway Administration, 2011). Here, noise can be defined as “any human sound that alters the behaviour of animals or interferes with their functioning” (Earthworks, 2014). The level of disturbance may be qualified as damage (harming health, reproduction, survivorship, habitat use, distribution, abundance or genetic distribution) or disturbance (causing a detectable change in behaviour). This introduction of new noise levels previously non-existent within the area and surrounds could have detrimental effects on the biodiversity and tourism of the surrounding areas, notably the HiP. At night when the natural ambient noises decrease, the noise produced from the mine will be increasingly noticeable. This introduction of unnatural ambient noise may interfere with vocal communication of some faunal species, interrupting or disturbing mating, location and territorial calls. This disturbance of communication may result in changes within species specific competition, and possibly 339 | P a g e

increased territorial conflict, as calls that may have previously deterred rivals are not being interpreted or received correctly. An increase in territorial defence could result in a decrease of breeding efficiency, as more time and energy has to be expended on territorial defence. The resultant increase in noise therefore could have a negative impact on species populations and the biodiversity of the wilderness areas located near the mine. Below are discussions pertaining to some of the species within the wilderness area that will possibly be affected by the noises and other impacts associated with the mine. 4.12.1.1 Elephants Elephants possess an extraordinary sense of hearing and emit infrasonic calls with overtones, of which they can both hear and determine the origin of the call. Most elephant communication is in the form of infrasonic rumbles, which may be heard by other elephants in herds at least 10.0 km away. These are used as calls of warning, greeting, rally, mating, food location, excitement, fear, etc. Infrasound is used by elephants as a long-distance communication system, which aids in keeping herds together in coordinated movements without losing contact or meeting with scarce resources. It also allows for males to locate fertile females in order to mate and for cows to keep track of their calves (Shepard, 2003). Ground Waves: As elephants send infrasonic calls to one another, a replica of the signal is sent as seismic waves, which are able to travel through the ground more than 1.5 times further than the infrasound in air (between 16.0 to 32.0 km) (Shepard, 2003). Vibrations in the earth may also be generated through stomping of the foot and flapping of the ears, both of which are used as defence mechanisms (mock charges). Ground vibrations may be used to greet or warn other herds, to locate mates or resources of water and food, or convey basic details about the location and moods of the herds, perhaps invoking anger or fear in other herds, of which many of these calls seem to be better received by the cows in the herd (Shepard, 2003). Elephants’ use of infrasound solves the questions attending the ability of males to find females for breeding, and the ability of separated family groups to coordinate their patterns of movement for weeks at a time without losing communication or converging on the same scarce resources (Shepard, 2003). Research has shown that elephants utilise the infrasonic sound medium, particularly through the ground, as a means of communication, sending warning signals and advertising of females when they are ready to mate (O'Connell-Rodwell, 2007; O'Connell-Rodwellet al., 2007; Wrege et al, 2010). Research on forest elephants that were exposed to exploration blasting by oil companies within central Africa showed that the elephants tended to avoid the areas under exploration, switched their behavioural patterns and became more nocturnally active(Wrege et al, 2010). The seismic detonations from the oil exploration elicited a limited response from the forest elephants. This switch of activity patterns and the apparent avoidance of open areas therefore could not be solely attributed to the blasting and ground vibrating of the oil exploration activities. The switch in behaviour at best could be conceived to be a culmination of the increased human presence as well as the blasting activities of the oil exploration. The increased human activities will be restricted to the study area and so will not encroach within the reserve. It must be noted though that the sound blasts, wave frequency and resultant seismic waves from the mining activities are likely to be of a much greater intensity, and could result in a stronger response from the elephant’s within the HiP wilderness area. It is likely that as a result the elephants will selectively avoid the areas of the reserve located near the mine (Dufour, 1980; Dr. Viljoen, J.Tshwane University of Technology, personal communication, 2014).

340 | P a g e

The mining and blasting activities associated with the mine will emit seismic signals through the ground and air which will be received by the elephants within the HiP (Cosijn, 2014, Zeeman, 2015). The air blast influences as a result of blasting even at a minimum charge per delay will impact upon the iMfolozi wilderness area, although it is considered that the blasts will not cause any direct mortality as the blast pressure in the iMfolozi wilderness area will be below dangerous levels (Zeeman, 2015). Various mines exist in South Africa and Botswana where game reserve areas are part of mine property. New Vaal Colliery has some small game and Debswana Orapa Diamond mine has a rather large area with various animals and specifically also rhino (Zeeman, 2015). No specific evidence exists of impacts upon animals on these reserves, however it is accepted that if these animals survive a certain habituation must occur (Zeeman, 2015). However it is still not completely certain how the elephants will respond to these seismic signals and blast noises; certainly as a foreign and unknown source it could cause a degree of disturbance, temporarily or long term. The mine’s seismic output, even if undeterring to the elephants, may result in a loss or disturbance in seismic communication between elephants themselves and between local herds, as these communication signals may be disrupted or eliminated completely when encountering the counter seismic waves that are being produced by the mine. Due to this disturbance, it is possible that the elephants will selectively avoid the areas of the HiP that are adjacent to the mine. This change in area utilisation of the elephants may place a higher ecological pressure on the remaining areas of the HiP, as the elephants will not utilise the whole reserve effectively. This may result in some areas being over-utilised, resulting in the possible revision of elephant and veld management plans, which could negatively affect elephant and other species populations within the HiP. 4.12.1.2 Vultures Birds are known to be sensitive to sound inputs into the environment, and are able to detect sound waves at levels that we as humans are unable to. It has been documented that during a test detonation of a nuclear bomb in France, pigeons found in the United States were disturbed by the resultant sound waves, which they could detect very well with their ability to hear infrasonic waves. If the infrasonic sound waves could cause a level of disturbance over this vast distance, it stands to reason that the vultures and other birds of prey within the wilderness area near the mine will likely also be impacted upon. The extent and severity of this impact is not yet fully known, however previous case studies on raptors that were exposed to sound disturbances showed that in some cases nest abandonment occurred. In other studies (BLM, 2006), noise disturbance resulted in a decrease in raptor nesting activity and productivity, as well as a decrease in species numbers in the areas near the noise disturbances (Earthworks, 2014; Federal Highway Administration, 2011). Nesting vultures are known to be sensitive to disturbances. Vultures nesting alongside roads that showed an increasing level of activity were seen to have an increased rate of nest desertion (Bridgeford and Bridgeford, 2003). EKZN raised concern regarding the impact that the mine will have on the current vulture populations and breeding site in the Comments to Fuleni Anthracite Project Draft Scoping Report. It has been noted that the HiP is considered to have a “high” nesting density of White-backed Vultures, an average nesting density of 24.4 nests/100 km² (Whateley, 1986). White-backed, White Headed and Lappet-faced Vultures are all known to utilise tall trees for nesting sites, with the White-backed Vulture often utilising tall trees within riparian habitats (Kemp and Kemp, 1975; Monadjem, 2001). With the current rate of land transformation throughout Southern Africa, more and more vultures have to rely on protected areas for breeding, as more and more there is a decrease in natural breeding habitat outside of protected areas (Whateley, 1986).

341 | P a g e

It is possible that the proposed mine and the associated noises (from blasting and mining activities) will have negative impacts on White-backed, White Headed and Lappet-faced Vultures that nest in relatively close proximity to the reserve boundary. These species are a conservation priority within the HiP and KwaZulu-Natal, and are listed as endangered and vulnerable by the National Environmental Management: Biodiversity Act (Act 10 of 2004). Noise disturbance as noted by Bridgeford and Bridgeford (2003) could result in the birds abandoning their nests and thereby compromising the breeding success of the vultures in the adjacent areas to the mine. Sensitivity to blasting needs to be considered for breeding vultures and known nesting sites need to be taken into consideration so that suitable buffers around these areas can be established in order to ensure that these sites are not impacted upon by blasting effects from the mine (Zeeman, 2015). As these species are priority conservation species, and part of the biodiversity aspect of the wilderness area, the loss of these species, notably the breeding sites, will negatively impact on the population numbers as well as detract from the wilderness areas biodiversity status. As a wilderness area, it is not acceptable to undergo species loss or decrease due to human impacts, as one of the aspects of a wilderness area is to provide a safe haven or refuge to species from anthropogenic impacts. If the wilderness area is unable to do this, it is not fulfilling one of the primary roles of a wilderness area. 4.12.1.3 Crocodiles The pans and river systems in the HiP host a number of Nile crocodile populations. A concern has been raised by the IEM (Integrated Environmental Management) EKZN section regarding the impact that the ground vibrations being transmitted from the mine will have a negative impact on these crocodile populations. In 1990, Crocodile Creek, a Nile crocodile breeding farm, had a mortality of 123 female crocodiles (80 – 218 cm in length) during the time of blasting operations while building the N2 highway approximately 2 km from the farm (Watson, 1990). Mortalities were attributed to increased stress levels which coincided with the time of the road construction. However, upon further investigation it is considered that other factors could have also had an influence on the crocodile mortalities, including an early winter, a virus as well as the fact that a large number of crocodiles from the group had been imported from Namibia not too long before the incident. Post mortem results indicated that the animals died from chronic stress, and had a multitude of recorded symptoms, including bite marks on the jaws and heads from intraspecific aggression, cessation of feeding, paralysis, deterioration of the quality of skin combined with septic lesions, loss of balance, and discolouration of the ventral scales, diarrhoea, and ultimately death. Although there was no specific evidence indicating a direct relationship between the deaths and blasting, it is possible that the blasting was a contributing factor. Blasting and ground vibrations are considered foreign and unknown to the species within the iMfolozi wilderness area at present, thus having no past exposure to these impacts it is likely that this will result in an increase in stress levels of the crocodiles. What is uncertain however is how they will react and how the mine will impact on their survival and breeding success. Consideration needs to be taken that the blasting from mine operational activities will have a higher intensity than the blasting from road construction, as in the case of Crocodile Creek. The higher intensity blasting could result in higher stress induced mortality rates amongst the crocodile populations that are in contact with the blast disturbances, and as such blasting mitigation measures as stated by Zeeman (2015) need to be considered and incorporated into the mining plans. From the available literature and taking into consideration the precautionary principal, no succinct connection between blasting, mortalities and breeding disturbances could be conclusively ascertained, resulting in the conclusion that mining in close proximity to crocodile populations is not recommended until further data indicating otherwise is available. 342 | P a g e

4.12.1.4 Dispersing and foraging carnivores Young male leopards and hyenas are known to disperse from their natal territories/ clans when they start to or just after they reach maturity (Holekamp and Smale, 1998; Fattebertet al., 2013). Often, these dispersing animals are still too young and immature to compete with the larger dominant males and as such, utilise the less ideal peripheral habitat areas as temporary refugia. The proposed mine is located within documented peripheral habitat area and is known to be used by these species, most likely for extended foraging as well as territorial and conflict avoidance. Wild dogs, which are known to have extensive home ranges and are not always restricted by fences, have also been seen from time to time in the footprint area and MRA area. The construction of the mine will invalidate large areas that are currently used as refugia for these young males and various other species, as well as for secondary foraging habitats. This may result in an increased human predator conflict scenario, in which the wildlife will invariable loose, or alternatively result in increased stress levels on territorial and dispersing males as conflict situations may increase due to the reduction of habitat previously used for dispersal and refuge. 4.12.1.5 Rhinos The HiP was the first designated protected area on the African continent established in 1895 to preventthe extinction of the Southern White Rhino (Ezemvelo KZN Wildlife, 2011). By the 1890s southern white rhinos had been hunted to near extinction and Hluhluwe-Imfolozi was their final refuge. In the 1950s, the park carried out the first aerial count of any species in the world and found 437 white rhinos remaining. The population was nurtured and grown and carefully distributed to other areas where they could breed to form new populations (Barbee, J. and Smith, D, 2014). Today, it is estimated that the worldwide Southern White Rhino population is around 20000 individuals. However, in light of the wilderness area and the mine, the Black Rhino must be brought into focus. It has been noted that the Black Rhinos have an increased breeding success rate within the wilderness area (Cryer, P, African Conservation Trust, personal communication, 2014). This can be attributed to the very low human presence and impact within the wilderness areas. The wilderness areas appear to provide a core population, from which animals disperse into the HiP. According to the IUCN the black rhino is listed as critically endangered, with the major threats facing it, from poaching to habitat limitations. Should the proposed Fuleni Anthracite Project be commissioned, it will increase the human impact on the wilderness areas, and in doing so, it is likely that the breeding rates of the black rhinos within the HiP will decrease. With the ever increasing poaching issue, which is discussed later in sections further below in the report, combined with the possible decrease in breeding rate, the population numbers within the HiP may start to decrease.

4.12.2 LIGHT AND DUST POLLUTION The proposed mine will result in an increase of ambient light within the surrounding areas, notably impacting on the HiP, as the proposed mine is to be active through the night. The increases in light willinvariably result in the attraction of a variety of insects, which could cause a shift in insect population numbers and demography within the study and surrounding areas. With the increased attraction of the insects, so there is likely to be an increase in insectivorous species, namely bats and other insectivorous animals. These species will likely encounter higher mortality risks as they come into greater contact with the mining infrastructureand activities. The introduced foreign light also threatens to affect a variety of faunal species, notably invertebrates that utilise the light of the moon and stars for guidance, as well as breeding cues. 343 | P a g e

The general operational activities of the mine, as well as blasting and increased vehicle traffic to and from the mine, is likely to result in a significant increase in dust pollution, including fine particles of coal dust from mining operations. These small airborne particles are known to have negative effects on humans inhabiting areas surrounding the mines, so a possible inference may be drawn that similar impacts could occur to the faunal species surrounding the mine, especially in the wilderness area. The degree to which this pollution will affect certain individual species is unknown, but it is possible that species will begin to avoid areas of higher pollution, notably those areas within the wilderness area that are located close to the overburden and product stockpiles. The dust pollution being blown into the wilderness area and light intrusion, especially at night, will impact upon the sense of wilderness and place that the individual experiences whilst in the wilderness area.

4.12.3 OTHER THREATS TO THE HIP AND IMFOLOZI WILDERNESS AREA 4.12.3.1 Run away fires Concern has been raised that due to the increase in human presence and activities, both mining and nonmining related, there will be a significant increase in the risk of run-away veld fires, both deliberate and accidental. These run-away fires will pose a direct threat to the HiP, which already falls under a fire management plan and protocol as designed and executed by the park ecologists. Any run-away fires that enter the park will have to be dealt with rapidly, a challenge in itself considering the remoteness and inaccessibility of the wilderness areas which form part of their character and management objectives. Unplanned burns within the wilderness area may result in unfavourable ecological conditions and disruptions of ecological processes, as well as the increased risk that alien vegetation may proliferate in these disturbed areas. However, it must be noted that if proper management principles are put into place by the mine, and strict no-fire regimes are practiced and enforced by the mine throughout the mining right area, it is possible that the mine may provide a buffer to the reserve with regard to run-away veld fires. 4.12.3.2 Wilderness status and experience Within South Africa, less than one percent of the land surface is proclaimed as a wilderness area. The primary objective of a wilderness area as stated by the IUCN is the long-term protection of ecological integrity of natural areas that are undisturbed by significant human activity. These areas must be free of modern infrastructure where natural forces and processes predominate, so that current and future generations have the opportunity to experience such areas. Wilderness has developed into a broad spectrum, not only factoring ecological integrity anymore, but also taking into account social and cultural aspects, providing modern man with an area to escape to, where he can experience life in its most simplistic form, where a sense of detachment from the world can be experienced. The HiP is a site of great cultural and historical significance, with Stone Age archaeological sites being present as well as San rock art paintings. More recently in history the HiP was known as King Shaka’s personal hunting preserve, with the proclaimed wilderness area providing modern man a sense of what it may have been like in those early days of history. Wilderness management differs from conventional reserve management, in that it incorporates an “ecocentric” management philosophy (Hendee and Dawson, 2002). The primary goal of wilderness management is to ensure that protection is provided to intact ecosystems whereby natural processes are allowed to happen free from human influence. This form of management aims to utilise management strategies that are aimed at benefiting society through maximizing natural conditions and processes 344 | P a g e

(Hendee and Dawson 2002). Wilderness areas thereby provide baseline of comparison for other designated reserves and natural areas as wilderness areas are considered to be in the most natural state possible with limited to no anthropogenic impacts that will invariably change the habitat and species composition of the area. In effect, true wilderness areas provide a benchmark for comparison for other natural areas and proclaimed reserves. Activities that occur adjacent to a wilderness area can have substantial impacts inside its boundaries, and vice versa so the designation of a wilderness area can substantially affect management of adjacent areas. In the case of the iMfolozi wilderness area, the development of the Fuleni Anthracite Project will have significant and long lasting impacts on the wilderness area itself, both from an environmental and social point of view. Much emphasis is placed on the “Wilderness experience” that is provided to a visitor of a wilderness area. Early insights into the wilderness experience arose from the need to understand why people visited wilderness. What has been found is that not all motives are shared by individuals (Cole, 2011), as an individual’s frame of reference will always determine the outcome of your perception. Roggenbuck and Driver (2000) suggest that whilst there are common motives for visiting wilderness (solitude and experiencing nature), not all these motives are shared and different individuals will have different motives for visiting wilderness. As each person is an individual with their own perceptions and background knowledge, so the experiences sought will vary among people, with little evidence showing that these experiences sought can only be realised within a wilderness setting (Stankey and Schreyer, 1987). Since the 1960’s, there has been a shift away from motives towards a greater focus on the thoughts, emotions and physical feelings that arise as a result of being within wilderness (Cole, 2011). What is evident is that all people accrue positive influences and experiences with scenery, natural features and the feelings of peace, quiet and the sense of escape (Hall et al. 2007). Wilderness experience has been labelled as the overarching umbrella under which naturalness, primitiveness, remoteness, solitude and freedom from confinement all fall. Wilderness and definitions thereof focus on the physical features that are present within a wilderness area, whilst wilderness experience describes the feelings and thoughts people may experience within these environments (Cole 2005). The wilderness experience (what people may feel, perceive or think whilst in wilderness) involves but is not limited to an appreciation of the natural environment, the opportunity to explore and live in a “primitive” way in an undisturbed environment where a person has a freedom from rules, regulations and the pressure of daily activities associated with modern society. Kay (2000) and Borrie & Roggenbuck (2001) also noted other elements that are involved within the wilderness experience, including the opportunities to learn about the natural environment, sensory awareness, spiritual development, development of an ethic of care and responsibility as well as a general enjoyment and appreciation of the aesthetic appeal of wilderness. Cole (2005) noted that visitors focused extensively on both the natural as well as social influences when it came to the wilderness experience. Environmental features such as water and animals contributed to a sense of wilderness, as did the lack of any developments. Importantly, Cole (2005) noted that the lack of development had a much higher impact on a person’s wilderness experience when compared to micro-scale recreational impacts (footpaths, signs of previous campsite/ trailists). One of the defining factors of wilderness that visitors experience is the sense of remoteness. Remoteness does not necessarily need to be directly linked to environmental conditions; instead a sense of remoteness is usually judged on perceived distances travelled and importantly the perceived distance from “civilisation” (Cole 2005). The presence of the Fuleni Anthracite Project may detract from this sense of remoteness as trailists will not experience a sense of removal or escapism from present day society and its pressures, thereby impacting and diminishing the wilderness experience. 345 | P a g e

The iMfolozi wilderness area is divided into various zones, according to the class of wilderness each zone falls within. The zones that will most likely be affected by the proposed Fuleni Anthracite Project are the primitive, semi-primitive and pristine wilderness zones. The semi-primitive zone borders the fence line where the proposed mine is to be located, and is described as an un-modified area usually on the periphery of the wilderness area. The area will commonly have views which will include human habitation outside of the reserve. The pristine and primitive wilderness zones fall in the visual impact area of the mine’s influence. In terms of the primitive wilderness area, human habitation is deemed to be visible only as a seldom occurrence; however the development of the mine will change this, and may result in sections of the primitive wilderness areas being reclassified as semi-primitive wilderness. The pristine zones will also be affected on a visual basis by the mine, and as such will also be faced with reclassification into primitive and even semi-primitive wilderness zones. These reclassifications will be detrimental to the wilderness area as a whole, as well as to tourism and the sense of place that the pristine wilderness areas provide. In light of these listed above, from a biodiversity, tourism and visual (SAS Visual Impact, 2015) point of view, the Fuleni Anthracite Project will likely result in the downgrading of the wilderness zones, notably the pristine and primitive zones, as they will no longer fulfil the requirements for those designations. A worst case scenario would be the complete de-designation of the HiP’s wilderness status as a direct result of the mine’s presence and subsequent impacts. The de-designation of the wilderness areas will mean the loss of the first and oldest wilderness area in Africa, notwithstanding the potential long term impacts on endangered species located within the wilderness areas (eg. Black Rhinos). It must be noted here that the two current mines in close proximity to the HiP, but not directly adjacent to the wilderness, which are located outside of the 5km guideline buffer can still be heard within the Park's boundaries, particularly at night (Ezemvelo KwaZulu-Natal Planning Division, IEM Section, 2014). The presence and disturbance of these mines are a contributing factor to the semi-primitive zonation of the habitat that is located along the borders of the HiP. Furthermore, the presence of the Fuleni Anthracite Project will through noise, light and visual (SAS Visual Impact, 2015) cues detract from the wilderness experience of trailists within the wilderness area. Gomez (2001) found that a large percentage of hikers/ trailists utilising different trails within Glacier National Park noted non-natural sounds and elements as a detracting element of their wilderness experience. Even though noise levels from mining activities may be kept to a minimum and within acceptable levels in terms of species disturbance and noise management, any non-natural noise that pervades into the wilderness area, regardless of the level, is likely to result in a decrease of the individuals overall wilderness experience. 4.12.3.3 Tourism Many people each year partake in the wilderness experience offered by the wilderness trails that run through the iMfolozi wilderness area. One of the main characteristics of these trails is to allow people to experiencea sense of what a primitive life is like, with no connection to the surrounding world, away from the mechanics of modern society. This experience will be lost, or at least, impacted upon due to the noise and light pollution of the proposed mine. No longer will the wilderness trails be able to offer a temporary escape from modern society, as the mine will provide a constant reminder of the ever expanding human presence. The mine will have a direct impact on the sense of place one experiences when in the wilderness areas, with a constant reminder that humans and the modern world are not far away, which is one of the key reasons behind declaring wilderness areas. It has been said by Dr. Ian Player that “the wilderness experience allows a person to heal themselves, their body, minds and souls through experiences they receive on a personal and individual level whilst in the wilderness areas”. 346 | P a g e

The development of the mine will almost certainly detract from these experiences, detract from the wilderness experience as a whole, and remove from society the chance of escapism and solitude that so many seek. With 50 years and 40000 people having completed the wilderness trails, it is definitely a point to take note of. The tourism draw of the wilderness area is fairly substantial, and the economic spin-offs from such reach not just the reserve but the local communities as well. The development of the mine will without a doubt impact on the trailists’ wilderness experience, and the likelihood of that person returning to HiP again, and new bookings may possibly decrease. 4.12.3.4 Security concerns and poaching With the development of the mine comes a marked increase of human presence. This increase places an increased security risk on the reserve, as poachers, both subsistence and commercial, will have easier access through the new road network, but are also easier hidden in the increased humanity. The southern border of the HiP area will have a greater exposure to people in the area, through greater access, more eyes looking in as well as newly developed vantage/ scouting points through the development of the overburden dumps. The HiP section has limited access within the reserve, owing to its wilderness status, so responding or increasing of patrols in these areas to counteract the possible increased poaching risk is both costly and unfeasible.If the previously mentioned patrols are to be increased, consideration needs to be given to the fact that this may entail an increase in vehicle traffic along the wilderness boundaries, which will further detract from the wilderness experience of the area.It must be noted that besides the possible increased poaching risk to priority species within the HiP, there is also the risk that poaching for the pot will increase in order to fulfil demands from the increased community numbers associated with mines. This form of subsistence poaching will likely come in the form of snare trapping for small to medium antelope species. These snares are made from crude wire nooses and are designed to constrict around the limb or neck of the animal. Although the target species will be that of small to medium antelope, these snares are often found around the necks and limbs of a number of species. Larger species and predators often break the snare off from wherever it is attached; with the snare remaining wrapped around the body part long afterwards. These snares often cause extensive damage to the animal, often resulting in death. The increased ambient light and sound from the mine, including the blasting noises, may serve to help mask the movements of poachers within the reserve, making it increasingly harder for anti-poaching units to detect the threat within the reserve. In order to try combat the perceived increase in poaching activities, it is suggestable that the mine look at increasing security patrols along the border where the MRA meets the HiP, should the project proceed to construction and operation. Furthermore, it is suggested that strict disciplinary actions be put into place by the mine with regards to poaching of any kind, and that vehicle and people movement be limited along the border of the HiP, with the exception of necessary personnel and security forces.

4.13 CULTURAL AND HERITAGE RESOURCES At present it is believed that the most significant heritage resources potentially affected by the proposed project are likely to be the following:    

Places associated with oral traditions and living heritage; Landscapes and natural features; Traditional burial places; and Archaeological sites. 347 | P a g e

It is unlikely that structures or buildings older than 60 years (other than those older than 100 years, which then constitute archaeological sites) are present in the proposed development area. Other than places associated with oral traditions and living heritage, as described above, it is possible and indeed likely that individual trees/medicinal plants are present. These are not strictly considered heritage resources in terms of heritage legislation, but in projects such as these are usually identified in the Social and/or Botanical/Biodiversity Impact Assessments, which provide recommendations for mitigation. It is unlikely that a palaeontological study of any nature will be necessary for this project, since coal-bearing strata are typically devoid of fossiliferous material. However, we will ascertain the requirements of Amafa in this regard. However, there are potential fatal flaws regarding landscapes and natural features and traditional burial places associated with this project. 





The HiP has high heritage significance at all levels for its historical, aesthetic, scientific, social/cultural/spiritual, educational and economic (including tourism) values. Potential impacts of mining on the park are likely to be indirect, including visual and noise pollution, and direct, by preventing its expansion beyond its current boundaries. These impacts would affect its overall heritage significance negatively for the duration of construction and operation of the mine and beyond, including its potential benefits to neighbouring communities. The Mfolozi River, which is the prime water source for the lake system within the iSimangaliso Wetland Park World Heritage Site, has medium-high to high heritage significance at all levels for its historical, aesthetic, scientific, social/cultural/spiritual, educational and economic (including tourism) values. Potential impacts of mining on the river are likely to be direct and indirect and could affect its overall heritage significance negatively for the duration of construction and operation of the mine and beyond, including its potential threat to the significance and viability of the iSimangaliso World Heritage Site. A large number of homesteads could be affected directly and indirectly by the proposed mining, including resettlement of families and their traditional burial places. Potential impacts on traditional burial places range from indirect (next-of-kin cannot access graves during mining activities for health and safety reasons) to direct alteration or destruction, or relocation. All human remains have high heritage significance at all levels due to their spiritual, social and cultural values and may not be altered in any way without the permission of the next-of-kin and a permit from Amafa aKwaZulu-Natali, the Provincial Heritage Resources Authority. It is always preferable to manage traditional burial places in situ, since relocation of graves has significant spiritual, emotional, financial and time implications.

A full Phase 1 HIA should be undertaken for this project and the report submitted to Amafa in fulfillment of the requirements of the NHRA.

4.14 SOCIO- ECONOMIC ASPECTS Environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably. Therefore social impacts have been defined as per Vanclay (2002: 190) as: “Social impacts includes all social and cultural consequences to human populations of any public or private actions that alter the ways in which people live, work, play, relate to one another, organise to meet their needs, and generally cope as members of society”. 348 | P a g e

A detail Social Impact Assessment (SIA) was conducted by Naledi Development and is not repeated here. Below a summary of the SIA – the reader is referred to ANNEX-12 for the full report.

4.14.1 BACKGROUND The SIA has been conducted taking the following into consideration:            

International Standards National and Provincial legislation and policies Provincial and Regional Development Plans Municipal and Community Profiles Public Participation and issues raised by affected parties Observations and field visits / surveys Study zone delineation and Social Mapping Anticipated social Impacts Human Right Risks Cumulative Impacts Mitigation measures, its efficiency and management strategies Monitoring programmes

The Provincial and District Spatial Development frameworks have identified the project area, as an area that requires social and economic intervention due to the poverty in the area. This is evident from the socio-economic profiles. The affected area and communities (Novunula, Ocilwane, Ntuthunga 1, Ntuthunga 2, Emakhwezini and Fuyeni have a population of approximately 12,600 people (close to 1600 households) which is about 10% of the municipal population. There are about 7-8 members per household, with gender evenly split between male and female. The age profile of household heads are mainly over the age of 40, with a small percentage (3%) households heads younger than 20 years, these are seen as a vulnerable group in the project area. HIV/AIDS within the municipal area is also quite high with 12% of the population incidence level. Although most of the community is literate, the education levels are not very high with only a small number of the population advancing into tertiary studies. The community is seen as very poor with an average household monthly income between R1600 – R3200 per household and an unemployment rate of 66%. Most households practise subsistence livelihoods through either the involvement in small business such as spaza shops, vegetable farming, crop production or the keeping of livestock. Households also collect natural resources such as medicinal plants and firewood, and some (less than 10%) also hunt in the project area. Communities bury their loved ones in community graveyards located outside the village with some households still burying within their yards. There are also places of worship within the communities where their religion is practiced with the most common being the Nazareth Baptist Church. Services are provided by the uThungulu District and Mfolozi Local Municipalities with some facilities/services provided by Provincial Departments (Roads, Health Services and Educational Services). The project area is serviced by the provincial Road P425, and several other secondary provincial roads that

349 | P a g e

link communities to the P425. Education facilities that are located within the area include two secondary schools and six primary schools. The area is further serviced by the Ocilwane Clinic and mobile clinics. The communities have water supply from a source external to the project area, and the majority of the households have water via communal taps or taps at their yards. There are still some households that fetch water from surface water resources. Sanitation levels are average in the area, 60% of households have Ventilated Improved Pit Latrines (current Government standard). Close to 90% of the households have access to electricity services.

