basic assessment report and environmental management ... · 2196, south africa ... magisterial...

BASIC ASSESSMENT REPORT

AND

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL

ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL

MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITES THAT HAVE BEEN

TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT, 2002 (MPRDA) (AS AMMENDED)

NAME OF APPLICANT: Bushveld Vametco (Pty) Ltd.

TEL NO: +27 (0)11 268 6555

FAX NO: +27(0) 11 268 5170

POSTAL ADDRESS:

PHYSICAL ADDRESS: Cnr Fricker and Harries roads, Illovo Edge Office Park, 2nd Floor, Illovo

2196, South Africa

FILE REFERENCE NUMBER SAMRAD:

FILE REFERENCE NUMBER SAMRAD:

DRAFT REPORT FOR COMMENT

1. IMPORTANT NOTICE:

In terms of the Mineral and petroleum Resources Development Act (Act 28 of 2002 as amended), the

Minister must grant a prospecting or mining right if among others the mining “will not result in

unacceptable pollution, ecological degradation or damage to the environment”.

Unless and 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 (Act 107 of 1998) (NEMA), it cannot be concluded that the said

activities will not result in unacceptable pollution, ecological degradation or damage to the

environment.

In terms of section 16(3)(b) of the EIA Regulations, 2014, any report submitted as part of an application

must be prepared in terms of section 17(1)(c) the competent Authority must check whether the

application has taken into account any minimum requirements applicable or instructions or guidance

provided by the competent authority to the submission of application.

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 are

submitted in the exact format of, and provide all the information required in terms of, this template.

Furthermore, please be advised that failure to submit the information required in the format provided

in this template will be regarded as a failure to meet the requirements of the Regulation and will lead

to the Environmental Authorization being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner must process and

interpret his/her research and analysis and use the findings gathered 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 the

applicant.

2. OBJECTIVE OF THE BASIC ASSESSMENT PROCESS

The objective of the basic assessment process is to, through a consultative process –

(a) Determine the policy and legislative content within which the proposed activity is located and how

the activity complies with the responds to the place 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 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 manage and monitored.

PART A

SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT

3. Contact person and correspondence address

a) Details of

i) Details of the EAP

Name of the Practitioner: Tashriq Naicker

Tel.no: 011 254 4811

Fax. No:

e‐mail address: [email protected]

ii) Expertise of the EAP

(1) The qualification of the EAP

(with evidence)

Tashriq holds a BSC (Hons) Environmental science from the University of Witwatersrand.

Please refer to Appendix A for a copy of the EAP’s qualification

(2) Summary of the EAP’s experience. (In carrying oath, the Environmental impact Assessment Procedure)

Tashriq is an Environmental Practitioner with more than ten years’ experience in the environmental field. His key experience includes project management, environmental impact assessments, mining, oil and gas exploration, oversight over specialist studies and management of specialist. Tashriq has worked extensively in South Africa and has project experience in other countries of Africa. He is well capable of executing a successful project, while ensuring quality control and legal compliance.

b) Location of the overall Activity.

Table 1 Location Details

Farm Name Krokodilkraal 426 Application area (Ha) 5ha Magisterial district: Bojanala Platinum District Municipality Distance and direction from nearest town The project area is located 7Km south west to

Brits and 12km south east to Ga-Rankuwa 21-digit Surveyor General Code for each farm portion

T0JQ00000000042600001

c) Locality map

(show nearest town, scale not smaller than 1:250000).

(See Appendix B)

Figure 1:Regional Locality Map

Figure 2: Site Locality Map

Figure 3: Study Area Map

d) Description of the scope of the proposed overall activity. Provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000

that shows the location, and area (hectares) of all the aforesaid main and listed activities, and

infrastructure to be placed on site.

Figure 4: Concept Project design and location

Figure 5: Illustration of Solar Panels and battery design

i) 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.)

ARIAL EXTENT OF THE ACTIVITY HA OR M²

LISTED ACTIVITY Mark with an X where applicable or affected.

APPLICABLE LISTING NOTICE (GNR 544, GNR 545 or GNR 546)

Construction of a 2.5 MW photovoltaic (PV) fixed tilt solar park with a 1MW/4 MWh Vanadium Redox Flow battery storage system. “The development of facilities or infrastructure for the generation of electricity from a renewable resource where: (ii) The electricity output is 10 megawatts or less, but the total extent of the facility covers an area in excess of 1 hectare.”

3Ha (footprint)

X EIA Regulations, Listing Notice 1 of 2014; Listed activity 1 of GN. R 327 (as amended),

Land clearance for the development of the PV Solar Panels and Battery storage. “The clearance of an area of 1 hectare or more, but less than 20 hectares of indigenous vegetation.”

3Ha (footprint)

X EIA Regulations, Listing Notice 1 of 2014; Listed activity 27 of GN. R 327 (as amended),

(ii) Description of the activities to be undertaken (Describe Methodology or technology to be employed, including the type of commodity to be

prospected/mined and for a linear activity, a description of the route of the activity)

Bushveld Vametco Holdings (Pty) Ltd (Bushveld Vametco) proposes to develop a 2.5 MW Photovoltaic

(PV) fixed tilt solar park with a 1MW/4 MWh Vanadium Redox Flow battery (VRFB) storage system.

The proposed project will be located within the Bushveld Vametco Alloys Mining right boundary. The

proposed project is linked to the existing Vametco Mine in that the proposed project intends to use

the Vanadium ore mined at Vametco Alloys Mine within the batteries and thereby enhance the

beneficiation process. The proposed project aims to investigate alternative economic streams (such

as battery storage technology) for the mine. The project area assessed is 5ha with a project footprint

of 3ha (for the solar PV panels and VRBF storage).

The project is designed to supply marginally less than 1MVA (999kVA) to the mine for 16 hours per

day and allow for off‐peak charging from the grid as an initial pilot project for Bushveld Vametco.

It is proposed that the system will be aligned to true North to take full advantage of late afternoon

generation, as the proposed generation period extends for a maximum of 4 hours beyond the solar

generation period. It is furthermore proposed that the storage will be installed on a string basis, in line

with current practice in the solar industry.

The design is premised by the fact that the battery will be fully discharged by approximately 22:00

(depending on the time of the year) and will recharge using mains power overnight, to an approximate

75% State of Charge (SOC), which will support early morning discharge from 6am. The excess solar

capacity, above the supplied 1 MW, will then charge the battery until the battery is fully charged. The

battery will then support the afternoon solar shoulder output to provide a constant output, until fully

discharged. The cycle then repeats.

The solar arrays would consist of 90 panels (double stacked) to provide a peak power of 31.5kW/h.

There would be 70 rows of panels, to provide a total solar output of 2,205 kWp. Each panel is

2005 x960mm (2 m X 0.96m) and 6 such panels will be mounted on a single support structure

(Figure 5). Each of the panels will cover an area of 12m2, with a spacing of 4.0m between each row.

The panels will be supported on I beam legs, with a central pole and framework supporting 6 panels.

The I beam legs will be mounted on 300mm diameter mini piles an estimated average of 1.8m deep

(final sizes to be determined individually by the EPC and ground engineer on site). The piles will be

hammered into the ground.

The VRFB will be centralised and consist of 10 standards 3X12m shipping containers, resting on

concrete slabs. The Vanadium electrolyte will be contained within individual pods, enclosed within

the larger container, which is sealed, and the battery module is located within a bunding, resulting in

a triple barrier protection. The 400V AC output will supply a 1MVA 400/6.6kV Isolation Transformer,

which will feed into the Vametco internal system grid via an existing 6.6kV supply line.

e) Policy and Legislative Context

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (a description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plants, guidelines, spatial tools, municipal development planning frameworks and 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 THE LEGISLTATION AND POLICY CONTEXT. (E.g. In terms of the National Water Act a Water Use License has / has not been applied for)

National Environmental Management Act 1998 (Act No. 107 Of 1998) (NEMA)

Throughout BAR and BA process as a whole

An Application for Environmental Authorisation has been submitted to the Department of Mineral Resources.

