Proposed establishment of a quarry in the Ngquza Hill ...slrconsulting.com/media/files/documents/Main-Report.pdf · Proposed establishment of a quarry in the Ngquza Hill Local Municipality,

Proposed establishment of a quarry in the Ngquza Hill Local

Municipality, Eastern Cape

Final Environmental Impact Report and

Environmental Management Programme Report

SLR Project No.: 723.19083.00003

Report No.: 5

April 2017

South African National Roads Agency SOC Ltd

Proposed establishment of a quarry in the Ngquza Hill Local

Municipality, Eastern Cape

Final Environmental Impact Report and

Environmental Management Programme Report

SLR Project No.: 723.19083.00003

Report No.: 5

April 2017

South African National Roads Agency SOC Ltd

ENVIRONMENTAL IMPACT ASSESSMENT REPORT

AND

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL

ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL

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

TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).

NAME OF APPLICANT: South African National Roads Agency SOC Ltd (SANRAL)

TEL NO: +27 41 398 3215

FAX NO: +27 41 492 0200

POSTAL ADDRESS: 20 Shoreward Drive (Adjacent Bay West Mall Entrance 4a),

Bay West, Port Elizabeth, 6025.

PHYSICAL ADDRESS: 20 Shoreward Drive (Adjacent Bay West Mall Entrance 4a),

Bay West, Port Elizabeth, 6025.

FILE REFERENCE NUMBER SAMRAD: EC 30/5/1/3/3/2/1/00066 BPEM

SLR Consulting (South Africa) (Pty) Ltd Page ii

SLR Ref. 723.19083.00003 Report No.5

Proposed establishment of a quarry in the Ngquza Hill Local Municipality, Eastern Cape

Environmental Impact Report April 2017

EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER

NAME: Mr Fuad Fredericks

RESPONSIBILITY ON PROJECT: Project management and quality control

QUALIFICATIONS: M.Sc. (Botany), HDE

PROFESSIONAL

REGISTRATION: Pr.Sci.Nat., CEAPSA

EXPERIENCE IN YEARS: 17

EXPERIENCE:

Fuad Fredericks has been involved in environmental consulting

since 1999 and is currently a Director of SLR Consulting (South

Africa) (Pty) Ltd. He has experience in a wide range of

environmental disciplines, including Environmental Impact

Assessments, Environmental Management Programmes,

Environmental Monitoring and Auditing, Environmental

Education and Public Consultation. He has been responsible for

management and quality control of environmental assessments

dealing with a number of highly complex and controversial

projects, such as the proposed toll roads on the national routes

in the Western Cape and the proposed toll road between the

Eastern Cape and KwaZulu-Natal. He also has extensive

experience in the environmental assessment, monitoring and

auditing of projects related to railway facilities, landfill sites,

wastewater treatment facilities, and water and sewage pipelines.

NAME: Nicholas Arnott

RESPONSIBILITY ON PROJECT: Project consultant and report writing

QUALIFICATIONS: B.Sc. Hons (Earth and Geographical Science)

PROFESSIONAL

REGISTRATION: Pr.Sci.Nat.

EXPERIENCE IN YEARS: 10

EXPERIENCE:

Nicholas Arnott has worked as an environmental assessment

practitioner since 2006 and has been involved in a number of

projects covering a range of environmental disciplines, including

Basic Assessments, Environmental Impact Assessments and

Environmental Management Programmes. He has gained

experience in a wide range of projects relating to mining,

infrastructure projects (e.g. roads), housing and industrial

developments.

SLR Consulting (South Africa) (Pty) Ltd Page iii

SLR Ref. 723.19083.00003 Report No.5



EXECUTIVE SUMMARY

1. INTRODUCTION

This Executive Summary provides a comprehensive synopsis of the Final Environmental Impact Report

(EIR) and Environmental Management Programme Report (EMPR) prepared as part of the Scoping and

Environmental Impact Assessment (EIA) process that has been undertaken for the proposal by the South

African National Roads Agency SOC Ltd (SANRAL) to develop a quarry within the Ngquza Hill Local

Municipality in the Eastern Cape Province (see Figure 1). The proposed quarry would act as a local source

of the necessary materials for construction of the Mthentu and Msikaba river bridges and other required

works on the N2 Wild Coast Toll Highway.

1.1 PURPOSE OF THIS REPORT

This report summarises the Scoping and EIA process undertaken, provides an overview of the proposed project,

describes the affected environment, presents the findings of the specialist studies and provides an assessment of the

potential impacts of the proposed project. It should be noted that all substantive changes to the draft report are

underlined and in a different font (Times New Roman) to the rest of the text.

This report is submitted to the Department of Mineral Resources (DMR) for consideration as part of the Application for

Environmental Authorisation in terms of Chapter 5 of the National Environmental Management Act, 1998 (No. 107 of

1998) (NEMA), as amended.

1.2 PROJECT BACKGROUND

SANRAL has commenced with preparations for construction of the greenfields sections of the N2 Wild Coast

Toll Highway project. Such preparations include the identification of potential quarry site locations for the

sourcing of the necessary construction materials for the Mthentu and Msikaba river bridges and other

required works on the N2 Wild Coast Toll Highway. Based on the outcomes of preliminary geotechnical

investigations, a suitable site for the establishment of a quarry has been identified within the Ngquza Hill

Local Municipality in the Eastern Cape Province. Accordingly, SANRAL is now proposing to establish a

quarry at this site.

On 5 September 2016, SANRAL lodged an application for Environmental Authorisation with the DMR in

terms of Section 24 of NEMA, as amended. The application was accepted by DMR on 10 October 2016.

1.3 LEGISLATIVE FRAMEWORK

In terms of the Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002) (MPRDA), a

Mining Right must be issued prior to the commencement of any quarrying activities. In terms of Section 106

of the MPRDA, SANRAL is exempted from applying for a Mining Right for the purposes of sourcing road

building material. However, SANRAL is still required to submit the relevant environmental reports in terms of

Chapter 5 of the NEMA to obtain an environmental authorisation.

SLR Consulting (South Africa) (Pty) Ltd Page iv

SLR Ref. 723.19083.00003 Report No.5

Proposed establishment of a quarry in the Ngquza Hill Local Municipality, Eastern Cape Environmental Impact Report

April 2017

Figure 1: Regional setting of the proposed quarry site.

SLR Consulting (South Africa) (Pty) Ltd Page v

SLR Ref. 723.19083.00003 Report No.5



The EIA Regulations 2014 promulgated in terms of Chapter 5 of the NEMA, and published in Government

Notice (GN) No. R982 (as amended), provides for the control of certain listed activities. The proposed

project triggers various activities contained in Listing Notices 1, 2 and 3 (as amended), thus a full Scoping

and EIA process must be undertaken in order for the DMR to consider an application for environmental

authorisation1.

In terms of the National Water Act, 1998 (No. 36 of 1998) (NWA), a Water Use Licence Application for the

following water use activities, at a minimum, would be required for the proposed quarry:

• Section 21(c) - Impeding and diverting the flow of water in a watercourse; and

• Section 21(i) - Altering the bed, banks, course or characteristics of a watercourse.

It is noted that in terms of the General Authorisation (GA) Regulations (GN No. 509 of 26 August 2016),

SANRAL would not be required to apply for a WULA for the proposed access road over the KwaDlambu

River, as it would be authorised under the GA, subject to compliance with the necessary conditions.

Furthermore, the Contractor(s) to be appointed for the operation of the quarry would be responsible for

determining suitable water sources and obtaining any permits, licence and/or authorisations which may

also be applicable for the abstraction of water from these sources, as appropriate.

The proposed quarry will also require authorisation in terms of the National Heritage Resources Act, 1999

(No. 25 of 1999) (NHRA). The NHRA stipulates that no person may disturb any grave or burial ground

older than 60 years without a permit. Human remains that are less than 60 years old are subject to

provisions of the Human Tissue Act, 1983 (No. 65 of 1983) and any other applicable local regulations.

The relocation of graves would require a permit issued by the Eastern Cape Provincial Heritage

Resources Authority (ECPHRA).

2. EIA PROCESS

2.1 SCOPING PHASE

The Scoping Phase complied with the requirements of NEMA and the EIA Regulations 2014, as set out in

GN No. R982 (as amended). This involved a process of notifying Interested and Affected Parties (I&APs)

of the proposed project and EIA process in order to ensure that all potential key environmental impacts,

including those requiring further investigation, were identified.

The Scoping Report, which was prepared in compliance with Appendix 2 of the EIA Regulations 2014,

was accepted by DMR on 14 December 2016. DMR’s acceptance of the Scoping Report stated that the

next phase of the EIA may proceed as outlined in the Plan of Study for EIA, which was appended to the

Scoping Report.

2.2 EIA PHASE

2.2.1 Specialist studies

Three specialist studies were undertaken to address following aspects: (1) potential impacts on terrestrial

and freshwater ecosystems; (2) potential blasting impacts; and (3) potential impacts on cultural heritage

1 Subsequent to the distribution of the Draft EIA and EMPR Report for comment, the EIA Regulations 2014,

Listing Notices 1, 2 and 3 were amended by GN No. R.326, R.327, R.325, and R.324 of 7 April 2017,

respectively. These amendments have been duly taken into account in the compilation of this final report.

SLR Consulting (South Africa) (Pty) Ltd Page vi

SLR Ref. 723.19083.00003 Report No.5



resources. The specialist studies involved the gathering of data relevant to identifying and assessing

environmental impacts that may occur as a result of the proposed project. These impacts were then

assessed according to pre-defined rating scales. Specialists also recommended appropriate mitigation or

optimisation measures to minimise potential negative impacts or enhance potential benefits, respectively.

2.2.2 Integration and Assessment

The EIR and EMPR has been prepared in compliance with Appendix 3 of the EIA Regulations 2014. The specialist

assessments and other relevant information have been integrated into the report. The Draft EIR and EMPR was

distributed for a 30-day comment period from 17 March to 19 April 2017 (taking into account the three public

holidays during this period) in order to provide I&APs with an opportunity to comment on any aspect of the

proposed project and the findings of the EIA process. One verbal and two written submissions were received during

the review and comment period.

The following steps are envisaged for the remainder of the EIA process:

• After the Minister of Mineral Resources (or delegated authority) has reached a decision, all I&APs

on the project database will be notified of the outcome of the application and the reasons for the

decision; and

• A statutory appeal period in terms of the National Appeal Regulations (GN No. R993) will follow the

issuing of the decision.

3. PROPOSED PROJECT DESCRIPTION

As noted above, SANRAL is proposing to establish a quarry to provide the necessary materials for the

construction of the Mthentu and Msikaba river bridges and other works on the N2 Wild Coast Toll

Highway. Based on the initial results of preliminary geotechnical investigations, a suitable site for the

establishment of a quarry has been identified within the Ngquza Hill Local Municipality in the Eastern

Cape Province.

The proposed project would entail the establishment of a quarry, various associated stockpiles, a

contractor’s camp and an access road (see Figure 2). The total footprint of the area to be developed is

anticipated to be approximately 50 ha, with the proposed quarry being about 25 ha in extent.

The following key facilities associated with the contractor’s camp are currently planned:

• Offices;

• Ablution facilities;

• Workshop;

• Stores;

• Fuel storage;

• Concrete batching; and

• Crushing and processing plant.

The paragraphs overleaf provide a more detailed description of the proposed operations.

SLR Consulting (South Africa) (Pty) Ltd Page vii

SLR Ref. 723.19083.00003 Report No.5


April 2017

Figure 2: Site plan of the proposed quarry.

CRUSHING PLANT

PRIMARY QUARRY

PRIMARY STOCKPILE

AREA

CONTRACTOR

CAMP

SECONDARY QUARRY

SECONDARY STOCKPILE

BACKUP

STOCKPILE

SLR Consulting (South Africa) (Pty) Ltd Page viii

SLR Ref. 723.19083.00003 Report No.5



3.1 QUARRY LAYOUT AND DEVELOPMENT

The proposed quarry could be either operated by a single operator or two operators simultaneously, thus

the site layout has been designed to make provision for two separate quarrying areas (Primary Quarry

and Secondary Quarry) that could be worked independently of each other. In the scenario that two

operators are involved, the Primary Quarry area would be worked by one operator along the east-west

face and the second operator would independently work the Secondary Quarry along the south-north

face.

The excavated material from each quarry area would then be processed by the crushing plant located on

the site. The processed material would be stockpiled and then loaded onto haul vehicles for transport to

the construction sites. Material that is not suitable for use in the construction works would be stockpiled

separately for use in the reshaping of the site during rehabilitation. Where two operators are involved at

the site, each operator would be responsible for the rehabilitation of their respective operational areas

(i.e. the separate Primary and Secondary quarry areas), as well as their portion of the overall site.

3.2 WASTE MANAGEMENT

Domestic waste generated during the course of the quarry operations would be collected and stored in

suitable receptacles on-site for collection and disposal at an appropriately licensed municipal waste site

or acceptable disposal facility.

3.3 WATER MANAGEMENT

It is anticipated that water would be required for dust suppression (on stockpiles and the access road)

and ancillary activities associated with the quarry operations (e.g. washing of vehicles and equipment).

The proposed source(s) and anticipated volumes required for the proposed project are not known at this

stage. The Contractor(s) to be appointed for the operation of the quarry would be responsible for



3.4 TRANSPORT

It is proposed that an access road would be established to link the proposed quarry site with the Holy

Cross - Mkambati Road. The proposed access road would cross a watercourse. The project engineer has

recommended that the proposed water crossing be a low-level river crossing structure comprising five

box culverts and positioned at the centre of the river. It was further recommended that the road section

located to the east of the river crossing be surfaced with concrete, while the road section to the west of

the river could be a gravel surface. The proposed access road would facilitate the transport of material by

truck from the site to the bridge construction and other areas.

4. AFFECTED ENVIRONMENT

4.1 BIOPHYSICAL ENVIRONMENT

The topography of the broader study area is very rugged and mountainous with deep and steep-sided

river valleys. The proposed quarry site itself is positioned on a hill and is bounded by two watercourses to

SLR Consulting (South Africa) (Pty) Ltd Page ix

SLR Ref. 723.19083.00003 Report No.5



the west, south and east of the site perimeter. The majority of the rivers in the region are considered to

have a high Ecological Importance and Sensitivity.

The natural vegetation of the study area is mapped as Ngongoni Veld, which is considered to be a

“Vulnerable” vegetation type. The proposed quarry site is located within an area identified as a terrestrial

“Critical Biodiversity Area (CBA) 2” and an aquatic “CBA2 estuary” in terms of the Eastern Cape

Biodiversity Conservation Plan Mapping.

Eight plant species of conservation concern were considered to potentially occur within the study area. Of

the eight species identified, two were confirmed to be present within the proposed quarry site, namely

Hypoxis hemerocallidea (Declining status) and Senecio umgeniensis (Threatened status), while further

verification is required to confirm the presence of a third species, Helichrysum cf. pannosum (Endangered

status). With respect to fauna, two mammal species (Cape Clawless Otter and Reddish-grey Musk

Shrew), three bird species (African Marsh-Harrier, Black Harrier and Black-Winged Lapwing) and twelve

endemic or near-endemic reptile species are thought to potentially occur within the project area.

4.2 CULTURAL HERITAGE ENVIRONMENT

Later Iron Age and two Early Iron Age sites have been historically identified in the broader study area.

From a cultural perspective, social capital is held in homesteads and graves, with grave sites often

associated with abandoned homesteads. The heritage specialist did not identify any archaeological sites

within the footprint of the proposed project and associated access road. However, a grave associated

with an old abandoned homestead was located in the eastern section of the project footprint.

4.3 SOCIO-ECONOMIC ENVIRONMENT

The Ngquza Hill Local Municipality (LM) is bordered by the Bizana LM to the north, the Port St John’s LM

to the south and the Ntabankulu LM to the northwest. The total population of the Ngquza Hill LM is

278 481, which is 20.4% of the total population of the O.R. Tambo District Municipality. Scattered rural

subsistence settlements predominate with some villages being fairly inaccessible. Approximately 95% of

the population of the municipality is recorded as living in traditional dwellings. The vast majority of the

population are not considered economically active (91 793 people) with only 18 524 people being

employed (Stats SA, 2011).

The proposed quarry site is largely undeveloped and sparsely populated with small dwellings (generally

comprising one to four structures). The remaining open areas are used for limited subsistence farming or

grazing. Road infrastructure in the area is poorly developed.

5. IMPACT ASSESSMENT CONCLUSIONS

A summary of the assessment of potential environmental impacts associated with the proposed project

activities and No-Go Alternative is provided in Table 5.1.

The majority of the impacts associated with the establishment and operation of the proposed quarry

would be largely localised, of long-term duration and of low intensity, and are considered to be of LOW

significance after mitigation. Key mitigation includes ensuring that the area of disturbance is limited to

what is absolutely necessary for the proposed operation, a detailed stormwater management plan is

developed and implemented, on-site pollution prevention measures are implemented and any complaints

received from third parties are addressed in accordance with a formal complaints procedure.

SLR Consulting (South Africa) (Pty) Ltd Page x

SLR Ref. 723.19083.00003 Report No.5



One of the key issues associated with the proposed quarry operation relates to the loss of vegetation and

the related impacts on fauna and associated biodiversity. All vegetation within the quarry footprint would

be lost during the course of the operations. Approximately 22 ha of Degraded Primary Grassland and 29

ha of Secondary Grassland (of the ‘Vulnerable’ Ngongoni vegetation type) would be lost. Furthermore,

conservation-important plant species may be destroyed/damaged if measures are not taken to preserve

these plants. The loss of Ngongoni Veld and conservation-important species is considered to be a high

intensity impact, localised over the duration of the proposed quarry operations. As the loss of Ngongoni

Veld due to quarry establishment is accommodated in the approved Biodiversity Offset Report for the N2

Wild Coast Toll Highway (Botha & Brownlie, 2015), the requisite biodiversity offset would compensate for

the loss of the vegetation type. The residual impact is assessed to be of MEDIUM to HIGH significance.

With respect to noise impacts, it is anticipated that the proposed quarry would exceed the SANS

guidelines with respect to increasing ambient background noise levels in excess of 3 to 5 dBA. However,

as it is recommended that the homesteads closest to the quarry operations (i.e. within the project footprint

and associated 600m blast zone – see below) should be relocated, the closest receptors would be

located further away from noise sources associated with the proposed operations. The residual noise

impact of the proposed project is deemed to be of local extent, long-term duration, medium intensity and

MEDIUM significance.

The relocation of a single unmarked grave site located within the project footprint will be required, as well

as any graves which may be associated with homesteads to be relocated in the adjacent area. As human

remains have high heritage significance for their social value, the potential permanent, localised impact is

assessed to be of high intensity. By ensuring that all applicable legislative requirements, guidelines and

regulations applicable to the removal of human remains are implemented for the relocation of graves, it is

anticipated that the residual impact would be of MEDIUM significance.

Where basting activities associated with the proposed quarry operations lead to the damage of third party

property or injury of people or animals, the impact would be of high intensity at a local level and endure in

the medium term and is deemed to be of medium significance without mitigation. The blasting specialist

has indicated that the human response to the modelled ground vibration levels would be at an

“unpleasant” level up to 592 m of the boundary of the quarry footprint. Consequently, it is recommended

that the relocation of households within 600 m of the quarry boundary be considered. By relocating third-

parties outside of the project footprint and the blasting zone (a distance of 600 m, as recommended by

the blasting specialist), the significance of the residual impact would reduce to LOW.

Not going ahead with the proposed quarry operations (No-Go Alternative) would result in the

maintenance of the status quo. No change to the current impacts experienced on the site would be

expected for terrestrial and freshwater ecosystems, ambient air quality, noise, heritage and cultural

resources, traffic and land uses. Furthermore, NO IMPACT with respect to blasting hazards and the influx

of job seekers would be anticipated. However, not proceeding with the proposed project would result in

the loss of direct and indirect socio-economic benefits of the proposed project and lost economic

opportunities related to costs already incurred in the initial planning phase. This is considered to be of

HIGH significance.

SLR Consulting (South Africa) (Pty) Ltd Page xi

SLR Ref. 723.19083.00003 Report No.5



Table 5.1: Summary of the significance of the potential impacts associated with the proposed

mining operations and No-Go Alternative.

Potential impact

Significance

Without

mitigation

With mitigation

POTENTIAL BIOPHYSICAL IMPACTS

Soil and land capability M L

Fauna and Flora Loss of vegetation H M - H

Loss of fauna and alteration of habitats L L

Hydrology (Surface Water) M L - M

Air Quality L L

Noise M M

POTENTIAL SOCIO-ECONOMIC IMPACTS

Heritage and Cultural Resources Unmarked grave site H M

Archaeological sites M L

Impacts on roads by project-related traffic M – H L - M

Blasting Hazards M L

Land Use L L

Creation of employment and business opportunities L (+ve) L (+ve)

Influx of job seekers to the area M L

NO-GO ALTERNATIVE

No-Go Alternative Soil and land capability L N/A

Fauna and Flora L N/A

Hydrology (Surface Water) L N/A

Air Quality

NO CHANGE TO CURRENT

IMPACTS

Noise

Heritage and Cultural Resources

Impacts on traffic

Land Use

Blasting Hazards NO IMPACT

Influx of job seekers

Lost Economic Opportunities H N/A

VH=Very High H=High M=Medium L=Low VL=Very low Insig =

insignificant

N/A=

Not applicable

5.1 REASONED OPINION OF ENVIRONMENTAL ASSESSMENT PRACTITIONER

The key principles of sustainability, including ecological integrity, economic efficiency, and equity and

social justice, are integrated below as part of the supporting rationale for recommending an opinion on

whether the proposed project should or should not be approved.

• Ecological integrity2

The potential disturbance of Ngongoni Veld and associated biodiversity is considered to be of high

intensity as all vegetation (and associated available habitat) within the quarry footprint would be

lost during the course of quarry operations. The area of disturbance (approximately 70 ha including

the proposed project footprint and associated access road) is considered to be relatively

substantial in comparison to the remaining intact area of this ‘Vulnerable’ vegetation type.

Furthermore, there are numerous conservation-important species present within the grassland

2 Ecological integrity is the abundance and diversity of organisms at all levels, and the ecological patterns, processes and structural

attributes responsible for that biological diversity and for ecosystem resilience.

SLR Consulting (South Africa) (Pty) Ltd Page xii

SLR Ref. 723.19083.00003 Report No.5



ecosystem at the site which may be destroyed/damaged if measures are not taken to preserve

these plants. By undertaking a plant search and rescue operation prior to the clearing of the site,

the impact on conservation-important species would be mitigated.

As the loss of Ngongoni Veld due to quarry establishment is accommodated in the approved

Biodiversity Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015), the loss of

the vegetation type within the project footprint would be compensated for and the overall

significance of the project impact on the conservation status of the vegetation type would be

reduced.

• Economic efficiency

The area surrounding the proposed quarry site is generally undeveloped with very limited socio-

economic opportunities. The proposed project would create local employment and business

opportunities. These potential benefits to the local economy would extend over the operational

lifespan of the proposed project. It is anticipated that a large number of the low- and semi-skilled

employment opportunities could be sourced from the local labour force, especially during the site

establishment phase. In terms of business opportunities for local companies, contract procurement

requirements would create business opportunities for the regional and local economy. A

percentage of the monthly wage bill earned by permanent staff would be spent in the regional and

local economy, which would benefit local businesses.

In light of the above, the proposed project is considered to be economically efficient, as it would

provide an opportunity to utilise natural resources within the Eastern Cape with associated socio-

economic benefits. With the recommended enhancement measures, any possible negative impact

associated with inward migration would be further reduced.

• Equity and social justice

While the proposed project would require the relocation of people residing within the project

footprint and the associated blasting zone (600m from the boundary of the quarry footprint), the

relocation would be undertaken by the appointed land management specialist in accordance with

the requirements of, amongst others, the Constitution of South Africa Act, 1996 (Act No. 108 of

1996) and the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996), as

applicable. These legislative provisions ensure, amongst others, that directly affected parties

receive fair and equitable treatment and that no person shall be worse off when compared to their

current situation.

It is the opinion of SLR that, in terms of the sustainability criteria described above and the nature and

extent of the proposed quarry activities, the generally LOW to MEDIUM significance residual impacts

should support a positive decision being made by the Minister of Mineral Resources (or delegated

authority) in this regard.

5.2 RECOMMENDATIONS

It is recommended that the following conditions should be included in the Environmental Authorisation

(EA), if a decision to grant an EA is issued:

• An Environmental Management Programme (EMP) for the construction and operational phases

must be implemented for the duration of the proposed project (refer to the EMP attached as

Appendix 6).

SLR Consulting (South Africa) (Pty) Ltd Page xiii

SLR Ref. 723.19083.00003 Report No.5



• Ensure that the existing Biodiversity Offset Agreement for the N2 Wild Coast Toll Highway, which

accommodates the potential loss of primary Ngongoni Veld due to stockpiling and/or the

establishment of borrow pits/quarries, is implemented effectively.

• A protected plant survey must be undertaken within the primary terrestrial Ngongoni grassland

within the project footprint, in order to confirm the presence and abundance of threatened and

protected plant species. This survey must be undertaken by a suitably qualified botanist, prior to

the commencement of construction, during the summer growing season (between November and

March). The protected plant survey must be used to develop a detailed protected plant rescue and

translocation protocol for threatened and protected plants (based on the preliminary guidelines

provided in Section 5.4 of the specialist terrestrial ecological report, attached as Appendix 4.1).

• Undertake a Baseline Water Quality Monitoring Survey prior to the commencement of construction

activities in order to collect baseline data for the monitoring of water quality impacts associated with

construction and operation of the quarry.

• Develop a detailed Stormwater Management Plan that describes how the design measures of

surface and near-surface water management facilities will be designed, constructed and operated

so that contaminated water is kept separate from clean water run-off through a system of berms,

channels, trenches, flood and erosion protection measures.

