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Scoping Report 1 SCOPING REPORT FOR LISTED ACTIVITIES ASSOCIATED WITH MINING RIGHT AND/OR BULK SAMPLING ACTIVITIES INCLUDING TRENCHING IN CASES OF ALLUVIAL DIAMOND PROSPECTING. SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED). NAME OF APPLICANT: Newshelf 1186 (Pty) Ltd TEL NO: 011 726 1047 FAX NO: 011 726 1087 POSTAL ADDRESS: Postnet Suite 115, Private Bag X17, Weltevreden Park, 1715 PHYSICAL ADDRESS: Constantia Office Park, Bridgeview House, Ground Floor, Corner 14th Avenue and Hendrik Potgieter Street ,Weltevreden Park FILE REFERENCE NUMBER SAMRAD: GP 30/5/1/2/2/10061 MR OCTOBER 2017

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Page 1: SCOPING REPORT FOR LISTED ACTIVITIES ASSOCIATED …

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SCOPING REPORT

FOR LISTED ACTIVITIES ASSOCIATED WITH MINING RIGHT

AND/OR BULK SAMPLING ACTIVITIES INCLUDING TRENCHING

IN CASES OF ALLUVIAL DIAMOND PROSPECTING.

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL

ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL

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

BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM

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

NAME OF APPLICANT: Newshelf 1186 (Pty) Ltd

TEL NO: 011 726 1047

FAX NO: 011 726 1087

POSTAL ADDRESS: Postnet Suite 115, Private Bag X17, Weltevreden Park, 1715

PHYSICAL ADDRESS: Constantia Office Park, Bridgeview House, Ground Floor, Corner 14th Avenue and

Hendrik Potgieter Street ,Weltevreden Park

FILE REFERENCE NUMBER SAMRAD: GP 30/5/1/2/2/10061 MR

OCTOBER 2017

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IMPORTANT NOTICE

In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as

amended), the Minister must grant a prospecting or mining right if among others the mining

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

environment”.

Unless an Environmental Authorisation can be granted following the evaluation of an

Environmental Impact Assessment and an Environmental Management Programme report

in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA), it

cannot be concluded that the said activities will not result in unacceptable pollution,

ecological degradation or damage to the environment.

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

application must be prepared in a format that may be determined by the Competent

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

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

guidance provided by the competent authority to the submission of applications.

It is therefore an instruction that the prescribed reports required in respect of applications

for an environmental authorisation for listed activities triggered by an application for a right

or permit are submitted in the exact format of, and provide all the information required in

terms of, this template. Furthermore please be advised that failure to submit the information

required in the format provided in this template will be regarded as a failure to meet the

requirements of the Regulation and will lead to the Environmental Authorisation being

refused.

It is furthermore an instruction that the Environmental Assessment Practitioner must

process and interpret his/her research and analysis and use the findings thereof to compile

the information required herein. (Unprocessed supporting information may be attached as

appendices). The EAP must ensure that the information required is placed correctly in the

relevant sections of the Report, in the order, and under the provided headings as set out

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below, and ensure that the report is not cluttered with un-interpreted information and that it

unambiguously represents the interpretation of the applicant.

OBJECTIVE OF THE SCOPING PROCESS

1) THE OBJECTIVE OF THE SCOPING PROCESS IS TO, THROUGH A

CONSULTATIVE PROCESS—

(a) identify the relevant policies and legislation relevant to the activity;

(b) motivate the need and desirability of the proposed activity, including the need and

desirability of the activity in the context of the preferred location;

(c) identify and confirm the preferred activity and technology alternative through an impact

and risk assessment and ranking process;

(d) identify and confirm the preferred site, through a detailed site selection process, which

includes an impact and risk assessment process inclusive of cumulative impacts and a

ranking process of all the identified alternatives focusing on the geographical, physical,

biological, social, economic, and cultural aspects of the environment;

(e) identify the key issues to be addressed in the assessment phase;

(f) agree on the level of assessment to be undertaken, including the methodology to be

applied, the expertise required as well as the extent of further consultation to be

undertaken to determine the impacts and risks the activity will impose on the preferred

site through the life of the activity, including the nature, significance, consequence,

extent, duration and probability of the impacts to inform the location of the

development footprint within the preferred site; and

(g) identify suitable measures to avoid, manage, or mitigate identified impacts and to

determine the extent of the residual risks that need to be managed and monitored.

_________

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ACRONYMS

AEL Atmospheric Emission Licence

BID Background Information Document

CBA Critical Biodiversity Area

C-Plan Gauteng Conservation Plan

CR Critically Endangered

DMR Department of Mineral Resources

DWS Department of Water and Sanitation

EC Electrical Conductivity

EIA Environmental Impact Assessment

EIAR Environmental Impact Assessment Report

EMPr Environmental Management Programme

EN Endangered

ESA Ecological Support Area

GDARD Gauteng Department of Agriculture and Rural Development

GDP Gross Domestic Product

GIS Geographical Information Systems

GPEMF Gauteng Province Environmental Management Framework

IAPs Interested and Affected Parties

IDP Integrated Development Plan

LED Local Economic Development

LoM Life of Mine

MM5 Fifth-Generation Mesoscale Model

MPRDA Minerals and Petroleum Resources Development Act (No. 28 0f 2002)

NAAQS National Ambient Air Quality Standards

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

NEMAQA National Environmental Management Air Quality Act, No. 39 of 2004

NEMBA National Environmental Management: Biodiversity Act, No. 10 of 2004

NEMPAA National Environmental Management Protected Areas Amendment Act, No. 31 of 2004

NEMWA National Environmental Management Waste Act, No. 59 of 2008

NFEPA National Freshwater Ecosystem Priority Areas

NHRA National Heritage Resources Act, No. 25 of 1999

NNR National Nuclear Regulator

NNRA National Nuclear Regulator Act, No. 47 of 1999

NWA National Water Act, No. 36 of 1998

PES Present Ecological State

PHRAG Provincial Heritage Resources Authority of Gauteng

RE Remaining Extent

REC Recommended Ecological Category

ROD Record of Decision

RSDF Regional Spatial Development Framework

SAHRA South African Heritage Resources Association

SANS South African National Standards

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SCC Species of Conservation Concern

TCTA Trans Caledon Tunnel Association

TDS Total Dissolved Solids

VU Vulnerable

WML Waste Management Licence

WUL Water Use Licence

WULA Water Use Licence Application

WWTW Wastewater Treatment Works

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SCOPING REPORT

2) CONTACT PERSON AND CORRESPONDENCE ADDRESS

a) Details of the EAP who prepared the report

Name of Environmental Assessment

Practitioners Prime Resources (Pty) Ltd

Physical Address: 70 - 7th Avenue, Parktown North, Johannesburg

Postal Address: PO Box 2316, Parklands, 2121

Telephone Number: 011 447 4888

Fax Number: 086 604 2219

Email: [email protected]

Professional Affiliations: PrEng; PrSciNat; SAIMM

b) Expertise of the EAP

i) The qualifications of the EAP (With evidence attached as Appendix 1)

Prime Resources (Pty) Ltd is a specialist environmental consulting firm providing environmental,

social, and related services, which was established in 2003. Prime Resources was founded by Peter

Theron (PrEng, SAIMM), the Managing Director and Principal Environmental Consultant of the firm.

Peter has a GDE Environmental Engineering from the University of Witwatersrand and over 30 years’

experience in the field of environmental science and engineering.

Gené Main (Pr.Sci.Nat, Environmental Science), the Project Manager and Principal Scientist for the

proposed project, has a M.Sc. (Botany) from the University of the Western Cape and ten years’

experience in the field of environmental science.

Amanda Tresise (Pr.Sci.Nat, Environmental Science), a Senior Environmental Scientist, has a M.Sc.

(Zoology) and a M.Sc. (Environmental Management) from the University of Johannesburg and five

years’ experience in the field of environmental science.

Louise Jones, an Environmental Scientist, has a M.Sc. (Environmental Science) from the University of

Witwatersrand and four years’ experience in the field of environmental science.

Bronwyn Grover, an Environmental Scientist, has a PhD (Environmental Analytical Chemistry) from

the University of Witwatersrand and one year experience in the field of environmental science.

Key Prime Resources Personnel CVs are attached as Appendix 1.

ii) Summary of the EAP’s past experience

A copy of the Prime Resources Company Profile is attached as Appendix 2.

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3) DESCRIPTION OF THE PROPERTY

Farm Name: Remaining Extent of Portion 3 of Modderfontein 76IR

Application area (Ha)

Mining Right Area: approximately 12 000 ha

Mining area: 226 ha

Surface infrastructure area: 6 ha

Magisterial district: Ekurhuleni South East Magisterial District

Brakpan Sub District

Distance and direction

from nearest town

300 m northeast of Sherwood Gardens and Huntingdon in Brakpan

North

21 digit Surveyor General

Code for each farm portion T0IR00000000007600003

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Locality map (show nearest town, scale not smaller than 1:250 000)

Figure 1: Cons Modder Project locality map

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Figure 2: Cons Modder shafts and planned underground mining area

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Figure 3: Cons Modder Project affected surface area at 7# and initial site layout

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Figure 4: Cons Modder Project affected surface area at 10# and initial site layout

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4) DESCRIPTION OF THE SCOPE OF THE PROPOSED OVERALL ACTIVITY

a) Listed and specified activities (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 – refer to Figure 3 and Figure 4.

NAME OF ACTIVITY (All activities including activities not listed)

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and

transport, Water supply dams and boreholes, accommodation, offices, ablution,

stores, workshops, processing plant, storm water control, berms, roads, pipelines,

power lines, conveyors, etc…etc…etc.)

AERIAL

EXTENT

Ha or m²

LISTED ACTIVITY

Mark with an X

where applicable

or affected.

APPLICABLE LISTING NOTICE

Shaft and winder 7# 200 m2

X

GNR984 of 2014, activity no. 17 -

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

right as contemplated in section 22 of the MPRDA 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

Shaft and winder 10# 200 m2

500T headgear bin 10# 50 m2

Compressors 7# 30 m2

Compressors 10# 10 m2

Drop set operating tower, concrete bank areas and covered loading areas 7# 450 m2

Drop set operating tower, concrete bank areas and covered loading areas 10# 300 m2

Railway loops 7# 100 m2

Railway loops 10# 100 m2

Administration buildings 7# (perimeter fence, gate, security office, offices, covered employee drop off area/bus stop and walkway, change house, lamp

room, banksman cabin and ablution facilities, potable water storage tank and pipeline)

1 100 m2

Administration buildings 10# (perimeter fence, gate, security office, offices, change house, lamp room, banksman cabin and ablution facilities, potable water storage tank and pipeline)

400 m2

General waste storage area 7# 50 m2

General waste storage area 10# 50 m2

Power lines and substations and generator sets 7# 1 000 m2

Power lines and substations and generator sets 10# 800 m2

Topsoil stockpile 10# 1 130 m2

Stormwater diversion infrastructure (trenches, silt traps and flow diffusing infrastructure) 7#

160 m2

Stormwater diversion infrastructure (trenches, silt traps and flow diffusing infrastructure) 10#

300 m2

Grout plant at 10# 1 950 m2

Workshops and stores at 7# 80 m2

Workshops and stores at 10# 80 m2

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NAME OF ACTIVITY (All activities including activities not listed)

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and

transport, Water supply dams and boreholes, accommodation, offices, ablution,

stores, workshops, processing plant, storm water control, berms, roads, pipelines,

power lines, conveyors, etc…etc…etc.)

AERIAL

EXTENT

Ha or m²

LISTED ACTIVITY

Mark with an X

where applicable

or affected.

APPLICABLE LISTING NOTICE

Laydown areas at 7# 1 200 m2

Laydown areas at 10# 1 300 m2

Boot wash at 7# 25 m2

Boot wash at 10# 25 m2

On-going prospecting activities N/A X

GNR984 of 2014, activity no. 19 - The removal and disposal of minerals contemplated in terms of section 20 of the MPRDA including— (a) associated infrastructure, structures and earthworks, directly related to prospecting of a mineral resource; or

(b) the primary processing of a mineral resource including winning, extraction, classifying, concentrating, crushing, screening or washing

Explosives delivery area 10# 200 m2 X

GNR983 of 2014, activity no. 14 - The development and related

operation 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 m3 or more but not exceeding 500 m3

GNR985 of 2014, activity no. 10 - The development and related operation 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 m3 in (c) Gauteng (iv) Sites identified as Ecological Support

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NAME OF ACTIVITY (All activities including activities not listed)

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and

transport, Water supply dams and boreholes, accommodation, offices, ablution,

stores, workshops, processing plant, storm water control, berms, roads, pipelines,

power lines, conveyors, etc…etc…etc.)