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

The project may trigger the requirements under Section 38 of the NHRA.

A Heritage Impact Assessment study has been undertaken in order to identify any heritage sites that may be present on site.

National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) (NEM:BA)

The possibility of the presence of protected flora and flora

An ecological assessment study has been undertaken in order to determine the ecological status of the project area.

f) 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).

South Africa is currently facing power supply shortages, this is evident through the power cut or load

shedding that has been occurring nationally. South Africa has, in the past, depended on non‐

renewable energy, mainly the burning of fossil fuel (coal) as a means of energy supply. Due to these

power supply challenges; South Africa has shifted its focus on the need to explore other means of

power supply such as the Independent Power Producer (IPP). The IPP projects makes use of renewable

energy as a means of energy production and supply. The proposed study is a pilot project for

combining PV solar with battery storage (Vanadium Redox Flow in this case), a new technology that

has been successfully implemented in the United States of America at the Maharishi University. This

pilot study will assess the economic and technological feasibility of such a project within the South

African context.

g) Motivation for the overall preferred site, activities and technology alternative

Motivation for the overall preferred site for the Bushveld Vametco project is based on the location of

the proposed project. As mentioned above, the proposed project is located within an existing Vametco

mining right boundary (Figure 1). The proposed project intends to use the Vanadium Ore mined at

Vametco Mine within the Vanadium Redox batteries and thereby enhance the beneficiation process.

The proposed project aims to investigate alternative economic streams (such as battery storage

technology) for the mine.

In addition, the proposed location of the solar panels and battery storage, within the Vametco mine,

is located within an area that has been disturbed by mining activities, which has effectively limited the

environmental sensitivity of the site. The preferred technology to be used is based on the need and

desirability for renewable energy in South Africa, and the success of this technology that was

implemented and is operational in the USA.

Alternatives considered for this project are the site layout alternatives. The environmental assessment

is based on a 5ha area of which 3ha will be used for the solar panels and battery storage. Site layout

will be arranged within the 5ha boundary in a manner which avoids any sensitivities identified on site.

h) Full description of the process followed to reach the proposed preferred 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 issues raised by interested

and affected parties, and the consideration of alternatives to the initially proposed site layout.

i) Details of the development footprint alternatives considered. With reference to the site plan provided as Appendix C and the location of the individual

activities on site, provide details of the alternatives considered with respect to:

(a) the property on which or location where it is proposed to undertake the activity;

The proposed solar panels and battery storage project is located within the Bushveld Vametco Alloys

Mining right boundary. The proposed project does not have any project location alternatives as the

project is located within the Vametco Mining right boundary as a pilot project for the Mine and within

a safe distance from the mining activities in a disturbed area.

(b) the type of activity to be undertaken;

The type of activity to be undertaken for this project is the installation of PV solar panels with a

Vanadium Flow Redox Battery Storage. There are no activity alternatives considered for this project,

as this is a pilot project for determining the feasibility of renewable energy with battery storage within

South Africa.

(c) the design or layout of the activity;

The exact layout of the project infrastructure within the preferred site boundary will be determined

once the Engineering Procurement and Construction vendor has been appointed (should the

environmental application be successful). Alternatives considered for this project are within the 5ha

project site. The project has a footprint of only 3ha and will be located within the 5ha project site in

an area with less environmental sensitivities.

(d) the technology to be used in the activity; There are no alternative technologies considered for this project. Technologies considered/preferred

for this project have been chosen based on the proven success at the Maharishi University in the USA.

Bushveld Vametco has therefore proposed to pilot this technology in South Africa using Vametco

alloys as part of their pilot study.

(e) the operational aspects of the activity; and The proposed project will not require high maintenance during its operational phase. It is anticipated

that two people will be employed during the operational phase of the project for maintenance

purposes. Activities during the operational phase of the project will entail the dry cleaning and safe

keeping of the solar panels and battery storage. There are no environmental or human health impact

anticipated during the operational phase. No alternative operational aspects are available for this

project.

(f) the option of not implementing the activity.

The option of not implementing the activity, implies that the conservative approach would be

followed. This pilot project affords the opportunity to evaluate other technological options for energy

production within the South African market. Should the no‐go option be approved, Bushveld Vametco

would not be able to investigate alternative energy production options and as such would be a

negative step within the energy sector. Thus, the no‐go option is not considered feasible.

ii) 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.

A Newspaper advert will be placed on the Rustenburg Herald newspaper on the 21st August 2019

and will be erected on site on the 19th August 2019. The public review period is from the 19

August 2019 to the 18 September 2019 where the report has been made available to I&AP’s for

comment.

iii) Summary of issues raised by I&APs (Complete the table summarising comments and issues raised, and reaction to those responses)

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 REFENCE in this report where the issues and or response were incorporated

Affected Parties

Landowner/s

Lawful occupier/s of the land

Landowners or lawful occupiers on adjacent properties

Municipal councillor

Municipal

Organs of state (responsible for infrastructure that may be affected Roads Department, Eskom, Telkom, DWA

Communities

Dept. of Land Affairs

Traditional Leaders

Dept. Environmental Affairs

Other Competent Authorities affected

Other Affected Parties

Interested Parties

The Public review period of the Draft Basic Assessment Report and supporting documents has been made available from 19 August 2019 to 18

September 2019. Once the review period is completed, all comments received will be captured in the table above and will be submitted to the

competent authority in the Final BAR.

iv) The Environmental attributes associated with the alternatives. (The

environmental attributed described must include socio‐economic, social,

heritage, cultural, geographical, physical and biological aspects)

(1) Baseline Environment

The section below provides baseline information of the receiving environment in which the proposed

Bushveld project is to be established. The purpose of this section is to identify the current state of the

environment before any construction commences, and to identify sensitive issues/areas such as

heritage sites or protected ecological aspects, which needs to be considered when conducting the

impact assessment. The baseline information is acquired from desktop research and previous

environmental studies conducted within and around the proposed site with ground verification.

(a) Type of environment affected by the proposed activity.

(its current geographical, physical, biological, socio‐ economic, and cultural

character).

Geography

The project is located within the North West province of South Africa, approximately 7 Km south west

to Brits and 12km south east to Ga‐Rankuwa.

Topography

The proposed study area is characterised by slightly undulating plains as well as hills and lowlands.

The surface elevation ranges from 1185 mamsl in the south‐west perimeter to 1140 mamsl on the

north‐west perimeter of the site. The ground surface is gently sloping toward the Rosespruit which is

located on the north of the proposed study area (JMA Consulting, 2014).

Geology and soils

The study area lies under the Rustenburg layered suite. The geology underlying the proposed study

area is the Pyramid Gabbro‐norites as illustrated in Figure 6. The Rustenburg Layered Suite forms part

of the Bushveld Igneous Complex which intruded into and on top of the older Pretoria Group

lithologies.

The Bushveld Igneous Complex (BIC) is separated into 5 limbs across South Africa, namely: an Eastern

limb, a South‐Eastern/Bethal limb, a Northern/Potgietersrus limb, a Western limb and a Far Western

Limb. The study area falls within the Western Limb of the Bushveld Igneous Complex, which has

historically and is still currently being mined extensively for Chromium, Platinum as well as the

associated Platinum Group Elements (PGE’s). The Bushveld Igneous Complex is subdivided into a felsic

suite namely the Rooiberg Group and three mafic suites, namely the Lebowa Granite Suite, the

Rashoop Granophyre Suite and the Rustenburg Layered Suite (JMA Consulting, 2014).

