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BASIC ASSESSMENT REPORT

AND

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT IN SUPPORT OF AN APPLICATION BY ESKOM SOC LTD FOR THE

INSTALLATION OF A 132 KV OVERHEAD POWERLINE AND SUBSTATION TO SUPPLY SAMANCOR’S LWALA MINE

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT 107 OF 1998) AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2008 (ACT 59 OF 2008) IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BECAUSE OF THE REQUIREMENTS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (ACT 28 OF 2002) (AS AMENDED).

Name of applicant: Eskom SOC LTD.

Tel no: +27 11 800 8111

Fax no: +27 86 292 4326

Postal Address: PO Box 1091, Johannesburg, 2001

Physical address: Megawatt Park, Maxwell Drive, Sunninghill, Sandton

File Reference Number: Still to be Issued

TABLE OF CONTENT TABLE OF CONTENT ....................................................................................................................... ii

LIST OF APPENDICES ..................................................................................................................... v

LIST OF ABBREVIATIONS & ACRONYMS ................................................................................... vii

1 IMPORTANT NOTICE ................................................................................................................ 1

2 OBJECTIVES OF THE BASIC ASSESSMENT PROCESS ....................................................... 2

PART A .............................................................................................................................................. 2

3 SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT ......................................... 2

3.1 Contact person and correspondence address ................................................................... 2

3.2 Location of the overall activity ............................................................................................ 3

3.3 Locality Map ....................................................................................................................... 3

3.4 Description of the Scope of the proposed overall Activity .................................................. 4

3.5 Policy and Legislative Context ........................................................................................... 8

3.6 Need and desirability of the proposed activities ................................................................. 9

3.7 Motivation of the overall preferred site, activities and technology alternative .................. 12

3.8 Full description of the process followed to reach the proposed referred alternatives

within the site ................................................................................................................... 13

a) Details of the development footprints alternatives considered ........................................ 13

3.9 Details of the Public Participation Process Followed ....................................................... 16

a) Summary of issues raised by I &AP’s .............................................................................. 18

3.10 The Environmental Attributes associated with the alternatives ........................................ 20

a) Baseline Environment ...................................................................................................... 20

3.11 Impacts and risk identified including the nature, significance consequence, extent,

duration and probability of the impacts, including degree to which these impacts .......... 31

3.12 Methodology used in determining and ranking the nature, significance,

consequences, extent, duration and probability of potential environmental impacts

and risks .......................................................................................................................... 42

a) Positive and negative impacts that the proposed activity (in terms of the initial site

layout) and alternatives will have on the environment and the communities that may

be affected ....................................................................................................................... 43

b) The possible mitigation measures that could be applied and the level of risk ................. 44

c) Motivation where no alternative sites were considered ................................................... 44

d) Statement motivating the alternative development location within the overall site .......... 45

e) Full description of the process undertaken to identify, assess and rank the impacts

and risks the activity will impose on the preferred site (In respect of the final site layout

plan) through the life of activity. ....................................................................................... 45

3.13 Assessment of each identified potentially significant impact and risk .............................. 46

3.14 Summary of specialist reports. ......................................................................................... 48

3.15 Environmental impact statement ...................................................................................... 49

a) Summary of the key findings of the environmental impact assessment; ......................... 49

b) Final site map .................................................................................................................. 49

c) Summary of positive and negative impacts and risks of the proposed activity and

identified alternatives; ...................................................................................................... 49

3.16 Proposed management impact objectives and the impact management outcomes for

inclusion in the EMPr; ...................................................................................................... 50

3.17 Aspects for inclusion as conditions of Authorisation ........................................................ 50

3.18 Description of any assumptions, uncertainties and gaps in knowledge ........................... 51

3.19 Reasoned option as to whether the proposed activity should or should not be

authorized ........................................................................................................................ 51

a) Reasons why the activity should be authorized or not ..................................................... 51

b) Conditions that must be included in the authorization ..................................................... 52

3.20 Period for which the Environmental authorization is required .......................................... 52

3.21 Undertaking ...................................................................................................................... 52

3.22 Financial Provision ........................................................................................................... 53

a) Explain how the aforesaid amount was derived .............................................................. 53

b) Confirm that this amount can be provided for from operating expenditure ...................... 53

3.23 Specific information may be required by the competent authority .................................... 53

a) Compliance with the provisions of section 24(4)(a) and (b) read with section 24(3) (a)

and (7) of the National Environmental Management (Act 107of 1998). The EIA must

include the:- ..................................................................................................................... 53

3.24 Other matters required in terms of section 24(4)(a) and (b) of the Act. ............................ 55

PART B ............................................................................................................................................ 56

1 ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT .............................................. 56

1.1 Draft Environmental Management Programme ................................................................ 56

a) Details of the EMP ........................................................................................................... 56

b) Description of the Aspect of the Activity .......................................................................... 56

c) Composite Map ................................................................................................................ 56

d) Description of Impact management objectives including management statements ........ 56

1.2 Impact management Outcomes ....................................................................................... 65

1.3 Impact Management Actions ............................................................................................ 71

1.4 Financial Provision ........................................................................................................... 75

a) Determination of the amount of Financial Provision ........................................................ 75

b) Monitoring of impact Management Actions ...................................................................... 77

c) Responsible persons ....................................................................................................... 83

1.5 Indicate the frequency of the submission of the performance assessment or

environmental audit report. .............................................................................................. 87

1.6 Environmental Awareness Plan ....................................................................................... 87

a) Manner in which the applicant intends to his or her employees of environmental risk

which may result from their work. .................................................................................... 87

b) Manner in which risks will be dealt with in order to avoid pollution or the degradation

of the environment. .......................................................................................................... 87

1.7 Specific information required by the Competent Authority ............................................... 87

1.8 UNDERTAKING ............................................................................................................... 88

TABLE OF FIGURES Figure 1: Alternative 1 layout map .................................................................................................... 14

Figure 2: Alternative 2 layout map .................................................................................................... 15

Figure 3: Geology recorded in study area ......................................................................................... 21

Figure 4: Soils recorded in study area .............................................................................................. 21

Figure 5: Average rainfall at WB 0589352 ........................................................................................ 23

Figure 6: Land use cover over study area ........................................................................................ 24

Figure 7: Critical Biodiversity Areas (CBA) and Ecological Support Units (ESU) in study area ........ 27

Figure 8: Water courses delineated within study area ...................................................................... 28

TABLES Table 1: PPP undertaken to date ..................................................................................................... 16

Table 2: Interested and affected parties comment table .................................................................. 18

Table 3: Monthly minimum, average and maximum rainfall at station WB 0589342 ....................... 22

Table 4: Details of study areas vegetation types ............................................................................. 25

Table 5: Critical Biodiversity Areas (CBA) and Ecological Support Units (ESU) over study

areas .................................................................................................................................. 26

Table 6: Community household and population statistics ................................................................ 29

Table 7: Sensitive and protected bird species that occurs or might occur within project area ......... 30

Table 8: Risk assessment ranking scale of the four factors (probability, duration, extent and

severity) used to determine significance ratings ................................................................ 42

Table 9: Table of risk significance .................................................................................................... 43

LIST OF APPENDICES APPENDIX 1 EAP DETAILS APPENDIX 2 PROJECT MAP(S) APPENDIX 3 EXISTING AND EXPIRED AUTHORISATIONS APPENDIX 4 SITE PLAN(S) APPENDIX 5 PROPERTY DESCRIPTIONS APPENDIX 6 SIP CONFIRMATION LETTER – NOT APPLICABLE APPENDIX 7 RECORD OF PPP APPENDIX 8 AUTHORITY CONSULTANT APPENDIX 9 SPECIALIST STUDIES APPENDIX 10 ADDITIONAL INFORMATION – NOT APPLICABLE

LIST OF ABBREVIATIONS & ACRONYMS

DMR – Department of Mineral Resources

EA – Environmental Authorisation

EAP – Environmental Assessment Practitioner

EIA – Environmental Impact Assessment

EIR – Environmental Impact Report

EMPr – Environmental Management Programme Report

EP – Environmental Practitioner

EMS – Environmental Management System

IDP – Integrated Development Plan

LED – Local Economic Development Strategy

MG – Middle Group

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

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

NEMAQA – National Environmental Management Air Quality Act, 2004 (Act 39 of 2004)

PPP – Public Participation Process

ROM – Run of Mine

SANS – South African National Standards

WML – Waste Management Licence

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1 IMPORTANT NOTICE

In terms of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) (As amended) (MPRDA), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment.”

Unless an Environmental Authorization can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment.

In terms of Section 16(3)(b) of the Environmental Impact Assessment (EIA) Regulations, 2014, promulgated in terms of NEMA, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of Section 17(c) of the same Regulations, the Competent Authority must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the Competent Authority to the submission of applications.

It is therefore an instruction that the prescribed reports required in respect of applications for an Environmental Authorization for listed activities triggered by an application for a right or a permit in terms of the MPRDA are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore, please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the regulation and will lead to an Environmental Authorisation being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner (EAP) must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the report, in the order, and under the provided headings as set out below, and ensure that the report is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.

2 OBJECTIVES OF THE BASIC ASSESSMENT PROCESS

The objectives of the Basic Assessment process are to, through a consultative process –

(a) Determine the policy and legislative context within which the proposed activity is located and how the activity complies with and response to the policy and legislative context;

(b) Identify the alternatives considered, including the activity, location, and technology

alternatives; (c) Describe the need and desirability of the proposed alternatives, (d) Through the undertaking of an impact and risk assessment process inclusive of cumulative

impacts which focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to determine: (i) the nature, significance, consequence, extent, duration, and probability of the impacts

occurring to; and (ii) the degree to which these impacts-

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

(e) Through a ranking of the site sensitivities and possible impacts the activity and technology

alternatives will impose on the sites and location identified through the life of the activity to- (i) identify and motivate a preferred site, activity and technology alternative; (ii) identify suitable measures to manage, avoid or mitigate identified impacts; and (iii) identify residual risks that need to be managed and monitored.

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This document has been prepared by ACER (Africa) Environmental Consultants

Report type: Basic Assessment Report (BAR) and Environmental Management Programme (EMP)

Project name: Draft Basic assessment report and Environmental management programme for the Eskom Lwala powerline and substation project

Project code: ESKOM/19/01

Name: Responsibility: Signature: Date:

Marius Alers Author / Compiler

02 / 07 / 2019

Giles Churchill Author / Compiler

16 / 07 / 2019

Taryn Bigwood Reviewer

27/07/2019

This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without ACER (Africa) Environmental Consultants’ prior written

consent.

PART A

3 SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT

ACER Africa (Pty) Ltd (ACER Africa) has been requested to undertake the Environmental Authorisation process associated with the construction and installation of a 132 KV overhead powerline and substation in terms of NEMA to the Limpopo Department of Mineral Resources (DMR) on behalf of the applicant ESKOM SOC LTD (ESKOM). The project will be located on the following properties; the farms Forest hill 117 KT and Clapham 118 KT, situated in the Fetakgomo Tubatse magisterial district, Limpopo Province.

3.1 Contact person and correspondence address

(a) Details of the EAP

Name of practitioner: Giles Churchill

Telephone: +27 35 340 2715

Fax: +27 35 340 2232

Email: [email protected]

(b) Expertise of the EAP

Mr Churchill has 13 years of experience in the environmental consulting field in South Africa and SADC countries. He has undertaken numerous environmental assessments across a range of sectors including irrigated agriculture (including sugar cane and processing), transport, ports, mining sector, renewable energy, and, protected areas management and conservation. His role in the assignments successfully completed has ranged from project manager, team leader, environmental assessment practitioner, specialist, internal reviewer, to team member, each role having different responsibilities and levels of accountability. In addition, he has been actively involved in compensation related activities in Mozambique in accordance to World Bank Standards and has an in-depth knowledge of stakeholder engagement, compensation procedures and identification of beneficiaries. He has extensive experience in the drafting of Environmental Management Programmes (EMPr’s) and has fulfilled the role of Environmental Compliance Officer on various developments over the last 12 years.

mailto:[email protected]

(c) The Qualifications of the EAP

Name Education Qualifications Professional Affiliations

Experience at Environmental Management

Mr Giles Churchill

MSc

International Association of Impact Assessment (South African Chapter).

SACNASP registered (No. 116348)

13 Years

Mr Marius Alers BSc - Hons

International Association of Impact Assessment (South African Chapter).

SACNASP registered (No. 400386/14)

9 Years

(d) Summary of EAP’s past experience

(In carrying out the Environmental Impact Assessment)

Please Refer to Appendix 1.

3.2 Location of the overall activity

Farm name: Forest hill 117 KT and Clapham 118 KT

Application area (Alternative 1):

Substation footprint 1,5 ha Loop-in and Loop-out 132 kV lines servitude size of 45 ha

Magisterial district: Sekhukhune District Municipality (SDM) and Fetakgomo Tubatse Local Municipality (FTLM)

Distance and direction from nearest town:

40 km north of Burgersfort

21-digit Surveyor General Code for each farm portion:

Forest hill 117 KT – T0KT00000000011700000 Clapham 118 KT – T0KT00000000011800000

3.3 Locality Map

(Show nearest town scale not smaller than 1:250000)

Please Refer to Appendix 2.

3.4 Description of the Scope of the proposed overall Activity

(Provide a plan drawn to scale acceptable to the Competent Authority but not less than 1: 10 000 that shows the location, area (Hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site)

(a) Listed and specified activities NAME OF ACTIVITY

(E.g. For prospecting - drill site, site camp, ablution facility, accommodation, equipment storage, sample storage, site office, access route etc…etc…etc

E.g. for mining,- excavations, blasting,

stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.)

AERIAL EXTENT OF THE ACTIVITY Ha or m2

LISTED ACTIVITY Mark with an X where applicable or affected

APPLICABLE LISTING NOTICE (GN.R 983, 984 or 985)

The clearance of an area of 300 square metres or more of indigenous vegetation

Servitude covers +/- 45,000 m2 but actual vegetation clearance is anticipated to be as follows: Substation = 15,000 m2

Loop -in-Loop-out Lines = 750 m2

X GN.R 985 as amended (GN.R 324) Listing Notice 3: Activity 12 Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; ii. Within critical biodiversity areas identified in bioregional plans

The proposed project involves the construction of a Lwala Sub-station as well as power lines to connect the sub-station to the Steelpoort-Twickenham 132 Kv line which will require the clearance of vegetation within the construction footprints. Project components include the installation of a Loop-in-Loop-out (LILO) 132 KV overhead line and construction of a substation (dimensions of 100 m X 150 m).

Servitude covers +/- 45,000 m2 but actual vegetation clearance is anticipated to be as follows: Substation = 4,331 m2

(actual footprint) however 20,000 m2 has been set aside for the

X GN.R 983 as amended (GN.R327) Listing Notice 1: Activity 27 The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation

NAME OF ACTIVITY (E.g. For prospecting - drill site, site camp,

ablution facility, accommodation, equipment storage, sample storage, site office, access route etc…etc…etc

E.g. for mining,- excavations, blasting,

stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.)

AERIAL EXTENT OF THE ACTIVITY Ha or m2

LISTED ACTIVITY Mark with an X where applicable or affected

APPLICABLE LISTING NOTICE (GN.R 983, 984 or 985)

substation and construction camp. Loop -in-Loop-out Lines = 750 m2

The proposed development will entail the construction of the following project components: 2 x 2 km new WOLF line for a

Loop In and Loop Out to the Steelpoort-Twickenham 132 kV line.

Construct a new substation called LWALA

2 x 132 kV feeder bays (Equip both feeder bays)

2 x 40 MVA 132/33 kV transformers 2 x 33 kV feeder bays

Powerline servitude of +/- 45,000 m2 and Substation footprint of +-4,331 m2

X GN.R 983 as amended (GN.R 327) Listing Notice 1: Activity 11 The development 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

(b) Description of the activities to be undertaken

(Describe Methodology or Technology to be employed, including the type of commodity to be prospected/mined and for a linear activity, a description of the route activity)

The aim of the project is to provide additional electricity to Lwala Mine and surrounding community areas where electricity demand is increasing. The construction of the Eskom substation and powerline will hereafter be referred to as the Lwala project. The proposed development will entail the construction of the following project components:

• 2 km of new WOLF line for a Loop-in and Loop-out to the Steelpoort-Twickenham 132 kV line;

• Construction of a new substation called LWALA which will include the following: 2 x 132 kV feeder bays (Equip both feeder bays); and 2 x 40 MVA 132/33 kV transformers with 2 x 33 kV feeder bays.