AERIAL

EXTENT

Ha or m²

LISTED ACTIVITY

Mark with an X

where applicable

or affected.

APPLICABLE LISTING NOTICE

Areas (ESAs) in the Gauteng Conservation Plan (v) Sites identified within threatened ecosystems listed in terms of the NEMBA (xi) Sites zoned for public open space or equivalent

zoning

Unpaved on-site roads at 7# and access road to Hospital Road from 7#

(assumed 6 m in width) 8 300 m2

X

GNR983 of 2014, activity no. 24 - The development of- (ii) a road with a

reserve wider than 13,5 meters, or where no reserve exists where the road is wider than 8 metres and is outside of an urban area and longer than 1 km GNR985 of 2014, activity no. 4 -

The development of a road wider than

4 metres with a reserve less than 13,5 metres in (c) Gauteng (iv) Sites identified as ESAs in the Gauteng Conservation Plan (v) Sites identified within threatened ecosystems listed in terms of the NEMBA (xii) Sites zoned

for public open space or equivalent zoning

Unpaved on-site roads at 10# and transport route from 10# to Hospital Road (assumed 8 m in width)

14 500 m2

GNR983 of 2014, activity no. 24 - The development of- (ii) a road with a reserve wider than 13,5 meters, or

where no reserve exists where the

road is wider than 8 metres and is outside of an urban area and longer than 1 km GNR985 of 2014, activity no. 4 - The development of a road wider than

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NAME OF ACTIVITY (All activities including activities not listed)

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and

transport, Water supply dams and boreholes, accommodation, offices, ablution,

stores, workshops, processing plant, storm water control, berms, roads, pipelines,

power lines, conveyors, etc…etc…etc.)

AERIAL

EXTENT

Ha or m²

LISTED ACTIVITY

Mark with an X

where applicable

or affected.

APPLICABLE LISTING NOTICE

4 metres with a reserve less than 13,5 metres in (c) Gauteng (v) Sites identified within threatened ecosystems listed in terms of the

NEMBA

Surface infrastructure areas 6 ha X

GNR983 of 2014, activity no. 27 - The clearance of an area of 1 ha or more, but less than 20 ha of indigenous vegetation

GNR983 of 2014, activity no. 30 - Any process or activity identified in terms of section 53(1) of the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004)

GNR985 of 2014, activity no. 12 -The clearance of an area of 300 square metres or more of indigenous vegetation - (c) Gauteng (ii) Within ESAs identified in the Gauteng Conservation Plan or bioregional plans

(iii) On land, where, at the time of the coming into effect of this Notice or thereafter such land was zoned open space, conservation or had an equivalent zoning

GNR985 of 2014, activity no. 15 -

The transformation of land bigger than 1000 square metres in size, to industrial use, where, such land was zoned open space, conservation or

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NAME OF ACTIVITY (All activities including activities not listed)

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and

transport, Water supply dams and boreholes, accommodation, offices, ablution,

stores, workshops, processing plant, storm water control, berms, roads, pipelines,

power lines, conveyors, etc…etc…etc.)

AERIAL

EXTENT

Ha or m²

LISTED ACTIVITY

Mark with an X

where applicable

or affected.

APPLICABLE LISTING NOTICE

had an equivalent zoning, on or after 02 August 2010

Activities requiring a Water Use Licence (WUL) - Infrastructure at 7# within 500 m of a wetland

3 ha

X

GNR984 of 2014, activity no. 6 -

The development of facilities or infrastructure for any process or activity which requires a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the

generation or release of emissions, pollution or effluent.

Activities requiring a Water Use Licence (WUL) - Containment of domestic wastewater at 7#

30 m2

Activities requiring a Water Use Licence (WUL) - Containment of domestic wastewater at 10#

30 m2

Activities requiring a Water Use Licence (WUL) - Containment of water containing waste in pollution control facilities at 7#

700 m2

Activities requiring a Water Use Licence (WUL) - Containment of water

containing waste in pollution control facilities at 10# 1 100 m2

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b) Description of the activities to be undertaken (Describe Methodology or technology to be

employed, and for a linear activity, a description of the route of the activity)

Newshelf 1186 (Pty) Ltd (the Applicant) holds prospecting rights over areas previously mined in the

East Rand Basin during the 1930s to 1950s. The Applicant is applying for a Mining Right over the Cons

Modder area for underground mining only. The Cons Modder Project is planned to be a small-scale

mining operation, with a Life of Mine (LoM) of 10 years. Construction is planned to begin in 2018 and

will take 1 year. The mine will operate for 8 years. After operations, decommissioning and

rehabilitation will take place for a period of 1 year (approximately in 2029).

The project will consist largely of re-equipping two existing incline shafts for the movement of men

and materials at Cons Modder 7 shaft (7#) and the movement of ore and waste rock at Cons Modder

10 shaft (10#). The two shafts are shallow, and the area has been mined historically from 60 to

150 mbs. Mining is planned to continue at approximately this depth. Hydropower will be used for

drilling, utilising underground water. There will be no ventilation shafts or surface fans, only

underground booster fans.

The Cons Modder shafts and mine void are dry as the Trans Caledon Tunnel Association (TCTA) is

presently dewatering to maintain a constant water level. This water level is below the reefs at the

Cons Modder shafts, currently at 153 mbs. Mining will occur approximately 25 m above the water

level.

Surface infrastructure (combined extent of 6 ha) is planned to be located on the Remaining Extent

(RE) of Portion 3 of Modderfontein 76IR. Minimal surface infrastructure is planned at each shaft,

incorporating an area of less than 3 ha at each shaft. Surface infrastructure at both shafts will include:

Perimeter fence, gate and security office (for access control)

Unpaved on-site roads (sealed using a chemical dust suppressant)

A steel headgear (21 m in height at 7# and 25 m in height at 10#)

Winder (the winder electrical equipment, hydraulics and driver’s cabin will all be housed in

shipping containers for ease of installation and decommissioning)

Substation and power lines for connection to nearest existing substation

Diesel generator sets (as standby)

Potable water storage tank and pipeline for connection to municipal supply

Ablution facilities and changehouses (linked to municipal sewer, conservancy and/or or

chemical facilities)

Boot wash areas

Concrete bank areas

Covered loading areas

A drop set operating tower

Several railway loops for the handling of empty and full cars on a continuous basis

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General waste storage area (hard-standing area for covered bins / skips)

Compressors (for the provision of compressed air to the necessary services and the refuge

chambers underground)

Stormwater diversion infrastructure (trenches, silt traps and flow diffusing infrastructure)

Pollution control infrastructure

Workshops and stores

Laydown areas

In addition, 10# will have a topsoil stockpile, grout plant, an explosives delivery area (enclosed) as

well as a 500 T headgear bin to allow for storage of ore hoisted at night. Hoisting will be a 24 h

operation while hauling will only occur for 12 h a day. The bin will be timber lined to reduce noise. 7#

will have a covered employee drop off area and walkway.

Connections for municipal water, electricity supply and sewage disposal will be from the nearest

suburbs.

Construction and Operations

A hoisting rate of 700 T of ore per day is expected at 10#. Waste rock hoisted from 10# will be

trucked directly to a nearby crushing facility and no waste rock will be stored or deposited on the site.

The crushing facility is approximately 800 m to the south east of 10#, which is approximately 1.5 km

by road. A contractor will transport any waste rock directly from the headgear bin to the crushing

facility.

Ore will be transported along the delineated transport route by 20 T trucks to the Modder East

Operations (Modder East) in Springs for processing. The fleet will comprise of 3 to 4 haul trucks.

Tailings material from the processing of the Cons Modder ore at the Modder East plant will be

deposited on the existing tailings storage facility at Modder East. Hauling will be limited to daylight

hours (06h00 - 18h00) including weekends. Approximately 35 trips are expected per 12 hours.

There will be three 8 h shifts per day and 440 employees in total. Employees will be transported to 7#

by taxi from designated pick-up areas. The majority of the employees (± 270) will make up the

morning shift (20 taxi trips). The afternoon shift will consist only of shaft personnel, who will require 4

taxi trips; however 20 trips in total will be required to transport the morning shift to designated drop-

off areas. Night shift personnel will require 9 taxi trips which will also cater for the return of afternoon

shift to designated drop-off areas.

Decommissioning and Rehabilitation

A period of 1 year has been assumed for decommissioning and rehabilitation. All surface infrastructure

will be removed. The area where the proposed surface infrastructure is to be removed will be

rehabilitated to return the area to the pre-mining state (i.e. aligned to the baseline environment) or

an improved state able, where possible, to support a suitable land use based on the planning

objectives for the area and specialist recommendations (i.e. industrial and large commercial

development at 7# and 10#).

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5) POLICY AND LEGISLATIVE CONTEXT

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (a description of the policy and

legislative context within which the development is proposed including an identification of all legislation, policies, plans, guidelines,

spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in

the assessment process)

REFERENCE WHERE APPLIED

The Mineral and Petroleum Resources Development Act (No. 28 of 2002) (MPRDA) is the key legislation governing mining activities within South Africa. It details the requirements and processes which need to be followed and adhered to by mining companies. The Department of Mineral Resources (DMR) is the competent authority that deals with all mining related applications.

An application for a Mining Right was submitted to the DMR on 4 October 2017, through the SAMRAD online system (awaiting acceptance).

An integrated application in terms of the MPRDA and NEMA is being undertaken. The

NEMA process for the proposed Cons Modder Project is described below.

The National Environmental Management Act, No. 107 of 1998 (NEMA) is enabling legislation intended to provide a framework for integrating environmental management into all developmental activities to promote co-operative environmental governance with regard to decision making by state organs on matters affecting the environment.

The EIA Regulations of GNR982, December 2014 as amended in 2017 serve to regulate the procedure and

criteria for submitting, processing and considering decisions for applications for Environmental Authorisation. These Regulations provide details on the process to be followed for the consultation of stakeholders and IAPs, the identification of the Competent Authority, and the various timeframes and application requirements for Environmental Authorisation. A further three Regulations, GNR983, GNR984, and GNR985 (all of 2014 as

amended in 2017), provide lists of activities for which Environmental Authorisation, either in the form of a Basic Assessment or Scoping and Environmental Impact Assessment Report (EIAR) / Environmental Management Programme (EMPr), is required before the activity can commence.

Since the enactment of the “One Environmental System” on 8 December 2014, the Environmental Authorisation process in terms of the NEMA must be followed for any mining activities requiring a right or permit in terms of the MPRDA to fulfil the requirements of Section 5A(a) of the Act. In instances where Environmental Authorisation is required for a mining project, the DMR is identified as the Competent Authority.

An application for Environmental Authorisation in terms of Section 24 of NEMA was submitted together with the Mining Right to the DMR for the NEMA listed activities triggered by the proposed Cons Modder Project.

The application was submitted to the DMR on 4 October 2017 (awaiting acceptance). According to the EIA

Regulations (2014) the following are to be submitted in support of the application for Environmental Authorisation:

Scoping Report (this document) together with the results of consultation with Interested and Affected Parties (IAPs) and State Departments, to be submitted to the Competent Authority within 44 days of submission of the application (on or before 17 November 2017); and the

This Scoping Report has been prepared to meet the requirements of the EIA Regulations (GNR982 of 2014).

Refer to Section 4)a) for the listed activities applicable to the proposed Cons Modder Project.

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EIAR and EMPr together with the results of consultation with IAPs and State Departments within 106

days of acceptance of the Scoping Report.

The National Environmental Management Air Quality Act, No. 39 of 2004 (NEMAQA) has placed the

responsibility for air quality management on local authorities that will be tasked with baseline characterisation, management and operation of ambient monitoring networks, licensing of listed activities, and emissions reduction strategies. GN893 of 2013 provides the list of activities in terms of Section 21(1)(a) for which an Atmospheric Emission Licence (AEL) is required in terms of Chapter 5 of the Act. This notice further establishes minimum emission standards for the listed activities.