The BIC is best known for its intimately interrelated mafic intrusive bodies and is the thickest and

most extensive structure of its kind in the world. Partial differentiation of the crystals from the

melt (due to the slow cooling of the magma) formed the indicative differentiated or layered

property of the BIC (JMA Consulting, 2014). Most of the mineralization in the Bushveld Igneous

Complex occurs within the Rustenburg Layered Suite. The Rustenburg Layered Suite is

economically the most important suite in the Bushveld Igneous Complex (JMA Consulting, 2014).

With regard to local geology, the proposed study area comprises of well‐developed, sandy clay layers.

The soil type dominating the study area is the Vertic A horizon soil type of the Acadia soil group (JMA

Consulting, 2014). Vertic soil forms are characterised by a high clay content and a predominance of

smectite minerals which swell and shrink in response to changes in their moisture content (JMA

Consulting, 2014).

Climate

During the summer, the daytime temperatures are in the upper twenties to early thirties but cool

slightly down during the evening to mid‐teens. Summer (mid‐October to mid‐February) is

characterised by hot, sunny weather often with afternoon thunderstorms of short duration (JMA

Consulting, 2014) In winter (May to July), daytime temperatures are in the mid‐teens to early twenties

dropping to single figures during the night. Frost occurs during winter but is not common. The rainfall

occurs mostly in summer – some 85% of the annual being recorded during this period. There is a

distinct seasonal variation in rainfall and the evaporation follows the same seasonal trend during the

year (JMA Consulting, 2014).

Vametco Alloys mine records rainfall on site. An average annual rainfall of 646 mm since 2001 has

been recorded. There are six South African Weather Service rainfall stations in close proximity to the

site, the closest station being the Magalieskraal. This station has indicated that the site experiences

slightly more rain than that recorded in other stations.

Land Use and Land Capability

The proposed project area is located within a larger cultivated land use environment and is located

within a mining land use associated with the Vametco Mining Right Boundary (Figure 7)

Figure 6: Site Geology Map

Figure 7:Land cover Map

Water resources

The proposed study area falls within the A21J quaternary catchment of the Crocodile (West) and

Marico Management Area of the Limpopo River primary catchment (Figure 8). The main water

resource within the catchment area is the Rosespruit river, which is one of the three tributaries of the

Crocodile River between the Hartbeespoort dam and the Roodekopies dam, draining the eastern

flank. The topography of the area is typical of the Bushveld with rather flat slopes and discrete

occurrences of mountainous areas (JMA Consulting, 2014).

Wetlands

During a wetland study undertaken as part of the Environmental Impact Assessment in 2014, three

wetland systems were identified within the north and northwest section of the larger Vametco Alloys

Mining Right Boundary. These systems were considered to be canalised in areas and the ecological

value of these wetlands in the northern section of the study area is considered to be of low biodiversity

significance (JMA Consulting, 2014). The wetland system that is located closest to the proposed

project site was considered to have no unique habitat and/or migratory connectivity for faunal

species. As indicated in Figure 9, a few wetland systems have been identified through desktop

assessment and use of the National Freshwater Ecosystem Priority Areas (NFEPA). However, based on

the high‐level ecological study undertaken for this project, no permanent wetlands have been

identified on site. Furthermore, the proposed project will have no impact on these wetland systems

identified within the larger mining area.

Figure 8: Water resources catchment map

Figure 9: NFEPA wetlands identified within the greater area

Groundwater

According to JMA Consulting (2014), the primary ground water occurrences within the study area are

in the joints and fractures occurring in the contact zones related to the heating and cooling of the

intrusive rocks as well as in fractures in the transitional zones between the weathered and un‐

weathered lithologies and adjacent to the dolerite and diabase intrusions. The major aquifer type

present in the study area is a shallow weathered zone aquifer occurring in weathered zones within

the granitic geological environment. The aquifer displays unconfined to semi‐unconfined conditions

(JMA Consulting, 2014). The mean annual recharge (MAR) to the ground water system for this the

major part of the study area is estimated to be between 37 mm and 50 mm per annum. The ground

water contribution to surface stream base flow is relatively low and is expected to be between 0 mm

and 10 mm per annum (JMA Consulting, 2014).

The proposed project will not impact the groundwater resources within the area.

Biodiversity

The proposed project site is located within the Savanna biome (Rutherford & Westfall, 1994) and is

situated within the Marikana Thornveld (Mucina & Rutherford, 2006) (Figure 10). This vegetation type

occurs in the North‐west and Gauteng Provinces. It occurs on plains from the Rustenburg area in the

west, through Marikana and Brits to the Pretoria area in the east. Altitude at which it typically occurs

ranges between 1050 to 1 450m (Mucina & Rutherford, 2006). Marikana Thornveld is thus listed as a

Vulnerable ecosystem (NEMBA Threatened Ecosystems, 2011).

Less than 1% is currently statutorily conserved in, for example, the Magaliesberg Nature Area and the

De Onderstepoort Nature Reserve. The vegetation type is considerably impacted, with 48% being

transformed, mainly as cultivated and urban or built‐up areas. Most agricultural development of this

unit is in the western regions towards Rustenburg, while in the east industrial development is the

greatest threat of land transformation. Erosion is very low to moderate. Alien invasive plants occur

localised in high densities, especially along the drainage lines (Mucina & Rutherford, 2006).

The ecological function and habitat integrity of the vegetation community is considered to be of

moderate to low importance, due to anthropogenic impacts such as dumping on site, grazing, mining

activities and bush encroachment by Vachellia karroo. Alien plant species encroachment is also

considered moderate, although in large sections towards the east of the study area, alien species such

as Flaveria bidentis occur in large stands.

Common grasses include Aristida congesta subsp. congesta, A. bipartita, Cynodon dactylon,

Dichanthium annulatum, Digitaria eriantha, Enneapogon cenchroides, Eragrostis sp., Fingerhuthia

africana, Heteropogon contortus, Ischaemum afrum, Melinis repens, Setaria sphacelata, S. verticillata,

Sporobolus nitens, Themeda triandra and Urochloa mossambicensis. Other species recorded in the

field layer include inter alia; Abutilon sp., Aloe transvaalensis, Corchorus asplenifolius, Drimiopsis

burkei subsp. burkei, Lantana rugulosa, Ledebouria cooperi, Solanum panduriforme and Zinnia

peruviana* (*denotes alien species).

According to Golder (2016) a study of aerial imagery suggests that an artificial earthen wall formed by

mine stockpiling has created the small depression, which receives water via sheet flow. Common

species recorded in the depression include Cyperus sp. Schoenoplectus sp., Ischaemum afrum,

Paspalum dilatatum and Paspalum distichum. A small stand of Phragmites australis reeds was also

recorded. Melia azedarach* (Syringa), Pennisetum setaceum* (Fountain Grass) and Xanthium

strumarium* were recorded in disturbed areas on‐site. The former two were mostly prevalent on

material stockpiles. All three are listed as a Category 1b alien invasive species, according to the NEMBA

Alien and Invasive Species Lists (2016).

Most of the site comprises a mixture of fine‐ and broad leaf trees, including Dichrostachys cinerea,

Diospyros lycioides subsp. lycioides, Vachellia nilotica, V. tortilis subsp. heteracantha and Ziziphus

mucronata. In localised pockets, Dichrostachys cinerea has formed dense monospecific thickets.

Woody species associated with rocky outcrops include inter alia, Combretum molle, Pappea capensis,

Sclerocarya birrea subsp. caffra and Vangueria infausta.

Based on the ecological opinion undertaken for the project site, it was identified that the project site

is dominated by short, open‐ to closed savanna Figure 11 and Figure 12), occurring on vertic clay soils.