Environmental authorisation is being sought from the Department of Mineral Resources (DMR) in terms of the National Environmental Management Act, 1998 (NEMA) (Act No. 108 of 1998) as amended, and the 2014 Environmental Impact Assessment Regulations GN.R 982 - 985 (as amended in 2017), as the listed activities associated with the construction of the Lwala Substation and Loop-in and Loop-out lines are directly related to the extraction and primary processing of a mineral or petroleum resource. The proposed project triggers listed activities in Listing Notice 1 GN.R 983 (as amended in GNR 327 of 07 April 2017) and Listing Notice 3 GN.R 985 (as amended in GNR 324 of April 2017), which requires the undertaking of a Basic Assessment involving technical studies and a process of public participation. Technical Details of the project

(A) Width, length of structure and material used in the Loop-in and Loop-out 132 kV lines

The footprint for the planted self-supporting mono-pole structures is 1,2 m x 1,2 m. The footprint for guyed monopole in-line strain is 0,95 m x 0,65 m with 4 x diagonal stays positioned up to 17,0 m from the structure centre. The footprint for guyed mono-pole angle strain is 0,95 m x 0,65 m with 5 - 7 x bi-sector and line stays positioned up to 22,0 m from the structure centre. The nominal lengths for the mono-pole structures vary between 18,0 m - 24,0 m. Normally 80 μm protective zinc coating is required for Eskom installations, but a 120 μm can be specified for special conditions.

Examples of the 132 kV monopole pylon structures

(B) Access Roads

Existing tar and dirt roads will be used to gain access during the construction and operational phase (maintenance purposes) of the project.

(C) The depth of the tower foundations

The self-supporting mono-pole structures will be planted at approximately 3 m deep. All other foundation excavations are 550 mm deep. Stays are installed 1.75 m deep.

Foundation excavation (source ESKOM)

(D) Materials used for tower foundations

1:10 soil/cement mixture is compacted for backfilling (if poor soil conditions are present on-site material will be imported from commercial licensed suppliers). For self-supporting mono-pole structures 25 MPa reinforced concrete pedestal foundations are used to anchor the structures. (E) Materials used for the substation foundations The substation platform will be constructed using suitable grade gravel (G5 and G7) which is then compacted and excavated to install the substation infrastructure. All materials will be sourced for licensed commercial suppliers and no borrows will be created on site. (F) Location of the Line and Substation Substation coordinates: Northern corner - 24°28'44.58"S and 30° 06'03.86"E South-Eastern corner - 24°28'47.23"S and 30° 06'05.18"E Southern corner - 24°28'47.83"S and 30° 06'03.61"E Western corner - 24°28'45.22"S and 30° 06'02.36"E Powerline coordinates (Preferred alternative): Beginning - 24°28'26.02"S and 30° 06'48.04"E Middle - 24°28'35.98"S and 30° 06'26.64"E

End - 24°28'46.11"S and 30° 06'04.97"E

3.5 Policy and Legislative Context

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (Description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plan, guidelines, spatial tools, Municipal development planning frameworks instruments that are applicable to this activity and are to be considered in the assessment process

REFERENCE WHERE APPLIED

HOW DOES THIS DEVELOPMENT COMPLY WITH AND RESPOND TO LEGISLATION AND POLICY CONTEXT? (E.g in terms of the National water Act a Water use license has/has not been applied for)

NEMA EIA Regulations 2014

BAR and EMPr

This BAR and EMPr were compiled in terms of the NEMA EIA Regulations 2014 as amended. The applicable requirements of the EIA Regulations were adhered to during the compilation of this report

MPRDA (No. 28 of 2002) and Regulations thereunder

BAR and EMPr

The applicable MPRDA Regulations were adhered to during the compilation of this report.

Guideline on Public Participation (March 2013)

BAR The public participation guideline was consulted to ensure that an adequate public participation process is undertaken.

Guideline on Alternatives (March 2013)

BAR and EMPr

This guideline was consulted to inform the consideration of alternatives.

Guideline on Need and Desirability (March 2013)

BAR and EMPr

This guideline was consulted to inform needs and desirability aspects of the proposed project.

NWA (No. 36 of 1998) GA A GA application might be needed if 21 (c) and (i) activities are triggered at the drainage lines and water course crossings. DWS will be consulted to establish whether a GA is required for the proposed development.

National Heritage Resources Act of 1999 (Act 25 of 1999) (NHRA).

BAR and SAHRA

A heritage impact assessment was completed for this application.

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

BAR and EMPr

A wetland identification and flora and fauna specialist study were undertaken for this application. Removal and control of all alien invasive plant species needs to be done in accordance with the Invasive Species Regulations, GN R598 of 2014.

The National Forests Act, 1998

BAR Tree permit applications will be compiled should any protected trees require translocation or removal during the construction phase of this development.

3.6 Need and desirability of the proposed activities

(Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location)

NEED AND DESIRABILITY OF THE PROPOSED PROJECT After the Need and Desirability Guideline Published in terms of the Environmental Impact

Assessment Regulations, 2010. Notice 792 of 2012 PART I: NEEDS

Question Answer Is the land use associated with the activity being applied for considered within the timeframe intended by the existing approved Spatial Development Framework agreed to be the relevant environmental authority?

Yes. The Fetakgomo Tubatse Local Municipality integrated development plan for 2018-2019 notes that the chrome mining operations and its associated structures are an integral part of its rationale to make use of the abundant natural resources in the area to create a strong, resilient and prosperous district and to promote job creation and investment into the area.

Should the development, or if applicable, expansion of the town/area concerned in terms of this land use occurs here at this point in time?

Yes, according to the Fetakgomo Tubatse Local Municipality, the proposed project falls within an area which is demarcated as “rural”, and the intention of development in this area is to create vibrant, equitable and sustainable rural development which provides investment and work opportunities.

Does the community/area need the activity and the associated land use concerned? This refers to the strategic as well as local level.

Yes it does. According to the Integrated Development Plan of 2018, this is a predominantly rural / agricultural region. Farming activities focus on cattle ranching, limited game farming, and maize cultivation. Chrome mining is an important economic driver in this area as it provides job opportunities and adds to SA’s exports. Without the proposed Lwala Substation and 132 kV lines the mine will not be able to operate, and the surrounding communities will not be able to access electricity.

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

Yes, the necessary services with adequate capacity are available for the development of the substation and powerlines. During

construction and operation of the substation the following services are required: Limited volumes of water will be sourced

from legally compliant water service providers.

Access to the site is along an existing road network and the project will not have a major impact on road congestion.

it must be noted however that this project is being implemented to provide capacity to the Lwala Mine which needs additional electricity for it to continue operating.

Is this development provided for in the infrastructure planning of the municipality, and if not what will the implication be on the infrastructure planning of the municipality (priority and placement of the services and opportunity cost)?

The development is not provided for in the infrastructure planning of the municipality as it is ancillary to the Lwala mining operation. Thus, the proposed project will not have any implications for the infrastructure planning of the municipality as no services and/or infrastructure needs to be upgraded or created to cater for this development. The proposed development will complement the infrastructure planning initiatives of the municipality as an additional substation run by Eskom will be available to service rural areas within the municipality.

Is the project part of a national programme to address an issue of national concern or importance?

No, this project is not part of a national programme to address an issue of national concern or importance directly, but indirectly, this activity will ensure the long-term sustainability of an existing mine and industry. The mining sector is a significant contributor to the National Gross Domestic Product as well as a large employer of people. In addition, the project will provide a source of electricity to surrounding rural communities which does address an issue of national concern in terms of service delivery to rural communities.

PART II: DESIRABILITY Is the development the best practicable environmental option for this land/site?

Yes. The sites identified for the project has the least impact on natural veld and agricultural fields. Project infrastructure was positioned in consultation with landowners and various specialists.

Would the approval of this application compromise the integrity of the existing approved and credible IDP and SDF as agreed to by the relevant authorities?

No. The proposed project aligns itself with the Fetakgomo Tubatse Local Municipality IDP. The following strategic objectives are sought to be achieved and are aligned with the objectives of the proposed project:

• Promote shared economic growth and job creation

• Improve financial sustainability • Continue institutional development,

transformation and innovation • Improve service delivery

Would the approval of this application compromise the integrity of the existing environmental management priorities for the area (e.g. as defined in EMFs), and if so, can it be justified in terms of sustainability considerations?

No, the integrity of the existing environmental management priorities for the area will not be compromised by this development.

Do location factors favour this land use at this place? (this relates to the contextualization of the proposed land use on this site within its broader context).

Yes, this area has been earmarked for mining development in the greater context of the province due to its location and geological significance. The geology largely dictates the location of the mine and the position of the Lwala Substation which is required to supply electricity to the mine.

How will the activity of the land use associated with the activity being applied for, impact on sensitive natural and cultural areas (built and rural/natural environment)?

The proposed development will exert an impact on the environment; but based on the findings of the Specialist Studies, and as per the specialist recommendations and the locality of the site, the impacts associated with this proposed development can be mitigated to an acceptable level (Low, Low-Medium). The powerline also crosses a CBA, but no vegetation clearance will take place in this area.

How will the development impact on people’s health and well-being? (E.g. In terms of noise, odours, visual character and sense of place, etc.)?

This area has a low density of residents and dwellings, the impacts on well-being, following mitigation, will be as follows:

• Visual: Low • Dust: Low • Noise: Low

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

No, the project will result in no unacceptable opportunity costs.

Will the proposed land use result in unacceptable cumulative impacts?

In terms of the cumulative impacts of the proposed development no unacceptable impacts have been identified. Impacts associated with the development are primarily confined to the construction phase which are temporary in nature and considered to be of low significance. All the anticipated impacts on the biophysical environment are rated as low while the impacts on the socio-economic environment are rated as positive.

3.7 Motivation of the overall preferred site, activities and technology alternative

Substation Position and Layout: The internal layout of the Lwala Substation (Appendix 4) is entirely dependent on its position in relation to the incoming loop-in and loop-out HV power lines, as well as the outgoing MV power lines. Due to the current mining operations and layout of the mine no additional internal layout alternatives were assessed as the proposed substation must tie into the existing mine layout. Similarly, no alternative sites for the substation were assessed as the mine has demarcated a site for the substation in the mine’s layout plan (Appendix 4). An area of 2 ha was assessed during this assessment for the placement of the substation. The substation which has a footprint of 4,331 m2 will be located within the 2-ha site assessed with the final position of the substation located to conform with the mine layout plan. Alignments of the Loop-in and Loop-out 132 kV powerlines: Given that the location of the substation within the mine’s property (Appendix 5) has been predetermined, based on the mine layout plan, alternative alignments for the Loop-in and Loop-

out lines were limited. Two possible alignment alternatives were assessed to link the substation to the existing Steelpoort-Twickenham 132 kV line located to the north east of the mine. For most of the risks assessed the risk ratings were similar for the two alternatives considered. The ecological study however identified some differences between the two alternatives in terms of risk ratings due to Alternative 1 crossing more drainage lines. The risk assessment found that the cumulative risk rating (when all risk ratings for ecological are added up) was 124 for Alternative 2 and 104 for Alternative 1, with Alternative 1 thus having a lower cumulative risk rating. The ecological specialist study also stated the following: “Additionally, as a result of Alternative 1 posing less risk of directly or indirectly impacting on the delineated watercourse within the study area it is recommended that this route be utilised for the proposed development.”

• Alternative 1 is thus the preferred option to proceed with.

Technology Alternatives: Alternative technologies have not been considered as the technology to be used is already considered as the most appropriate technology and in some cases has been specifically designed for the existing environmental conditions and terrain, as specified by standard Eskom specifications and international best practice. The pylons under consideration for this project are the most appropriate based on the terrain and design integrity as well as for the purpose for which the powerline is to be constructed. The power line structures proposed for this project are single circuit steel monopoles

3.8 Full description of the process followed to reach the proposed referred alternatives within the site

(NB!!- This section is about the determination of the specific site layout and the location of infrastructure and activities on site, having taken into consideration the issue raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout.)

a) Details of the development footprints alternatives considered

With reference to the site plan provided as Appendix 4 and the location of the individual activities on site, provide details of alternatives considered with respect to: (a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational expects of the activity; and (f) the option of not implementing the activity.

NEMA requires that alternatives be considered during the EIA process. According to DEA (2004)1 “an alternative can be defined as a possible course of action, in place of another, that would meet the same purpose and need”.

Process followed to reach the proposed referred alternatives:

Design or layout Alternative:

Alternative 1 (Preferred option)

The first, and preferred, option is a 1.4 km linear straight line from the Steelpoort-Polokwane 132 KV main line to the planned Lwala Substation.

Alternative 1 falls entirely on the Clapham 118 KT farm and potentially affect the Ga-Manyaka community. Alternative 2 falls within ward 8 and 17 of the Fetakgomo Tubatse Local Municipality.

Alternative 1 is illustrated in Figure 1 below.

Figure 1: Alternative 1 layout map

Alternative 2

The second, and alternative, option is a 2 km linear non-straight line from the Steelpoort-Polokwane 132 KV main line to the planned Lwala Substation.

Alternative 2 falls on both the Forest hill 117KT and Clapham 118 KT farm and affects potentially all three nearby communities of Ga-Manyaka, Ga-Mashishi and Ga-Kgoete. Alternative 2 also falls within ward 8 and 15 of the Fetakgomo Tubatse Local Municipality.

Alternative 2 is illustrated in Figure 2 below.

Figure 2: Alternative 2 layout map

Technology Alternatives

No design alternatives were considered as the technology to be used is already considered as the most appropriate technology and in some cases has been specifically designed for the existing environmental conditions and terrain, as specified by standard Eskom specifications and international best practice.

No-go Alternative

The “no-go” alternative assumes that the project is not implemented and therefore the associated Lwala mine will not be able to ramp up on-site processing and other ancillary services. This could hamper the operation’s economic viability and bring ramp-up, and potentially even normal operations, to a halt, which would cause equivalent economical losses. In addition, the proposed project is aimed to provide electricity to the surrounding community areas once mining has been completed and will play a key role in Eskom’s distribution network for the area even after the mine has been decommissioned and rehabilitated.

3.9 Details of the Public Participation Process Followed

(Describe the process undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public meetings. (information to be provided to affected parties must include sufficient detail of the intended operation to enable them to assess what impact the activities will have on them or on the use of their land.)

Consultation with the public forms an integral component of the environmental authorisation process and is to address Section 23 of NEMA. The Public Participation Process (PPP) has been structured to provide I&APs with an opportunity to gain more knowledge about the proposed project, to provide input through the review of documents/reports, and to voice any issues or concern at various stages throughout the EIA process. This process includes all I&AP’s (e.g. directly affected landowners, national-, provincial- and local authorities, and local communities etc.).

The PPP will be managed to meet these objectives throughout the BA. The approach followed for the PPP is according to Chapter 6 of the EIA Regulations, 2014 published in Government Notice No. 982 of 4 December 2014.

The PPP conducted to date is summarised below:

Table 1: PPP undertaken to date

Task Details Date

I&AP notification (relevant authorities and I&APs) I&AP identification

An I&AP database was developed for the project by establishing the jurisdiction of organisations, individuals and businesses in proximity to the project site or within an interest in the proposed development. The database of I&APs includes the landowner, the adjacent landowners, relevant district and local municipal officials, relevant national and provincial government officials, and organisations. This database is being augmented via chain referral during the BA process and will be continually updated as new I&APs are identified throughout the project lifecycle. The current list of potential I&APs is attached in Appendix 7.

Continuous process

Site notices Site notices with a size of 297 mm x 420 mm were erected at strategic points to inform the general public of the proposed projects and the PPP. Photos of the site notices have been included in Appendix 7 of the draft Basic Assessment Report (DBAR) and an example is provided below.

Onsite Notices displayed within the project area

4 June 2019

Initial Notification

Initial notification letters were sent to various stakeholders including affected farm owners and organs of state (Appendix 7). Emails were sent to the identified I&APs, notifying them of the availability of the Background Information Document (BID) (Appendix 7) for the proposed project for perusal and comment. Authorities and I&APs were given 30 days within which to register and submit initial comments on the proposed project.

3 June 2019

Media Adverts

The Steelburger newspapers were used to advertise the project in both English and Sepedi (Appendix 7).

31 May 2019

Comments received

The comments received from the landowners to date are captured in the Issues and Response Report.