4.14.2 IMPACTS AND MITIGATION Community and other neighbouring activities will be affected by the development of the Fuleni Anthracite Project. The impacts have been divided into impacts on:   

Social Capital Human Capital Productive Capital

The main impacts identified and assessed as medium to high pre-mitigation are summarise in Table 93. Table 93: Social impacts associated with Fuleni Anthracite Project Impact SOCIAL CAPITAL Population and Demographic Change  Influx of job seekers with associated secondary impacts

Proposed Mitigation  



  

 Change/disruption of power relationships  Increased internal inequalities within communities between those who benefit directly from the mine and those who do not  Competition for power of direction and decision-making between Traditional Authorities and Community Leaders  Competition for power over benefit allocation amongst Mhlana Traditional communities and with neighbouring Traditional areas



   



Development and Implementation of an Influx and Land use Management Plan Priority employment from local communities with the development of recruitment procedures and utilizing the existing skills database compiled from the local communities Establishing early on skills development programmes in areas where most employment opportunities will be available such as operators and artisans Implementation of bursary programme and practical skills programmes as part of the Social and Labour Plan Establishment of a local labour recruitment committee to monitor recruitment procedures and results Engage with Traditional Authority to manage and monitor site allocation to job seekers and/or employees in the local communities Induction of contractors and workforce with regard to their code of conduct in the local communities Broad based engagement and participation in the process and activities that will influence Traditional Authorities and local communities Equal distribution of benefits amongst affected communities Consistent application of compensation rates to all Project Affected Households/Persons Internal capacitation of staff / resources utilised to engage and operate in the area (Internal Induction) External capacitation of community leadership structures to empower existing structures on the consequences and benefits of mining development, pre-construction and throughout operations Preference to relocation host options within the same villages

350 | P a g e

Impact Disruption in daily living and movement patterns  Increase traffic numbers caused by transport and/or traffic of employees from their place of residence to their place of work.

Dissimilarity in Social Practices and Disruption of Social Networks  Disruption of Social Networks and increase in developmental diseases.

Resettlement or displacement of individuals or families  Displacement of 124 households premitigation residing in Ocilwane, Ntuthunga 1 and Patane villages

Impact Equity  Increase unequal access to opportunities or resources

Perceptions of and Feelings in relation to the project  Establishment of conflict between the developer and the local communities  Objection against the development

Change in Cultural Practices  Displacement of 248 graves premitigationlocated in Ocilwane, Ntuthunga 1 and Patane villages

HUMAN CAPITAL Participation of Local Communities in Employment Opportunities and Skills Development (Positive)

Proposed Mitigation and traditional authority areas  Traffic minimized through bus and combi services to transport workers to the project site  Low speed limits on access roads with public drop-off / pick-up areas as to not disrupt the flow of traffic  Road crossings should be managed by signing and traffic management measures  Issues and Grievance Procedure available to local people to report bad driving or rules traversing  Employment of local people on the mine to improve the poverty levels in the host and neighbouring communities  Code of Conduct to form part of induction of new workers with a clear statement and procedure regarding access, conduct and identification. All workers should wear clothing marked (and reflective vests) with the logo of the construction firm/contractor or sub-contractor as well as identification cards that cannot be easily forged, so that they can be easily recognized as being legitimate.  Grievance Procedure within the local communities  Application of the Avoidance Principle by reducing the footprints of Open Pit 1, 2 & 6 (see maps in paragraph 7) (reduced resettlement to 86)  Application of the Avoidance Principle by realigning access road  Resettlement of structures that cannot be avoided in terms of the resettlement strategy  Benefits must be ploughed back into the community. Participation in Regional Forums can assist in ways whereby the company can assist recipients, and  Employment should be prioritized to local communities  Local beneficiation programmes to be implemented as part of the Social and Labour Plan  Establish ongoing Consultative Forums with concerned groups to air concerns, find possible mitigation measures for their perceived impacts and monitor implementation and effectiveness of mitigation measures  Continuous communication with all stakeholders providing information on anticipated impacts and planned mitigation measures  Application of the Avoidance Principle by reducing the footprints of Open Pit 1, 2 & 6 (see maps in paragraph 7) – reduced impact to 172 graves  Application of the Avoidance Principle by realigning access road  Resettlement of graves that cannot be avoided in terms of the resettlement strategy  

 

Source the maximum number of employees from the local area for temporary job opportunities Implement skills development programmes in the areas where most job opportunities will be created, i.e. operators and drivers Make available bursary opportunities to build skill capital in the region Establish a database of local people with information on

351 | P a g e

Impact

Equity Participation of the Local Communities (Positive) Participation of local business in procurement opportunities

Health Impacts  Increase in health incidents related to air pollution  Increases of Developmental diseases

Noise impacts  Increased noise levels in the local communities  Increased noise levels near educational facilities that may affect education Safety impacts  Increase in Crime  Increase in social pathologies such as alcohol abuse, prostitution and vandalism  Increase in theft, burglary, armed robbery, assault and even murder  Increase in poaching in the neighbouring conservation areas

Proposed Mitigation qualifications and skills, utilize this database to develop skills plans and recruit local people.  Implement portable skills development programmes  Design and implement economic development programmes that will assist people being retrenched in sustaining their livelihoods  Establish a future forum with representation from the workforce to discuss potential difficulties and solutions  Implementation of programmes to minimize and mitigate the impact of downscaling and retrenchment  Development of strict guidelines in terms of representation and utilisation of equity funding  Consultation and Feedback on results on a regular basis  Establish a database of local businesses, utilize this database to establish partnerships between local and larger service providers as well as locally preferred work packages  Consultation and Feedback on results on a regular basis  Implementation of capacity building programmes to minimize and mitigate the impact of mine downscaling and closure.  Closure plan implementation  Mitigation measures to minimize air pollution  Air quality and health monitoring systems to be implemented  Communication Strategy to keep community informed of air quality risks and mitigation measures  Health awareness programmes with workers and communities to educate on sexually transmitted diseases and HIV/AIDS and other illnesses such as TB and Malaria  Provision of preventative measures (including condoms)  Collaboration with local health practitioners Ocilwane clinic, health committees and home-based care organisations  Ensure noise levels post mitigation at night is below 40 dB  Ensure noise levels post mitigation during the day is below 50dB  If the noise levels cannot be mitigated below these levels, an assessment of the housing within the community that may be impacted must be conducted.  Cooperation, Participation and support to the anti-poaching initiatives in the area.  Increased security measures (fencing, access control and monitoring) on mine premises. Properly constructed and secured fences can control access to mine sites. Implementing strict access control of the project site and specifically the contractors workforce camp. Curfew times to be established in accommodation areas. Construction workers accommodated on mine are identified and marked with clear identifiable clothing  Code of Conduct to form part of induction of new workers with a clear statement and procedure regarding access, conduct and identification. All workers should wear clothing marked (and reflective vests) with the logo of the construction firm/contractor or sub-contractor as well as identification cards that cannot be easily forged, so that they can be easily recognized as being legitimate.  Workers to be screened including criminal background checks.  Employment of local people on the mine to improve the

352 | P a g e

Impact

Safety impacts  Infrastructure & Operational safety  Increased road accidents due to increased traffic volumes

Change in sense of place and change in tourism activities due to  Increase nuisance effect due to increased levels of dust and noise  Increase in traffic with a disruptive effect  Visual intrusion of mining infrastructure

PRODUCTIVE CAPITAL Change in community infrastructure  Impact on 3 community schools premitigation in Ocilwane and Ntuthunga 1

Proposed Mitigation poverty levels in the host and neighbouring communities  Workers should be urged to recognize and report suspicious activity and signs of burglary and be informed of crime prevention measures that they themselves can take.  Ibutho Coal to participate and support existing community policing forums and project security to properly secure the project area and surrounding area  Implement downscaling and retrenchment strategies  Implement portable skills development programmes  Design and implement economic development programmes that will assist people being retrenched in sustaining their livelihoods  Conduct regular full risk assessment and have procedures in place to deal with emergency incidents  Make available a complaint and grievance mechanism where people can lodge any complaint or raise issues regarding damages to their property due to risk and safety exposure  Involve local emergency services to support on mine emergency procedures  Establish on site emergency equipment and appoint safety staff  Continuous communication with all stakeholders providing information on anticipated impacts and planned mitigation measures  Establish ongoing Consultative Forums with concerned groups to air concerns, refine mitigation measures for their perceived impacts and monitor implementation and effectiveness of mitigation measures  Implementation of traffic management measures  Implementation of insulation and mitigation measures for noise  Implementation of visual barriers and other mitigation measures as recommended in the visual study  Implementation of particle and dust suppression methods  Colour schemes must complement the local environment.  Minimising disturbance to vegetated areas outside the critical development areas where possible  Revegetation/rehabilitation of disturbed sites in parallel with development  Rehabilitation and Reclamation of affected areas 

 Change in Community services  Increased pressure on current services to accommodate growth



  

Application of the Avoidance Principle by reducing the footprints of Open Pit 1, 2 & 6 (see maps in paragraph 7) – reduce impact so that no schools need to be relocated Resettlement education facilities that cannot be avoided in terms of the resettlement strategy Establishment of a construction accommodation camp to house those employees that cannot be sourced from the local community due to a lack of skills Linkages with skills development programmes to optimize skills levels in local communities Source majority of the Level B construction employees from the local community Continuous assessment and monitoring of infrastructure and services capacity in focal points (assessment every 5 years)

353 | P a g e

Impact

Change in housing needs/demands  Increased pressure on formal towns to supply housing  Increase occurrence of informal housing in the local communities

Change in access to resources that sustain livelihoods  Loss of grazing land  Loss of arable land (25 households)  Loss of vegetable gardens  Loss of access to medicinal plants  Loss of access to firewood  Loss of livestock drinking dam (1)

Proposed Mitigation  Determine scale of assistance required at focal points and enter into an agreement with the municipality  Participate in regional development planning forums of the municipality to continuously assess and monitor capacity, determine assistance required  Linkages with skills development programmes to optimize skills levels in local communities  Source majority of the Level B construction employees from the local community  Provision of construction accommodation on site  Discussions, agreements and procedures within the host and neighbouring communities to manage site / stand allocation to new residents / parties and village development plans within the villages to limit informal / squatting  Monthly engagement with Traditional Authorities to manage and monitor influx and housing / site allocations  Facilitation of housing development for external workforce  Link-up with planned housing developments and private developers to unlock possible development to supply the projected demand  Subsidy programmes to employees to access housing  Participate in Regional Structures to plan for anticipated impacts, starting during the Construction Phase to ensure planning is done in advance  Demarcated areas where fire wood can be collected that was cleared for the Construction Phase  Establishment of medicinal plant nursery  Provision of alternative grazing land  Leasing of community land impacted by mining  Monitoring the impact on livestock  Fair compensation negotiated and agreed with households that will lose access to agricultural land or vegetable gardens  Continuous consultation with Conservation bodies discussing co-existence and mitigation measures  Implement a consultation programme with regional stakeholders in the development of a closure plan and rehabilitation programme  Determine the regional needs and characteristics to ensure post mining use of land enhances the regional characteristics

4.14.3 SOCIAL MANAGEMENT STRATEGIES In combination with the mitigation measures listed in Section 4.14.2, the implementation of Social Management Strategies will assist in the management of social impacts. The following strategies are proposed:   

Communication and Consultation Plan: Ensuring continuous engagement with project affected parties and stakeholders. Issue and Grievance Management Strategy: To ensure the appropriate management of issues and grievances. Influx Management Strategy: To manage the influx of job seekers 354 | P a g e





 



 

Resettlement, Compensation and Mitigation Strategy: to compensate and mitigate for direct and indirect project impacts resulting either a physical or economical loss (attached as a separate document). Employment Strategy o Recruitment Strategy: to maximise employment opportunities for the local communities and reduce the influx of a foreign labour force whilst ensuring an effective construction and operational process. o Skills Audit: to capture all project relevant skills in the project area with the aim to enhance local employment figures. o Recruitment Manual: to include a list of employment opportunities that will become available during the project planning, construction and operational phases and provide guidelines on procedures to be followed by aspiring employment seekers and employers. o Employment Information Desk: to establish an employment information desk to assist with the day to day management of project related labour issues. o Human Resource Development and Training Strategy: to identify appropriate training and skills transfer opportunities that will enhance the skills level of the local labour force both during and after project implementation. Procurement Policy: to ensure that local business outfits, especially those of HDIs, women and SMMEs get allocated a fair business share of project related business opportunities. Community Institutional and Economic Enhancement Strategy: to ensure involvement, participation and ownership in project related processes, during the planning, implementation and operations and maintenance phases of the project. Housing and Infrastructure Policy: to ensure that project related housing and service delivery are designed and implemented such that it stands to alleviate local housing and service delivery stumbling blocks in the longer-term. Education Strategy: to ensure that probable impacts on project area educational facilities are manageable and design applicable mitigation measures where applicable. Health Strategy o Occupational Health and Safety Strategy: to ensure that during the project construction process and the operational phase of the project, employees receive adequate health support from the project team for work-related health problems. o Community Health and Welfare Strategy: to ensure that the project intervention will not have a negative impact on the health and welfare infrastructure in the project area, and to suggest appropriate measures to enhance the capacity of existing health infrastructure. o Traffic Safety and Awareness Strategy: to ensure that appropriate traffic management measures are planned and employed, in anticipation of the the major increase in both heavy and light vehicle traffic. o Community Safety and Security Strategy: to ensure that the project areas as well as the impacted communities are protected adequately through the formal policing system as well as additional safety measures such as additional security at the project sites and community policing in the project area. o Anti-poaching Collaboration Strategy: to effectively collaborate with stakeholders to determine and minimize any contributing factor the mine development has on poaching activities.

355 | P a g e





Archaeological and Heritage Strategy: to ensure that archaeological and heritage resources are managed in accordance with relevant legislation and in consultation with all relevant interested and affected parties. Social Monitoring and Evaluation Strategy: to ensure that the project intervention process is monitored with the aim of implementing corrective measures if and when required.

Please refer to the Social Impact Assessment for further details on the proposed strategies.

4.14.4 CONCLUSIONS The Fuleni Anthracite Project has the potential to significantly enhance the standard of living of those directlyaffected as well as of the population in the Mfolozi Local Municipal area in terms ofemployment, skills development, creation of small businesses and socialdevelopment. These impacts are particularly important in an area where poverty is endemicand employment opportunities are few. Expectations of job opportunities and developmentprojects are high amongst local residents. It is very important to develop a strategy of equitable distribution ofjob opportunities and benefits amongst the affected parties. The skills base in the area is low. In order to optimise local employment opportunities skills development will be necessary.Particular attention will need to be given to women and the youth. The project will cause negative impacts which need to be managed. An influx of job seekers to the area potentially leading to prostitution and HIV/AIDS, increasesin crime, prices of goods and services increasing, increased stress on local social servicesand land use are impacts that are particularly difficult to manage, because theProject does not have direct control over these and will need to work in collaboration withother stakeholders to minimize the impacts, realizing that full mitigation is not possible. Potential loss of livelihoods and other assets also needs to be considered. Although the Project is committed to minimize resettlement, land, which is the most important asset of localresidents, will be affected. A fair and transparent Resettlement Action Plan and Stakeholder Engagement Plan will be critical to mitigate the loss of assets and livelihoods. The objective of the project should be to establish and manage a balance between the benefits created and the mitigation, management and compensation for losses of the Fuleni Anthracite Project. If authorities, in reviewing the report, make an affirmative decision, continuous management, monitoring and evaluation of social impacts must be implemented to ensure the effectiveness of the mitigation measures and management strategies.

356 | P a g e

4.15 CUMULATIVE IMPACTS According to the Department of Environmental Affairs and tourism (DEAT), 2004,Cumulative effects can be defined as the total impact that a series of developments, either present, past or future, will have on the environment within a specific region over a specific period of time. According to DEAT, impacts occur when thresholds are passed or when interaction is antagonistic. Planning to address cumulative effects involves delineating spatial and temporal boundaries, determining future development and determining the significance of cumulative impacts. Cumulative effects are commonly understood as the impacts which combine from different projects and which result in significant change, which is larger than the sum of all the impacts. Cumulative effects can be characterized according to the pathway it follows. One pathway could be the persistent additions from one process. Another pathway could be the compounding effect from one or more processes. Cumulative effects can therefore occur when impacts are:    

additive (incremental); interactive; sequential; or synergistic.

Cumulative impacts can occur over different temporaland spatial scales by interacting, combining andcompounding so that the overall effect often exceeds the simple sum of previous effects. For the purposes of this study, aspects highlighted in the table below formed the focus of this cumulative assessment, while the ones not highlighted were considered to be beyond the scope of this study. Principles of cumulative effects assessment (adapted from the Council on Environmental Quality, 1997) (DEAT 2004) Cumulative effects are caused by the aggregate of past, present, and reasonably foreseeable future actions. The effects of a proposed action on a given resource include the present and future effects added to the effects that have taken place in the past.If an environment is already degraded the effects of new plans or programmes on this environment may be more serious. Consideration of quality of the environment before the project, plan or programme is implemented is vital to predict what the quality of the environment will be after the project plan or programme is implemented. Cumulative effects are the total effects, including both direct and indirect effects, on a given resource, ecosystem, and human community of all actions taken, no matter who has taken the action. For cumulative effects from disparate activities may add up to or interact to cause additional effects not apparent when looking at the individual effects one at a time. The practicalities of this are complicated in terms of whose responsibility the assessment is. It is not practical to analyse the cumulative effects of an action on every environmental receptor, the list of environmental effects must focus on those that are truly meaningful. For cumulative effects analysis to help the decision-maker and inform interested parties, it must be limited to effects that can be evaluated meaningfully. Boundaries must be set so analysts are not attempting to measure effects on everything. The significant effects of the action should be chosen through careful scoping. Cumulative effects on a given resource, ecosystem, and human community are rarely aligned with political or administrative boundaries. Cumulative effects analysis on natural systems must use natural ecological boundaries and analysis of human communities must use actual socio-cultural boundaries to ensure all effects are included. Analysis of effect cannot stop at an administrative boundary. However, this causes problems with mitigation and monitoring of effects if the plan/programme makers have no jurisdiction to implement mitigation outside of their administrative area. Cumulative effects may result from the accumulation of similar effects or the synergistic interaction of different effects. Repeated actions may cause effects to build up through simple addition (more and more of the same type of effects), and the same or different actions may produce effects that interact to produce cumulative effects greater than the sum of the effects. Cumulative effects may last for years beyond the life of the action that caused the effects. Some actions cause damage lasting far longer than the life of the action itself (e.g., acid mine drainage, radioactive waste contamination, species extinction). Cumulative effects analysis needs to apply the best science and forecasting techniques to assess potential catastrophic consequences in the future. Each affected resource, ecosystem, and human community must be analysed in terms of its capacity to accommodate additional effects, based on this own time and space parameters. Analysis tend to think in terms of how the resource, ecosystem, and human community will be modified given the actions development needs. The most effective cumulative effects analysis focuses on what is needed to ensure long-term productivity or sustainability of the resource.

357 | P a g e

According to DEAT (2004), cumulative impact assessment is only possible as long as the objectives are modest, thescience robust and defendable and uncertainty levels specified. The information provided in this section has been compiled while using the best available information and methods to achieve these goals and thereby provide information for informed analyses of the cumulative extent of impacts from the project. All specialist studies undertaken during the environmental and socio-cultural impact assessment for which a spatial attribute can be considered were compiled into a database. The table below presents the data utilisedin the generation of the cumulative impact mapping. Table 94: Data sets and information considered during cumulative impact assessment Map Socio-cultural cumulative impact assessmentmap

Sensitive receptors Houses, schools, clinics; Boreholes; Graveyards and other heritage features; Somopho Nature Reserve; and Potential Lodges

Wilderness resources and HiP cumulative impact assessmentmap

The HiP; and Wilderness areas including the different classifications of various areas of wilderness within the HiP

Biophysical resources cumulative impact assessmentmap

HiP Ecological sensitivity including: Floral resources; Faunal resources; and Wetland and riverine resources; Surface water quality sensitivity (with mitigation); Surface water quantity sensitivity (with mitigation); Groundwater resources; Somopho nature reserve; Potential Lodges; and High potential and sensitive soils. Houses, schools, clinics Boreholes Graveyards

Cumulative zone of influence requiring relocation of the local community (Health and Safety)

Impact data sets considered Mining footprint Supply Dam & breakage floodline Blasting and vibration impacts Groundwater drawdown and pollution plumes Air quality (with mitigation) Noise (with mitigation) Visual Mining footprint Blasting and vibration impacts Groundwater drawdown and pollution plumes Air quality impacts (with mitigation) Noise impacts (with mitigation) Visual impacts Mining footprint Blasting and vibration impacts Air quality impacts (with mitigation) Noise impacts (with mitigation)

Mining footprint Supply Dam & breakage floodline Blasting and vibration impacts Air quality (with mitigation) Noise (with mitigation)

Each specialist was instructed to supply spatial sensitivity data for GIS analyses. All specialists were instructed to define all zones of impact as high, medium or low sensitivity zones. This data was then used in the development of the sensitivity database. The detail methodology used is described in the Cumulative Sensitivity Analysis report (ANNEX-16) and is not repeated here. 358 | P a g e

4.15.1 CUMULATIVE SOCIO-CULTURAL IMPACT MAPPING The socio-cultural aspect of this project considered the factors that may have a direct and/ or indirect impact on the human population within the MRA area. The sensitive receptors were thus identified by the social specialist as houses, schools, clinics, graveyards and other heritage features, and were therefore classified as high sensitivity anthropogenic receptors. In addition to the abovementioned receptors, a consensus was reached during the workshop that boreholes, the Somopho Nature Reserve and Potential Lodges within and around the HiP were to be included as highly sensitive receptors. Once the relevant cumulative impact data sets, as presented in Table 94, were overlaid onto the sensitive receptors, the high impact zones were merged and a high zone of influence (impact) was generated. In addition, the medium zone of influence was also generated (Figure 142). Since the HiP was not considered as a sensitive receptor for the cumulative socio-cultural impact mapping, the portions of high and medium impact zones extending into the HiP were eliminated for the purpose of this map. During the GIS Analyses, it was evident that visual and noise (45dBA contour) impacts extended the furthest into the MRA and surrounding properties, thus the contours of these two impacts were merged to develop the high zone of influence as illustrated in Figure 142. It is important to note that the level of noise differs between the HiP and the area outside the park, which was determined by the noise specialist as any disturbance producing noise equal to and higher than 35dBA is regarded as a high impact on the HiP, and any disturbance producing noise equal to and higher than 45dBA outside the park is considered a high impact. When the medium impact zones were overlaid it was evident that air quality had the greatest extent of impact on the environment, along with visual, noise and blasting impacts, thus these impacts were merged to generate the medium zone of influence as illustrated in Figure 142. Based on the zones of influence produced, it was evident that the majority of the sensitive receptors fall within the high zone of influence. Very few sensitive receptors fall within the medium zone of influence and the Somopho Nature Reserve as well as the potential lodges fall outside both the high and medium impact zones, thus it may be concluded that these features fall within a low impact zone.

4.15.2 CUMULATIVE IMPACT MAPPING FOR WILDERNESS RESOURCES AND THE HIP For the purpose of the cumulative impact mapping of the HiP, the appropriate wilderness classes (Zonation) were utilised to illustrate the various sensitivities of the park. The wilderness classes include: pristine, primitive, semi-primitive, partially modified and modified wilderness, however for the purpose of this report three levels of sensitivity (high, medium, low) were utilised in order to simplify the results. Based on the descriptions of the wilderness classes the pristine wilderness and primitive wilderness was defined as highly sensitive, semi-primitive and partially modified wilderness was categorised as moderately sensitive and modified wilderness was categorised to have a low sensitivity. Since this map was generated to illustrate the sensitivity of the park and the extent of the impacts on it, it was not deemed necessary to indicate the extent of the impacts on the MRA side. Note: the noise level for the HiP as determined by the specialist to have a high impact on the park was 35dBA and higher.

359 | P a g e

Figure 142: Cumulative socio-cultural impact map

Once the impacts were overlaid, it was evident that the visual and noise impacts extended the furthest into the park, thus these impact zones were merged to create the zone of high influence with regards to the park. The medium and low zones of influence were purely based on the visual impacts, since the noise and air quality impacts did not extend that far into the HiP. As demonstrated in Figure 143, the zone of high influence encroaches into the moderately sensitive areas of the HiP, whereas the zone of medium influence encroaches into the highly sensitive areas of the park and the zone of low influence encroaches into areas of moderate and low importance.

360 | P a g e

Figure 143: Cumulative Impact Map for Wilderness Resources and the HiP

4.15.3 CUMULATIVE BIOPHYSICAL IMPACT MAPPING The specialists reached a consensus as to which features will be classified as sensitive receptors for the purpose of the biophysical map. It was agreed that for illustrative purposes that best presented the results, the sensitive receptors be categorised by the relevant specialists into high, medium and low sensitive receptors. Furthermore, it was stipulated that the categories of sensitive receptors for surface water and ecological sensitivity as mentioned in Table 94 be displayed separately. Since the HiP is considered to be of significant ecological importance, it was preferred to include it as a high ecological sensitivity receptor. It is important to note that the agricultural potential and sensitivity of soils were taken into consideration during the GIS Analyses, the agricultural potential study was however confined to the mining footprint area of the project and the three levels of impacts of the ecological study eliminated the impacts of the agricultural potential and sensitive soils. Based on the outcome of the GIS Analyses, it is evident that noise and air quality may have the greatest impact on the ecological integrity of the area, and was therefore used as the determining factors for both high and medium zones of influence. During the assessment of the area the ecological specialists identified several threatened floral and faunal species along with highly sensitive habitat, which increases the ecological importance and sensitivity of the area. Figure 144 clearly illustrates that the mining footprint area is located within a highly sensitive area, and should mining activities be permitted in this area it will have a large effect on the ecological importance and sensitivity of the area. 361 | P a g e

It is evident that the impacts of the mine will encroach into the HiP, which poses a significant threat to the park in that anthropogenic disturbance such as mining activities will impact biophysical resources both within and outside of the HiP.

Figure 144: Cumulative Biophysical Impact Map

4.15.4 MAPPING OF CUMULATIVE DISPLACEMENT ZONE The purpose of this map is to illustrate the various high health and safety impact zones associated with the proposed Fuleni Anthracite Project, in order to determine which communities will be affected by the mining activities and required to relocate due to the health and safety risks that would arise from the mining activities. The individual high impacts, i.e. blasting, noise and air quality, are presented individually in Figure 145.

362 | P a g e

Figure 145: Cumulative Displacement Zone Map

Blasting: The blasting specialist study concluded that a minimum safe blasting distance of 306m be maintained from communities; however, recommends that no blasting should take place within 500m of any humans or animals. It is therefore recommended that all households within a distance of 500m from blasting areas (open pits) be relocated to a safer area in consultation with the household and in accordance with the Resettlement, Compensation and Mitigation Strategy (ANNEX-18). Air quality: The air quality specialist study identified two areas within the communities where air quality levels may be above the recommended health standards, depending on the weather conditions. However the potential for a health impact is moderate to low as the dust created by the mine are not in high or toxic concentrations, therefore resettlement of households in these areas are not recommended. Noise: The noise specialist study identified quite a large area where the noise levels may be above the recommended noise standards for a semi-rural environment. However, the noise levels are not so high that it will cause hearing loss, but may lead to irritation andlack of sleep (deprivation). It may also impact on the learning ability of children at school. Resettlement of households is not recommended.

363 | P a g e

4.16 DISPLACEMENT FACILITIES

OF

HOUSEHOLDS

AND

COMMUNITY

ASSETS

AND

The Fuleni Anthracite Project will physically displace a number of households. The households that need to be displaced (as presented here) are based on the cumulative displacement zone mapping and the recommendations that flowed from this – refer to previous section. Displacement will take place in three phases:   

Phase 1: Development of Open Pits 2 & 3 with associated infrastructure (commence in Year 1), including upgrading / construction of access road Phase 2: Continuous development of Phase 1 and the addition of Open Pit 1 with associated infrastructure (commence in Year 6) Phase 3: Continuous development of Phases 1 & 2 an the addition of Open Pits 4, 5 & 6 with associated infrastructure (commence in Year 11)

4.16.1 YEAR 1 – 5 DEVELOPMENT / IMPACTS The Phase 1 development takes place near the Ocilwane and Novunula communities and will commence in year 1. 4.16.1.1 Impact – No Mitigation Phase 1 of the development will require the following displacement if impacts cannot be further mitigated: 

 

18 households from the Ocilwane community with an associated estimated 36 graves and 24 arable fields (28 ha), grazing land and a livestock watering dam. These households are specifically impacted on by the open pits’ current poition and extent. 5 households from the Patane community directly affected by the new access road construction with an associated 10 graves. 50 households from the Ocilwane community are located within the displacement zone, where structures will be affected by air quality, blasting and noise with an associated 100 graves. Within this radius there are also two schools.

4.16.1.2 Application of the Avoidance Principle To mitigate the physical displacement through avoidance is only possible to an extent, i.e. reduction of Open Pit 2 footprint and associated Displacement Zone as well as the realignment of the access road road where it passes through the Patane community.

364 | P a g e

Figure 146: Phase 1 Displacement Zone

Figure 147: Phase 1 Access Road Displacement

365 | P a g e

Reduced Open pit footprint

Reduced Displacement Zone Figure 148: Proposed mitigation of Phase 1 (avoidance)

Figure 149: Proposed mitigation of Phase 1 Access Road (avoidance)

366 | P a g e

The avoidance principle will reduce the impact (post mitigation) to the following: 

 

18 households from the Ocilwane community with an associated estimated 36 graves and 24 arable fields (28ha) grazing land and a livestock watering dam. These households are specifically impacted on by the open pits – this impact remains post mitigation. No households from the Patane community would be affected by the new road construction – this impact is reduced post mitigation. 39 households (reduced by 11) from the Ocilwane community and an associated 78 graves are still located within the displacement zone. The two schools are now outside the displacement zone – this impact is reduced post mitigation.