The ambient air quality standards (GN1210 of 2009) were determined based on international best practice for PM10 (particulates with an aerodynamic diameter of 10 micron), dust-fall, sulphur dioxide (SO2), nitrogen dioxide

(NO2), ozone (O3), carbon monoxide (CO), lead (Pb), benzene and recently PM2.5. The PM2.5 standards were published in GN486 of 2012. Section 32 of NEMAQA allows for the promulgation of measures to control and

monitor dust. The National Dust Control Regulations (GNR827 of 2013) prescribe general measures for the control of dust in all areas, including residential and light commercial areas.

Section 33 of NEMAQA relates to rehabilitation of mining operations, and states that an Applicant must notify the minister five years prior to mine closure of the planned closure and provide a closure and rehabilitation plan

for the prevention of pollution of the atmosphere by dust after operations have ceased. Provision for this will be made in the closure plan.

Air quality monitoring and management measures will be stipulated in the EMPr, to ensure that the Applicant complies with the above legislative requirements, following a specialist study to determine the likely impacts to air quality resulting from the proposed activities at the Cons Modder Project.

Refer to Section 4)a) for the listed activities

applicable to the proposed Cons Modder Project.

Refer to Section 11)a)i) for a detailed description of the ambient air quality within the proposed Cons Modder Project area.

Refer to Section 11)c) for the potential

impacts on ambient air and Section 11)c)iii) for potential mitigation.

Refer to Section 12)c) for the plan of study, including specialist air quality assessment, for the EIA phase.

The National Heritage Resources Act, No. 25 of 1999 (NHRA) serves to protect and manage South African

heritage and cultural resources, which include places, buildings, structures and equipment of cultural significance, historical settlements and townscapes, archaeological and paleontological sites, graves and burial grounds. The Act protects any heritage resources from damage by developments by stipulating in Section 38 that any person intending on undertaking any form of development which involves the activities listed below must, at the earliest stage of initiation, notify the South African Heritage Resources Association (SAHRA) specifically the Provincial Heritage Resources Authority of Gauteng (PHRAG):

A. the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length;

B. the construction of a bridge or similar structure exceeding 50 m in length; C. any development or other activity which will change the character of a site—

i. exceeding 5 000 m2 in extent; or ii. involving three or more existing erven or subdivisions thereof; or

iii. involving three or more erven or divisions thereof which have been consolidated within

the past five years; or iv. the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial

heritage resources authority; D. the re-zoning of a site exceeding 10 000 m2 in extent; or E. Any other category of development provided for in regulations by SAHRA or a provincial heritage

Refer to Section 11)a)iii) for a detailed description of the cultural and heritage resources within the Cons Modder Project

area.

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resources authority.

Of the activities listed above, items A is triggered by the Cons Modder Project.

Section 38(8) of the Act states that if heritage considerations are taken into account as part of an application

process undertaken in terms of NEMA and the EIA process, there is no need to undertake a separate application in terms of the NHRA. Heritage considerations will form part of this environmental process. In terms of the requirements of the NHRA, archaeology and palaeontology specialists were appointed to conduct an assessment of the area. No findings of significance were made within the Cons Modder Project surface infrastructure footprints and surrounds. However, mitigation measures for potential chance finds will be included in the EMPr.

The National Water Act, No. 36 of 1998 (NWA) regulates all matters relating to inland water resources. It thus operates as a management instrument with the lead authority being the DWS. This Act provides mechanisms for the prevention of the pollution of water resources to support the management of water as a renewable resource. Section 21 of the Act lists water uses for which authorisation is required from the DWS.

Regulation GN704 of 1999 provides regulations for the use of water for mining and related activities and is aimed to further protect water resources. These regulations describe how mining activities should be managed to protect water resources. The Act thus plays a crucial role in the mining process as many mining-related

activities use water as listed in Section 21, thereby requiring approval from DWS.

An application for a Water Use Licence (WUL) will be submitted to DWS for the location of 7# within 500m from the boundary of a delineated wetland, and for the establishment of infrastructure at both shafts for the containment of domestic wastewater, storage of contaminated water, and stormwater management.

A confirmation email stating that the online WUL application process has commenced is attached as Appendix 3.

Refer to Section 4)a) for the listed activities applicable to the proposed Cons Modder Project.

Refer to Section 11)a)v) and Section 11)a)vi) for a detailed description of the groundwater and surface water resources within the Cons Modder Project area.

Refer to Section 11)c) for the potential impacts on water resources and Section 11)c)iii) for potential mitigation.

Refer to Section 12)c) for the plan of study, including specialist assessment of impacts on water resources, for the EIA phase.

The National Environmental Management Waste Act, No. 59 of 2008 (NEMWA) serves to reform the

laws regulating waste management in order to protect public and environmental health by providing measures for the prevention of pollution and ecological degradation and to provide defining requirements for the licensing and control of waste management activities. GN921 of 2013 provides definitions for activities which require a waste management licence and identifies the relevant environmental authorisations which are further required for said activities. The Cons Modder Project does not require a Waste Management Licence (WML).

The storage of waste above the specific thresholds (in excess of 100 m3 of general waste or 80 m3 of hazardous waste) for a period of more than 90 days triggers a Category C activity which requires compliance with the National Norms and Standards for the Storage of Waste (GN926 of 2013). A commitment to abide by the norms and standards will be included in the EMPr, should waste be stored in excess of threshold values and for longer than 90 days.

The Hazardous Substances Act, No. 15 of 1973 aims to control substances that may cause injury, ill-health,

or death through their toxic, corrosive, irritant, strongly sensitising or flammable nature, or by the generation of pressure. The Act provides for the division of such substances or products into groups in relation to the degree of danger as well as the prohibition and control of the importation, manufacture, sale, use, operation, application, modification, disposal or dumping of such substances and products. Hazardous materials such as explosives and hydrocarbons will be handled on site. The Applicant will ensure that any hazardous materials on

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site are handled in a manner in line with that described in the Act.

The purpose of the National Environmental Management: Biodiversity Act, No. 10 of 2004 (NEMBA) is to provide for the management and conservation of South Africa’s biodiversity within the framework of the

NEMA. This includes, among others, the protection of species and ecosystems.

Section 52 of the Act provides for listing of threatened or protected ecosystems, in one of four categories: Critically Endangered (CR), Endangered (EN), Vulnerable (VU) or Protected. The main purpose of listing threatened ecosystems is to reduce the rate of ecosystem and species extinction and includes the prevention of further degradation and loss of structure, function and composition of threatened ecosystems. Threatened terrestrial ecosystems have been delineated based on the South African Vegetation Map, national forest types and priority areas identified in a provincial systematic biodiversity plan.

According to the Gauteng Conservation Plan (C-Plan) a portion of the 7# area falls within an Ecological Support

Area (ESA).

The project area falls within the Soweto Highveld Grassland vegetation type which is a threatened ecosystem listed as Vulnerable in terms of Section 52 of NEMBA.

The Westdene Pan Nature Reserve is located approximately 8 km west of 7#; 7# also falls within the 10 km buffer of the Korsman Bird Sanctuary, while the Blesbokspruit Ramsar site is located approximately 9 km to the

east of Cons Modder 10#. No other protected or conservation areas are located within 10 km of the study area.

Chapter 4, Part 2 of the Act provides for listing of species as threatened or protected. If a species is listed as threatened, it should be further classified as critically endangered, endangered or vulnerable (GNR151 of 2007). The Act also defines restricted activities in relation to a specimen of a listed threatened or protected species (GNR152 of 2007).

A baseline flora and fauna survey was conducted in April 2017. No species of conservation concern were identified. The floral species Crinum bulbispermum (Orange River Lily - Declining) has a very low probability of

being present within the transformed habitat unit. However, none are likely to occur due to the high levels of historical and ongoing anthropogenic activity and habitat transformation that has taken place in the immediate vicinity. In the unlikely event that species of conservation concern are identified permits for the removal and relocation of any plant species of conservation concern will need to be obtained from the Gauteng Department of Agriculture and Rural Development (GDARD) prior to the commencement of construction.

Refer to the terrestrial ecology baseline in Section 11)a)xi)

Refer to Section 11)c) for the potential

impacts on biodiversity and Section 11)c)iii) for potential mitigation.

Refer to Section 12)c) for the plan of study, including specialist assessment of impacts on biodiversity, for the EIA phase.

The Mine Health and Safety Act, No. 29 of 1996 and the Regulations thereto provide for protection of the health and safety of staff and other persons at mines and, for that purpose to promote a culture of health and safety; to provide for the enforcement of health and safety measures; to provide for appropriate systems of employee, employer and State participation in health and safety matters; to establish representative tripartite institutions to review legislation, promote health and enhance properly targeted research; to provide for

effective monitoring systems and inspections, investigations and inquiries to improve health and safety; to promote training and human resources development; to regulate employers' and staff' duties to identify hazards

and eliminate, control and minimise the risk to health and safety; to entrench the right to refuse to work in dangerous conditions; and to give effect to the public international law obligations of the Republic relating to mining health and safety. The Applicant will ensure that operations on site are in line with the requirements of

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the Act and Regulations.

The National Nuclear Regulator Act, No. 47 of 1999 (NNRA) applies to the siting, design, construction,

operation, decontamination, decommissioning and closure of any nuclear installation; vessels propelled by nuclear power or having radioactive material on board which is capable of causing nuclear damage; and any action which is capable of causing nuclear damage. The NNR is regulated by the National Nuclear Regulator and Certificates of Registration are required for radiation sources above a certain threshold. The NNRA also makes provision for safety standards and regulatory practices by means of the regulations (GNR388 of 2006).

No radioactive materials to be stored on site. Ore will be transported to Modder East for processing. Waste rock

will be removed to a nearby crushing facility. The Cons Modder Project does not require a Certificate of Registration in terms of the NNRA.

The City of Ekurhuleni Integrated Development Plan (IDP) (2013/14 - 2015/16) provides the regional socio-economic context of the project area. The IDP states that the City of Ekurhuleni has a total surface area of

1 975 km² that accommodates a population of approximately 3 million. Migration into the area is a key challenge, which is evident in the number of informal settlements and by the informal trading activity. The City

of Ekurhuleni is considered an industrial hub. Economically active people constitute 41.5 % of the population. The area contributes approximately 6.1 % to national production. Over the period 1996 to 2011, the economy grew by an estimated average of 3.2 % per annum. The main contributing sectors have been identified as retail, entertainment, aviation, property development, mining and manufacturing (food and beverage, packaging, chemicals, metal, services, and other manufacturing services). The City of Ekurhuleni has a 100 year history of mining which has resulted in environmental deficits including acid mine drainage, undermined degraded areas, and mine dumps containing radio-active materials. Approximately 41 % of the City of Ekurhuleni has been

identified as being of importance for protection for agriculture, 22 % of this is of high importance, while 19 % is of moderate to high importance. The natural environment of the City of Ekurhuleni can be broken down as follows: 19 % Critical Biodiversity Areas, 18 % Ecological Areas, 1 % Protected Areas, 16 Threatened Plant

Species, 14 Threatened Animal Species, and 10 % Threatened Ecosystems. The industrial and urban development that has shaped the City of Ekurhuleni has resulted in high levels of pollution impacting soil, water and air resources. It has also resulted in degradation of ecosystems and the subsequent loss of biodiversity.

Refer to the social baseline in Section 11)a)viii) This has also been taken into consideration in the determining of the need and desirability of the project, refer to Section 6) and Appendix 4.

The City of Ekurhuleni Regional Spatial Development Framework (RSDF)(2015) provides the framework for making resource-effective decisions regarding planning. The project area falls within Region D as per the City of Ekurhuleni RSDF. Region D is characterised by three well-established urban nodes: Benoni, Brakpan and Springs. These areas are in a state of decay and are in need of maintenance and upgrade. Low-density residential housing components are associated with each of these urban nodes. Approximately 22% of the land in Region D is affected by surface mining (disturbed land, mine dumps and slimes dams). These surface mined

areas are not considered practical for future development due to the high rehabilitation costs. Areas of underground mining could be at risk of mining-induced subsidence, but this is dependent on the depth of mining below ground level. Numerous areas of existing mining-induced subsidence or sinkholes have been identified

and appear to follow the gold bearing reef outcrop. Approximately 60% of Region D is classified as dolomitic land and 17% of the region is affected by surface exposed dolomite. Region D is located favourably in terms of the economic activity and employment area of Gauteng and Benoni, Brakpan and Springs are considered important growth nodes.