Continuous

Community meetings were held on 11 June 2019, 19 June 2019 and 27 June 2019, respectively, at the Ga-Mashishi village (Roka Mashishi traditional council), Ga-Kgoete village (Nareng Thokoane Traditional council) and Ga-Manyaka village (Manyaka community development forum).

Comment on DBAR

All the relevant stakeholders will be notified of the availability of the DBAR to provide their comments.

Date to be confirmed

a) Summary of issues raised by I &AP’s

(Complete the table summarising comments and issues raised, and recreation to those responses)

A number of comments have been received from potentially affected parties regarding the proposed project during community meetings. No objections to the proposed prospecting activities have been received, though.

All comments received are tabled below:

Table 2: Interested and affected parties comment table

Interested and affected parties List the names of persons consulted in this column, and mark with an X where those who must be consulted were in fact consulted

Date Comments received

Issues Raised EAP’s Response to issues as mandated by the applicant

Section and paragraph reference in this report where the issues and or response were incorporated

AFFECTED PARTIES Landowner/s (Ga-Mashishi – Roka Mashishi traditional council)

X 11 June 2019 • Various concerns were raised regarding the dust and vibration from the blasting and mining nearby. (not project related)

• Requests were made to create local employment opportunities.

• Further requests were made that such sourcing of local employment happens according to the community processes.

• Requests were made for the basic assessment reports to be made available for review.

• All matters raised were addressed in this document and in the EMPr.

EMPr Section 4.2

Landowners (Ga-Manyaka – Manyaka community development forum)

X 19 June 2019 • It was requested that Eskom ensure it engages with the owner / authority of that specific land and not just all the communities in an effort


EMPr Section 4.2

Interested and affected parties List the names of persons consulted in this column, and mark with an X where those who must be consulted were in fact consulted

Date Comments received

Issues Raised EAP’s Response to issues as mandated by the applicant

Section and paragraph reference in this report where the issues and or response were incorporated

to reduce friction between the adjoining communities.

• Concern was raised regarding the sourcing of the specialists for the project from outside of the communities.

• Requests were made for Skills development from Eskom.

• Concern was raised regarding potential damage to crop fields.

Landowners (Ga-Kgoete – Nareng Thokoane traditional council)

X 27 June 2019 • Concern was raised regarding potential damage to crop fields.


EMPr Section 4.2 and 4.3

Mr Tshifhiwa Mathase DAFF – Forester

X 14 June 2019 • Protection of individual protected trees as pertained on the National Forest Act, Act 84 of 1998. Protection of Natural Forests.

• Take into consideration the responsibilities of Landowners outlined on National Veld and Forest Fire Act, Act 101 of 1998.


Section 3.5; 3.11; 3.23 and Refer to Part B - EMPr

Mr Izak van der Merwe DAFF

X 6 June 2019 • I forward this invitation also to my colleagues in the regional and H/Office units. The regional office has the primary mandate for the licensing if protected trees are affected, and thus also comment inputs, but we support them.

• Noted N/A

3.10 The Environmental Attributes associated with the alternatives

(The environmental attributed described must include socio- economic, social, heritage, cultural, geographical, physical and biological aspects.) a) Baseline Environment

(i) Type of environment affected by the proposed activity

(Its current, geographical, physical, biological, socio-economic, and heritage character).

Geology From the ecological specialist study, it was found that the study area was underlain by two (2) lithostratigraphic units, namely the Dwars River Sub-suite and the Rustenburg Layered Suite, which were both deposited within the Vaalian Era of the Proterozoic Eon. The Dwars River Sub-suite consists of pyroxenite, norite, anorthosite and chromitite, whereas the Rustenburg Layered Suite contained bronzite, harzburgite as well as norite. Both abovementioned lithostratigraphic units can be described as highly impermeable underlying sequences that weather to create well-draining soils that exhibit moderate particle cohesion, and thus low moisture retention properties. The geological layout over the project study area is indicated in Figure 3 below. Soils The ecological specialist study (see Appendix 9) found that the hydrological soil group B/C formed most of the material overlying the geological lithostratigraphic units, with a small section of group C situated to the north east of the study area in the vicinity of Alternative 1. Hydrological soil group B/C demonstrates moderate inherent runoff potential as a result of moderate infiltration rates and effective depth and drainage, whereas group C can be characterised as having moderately high inherent runoff potential. This can be attributed to the infiltration rate of group C being slow or deteriorating gradually and a restrictive underlying layer. This coupled with the impermeable sub-terrain geologies may result in subsurface flow occurring above the B soil horizon during and subsequent to heavy rainfall events. The hydrological soil groups over the study area are indicated in figure 3-4 below.

Figure 3: Geology recorded in study area

Figure 4: Soils recorded in study area

Climate The weather data from weather station WB 0589342 were used to determine annual minimum, average and maximum rainfall for the area. As shown in Table 1, for the period 1903-2000, the total monthly rainfall from January to December is presented. The annual average of 630 mm is reported for the study area. Table 3: Monthly minimum, average and maximum rainfall at station WB 0589342

Month Rainfall (mm) WB 0589342 (1903 to 2000) Minimum Average Maximum

September 0 14.7 86.2 October 0 49 152.9 November 4.5 97.2 273.5 December 10.4 103.2 274.5 January 18.6 123.6 328.3 February 15 88 204.6 March 4.2 82.6 224.6 April 0 40.6 166.1 May 0 14.4 133.3 June 0 3.5 42.7 July 0 4.8 76.2 August 0 7.9 94.2 Totals 150 630 1104

Figure 5: Average rainfall at WB 0589352 Land use

During the ecological study the dominant land uses associated with the project area were recorded to be woodland/open bushveld, cultivated subsistence agricultural practices and a variety of rural villages with different classifications (Figure 6). However, subsequent to conducting the field survey relevant to the vegetation study it was observed that the areas that had been classified as woodland/open bushveld were significantly encroached by Invasive Alien Plant Species (IAPS), such as Dichrostachys cinerea (Sicklebush) presumably as a result of the significant historical agricultural practices that have taken place within the study area. Consequently, all watercourses presented within these sections were also recorded, during the ecological study field work, to have been moderately to highly degraded by agricultural practices and livestock overgrazing, which had presumably led to the proliferation of erosion features and several IAPS within them. The land use cover over the study area is indicated in Figure 6 below.

0

20

40

60

80

100

120

140Ra

infa

ll (m

m)

Average rainfall (WB 0589352)

Figure 6: Land use cover over study area

Vegetation

The ecological study used the vegetation types that were identified and delineated on a national scale by Mucina and Rutherford (2006). The most recent version of the dataset at the time of this study was from 2018 (SANBI, 2006-2018). As this delineation was at a national scale, the on-site land cover and vegetation condition was compared to this delineation in order to determine whether changes had occurred on-site. The study area associated with the proposed development was recorded to extend into the Sekhukhune Plains Bushveld vegetation type, which was classified as being vulnerable in terms of conservation status (SANBI, 2006-2018) (Table 2). The wetland vegetation (WetVeg) type within the study area was recorded to be the Central Bushveld Group 7 type, which was also classified as least threatened (Driver et al., 2011). It must however be noted that the condition of all the vegetation types was observed to have been moderately-to-largely degraded as a result of historic and current subsistence and livestock activities, as well as infrastructural developments.

The Sekhukhune Plains Bushveld vegetation type was dominant within the study area. This vegetation type is largely short thornveld and can be classified as a semi-arid area (Mucina & Rutherford, 2006). Table 2 below presents the general characteristics associated with the aforementioned terrestrial vegetation type. Table 4: Details of study areas vegetation types

Attribute Sekhukhune plains bushveld

Distribution Limpopo and Mpumalanga Provinces: Lowland area from Burgersfort and the lower basin of the Steelpoort River in the south, northwards through the plains of the Motse River basin to Jobskop and Legwareng.

Conservation Status

Vulnerable. National conservation target is 19%. Nearly 2% was statutorily conserved in Potlake, Bewaarkloof and Wolkberg Caves Nature Reserves. Approximately 25% of the vegetation type had been transformed and is mainly under dry-land subsistence cultivation.

Geology and Soils

Complex geology with rocks mafic and ultramafic intrusive rocks of the main to lower zones of the Rustenberg Layered Suite. The majority of its distribution consisted of red apedal soils. Deep, loamy Valsrivier soils were characteristic on the plains and shallow Glenrosa soils were recorded on the low-lying, rocky hills.

Biologically Important Taxa

Lydenburgia cassinoides, Nuxia gracilis, Amphiglossa triflora, Asparagus fourei, Hibiscus barnardii, Orthosiphon fruticosus, Petalidium oblongifolium, Searsia batophylla, Asparagus sekukuniensis, Aneilema longirrhizum, Chlorophytum cyperaceum and Piaranthus atrosanguineus.

Limpopo conservation plan and priority areas

The locations of the proposed development inclusive of the two potential alternative powerline alignments assessed do not overlap with a Threatened Terrestrial Ecosystem (NEM:BA (Act no. 10 of 2004)), or cross the Core or Buffer areas of a protected area and will not affect any focus areas for the National Protected Area Expansion Strategy (NPAES) (NPAES, 2010). However, as per the Limpopo Conservation Plan v.2: Technical Report (2013) dataset both Alternative 1 and 2 will traverse one (1) Critical Biodiversity Area (CBA) 1 and one (1) Ecological Support Area (ESA) 2, with Alternative 2 being calculated to have a larger footprint then the preferred Alternative 1 (Figure 7). Table 3 below describes the conservation planning units relevant to the study area. The aim of the Limpopo Conservation Plan was to identify areas to sustain ecological and evolutionary processes to allow for the long-term persistence of biodiversity. Climate change provision in the form of terrestrial and riverine corridors, hydrological processes and species

requirements form the basis of the conservation plan. The particular features of the proposed development that included the site as priority area for the plan are listed below (Desmet et al., 2013):

• In terms of alignment with other plans the powerline crosses several sections considered by the Mpumalanga Biodiversity Conservation Plan (MBCP) as important and necessary.

• The site and the surrounding areas support threatened plant species. • The entire site falls within the Sekhukhuneland Centre of Endemism. • The dominant vegetation type associated with the proposed development is Endemic

to Limpopo. Table 5: Critical Biodiversity Areas (CBA) and Ecological Support Units (ESU) over study areas

Biodiversity priority area categories

Description

Critical Biodiversity Area 1 Mandatory (CB1)

Indicates that the Planning Unit (PU) contains one or more features with a very high irreplaceability score. There are no other localities which have the potential to meet the conservation target for this feature. It must be noted that both powerline alignment will be able to span the CB1 areas on site.

Ecological Support Area 2 (ESA2)

Indicate areas that are not in a natural state but are important to maintain ecological processes. It must be noted that the ESA2 areas within the proposed development footprint have been severely impacted on by anthropogenic factors and now consist predominantly of (IAPS), such as Dichrostachys cinerea (Sicklebush)

Figure 7: Critical Biodiversity Areas (CBA) and Ecological Support Units (ESU) in study area National freshwater ecosystem priority areas (NFEPAs) The NFEPA database provides strategic spatial priorities for conserving South Africa’s freshwater ecosystems and supporting sustainable use of water resources. FEPAs were identified based on a range of criteria dealing with the maintenance of key ecological processes and the conservation of ecosystem types and species associated with rivers, wetlands and estuaries (Driver et al., 2011). Subsequent to an analysis of the NFEPA river and wetland datasets, at a desktop level and during a field assessment, it was concluded that one (1) riverine system (i.e. the Matadi River) was determined to be at-risk of being impacted on by the proposed development. The system was classified as ‘natural’ according to Driver et al. (2011) and this was confirmed during the field survey according to the Ollis et al. (2013) wetland and riverine classification tool, see Appendix 9 for more detail. The delineated watercourses over the study area is indicated in Figure 8 below.

Figure 8: Water courses delineated within study area

Heritage

During the heritage assessment, the transects walked and inspected by the specialists during the specialist’s study revealed no surface Stone Age, Iron Age or historical archaeological remains (see Appendix 9). Primary context material was not expected due to previous ploughing activity and current mining and associated infrastructure disturbance. Graves within the previously ploughed areas are unlikely and no graves were reported.

An application has been submitted to the relevant authorities (SAHRA) to exempt the proposed Substation site and chosen powerline route alignment, and any ancillary activities, from any further heritage assessment or mitigation.

Social and Socio-Economic Aspects

The project falls in the Limpopo Province, within the Burgersfort Magisterial District, the Sekhukhune District Municipality and the Fetakgomo Tubatse Local Municipality (FTLM). The nearest major town is Burgersfort.

The main three wards surrounding the project is ward 8 (ward ID 94706008), ward 15 (ward ID 94706015) and ward 17 (ward ID 94706017) of FTLM. Each of these ward’s number of households, gender makeup and population statistics are tabled in Table 4 below. Table 6: Community household and population statistics

Ward No. Villages Households People Male Female

8 Diphale, Seuwe, Magabaneng, Madikane, Modimole, Mantsakane 4 297 17 188 49.97% 50.03%

15 Ditwebeleng, Kgwete, Shakung, Masete Morapaneng, Mashishi 11 846 47 960 42.08% 57.92%

17 Mahlokoane, Manyaka, Maapea, Mphethi, Selala 5 450 19 845 48.49% 51.51%

The 2018/2019 IDP for FTLM shows poverty levels of 42.2 % and higher education levels at less than 3 % of the population. The area is thus considered a largely low-income area with high poverty rates and low higher education levels. The water supply in the 3 wards (8, 15, and 17) is largely communal boreholes with reservoirs and pipe distribution from the reservoirs. Of this, most households do not have piped water which, for the entire FTLM, is at 53.6 % (Statistics South Africa Community survey (2016)). This means that most households collect water from a communal tap and carry or transport water to the household each day. The total number of households in FTLM without proper sanitation is 78% (IDP FTLM 2018/2019) with roughly 80% of the households in the municipality using pit latrines. The area is also known for high unemployment rates, some of the highest in the country.

Avifauna

The site is located on Sekhukhune Plains Bushveld. This is part of the Savanna biome with 0.8% of this vegetation protected. The vegetation’s status is Vulnerable. For avifauna the vegetation is a mix of grassland with some thorn bushes and small to medium trees. The micro habitats identified on, or within close proximity to, the study site include grassland, riverine areas and bushveld areas. Of these micro habitats, it is the riverine area that is the most sensitive for avifauna. It must be noted that the Matadi River was dry and disturbed by human activity and litter when observed on the field trip. That said, when it contains water it would be an important habitat for birds.

Red Listed bird species likely to make use of the above described micro habitats are shown in Table 5. It must be stressed that birds can and will, by virtue of their mobility, utilise almost any areas in a landscape from time to time. However, the analysis in Table 5 represents each species’ most preferred or normal habitats. These locations are where most of the birds of that species will spend most of their time and as such, that is where impacts on those species will be most significant. Table 5 makes use of the specialist’s extensive experience gained through personal observations of the relevant bird species. Table 7: Sensitive and protected bird species that occurs or might occur within project area

Common name Taxonomic name

Regional status Preferred micro-habitat Status

on-site Cape Vulture Gyps

coprotheres EN Wide range of habitats linked to

food availability Possible

Tawny Eagle Aquila rapax EN Open savanna woodland. Possible White-backed

Vulture Gyps africanus EN Savanna, woodland and

bushveld. Possible

Lanner Falcon Falco biarmicus VU Open grassland, open or cleared woodland and agricultural areas.

Possible

Secretarybird Sagittarius serpentarius

VU Open grassland with scattered trees and shrubs.

Possible

Verreaux's Eagle Aquila verreauxii VU Mountainous and rocky areas with large cliffs

Unlikely

Abdim's Stork Ciconia abdimii NT Grassland, savanna woodland, pan edges, pastures, cultivated

land and suburban areas.

Possible

(ii) Description of the current land uses

The current land use within the project area consists of informal settlements, subsistence farming practices (including grazing areas) and mining. Within the proposed development footprint and along the powerline servitudes the predominant land use is agriculture however none of the fields within the project area have been cultivated for at least ten years based on the size of the Dichrostachys cinerea (Sicklebush) on site and grazing of livestock seems to be the predominant landuse.

(iii) Description of specific Environmental features and infrastructure on the site

Little to no infrastructure is located on the farm portions. Some fences will have to be crossed by the powerlines but no infrastructure or buildings are located within the proposed development footprint.

(iv) Environmental and current land use map.

(Show all environmental and current land use features)

Please refer to Appendix 2.

3.11 Impacts and risk identified including the nature, significance consequence, extent, duration and probability of the impacts, including degree to which these impacts

(Provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability, and duration of the impacts. Please indicate the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and can be avoided, managed or mitigated).