4.16.2 YEAR 6 – 10 DEVELOPMENT / IMPACTS The Phase 2 development takes place near the Ocilwane and Ntuthunga 2 communities and will commence in year 6. 4.16.2.1 Impact – No Mitigation Phase 2 of the development will require the following additional displacement if impacts cannot be further mitigated:  

No households due to the physical mine footprint will be displaced, and only 1 arable field as well as grazing land. 16 additional households from the Ocilwane community are located within the displacement zone with associated 32 graves, where structures will be affected by air quality, blasting and noise. Within this radius the two Ocilwane schools are also located.

4.16.2.2 Application of the Avoidance Principle To mitigate the physical displacement through avoidance is only possible to an extent, i.e. reduction of Open Pit 1 footprint and associated Displacement Zone. The avoidance principle will reduce the impact (post mitigation) to the following:  

No households due to the physical mine footprint will be displaced, and only 1 arable field as well as grazing land – this impact remains post mitigation. 13 households (reduced by 3) from the Ocilwane community with associated 26 graves are still located within the displacement zone. The two schools are now outside the displacement zone this impact is reduced post mitigation.

367 | P a g e

Figure 150: Phase 2 Displacement Zone

Reduced Open pit footprint

Reduced Displacement Zone Figure 151: Proposed mitigation of Phase 2 (avoidance)

368 | P a g e

4.16.3 YEAR 11 – 15 DEVELOPMENT / IMPACTS The Phase 3 development takes place near the Ntuthunga 1 and Ntuthunga 2 communities and will commence in year 11. 4.16.3.1 Impact – No Mitigation Phase 3 of the development will require the following additional displacement if impacts cannot be further mitigated:  

1 households from the Ntuthunga 1 community will be displaced with an associated 2 graves. 34 additional households from the Ntuthunga community with an associated 68 graves are located within the displacement zone, where structures will be affected by air quality, blasting and noise. Within this radius the one Ntuthunga school is also located

Figure 152: Phase 3 Displacement Zone

4.16.3.2 Application of the Avoidance Principle To mitigate the physical displacement through avoidance is only possible to an extent, i.e. reduction of Open Pit 6 footprint and associated Displacement Zone. The avoidance principle will reduce the impact (post mitigation) to the following:  

No households due to the physical mine footprint will be displaced - this impact is reduced post mitigation. 16 households (reduced by 18) from the Ntuthunga 1 community with an associated 32 graves are still located within the displacement zone. The one school is now outside the displacement zone. 369 | P a g e

Reduced Open pit footprint

Reduced Displacement Zone Figure 153: Proposed mitigation of Phase 3 (avoidance)

4.16.4 DISPLACE SUMMARY Table 95: Displacement summary before and after mitigation (avoidance) Community

Phase

Aspect & Number

Proposed Mitigation

Post mitigation

Ocilwane Community

Phase 1 Mine Infrastructure and Displacement Zone Commence in Year 1

68 households 136 graves 24 arable fields Livestock dam 2 schools Grazing

57 households 114 graves 24 arable fields Livestock watering dam Grazing

Phase 2 Mine Infrastructure and Displacement Zone Commence in Year 6

Reduction of Open Pit 2 Resettlement and compensation of affected households Replacement of dam Resettlement of graves Replace / compensate for arable land and grazing lost Reduction of Open Pit 1 Resettlement and compensation of affected households Resettlement of graves Replace / compensate for arable land and grazing lost Reduction of Open Pit 6 Resettlement and compensation of affected households Resettlement of graves Replace / compensate for grazing lost Realign road

Ntuthunga 1 Community

Phase 3 Mine Infrastructure and Displacement Zone Commence in Year 11

16 households 32 graves 1 arable field 2 schools (same as above) Grazing 35 households 70 graves 1 school Grazing

Patane Community

Phase 1 Access Road Commence in Year 1

5 households 10 graves

TOTAL

124 households 248 graves 3 schools 25 arable fields Livestock dam Grazing

13 households 26 graves 1 arable field Grazing

16 households 32 graves Grazing

No households / graves 86 households 172 graves 25 arable Livestock dam Grazing

370 | P a g e

4.17 QUANTIFICATION OF IMPACT ON DIRECTLY AFFECTED PERSONS Table 96 provides a high-level monetary quantification of the impacts on directly affected persons and activities. Please note that the values are estimates only, on the conservative side, and may be an overestimation of the actual costs. Table 96: Monetary quantification of impact on directly affected persons

Impact

Assumption for Quantification

Relocation of households#

Relocation of graves

##

Estimated Cost

LOM cost (based on 32 years)

86 households @ R1.5m per household, inclusive of services

R 129 million (once-off)

R 129 million

172 graves @ R60,000 per grave, inclusive of ceremony

R 10.32 million (once-off)

R 10.32 million

Impact on arable plots, vegetable gardens and other services

Macro-economic model estimation of R 4 million per annum

R 4 million per annum

R 128 million

Loss of income on Wilderness Trails###

1 000 people per annum with an estimated expenditure of R 3 000 per trip

R 3 million per annum

R 96 million

Lease agreement with Mhlana Traditional Council

1 750 ha @ R5,000 per ha per annum (third of value)

R 8.75 million per annum

R 280 million

Loss of grazing to individual livestock farmers

1750 ha @ R15,000 per ha

R 26.25 million (once-off)

R 26.25 million

TOTAL:

R669.57 million

Notes: #: Impact after application of the Avoidance Principle – refer to Section 4.16. ##: Based on an estimation of 2 graves per household buried within yard. It could be substantially more. ###: Excludes the impact on animals, conservation and possible de-designation of the wilderness status.

371 | P a g e

5 ASSESSMENT AND EVALUATION INCLUDING MITIGATION MEASURES

OF

POTENTIAL

IMPACTS

RISK ASSESSMENT CRITERIA

5.1

According to the NEMA Regulations, ‘significant impact means an impact that by its magnitude, duration, intensity or probability of occurrence may have a notable effect on one or more aspects ofthe environment’. In line with the Regulations, and based on the qualitative findings of the activities undertaken, each potentially significant impact has been assessed with regard to:      

the nature and status of the impact; the extent and duration of the impact; the probability of the impact occurring; the effect of significance on decision‐makings; the weight of significance; and the mitigation efficiency.

5.1.1 IMPACT SIGNIFICANCE 5.1.1.1 Nature and Status The ‘nature’ of the impact describes what is being affected and how. The ‘status’ is based on whether the impact is positive, negative or neutral. 5.1.1.2 Spatial Extent ‘Spatial Extent’ defines the spatial or geographical scale of the impact. Category Site Local District Region Provincial National International

Rate 1 2 3 4 5 6 7

Descriptor Site of the proposed development Limited to site and/or immediate surrounds (500m zone of influence) Mfolozi Municipal area Uthungulu District, and direct neighbouring district Kwazulu Natal Province South Africa Beyond South African borders

5.1.1.3 Duration ‘Duration’ gives the temporal scale of the impact. Category Temporary Short term Medium term

Rate 1 2 3

Long term

4

Permanent

5

Descriptor 0 – 1 years 1 – 5 years 5 – 15 years Where the impact will cease after the operational life of the activity either because of natural process or by human intervention Where mitigation either by natural processes or by human intervention 372 | P a g e

Category

Rate

Descriptor will not occur in such a way or in such a time span that the impact can be considered as transient

5.1.1.4 Probability The ‘probability’ describes the likelihood of the impact actually occurring. Category Rare

Rate 1

Improbable

2

Probable Highly probable Definite

3 4 5

Descriptor Where the impact may occur in exceptional circumstances only Where the possibility of the impact materialising is very low either because of design or historic experience Where there is a distinct possibility that the impact will occur Where it is most likely that the impact will occur Where the impact will occur regardless of any prevention measures

5.1.1.5 Intensity ‘Intensity’ defines whether the impact is destructive or benign, in other words the level of impact on the environment. Category

Rate

Insignificant

1

Low

2

Medium

3

High

4

Very High

5

Descriptor Where the impact affects the environment is such a way that natural, cultural and social functions and processes are not affected. Localised impact and a small percentage of the population is affected Where the impact affects the environment is such a way that natural, cultural and social functions and processes are affected to a limited extent Where the affected environment is altered in terms of natural, cultural and social functions and processes continue albeit in a modified way Where natural, cultural or social functions or processes are altered to the extent that they will temporarily or permanently cease Where natural, cultural or social functions or processes are altered to the extent that they will permanently cease and it is not possible to mitigate or remedy the impact

5.1.1.6 Ranking, Weighting and Scaling The weight of significance define the level or limit at which point an impact changes from low to medium significance, or medium to high significance. The purpose of assigning such weights serves to highlight those aspects that are considered the most critical to the various stakeholders and ensure that the element of bias is taken into account. These weights are often determined by current societal values or alternatively by scientific evidence (norms, etc.) that define what would be acceptable or unacceptable to society and may be expressed in the form of legislated standards, guidelines or objectives. The weighting factor provides a means whereby the impact assessor can successfully deal with the complexities that exist between the different impacts and associated aspect criteria.

373 | P a g e

Spatial Extent

Site (1) Local (2) District (3) Regional (4) Provincial (5)

Intensity / Severity

Probability

Weighting factor

Significance Rating (SR WOM) Premitigation

Insignificant (1)

Rare (1)

Low (1)

Low (0 – 19)

Minor (2)

Unlikely (2)

Low to Medium (2)

Medium (3)

Possible (3)

Medium (3)

Duration

Short term (1) Short to Medium term (2) Medium term (3)

Low to Medium (20 – 39) Medium (40 – 59)

Mitigation Efficiency (ME)

Significance Rating (SRWM) Post Mitigation

High (0.2)

Low (0 – 19)

Medium to High (0.4) Medium (0.6)

Low to Medium (20 – 39) Medium (40 – 59)

National (6)

Long term (4)

High (4)

Likely (4)

Medium to High (4)

Medium to High (60 – 79)

Low to Medium (0.8)

Medium to High (60 – 79)

International (7)

Permanent (5)

Very high (5)

Almost certain (5)

High (5)

High (80 – 110)

Low (1.0)

High (80 – 110)

5.1.1.7 Impact significance without mitigation (WOM) Following the assignment of the necessary weights to the respective aspects, criteria are summed and multiplied by their assigned weightings, resulting in a value for each impact (prior to the implementation of mitigation measures). Equation 1: Significance Rating (WOM) = (Extent + Intensity + Duration + Probability) x Weighting Factor 5.1.1.8 Effect of Significance on Decision‐makings Significance is determined through a synthesis of impact characteristics as described inthe above paragraphs. It provides an indication of the importance of the impact in termsof both tangible and intangible characteristics. The significance of the impact “without mitigation” is the prime determinant of the nature and degree of mitigation required. Rating Negligible

Low

Rate 0

1-19

Low to Medium

20 – 39

Medium

40 – 59

Medium to High

60 -79

High

80 – 110

Descriptor The impact is non-existent or insignificant, is of no or little importance to decision making. The impact is limited in extent, even if the intensity is major; the probability of occurrence is low and the impact will not have a significant influence on decision making and is unlikely to require management intervention bearing significant costs. The impact is of importance, however, through the implementation of the correct mitigation measures such potential impacts can be reduced to acceptable levels. The impact and proposed mitigation measures can be considered in the decisionmaking process The impact is significant to one or more affected stakeholder, and its intensity will be medium or high; but can be avoided or mitigated and therefore reduced to acceptable levels. The impact and mitigation proposed should have an influence on the decision. The impact is of major importance but through the implementation of the correct mitigation measures, the negative impacts will be reduced to acceptable levels. The impact could render development options controversial or the entire project unacceptable if it cannot be reduced to acceptable levels; and/or the cost of management intervention will be a significant factor and must influence decisionmaking.

374 | P a g e

5.1.2 MITIGATION “Mitigation” is a broad term that covers all components of the ‘mitigation hierarchy’ defined hereunder. It involves selecting and implementing measures, amongst others, to conserve biodiversity and to protect, the users of biodiversity and other affected stakeholders from potentially adverse impacts as a result of mining or any other landuse. The aim is to prevent adverse impacts from occurring or, where this is unavoidable, to limit their significance to an acceptable level. Offsetting of impacts is considered to be the last option in the mitigation hierarchy for any project. The mitigation hierarchy in general consists of the following in order of which impacts should be mitigated: 







Avoid/prevent impact: can be done through utilising alternative sites, technology and scale of projects to prevent impacts. In some cases if impacts are expected to be too high the “no project” option should also be considered, especially where it is expected that the lower levels of mitigation will not be adequate to limit environmental damage and eco-service provision to suitable levels. Minimise (reduce) impact: can be done through utilisation of alternatives that will ensure that impacts on biodiversity and ecoservices provision are reduced. Impact minimisation is considered an essential part of any development project. Rehabilitate (restore) impact is applicable to areas where impact avoidance and minimisation are unavoidable where an attempt to re-instate impacted areas and return them to conditions which are ecologically similar to the pre-project condition or an agreed post project land use, for example arable land. Rehabilitation can however not be considered as the primary mitigation toll as even with significant resources and effort rehabilitation that usually does not lead to adequate replication of the diversity and complexity of the natural system. Rehabilitation often only restores ecological function to some degree to avoid ongoing negative impacts and to minimise aesthetic damage to the setting of a project. Practical rehabilitation should consist of the following phases in best practice: o Structural rehabilitation which includes physical rehabilitation of areas by means of earthworks, potential stabilisation of areas as well as any other activities required to develop a long terms sustainable ecological structure; o Functional rehabilitation which focuses on ensuring that the ecological functionality of the ecological resources on the subject property supports the intended post closure land use. In this regard special mention is made of the need to ensure the continued functioning and integrity of wetland and riverine areas throughout and after the rehabilitation phase. o Biodiversity reinstatement which focuses on ensuring that a reasonable level of biodiversity is re-instated to a level that supports the local post closure land uses. In this regard special mention is made of re-instating vegetation to levels which will allow the natural climax vegetation community of community suitable for supporting the intended post closure land use. o Species reinstatement which focuses on the re-introduction of any ecologically important species which may be important for socio-cultural reasons, ecosystem functioning reasons and for conservation reasons. Species re-instatement need only occur if deemed necessary. Offset impact: refers to compensating for latent or unavoidable negative impacts on biodiversity. Offsetting should take place to address any impacts deemed to be unacceptable which cannot be mitigated through the other mechanisms in the mitigation hierarchy. The objective of biodiversity offsets should be to ensure no net loss of biodiversity. Biodiversity offsets can be considered to be a last resort to compensate for residual negative impacts on biodiversity. 375 | P a g e

According to the DMR (2013) “Closure” refers to the process for ensuring that mining operations are closed in an environmentally responsible manner, usually with the dual objectives of ensuring sustainable postmining land uses and remedying negative impacts on biodiversity and ecosystem services. The significance of residual impacts should be identified on a regional as well as national scale when considering biodiversity conservation initiatives. If the residual impacts lead to irreversible loss or irreplaceable biodiversity the residual impacts should be considered to be of very high significance and when residual impacts are considered to be of very high significance, offset initiatives are not considered an appropriate way to deal with the magnitude and/or significance of the biodiversity loss. In the case of residual impacts determined to have medium to high significance, an offset initiative may be investigated. If the residual biodiversity impacts are considered of low significance no biodiversity offset is required. 5.1.2.1 Impact significance with mitigation measures (WM) In order to gain a comprehensive understanding of the overall significance of the impact, after implementation of the mitigation measures, it was necessary to re-evaluate the impact. 5.1.2.2 Mitigation Efficiency (ME) The most effective means of deriving a quantitative value of mitigated impacts is to assign each significance rating value (WOM) a mitigation effectiveness (ME) rating. The allocation of such a rating is a measure of the efficiency and effectiveness, as identified through professional experience and empirical evidence of how effectively the proposed mitigation measures will manage the impact. Thus, the lower the assigned value the greater the effectiveness of the proposed mitigation measures and subsequently, the lower the impacts with mitigation. Equation 2: Significance Rating (WM) = Significance Rating (WOM) x Mitigation Efficiency (ME) Mitigation Efficiency is rated out of 1 as follows: Category Not Efficient (Low) Low to Medium

Rate 1 0.8

Medium

0.6

Medium to High

0.4

High

0.2

Descriptor Mitigation cannot make a difference to the impact Mitigation will minimize impact slightly Mitigation will minimize impact to such an extent that it becomes within acceptable standards Mitigation will minimize impact to such an extent that it is below acceptable standards Mitigation will minimize impact to such an extent that it becomes insignificant

5.1.2.3 Significance Following Mitigation (SFM) The significance of the impact after the mitigation measures are taken into consideration. The efficiency of the mitigation measure determines the significance of the impact. The level of impact is therefore seen in its entirety with all considerations taken into account.

376 | P a g e

5.2

ENVIRONMENTAL IMPACT RISK MATRIX

Sensitive Receptor

Environmental Aspect

Biophysical Environment

Soils

Biophysical Environment

Soils

Biophysical Environment

Soils

Biophysical Environment Biophysical Environment Biophysical Environment Biophysical Environment Biophysical Environment Biophysical Environment Biophysical Environment Biophysical Environment Biophysical Environment

Soils

Soils Soils

Soils

Flora Flora

Potential Impact Impedance of a stockpile is envisaged to cover 1 ha of the soils of the Clovelly soil form, which is of medium agricultural potential Impact on hydropedological functioning of the deep Arcadia soils found in and around stream channels and preferential water flow channels Loss of soil depth (volume), fertility and organic carbon content Possible chemical pollution of soil through polluted water, stockpiling of material and/or spillages of chemicals and hazardous material Compaction, crusting and hard-setting of rehabilitated areas Erosion of stockpiles and cleared areas during mining Surface subsidence due to underground mining and/or pit subsidence impacting on the hydropedological functioning of the area Impact on sensitive floral habitat & diversity Impact on species of conservation concern

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Negative

Permanent

Site specific

Highly Probable

Medium

Medium to High

Medium

High

Low

Negative

Permanent

Site specific

Definite

High

Medium to High

Medium to High

Low to Medium

Medium

Negative

Long Term

Site specific

Highly Probable

Medium

Medium

Low to Medium

Medium

Low to Medium

Negative

Long Term

Site specific

Probable

Medium

Medium to High

Medium

Medium to High

Low

Negative

Long Term

Site specific

Probable

High

High

Low to Medium

Medium

Negative

Long Term

Regional

Probable

Medium

High

Medium to High Medium to High

Medium

Medium

Negative

Long Term

Local

Probable

Medium

Medium to High

Medium

Medium

Low to Medium

Negative

Long Term

District

Definite

High

High

High

Negative

Long Term

District

Definite

High

High

High

Low to Medium Low to Medium Low to Medium Low to Medium

Medium to High Medium to High Medium to High Medium to High

Low to Medium

Medium to High

Fauna

Impact on faunal habitat & diversity

Negative

Long Term

District

Definite

High

High

High

Fauna

Impact on species of conservation concern

Negative

Long Term

District

Definite

High

High

High

Fauna

Effect of blasting on sensitive fauna (elephants, crocodiles)

Negative

Long Term

Regional

Highly Probable

High

High

High

377 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Biophysical Environment

Fauna

Effects of blasting on sensitive avifauna

Negative

Long Term

Regional

Highly Probable

High

High

High

Low to Medium

Medium to High

Biophysical Environment

Fauna

Negative effect of lighting pollution on faunal species

Negative

Long Term

Regional

Highly Probable

High

Medium to High

Medium to High

Low to Medium

Medium

Biophysical Environment

Fauna

Killing of animals and avifauna on the roads, especially nocturnal animals/birds

Negative

Long Term

Regional

Highly Probable

High

High

High

Low to Medium

Medium to High

Biophysical Environment

Fauna

Negative

Long Term

Regional

Highly Probable

High

High

High

Low to Medium

Medium to High

Biophysical Environment

Wetlands and Aquatic Systems

Negative

Permanent

Site specific

Definite

High

High

Medium to High

Low to Medium

Medium to High

Biophysical Environment

Wetlands and Aquatic Systems

Impact on wetland hydrological function and sediment balance

Negative

Permanent

Local

Definite

High

High

High

Low to Medium

Medium to High

Biophysical Environment

Wetlands and Aquatic Systems

Negative

Long Term

Local

Highly Probable

High

Medium to High

Medium

Low to Medium

Medium

Biophysical Environment

Surface Water

Loss of aquatic habitat, biodiversity and sensitive taxa Impedance of flood-lines and water courses by placement of stockpiles, infrastructure and mining pits

Negative

Permanent

Site specific

Definite

Very High

Medium to High

Medium to High

Not Efficient

Medium to High

Biophysical Environment

Surface Water

Reduction in MAR in Mfolozi River

Negative

Long Term

Regional

Definite

High

High

High

Low to Medium

Medium to High

Biophysical Environment

Surface Water

Changes to peak flows in Mfolozi River and tributaries

Negative

Long Term

Regional

Highly Probable

High

Medium to High

Medium to High

Medium

Low to Medium

Biophysical Environment

Surface Water

Drying up of tributaries due to stream diversions

Negative

Permanent

Site specific

Definite

Very High

Medium

Medium

Not Efficient

Medium

Biophysical Environment

Surface Water

Increased sediment loads due to canalization of water

Negative

Long Term

Regional

Highly Probable

High

High

High

Medium

Medium

Biophysical Environment

Surface Water

Increased sediment loads due to vegetation clearance and compaction

Negative

Long Term

Regional

Highly Probable

High

High

High

Medium

Medium

Biophysical Environment

Surface Water

Increased sediment loads due to uncontrolled runoff from stockpiles and disturbed areas

Negative

Long Term

Regional

Highly Probable

High

High

High

Medium

Medium

Power line impacts on avifauna in the area, with specific mention of the vultures Loss of wetland and riparian habitat and ecological and socio-cultural service provision

378 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Biophysical Environment

Surface Water

Pollution as a result of leachate and runoff from stockpiles

Negative

Long Term

Regional

Highly Probable

High

High

High

Medium

Medium

Biophysical Environment

Surface Water

Negative

Long Term

Regional

Highly Probable

High

High

High

Medium

Medium

Biophysical Environment

Surface Water

Negative

Long Term

Local

Highly Probable

High

High

Medium to High

Medium to High

Low to Medium

Biophysical Environment

Surface Water

Negative

Long Term

Local

Improbable

High

Medium to High

Medium

Medium

Low to Medium

Biophysical Environment

Groundwater

Negative

Long Term

Local

Definite

High

High

Medium to High

Not Efficient

Medium to High

Biophysical Environment

Groundwater

Negative

Long Term

Local

Highly Probable

High

Medium to High

Medium

Medium

Low to Medium

Biophysical Environment

Groundwater

Negative

Long Term

Local

Highly Probable

High

Medium to High

Medium

Medium

Low to Medium

Communities

Land Use

Negative

Permanent

Site specific

Definite

High

High

Medium to High

Medium

Medium

Communities

Land Use

Negative

Permanent

Site specific

Definite

High

High

Medium

Medium

Communities

Land Use

Negative

Long Term

Site specific

Definite

High

High

Medium

Medium

Communities

Land Use

Loss of access to natural resources

Negative

Long Term

Site specific

Definite

High

High

Medium

Medium

Communities

Groundwater (boreholes)

Mining through of user borehole FUL17

Negative

Permanent

Site specific

Highly Probable

High

Medium to High

Medium

Not Efficient

Medium

Communities

Groundwater (boreholes)

Lowering of water levels of user borehole FUL21

Negative

Long Term

Site specific

Highly Probable

High

High

Medium to High

Not Efficient

Medium to High

Communities

Groundwater (boreholes)

Water quality impacts of user boreholes

Negative

Long Term

Site specific

Highly Probable

High

High

Medium to High

Low to Medium

Medium

Pollution due to uncontrolled releases from the mining footprint and infrastructure areas Pollution as a result of accidental spillages of chemicals and hazardous material Impact on surface water quality as a result of groundwater interaction Lowering of groundwater levels indicating a cone of depression with a radius of ≈ 700m Effect on groundwater quality due to infiltration of poor quality water/effluent from wet sources (PCDs, etc) Effect on groundwater quality due to poor quality leachate generated through dry hazardous material / stockpiles Relocation of households and associated graves within 500 m radius from open pits (blasting) Loss of communal gardens and vegetable plots – 35 ha Loss of grazing – 1 750 ha (total footprint)

Medium to High Medium to High Medium to High

379 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact Expected dust fallout during construction is predicted to be relatively low, and will not exceed the National Standards for ambient air quality Expected particulate emission plumes indicate exceedences to both the PM10 and PM2.5 standards Increased dust levels as a result of onsite hauling of ROM Increased dust levels along the access road due to increased traffic and large trucks Intermittent increase in dust levels due to blasting

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Negative

Short Term

Local

Highly Probable

Medium

High

Medium

Medium to High

Low to Medium

Negative

Long Term

District

Definite

High

High

High

Medium

Medium

Negative

Long Term

Local

Definite

High

High

Medium to High

Medium

Medium

Negative

Long Term

District

Definite

High

High

High

Medium

Medium

Negative

Long Term

Local

Definite

High

High

Medium to High

Medium to High

Low to Medium

Communities

Air quality

Communities

Air quality

Communities

Air quality

Communities

Air quality

Communities

Air quality

Communities

Air quality

Heavy metal exposure as a result of coal dust, impacting on community health

Negative

Long Term

Local

Improbable

High

High

Medium to High

Medium to High

Low to Medium

Communities

Air quality

Coal bed methane released from the coal bed during mining operations predicted to be 84 074 306 m³ for the LOM

Negative

Long Term

National

Highly Probable

High

High

High

Low to Medium

Medium to High

Communities

Air quality

Increased particulate emission due to exhaust tailpipe emissions from vehicles

Negative

Long Term

Local

Highly Probable

High

High

Medium to High

Medium to High

Low to Medium

Communities

Air quality

Negative

Long Term

Local

Probable

Very High

High

Medium to High

Medium to High

Low to Medium

Communities

Ambient noise

Negative

Short Term

Local

Definite

Medium

High

Medium to High

Medium to High

Low to Medium

Communities

Ambient noise

Negative

Long Term

District

Definite

High

High

High

Low to Medium

Medium to High

Communities

Ambient noise

Negative

Long Term

Regional

Definite

High

High

High

Low to Medium

Medium to High

Potential health risk to the surrounding communities as a result of elevated PM levels Potential for noise impact during construction at sites in the immediate vicinity of the construction activity Elevated noise levels expected from the mining operation, in excess of the National standards for rural and suburban residential Elevated noise levels expected along the access road due to increase in traffic and large trucks

380 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Communities

Ambient noise

Noise disturbances / health effects caused by elevated noise levels

Negative

Long Term

Local

Probable

Very High

High

Medium to High

Medium

Medium

Communities

Ambient noise

Intermittent high noise levels due to blasting

Negative

Long Term

Local

Definite

High

High

Medium to High

Medium

Medium

Communities

Blasting

Health, safety and nuisance impacts related to blasting, including: ground vibration, air blast and fly rock

Negative

Long Term

Local

Highly Probable

Very High

High

Medium to High

Medium

Medium

Communities

Blasting

Sensitive structures – schools and clinics

Negative

Long Term

Provincial

Probable

Very High

High

High

Medium

Medium

Communities

Blasting

Structural damage to houses and other structures

Negative

Permanent

Local

Highly Probable

Very High

High

High

Medium

Medium

Communities

Blasting

Potential for impact on user borehole FUL21

Negative

Long Term

Site specific

Probable

High

High

Medium to High

Not Efficient

Medium to High

Communities

Blasting

The occurrence of fumes in the form the NOx gaseous format

Negative

Long Term

Site specific

Improbable

Very High

Medium to High

Medium

Medium to High

Low

Communities

Visual

Visual intrusion of mining activities, impacting on the sense of place

Negative

Long Term

District

Definite

High

High

High

Medium

Medium

Communities

Visual

Impact due to nighttime lighting

Negative

Long Term

District

Highly Probable

High

High

Medium to High

Medium

Medium

Communities

Traffic

Impact on pedestrian activity along the new access road due to increase in large trucks

Negative

Long Term

Regional

Definite

Very High

High

High

Medium

Medium

Communities

Traffic

Safety of other road users, increase in traffic accidents

Negative

Long Term

Regional

Definite

Very High

High

High

Medium to High

Low to Medium

Communities

Traffic

Impact of increase in traffic on domestic animals

Negative

Long Term

Regional

Probable

High

High

Medium to High

Medium to High

Low to Medium

Communities

Roads

Open Pit 2 will result in the realignment of both D873 and L1791 resulting in longer travelling distances and reduced access to the schools and clinic in Ocilwane (from Novunula)

Negative

Long Term

District

Definite

High

High

High

Medium

Medium

Communities

Roads

Access and alternative access during incidents by emergency health services

Negative

Long Term

Provincial

Highly Probable

Very High

High

High

Medium to High

Low to Medium

381 | P a g e

Sensitive Receptor

Environmental Aspect

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

HiP and Mfolozi Wilderness Area

Water resources

Negative

Long Term

Regional

Rare

High

High

Medium to High

High

Low

HiP and Mfolozi Wilderness Area

Air quality

Negative

Long Term

Regional

Definite

Very High

High

High

Not Efficient

High

HiP and Mfolozi Wilderness Area

Noise levels

Elevated noise levels expected within the HiP and Wilderness Area.