• Relocate all households within the quarry footprint and 600 m from the quarry boundary.

• Monitor ground vibration and air blast to ensure that the generated levels of ground vibration and

air blast comply with recommendations. The monitoring of ground vibration must qualify the

expected ground vibration and air blast levels and assist in mitigating these aspects properly. Ten

monitoring positions have been proposed by the blasting specialist (see Figure 18 and Table 17 of

Appendix 4.3).

• Develop a comprehensive Rehabilitation and Closure Plan prior to the decommissioning and

closure of the proposed quarry operation.

SLR Consulting (South Africa) (Pty) Ltd Page xiv

SLR Ref. 723.19083.00003 Report No.5



TABLE OF CONTENTS

DOCUMENT INFORMATION......................................................................................................................... i

EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER ...................................................... ii

EXECUTIVE SUMMARY .............................................................................................................................. iii

TABLE OF CONTENTS ............................................................................................................................. xiv

ACRONYMS AND ABBREVIATIONS ......................................................................................................... xx

PART A - FINAL ENVIRONMENTAL IMPACT REPORT

1. CONTACT PERSON AND CORRESPONDENCE ADDRESS........................................................... 1

1.1. DETAILS OF THE EAP WHO PREPARED THE REPORT ..................................................... 1

1.2. EXPERTISE OF THE EAP ....................................................................................................... 1

2. DESCRIPTION OF THE PROPERTY ................................................................................................. 1

3. LOCALITY MAP .................................................................................................................................. 2

4. DESCRIPTION OF THE SCOPE OF THE PROPOSED OVERALL ACTIVITY ................................. 2

4.1. LISTED AND SPECIFIED ACTIVITIES .................................................................................... 2

4.2. DESCRIPTION OF THE ACTIVITIES TO BE UNDERTAKEN ................................................. 6

4.2.1. PROJECT OVERVIEW ................................................................................................ 6

4.2.2. QUARRY LAYOUT AND DEVELOPMENT ................................................................. 6

4.2.3. WASTE MANAGEMENT .............................................................................................. 8

4.2.4. WATER MANAGEMENT ............................................................................................. 8

4.2.5. TRANSPORT ............................................................................................................... 8

5. POLICY AND LEGISLATIVE CONTEXT ............................................................................................ 8

5.1. LEGISLATIVE REQUIREMENTS ............................................................................................. 8

5.1.1. OVERVIEW OF THE “ONE ENVIRONMENTAL SYSTEM” ........................................ 8

5.1.2. MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002

(MPRDA) ...................................................................................................................... 8

5.1.3. NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (NEMA) ........................ 9

5.1.4. NATIONAL WATER ACT, 1998 (NWA) ....................................................................... 9

5.1.5. NATIONAL HERITAGE RESOURCES ACT, 1999 (NHRA) ...................................... 10

5.1.6. NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT, 2004

(NEM:BA) ................................................................................................................... 11

5.2. GUIDELINES AND POLICIES ................................................................................................ 11

6. NEED AND DESIRABILITY OF THE PROPOSED PROJECT......................................................... 12

7. MOTIVATION FOR THE PREFERRED DEVELOPMENT FOOTPRINT WITHIN THE

APPROVED SITE INCLUDING THE PROCESS FOLLOWED TO DEFINE THE PREFERRED

DEVELOPMENT ALTERNATIVES ................................................................................................... 13

7.1. DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED ....................................... 13

7.1.1. PROPERTY ON WHICH OR LOCATION WHERE IT IS PROPOSED TO

UNDERTAKE THE ACTIVITY.................................................................................... 13

7.1.2. TYPE OF ACTIVITY TO BE UNDERTAKEN ............................................................. 16

7.1.3. DESIGN OR LAYOUT OF THE ACTIVITY ................................................................ 16

7.1.4. TECHNOLOGY TO BE USED IN THE ACTIVITY ..................................................... 16

7.1.5. OPERATIONAL ASPECTS OF THE ACTIVITY ........................................................ 17

7.1.6. OPTION OF NOT IMPLEMENTING THE ACTIVITY ................................................. 17

SLR Consulting (South Africa) (Pty) Ltd Page xv

SLR Ref. 723.19083.00003 Report No.5



7.2. DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED ................................ 17

7.2.1. SCOPING PHASE ..................................................................................................... 17

7.2.2. SUMMARY OF ISSUES RAISED BY I&APS ............................................................. 20

8. THE ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE DEVELOPMENT

FOOTPRINT ALTERNATIVES ......................................................................................................... 25

8.1. BASELINE ENVIRONMENT ................................................................................................... 25

8.1.1. CLIMATE .................................................................................................................... 25

8.1.2. TOPOGRAPHY .......................................................................................................... 25

8.1.3. GEOLOGY AND SOILS ............................................................................................. 25

8.1.4. BIODIVERSITY .......................................................................................................... 26

8.1.5. CULTURAL/HERITAGE ENVIRONMENT ................................................................. 31

8.1.6. REGIONAL SOCIO-ECONOMIC ENVIRONMENT ................................................... 32

8.1.7. CURRENT LAND USES ............................................................................................ 32

8.2. IMPACTS AND RISKS IDENTIFIED INCLUDING THE NATURE, SIGNIFICANCE,

CONSEQUENCE, EXTENT, DURATION AND PROBABILITY OF THE IMPACTS .............. 34

8.2.1. POTENTIAL BIOPHYSICAL IMPACTS ..................................................................... 34

8.2.2. POTENTIAL SOCIO-ECONOMIC IMPACTS ............................................................ 43

8.2.3. NO-GO ALTERNATIVE ............................................................................................. 50

8.3. METHODOLOGY USED IN DETERMINING AND RANKING THE NATURE,

SIGNIFICANCE, CONSEQUENCES, EXTENT, DURATION AND PROBABILITY OF

POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS ...................................................... 51

8.3.1. EXTENT ..................................................................................................................... 53

8.3.2. DURATION................................................................................................................. 53

8.3.3. INTENSITY................................................................................................................. 53

8.3.4. SIGNIFICANCE .......................................................................................................... 54

8.3.5. STATUS OF IMPACT ................................................................................................ 54

8.3.6. PROBABILITY ............................................................................................................ 55

8.3.7. DEGREE OF CONFIDENCE ..................................................................................... 55

8.3.8. LOSS OF RESOURCES ............................................................................................ 55

8.3.9. DEGREE TO WHICH IMPACT CAN BE MITIGATED ............................................... 55

8.3.10. REVERSIBILITY OF AN IMPACT .............................................................................. 55

8.4. 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 ................................ 56

8.5. THE POSSIBLE MITIGATION MEASURES THAT COULD BE APPLIED AND THE

LEVEL OF RISK...................................................................................................................... 56

8.6. MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED........................... 56

8.7. STATEMENT MOTIVATING THE ALTERNATIVE DEVELOPMENT LOCATION

WITHIN THE OVERALL SITE ................................................................................................ 56

9. FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND

RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED

SITE................................................................................................................................................... 57

9.1. ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND

RISK ........................................................................................................................................ 58

9.2. SUMMARY OF SPECIALIST REPORTS ............................................................................... 61

10. ENVIRONMENTAL IMPACT STATEMENT ...................................................................................... 63

SLR Consulting (South Africa) (Pty) Ltd Page xvi

SLR Ref. 723.19083.00003 Report No.5



10.1. SUMMARY OF THE KEY FINDINGS OF THE ENVIRONMENTAL IMPACT

ASSESSMENT........................................................................................................................ 63

10.2. FINAL SITE MAP .................................................................................................................... 63

10.3. SUMMARY OF THE POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS OF THE

PROPOSED ACTIVITY AND IDENTIFIED ALTERNATIVES ................................................ 64

11. PROPOSED IMPACT MANAGEMENT OBJECTIVES AND THE IMPACT MANAGEMENT

OUTCOMES FOR INCLUSION IN THE EMPR ................................................................................ 65

12. FINAL PROPOSED ALTERNATIVES ............................................................................................... 65

13. ASPECTS FOR INCLUSION AS CONDITIONS OF AUTHORISATION .......................................... 65

14. DESCRIPTION OF ANY ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE ........ 65

14.1. REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY SHOULD OR

SHOULD NOT BE AUTHORISED .......................................................................................... 65

14.2. REASONS WHY THE ACTIVITY SHOULD BE AUTHORISED OR NOT .............................. 67

14.3. CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION ............................... 67

14.3.1. SPECIFIC CONDITIONS TO BE INCLUDED INTO THE COMPILATION AND

APPROVAL OF EMPR .............................................................................................. 67

14.3.2. REHABILITATION REQUIREMENTS ....................................................................... 67

14.3.3. PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS

REQUIRED ................................................................................................................ 68

15. UNDERTAKING ................................................................................................................................ 68

16. FINANCIAL PROVISION .................................................................................................................. 68

16.1. EXPLAIN HOW THE AFORESAID AMOUNT WAS DERIVED .............................................. 68

16.2. CONFIRM THAT THIS AMOUNT CAN BE PROVIDED FOR FROM OPERATING

EXPENDITURE....................................................................................................................... 68

17. DEVIATIONS FROM THE APPROVED SCOPING REPORT AND PLAN OF STUDY ................... 69

17.1. DEVIATIONS FROM THE METHODOLOGY USED IN DETERMINING THE

SIGNIFICANCE OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS ..................... 69

17.2. MOTIVATION FOR THE DEVIATION .................................................................................... 69

18. OTHER INFORMATION REQUIRED BY THE COMPETENT AUTHORITY .................................... 69

18.1. IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY AFFECTED

PERSON ................................................................................................................................. 69

18.2. IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF THE

NATIONAL HERITAGE RESOURCES ACT .......................................................................... 69

19. OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT ........ 69

PART B - FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1. FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT .............................................. 1

1.1. DETAILS OF THE EAP ............................................................................................................. 1

2. DESCRIPTION OF THE ASPECTS OF THE ACTIVITY .................................................................... 1

3. COMPOSITE MAP .............................................................................................................................. 1

4. DESCRIPTION OF IMPACT MANAGEMENT OBJECTIVES............................................................. 1

4.1. DETERMINATION OF CLOSURE OBJECTIVES .................................................................... 1

4.2. THE PROCESS FOR MANAGING ANY ENVIRONMENTAL DAMAGE, POLLUTION,

PUMPING AND TREATMENT OF EXTRANEOUS WATER OR ECOLOGICAL

DEGRADATION AS A RESULT OF UNDERTAKING A LISTED ACTIVITY ........................... 2

4.3. POTENTIAL RISK OF ACID MINE DRAINAGE ....................................................................... 2

SLR Consulting (South Africa) (Pty) Ltd Page xvii

SLR Ref. 723.19083.00003 Report No.5



4.3.1. INDICATE WHETHER OR NOT THE MINING CAN RESULT IN ACID MINE

DRAINAGE................................................................................................................... 2

4.3.2. STEPS TAKEN TO INVESTIGATE, ASSESS, AND EVALUATE THE IMPACT

OF ACID MINE DRAINAGE ......................................................................................... 2

4.3.3. ENGINEERING OR MINE DESIGN SOLUTIONS TO BE IMPLEMENTED TO

AVOID OR REMEDY ACID MINE DRAINAGE ............................................................ 3

4.3.4. MEASURES THAT WILL BE PUT IN PLACE TO REMEDY ANY RESIDUAL

OR CUMULATIVE IMPACT THAT MAY RESULT FROM ACID MINE

DRAINAGE................................................................................................................... 3

4.4. VOLUMES AND RATE OF WATER USE REQUIRED FOR THE MINING, TRENCHING

OR BULK SAMPLING OPERATION ........................................................................................ 3

4.5. HAS A WATER USE LICENCE HAS BEEN APPLIED FOR? .................................................. 3

4.6. IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES ......................................... 4

4.7. IMPACT MANAGEMENT OUTCOMES .................................................................................... 7

4.8. IMPACT MANAGEMENT ACTIONS......................................................................................... 8

5. FINANCIAL PROVISION .................................................................................................................. 10

5.1. DETERMINATION OF THE AMOUNT OF FINANCIAL PROVISION .................................... 10

5.1.1. DESCRIBE THE CLOSURE OBJECTIVES AND THE EXTENT TO WHICH

THEY HAVE BEEN ALIGNED TO THE BASELINE ENVIRONMENT

DESCRIBED UNDER REGULATION 22 (2) (D) ....................................................... 10

5.1.2. CONFIRM SPECIFICALLY THAT THE ENVIRONMENTAL OBJECTIVES IN

RELATION TO CLOSURE HAVE BEEN CONSULTED WITH LANDOWNER

AND INTERESTED AND AFFECTED PARTIES....................................................... 10

5.1.3. 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 ..... 10

5.1.4. COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE

OBJECTIVES ............................................................................................................. 10

5.1.5. CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION

REQUIRED TO MANAGE AND REHABILITATE THE ENVIRONMENT IN

ACCORDANCE WITH THE APPLICABLE GUIDELINE ........................................... 11

5.1.6. CONFIRM THAT THE FINANCIAL PROVISION WILL BE PROVIDED AS

DETERMINED ........................................................................................................... 11

6. MECHANISMS FOR MONITORING COMPLIANCE WITH AND PERFORMANCE

ASSESSMENT AGAINST THE ENVIRONMENTAL MANAGEMENT PROGRAMME AND

REPORTING ..................................................................................................................................... 12

6.1. INDICATE THE FREQUENCY OF THE SUBMISSION OF THE PERFORMANCE

ASSESSMENT REPORT ....................................................................................................... 15

7. ENVIRONMENTAL AWARENESS PLAN ......................................................................................... 15

7.1. MANNER IN WHICH THE APPLICANT INTENDS TO INFORM HIS OR HER

EMPLOYEES OF ANY ENVIRONMENTAL RISK WHICH MAY RESULT FROM THEIR

WORK ..................................................................................................................................... 15

7.2. MANNER IN WHICH RISKS WILL BE DEALT WITH IN ORDER TO AVOID

POLLUTION OR THE DEGRADATION OF THE ENVIRONMENT ....................................... 15

8. SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY ................................ 15

9. UNDERTAKING ................................................................................................................................ 15

SLR Consulting (South Africa) (Pty) Ltd Page xviii

SLR Ref. 723.19083.00003 Report No.5



List of Appendices

Appendix 1: CVs and Proof of Registration of the EAP

Appendix 2: DMR Acceptance of the Scoping Report

Appendix 3: Public Participation Process

Appendix 3.1: I&AP Database

Appendix 3.2: I&AP Notification letters

Appendix 3.3: I&AP Correspondence

Appendix 3.4: Comments and Responses Report

Appendix 4: Specialist Reports

Appendix 4.1: Terrestrial and Aquatic Ecosystems

Appendix 4.2: Blasting Impact

Appendix 4.3: Cultural Heritage

Appendix 5: Undertaking

Appendix 6: EMP

List of Figures

FIGURE 3-1: REGIONAL SETTING OF THE PROPOSED QUARRY SITE ................................................................ 3

FIGURE 4-1: SITE PLAN OF THE PROPOSED QUARRY. ......................................................................................... 7

FIGURE 7-1: GOOGLE EARTH IMAGE OF THE IDENTIFIED ALTERNATIVE SITES FOR THE PROPOSED

QUARRY (THE PREFERRED ALTERNATIVE IS SHADED RED). ...................................................... 15

FIGURE 8-1: CRITICAL BIODIVERSITY AREAS IN THE BROADER STUDY AREA. THE PROPOSED QUARRY

LOCATION IS INDICATED AS A BLUE DOT (SOURCE: SANBI BIODIVERSITY GIS, 2016). ............ 27

FIGURE 8-2: IDENTIFIED VEGETATION COMMUNITIES WITHIN THE STUDY AREA. ......................................... 28

FIGURE 8-3: MAPPED WATERCOURSE UNITS WITHIN 500 M OF THE PROPOSED QUARRY FOOTPRINT

AREA. ................................................................................................................................................... 30

FIGURE 8-4: IDENTIFIED SCHOOLS, POLICE STATIONS AND HEALTH CARE FACILITIES WITHIN THE

BROADER STUDY AREA. ................................................................................................................... 33

List of Tables

TABLE 4-1: LIST OF ACTIVITIES/INFRASTRUCTURE ASSOCIATED WITH THE PROPOSED PROJECT ........... 4

TABLE 5-1: LIST OF POSSIBLE WATER USE ACTIVITIES IN TERMS OF THE NWA. ......................................... 10

TABLE 5-2: GUIDELINES AND POLICIES RELEVANT TO THE PROPOSED PROJECT. .................................... 12

TABLE 7-1: POTENTIAL ALTERNATIVE QUARRY SITES INITIALLY INVESTIGATED FOR DEVELOPMENT

(THE PREFERRED SITE IS SHADED). ............................................................................................... 13

TABLE 8-1: ASSESSMENT OF THE POTENTIAL IMPACT ON SOIL AND LAND CAPABILITY. ........................... 35

TABLE 8-2: ASSESSMENT OF THE POTENTIAL IMPACT ASSOCIATED WITH THE LOSS OF VEGETATION. 37

TABLE 8-3: ASSESSMENT OF THE POTENTIAL IMPACT ASSOCIATED WITH THE LOSS OF FAUNA AND

ALTERATION OF FAUNAL HABITAT. ................................................................................................. 38

TABLE 8-4: ASSESSMENT OF THE POTENTIAL IMPACTS ON SURFACE WATER FEATURES. ...................... 40

TABLE 8-5: ASSESSMENT OF THE POTENTIAL IMPACTS ON AIR QUALITY. ................................................... 41

TABLE 8-6: ASSESSMENT OF THE POTENTIAL IMPACTS ON AMBIENT NOISE LEVELS. ............................... 42

TABLE 8-7: ASSESSMENT OF THE POTENTIAL IMPACT ON HERITAGE RESOURCES. .................................. 43

TABLE 8-8: ASSESSMENT OF THE POTENTIAL IMPACT ON ROAD TRAFFIC. ................................................. 45

TABLE 8-9: ASSESSMENT OF THE POTENTIAL BLASTING IMPACTS. .............................................................. 47

TABLE 8-10: ASSESSMENT OF THE POTENTIAL IMPACT ON LAND USE. .......................................................... 48

TABLE 8-11: ASSESSMENT OF THE POTENTIAL SOCIAL IMPACT RELATED TO EMPLOYMENT AND THE

CREATION OF BUSINESS OPPORTUNITIES DURING OPERATION. .............................................. 49

SLR Consulting (South Africa) (Pty) Ltd Page xix

SLR Ref. 723.19083.00003 Report No.5



TABLE 8-12: ASSESSMENT OF THE POTENTIAL SOCIAL IMPACT RELATED TO THE INFLUX OF

OPERATION WORKERS. .................................................................................................................... 50

TABLE 8-13: ASSESSMENT OF THE POTENTIAL IMPACTS RELATED TO THE NO-GO ALTERNATIVE. ........... 51

TABLE 10-1: SUMMARY OF THE SIGNIFICANCE OF THE POTENTIAL IMPACTS ASSOCIATED WITH THE

PROPOSED QUARRY OPERATIONS AND NO-GO ALTERNATIVE. ................................................. 63

SLR Consulting (South Africa) (Pty) Ltd Page xx

SLR Ref. 723.19083.00003 Report No.5



ACRONYMS AND ABBREVIATIONS

Below a list of acronyms and abbreviations used in this report.

Acronyms / Abbreviations

Meaning

CBA Critical Biodiversity Area

DMR Department of Mineral Resources

DWS Department of Water and Sanitation

EAP Environmental Assessment Practitioner

ECPHRA Eastern Cape Provincial Heritage Resources Authority

EIR Environmental Impact Report

EMP Environmental Management Programme

EMPR Environmental Management Programme Report

GN Government Notice

I&AP Interested and Affected Party

IEM Integrated Environmental Management

MPRDA Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002)

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

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

NWA National Water Act, 1998 (No. 36 of 1998)

SANRAL South African National Roads Agency SOC Ltd

SLR SLR Consulting (South Africa) (Pty) Ltd

PART A

FINAL ENVIRONMENTAL IMPACT REPORT

SLR Consulting (South Africa) (Pty) Ltd Page 1

SLR Ref. 723.19083.00003 Report No.5



1. CONTACT PERSON AND CORRESPONDENCE ADDRESS

1.1. DETAILS OF THE EAP WHO PREPARED THE REPORT

The contact details of the Environmental Assessment Practitioner (EAP) who prepared this Final

Environmental Impact Report (EIR) and Environmental Management Programme Report (EMPR) are

provided below.

Neither SLR Consulting (South Africa) (Pty) Ltd (SLR) nor any of the specialists involved in the

environmental assessment process have any interest in the proposed project other than fair remuneration

for consulting services rendered as part of the environmental assessment process.

EAP: SLR Consulting (South Africa) (Pty) Ltd

Contact Person: Fuad Fredericks

Postal Address PO Box 10145

Caledon Square Postal Code: 7905

Telephone 021 461 1118 Cell: -

E-mail: [email protected] Fax: 021 461 1120

1.2. EXPERTISE OF THE EAP

The expertise of the individuals who were involved in the preparation of this Final EIR and EMPR are

provided on Page ii. The relevant curricula vitae and proof of registrations of the EAP are provided in

Appendix 1.

2. DESCRIPTION OF THE PROPERTY

The South African National Roads Agency SOC Ltd (SANRAL) is proposing to develop a quarry within

the Ngquza Hill Local Municipality in the Eastern Cape Province. Details regarding the location of the

proposed quarry are provided below.

Farm Name Un-alienated state land. Corner of property point co-ordinates

A 31° 11' 43.09" S 29° 49' 3.78" E

B 31° 11' 43.89" S 29° 49' 9.42" E

C 31° 11' 47.18" S 29° 49' 14.08" E

D 31° 12' 7.31" S 29° 49' 31.33" E

E 31° 12' 11.95" S 29° 49' 27.92" E

F 31° 12' 12.98" S 29° 49' 26.70" E

G 31° 12' 13.22" S 29° 49' 24.32" E

H 31° 12' 12.95" S 29° 49' 21.18" E

I 31° 12' 12.37" S 29° 49' 18.14" E

J 31° 12' 12.22" S 29° 49' 15.30" E

K 31° 12' 12.81" S 29° 49' 12.03" E

L 31° 12' 14.95" S 29° 49' 9.81" E

M 31° 12' 9.51" S 29° 49' 5.33" E


SLR Ref. 723.19083.00003 Report No.5



N 31° 12' 3.62" S 29° 49' 1.00" E

Corner of property point co-ordinates

O 31° 12' 0.07" S 29° 48' 59.92" E

P 31° 11' 57.32" S 29° 49' 3.34" E

Q 31° 11' 52.72" S 29° 49' 3.46" E

R 31° 11' 48.23" S 29° 49' 2.20" E

Application area (ha) 50 hectares (ha)

Magisterial district Flagstaff

Tribal Authority Sipaqeni Traditional Authority

Distance and direction from nearest town

Flagstaff (located approximately 34 km to the north-west) is the nearest town.

21 digit Surveyor General Code for each farm portion

Not applicable.

3. LOCALITY MAP

The regional setting of the study area indicating the locality of the proposed quarry site is provided in

Figure 3-1 overleaf.

4. 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.

SANRAL has commenced with preparations for construction of the greenfields sections of the N2 Wild

Coast Toll Highway project. Such preparations include the identification of potential quarry site locations

for the sourcing of the necessary construction materials for the Mthentu and Msikaba river bridges and

other required works on the N2 Wild Coast Toll Highway. Based on the outcomes of preliminary

geotechnical investigations, a suitable site for the establishment of a quarry has been identified within the

Ngquza Hill Local Municipality in the Eastern Cape Province. Accordingly, SANRAL is now proposing to

establish a quarry at this site. A description of the proposed quarry and associated activities is provided in

Section 4.2 below.

4.1. LISTED AND SPECIFIED ACTIVITIES

The EIA Regulations 2014 promulgated in terms of Chapter 5 of National Environmental Management Act

(NEMA), 1998 (Act 107 of 1998), and published in Government Notice (GN) No. R982, provides for the

control of certain listed activities1. These activities are listed in GN No. R983 (Listing Notice 1), R984

(Listing Notice 2) and R985 (Listing Notice 3) of 4 December 2014, and are prohibited until Environmental

Authorisation has been obtained from the competent authority. The Minister of Mineral Resources

remains responsible for the granting of Environmental Authorisation for Mining Right Applications in terms

of NEMA. Such Environmental Authorisation, which may be granted subject to conditions, will only be

considered once there has been compliance with GN No. R982 (as amended).

1 Subsequent to the distribution of the Draft EIA and EMPR Report for comment, the EIA Regulations 2014, Listing

Notices 1, 2 and 3 were amended by GN No. R.326, R.327, R 325, and R.324 of 7 April 2017, respectively. These

amendments have been duly taken into account in the compilation of this final report.


SLR Ref. 723.19083.00003 Report No.5


April 2017

Figure 3-1: Regional setting of the proposed quarry site.


SLR Ref. 723.19083.00003 Report No.5



GN No. R982 (as amended) sets out the procedures and documentation that need to be complied with

when applying for Environmental Authorisation. A Basic Assessment process must be applied to an

application if the authorisation applied for is in respect of an activity(ies) listed in Listing Notice 1 and / or

3 (as amended) and a Scoping and Environmental Impact Assessment (EIA) process must be applied to an

application if the authorisation applied for is in respect of an activity(ies) listed in Listing Notice 2 (as

amended).

The proposed project triggers various activities contained in Listing Notices 1, 2 and 3, as amended (see

Table 4-1), thus a full Scoping and EIA process must be undertaken in order for the Department of

Mineral Resources (DMR) to consider the application in terms of NEMA and make a decision as to

whether to grant or refuse Environmental Authorisation. Where applicable, the listed activities described in

Table 4-1 have been updated to incorporate the amendments included in GN No. R.327, R. 325, and R.324 of 7

April 2017.