CONSTRUCTION AND OPERATION

Pre-mitigation Post-mitigation

Impact Alternative 1 Alternative 2 Mitigations

Alternative 1 Alternative 2

Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk

Ecological risks

Disturbance of natural vegetation by means of clearing, grubbing, excavation, infilling and maintenance works. This may reduce in a loss of biodiversity and potentially SCC.

8 1 1 5 50 6 1 1 5 40 1) Indigenous vegetation which

does not interfere with the development must be left undisturbed;

2) Protected or endangered species may occur on or near the development site. Special care should be taken not to damage such species;

3) Search, rescue and replanting of all protected and endangered species likely to be damaged during project development must be identified by the relevant specialist and completed prior to any development or clearing;

4) Permits for removal must be obtained from the relevant CA prior to the cutting or clearing of the affected species, and they must be filed;

5) The Environmental Audit Report must confirm that all identified species have been rescued and replanted and that the location of replanting is compliant with conditions of approvals;

6) Trees felled due to construction must be documented and form part of the Environmental Audit Report;

7) Rivers and watercourses must be kept clear of felled trees, vegetation cuttings and debris;

8) Only a registered pest control operator may apply herbicides on a commercial basis and commercial application must be

2 1 1 2 8 4 1 1 3 18

Loss of vegetation in the direct footprint of the proposed development.

4 1 5 5 50 6 1 5 5 60 4 1 5 5 50 4 1 5 5 50

Encroachment of invasive and alien plant species (IAPS).

6 2 4 5 60 6 2 4 5 60 4 2 2 3 24 6 2 2 3 30

Fragmentation of ecosystems as a result 2 1 5 2 16 4 1 5 2 20 0 1 5 2 12 2 1 5 2 16




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk of the proposed development.

carried out under the supervision of a registered pest control operator, supervision of a registered pest control operator or is appropriately trained;

9) A daily register must be kept of all relevant details of herbicide usage;

10) All protected species and sensitive vegetation not removed must be clearly marked and such areas fenced off in accordance to Section 5.3: Access restricted areas.

11) Alien invasive vegetation must be removed and disposed of at a licensed waste management facility.

12) The pylon foundation should be placed outside of the delineated riparian zone and watercourses

Loss of SCC and culturally significant plant species.

8 1 1 3 30 8 1 1 4 40 2 1 2 2 10 2 1 2 2 10

Avifauna risks

Habitat destruction for the power line alignment and substation footprint.

4 1 3 3 24 4 1 3 3 24 1) No interference with livestock

must occur without the landowner’s written consent and with the landowner or a person representing the landowner being present;

2) The breeding sites of raptors and other wild birds species must be taken into consideration during the planning of the development programme;

3) Breeding sites must be kept intact and disturbance to breeding birds must be avoided. Special care must be taken where nestlings or fledglings are present;

4) Special recommendations of the avian specialist must be adhered

2 1 3 2 12 2 1 3 2 12

Disturbance during construction and maintenance along the power line alignment and substation footprint.

6 2 3 3 33 6 2 3 3 33 4 2 3 2 18 4 2 3 2 18

Electrocutions of larger bird species sitting on 8 1 4 4 52 8 1 4 4 52 4 1 4 2 18 4 1 4 2 18




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk the power line structures.

to at all times to prevent unnecessary disturbance of birds;

5) No poaching must be tolerated under any circumstances. All animal dens in close proximity to the works areas must be marked as Access restricted areas;

6) No deliberate or intentional killing of fauna is allowed;

7) In areas where snakes are abundant, snake deterrents to be deployed on the pylons to prevent snakes climbing up, being electrocuted and causing power outages; and

8) No Threatened or Protected species (ToPs) and/or protected fauna as listed according NEMBA (Act No. 10 of 2004) and relevant provincial ordinances may be removed and/or relocated without appropriate authorisations/permits.

9) Mark the section that crosses the river with anti-collision marking devices. These must be installed on the earth wire at 10m spacings and alternating light and dark colour devices.

10) The powerline design to be used must have enough clearances for birds to navigate and prevent and reduce electrocutions (preferably the monopole design, or similar, with greater than 1.8 m clearances).

Collisions of birds with the overhead power line cables. Sensitive species include the larger, slower flying species such as storks or Secretarybird as well as raptors

6 1 4 3 33 6 1 4 3 33 2 1 4 2 14 2 1 4 2 14

Air quality risks

Dust emissions (Particulate matter 4 1 3 3 24 4 1 3 3 24

1) Take all reasonable measures to minimise the generation of dust 2 1 3 2 12 2 1 3 2 12




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk emmissions, inhalation and settlement)

as a result of project development activities to the satisfaction of the ECO;

2) Removal of vegetation must be avoided until such time as soil stripping is required and similarly exposed surfaces must be revegetated or stabilised as soon as is practically possible;

3) Excavation, handling and transport of erodible materials must be avoided under high wind conditions or when a visible dust plume is present;

4) During high wind conditions, the EO must evaluate the situation and make recommendations as to whether dustdamping measures are adequate, or whether working will cease altogether until the wind speed drops to an acceptable level;

5) Where possible, soil stockpiles must be located in sheltered areas where they are not exposed to the erosive effects of the wind;

6) Where erosion of stockpiles becomes a problem, erosion control measures must be implemented at the discretion of the EO;

7) Vehicle speeds must not exceed 40 km/h along dust roads or 20 km/h when traversing unconsolidated and non-vegetated areas;

8) For significant areas of excavation or exposed ground, dust suppression measures must be used to minimise the spread of dust.

Gas emissions (Gas emission inhalation and contamination from vehicle emissions and equipment use (eg. cutting torches, welding and other)

6 1 4 3 33 6 1 4 3 33 2 1 4 2 14 2 1 4 2 14

Visual risks

Construction activities ie. cleared areas, 2 2 1 3 15 2 2 1 3 15

2 1 3 2 12 2 1 3 2 12




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk vehicles moving, excavation heaps, etc. might affect the areas visual appeal

Powerline, posts and maintenance servitude might affect visual aesthetics

2 1 5 1 8 2 1 5 1 8

2 1 5 1 8 2 1 5 1 8

Storm water and wastewater risks

Increase in erosion 4 2 2 3 24 2 2 1 3 15

1) Runoff from the cement/ concrete batching areas must be strictly controlled, and contaminated water must be collected, stored and either treated or disposed of at a registered facility.

2) All spillage of oil must be controlled by the use of an approved absorbent material and the used absorbent material disposed of at an appropriate waste disposal facility;

3) Natural storm water runoff not contaminated during the development and which is not considered contaminated in terms of the NWA, may be released back into to the river / runoff system;

2 1 3 2 12 2 1 3 2 12

Contamination of storm water, surface water and groundwater

4 1 4 2 18 4 1 4 2 18 4 1 4 1 9 4 1 4 1 9

Impacts on watercourse and riparian/wetland habitats

6 1 4 2 22 6 1 4 2 22 1) All watercourses must be

protected from direct or indirect spills of pollutants such as solid waste, sewage, cement, oils, fuels, chemicals, aggregate tailings, wash and contaminated water or organic material resulting from the Contractor’s activities;

2) In the event of a spill, prompt action must be taken to clear the polluted or affected areas;

3) Where possible, no development equipment must traverse any seasonal or permanent wetland

4 1 4 1 9 4 1 4 1 9




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Development of permanent watercourse crossing must only be undertaken where no alternative access to tower position is available;

4) There must not be any impact on the long-term morphological dynamics of watercourses or estuaries;

5) Existing crossing points must be favoured over the creation of new crossings (including temporary access). When working in or near any watercourse, the following environmental controls and consideration must be taken: a) Water levels during the

period of construction; b) During the execution of the

works, appropriate measures to prevent pollution and contamination of the riparian environment must be implemented e.g. including ensuring that construction equipment is well maintained;

c) Where earthwork is being undertaken in close proximity to any watercourse, slopes must be stabilised using suitable materials, i.e. sandbags or geotextile fabric, to prevent sand and rock from entering the channel; and

d) Appropriate rehabilitation and re-vegetation measures for the watercourse banks must be implemented timeously. In this regard, the banks should be appropriately and incrementally stabilised as soon as development allows.

Social and heritage risks




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Disruptions to farming activities and potential loss of crops

8 1 4 1 13 8 1 4 1 13 1) No crop fields were identified.

However, where such is identified, avoid disruptions to the crop fields. Where it cannot be avoided, the crop fields owners should be appropriately compensated or assisted with alternatives

2 1 3 2 12 2 1 3 2 12

Potential disturbance of cultural heritage resources

6 1 5 1 12 6 1 5 1 12 1) Identify, demarcate and prevent

impact to all known sensitive heritage features on site in accordance with the No-Go procedure in Section 5.3: Access restricted areas;

2) Carry out general monitoring of excavations for potential fossils, artefacts and material of heritage importance;

3) All work must cease immediately, if any human remains and/or other archaeological, palaeontological and historical material are uncovered. Such material, if exposed, must be reported to the nearest museum, archaeologist / palaeontologist (or the South African Police Services), so that a systematic and professional investigation can be undertaken. Sufficient time must be allowed to remove/collect such material before development recommences.

6 1 5 1 12 6 1 5 1 12

General risks

Contamination from handling, storage, transporting and usage of hazardous substances

4 1 2 3 21 4 1 2 3 21 1) The use and storage of

hazardous substances to be minimised and non-hazardous and non-toxic alternatives substituted where possible;

2) All hazardous substances must be stored in suitable containers

2 1 3 2 12 2 1 3 2 12




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk as defined in the Method Statement;

3) Containers must be clearly marked to indicate contents, quantities and must be leak proof;

4) All storage areas must be bunded. The bunded area must be of sufficient capacity to contain a spill / leak from the stored containers;

5) An Alphabetical Hazardous Chemical Substance (HCS) control sheet must be drawn up and kept up to date on a continuous basis;

6) All hazardous chemicals that will be used on site must have Material Safety Data Sheets (MSDS);

7) All employees working with HCS must be made aware of the safe use of the substance and the use of the safety data sheet;

8) The Contractor must ensure that diesel and other liquid fuel, oil and hydraulic fluid is stored in appropriate storage tanks or in bowsers that meets the relevant SANS standard for storage of hazardous substances;

9) The tanks/ bowsers must be situated on a smooth impermeable surface (concrete) with a permanent bund. The impermeable lining must extend to the crest of the bund and the volume inside the bund must be 130% of the total capacity of all the storage tanks/ bowsers (110% statutory requirement plus an allowance for rainfall);

10) Provision must be made for refuelling at the storage area by protecting the soil with an impermeable groundcover. Where dispensing equipment is




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk used, a drip tray must be used to ensure small spills are contained; All empty externally dirty drums must be stored on a drip tray or within a bunded area;

11) No unauthorised access into the hazardous substances’ storage areas must be permitted;

12) Adequate fire-fighting equipment must be made available at all hazardous storage areas;

13) Where refuelling away from the dedicated refuelling station is required, a mobile refuelling unit must be used. Appropriate ground protection such as drip trays must be used;

14) An appropriately sized spill kit kept onsite relevant to the scale of the activity/s involving the use of hazardous substance must be available at all times;

Loss of toposil 4 1 3 3 24 4 1 3 3 24

1) All material that is excavated during the project development phase (either during piling (if required) or earthworks) must be stored appropriately on site in order to minimise impacts to watercourses, watercourses and water bodies;

2) All stockpiled material must be maintained and kept clear of weeds and alien vegetation growth by undertaking regular weeding and control methods;

3) Topsoil stockpiles must not exceed 2 m in height;

4) During periods of strong winds and heavy rain, the stockpiles must be covered with appropriate material (e.g. cloth, tarpaulin etc.);

5) Where possible, sandbags (or similar) must be placed at the bases of the stockpiled material in

4 1 3 4 8 4 1 3 4 8




Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk Se Ex Du Pr Risk order to prevent erosion of the material.

3.12 Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks

(Describe how the significance, probability and duration of the aforesaid identified impacts that were identified through the consultation process were determined in order to decide the extent to which the initial site layout needs revision).

The significance (quantification) of potential environmental impacts identified have been determined using a ranking scale, based on the following (terminology has been taken from the Guideline Documentation on EIA Regulations, of the Department of Environmental Affairs and Tourism, April 1998):

Occurrence

• Probability of occurrence (how likely is it that the impact may occur?)

• Duration of occurrence (how long may it last?)

Severity

• Magnitude (severity) of impact (will the impact be of high, moderate or low severity?)

• Scale/extent of impact (will the impact affect the national, regional or local environment, or only that of the site?)

Each of these factors has been assessed for each potential impact using the ranking scales represented

Table 8: Risk assessment ranking scale of the four factors (probability, duration, extent and severity) used to determine significance ratings

Probability Duration 1 - very improbable (probably will not

happen 2 - improbable (some possibility, but low

likelihood) 3 - probable (distinct possibility) 4 - highly probable (most likely) 5 - definite (impact will occur regardless

of any prevention measures)

1 - of a very short duration (0–1 years) 2 - of a short duration (2-5 years) 3 - medium-term (5–15 years) 4 - long term (> 15 years) 5 - permanent

Extent Severity 1 - limited to the site 2 - limited to the local area 3 - limited to the region 4 - will be national 5 - will be international

0 - small and will have no effect on the environment 2 - minor and will not result in an impact on processes 4 - low and will cause a slight impact on processes 6 - moderate and will result in processes continuing but

in a modified way 8 - high (processes are altered to the extent that they

temporarily cease) 10 - very high and results in complete destruction of

patterns and permanent cessation of processes

The environmental significance of each potential impact is assessed using the following formula:

Significance Points (SP) = (Magnitude + Duration + Extent) x Probability

The maximum value is 100 Significance Points (SP). Potential environmental impacts were rated as high, moderate or low significance on the following basis:

• < 30 significance points = LOW environmental significance. • 31- 60 significance points = MODERATE environmental significance • 60 significance points = HIGH environmental significance

This section in the final impacts table then summarises the potential impacts associated to the three different phases of the proposed development activities. The potential impacts and risks are explored by investigating each aspect (i.e. air quality, Wetland and Ecological, heritage and social) associated to the proposed activities.

• For the purpose of this section, the mitigation measures recommended will only be summarise to demonstrate the approach taken to manage each risk. A detailed mitigation plan will form part of the final BAR and EMPr.

Table 9: Table of risk significance

Colour Significance Points Explanation

≤ 30 LOW environmental significance

31 - 60 MODERATE environmental significance

> 60 HIGH environmental significance

a) Positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the communities that may be affected

(Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)

Positive impacts:

It has been demonstrated that the proposed activities, after mitigation, will have low levels of impact on the environment (biophysical and social). Furthermore, this project will contribute to the Key performance objectives of the Local Municipality, ensuring the protection and creation of sustainable and long-term job opportunities. In addition, once

the mine closes the Substation and electrical transmission lines will play an important role in providing electricity to the surrounding communities through the implementation of future electrical distribution networks to communities by Eskom.

Negative Impacts:

The impacts assessments focused largely on the ecological assessment, which included soils, vegetation and wetlands, avifauna assessment and heritage assessment. The other risks, mainly to air, groundwater, surface water, and social, were assessed but no specialist studies or specialists’ input were obtained in terms of the impact assessment as these were pre-screened as insignificant and confirmed during the environmental assessment undertaken. The impact summaries below thus largely focus on the “at-risk” areas of ecology (soil, vegetation and wetland), avifauna and heritage.

The key negative impacts were narrowed down to:

1. The crossing of the critical biodiversity area (CBA) in the Matadi river; 2. The removal of protected and other species of conservation concern (SCC); 3. The clearing of vegetation and associated ecological disturbances and impacts

(such as erosion, encroachment of IAPS, etc.) 4. The electrocution, collision with and habitat destruction of bird species, and

especially protected or endangered bird species (SCC)

None of these impacts were however found to be a high-risk post mitigation and even pre-mitigation. Some were moderate risk during pre-mitigation, but all could be mitigated to a low risk, except risk No. 2 in the table in section 3.11 above, which were assessed to remain moderate.

b) The possible mitigation measures that could be applied and the level of risk

(With regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/ discussion of the mitigations or site layout alternatives available to accommodate or address their concerns, together with an assessment of the impacts or risk associated with the mitigation or alternatives considered).