Anthropogenic disturbances include gravel roads, powerlines and material stockpiles (Golder, 2019).

Notable features include small rocky outcrops (Figure 13) and a depression formed by stockpiling

activities (Figure 14) (Golder, 2019).

Figure 10: Vegetation Map

Figure 11: Densely wooded area of short savanna

Figure 12: Open area of short savanna

Figure 13: A small rocky outcrop in the Project site

Figure 14: Depression created by mine stockpiling activities

Heritage

The project falls within a well‐documented cultural landscape. Many Iron Age Sites around Brits to

Zeerust have been recorded previously (Berg, 1999:7‐8). The general project area was previously

inhabited by Tswana speaking communities from around AD1600. A section of the proposed project

site (see Figure 15 to Figure 18) yielded undecorated potsherds which were possibly exposed by

erosion. Most of the potsherds were not in their original positions, they were probably washed away

by erosion from their original place. Although visibility within the development site was compromised

by thick vegetation cover, the discoveries within the proposed development site provides an insight

of the potential of recovering similar findings during clearance and construction.

The affected landscape is heavily degraded from previous and current mining activities, and associated

infrastructure developments. This limits the chances of encountering significant in situ archaeological

sites to be preserved in situ. The area affected by the proposed development is broad and it was

assumed that there was always a chance of finding archaeological sites. However, the chances of

recovering significant archaeological materials were seriously compromised and limited due to

infrastructure developments and other destructive land use activities such as bulk water pipeline, road

works and powerlines that already exist on the project area. Two clusters of farm dwellings and

structures were recorded within the proposed development site. These were deemed to be younger

than 60 years and therefore do not trigger Section 34 of the NHRA.

Based on the field study results and field observations, the author concluded that the receiving

environment for the proposed development is medium to high potential to yield previously

unidentified archaeological sites during subsurface excavations and construction work, and therefore

the chance find procedure (CFP) as attached to the Heritage Study must be implemented on site.

Furthermore, the heritage practitioner concluded that the project may proceed, with the

implementation of the mitigation measures outlined and the CFP.

Figure 15: View of potsherds recorded within proposed development site

Figure 16: View of potsherds recorded within proposed development site

Figure 17: View of undecorated potsherds recorded within the proposed development site

Figure 18: View of undecorated potsherds recovered from the proposed development site

Socio‐economic

The Madibeng Local Municipality is known for its diversified economy: agriculture, mining,

manufacturing and tourism are the dominant sectors. The Madibeng Local Municipality is

predominantly a rural municipality stretching over 3812.48 km2 and accounts for approximately 21%

of the total area of Bojanala Platinum District area. In addition to limited urban development the

Madibeng consists of, 43 Villages and 9 000 farm portions with a total of 36 wards (IDP, 2016).

According to Stats SA (2011), Madibeng has a population size of approximately 447 381, with an

average annual growth rate of 3.17%. The male population is approximately 53%, slightly higher than

that of the female population which is 47%. The highest population group is within ages 15‐65 years.

The level of education is low with only 27.60% of the population having higher education and 7.8

having no education at all. The Municipality is further characterized by low level of income, with 50.6%

of the population earning below R800.00 per month. Unemployment is high at 30.4% of which youth

unemployment (15‐34) accounts for 38.2% (IDP, 2016).

(b) Description of the current land uses The proposed project area is located in an area that is currently used for mining and associated

activities.

(c) Description of specific environmental features and infrastructure on the site. Specific environmental features are the identified rocky outcrop and infrastructure on site includes

the Vametco Alloys mine, a 6.6 kv Vametco powerline, a water pipeline, overburden and topsoil

stockpiles and a mini substation.

(d) Environmental and current land use map.

Please refer to Figure 7 for a land cover map.

v) Impacts and risks identified including the nature, significance, consequence, extent,

duration and probability of the impacts, including the 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).

Potential impacts resulting from the proposed project are grouped into different phases as seen

below.

Construction

The construction phase of the project will include vegetation removal/ land clearance for the

installation of the solar panels and battery storage. Environmental impacts anticipated throughout the

construction phase are identified as follows:

Potential increase in ambient dust levels;

Habitat loss and impact on biodiversity;

Potential increase in ambient noise levels;

Possible contamination of ground and surface water;

Possible soil contamination;

Potential loss of heritage and cultural aspects;

Positive impact on job creation; and

Potential negative impact due to social unrest.

Operation

Positive impact on job creation (albeit minimal);

Potential impact on fauna; and

Potential visual disturbances.

Decommission

Potential increase in ambient dust levels;

Potential impact on noise generation;

Positive impact on job creation; and

Potential waste generation.

Table 2: Impact Assessment Significance Rating

Environmental Aspect

Phase Nature of potential impact/risk Environmental Impact Significance Before Mitigation

Impact Management Actions (Proposed Mitigation Measures)

Environmental Impact Significance After Mitigation

Severity Occurrence Severity Occurrence

Mag

nitu

de

Sca

le

Dur

atio

n

Pro

babi

lity

Sig

nific

ance

Sig

nific

ance

ra

ting

Mag

nitu

de

Sca

le

Dur

atio

n

Pro

babi

lity

Sig

nific

ance

Sig

nific

ance

ra

ting

Air Quality Construction and

decommissioning Possible increase in dust generation,

PM10 and PM2.5 as a result of land clearance, operation of heavy machinery, and material movement.

Increase in carbon emissions and ambient air pollutants (NO2 and SO2) as a result of movement of vehicles and operation of machinery/equipment.

8 2 1 4 44

Moderate

Dust suppression on haul and dirt roads within the project footprint;

Water regularly (with water trucks) or the use of an alternative binding agent to ensure effective dust suppression in areas where materials removal placement or manipulation is occurring;

Restrict traffic to designated roads and minimise unnecessary traffic;

Dust generating materials transported on public roads must be covered;

Enforce speed limits on site;

Regular inspections and maintenance on all vehicles to ensure the functioning of the exhaust systems to reduce excessive emissions and limit air pollution;

Limit site clearance to areas identified for construction as per construction schedule;

Where practical, rehabilitation should be undertaken progressively; and

Vegetate and stabilise exposed areas.

6 2 1 3 27

Low

Biodiversity Construction Loss of habitat and ecological structure as a result of site clearance activities.

Potential spreading of alien invasive species as indigenous vegetation is removed, and pioneer alien species are provided with a chance to flourish.

Habitat fragmentation as a result of construction activities of the access roads leading to loss of floral diversity; and

Movement of construction vehicles and machinery may result in collision with fauna, resulting in loss of fauna.

8 1 5 3 42

Moderate

Land clearance to be limited to the location of the solar panels so that the proposed development footprint can be kept to a minimum;

Movement of vehicles will be restricted to designated areas to limit impact on vegetation;

Use of existing access roads should be promoted;

Any species of conservation concern that may be encountered during land clearance should be handled with care as instructed by the Environmental Officer on site;

Alien vegetation encroachment must be controlled within project footprint and within vicinity areas;

Site should be re‐vegetated with indigenous vegetation and rehabilitated to its near natural state as far as possible after construction where practical; and

No informal fires shall be permitted in the vicinity of construction areas.

6 1 4 2 13

Low

Heritage Construction The proposed project has the potential to impact on sites of archaeological importance.

8 1 1 4 40

Moderate Cease all work in immediate vicinity of a find an

notify the EO on site; 4 1 1 2 12

Low

Noise Construction and

decommissioning The use of vehicles and machinery

during the construction phase may generate noise in the immediate vicinity.

6 2 1 3 27

Low

Noise generating activities must be limited to

normal working hours as per the mine’s current

activities;

Construction machines/vehicles should be switched off when not in operation, no machine /vehicles should be left idling;

Vehicles and operating machines should be inspected and maintained regularly;

Install suitable mufflers on engine exhausts and compressor components to reduce noise; and

Surrounding communities must be informed of any noisy activities that will be taking place adjacent to them 24 hours in advance.