Table 4-1: List of activities/infrastructure associated with the proposed project

NAME OF ACTIVITY

APPROXIMATE AERIAL EXTENT OF THE ACTIVITY

LISTED ACTIVITY NUMBER AND LISTING NOTICE, AS AMENDED

Construction of proposed access road to the quarry site.

“The development of -

(ii) infrastructure or structures with a physical footprint of 100 square

metres or more; where such development occurs -

(a) within a watercourse…”

Greater than

100 m2

GNR 983 (Activity 12

of Listing Notice 1)

“The development of a road wider than 4 metres with a reserve

less than 13.5 metres:

(a) In Eastern Cape:

ii. Within critical biodiversity areas identified in bioregional

plans… ”

Approximately

0.4 ha

GNR 985 (Activity 4 of

Listing Notice 3)

“The development of -

(ii) infrastructure or structures with a physical footprint of 10 square

metres or more;

where such development occurs -

(a) within a watercourse…


i. Outside urban areas, in:

(ff) Critical biodiversity areas or ecosystem service

areas as identified in systematic biodiversity

plans adopted by the competent authority or in

bioregional plans… ”

Greater than

100 m2



Fuel storage.

“The development of facilities or infrastructure, for the storage, or

for the storage and handling, of a dangerous good, where such

storage occurs in containers with a combined capacity of 80 cubic

metres or more but not exceeding 500 cubic metres.”

Approximately 2 ha



“The development of facilities or infrastructure for the storage, or

storage and handling of a dangerous good, where such storage

occurs in containers with a combined capacity of 30 but not

exceeding 80 cubic metres:


i. Outside urban areas, in:

(ee) Critical biodiversity areas as identified in systematic




SLR Ref. 723.19083.00003 Report No.5



NAME OF ACTIVITY

APPROXIMATE AERIAL EXTENT OF THE ACTIVITY

LISTED ACTIVITY NUMBER AND LISTING NOTICE, AS AMENDED

biodiversity plans adopted by the competent authority or

in bioregional plans;

(ii) Areas on the watercourse side of the development

setback line or within 100 metres from the edge of a

watercourse where no such setback line has been

determined…”

Establishment of the contractor’s camp and stockpiles.

“The infilling or depositing of any material of more than 10 cubic

metres into, or the dredging, excavation, removal or moving of soil,

sand, shells, shell grit, pebbles or rock of more than 10 cubic metres

from -

(i) a watercourse…”

Approximately 2 ha GNR 983 (Activity 19


Site clearance for the establishment of the proposed quarry

and associated infrastructure.

“The clearance of an area of 20 hectares or more of indigenous

vegetation…” 50 ha



“The clearance of an area of 300 square metres or more of

indigenous vegetation…


ii. Within critical biodiversity areas identified in bioregional

plans… ”



Operation of the proposed quarry.

“Any activity including the operation of that activity which requires a

mining right as contemplated in Section 22 of the Mineral and

Petroleum Resources Development Act, 2002 (No. 28 of 2002),

including –

(a) associated infrastructure, structures and earthworks, directly related

to the extraction of a mineral resource; or

(b) the primary processing of a mineral resource including winning,

extraction, classifying, concentrating, crushing, screening or

washing;…”

50 ha GNR 984 (Activity 17

Listing Notice 2)

Decommissioning of the mining activities following the

completion of mine operations.

“The decommissioning of any activity requiring -

(i) a closure certificate in terms of section 43 of the Mineral and

Petroleum Resources Development Act, 2002 (No. 28 of

2002); or

(ii) a …mining right… where the throughput of the activity has

reduced by 90% or more over a period of 5 years excluding

where the competent authority has in writing agreed that such

reduction in throughput does not constitute closure.”

50 ha GNR 983 (Activity 22



SLR Ref. 723.19083.00003 Report No.5



4.2. 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. Including associated structures and infrastructure.

4.2.1. PROJECT OVERVIEW

As noted above, SANRAL is proposing to establish a quarry to provide the necessary construction

materials for the Mthentu and Msikaba river bridges and other works on the N2 Wild Coast Toll Highway.

The proposed project would entail the establishment of a quarry, various associated stockpiles, a

contractor’s camp and an access road (see Figure 4-1). The total footprint of the area to be developed is

anticipated to be approximately 50 ha, with the proposed quarry being about 25 ha in extent.

The following key facilities associated with the contractor’s camp are currently planned:

• Offices:

• Ablution facilities;

• Workshop;

• Stores;

• Fuel storage;

• Concrete batching; and;

• Crushing and processing plant.

In addition to the required road within the confines of the quarry site, the proposed access road would link

the quarry to the Holy Cross – Mkambati road situated on the south-eastern boundary of the site.

4.2.2. QUARRY LAYOUT AND DEVELOPMENT

The proposed quarry could be either operated by a single operator or two operators simultaneously, thus

the site layout has been designed to make provision for two separate quarrying areas (Primary Quarry

and Secondary Quarry) that could be worked independently of each other. In the scenario that two

operators are involved, the Primary Quarry area would be worked by one operator along the east-west

face and the second operator would independently work the Secondary Quarry along the south-north

face.

The excavated material from each quarry area would then be processed by the crushing plant located on

the site. The processed material would be stockpiled and then loaded onto haul vehicles for transport to

the bridge construction and other sites. Material that is not suitable for use in the construction of the

bridges or other works would be stockpiled separately for use in the reshaping of the site during

rehabilitation. Where two operators are involved at the site, each operator would be responsible for the

rehabilitation of their respective operational areas (i.e. the separate Primary and Secondary quarry areas,

respectively), as well as their portion of the overall site.

Vegetation would be cleared from the site as the quarry is developed, with any seed-bearing material to

be kept separate for use during rehabilitation or preferably mulched into the topsoil. Topsoil would, where

possible, be stripped to an appropriate depth and stockpiled separately from other soil layers in piles not

exceeding 2 m in height.

To minimise any impacts on the surrounding land, the extent of the area disturbed during the operations

would be limited as far as possible. In this regard, the quarry and associated activities and infrastructure

would be carefully planned to ensure that the footprint is kept to a minimum and remains within the

confines of the site.


SLR Ref. 723.19083.00003 Report No.5


April 2017

Figure 4-1: Site plan of the proposed quarry.

CRUSHING PLANT

PRIMARY QUARRY

PRIMARY STOCKPILE

AREA

CONTRACTOR

CAMP

SECONDARY QUARRY

SECONDARY STOCKPILE

BACKUP

STOCKPILE


SLR Ref. 723.19083.00003 Report No.5



4.2.3. WASTE MANAGEMENT

Domestic waste generated during the course of the quarry operations would be collected and stored in

suitable receptacles on-site for collection and disposal at an appropriately licensed municipal waste site

or acceptable disposal facility.

4.2.4. WATER MANAGEMENT

It is anticipated that water would be required for dust suppression (on stockpiles and the access road)

and ancillary activities associated with the quarry operations (e.g. washing of vehicles and equipment).

The proposed source(s) and anticipated volumes required for the proposed project are not known at this

stage. The Contractor(s) to be appointed for the operation of the quarry would be responsible for



4.2.5. TRANSPORT

As mentioned above, it is proposed that an access road would be established to link the proposed quarry

site with the Holy Cross - Mkambati Road. The proposed access road would cross a watercourse. The

project engineer has recommended that the proposed water crossing be a low-level river crossing

structure comprising five box culverts and positioned at the centre of the river. It was further

recommended that the road section located to the east of the river crossing be surfaced with concrete,

while the road section to the west of the river could be a gravel surface. The proposed access road would

facilitate the transport of material by truck from the site to the bridge construction and other areas.

5. POLICY AND LEGISLATIVE CONTEXT

An overview of the key legislative requirements applicable to the proposed project is provided below.

5.1. LEGISLATIVE REQUIREMENTS

5.1.1. OVERVIEW OF THE “ONE ENVIRONMENTAL SYSTEM”

The “One Environmental System” commenced on 8 December 2014, removing the environmental

regulation of prospecting, mining, exploration and production and related activities from the Mineral and

Petroleum Resources Development Act, 2002 (No. 28 of 2002) (MPRDA) and transferring it to NEMA.

Under the “One Environmental System”, the Minister of Mineral Resources (or delegated authority) is the

competent authority responsible for issuing Environmental Authorisations in terms of NEMA for mining

and petroleum related activities. The Minister of Environmental Affairs, however, remains the appeal

authority for these authorisations.

5.1.2. MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA)

In terms of the MPRDA, a Mining Right must be obtained prior to the commencement of any mining

activities.


SLR Ref. 723.19083.00003 Report No.5



A requirement for obtaining a Mining Right is that an applicant must submit an application in terms of

Section 22(1) of the MPRDA to the Regional Manager, who must accept the application within 14 days if,

inter alia, no other person holds a Prospecting Right, Mining Right, Mining Permit or Retention Permit for

the same mineral and land. If the application for a Mining Right is accepted, the Regional Manager must

request that the applicant comply with Chapter 5 of NEMA with regards to consultation and reporting (see

Section 5.1.3 below).

It is noted that in terms of Section 106 of the MPRDA, SANRAL is exempted from applying for a Mining

Right to develop a quarry for the purposes of sourcing road building material. However, SANRAL is still

required to obtain Environmental Authorisation in terms of NEMA. In this regard, SANRAL lodged an

Application for Environmental Authorisation with the DMR on 5 September 2016. DMR accepted the

application on 10 October 2016 (see Appendix 2).

5.1.3. NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (NEMA)

Section 2 of NEMA sets out a range of environmental principles that are to be applied by all organs of

state when taking decisions that significantly affect the environment. Included amongst the key principles

is that all development must be socially, economically and environmentally sustainable and that

environmental management must place people and their needs at the forefront of its concern, and serve

their physical, psychological, developmental, cultural and social interests equitably. NEMA also provides

for the participation of Interested and Affected Parties (I&APs) and stipulates that decisions must take into

account the interests, needs and values of all I&APs.

Chapter 5 of NEMA outlines the general objectives and implementation of Integrated Environmental

Management (IEM), which provides a framework for the integration of environmental issues into the

planning, design, decision-making and implementation of plans and development proposals. Section 24

provides a framework for granting of Environmental Authorisations. In order to give effect to the general

objectives of IEM, the potential impacts on the environment of listed activities must be considered,

investigated, assessed and reported on to the competent authority. Section 24(4) provides the minimum

requirements for procedures for the investigation, assessment and communication of the potential impact

of activities. A summary of the EIA Regulations 2014, as amended, and an outline of the identified listed

activities which are triggered in terms of these regulations are provided in Section 4.1 above.

5.1.4. NATIONAL WATER ACT, 1998 (NWA)

The National Water Act, 1998 (No. 36 of 1998) (NWA) provides a legal framework for the effective and

sustainable management of water resources4 in South Africa. It serves to protect, use, develop,

conserve, manage and control water resources as a whole, promoting the integrated management of

water resources with the participation of all stakeholders. In terms of this Act, all water resources are the

property of the State and the Scoping and EIA process is used as a fundamental management tool.

A Water Use Licence is required for any new water use that is not listed in Schedule 1 or that is not

covered by a General Authorisation. Water uses that may require Water Use Licensing or General

Authorisation are listed in Table 5-1. A Water Use Licence Application (WULA) would need to be

submitted to the Department of Water and Sanitation (DWS) Eastern Cape Regional Office for approval, if

these activities are not considered to be Generally Authorised.

4 A water resource includes a watercourse, surface water, estuary or aquifer, and, where relevant, its bed and banks. A

watercourse means a river or spring; a natural channel in which water flows regularly or intermittently; a wetland, lake or dam, into which or from which water flows; and any collection of water that the Minister may declare to be a watercourse.


SLR Ref. 723.19083.00003 Report No.5



The terrestrial and aquatic ecosystems specialist deems that a WULA for the water use activities

specified in Table 5-1 below, at a minimum, would be required for the proposed quarry as the risk of

altering the characteristics of downstream watercourses may be deemed Moderate (even with

appropriate mitigation) according to the DWS Risk Matrix/Assessment method applied to the project.

In terms of the recent General Authorisation (GA) Regulations (GN No. 509 of 26 August 2016),

published in terms of Section 39 of the NWA for Section 21(c) and/or (i) water use, a number of activities

are Generally Authorised for State Owned Companies (SOC’s) and institutions. These activities are then

subject only to compliance with the conditions of the GA, including “all maintenance of bridges over rivers,

streams and wetlands and the new construction of bridges done according to the SANRAL Drainage

Manual or similar norms and standards”. Thus, it is deemed that SANRAL would not be required to apply

for a WULA for the proposed access road over the KwaDlambu River, as it would be authorised under the

GA, subject to compliance with the necessary conditions.

Furthermore, as mentioned in Section 4.2.4 above, the Contractor(s) to be appointed for the operation of

the quarry would be responsible for determining suitable water sources and obtaining any permits, licence

and/or authorisations which may also be applicable for the abstraction of water from these sources, as

appropriate.

Table 5-1: List of possible water use activities in terms of the NWA.

Water

Use No. Water Use Description

Description of the water use in relation to the proposed

project

21(c) Impeding and diverting the flow of

water in a watercourse

The establishment of the proposed quarry may impact on water

resources within the project site and surrounds. In addition, the

proposed access road would pass through a watercourse

located on the eastern boundary of the site. These project

components may require the impeding of water and / or altering

of the bed and banks of the watercourse. 21(i)

Altering the bed, banks, course or

characteristics of a watercourse

5.1.5. NATIONAL HERITAGE RESOURCES ACT, 1999 (NHRA)

Section 38(1) of the National Heritage Resources Act (NHRA) (No. 25 of 1999) lists development

activities that would require authorisation by the responsible heritage resources authority. The activity

applicable to the proposed project is the following:

“(c) Any development or other activity which will change the character of a site: (i) exceeding

5 000 m2 in extent.”

The NHRA requires that a person who intends to undertake a listed activity must notify the relevant

heritage authority at the very earliest stages of initiating such a development. The relevant heritage

authority would then, in turn, notify the person whether a Heritage Impact Assessment Report should be

submitted. However, according to Section 38(8) of the NHRA, a separate report would not be necessary

if an evaluation of the impact of such development on heritage resources is required in terms of any other

applicable legislation. The decision-making authority should, however, ensure that the heritage evaluation

fulfils the requirements of the NHRA and take into account in its decision-making any comments and

recommendations made by the relevant heritage resources authority.

In terms of Section 34(1) of the Act, no person may, without a permit issued by the responsible heritage

resources authority, alter or demolish any structure or part of a structure which is older than 60 years.


SLR Ref. 723.19083.00003 Report No.5



Also, in terms of Section 35(4) of the Act, no person may, without a permit issued by the responsible

heritage resources authority, destroy, damage, excavate, alter or remove from its original position, or

collect, any archaeological material or object.

Furthermore, some grave sites are associated with existing residences within the proposed quarry site. In

terms of Section 36(3) of the Act, no person may, without a permit issued by the responsible heritage

resources authority, destroy, damage, alter, exhume or remove from its original position or otherwise

disturb any grave or burial ground older than 60 years, which is situated outside a formal cemetery

administered by a local authority. Human remains that are less than 60 years old are subject to provisions

of the Human Tissue Act 1983 (No. 65 of 1983) and any other applicable local regulations.

The specialist heritage study has been undertaken in compliance with the NHRA as required and will be

lodged with the Eastern Cape Provincial Heritage Resources Authority (ECPHRA) as the competent

heritage authority.

5.1.6. NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT, 2004

(NEM:BA)

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

the management and conservation of South Africa’s biodiversity and the protection of species and

ecosystems that warrant national protection.

NEM:BA regulates the carrying out of restricted activities that may harm listed threatened or protected

species or activities that encourage the spread of alien or invasive species subject to a permit. The list of

restricted activities relate to the keeping, moving, having in possession, importing, exporting and selling of

species. NEM:BA also makes provision for the publication of bioregional plans and the listing of

ecosystems and species that are threatened or in need of protection. Threatened or Protected Species

Regulations (2007), Guidelines for the Determination of Bioregions and the Preparation and Publication of

Bioregional Plans (2009) and a National List of Ecosystems that are Threatened and in Need of

Protection (2011) have been promulgated in terms of NEM:BA.

Within the published bioregional (spatial) plans, terrestrial and aquatic features that are critical for

conserving biodiversity and maintaining ecosystem functioning are indicated as Critical Biodiversity Areas

(CBAs). Bioregional plans thus provide the guidelines for avoiding the loss or degradation of natural

habitat in CBAs with the aim of informing EIA processes and land-use planning (including Environmental

Management Frameworks (EMFs), Spatial Development Frameworks (SDFs), and Integrated

Development Plans (IDPs)). CBAs mapped in terms of the Eastern Cape Biodiversity Conservation Plan

are discussed in Section 8.1.4.

5.2. GUIDELINES AND POLICIES

The guidelines and policies listed in Table 5-2 have been taken into account during the Scoping and EIA

process.


SLR Ref. 723.19083.00003 Report No.5



Table 5-2: Guidelines and policies relevant to the proposed project.

Guideline Governing

body Applicability

Scoping, Integrated Environmental Management,

Information Series 2 (2002) DEA

This guideline was consulted to obtain

guidance on how to implement scoping.

Stakeholder Engagement, Integrated Environmental

Management, Information Series 3 (2002) DEA

These public participation guidelines

were consulted to ensure that an

adequate public participation process

was undertaken. IEM Guideline Series (Guideline 7): Public participation in

the EIA process (2012)

Specialist Studies, Integrated Environmental Management, Information Series 4 (2002)

DEA

This guideline was consulted to ensure

adequate development of terms of

reference for specialist studies.

Impact significance, Integrated Environmental

Management, Information Series 5 (2002) DEA

This guideline was consulted to inform

the assessment of significance of

impacts of the proposed project.

Cumulative Effects Assessment, Integrated

Environmental Management, Information Series 7 (2004) DEA

This guideline was consulted to inform the consideration of potential

cumulative effects of the proposed

project.

Criteria for determining Alternatives in EIA, Integrated

Environmental Management, Information Series 11

(2004)

DEA This guideline was consulted to inform

the consideration of alternatives.

Environmental Management Plans, Integrated

Environmental Management, Information Series 12

(2004)

DEA

This guideline was consulted to ensure

that the Environmental Management

Programme (EMPR) has been

adequately compiled.

IEM Guideline Series (Guideline 9): Guideline on Need

and Desirability (2014) DEA

This guideline was consulted to inform

the need and desirability aspects of the proposed project.

6. NEED AND DESIRABILITY OF THE PROPOSED PROJECT Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location

As noted previously, the proposed quarry is required for the sourcing of materials to facilitate the

construction of the Mthentu and Msikaba river bridges and other works associated with the proposed N2

Wild Coast Toll Highway. The rationale for the N2 Wild Coast Toll Highway project is to provide an

improved, shorter and safer road link between the Eastern Cape/Western Cape and KwaZulu-Natal and

is considered of strategic importance to the region and the country as a whole. Given that large volumes

of construction materials would be required for the project, the development of a local source for this

material is considered to be highly beneficial.

It is deemed that obtaining the required quality of material from commercial sources would be expensive,

as the closest commercial sources are located a considerable distance (up to 200 km away) from the

bridge construction areas. Substantial cost savings would accrue to the project by eliminating the cost of

transportation of large volumes of material from existing commercial sources. Added advantages for the

establishment of a local source of material include avoiding negative impacts on road safety of the

surrounding road network by the presence of haul vehicles and reducing air pollution emissions from haul

trucks by reducing haul distances.

On completion of the N2 Wild Coast Highway construction, it is possible that the local community may

take ownership of the quarry site. The final use of the quarry site, and the related closure objectives, will

be determined in consultation with the local communities via the SANRAL-appointed land management

specialist.


SLR Ref. 723.19083.00003 Report No.5



7. MOTIVATION FOR THE PREFERRED DEVELOPMENT

FOOTPRINT WITHIN THE APPROVED SITE INCLUDING THE

PROCESS FOLLOWED TO DEFINE THE PREFERRED

DEVELOPMENT ALTERNATIVES

7.1. DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED

7.1.1. PROPERTY ON WHICH OR LOCATION WHERE IT IS PROPOSED TO

UNDERTAKE THE ACTIVITY

According to the design engineer, the primary rationale behind the selection of the preferred site

alternative relate to the area available to establish the proposed quarry, topography, level of existing

development, and availability and quantity of suitable material. The locality of the identified alternative

quarry sites which were investigated by the design engineer are illustrated in Figure 7-1 overleaf.

The preferred site alternative is considered to be sufficiently large to allow for the stockpiling of material,

as well as the establishment of the contractor’s camp and placement of crushing equipment (previous

experience has shown that for a project of this nature, an area in excess of 40 ha is required). Secondly,

the site has a topography suitable for quarry development and is relatively undeveloped (in comparison to

other potential quarry sites identified). Lastly, the laboratory test results undertaken have indicated that

the Dwyka Formation tillite underlying the site is considered suitable for use as fine and coarse concrete

aggregate. The rationale for the exclusion of other possible alternative sites which were investigated is

provided in Table 7-1.

Table 7-1: Potential alternative quarry sites initially investigated for development (the

preferred site is shaded).

Site Material

Source

Latitude Longitude Suitability

SQ1 Dwyka

Formation

Tillite

31°11'51.06"S 29°49'7.83"E This site is considered to be the most suitable for the

following reasons:

• The site is relatively undeveloped;

• There is a large enough area to undertake the

proposed quarry operations;

• There is sufficient quantities of unweathered

rock available;

• The site is relatively close to both bridge

construction sites (within 15km) and other

works.

SQ2 Dwyka

Formation

Tillite

31°12'7.36"S 29°47'31.91"E While the site is possibly suitable (given it is located

close to both bridge construction sites and suitable

material is present) it is currently not preferred due

to:

• Insufficient space to incorporate all activities

associated with the quarry operations; and

• The topography of the site would make

quarrying difficult and costly.

However, it is possible that SANRAL may wish to

establish an additional quarry at this site in the

future. A separate environmental authorisation


SLR Ref. 723.19083.00003 Report No.5



Site Material

Source

Latitude Longitude Suitability

process will then be undertaken in this regard.

NQ6 Dwyka

Formation

Tillite

31° 4'22.59"S 29°57'0.32"E Establishing a quarry on this site is not considered

feasible due to:

• Space constrains; and

• Close proximity to a school.

Flagstaff Karoo

Dolerite


possible due to:

• The large haul distance to the bridge

construction sites (greater than 50 km); and

• An Eskom substation has recently been

constructed on the site.

Holy Cross Karoo

Dolerite


possible due to:

• The large haul distance to the bridge

construction sites (greater than 50 km); and

• An extensive layer (30 m deep) of poor quality

overburden overlaying the required source

materials.

Mtonjeni Msikaba

Formation

Sandstone

31°13'15.42"S 29°51'35.17"E The availability of suitable materials has not yet been

confirmed at this site. Thus, the site cannot be

considered at this stage.

Mtentu

South

Approach

Msikaba

Formation

Sandstone

31°11'18.67"S 29°55'43.85"E Establishing a quarry on this site is not considered

possible as the quality of the source material is sub-

standard.

Mtentu North

Approach

Msikaba

Formation

Sandstone



standard.

Msikaba

South

Approach

Msikaba

Formation

Sandstone



standard and not available in sufficient quantities.

Msikaba

North

Approach

Msikaba

Formation

Sandstone



standard.

Mahana Msikaba

Formation

Sandstone

31° 9'29.55"S 30° 1'32.15"E Establishing a quarry on this site is not considered


standard.

Makwateni Msikaba

Formation

Sandstone



standard.

Mpetsheni Karoo

Dolerite


possible due to:

• The presence of excessive overburden; and

• The quantity of available material is inadequate.

Telawayeka Dwyka

Formation

Tillite


possible as the local communities denied access to

the site for physical testing.

Mtontsasa Karoo

Dolerite

31°13'32.40"S 29°41'24.05"E The availability of suitable materials has not yet been

confirmed at this site. Thus, the site cannot be

considered at this stage.


SLR Ref. 723.19083.00003 Report No.5


April 2017

Figure 7-1: Google Earth Image of the identified alternative sites for the proposed quarry (the preferred alternative is shaded red).


SLR Ref. 723.19083.00003 Report No.5



7.1.2. TYPE OF ACTIVITY TO BE UNDERTAKEN

No alternatives pertaining to the type of activity to be undertaken have been considered for the proposed

project.

7.1.3. DESIGN OR LAYOUT OF THE ACTIVITY

The preferred layout of the proposed quarry site has been informed by the outcomes of the public

participation process and site sensitivity investigations undertaken as part of the Scoping Process.

Based on the original layout presented in the Scoping Report, the terrestrial and freshwater ecosystems

specialist recommended that the quarry layout should be revised in order to take into account the location

and extent of the proposed aquatic buffer zones associated with wetlands and riparian areas located on

the site. The specialist recommended a variable aquatic buffer zone width of between 18 m and 40 m,

based on the sensitivity of each receiving watercourse. The recommendations of the specialist have been

taken into consideration by the project engineer and the layout of the proposed quarry has been revised

accordingly (refer to Figure 4-1).

With respect to the proposed access road crossing over the KwaDlambu River, three possible

configurations of the low-level crossing structure were designed by the project engineer:

• a 3-cell structure with each cell measuring 3.6m wide x 3.6m high and a total length of 10.8 m;

• a 4-cell structure with each cell measuring 3.0m wide x 3.0m high and a total length of 12 m; and

• a 5-cell structure with each cell measuring 5.0m wide x 2.0m high and a total length of 25 m.