Negative

Long Term

Regional

Definite

Very High

High

High

Not Efficient

High

Visual

Visual impacts on Mfolozi Wilderness Area and greater HiP as a result of mainly the stockpile operations on the border of the HiP, impacting on the sense of place

HiP and Mfolozi Wilderness Area

Negative

Long Term

Regional

Definite

Very High

High

High

Low to Medium

Medium to High

HiP and Mfolozi Wilderness Area

Biophysical

Run away fires

Negative

Long Term

Regional

Probable

Very High

High

High

Medium to High

Low to Medium

HiP and Mfolozi Wilderness Area

Biophysical

Increased poaching

Negative

Long Term

Regional

Probable

Very High

High

High

Medium

Medium

HiP and Mfolozi Wilderness Area

Tourism

Impact on tourism

Negative

Long Term

Provincial

Highly Probable

Very High

High

High

Low to Medium

Medium to High

iSimangaliso Wetland Park and Lake St Lucia

Surface water

Water quality and quantity impacts on downstream sensitive areas

Negative

Long Term

Provincial

Improbable

Very High

High

High

Medium to High

Low to Medium

Mvamanzi Pan system

Surface water

Impact on MAR and hydrological balance of Mvamanzi Pan as a result of the damming of water (water supply dam)

Negative

Long Term

District

Highly Probable

Very High

High

High

Medium

Medium

Mvamanzi Pan system

Surface water

Downstream impacts associated with dam failure / breakage

Negative

Long Term

District

Improbable

Very High

High

Medium to High

Medium to High

Low to Medium

Residual Impacts

HiP and Mfolozi Wilderness Area

Negative

Long Term

National

Highly Probable

Very High

High

High

Not Efficient

High

Residual Impacts

HiP and Mfolozi Wilderness Area

Negative

Permanent

International

Highly Probable

Very High

High

High

Not Efficient

High

Potential Impact Impact on surface water resources within the HiP The maximum concentration for the operational PM10 emissions is seen within in the HiP’s fenceline

High levels of air quality and noise impacting on the Wilderness Area and overall sense of place Potential de-designation of Wilderness status as a result of the high levels of visual intrusion, noise and emissions

382 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Residual Impacts

Land Use and land capability

Impact on ecosystem

Negative

Permanent

Regional

Highly Probable

Very High

High

High

Low to Medium

Medium to High

Residual Impacts

Land Use and land capability

Post-closure land use and land capability

Negative

Permanent

Local

Highly Probable

Very High

High

High

Medium

Medium

Residual Impacts

Land Use and land capability

Negative

Permanent

Regional

Highly Probable

Very High

High

High

Medium

Medium

Negative

Permanent

District

Highly Probable

Very High

High

High

Low to Medium

Medium to High

Downstream movement of a deeper groundwater pollution plume

Negative

Permanent

District

Highly Probable

Very High

High

High

Low to Medium

Medium to High

Decant into the shallow aquifer or on surface at the lowest surface elevations intersected by the pits

Negative

Permanent

Regional

Highly Probable

Very High

High

High

Low to Medium

Medium to High

Residual Impacts

Residual Impacts

Residual Impacts

Surface and groundwater resources Surface and groundwater resources Surface and groundwater resources

Erosion of post-mining landscape, especially where the slope is greater than eight percent. Deterioration of groundwater quality within the back-filled open pits due to acid rock drainage reactions

383 | P a g e

5.3

SOCIAL IMPACT RISK MATRIX

Social Aspect

Population and Demographic Change

Change/disruption of power relationships

Potential Impact

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Conflict between job seekers and local communities

Negative

Short Term

Local

Highly Probable

High

Medium to High

Medium

Medium to High

Low

Increase in social pathologies such as crime, safety, health, prostitution

Negative

Short Term

Local

Probable

High

Medium

Low to Medium

Medium

Low

Impact on social characteristics and dynamics of rural areas

Negative

Long Term

District

Highly Probable

Medium

Low to Medium

Low to Medium

Low to Medium

Low to Medium

Conflict between job seekers and local communities

Negative

Long Term

Local

Highly Probable

High

Medium to High

Medium

Medium to High

Low to Medium

Pressure on community infrastructure and services

Negative

Long Term

District

Highly Probable

High

Medium to High

Medium to High

Medium

Low to Medium

Increase in social pathologies such as crime, safety, health, prostitution

Negative

Long Term

Local

Probable

Very High

Medium

Medium

Medium

Low to Medium

Negative

Long Term

Local

Probable

Medium

Medium to High

Medium

Low to Medium

Low to Medium

Negative

Medium Term

Local

Definite

High

High

Medium to High

Low to Medium

Medium

Negative

Short Term

District

Definite

High

High

Medium to High

Low to Medium

Medium

Negative

Medium Term

Local

Highly Probable

Medium

Medium to High

Medium

Medium

Low to Medium

Negative

Permanent

Local

Highly Probable

Medium

Medium to High

Medium

Medium to High

Low to Medium

Negative

Temporary

Local

Highly Probable

High

Medium to High

Medium

Low to Medium

Low to Medium

Negative

Long Term

Local

Highly Probable

High

Medium to High

Medium

Medium

Low to Medium

Increased internal inequalities within communities Competition for power of direction and decision-making between traditional authorities and community leaders Competition for power over benefit allocation amongst Mhlana traditional communities and with neighbouring traditional areas Tension and conflict between residents and outsiders

Disruption in daily living and movement patterns

Loss of traditional authority subjects if a household chooses to relocate outside the Mhlana traditional authority jurisdiction Increase in traffic numbers caused by supplying of goods during construction phase Increase in traffic numbers caused by supplying of goods during operational phase

384 | P a g e

Social Aspect

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Negative

Long Term

Local

Highly Probable

Medium

Medium

Low to Medium

Medium to High

Low

Negative

Permanent

Local

Definite

Very High

High

High

Low to Medium

Medium to High

Negative

Permanent

Local

Definite

Very High

High

High

Medium

Medium

Access to clinic located in Ocilwane from Novunula due to road diversion

Negative

Permanent

Local

Definite

Very High

High

High

Low to Medium

Medium to High

Access and alternative access during incidents by emergency health services

Negative

Long Term

Local

Highly Probable

High

Medium to High

Medium

Medium

Low to Medium

Tension and Conflict due to dissimilar social practices

Negative

Medium Term

Local

Probable

High

Medium to High

Medium

Medium

Low to Medium

Disruption of social networks

Negative

Long Term

Local

Highly Probable

High

High

Medium to High

Low to Medium

Medium

Increases in Developmental diseases

Negative

Long Term

Local

Probable

High

Medium to High

Medium

Medium to High

Low to Medium

Increase in Social Pathologies such as crime, prostitution, teenage pregnancies

Negative

Long Term

Local

Probable

High

Medium to High

Medium

Medium

Low to Medium

Displacement of households impacted by the mine footprint

Negative

Permanent

Site specific

Definite

Very High

High

High

Medium

Medium

Displacement of households within the displacement zone

Negative

Permanent

Local

Highly Probable

Very High

High

High

Medium

Medium

Unequal distribution of benefits between those who are primarily impacted and those who receive benefits

Negative

Long Term

Local

Probable

Medium

Medium

Low to Medium

Medium to High

Low

Exacerbation of class equalities

Negative

Long Term

Local

Improbable

Medium

Medium

Low to Medium

Medium

Low

Increase unequal access to opportunities or resources

Negative

Long Term

Local

Probable

Medium

Medium to High

Medium

Low to Medium

Low to Medium

Establishment of conflict between the developer and the local communities

Negative

Medium Term

Local

Definite

Very High

High

Medium to High

Medium

Medium

Objection against the development

Negative

Long Term

Internati onal

Definite

Very High

High

High

Low to Medium

High

Potential Impact Increase traffic numbers caused by transport and/or traffic of employees from their place of residence to their place of work Road diversions causing further distances to travel Access to schools located in Ocilwane from Novunula due to road diversion

Dissimilarity in Social Practices and Disruption of Social Networks

Resettlement or displacement of individuals or families

Impact Equity

Perceptions of and Feelings in relation to the project

385 | P a g e

Social Aspect

Change in Cultural Practices

Potential Impact

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Displacement of graves impacted by the mine footprint

Negative

Permanent

Site specific

Definite

Very High

High

High

Medium

Medium

Negative

Permanent

Local

Highly Probable

Very High

High

High

Medium

Medium

Negative

Long Term

Local

Probable

High

High

Medium to High

Low to Medium

Medium

Positive

Long Term

Provincial

Definite

High

Medium to High

Medium to High

Not Efficient

Medium to High

Negative

Short Term

Local

Probable

High

Medium to High

Medium

Medium to High

Low

Positive

Long Term

Local

Highly Probable

High

Medium to High

Medium

Not Efficient

Medium

Negative

Medium Term

Local

Probable

Medium

Medium to High

Medium

Medium

Low to Medium

Negative

Permanent

Local

Probable

Medium

Medium

Low to Medium

Medium to High

Low

Positive

Long Term

Local

Definite

High

Medium to High

Medium to High

Not Efficient

Medium to High

Negative

Medium Term

Local

Probable

Medium

Medium to High

Medium

Medium

Low to Medium

Positive

Long Term

Regional

Highly Probable

High

Medium to High

Medium to High

Not Efficient

Medium to High

Negative

Medium Term

District

Probable

Medium

Medium

Low to Medium

Medium

Low to Medium

Negative

Medium Term

Local

Probable

Medium

Medium

Low to Medium

Medium

Low

Negative

Long Term

Local

Probable

High

Medium

Medium to High

Low to Medium

Increases in Developmental diseases

Negative

Long Term

Local

Probable

High

Medium

Medium to High

Low to Medium

Increased noise levels in the local communities

Negative

Long Term

Local

Highly Probable

High

Medium to High

Medium

Medium

Displacement of household associated graves within the displacement zone Disruption of Ancestral and other Religious Practices Increase in available employment opportunities locally

Participation of Local Communities in Employment Opportunities and Skills Development

Equity Participation of the Local Communities

Participation of local business in procurement opportunities

Health Impacts

Noise Impacts

Availability of appropriately qualified workers Increase in skills development programmes and therefore skill levels of the local communities Employment of skilled outsiders creates tension and conflict in the local communities Loss of job opportunities due to downscaling of the mine employment Empowerment of local communities through equity participation Increased tension and conflict between communities on the distribution of benefits Empowerment of local business through procurement and capacity building Increased tension and conflict between business in competition for contracts Loss of business opportunities during downscaling causing economic hardship and retrenchment Increase in health incidents related to air pollution

Medium to High Medium to High High

386 | P a g e

Social Aspect

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Negative

Long Term

Local

Highly Probable

Very High

High

Medium to High

Medium

Medium

Negative

Long Term

Local

Probable

High

Medium to High

Medium

Medium

Low to Medium

Increase in theft, burglary, armed robbery, assault and even murder

Negative

Medium Term

Local

Probable

High

Medium to High

Medium

Medium

Low to Medium

Increase in poaching in the neighbouring conservation areas

Negative

Short Term

Local

Probable

Very High

High

Medium to High

Low to Medium

Medium

Increased road accidents due to increased traffic volumes

Negative

Long Term

Local

Highly Probable

High

High

Medium to High

Medium to High

Low to Medium

Increased Fire risks surrounding the mine site

Negative

Long Term

Local

Probable

Very High

Medium to High

Medium

Medium to High

Low to Medium

Increase nuisance effect due to increased levels of dust and noise

Negative

Long Term

Local

Definite

Very High

High

High

Medium

Medium

Negative

Medium Term

Local

Probable

Medium

Medium to High

Medium

Medium

Low to Medium

Negative

Long Term

Local

Definite

Very High

High

High

Medium

Medium

Negative

Long Term

Local

Highly Probable

Very High

High

Medium to High

Medium

Medium

Decrease in tourists and visitors during the Construction Phase

Negative

Short Term

Local

Highly Probable

High

Medium to High

Medium

Medium

Low to Medium

Decrease in tourists and visitors during the Operational Phase

Negative

Long Term

District

Highly Probable

Very High

High

High

Medium

Medium

Loss of therapeutic effect in Wilderness Therapy Programmes

Negative

Long Term

National

Highly Probable

Very High

Medium to High

Medium to High

Low to Medium

Medium to High

Displacement of education facilities within the displacement zone

Negative

Permanent

Site specific

Highly Probable

Very High

High

Medium to High

High

Low

Adequacy of services to sustain the increase demand

Negative

Medium Term

District

Probable

High

Medium

Low to Medium

Medium

Low to Medium

Increased pressure on current services to accommodate growth

Negative

Long Term

District

Highly Probable

High

Medium to High

Medium to High

Medium

Low to Medium

Potential Impact Increased noise levels near educational facilities that may affect education Increase in social pathologies such as alcohol abuse, prostitution and vandalism

Safety impacts: Increase in Crime

Safety impacts: Infrastructure & Operational safety

Change in sense of place

Change in tourism opportunities

Change in community infrastructure Change in Community services

Increase in traffic with a disruptive effect Visual intrusion of mining infrastructure Decrease in Sense of Place in the Wilderness Area located in proximity to the mine area

387 | P a g e

Social Aspect

Change in housing needs/demands

Potential Impact

Nature of Impact

Duration

Extent

Probability

Intensity

Weighting Factor

Impact Significance

Mitigation Efficiency

Impact Significance

Decrease in population growth and ability to sustain services post closure

Negative

Long Term

District

Probable

High

Medium to High

Medium

Medium to High

Low to Medium

Increased pressure on formal towns to supply housing

Negative

Long Term

District

Highly Probable

High

Medium to High

Medium to High

Medium

Low to Medium

Increased property prices due to high demand in formal towns

Positive

Medium Term

District

Probable

Medium

Medium to High

Medium

Not Efficient

Medium

Increase occurrence of informal housing in the local communities

Negative

Medium Term

Local

Highly Probable

High

Medium to High

Medium

Medium

Low to Medium

Increased informal rental income as a source of ncome within formal and informal / rural towns

Positive

Medium Term

Local

Highly Probable

High

Medium to High

Medium

Not Efficient

Medium

Decrease of property prices within formal towns post closure

Negative

Short Term

District

Probable

Medium

Medium

Low to Medium

Medium

Low

Negative

Permanent

Local

Probable

High

Medium to High

Medium

Medium to High

Low to Medium

Negative

Short Term

District

Probable

Medium

Medium

Low to Medium

Medium

Low

Loss of grazing land

Negative

Permanent

Definite

Very High

High

High

Low to Medium

Medium to High

Loss of arable land

Negative

Permanent

Definite

High

High

Medium to High

Medium

Medium

Loss of vegetable gardens

Negative

Permanent

Definite

Very High

High

High

Medium to High

Low to Medium

Loss of access to medicinal plants

Negative

Permanent

Site specific

Highly Probable

Very High

High

Medium to High

Medium to High

Low to Medium

Loss of access to firewood

Negative

Permanent

Site specific

Highly Probable

High

Medium to High

Medium

Medium

Low to Medium

Loss of livestock drinking dam

Negative

Permanent

Site specific

Definite

High

Medium to High

Medium to High

Medium to High

Low to Medium

Economic hardship due to the loss of rental income as a source of income within formal and informal / rural towns, post closure Surplus housing supply as people migrate out of formal towns, post closure

Change in access to resources that sustain livelihoods

Site specific Site specific Site specific

388 | P a g e

6 COMPARATIVE ASSESSMENT OF LAND USE AND DEVELOPMENT ALTERNATIVES LAND USE ALTERNATIVES

6.1

The existing land use can be described as rural residential, either in a scattered pattern or clustered into small villages. Subsistence agriculture is practiced. The proposed site is bordered to the north-west by the HiP which is administered by Ezemvelo KZN Wildlife. The Somkhele Mine lies to the north of the proposed Fuleni Anthracite Project. Alternative land use options that have been identified include:       

Status quo i.e. land used for community and grazing Expansion of the HiP as proposed by EKZN Commercial farming Commercial forestry Tourism on and adjacent to MRA Mining (proposed Fuleni Anthracite Project or others) Potential co-existence of viable land use alternatives

The viability of the alternative land uses together with the rationale behind this are summarized in Table 97 and discussed in the following sections. Table 97: Viability of alternative land uses

Land Use

Rationale

Viability

Communities with communal grazing and subsistence farming

Status Quo (No-Go Option)

√

Expansion of HiP (conservation)

Impact on communal grazing Potential resettlement, depending on extent of expansion

√

Commercial farming

Crop production potential too low Water restrictions

X

Commercial forestry

Soils not conducive to forestry Water restrictions

X

Tourism

Area inhabited and fairly degraded Infrastructure restrictions Possibility with HiP

X

Mining

Mineral resource proven Resettlement required Water / Environmental / Social / Conservation restrictions

√

Co-existence (combination of viable land uses)

Water / Environmental / Social / Conservation restrictions Authority & IAP buy-in required

?

389 | P a g e

6.1.1 STATUS QUO Current economic activities in the area include:  

Subsistence farming; and Local businesses, including brick making, retail (shops and shebeens) and in small enterprises such as carpentry, sewing, baking.

6.1.1.1 Subsistence farming Despite the fact that some areas in the Mfolozi LM have a decent agricultural potential, land in the Ingonyama Trust areas such as where the mine is proposed are not farmed to the extent that they could be. They are mainly used at a subsistence or traditional agricultural level. Agriculture is regarded as a potential growth sector in the district and as a means of alleviating poverty. Some of the negative effects of the mine footprint on crops and grazing include:      

Loss of grazing land Loss of arable land (25 arable fields, 35 ha) Loss of vegetable gardens Loss of access to medicinal plants Loss of access to firewood Loss of livestock drinking dam (1 dam)

These losses have been estimated in the economic impact model and an estimate of R 4 million per year in lost revenue for grazing, vegetable gardens and access to other services is estimated. 6.1.1.2 Local Businesses Some small businesses and homesteads will need to be relocated in order for the mine to be developed and these are discussed in detail in the Social Impact Assessment (ANNEX-12). Whilst removals are difficult and unsettling for residents they have positive economic impacts as long as the recipients of the new homes are not placed in a worse position than they were previously then the long term effects are positive. Things to consider which may negatively affect residents include:    

Location relative to sources of electricity and water Location of transport links and roads Location of schools and places of work Location of health care facilities, shops and pension payout points

Relocating businesses is trickier as they must not be moved from their existing market; however the huge increase in local labour force spending will assist local shop owners and transport operators. The multiplier effect of the mine will impact on them positively.

6.1.2 COMMERCIAL FARMING / FORESTRY The sugar cane and forestry/timber sectors are currently the major economic sectors in the region. Despite the fact that some areas in the Mfolozi LM have a decent agricultural potential, land in the Ingonyama Trust areas such as where the mine is proposed are not farmed to the extent that they could be. They are mainly 390 | P a g e

used at a subsistence or traditional agricultural level. Agriculture is regarded as a potential growth sector in the district and as a means of alleviating poverty. However, the soil specialist report (ANNEX-2) indicated that the agricultural potential within the Fuleni Anthracite Project footprint is low and can mainly support grazing and to a small extent, some subsistence farming. The lack of lack of water and infrastructure and remoteness of the area further renders the area not suitable for commercial farming, including forestry/timber production.

6.1.3 TOURISM 6.1.3.1 Local tourism Whilst there is no current tourism in the mining area and very little in the local municipality as a whole, there is a lot of potential. With the HiP adjacent to the site and a steady stream of tourists travelling up the N2 the opportunities are vast and need to be explored. The nature of the Fuleni Anthracite Project is such that one can expect the number of business tourists visiting nearby tourist accommodation to increase. A portion of these business tourists may be from head office, visiting the site, or simply employees staying overnight rather than driving back to their homes in Richards Bay. Rather than being regarded as a negative impact, an influx of potential business tourists should be seen as a positive impact for the area. Business tourism tends to stabilise tourism demand over a typical year as it provides occupancy during the weekand in months outside of school holiday, rather than at weekends and in months during school holidays. Since there are no tourist facilities in the immediate Fuleni Anthracite Project area, this business segment of tourism demand will assist facilities in Kwambonambi and Mfolozi LM stay viable during quiet periods. The overall significance of this positive impact is regarded as low to moderate as the number of business tourists visiting the area as a result of the development is not known. 6.1.3.2 HiP and iMfolozi Wilderness Area A major potential impact of the proposed Fuleni Anthracite Project is on the tourism industry in HiP and the iMfolozi Wilderness Area. The existence of the mine will negatively affect the sense of place of this established tourism destination. It is difficult to explain or quantify the concept of ‘sense of place’ yet this is a very important concept for tourists. Broadly speaking, a ‘sense of place’ refers to the subjective emotional feeling one attaches to a destination. This can be informed by a number of physical and metaphysical attributes. The most general ‘sense of place’ for HiP is one of a tranquil game reserve set in a pristine and beautiful environment where animals abound. Key attributes supporting this ‘sense of place’ are that the reserve is quiet, relaxing, ecologically well preserved and tourist friendly. For this reason HiP attracts a large number of eco-tourists, adventurers and birders. The Fuleni Anthracite Project will certainly, to varying degrees, impact the HiP’s sense of place by way of visual, noise and dust impacts as well as by generally making the area surrounding the park busier. The GIS sensitivity analysis for this study suggests a high zone of influence over parts of the wilderness area. The medium influence over large portions of the pristine wilderness area could have significant impacts on wilderness tourism, with people traversing though these areas no longer experiencing the true ‘wilderness’ 391 | P a g e

experience as they were seeking. The medium and low impacts are visual. The mining stockpiles will be visible from parts of the reserve frequented by large number of tourists. It is more in the metaphysical sense or abstract sense; however, that mining may negatively impact on ecotourism ‘sense of place’ of the area. The notion that the game reserve will now have a large industrial mining operation on its border will impact greatly on the environmentally-friendly characteristic of the park and in particular the iMfolozi Wilderness Area and eco-tourists are likely to feel that the environmental tourism product previously offered by the reserve will be degraded. Similarly the ‘sense’ of tranquility may also be eroded. The degree to which this change in ‘sense of place’ negatively affects the number of eco-tourists who will visit the reserve is open to speculation. It is regarded as unlikely that the number of tourists visiting the HiP will be much diminished. This is because the main tourist areas of the reserve are more than 12 km from the proposed development. Also the reserve attracts large numbers of people seeking only the “Big 5” experience. There are many existing sites within the reserve where human settlements, agriculture, overgrazing and industrial activity can be viewed in the distance. It is therefore not anticipated that any large loss of self drive and safari vehicle tourist revenue will result from the development being located alongside the reserve. The main loss of potential tourist revenue is from the loss of the ‘sense of wilderness’ experienced on the Wilderness Trail. This intrinsic value of the Wilderness Area to South Africans must also not be ignored. However, the very nature of the wilderness area means that it does not attract a large amount of tourists to that part of the parkIt is the estimate of this team that approximately 1000 people participate in a wilderness trail experience every year and spend approximately R3000 per trip. This is based on 10 people per trip, 2-3 trips per week for 9 months of the year. A worst case scenario would be the complete de-designation of the HiP’s wilderness status as a direct result of the mine’s presence and subsequent impacts. The de-designation of the HiP as a result of the proposed mine potentially has international ramifications in terms of wilderness conservation and will highlight on an international stage the loss of conservation status of natural resources in South Africa. It is not possible to quantify this potential impact in terms of economic value.

6.1.4 CONSERVATION Three issues are of importance here, namely:   

Potential expansion of the HiP Impact on animal species in the HiP Potential increase in poaching activities

6.1.4.1 Potential Expansion of the HiP The proposed Fuleni Anthracite Project may have an impact on the planned HiP expansion onto Traditional Authority land. Three Community Nature Reserves were recently declared directly to the west of the MRA area, in the Ntambanana Local Municipality (KZN Municipal Notice No. 42 of 12 June 2014), namely:  

Somopho Community Nature Reserve on a portion of Portion 1 of Fuleni Reserve No. 14375 Obuka Community Nature Reserve on a portion of Reserve No. 11 No. 15831 392 | P a g e



Mandlakazi Community Nature Reserve on a portion of Portion 11 of Reserve No. 12 No. 15832

According to the KZN Spatial Development Framework, the Fuleni Anthracite Project area is not earmarked for conservation, rather within identified areas of Economic Support and Social Need. The project area is neighboured to the north by Biodiversity priority areas and to the south by further Areas of Economic support. However, in their comments on the draft Scoping Report dated 9 May 2014 Ezemvelo KZN Wildlife indicated that the MRA area falls within a protected area expansion known as the “iMfolozi Valley Project Area” as shown in Figure 154. It is noted that the iMfolozi Valley Project Area was not included in the areas listed in KZN Municipal Notice No. 42 of 12 June 2014.

Figure 154: Map showing ground-truthed geographical possibilities for protected area expansion (iMfolozi Valley Project Area) (EKZN)

6.1.4.2 Impact on animal species Due to the proximity of the proposed mine to the HiP, it is considered likely that these activities will have an impact on the wildlife of the reserve and specifically upon species within the wilderness areas. Seismic activity or ground vibrations are of specific concern, as these vibrations may result in a change in area utilisation and behaviour (Elephants, Rhinos and Vultures) as well as increased stress which may lead to mortality (Nile Crocodiles). The development of the mine may affect the current breeding success rates experienced in the wilderness areas by black rhino, as well as interfere with the current vulture nesting sites located in the southern sections of the wilderness area. 393 | P a g e

Although some research and case studies are available, as presented in a number of the specialist reports, it is still not completely certain how the animals will respond to seismic signals and blast noises, certainly as a foreign and unknown source it could cause a degree of disturbance, temporarily or long term. The mine’s seismic output, even if undeterring to the elephants, may result in a loss or disturbance in seismic communication between elephants themselves and between local herds, as these communication signals may be disrupted or eliminated completely when encountering the counter seismic waves that are being produced by the mine. Due to this disturbance, it is possible that the elephants will selectively avoid the areas of the HiP that are adjacent to the mine. This change in area utilisation of the elephants may place a higher ecological pressure on the remaining areas of the HiP, as the elephants will not utilise the whole reserve effectively. This may result in some areas being overutilised, resulting in the possible revision of elephant and veld management plans, which could negatively affect elephant and other species populations within the HiP. 6.1.4.3 Increased Poaching With the development of the mine comes a marked increase of human presence. This increase places an increased security risk on the reserve, as poachers, both subsistence and commercial, will have easier access to the Wilderness Area, and will be less conspicuous amongst the new migrant workers and job seekers that inevitably move in when a new mine is developed. It is considered likely that there will be a marked increase in the poaching of rhinos in the Wilderness Area should the mine be commissioned. It is also likely that subsistence or small scale poaching for the bush meat trade will also increase, due to the increased number of people the mine would attract. It is however suggested that it is possible to combat the perceived increase in poaching activities by means of increasing mine security patrols along the border where the MRA meets the HiP. Strict disciplinary actions can be put into place by the mine with regards to poaching of any kind, and vehicle and people movement can be limited along the border of the HiP, with the exception of necessary personnel and security forces. It is not possible at this stage to accurately estimate in economic terms the potential negative impact on conservation in the area and further work is required in close consultation with Ezemvelo KZN Wildlife. Such negative impacts could include the impact on tourism for the HiP, potential loss of game through increased poaching and decreased fertility, etc.

6.2

MACRO-ECONOMIC IMPACT ANALYSIS

Graham Muller Associates conducted an investigation into the economic feasibility and the economic impacts induced by the mining operations at the Fuleni Anthracite Project in relation to existing land use activities. In general, the macro-economic impact analysis shows a positive picture for both the local economic impacts as well as the South African economy.

394 | P a g e

Table 98: Comparison of the local economic activities baseline and estimated negative impact of the proposed mine (2015 prices) Type of Spend Type of Impact Mine Negative* Type of Spend Type of Impact Mine Negative* Average Additional GVA per year (25 years) Average Sustainable Employment Opportunities (25 years) CAPEX GDP Direct R67.71 N/A CAPEX** Direct 148 N/A (Rand Employment Indirect/Induced R60.07 N/A Indirect/Induced 242 N/A millions) Total R127.82 N/A Total 390 N/A OPEX GDP Direct R214.34 - R4.30 OPEX Direct 392 - 27 (Rand Employment Indirect/Induced R172.17 - R4.48 Indirect/Induced 697 - 18 millions) Total R386.51 - R8.78 Total 1 079 - 45 *Full assessment of negative impacts and loss has not been made and as such are not indicative of the full potential negative impact of the investment. Totals may not add up due to rounding.