All issues and concerns raised by affected parties have been listed and incorporated in the EMPr to ensure that these concerns are mitigated.

c) Motivation where no alternative sites were considered

Alternative sites and layouts have been determined and these are described in detail in Paragraph 3.7. included in 3.7 is the motivation where no site alternatives were considered.

d) Statement motivating the alternative development location within the overall site

(Provide a statement motivating the final site layout that is proposed)

The site location alternatives have been discussed earlier, and the final powerline and substation positions have taken into consideration affected parties’ contributions, the specialist assessments and the configuration and layout of Lwala Mine. It is the EAPs opinion that the preferred layouts selected are the best positions to cater for the project requirements and to prevent impacts on the receiving environment.

e) Full description of the process undertaken to identify, assess and rank the

impacts and risks the activity will impose on the preferred site (In respect of the final site layout plan) through the life of activity.

(Including (i) a description of all environmental issues and risks that are identified during environmental impacts assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which to the issue and risk could be avoided or addressed by the adoption of mitigation measures.)

ESKOM, the EAP and the appointed specialists conducted remote and field surveys to identify and determine the environmental attributes associated with the environmental impacts during the proposed activity. The team then evaluated the best possible positions for the powerline and substation. Aspects considered in the determination of the sites included, amongst others, specialist consultation on wetlands, ecological importance, occurrence and proximity of heritage resources, landowner’s consultation, and the presence of other infrastructure. Impacts were then assessed individually, and mitigation measures identified to reduce impacts on the environment associated with the development. These mitigation measures are included in the Environmental Management Programme (EMPr) (See Part B).

3.13 Assessment of each identified potentially significant impact and risk

(This section of the report must consider all the known typical impacts of each of the activities (including those that could or should have been identified by knowledgeable persons) and not only those that were raised by registered interested and affected parties).

NAME OF ACTIVITY e.g. for prospecting- drill site,

site camp, ablution facility

accommodation, equipment

storage, sample storage, site

office, access route etc.

e.g. for mining- excavation,

blasting, stockpiles, discard

dumps or dams, loading hauling

and transport, water supply

dams and boreholes,

accommodation, offices,

ablution, stores, workshops,

processing plant, storm water

control berm, roads, pipelines,

powerlines, conveyors, etc

POTENTIAL IMPACT (including the potential

impacts for cumulative

impacts)

(e.g. dust noise, drainage

surface disturbance, fly rock

surface water contamination,

ground water contamination,

air pollution etc.)

ASPECTS AFFECTED

PHASE In which impact is

anticipated

(e.g. construction,

commissioning,

operational

Decommissioning

closure, post-closure)

SIGNIFICANCE If not mitigated

MITIGATION TYPE (Modify, remedy, control, or

stop) through (e.g. noise

control measures, storm water

control, dust control,

rehabilitation, design measures

blasting controls, avoidance,

relocation, alternative activity

etc…etc)

e.g. modify through alternative

method control through noise

control through management

and monitoring through

rehabilitation.

SIGNIFICANCE If mitigated

Site Establishment and construction activities

Dust Generation

Site clearance, soil stripping.

Pre-Construction / construction

Refer to section 3.11 Please refer to the EMPr Refer to section

3.11

Erosion

Loss of riparian habitat function and diversity Destruction of Agricultural resources/ grazing area and loss of Biodiversity Loss of heritage resources (graves, homesteads or historical sites)

NAME OF ACTIVITY e.g. for prospecting- drill site,

site camp, ablution facility

accommodation, equipment

storage, sample storage, site

office, access route etc.

e.g. for mining- excavation,

blasting, stockpiles, discard

dumps or dams, loading hauling

and transport, water supply

dams and boreholes,

accommodation, offices,

ablution, stores, workshops,

processing plant, storm water

control berm, roads, pipelines,

powerlines, conveyors, etc

POTENTIAL IMPACT (including the potential

impacts for cumulative

impacts)

(e.g. dust noise, drainage

surface disturbance, fly rock

surface water contamination,

ground water contamination,

air pollution etc.)

ASPECTS AFFECTED

PHASE In which impact is

anticipated

(e.g. construction,

commissioning,

operational

Decommissioning

closure, post-closure)

SIGNIFICANCE If not mitigated

MITIGATION TYPE (Modify, remedy, control, or

stop) through (e.g. noise

control measures, storm water

control, dust control,

rehabilitation, design measures

blasting controls, avoidance,

relocation, alternative activity

etc…etc)

e.g. modify through alternative

method control through noise

control through management

and monitoring through

rehabilitation.

SIGNIFICANCE If mitigated

Disturbance of and impact to avifauna habitat and bird movement

Rehabilitation and

Decommissioning

Dust Generation

Demolition and

removal of

structures then

restoring site to

its original

status

Decommissioning

and rehabilitation

Refer to section

3.11 Please refer to the EMPr

Refer to section

3.11

Erosion Contamination of Surface / subsurface Water and wetlands Alien plant management and weeds Hydrocarbon contamination Topsoil loss or mismanagement Socio Economic factors which are impacted on by loss of Game Species Noise

The supporting impacts assessment conducted by the EAP must be attached as an appendix, marked Appendix

3.14 Summary of specialist reports.

(This summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular form):-

List of Studies undertaken

RECOMMENDATIONS OF SPECIALIST REPORTS

SPECIALISTS RECOMMENDATIONS THAT HAVE

BEEN INCLUDED IN THE EIA REPORT

(Mark with an X where applicable)

REFERENCE TO APPLICABLE SECTION OF REPORT WHERE

SPECIALIST RECOMMENTIONS HAVE BEEN INCLUDED

Heritage Impact Assessment Please refer to Appendix 9 X Please refer to Section 4.1 (iv) Ecological Assessment Please refer to Appendix 9 X Please refer to Section 4.1 (iv) Afivauna Assessment Please refer to Appendix 9 X Please refer to Section 4.1 (iv)

3.15 Environmental impact statement

a) Summary of the key findings of the environmental impact assessment;

The impacts assessments focused largely on the ecological assessment, which included soils, vegetation and wetlands, avifauna assessment and heritage assessment. The other risks, mainly to air, groundwater, surface water, and social, were assessed but no specialist studies or specialists’ input were obtained in terms of the impact assessment as these were pre-screened as insignificant and confirmed during the environmental assessment undertaken. The impact summaries below thus largely focus on the “at-risk” areas of ecology (soil, vegetation and wetland), avifauna and heritage.

The key negative impacts were narrowed down to:

5. The crossing of the critical biodiversity area (CBA) in the Matadi river; 6. The removal of protected and other species of conservation concern (SCC); 7. The clearing of vegetation and associated ecological disturbances and impacts (such

as erosion, encroachment of IAPS, etc.) 8. The electrocution, collision with and habitat destruction of bird species, and especially

protected or endangered bird species (SCC)

None of these impacts were however found to be a high-risk post mitigation and even pre-mitigation. Some were moderate risk during pre-mitigation, but all could be mitigated to a low risk, except risk no. 2 in the table in section 3.11, which were assessed to remain moderate

b) Final site map

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

Please refer to Appendix 2.

c) Summary of positive and negative impacts and risks of the proposed activity and identified alternatives;

Please refer to Section 3.8, 3.12 (a) and 3.15.

3.16 Proposed management impact objectives and the impact management outcomes for inclusion in the EMPr;

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

Environmental Management System (EMS) objectives

The environmental objectives for the construction, decommissioning and operational phases are to:

• Comply with all applicable legislation and other requirements. • Practicing responsible stewardship by adopting world class standards. • Proactively identifying and managing significant environmental impacts and risks in

order to:

o optimise resource consumption; o prevent or minimise the release of effluent; o mitigate impacts on climate change; o minimise waste; o rehabilitate disturbed land and protect environmental biodiversity; and o protect cultural heritage resources.

• Engaging with all interested and affected parties towards the shared goal of improving the environment.

• Setting objectives and, where possible, quantitative targets, to determine continual improvement in environmental performance and the prevention of pollution.

Impact management outcomes:

The key impact management outcomes would be the efficient and environmentally responsible management of the site and to rehabilitate correctly. With the successful implementation of the recommended mitigation measures and rehabilitation of the powerline and substation site, these will be converted back into productive agricultural sites or grazing areas.

3.17 Aspects for inclusion as conditions of Authorisation

(Any aspects which must be made conditions of the Environmental Authorisation)

• It is recommended that that the procedure for chance finds proposed by the heritage specialist be implemented should a chance find occur.

• A qualified ECO must be appointed for the project to ensure compliance with the EMP; • No pylon structures should be erected within 32 m of a drainage line or watercourse; • Construction of the powerlines is to be undertaken in the dry season. • Use the steel monopole powerline tower with clearances greater than 1.8 m to avoid

electrocutions of sensitive species; • Mark the section of the new power line that crosses the river with suitable bird anti-

collision marking devices.

3.18 Description of any assumptions, uncertainties and gaps in knowledge

(Which relate to the assessment and mitigation measures proposed)

This BA is based on the following assumption(s): • The information provided by the applicant is accurate, sufficient and unbiased, and that

no information that could change the outcome of the authorisation process has been withheld.

• The information obtained from the specialist baseline studies undertaken for this project is accurate and unbiased.

• Necessary authorisations will be obtained from relevant departments. • ESKOM SOC LTD will follow the conditions of the EA and applicable legislation for the

duration of the project.

3.19 Reasoned option as to whether the proposed activity should or should not be authorized

a) Reasons why the activity should be authorized or not

The risk assessment has shown that, with the mitigations implemented as per the EMPr report, the activities will have an overall low impact on the environment. The powerline land occupation footprint is very small (mainly pylons and supports) and any construction disturbances can be effectively rehabilitated. The powerline also plays a critical role in unlocking further economic potential from the nearby Lwala Mine and rejection of the application will see these opportunities lost to an area that desperately needs investment.

With a low impact, high rehabilitation potential and high economic relevance, the EAP is of the opinion that there isn’t enough reason not to approve the project, with the overall risk low and the overall economic importance high.

It is thus the considered opinion of the Environmental Assessment Practitioner that the project activities alternatives, potential impacts, and landowner concerns, have been adequately identified and assessed. Relevant and implementable mitigation measures have also been identified. These mitigation measures will reduce the identified impacts significance to a low risk. Considering this, the alternative 1 can be authorised.

b) Conditions that must be included in the authorization

• Any changes to, or deviations from the project description set out in this application must be approved, in writing, by the competent authority before such deviations may be affected.

• It is recommended that that the procedure for chance finds proposed by the heritage specialist be implemented should a chance find occur.

• A qualified ECO must be appointed for the project to ensure compliance with the EMPr;

• No pylon structures should be erected within a drainage line; • Use the steel monopole powerline tower with clearances greater than 1.8m to avoid

electrocutions of sensitive species; • Mark the section of the new power line that crosses the river with suitable anti-

collision marking devices; • Include monitoring requirements as per the specialist’s reports; and • Disturbed areas are to be rehabilitated, as close as possible, to the original pre-

extraction state.

3.20 Period for which the Environmental authorization is required

Indefinite, the proposed Lwala Substation and powerlines will remain operational even after the Lwala Mine stops production and is rehabilitated. Once the mine closes the electrical infrastructure will be maintained and operated by Eskom to supply electricity to surrounding rural communities.

3.21 Undertaking

(Confirm that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the basic assessment report and the Environmental Management Programme report.)

Yes, the above-mentioned aspects are provided for at the end of this report and applies to the full content of both the BA and EMP reports.

3.22 Financial Provision

(State the amount that is required to both manage and rehabilitate the environment in respect to rehabilitation.)

The substation and powerline’s use will remain after closure of the mine as the powerline and substation will be used to supply electricity to the expanding communities surrounding the mine. Thus, it will not be dismantled, demolished and rehabilitated but its use will simply change from predominantly mine supply to predominantly residential supply. No closure of the site is thus planned. Rehabilitation after construction (concurrent rehabilitation) and, where required, during operations forms part of the normal operating activities and is included in the EMPr. Concurrent rehabilitation will take place.

a) Explain how the aforesaid amount was derived

No calculation was done as the site is not scheduled for closure even following the mine’s scheduled closure. The powerline and substation are expected to remain in use indefinitely until it is not viable to operate anymore.

b) Confirm that this amount can be provided for from operating expenditure

(Confirm that the amount is anticipated to be an operating cost and is provided for as such in the mining work programme, Financial and Technical Competence Report or Prospecting work programme as the case may be)

Not required

3.23 Specific information may be required by the competent authority

a) Compliance with the provisions of section 24(4)(a) and (b) read with section 24(3) (a) and (7) of the National Environmental Management (Act 107of 1998). The EIA must include the:-

The Impact Assessment highlighted that the impact, post mitigation, from the proposed activities can be considered low with only one moderate impact.

• It is recommended that prior to clearing any area, a walkthrough survey is undertaken by an expert to identify any protected flora species. If any protected species are found a destruction permit must be obtained from the relevant authority for the species to be destroyed or, if one is able to relocate the species, a search, rescue and re-planting permit must be obtained for that specific species. Once the permits have been received, the proposed activities can continue.

• All activities must be managed to ensure that no water sources are polluted or negatively impacted.

• Due to the nature of the soils in the area being dispersive the potential for erosion is high. The cleared areas are to be rehabilitated and monitored for erosion.

• Noise is to be kept to a minimum in accordance with the SANS standards for rural areas and activities are to be restricted to normal labour law working hours.

• Dust is to be monitored (visual inspection and complaints) and kept to a minimum and addressed where required.

• All livestock and wildlife are always to be protected. If any wildlife or livestock is impacted in any way by the activities the owner of the animal is to be compensated at the commercial value for the impacted animal.

• Access to the project site are to be appropriately managed to avoid animals entering the construction and work sites.

• No agricultural fields were identified. However, where such is identified, avoid disruptions to the crop fields. Where it cannot be avoided, the agricultural fields owners should be appropriately compensated or assisted with alternatives.

See Appendix 9 for detail from the specialist reports.

(i) Impact on the socio-economic conditions of any directly affected person

(Provide the results of investigation, assessment and evaluation of the impact of mining bulk sample or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as an Appendix)

The objective of the project activities is to provide electricity to the newly established Lwala mine. This will allow it to reach its production and processing targets and ensures the future sustainability of the operation. In addition, the substation will provide electricity to surrounding rural communities strengthening the existing Eskom distribution network in the region and improving the reliability of electricity supply to the area. This will have a positive impact on the socio-economic conditions of the region.

(ii) Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act.

(provide the results of investigation, assessment and evaluation of the impact of mining bulk sample or alluvial diamond prospecting on any national referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act no. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act attach that investigation report as Appendix 2.19.2 and confirm that the applicable mitigation is reflected in 2.5.3, 2.11.6 and 2.12 herein).

The heritage impact assessment was evaluated, and no heritage resources were observed on the project area. See the Heritage Impact Assessment Report in Appendix 6.

3.24 Other matters required in terms of section 24(4)(a) and (b) of the Act.

(the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4) (b)(i) of the Act and motivation if no reasonable or feasible alternatives as contemplated in sub regulation 22(2)(h), exist. The EAP must attach such motivation as Appendix).

Please refer to Section 3.8.

PART B

1 ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1.1 Draft Environmental Management Programme

a) Details of the EMP

(Confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A, section 1 (a) herein as required).

Yes, details of EAP have been provided in Part A, Section 1(a) of this document.

b) Description of the Aspect of the Activity

(Confirm that the requirement to describe the aspects of the activity that are covered the draft environmental management programme is already included in PART A, section (1) (h) herein as required).

Yes, a description of the activities to be undertaken has been provided in Part A of this document.

c) Composite Map

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

Please refer to Appendix 2

d) Description of Impact management objectives including management statements

(i) Determination of closure objectives

(Ensure that the closure objectives are informed by the type of environment described)

The closure objectives for the listed activities are to:

• Restore the area as close as possible to the pre-project state to allow for the establishment of natural vegetation over time;

• Minimise erosion in areas that are already disturbed; • Restore ecological function of the soils, vegetation and drainage;

• Ensure the areas are safe for all people and livestock; • Minimise the establishment of alien vegetation; • Protect drainage lines and watercourses; • Ensure that no temporary infrastructure is left on-site during long periods of cessation

or upon closure; and • Ensure environmental risks are minimised.

(ii) Volume and rate of water use required for the operation.

Other than limited water for ablution facilities at the substation no water will be required for the operational phase of the substation and power lines. Limited water for the construction of the substation will be required and some water maybe required for dust suppression during construction of the substation platform. All water will be sourced from a legally accessible site or via a Water Service Provider.

(iii) Has a water use licence has been applied for?