The project engineer has indicated that the 3-cell and 4-cell structures would require large quantities of fill

and excavation at the approach roads leading to the river. However, the 5-cell structure can be designed

as a culvert under fill or as a low-level river crossing and would therefore require the least amount of cut

and fill at the approach road sites.

The terrestrial and freshwater ecosystems specialist noted that the 3-cell structure would be narrower

than the active channel of the river. Thus, it is anticipated that this structure would concentrate flows and

increased flow velocities within the river channel. This may result in scouring and possible long-term

channel incision. Furthermore, the 3-cell structure would require infilling of the river to elevate the road

infrastructure well above the high-water mark. Similar impacts are anticipated from the 4-cell structure,

albeit of less intensity. As the 5-cell structure would span the entire width of the active channel, it would

maintain spread flows, channel width and limit the risk of scouring below the structure. In light of the

engineering and environmental suitability highlighted above, the 5-cell structure is the preferred road

crossing structure for the proposed project.

7.1.4. TECHNOLOGY TO BE USED IN THE ACTIVITY

No other alternatives pertaining to alternative technologies to be used in the operation of the proposed

quarry have been considered for the proposed project.


SLR Ref. 723.19083.00003 Report No.5



7.1.5. OPERATIONAL ASPECTS OF THE ACTIVITY

As noted in Section 4.2.2 above, the proposed quarry could be either operated by a single operator or two

operators simultaneously. Accordingly, the site layout has been designed to make provision for two

separate quarrying areas (Primary Quarry and Secondary Quarry) that could be worked independently of

each other. The nature of the potential impacts associated with the proposed project are not anticipated

to be materially different should the quarry be operated by a single operator or by two operators

simultaneously. Where two operators are involved at the site, each operator would be responsible for the

rehabilitation of the area they operated in (i.e. the separate Primary and Secondary quarry areas), as well

as their portion of the overall site.

7.1.6. OPTION OF NOT IMPLEMENTING THE ACTIVITY

The option of not implementing the activity is referred to as the No-Go alternative. In this scenario, the

potential impacts assessed in Section 8.2 would not materialise. The implications of the No-Go alternative

would also include, amongst others, the following:

• The direct economic benefits associated with the quarry operation for sourcing of material for the

construction of the bridges and other works associated with the N2 Wild Coast Toll Highway would

be lost. Furthermore, any possible indirect economic benefits of the quarry operation (related to

the procurement of goods and services and the spending power of employees) would also be lost;

and

• In the event that construction materials would have to be obtained from commercial sources, there

would be other potential negative impacts associated with the movement of heavy haul vehicles

over large distances on the surrounding provincial and national road network (e.g. damage to roads

from heavy loads, road safety and air pollution).

The No-Go alternative is assessed in detail in Section 8 of the report.

7.2. 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.

7.2.1. SCOPING PHASE

The Scoping Phase (including the compilation of the Scoping Report) complied with the requirements of

NEMA and the EIA Regulations 2014, as set out in GN No. R982 (as amended). This involved a process of

notifying I&APs of the proposed project and EIA process in order to ensure that all potential key

environmental impacts, including those requiring further investigation, were identified.

The Scoping Phase also included a pre-application public participation process. Although this is not a

legislated requirement of the EIA Regulations 2014, it provided an opportunity to notify I&APs of the

proposed project and to raise any initial issues or concerns regarding the proposed quarrying activities.


SLR Ref. 723.19083.00003 Report No.5



The steps / tasks undertaken during the Scoping Phase are summarised in Box 7.1.

The Scoping Report was accepted by DMR on 14 December 2016 (see Appendix 2). DMR’s acceptance

of the Scoping Report stated that the next phase of the EIA may proceed as outlined in the Plan of Study

for EIA, which was appended to the Scoping Report.

Box: 7.1: Tasks undertaken during the Scoping Phase.

The Scoping Phase public participation process involved the following:

• An initial consultation meeting was held with Chief Khanyayo on 25 July 2016 to provide preliminary

background information regarding the proposed project and to confirm the preferred approach to be followed

for the public participation process going forward.

• Following the compilation of the Scoping Report, a formal notification letter was distributed to potential

Interested and Affected Parties (I&APs), a notice was erected on site and media advertisements were placed

in the Uvo Lwethu (previously known as The Fever) and The Daily Dispatch newspapers on 8 September

2016.

• The purpose of the notification letter, site notice, and newspaper advertisements was to convey information

on the proposed project, to invite I&APs to register on the project database and provide notice that the

Scoping Report was released for a 30-day review and comment period from 5 September to 6 October 2016.

Copies of the report were made available at the following locations:

o Flagstaff Public Library, Clubhouse, Flagstaff;

o The residence of Chief Khanyayo, Khanyayo Village;

o Cape Town offices of SLR; and

o On the SLR website (www.ccaenvironmental.co.za).

• A public meeting was held during the above-mentioned registration and comment period at the residence of

Chief Khanyayo, Khanyayo Village on 13 September 2016 at 11h00.

• A total of five written submissions were received during the above-mentioned review and comment period.

The submissions were collated and responded to in the Comments and Responses Report and attached to

the final Scoping Report which was submitted to the DMR for consideration and acceptance on 26

September 2016. A summary of the issues raised by I&APs is provided in Section 7.2.3.

• The Scoping Report was accepted by DMR on 14 December 2016 (see Appendix 2).

7.2.2. EIA PHASE

The Draft EIR and EMPR was distributed for a 30-day comment period from 17 March to 19 April 2017 (taking into

account the three public holidays during this period) in order to provide I&APs with an opportunity to comment on

any aspect of the proposed project and the findings of the EIA process. The public participation tasks undertaken

during this phase are summarised in Box 7.2 and all supporting information is presented in appendices to this report

(Appendix 3.1 to 3.4).

Box: 7.2: Tasks undertaken during the EIA Phase.

1. Draft EIR and EMPR availability

Copies of the Draft EIR and EMPR were made available at the following locations for the duration of the review and

comment period (17 March to 19 April 2017):

• Flagstaff Public Library, Clubhouse, Flagstaff;

• The residence of Chief Khanyayo, Khanyayo Village;

• Cape Town offices of SLR; and

• On the SLR website (www.slrconsulting.com).


SLR Ref. 723.19083.00003 Report No.5



Box: 7.2: Tasks undertaken during the EIA Phase (continued).

2. I&AP notification

A notification of the availability of the Draft EIR and EMPR for review and comment was sent to all I&APs registered on the

project database via sms or email. The notification also informed them of where the report could be accessed and reviewed.

Copies of the report were also sent directly to the following key authorities (see Appendix 3.2 for letters and proof of

distribution):

No. Organisation Contact Person

1. Department of Agriculture, Forestry and Fisheries Ms G. Sgwabe

2. Department of Environmental Affairs: Biodiversity and Conservation Directorate Mr S. Tshitwamulomoni

3. Eastern Cape Department of Economic Development and Environmental Affairs Regional Director

4. Department of Rural Development and Land Reform Ms N. Tamba

5. Department of Roads and Public Works Mr K. Tyali

6. Department of Water and Sanitation Ms P. Makhanya

7. Eastern Cape Provincial Heritage Resources Authority Ms A. Maxonga

8. Eastern Cape Parks and Tourism Agency Ms B. Geach

9. Ngquza Hill Local Municipality Mr M. Fihlani

10. OR Tambo District Municipality Mr O. Hlazo

3. Comments received on the Draft EIR and EMPR

One verbal and two written submissions were received during the review and comment period. Comments

received from I&APs on the Draft EIR and EMPR have been collated into a Comments and Responses Report

and appended to this final report. An updated summary of the issues raised by the I&APs is provided in Section

7.2.3 overleaf (this includes correspondence from the Department of Water and Sanitation which was received

following the submission of the Final Scoping Report and prior to the release of the Draft EIR and EMPR for

comment).


SLR Ref. 723.19083.00003 Report No.5


April 2017

7.2.3. SUMMARY OF ISSUES RAISED BY I&APS

Interested and Affected Parties

Date Received Issues raised EAPs response to issues

Section of

report

Other Affected Parties

Mxolisi Magadikiti 13 September

2016

Construction vehicles driving past pedestrians walking alongside

the roads at high speed. This is dangerous and causes dust which

affects people’s eyes and health.

Measures to regulate vehicle usage on site, and in the surrounding

area, have been included in the Environmental Management

Programme (EMP) for the construction and operational phases. All

contractors appointed by SANRAL for the proposed project will be

required to comply with the recommendations of the EMP during the

construction and operational phases.

Appendix 6

Sonwabile Jama

Chief Khanyayo

Khanyayo

Traditional Council

13 September

2016

The Khanyaho Traditional Council is satisfied with the

environmental assessment and consultation process undertaken

thus far and have read, reviewed and understood the proposed

project description and the implications thereof for our community.

We hereby extend our support through this letter for the project

and officially indicate that we have no objection to the project in

principle. We also confirm that our no-objection applies to all

projects or activities to be implemented within the scope of the

project subject to certain conditions.

The letter of no-objection has been noted and acknowledged.

N/A

Mxolisi Magadikiti 13 September

2016

I would like to know what criteria SANRAL will be using to uplift the

local community from this project.

An assessment of the potential negative and positive impacts

associated with the proposed project, as appropriate, has been

provided in Section 8.2 of the EIR.

It is anticipated that appropriate targets for employment and training

of local persons from the local community would be incorporated into

the conditions of the contract to operate the proposed quarry.

Section 8.2

Simphiwe Kaqa 13 September

2016

I am not from the Khanyayo village, but I would like to see this

community uplifted socially and economically.

Mxolisi Magadikiti 13 September 2016

We would like to request that SANRAL take the youth and train them so that they are not excluded from the job opportunities

because of lack of experience and qualifications.

Dlamini Mbikwa 13 September

2016

The people are saying this project is only for the benefit of the

residents of the Khanyayo village but this meeting was advertised in the newspaper so anyone should be allowed to benefit from this project.

Mam’ Mthembu 13 September 2016

Thank you for clarifying that even though people will not be getting jobs today, there are such plans in the future for this community. But please do not delay!

These comments are noted.

N/A Simlindiwe 13 September

2016 We understand that this is the initial stage of this project, however please do not delay. Let us open that quarry because we need jobs.


SLR Ref. 723.19083.00003 Report No.5


April 2017



Section of

report

Xolisile Skhonza 13 September 2016

We have heard that some homes will be relocated. We would like to get a clear understanding of which homes will be moved.

SANRAL has appointed a land management specialist which will undertake a separate process with the traditional council and

community in terms of the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996) and will liaise directly with the Department of Rural Development and Land Reform, as required in

this regard.

N/A

Sebitso Thoka, Department of Rural

Development and Land Reform

8 September 2016

Please note that the proposed development is governed by the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of

1996), and one of the apex requirements is that you should make an application to the Department of Rural Development and Land Reform (DRDLR) requesting disposal of land tenure rights since

the Minister; Hon G Nkwinti is the custodian. Such projects should benefit the land rights holders and the Government at large in fighting the triple challenges facing by our communities i.e.

unemployment, inequality and poverty. Having said that, please find the attached documents to familiarise yourself with and the requirements thereof. And please note that there is no prescribed

application form to be used, just draft a normal application on your company’s letterhead.

Sonwabile Jama

Chief Khanyayo

Khanyayo Traditional

Council

16 March 2017 The traditional council and the people of Khanyayo village would like to

make it clear that no construction shall commence before the following

conditions have been met:

1. People living on the proposed quarry area are to be relocated and

new houses are to be built for the affected families (dates of these

activities to be supplied to the traditional council)

2. Graves are to be relocated prior to any construction activities (dates

of these activities to be supplied to the traditional council)

3. A fence surrounding the quarry area is to be constructed as soon as

possible (dates to be supplied to the traditional council)

These comments are noted.

N/A

Charmaine Jasmin 19 April 2017 I would like to raise my OBJECTION in the manner in which SANRAL

has conducted itself with regard to the quarry. Whilst we have no

objection to the highway being built, we object to the manner in which

SANRAL started this EIA process from the onset!

This objection is noted.

N/A

Last year’s meeting (where SANRAL presented to the community a

notice for an EIA for the Quarry) we were lead to believe that it was a

meeting to let the community know what opportunities were available to

them, and not one to discuss the matter of the quarry! Not having been

aware that the quarry was going to be discussed, deprived us of the

opportunity to raise pertinent questions.

The purpose of the public meeting (held at the residence of Chief

Khanyayo, Khanyayo Village on 13 September 2016 at 11h00) during the

Scoping Phase was to, amongst others, convey information on the proposed

project, invite I&APs to register on the project database and provide notice

that the Scoping Report was released for a 30-day review and comment

period. The public meeting provided an additional opportunity for I&APs to

raise any queries or concerns they may have had regarding the proposed

project. I&APs were also invited to provide written submissions during the

review and comment periods for the Draft Scoping and Draft EIR and

EMPR reports.

Section 7.2.1


SLR Ref. 723.19083.00003 Report No.5


April 2017



Section of

report

Charmaine Jasmin 19 April 2017 What are SANRAL's plans around the management, ownership and

operations with regard to the quarry? Whether local business people

would be given an opportunity to participate in these ventures and be

empowered by the skills transfer that these opportunities bring, so once

the road is constructed, the quarry can continue operating?

Currently the access roads are being constructed, and we are of the

opinion that the allocation of work seems to be already predetermined!

It is anticipated that either one or two contractors would be appointed to

operate and manage the proposed quarry operations. The appropriate targets

for employment and training of local persons from the local community

would be incorporated into the conditions of the contract to operate the

proposed quarry. On completion of the N2 Wild Coast Toll Highway

construction, it is possible that the local community may take ownership of

the quarry site. The final use of the quarry site, and the related closure

objectives, will be determined in consultation with the local communities

via the SANRAL-appointed land management specialist.

Section 4.2.1

of EIR and

Section 4 of

the EMPR

Organs of State

M.R. Dinga

Deputy Director

(Acting): Forestry

Regulation and

Support Eastern

Cape

10 October 2016 I think it would have been appropriate to include the National

Forests Act, 1998 (No. 84 of 1998) (NFA) amongst the legislations

to be considered. The inclusion of the NFA in the legislation to be

considered is also supported by the mention of the possible

clearance of an area of 20 hectares or more of indigenous

vegetation. Nevertheless it is hoped that the impact and clearance

mentioned will not affect a natural forest because if that would be

the case, then NFA will have to be considered and be included in

the legislations that have been considered when the report was

being compiled. Lastly an authorisation from DAFF would have to

be applied for, in the normal procedure if the flora under

consideration is a natural forest.

The findings of the baseline specialist aquatic and terrestrial

ecosystems investigation indicated that there are no natural forest

areas located within the study area. Thus, it is deemed that no

authorisation from DAFF needs to be applied for.

Section 8.1

Mr Lonwabo Mini

Department of Water

and Sanitation

Mzimvubu to

Tsitsikamma Proto-

CMA

Water Use Catchment

Regulation

31 October 2016 The Department of Water and Sanitation has no objections to the

proposed activity provided the following are adhered to that:

1. Water abstraction from water courses or boreholes and Section 21

water uses need to be authorized by this Department,

3. All activities carried out should comply with the requirements of the

National Water Act (Act 36 of 1998) and other related legislation.

4. No prospecting mining activity should occur in close proximity to a

water resource or within the 1:100 year flood line.

The necessary water use authorisation requirements applicable to the

project are discussed in Section 5.1.4 above.

Section 5.1.4

5. Confine any polluted water systems away from the clean water

systems. Collect water arising within any dirty area, including water

seeping from mining operations, outcrops or any other activity, into

a dirty water system.

6. Design, construct, maintain and operate any dirty water system at the

mine or activity so that it is not likely to spill into any clean water

system more than once in 50 years.

7. Silt fences should be used to prevent soil eroding from nearby

It has been recommended that a detailed Stormwater Management Plan be

developed for the project. The Stormwater Management Plan must describe

how the design measures of surface and near-surface water management

facilities will be designed, constructed and operated so that contaminated

water is kept separate from clean water run-off through a system of berms,


Section

8.2.1.3


SLR Ref. 723.19083.00003 Report No.5


April 2017



Section of

report

mining activities reaching watercourses.

5. Design, Construct, Maintain and Operate any dam or tailings dam

that forms part of a dirty water system to have a minimum freeboard

of 0.8 metres above full supply level.

The proposed project will not entail the construction of any dams. N/A

7. Solid waste should be disposed of at a licensed waste disposal site.

8. All procedures and equipment used must be in accordance with the

Occupational Health and Safety Act & Regulations of South Africa.

9. The developer must exercise suitable precautions with the storage,

handling and transport of all materials that could adversely affect the

environment. Such precautions may include the use of bund walls. If

pollution of any surface or groundwater occurs, it shall immediately

be reported to this Department and appropriate mitigation measures

must be employed.

10. Storage of material, chemicals, fuels, etc. must not pose a risk to the

surrounding environment and this includes surface and groundwater.

Such storage areas must be located outside the 1:100 year floodline

of any watercourse and must be fenced to prevent unauthorised

access into the area.

11. Temporary bund walls must also be constructed around chemical or

fuel storage areas to contain possible spillages. The floor and wall of

the bund area must be impervious to prevent infiltration of any

spilled/leaked fuel, oil or hazardous substance into the soil.

12. Within 6 months of the storage tanks ceasing to be functional for the

purpose for which they have been authorised, they must be removed

and the site including all associated infrastructure must be

rehabilitated.

13. Notwithstanding the above, the responsibility rests with the

applicant to identify any sources or potential sources of pollution

from his undertaking and to take appropriate measures to prevent

any pollution of the environment.

15. Chemical toilets should be:

o Placed outside areas susceptible to flooding.

o Maintained in a sound, clean sanitary condition free of insects,

overflowing, leakages and other harmful conditions.

o Not create public health hazard or nuisance.

o Waste water from chemical toilets should not be discharged to a

water resource. If not going to be used for a long time, empty

and keep clean.

The recommended environmental management measures to be

implemented during the construction and operational phases of the

proposed project are provided in the EMP (see Appendix 6).

Appendix 6


SLR Ref. 723.19083.00003 Report No.5


April 2017



Section of

report

S. Songca

Eastern Cape

Department of

Economic

Development,

Environmental Affairs

and Tourism

19 April 2017 The KwaDlambu is a very important tributary of the Msikaba River. It is

of note that there are various plant endemics which are found on the

banks of the KwaDlambu. Therefore, one must make sure that such plants

are not disturbed by quarry mining operations.

The aquatic and terrestrial ecology specialist has recommended that a

protected plant survey be undertaken in order to confirm the presence and

abundance of threatened and protected plant species. The survey would be

used to develop a detailed protected plant rescue and translocation protocol

for any threatened and protected species identified within the project

footprint.

Section

8.2.1.2

Notwithstanding the above, an alternative site suitable for this activity

might be useful.

The primary rationale for the selection of the preferred site alternative relate

to the area available to establish the proposed quarry, topography, level of

existing development, and availability and quantity of suitable material. The

rationale for the exclusion of other possible alternative sites which were

investigated is provided in Table 7 1.

Section 7.1.1

Mitigatory measures for avoiding impact on the wetland environment

must be employed.

The recommended mitigation measures for the identified impacts on

wetlands associated with the construction and operational phases of the

proposed project are provided in the EMP (see Appendix 6).

Appendix 6

It is necessary and important to properly describe anticipated changes

which might occur within the nearby homesteads of 600 m away from the

site as a result of quarry operation and evaluation of conflicts that could

arise during operation.

An assessment of the potential negative and positive impacts associated

with the proposed project, as appropriate, has been provided in Section 8.2

of the EIR. Section 8.2

No mining is allowed within 32m from the banks of the river, stream,

watercourse, wetland or any water body drainage without a permit.

The recommended aquatic buffer zones associated with wetlands and

riparian areas located on the site have been incorporated into the updated

layout plan for the project (refer to Section 71.3). The necessary water use

authorisation requirements applicable to the project are discussed in Section

5.1.4 above.

Sections 5.1.4

and 7.1.3

Soil erosion mitigation measures must be in place to avoid severe soil

erosion.

The recommended mitigation measures for soil-erosion related impacts

associated with the construction and operational phases of the proposed

project are provided in the EMP (see Appendix 6).

Appendix 6

Ngquza Hill Local municipality must be consulted about the proposed

development.

A copy of the Draft EIR and EMPR report was sent directly to the local

municipality.

Section 7.2.2

and

Appendix 3.2


SLR Ref. 723.19083.00003 Report No.5



8. THE ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE

DEVELOPMENT FOOTPRINT ALTERNATIVES The environmental attributes associated with the alternatives described must include socio-economic, social, heritage, cultural, geographical, physical and biological aspects

8.1. BASELINE ENVIRONMENT

This section provides a general description of the key biophysical, cultural/heritage and socio-economic

characteristics of the study area.

8.1.1. CLIMATE

The climate of the broader region is influenced by the semi-permanent Indian high pressure cell that shifts

both in latitude and longitude. The northern part of the Eastern Cape experiences cool sub-tropical

conditions which vary between the coastal and inland environments. The temperatures experienced

inland tend to be more extreme when compared to the milder temperatures and higher rainfall of the

coastal areas. The region is predominantly a summer rainfall area with most rains occurring from October

to March.

8.1.2. TOPOGRAPHY

The topography of the broader region is very rugged and mountainous with deep and steep-sided river

valleys. The proposed quarry site itself is positioned on a hill and is bounded by two watercourses to the

west, south and east of the site perimeter.

8.1.3. GEOLOGY AND SOILS

The geology of the region is characterised by the Cape Super Group rocks that consist of sandstones,

shales and quartzites of Palaeozoic age. These rest unconformably upon older formations and are

followed by the Karoo Super Group rocks. The succession of the Cape Super Group rocks allows the

identification of three groups, namely the Witteberg Group – quartzites and subordinate shales, the

Bokkeveld Group – shales, flagstones and sandstones, and the Table Mountain Group – thick

unfossilised grits with scattered pebbles (CCA, 2009).

The sandstones of the Pondoland region are defined as generally white/sometimes reddish sandstones

stretching north-east from Port St Johns through “Natal” into “Zululand” and are correlated with the Table

Mountain Sandstone of the Cape. A wide terrace belt occurs along the Pondoland coast, stretching into

KwaZulu-Natal. The inland section of beds forms a flat plateau, while in the coastal section the

sandstones dip seawards beneath the Karoo beds, sometimes forming the actual shore. The Natal

Sandstones consist of a number of formations, with the Msikaba Formation being the most southerly,

stretching from Port St Johns to just north of Port Shepstone.


SLR Ref. 723.19083.00003 Report No.5



8.1.4. BIODIVERSITY

8.1.4.1. Vegetation

There are three biomes located within the Ngquza Hill Local Municipality, namely Grassland, Indian

Ocean Coastal and the Savanna Biome. The natural vegetation within the study area is mapped as

Ngongoni Veld, which is considered to be a “Vulnerable” vegetation type in terms of the National List of

Ecosystems that are considered to be threatened and are in need of protection (the ‘National List’)5. The

study area is located within the vicinity of several rural dwellings typical of the area and it is anticipated

that the vegetation has been partially modified by grazing and other activities typically associated with

such settlements in the area.

Critical Biodiversity Areas (CBAs) mapped in terms of the Eastern Cape Biodiversity Conservation Plan

(ECBCP) mapping are presented in Figure 8-1 below. The proposed quarry site is located within an area

identified as terrestrial “Critical Biodiversity Area 2 (CBA)”. In terms of the Conservation Plan, the

preferred land use objective for “CBA 2” areas is to “maintain biodiversity in near natural state with

minimal loss of ecosystem integrity and no transformation of natural habitat should be permitted”.

From fieldwork undertaken by the aquatic and terrestrial ecology specialist, four vegetation communities

were identified within the study area (see Figure 8-2), namely:

• Terrestrial Ngongoni grassland which can be subdivided into:

a. Degraded Primary Grassland; and

b. Secondary Grassland.

• Small and localised areas of scrub, mostly comprised of alien species; and

• Small and localised transformed areas (homesteads and cultivated lands).

The Degraded Primary Grassland community is considered to have modest herbaceous and geophyte

diversity despite being subjected to various anthropogenic impacts. The dominant species is Aristida

junciformis subsp. junciformis (Ngongoni Grass) with other notable species including Moraea elliotii, a

single specimen of a Dierama sp. (not in flower and could only be identified to genus level) and the orchid

Eulophia hians var. hians. Additional specimens of this orchid species, as well as other species are

expected to still appear in the summer months after good rains.

The Secondary Grassland community contain numerous shallow rock exposures where the grass

Microchloa caffra and the bulbs Albuca setosa and Ornithogalum juncifolium were found. A small number

of Aloe maculata plants were also seen near one of the rock outcrops. The rock exposures generally

provide habitat for Brachystelma species, some of which are rare, but if these species are present, they

would only be seen during late summer.

Approximately four (4) specimens of a plant were observed that appeared to resemble Helichrysum

pannosum, which is an endangered species (Raimondo et al., 2009). However, the plants could not be

positively identified. One individual of the uncommon (previously considered Vulnerable but now listed as

Data Deficient) Senecio cf. umgeniensis was also observed.

Small and localised areas of scrub, mostly comprised of alien species were found outside the mapped

extent of grassland areas described above. This vegetation comprised the indigenous pioneer species

Maesa lanceolata and the alien species Acacia mearnsii, Caesalpinia decapetala, and Rubus cuneifolius.

5 Published in terms of Government Notice R.1002 of 9 December 2011.


SLR Ref. 723.19083.00003 Report No.5


April 2017

Figure 8-1: Critical Biodiversity Areas in the broader study area. The proposed quarry location is indicated as a blue dot (Source: SANBI

Biodiversity GIS, 2016).


SLR Ref. 723.19083.00003 Report No.5



Figure 8-2: Identified vegetation communities within the study area.