The table splits the impact into impact from capital investment and impact from operating activities. Since construction** and other short-term activities are more likely to shift employment than create new employment, real sustainable employment is measured on the impact of the on-going operating activities. All new investment will have impact on GDP however. From the above table it appears that the impact of the mine on South Africa is R386.51 million per year total GDP from operating activities, R127.82 million per year from capital investment and construction, and sustains 1 079 employment opportunities of which 392 are direct (the number direct jobs estimated from the investment proposal is 367 sustainable opportunities, averaged over 25 years). The negative impact represented by the table above is based on the economic estimates of existing land uses in the area (where available and/or possible to estimate) as discussed in the previous section. Therefore the impact on the loss of farmland on the site (35 hectares), if it were to be used for agriculture (farming potatoes was chosen as this is a high value product and a ‘best case’ scenario) and the estimated impact on the Wilderness Trails within HiP. According to this estimate, the mine will cost the local economy at least R8.78 million in total GDP on average per year, of which R4.30 million per year is direct. The total projected employment losses are 45 sustainable employment opportunities, of which 27 are direct. Although this methodology attempts to arrive at the total net impact of the investment on the local economy, without a more complete engagement and input with key stakeholders such as Ezemvelo KZN Wildlife, it may not cover the full negative impact of the investment. Graham Muller Associates concluded as follow: 



The Fuleni Anthracite Project is a large project and has a myriad of impacts both positive and negative. Groups impacted will include the unemployed in the local economy; building contractors; subsistence farmers in the Fuleni area; and tourism establishment owners and eco-tourists. Positive (partial) impacts on the local economy: The Fuleni project, with expenditure of R127m, is expected to contribute significantly to GDP in the construction phase, though this will be spread over the years in which construction takes place. The mine will directly create at nearly 400 jobs in the district and a further 600 indirectly in the rest of the national economy. The impact of the operational activities of the Fuleni Mining project will be additional GDP of nearly R400m per annum. 395 | P a g e









Negative Impact on local tourism and residents: The economic impact on the neighbouring HiP is limited by the fact that most impacts are moderate to low and the area of the reserve where impacts may be felt most severely is not the core tourist area of the park. It is therefore recommended that financial compensation be considered in those cases where impact and alternative forms of mitigation prove unworkable. Relative to the economic value forecast to be added by the mining operations the financial mitigation that would be involved will be relatively modest. Adverse impacts resulting from heavy mining vehicles on rural roads need to be mitigated through the construction of dedicated roads for the use of mining vehicles. Where residents are negatively affected compensation must be provided. The mining footprint area could be, and currently is, used for other economic activities. The lost opportunities of alternative land use which the mine will eliminate are not significant relative to the benefits of the mining the area. The low agricultural potential, lack of water and infrastructure and remoteness of the area make mining the best option. Mining will provide jobs and income to the local community and the environmental offset for the loss of land will provide surrounding areas with a capital injection needed to create new parks, game reserves and sustainable tourism activities. While the Fuleni Project is expected to have some negative economic impacts, the negative economic impact on the district of the project not occurring will, by virtue of output and job losses, far eclipse any other negative economic externalities. As such the mining project must be regarded as being of net benefit to the district economy. Mitigation measures for negative externality impacts associated with the mining, in order to maximise the net positive impact of the proposed mining project for the district economy, are as follow:

Objective Managing dust pollution

Monitor noise pollution Devaluation of property adjacent to mine Compensation for possible loss of accreditation of HluhluweImfolozi Wilderness Area as ‘Wilderness’ Heavy vehicle restrictions on neighbouring farms Managing dust pollution Limiting the poaching of labour from Ezemvelo KZN Wildlife and other mines Lessening the visual impact of mining Maximising the benefit of an influx of people Ensuring access to the Ezemvelo KZN Wildlife camps and bases

Measures, criteria or principles Dust pollution needs to be monitored by an independent assessor to establish the extent that it is a nuisance and a cost to neighbouring properties. If this proves true a financial mitigation needs to be negotiated with affected parties. If noise proves to be unbearable nuisance for people living on farms adjacent to mining activity at sites, the affected residents will need to be temporarily moved and compensated for the cost and inconvenience. Property prices will seriously be affected by the mining at and / or the construction of the stockpiles. A non-compulsory pre-mining market related offer should be made for the purchase of these properties. The potential loss of the Wilderness Area must be compensated for. A similarly farm, game reserve or piece of land must be converted to wilderness to compensate for the loss of approximately 50% of the pristine wilderness within Hluhluwe-Imfolozi which has been compromised by the coal mines location. All heavy vehicles must be restricted to designated routes and not permitted on roads. These routes must be maintained in good working order by the mine. Dust levels and the impact thereof need to be monitored in the Siyaya Coastal Park. An adequate buffer of trees needs to be planted on the town’s southern periphery. Recruit new employees from the large pool of unemployed within the traditional authority A line of trees should be planted alongside the stockpiles and pits screening the mining operations on all sides. Fuleni Coal Mine should, where possible, support local accommodation establishments when hosting visitors from out of town. Provide a servitude enabling Ezemvelo KZN Wildlife to access the isolated parts of the Hluhluwe-Imfolozi bordering the mine Maintain manage and secure the border fence between the mine and Hluhluwe-

396 | P a g e

Objective

Supporting eco-tourism development in HluhluweImfolozi as a way of offsetting any losses due to changes in ‘sense of place’ Encouraging educational tourism at the Fuleni site

6.3

Measures, criteria or principles Imfolozi to ensure no animals enter the mine and no humans use the mine to enter the park for any non sanctioned reasons. Financially compensate Hluhluwe-Imfolozi for loss of tourism revenue on the Wilderness Trails Financially support the anti-poaching initiatives of Hluhluwe-Imfolozi. Financially support the upgrade of the roads in the Hluhluwe-Imfolozi. Sponsor the extension of Hluhluwe-Imfolozi to offset the mining footprint and compensate for loss of Wilderness Offer educational tours to school groups describing the mining process and the importance of nature conservation.

POTENTIAL FOR CO-EXISTENCE

In conclusion, the overarching impacts that the mine will impose upon the HiP and iMfolozi Wilderness Area are far reaching and as of yet not definitive. What is known is that the mine is likely to have a negative impact on the wilderness area, the biodiversity and species conservation, with the possible resultant loss of the HiPs wilderness status. Unless it is possible to mitigate impacts in such a way as to support the adjacent land use as functional wilderness, or come to an agreement with EKZN for potential environmental offsets and compensation as proposed by Graham Muller Associates to compensate for the loss of Wilderness, co-existence may pose to be very difficult to achieve.

397 | P a g e

DEVELOPMENT ALTERNATIVES

6.4

Infrastructure to support the Fuleni Anthracite Project mining activities has been laid out and engineered to best suit the topography and mining pit layouts, with the least possible impact on existing homesteads and villages, and is described in Section 4 of this report.

6.4.1 MINE SITE LOCATION It is important to note that Ibutho was granted a prospecting right on the farm Fuleni Reserve No. 14375. No site location alternatives have been considered as mining can only be undertaken in areas where economically mineable resources occur. This area was established through extensive prospecting and geological modelling over a number of years:  

Prospecting commenced in 2009, including ground mapping, aerial geophysical surveys and core drilling (234 boreholes drilled). Concept and feasibilities have been completed, identifying an extractable anthracite resource of 40 million tonnes in the area of the proposed mining footprint.

6.4.2 MINING METHODOLOGY Apart from the No-Go Option, three alternatives were evaluated in respect of the mining methodology, namely:   

Opencast only Combination opencast & underground Underground only

Selection of a mining method is always dictated by the ore-body or resource, although from an environmental perspective, underground mining would be the most suitable as this would limit the surface disturbance and impact on the biodiversity of the area. However, a large portion of the resource will be lost due to the safety risks associated with mining of shallow resources. A combined mining plan including both opencast and underground mining was thus opted for in order to optimize the mineral resource utilization. Opencast allows for in-pit disposal of the mine residue (discard and slurry filter cake) which is positive in terms of groundwater quality management, visual impact (no surface dumps) and the general biodiversity of the area.

6.4.3 LOCATION OF FULENI CHPP At the commencement of the investigations, 4 alternative locations for the beneficiation area were identified. These locations were selected on the basis of topography, distance from nearest dwellings, contiguous available area, distance from proposed open cast pits, storm water catchments and distance from product delivery route.  

Alternative A: Alternative A was positioned to the West of Pit 4 and was discarded due to its proximity to the National Park boundary. Alternative B: Alternative B was positioned to the South-East of Pit 3 and was discarded due to the site falling within an ecologically sensitive area. 398 | P a g e

 

Alternative C: Alternative C was positioned to the East of Pit 4 and was discarded because it would entail significant relocation of the local community. Alternative D: Alternative D is the site selected due to the fact that it requires no relocation of homesteads, it has a minimum impact on the sensitive areas and requires limited storm water management measures as a result of the topography.

Figure 155: Alternative locations investigated for the Fuleni CHPP

6.4.4 PRODUCT HAULAGE / MINE ACCESS ROUTE Six potential routes were identified. The six routes were evaluated against a matrix of selection criteria, which included:       

Environmental and safety issues; Route distances – the evaluation differentiated between national roads, existing surfaced (tar) roads, existing gravel roads to be upgraded, and new gravel roads; Construction work required; Estimated capital cost; Major stream crossings; Advantages of each route; and Disadvantages of and risks associated with each route.

399 | P a g e

Figure 156: Alternative routes for product haulage

During the Pre-Feasibility Prodelko recommended that Routes 1 to 3 and Route 6 be eliminated for a number of engineering and other reasons, and that feasibility design work be undertaken for Routes 4 and 5. 



Route 4 intersects with the N2 National Road at Kwambonambi and follows an existing tar road in a north-western direction for approximately 6.3 km. It then turns northward towards the mine site. This section of the road will be approximately 21.42 km long and have a gravel surface, of which 18.45 km will be constructed by upgrading existing gravel roads and approximately 2.97 km will be constructed as a new road. The tarred section of this route requires no upgrading. It is expected, though, that Ibutho will have to contribute towards the maintenance of this section of road once it commences mining operations. It can be assumed that this road has not been designed and constructed to carry mine haul traffic. Its design life will be reduced significantly by such traffic. The risk that Ibutho will be held responsible for substantial repair and reconstruction work to this road is therefore expected to be a real possibility. The intersection of this road with the N2 exists, and it also requires no upgrading. The first 2.23 km and the last 0.72 km of this section of tar road traverses residential areas, whilst the remaining 3.31 km traverses agricultural land. Route 5 follows the N2 National Road from the Kwambonambi off-ramp northward for a distance of approximately 15.63 km to an existing off-ramp located approximately 1.6 km south of the bridge of the N2 over the Mfolozi River. From the off-ramp the route turns westward towards the mine site. This section of the road will be approximately 20.87 km long and have a gravel surface, of which 15.70 km will be constructed by upgrading existing gravel roads and approximately 5.17 km will be constructed as a new road. The entire length of the road is sparsely populated, with a section of approximately 2 km that is somewhat more densely populated. 400 | P a g e

For both options the existing gravel roads will mostly require complete reconstruction before it can be used by Ibutho for haulage purposes, because of its present horizontal and vertical alignment, inadequate road width, position of existing storm water channels alongside these roads, required road pavement and quality of existing surface gravels. The selected route selected was Route 5, as shown in Figure 157. The salient information used to compare the two routes is summarised below (Prodelko, 2014).

401 | P a g e

Figure 157: Selected Mine Access Route (Route 5)

6.4.5 WATER SOURCES The following water sources have been investigated:   





Direct abstraction from the Mfolozi River: The Mfolozi River is a water-stressed river and it is unlikely that the DWS will grant a permit to abstract water directly from the river. Boreholes: From the various geotechnical investigations it was shown that there is little likelihood of finding sufficient underground water for the mine. Off-channel storage from the Mfolozi River: Off-channel storage utilising flood water from the Mfolozi River. A desktop study revealed that the topography of the area did not lend itself to any viable or economical solution using this idea. Supply dam on the Mvamanzi River: The Mvamanzi River, which passes about 1 km south of the plant area and flows into the Mfolozi River, appears to be a viable source if some storage is provided. The position of the Supply Dam is shown in Figure 81 and Figure 158. In addition to the above, an additional source of water is the rainfall falling on the site, together with the re-use of water draining from the site. Treated sewage effluent will also be recycled via the Polcon Dams.

Two meetings were held with the DWS, one with the National Office in Pretoria on 17 July 2013 and one with the Durban Regional Office on 12 November 2013. DWS sees the in-stream storage dam on the Mvamanzi River as a viable option, provided that the siltation could be managed. They also reiterated that 402 | P a g e

the impact on the downstream users and the Ecological Reserve will need to be determined (removal of surface runoff from the system) prior to a final decision.

6.4.6 STOCKPILE PLACEMENT A number of overburden and topsoil stockpiles are required to facilitate mining, as shown Figure 158. From this figure it is clear that the majority of stockpiles are placed to the north-west of the mining footprint, the main reasons being:  

The area is not populated, thus by placing the stockpiles in this area, the social impacts are limited, apart from the loss in grazing land. The stockpiles will act as a visual and noise barrier between the mining operations and the sensitive HiP and wilderness area.

The alternative is to place the stockpiles to the south of the mining footprint, which will have a larger impact on:  

Increased number of households needed to be relocated, specifically in the Ocilwane and Ntuthunga 2 communities. The Mvamanzi River and downstream Mvamanzi Pan system due to the close proximity of these stockpiles to the sensitive water resources.

403 | P a g e

Figure 158: Opencast pits and stockpiles in relation to the adjacent communities

404 | P a g e

6.4.7 MINE RESIDUE MANAGEMENT 6.4.7.1 Slurry Management Two options were evaluated:  

Surface slurry ponds Inclusion of a filter press within the system

The inclusion of a filter press within the process would facilitate increased recycling of water, reduce the risk of spillages and acid-mine drainage and limit the impact on air quality as the residue will be consolidated. Thus, even though this would mean a higher capital cost input, from an environmental perspective this is the preferred option. 6.4.7.2 Discard Management Three options were evaluated for the management of the mine residue (discard and slurry) associated with the proposed project. Two surface facilities were looked at, namely surface discard dumps and slurry facilities and a co-disposal facility catering for both. The third option that was evaluated is in-pit disposal of mine residue during rehabilitation of the opencast pits. From a groundwater perspective, the in-pit disposal is the option that would (potentially) cause the least impact owing to the fact that the acid-forming residue could be placed at the bottom of the pit, allowing the residue to be inundated with water. This would reduce the potential for oxidation and the formation of acid-mine drainage. In-pit disposal would also facilitate a free-draining final profile which from a visual and end-land use perspective is the preferred option. Surface residue facilities would have a huge visual impact as well as long-term maintenance issues. Due to constraints in the mining schedule and the bulking factor of the overburden, a temporary discards stockpile will be constructed at the plant area to accommodate the surplus discard until such time as sufficient pit space is available for in-pit disposal.

405 | P a g e

7 LIST OF SIGNIFICANT IMPACTS AND MITIGATION MEASURES CONCERNS RAISED BY IAPS

7.1

7.1.1 STAKEHOLDER COMMENTS 7.1.1.1 Comments by Government Departments   

        

 

Compliance with legislation, application for all relevant licenses must be done in advance. No development can take place without all licenses. Early on planning to ensure Government planning is in line with implementation of the project and the establishment of a Governmental Technical Task Team prior to development commencing. If an impact on households, schools, clinics and agricultural land cannot be avoided, the various relevant Departments would need to know how resettlement will be scheduled over the life of mine. This will ensure that internal planning is done in advance. Secondary transport / traffic impacts must be considered, i.e. safety of pedestrians, Emergency Medical Services access. Households affected by resettlement must be consulted in terms of the host area options available. Development can stimulate economic growth in the area, which is known to struggle with high unemployment rates, illiteracy, low educational performance and poverty. Employment and skills development must be focused on the local people and consideration must be given to training facilities and services in the KwaZulu Natal area. Proximity to and impact on the protected HiP and Wilderness area, and associated buffer zones, specifically in respect of noise, dust, lighting, visual exposure and sense of place. Impact the mine will have on future growth and expansion plans for the HiP, as well as proposed corridors to link neighbouring reserves. Potential impact on the HiP must be quantified, sensitivity mapping concluded from the specialist studies and then buffer zones determined and agreed with EKZN. Impact on the catchment water balance and water quality, with specific mention of the potential impact on the downstream iSimangaliso WHS. Increased sedimentation risks due to the large scale clearing of vegetation cover and its potential impact on sensitive downstream aquatic habitats in the Mfolozi River catchment, with specific mention of the Mvamanzi pan and St Lucia Lake. Potential impact on the iSimangaliso Wetland Park and WHS must be investigated and further engagements with the Park once specialist studies are complete and impacts are determined. Increased pressure on existing community services and facilities such as clinics, schools, water, and electricity.

406 | P a g e

7.1.1.2 Comments by Environmental and Community Advocacy Groups, NGO’s and Environmental Concerned Groups 



   



Overall ecology of the area: o How mining practices may have a detrimental effect on the ecology and species composition of the areas surrounding the mining area and specifically RDL and TOPS listed species that utilise the area, either permanently or periodically; o How mining practices may affect faunal behavioural patterns, especially of those species sensitive to subsonic and ground vibrations, in the areas surrounding the mine, with special mention to those species present in the neighbouring HiP; o Impacts on migratory movements and ecological corridors and biodiversity linkages between upstream habitats such as the HiP and the downstream coastal habitats; o Impacts from alien vegetation and other edge effects; o Rhino conservation and increased poaching risks. Tourism and how it will be affected in terms of: o Noise and visual impacts, with special emphasis on wilderness trails and wildlife safaris that are conducted in the southern sections of the HiP; o Overall impact on all aspects of tourism in the area and the HiP. Proximity to and impact on the protected HiP and Wilderness area, and associated buffer zones, specifically in respect of noise, dust, lighting, visual exposure and sense of place. Impact the mine will have on future growth and expansion plans for the HiP, as well as proposed corridors to link neighbouring reserves. Impact on the catchment water balance and water quality, with specific mention of the potential impact on the downstream iSimangaliso WHS. Increased sedimentation risks due to the large scale clearing of vegetation cover and its potential impact on sensitive downstream aquatic habitats in the Mfolozi River catchment, with specific mention of the Mvamanzi pan and St Lucia Lake. Level of consultation with affected communities and the Ingonyama Trust Board.

7.1.1.3 Comments by the affected and neighbouring communities              

Disruption and displacement of households in close proximity to the proposed mining footprint. Potential resettlement – how will it be done, host areas, replacement of all assets. Disruption of social networks and cultural believes. Community livelihood, e.g. loss of grazing land / arable plots. Impact on burial sites and cultural / heritage sites of importance. The impact on the livelihood of the community during the decommissioning phase. Increased strain on infrastructure / water demand. Health, security and social issues. Blasting damages to houses. Non-delivery on promises of employment and skills development. Job opportunities specifically for the Youth. Skills development opportunities and Bursaries for the children of the area. Local Economic Development projects (SLP). Local procurement and SMME opportunities.

407 | P a g e

For a complete list of comments raised, please refer to One-on-one engagement records (ANNEX-1.18), minutes (ANNEX-1.11 to 1.17) and the Comments and Response Report (ANNEX-1.22 and 1.23). 7.1.1.4 Objections A total of 527 objections have been received, please refer to ANNEX-1.24 for a list of objections received.

7.1.2 PERCEPTIONS OF COMMUNITY BASED ON THE SOCIAL SURVEY The graphs below show the perceptions of the Ntuthunga 1&2 and Novunula communities, who participated in the Social / Household Survey, on the Fuleni Anthracite Project. 

Awareness

Coal mining activity awareness

0.0%



10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0%

Aware: Not aware: Did not respond:

Knowledge about Ibutho

Ibutho Coal Mining Company

0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0% 45.0% 50.0%

Do not know Ibutho Coal: Did not respond:

Expectancy with regards to benefits

Feeling's of the communty regards benifitting from the coal mining activity



Know of Ibutho Coal

Did not respond: Will not benifitt: Will benifitt: 0.0%

10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0%

408 | P a g e

Potential benefits

Views on how the community will benefit



Infrastructure / development:

Employment:

0.0%



Support

Community support for coal mining in their area

0.0%



10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0%

10.0%

20.0%

30.0%

Support mining:

40.0%

50.0%

60.0%

70.0%

63.8%

Do not support mining:

12.0%

Did not respond:

24.2%

Concerns Livestock & grazing affected:

Communities first priority listing of concerns

Employment issues: Affect electricity supply: Crime: Development of malls: Education: Noise: Bridges: Dams: Home cracking (Mining earth tremors): Illness: Relocation of homes: Water Pollution: Transport: Air pollution: 0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0% 45.0%

409 | P a g e

Community concerns priorities listed as a % average of all 3 priorities



Priorities Livestock & grazing affected: Employment issues: Affect electricity supply: Crime: Development of malls: Education: Noise: Bridges: Dams: Home cracking (Mining earth tremors): Illness: Relocation of homes: Water Pollution: Transport: Air pollution: 0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

The survey revealed that although the majority of people in the project area are in support of the mining activity, almost all communities raised similar concerns about the proposed mine and its effects on their livelihood. These include the following:        

Air pollution Water Pollution Relocation of homes Illnesses Cracks to their home structures (due to mining earth tremors/blasting) Noise Increase in crime Livestock & grazing affected

410 | P a g e

7.2

ENVIRONMENTAL IMPACTS AND MITIGATION

Sensitive Receptor Biophysical Environment

Environmental Aspect Soils

Biophysical Environment

Soils

Biophysical Environment

Soils

Potential Impact

Mitigation Measures

Impedance of a stockpile is envisaged to cover 1 ha of the soils of the Clovelly soil form, which is of medium agricultural potential Impact on hydropedological functioning of the deep Arcadia soils found in and around stream channels and preferential water flow channels

Reposition stockpile to avoid the Clovelly soil form.

Loss of soil depth (volume), fertility and organic carbon content



It is doubtful that the areas will ever function in the same manner as is presently the case from a hydropedological perspective. An alternative to the traditional approach to rehabilitation is proposed, i.e. to implement a network of constructed wetland systems (stabilised using gabions, swales and berms) in the areas where the open pits are to be filled in is envisaged. This will minimise erosion, ensure that water is kept in the vadose zone, lead to plant species diversity and restore some sort of grazing capacity to the land.

 

Biophysical Environment

Soils

Biophysical Environment

Soils

Possible chemical pollution of soil through polluted water, stockpiling of material and/or spillages of chemicals and hazardous material Compaction, crusting and hard-setting of rehabilitated areas

Biophysical Environment

Soils

Erosion of stockpiles and cleared areas during mining

       

Biophysical Environment

Soils

Surface subsidence due to underground mining and/or pit subsidence impacting on the hydropedological functioning of

 

The available topsoil will be stripped prior to mining and placed directly (as far as practicably possible) on levelled spoils. All available topsoil areas will be seeded prior to the start of the rainy season to ensure maximum drainage from these areas of clean water back into the catchment system without excessive suspended solids. Soil analysis will be performed prior to seeding and the soil fertility rectified (if necessary) to facilitate vigorous growth. Organic fertilisers will be used as far as possible. Develop and implement hydrocarbon management procedure to prevent accidental spillages. Reclamation of soils in the event of accidental spillages. Soil analyses and amelioration during reclamation. Include further research on preventing these aspects in the rehabilitation trials. Selective stockpiling of soils as proposed by the soil specialist to prevent erosion. Erosion of stockpile material must be managed, e.g. slope and orientation of stockpile, movement of surface water. Implementation of appropriate storm water management structures to prevent uncontrolled runoff. Maintain appropriate safety factors to prevent subsidence due to pillar failure in the underground workings. Compaction of overburden and discards placed in the bottom of the pits

411 | P a g e

Sensitive Receptor

Biophysical Environment

Environmental Aspect Flora

Potential Impact the area Impact on sensitive floral habitat & diversity

Mitigation Measures to limit the potential for subsidence on the rehabilitated open pits.   



 



      Biophysical

Flora

Impact on species of conservation concern



Development of Biodiversity Action Plan (BAP) prior to construction. In areas included in the proposed mining plan, the natural vegetation will be retained as long as possible before topsoiling commences in order to limit dust and erosion. In areas not impacted by the mining activities, the natural vegetation will be maintained by implementing the following: burning programmes; rotational grazing programmes; alien vegetation eradication programme; and restricting vehicle movement to existing roads. An alien floral control plan must be designed and implemented in order to monitor and control alien floral recruitment in disturbed areas. Furthermore, it is strongly recommended that alien floral control is implemented by the mine in the wider MRA. The alien floral control plan must be implemented for a period of 5 years after decommissioning and closure. A reclamation plan will be implemented and updated on a regular basis. A nursery will be developed in conjunction with a suitably qualified specialist where indigenous/endemic plant species must be propagated with focus on rehabilitation to ensure sufficient plant material for reclamation. Rehabilitation trials will be undertaken from the commencement of construction in order to determine the efficiency of rehabilitation methods and the suitability of flora propagated in the nursery for rehabilitation. The nursery plan and rehabilitation plan will be continuously updated in accordance with the trial results in order to ensure that optimal rehabilitation measures are employed. No collection of firewood, RDL/Protected or medicinal floral species must be allowed by mining personnel. No illicit fires must be allowed during any phases of the proposed mining development. Illegal access will be limited to prevent illegal hunting and snaring of fauna in the area. An environmental awareness campaign will be implemented, both internally and externally (local communities). Initiate an ecological offset initiative together with the relevant stakeholders. A protected and RDL floral relocation, monitoring and management plan

412 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures

Environment 



   Biophysical Environment

Fauna

Impact on faunal habitat & diversity

 

   

Biophysical Environment

Fauna

Impact on species of conservation concern

 

will be designed and implemented by a suitably qualified specialist and should address all species which can be successfully rescued and relocated. During the surveying and site-pegging phase of surface infrastructure, all RDL/protected species which will be affected by surface infrastructure will be marked and where possible, relocated to suitable habitat surrounding the disturbance footprint. If relocation is impossible or any of the protected species are destroyed, 3 plants for every protected plant destroyed will be propagated in the nursery. Annual flora rescue operations will be undertaken during the growing season in the areas planned to be mined and/or disturbed within the next year. A rescue and relocation programme for fauna species will be developed and implemented with the assistance of specialists in this field. An environmental awareness campaign will be launched, both internally and externally (local communities). Development of Biodiversity Action Plan (BAP) prior to construction. Sensitive faunal habitat and associated buffer zones adjacent to footprint areas must be designated as No-Go areas and no mining vehicles, personnel, or any other mining related activities are to encroach upon these areas. No trapping, collecting or hunting of faunal species will be allowed during any phases of the proposed mining development. The mine will employ security personnel to monitor and secure the fence line of the HiP during all phases of mining in order to curb security and poaching risks to the HiP. All voids, or open pits will be fenced off in order to prevent faunal species falling into such features. Blasting will take place outside of times of increased faunal activity, especially dawn to mid-morning and mid-afternoon to dusk, and ideally during midday (12:00 to 14:00). A protected and RDL faunal relocation (with focus on Arachnids such as Harpactira gigas and Hadogenes sp.), monitoring and management plan will be designed and implemented by a suitably qualified specialist. During the surveying and site-pegging phase of surface infrastructure, all RDL/protected arachnid species which are found will be relocated to suitable habitat surrounding the disturbance footprint. The relocation process will be overseen by a suitable qualified specialist.

413 | P a g e

Sensitive Receptor Biophysical Environment

Environmental Aspect Fauna

Potential Impact

Mitigation Measures

Effect of blasting on sensitive fauna (elephants, crocodiles)



Biophysical Environment Biophysical Environment

Fauna

Effects of blasting on sensitive avifauna

Crocodiles: Pit 1 it must be considered a sensitive area due to its close proximity to the Mfolozi River. A single blast hole detonation process will be required from blasting in Pit 1 to ensure that ground vibration levels are kept below 13mm/s.  Elephants: Monitor behavior through research to determine potential short- and long-term effects on elephants and other sensitive faunal species. Air blast levels to be kept below 129 dB.

Fauna

Negative effect of lighting pollution on faunal species



Biophysical Environment

Fauna

Killing of animals and avifauna on the roads, especially nocturnal animals/birds

  

Biophysical Environment

Fauna

Power line impacts on avifauna in the area, with specific mention of the vultures

 

Biophysical Environment

Wetlands and Aquatic Systems

Loss of wetland and riparian habitat and ecological and sociocultural service provision



   

Lighting pollution and its effect on fauna (with special mention of invertebrates, bats and avifauna) will be effectively mitigated with the following guidelines in mind with due cognizance take of health and safety requirements: o Downward facing lights must be installed and limited to absolutely essential areas; o Lights must face a way from the HiP; and o Covers/light diffusers must be installed to lessen the intensity of illumination if at all possible. Maintaining vehicle speeds. Off-site hauling of product should be limited to between the hours of 06h00 to 20h00. Implementation of an Environmental Awareness Programme for trucking contractor. Power line will be designed in such a way that the impacts to birds will be minimized. The spacing between conductors, the height of the conductors above the ground and proximity to trees will be optimized. EWT and BLSA will be consulted during the final design and routing of the power line. Maintain a buffer zone of 100 m from the 1:100 year flood-line of major drainage lines (Mfolozi and Mvamanzi Rivers) to reduce impact on aquatic systems. Where necessary, re-position / re-align mining pits, stockpiles and infrastructure to avoid the 1:100 year flood-line plus a buffer zone of 100m at the major drainage lines (Mfolozi and Mvamanzi Rivers). No dumping of waste should take place within the riparian zone. If any spills occur, they should be immediately cleaned up. Implement alien vegetation control program within wetland areas with special mention of water loving tree species. Ongoing wetland monitoring to determine any deterioration in the

414 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures  

Biophysical Environment

Wetlands and Aquatic Systems

Impact on wetland hydrological function and sediment balance







Biophysical Environment

Wetlands and Aquatic Systems

Loss of aquatic habitat, biodiversity and sensitive taxa

Biophysical Environment

Surface Water

Impedance of flood-lines and water courses by placement of stockpiles, infrastructure and mining pits

Biophysical Environment

Surface Water

Reduction in MAR in Mfolozi River  0.06% of Mfolozi River catchment  1.26% of quaternary catchment W23A

    

Present Ecological State (PES) of the wetland systems. All affected riparian and wetland systems must be monitored for moisture stress and monitor all potentially affected riparian zones for changes in riparian vegetation structure. Biodiversity offset programmes should include wetland offsets where appropriate. Implementation of watercourse alterations that is stable in the long term, in that they mimic the naturally stable characteristics of flow within the current catchment. Engineering of stream and wetland crossings to ensure that they comply with DWA requirements in terms of limiting channeling of flow and increasing flow velocity. Any proposed design mitigation and methods will be evaluated by an appropriate wetland as well as a storm water specialist. During the construction and operational phases erosion berms will be installed on roadways to prevent gully formation and siltation of the wetland resources. The following points should serve to guide the placement of erosion berms: o Where the track has slope of less than 2%, berms every 50m should be installed; o Where the track slopes between 2% and 10%, berms every 25m should be installed; o Where the track slopes between 10%-15%, berms every 20m should be installed; and o Where the track has slope greater than 15%, berms every 10m should be installed.  Implementation of a biodiversity monitoring programme for early detection of potential impacts.  Water quality and aquatic monitoring to assess the suitability of the water to support aquatic life. Where necessary, re-position / re-align mining pits, stockpiles and infrastructure to avoid the 1:100 year flood-line plus a buffer zone of 100m at the major drainage lines (Mfolozi and Mvamanzi Rivers). Diversion of non-perennial streams around the open pits. Minimise the water demand and wastage of water. Re-use process water where possible. Minimise the loss of yield during the operational phase by: o Minimising the footprint of dirty areas as far as is practical. o Ensuring clean water from areas upslope of dirty areas is diverted

415 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures around the dirty areas. Continuous rehabilitation of opencast areas, according to a defined schedule to avoid rehabilitation backlogs. Design and install appropriate outlet structures to retard flow velocity. Construct energy dissipating structures along steep slopes. o

Biophysical Environment Biophysical Environment

Surface Water

Changes to peak flows in Mfolozi River and tributaries

 

Surface Water

Drying up of tributaries due to stream diversions



Biophysical Environment

Surface Water

Increased sediment loads due to canalization of water

Biophysical Environment

Surface Water

Increased sediment loads due to vegetation clearance and compaction

Biophysical

Surface Water

Increased sediment loads due to uncontrolled runoff from

All affected riparian and wetland systems must be monitored for moisture stress and monitor all potentially affected riparian zones for changes in riparian vegetation structure.  Evaluate the need for environmental releases to maintain sensitive tributaries that could be reinstated after mining.  Design and install appropriate outlet structures to retard flow velocity.  Construct energy dissipating structures along steep slopes.  Side slopes of earth berms / canals to be designed to 1:3 and protected & vegetated to prevent erosion. Adequate storm water management will be incorporated into the design of the proposed development throughout all phases in order to prevent erosion of topsoil and the loss of floral habitat. In this regard, special mention is made of:  Curtailment of sheet runoff from cleared areas, paved surfaces and access roads.  Slow down of runoff from paved surfaces by the strategic placement of berms.  Provision of berms and/or paddocks at overburden and topsoil stockpiles to contain runoff.  Stabilisation of any erosion in and around the stockpiles and infrastructure areas.  Construction of energy dissipating structures along steep slopes.  Final topsoiling and re-vegetation according to the rehabilitation plan.  All available topsoil areas will be seeded prior to the start of the rainy season to ensure maximum drainage from these areas of clean water back into the catchment system without excessive suspended solids.  Sediment controls should be installed and maintained along the site perimeter on all down-gradient sides of the construction. Temporary and/or permanent soil stabilisation measures should be applied immediately on all disturbed areas as grading progresses, and on all roadways. Sediment barriers may include sediment fences, berms, and straw wattles.  Provision of berms and/or paddocks at overburden and discards

416 | P a g e

Sensitive Receptor

Environmental Aspect

Environment

Potential Impact stockpiles and disturbed areas

Mitigation Measures stockpiles to contain runoff. Stabilisation of any erosion in and around the stockpiles and infrastructure areas.  Construction of energy dissipating structures along steep slopes.  Final topsoiling and re-vegetation according to the rehabilitation plan.  Appropriate geo-liners to be constructed for the stockpiles, depending on the waste classification of this material.  Provision of berms and/or paddocks at overburden and discards stockpiles to contain runoff.  Reuse of this water for dust suppression on and around the stockpile areas.  No dirty water runoff will be permitted to reach the wetland and riverine resources during the entire life of mine.  Separation of clean and dirty water through implementation of the SWMP.  Directing and containment of dirty water runoff to PCDs and providing silt traps.  Design dirty water management infrastructure for the 1:50 year flood event.  HDPE liners to be implemented at PCDs.  Strict control of sewage water treatment must take place and the sewage system should form part of the mine’s closed process water system.  Develop and implement hydrocarbon management procedure to prevent accidental spillages.  Bulk facilities and chemical stores to be concrete lined and bunded to a capacity of 110%.  Spillages must be cleaned up immediately in line with the Spill Management procedure. No interaction expected during the operational phase due to dewatering activities, thus no mitigation required. 