No Water Use License is required for the proposed development as it does not have any significant impact on any water resources. The Department of Water and Sanitation has been notified of the proposed development and if required a General Authorization application in terms of the NWA will be prepared and submitted to the Olifants River Water Management Area Proto Catchment Management Agency.

(iv) Impacts to be mitigated in their respective phases

(Measures to rehabilitate the environment affected by the undertaking of any listed activity)

ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of

disturbance MITIGATION MEASURES

COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

Site Establishment Pre-construction or operation

Please refer to 3.4 in the BAR

• Vegetation clearing may only take place within the development footprint and should only proceed after a walkthrough has been done and any protected species rescued and relocated.

• If any SCC or protected species (as listed in the Ecological specialist report under Table 32, pages 70-73) are identified within the proposed footprint, effective rescue and relocation of them must be undertaken by a qualified botanist and/or ECO. If any such protected species are found, the relevant removal and relocation permits must be obtained from DAFF.

• Replace the soil profile in its natural sequence to avoid soil and nutrient loss. • The area affected by the proposed development must be kept to a minimum and,

where not on designated areas, may not encroach into natural habitat without the approval of the ECO.

• Apply dust suppression where required. • A method statement must be provided by the contractor prior to any onsite

activity that includes the layout of the construction camp in the form of a plan showing the location of key infrastructure and services (where applicable), including but not limited to offices, overnight vehicle parking areas, stores, the workshop, stockpile and lay down areas, hazardous materials storage areas (including fuels), the batching plant (if one is located at the construction camp), designated access routes, equipment cleaning areas and the placement of staff accommodation, cooking and ablution facilities, waste and wastewater management;

• Location of camps must be within approved area to ensure that the site does not impact on sensitive areas identified in the environmental assessment or site walk through;

• Sites must be located where possible on previously disturbed areas; • The use of existing accommodation for contractor staff, where possible, is

encouraged. • Where the walkthrough identified any heritage resources, the chance find

procedure must be implemented.

All recommendations and mitigation measures will ensure the preservation of the topsoil, protection of any protected species in clearance area and minimize any further environmental degradation or damage to heritage sites.

During site establishment, site management and decommissioning.

ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of


COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

Restricted areas Pre-construction Please refer to 3.4 in the BAR

• Identification of access restricted areas is to be informed by the environmental assessment, site walk through and any additional areas identified during development;

• Erect, demarcate and maintain a temporary barrier with clear signage around the perimeter of any access restricted area, colour coding could be used if appropriate; and

• Unauthorised access and development related activity inside access restricted areas is prohibited.

All recommendations and mitigation measures will ensure that sensitive or restricted areas remains unaffected and protected.

During pre-construction activities.

Access roads Pre-construction and construction


• An access agreement must be formalised and signed by the DPM, Contractor and landowner before commencing with the activities;

• All private roads used for access to the servitude must be maintained and upon completion of the works, be left in at least the original condition

• All contractors must be made aware of all these access routes. • Any access route deviation from that in the written agreement must be closed

and re-vegetated immediately, at the contractor’s expense; • Maximum use of both existing servitudes and existing roads must be made to

minimize further disturbance through the development of new roads; • Access roads in flattish areas must follow fence lines and tree belts to avoid

fragmentation of vegetated areas or croplands • Access roads must only be developed on pre-planned and approved roads.

If all of the mitigation measures are followed, then the degradation from access roads will be prevented where existing roads are used and minimized where new roads are to be built.

During construction, operation and decommissioning phase

Fencing and access control

Pre-construction, Operational and decommissioning and rehabilitation


• Use existing gates provided to gain access to all parts of the area authorised for development, where possible;

• All gates must always be fitted with locks and be kept locked during the development phase, unless otherwise agreed with the landowner;

• At points where the line crosses a fence in which there is no suitable gate within the extent of the line servitude, on the instruction of the DPM, a gate must be installed at the approval of the landowner;

• Care must be taken that the gates must be so erected that there is a gap of no more than 100 mm between the bottom of the gate and the ground;

• Where gates are installed in jackal proof fencing, a suitable reinforced concrete still must be provided beneath the gate;

• Original tension must be maintained in the fence wires; • All gates installed in electrified fencing must be re-electrified; • All demarcation fencing and barriers must be maintained in good working order

for the duration of the development activities; • Fencing must be erected around the camp, hazardous storage areas, and all

designated access restricted areas, where applicable;

If all of the mitigation measures are followed, then the area will be appropriately secured with fencing to prevent access.


ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of


COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

• Any temporary fencing to restrict the movement of life-stock must only be erected with the permission of the landowner.

• All fencing must be developed of high-quality material bearing the SABS mark; • The use of razor wire as fencing must be avoided; • Fenced areas with gate access must remain locked after hours, during weekends

and on holidays if staff is away from site. Site security will be required at all times; • On completion of the development phase all temporary fences are to be

removed; • The contractor must ensure that all fence uprights are appropriately removed,

ensuring that no uprights are cut at ground level but rather removed completely.

Storm water and wastewater management

Construction, operation, Decommissioning and Rehabilitation


• Contaminated runoff water must be collected, stored and either treated or disposed of off-site, at a location approved by the project manager;

• All spillage of oil onto concrete or soil surfaces must be controlled by the use of an approved absorbent material and the used absorbent material disposed of at a licensed waste disposal facility;

• Topsoil must be removed immediately after clearing vegetation cover, to prevent water and wind erosion from reducing the volume of soil.

• No topsoil or fertile soil (dark soil) may be stored within 32 m of a drainage line, watercourse or wetland

• Where applicable, construct berms in order to prevent rill erosion and donga formation.

• All cleared areas and sumps are to be monitored for erosion daily, any erosion forming is to be remediated with immediate effect.

If all of the mitigation measures are followed, then the runoff from the area will remain unpolluted and effectively controlled


Waste management



• All measures regarding waste management must be undertaken using an integrated waste management approach;

• Sufficient, covered waste collection bins (scavenger and weatherproof) must be provided;

• A suitably positioned and clearly demarcated waste collection site must be identified and provided;

• The waste collection site must be maintained in a clean and orderly manner; • Waste must be segregated into separate bins and clearly marked for each

waste type for recycling and safe disposal; • Staff must be trained in waste segregation; • Bins must be emptied regularly; • General waste produced onsite must be disposed of at registered waste

disposal sites/ recycling company; • Hazardous waste must be disposed of at a registered waste disposal site; • Certificates of safe disposal for general, hazardous and recycled waste must be

maintained.

If all of the mitigation measures are followed then waste will be appropriately handled so as to prevent pollution, nuisance and other resultant waste effects.


ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of


COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

Protection of watercourses



• All watercourses must be protected from direct or indirect spills of pollutants such as solid waste, sewage, cement, oils, fuels, chemicals, aggregate tailings, wash and contaminated water or organic material resulting from the Contractor’s activities;

• In the event of a spill, prompt action must be taken to clear the polluted or affected areas;

• No wetlands were found, but where identified, no development equipment must traverse any seasonal or permanent wetland

• Development of permanent watercourse crossing must only be undertaken where no alternative access to tower position is available;

• There must not be any impact on the long-term morphological dynamics of watercourses or estuaries;

• Existing crossing points must be favoured over the creation of new crossings (including temporary access)

• When working in or near any watercourse, the following environmental controls and consideration must be taken:

a) Water levels during the period of construction; b) During the execution of the works, appropriate measures to prevent

pollution and contamination of the riparian environment must be implemented e.g. including ensuring that construction equipment is well maintained;

c) Where earthwork is being undertaken near any watercourse, slopes must be stabilised using suitable materials, i.e. sandbags or geotextile fabric, to prevent sand and rock from entering the channel; and

d) Appropriate rehabilitation and re-vegetation measures for the watercourse banks must be implemented timeously. In this regard, the banks should be appropriately and incrementally stabilised as soon as development allows.

If all of the mitigation measures are followed then the watercourses will be protected and, where it cannot be protected, additional actions taken to minimize impact to watercourses


Vegetation clearing and management



• Indigenous vegetation which does not interfere with the development must be left undisturbed;

• Protected or endangered species may occur on or near the development site. Special care should be taken not to damage such species;

• Search, rescue and replanting of all protected and endangered species likely to be damaged during project development must be identified by the relevant specialist and completed prior to any development or clearing;

• Permits for removal must be obtained from the relevant CA prior to the cutting or clearing of the affected species, and they must be filed;

If all of the mitigation measures are followed, then any sensitive or protected vegetation will be protected, and the other vegetation


ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of


COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

• The Environmental Audit Report must confirm that all identified species have been rescued and replanted and that the location of replanting is compliant with conditions of approvals;

• Trees felled due to construction must be documented and form part of the Environmental Audit Report;

• Rivers and watercourses must be kept clear of felled trees, vegetation cuttings and debris;

• Only a registered pest control operator may apply herbicides on a commercial basis and commercial application must be carried out under the supervision of a registered pest control operator, supervision of a registered pest control operator or is appropriately trained;

• A daily register must be kept of all relevant details of herbicide usage; • All protected species and sensitive vegetation not removed must be clearly

marked and such areas fenced off in accordance to Section 5.3: Access restricted areas.

• Alien invasive vegetation must be removed and disposed of at a licensed waste management facility.

degradation will be minimized.

Protection of fauna



• No interference with livestock must occur without the landowner’s written consent and with the landowner or a person representing the landowner being present;

• The breeding sites of raptors and other wild bird species must be taken into consideration during the planning of the development programme;

• Breeding sites must be kept intact and disturbance to breeding birds must be avoided. Special care must be taken where nestlings or fledglings are present;

• Special recommendations of the avian specialist must be adhered to at all times to prevent unnecessary disturbance of birds;

• No poaching must be tolerated under any circumstances. All animal dens near the works areas must be marked as Access restricted areas;

• No deliberate or intentional killing of fauna is allowed; • In areas where snakes are abundant, snake deterrents to be deployed on the

pylons to prevent snakes climbing up, being electrocuted and causing power outages; and

• No Threatened or Protected species (ToPs) and/or protected fauna as listed according NEMBA (Act No. 10 of 2004) and relevant provincial ordinances may be removed and/or relocated without appropriate authorisations/permits.

• Collisions of sensitive bird species with the new power line are possible along the new power line alignment. The most sensitive area would be the river crossing, especially when this has water flowing. This can be mitigated by

If all of the mitigation measures are followed, then any sensitive or protected fauna will be protected, and any fauna disturbances will be minimized.

During pre-construction, construction, operation and decommissioning.

ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of


COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

marking the section that crosses the river with anti-collision marking devices. These must be installed on the earth wire at 10metre spacing and alternating light and dark colour devices. Eskom will be responsible for maintaining these marking devices in working order for the full power line lifespan.

• Electrocutions are likely should the incorrect power line tower design be used. To mitigate this impact the design to be used must have enough clearances for birds to navigate and prevent and reduce electrocutions (preferably the monopole design, or similar, with greater than 1.8 m clearances).

Heritage resources Pre-construction and construction


• Identify, demarcate and prevent impact to all known sensitive heritage features on site in accordance with the No-Go procedure in Section 5.3: Access restricted areas;

• Carry out general monitoring of excavations for potential fossils, artefacts and material of heritage importance;

• All work must cease immediately, if any human remains and/or other archaeological, palaeontological and historical material are uncovered. Such material, if exposed, must be reported to the nearest museum, archaeologist / palaeontologist (or the South African Police Services), so that a systematic and professional investigation can be undertaken. Sufficient time must be allowed to remove/collect such material before development recommences.

If all of the mitigation measures are followed, then any sensitive or protected fauna will be protected, and any fauna disturbances will be minimized.

During pre-construction and construction.

Hazardous substances



• The use and storage of hazardous substances to be minimised and non-hazardous and non-toxic alternatives substituted where possible;

• All hazardous substances must be stored in suitable containers as defined in the Method Statement;

• Containers must be clearly marked to indicate contents, quantities and safety requirements;

• All storage areas must be bunded. The bunded area must be of sufficient capacity to contain a spill / leak from the stored containers;

• An Alphabetical Hazardous Chemical Substance (HCS) control sheet must be drawn up and kept up to date on a continuous basis;

• All hazardous chemicals that will be used on site must have Material Safety Data Sheets (MSDS);

• All employees working with HCS must be made aware of the safe use of the substance and the use of the safety data sheet;

• The Contractor must ensure that diesel and other liquid fuel, oil and hydraulic fluid is stored in appropriate storage tanks or in bowsers;


ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of


COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

• The tanks/ bowsers must be situated on a smooth impermeable surface (concrete) with a permanent bund. The impermeable lining must extend to the crest of the bund and the volume inside the bund must be 130% of the total capacity of all the storage tanks/ bowsers (110% statutory requirement plus an allowance for rainfall);

• Provision must be made for refuelling at the storage area by protecting the soil with an impermeable groundcover. Where dispensing equipment is used, a drip tray must be used to ensure small spills are contained;

• All empty externally dirty drums must be stored on a drip tray or within a bunded area;

• No unauthorised access into the hazardous substances’ storage areas must be permitted;

• Adequate fire-fighting equipment must be made available at all hazardous storage areas;

• Where refuelling away from the dedicated refuelling station is required, a mobile refuelling unit must be used. Appropriate ground protection such as drip trays must be used;

• An appropriately sized spill kit kept onsite relevant to the scale of the activity/s involving the use of hazardous substance must be available at all times;

Dust generation



• Take all reasonable measures to minimise the generation of dust as a result of project development activities to the satisfaction of the ECO;

• Removal of vegetation must be avoided until such time as soil stripping is required and similarly exposed surfaces must be revegetated or stabilised as soon as is practically possible;

• Excavation, handling and transport of erodible materials must be avoided under high wind conditions or when a visible dust plume is present;

• During high wind conditions, the ECO must evaluate the situation and make recommendations as to whether dust damping measures are adequate, or whether working will cease altogether until the wind speed drops to an acceptable level;

• Where possible, soil stockpiles must be located in sheltered areas where they are not exposed to the erosive effects of the wind;

• Where erosion of stockpiles becomes a problem, erosion control measures must be implemented at the discretion of the ECO;


ACTIVITIES PROJECT

PHASE

SIZE AND SCALE of


COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

• Vehicle speeds must not exceed 40 km/h along dust roads or 20 km/h when traversing unconsolidated and non-vegetated areas;

• For significant areas of excavation or exposed ground, dust suppression measures must be used to minimise the spread of dust.

1.2 Impact management Outcomes

(A description of impact management outcomes, identifying the standard of impact management required for the aspects contemplated in paragraph.)

ACTIVITY POTENTIAL

IMPACT ASPECTS

AFFECTED PROJECT

PHASE MITIGATION TYPE

STANDARD TO BE

ACHIEVED

All activities Loss of natural vegetation and faunal habitat

All aspects Pre-construction

Construction

Remedy through Rehabilitation and Control through management and monitoring. • Indigenous vegetation which does not interfere with the development must be left

undisturbed; • Protected or endangered species may occur on or near the development site.

Special care should be taken not to damage such species; • Search, rescue and replanting of all protected and endangered species likely to

be damaged during project development must be identified by the relevant specialist and completed prior to any development or clearing;

• Permits for removal must be obtained from the relevant CA prior to the cutting or clearing of the affected species, and they must be filed;

• The Environmental Audit Report must confirm that all identified species have been rescued and replanted and that the location of replanting is compliant with conditions of approvals;

• Trees felled due to construction must be documented and form part of the Environmental Audit Report;

• Rivers and watercourses must be kept clear of felled trees, vegetation cuttings and debris;

• Only a registered pest control operator may apply herbicides on a commercial basis and commercial application must be carried out under the supervision of a

All standards

ACTIVITY POTENTIAL

IMPACT ASPECTS

AFFECTED PROJECT


STANDARD TO BE

ACHIEVED

registered pest control operator, supervision of a registered pest control operator or is appropriately trained;

• A daily register must be kept of all relevant details of herbicide usage; • All protected species and sensitive vegetation not removed must be clearly

marked and such areas fenced off in accordance to Section 5.3: Access restricted areas.

• Alien invasive vegetation must be removed and disposed of at a licensed waste management facility.