The aquatic and terrestrial ecology specialist assessed the Degraded Primary Grassland vegetation to

have a “moderate” ecological sensitivity and importance, while the Secondary Grassland and Alien Scrub

vegetation communities were considered to be “low”. The transformed areas were assessed to be of

“very low” ecological sensitivity and importance.

Using available desktop information, the aquatic and terrestrial ecology specialist identified eight plant

species of conservation concern which were considered to potentially occur within the study area.

Species of conservation concern refer to species of flora (plants) and fauna (animals) that have a high

conservation importance in terms of preserving South Africa's high biological diversity and include

threatened species that have been classified as ‘at high risk of extinction in the wild’. Of the eight species

identified, two were confirmed to be present within the proposed quarry site, namely Hypoxis

hemerocallidea (Declining status) and Senecio umgeniensis (Threatened status), while further verification

is required to confirm the presence of a third species, Helichrysum cf. pannosum (Endangered status),

as the plant was not flowering at the time of the site visit. The remaining species of concern are

considered unlikely to be present on site given the lack of suitable habitat for these species.

8.1.4.2. Fauna

With respect to fauna, it should be noted that the broader region has not been extensively studied outside

of protected areas and is not known to exhibit many unique features. Available information indicates that

within protected areas there is high faunal biodiversity and numerous endemic species. Outside of these


SLR Ref. 723.19083.00003 Report No.5



areas, the fauna is, in general, considered to be impoverished due to large-scale overgrazing and other

human-induced impacts associated with rural settlements.

Various fauna species of conservation concern that could potentially occur within the study area were

identified by the aquatic and terrestrial ecology specialist using desktop information (see Appendix 4.1).

With respect to mammal species, it is noted that the lack of species-specific habitat for most of the

identified species, and the proximity to human activities, greatly reduces the likelihood of their occurrence

at the site. The Cape Clawless Otter and the Reddish-grey Musk Shrew are the only important mammal

species considered likely to occur within the study area.

Three bird species of conservation concern were identified as potentially utilising the grassland and

wetland/riverine habitat at the site and surrounds, namely the African marsh-harrier (Circus ranivorus),

Black Harrier (Circus maurus), and Black-winged Lapwing (Vanellus melanopterus).

Twelve endemic or near-endemic reptile species of conservation concern were considered to be

potentially located within the study area, particularly in the more intact grassland and wetland/riverine

habitats. The site falls within the distributional range of four threatened reptiles, namely the Pondo Dwarf

Chameleon (Endangered), Kentani Dwarf Chameleon (Vulnerable), Kwa-Zulu Natal Black Snake (Near

Threatened) and the Variable Legless Skink (Endangered). From the site visit undertaken by the

specialist, only a single terrapin species was recorded in the KwaDlambu River.

No amphibian species of conservation concern are considered likely to be present at the site or within the

surrounding aquatic habitats due to the lack of suitable habitat provided for key species. Only a few

common stream frogs (such as the Clicking Stream frog) could be identified by the specialist through calls

within the watercourses adjacent to the site.

The aquatic and terrestrial ecology specialist noted that there is no known available information on

invertebrates for the study area to enable the assessment of potential occurrence for invertebrate

species.

8.1.4.3. Aquatic features

There are a number of important rivers in the broader region, in particular the Msikaba and Mthentu

rivers. These rivers are typically associated with deeply incised gorges.

In terms of the National Freshwater Ecosystem Priority Area (NFEPA) mapping for the area, the perennial

KwaDlambu River (a tributary of the Msikaba River) is the primary drainage feature in the catchment. It

has been classified as a “B” category (largely natural) river FEPA, with the catchment area highlighted as

an Upstream Management Area (UMA), which refers to sub-quaternary catchments in which human

activities need to be managed to prevent degradation of downstream river FEPAs and Fish Support

Areas. No wetland FEPAs have been classified within the study area, however, the wetland vegetation

group (the Sub-Escarpment Savanna group) is regarded as Endangered and generally “Hardly protected”

at a national level.

In terms of the ECBCP Mapping, the KwaDlambu River and its catchment area (which incorporates the

proposed quarry site) is located within an area designated as “aquatic CBA2 estuary”. In terms of the

ECBCP, the area represents critically important river sub-catchments in a near-natural state that are

considered critical catchment management areas for important downstream estuaries (i.e. the Msikaba

River Estuary in this case). According to the ECBCP land-use planning for CBA2 estuary catchments,


SLR Ref. 723.19083.00003 Report No.5



focus is given to the management of Mean Annual Runoff (MAR) in order to sustain the functioning of

important downstream estuaries. The desired management objective for these aquatic CBAs should be to

limit the total transformation of these catchments to less than 15%, with any reduction in MAR limited to

less than 25%.

The quarry site itself is bounded by two watercourses, i.e. a small tributary of the KwaDlambu River to the

west and the KwaDlambu River itself to the south/east. Twenty-one definable watercourse units (i.e.

rivers and wetlands) were mapped within a 500 m radius of the quarry footprint area by the aquatic and

terrestrial ecology specialist. The individual watercourses (including seepage and valley bottom wetlands,

as well as channelled watercourses) are illustrated in Figure 8-3 below.

Figure 8-3: Mapped watercourse units within 500 m of the proposed quarry footprint area.


SLR Ref. 723.19083.00003 Report No.5



The aquatic and terrestrial ecology specialist then undertook a qualitative screening assessment to

identify which of the identified watercourses are likely to be measurably negatively affected by the

proposed project and/or likely to trigger a water use as contemplated in terms of Section 21 (c) and (i) of

the NWA. From the screening assessment, the following aquatic features were considered for further

assessment:

• Three river units (C3-R01 KwaDlambu River, C1-R01 and C2-R01);

• One stream unit (C1-S01); and

• Five wetland units (C1-W01, C1-W02, C2-W01, C2-W04 and C3-W02).

The identified wetland and channelled rivers/streams were generally classified as seep (hillslope

seepage) wetlands located on hillsides/slopes, characterised mainly by subsurface flows and diffuse

water movement. The rivers and streams were classified according to the nature of flows and size of the

present active channel and were characterised as seasonal rivers (C1-R01 and C2-R01), a perennial

river (KwaDlambu River) and ephemeral stream (C1-S01).

The Present Ecological State (PES) for the identified wetland units was assessed to be “Moderately

Modified” (a “C” PES Ecological Category), with a moderate change in ecosystem processes and loss of

natural habitats having occurred but with the natural habitat remaining predominantly intact in most

instances. Existing impacts (such as poor land use management, soil erosion and establishment of alien

invasive plant species) on these wetlands have resulted in a moderate level of modification to wetland

condition, with wetland hydrology and vegetation showing the greatest level of modification.

The PES of the identified river/stream units were generally considered to be “Fair” to “Poor” (a “C” or “D”

PES) as a result of existing on-site impacts (including poor catchment management, alteration of flow

patterns leading to bed and bank erosion, livestock moving and grazing and establishment of alien

invasive plant species).

Owing to the small wetland size and significantly high level of ecosystem degradation that has already

occurred, the various wetlands were found to generally provide only low to moderate levels of ecosystem

goods and services. Overall, wetland C1-W01, C2-W01 and C2-W04 appear to be the most functionally

important wetlands at the site. The Ecological Importance and Sensitivity (EIS) of the various wetland

units were generally assessed as being of moderately low EIS (i.e. wetlands typically play a small/limited

functional role in the landscape). The identified river/stream units were assessed as being of low EIS with

the exception of the larger KwaDlambu River (C3-R01) which was assessed as being of moderate EIS.

8.1.5. CULTURAL/HERITAGE ENVIRONMENT

The cultural/heritage environment of the broader region may be considered an integral part of an

ethnographic landscape that has evolved over the last 1 000 years, due to extensive livestock

management within the context of low-density human settlement and subsistence agriculture. Social

capital is held in homesteads and graves, with grave sites often left at homestead sites which have since

been abandoned.

A few Later Iron Age and two Early Iron Age sites have been identified in the general area of the

Mkambati Nature Reserve (Granger and Feely, 1985; Feely, 1987). Charred remains of the rare

Mkambati palm nut, dating back almost 5 000 years, have been discovered in the area.


SLR Ref. 723.19083.00003 Report No.5



The heritage specialist did not identify any archaeological sites within the footprint of the proposed project

and associated access road (see Appendix 4.2). However, a grave associated with an old abandoned

homestead was located in the eastern section of the footprint (GPS co-ordinates: S 31º 11’ 56.19”

E 29º 49’ 19.98). The unmarked grave is indicated by a raised soil heap and is approximately 2 m x 1.6 m

in extent. The grave appears to be older than 60 years old and is therefore protected in terms of the

NHRA.

Seven contemporary Mphondo homesteads were observed within the project footprint. While no obvious

graves were visible in the immediate environs of these homesteads, the specialists noted that grave sites

less than 60 years could potentially be associated with these dwellings. It is anticipated that, if present,

the exhumation and reburial of these graves will be addressed in conjunction with the homestead

relocation process to be undertaken by SANRAL’s land management service provider prior to the

establishment of the proposed quarry operations, with due consideration of applicable legislative and

approval requirements.

8.1.6. REGIONAL SOCIO-ECONOMIC ENVIRONMENT

The Eastern Cape is one of the poorer provinces in South Africa. Its economy has been characterised in

the province’s 2004-2014 Provincial Growth and Development Plan (PGDP) as having “extreme levels of

uneven development”. Spatially, it is the second-largest province, covering almost 14 % of the total

surface area of South Africa (CCA, 2009).

The annual average economic growth for the provincial economy over the last decade was 2.2 % against

the national average of 2.8 %. Farming is an important contributor to household livelihoods in the region,

but it is largely a subsistence activity. The region surrounding the proposed quarry site is considered to

be generally representative of the undeveloped rural hinterland of the province (particularly with reference

to the former Transkei and Ciskei homelands) and consists of weak subsistence agriculture and very

limited socio-economic growth.

The Ngquza Hill Local Municipality (LM) is bordered by the Bizana LM to the north, the Port St John’s LM

to the south and the Ntabankulu LM to the northwest. It comprises the magisterial areas of Lusikisiki and

Flagstaff. The total population of the Ngquza Hill LM is 278 481, which is 20.4% of the total population of

the O.R. Tambo District Municipality.

Scattered rural subsistence settlements predominate with some villages being fairly inaccessible.

Approximately 95% of the population of the municipality recorded as living in traditional dwellings. Given

the rural nature of the Ngquza Hill LM, the vast majority of the population are not considered economically

active (91 793 people) with only 18 524 people being employed (Stats SA, 2011).

8.1.7. CURRENT LAND USES

The proposed quarry site is largely undeveloped and sparsely populated with small dwellings (generally

comprising one to four structures) typically associated with the region. The remaining open areas are

typically used for limited subsistence farming or grazing. Road infrastructure in the area is poorly

developed and typically comprises unsurfaced roads. The identified schools, police stations and health

care facilities within the broader study area are illustrated in Figure 8-4.


SLR Ref. 723.19083.00003 Report No.5


April 2017

Figure 8-4: Identified schools, police stations and health care facilities within the broader study area.


SLR Ref. 723.19083.00003 Report No.5



8.2. IMPACTS AND RISKS IDENTIFIED INCLUDING THE NATURE,

SIGNIFICANCE, CONSEQUENCE, EXTENT, DURATION AND PROBABILITY

OF THE 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.

This section describes and assesses the significance of potential impacts associated with the proposed

project. All impacts are systematically assessed and presented according to predefined rating scales

(see Section 8.3 below). Mitigation or optimisation measures are proposed which could ameliorate the

negative impacts or enhance potential benefits, respectively. The status of all impacts should be

considered to be negative unless indicated otherwise. The significance of impacts without and with

mitigation is also assessed.

8.2.1. POTENTIAL BIOPHYSICAL IMPACTS

8.2.1.1. Soil and land capability

Description of impact

Topsoil is generally a resource of high value, containing a gene bank of seeds of indigenous species. A

loss of topsoil (through sterilisation, erosion or contamination) would generally result in a decrease in the

rehabilitation and future land use potential of any land that is disturbed.

Assessment

The aquatic and terrestrial ecology specialist has noted that there is evidence of existing soil erosion

impacts within the project footprint as a result of over-grazing and associated poor land use management

(see Appendix 4.1). Given the current rural land use of the site, no material pre-existing soil pollution

impacts have been identified on the site.

The anticipated direct impacts on soil resources include:

• Removal of topsoil and subsoil within the project footprint for the establishment of the proposed

quarry, access road and associated infrastructure; and

• Pollution of soil as a result of ad-hoc spills and point-source contaminants.

Indirect impacts include the compaction of soils through the movement of people and vehicles within the

project footprint. Increased runoff from these compacted surfaces may result in the erosion of soil

resources outside of the project footprint.

The physical disturbance of soils would predominately take place during establishment of the quarry and

associated infrastructure, as well as during the construction of the proposed access road. The presence

of construction vehicles and associated equipment also pose a risk of ad-hoc hydrocarbon spills in this

phase. During the operation of the quarry, following the removal of topsoil and subsoil from the quarry

footprint, no further physical disturbance of soil resources is anticipated. However, there is a risk of point-

source contamination from storage areas and stationary equipment, as well as ad-hoc spills from vehicles

traversing the site.

Given that there are limited pre-existing impacts on soil resources within the project footprint, the above-

mentioned impacts are considered to be of medium intensity and localised over the duration of the


SLR Ref. 723.19083.00003 Report No.5



proposed quarry operations. The significance of this impact is deemed to be medium without mitigation.

However, it is anticipated that as part of the establishment of the proposed operations, topsoil and subsoil

would be removed and stockpiled for use during rehabilitation of the quarry. Furthermore, the

implementation of pollution-control measures throughout the project life-cycle would reduce the incidence

of ad-hoc and point-source contamination of soil resources. This would reduce the impact significance to

LOW (see Table 8-1).

Mitigation

The following mitigation measures are recommended:

• Limit the disturbance of soils to what is absolutely necessary for earthworks, on-going activities,

infrastructure footprints and use of vehicles.

• Provide adequate sanitary facilities for contractors for the life of the project. Waste from these

facilities must be disposed of and treated at an appropriate disposal facility.

• Conduct proper management of hazardous substances to avoid spillages during all the phases of

the project. If spills do occur and soils become contaminated, the appropriate remedial measures

should be identified in consultation with an appropriately qualified specialist. Where in-situ clean-up

and remediation of spill incidents is not possible, the polluted soils should be classified as wastes

and disposed of. After removal of the contaminated soils, the affected areas should be suitably

rehabilitated.

• The following mitigation measures are specific to soil stockpiles:

> Topsoil (top 300 – 400 mm) should be removed from areas to be disturbed within the project

footprint, including temporary activities and stockpiled separately from the subsoil for

rehabilitation purposes;

> Stockpiles should be demarcated to minimise the risk of disturbance and contamination;

> Stockpiles should not be compacted;

> Stockpiles should be monitored regularly to identify any alien invasive plants, which should

be removed when they germinate to prevent contamination of the seed bank; and

> Topsoil should be replaced after the subsoil has been replaced and compacted.

• As a general principle, storage areas and vehicle maintenance areas should be surfaced with

impermeable substrates and should have appropriate runoff containment measures, such as oil traps

or bunds, in place.

Table 8-1: Assessment of the potential impact on soil and land capability.

Rating criteria Without Mitigation With Mitigation

Extent Local Local

Duration Long-term Long-term

Intensity Medium Low

Significance Medium LOW

Status Negative Negative

Probability Definite Definite

Confidence High High

Nature of cumulative impact Other activities that may contribute to the cumulative impact on the

soils include over-grazing, and associated poor land-management

practices. The cumulative impact is considered to be of LOW to

MEDIUM significance depending on the total extent of these

impacts.

Degree to which impact can be reversed Partially reversible

Degree to which impact may cause

irreplaceable loss of resources

Medium

Degree to which impact can be

mitigated

Medium


SLR Ref. 723.19083.00003 Report No.5



8.2.1.2. Fauna and Flora

Loss of vegetation


All vegetation within the proposed project footprint would either be stripped or disturbed during the course

of the proposed operations. Furthermore, there could be potential secondary impacts on flora (such as

change in species composition, reduction of total biomass and productivity) as a result of changes to

surface and groundwater quantity and quality, and changes in ambient air quality.

Assessment

The construction of the haul road and establishment of the quarry would necessitate clearing of

indigenous grassland vegetation within the development footprint. This would result in permanent loss of

the terrestrial grassland vegetation at the site.

The potential impacts on vegetation would be most significant in areas that are still largely natural and

which contain or support important flora. Approximately 55 ha of the Ngongoni Veld vegetation type would

be transformed. The aquatic and terrestrial ecology specialist has indicated that of the 55 ha,

approximately 4 ha has been completely transformed, while the remainder of the site comprises

Degraded Primary Grassland (22 ha) and Secondary Grassland (29 ha). In addition, the proposed access

road would have a footprint of approximately 14.7 ha, of which approximately 5.9 ha comprises an

existing dirt road.

In addition to the loss of the Ngongoni Veld Type, there are conservation-important plant species located

at the site (refer to Section 8.1.4.1) which may be destroyed/damaged if measures are not taken to

preserve these plants.

The loss of the Ngongoni Veld vegetation type and conservation-important plant species is considered to

be a high intensity impact, localised over the duration of the proposed quarry operations. The significance

of this impact is deemed high without mitigation. However, it is understood that the approved Biodiversity

Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015) makes provision for the loss

of Transkei Coastal Belt Dolerite & Shale Grassland (including Ngongoni Veld) due to stockpiling and/ or

the establishment of borrow pits/quarries to supply additional road material. Thus, it is anticipated that the

loss of Ngongoni Veld associated with the proposed project would be accommodated within the existing

Biodiversity Offset Agreement for the N2 Wild Coast Toll Highway. Accommodating the loss of Ngongoni

Veld within the existing Biodiversity Offset agreement, together with a plant search and rescue operation

prior to the commencement of site clearing, would slightly reduce the impact significance to MEDIUM to

HIGH (see Table 8-2).

Mitigation


• Undertake a protected plant survey within the primary terrestrial Ngongoni grassland within the

project footprint, in order to confirm the presence and abundance of threatened and protected plant

species. This survey must be undertaken by a suitably qualified botanist, prior to the

commencement of construction, during the summer growing season (between November and





accommodates the potential loss of Ngongoni Veld, is implemented effectively.


SLR Ref. 723.19083.00003 Report No.5



• Demarcate the quarry site footprint prior to commencement of construction using appropriate

fencing material. Areas outside of the development footprint and operational area are to be

considered sensitive ‘No-Go’ areas.

• All disturbed terrestrial areas beyond the project footprint that are intentionally or accidentally

disturbed must be rehabilitated as per the rehabilitation guidelines included in the specialist

terrestrial ecological report (see Appendix 4.1).

• Implement measures to curb the spread of alien invasive species. In this regard post-construction

monitoring must be undertaken and any seedlings removed prior to establishment.



Table 8-2: Assessment of the potential impact associated with the loss of vegetation. •


Extent Local Local


Intensity High Medium - High

Significance High MEDIUM - HIGH




Nature of cumulative impact Other activities that may contribute to the cumulative impact on flora

include over-grazing, and associated poor land-management

practices. The cumulative impact is considered to be of LOW to

MEDIUM significance depending on the total extent of these

impacts.

Degree to which impact can be reversed Partially reversible



Medium


mitigated

Medium

Loss of fauna and alteration of faunal habitats


Faunal habitats may be lost through the clearing of vegetation, as well as alteration of habitat due to the

operation of the proposed quarry. Terrestrial faunal species may be directly impacted through direct

mortality of individuals or indirectly through disturbance from project activities, during the life of the

project.

Assessment

The clearance of vegetation within the project footprint reduces the availability of habitat and food sources

for local animals. In addition, the establishment of the quarry and increased anthropogenic activity in the

area would lead to other disturbance and restrict faunal movement between natural areas in the broader

area. Those species that cannot effectively vacate the area during development of the quarry may suffer

direct mortality during site clearing and earthworks. The majority of the larger faunal species occurring on

the site would be able to flee the site to similar habitat in the surrounding area. Smaller vertebrate

species (e.g. reptiles and small mammals) may, however, be directly impacted.

The establishment and operation of the quarry is likely to also result in the alteration of the ambient

environment through nuisance factors such as noise, vibrations and light pollution. Locally common


SLR Ref. 723.19083.00003 Report No.5



species already occurring at the site are likely to be less sensitive to noise/light disturbance (due to the

proximity of the existing homesteads) and can probably become habituated to the operations located at

the site.

Assessment of the potential impact of direct mortality on faunal species was considered in light of

impacting on a species as a whole and not an individual animal. In order to accurately assess the

potential long-term impacts on a species as a whole, the possibility of impacting on species of

conservation concern was specifically considered. A number of species of conservation concern (Cape

Clawless Otter, Reddish-grey Musk Shrew, African Marsh-Harrier, Black Harrier, Black-Winged Lapwing

and twelve endemic or near-endemic reptile species) are thought to potentially occur in the area (refer to

Section 8.1.4.2). Based on the surrounding anthropogenic disturbance in the vicinity of the proposed

quarry site and the mobile nature of the identified species, it is not expected that these species of

conservation concern would be encountered in significant numbers on the proposed site. Thus, no long-

term impact from direct mortality of any species of conservation concern as a whole is expected.

No unique faunal habitats in relation to the larger area were identified on the proposed site, thus no long-

term impact on any other terrestrial faunal species that may occur on the site is expected. The potential

direct mortality of terrestrial faunal species of conservation concern is considered to be of local extent, of

long-term duration and of low intensity. Therefore the impact is rated to be of LOW significance without

and with mitigation (see Table 8-3).

Mitigation


• Limit the area of disturbance to what is absolutely necessary for the proposed operation.

• Ensure that every effort is made to save and relocate any amphibian, reptile, bird or mammal

encountered during site preparation that cannot flee of its own accord.

• Relocate these animals to a suitable area immediately outside the proposed project footprint, but

under no circumstance to an area further away.

Table 8-3: Assessment of the potential impact associated with the loss of fauna and alteration of

faunal habitat.


Extent Local Local


Intensity Low Low

Significance Low LOW


Probability Probable Improbable


Nature of cumulative impact Other activities that may contribute to the cumulative impact on

fauna include habitat disturbance through development, over-

grazing, and poor land-management practices. The cumulative impact is considered to be LOW.

Degree to which impact can be reversed Irreversible



Low


mitigated

Very low


SLR Ref. 723.19083.00003 Report No.5



8.2.1.3. Hydrology (Surface Water)


There are a number of surface water resources located within the vicinity of the proposed project

footprint. Several of these aquatic features were identified as surface water resources that would likely be

measurably affected by the proposed project. Such potential impacts include physical disturbance, flow

modification, erosion / sedimentation and alterations of water quality. Upon closure, the presence of the

quarry would also lead to a permanent change to the drainage patterns within the area.

Assessment

Following the completion of the Scoping Phase, the proposed site plan (refer to Figure 4-1) was revised

by the project engineer to incorporate aquatic buffer zones (ranging between 18 – 40m from the edge of

watercourses) as recommended by the aquatic and terrestrial ecology specialist. Thus, the establishment

of the quarry is unlikely to directly result in the destruction and or modification of the watercourses.

However, the construction of the proposed access road over the KwaDlambu River would likely lead to

the destruction and or modification of instream and riparian habitat at the proposed river crossing.

The aquatic and terrestrial ecology specialist noted that aquatic impacts can typically be grouped into

three categories: (i) the destruction and modification of aquatic habitat; (ii) flow modification and erosion /

sedimentation; and (iii) alteration of water quality. The potential impact of the proposed project for the

construction and operational phases with respect to these three categories has been assessed in detail in

the specialist report (see Appendix 4.2).

In summary, contamination, flow modification and related erosion / sedimentation impacts are likely to

arise but would be localised for the construction phase. Site clearing and earthworks upslope of the

identified watercourses would reduce groundcover and associated runoff infiltration rates would lead to

slightly increased peak discharges reaching these watercourses. During the operational phase, it is

expected that there would be increased water inputs to the downstream wetlands and streams/rivers due

to stormwater runoff. With respect to pollution, while the potential sources of contaminants would likely

be fewer than the construction phase, the poor management of sediment-laden stormwater generated by

the quarry site would be more significant.

Overall, the potential impacts of the project on surface water features is considered to be a localised,

long-term impact of medium intensity. The significance of the impacts is, therefore, assessed to be

medium before mitigation. With the implementation of mitigation, the intensity of the impacts would be

partially reduced and would be of LOW to MEDIUM significance (see Table 8-4).

Mitigation



activities in order to collect baseline data for the monitoring of water quality impacts linked to

construction and operation of the proposed quarry.


surface and near surface water management facilities will be designed, constructed and operated



• Prevent contaminated runoff emanating from the project site directly entering rivers / streams.

• Limit the areas of disturbance to what is absolutely necessary for earthworks, on-going activities,

infrastructure footprints and use of vehicles. No arbitrary movement of vehicles through wetland

areas should be permitted. Once the project design is finalised and the associated project footprint


SLR Ref. 723.19083.00003 Report No.5



is determined, the area located outside of the site should be clearly demarcated and regarded as a

‘no-go’ area.

• Handle all hazardous chemicals (new and used), contaminated water, stockpiles, and general

waste in a manner that they do not contaminate surface water run-off or near surface water flow.

• Locate ablution facilities at least 32 m away from the river systems and wetland areas.

Table 8-4: Assessment of the potential impacts on surface water features.


Extent Local Local


Intensity Medium Low to Medium

Significance Medium LOW to MEDIUM


Probability Probable Probable


Nature of cumulative impact Poor land-management practices may contribute to the cumulative impact on surface water features. The cumulative impact is considered

to be of LOW to MEDIUM significance.