Biophysical Environment

Surface Water

Pollution as a result of leachate and runoff from stockpiles

Biophysical Environment

Surface Water

Pollution due to uncontrolled releases from the mining footprint and infrastructure areas

Biophysical Environment

Surface Water

Pollution as a result of accidental spillages of chemicals and hazardous material

Biophysical Environment Biophysical Environment

Surface Water

Impact on surface water quality as a result of groundwater interaction Lowering of groundwater levels indicating a cone of depression with a radius of ≈ 700m

Biophysical Environment

Groundwater

Groundwater

Effect on groundwater quality due to infiltration of poor quality water/effluent from wet sources (PCDs, etc)

   

Implementation of a monitoring programme to confirm impact predictions. Compensate or provide alternative water supply to affected groundwater users. Leachate formed in open pits will be pumped to the processing facility for re-use. Dirty water dams (PCDs) to be plastic lined (HDPE) to prevent

417 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures

Biophysical Environment

Groundwater

Effect on groundwater quality due to poor quality leachate generated through dry hazardous material / stockpiles

Communities

Land Use

Relocation of households and associated graves within 500 m radius from open pits (blasting)

Communities

Land Use

Loss of communal gardens and vegetable plots – 35 ha

Communities

Land Use

Loss of grazing – 1 750 ha (total footprint)

Communities

Land Use

Loss of access to natural resources

Communities

Groundwater (boreholes) Groundwater (boreholes) Groundwater (boreholes)

Mining through of user borehole FUL17

groundwater contamination. Dirty water canals in the infrastructure area to be concrete lined to prevent groundwater contamination.  Monitoring boreholes will be installed in appropriately selected sites prior to commencement of mining to detect changes in water quality and water levels with time.  Appropriate geo-liners to be constructed for the stockpiles, depending on the waste classification of this material.  Discards stockpile and stockpiling of any other carbonaceous material will be designed with a competent liner with a leachate collection system.  Stockpiles will be compacted and vegetated (where appropriate) as soon as possible to minimise infiltration.  Implement the avoidance principle where practicable.  Resettle remaining directly impacted households in line with the Resettlement, Compensation and Mitigation Strategy. Compensate and/or replace – refer to Resettlement, Compensation and Mitigation Strategy. Compensate and/or replace – refer to Resettlement, Compensation and Mitigation Strategy. Establishment of medicinal plant nursery. Replace drinking water dam at appropriate location. Monitoring the impact on livestock. Demarcated areas where fire wood can be collected that were cleared for the Construction Phase. Collaborate with local stakeholders in terms of regional planning to ensure certain areas are protected for tourism and hunting activities. Compensate or provide alternative supply to affected borehole owner.

Lowering of water levels of user borehole FUL21



Water quality impacts of user boreholes





Communities Communities



Embark on property specific investigations to determine the baseline of water use, yield and quality of all known boreholes in the area. These external boreholes will be included in the groundwater monitoring programme and monitored on a quarterly basis. If an impact is detected, further investigation will be done to determine the origin of the impact. If the impact is proved to have been caused by the Fuleni Anthracite Project, Ibutho Coal will enter into discussions with the borehole owners impacted regarding compensation and/or alternative water supply.

418 | P a g e

Communities

Environmental Aspect Air quality

Communities

Air quality

Sensitive Receptor

Potential Impact

Mitigation Measures

Expected dust fallout during construction is predicted to be relatively low, and will not exceed the National Standards for ambient air quality Expected particulate emission plumes indicate exceedences to both the PM10 and PM2.5 standards



Occupational Health and Safety Standards for construction are very strict in terms of respirable dust, and therefore the construction team will need to ensure dust levels are kept to a minimum.

  

Limit the area of operation to what is absolutely necessary. Rehabilitation should be performed on an on-going basis. During the pre-mining preparation of the area, ensure that only the bare minimum amount of vegetation is removed from the site. It is recommended that the natural vegetation, as far as possible, be left undisturbed to ensure there is ample ground cover. During the processing of material, the material should be kept damp to ensure the dust does not escape during the processing. Windshield (barriers) to be implemented between the mining operations and sensitive receptors. These barriers are typically large trees with good foliage coverage. The substitute of the wind barriers is a wind shield made from a prose material (shade cover). Develop an air quality management program (AQMP) which will provide the mine health, safety and environment person to report to the managers about the air quality impact the mine has on the surrounding environment. This AQMP should include monitoring schedules and can be used to determine if some mitigation measures are capable in reducing the emission effectively and to determine areas of concern. Set the speed limit for hauling vehicles and vehicles in general to 40 km/h and enforce the speed limits specified. Include speed-bumps to control the speed limits, also include a program of wet-suppression of the unpaved roads with major vehicle activity. Limit the load size of the vehicles to ensure the wind in transit does not pick up more dust that need be. Set the speed limit for hauling vehicles and vehicles in general to 40 km/h, reducing the speed limit over sections of the road where there is high pedestrian activity. Actively enforce the speed limits specified. Include speed-bumps to control the speed limits, also include a program of wet-suppression of the unpaved roads with major vehicle activity. All trucks leaving the site should be covered to ensure dust is not generated from the product being transported. All trucks leaving the site should be cleaned of excess dust, either through washing or air curtain, and all trailers should be covered to prevent dust when product is transported out of the mine area. The provision of paved road surfaces in high pedestrian activity sections

 



Communities

Air quality

Increased dust levels as a result of on-site hauling of ROM

  

Communities

Air quality

Increased dust levels along the access road due to increased traffic and large trucks

     

419 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures will reduce dust. If the busy pedestrian sections are not paved then regular routine road maintenance plan must be adhered to (as dictated by the daily traffic volumes).  Access road must be suitably maintained to limit erosion and dust pollution.  Implementation of Blasting Procedure and blast design guidelines.  Blasting should only be undertaken when wind speeds are below 12km/h (light breeze) Analysis shows that even during the worst case scenario, exposure will not exceed the WHO standards. No mitigation required. Ongoing methane monitoring to determine levels of methane released to the atmosphere. 

Communities

Air quality

Intermittent increase in dust levels due to blasting

Communities

Air quality

Communities

Air quality

Communities

Air quality

Communities

Air quality

Heavy metal exposure as a result of coal dust, impacting on community health Coal bed methane released from the coal bed during mining operations predicted to be 84 074 306 m³ for the LOM Increased particulate emission due to exhaust tailpipe emissions from vehicles Potential health risk to the surrounding communities as a result of elevated PM levels

Communities

Ambient noise

Communities

Ambient noise

Potential for noise impact during construction at sites in the immediate vicinity of the construction activity Elevated noise levels expected from the mining operation, in excess of the National standards for rural and suburban residential

 

Employ latest technology to reduce vehicle exhaust gas emissions. Use of low sulphur diesel.



Health impact is moderate to low as the pollutants generated by the mine are not in high or toxic concentrations.  Select a group of community members to monitor if there are any health effects. They will receive lung function testing prior to construction and thereafter on a regular basis. The monitoring programme will use the same people throughout the study and will include the elderly and disabled, children and youth to determine any adverse health effects.  Provide the necessary medical treatment and compensate community members, if the testing and monitoring shows that there are health effects caused by the mine. Construction to be restricted from 06h00 to 18h00 with no activities (or at least no noisy construction activities) at night. 



The latest technology incorporating maximum noise mitigation measures for components of the complex should be designed into the system. The noise mitigation measures will need to be designed and/or checked by an acoustical engineer in order to optimise the design parameters and ensure that the cost/benefit of the measure is optimised. When ordering plant and machinery, manufacturers should be requested to provide details of the sound power level. Where possible, those with the lowest sound power level (most quiet) should be selected.

420 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures  o

Communities

Ambient noise

Elevated noise levels expected along the access road due to increase in traffic and large trucks

Communities

Ambient noise

Noise disturbances / health effects caused by elevated noise levels

The design process is to consider, inter alia, the following aspects: The position and orientation of buildings, plant and stockpiles on the site. o The design of the buildings to minimise the transmission of noise from the inside to the outdoors. o The insulation of particularly noisy plant and equipment.  The stockpiles of spoil rock and overburden (berms) from the opencast pit excavations should, where possible, be used as interim or long-term noise attenuation barriers. Specifically such berms should be constructed (where necessary) around all six of the planned pits, and around the coal processing plant.  Use of low-noise generation plant and equipment.  Where possible, stationary noisy equipment (for example compressors, pumps) should be encapsulated in buildings, acoustic covers, screens or sheds. Specifically, the processing plant and conveyor drives should be housed in buildings.  Portable acoustic shields should be used in the case where noisy equipment is not stationary (for example drills, angle grinders, chipping hammers, poker vibrators).  All plant, equipment and vehicles are to be kept in good repair.  At commissioning of the mine, noise monitoring guidelines are to be prepared and implemented. This should include a re-evaluation of individual noise component over the LOM.  All vehicles to be kept in good repair.  Regular maintenance of the road.  All vehicles should have engines and gearboxes encapsulated. Noise control measures on machinery should be agreed with the manufacturer. Encapsulation should achieve at least a 5dBA reduction.  Haul operations should be limited to between the hours of 06h00 to 20h00.  Noise barriers may need to be built some residential areas along the external haul route. This aspect needs closer investigation. The noise levels are however not high enough to cause any hearing loss. The most prominent impacts will be noise disturbance that could lead to irritation, possible sleep deprivation, or affecting children's learning ability and concentration levels at school.  Implement an extensive noise-monitoring programme within the community to determine the actual noise levels.

421 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures 

Communities

Ambient noise

Intermittent high noise levels due to blasting

Communities

Blasting

Health, safety and nuisance impacts related to blasting, including: ground vibration, air blast and fly rock

Monitor and investigate all complaints from members of the community regarding irritation, trouble to sleep and lack of rest and calmness.  Establish a community hearing conservation programme in conjunction with the Department of Labour and the Department of Health. The hearing conservation programme will include noise level monitoring, testing people's hearing, providing hearing protection (where noise levels require such) and providing education and training.  Implement further measures such as noise shields between the mine and the communities as well as measures to shield the school from the noise, should the noise monitoring indicate unacceptable levels.  Acoustic insulation of houses and school classrooms such as double glazing and sealing of the roof eaves should be investigated further. Note that while it is possible to improve sound insulation of windows, this is only effective as long as windows stay closed. This implies that forced ventilation systems (either air conditioning or fans) should also be installed. Blasting to be restricted to daylight hours, between 12:00 and 14:00. Implementation of Blasting Procedure and blast design guidelines.  

  



Communities

Blasting

Sensitive structures – schools and clinics



Implementation of Blasting Procedure and blast design guidelines. Safe blasting distance calculated to be 306m; however, it was recommended that all households within 500m of the open pits be relocated to new areas. Refer to Resettlement, Compensation and Mitigation Strategy. All animals and people within 500m of a blast must be evacuated. All roads within 500m of a blast must be closed. Blasting time must be fixed and blasting notice boards setup at various routes around the project area that will inform the community blasting dates and times. A recommended good blasting time will be between 12:00 and 14:00. Implementation of permanent seismographs to monitor ground vibration and air blast of every blast to ensure adherence to blast designs. Schools: There are three schools that are located within the 500m safe blasting distance of the current mine design. The schools are out of range of the calculated fly rock distances. Two scenarios can apply: o Reduction of mining footprint of Pit 1, 2 & 6 to place the schools outside of the 500m safe blasting distance. In this case the blast design guidelines to maintain safe ground vibration should be adhered to (preferred option).

422 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures o

Communities

Blasting

Structural damage to houses and other structures

Communities

Blasting

Potential for impact on user borehole FUL21

Communities

Blasting

The occurrence of fumes in the form the NOx gaseous format

Communities

Visual

Visual intrusion of mining activities, impacting on the sense of place

Relocation of schools in consultation with the Department of Education and affected communities.  Clinic: There is no equipment that will require influence on the blasting operations with regards to allowable ground vibration. The structure remains the critical item and the calculated levels of ground vibration as expected are within the allowable limits. The clinic therefore requires no other specific mitigations. o A regular review of the clinic’s asset register must be done to ensure that the same applies for new equipment purchased.  A number of structures will be identified as a representative sample and instrumented with crack gauges during the photographic survey and reinspected on a regular basis. The gauges measures crack changes and tracking of the crack changes can be made on a regular basis.  A 1500m equates to 2.3 mm/s of expected ground vibration for the charge used. This level of ground vibration is already perceptible and people in structures could experience ground vibration negatively. Preblasting photographic inspections will be done on all houses and other structures prior to blasting within this distance. Monthly monitoring of boreholes close to pit areas must be done to review possible damage from blasting. The not a given and very dependent on various factors. However the occurrences of fumes should be closely monitored.        

The construction site must be kept in a neat and orderly condition at all times. All operational facilities should be actively maintained. Areas for material storage, waste sorting and temporary storage, batching and other potentially intrusive activities must be designated and screened off as far as is considered feasible. The development footprint and disturbed areas are to be kept as small as possible and the areas cleared of natural vegetation must be kept to a minimum. The extent of all surface infrastructure footprint areas and permanent structures must be minimised to what is absolutely essential. As far as possible, existing roads are to be utilised, also for construction purposes, to prevent cumulative impacts from roads and traffic. The height of infrastructure and stockpiles should be a low as possible. Infrastructure should not be placed on ridgelines, summits, or other locations where they would be silhouetted against the sky.

423 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures  

  





  



Infrastructure such as stockpiles must be shaped and rounded to blend in with the surrounding undulating landscape, especially along the skyline. Where mining infrastructure must be sited within view of visually sensitive areas, it must be placed as far away as possible or within lower-lying areas where it may be screen by topography. Where full screening of infrastructure components is not possible, final placement siting should take advantage of partial screening opportunities. Avoid placing of mining infrastructure in front of visually prominent landscape features, that naturally draw an observer’s attention, such as the prominent hills within the north of the Mining Footprint Area. As far as possible, surface infrastructure should be placed in areas that have already been disturbed, with due consideration for VAC, possible cumulative effects and impacts on the surrounding communities. New roads are to follow the undulating contours of the landforms in order to make it less visually prominent and to reduce the need for cut and fill activities. Siting of roads should avoid steep side slopes and ridge faces. It must be ensured that all buildings fit its surroundings through the appropriate use of colour and material selection in order to lower the visibility. Natural colours should be used in all instances and the use of highly reflective material should be avoided. Any metal surfaces should be painted to fit in with the natural environment in a colour that blends in effectively with the background. White structures are to be avoided as these will contrast significantly with the natural surroundings. The identification of appropriate colours and textures for facility materials should take into account both summer and winter appearance. The use of permanent signs and project construction signs should be minimised and visually unobtrusive. Where possible, screening of the mining operations should be implemented through, for example, planting the project boundaries with indigenous vegetation. Vegetation can, despite its visual porosity, function as a screen when a sufficient mass is employed. In areas where screening topography and vegetation are absent, natural-looking constructed landforms and vegetative or architectural screening may be used to minimise visual impacts. Care should however be taken to avoid additional surface disturbance.

424 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures   

Communities

Visual

Impact due to nighttime lighting



  

   

  

Stockpiles should be placed to screen the open pit activities from the potential viewers. Stockpiles are to be revegetated where possible. Concurrent/ progressive rehabilitation must be implemented as far as possible and disturbed areas must be rehabilitated as soon as areas become available. Offsite mitigation serves as a means to offset a loss of visual landscape integrity. For example, offsite mitigation could include reclaiming unnecessary roads, removing abandoned buildings, reclaiming abandoned mine sites, putting utility lines underground, rehabilitating and revegetating existing erosion or disturbed areas, or establishing scenic conservation easements. A lighting engineer should be consulted to assist in the planning and placement of light fixtures for the mining facility and all ancillary infrastructures in order to reduce visual impacts associated with glare and light trespass. Outdoor lighting must be strictly controlled. High light masts should be avoided. Any high lighting masts should be covered to reduce the glow. Construction activities should be restricted to daylight hours as far as possible, in order to limit the need to bright floodlighting and the potential for skyglow. Lighting use should be minimised during construction and operations. During construction, localised and portable lighting should be used where and when the work is occurring;. Up-lighting of structures must be avoided, with lighting installed at downward angles, thereby minimising the light spill. Lighting fixtures must be selected and placed so that they direct their light on the intended area only, to avoid light spill and offsite light trespass. Care should be taken when selecting luminaries to ensure that appropriate units are chosen and that their location will reduce spill light and glare to a minimum. Only “full cut-off” light fixtures that direct light only below the horizontal must be used on the plant infrastructure and offices. Censored and motion lighting may be installed at office areas and workshops to prevent use of lights when not needed. Selective lighting must be used for the construction camps and other secured areas. Light sources must be shielded by physical barriers.

425 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures   



Communities

Traffic

Impact on pedestrian activity along the new access road due to increase in large trucks

   



Communities

Traffic

Safety of other road users, increase in traffic accidents

 

 Communities

Traffic

Impact of increase in traffic on domestic animals

 

Minimum wattage light fixtures should be used, with the minimum intensity necessary to accomplish the light's purpose. Mounting heights of lighting fixtures must be limited by using foot-lights or bollard level lights. Vehicle-mounted lights or portable light towers are preferred over permanently mounted lighting for night-time maintenance activities. If possible, such lighting should be equipped with hoods or louvers and be aimed toward the ground to avoid causing glare and skyglow. The use of low-pressure sodium lamps, yellow LED lighting, or an equivalent reduces skyglow and wildlife impacts. Bluish-white lighting is more likely to cause glare and attract insects, and is associated with other human physiological issues. The road geometric upgrades that will be implemented along the new access road will improve safe stopping site distance. If the sections around the high pedestrian activity areas are paved then traffic calming measures in the form of speed humps should be implemented. The provision of traffic warning signs and decrease in speed limit for trucks over the affected sections to 40km/h. All trucks servicing the Fuleni Anthracite Project should be installed with tracking devices and the development management should employ an independent assessor monitor the speed over the affected sections and provide the controlling authorities with a detailed report at regular intervals. Provision of dedicated pedestrian footpaths in the high pedestrian areas that are physically separated from roadway (by barriers) and that have openings at selected locations and at formal pedestrian crossings. All heavy vehicles must be restricted to designated routes and not permitted on other roads. As part of the development there will be road geometric improvements made to the road network. These upgrades are focused on improving the safety of the road and will hence have a positive impact on other road users. Identification and regular maintenance of an alternative access road for Medical Emergency Services. The proposed geometric upgrades will improve the safety along this route. It is however recommended that warning signs be placed along the route where there is high domestic animal activity.

426 | P a g e

Sensitive Receptor Communities

Environmental Aspect Roads

Potential Impact

Mitigation Measures

Open Pit 2 will result in the realignment of both D873 and L1791 resulting in longer travelling distances and reduced access to the schools and clinic in Ocilwane (from Novunula)

   

Communities

Roads

HiP and Mfolozi Wilderness Area HiP and Mfolozi Wilderness Area

Water resources

HiP and Mfolozi Wilderness Area

Noise levels

HiP and Mfolozi Wilderness Area

Visual

Air quality

Access and alternative access during incidents by emergency health services Impact on surface water resources within the HiP

Students walking along affected sections of D873 and L1791 should be provided with a footpath that circumnavigates close as safely possible around Pit 2. All the necessary safety measures should be put in place. Alternative methods for school children mode of transport to schools must be explored, i.e. issue of bicycles to school children or contracting school busses. Engagement with Department of Health to arrange regular (weekly) Mobile Clinic services in Novunula. Issues and Grievance Management Plan

Identification and regular maintenance of an alternative access road for Medical Emergency Services.

Mining and infrastructure footprint areas lie within a different quaternary catchment, so no impact or mitigation required. The maximum concentration for the operational PM10 The impact is mainly caused by the stockpile operation on the edge of the emissions is seen within in the HiP’s fenceline HiP. The following mitigation measures need to be implemented:  Limit the height and slope of stockpiles to reduce wind entrainment.  Cladding and/or vegetation of stockpiles: Vegetation of stockpiles where possible, the stockpiles can also be covered by large rock fragments to ensure the silt area that can be picked up by wind is reduced and kept to a minimum.  Windshield (barriers) to be implemented on the slopes and surface of the stockpile, these barriers are typically large trees with good foliage coverage. The substitute of the wind barriers is a wind shield made from a prose material (shade cover).  Redesign of stockpiles to reduce the funneling (canyon) effect. Elevated noise levels expected within the HiP and Wilderness The mitigation measures proposed for the community impacts also refer to Area the HiP and Wilderness Area. In addition, the following is recommended:  The stockpiles on the border of the HiP will act as noise barriers albeit only after construction thereof is completed.  No work on stockpiles at night in order to cut down on generated noise.  With regard to wildlife, surveys need to set up to establish the vulnerability of any endangered species in the vicinity of the proposed mine site. Visual impacts on Mfolozi Wilderness Area and greater HiP as The mitigation measures proposed for the community impacts also refer to a result of mainly the stockpile operations on the border of the the HiP and Wilderness Area. In specific the following applies:

427 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures

HiP, impacting on the sense of place

   



 



HiP and Mfolozi Wilderness Area

Biophysical

Run away fires

 



HiP and Mfolozi Wilderness Area

Biophysical

Increased poaching



The development footprint and disturbed areas are to be kept as small as possible and the areas cleared of natural vegetation must be kept to a minimum. Infrastructure should not be placed on ridgelines, summits, or other locations where they would be silhouetted against the sky. Infrastructure such as stockpiles must be shaped and rounded to blend in with the surrounding undulating landscape, especially along the skyline. New roads are to follow the undulating contours of the landforms in order to make it less visually prominent and to reduce the need for cut and fill activities. Siting of roads should avoid steep side slopes and ridge faces. Where possible, screening of the stockpile operations should be implemented through, for example, planting the project boundaries with indigenous vegetation. Vegetation can, despite its visual porosity, function as a screen when a sufficient mass is employed. Stockpiles should be placed to screen the open pit activities from the potential viewers. Stockpiles are to be revegetated where possible. Concurrent/ progressive rehabilitation must be implemented as far as possible and disturbed areas must be rehabilitated as soon as areas become available. Offsite mitigation serves as a means to offset a loss of visual landscape integrity. For example, offsite mitigation could include reclaiming unnecessary roads, removing abandoned buildings, reclaiming abandoned mine sites, putting utility lines underground, rehabilitating and revegetating existing erosion or disturbed areas, or establishing scenic conservation easements. Strict no-fire regimes will be enforced throughout the MRA area. No illicit fires will be allowed during any phases of the proposed mining development. Veld fires will be controlled in the revegetated areas and a rotational burning programme will be developed for the area in consultation with experts in this field. An emergency procedure will be developed in conjunction with the communities, Ezemvelo KZN (HiP) and the local fire department to ensure in the event of a surface fire, the requirements of the National Veld and Forest Fires Act will be met. No trapping, collecting or hunting of faunal species will be allowed during any phases of the proposed mining development.

428 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures 

HiP and Mfolozi Wilderness Area

Tourism

Impact on tourism

iSimangaliso Wetland Park and Lake St Lucia

Surface water

Water quality and quantity impacts on downstream sensitive areas

Mvamanzi Pan system

Surface water

Impact on MAR and hydrological balance of Mvamanzi Pan as a result of the damming of water (water supply dam)

Mvamanzi Pan system

Surface water

Downstream impacts associated with dam failure / breakage

The mine will employ security personnel to monitor and secure the fence line of the HiP during all phases of mining in order to curb security and poaching risks to the HiP.  Develop and implement an Anti-poaching Collaboration Strategy to effectively collaborate with stakeholders to determine and minimize any contributing factor the mine development has on poaching activities.  Improvement of awareness amongst local communities regarding the importance of conservation.  Collaboration with EKZN Wildlife to manage and combat increases in poaching.  Provide a servitude enabling EKZN Wildlife to access the isolated parts of the HiP bordering the mine.  Maintain manage and secure the border fence between the mine and HiP to ensure no animals enter the mine and no humans use the mine to enter the park for any non sanctioned reasons.  Financially support the anti-poaching initiatives of HiP.  Financially compensate HiP for loss of tourism revenue on the Wilderness Trails.  Where possible, support local accommodation establishments when hosting visitors from out of town.  Identify potential tourism opportunities with the local communities and EKZN Wildlife.  Offer educational tours to school groups describing the mining process and the importance of nature conservation.  Negligible impact envisaged, no mitigation required.  Implement monitoring programme for early detection and rectification of any issues of concern.  Special measures are required to assure continuation of a normal flow pattern to the wetland, e.g. environmental releases.  Dam will act as sediment trap, reducing the sediment load to the Mvamanzi Pan and downstream Mfolozi River. Operation and Maintenance (O&M) requirements of the dam should include the following but not limited to:  The embankment dam should be inspected at regular intervals (as per DWA Dam safety office) for evidence of the development of unfavourable conditions. The downstream slope should be carefully inspected for indications of cracks, slides, sloughs, subsidence, and impairment of slope protection, springs, seeps, or boggy areas caused by seepage from the dam. The upstream slope of the embankment

429 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures should be carefully inspected for adequate protection of the embankment.  The maintenance of the embankments and spillway should consist of the removing of debris (upstream face), replacing disintegrated riprap, repairing eroded material, controlling undesirable vegetation and rodents. It is unlikely that the available technology of mitigation measures are able to reduce the emission factors and noise levels to an acceptable level within the Wilderness Area. Therefore, additional innovative engineering methods and designs must be implemented to identify additional mitigation measures which may reduce the level of impact. These processes of design must be done in combination and with the mine engineers and air quality and acoustic specialists to come up with a totally new concept of design to improve (reduce) the mitigation potential.

Residual Impacts

HiP and Mfolozi Wilderness Area

High levels of air quality and noise impacting on the Wilderness Area and overall sense of place

Residual Impacts

HiP and Mfolozi Wilderness Area

Potential de-designation of Wilderness status as a result of the high levels of visual intrusion, noise and emissions

Residual Impacts

Land Use and land capability

Impact on ecosystem

Residual Impacts

Land Use and land capability

Post-closure land use and land capability



The potential loss of the Wilderness Area must be compensated for. A similarly farm, game reserve or piece of land could be converted to wilderness to compensate for the loss of approximately 50% of the pristine wilderness within HiP which has been compromised by the coal mines location.  Sponsor the extension of the HiP to offset the mining footprint and compensate for loss of Wilderness status.  Financially support the upgrade of the roads in the HiP. Since effective mitigation through avoidance, impact minimisation and rehabilitation is deemed unlikely to adequately limit the impact on the receiving ecology, it is deemed important that an ecological offset initiative be initiated to contribute to the conservation of the area. In particular mention is made of initiatives focused on the purchase of land to create the ecological corridors linking the various areas currently functioning as conservation areas.  