4 1 1 2 12

Low

Ground and surface

water

Construction Localised spillages of hydrocarbons from machinery leading to groundwater contamination;

Increase of surface runoff and potentially contaminated water.

8 2 1 3 33

Moderate

No washing or servicing of vehicles should be allowed on site;

Refuelling of vehicles will only be allowed in designated areas;

All construction equipment shall be parked in a demarcated area and shall be equipped with drip trays while parked;

Bulk storage of hydrocarbons must be situated in a dedicated area which will include a bund or a drain, where necessary, to contain any spillages during the use, loading and off‐loading of the material;

Bund areas must be impermeable;

Spill kits shall always be available and utilised for the cleaning of spills on site;

6 1 1 2 16

Low

Soil Construction Localised clearing of vegetation and compaction of the construction footprint will result in the soils being particularly more vulnerable to soil erosion; and

Localised loss of soil and land capability due to reduction in nutrient status ‐ de‐nitrification and leaching due to stripping footprint areas.

8 2 1 3 33

Moderate

All spill incidences should be reported to the ECO immediately and soil contamination should be cleaned and handled accordingly;

Potentially contaminating wastes will be stored in bunded areas until removed by a reputable contractor for disposal at an appropriately licensed facility.

6 1 1 2 16

Low

Social Construction and

decommissioning Influx of job seekers will have a

negative social impact on the landowners and land occupiers.

8 2 1 4 44

Moderate Recruitment practises will favour locals, people

with the skills and qualifications should be

preferred for jobs (where feasible); and

the recruitment of labourers should be well

advertised and documented to ensure a

transparent process.

6 2 1 3 27

Low

Social Construction and

decommissioning Potential job creation for locals

6 2 1 4 36

Positive

Recruitment practises will favour locals, people

with the skills and qualifications should be

preferred for jobs (where feasible); and

the recruitment of labourers should be well

advertised and documented to ensure a

transparent process.

8 2 1 4 44

Positive

Visual Operation Potential reflective light impact from the solar panels;

8 2 5 2 30

Mod

erat

e

The location of the site has limited visibility to visual receptors;

Lighting will meet operational requirements without causing excessive illumination;

Night lighting will be directed inwards, downwards and away from local residential communities; and

Up‐lighting of structures will be avoided.

6 1 5 2 24

Low

Waste Decommissioning

Potential environmental pollution as a

result of inappropriate waste management practices with decommissioned structures.

6 1 1 3 24

Low

Waste separation practices should be enforced. Any hazardous waste generated on site should be separated from general waste and should be managed and stored accordingly;

A reputable waste management company should be appointed to handle waste on site;

No littering shall be allowed in and around the site.

4 1 1 2 12

Low

vi) 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).

Methodology for assessing impacts

The significance of the identified impacts will be determined using the approach outlined below

(terminology from the Department of Environmental Affairs Guideline document on EIA Regulations,

April 1998). This approach incorporates two aspects for assessing the potential significance of impacts,

namely occurrence and severity, which are further sub‐divided as follows:

Occurrence Severity

Probability of

occurrence

Duration of

occurrence

Scale/extent of impact Magnitude (severity)

of impact

To assess each of these factors for each impact, the following four ranking scales are used:

Magnitude Duration

10 ‐ Very high/don’t know 5 ‐ Permanent

8 ‐ High 4 ‐ Long‐term (longer than 10 years, with impact ceasing after closure of the project)

6 ‐ Moderate 3 ‐ Medium‐term (4‐10 years)

4 ‐ Low 2 ‐ Short‐term (1‐3 years)

2 ‐ Minor 1 – Immediate (less than a year)

Scale Probability

5 ‐ International 5 ‐ Definite/don’t know

4 ‐ National 4 ‐ Highly probable

3 ‐ Regional 3 ‐ Medium probability

2 ‐ Local 2 ‐ Low probability

1 ‐ Site only 1 ‐ Improbable

Once these factors are ranked for each impact, the significance of the two aspects, occurrence and

severity, is assessed using the following formula:

SP (significance points) = (magnitude + duration + scale) x probability

The maximum value is 100 significance points (SP). The impact significance will then be rated as

follows:

SP >75 Indicates high

environmental significance

An impact which could influence the decision about

whether or not to proceed with the project regardless

of any possible mitigation.

SP 30 – 75 Indicates moderate


An impact or benefit which is sufficiently important to

require management and which could have an

influence on the decision unless it is mitigated.

SP <30 Indicates low


Impacts with little real effect and which should not

have an influence on or require modification of the

project design.

+ Positive impact An impact that is likely to result in positive

consequences/effects.

For the methodology outlined above, the following definitions were used:

Magnitude is a measure of the degree of change in a measurement or analysis (e.g., the area

of pasture, or the concentration of a metal in water compared to the water quality guideline

value for the metal), and is classified as none/negligible, low, moderate or high. The

categorization of the impact magnitude may be based on a set of criteria (e.g. health risk

levels, ecological concepts and/or professional judgment) pertinent to each of the discipline

areas and key questions analysed. The specialist study must attempt to quantify the

magnitude and outline the rationale used. Appropriate, widely‐recognised standards are to

be used as a measure of the level of impact.

Scale/Geographic extent refers to the area that could be affected by the impact and is

classified as site, local, regional, national, or international.

Duration refers to the length of time over which an environmental impact may occur i.e.

immediate/transient, short‐term (1 to 3 years), medium term (4 to 10 years), long‐term

(greater than 10 years with impact ceasing after closure of the project), or permanent.

Probability of occurrence is a description of the probability of the impact actually occurring as

improbable (less than 5% chance), low probability (5% to 40% chance), medium probability (40%

to 60% chance), highly probable (most likely, 60% to 90% chance) or definite (impact will definitely

occur).

vii) The positive and negative impacts that the proposed activity (in terms of the initial site

layout) and alternatives will have on the environment and the community that may be

affected.

(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)

The proposed project will have moderate to low impact (before mitigation) on the current

environment. Negative impacts associated with the project have been listed in section (v) above.

Majority of these impacts are expected during the construction phase with some ceasing with

construction. However, the overall proposed project is anticipated to have minimal negative

impact on the environment with the application of mitigation measures.

A positive impact identified includes the creation of jobs mainly during the construction phase of

the project. The construction and implementation of the solar panels and battery storage also

have a positive impact towards the energy sector of South Africa, as it will provide insight on the

possible ways of renewable energy through this pilot study.

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

(With regard to the issues and concerns raised by affected parties provide a list of the issues raised

and an assessment/ discussion of the mitigations or site layout alternatives available to

accommodate or address their concerns, together with an assessment of the impacts or risks

associated with the mitigation or alternatives considered).

Please refer to Section v for the management and mitigation measures.

ix) Motivation where no alternative sites were considered As discussed previously, the preferred site is located within the Vametco Alloys Mining Right

Boundary. The proposed solar panels and battery storage system will supply power to the Vametco

mine, hence the preferred location. Site layout alternatives will be considered based on the site

conditions within the 5ha project boundary to ensure minimal impact on sensitivities within the

environment.

x) Statement motivating the alternative development location within the overall site.

(Provide a statement motivating the final site layout that is proposed) The final site layout will be located within the proposed 5Ha project footprint. Based on the ecological

and the heritage study, the exact location of the proposed project will be located away from all

identified sensitive areas, refer to Figure 19.

Figure 19: Sensitive areas identified within the Study Area

xi) 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 the activity.