Low


mitigated

Very low

8.2.1.4. Air Quality


The activities most likely to generate emissions during the construction phase include excavations,

earthworks, removal of spoil, storage of materials and vehicle movement on haulage routes and public

roads. For the operational phase, the main sources of particulate emissions would be blasting activities,

crushing and screening, material handling, vehicle entrainment of dust on unsurfaced haul roads, and

wind erosion on exposed areas. These emissions could have an impact on the air quality of the site and

surrounding areas and typically comprise the following elements (i) particulates less than 10 microns in

size, (ii) larger total suspended particulates that relate to dust fallout, and (iii) gas emissions, in particular

sulphur dioxide, oxides of nitrogen, carbon monoxide and Volatile Organic Compounds from vehicle

exhaust emissions. At certain concentrations, each of these contaminants can have health and/or

nuisance impacts.

Assessment

Existing emission sources that influence ambient air quality in the vicinity of the project site include

vehicle entrainment of dust on unsurfaced roads, subsistence agricultural activities, domestic fuel burning

and veld fires. The anticipated emissions as a result of the proposed project would likely contribute to the

current ambient air quality experienced in the area and lead to potential impacts on local communities,

primarily due to nuisance and aesthetic impacts associated with fugitive dust emissions. The extent of

emissions will vary substantially from day to day and will be dependent on the level of activity, the specific

operations being undertaken and the prevailing meteorological conditions.

The expected impact of emissions for the proposed quarry would be most significant in the immediate

vicinity of the operations. As the proposed project would require the relocation of third parties residing


SLR Ref. 723.19083.00003 Report No.5



within the identified quarry site (and associated blasting zone), the intensity of air quality impacts would

be low in the long-term with an overall LOW significance without and with mitigation (see Table 8-5).

Mitigation


• Limit the areas of disturbance to what is absolutely necessary for earthworks, on-going activities,

infrastructure footprints and use of vehicles.

• Apply dust suppression on unpaved roads through chemical binding agents and/or water combined

with vehicle speed and volume controls, where possible.

• Install appropriate dust controls at the crushing and screening operation. Control measures should

aim to achieve a 50% control efficiency.

• Maintain all vehicles to achieve optimal exhaust emissions.

• Where complaints from third-parties are received, immediate steps should be taken to address the

issue (in accordance with a formal air quality complaints procedure).

Table 8-5: Assessment of the potential impacts on air quality.


Extent Local Local


Intensity Low Low




Confidence Medium Medium

Nature of cumulative impact Additional emissions from other vehicles could contribute to impacts

on the ambient air quality of the region.

Degree to which impact can be reversed Partially Reversible



Low


mitigated

Very low

8.2.1.5. Noise


The establishment and operation of the proposed quarry will lead to the generation of noise. Two types of

noise-related impacts are distinguished: noise disturbance and noise nuisance. The former is noise that

can be registered as a discernible reading on a sound level meter and the latter, although it may not

register as a discernible reading, may cause nuisance because of its tonal character (e.g. distant

humming noises).

Assessment

The South African National Standard (SANS) guidelines for noise (SANS 10103, 2008) stipulates that

noise levels from a development that cause ambient background noise levels to increase in excess of 3 to

5 dBA will create a noise disturbance.

No quantification of the current ambient noise levels for the site were undertaken, however given the rural

nature of the site, it is assumed that the SANS limits for rural areas (45 dBA during the day and 35 dBA

during the night) would be applicable. The prevailing ambient noise levels surrounding the project


SLR Ref. 723.19083.00003 Report No.5



footprint comprise a combination of domestic sources (i.e. residential homesteads) and linear noise

sources (e.g. roads).

The construction of the proposed access road, establishment and subsequent operation of the proposed

quarry would likely result in in the generation of disturbance (e.g. through blasting activities and operation

of crushing and screening equipment) and nuisance (e.g. movement of heavy vehicles) noise impacts, in

exceedances of the SANS guideline limit for rural areas when in close proximity to residential receptors.

However, as residents within the quarry footprint and associated blast zone would need to be relocated,

these receptors would be located further away from the potential noise sources associated with the

proposed operations.

It should also be noted that noise pollution (disturbance and nuisance) will have different impacts on

different receptors because some are very sensitive to noise and others are not. For example, workers do

not expect a noise free work environment and so they will be less sensitive to environmental noise

pollution at work. In contrast, neighbouring residents may be sensitive to additional noise and so any

change to ambient noise levels because of operation-related noise may have a negative impact on them

and their anticipated residential experience. The potential noise impact on the closest receptors is

deemed to be of local extent, long-term duration, medium intensity and overall MEDIUM significance

without and with mitigation (see Table 8-6).

Mitigation


• Maintain all vehicles and equipment to limit noise emissions.

• Document all noise complaints and ensure reasonable efforts are made to investigate and address

the area of concern. Options available for reducing noise impacts include but are not limited to:

> Changing operating hours;

> Equipping noise sources with silencers;

> Construction and/or maintenance of noise attenuation measures (e.g. noise berms and

placing noise sources sub surface); and

> Consulting a noise specialist for mitigation advice.

• Where necessary, use noise monitoring as part of the investigatory process into noise complaints

and assessment of the impact of mitigation and, if required, the alteration thereof.

Table 8-6: Assessment of the potential impacts on ambient noise levels.


Extent Local Local


Intensity Medium Medium

Significance Medium MEDIUM



Confidence Medium Medium

Nature of cumulative impact The generation of additional noise could contribute to impacts on the ambient noise level experienced in proximity to the site.




Low


mitigated

Very low


SLR Ref. 723.19083.00003 Report No.5



8.2.2. POTENTIAL SOCIO-ECONOMIC IMPACTS

8.2.2.1. Heritage and Cultural Resources


The establishment of the proposed quarry and associated access road could disturb cultural heritage

material, including fossils and other archaeological material. During the course of the quarry operations,

it is also possible that undiscovered cultural heritage material could be unearthed.

Assessment

The cultural/heritage environment of the broader region is characterised by the low-density human

settlement and subsistence agriculture activities which have taken place over the last 1 000 years.

However, the site itself is not part of any known cultural landscape.

A single unmarked grave site was identified within the project footprint. The heritage specialist further

noted that additional grave sites (most probably younger than 60 years old) could potentially be

associated with the contemporary homesteads which would require relocation. The heritage specialist did

not identify any other archaeological sites within the footprint of the proposed project and associated

access road (see Appendix 4.2).

The identified grave site (as well as any other grave sites associated with the homesteads to be

relocated) would need to be relocated as it is situated within the project footprint. Since all human


assessed to be of high intensity and significance. By ensuring that all applicable legislative requirements,

guidelines and regulations applicable to the removal of human remains are implemented for the relocation

of the grave site, it is anticipated that the significance of the potential impact would reduce to MEDIUM

(see Table 8-7).

It is possible that the construction of the proposed access road, or the operation of the quarry itself could

result in the alteration or destruction of archaeological material. The potential impact on archaeological

material is considered to be a localised, permanent impact of medium intensity. The significance of this

impact is, therefore, assessed to be medium before mitigation and LOW with mitigation (see Table 8-7).

Table 8-7: Assessment of the potential impact on heritage resources.


Impact on unmarked grave site

Extent Local Local

Duration Permanent Permanent

Intensity High Medium

Significance High MEDIUM




Impact on archaeological sites

Extent Local Local

Duration Permanent Permanent




Probability Improbable Improbable

Confidence Medium to high Medium to high


SLR Ref. 723.19083.00003 Report No.5



Nature of cumulative impact While the broader area is largely undeveloped, future development

within could result in a cumulative loss of heritage resources over

time.




Medium to High


mitigated

Low

Mitigation


• Before relocation of the identified grave site (or any other grave sites older than 60 years) may occur,

the necessary permit application in terms of Section 36 of the NHRA must be followed in order to

obtain the required approval from the ECPHRA prior to the commencement of the proposed quarry

operations.

• The exhumation and reburial of any other grave sites younger than 60 years must be discussed with

the homestead occupants as part of the SANRAL land management process. The exhumation of

such sites must be undertaken by a local registered undertaker.

• Should any human remains be disturbed, exposed or uncovered during excavation, these must

immediately be reported to the South African Police Service and, if suspected that the remains are

older than 60 years, ECPHRA.

• Ensure that environmental induction/awareness courses for construction and quarry operation

personnel includes the relevant heritage-related aspects to enable personnel to participate effectively

in heritage resource management. A suitably experienced archaeologist should undertake induction

and training of the ECO and relevant site management personnel in the identification and

monitoring/recovery protocols for heritage resources (including marked and unmarked burial grounds

and graves) during the course of operations, as appropriate.

8.2.2.2. Impacts on roads by project-related traffic


The establishment and operation of the proposed quarry would result in an increase in traffic volumes on

the surrounding road network.

Assessment

Current traffic movement along the road network in proximity of the project site predominately consists of

pedestrian movement and privately owned vehicles. Due to the rural nature of the area, the current road

use frequency in the region is considered to be low.

The commencement of the proposed project would lead to an increase in traffic volumes within the

region, the majority of which would comprise heavy construction vehicles and trucks. During the

operational phase, haul trucks would be required to undertake regular trips to and from the site to

transport the quarried material.

Given the relatively low traffic volumes currently experienced within the surrounding road network it is

anticipated that sufficient reserve capacity within the road network would be available to accommodate

the additional project traffic. However, the increased movement of heavy vehicles presents a higher risk

for traffic-related safety incidents.


SLR Ref. 723.19083.00003 Report No.5



The potential impact related to the movement of heavy vehicles is considered to be local to regional in

extent, long-term and of medium intensity. The significance of this potential impact is, therefore, assessed

to be medium to high before mitigation. With the implementation of mitigation, the intensity of the impact

would reduce and would be of LOW to MEDIUM significance (see Table 8-8).

Mitigation


• Ensure that all vehicles are road-worthy and drivers are qualified and made aware of the potential

road safety issues within the area and adhere to speed limits.

• Record and respond appropriately and without delay, to any complaints about usage of roads by

quarry vehicles.

Table 8-8: Assessment of the potential impact on road traffic.


Extent Local to Regional Local to Regional



Significance Medium to High LOW to MEDIUM




Nature of cumulative impact While the broader area is largely undeveloped, future development

within the region could result in a cumulative impact on road traffic.

Degree to which impact can be reversed Fully Reversible



Low


mitigated

Medium

8.2.2.3. Blasting Hazards


Blasting activities have the potential to impact on people, animals and structures located in the vicinity of

the proposed quarry. Blast hazards include ground vibration, air blast, fly rock, blast fumes and dust.

Ground vibrations travel directly through the ground and have the potential to cause damage to

surrounding structures. Air blasts result from the pressure released during the blast resulting in an air

pressure pulse (wave), which travels away from the source and has the potential to damage surrounding

structures. Fly rock is the release of pieces of rock over a distance and can be harmful to people and

animals and damage structures and property. Blast fumes and dust, caused by the explosion, can be

considered significant nuisance factors. Ground vibrations and air blasts have the potential to cause

nuisance to people and animals even if blasts occur within legal limits.

Assessment

No blasting activities are anticipated during the construction of the proposed access road and

establishment of the quarry itself. The potential blasting impacts associated with the operation of the

proposed quarry were assessed in detail by the blasting specialist (see specialist report attached in

Appendix 4.3). The blasting specialist modelled the expected levels of ground vibration, air blast and fly

rock from the boundary of the proposed quarry and calculated the distances of influence on third parties

for each of the potential impacts.


SLR Ref. 723.19083.00003 Report No.5



With respect to human perception of ground vibration, the modelled ground vibration levels showed that

‘intolerable’ levels would be experienced up to a distance of 258 m from the quarry boundary and

‘unpleasant’ levels could be anticipated up to 592 m. For this reason the blasting specialist has

recommended that the relocation of households within 600 m of the quarry boundary be considered. The

modelled levels of air blasts indicate that the current accepted limit of air blast (134 dB) would be

exceeded up to a distance of 333 m from the quarry boundary. There would be a high probability of

damage to public property and complaints as a result of air blast impacts within this area. The

occurrence of fly rock in any form will have a negative impact if found to travel outside the zone deemed

to be unsafe. The modelling undertaken by the blasting specialist noted that the minimum unsafe distance

for fly rock would be 206 m from the quarry boundary.

Should the basting activities lead to damage of third party property or injury of people or animals, the

impact would be of high intensity at a local level and endure in the medium term. Therefore, this impact is

assessed to be of medium significance without mitigation. By relocating third-parties outside of the

project footprint and the blasting zone (a distance of 600 m, as recommended by the blasting specialist),

the significance of this impact reduces to LOW with mitigation (see Table 8-9).

Mitigation



• Implement a monitoring programme for recording blasting operations. The following elements

should be part of such a monitoring program:

> Ground vibration and air blast results;

> Blast information summary;

> Meteorological information at time of the blast;

> Video recording of the blast; and

> Fly rock observations.

• Review the initial blast design and prepare a detailed blasting code of practice for the project. The

following blast designs are recommended:

> Blast initiation should be electronic;

> Blastholes should be 89 mm in diammeter;

> Stemming lengths must be at least 30 times the blasthole diameter (89 mm x 30 mm = 2.7 m);

and

> Use crushed aggregate as stemming material at 10 % of the blasthole diameter (7 - 12 mm).




monitoring positions are proposed by the blasting specialist (see Figure 18 and Table 17 of

Appendix 4.3).

• Undertake pre-blast photographic surveys of all structures up to 1000 m from the quarry area.

• Respond immediately to any blast-related complaints. These complaints and the follow-up actions

should be dated, documented and kept as records for the duration of the operation. Where proven

blast-related damage has been caused, appropriate compensation must be provided to affected

parties.


SLR Ref. 723.19083.00003 Report No.5



Table 8-9: Assessment of the potential blasting impacts.


Extent Local Local

Duration Medium Term Medium Term

Intensity High Medium



Probability Highly Probable Highly Probable


Nature of cumulative impact No other cumulative blasting impacts are anticipated.




Medium


mitigated

Medium

8.2.2.4. Land use


In order to establish the proposed quarry, as well as to ensure the safety of people within the possible

blasting zone, individuals residing within these areas would be physically relocated. Members of the local

community would no longer be able to occupy homesteads located within these areas and conduct

subsistence farming within the remaining areas of the project site until rehabilitation of the site has been

completed.

Assessment

In addition to the scattered households within the project footprint and associated blasting zone, the site

is predominately utilised for limited subsistence agriculture and livestock grazing. As the proposed project

would require the relocation of homesteads, it is anticipated that the relocation process would also entail

the reallocation of associated arable land. The relocation process would be undertaken by SANRAL’s

land management service provider prior to the establishment of the proposed quarry operations. Prior to

the closure of the proposed operations, a rehabilitation and closure plan for the site would need to be

developed. This plan would consider the proposed future land use of the project site and ensure that

disturbed areas are suitably shaped and rehabilitated to facilitate this identified land use.

The potential impact is considered to be a localised, long-term impact of low intensity. The significance of

this impact is, therefore, assessed to be LOW before and after mitigation (see Table 8-10).

Mitigation


• Implement the commitments contained within the EMP with a view not only to prevent and/or

mitigate the various environmental and social impacts, but also to prevent negative impacts on

surrounding land uses.

• If a situation arises where any surrounding land use are negatively affected by the operations, the

quarry operator will immediately take steps to address the cause of the impacts.

• Incorporate measures to achieve the future land use plans for the project site during closure

planning.


SLR Ref. 723.19083.00003 Report No.5



Table 8-10: Assessment of the potential impact on land use.


Extent Local Local


Intensity Low Low




Cumulative impact Low Low

Nature of Cumulative impact The establishment of additional projects in the area could impact on existing land

uses.

Degree to which impact can

be reversed

Partially Reversible

Degree to which impact may

cause irreplaceable loss of

resources

Low


be mitigated / optimised

None

8.2.2.5. Creation of employment and business opportunities


The proposed development would create a number of local employment and business opportunities

during operation. In addition, there would be an opportunity for skills development and on-site training. It is anticipated that an increase in the number of income-earning people would also have a multiplier effect

on the trade of other goods and services in other sectors within the area.

Assessment The proposed project would create a limited number of employment opportunities during the site

establishment and operational phases. The majority of the low- and semi-skilled employment

opportunities are likely to benefit historically disadvantaged members of the community. The

implementation of a skills development and training programme would increase the number of skilled

local employment opportunities.

The benefits to the local economy would extend over the operational lifespan of the proposed project.

A percentage of the monthly wage bill earned by permanent staff would be spent in the regional and local

economy, which would benefit local businesses in the region.

The creation of employment and business opportunities during the site establishment and operational

phases is likely to result in a long-term, local impact of low intensity. The significance of this potential

impact is, therefore, assessed to be LOW (positive) before and after optimisation (see Table 8-11).

Optimisation

• The Applicant should, where reasonable and practical, implement a ‘locals first’ employment policy,

especially for semi- and low-skilled job categories, and appoint local contractors/sub-contractors

that are compliant with Black Economic Empowerment (BEE) criteria.

• A training and skills development programme for locals should be implemented during the first five

years of operation.


SLR Ref. 723.19083.00003 Report No.5



Table 8-11: Assessment of the potential social impact related to employment and the creation

of business opportunities during operation.


Extent Local Local


Intensity Low Low

Probability Probable Definite


Significance Low (positive) LOW (POSITIVE)

Cumulative impact Low (positive) Low (positive)

Nature of Cumulative impact Potential cumulative impacts linked to employment and business opportunities would

depend on other construction projects being implemented in the same timeframe.


be reversed

Fully reversible

Degree to which impact may

cause irreplaceable loss of

resources

N/A


be mitigated / optimised

Low

8.2.2.6. Influx of job seekers to the area


The establishment of the proposed project is likely to attract job seekers to the area during the operation

phase, which could pose a number of risks to the local community. While the presence of job seekers and

their families does not in itself constitute a social impact, the manner in which they conduct themselves

could affect the local community. In the case of local communities the most significant risks include:

• Impact on existing social networks and community structures.

• Pressure on local services, such as schools, clinics, etc.

• Competition for scarce jobs.

• Increase in incidences of crime.

• Increase in transmission of sexually transmitted diseases (STDs).

Assessment The potential risk posed by job seekers is considered to have a localised, long-term to permanent impact

of medium intensity for the community as a whole. The significance of this potential impact is, therefore,

assessed to be medium before mitigation. The implementation of a local employment strategy would

reduce these risks to a large extent. The effective implementation of the proposed mitigation measures

would reduce the potential social impact to LOW significance (see Table 8-12).

Mitigation

• A ‘locals first’ employment policy should be implemented.

• Monitoring of the implementation of the mitigation measures recommended for the proposed

project should be undertaken by the Environmental Monitoring Committee which has already been

established for the construction phase of the N2 Wild Coast Toll Highway.


SLR Ref. 723.19083.00003 Report No.5



Table 8-12: Assessment of the potential social impact related to the influx of operation

workers.


Extent Local Local






Cumulative impact Medium Medium

Nature of Cumulative impact The presence of labourers involved with other developments in the area may exacerbate the risks.

Degree to which impact can be reversed

Irreversible (in case of HIV/AIDs, unwanted pregnancies etc.)

Degree to which impact may cause irreplaceable loss of resources

Low

Degree to which impact can be mitigated / optimised

Low

8.2.3. NO-GO ALTERNATIVE


The no-go alternative would result in the maintenance of the status quo. While none of the impacts

associated with the proposed project (as described above) would occur, the implementation of the no-go

alternative would result in lost economic opportunities, such as:

• The direct economic benefits associated with the proposed project would be lost to the local and

regional economies;

• The possible indirect economic benefits derived from the procurement of goods and services and

the spending power of employees would also be lost; and

• Lost economic opportunities related to sunken costs (i.e. costs already incurred) of initial desktop

investigations and previous prospecting activities.

Assessment

With respect to the identified biophysical impacts described in Section 8.2.1 above, the no-go alternative

would result in the site remaining in its current state with no change to the current impacts on ambient air

quality or noise levels in the area. However, the current over-grazing and associated poor land use

management activities would likely continue for the foreseeable future. These activities would lead to

additional soil erosion impacts, sedimentation of surface water features and the related degradation of

natural vegetation and faunal habitats. The negative impacts would be of low intensity and highly

localised over the long-term. Thus, the potential negative impact of the no-go alternative on soil and land

capability, fauna and flora and hydrology is considered to be of LOW significance.

With respect to the potential socio-economic impacts described in Section 8.2.2, the status quo would

have NO IMPACT on heritage and cultural resources, traffic and existing land uses. Furthermore, there

would be no influx of job seekers and there would be no blasting impacts. However, the potential impact

related to the lost economic opportunities described above is considered to be of HIGH significance (see

Table 8-13).


SLR Ref. 723.19083.00003 Report No.5



Table 8-13: Assessment of the potential impacts related to the No-Go alternative.

Rating criteria Without Mitigation

Air Quality, Noise, Heritage and Cultural Resources, Traffic, Blasting, Land Use and Influx of Job Seekers

Extent

NO IMPACT

Duration

Intensity

Significance

Status

Probability

Confidence

Soil and Land Capability, Fauna and Flora and Hydrology

Extent Local

Duration Long-term

Intensity Low

Significance LOW

Status Negative

Probability Probable

Confidence Low

Lost Economic Opportunities

Extent Regional

Duration Permanent

Intensity Medium

Significance Improbable

Status Low

Probability HIGH

Confidence Yes

Nature of cumulative impact Increased construction costs associated with the N2 Wild Coast Toll

Highway.

Degree to which impact can be reversed Reversible



N/A


mitigated

N/A

8.3. METHODOLOGY USED IN DETERMINING AND RANKING THE NATURE,

SIGNIFICANCE, CONSEQUENCES, EXTENT, DURATION AND

PROBABILITY OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS

The assessment of potential environmental impacts will involve consideration of the following criteria:

• Extent of impact;

• Duration of impact;

• Intensity of impact;

• Status of impact;

• Probability of impact occurring;

• Significance of impact;

• Degree to which impact can be mitigated;

• Degree to which a resource is lost;

• Reversibility of impact;

• Nature of cumulative impacts; and

• Degree of confidence of assessment.


SLR Ref. 723.19083.00003 Report No.5



In assigning significance ratings to potential impacts before and after mitigation, specialists are instructed

to follow the approach presented below:

1. The core criteria for determining significance ratings are “extent” (Section 8.3.1), “duration”

(Section 8.3.2) and “intensity” (Section 8.3.3). The preliminary significance ratings for combinations

of these three criteria are given in Section 8.3.4.

2. Additional criteria to be considered, which could “increase” the significance rating if deemed

justified by the specialist, with motivation, are the following:

• Permanent / irreversible impacts (as distinct from long-term, reversible impacts);

• Potentially substantial cumulative effects (see Item 9 below); and

• High level of risk or uncertainty, with potentially substantial negative consequences.

3. Additional criteria to be considered, which could “decrease” the significance rating if deemed

justified by the specialist, with motivation, is the following:

• Improbable impact, where confidence level in prediction is high.

4. The status of an impact is used to describe whether the impact will have a negative, positive or

neutral effect on the surrounding environment. An impact may therefore be negative, positive (or

referred to as a benefit) or neutral (Section 8.3.5).

5. Describe the impact in terms of the probability of the impact occurring (Section 8.3.6) and the

degree of confidence in the impact predictions, based on the availability of information and

specialist knowledge (Section 8.3.7).

6. Describe the degree to which a resource is impacted (Section 8.3.8);

7. When assigning significance ratings to impacts after mitigation, the specialist needs to:

• First, consider probable changes in intensity, extent and duration of the impact after

mitigation, assuming effective implementation of mitigation measures, leading to a revised

significance rating; and

• Then moderate the significance rating after taking into account the likelihood of proposed

mitigation measures being effectively implemented. Consider:

o Any potentially significant risks or uncertainties associated with the effectiveness of

mitigation measures;

o The technical and financial ability of the proponent to implement the measure; and

o The commitment of the proponent to implementing the measure, or guarantee over

time that the measures would be implemented.

8. Describe the degree to which an impact can be mitigated or enhanced (Section 8.3.9) and reversed

(Section 8.3.10)

9. The cumulative impacts of a project should also be considered. “Cumulative impacts” refer to the

impact of an activity that may become significant when added to the existing activities currently

taking place within the surrounding environment.

10. Where applicable, assess the degree to which an impact may cause irreplaceable loss of a

resource. A resource assists in the functioning of human or natural systems, i.e. specific minerals,

water, etc.


SLR Ref. 723.19083.00003 Report No.5



The significance ratings are based on largely objective criteria and inform decision-making at a project

level as opposed to a local community level. In some instances, therefore, whilst the significance rating

of potential impacts might be “low” or “very low”, the importance of these impacts to local communities or

individuals might be extremely high. The importance which I&APs attach to impacts must be taken into

consideration, and recommendations should be made as to ways of avoiding or minimising these

negative impacts through project design, selection of appropriate alternatives and / or management.

The relationship between the significance ratings after mitigation and decision-making can be broadly

defined as follows:

Significance rating Effect on decision-making

INSIGNIFICANT; VERY LOW; LOW

Will not have an influence on the decision to proceed with the proposed project, provided

that recommended measures to mitigate negative impacts are implemented.

MEDIUM Should influence the decision to proceed with the proposed project, provided that

recommended measures to mitigate negative impacts are implemented.

HIGH; VERY HIGH Would strongly influence the decision to proceed with the proposed project.

8.3.1. EXTENT

“Extent” defines the physical extent or spatial scale of the impact.

Rating Description

LOCAL Extending only as far as the activity, limited to the site and its immediate surroundings. Specialist studies to specify extent.

REGIONAL Specialist studies to specify extent.

NATIONAL South Africa

INTERNATIONAL

8.3.2. DURATION

“Duration” gives an indication of how long the impact would occur.

Rating Description

SHORT-TERM 0 - 5 years

MEDIUM-TERM 6 - 15 years

LONG-TERM Where the impact will cease after the operational life of the activity, either because of natural

processes or by human intervention.