Define, in consultation with all IAPs, the final (post-closure) land use for the mining area, including mining areas, surface and water management infrastructure, mine residue facilities, etc. Develop a final land use plan and implementation programme as part of the closure plan, taking into account important issues such as ongoing operational and maintenance requirements and long-term responsibilities and ownership. Set final closure objectives and standards to ensure conformance to the

430 | P a g e

Sensitive Receptor

Environmental Aspect

Potential Impact

Mitigation Measures

 Residual Impacts

Land Use and land capability

Erosion of post-mining landscape, especially where the slope is  greater than eight percent



   Residual Impacts

Residual Impacts

Residual Impacts

Impact on surface and groundwater resources Impact on surface and groundwater resources Impact on surface and groundwater resources

Deterioration of groundwater quality within the back-filled open pits due to acid rock drainage reactions Downstream movement of a deeper groundwater pollution plume Decant into the shallow aquifer or on surface at the lowest surface elevations intersected by the pits

    

 

final land use plan and the requirements of the IAPs and relevant environmental legislation. Develop a detailed closure plan for the Fuleni Anthracite Project five years prior to closure and obtain approval from the relevant authorities. All rehabilitated spoils placed within the opencast section will be made free-draining as far as practically possible. Grassing will be undertaken on a seasonal basis, to ensure germination of the grass species. This will to ensure maximum drainage from these areas of clean water back into the catchment system without excessive erosion or suspended solids. Preventing and managing erosion of rehabilitated surfaces, such as post mining landforms. The transition to natural systems considered sustainable in the long term taking account of possible exposure to fire and drought is important. Ensuring stability of remaining (if required) stockpiles. Ensuring that where activities have affected streams, these areas are not prone to erosion or deterioration in the future. In particular, the stability of the river diversions is a key issue Investigate the feasibility of constructing a network of constructed wetland system as part of the Rehabilitation Plan. Deposit mine residue in the open pits as far as possible, thereby controlling the migration of high sulphate leachate. The horizons that are potentially acid generating will be placed at the bottom of the pit, where it will be submerged below the water table, preventing oxidation. Open pit areas will be rehabilitated and vegetated as soon as possible to reduce the oxidation and the potential generation of acid-mine drainage. Dedicated monitoring programme and modeling to quantify and verify post-closure water balance and decant water quality. The model will be revised at least every 5 years. Ongoing evaluation and reassessment of alternative options for the final water use and required associated water quality, together with the technologies required to achieve the required quality. The final land use will also be used to evaluate the post closure water management. Active involvement in any regional integrated water management plans developed in the area.

431 | P a g e

7.3

SOCIAL IMPACTS AND MITIGATION

Impact SOCIAL CAPITAL Population and Demographic Change  Influx of job seekers with associated secondary impacts

Proposed Mitigation  



  

 Change/disruption of power relationships  Increased internal inequalities within communities between those who benefit directly from the mine and those who do not  Competition for power of direction and decision-making between Traditional Authorities and Community Leaders  Competition for power over benefit allocation amongst Mhlana Traditional communities and with neighbouring Traditional areas



   

 Disruption in daily living and movement patterns  Increase traffic numbers caused by transport and/or traffic of employees from their place of residence to their place of work.

   

Dissimilarity in Social Practices and Disruption of Social Networks  Disruption of Social Networks and increase in developmental diseases.

Resettlement or displacement of individuals or families  Displacement of 124 households pre-

 

 

Development and Implementation of an Influx and Land use Management Plan Priority employment from local communities with the development of recruitment procedures and utilizing the existing skills database compiled from the local communities Establishing early on skills development programmes in areas where most employment opportunities will be available such as operators and artisans Implementation of bursary programme and practical skills programmes as part of the Social and Labour Plan Establishment of a local labour recruitment committee to monitor recruitment procedures and results Engage with Traditional Authority to manage and monitor site allocation to job seekers and/or employees in the local communities Induction of contractors and workforce with regard to their code of conduct in the local communities Broad based engagement and participation in the process and activities that will influence Traditional Authorities and local communities Equal distribution of benefits amongst affected communities Consistent application of compensation rates to all Project Affected Households/Persons Internal capacitation of staff / resources utilised to engage and operate in the area (Internal Induction) External capacitation of community leadership structures to empower existing structures on the consequences and benefits of mining development, pre-construction and throughout operations Preference to relocation host options within the same villages and traditional authority areas Traffic minimized through bus and combi services to transport workers to the project site Low speed limits on access roads with public drop-off / pick-up areas as to not disrupt the flow of traffic Road crossings should be managed by signing and traffic management measures Issues and Grievance Procedure available to local people to report bad driving or rules traversing Employment of local people on the mine to improve the poverty levels in the host and neighbouring communities Code of Conduct to form part of induction of new workers with a clear statement and procedure regarding access, conduct and identification. All workers should wear clothing marked (and reflective vests) with the logo of the construction firm/contractor or sub-contractor as well as identification cards that cannot be easily forged, so that they can be easily recognized as being legitimate. Grievance Procedure within the local communities Application of the Avoidance Principle by reducing the footprints of Open Pit 1, 2 & 6 (see maps in paragraph 7) (reduced resettlement to 86)

432 | P a g e

Impact mitigation residing in Ocilwane, Ntuthunga 1 and Patane villages

Impact Equity  Increase unequal access to opportunities or resources

Perceptions of and Feelings in relation to the project  Establishment of conflict between the developer and the local communities  Objection against the development

Change in Cultural Practices  Displacement of 248 graves premitigationlocated in Ocilwane, Ntuthunga 1 and Patane villages

HUMAN CAPITAL Participation of Local Communities in Employment Opportunities and Skills Development (Positive)

Proposed Mitigation  Application of the Avoidance Principle by realigning access road  Resettlement of structures that cannot be avoided in terms of the resettlement strategy  Benefits must be ploughed back into the community. Participation in Regional Forums can assist in ways whereby the company can assist recipients, and  Employment should be prioritized to local communities  Local beneficiation programmes to be implemented as part of the Social and Labour Plan  Establish ongoing Consultative Forums with concerned groups to air concerns, find possible mitigation measures for their perceived impacts and monitor implementation and effectiveness of mitigation measures  Continuous communication with all stakeholders providing information on anticipated impacts and planned mitigation measures  Application of the Avoidance Principle by reducing the footprints of Open Pit 1, 2 & 6 (see maps in paragraph 7) – reduced impact to 172 graves  Application of the Avoidance Principle by realigning access road  Resettlement of graves that cannot be avoided in terms of the resettlement strategy  

 

 

  Equity Participation of the Local Communities (Positive) Participation of local business in procurement opportunities

  

 

Health Impacts  Increase in health incidents related to air

  

Source the maximum number of employees from the local area for temporary job opportunities Implement skills development programmes in the areas where most job opportunities will be created, i.e. operators and drivers Make available bursary opportunities to build skill capital in the region Establish a database of local people with information on qualifications and skills, utilize this database to develop skills plans and recruit local people. Implement portable skills development programmes Design and implement economic development programmes that will assist people being retrenched in sustaining their livelihoods Establish a future forum with representation from the workforce to discuss potential difficulties and solutions Implementation of programmes to minimize and mitigate the impact of downscaling and retrenchment Development of strict guidelines in terms of representation and utilisation of equity funding Consultation and Feedback on results on a regular basis Establish a database of local businesses, utilize this database to establish partnerships between local and larger service providers as well as locally preferred work packages Consultation and Feedback on results on a regular basis Implementation of capacity building programmes to minimize and mitigate the impact of mine downscaling and closure. Closure plan implementation Mitigation measures to minimize air pollution Air quality and health monitoring systems to be implemented

433 | P a g e

Impact pollution  Increases of Developmental diseases

Noise impacts  Increased noise levels in the local communities  Increased noise levels near educational facilities that may affect education Safety impacts  Increase in Crime  Increase in social pathologies such as alcohol abuse, prostitution and vandalism  Increase in theft, burglary, armed robbery, assault and even murder  Increase in poaching in the neighbouring conservation areas

Safety impacts  Infrastructure & Operational safety  Increased road accidents due to increased traffic volumes

Change in sense of place and change in tourism activities due to

Proposed Mitigation  Communication Strategy to keep community informed of air quality risks and mitigation measures  Health awareness programmes with workers and communities to educate on sexually transmitted diseases and HIV/AIDS and other illnesses such as TB and Malaria  Provision of preventative measures (including condoms)  Collaboration with local health practitioners Ocilwane clinic, health committees and home-based care organisations  Ensure noise levels post mitigation at night is below 40 dB  Ensure noise levels post mitigation during the day is below 50dB  If the noise levels cannot be mitigated below these levels, an assessment of the housing within the community that may be impacted must be conducted.  Cooperation, Participation and support to the anti-poaching initiatives in the area.  Increased security measures (fencing, access control and monitoring) on mine premises. Properly constructed and secured fences can control access to mine sites. Implementing strict access control of the project site and specifically the contractors workforce camp. Curfew times to be established in accommodation areas. Construction workers accommodated on mine are identified and marked with clear identifiable clothing  Code of Conduct to form part of induction of new workers with a clear statement and procedure regarding access, conduct and identification. All workers should wear clothing marked (and reflective vests) with the logo of the construction firm/contractor or sub-contractor as well as identification cards that cannot be easily forged, so that they can be easily recognized as being legitimate.  Workers to be screened including criminal background checks.  Employment of local people on the mine to improve the poverty levels in the host and neighbouring communities  Workers should be urged to recognize and report suspicious activity and signs of burglary and be informed of crime prevention measures that they themselves can take.  Ibutho Coal to participate and support existing community policing forums and project security to properly secure the project area and surrounding area  Implement downscaling and retrenchment strategies  Implement portable skills development programmes  Design and implement economic development programmes that will assist people being retrenched in sustaining their livelihoods  Conduct regular full risk assessment and have procedures in place to deal with emergency incidents  Make available a complaint and grievance mechanism where people can lodge any complaint or raise issues regarding damages to their property due to risk and safety exposure  Involve local emergency services to support on mine emergency procedures  Establish on site emergency equipment and appoint safety staff  Continuous communication with all stakeholders providing information on anticipated impacts and planned mitigation

434 | P a g e

Impact  Increase nuisance effect due to increased levels of dust and noise  Increase in traffic with a disruptive effect  Visual intrusion of mining infrastructure

PRODUCTIVE CAPITAL Change in community infrastructure  Impact on 3 community schools premitigation in Ocilwane and Ntuthunga 1

Proposed Mitigation measures  Establish ongoing Consultative Forums with concerned groups to air concerns, refine mitigation measures for their perceived impacts and monitor implementation and effectiveness of mitigation measures  Implementation of traffic management measures  Implementation of insulation and mitigation measures for noise  Implementation of visual barriers and other mitigation measures as recommended in the visual study  Implementation of particle and dust suppression methods  Colour schemes must complement the local environment.  Minimising disturbance to vegetated areas outside the critical development areas where possible  Revegetation/rehabilitation of disturbed sites in parallel with development  Rehabilitation and Reclamation of affected areas 

 Change in Community services  Increased pressure on current services to accommodate growth



    

Change in housing needs/demands  Increased pressure on formal towns to supply housing  Increase occurrence of informal housing in the local communities

   

  

 

Application of the Avoidance Principle by reducing the footprints of Open Pit 1, 2 & 6 (see maps in paragraph 7) – reduce impact so that no schools need to be relocated Resettlement education facilities that cannot be avoided in terms of the resettlement strategy Establishment of a construction accommodation camp to house those employees that cannot be sourced from the local community due to a lack of skills Linkages with skills development programmes to optimize skills levels in local communities Source majority of the Level B construction employees from the local community Continuous assessment and monitoring of infrastructure and services capacity in focal points (assessment every 5 years) Determine scale of assistance required at focal points and enter into an agreement with the municipality Participate in regional development planning forums of the municipality to continuously assess and monitor capacity, determine assistance required Linkages with skills development programmes to optimize skills levels in local communities Source majority of the Level B construction employees from the local community Provision of construction accommodation on site Discussions, agreements and procedures within the host and neighbouring communities to manage site / stand allocation to new residents / parties and village development plans within the villages to limit informal / squatting Monthly engagement with Traditional Authorities to manage and monitor influx and housing / site allocations Facilitation of housing development for external workforce Link-up with planned housing developments and private developers to unlock possible development to supply the projected demand Subsidy programmes to employees to access housing Participate in Regional Structures to plan for anticipated impacts, starting during the Construction Phase to ensure planning is done in advance

435 | P a g e

Impact Change in access to resources that sustain livelihoods  Loss of grazing land  Loss of arable land (25 households)  Loss of vegetable gardens  Loss of access to medicinal plants  Loss of access to firewood  Loss of livestock drinking dam (1)

Proposed Mitigation  Demarcated areas where fire wood can be collected that was cleared for the Construction Phase  Establishment of medicinal plant nursery  Provision of alternative grazing land  Leasing of community land impacted by mining  Monitoring the impact on livestock  Fair compensation negotiated and agreed with households that will lose access to agricultural land or vegetable gardens  Continuous consultation with Conservation bodies discussing co-existence and mitigation measures  Implement a consultation programme with regional stakeholders in the development of a closure plan and rehabilitation programme  Determine the regional needs and characteristics to ensure post mining use of land enhances the regional characteristics

7.3.1 SOCIAL MANAGEMENT STRATEGIES In combination with the mitigation measures listed in Section 4.14.2, the implementation of Social Management Strategies will assist in the management of social impacts. The following strategies are proposed:    





Communication and Consultation Plan: Ensuring continuous engagement with project affected parties and stakeholders. Issue and Grievance Management Strategy: To ensure the appropriate management of issues and grievances. Influx Management Strategy: To manage the influx of job seekers Resettlement, Compensation and Mitigation Strategy: to compensate and mitigate for direct and indirect project impacts resulting either a physical or economical loss (attached as a separate document). Employment Strategy o Recruitment Strategy: to maximise employment opportunities for the local communities and reduce the influx of a foreign labour force whilst ensuring an effective construction and operational process. o Skills Audit: to capture all project relevant skills in the project area with the aim to enhance local employment figures. o Recruitment Manual: to include a list of employment opportunities that will become available during the project planning, construction and operational phases and provide guidelines on procedures to be followed by aspiring employment seekers and employers. o Employment Information Desk: to establish an employment information desk to assist with the day to day management of project related labour issues. o Human Resource Development and Training Strategy: to identify appropriate training and skills transfer opportunities that will enhance the skills level of the local labour force both during and after project implementation. Procurement Policy: to ensure that local business outfits, especially those of HDIs, women and SMMEs get allocated a fair business share of project related business opportunities.

436 | P a g e





 





Community Institutional and Economic Enhancement Strategy: to ensure involvement, participation and ownership in project related processes, during the planning, implementation and operations and maintenance phases of the project. Housing and Infrastructure Policy: to ensure that project related housing and service delivery are designed and implemented such that it stands to alleviate local housing and service delivery stumbling blocks in the longer-term. Education Strategy: to ensure that probable impacts on project area educational facilities are manageable and design applicable mitigation measures where applicable. Health Strategy o Occupational Health and Safety Strategy: to ensure that during the project construction process and the operational phase of the project, employees receive adequate health support from the project team for work-related health problems. o Community Health and Welfare Strategy: to ensure that the project intervention will not have a negative impact on the health and welfare infrastructure in the project area, and to suggest appropriate measures to enhance the capacity of existing health infrastructure. o Traffic Safety and Awareness Strategy: to ensure that appropriate traffic management measures are planned and employed, in anticipation of the the major increase in both heavy and light vehicle traffic. o Community Safety and Security Strategy: to ensure that the project areas as well as the impacted communities are protected adequately through the formal policing system as well as additional safety measures such as additional security at the project sites and community policing in the project area. o Anti-poaching Collaboration Strategy: to effectively collaborate with stakeholders to determine and minimize any contributing factor the mine development has on poaching activities. Archaeological and Heritage Strategy: to ensure that archaeological and heritage resources are managed in accordance with relevant legislation and in consultation with all relevant interested and affected parties. Social Monitoring and Evaluation Strategy: to ensure that the project intervention process is monitored with the aim of implementing corrective measures if and when required.

Please refer to the SIA (ANNEX-12) for further details on the proposed strategies.

437 | P a g e

8 STAKEHOLDER ENGAGEMENT OBJECTIVES OF PUBLIC PARTICIPATION

8.1

The fundamental objectives of the public participation process are as follow:       

Meet legal and formal requirements; Identify public concerns and values; Improve decision-making. Public involvement can often produce better “technical decisions” than a strictly technically oriented decision process; Establish and maintain good relationships with IAPs; Provision and sharing of information throughout the process; Find and build common ground and move from extremes; and Stimulate two-way engagement on specific issues. In many cases, not all IAPs wish to be involved in every issue of the project all of the time. Most IAPs are partially involved, and therefore prefer to be only included in key elements of the process.

PRINCIPLES OF PUBLIC PARTICIPATION

8.2

The public participation process should endeavour to embrace the following principles:           

Inclusive involvement of stakeholders and IAPs. Integration of public issues/knowledge and technical assessments. Mutual respect for each other’s knowledge, abilities and inputs. Consideration of alternatives. Flexibility of the public participation process to adapt to different circumstances. Transparency of the process and information availability. Accountability of commitments made. Accessibility to information. Efficiency of the Public Participation Plan. Suitability of scale of involvement. Feedback to and from stakeholders.

METHODS OF PUBLIC PARTICIPATION

8.3

The following methods were be utilised throughout the Public Participation process:         

Background Information Documents, Information Flyers, and Posters Advertisements and Notices; Authority meetings; Landowner, Traditional Authority and Community meetings; Public Meetings and/or Open Days; Community Forums and Group Presentations; One-on-One interviews / engagements Electronic and email correspondence; and Other Methods. 438 | P a g e

8.4

PUBLIC PARTICIPATION PROCESS FOLLOWED

The following figure indicates the process followed. The process is currently still in EIA phase and the activities indicated in pink below shows activities that still need to take place.

Figure 159: Public Participation Process

8.5

REGISTER OF INTERESTED AND AFFECTED PARTIES (IAPS) (ANNEX-1.3)

All key interested and affected parties were identified at the onset of the Public Participation Process in June 2013. The initial list of IAPs included all resident communities, the Traditional Authority, Ingonyama Trust, neighbouring land owners, relevant Government Departments, Government Institutions / Agencies / Parastatals and Environmental Interest groups / NGO’s such as EWT andBirdlife SA. The IAP register was opened in June 2013 and are maintained and updated throughout the process as required by the National Environmental Management Act, and EIA Regulations, 2010. Please refer to ANNEX-1.3 for a copy of the IAP Register. 439 | P a g e

PROJECT NOTIFICATIONS (ANNEX-1.4 & 1.5)

8.6

8.6.1 PUBLIC PARTICIPATION NOTIFICATIONS All parties registered on the Interested and Affected Party and Property Registers were notified at various stages of the Process via the following methods: 



Background Information document as Project Notification were sent to all initial registered IAPs according to the following methodology: o Via Email, where email addresses existed and were available o Via Fax, where a fax number existed o Via, Post, if neither an email nor a fax is available, but a Postal address is available o Via SMS, where a cell phone number was available The Project Notification was sent via the methods stated above: o Notification (Background Information Document) of Mining Right Application and Invitation to Register from 10 February 2014 (Refer to ANNEX-1.4). o Notification of the availability of the draft Scoping Report on 7 March 2014 (Refer to ANNEX-1.5). o Notification of the availability of the final Scoping Report on 10 July 2014 (Refer to ANNEX1.5). o Notification of the extended process and the availability of theamendedFinal Scoping Report were distributed on 3March 2015 (Refer to ANNEX-1.5). o Notification of the acceptance of the Amended Final Scoping Report was sent out on 17 April 2015 (Refer to ANNEX-1.5)

8.6.2 ADVERTISEMENTS AND ON-SITE NOTIFICATIONS (ANNEX-1.6 & 1.7) 







Advertisements were placed at announcement of the project and thereafter in English, and Zulu (ANNEX-1.6) in the following local newspapers: o The Zululand Observer (English) o The Zululand Observer (Zulu) o The Natal Mercury (English) o Isolezwe (isiZulu) Advertisements were placed in the above mentioned local newspapers for the following notifications (Refer to ANNEX-1.6): o Notification of Mining Right Application and Invitation to Register between 14 and 20 February 2014 requesting all those interested to register by 2 March 2014. o Notification of the availability of the draft Scoping Report between 7 and 14 March 2014 requesting those wishing to comment, to submit comments by 2 May 2014. On request from IAPs the comment period was extended to 12 May 2014. On site notices were placed at the following locations: o iMfolozi Library in Kwambonambi o Empangeni Library o Richards Bay Library On site notices were placed at the above-mentioned Public Places for the following notifications (ANNEX-1.7): o Notification of the availability of the draft Scoping Report on 9 March 2014. 440 | P a g e

o o

Notification of the availability of the final Scoping Report on 10 July 2014 Notification of amendment to the final Scoping Report will be distributed from 2 March 2015

8.6.3 ESTABLISHMENT / COMMUNICATION OF CHANGE The IDM Consultants assisted the EAP in the administration of the Public Participation Process up to the draft Scoping Report that was made available in March / April 2014. Post the draft Scoping Report IDM Consultants chose to withdraw from the project and Naledi Development was appointed to assist with the administration of the required Public Participation component of the final Scoping and EIA Phase. As part of the change, the Public Participation Office initiated a dedicated email and fax number to ensure all stakeholder notifications and submissions are housed on one system. Project Email: [email protected] Project Fax: 086 776 3478 A notification letter was compiled to inform all registered IAPs of the change in the Public Participation Office details, see ANNEX-1.5 for the notification.

INFORMATION DISTRIBUTED

8.7

8.7.1 BACKGROUND INFORMATION DOCUMENT (ANNEX-1.4) A Background Information Document was compiled containing the following information: 



       

Notification of an application for a Mining Right in terms of the Mineral and Petroleum Resources Development Act, submitted to the Department of Mineral Resources (DMR Reference KZN 30/5/1/2/1/10045MR, subsequently changed to KZN 30/5/1/2/1/10060MR) Notification of an application for Environmental Authorisation in terms of the National Environmental Management Act, submitted to Department of Agriculture and Environmental Affairs, subsequently changed to Department of Economic Development, Tourism and Environmental Affairs (EDTEA Reference DC 28/0035/2013: KZN/EIA/0001371/2013) Locality of the Project, including a locality map (scale 1: 180 000) Project Description, including a proposed project lay-out Reasoning / motivation for the project Explanation of the Mining Right Application and Environmental Authorisation Process List of Specialist studies to be undertaken Explanation of the envisaged Public Participation Process Invitation to register, and inform other relevant parties to do the same Provide / submit initial comments on the project

The Background Information Document was translated into isiZulu and distributed to interested and affected parties. The document was also provided at all focus group meetings to Authorities, Traditional Authority, Indunas and Community members. Please refer to ANNEX-1.4 for a copy of the Background Information Document.

441 | P a g e

8.7.2 NON-TECHNICAL SUMMARY OF THE SCOPING REPORT (ANNEX-1.8) Post the draft, final and amended Final Scoping Report, a non-Technical Summary was compiled of the report and translated into isiZulu. This summary was made available to Traditional Council, the Village induna’s and community leaders and members at engagement sessions. See the Non-Technical Summary of the Scoping Report attached as ANNEX-1.8. The draft EIR/EMPr Report will be accompanied with a Non-Technical Summary of the report, which will be translated into isiZulu. This summary will be made available to all registered IAPs and distributed to the Traditional Council, Induna’s and Fuleni Mining Forum members after completion of the EIR/EMPr.

8.7.3 INFORMATION BOOKLETS (ANNEX-1.9) As part of the Public Participation Process conducted with the rural communities affected and surrounding the proposed project area, it was evident that the community needed a number of key clarifications on the company’s structure and their policies in terms of benefits (i.e. community ownership, employment, skills development, procurement) and impacts (i.e. resettlement, grazing land and grave exhumation). A project booklet summarizing the information and the policies were compiled, translated into isiZulu and distributed to local communities affected by the project. Please refer to ANNEX-1.9 for a copy of the Booklet. The results from the specialist studies was summarised in a Booklet that was translated into isiZulu and distributed amongst the affected communities surrounding the mine development at a combined community meeting held on 17 May 2015.

8.7.4 POSTERS (ANNEX-1.10) As part of the additional Community Engagement, a presentation was compiled to explain the Mining Right and Environmental Authorisation Process, the Project Description, and the initial anticipated risks and impacts. This presentation was converted into posters that were printed in A0 size and put up at Community meetings as an engagement methodology and tool.Please refer to ANNEX-1.10 for a copy of the Presentation and Posters. The preliminary results of the EIA was summarised on posters which was translated into isi-Zulu and used at community meetings as an engagement tool. Refer to ANNEX-1.10 for copies.

IAP ENGAGEMENT AND MEETINGS (ANNEX-1.11 TO 1.19)

8.8

A number of Public Participation and Stakeholder Engagement meetings were held. The minutes and attendance registers of the meetings are attached as ANNEX-1.11 to 1.19.

8.8.1 GOVERNMENT AUTHORITY ENGAGEMENT (ANNEX-1.11) The following Authority engagements were embarked on: 

Intergovernmental Authority meeting held on 26 March 2014 at the Richards Hotel in Richards Bay o The following Departments were invited and attended (indicated in brackets)  Department of Mineral Resources (tendered apology) 442 | P a g e











 Department of Water Affairs (tendered apology)  Department of Agriculture and Environmental Affairs (attended)  Department of Forestry (attended)  Department of Rural Development and Land Reform (not attended)  Department of Land Affairs (not attended)  Department of Health (not attended)  Department of Transport (not attended)  National Roads Agency (not attended)  AMAFA (not attended)  Ezemvelo KZN Wildlife (attended) o Minutes, the Presentation and Attendance Register is attached as ANNEX-1.11-1 Kwazulu-Natal Department of Economic Development and Tourism (KZNDED) (previously Economic Development, Tourism and Environmental Affairs (EDTEA) (ANNEX-1.11.2) o A meeting was held with KZNDED on 25 August 2014, the purpose of the meeting was to present the Scoping Report and conduct a site visit. Refer to ANNEX-1.11.2 for the minutes of the meeting. o Comments and a Rejection of the final Scoping Report pending outstanding aspects being addressed was received from KZNDED on 15 September 2015 and a detailed response was provided (see ANNEX-1.11.2). o A meeting was held on 5 November 2014, the purpose of the meeting was to discuss the comments received. The minutes, presentation and attendance register is attached as ANNEX-1.11.2. o KZNDED accepted the amended Final Scoping Report on 14 April 2015, the acceptance letter is attached in ANNEX-1.11.2 Kwazulu-Natal Department of Water and Sanitation (DWS) (ANNEX-1.11.3) o A meeting was held on 12 November 2013 with Department of Water and Sanitation. Please refer to ANNEX-1.11.3 for the minutes and attendance register. o Comments were received on the Final Scoping Report, which is being addressed during the EIA Phase and once an Integrated Water Use License is applied for by the applicant (see ANNEX-1.11.3). Kwazulu-Natal Department of Agriculture and Rural Development (DARD) (ANNEX-1.11.4) o A meeting was held on 19 November 2014, with the purpose to introduce the project and discuss potential risks and impacts on the agricultural land currently utilised as communal grazing and subsistence farming. Please refer to ANNEX-1.11.4 for the minutes, presentation and attendance register. Kwazulu-Natal Department of Education (ANNEX-1.11.5) o A meeting was held on 20 November 2014 with the Provincial Department and on 10 February 2015 with the District office, with the purpose of introducing the project and discussing potential risks, impacts and benefits the project may have on existing education facilities and services. Please refer to ANNEX-1.11.5 for the minutes, presentations and attendance registers. Kwazulu-Natal Department of Transport (ANNEX-1.11.6) o A meeting was held on 19 November 2014 with the Provincial Department and on 12 February 2015 with the District office, with the purpose to introduce the project and discuss potential impacts the project may have on the current road network as well as the 443 | P a g e







Departments inputs into the planned Access road. Please refer to ANNEX-1.11.6 for the minutes, presentations and attendance registers. o Comments have been received from Mr Wally Bennet from the Department of Transport on the Traffic Impact Assessment, a response was forwarded. Kwazulu-Natal Department of Health (ANNEX-1.11.7) o A meeting was held on 10 February 2015 with the District Office, with the purpose to introduce the project and discuss potential impacts the project may have on Health facilities and services in the local area. Please refer to ANNEX-1.11.7 for the minutes, presentation and attendance register. uThungulu District Municipality (ANNEX-1.11.8) o An initial attempt to schedule a meeting with the UThunguluDistrict Municipality (UDM) prior to the submission of the draft Scoping Report was unsuccessful, see correspondence attached as ANNEX-1.11.8. o A subsequent meeting was scheduled with the UDM’s planning division on 19 November 2014, where their requirements for rezoning was discussed as well as the Environmental Protection divisions involvement in the project. Please refer to ANNEX-1.11.8 for the minutes, presentation and attendance register. Mfolozi Local Municipality (ANNEX-1.11.9) o A meeting was held with the Umfolozi Local Municipality (ULM) on 31 March 2014and again on 19 November 2014 with the Integrated Development Planning Division, with the purpose to introduce the project, discuss the Social and Labour Plan and gain inputs into the process. Please refer to ANNEX-1.11.9 for the minutes, presentation and the attendance register1. o A meeting was held with the Municipal Council on 31 March 2015, the presentation provided is attached in ANNEX-1.11.9. o After the availability of the draft EIA, the results of the EIR/EMPr will be presented to an Intergovernmental Meeting where all relevant Departments will be invited (including District and Local Municipal representatives). The draft EIR/EMPr will be provided to key relevant Departments for the comments and inputs, and included / addressed in the final EIR/EMPr report.

8.8.2 EZEMVELO KZN WILDLIFE ENGAGEMENT (ANNEX-1.12) The following engagement with Ezemvelo KZN Wildlife (EKZN) through correspondence and meetings has taken place:  

 

A meeting was held with EKZN on 13 November 2013. The purpose of the meeting was to introduce the project. Correspondence with EKZN during the announcement and Scoping Phase. The purpose of the correspondence was initiated by the meeting held on 13 November 2013, and was to exchange information that may be relevant to the various specialist studies being conducted. Comments on the draft Scoping Report was received on 9 May 2014, refer to ANNEX-1.12 for a copy. Responses were provided in the final Scoping Report’s Comments and Response Report. No comments were received on the final Scoping Report.

1The

attendance register for the meeting of 31 March 2014 was held by the Municipal Administrative Officer, a copy of the register was requested but not yet received. 444 | P a g e





A meeting was held with Ezemvelo KZN Board on 22 September 2014. The purpose of the meeting was to present the Fuleni Project. The outcome of the meeting was to further engage with the IE Planning division on the results of the specialist studies. Please refer to ANNEX-1.12 for a copy of the meeting notes and the presentation. The commitment made during the engagement with the Ezemvelo KZN Wildlife Board for further engagements will be conducted after the availability of the draft EIA before the completion of the EIA phase. Meetings will be focused on the buffer zone and exploring the possibility of coexistence.