(Including (i) a description of all environmental issues and risks that were identified during the

environmental impact assessment process and (ii) an assessment of the significance of each

issue and risk and an indication of the extent to which the issue and risk could be avoided or

addressed by the adoption of mitigation measures.)

Potential impacts associated with the proposed project were identified through the following process:

Desktop assessment: previous studies undertaken within the study area, google imagery,

spatial development plans and title deeds where amongst other resources used during the

desktop assessment process. Desktop study was undertaken to determine the environmental

setting in which the project is located.

A site visit to the proposed project area was undertaken to identify any on the ground

potential impacts that may result due the proposed project.

Stakeholder engagement process undertaken, once this process is completed all comments

and issues raised will be captured and incorporated into the final Basic Assessment Report.

The rating of the identified impacts was undertaken in a quantitative manner as provided in

Section v (impact rating). The ratings were undertaken in a manner to calculate the significance

of each of the impacts. The identification of management and mitigation measures was done

based on the significance of the impacts and measures included are considered sufficient,

appropriate and practical to protect the environment.

xii) 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).

ACTIVITY Whether listed or not listed. (E.g. Excavations, blasting, stockpiles, discard dumps or dams, loading, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyers, etc...etc...etc.)

POTENTIAL IMPACT (E.g. dusts, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc...etc.)

ASPECTS AFFECTED

PHASE In which impact is anticipated. (E.g. Construction, commissioning, operational, decommissioning, closure, post‐closure.)

SIGNIFINCANCE If not mitigated

MITIGATION TYPE (modify, remedy, control, or stop) Through (e.g. noise control measures, stormwater control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc...etc. E.g. Modify through alternative method. Control through noise control. Control through management and monitoring through rehabilitation....

SIGNIFICANCE If mitigated

REFER TO Table 2 ABOVE

k) 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

SPECIALITST RECOMMENDATIONS THAT HAVE BEEN INCLUDED IN THE EIA REPORT (Mark with

REFERENCE TO APPLICABLE SECTION OF REPORT WHERE SPECIALITS RECOMMENDATIONS HAVE BEEN INCLUDED

Ecological Assessment Table 2

Heritage Impact Assessment Table 2

Attach copies of Specialist Reports as appendices. Please refer to Appendix D and E, respectively.

l. Environmental impact statement (i) Summary of the key findings of the environmental impact assessment

Based on the environmental impact assessment undertaken for this project, the following key

findings were identified:

The proposed project is located within an area currently used for mining that is already disturbed

and will therefore have minimal impacts on the current environmental setting. Potential impacts

identified during the impact assessment include impacts on:

air quality,

biodiversity

cultural heritage and archaeological sites,

noise,

surface water;

groundwater;

soil; and

Visual.

The majority of these impacts will cease with construction. The impacts will be localised, short

term and will have a moderate or low significance (before mitigation). The potential

environmental impacts can be reduced to a low significance with implementation of mitigation

and monitoring.

The construction phase is anticipated to run for three months with approximately 20 people

employed during this phase. It is expected that only two or three employees will be employed

during the operational phase to run the day to day maintenance of the solar panels.

Since the proposed project is located within an already established mining area, the existing

mining equipment and infrastructure will be used were needed.

(ii) 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 Figure 1 for a locality map representing the site map. A final site layout map will be

developed once an EPC vendor has been chosen. Figure 4 and Figure 5 provides an illustration of a

concept layout.

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

It is anticipated that the proposed project will have minimal impacts on the environment. The

potential impacts as discusses above are of medium to low significance without mitigation measures

and of low significance with mitigation measures. The majority of these impacts will cease with

construction which is expected to last for a period of three months. This project is a small‐scale project

covering an area of 5ha with a development footprint only covering 3ha. Negative and positive impacts

identified include:

Potential impact on ambient air quality resulting from dust fallout due to vehicle movement

and vegetation clearance;

Potential biodiversity loss due to vegetation clearance for the construction and establishment

of the solar panels and battery storage;

Potential impact on cultural heritage and/or archaeological sites as a result of land clearance

and construction activities;

Potential increase in ambient noise levels resulting from transportation vehicles and

construction activities;

Potential impact on the local watercourses due to hydrocarbon spills from vehicles and

construction equipment;

Potential soil contamination due to hydrocarbon spills from vehicles and construction

equipment;

Social unrest and influx of job seekers to site may result in increased opportunistic crimes;

Possible job creation for a few locals during construction and operation.

Potential visual impacts as a results of PV solar panels.

m) Proposed impact management objectives and the impact management outcomes of

inclusion in the EMPr.

(Based on the assessment and where applicable the recommendations from specialist reports, the

the development for inclusion in the EMPr as well as for inclusion as conditions of authorization.)

An Environmental Management Program (EMPr) is a living document that can be updated and

reviewed as needed. This document is regarded as a guide to effectively manage unavoidable

impacts, with the aim of sustaining the environmental integrity. Therefore, the objectives of the

EMPr will be to:

Provide sufficient information on the project background and project outcomes;

Identify and provide mitigation measures for all potential impacts;

Ensure that mitigation measures are implemented throughout the project life cycle;

To ensure that the environment is protected and sustained; and

Provide a management plan that is effective and practical for implementation.

n). Aspects for inclusion as conditions of Authorization

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

The EMPR is a legally binding document and must be complied with.

An Environmental Control Officer should be appointed.

A community liaison officer should be appointed to ensure community concerns are

addressed.

Should any protected trees be required to be removed or trimmed, the necessary permits

must be obtained.

o) Description of any assumptions, uncertainties and gaps in knowledge

(Which relate to the assessment and mitigation measures proposed)

The following assumptions, uncertainties and gaps in knowledge have been identified;

Literature review for similar project is limited in South Africa;

There is no detailed final site layout available for this project due to the nature of the

project and the assumption that Vametco Mine infrastructure will be used as far as

possible.

p) Reasoned opinion as to whether the proposed activity should or should not be authorized

i) Reasons why the activity should be authorized or not.

The proposed project should be authorised as the impacts emanating from the project can be

effectively mitigated to acceptable levels. This pilot project will determine whether a Solar PV

hybrid battery storage facility is viable within the South African market. Should it be feasible, the

energy sector within the country would greatly benefit.

ii)Conditions that must be included in the authorization

Please refer to section (n) above.

q) Period for which the Environmental Authorization is required

The environmental authorization is required for the duration of 30 years.

r) 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.)

The undertaking by the EAP has been provided at the end of the EMPr and is applicable to both

the BAR and the EMPr.

s) Financial Provision

(State the amount that is required to both manage and rehabilitate the environment in respect or

rehabilitation.)

The proposed project is not a mining project and therefore, the financial provision for rehabilitation

not applicable, however approximately R 5.3 million will be required at decommissioning and closure

of the solar plant and for rehabilitation of the associated footprint area Table 3. Allowance of the

R5.3 million will be made available and incorporated into the mine’s existing site‐wide closure

costing, as part of the required annual revision, for submission to the Department of Mineral

Resources (DMR) for approval. The cost will also be incorporated into Vametco’s site‐wide closure

costs.

(i) Explain how the aforesaid amount was derived

The scheduled closure costs reflected in Table 3 and Appendix F are structured in the format that is

routinely used for the presentation of the closure costs for mine sites by reflecting the costs in terms

of the following categories:

Infrastructural areas;

General surface reclamation;

Pre‐site relinquishment monitoring and aftercare; and

Additional allowances.

The cost estimate quantities were taken from available plans and maps supplied by Bushveld

Vametco. Unit rates were obtained from Golder Associates’ data base and/or in consultation with

demolition practitioners.

(ii) 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).

It is confirmed that the amount will be provided for and will form part of the mine’s operating

expenditure.

t) Specific Information required by the competent Authority

(i) Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of

the National Environmental Management Act (Act 107 of 1998). The EIA report must include the:‐

(1) Impact on the socio‐economic conditions of any directly affected person.

(Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling 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 socio‐economic conditions of any directly affected person will not be affected by the proposed

project. Impacts considered will include job creation as a result of the erection of the solar panels and

battery storage. However, this may come with negative impacts within the community due to

competition for jobs that may lead to social unrest.

(2) 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 the mining, bulk

sampling or alluvial diamond prospecting on any national estate 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 the 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).

None identified.

u) Other matters required in terms of sections 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 4).

Refer to section h above.

PART B

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1 Draft environmental management programme.

a) Details of the EAP

(Confirm that the requirement for the provision of the details and expertise of the EAP are

already included in PART A, section 1(a) herein as required).

Details of the EAP are included in Part A Section 1 (a)

b) Description of the Aspects of the Activity

(Confirm that the requirement to describe the aspects of the activity that are covered by the

draft environmental management programme is already included in PART A, section (1) (h)

herein as required).

The EAP hereby confirms that the requirement to describe the aspects of the activity that are

covered by the draft environmental programme is already included in PART A, section (1) (h).

c) Composite Map

(Provide a map (Attached as an Appendix) at an appropriate scale which superimposes the

proposed activity, its associated structures, and infrastructure on the environmental sensitivities

of the preferred site, indicating any areas that should be avoided, including buffers)

Please refer to Figure 19 and Appendix h for a composite sensitivity map.

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 objective of the proposed project is to rehabilitate the site and reinstate it to the

land use determined for the overall Vametco Mine site as per the Bushveld Vametco Closure

Cost Report attached as Appendix F mine’s closure plan.

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

The operation of the solar panels and the battery storage will make use of dry cleaning and therefore,

no water will be required.

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

A water use license is not required for this project.

(iv) Impacts to be mitigated in their respective phases

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

ACTIVITY Whether listed or not listed. (E.g. Excavations, blasting, stockpiles, discard dumps or dams, loading, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyers, etc...etc...etc.)

PHASE of operation in which activity will take place. State: Planning and design, Preconstruction, Construction, Operational, rehabilitation, Closure, Post closure

SIZE AND SCASLE of disturbance (volumes, tonnages and hectares or m2 )

MITIGATION MEASURES (describe how each of the recommendations herein will remedy the cause of pollution or degradation and migration of pollutants)

COMPLIANCE WITH STANDARDS (A description of how each of the recommendations herein will comply with any prescribed environmental management standards or practices that have been identified by Competent Authorities)

TIME PERIOD FOR IMPLEMENTATION Describe the time period when the measures in the environmental management programme must be implemented. Measures must be implemented when required. With regard to Rehabilitation specifically this must take place at the earliest opportunity. With regard to Rehabilitation therefore state either: ‐ Upon cessation of the individual activity Or Upon the cessation of mining, bulk sampling or alluvial diamond prospecting as the case may be

STANDARDS TO BE ACHIEVED (Impact avoided, noise levels, dust levels, rehabilitation standards, end use objectives etc.)

Land clearing causing increase in ambient dust levels

Construction 3ha Dust suppression on haul and dirt roads within the project footprint;

Water regularly (with water trucks) or the use of an alternative binding agent to ensure effective dust suppression in areas where materials removal placement or manipulation is occurring;

Restrict traffic to designated roads and minimise unnecessary traffic;

Dust generating materials transported on public roads must be covered;

Enforce speed limits on site;

Regular inspections and maintenance on all vehicles to ensure the functioning of the exhaust systems to reduce excessive emissions and limit air pollution;

Limit site clearance to areas identified for construction as per construction schedule;

Where practical, rehabilitation should be undertaken progressively; and

Vegetate and stabilise exposed areas.

All recommendations within this document will comply with applicable NEMA: AQA 39 of 2004 Vametco environmental policies will be applicable to this project.

The recommended mitigation measures should be implemented upon commencement of each activity and throughout the life cycle of the activity.

No air pollution complaints; and Compliance to Ambient Air Quality Standards

Land clearing activities causing loss of biodiversity

Construction 3ha Land clearance to be limited to the location of the solar panels so that the proposed development footprint can be kept to a minimum;

Movement of vehicles will be restricted to designated areas to limit impact on vegetation;

Use of existing access roads should be promoted;

Any species of conservation concern that may be encountered during land clearance should be handled with care as instructed by the Environmental Officer on site;

All recommendations within this document will comply with applicable NEMA and DMR regulations. Vametco environmental policies will be applicable to this project.


Minimal biodiversity loss; and No faunal mortalities within project area.

Alien vegetation encroachment must be controlled within project footprint and within vicinity areas;

Site should be re‐vegetated with indigenous vegetation and rehabilitated to its near natural state as far as possible after construction where practical; and

No informal fires shall be permitted in the vicinity of construction areas.

Land clearing impacting on potential archaeological signatures

Construction 3ha Cease all work in immediate vicinity of a find an notify the EO on site;

compliance with SAHRA


Handling of chance finds in accordance with the requirements of the National Heritage Resources Act, Act 25 of 1999

Transportation and heavy machinery increase ambient noise levels

Construction ‐ Noise generating activities must be limited to normal

working hours as per the mine’s current activities;

Construction machines/vehicles should be switched off when not in operation, no machine /vehicles should be left idling;

Vehicles and operating machines should be inspected and maintained regularly;

Install suitable mufflers on engine exhausts and compressor components to reduce noise; and

Surrounding communities must be informed of any noisy activities that will be taking place adjacent to them 24 hours in advance.



Compliance with the national noise limits within a mining area; No complaints received as result of noise generated from the site

Hydrocarbon spillages from Construction vehicles leading to ground and surface water contamination

Construction 5ha No washing or servicing of vehicles should be allowed on site;

Refuelling of vehicles will only be allowed in designated areas;

All construction equipment shall be parked in a demarcated area and shall be equipped with drip trays while parked;

Bulk storage of hydrocarbons must be situated in a dedicated area which will include a bund or a drain, where necessary, to contain any spillages during the use, loading and off‐loading of the material;

Bund areas must be impermeable;

Spill kits shall always be available and utilised for the cleaning of spills on site;



No uncontained spillages resulting in surface water contamination Hydrocarbon management in accordance with the Vametco operational procedures

Hydrocarbon spillages from Construction vehicles leading to soil contamination

Construction 5ha All spill incidences should be reported to the ECO immediately and soil contamination should be cleaned and handled accordingly;

Potentially contaminating wastes will be stored in

bunded areas until removed by a reputable contractor for

disposal at an appropriately licensed facility.



Hydrocarbon management in accordance with the Vametco operational procedures

Social unrest Construction Recruitment practises will favour locals, people with the

skills and qualifications should be preferred for jobs

(where feasible); and

‐ The recommended mitigation measures should be implemented upon commencement of each

No incidences of project induced social conflict recorded;

the recruitment of labourers should be well advertised

and documented to ensure a transparent process.

activity and throughout the life cycle of the activity.

Visual intrusion created by the solar PV panels

Operation The location of the site has limited visibility to visual receptors;

Lighting will meet operational requirements without causing excessive illumination;

Night lighting will be directed inwards, downwards and away from local residential communities; and

Up‐lighting of structures will be avoided.



No complaints regarding the reflective potential of the solar panels

Waste generation Decommissioning 5ha Waste separation practices should be enforced. Any hazardous waste generated on site should be separated from general waste and should be managed and stored accordingly;

A reputable waste management company should be appointed to handle waste on site;

No littering shall be allowed in and around the site.



Management of waste in accordance with the Vametco operational procedures. Compliance with the National Environmental Waste Act, Act 59 of 2008

e) Impact Management Outcomes (A description of impact management outcomes, identifying the standard of impact management required for the

aspects contemplated in paragraph ()

ACTIVITY Whether listed or not listed. (E.g. Excavations, blasting, stockpiles, discard dumps or dams, loading, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyers, etc... etc.... etc.).