PERMANENT Where mitigation either by natural processes or by human intervention will not occur in such a

way or in such time span that the impact can be considered transient.

8.3.3. INTENSITY

“Intensity” establishes whether the impact would be destructive or benign.

Rating Description

ZERO TO VERY LOW Where the impact affects the environment in such a way that natural, cultural and social

functions and processes are not affected.

LOW Where the impact affects the environment in such a way that natural, cultural and social

functions and processes continue, albeit in a slightly modified way.

MEDIUM Where the affected environment is altered, but natural, cultural and social functions and

processes continue, albeit in a modified way.


SLR Ref. 723.19083.00003 Report No.5



Rating Description

HIGH Where natural, cultural and social functions or processes are altered to the extent that it will

temporarily or permanently cease.

8.3.4. SIGNIFICANCE

“Significance” attempts to evaluate

the importance of a particular impact, and in doing so incorporates the

above three scales (i.e. extent, duration and intensity).

Rating Description

VERY HIGH Impacts could be EITHER:

of high intensity at a regional level and endure in the long term 6;

OR of high intensity at a national level in the medium term;

OR of medium intensity at a national level in the long-term.

HIGH Impacts could be EITHER:

of high intensity at a regional level and endure in the medium term;

OR of high intensity at a national level in the short term;

OR of medium intensity at a national level in the medium term;

OR of low intensity at a national level in the long term;

OR of high intensity at a local level in the long term;

OR of medium intensity at a regional level in the long term.

MEDIUM Impacts could be EITHER:

of high intensity at a local level and endure in the medium term;

OR of medium intensity at a regional level in the medium term;

OR of high intensity at a regional level in the short term;

OR of medium intensity at a national level in the short term;

OR of medium intensity at a local level in the long-term;

OR of low intensity at a national level in the medium term;

OR of low intensity at a regional level in the long term.

LOW Impacts could be EITHER

of low intensity at a regional level and endure in the medium term;

OR of low intensity at a national level in the short term;

OR of high intensity at a local level and endure in the short term;

OR of medium intensity at a regional level in the short term;

OR of low intensity at a local level in the long term;

OR of medium intensity at a local level and endure in the medium term.

VERY LOW Impacts could be EITHER

of low intensity at a local level and endure in the medium term;

OR of low intensity at a regional level and endure in the short term;

OR of low to medium intensity at a local level and endure in the short term.

INSIGNIFICANT Impacts with:

Zero to very low intensity with any combination of extent and duration.

UNKNOWN In certain cases it may not be possible to determine the significance of an impact.

8.3.5. STATUS OF IMPACT

The status of an impact is used to describe whether the impact would have a negative, positive or zero

effect on the affected environment. An impact may therefore be negative, positive (or referred to as a

benefit) or neutral.

6 For any impact that is considered to be “Permanent” apply the “Long-Term” rating.


SLR Ref. 723.19083.00003 Report No.5



8.3.6. PROBABILITY

“Probability” describes the likelihood of the impact occurring.

Rating Description

IMPROBABLE Where the possibility of the impact to materialise is very low either because of design or

historic experience.

PROBABLE Where there is a distinct possibility that the impact will occur.

HIGHLY PROBABLE Where it is most likely that the impact will occur.

DEFINITE Where the impact will occur regardless of any prevention measures.

8.3.7. DEGREE OF CONFIDENCE

This indicates the degree of confidence in the impact predictions, based on the availability of information

and specialist knowledge.

Rating Description

HIGH Greater than 70% sure of impact prediction.

MEDIUM Between 35% and 70% sure of impact prediction.

LOW Less than 35% sure of impact prediction.

8.3.8. LOSS OF RESOURCES

“Loss of resource” refers to the degree to which a resource is permanently affected by the activity, i.e. the

degree to which a resource is irreplaceable.

Rating Description

LOW Where the activity results in a loss of a particular resource but where the natural, cultural

and social functions and processes are not affected.

MEDIUM Where the loss of a resource occurs, but natural, cultural and social functions and

processes continue, albeit in a modified way.

HIGH Where the activity results in an irreplaceable loss of a resource.

8.3.9. DEGREE TO WHICH IMPACT CAN BE MITIGATED

This indicates the degree to which an impact can be reduced.

Rating Description

NONE No change in impact after mitigation.

VERY LOW Where the significance rating stays the same, but where mitigation will reduce the

intensity of the impact.

LOW Where the significance rating drops by one level, after mitigation.

MEDIUM Where the significance rating drops by two to three levels, after mitigation.

HIGH Where the significance rating drops by more than three levels, after mitigation.

8.3.10. REVERSIBILITY OF AN IMPACT

This refers to the degree to which an impact can be reversed.

Rating Description

IRREVERSIBLE Where the impact is permanent.

PARTIALLY REVERSIBLE Where the impact can be partially reversed.

FULLY REVERSIBLE Where the impact can be completely reversed.


SLR Ref. 723.19083.00003 Report No.5



8.4. 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

Refer to Section 8.2 for a discussion of the identified positive and negative impacts of the proposed

project.

8.5. 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.

The identified mitigation measures, together with an assessment of the impacts is provided in Section 8.2

above.

8.6. MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED

As noted in Section 7.1.1, various site alternatives were investigated by the design engineer. The

rationale for selecting the preferred site and exclusion of other possible alternative sites which were

investigated is provided in Table 7-1.

8.7. STATEMENT MOTIVATING THE ALTERNATIVE DEVELOPMENT

LOCATION WITHIN THE OVERALL SITE

The primary rationale for the selection of the preferred site alternative is provided in Section 7.1.1 and

relates to the area available to establish the proposed quarry, topography, level of existing development,

availability and quantity of suitable material.

The proposed project layout has been informed by the outcomes of the Scoping Process and has been

refined based on the baseline input provided by the terrestrial and freshwater ecosystems specialist (refer

to Section 7.1.3). In this regard the project layout has taken into account the recommended aquatic buffer

zones associated with wetlands and riparian areas located on the site.

Given the above, the proposed project layout provided in Figure 4-1 is deemed to be the preferred

alternative.


SLR Ref. 723.19083.00003 Report No.5



9. FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO

IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE

ACTIVITY WILL IMPOSE ON THE PREFERRED SITE

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.

Refer to Section 8.2, which provides a detailed description of the environmental issues / risks that were

identified during the environmental impact assessment process and assessed in this EIR.


SLR Ref. 723.19083.00003 Report No.5


April 2017

9.1. ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK

ACTIVITY (e.g. excavations, blasting, stockpiles, hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, roads, etc.)

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

ASPECTS AFFECTED

PHASE (e.g. Construction, commissioning, operational, decommissioning, closure)

SIGNIFICANCE (UNMITIGATED)

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.)

Significance (mitigated)

Extent to which the impact can be avoided or addressed through the implementation of management measures

Civil works – related to infrastructure establishment

Site Establishment

Quarry Operation

Transport systems

Waste management

Rehabilitation

Maintenance and aftercare of rehabilitated areas

Loss of soil resources and land capability through pollution and physical disturbance

Soil and land capability

Construction Operation Decommissioning Closure

Medium • Restrict project footprint • Pollution prevention

measures • Stockpile topsoil

Low Can be managed/mitigated to acceptable levels

Earthworks - for all surface infrastructure

Site Establishment

Quarry Operation

Transport systems

Waste management

Rehabilitation


Loss of vegetation Terrestrial Biodiversity

Construction Operation Decommissioning

High • Implementation of the biodiversity offset

• Restrict project footprint • Rehabilitate disturbed

areas • Prevention of the killing of

animal species • Pollution prevention

measures • Prevention of the

disturbance of ecosystems

Medium to High Can be managed/mitigated to acceptable levels


Site Establishment

Quarry Operation

Transport systems

Rehabilitation


Loss of fauna and alteration of faunal habitats

Terrestrial Biodiversity


Low Low Can be managed/mitigated to acceptable levels


Site Establishment

Quarry Operation

Transport systems

Physical disturbance and pollution of surface water resources

Surface water

Construction Operation Decommissioning Closure

Medium • Implement a monitoring programme

• Implement a stormwater management plan

• Implement emergency response procedure

Low to Medium Can be managed/mitigated to acceptable levels


SLR Ref. 723.19083.00003 Report No.5


April 2017



ASPECTS AFFECTED






Waste management

Rehabilitation


• Implementation and maintenance of licence requirements

• Pollution prevention measures


Site Establishment

Quarry Operation

Transport systems

Rehabilitation


Air quality Air Construction Operation Decommissioning Closure

Low • Restrict project footprint • Apply dust suppression

measures • Implementation of an air

quality complaints procedure



Site Establishment

Quarry operation

Transport systems

Noise pollution Noise Construction Operation Decommissioning

Medium • Maintenance of vehicles and equipment

• Implementation of a noise complaints procedure

Medium Can be managed/mitigated to acceptable levels


Site Establishment

Quarry operation

Transport systems Rehabilitation

Loss of heritage and cultural resources

Heritage and cultural resources


Medium (for archaeological sites) to High (for graves)

• Exhume and relocate graves in accordance with the applicable legislation and procedures

• Where archaeological material is discovered, implement emergency response procedure

Low (for

archaeological

sites) to

Medium(for

graves)

Can be avoided

Transport system Traffic impact Traffic Construction Operation Decommissioning

Medium to High • Implementation of a traffic safety programme

• Implementation of a traffic complaints procedure

Low to Medium Can be managed/mitigated to acceptable levels

Quarry operation

Blasting impacts (fly rock, air blasts and ground vibrations)

Blasting Operation Medium • Relocate households outside of blasting zone

• Implementation of a blast management plan

• Pre-mining photographic crack survey



SLR Ref. 723.19083.00003 Report No.5


April 2017



ASPECTS AFFECTED






• Communication of planned blasting times with stakeholders

• Pre-blast warning • Monitoring blasts • Audit and review to adjust

blast design were necessary

• Investigate blast-related complaints

Loss of soil resources and land capability through pollution and physical disturbance

Quarry operation

Land use impact Land use Construction Operation Decommissioning

Low

• Implementation of EMP commitments

• Take necessary steps to prevent negative impact on surrounding land

• Closure planning to incorporate measures to achieve future land use plans


Establishment of the quarry Quarry operation

Creation of employment and business opportunities

Socio-economic

Construction Operation

Low positive • Hire people from closest communities

• Local procurement of goods and services

Low positive N/A

Establishment of the quarry

Presence of the quarry operation

Influx of job seekers to the area


Medium • Employment and procurement opportunities provided to closest communities

• Monitor and prevent the development of informal settlements through the interaction with local authorities and law enforcement officials



SLR Ref. 723.19083.00003 Report No.5



9.2. 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:

Attach copies of Specialist Reports as appendices

The following specialist studies have been undertaken and are attached in Appendix 4.

SPECIALIST STUDY SPECIALIST APPENDIX

Terrestrial and freshwater ecosystems Eco-Pulse Environmental Consulting Services 4.1

Blasting impact Blast Management and Consulting 4.2

Cultural heritage resources Active Heritage 4.3

LIST OF STUDIES UNDERTAKEN

RECOMMENDATIONS OF SPECIALIST REPORTS

SPECIALIST RECOMMENDATIONS THAT HAVE BEEN INCLUDED IN THE EIA REPORT (Mark with an X where applicable)

REFERENCE TO APPLICABLE SECTION OF REPORT WHERE SPECIALIST RECOMMENDATIONS HAVE BEEN INCLUDED.

Terrestrial and

freshwater

ecosystems

The aquatic and terrestrial ecology specialist

made several recommendations with regards to

mitigation for the proposed project. The

recommendations pertain to, inter alia, aquatic

buffer zones, demarcation of ‘no-go’ areas,

design of the proposed access road and

associated culverts, stormwater management

design, pollution prevention measures, erosion

control, alien invasive species monitoring and

control and monitoring and rehabilitation. See

Sections 4.5 and 5.3 of the specialist report for

more detail in this regard. It was further noted

that the loss of Ngongoni Veld associated with

the proposed project could be accommodated

within the existing Biodiversity Offset Agreement

for the N2 Wild Coast Toll Highway.

X Section 8.2.1.2 and

Section 8.2.1.3

Blasting The blasting specialist indicated that relocation

of households within 600 m from the pit

boundary should be considered.

The following blast designs were recommended:

• Blast initiation should be electronic;

• Blastholes should be 89 mm in diammeter;

• Stemming lengths must be at least 30

times the blasthole diameter (89 mm x

30 mm = 2.7 m); and

• Use crushed aggregate as stemming

material at 10 % of the blasthole diameter

(7 - 12 mm).

It was further recommended that a minimum

area of 206 m around a blast should be cleared

of people and animals before blasting. The final

blast designs should be used to determine the

X Section 8.2.2.3


SLR Ref. 723.19083.00003 Report No.5



final decision on safe distance to evacuate

people and animals. Blasting should not take

place early in the morning, when there is a

possibility of atmospheric inversion, during

periods of poor visibility (e.g. fog or night), too

late in the afternoon during winter and when

wind is blowing strongly in the direction of

receptors.

The blasting specialist also recommended

various ground vibration and air blast levels

limits for blasting operations (see Table 20 of the

specialist report attached in Appendix 4.2).

Additional recommendations were made

pertaining to blasting times, undertaking

photographic surveys of all structures up to

1000 m from the quarry area and implementing

a ground vibration and air blast monitoring.

Cultural

heritage

resources

Before relocation of the identified grave site (or

any other grave sites older than 60 years) may

occur, the necessary permit application in terms

of Section 36 of the National Heritage

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

must be followed in order to obtain the required

approval from the Eastern Cape Heritage

Resources Agency (ECPHRA) prior to the

commencement of the proposed quarry

operations.

With respect to the contemporary homesteads

located within the project footprint, it was

recommended that these be evaluated by

SANRAL’s land management service provider

and should any graves be identified, then their

possible exhumation and reburial must be

discussed with the homestead occupants. As

these graves would most probably be younger

than 60 years old their exhumation would have

to be conducted by a local registered

undertaker.

Where palaeontological, archaeological, or

historical materials are uncovered during the

commencement of the proposed quarry

operations, the activities should cease

immediately pending an evaluation by the

heritage authorities.

X Section 8.2.2.1


SLR Ref. 723.19083.00003 Report No.5



10. ENVIRONMENTAL IMPACT STATEMENT

10.1. SUMMARY OF THE KEY FINDINGS OF THE ENVIRONMENTAL IMPACT

ASSESSMENT

A summary of the assessment of potential environmental impacts associated with the proposed quarry

activities and No-Go Alternative is provided in Table 10-1 overleaf.

Table 10-1: Summary of the significance of the potential impacts associated with the proposed

quarry operations and No-Go Alternative.

Potential impact

Significance

Without

mitigation

With mitigation

POTENTIAL BIOPHYSICAL IMPACTS

Soil and land capability M L

Fauna and Flora Loss of vegetation H M - H

Loss of fauna and alteration of habitats L L

Hydrology (Surface Water) M L - M

Air Quality L L

Noise M M

POTENTIAL SOCIO-ECONOMIC IMPACTS

Heritage and Cultural Resources Unmarked grave site H M

Archaeological sites M L

Impacts on roads by project-related traffic M – H L - M

Blasting Hazards M L

Land Use L L

Creation of employment and business opportunities L (+ve) L (+ve)

Influx of job seekers to the area M L

NO-GO ALTERNATIVE

No-Go Alternative Soil and land capability L N/A

Fauna and Flora L N/A

Hydrology (Surface Water) L N/A

Air Quality

No change to current impacts.

Noise

Heritage and Cultural Resources

Impacts on traffic

Land Use

Blasting Hazards No impact.

Influx of job seekers

Lost Economic Opportunities H N/A

VH=Very High H=High M=Medium L=Low VL=Very low Insig =

insignificant

N/A=

Not applicable

10.2. FINAL SITE MAP

The final site map of the proposed quarry has been included as Figure 4-1.


SLR Ref. 723.19083.00003 Report No.5



10.3. SUMMARY OF THE POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS

OF THE PROPOSED ACTIVITY AND IDENTIFIED ALTERNATIVES

The majority of the impacts associated with the establishment and operation of the proposed quarry

would be largely localised, of long-term duration and of low intensity, and are considered to be of LOW

significance after mitigation. Key mitigation includes ensuring that the area of disturbance is limited to

what is absolutely necessary for the proposed operation, a detailed stormwater management plan is

developed and implemented, on-site pollution prevention measures are implemented and any complaints

received from third-parties are addressed in accordance with a formal complaints procedure.

One of the key issues associated with the proposed quarry operation relates to the loss of vegetation and

the related impacts on fauna and associated biodiversity. All vegetation within the quarry footprint would

be lost during the course of the operations. Approximately 22 ha of Degraded Primary Grassland and 29

ha of Secondary Grassland (of the ‘Vulnerable’ Ngongoni vegetation type) would be lost. Furthermore,

conservation-important plant species may be destroyed/damaged if measures are not taken to preserve

these plants. The loss of Ngongoni Veld and conservation-important species is considered to be a high

intensity impact, localised over the duration of the proposed quarry operations. As the loss of Ngongoni

Veld due to quarry establishment is accommodated in the approved Biodiversity Offset Report for the N2

Wild Coast Toll Highway (Botha & Brownlie, 2015), the requisite biodiversity offset would compensate for

the loss of the vegetation type. The residual impact is assessed to be of MEDIUM to HIGH significance.

With respect to noise impacts, it is anticipated that the proposed quarry would exceed the SANS

guidelines with respect to increasing ambient background noise levels in excess of 3 to 5 dBA. However,

as it is recommended that the homesteads closest to the quarry operations (i.e. within the project footprint

and associated 600m blast zone – see below) should be relocated, the closest receptors would be

located further away from noise sources associated with the proposed operations. The residual noise

impact of the proposed project is deemed to be of local extent, long-term duration, medium intensity and

MEDIUM significance.

The relocation of a single unmarked grave site located within the project footprint will be required, as well

as any graves which may be associated with homesteads to be relocated in the adjacent area. As human


assessed to be of high intensity. By ensuring that all applicable legislative requirements, guidelines and

regulations applicable to the removal of human remains are implemented for the relocation of graves, it is

anticipated that the residual impact would be of MEDIUM significance.

Where basting activities associated with the proposed quarry operations lead to the damage of third party

property or injury of people or animals, the impact would be of high intensity at a local level and endure in

the medium term and is deemed to be of medium significance without mitigation. The blasting specialist

has indicated that the human response to the modelled ground vibration levels would be at an

“unpleasant” level up to 592 m of the boundary of the quarry footprint. Consequently, it is recommended

that the relocation of households within 600 m of the quarry boundary be considered. By relocating third-

parties outside of the project footprint and the blasting zone (a distance of 600 m, as recommended by

the blasting specialist), the significance of the residual impact would reduce to LOW.

Not going ahead with the proposed quarry operations (No-Go Alternative) would result in the

maintenance of the status quo. No change to the current impacts on terrestrial and freshwater

ecosystems, ambient air quality, noise, heritage and cultural resources, traffic and land uses is

anticipated. Furthermore, there would be NO IMPACT with respect to blasting hazards and the influx of

job seekers. However, not proceeding with the proposed project would result in the loss of direct and

indirect socio-economic benefits of the proposed project and lost economic opportunities related to costs

already incurred in the initial planning phase. This is considered to be of HIGH significance.


SLR Ref. 723.19083.00003 Report No.5



11. PROPOSED IMPACT MANAGEMENT OBJECTIVES AND THE

IMPACT MANAGEMENT OUTCOMES FOR INCLUSION IN THE

EMPR

The impact management objectives and outcomes for inclusion in the EMPR are detailed under the

mitigation measures listed in Section 8.2 above.

12. FINAL PROPOSED ALTERNATIVES

The final proposed preferred alternatives for the proposed project entail the site layout plan included in

Figure 4-1 and the overall project description provided in Section 4.

13. ASPECTS FOR INCLUSION AS CONDITIONS OF

AUTHORISATION

Recommendations for any aspects that must be made a condition of the Environmental Authorisation are

included in in Section 14.3 below.

14. DESCRIPTION OF ANY ASSUMPTIONS, UNCERTAINTIES AND

GAPS IN KNOWLEDGE

The EIA assumptions and limitations are listed below:

• The Scoping and EIA assumes that SLR has been provided with all relevant project information

and that it was correct and valid at the time it was provided.

• Specialists have been provided with all the relevant project information in order to produce

accurate and unbiased assessments.

• There will be no significant changes to the project description or surrounding environment between

the completion of the EIR and implementation of the proposed project that could substantially

influence findings, recommendations with respect to mitigation and management etc.

• The blasting assessment is based, to a large extent, on a generic description of the proposed

quarrying activities, as the specific details were not available at the time of writing the blasting

impact report (e.g. exact timing and duration of blasts, sound levels, etc.).

These assumptions and limitations, however, are not considered to have any negative implications in

terms of the credibility of the results of the EIA process.

14.1. REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY

SHOULD OR SHOULD NOT BE AUTHORISED

The key principles of sustainability, including ecological integrity, economic efficiency, and equity and

social justice, are integrated below as part of the supporting rationale for providing an opinion on whether

the proposed project should or should not be approved.


SLR Ref. 723.19083.00003 Report No.5



• Ecological integrity7

The potential disturbance of Ngongoni Veld and associated biodiversity is considered to be of high

intensity as all vegetation (and associated available habitat) within the quarry footprint would be

lost during the course of quarry operations. The area of disturbance (approximately 70 ha including

the proposed project footprint and associated access road) is considered to be relatively

substantial in comparison to the remaining intact area of this ‘Vulnerable’ vegetation type.

Furthermore, there are numerous conservation-important species present within the grassland

ecosystem at the site which may be destroyed/damaged if measures are not taken to preserve

these plants. By undertaking a plant search and rescue operation prior to the clearing of the site,

the impact on conservation-important species would be mitigated.

As the loss of Ngongoni Veld due to quarry establishment is accommodated in the approved

Biodiversity Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015), the loss of

this vegetation type within the project footprint would be compensated for and the overall

significance of the project impact on the conservation status of the vegetation type would be

reduced.

• Economic efficiency

The area surrounding the proposed quarry site is generally undeveloped with very limited socio-

economic opportunities. The proposed project would create local employment and business

opportunities. These potential benefits to the local economy would extend over the operational

lifespan of the proposed project. It is anticipated that a large number of the low- and semi-skilled

employment opportunities could be sourced from the local labour force, especially during the site

establishment phase. In terms of business opportunities for local companies, contract procurement

requirements would create business opportunities for the regional and local economy. A

percentage of the monthly wage bill earned by permanent staff would be spent in the regional and

local economy, which would benefit local businesses.

In light of the above, the proposed project is considered to be economically efficient, as it would

provide an opportunity to utilise natural resources within the Eastern Cape with associated socio-

economic benefits. With the recommended enhancement measures, any possible negative impact

associated with inward migration would be further reduced.

• Equity and social justice

While the proposed project would require the relocation of people residing within the project

footprint and the associated blasting zone (600m from the boundary of the quarry footprint), the

relocation would be undertaken by the appointed land management specialist in accordance with

the requirements of, amongst others, the Constitution of South Africa Act, 1996 (Act No. 108 of

1996) and the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996), as

applicable. These legislative provisions ensure, amongst others, that directly affected parties

receive fair and equitable treatment and that no person shall be worse off when compared to their

current situation.

It is the opinion of SLR that, in terms of the sustainability criteria described above and the nature and

extent of the proposed quarry activities, the generally LOW to MEDIUM significance residual impacts

should support a positive decision being made by the Minister of Mineral Resources (or delegated

authority) in this regard.

7 Ecological integrity is the abundance and diversity of organisms at all levels, and the ecological patterns, processes and structural

attributes responsible for that biological diversity and for ecosystem resilience.


SLR Ref. 723.19083.00003 Report No.5



14.2. REASONS WHY THE ACTIVITY SHOULD BE AUTHORISED OR NOT

See rationale provided in Section 14.1 above as to why the proposed activity may be authorised.

14.3. CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION

14.3.1. SPECIFIC CONDITIONS TO BE INCLUDED INTO THE COMPILATION AND

APPROVAL OF EMPR

The following specific conditions are recommended:


accommodates the potential loss of primary Ngongoni Veld due to stockpiling and/or the

establishment of borrow pits/quarries, is implemented effectively.

• A protected plant survey must be undertaken within the primary terrestrial Ngongoni grassland

within the project footprint, in order to confirm the presence and abundance of threatened and

protected plant species. This survey must be undertaken by a suitably qualified botanist, prior to

the commencement of construction, during the summer growing season (between November and





activities in order to collect baseline data for the monitoring of water quality impacts associated with

construction and operation of the quarry.


surface and near-surface water management facilities will be designed, constructed and operated







monitoring positions have been proposed by the blasting specialist (see Figure 18 and Table 17 of

Appendix 4.3).



14.3.2. REHABILITATION REQUIREMENTS

Requirements for rehabilitation have been outlined in Sections 4.5.3 (rehabilitation guidelines for the

access road crossing the KwaDlambu River) and 5.3.3 (rehabilitation guidelines for terrestrial habitat) of

the aquatic and terrestrial ecology specialist report (see Appendix 4.1). Notwithstanding the above, given

the long-term nature of the proposed operations, it is further recommended that a comprehensive

Rehabilitation and Closure Plan be developed prior to the decommissioning and closure of the proposed

quarry operation.

In summary, during rehabilitation, the topography would be finished off so that the sides of the quarry

area are shaped in accordance with the recommendations of the project engineer and contoured to

prevent rapid runoff of water that could cause soil erosion.