According to the City of Ekurhuleni RSDF, 7# falls within an area classified as open space and 10# falls within

This has been taken into consideration in the

determining of the need and desirability of the project, refer to Section 6) and Appendix 4.

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and area classified as mining (Figure 5). Areas classified as open space have functioning processes that should

be maintained. The objective is to ensure continued functioning of the area (ecological / agricultural / open space) and that the area is not compromised. Developments within these areas should be limited to existing footprints, if present, and should avoid encroaching on natural or agricultural landscapes. Development should

be undertaken in such a way that ecological and open space networks remain intact, so that fragmentation of the system, resulting in the isolation of ecologically important areas and open space, does not occur. The relevant environmental assessments should be undertaken for any proposed development within these areas. In addition, the relevant national, provincial and local legislative requirements must be adhered to for all proposed developments. The 7# area will be limited to an existing footprint transformed by previous mining activities and the necessary environmental assessment is being undertaken - this process. The relevant national, provincial and local legislative requirements will be adhered to for the proposed

development as described above.

The Gauteng Province Environmental Management Framework (GPEMF) (2015) provides a framework to guide decision-making regarding land-use at all levels of planning. According to the GPEMF, 7# falls within Zone 1: Urban development zone and 10# falls within Zone 5: Industrial and large commercial focus zone. The intention with Zone 1 is to streamline urban development activities in it and to promote development infill,

densification and concentration of urban development, in order to establish a more effective and efficient city region that will minimise urban sprawl into rural areas. The intention within Zone 5 is to streamline non-polluting industrial and large scale commercial (warehouses etc.) activities in areas that are already used for such purposes and areas that are severely degraded but in proximity to required infrastructure. Refer to Figure 6. Zone 1 is undesirable for mining and Zone 5 is compatible with mining.

This has been taken into consideration in the determining of the need and desirability of

the project, refer to Section 6) and Appendix 4 as well as the planned post mining land use.

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Figure 5: City of Ekurhuleni RSDF

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Figure 6: GPEMF zoning of the project area

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6) NEED AND DESIRABILITY OF THE PROPOSED ACTIVITIES (Motivate the need and

desirability of the proposed development including the need and desirability of the activity in the

context of the preferred location)

The Scoping Phase has thus far considered the majority of the aspects as to the “need and

desirability”. A detailed need and desirability report has been prepared according to the NEMA Need

and Desirability Guideline (GN891 of 2014), and attached as Appendix 4. Any aspects which could not

be addressed during the Scoping Phase, which mostly relate to impact assessment, will be addressed

during the EIA Phase.

7) PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED

The period for which authorisation is required will be from the year 2018 to the year 2029.

8) DESCRIPTION OF THE PROCESS FOLLOWED TO REACH THE PROPOSED

PREFERRED SITE (NB!! – This section is not about the impact assessment itself; It is about

the determination of the specific site layout having taken into consideration (1) the comparison of

the originally proposed site plan, the comparison of that plan with the plan of environmental

features and current land uses, the issues raised by interested and affected parties, and the

consideration of alternatives to the initially proposed site layout as a result.)

No alternative site locations were assessed as the locations of the access shafts are based on the

location of the existing shafts to be refurbished. The location of the associated infrastructure is based

on the access shaft locations and limited to areas previously transformed by mining activities and has

been kept to the minimum extent possible. The access roads to be constructed are the shortest routes

to join the existing roads, avoiding all existing developments.

9) DETAILS OF ALL ALTERNATIVES CONSIDERED (With reference to the site plan and the

location of the individual activities on site, provide details of the alternatives considered with

respect to:

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

(b) the type of activity to be undertaken;

(c) the design or layout of the activity;

(d) the technology to be used in the activity;

(e) the operational aspects of the activity; and

(f) the option of not implementing the activity.)

a) Site Alternatives

No alternative site locations were assessed as the locations of the project is based on the location of

the existing shafts to be refurbished. The location of the associated infrastructure is based on the

access shaft locations. It has been restricted to areas previously transformed by mining activities, and

has been kept to the minimum extent possible.

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b) Type of Activity

There are no alternatives to the type of mining (underground mining) as this is determined by the

depth of the mineral resource to be targeted.

c) Design and Layout Alternatives

The surface infrastructure footprint was based on the location of existing shafts, and has been kept to

the minimum extent possible, and confined to transformed areas. Initial baseline specialist studies

were undertaken and no additional alternatives were recommended. The following design and layout

alternatives were assessed:

Ore Storage

Alternatives in terms of ore storage assessed included an ore storage stockpile or the use of a

headgear ore bin. A headgear bin was selected as the preferred ore storage alternative as it requires

less surface area and has a lower pollution potential.

Headgear Bin Size

Alternatives in terms of headgear bin storage capacity were assessed. A 500 ton headgear bin was

selected as the preferred alternative as it would allow for the storage of ore hoisted at night so that

hauling activities could to be limited to daylight hours to reduce road safety risks and noise nuisance.

Transport Route

Transport route alternatives were assessed by a traffic specialist.

The preferred transport route comprises an access road from 10#, portions of Hospital Road, Main

Reef Road (R29), Putfontein Road (R51), Main Reef Road, Orpiment Avenue and Cloverfield Weg. The

outbound trip (Modder East to 10#) comprises Orpiment Avenue to the signalized intersection at the

Putfontein Road (R51). This route is slightly longer but is a safer intersection for trucks to turn right

into Putfontein Road (R51) (refer to Figure 7 - the red route).

The alternative transport route comprises portions of Hospital Road, Main Reef Road, Putfontein Road,

Modderbee Road, Outeniqua Road and Cloverfield Weg (refer to Figure 7 - the green route).

The preferred route (Cloverfield Weg) currently has slightly more heavy vehicles than the alternative

route (Outeniqua Road) and therefore the impact on Outeniqua Road would be higher. More

importantly, Cloverfield Weg is currently 7 m wide and Outeniqua Road is 6 m wide. Wider roads are

more suitable for trucks. Furthermore, from site observations, the houses and fence lines are set off

further from the road edge on Cloverfield Weg whereas Outeniqua Road has houses and fences closer

to the road edge. Cloverfield Weg is more suited for heavy vehicles than Outeniqua Road.

An intersection on the alternative route (Modder Road / Outeniqua Road), comprises a small traffic

circle with an internal diameter of 8 m. This circle is currently too small to accommodate haul trucks.

Therefore, based on road class, road safety and land use factors, the preferred route is therefore

proposed (refer to Figure 7 - the red route).

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Figure 7: Transport route alternatives

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d) Operational Alternatives

As the operation will comprise of the refurbishment of existing shafts for underground mining and the

ore will be transported to Modder East for processing, there are no operational alternatives.

e) The “No-Go” Option

If the Cons Modder Project does not go ahead, the area will likely not be developed for mining.

Alternative development may be possible, but the Applicant is unaware of any such proposals at

present. The additional employment opportunities (approximately 440), contribution to Gross

Domestic Product (GDP) and the local economic development initiative/s associated with the Cons

Modder Project will not be realised. The no-go option will however prevent the associated

environmental and social impacts [yet to be assessed in detail, but refer to Section 11)c) for a high

level assessment] associated with mining at the Cons Modder Project area.

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10) 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)

The public participation process to be followed will meet the requirements of Chapter 6 of the NEMA

EIA Regulations, GNR982 of 2014.

Landowner Notification

The current landowner of the farm where the surface infrastructure is to be located (i.e. the

Remaining Extent of Portion 3 of Modderfontein 76IR) has been identified as Mr Meyer. He was

provided with written notification of the project at a meeting held between the Newshelf and the

landowner on 12 May 2017 (refer to Appendix 5.1).

Scoping Phase public participation process

Media Notice

A media notice (in English) was published in a local newspaper (Brakpan Herald) on 13 October 2017,

providing a brief project description, legislative requirements, the process to be followed to register as

an Interested and Affected Party (IAP), availability and location of the Scoping Report, and contact

details of the EAP for more information (attached as Appendix 5.2).

Site Notices

Site notices (in English) were posted up on site and at conspicuous locations within the surrounding

communities on 12 October 2017, providing a brief project description, legislative requirements, the

process to be followed to register as an Interested and Affected Party (IAP), availability and location of

the Scoping Report, and contact details of the EAP for more information (attached as Appendix 5.3).

IAP Registration

An IAP register will be opened and representatives from all of the relevant State Departments, as well

as any IAPs requesting to register, will be added to the database (attached as Appendix 5.4).

Commenting Period

The Scoping Report has been made available for comment to State Departments (including the

Competent Authority) via email or hard copy as requested, and placed within the public domain on the

Prime Resources website (www.resources.co.za), at the Brakpan Library and at the Modder East

Operations security office, for a 30 day period (13 October to 13 November 2017).

Background Information Document

A Background Information Document (BID) has been compiled and translated into Afrikaans, and

provides a brief project description and potential impacts, the legislated environmental process,

availability of the Scoping Report, the process to follow to register as an IAP, and contact details for

queries. The BID has been made available to State Departments and IAPs via email on 12 October

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2017, and to surrounding residents by hand on 13 October 2017. The BID will also be made available

to any IAPs requesting further information (attached as Appendix 5.5).

Public Meetings

Depending on feedback received from IAPs, focus group meetings may be scheduled during the 30

day commenting period. Should such meetings be required, registered IAPs will be informed of the

details of the meetings via email and SMS.

Comments and Response Report

A Comments and Response Report will be compiled, which will be submitted to the Competent

Authority for consideration as part of the Scoping Report, after the 30 day commenting period has

ended. During the EIA phase further public participation will be conducted. Refer to Section 12) for the

details of the feedback engagement process to be followed.

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a) Summary of issues raised by IAPs (Complete the table summarising comments and issues raised, and reaction to those responses)

This table will be completed following the Scoping Phase public participation process, and will be referred to as the Comments and Response Report.

INTERESTED AND AFFECTED PARTIES

(list the names of persons consulted in this column,

and mark with an X where those who must be

consulted were in fact consulted)

DATE

COMMENTS

RECEIVED

ISSUES RAISED EAPS RESPONSE TO ISSUES AS

MANDATED BY THE APPLICANT

CONSULTATION

STATUS

(consensus

dispute, not

finalised, etc.)

AFFECTED PARTIES

Landowner/s Surface Infrastructure Area - Petrus

Hendrik Meyer - RE of Ptn 3 RE

Modderfontein 76 IR

x

Mining Area - Morning Tide Investments

47 Pty Ltd - Ptn 46 RE Modderfontein 76

IR

x

Mining Area - State Mines Country Club

- Ptns 60 and 61 RE Modderfontein 76

IR

x

Mining Area - ERF 1205 Rensburg Pty

Ltd - Ptn 69 Modderfontein 76 IR x

Mining Area - Market Pro Investments

106 Pty Ltd (South African Bank of

Athens Ltd and Absa Bank Ltd) - Ptn 95

RE Modderfontein 76 IR

x

Lawful occupier/s of the land Ptn 95 Modderfontein 76 IR - Manhattan

Corporation x

Ptn 69 Modderfontein 76 IR –Scoops

Sand and Stone x

Landowners or lawful occupiers on adjacent

properties

Ptn 24 Modderfontein 76 IR – Transnet

Ltd x

Ptn 64 Modderfontein 76 IR – Mun

Brakpan x

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Ptn 189 Geduld 123 IR - Ekurhuleni

Metropolitan Municipality x

Ptn 138 RE Geduld 123 IR - Fullimput

1480 CC x

Ptn 56 RE Geduld 123 IR - Tristar Prop

CC x

Municipal ward councillor Ward Councillor Ward 97 - Brandon

Pretorius x

Ward Councillor Ward 71 - Solani

Silawula

Ward Councillor Ward 72 - Ramesh

Sheodin x

Ward Councillor Ward 73 - Sinethemba

Rodney Metiwane x

Municipality City of Ekurhuleni - Stewart Green x Organs of state (responsible for infrastructure

that may be affected Roads Department,

Eskom, Telkom, DWS etc.)