8.8.3 ISIMANGALISO WETLAND PARK ENGAGEMENT (ANNEX-1.13) The following engagement with isiMangaliso Wetland Park through correspondence has taken place: 

 





Comments on the draft Scoping Report was received on 16 May 2014 (allowance for late submission was provided), concerns were raised regarding the potential impact the mine development will have on the isiMangaliso Wetland Park and World Heritage Site status. Please refer to ANNEX-1.13 for a copy of the comments submitted. Comments were further received on the final Scoping Report on 4 August 2014. Please refer to ANNEX-1.13 for a copy of the comments and response provided. Attempts have been made to secure a meeting with isiMangaliso during the Scoping Phase, see correspondence attached as ANNEX-1.13. isiMangaliso has indicated that such a meeting may be scheduled once their comments have been addressed in the EIA report. Once the draft report is available such a meeting will be scheduled. Comments were further received on the amended Final Scoping Report on 27 March 2015. Please refer to ANNEX-1.13 for a copy of the comments and ANNEX-1.22 for the response contained in the Comments and Response report. Further comments and concerns were raised in correspondence on 6 and 11 May 2015 regarding the process. Refer to ANNEX-1.13 for copies of the submissions.

8.8.4 INGONYAMA TRUST ENGAGEMENT (ANNEX-1.14) An attempt to set-up a meeting with the Ingonyama Trust Board was made early on in the process. As part of their administrative process, they have specific requirements prior to a development gaining an opportunity to present the project to the Board meetings. This required process was confirmed by the ITB’s legal representative, Judge Ngwenya. These requirements are being attended to by Ibutho Coal as part of their lease discussions and negotiations. Please refer to ANNEX-1.14 for correspondence with the Ingonyama Board Trust.Post Mining Right decision, Ibutho Coal will attempt to obtain a Traditional Council Resolution, there after the applications for a lease agreement will be followed. In parallel with this process, Ingonyama Trust is being kept up to date on the process progress. Hard copies of the reports are supplied to the ITB as well as the Non-Technical summary for their inputs and comments.

8.8.5 MHLANA TRADITIONAL COUNCIL ENGAGEMENT (ANNEX-1.15) The Mhlana Traditional Council has been extensively engaged over the past 12 months to explain the required process, build capacity and understanding of the project, obtain facilitation and support for arranging community engagement sessions. All available records have been attached as ANNEX-1.15. The following meetings have been held: 445 | P a g e







 









   

Meeting with the Mhlana Traditional Council on 12 February 2014. The purpose of the meeting was to present the Background Information Document (which was distributed). Please refer to ANNEX1.15 for the minutes and attendance register of the meeting. Meeting held with Mhlana Traditional Council on 28 May 2014. The purpose of the meeting was to introduce specialist that will be conducting the Heritage Impact Assessment and Social Survey. See meeting note attached in ANNEX-1.15. Meeting with the Mhlana Traditional Council and Community Representatives were held on 1 July 2014 to discuss progress of the project and the commencement of specialist fieldwork. Refer to meeting note attached in ANNEX-1.15. Meeting held with the Mhlana Traditional Council on 23 July 2014. The purpose of the meeting was to explain the establishment of the Fuleni Mining Forum (FMF). Meeting with the Mhlana Traditional Council on 14 September 2014. The purpose of the meeting was to present the findings of the Scoping Report and explain the process going forward. A copy of the Non-Technical Summary was provided. The minutes are attached in ANNEX-1.15. A meeting was held with representatives from the Mhlana Traditional Council on 3 October 2014 to discuss the challenges and way forward on the engagement process. This meeting resulted in the meeting of 9 October 2014 taking place. Refer to ANNEX-1.15 for minutes of the meeting. Meeting with the Mhlana Traditional Council, FMF and directors of Ibutho Coal on 9 October 2014. The purpose of the meeting was to present the Ibutho Coal policies, EIA process to be followed and other information contained in the Information Flyer to the meeting. Please refer to ANNEX-1.9 for a copy of the information flyer. Meeting with Mhlana Traditional Council on 21 January 2015. The purpose of the meeting was to update the Traditional Council on the various community engagement activities planned for the project and EIA process. Meeting with the Mhlana Traditional Council on 11 February 2015. The purpose of the meeting was to present progress on the project, the Social and Labour Plan and obtain permission to continue with the process. Please refer to ANNEX-1.15 for the resolution taken and attendance register. Further general / ad-hoc meetings were held with the indunas of the affected communities, which are listed under paragraph 8.8.11. Ongoing engagement with the Traditional Council has continued. The preliminary results of the EIA will be discussed with the Traditional Council. Hard copies of the reports are supplied to the Traditional Council as well as the Non-Technical summaries for their inputs and comments.

8.8.6 FULENI MINING FORUM ENGAGEMENT (ANNEX-1.16) The Fuleni Mining Forum was established in July 2014 with the following objectives:   

Receive all information regarding the proposed development and the associated impacts on the communities; To analyse and communicate the information to their relevant communities; and To provide feedback to Ibutho Coal on issues and questions from their respective communities.

The following meetings were held with the Fuleni Mining Forum: 

First meeting was held on 10 August 2014. The purpose of the meeting was to discuss the proposed Terms of Reference. Please refer to Annex-1.16 for a copy of the Terms of Reference. 446 | P a g e





Fuleni Mining Forum Meeting held on 24 August 2014, the purpose of the meeting was to present the project and environmental process, as well as the draft Scoping Report. The Non-Technical Summary of the Scoping Report was made available. Please refer to Annex-1.16 for the minutes and attendance register of the meeting. A meeting was held with the Mhlana Traditional Council and the Fuleni Mining Forum Meeting on 9 October 2014. The purpose of the meeting was to present the Ibutho Coal policies, EIA process to be followed and other information contained in the Information Booklet to the meeting. Please refer to Annex-1.9 for copies of the information booklets.

8.8.7 BROADER COMMUNITY ENGAGEMENT (ANNEX-1.17) 















A meeting was held at Ocilwane Community on 31 August 2014. The meeting was well attended by the community and also included representatives from the Community and Wilderness Alliance (including MACUA). The Environmental Assessment Practitioner was allowed to present the Project Description, the Mining Right and Environmental Authorisation Process. Unfortunately time was not allowed to explain the initially identified risks, impacts and benefits the project may have for the local communities. Please refer to ANNEX-1.17.1 for the minutes. No attendance register was completed. A meeting was scheduled to be held at Novunula on 31 August 2014, but was cancelled post the meeting held in the morning with the Ocilwane Community on the recommendation of the Traditional Council. A meeting was held with the Ntuthunga 1 Community on 14 September 2014. The purpose of the meeting was to explain the proposed project, the Mining Right and Environmental Authorisation process, and the preliminary risks, impacts and benefits the project may have. Please refer to ANNEX-1.17.2 for the minutes of the meetingand attendance register. A meeting was held with the Ntuthunga 2 Community on 21 September 2014. The purpose of the meeting was to explain the proposed project, the Mining Right and Environmental Authorisation process, and the preliminary risks, impacts and benefits the project may have. Unfortunately time was not allowed to give the presentation, due to concerns raised regarding representation from Ibutho Coal, the Prospecting Right Processand Social Survey concerns. Refer to ANNEX-1.17.3 for the minutes of the meeting. No attendance register was completed. A meeting was called at Fuyeni and eMakhwezini on 2 October 2014. The meeting was unfortunately cancelled by the Induna and Forum members due to other commitments on short notice. A combined community meeting was held with Fuyeni, eMakhwezini and Ntuthunga 1 on 7 December 2014. The purpose of the meeting was to discuss any questions or concerns the community may have regarding the project. The information flyer was distributed prior to the meeting and posters on the process and community risks, impacts and benefits were displayed. Please refer to ANNEX-1.17.4 for the minutes and attendance register. A meeting was held with the Nhlabosini and Ncutshini (including Mendu) Communities on 25 January 2015 to present and discuss the proposed Access Road to the mine development that will pass through these communities. The information flyer was distributed in the meeting. Posters were utilised to present the project, the planned access road and potential risks and impacts to the community. Please refer to ANNEX-1.17.4 for the minutes and attendance register of this meeting. A meeting was held with Ntuthunga 2 on 14 May 2015, refer to ANNEX-1.17.5 for the minutes and attendance register 447 | P a g e



A combined Community meeting with members from Ocilwane, Novunula, Ntuthunga 1, Ntuthunga 2, Fuyeni, Emakhwezini and Enhlabosini was held on 17 May 2015. The posters with the preliminary EIA results were made available at the meeting and the Information Booklet containing a summary of the results distributed. Although the Traditional Authority decided to stop the meeting early, information was provided to affected communities.

8.8.8 ONE-ON-ONE ENGAGEMENT (ANNEX-1.18) One-on-one engagements were done through two processes, the social survey visits and the distribution of the information flyer: 



The conducting of the Social Survey, where affected households were requested to provide comments and concerns, please refer to ANNEX-1.18-1 for copies of the completed survey forms. The following villages were included: o Novunula o Ntuthunga 1 o Ntuthunga 2 o The Ocilwane Community could not be visited to complete the Social Survey, as access was being denied due to historical difference between the community, the Traditional Council and Ibutho with regards to the Prospecting Right Process. Further attempts have been made to gain access to this community as can be seen from the Fuleni Mining Forum meetings discussed under paragraph 8.8.4 above. The distribution of the Information Flyer was done by the Fuleni Mining Forum members during November, December and January in Novunula, Fuyeni and eMakhwezini and comments were recorded. The flyer was also distributed to Ntuthunga 1 on7 December 2014, prior to a meeting held, comments were shared at the meeting. The distribution of the Information Flyer is planned for Ntuthunga 1 & 2 as well as Ocilwane, prior to engagement sessions being confirmed with the Traditional Council and the Fuleni Mining Forum members. Records of comments and questions by each household were captured during the distribution process; copies of these records are attached as ANNEX-1.18.2.

8.8.9 OTHER ENGAGEMENTS WITH ENVIRONMENTAL NGO’S (ANNEX-1.19) An organisation was formed of like-minded people to comment on and engage with regards to the Fuleni Project. The organisations’ name is the Community and Wilderness Alliance (under the auspices of Global Environmental Trust), and represents various Environmental Advocacy Groups, Non-Profit Organisations, and environmental concerned citizens. The organisation formally registered on 12 May 2014 although many of the organisations it represents had already registered previously. In response to the Mining Right Application as well as the subsequent draft, final and amended final Scoping Report, the Community and Wilderness Alliance, their supporting organisations and people have objected and opposed the Fuleni Anthracite Project. The majority of the objections received as listed in ANNEX-1.24, are concerned citizens involved with this organisation. They have appointed legal representation headed by attorney Kirsten Youens, who have submitted comments on the Final and Amended Final Scoping Report. Please refer to ANNEX-1.19 for a copy of the comments and response. It is also included in the Comments and Response Report (attached as ANNEX-1.22).

448 | P a g e

This stakeholder has also indicated their intent to appeal the acceptance of the Amended Final Scoping Report. Earth Watch has also submitted comments on the Draft (12 May 2014), the final (17 July 2014) and the amended (6 April 2015) Final Scoping Report. Refer to ANNEX-1.19 for the comments as well as ANNEX1.22 where responses have been provided by the EAP.

8.8.10 EXPLORATION RIGHT APPLICANT – UMBONO CBM SOMKHELE (ANNEX-1.20) The Petroleum Resources Agency of South Africa (PASA) was contacted to obtain the details of the Exploration Right Applicant. They confirmed that the applicant is Umbono CBM Somkhele, but indicated that the application has been abandoned. Umbonohas subsequently confirmed this. See ANNEX-1.20 for a copy of the correspondence.

8.8.11 GENERAL IAP ENGAGEMENT (ANNEX-1.21) A number of other correspondence and comments were received from interested and affected parties prior to the Draft Scoping Report being available as well as post the draft Scoping Report. These comments were acknowledged and included in the Comments and Response Reports, please refer to ANNEX-1.21 for a register of all comments received, as well as the acknowledgement provided. Several meetings have also been held with the Traditional Induna’s, Ward Councillor and Forum Representatives to secure community meetings: 

  

 

  

Meeting held with the Ntuthunga 1, Fuyeni and eMakhwezini Forum members on 4 December 2014. The purpose of the meeting was to discuss the arrangements for the planned Community meeting on 7 December 2014 with the said communities. Meeting held with the Ocilwane and Novunula Forum members on 11 December 2014. The purpose of the meeting was to discuss a possible date to engage these communities on the project. Meeting held with the Ocilwane and Novunula Forum members on 15 December 2014. The purpose of the meeting was to discuss a possible date to engage these communities on the project. Meeting held with Nkosi and his indunas on 14 January 2015. The purpose of the meeting was to provide the intent of meeting with the communities of Ocilwane, Novunula and Ntuthunga 2 in the New Year. Meeting held with the Ward Councillor and the Nkosi’s spokesperson on 19 January 2015 to discuss challenges in arranging the community meeting referred to above. Meeting held with Inkosi, Indunas and the Ward Councillor on 29 January 2015to discuss nonattendance by Traditional Council and Community representatives in arranging the community meeting referred to above. Meeting with the Community FMF members on 5 February 2015. Not all could attend so meeting was postponed. Meeting with the Community FMF members on 13 February 2015. Not all could attend so meeting was postponed. Meeting held with Inkosi, Indunas and the Ward Councillor on 29 January 2015to discuss the challenges and non-attendance by Community representatives in arranging the community meeting referred to above.

449 | P a g e

8.8.12 PUBLIC OPEN DAY A Public Open Day will be held after the availability of the draft EIA, where all interested and affected parties will be provided with an opportunity to raise concerns, make comments and or suggestions to the Environmental Assessment Practitioner and the Applicant. The meeting will be held within the Municipal area.

IAP COMMENTS, SUGGESTIONS AND CONCERNS

8.9

8.9.1 SCOPING REPORT, COMMENTING PERIOD AND COMMENTS AND RESPONSE REPORT (ANNEX-1.22 & 1.23) The Scoping Report compiled included the following information:        

Project Background (including locality, community description, short project description, motivation for the project and the specialist team) Legal Framework Existing Status of the Cultural, Socio-economic and Biophysical Environment Detailed Project Description Description of Potential Impacts associated with the activity Land use or Development Alternatives Stakeholder Engagement Plan of Study (providing an overview of further studies and work to be embarked upon during the EIA/EMPr Phase)

The Scoping Report has gone through three versions due to extensive comments received from both stakeholders and authorities. For the sake of clarification those versions are:   

Version 1: Draft Scoping Report made available on 7 March 2014 Version 2: Final Scoping Report made available on 10 July 2014 Version 3: Amendment to the Final Scoping Report made available on 3 March 2015

The Draft Scoping Report (version 1) was made available for comment to all interested and affected parties on 7 March 2014 for an initial period of 56 days which included 5 public holidays and later extended to 66 days which included 6 public holidays. The report was placed at the Public Places and a hard copy was provided to the following parties:      

Department of Agriculture and Environmental Affairs, subsequently changed to Department of Economic Development, Tourism and Environmental Affairs in Kwa-Zulu Natal on 5 March 2014 Department of Mineral Resources in Kwa-Zulu Natal on 6 March 2014 Mhlana / Mthwethwe Traditional Authority on 9 March 2014 Ezemvelo KZN Wildlife prior to the meeting held on 26 March 2014 Umfolozi Local Municipality on 31 March 2014 (as part of a meeting to present the report)2 uThungulu District Municipality on 10 April 2014 (as part of a meeting to present the report)3

2A

number of attempts were made to present the draft Scoping report to the Mfolozi Local Municipality immediately after it was finalised, but a meeting could unfortunately not be confirmed before the given date 450 | P a g e

  

iMfolozi Library on 7 March 2014 Empangeni Library on 7 March 2014 Richards Bay Library on 7 March 2014

A total of 256 comments submissions were received. See ANNEX-1.5 for the Project Notifications, ANNEX1.6 for advertisements placed and ANNEX-1.7 for the on-site notification and hard copies. Copies of the submission with responses are summarised in the Comments and Response Reports attached as ANNEX1.22, and copies of the submissions are attached as ANNEX-1.23. The final Scoping Report (version 2) was made available to all registered interested and affected parties on 10 July 2014. A total of 10 further comment submissions were received.See ANNEX-1.5 for the Project Notifications and ANNEX-1.7 for the on-site notification and hard copies. Copies of the submission with responses are summarised in the Comments and Response Reports attached as ANNEX-1.22, and copies of the submissions are attached as ANNEX-1.23. The amended final Scoping Report (version 3) was made available to all registered interested and affected parties on 3 March 2015. A total of 5 further comment submissions were received. Copies of the submission with responses are summarised in the Comments and Response Reports attached as ANNEX1.22.

8.9.2 AVAILABILITY OF THE EIR/EMPR REPORT The draft EIR/EMPr report will be made available for 60 calendar days. Notification and advertisements will be placed to ensure all registered and other IAPs are made aware of the reports availability. Hard copies of the reports will be submitted to Authorities, and will also be placed in the Public Places. The report will be available for download or a Compact Disc can be posted on request. Provision will be made to distribute the Non-Technical Summary of the Report in the communities.

8.9.3 IAP COMMENTS, SUGGESTIONS AND CONCERNS (ANNEX-1.22 & 1.23) A number of comments have been received throughout the Environmental Authorisation Application process. The comments are summarised in the Comments and Response Report attached as ANNEX-1.22. Comments are also contained in the meeting minutes and the one-on-one engagements conducted in the communities. Below is an overview of the primary comments and concerns, and should not be seen as an exhaustive list, as all comments are taken into consideration in the Environmental Impact Assessment Process. 8.9.3.1 Comments made by Government Departments  

Compliance with legislation, application for all relevant licenses must be done in advance. No development can take place without all licenses. Early on planning to ensure Government planning is in line with implementation of the project and the establishment of a Governmental Technical Task Team prior to development commencing.

3A

number of attempts were made to present the draft Scoping report to the uThungulu District Municipality immediately after it was finalised, but a meeting could unfortunately not be confirmed before the given date 451 | P a g e



      

 





If an impact on households, schools, clinics and agricultural land cannot be avoided, the various relevant Departments would need to know how resettlement will be scheduled over the life of mine. This will ensure that internal planning is done in advance. Secondary transport / traffic impacts must be considered, i.e. safety of pedestrians, Emergency Medical Services access. Households affected by resettlement must be consulted in terms of the host area options available Development can stimulate economic growth in the area, which is known to struggle with high unemployment rates, illiteracy, low educational performance and poverty. Employment and skills development must be focussed on the local people and consideration must be given to training facilities and services in the Kwa-Zulu Natal area. Proximity to and impact on the protected HiP and Wilderness area, and associated buffer zones, specifically in respect of noise, dust, lighting, visual exposure and sense of place. Impact the mine will have on future growth and expansion plans for the HiP, as well as proposed corridors to link neighbouring reserves. Potential impact on the Hluhluwe-Umfolozi Nature Reserve must be quantified, sensitivity mapping concluded from the specialist studies and then buffer zones determined and agreed with Ezemvelo KZN Wildlife Impact on the catchment water balance and water quality, with specific mention of the potential impact on the downstream iSimangaliso WHS. Increased sedimentation risks due to the large scale clearing of vegetation cover and its potential impact on sensitive downstream aquatic habitats in the Mfolozi River catchment, with specific mention of the Mvamanzi pan and St Lucia Lake. Potential impact on the isiMangaliso Wetland Park and World Heritage site must be investigated and further engagements with the Park once specialist studies are complete and impact is determined. Increased pressure on existing community services and facilities such as clinics, schools, water, and electricity.

8.9.3.2 Comments made by Environmental and Community Advocacy Groups, NGO’s and Environmental Concerned Groups 



Overall ecology of the area: o How mining practices may have a detrimental effect on the ecology and species composition of the areas surrounding the mining area and specifically RDL and TOPS listed species that utilise the area, either permanently or periodically; o How mining practices may affect faunal behavioural patterns, especially of those species sensitive to subsonic and ground vibrations, in the areas surrounding the mine, with special mention to those species present in the neighbouring HiP; o Impacts on migratory movements and ecological corridors and biodiversity linkages between upstream habitats such as the HiP and the downstream coastal habitats; o Impacts from alien vegetation and other edge effects; o Rhino conservation and increased poaching risks. Tourism and how it will be affected in terms of: o Noise and visual impacts, with special emphasis on wilderness trails and wildlife safaris that are conducted in the southern sections of the HiP; o Overall impact on all aspects of tourism in the area and the HiP. 452 | P a g e

   

 

Proximity to and impact on the protected HiP and Wilderness area, and associated buffer zones, specifically in respect of noise, dust, lighting, visual exposure and sense of place. Impact the mine will have on future growth and expansion plans for the HiP, as well as proposed corridors to link neighbouring reserves. Impact on the catchment water balance and water quality, with specific mention of the potential impact on the downstream iSimangaliso WHS. Increased sedimentation risks due to the large scale clearing of vegetation cover and its potential impact on sensitive downstream aquatic habitats in the Mfolozi River catchment, with specific mention of the Mvamanzi pan and St Lucia Lake. Level of consultation with affected communities and the Ingonyama Trust Board. Role of the Public Participation Officer

8.9.3.3 Comments made by the affected and neighbouring communities              

Disruption and displacement of households in close proximity to the proposed mining footprint Potential resettlement – how will it be done, host areas, replacement of all assets Disruption of social networks and cultural believes Community livelihood, e.g. loss of grazing land / arable plots Impact on burial sites and cultural / heritage sites of importance The impact on the livelihood of the community during the decommissioning phase Increased strain on infrastructure / water demand Health, security and social issues Blasting damages to houses Non-delivery on promises of employment and skills development Job opportunities specifically for the Youth Skills development opportunities and Bursaries for the children of the area Local Economic Development projects (SLP) Local procurement and SMME opportunities

For a complete list of comments raised, please refer to On-on-one engagement records (ANNEX-1.16), minutes (ANNEX-1.11 – 1.21) and the Comments and Response Report (ANNEX-1.22 and 1.23). 8.9.3.4 Objections (ANNEX-A23) A total of 527 objections have been received, please refer to ANNEX-1.24 for a list of objections received.

453 | P a g e

9 ADEQUACY OF PREDICTIVE METHODS AND KNOWLEDGE GAPS Sources of uncertainty and risk commonly associated with projects are linked to: 



The studies were carried out with the information available to the specialists at the time of executing the study, within the available timeframe and budget. The sources consulted are not exhaustive and additional information which might strengthen arguments or contradict information in this and the specialist reports might exist. The specialists did endeavour to take an evidence-based approach in the compilation of this report and did not intentionally exclude scientific information relevant to the assessment.

Below a number of limitations and assumptions highlighted by the specialists: Heritage Impact Assessment eThembeni Cultural Heritage conducted a baseline heritage assessment in 2013, the results which are presented in this report. They recommended that a Phase 1 Heritage Impact Assessment be conducted during the EIA Phase of the Fuleni Anthracite Project. Numerous attempts were made to conduct such study; however, due to community resistance the EIA team could not secure access to perform the Phase 1 HIA. An Archaeological and Heritage Strategy has been developed for the project, which includes the undertaking of a Phase 1 HIA prior to construction. Social Impact Assessment 





The 2011 Census is the most current source of official statistics and this has been used for generating a baseline profile of the study area. It should be noted that this data may now be out of date to some degree and may no longer accurately reflect the current socio‐economic profile. Lack of adequate information at the household level in the Ocilwane community due to refusal for access. However, statistics from neighbouring communities and census data were utilised to address the knowledge shortage. Assessment of the impact on sense of place is based on the specialists’ opinion as sense of place is a very personal experience, and is not easily measurable.

Blasting Impact Assessment 





The blasting assessment is based on data provided and international accepted methods and methodology used for calculations and predictions. Assumptions had to be made based on best practice specifically for ground vibration, air blast and fly rock. These factors can be controlled and is manageable. Unknown factors include locations where sensitive animals are most likely to occur. The presence of crocodiles in the specific areas was identified as a possible sensitivity. At the time of this report the exact birdlife was also not known. Though the report tried to address factors associated with blasting operations these unknowns require further investigation. It is also true that surface surroundings change continuously and this should be taken into account prior to any final blast design and review of this report.

454 | P a g e

Visual Impact Assessment 









No specific national legal requirements for VIAs exist in South Africa. Due to a lack of visual and aesthetic specialist guidelines within the KwaZulu Natal Province, the guidelines for the Western Cape was used. No detailed information about building finishes and colours, and lighting types and positioning were available prior to completion of the assessment, and assumptions, related to industry standards, have been made regarding these elements. The viewsheds illustrated in this report indicate the areas from which the proposed project is likely to be visible and does not take local vegetation and man-made structures into account and such components are not permanent and are not included in the databases utilised for viewshed analysis. Potential sensitive receptor sites, indicated to fall within the viewsheds have therefore been ground-truthed during the field assessment. The HiP was not visited during the field assessment due to difficulty of access to remote areas within the south of the park. The border between the HiP and the mining footprint area was however visited and assessed. Measuring abstract or qualitative aspects of the environment and the intangible value of elements of visual and aesthetic significance are difficult to quantify and as such depend to some extent on subjective judgments. It therefore is necessary to differentiate between aspects that involve a degree of subjective opinion and those that are normally more objective and quantifiable.

Biodiversity, Wetland and Aquatic Assessments 





Due to the nature and habits of most faunal taxa it is unlikely that all species would have been observed during a site assessment of limited duration. Therefore, site observations are compared with extensive literature studies where necessary to augment site observations. Sampling by its nature, means that not all individuals are assessed and identified. With ecology being dynamic and complex, some aspects (some of which may be important) may have been overlooked due to seasonal and temporal variances. It is, however, expected that most faunal and floral communities have been accurately assessed and considered and sufficient information is available to allow informed decision making to take place. Due to the phasing of the project, access difficulties due to community concerns and unseasonal drought conditions, no effective wet season survey could be performed. However, site assessments were undertaken during early autumn, early summer and during winter. Additionally, extensive literature reviews of national, regional and local species databases were undertaken in order to

455 | P a g e

 



address any perceived gaps in knowledge in order to accurately assess the faunal and floral ecology of the area. Due to community concerns and safety some areas such as the Mvamanzi Pan could not be assessed in detail due to access being denied during site assessment. The wetland assessment is confined to the mining footprint areas, as well as areas of relevance immediately adjacent to the study area and does not include the neighbouring and adjacent properties. The general surroundings were however considered in the desktop assessment of the study area. In addition it must be noted that the core focus of the study was on the areas to be affected by surface mining operations while less detailed investigations of the full MRA were undertaken. The wetland delineation as presented in this report is regarded as a best estimate of the wetland boundary based on the site condition present at the time of the assessment and limitations in the accuracy of the delineation due to disturbances created by grazing, existing development and anthropogenic disturbances are deemed possible. Wetland areas were also cross referenced with the soil and land capability assessment to ensure accurate classification and delineation of wetland soils.

Noise Impact Assessment Although the layout of the planned surface works and related infrastructure have been finalised, not all detailed specifications are known. Where this is the case, general concepts have been used in the noise impact evaluation and these are adequate to provide a sound basis for the analysis of typical noise conditions and impacts that are likely to prevail on the project. Data related to construction have been sourced from various consultants and contractors, British Standard BS 5228 and the experience that JKA has had working on similar sites. Air Quality Impact Assessment The key to an accurate air dispersion model is to know and understand all sources that could give rise to airborne pollutants. The emission inventory provides the information necessary to complete the setup of an atmospheric dispersion model. The fewer assumptions made during the calculations of emission rates and the setup, the more accurate the results from the model will be. The emission inventory can be based on actual measurements taken at sources, if possible, and/or can be calculated from approved calculation methods (either from the US EPA AP-42 document or the Australian Government NPI document). For the Fuleni Anthracite Project use was made of the US EPA AP-42 for most calculations as limited source specific information is available for the project given that it is not operational yet. It is important to note though that the emission inventory assumes the worst case conditions and the statistically second highest concentration is compared to the national standard. Macro-Economic Assessment Although the macro-econommic assessment attempts to arrive at the total net impact of the investment on the local economy, a full assessment of negative impacts and loss has not been made and the results as such are not indicative of the full potential negative impact of the investment. Without a more complete engagement and input with key stakeholders such as Ezemvelo KZN Wildlife, it may not cover the full negative impact of the investment.

456 | P a g e

10 ENVIRONMENTAL STATEMENT TO BE COMPLETED ONCE COMMENTS RECEIVED ON DRAFT EIA.

457 | P a g e

11 TECHNICAL SUPPORT AND REFERENCES ANNEX-1

Stakeholder Engagement Records

ANNEX-2

Soils, Land Use & Land Capability

Rossouw Associates, 2015

ANNEX-3

Biodiversity Impact Assessment

Scientific Aquatic Services, 2015

ANNEX-4

Surface Water Impact Assessment

WSM Leshika, 2015

ANNEX-5

Groundwater Impact Assessment

Groundwater Complete, 2015

ANNEX-6

Air Quality Impact Assessment

Royal Haskoning DHV, 2012

ANNEX-7

Noise Impact Assessment

Jongens Keet Associates, 2015

ANNEX-8

Ground Vibration & Air Blast Impact Assessment

Blast Management & Consulting, 2015

ANNEX-9

Visual Impact Assessment

Scientific Aquatic Services, 2015

ANNEX-10

Wilderness Risk Assessment

Scientific Aquatic Services, 2015

ANNEX-11

Heritage and Cultural Impact Assessment

eThembeni Cultural Heritage, 2013

ANNEX-12

Social Impact Assessment

Naledi Development, 2015

ANNEX-13

Macro-Economic Impact Assessment

Graham Muller Associates, 2015

ANNEX-14

Health Risk Assessment

Occupational Care SA, 2015

ANNEX-15

Traffic Impact Assessment

ARUP, 2015

ANNEX-16

Cumulative Sensitivity Analysis

Scientific Aquatic Services, 2015

ANNEX-17

Rehabilitation Plan

Ukwazi, 2015

ANNEX-18

Resettlement, Compensation and Mitigation Strategy

References used for the EIA are provided in the individual specialist reports.

458 | P a g e