SLR Ref. 723.19083.00003 Report No.5



Shaping of the quarry would provide flowing curves that blend with the surrounding landscape in

preference to sharp angles. Topsoil and mulched vegetation stripped during site clearance would be

spread evenly across the quarry area as soon as possible after each phase of extraction, where

applicable. For revegetation of the site, the ideal species for seeding would be mat-forming or tufted

pioneer grasses that can become quickly established at the site to provide immediate cover in order to

stabilise soils and reduce erosion risk. The initial pioneer grass cover (annuals) would then be replaced

by subclimax and climax grass species naturally occurring at the site, such as Aristida junciformis subsp.

junciformis, which will typically outcompete pioneer grasses over time through natural successional

processes. Recommended pioneer grasses for attaining an initial cover at disturbed sites (based on the

climate and soil occurring at the site) may include Cynodon dactylon (Couch grass), Chloris gayana

(Rhodes grass), Eragrostis tef and Urochloa mosambicensis (Bushveld signal grass).

14.3.3. PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED

The period for which the Environmental Authorisation is required would be for the total estimated Life of

Mine for the operations (15 years).

15. UNDERTAKING

The undertaking by the EAP is included in Appendix 4 of the main report.

16. FINANCIAL PROVISION

16.1. EXPLAIN HOW THE AFORESAID AMOUNT WAS DERIVED

In terms of Section 24P of NEMA and associated regulations pertaining to the financial provision

(GN No. R1147), an applicant for Environmental Authorisation must, before the Minister of Mineral

Resources issues the Environmental Authorisation, comply with the prescribed financial provision for the

rehabilitation, closure and ongoing post-decommissioning management of negative environmental

impacts.

SANRAL would discuss and conclude the nature and quantum of the financial provision required for the

management and remediation of environmental damage with DMR. It is understood that in terms of the

agreement between SANRAL and DMR, it is anticipated that the contract for the proposed works would

include a 10% retention (up to a limit of R1 million) which is to be withheld until all work (inclusive of a

rehabilitation work set out in the EMP) has been completed to the satisfaction of the engineering team

and DMR.

16.2. CONFIRM THAT THIS AMOUNT CAN BE PROVIDED FOR FROM

OPERATING EXPENDITURE

The estimated cost for the proposed rehabilitation would be included in the operational expenditure

planned for the proposed quarry operations.


SLR Ref. 723.19083.00003 Report No.5



17. DEVIATIONS FROM THE APPROVED SCOPING REPORT AND

PLAN OF STUDY

17.1. DEVIATIONS FROM THE METHODOLOGY USED IN DETERMINING THE

SIGNIFICANCE OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS

This section is not applicable given that the impact assessment methodology used to determine the

significance of potential environmental impacts and risks in the EIR and EMP did not deviate from the

plan of study outlined in the Scoping Report.

17.2. MOTIVATION FOR THE DEVIATION

Not applicable.

18. OTHER INFORMATION REQUIRED BY THE COMPETENT

AUTHORITY

18.1. IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY

AFFECTED PERSON

The identified impacts on the socio-economic condition of directly affected persons and the proposed

mitigation measures to manage these impacts are provided in Section 8.2.2 above.

18.2. IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF

THE NATIONAL HERITAGE RESOURCES ACT

The identified potential impacts on cultural heritage resources and the proposed mitigation measures to

manage these impacts are provided in in Section 8.2.2.1 above.

19. OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A)

AND (B) OF THE ACT

No other matters are required in terms of Section 24(4)(A) and (B) of the Act.

PART B

FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME

REPORT


SLR Ref. 723.19083.00003 Report No.5


Environmental Management Programme Report April 2017

1. FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME

REPORT

1.1. 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 as

required.

The contact details of the EAP who prepared this EIR and EMPR are provided in Section 1.1 of the EIR

(refer to Part A). The expertise of the individuals who prepared this EIR and EMPR are provided on

Page ii of Part A. The relevant curricula vitae and proof of registrations are provided in Appendix 1.

2. DESCRIPTION OF THE ASPECTS OF THE ACTIVITY

Description of the aspects of the activity. Confirm that the requirement to describe the aspects of the activity that are

covered by the environmental management programme is already included in PART A as required.

The description of the activities to be undertaken as part of the development of the proposed quarry is

included in Section 4 of the EIR.

3. 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.

A map showing the extent of the proposed quarry site, access road and associated infrastructure is

provided in Part A, Figure 4-1 of the EIR. The location of the identified vegetation communities and

protected plant species, as well as the identified surface water features and associated buffer areas, in

relation to the project footprint, are illustrated in Part A, Figures 8-2 and 8-3 of the EIR, respectively.

4. DESCRIPTION OF IMPACT MANAGEMENT OBJECTIVES

4.1. DETERMINATION OF CLOSURE OBJECTIVES

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

The objectives for closure of the proposed quarry are to:

• Initiate a consultative process with the local community to identify and confirm a suitable end use

for the quarry, closer to the time of closure. It is currently proposed that the local community

would continue with the quarry operations following the completion of construction of the N2 Wild

Coast Toll Highway. The anticpated life of the quarry would be 15 years.

• Implement progressive rehabilitation, as far as possible, throughout the life of the quarry to reduce

the rehabilitation efforts required at the time of closure. These measures include:

o Rehabilitation and seeding / planting of areas where quarrying and surface activities

have ceased;

o Storing of sufficient quantities of topsoil (all available topsoil) for future rehabilitation

efforts;


SLR Ref. 723.19083.00003 Report No.5



o Erosion prevention; and

o Stabilisation and re-shaping of eroded steep slopes on berms and stockpiles.

• Remove all product stockpiles.

• For all slopes:

o Investigate slope stability to determine the final safe / stable slope angle;

o The final profile of quarry slopes would depend on their overall stability, with due

consideration of factors such as pre-existing joints, fault patterns, and permeating ground

water (if any);

o Avoid long slopes, which could pose a safety hazard; and

o Seed slopes with mixed natural grass species as per the recommendations of the aquatic

and terrestrial ecology specialist.

• Discourage access to areas posing a safety hazard, in accordance with applicable legal and

regulatory requirements.

• Stabilise rehabilitated ground against wind and water erosion.

• Reduce residual impacts on surface water as well as landscape character.

• Establish self-sustaining natural vegetation cover on all disturbed areas.

4.2. THE PROCESS FOR MANAGING ANY ENVIRONMENTAL DAMAGE,

POLLUTION, PUMPING AND TREATMENT OF EXTRANEOUS WATER OR

ECOLOGICAL DEGRADATION AS A RESULT OF UNDERTAKING A

LISTED ACTIVITY

The mitigation measures outlined in Part A, Section 8.2 and in the Environmental Management

Programme (EMP) prepared for the construction and operational phases (see Appendix 6) have been

identified in order to manage and reduce impacts and prevent unnecessary damage to the environment

as a result of the proposed project. In the event that incidents that may result in environmental damage

occur, the emergency response procedure will be implemented to avoid pollution or degradation (see

Section 2.7 of the EMP). It is noted that due to the nature of the proposed quarry operations, the

“pumping and treatment of extraneous water“ is not required.

4.3. POTENTIAL RISK OF ACID MINE DRAINAGE

4.3.1. INDICATE WHETHER OR NOT THE MINING CAN RESULT IN ACID MINE

DRAINAGE

Not applicable. The proposed project does not include any activities which would result in acid mine

drainage.

4.3.2. STEPS TAKEN TO INVESTIGATE, ASSESS, AND EVALUATE THE IMPACT OF

ACID MINE DRAINAGE

Not applicable.


SLR Ref. 723.19083.00003 Report No.5



4.3.3. ENGINEERING OR MINE DESIGN SOLUTIONS TO BE IMPLEMENTED TO AVOID

OR REMEDY ACID MINE DRAINAGE

Not applicable.

4.3.4. MEASURES THAT WILL BE PUT IN PLACE TO REMEDY ANY RESIDUAL OR

CUMULATIVE IMPACT THAT MAY RESULT FROM ACID MINE DRAINAGE

Not applicable.

4.4. VOLUMES AND RATE OF WATER USE REQUIRED FOR THE MINING,

TRENCHING OR BULK SAMPLING OPERATION

It is anticipated that a minimal volume of water would be required for the operation of the proposed quarry

(e.g. for dust suppression, potable water etc.). As noted in Part A, Section 4.2.4, water would be sourced

by the appointed contractor(s).

4.5. HAS A WATER USE LICENCE HAS BEEN APPLIED FOR?

The anticipated water use authorisation requirements of the proposed project are described in Part A,

Section 5.1.4 of the EIR. In this regard, a separate Water Use Licence Application will be submitted to

the Department of Water and Sanitation (DWS) Eastern Cape Regional Office for approval. Water

abstraction licensing / authorisation would need to be applied for / registered by the appointed

contactor(s).


SLR Ref. 723.19083.00003 Report No.5

Proposed establishment of a quarry in the Ngquza Hill Local Municipality, Eastern Cape Environmental Management Programme Report

April 2017

4.6. IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES

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

ACTIVITIES PHASE of operation in which activity will take place. State Planning and Design, Pre-Construction, Construction, Operational, Rehabilitation Closure.

SIZE AND SCALE 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.

Site selection and final

quarry layout

Planning and design Approximately 55 ha

for the proposed

quarry and 14.7 ha for

the proposed access

road

• The site layout plan has been amended based on

specialist recommendations in order to allow for

buffer areas between the quarry activities and

identified watercourses.

Specialist

recommendations (see

Appendix 4.1 to 4.3)

During EIA process

Site demarcation Pre-construction Individual footprints of

project components

• Demarcate the quarry site footprint using

appropriate fencing material.

• Areas outside of the development footprint and

operational area are to be considered sensitive ‘No-

Go’ areas.

Quarry plan and EMP

(see Sections 2.13.2

and 3.3 of the EMP

attached as Appendix 6)

During site establishment

Site clearance Site establishment

and access road

construction

Approximately 55 ha

for the proposed

quarry and 14.7 ha for

the proposed access

road

• Strip topsoil layer up to at least 300 mm where

possible and store separately.

• Keep seed-bearing material separate for use during

rehabilitation or preferably mulch vegetation into the

topsoil.

• Vegetation clearing shall take place in a phased

manner in order to retain vegetation cover for as

long as possible. This would reduce the size of

areas where dust can be generated and sediment

runoff may take place.

Quarry plan and EMP

(see Section 2.13.3 of

the EMP)


Stockpiling Operational Unknown at this stage,

but within the project

footprint

• Temporary stockpiling of excavated material shall

take place in demarcated areas.

• Stockpiles shall be positioned and sloped to create

the least visual impact and to reduce dust

generation.

Quarry plan and EMP

(see Section 3.3.2.4 of

the EMP)

During operational phase


SLR Ref. 723.19083.00003 Report No.5


April 2017

ACTIVITIES PHASE SIZE AND SCALE OF

DISTURBANCE

MITIGATION MEASURES COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

Topsoil management Operational and

rehabilitation

Up to 300 mm depth

across the project

footprint

• Topsoil shall be stored separately and in stockpiles

not exceeding 2 m in height.

• Topsoil stockpiles shall be protected from erosion by

wind and rain by providing suitable stormwater and

cut off drains and/or by establishing suitable

temporary vegetation, if necessary.

• Topsoil stockpiles shall be monitored regularly to

identify and remove any alien plants.

Quarry plan and EMP

(see Sections 2.13.3.2

and 2.13.3.3 of the

EMP)

During site establishment and

operational phase

Blasting Operational Quarry footprint and

600 m blasting zone

• Relocate households outside of blasting zone. • Implementation of a blast management plan. • Pre-mining photographic crack survey. • Communication of planned blasting times with

stakeholders. • Pre-blast warning. • Monitoring blasts. • Audit and review to adjust blast design were

necessary. • Investigate blast-related complaints.

Quarry plan and EMP

(see Section 3.3.13.2 of

the EMP)


Transport Operational Unknown, but limited

to proposed access

roads and provincial

road network

• Vehicle movement shall be limited to defined tracks

and roads.

• Material from the quarry shall be appropriately

secured to ensure safe passage between

destinations.

• Movement of construction vehicles shall be limited

to daylight hours.

• Dangers associated with the movement of large

haulage vehicles shall be clearly sign-posted.

EMP (see Sections

2.13.1.1 and 3.3.11 of

the EMP)


Ablution facilities Operational Unknown at this stage,

but within the project

footprint

• The appointed contractor shall provide and maintain

adequate portable ablution facilities. These facilities

must be easily accessible and shall be secured in

order to prevent them from blowing over.

• Ablution facilities shall be located at least 32 m

away from the river systems and wetland areas.

• A suitable sub-contractor shall be appointed to

empty toilets on a regular basis.

EMP (see Section

2.13.1.2 of the EMP)


Refuelling and

maintenance

Operational Within project footprint • Should any refuelling of plant be required at the

quarry site, a drip tray shall be used.

• Ensure that there is always a supply of absorbent

material readily available in order to treat any minor

EMP (see Sections

2.13.5 and 3.3.3 of the

EMP)



SLR Ref. 723.19083.00003 Report No.5


April 2017

ACTIVITIES PHASE SIZE AND SCALE OF

DISTURBANCE

MITIGATION MEASURES COMPLIANCE WITH

STANDARDS

TIME PERIOD FOR

IMPLEMENTATION

hydrocarbon leaks or spills.

• Ensure that all vehicles and equipment are kept in

good working order and serviced regularly in order

to prevent hydrocarbon leaks.

Stormwater and soil

erosion

Operational and

rehabilitation

Within and downslope

of quarry footprint

• Develop a detailed Stormwater Management Plan

that describes the methodology for undertaking

construction of the stormwater infrastructure. The

stormwater plan should describe the design

measures surface and near surface water

management facilities will be designed, constructed

and operated so that contaminated water is kept

separate from clean water run-off through a system

of berms, channels, trenches, flood and erosion

protection measures.

• No stormwater run-off is to be routed directly to any

drainage lines.

EMP (see Sections

2.13.7 and 3.3.5 of the

EMP)

During operational phase and

rehabilitation

Changes to existing land

uses

Operational Within and in close

proximity to quarry

footprint

• Relocate all households within 600 m from the

quarry boundary outside of the project footprint and

assocaited blasting zone.

• Implement the EMP commitments with a view not

only to prevent and/or mitigate the various

environmental and social impacts, but also to

prevent negative impacts on surrounding land uses.

• If a situation arises where any surrounding land use

are negatively affected by the operations, the

contractor will immediately take steps to address the

cause of the impacts.

• Incorporate measures to achieve the future land use

plans for the project site during closure planning.

EMP (see Section 3.3.7

of the EMP)

During site establishment and

operational phase


SLR Ref. 723.19083.00003 Report No.5


April 2017

4.7. IMPACT MANAGEMENT OUTCOMES

A description of impact management outcomes, identifying the standard of impact management required.



ASPECTS AFFECTED






Refer to Part A, Section 9.1 of the EIR.


SLR Ref. 723.19083.00003 Report No.5


April 2017

4.8. IMPACT MANAGEMENT ACTIONS

A description of impact management actions, identifying the manner in which the impact management objectives and outcomes will be achieved.

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, etc.).

POTENTIAL IMPACT

(E.g. Dust, noise, drainage surface disturbance, fly rock, surface water contamination,

groundwater contamination, air pollution etc.).

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.).

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. 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.)

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

Site preparation (includes,

site demarcation, site

access, vegetation clearing

etc.)

Loss of natural vegetation

and faunal habitat due to

site clearing

As per measures included in the

table provided in Section 9.1 of

the EIR and the EMP attached as

Appendix 6.

At commencement of site establishment

and construction of access road EIR and EMP

Soil erosion

Excavation

Surface water

contamination




Appendix 6.

For the duration of operational phase EIR and EMP

Air Quality

Noise

Heritage / archaeology

Land use

Job creation

Blasting

Air Quality As per measures included in the



Appendix 6.


Applicable norms and standards Noise

Land use

Storage of excavated

material (stockpiling etc.)

Air Quality As per measures included in the



Appendix 6.


Soil pollution

Surface water

contamination


SLR Ref. 723.19083.00003 Report No.5


April 2017

ACTIVITY POTENTIAL IMPACT MITIGATION TYPE TIME PERIOD FOR IMPLEMENTATION COMPLIANCE WITH STANDARDS

Transport of resource

(loading, hauling, roads etc.)

Traffic safety and access As per measures included in the


the EIR.

At commencement of site establishment

and for the duration of operational phase EIR and EMP

Air Quality

Rehabilitation and closure

(shaping, removal of

infrastructure, spreading of

topsoil etc.)

Unsuccessful rehabilitation

resulting in poor vegetation

cover, erosion, loss of

grazing and cultivation

potential etc.



the EIR.

Immediately after completion of material

extraction and during final closure

activities

EIR and EMP

Approved Rehabilitation and

Closure Plan


SLR Ref. 723.19083.00003 Report No.5



5. FINANCIAL PROVISION

5.1. DETERMINATION OF THE AMOUNT OF FINANCIAL PROVISION

5.1.1. DESCRIBE THE CLOSURE OBJECTIVES AND THE EXTENT TO WHICH THEY

HAVE BEEN ALIGNED TO THE BASELINE ENVIRONMENT DESCRIBED UNDER

REGULATION 22 (2) (D)

The objectives for closure of the proposed quarry are outlined in Section 4.1 above. The main closure

objective is to ensure that the quarry footprint would be shaped and rehabilitated in order to allow for the

establishment of natural vegetation over time or, where applicable, the facilitation of the end land use

identified for the site during detailed closure planning.

5.1.2. CONFIRM SPECIFICALLY THAT THE ENVIRONMENTAL OBJECTIVES IN

RELATION TO CLOSURE HAVE BEEN CONSULTED WITH LANDOWNER AND

INTERESTED AND AFFECTED PARTIES

Proof of consultation with I&APs is provided in Part A, Section 7.2 of the EIR. No specific comments

relating to the environmental objectives for closure have been received.

5.1.3. 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

Given the long-term nature of the proposed operations, it is recommended that a comprehensive

Rehabilitation and Closure Plan be developed prior to the decommissioning and closure of the proposed

quarry operation. The scale and aerial extent of the proposed quarry at closure is provided in Part A,

Figure 4-1 of the EIR.

Notwithstanding the above, the specific requirements for rehabilitation have been outlined in

Sections 4.5.3 (rehabilitation guidelines for the access road crossing the KwaDlambu River) and 5.3.3

(rehabilitation guidelines for terrestrial habitat) of the aquatic and terrestrial ecology specialist report (see

Appendix 4.1).

5.1.4. COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE

OBJECTIVES

The rehabilitation measures outlined in the aquatic and terrestrial ecology specialist report (as noted

above) are considered to be compatible with the closure objectives identified for the site.


SLR Ref. 723.19083.00003 Report No.5



5.1.5. CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION

REQUIRED TO MANAGE AND REHABILITATE THE ENVIRONMENT IN

ACCORDANCE WITH THE APPLICABLE GUIDELINE

In terms of Section 24P of NEMA and associated regulations pertaining to the financial provision (GN No.

R1147), an applicant for Environmental Authorisation must, before the Minister of Mineral Resources

issues the Environmental Authorisation, comply with the prescribed financial provision for the

rehabilitation, closure and ongoing post decommissioning management of negative environmental

impacts.

SANRAL would discuss and conclude the nature and quantum of the financial provision required for the

management and remediation of environmental damage with DMR. It is understood that in terms of the

agreement between SANRAL and DMR, it is anticipated that the contract for the proposed works would

include a 10% retention (up to a limit of R 1 million) which is to be withheld until all work (inclusive of all

rehabilitation work set out in the EMP) has been completed to the satisfaction of the engineering team

and DMR.

5.1.6. CONFIRM THAT THE FINANCIAL PROVISION WILL BE PROVIDED AS

DETERMINED

The estimated cost for the proposed rehabilitation would be included in the operational expenditure

planned for the proposed quarry operations.


SLR Ref. 723.19083.00003 Report No.5


April 2017

6. MECHANISMS FOR MONITORING COMPLIANCE WITH AND PERFORMANCE ASSESSMENT

AGAINST THE ENVIRONMENTAL MANAGEMENT PROGRAMME AND REPORTING THEREON Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including a) Monitoring of Impact Management Actions; b) Monitoring and reporting frequency; c) Responsible persons; d) Time period for implementing impact management actions; and e) Mechanism for monitoring compliance.

The functional requirements for monitoring have been listed below with further details being provided in the EMP for the construction and operational phases (see

Appendix 6).

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 PERIODS FOR IMPLEMENTING

IMPACT MANAGEMENT ACTIONS

Authorisation and

administration

Relevant

authorisations,

registrations and

permits are in place

• Ensure that all relevant authorisations and

permits have been obtained (e.g. Water Use

Authorisation, blasting etc.).

• Ensure that a copy of the EIR and EMP are

provided to all relevant stakeholders and kept

on-site.

Applicant Prior to site establishment

Site preparation Site establishment,

demarcation,

vegetation clearing, soil

erosion

• Site demarcation, fencing and identification of

no-go areas.

• Provision of appropriate ablution facilities and

eating areas.

• Vegetation and topsoil clearing.

• Soil erosion due to vegetation clearing.

ECO, Resident Engineer,

appointed Contractor,

Environmental Officer

(EO)


Daily monitoring by the Contractor’s designated

EO and monthly auditing by ECO


SLR Ref. 723.19083.00003 Report No.5


April 2017


MONITORING

PROGRAMMES


MONITORING

ROLES AND

RESPONSIBILITIES






Excavation

Surface water

contamination • Maintain designated buffer areas from

identified surface water features (refer to

Figure 8-3 of the EIR).

• Prevent contaminated run-off from entering

surface water features.

• Maintenance of machinery and equipment,

refuelling, supply of absorbent material, leaks

and spills.

EO, ECO, Quarry

Operator and

Environmental Site

Officer (ESO)

Daily monitoring during operational phase (Quarry

Operator and ESO)

Construction (daily monitoring by the EO and

monthly auditing by ECO) and Operation (daily by

ESO)

Dust

• Dust suppression measures.

• Securing of material loads during

transportation and compliance with speed

limits.

ECO, EO, and ESO Construction (daily monitoring by the EO and


ESO)

Noise • Compliance with local by-laws and regulations

regarding the generation of noise and hours of

operation.



ESO)

Blasting • Monitor compliance with blast management plan.

• Audit and review to adjust blast design. • Investigate blast-related complaints.

Quarry Operator and

ESO

Operation (as required by ESO)

Heritage / archaeology • Notify the SAPS and ECPHRA or SAHRA

should human remains be uncovered.

ECO, EO, ESO Construction (daily monitoring by the EO and


ESO)

Land use • Site to be rehabilitated in line with closure

objectives and in consultation with local

community.

Applicant and Quarry

Operator

During decommissioning and closure phase

Fire hazard • Avoid damage to surrounding private property

and infrastructure due to runaway fires by

ensuring that the necessary fire prevention

measures are in place.



ESO)

Storage of material

(stockpiling etc.)

Waste management • Avoid pollution from inappropriate solid waste

and wastewater management.

EO, ECO, Quarry

Operator and ESO



Quarry Operator and ESO)


SLR Ref. 723.19083.00003 Report No.5


April 2017


MONITORING

PROGRAMMES


MONITORING

ROLES AND

RESPONSIBILITIES






Dust from stockpiles • Appropriate storage of excavated material

stockpiles and dust suppression measures.

EO, ECO, Quarry

Operator and ESO




Loss or contamination

of topsoil

• Appropriate management and monitoring of

topsoil stockpiles.

EO, ECO, Quarry

Operator and ESO




Transport of resource

(loading, hauling,

roads etc.)

Traffic safety and

access

• Traffic safety measures linked to vehicle

speed, access route etc.

EO, ECO, Quarry

Operator and ESO




Loss of material from

haul vehicles

• Appropriately secure material loads to ensure

safe passage between destinations.



ESO)

Rehabilitation and

closure

Rehabilitation success • Rehabilitation of quarry is to be undertaken in

a phased manner, wherever possible, and in

accordance with an approved rehabilitation

plan.

Applicant and Quarry

Operator

During decommissioning and closure phase


SLR Ref. 723.19083.00003 Report No.5



6.1. INDICATE THE FREQUENCY OF THE SUBMISSION OF THE

PERFORMANCE ASSESSMENT REPORT

Performance Assessment Reports, as required by the NEMA EIA Regulations 2014, would be prepared

and submitted every two years to DMR or as often as requested by DMR.

In addition, the appointed ECO would undertake regular site audits during the site establishment /

construction phase (see Section 2.12 of the EMP). Copies of the site audits reports could be submitted to

DMR if requested.

7. ENVIRONMENTAL AWARENESS PLAN

7.1. MANNER IN WHICH THE APPLICANT INTENDS TO INFORM HIS OR HER

EMPLOYEES OF ANY ENVIRONMENTAL RISK WHICH MAY RESULT

FROM THEIR WORK

Before the commencement of any activities at the site, the appointed Contractor's site management staff

should attend an environmental awareness-training course (see Section 2.6 of the EMP for contents of

the training course).

7.2. MANNER IN WHICH RISKS WILL BE DEALT WITH IN ORDER TO AVOID

POLLUTION OR THE DEGRADATION OF THE ENVIRONMENT

Risks would be managed and environmental impacts prevented or minimised by the implementation of

the recommended mitigation measures and EMP (Appendix 6). SANRAL would be responsible for the

implementation of the required mitigation measures in order to avoid pollution or degradation of the

environment. Appropriate implementation of the recommended mitigation measures and EMP would be

monitored through regular site audits during site establishment and operation.

8. SPECIFIC INFORMATION REQUIRED BY THE COMPETENT

AUTHORITY

Among others, confirm that the financial provision will be reviewed annually

The financial provision as set out above would be reviewed on an annual basis or as requested by DMR.

9. UNDERTAKING

Refer to Appendix 6 of the main report.

Documents

Proposed establishment of a quarry in the Ngquza Hill ...slrconsulting.com/media/files/documents/Main-Report.pdf · Proposed establishment of a quarry in the Ngquza Hill Local Municipality,