Gautrans - R Swartz x Eskom – Deidre Herbst x DWS - Phyllis Maphakela x Randwater – S. Mosai Communities

Brakpan North (Sherwood Gardens and

Huntingdon)

x

State Mines / Emagaleni Informal

Community

x

Kingsway x

Dersley x

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Eastvale x

Presidents Dam x

Skoonplaas Informal Community x

Department Land Affairs DRDLR - Cathrine Rebecca Mahlangu x

Traditional Leaders

N/A

Department Environmental Affairs GDARD - Steven Mukhola x Other Competent Authorities affected

PHRAG via SAHRIS x DAFF - Phyllystas Mmakola x OTHER INTERESTED / AFFECTED PARTIES

Organisations

AgriSA – Janse Rabie Brakpan Community Policing Forum (CPF)

(Sector One) – Lee Ann Kuilder

Dersley Community Association – Marie Buchner Eastvale Community Policing Forum (CPF) – Rana

Marie

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11) THE ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE SITES

a) Baseline environment (Type of environment affected by the proposed activity - its current

geographical, physical, biological, socio- economic, and cultural character)

i) Air Quality

The following information was obtained from the air quality study dated July 2017 (attached as

Appendix 6).

Meteorological Character

Site specific MM5 modelled meteorological data set for three calendar years (2014 – 2016) was

obtained from Lakes Environmental Consultants to determine local prevailing meteorological

conditions for the project area.

According to the modelled data for the project area, the prevailing winds originate from the north-

east, with average wind speeds of between 3.60 and 5.70 m/s. Calm conditions (wind speeds < 1

m/s) are experienced for 6.94 % of the period (refer to Figure 8). The diurnal wind rose shows

predominant winds originating from north-west during day time, with calm conditions experienced

4.68 % of the time. The nocturnal wind rose indicates that the wind predominantly originates from

north-east at night, with increased wind speeds and fewer calm conditions experienced (2.09 %).

During all four seasons, winds predominantly originate from the north-east. Calm conditions occur

mostly during the autumn and winter months (8.79 % and 9.50 % respectively), and the least

during spring months (3.54 %). The highest average temperature (30.2˚C) was experienced in the

summer month of January and the lowest average temperature (8˚C) was experienced in the

winter month of July. The average monthly relative humidity was the lowest in October (62 %) and

highest in May (77 %) with the average relative humidity remaining fairly constant throughout the

rest of the year. The highest monthly precipitation was experienced in the spring and summer

months from October to January (ranging from 0.29 to 0.32 mm/h) with the lowest experienced in

the autumn and winter months May, June and July (ranging from 0 to 0.1 mm/h).

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Figure 8: Wind rose depicting the average wind speed and direction for the proposed

project area for the period of January 2014 to December 2016

Sensitive Receptors

Sensitive receptors include all permanently occupied surrounding areas which may be impacted by

the proposed project in terms of air quality. These were identified as the residential areas of

Sherwood Gardens and Huntingdon in Brakpan North as well as the State Mines Community (or

Emagaleni Community) associated with historical mine infrastructure approximately 360 m from

10#. Additional sensitive receptors include surrounding businesses (Manhattan Corporation

adjacent to 7# and Scoops adjacent to 10#) and the State Mines Country Club adjacent to 7#, due

to their proximity to the project.

Existing Emission Sources

The air quality management plans for the City of Ekurhuleni, Gauteng Province and the Highveld

Priority Area were reviewed to identify existing emissions in the region. From a regional

perspective, sources of air pollution include:

Agricultural activities;

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Industrial and commercial fuel burning;

Vehicle exhaust emissions;

Rail transportation;

Mine tailings storage facilities;

Industrial activities;

Waste treatment; and

Household fuel burning.

From a local perspective, the surrounding communities are mostly formal and electrified and

pollutants associated with the combustion of biofuel are therefore expected to be low. The

surrounding road network is also mostly paved, eliminating the usual entrainment of dust

associated with the use of unpaved roads. Local sources of air pollution include:

Existing mining activities (gold and dolomite mining);

Vehicle exhaust emissions from vehicles travelling on the surrounding road network; and

Fugitive dust emissions from inadequately rehabilitated historical mining areas and

historical gold mine tailings storage facilities.

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ii) Aquatic Ecology

The following information was obtained from the wetlands and aquatic ecology study dated

December 2016 (attached as Appendix 7). It was visually apparent from a site visit that the water

quality within the only stream associated with the project area (referred to as the Jan Smuts

Stream for the purposes of this report), was far from ideal. An aquatic macro-invertebrate

community of low diversity and sensitivity is highly likely to occur and fish are likely absent. The

specialist was of the opinion that a detailed aquatic assessment would not have added value to or

altered the findings of the study in any material way and therefore a detailed assessment of these

communities was not undertaken.

iii) Archaeology

The following information was obtained from the archaeological study dated April 2017 (attached

as Appendix 8).

No known Stone Age sites or artefacts are present in the area and no Stone Age tools were

identified during a site visit. If any Stone Age artefacts are to be found in the area then it would

likely be single, out of context, stone tools. No Early Iron Age sites are known in the area.

7# is located adjacent to the State Mines Country Club and was open and accessed by illegal

miners at the time of the site visit in April 2017. The area around the shaft is used for informal

refuse/rubble dumping, and one of the structures close by is used by the Zion Christian Church as

a church building. There are structural remains of old mining related buildings which have been

vandalized and are in ruins, and as a result have no heritage significance. Many of the old mining

related buildings consist only of foundations.

10# had been closed-off and could not be accessed by illegal miners at the time of the site visit.

There are no well-preserved and significant cultural heritage resources in proximity to the shaft.

Old opencast mine workings, as well as various buildings and structures associated with mine

compounds and living quarters are located some distance away (360 m) from the shaft area and

will not be impacted by the proposed new development activities. These mining related structures

are heavily vandalized and in the process of being demolished. Many of these also date to around

the 1960s and 1970s and possibly later, based on the bricks and tiles that were noted, and are

therefore less than 60 years of age and not of heritage significance.

No pre-historical sites, features or material were identified in the areas which may be impacted.

Two significant features were however identified on a historical map of the area (dated December

1952) namely two “Native Cemeteries”. According to the map one cemetery is located to the

north-east of 7# and the other to the north of 10#. Both are located a fair distance from the areas

which may be impacted and as such did not form part of the scope of the archaeological study.

However, these cemetery locations (if they are still in existence) should be taken into account

should expansion into these areas be planned.

iv) Blasting

The following information was obtained from the blasting study, dated May 2017 (attached as

Appendix 9).

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The two shafts are shallow, and the area has been mined historically from 60 to 150 mbs. Mining

is planned to continue at approximately this depth. There are no current blasting activities

occurring at the proposed underground mining area.

v) Hydrogeology

The following information was obtained from the hydrogeology specialist opinion, dated May 2017

(attached as Appendix 10) as well as additional sampling undertaken in August 2017.

The area to be mined is located within the East Rand Basin, which has been previously mined.

There are two types of aquifer systems in the region. The first comprises of localised shallow

surface aquifers. Surface aquifers form in situations where the water seepage through the upper

rock strata is slower than the rate of rainfall recharge. The shallow surface aquifers are not

uniformly distributed as their positions are dependent on local geological features, such as fissures.

The second aquifer type in the region is the extensive, deep basin aquifer. On a regional scale, the

current inorganic water quality of the East Rand Basin is considered to be contaminated due to

historic mining activities. Down gradient of the site, TCTA is currently pumping and treating basin

water to maintain a water level that is low enough to prevent decant of the basin water onto

surface. This water level is below the reefs at the Cons Modder shafts, currently at 153 mbs.

Service water will be pumped from the East Rand Basin and re-used (reticulated) underground as

required. No basin water will be pumped to surface. Only potable drinking water supplies will be

taken underground (through connections to municipal supply) and no surface water resources or

shallow aquifer resources water will be required by the mine.

Water Quality

Samples of the groundwater below 7# and 10# were taken in August 2017. These samples were

single grab samples and do not represent the spatial and temporal variations in water quality in

the area. The depth at which the samples were obtained was recorded as 157 m below surface.

The results are summarised in Table 1. The analyses were conducted by the SANAS certified

Intertek Environmental Laboratory. The results indicate that the water in the region of 7# is acidic

and that near 10# is circum-neutral. The water is not suitable for use as drinking water as the

concentrations for iron, manganese and sulphate for both shafts as well as selenium at 7# and

aluminium at 10# exceed SANS 241-1:2015 drinking water standards.

The difference in water qualities may be attributed to different amounts of surface infiltration or

variable contributions from oxidised mine workings.

Table 1: Deep aquifer groundwater quality results

Analyte Unit 7# 10# SANS 241-1: 2015 drinking

water quality

pH 3.1 6.4 > 5, <9.5

Turbidity NTU 234 387

Dissolved Oxygen mg/l 2.38 2.68

Electrical Conductivity µS/m 158 186 <170

Total dissolved solids mg/l 1 038 1 230 <1 200

Total suspended solids mg/l 147 112

Total Alkalinity CaCO3 mg/l <1 305

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Analyte Unit 7# 10# SANS 241-1: 2015 drinking

water quality

Cl (free) mg/l 0.56 0.50 <5

Cl- mg/l 48.2 70.1 <300

F- mg/l <0.02 <0.02 <1.5

SO42-

mg/l 909 1 223 <500 (health), <250 (aesthetic)

NH3 mg/l 0.68 1.77 <1.5

NO3- mg/l <0.10 <0.10 <11

NO2-

mg/l <0.002 <0.002 <0.9

CN- mg/l <0.010 <0.010 <0.2

Al mg/l 0.291 7.13 <0.3 (operational)

As mg/l <0.005 <0.005 <0.01

Ca mg/l 199 314

Cd mg/l <0.005 <0.005 <0.003

Co mg/l <0.005 <0.005 <0.5

Cr mg/l <0.005 0.011 <0.05

Cu mg/l <0.005 <0.005 <2

Fe mg/l 3.99 4.35 < 2 (health), <0.3 (aesthetic)

Hg mg/l <0.005 <0.005 <0.006

K mg/l 11.6 29.9

Mg mg/l 123 152

Mn mg/l 5.52 4.46 <0.4 (health), <0.1 (aesthetic)

Na mg/l 76.8 138 <200

Ni mg/l 0.007 0.016 <0.07

Pb mg/l <0.005 <0.005 <0.01

Sb mg/l <0.005 0.008 <0.020

Se mg/l 0.045 0.006 <0.04

V mg/l <0.005 0.008 <0.2

Zn mg/l 0.013 0.013 <5

Bromofrom µg/l <5 <5 <100

Chloroform µg/l <5 <5 <300

Bromodichloromethan µg/l <10 <10 < 60

Dibromochloromethane µg/l <2 <2 <100

Trichloroetylene µg/l <5 <5

Values indicated in red exceed SANS 241-1:2015 guidelines

Hydrocensus

During the September 2017 hydrocensus, six borehole users in the area were identified (refer to

Figure 9). Of these, five were located within residential properties. Only one of the residential

boreholes was used for potable supply, this being the non-profit organisation which supplies its

130 residents with treated potable water. The one non-residential borehole was situated at

Presidents Park and was fitted with a wind pump which was broken at the time of the hydrocensus.

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Figure 9: Hydrocensus boreholes

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vi) Hydrology

The following information was obtained from the hydrology study dated December 2016 (attached

as Appendix 11).

Surface Water Resources

There is a perennial pan (the Jan Smuts Dam) to the south-west of the project area. The Jan

Smuts Wastewater Treatment Works (WWTW), on the eastern bank of the Jan Smuts Dam,

discharges its effluent into this dam. The Jan Smuts Dam has an outlet into a small, unnamed,

watercourse (referred to as the Jan Smuts Stream for the purposes of this report) flowing in a

north-easterly direction towards a second (but larger) unnamed stream (referred to as the Cowles

Stream for the purposes of this report) flowing through the Alexander and Cowles Dams into the

Blesbokspruit.