• No interference with livestock must occur without the landowner’s written consent and with the landowner or a person representing the landowner being present;

• The breeding sites of raptors and other wild bird species must be taken into consideration during the planning of the development programme;

• Breeding sites must be kept intact and disturbance to breeding birds must be avoided. Special care must be taken where nestlings or fledglings are present;

• Special recommendations of the avian specialist must be adhered to at all times to prevent unnecessary disturbance of birds;

• No poaching must be tolerated under any circumstances. All animal dens in close proximity to the works areas must be marked as Access restricted areas;

• No deliberate or intentional killing of fauna is allowed; • In areas where snakes are abundant, snake deterrents to be deployed on the

pylons to prevent snakes climbing up, being electrocuted and causing power outages; and

• No Threatened or Protected species (ToPs) and/or protected fauna as listed according NEMBA (Act No. 10 of 2004) and relevant provincial ordinances may be removed and/or relocated without appropriate authorisations/permits.

• Collisions of sensitive bird species with the new power line are possible along the new power line alignment. The most sensitive area would be the river crossing, especially when this has water flowing. This can be mitigated by marking the section that crosses the river with anti-collision marking devices. These must be installed on the earth wire at 10metre spacing and alternating light and dark colour devices. Eskom will be responsible for maintaining these marking devices in working order for the full power line lifespan.

• Electrocutions are likely should the incorrect power line tower design be used. To mitigate this impact the design to be used must have enough clearances for birds

ACTIVITY POTENTIAL

IMPACT ASPECTS

AFFECTED PROJECT


STANDARD TO BE

ACHIEVED

to navigate and prevent and reduce electrocutions (preferably the monopole design, or similar, with greater than 1.8 m clearances).

Visual impacts

Remedy through Rehabilitation and Control through management and monitoring. • All areas outside of the borehole footprints should be regarded as no-go areas. • Topsoil, fertile soil (dark soil) and inert material are to be stored no higher than

2m to reduce the visual impact of the site.

Aesthetically pleasing

Soil erosion

Remedy through Rehabilitation and Control through management and monitoring. • Topsoil must be removed immediately after clearing vegetation cover, to prevent

water and wind erosion from reducing the volume of soil. • No topsoil or fertile soil (dark soil) may be stored within 32 m of a drainage line,

watercourse or wetland • Where applicable, construct berms in order to prevent rill erosion and donga

formation. • All cleared areas and sumps are to be monitored for erosion daily, any erosion

forming is to be remediated with immediate effect.

No Erosion or degradation of the Landscape

Introduction of alien invasive plant species

Remedy through Rehabilitation and Control through management and monitoring. • All sites disturbed by construction activities must be monitored for exotic or

invasive plant species and weeds. • Site clearance will encourage the introduction of alien invasive plant species, the

contractor should train the labourers on the removal and disposal of alien vegetation (Mechanical and Chemical).

• Chemical or mechanical removal may be used. If chemical methods are used the method of use is to be undertaken in accordance with manufacturer’s specification for the weeds and this method and management is to be approved by the ECO.

• Any eradicated exotic/invasive plant or weed vegetation must be removed from site and disposed of at an approved waste disposal facility or an alternative eradication method approved by the competent authority.

Area free of Alien Invasive plant species

ACTIVITY POTENTIAL

IMPACT ASPECTS

AFFECTED PROJECT


STANDARD TO BE

ACHIEVED

Loss of Heritage Sites

Control through monitoring and management and through avoidance. • Identify, demarcate and prevent impact to all known sensitive heritage features

on site in accordance with the No-Go procedure in Section 5.3: Access restricted areas;

• Carry out general monitoring of excavations for potential fossils, artefacts and material of heritage importance;

• All work must cease immediately, if any human remains and/or other archaeological, palaeontological and historical material are uncovered. Such material, if exposed, must be reported to the nearest museum, archaeologist / palaeontologist (or the South African Police Services), so that a systematic and professional investigation can be undertaken. Sufficient time must be allowed to remove/collect such material before development recommences.

All heritage artefacts are preserved

Dust Generation

Remedy through Rehabilitation and Control through management and monitoring. • Take all reasonable measures to minimise the generation of dust as a result of

project development activities to the satisfaction of the EO; • Removal of vegetation must be avoided until such time as soil stripping is

required and similarly exposed surfaces must be revegetated or stabilised as soon as is practically possible;

• Excavation, handling and transport of erodible materials must be avoided under high wind conditions or when a visible dust plume is present;

• During high wind conditions, the EO must evaluate the situation and make recommendations as to whether dust damping measures are adequate, or whether working will cease altogether until the wind speed drops to an acceptable level;

• Where possible, soil stockpiles must be located in sheltered areas where they are not exposed to the erosive effects of the wind;

• Where erosion of stockpiles becomes a problem, erosion control measures must be implemented at the discretion of the EO;

• Vehicle speeds must not exceed 40 km/h along dust roads or 20 km/h when traversing unconsolidated and non-vegetated areas;

• For significant areas of excavation or exposed ground, dust suppression measures must be used to minimise the spread of dust.

Area is free from dust

ACTIVITY POTENTIAL

IMPACT ASPECTS

AFFECTED PROJECT


STANDARD TO BE

ACHIEVED

Loss of Topsoil

Remedy through Rehabilitation and Control through management and monitoring. • All material that is excavated during the project development phase (either during

piling (if required) or earthworks) must be stored appropriately on site in order to minimise impacts to

• watercourses, watercourses and water bodies; • All stockpiled material must be maintained and kept clear of weeds and alien

vegetation growth by undertaking regular weeding and control methods; • Topsoil stockpiles must not exceed 2 m in height; • During periods of strong winds and heavy rain, the stockpiles must be covered

with appropriate material (e.g. cloth, tarpaulin etc.); • Where possible, sandbags (or similar) must be placed at the bases of the

stockpiled material in order to prevent erosion of the material

Rehabilitation objectives will be achieved

Degradation to any water courses

or wetlands

Avoidance Control through management and monitoring • All watercourses must be protected from direct or indirect spills of pollutants such

as solid waste, sewage, cement, oils, fuels, chemicals, aggregate tailings, wash and contaminated water or organic material resulting from the Contractor’s activities;

• In the event of a spill, prompt action must be taken to clear the polluted or affected areas;

• Where possible, no development equipment must traverse any seasonal or permanent wetland

• Development of permanent watercourse crossing must only be undertaken where no alternative access to tower position is available;

• There must not be any impact on the long-term morphological dynamics of watercourses or estuaries;

• Existing crossing points must be favoured over the creation of new crossings (including temporary access)

• When working in or near any watercourse, the following environmental controls and consideration must be taken:

o Water levels during the period of construction; o During the execution of the works, appropriate measures to prevent

pollution and contamination of the riparian environment must be

Watercourses or wetlands will not be affected

ACTIVITY POTENTIAL

IMPACT ASPECTS

AFFECTED PROJECT


STANDARD TO BE

ACHIEVED

implemented e.g. including ensuring that construction equipment is well maintained;

o Where earthwork is being undertaken in close proximity to any watercourse, slopes must be stabilised using suitable materials, i.e. sandbags or geotextile fabric, to prevent sand and rock from entering the channel; and

o Appropriate rehabilitation and re-vegetation measures for the watercourse banks must be implemented timeously. In this regard, the banks should be appropriately and incrementally stabilised as soon as development allows.

1.3 Impact Management Actions

(A description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (c) and (d) will be achieved).

ACTIVITY POTENTIAL IMPACT MITIGATION TYPE TIME PERIOD FOR IMPLEMENTATION

COMPLIANCE WITH STANDARDS

Site establishment

• Loss of natural vegetation and faunal habitat due to site clearing;

• Visual impacts; • Soil erosion; • Loss of land

capability; • Dust emissions; • Introduction of

weeds and alien invasive plants

Control through avoidance, management and Monitoring • Vegetation clearing may only take place within the development

footprint and should only proceed after a walkthrough has been done and any protected species rescued and relocated.

• If any SCC or protected species (as listed in the specialist report under Table 32, pages 70-73) are identified within the proposed footprint, effective rescue and relocation of them must be undertaken by a qualified botanist and/or ECO. If any such protected species are found, the relevant removal and relocation permits must be obtained from DAFF.

• Replace the soil profile in its natural sequence to avoid soil and nutrient loss.

• The area affected by the proposed development must be kept to a minimum and, where not on designated areas, may not encroach into natural habitat.

• Apply dust suppression where required. • A method statement must be provided by the contractor prior to any

onsite activity that includes the layout of the construction camp in the form of a plan showing the location of key infrastructure and services (where applicable), including but not limited to offices, overnight vehicle parking areas, stores, the workshop, stockpile and lay down areas, hazardous materials storage areas (including fuels), the batching plant (if one is located at the construction camp), designated access routes, equipment cleaning areas and the placement of staff accommodation, cooking and ablution facilities, waste and wastewater management;


• Sites must be located where possible on previously disturbed areas;

During pre-construction

BAR and EMPr

• The use of existing accommodation for contractor staff, where possible, is encouraged.

• Where the walkthrough identified any heritage resources, the chance find procedure must be implemented.

Construction of structures and/or facilities (storage, berms, fence, ablution facilities etc.)

• Soil erosion; • Noise pollution; • Dust generation; • Traffic congestion; • Introduction of

weeds and alien invasive plants.

Control through avoidance, management and Monitoring • Erosion protection measures being in place. • Drainage channels must be protected to prevent scour, so that

runoff will be collected and conducted past the excavation or spoil area.

• Compliance with local by-laws and regulations regarding the noise and hours of operation.

• Application of soil binders or dust suppressants in areas prone to dust generation.

• Site clearance will encourage the introduction of alien invasive plant species, The Sasol Mining contractor should train the labourers on the removal and disposal of alien vegetation.

• All sites disturbed by construction activities must be monitored for exotic or invasive plant species and weeds.

• Any eradicated exotic/invasive plant or weed vegetation must be removed from site and disposed of at an approved waste disposal facility.

During construction

BAR and EMPr’ Best Practice Guideline (G1) Storm Water Management

Construction of access roads

• Soil erosion • Noise pollution; • Dust generation; • Traffic congestion; • Introduction of

weeds and alien invasive plants.

Control through avoidance, management and Monitoring • An access agreement must be formalised and signed by the DPM,

Contractor and landowner before commencing with the activities; • All private roads used for access to the servitude must be maintained

and upon completion of the works, be left in at least the original condition

• All contractors must be made aware of all these access routes. • Any access route deviation from that in the written agreement must

be closed and re-vegetated immediately, at the contractor’s expense; • Maximum use of both existing servitudes and existing roads must be

made to minimize further disturbance through the development of new roads;

• In circumstances where private roads must be used, the condition of the said roads must be recorded in accordance with section 4.9: photographic record; prior to use and the condition thereof agreed by the landowner and the contractor;

During construction BAR and EMPr

• Access roads in flattish areas must follow fence lines and tree belts to avoid fragmentation of vegetated areas or croplands

• Access roads must only be developed on pre-planned and approved roads.

Storing and Stockpiling and/or storing of material

• Dust from stockpiles;

• Soil erosion; • Visual impact; • Introduction of


Control through avoidance, management and Monitoring • Surface water runoff must be appropriately channelled through or

around the stockpile areas to prevent erosion damage resulting from stormwater runoff.

• All material that is excavated during the project development phase (either during piling (if required) or earthworks) must be stored appropriately on site in order to minimise impacts to watercourses, watercourses and water bodies;

• All stockpiled material must be maintained and kept clear of weeds and alien vegetation growth by undertaking regular weeding and control methods;

• Topsoil stockpiles must not exceed 2 m in height; • During periods of strong winds and heavy rain, the stockpiles must

be covered with appropriate material (e.g. cloth, tarpaulin etc.); • Where possible, sandbags (or similar) must be placed at the bases

of the stockpiled material in order to prevent erosion of the material.

During operation BAR and EMPr

Rehabilitation and closure (removal of temporary infrastructure, spreading of topsoil, etc.)

• Demolition of structures;

• Soil erosion; • Noise pollution; • Dust generation;

Control through avoidance, management and Monitoring and Rehabilitation • All the waste from demolition must collected from site for disposal. • Material loads must be properly covered during transportation.

Speed limits for vehicles on unpaved roads must be enforced and haul distances minimised as far as possible.

• Sites are to be rehabilitated in line with closure objectives and in consultation with landowners.

• All areas disturbed by construction activities must be subject to landscaping and rehabilitation; All spoil and waste must be disposed of to a registered waste site;

• All slopes must be assessed for contouring, and to contour only when the need is identified in accordance with the Conservation of Agricultural Resources Act, No 43 of 1983

• All slopes must be assessed for terracing, and to terrace only when the need is identified in accordance with the Conservation of Agricultural Resources Act, No 43 of 1983;

Immediately after completion of each phase of material extraction and during final closure activities.

BAR and EMPr

• Berms that have been created must have a slope of 1:4 and be replanted with indigenous species and grasses that approximates the original condition;

• Where new access roads have crossed cultivated farmlands, that lands must be rehabilitated by ripping which must be agreed to by the holder of the EA and the landowners;

• Indigenous species must be used for with species and/grasses to where it compliments or approximates the original condition;

• Stockpiled topsoil must be used for rehabilitation (refer to Section 5.24: Stockpiling and stockpiled areas);

• Stockpiled topsoil must be evenly spread to facilitate seeding and minimise loss of soil due to erosion;

• Before placing topsoil, all visible weeds from the placement area and from the topsoil must be removed;

• Subsoil must be ripped before topsoil is placed; • The rehabilitation must be timed so that rehabilitation can take place

at the optimal time for vegetation establishment; • Where impacted through construction related activity, all sloped

areas must be stabilised to ensure proper rehabilitation is affected and erosion is controlled;

• Sloped areas stabilised using design structures or vegetation as specified in the design to prevent erosion of embankments. The contract design specifications must be adhered to and implemented strictly;

• Spoil can be used for backfilling or landscaping if it is covered by a minimum of 150 mm of topsoil.

• Where required, re-vegetation including hydro-seeding can be enhanced using a vegetation seed mixture as described below. A mixture of seed can be used provided the mixture is carefully selected to ensure the following:

o Annual and perennial plants are chosen; o Pioneer species are included; o Species chosen must be indigenous to the area with the

seeds used coming from the area; o Root systems must have a binding effect on the soil; o The final product must not cause an ecological imbalance

in the area

1.4 Financial Provision

a) Determination of the amount of Financial Provision

(i) Describe the closure objectives and the extent to which they have been aligned to the baseline environment described under the Regulation.

(Rehabilitation measures have been designed to meet closure objectives)

The project will remain operational post-closure of the Lwala Mine. Hence, no closure is scheduled for the project. The concurrent rehabilitation objectives will be to return the rehabilitation areas to its pre-project state and restore the ecological functions.

(ii) Confirm specifically that the environmental objectives in relation to closure have been consulted with landowner and interested and affected parties.

Proof of consultation is attached as Appendix 7. Further comments on the rehabilitation measures and closure objectives are expected after review of the DBAR. Should any issues be raised regarding closure objectives, they will be addressed and included in the final BAR.

(iii) Provide a rehabilitation plan that describes and shows the scale and aerial extent of the main mining activities, including the anticipated mining area at the time of closure.

Refer to section 3.22.

(iv) Explain why it can be confirmed that the rehabilitation plan is compatible with the closure objectives.

The project will remain operational post-closure of the Lwala Mine. Hence, no closure is scheduled for the project. The concurrent rehabilitation objectives will be to return the rehabilitation areas to its pre-project state and restore the ecological functions.

(v) Calculate and state the quantum of the financial provision required to manage and rehabilitate the environment in accordance with the applicable guideline.

Not required, see section 3.22

(vi) Confirm that the financial provision will be provided as determined.

Not required, see section 3.22

(vii) Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including

b) Monitoring of impact Management Actions

SOURCE ACTIVITY IMPACT REQUIRING

MONITORING PROGRAMMMES

FUNCTIONAL REQUIREMENT FOR MONITORING

ROLES AND RESPONSIBILITIES

(FOR THE EXECUTION OF THE MONITORING PROGRAMMES)

MONITORING AND REPORTING FREQUENCY AND TIME PERIODS

FOR IMPLEMENTING IMPACT MANAGEMENT ACTIONS

Environmental permits and authorisations

• Not applicable (relevant authorisations, registrations and permits are underway)

• To ensure that all relevant authorisations and permits have been obtained and are located on site at all times.

• Ensure that a copy of the BAR and EMPR are kept on-site and communicated to site personnel.

ECO Prior to site establishment

Site establishment

• Loss of natural vegetation

• Soil erosion • Loss of land

capability • Visual impacts and • Introduction of


• Dust emissions • Noise • Heritage

• Vegetation clearing may only take place within the development footprint and should only proceed after a walkthrough has been done and any protected species rescued and relocated.