POTENTIAL IMPACT (E.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc... etc... etc

ASPECTS AFFECTED

PHASE In which impact is anticipated (e.g. Construction, commissioning, operational, decommissioning, closure, post‐closure)

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 Controlling through management and

monitoring Remedy through rehabilitation.

STANDARDS TO BE ACHIEVED (Impact avoided, noise levels, dust levels, rehabilitation standards, end use objectives etc.)

REFER TO SECTION d above

i) Financial Provision

(1) Determination of the amount of Financial Provision

(a) Describe the closure objectives and the extent to which they have been aligned to the

baseline environment described under the Regulation.

Based on the current state of the environment, the proposed project will not have significant impacts

on the condition of the environment. Therefore, the closure objective of the proposed project will tie

into the overall Vametco mine closure objective. It is, however, an aim of Bushveld Vametco to

reinstate the proposed area to the land use identified in the overall Vametco Mine Closure Plan.

(b) Confirm specifically that the environmental objectives in relation to closure have been

consulted with landowner and interested and affected parties

The draft BAR and EMPr will be made available to all registered I&APs for review and comments for a

period of 30 days. All comments received and responses provided to the stakeholders will be

incorporated into the final BAR and EMPr and will be collated into a Comments and Responses Report

(CRR).

(c) 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

The rehabilitation plan of the proposed project will be aligned with the overall Bushveld Vametco

Alloys Mine rehabilitation plan as the project is located within the mining right boundary.

Rehabilitation of the proposed project will include the following activities:

The dismantling of the PV solar panels, battery storage and all metals structures within the

project footprint;

Re‐vegetation of all exposed areas on the project footprint with locally indigenous species;

and

If deemed necessary, post‐closure monitoring of the environmental performance against the

EMPr and other permitting conditions.

(d) Explain why it can be confirmed that the rehabilitation plan is compatible with the

closure objectives

As discussed previously, impacts that will result from the proposed project are limited to the project

footprint and are of short duration, mainly occurring during the construction phase. Where possible,

rehabilitation will run concurrently with other phases. The rehabilitation plan will be put in place in

order to yield the closure objectives, which will align with the Mine’s plans.

(e) Calculate and state the quantum of the financial provision required to manage and

rehabilitate the environment in accordance with the applicable guideline

The closure costs for the Bushveld Vametco solar plant for the planned closure situation, as reflected

in Appendix F, amount to R 5.3 million. Table 3 summarises the costs at August 2019.

Table 3: Scheduled closure costs

18113653 Bushveld Energy Closure Costs, as at August 2019

Closure components Scheduled Closure (2049)

1 Infrastructural aspects R 4 293 926,65

2 General surface rehabilitation R 10 846,96

3 Reinstatement of drainage lines R ‐

Sub‐Total 1 R 4 304 773,62

5 Post‐Closure Aspects

5.1 Surface water monitoring R ‐

5.2 Groundwater monitoring R ‐

5.3 Rehabilitation monitoring R 891,98

5.4 Care and maintenance R 4 927,20

Sub‐Total 2 R 5 819,18

4 Additional Allowances

4.1 Preliminary and general R 516 572,83

4.2 Contingencies R 430 477,36

4.3 Additional studies R ‐

Sub‐Total 3 R 947 050,20

Grand Total

Excl. VAT. (Sub‐total 1 +2 +3) R 5 257 642,99

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

It is confirmed that the financial provision will be provided for as determined.

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

including

g) Monitoring of Impact Management Actions

h) Monitoring and reporting frequency

i) Responsible persons

j) Time period for implementing impact management actions

k) Mechanism for monitoring compliance

SOURCE ACTIVITY IMPACTS REQUIRING MONITORING PROGRAMMES

FUNCTIONAL REQUIREMENTS FOR MONITORING

ROLES AND RESPONSIBILITIES (FOR THE EXECUTION OF THE MONITORING PROGRAMMES)

MONITORING AND REPORTING FREQUENCY and TIME PEROIDS FOR IMPLEMENTING IMPACT MANAGEMENT ACTIONS.

Land clearing Increase in ambient dust levels Dust suppression should be done as and when required; and

Environmental Control officer (ECO)

Continuous

Land clearing Biodiversity loss Alien invasive species encroachment

Monitor the extent of vegetation lost; Monitor the extent of alien vegetation encroachment; Implement plans for alien invasive species eradication;

ECO Monthly

Land clearing Destruction of archaeological sites

No activities should take place in areas of archaeological importance Should any chance finds be unearthed, the ECO must be notified.

ECO Continuous

Transportation Noise pollution Ensure that activities keep to the recommended operational hours;

Site manager Continuous

Transportation Soil contamination

Monitor and inspect soil contamination (in the event of an incident); Inspect vehicles and equipment for possible leakages; Ensure proper rehabilitation measures are adhered to in order to return the soil quality to its previous state.

ECO Continuous

Transportation Watercourses contamination Monitor and inspect spill contamination; Inspect vehicles and equipment for possible leakages;

ECO and site manager Continuous

Installation of PV solar panels and battery storage

Reflective impacts from solar panels

Monitor and respond to complaints received about the reflective impact form the solar panels during this pilot study.

Site manager Continuous

Waste Waste management Maintain a waste manifest book to record volumes of waste leaving the site, including recyclables. Keep safe disposal certificates on file on site for Hazardous waste. Way Bridge slips must be obtained for all waste streams and kept on file on site.

ECO Continuous

l) Indicate the frequency of the submission of the performance assessment / environmental

audit report

N/A

m) Environmental awareness plan

(1) Manner in which the applicant intends to inform his or her employees of any

environmental risk which may result from their work

Employees on site will be notified of environmental risks through the following processes:

Induction – staff will be inducted prior to commencement of any work. Visitors will also be

inducted upon arrival to site. Induction procedures already implemented at the Vametco

mine will be utilised.

Environmental awareness: environmental awareness will be offered to staff as and when

required based on the environmental risks and incidents identified within the site and

surrounds.

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

of the environment.

As discussed above, employees will be informed of the possible risks which may result from their work,

and employees will be informed of best possible ways to avoid environmental risks from occurring.

Induction and environmental awareness undertaken will address all possible consequences of the

environmental risk and mitigation measures to be implemented in order to address the risks. This

EMPr will be used as a guide on site to avoid or reduce the impacts that may result from possible risks.

(n) Specific information required by the Competent Authority (Among others, confirm that

the financial provision will be reviewed annually)

None

2) 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; and

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.

REFERENCES

Golder Associates (2019). Ecological Opinion of the Proposed Bushveld Vametco Project Site.

Technical report.

JMA (2014). EVRAZ Vametco EIA Scoping Report & Plan of Study. Draft for I&AP Review. Volume 1 of

2.

JMA (2018) Closure Cost Report. Version 1. DMR Reference: NW30/5/1/2/3/2/1/08 EM

Local Municipality of Madibeng (2016). Draft IDP Review 2015/2016.

Mucina, L. and Rutherford, M. (2006) The Vegetation of South Africa, Lesotho and Swaziland.

NEMBA Alien and Invasive Species Lists National Environmental Management: Biodiversity Act (Act

No. 10 of 2004) ‐ Alien and invasive species lists. (2016). South Africa.

NEMBA Threatened Ecosystems National Environmental Management: Biodiversity Act (Act No. 10

of 2004) ‐ National list of threatened terrestrial ecosystems for South Africa (2011). South Africa.

SANBI (2017) Red List of South African Plants, South African National Biodiversity Institute. Available

from: http://redlist.sanbi.org/ [Accessed 2 January 2018].

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