Catchment Description

The Cons Modder Project area locates in quaternary catchment C21D, within the Upper Vaal River

Water Management Area (refer to Figure 10). A non-perennial stream, the Jan Smuts Stream,

flows between the two Cons Modder shafts and also across a comparatively narrow part of the

underground mining area. This stream originates at the Jan Smuts Dam and, after flowing across

the mining area, flows into the Cowles Stream, which is a tributary of the Blesbokspruit. The upper

reaches of the Blesbokspruit drains this quaternary catchment, and then continues through

quaternary catchments C21E and C21F before reaching its confluence with the Suikerbosrant

River. The primary river draining the region is the Vaal River, which flows from its origin along the

continental watershed near Breyten towards its confluence with the Orange River near the town of

Douglas.

Quaternary catchment C21D has a mean annual rainfall of 697.98 mm but this catchment includes

areas with slightly higher rainfall values. The Cons Modder shafts are located within an area that

has an average rainfall of approximately 720 mm. The mean annual runoff for this catchment (i.e.

the rainfall that reaches the surface streams as surface runoff) is 36.1 mm/a. The A-Pan

Evaporation at the Cons Modder Project area is approximately 2 140 mm/a.

Drainage Density

The only stream of importance near the project area is the Jan Smuts Stream, which drains the

entire project area. The catchment of the Jan Smuts Stream is 18 443 417 m² and would produce

an annual runoff of 665 807 m³/a. The drainage density for the Jan Smuts Stream up to its

confluence with the Cowles Stream is 0.171 km2.

Flow

There are no flow-gauging stations in the Jan Smuts Stream. The bulk of the water flowing in the

Jan Smuts Stream is sewage effluent produced by the Jan Smuts WWTW. The design capacity of

the WWTW is presently 10 Mℓ/d and treats sewage received from the Brakpan, Dalview, Dalpark

and Vulcania areas. In addition to the sewage effluent, natural drainage from the catchment will

contribute to the flow in the Jan Smuts Stream. Natural runoff comprises on average only

approximately 15.4 % of the total flow in the Jan Smuts Stream.

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50- and 100- Year Flood Lines

Only the 100 year floodlines of the Jan Smuts Stream were modelled, because of the small

catchment size (less than 50 km2).

7# is located approximately 350 m away from the 100-year floodline of Jan Smuts Stream and

10# is located approximately 700 m away (refer to Figure 11).

A storm with a return period of 100 years falling over the catchment will have a time of

concentration of just less than 40 minutes. This storm will produce the highest discharge of

143.10 m³/s in the Jan Smuts Stream at the Cons Modder Project area.

Surface Water Use

There are no downstream water users for the water in the Jan Smuts Stream.

Surface Water Quality

Due to the discharge of approximately 10 Mℓ/d of treated sewage effluent from the Jan Smuts

WWTW entering the Jan Smuts Dam, the bulk of the water flowing in the Jan Smuts Stream, under

normal circumstances, would comprise of sewage effluent.

Four water samples were collected during a site visit in November 2016 - in the Jan Smuts Stream,

upstream and downstream of the Cons Modder shafts; and from the Cowles Stream, upstream and

downstream from the confluence with the Jan Smuts Stream. During and prior to the time that the

samples were collected, this area experienced heavy rainfall and the flow would therefore have

been greater than expected during normal dry-weather flow (refer to Figure 12).

The sample results were compared to the South African National Standard (SANS) 241-1:2015

(drinking water standard for South Africa). In general, the water quality in the Jan Smuts Stream

and Cowles Stream was good, with none of the determinants exceeding the SANS 241-1:2015

standard (refer to Table 2).

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Table 2: Chemical analysis results of the surface water samples in November 2016,

collected from the Jan Smuts and Cowles Streams

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Figure 10: Quaternary catchment

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Figure 11: 100-year flood line of the Jan Smuts Stream

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Figure 12: Surface water sampling points

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vii) Noise

The following information was obtained from the noise study dated May 2017 (attached as

Appendix 12).

Existing Ambient Noise

Baseline noise monitoring was measured at four sites / measuring points (refer to Table 3 and

Figure 13).

Table 3: Noise monitoring points

Site no. Location Category

1 Outside the boundary of 7# site and 8 m from the boundary

of the State Mines Country Club Residential /Urban

2 Northwest corner of Abramowitz Street near 10# Residential / Urban

3 Boundary of the R51 Benoni to Springs road and SASOL

Service station Residential / Urban

4 10 m from the Cloverfield road centreline adjacent to the

Modder East residential area Residential / Urban

Existing noise sources at sites 1 and 2 include natural sources such as birds, insects, remote road

traffic from local roads and remote air traffic notably from ORT International Airport and from local

airfields. The measured ambient noise levels of between 35 and 45 dB(A) are typical of a suburban

area such as this in the absence of main roads and commercial activity.

Existing noise levels at site 3, between 66 and 68 dB(A), is typical of a main road with consistent

high traffic flow (1 800 - 3 600 vehicles/hour) which dominates the noise climate to the extent that

the background noise is primarily from distant vehicles.

Existing noise levels at site 4, between 62 and 65 dB(A), is typical of a main road with consistent

traffic flow (300 - 450 vehicles/hour) which dominates the noise climate. Background noise is from

natural sources, primarily from birds, insects, and domestic activities.

The area generally experiences the low ambient noise levels typical of suburban and semi-rural

environments. The area is predominantly residential, open veld and worked out mining areas with

no excessively noisy industries or similar sources of noise in the vicinity. The background noise

levels at the two measurement positions representing the shaft sites are typically around 40-50

dB(A) during daytime (06h00 to 18h00) and it is assumed that levels during the night would be 10

dB(A) less than daytime levels, which is well within the recommended zone values of 50 dB(A) and

40 dB(A) for a suburban residential area during the day and night respectively.

Sensitive Receptors

Noise sensitive receptors are the residential dwellings of Sherwood Gardens and Huntingdon as

well as the State Mines / Emagaleni Community in proximity to 10#, as activities at 10# may have

significant noise impacts (refer to Figure 15). Although activities at 7# are not expected to have

significant noise impacts, the noise from increased activity may result in nuisance to adjacent

residents of Sherwood Gardens and the employees and golfers at the adjacent State Mines Country

Club.

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Figure 13: Noise measurement points

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viii) Palaeontology

The following information was obtained from the palaeontology study dated April 2017 (attached

as Appendix 13).

The oldest rocks in the project area to the south are the volcanic rocks of the Klipriviersberg Group

and Ventersdorp Supergroup, which are divided into a number of formations. The lower formations

comprise conglomerates, quartzites and lavas. The upper formations are porphyritic lavas. The

Black Reef Formation (quartzite) outcrops to the south west of Brakpan. Dolomites and cherts of

the Malmani subgroup underlie the shaft areas, as well as the shales of the Permian Vryheid

Formation. Other rocks of the Pretoria Group occur in the area and these are mostly volcanic in

origin.

The Black Reef Formation and Malmani Subgroup contain banded ironstone and dolomites, which

although formed by the chemical activities of ancient algae, photosynthesis and oxygen

production, are not known to have preserved fossil algae near Brakpan. Some formations within

the ancient Pretoria Group represent marginal marine or lacustrine deposits with trace fossils of

microbial mats and some ripple marks, for example the Daspoort and Magaliesberg formations, but

not the particular formations represented in the Brakpan area.

The Dwyka Formation represents the receding glacial deposits from the Upper Carboniferous and

Early Permian, a time period when land plants were abundant in the warmer regions to the far

palaeo-north of Brakpan. Rare Dwyka fossils (Glossopteris leaves, Stigmaria roots, lycopods and

sphenophytes) have been reported near Vereeniging, about 75 to 100 km southwest of Brakpan

but no fossils have been reported in proximity to the shaft areas and surrounds. Likewise, no fossil

plants of the Glossopteris flora have been reported from the Vryburg Formation around Brakpan.

There is no coal mining in this region, probably as the coal seams are not economic or are severely

altered by the intrusive dolerite dykes which are abundant to the south. These dolerite dykes are

too old to contain vertebrate body fossils.

Based on the geology of the area and the current palaeontological records, it can be assumed that

the formation and layout of the basement rocks, dolomites, sandstones, shales, coals, quartzites,

basalts and volcanic rocks are typical for the country and do not contain any fossil material. The

sediments of the Dwyka and Vryheid Formations could contain impression fossils of plants of the

Glossopteris flora, however, this is unlikely due to the transformed nature of the area and the fact

that they have yet to be recorded in the area.

ix) Socio-economic

The following information was obtained from the socio-economic study currently underway.

Provincial Context

Gauteng is the smallest of South Africa’s provinces. The population in 2016 was estimated to be

approximately 13 399 725 people, or approximately 24.1% of South Africa’s population. Gauteng

continues to serve as the economic engine room of the country and the subcontinent, responsible

for over 34.8% of the country’s GDP. The Gauteng Province is divided into three metropolitan

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municipalities (City of Ekurhuleni, City of Johannesburg and City of Tshwane) and two district

municipalities (Sedibeng and District). The most important sectors contributing to Gauteng’s

economy are finance, real estate and business services, manufacturing, and general government

services.

Regional Context

The project area is located within Ward 97 of the City of Ekurhuleni Municipality. The City of

Ekurhuleni’s strategic planning framework includes the long term strategic framework, the Growth

and Development Strategy 2055, the Medium Term Revenue and Expenditure Framework, the IDP

and the annual Service Delivery and Budget Implementation Plan.

In the medium term the strategic objectives and goals are informed by the governing party’s

political priorities which are summarised in the election manifesto. The election manifesto

prioritised the following priority areas:

Build local economies to create more employment, decent work and sustainable livelihood;

Improve local public services and broaden access to them;

Build more united, non-racial, integrated and safer communities;

Promote more active community participation in local government; and

Ensure more effective, accountable and clean local government that works together with

national and provincial government.

From the above strategic objectives and goals a five year IDP is then drafted to act as the principal

strategic planning instrument. The IDP is not only top down in its development but is also bottom

up as it annually gives due regard to community inputs through the determination of ward

priorities. More critically it links planning to municipal budgeting thereby directing implementation

and development. The municipal mandate according to Section 152 of the Constitution is to:

Promote democratic and accountable government for local communities;

Ensure the provision of sustainable services to communities;

Promote a safe and healthy environment; and

Encourage community participation in local government.

The population of the City of Ekurhuleni is approximately 3 379 104 with 1 299 490 households.

The main towns within the City of Ekurhuleni include Alberton, Bedfordview, Benoni, Boksburg,

Brakpan, Edenvale, Germiston, Katlehong, Kempton Park, Nigel, Olifantsfontein, Springs, Tembisa,

Tokoza and Vosloorus.

The unemployment rate of the City of Ekurhuleni stands at about 34.4 %. The municipality is an

important manufacturing centre and the main economic sectors are: manufacturing (23 %),

finance and business services (22 %), community services (19 %), trade (15 %), transport

(11 %), construction (5 %), electricity (3 %) and mining (2 %).

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Regional Socio-Economic Profile

The two major religions practiced in the study area are Christianity and traditional African belief,

although a merging of the two is common. The major Christian denominations are Zion Christian

Church, Apostolic Faith Mission, Catholic, Dutch Reformed, Lutheran and Methodist Church.

Table 4 below indicates population, gender, race, language and age demographics for Gauteng, in

comparison with the City of Ekurhuleni and Ward 97 based on information from the 2011 census.

Table 4: Population demographics relevant to the Cons Modder Project area (2011)

Category Gauteng City of Ekurhuleni Ward 97

Total population 13 399 725 3 379 104 34 633

Gender (%)

Female 49.6 48.8 50.3

Male 50.4 51.2 49.7

Race (%)

Black African 77.4 78.7 33

Coloured 3.5 2.7 1.9

Indian or Asian 2.9 2.1 2.1

White 15.6 15.8 63

Language (%)

IsiZulu 19.5 28.6 9.9

English 13.1 11.9 14.1

Afrikaans 12.3 11.8 56

Sepedi 10.5 11.3 3.6

Sesotho 11.4 9.9 3.7

Age (%)

0 - 18 27.9 24.4 26.7

18 - 64 23 71.8 66.1

Over 65 2.5 3.8 7.3

The majority of the population within the project area (Ward 97) speaks Afrikaans as their first

language.