• If any SCC or protected species (as listed in the ecological specialist report under Table 32, pages 70-73) are identified within the proposed footprint, effective rescue and relocation of them must be undertaken by a qualified botanist and/or ECO. If any such protected species are found, the relevant removal and relocation permits must be obtained from DAFF.

• Replace the soil profile in its natural sequence to avoid soil and nutrient loss.

• The area affected by the proposed development must be kept to a minimum and, where not on designated areas, may not encroach into natural habitat without the approval of the ECO.

• Apply dust suppression where required. • A method statement must be provided by the contractor prior

to any onsite activity that includes the layout of the

ECO Daily monitoring by the ECO








construction camp in the form of a plan showing the location of key infrastructure and services (where applicable), including but not limited to offices, overnight vehicle parking areas, stores, the workshop, stockpile and lay down areas, hazardous materials storage areas (including fuels), the batching plant (if one is located at the construction camp), designated access routes, equipment cleaning areas and the placement of staff accommodation, cooking and ablution facilities, waste and wastewater management;


• Sites must be located where possible on previously disturbed areas;

• The use of existing accommodation for contractor staff, where possible, is encouraged.

• Where the walkthrough identified any heritage resources, the chance find procedure must be implemented.

Construction of structures and/or facilities on site (storage, berms, fence, ablution facilities etc.)

• Soil erosion • Loss of land

capability • Visual impacts and • Introduction of


• Dust emissions • Noise

• To ensure the no-go areas are identified communicated and demarcated.

• Vegetation clearing must be limited to the demarcated area. • Maintain access control as per fencing actions in section 4.1

d (iv) above • Ensure dust suppression schedule and measures are in place

in areas prone to dust generation. • Ensure alien plants and weeds are always managed, to

prevent a seed bank from establishing through drawing up an alien plants monitoring and clearing schedule.

• Daily checks for erosion are to be done and repaired if identified.

• All plant and vehicles are to be checked on a daily basis using a daily checklist to identify any problems with equipment.

ECO Daily monitoring by the ECO.








Construction of access roads

• Soil erosion • Noise pollution; • Dust generation; • Traffic congestion.

• An access agreement must be formalised and signed by the DPM, Contractor and landowner before commencing with the activities;

• All private roads used for access to the servitude must be maintained and upon completion of the works, be left in at least the original condition

• All contractors must be made aware of all these access routes. • Any access route deviation from that in the written agreement

must be closed and re-vegetated immediately, at the contractor’s expense;

• Maximum use of both existing servitudes and existing roads must be made to minimize further disturbance through the development of new roads;

• In circumstances where private roads must be used, the condition of the said roads must be recorded in accordance with section 4.9: photographic record; prior to use and the condition thereof agreed by the landowner, the DPM, and the contractor;

• Access roads in flattish areas must follow fence lines and tree belts to avoid fragmentation of vegetated areas or croplands

• Access roads must only be developed on pre-planned and approved roads.

ECO

Daily monitoring by the ECO.








Stockpiles of soil and inert material.

• Surface and ground water contamination;

• Dust generation; • Noise pollution; • Visual impacts; • Disruption of

services; and • Waste • Introduction of


• To ensure no contaminated run-off from entering drainage lines

• Ensure dust suppression measures are in place in areas prone to dust generation

• All documentation relating to waste stipulated in the above sections is to be checked on a weekly basis

• Ensure the surface water runoff is appropriately channelled through or around the stockpile areas to prevent erosion damage resulting from stormwater runoff.

• Monitor the size of the stockpile that it does not exceed the designated height

• All material that is excavated during the project development phase (either during piling (if required) or earthworks) must be stored appropriately on site in order to minimise impacts to watercourses, watercourses and water bodies;

• All stockpiled material must be maintained and kept clear of weeds and alien vegetation growth by undertaking regular weeding and control methods;

• During periods of strong winds and heavy rain, the stockpiles must be covered with appropriate material (e.g. cloth, tarpaulin etc.);

• Where possible, sandbags (or similar) must be placed at the bases of the stockpiled material in order to prevent erosion of the material

Project Manager, Appointed Contractor, ECO.

Daily monitoring by the Contractor’s or Eskom’s designated ECO.

Water and Storm water

• Soil erosion; • Water quality

• Runoff contaminated water must be collected, stored and either treated or disposed of off-site, at a location approved by the project manager;

• All spillage of oil onto concrete surfaces must be controlled by the use of an approved absorbent material and the used absorbent material disposed of at an appropriate waste disposal facility;

• Natural storm water runoff not contaminated during the development and clean water can be discharged directly to

ECO

Daily monitoring by the ECO








watercourses and water bodies, subject to the Project Manager’s approval and support by the EO;

• Water that has been contaminated with suspended solids, such as soils and silt, may be released into watercourses or water bodies only once all suspended solids have been removed from the water by settling out these solids in settlement ponds. The release of settled water back into the environment must be subject to the Project Manager’s approval and support by the EO.

• Topsoil must be removed immediately after clearing vegetation cover, to prevent water and wind erosion from reducing the volume of soil.

• No topsoil or fertile soil (dark soil) may be stored within 32 m of a drainage line, watercourse or wetland

• Where applicable, construct berms in order to prevent rill erosion and donga formation.

• All cleared areas and sumps are to be monitored for erosion daily, any erosion forming is to be remediated with immediate effect.

Rehabilitation and closure

• Demolition of structures;

• Noise pollution; • Dust generation; • Rehabilitation by

replacing soil and encouraging growth of indigenous vegetation

• All the waste from demolition must collected from site for disposal.

• Material loads must be properly covered during transportation. Speed limits for vehicles on unpaved roads must be enforced and haul distances minimised as far as possible.

• Sites are to be rehabilitated in line with closure objectives and in consultation with landowners.

• All areas disturbed by construction activities must be subject to landscaping and rehabilitation; All spoil and waste must be disposed of to a registered waste site;

• All slopes must be assessed for contouring, and to contour only when the need is identified in accordance with the Conservation of Agricultural Resources Act, No 43 of 1983

ECO

During rehabilitation, daily and after rehabilitation and before closure. The closure audit will be undertaken by ECO. After rehabilitation is completed the area will be checked monthly to confirm sustainability of the rehabilitation.








• All slopes must be assessed for terracing, and to terrace only when the need is identified in accordance with the Conservation of Agricultural Resources Act, No 43 of 1983;

• Berms that have been created must have a slope of 1:4 and be replanted with indigenous species and grasses that approximates the original condition;

• Where new access roads have crossed cultivated farmlands, that lands must be rehabilitated by ripping which must be agreed to by the holder of the EA and the landowners;

• Indigenous species must be used for with species and/grasses to where it compliments or approximates the original condition;

• Stockpiled topsoil must be used for rehabilitation (refer to Section 5.24: Stockpiling and stockpiled areas);

• Stockpiled topsoil must be evenly spread to facilitate seeding and minimise loss of soil due to erosion;

• Before placing topsoil, all visible weeds from the placement area and from the topsoil must be removed;

• Subsoil must be ripped before topsoil is placed; • The rehabilitation must be timed so that rehabilitation can

take place at the optimal time for vegetation establishment; • Where impacted through construction related activity, all

sloped areas must be stabilised to ensure proper rehabilitation is affected and erosion is controlled;

• Sloped areas stabilised using design structures or vegetation as specified in the design to prevent erosion of embankments. The contract design specifications must be adhered to and implemented strictly;

• Spoil can be used for backfilling or landscaping if it is covered by a minimum of 150 mm of topsoil.

• Where required, re-vegetation including hydro-seeding can be enhanced using a vegetation seed mixture as described








below. A mixture of seed can be used provided the mixture is carefully selected to ensure the following:

- Annual and perennial plants are chosen; - Pioneer species are included; - Species chosen must be indigenous to the area

with the seeds used coming from the area; - Root systems must have a binding effect on the

soil; - The final product must not cause an ecological

imbalance in the area

c) Responsible persons

Responsible perosn Roles and responsibilities Project Manager Role

The Project Developer is accountable for ensuring compliance with the EMPr and any conditions of approval from the competent authority (CA). Where required, an environmental control officer (ECO) must be contracted by the Project Developer to objectively monitor the implementation of the EMPr according to relevant environmental legislation, and the conditions of the environmental authorisation (EA). The Project Developer is further responsible for providing and giving mandate to enable the ECO to perform responsibilities, and he must ensure that the ECO is integrated as part of the project team while remaining independent. Responsibilities • Be fully conversant with the conditions of the EA; • Ensure that all stipulations within the EMPr are communicated and adhered to by the Developer and its Contractor(s); • Issuing of site instructions to the Contractor for corrective actions required; • Monitor the implementation of the EMPr throughout the project by means of site inspections and meetings. Overall management of the project and EMPr

implementation; and • Ensure that periodic environmental performance audits are undertaken on the project implementation.

Site supervisor Role

Responsible perosn Roles and responsibilities The DSS reports directly to the DPM, oversees site works, liaises with the contractor(s) and the ECO. The DSS is responsible for the day to day implementation of the EMPr and for ensuring the compliance of all contractors with the conditions and requirements stipulated in the EMPr. Responsibilities • Ensure that all contractors identify a contractor’s Environmental Officer (ECO); • Must be fully conversant with the conditions of the EA. Oversees site works, liaison with Contractor, DPM and ECO; • Must ensure that all landowners have the relevant contact details of the site staff, ECO; • Issuing of site instructions to the Contractor for corrective actions required; • Will issue all non-compliances to contractors; and • Ratify the Monthly Environmental Report.

Environmental Control Officer (ECO)

Role The ECO should have appropriate training and experience in the implementation of environmental management specifications. The primary role of the ECO is to act as an independent quality controller and monitoring agent regarding all environmental concerns and associated environmental impacts. In this respect, the ECO is to conduct periodic site inspections, attend regular site meetings, pre-empt problems and suggest mitigation and be available to advise on incidental issues that arise. The ECO is also required to conduct compliance audits, verifying the monitoring reports submitted by the contractors Environmental Officer (cEO). The ECO provides feedback to the DSS and Project Manager regarding all environmental matters. The Contractor and cEO are answerable to the Environmental Control Officer for non-compliance with the Performance Specifications as set out in the EA and EMPr. The ECO provides feedback to the DSS and Project Manager, who in turn reports back to the Contractor and potential and Registered Interested &Affected Parties’ (RI&AP’s), as required. Issues of non-compliance raised by the ECO must be taken up by the Project Manager and resolved with the Contractor as per the conditions of his contract. Decisions regarding environmental procedures, specifications and requirements which have a cost implication (i.e. those that are deemed to be a variation, not allowed for in the Performance Specification) must be endorsed by the Project Manager. The ECO must also, as specified by the EA, report to the relevant CA as and when required. Responsibilities The responsibilities of the ECO will include the following: • Be aware of the findings and conclusions of all EA related to the development; • Be familiar with the recommendations and mitigation measures of this EMPr; • Be conversant with relevant environmental legislation, policies and procedures, and ensure compliance with them; • Undertake regular and comprehensive site inspections / audits of the construction site according to the EMPr and applicable licenses in order to monitor

compliance as required; • Educate the construction team about the management measures contained in the EMPr and environmental licenses; • Compilation and administration of an environmental monitoring plan to ensure that the environmental management measures are implemented and are

effective; • Monitoring the performance of the Contractors and ensuring compliance with the EMPr and associated Method Statements;

Responsible perosn Roles and responsibilities • In consultation with the Developer Site Supervisor order the removal of person(s) and/or equipment which are in contravention of the specifications of

the EMPr and/or environmental licenses; • Liaison between the DPM, Contractors, authorities and other lead stakeholders on all environmental concerns; • Compile a regular environmental audit report highlighting any non-compliance issues as well as satisfactory or exceptional compliance with the EMPr; • Validating the regular site inspection reports, which are to be prepared by the contractors Environmental Officer (cEO); • Checking the cEO’s record of environmental incidents (spills, impacts, legal transgressions etc.) as well as corrective and preventive actions taken; • Checking the cEO’s public complaints register in which all complaints are recorded, as well as action taken; • Assisting in the resolution of conflicts; • Facilitate training for all personnel on the site – this may range from carrying out the training, to reviewing the training programmes of the Contractor; • In case of non-compliances, the ECO must first communicate this to the Senior Site Supervisor, who has the power to ensure this matter is addressed.

Should no action or insufficient action be taken, the ECO may report this matter to the authorities as non-compliance; • Maintenance, update and review of the EMPr; • Communication of all modifications to the EMPr to the relevant stakeholders.

Contractor’s Environmental Officer (cEO)

Role Each Contractor affected by the EMPr should appoint a cEO, who is responsible for the on-site implementation of the EMPr (or relevant sections of the EMPr). The Contractor’s representative can be the site agent; site engineer; a dedicated environmental officer; or an independent consultant. The Contractor must ensure that the Contractor’s Representative is suitably qualified to perform the necessary tasks and is appointed at a level such that she/he can interact effectively with other site Contractors, labourers, the Environmental Control Officer and the public. As a minimum the cEO shall meet the following criteria: Responsibilities • Be on site throughout the duration of the project and be dedicated to the project; • Ensure all their staff are aware of the environmental requirements, conditions and constraints with respect to all of their activities on site; • Implementing the environmental conditions, guidelines and requirements as stipulated within the EA, EMPr and Method Statements; • Attend the Environmental Site Meeting; • Undertaking corrective actions where non-compliances are registered within the stipulated timeframes; • Report back formally on the completion of corrective actions; • Assist the ECO in maintaining all the site documentation; • Prepare the site inspection reports and corrective action reports for submission to the ECO; • Assist the ECO with the preparing of the monthly report; and • Where more than one Contractor is undertaking work on site, each company appointed as a Contractor will appoint a cEO representing that company.

Contractor Role The Contractor appoints the cEO and has overall responsibility for ensuring that all work, activities, and actions linked to the delivery of the contract are in line with the EMPr and that Method Statements are implemented as described. External contractors must ensure compliance with this EMPr while performing the onsite activities as per their contract with the Project Developer. The contractors are required, where specified, to provide Method Statements setting out in detail how the impact management actions contained in the EMPr will be implemented during the development or expansion of substation infrastructure for the transmission and distribution of electricity activities.

Responsible perosn Roles and responsibilities Responsibilities • project delivery and quality control for the development services as per appointment; • employ a suitably qualified person to monitor and report to the Project Developer’s appointed person on the daily activities on-site during the construction

period; • ensure that safe, environmentally acceptable working methods and practices are implemented, and that equipment is properly operated and maintained,

to facilitate proper access and enable any operation to be carried out safely; • attend on site meeting(s) prior to the commencement of activities to confirm the procedure and designated activity zones; • ensure that contractors’ staff repair, at their own cost, any environmental damage as a result of a contravention of the specifications contained in EMPr,

to the satisfaction of the ECO.

1.5 Indicate the frequency of the submission of the performance assessment or environmental audit report.

Performance Assessment Reports (PAR), as required by the NEMA EIA Regulations 2014, will be prepared and submitted weekly (internally by the EO to the ECO) or as often as requested. In addition, the appointed ECO would undertake monthly site inspections during the construction periods, after rehabilitation has been completed the site is to be monitored. Copies of the site audit reports will be submitted to DMR if requested.

1.6 Environmental Awareness Plan

a) Manner in which the applicant intends to his or her employees of environmental risk which may result from their work.

Before the commencement of any activities, Eskom’s appointed Contractor's site management staff will be required to attend environmental awareness training which includes training on the content of the Environmental Authorisation the EMP and all licences.

b) Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment.

The following documents will be used as reference for identifying and managing impacts:

• Approved EMPr; • Approved EA; and • EMS.

The applicant (ESKOM) and contractors will be responsible for the implementation section 28 of NEMA at all times “duty of care” to mitigate any impacts in order to avoid pollution or degradation of the environment.

Appropriate implementation of the recommended mitigation measures specified in the EMPr will be monitored through monthly site audits by an EP and annual EMP audits undertaken by a third party.

1.7 Specific information required by the Competent Authority

(Amongst others, confirm that the financial provision will be reviewed annually)

Not required, see section 3.22.

1.8 UNDERTAKING

The EAP herewith confirms

a) the correctness of the information provided in the reports

b) the inclusion of comments and inputs from stakeholders and I&APs;

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

d) that the information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected parties are correctly reflected herein.

Signature of the environmental assessment practitioner:

ACER Africa Environmental Consultants (Pty) Ltd

Name of company:

16/07/2019

Date:

-END-

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