In terms of age distribution, the City of Ekurhuleni and Ward 97 are similar, with about a quarter

of the population being below 18 years old, and about 70 % of the population being between 18

and 64 years old (potentially economically active age). The dependency ratio per 100 in the City of

Ekurhuleni is approximately 40 % (number of people under 15 and over 65 that depend on people

of a working age).

Table 5 below indicates the education profile of Gauteng, the City of Ekurhuleni and the study area.

According to the Gauteng Education Department, there are about 483 schools in the City of

Ekurhuleni, 77 combined, 261 primary, 121 secondary and 24 other schools.

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Table 5: Education profile of the Cons Modder Project area (%) (2011)

Category Gauteng City of Ekurhuleni Ward 97

No schooling aged 20+ 3.6 3.6 1.2

Grade 12/ Grade 12 aged 20+ 39.7 35.4 47.3

Higher education aged 20+ 10.9 14.6 7

Nearly 50 % of the population in Ward 97, aged 20+, have a Grade 12 however access to higher

education is low, with only 7 % of the population having undergone higher education.

Because the education system is failing to provide the skills or competence or qualifications which

are required for the economy, an endemic skills-gap exists. Only a small percentage of pre-school

children have access to quality early childhood development.

In the City of Ekurhuleni there are 1 299 490 households, 77.4 % of which are formal dwellings,

with the average household size being 2.9 people. 31.3 % of the households are female headed.

In Ward 97 there are 9 986 households, 81.2 % of which are formal dwellings, with the average

household size being 2 people. 27.5 % of the households are female headed.

Table 6 below indicates the service delivery profile of Gauteng. Service delivery within Gauteng

and the City of Ekurhuleni is good, with around 88 % of households having their refuse removed

once a week and about 85 % of households having flush toilets connected to sewer. In Ward 97,

95 % of households have their refuse removed once a week and about 97 % of households have

flush toilets connected to sewer.

Table 6: Service delivery profile of the Cons Modder Project area (StatsSA 2011)

Category Gauteng City of Ekurhuleni Ward 97

Refuse removal (%)

Removed once a week 88.6 88.4 95

Sanitation (%)

Flush toilet to sewer 86.4 85 96.9

Water provision (%)

Pipe water (inside dwelling) from

regional /local water scheme 93.5 95.8 96.3

Energy provision (%)

Electricity for at least one of

cooking, heating or lighting 87.9 82.2 97.3

There are about 94 primary health care facilities in the City of Ekurhuleni, 74 clinics, 5 mobile

health services and 7 district hospitals.

Health facilities in the City of Ekurhuleni are overstretched, responsibilities are overlapping and a

“whole of government” approach to health and social development is missing as supply driven

approaches to poverty alleviation and social development are led by silo institutions. The City of

Ekurhuleni has made efforts to ensure that it accelerates access to healthcare and continues to

improve facilities in order to provide a comprehensive package of primary healthcare services to

residents of the metro.

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Amongst key projects is addressing the HIV pandemic. The metro aims to increase access to 80 %

for HIV-positive clients by provision of antiretroviral services or fixed-dosed combinations. HIV

incidence has declined from 27 % reported in March 2011 to 15 % as at the end of September

2013, registering a decline of 12 %.

The project area is located within Region D of the City of Ekurhuleni according to the RSDF. Region

D accommodates a total population of 233 000 of which Ward 97 accommodates 34 633. There are

estimated to be 71 700 households within Region D with a population density of 1 090 people per

km2. The ratio of males to females is 1:1 and the predominant age category is 30 - 34 years,

unlike that of the greater City of Ekurhuleni which has a predominant age group of 25 to 29.

In 2012, 22.7 % of the region’s total population was living in poverty; similar to that of the greater

City of Ekurhuleni. Urban development in Region D is predominantly concentrated around Benoni,

Brakpan and Springs. However the eastern, western, southern and central areas within Region D

are more developed than the northern areas. The existing residential component in Region D

predominantly accommodates the middle income group. Higher income groups reside in areas such

as Presidents Dam (Springs), Petersfield Extension (Springs) and Sonneveld (Brakpan). The lower

income or more affordable residential areas include Geduld (Springs), Welgedacht (Springs) and

Wright Park (Springs). Refer to Figure 14 and Figure 15.

Local Context

The nearest residential areas in proximity to the shaft areas include the Sherwood Gardens and

Huntingdon suburbs of Brakpan North (refer to Figure 15) and an informal settlement, referred to

as the State Mines Community (refer to Figure 16). The residents of this informal settlement refer

to themselves as the Emagaleni Community.

The suburbs of Sherwood Gardens and Huntingdon are the closest formal suburbs to the proposed

mine shafts. The outer limits of the suburbs are approximately 500 m away from the proposed

shaft locations. The two suburbs can be described as typically low density, middle income suburbs.

There are large areas of open space and historical mining areas surrounding the suburbs. The

State Mines Country Club is located in close proximity to 7#.

Below is a summary of the current statistical profile as per the findings of the social surveys

conducted in April and August 2017:

Employment and education: private residences were large and well looked after, with well-

maintained gardens and significant security. The survey indicated that most private

resident owners run their own businesses, are employed elsewhere, or have retired. It can

thus be inferred that most owners are medium / high income earners. This is in line with

the statistical information for Ward 97;

Household utilities: Houses in these suburbs have electricity, piped water, flush toilets and

regular refuse removal. This is again in line with the statistical information for Ward 97,

which shows that almost 100 % of households have access to these services. Only one

property was using borehole water instead of municipal water supply for its 150 to 160

residents.

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Sense of place: The suburbs of Sherwood Gardens and Huntingdon can be described as

relatively quiet, well-established suburbs. Some of the residents indicated that they

consider the suburb to be peaceful with a low crime rate, whereas the majority felt that it

was a medium / high crime area. Open space borders the suburbs and this is characterised

by historical mine workings, illegal mining operations and illegal dumping. The land has

small hills and several clumps of trees, which shield the view of the historical mine

workings from the majority of the suburb. The noise study conducted as part of the EIA

process found the baseline noise levels on the edge of the suburbs to be classed as

typically suburban.

The Emagaleni Community (also known as State Mines Community) reside in the old mine houses

off Hospital Road, and in erected informal dwellings / shacks near to the old mine houses and the

old explosives shed. This community has an estimated population of 150 people, made up of

approximately 50 households. According to data collected, members of this community first

settled here 30 years ago. The majority of households stated they had been there between 11 and

20 years, and the most recent in the surveyed group was established 6 years ago. This implies

that there has not been a large influx of people into the community in recent years.

Due to the proximity of the community to historical mine workings, there is a possibility that there

are illegal miners active and possibly resident in the area. However, due to the security and police

presence during site visits and interviews, it is assumed that any illegal miners resident in the

community were not present and did not form part of the community that chose to be interviewed.

A mobile clinic visits once a month. There is a small tuck shop within the hostel, run by one of the

residents; there are no formal shops nearby.

Below is a summary of the current statistical profile as per the findings of the social survey

conducted in April 2017:

Age and gender: the community ranges from ages of 1 to 71 and the male to female ratio

appears to be 1:1;

Education and employment: Two thirds of households interviewed reported that no one in

the household was employed. The types of employment held by interviewees included

security, mechanic and mining. Almost half of households indicated that they relied on

piece jobs (general labour, gardening, etc.) for income.

Household utilities: Households do not have electricity, but do have piped water in

communal taps and communal chemical toilets provided by EMM.

Sense of place: The houses were observed to be in poor condition. Although the basic

service provision needs of the community are being met they are still considered an

informal settlement, as they do not have access to electricity or formal sanitation.

However, it should also be noted that this community is well established and has

expressed concern about being relocated and / or losing their homes. Some of the

members of the community have been there for over 30 years.

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Proposed Surface Infrastructure Footprint and Immediate Surrounds

Both the 7# and 10# areas are located on the Remaining Extent of Portion 3 of Modderfontein

76IR, which is owned by one landowner, Mr Meyer.

7# is located adjacent to the State Mines Country Club and is occasionally accessed by illegal

miners. The area surrounding the shaft is used for informal refuse/rubble dumping. There are also

structural remains of old mine infrastructure in the area which have been vandalized and are in

ruins and many consist only of foundations. One of the structures in proximity to 7# is used by the

Zion Christian Church as a church building.

Old opencast mine workings are located adjacent to the 10# area. Various buildings and structures

associated with old mine compounds and living quarters are located approximately 360 m away

from the shaft area. The Emagaleni Community have established around the old mine living

quarters and explosives magazine (refer to Figure 16).

Proposed Transport Route

The residential areas along the proposed transport route include Kingsway (Ward 73) as well as

Dersley, Eastvale and Skoonplaas (Ward 72). Refer to Figure 15.

Ward 73

Below is a summary of the statistical profile of Kingsway from the 2011 Census:

Total population: 13 562

Age: 21.6% youth and 69 % working age

Gender ratio: 51 % male

Education: 3.3 % have no schooling, 42.9 % have completed matric and 7.2 % have

higher education

Household utilities: 97.3 % have refuse removed regularly, 97.8 % have a flush toilet

connected to sewer, 97.9 % have piped water inside dwelling from regional /local water

scheme and 95.8 % have electricity for lighting

Ward 72

Below is a summary of the statistical profile of Ward 72 from the 2011 Census:

Age: median age is 28

Gender ratio: 53 % male

Education: 74.2 % have completed Grade 9 or higher and 47.6% have completed matric

Employment: 50.9 % are employed, 78 % of whom are employed in the formal sector

Household utilities: 62.3 % have refuse removed regularly , 63 % have access to flush or

chemical toilet, 93.8 % have piped water inside dwelling from regional /local water scheme

and 51.1 % have electricity for at least one of cooking, heating or lighting

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Figure 14: Communities surrounding the project area

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Figure 15: Brakpan North communities in proximity to the shaft areas

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Figure 16: Location of Emagaleni Community relative to the old mine living quarters

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x) Soil

The following baseline information was obtained from the soil study dated May 2017 (attached as

Appendix 14). A soil impact assessment dated July 2017 is also attached as Appendix 14.

The project area falls within the Ba1 land type which covers an area of complex and variable

geology and has a wide range of soils. The topography of the site is flat with distinct historical

mining impacts. An aerial photograph interpretation exercise indicates extensive historical mining

related impacts and that both sites have been altered significantly and in their entirety from the

natural pre-development reference state.

In the case of 7# the conditions are dominated by rubble that appears to be, at least partially,

derived from the demolition of structures on the site and partially from rubble having been dumped

on the site from outside sources. In the case of 10# the impacts are more closely related to

historical gold mining activities in the form of old treatment and handling infrastructure footprints

as well as more recent excavation activities.

It is evident that the site conditions are the same as those of a much wider area and that these

conditions are typical of gold mining activity footprints. As such the following conditions may be

present on the sites:

Elevated heavy metal and metalloid levels;

Elevated sulphate levels with associated low pH due to pyrite oxidation from tailings and

rock materials;

Elevated radiological signatures associated with the gold ores and tailings; and

Distinct surface and subsurface hydrological alteration of the site due to surface sealing,

concrete foundations and surface topography alteration.

A soil survey and impact assessment was undertaken in July 2017 (attached as Appendix 14).

Samples were obtained at the locations within and surrounding the proposed shaft areas. The

survey found that the soil at both shafts has been impacted by historical mining activities. The soil

at 7# exhibits manganese contamination close to the shaft. This area should not be used for urban

development due to contamination and stability concerns related to developing close to an open

shaft. Other metal levels are mostly within the guidelines for residential areas, with the exception

of iron. The soil at 10# shows more extensive pre-existing contamination than 7#, with elevated

concentrations of lead, manganese, arsenic and zinc. The future land use at 10# is however

planned for industrial development or further mining.

xi) Subsidence

The following information was obtained from the subsidence specialist opinion, dated April 2017

(attached as Appendix 15).

The general rock mass conditions and stratigraphic sequence at the Cons Modder mining area is

similar to that of the neighbouring and operational Modder East operations.

Based on the evaluation of geological borehole logs of exploration holes drilled from surface in the

Cons Modder mining area and information contained in the rock burst and rock fall Code of Practice

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(COP) of Modder East, it is evident that the rocks contained in the hanging wall above the reef are

substantial and competent. The overburden and soft soils in the area are limited to a few meters,

with an average depth from surface of 7.2 m. The Karoo age rocks follow, which include coal

seams and tillites. A general observation is that an intrusive rock was intersected in most of the

boreholes, relatively close to surface. This intrusive material is referred to as a dolerite sill in the

Modder East COP and is likely to be weathered. A syenite sill is also referred to and is indicated as

a competent rock. From the logged information it appears that the dolerite sill is moderately to

heavily weathered close to surface with deeper intersections showing little signs of weathering.

The formation of sinkholes, where dolomite is present, is always a matter of concern. The Monte

Christo Dolomite is however described as being a hard weathering formation and not cavernous in

nature. The formation contains perched water tables that exist along several granophyric and

dolerite sills. The Black Reef Quartzite located in the hanging wall of the Black Reef appears to be a

competent rock type. The Modder East COP indicates this as a strong and good quality rock mass.

The blocks of ground below the Jan Smuts Stream and 100 year floodline will be left intact. Future

mining is planned on the northern and southern sides of the 100 year floodline and should not

influence the behaviour of the pillars located below the stream, provided that the large unmined

blocks of ground remain intact below the stream area.

The previous underground mining was completed a relatively long time ago and the area has been

stable without recorded subsidence. This is likely attributable to the competent rock masses above

the reef horizon and small mining spans between three substantial un-mined blocks, providing

adequate regional stability to the area.

xii) Terrestrial Ecology

The following information was obtained from the terrestrial ecology study, dated May 2017

(attached as Appendix 16).

The project area falls within the Grassland Biome, within the Mesic Highveld Grassland Bioregion,

and further within the Soweto Highveld Grassland vegetation type which is a threatened

ecosystem, listed as Vulnerable in terms of Section 52 of NEMBA (refer to Figure 17).

According to the Gauteng C-Plan (2011), the southern portion of 7# is considered to be a Critical

Biodiversity Area (CBA). This CBA is considered an important area for "Orange” listed plant habitat,

and for primary vegetation. A CBA is an area considered important for the survival of threatened

species and includes valuable ecosystems such as wetlands, untransformed vegetation and ridges.

The northern portion of the 7# area falls within an ESA (refer to Figure 18). An ESA provides

connectivity and important ecological processes between CBAs and is therefore important in terms

of habitat conservation.

According to the Mining and Biodiversity Guidelines (2013), the majority of the project area falls

within an area considered to be of Highest Biodiversity Importance (refer to Figure 19). These are

areas where mining is not legally prohibited, but where there is a very high risk from mining due to

their potential biodiversity significance and importance to ecosystem services (e.g. water flow

regulation and water provisioning). The south-eastern corner of the 10# area falls within an area

considered to be of Moderate Biodiversity Importance (refer to Figure 19). These include ESAs,

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vulnerable ecosystems as well as focus areas for protected area expansion. These areas are of

moderate biodiversity value and therefore are at a moderate risk from mining. EIAs and associated

specialist studies should focus on confirming the presence and significance of these biodiversity

features, identifying features (e.g. threatened species) not included in the existing datasets, and

on providing site-specific information to guide the application of the mitigation hierarchy.

Habitat Unit

Following the field assessment of the project area and the associated habitat in April 2017, it was

concluded that there is one main habitat unit, namely the Transformed Habitat Unit. This habitat

unit comprises of land that is currently dominated by alien vegetation and has been disturbed as a

result of historical mining activities. This habitat type has been largely transformed as a result of

mining activities resulting in habitat clearing and dumping of waste material. In terms of habitat

provision this habitat is considered to have very low habitat provision capabilities, and is under

constant land changing impacts from earth moving/dumping activities.

Species Composition

The species composition of the habitat contains some floral species representative of the Soweto

Highveld Grassland vegetation type, but these species are also common species occurring

throughout the grassland biome in many vegetation types and some are also an indication of

disturbed veld. Thus, the vegetation associated with the project area is no longer representative of

intact Soweto Highveld Grassland as floral diversity is considered to be low. Indigenous floral

species observed within the habitat unit included Cynodon dactylon (Scutch Grass), Eragrostis

gummiflua (Gum Grass), Celtis africana (White Stinkwood), Urochloa mosambicensis (Bushveld

signal grass) and Searsia lancea (Karee).

A high abundance of alien and invasive floral species were present within this habitat unit, such as

Tagetes minuta (Southern Cone Marigold), Bidens pilosa (Blackjack), Melia azedarach (Chinaberry

- Category 3), Acacia mearnsii (Black Wattle- Category 2) and Lantana camara (Tickberry -

Category 1b). Alien and invasive plants out-compete indigenous species, altering the species

composition and habitat provision capabilities of the project area.

The faunal diversity within the project area was low and comprised mainly of avifaunal and

invertebrate species. Common faunal species encountered during the field assessment included

Streptopelia capicola (Cape turtle dove), Streptopelia senegalensis (Laughing dove), Acridotheres

tristis (Common Myna) and Bostrychia hagedash (Hadeda Ibis).

Species of Conservation Concern

No faunal or floral species of conservation concern (SCC) were encountered during the field

assessment. Preferred faunal and floral SCC habitat has been negatively affected by historical

mining activities and current anthropogenic activities, as vegetation composition has changed and

high levels of alien and invasive vegetation are present. Long term alien plant proliferation

combined with ongoing anthropogenic impacts will result in the continued large scale loss of

indigenous floral diversity within the project area. Alien and invasive proliferation present within

the study area has altered preferred habitat for faunal species which may occur based on desktop

data, namely Atelerix frontalis (Southern African Hedgehog - Near Threatened) and it is deemed

highly unlikely that this species will be present within the project area. The project area is further

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not linked to any larger areas capable of supporting faunal SCC, thereby minimising the potential

movement of such species to and from the area.

The herbaceous plant, Crinum bulbispermum (Orange River Lily - Declining) has a very low

probability of being present within the project area. However, it is highly unlikely to occur due to

the level of habitat transformation already associated with the project area and immediate

surrounding area.

Ecological Integrity

The ecological integrity of this habitat unit is considered to be low. The high levels of ongoing

anthropogenic activity within the area, such as dumping of building rubble further reduces habitat

integrity of the project area. Thus, the area is not considered to be important in terms of terrestrial

ecological conservation.

Environmental Sensitivity

Soweto Highveld Grassland is considered to be an Endangered vegetation type. Due to historical

mining activities and current activities within the area, the project area is no longer representative

of this vegetation type, and it is considered to be of low conservation importance. According to the

Gauteng C-Plan, ESA and CBAs are present within the 7# area. However, ecological conditions

encountered on site are not representative of ESA nor CBAs as a result of the degraded terrestrial

ecology associated with the project area.

The 7# and 10# areas are of low ecological importance and sensitivity. Development activities

would therefore have a low impact on the faunal and floral component of the project area, as

significant transformation has already occurred.

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Figure 17: Ecosystem associated with the project area

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Figure 18: Gauteng C-Plan classification of the project area

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Figure 19: Mining and Biodiversity Guideline classification of the project area

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xiii) Traffic

The following information was obtained from the traffic study, dated June 2017 (attached as

Appendix 17).

The proposed transport route comprises an access road from 10#, portions of Hospital Road, Main

Reef Road (R29), Putfontein Road (R51), Main Reef Road, Orpiment Avenue and Cloverfield Weg.

From the starting point at 10# the access route is in-situ gravel road up to Hospital Road. The

width of this gravel road varies between 3 m and 6 m and it is generally in poor condition. This

access road passes through a community area and the intersection with Hospital Road is

approximately 200 m from the Emagaleni informal community. No motorized traffic was observed

on this access road but several pedestrians were observed. The access road narrows to 2m in

width nearer to the 10# site with a gentle vertical grade of approximately 1 %.

Hospital Road is an asphalt paved road, approximately 7 m wide and appears to be in poor

condition, with large potholes, crocodile cracks and transverse cracks being observed. This road is

surrounded by an undeveloped mining zone area. High traffic volumes were observed with a

mixture of cars, trucks and mini-bus taxis. No speed limit signage was observed and vehicles

appeared to be driving at speeds between 80 and 100 km/h. A number of pedestrians and cyclists

were also observed along this road, walking and cycling within the road carriageway as the road

verge has long grass and no shoulders and / or sidewalks exist. Hospital Road has a slight camber

to enable surface runoff. This road is well suited to carry heavy vehicles in terms of function and

class, but not in terms of pavement structure.

Main Reef Road is an asphalt paved road, approximately 7 m wide and is generally in average

condition. This road passes through an undeveloped residential zoned area. High traffic volumes

with a mixture of cars, trucks and mini-bus taxis were observed. No speed limit signage was

observed and vehicles were travelling at an average speed of 80 km/h. Drivers were noted to be

impatient with slow moving vehicles. Low volumes of pedestrians were observed walking on the

road verge. Although no sidewalks exist there is a 300 mm shoulder. The shoulder reduces to

almost non-existent midway of this section. The road edge is slightly eroded and most of the verge

is in-situ material.

Putfontein Road is a paved road surface, which is approximately 10 m wide and is generally in

good condition. This road is surrounded by residential area. The traffic volume along this

subsection was observed to be high, with a mixture of cars, trucks, buses, mini-bus taxis and a

moderate volume of pedestrians crossing the Main Reef Road / Putfontein Road (R51) intersection

and walking along R51 subsection on the road shoulder. The speed limit on Putfontein Rd is

80 km/h. Putfontein Road (R51) surface is in good condition and since it is a regional arterial road,

it is well suited in terms of functionality and pavement structure to carry heavy vehicles.

Main Reef Road is a paved surface road approximately 8 m wide and is generally in an average

condition. The road passes through a quiet residential area. The traffic along this road was

observed to be low volumes with mainly cars and a few pedestrians walking on the road verge.

Traffic control signs were observed. A few pedestrians were noted on the road grass verge, where

there is no shoulder but a wide well-maintained verge. Main Reef Rd through Dersley was observed

to be in average condition, with crocodile cracks observed.

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Orpiment Avenue and Cloverfield Weg are paved surface roads, approximately 7 m wide and

generally in average condition. Orpiment Avenue passes through a residential area and a nursery

school was observed approximately 10 m from the road edge. The traffic along this road was

observed to be moderate volumes with cars, trucks, mini-bus taxis and a few pedestrians walking

on the wide verge. The speed limit is marked as 60 km/h. Orpiment Avenue continues onto

Cloverfield Weg, which is a similar road condition and a few pedestrians and a cyclist were

observed along this subsection on the road verge. Cloverfield Weg is also surrounded by residential

areas but houses are set far from the road edge. Sidewalks and shoulders do not exist on a large

portion of Cloverfield Weg and it is surrounded by undeveloped land, however most of this land is

zoned for residential development. Orpiment Avenue and Cloverfield Weg were also observed to be

in average condition, with crocodile and transverse cracks observed along the road subsection.

Critical intersections that could potentially be affected by the Cons Modder Project, specifically

hauling activities, were assessed. Traffic counts were conducted at three intersections associated

with the proposed transport route on 11 May 2017. Refer to Figure 20. Survey times were from

06h00 to 18h00.

Intersection 1:

Peak hours at Intersection 1 are between 06h30 and 07h30 (with a total of 1 534 vehicles

travelling through the intersection), between 14h00 and 15h00 (with a total of 760 vehicles

travelling through the intersection) and between 16h45 and 17h45 (with a total of 1 567 vehicles

travelling through the intersection).

Intersection 2:

Peak hours at Intersection 2 are between 06h45 and 07h45 (with a total of 3 664 vehicles

travelling through the intersection), between 14h00 and 15h00 (with a total of 2 220 vehicles

travelling through the intersection) and between 16h30 and 17h30 (with a total of 3 444 vehicles

travelling through the intersection).

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Intersection 3:

Peak hours at Intersection 3 are between 07h45 and 08h45 (with a total of 248 vehicles travelling

through the intersection), between 14h00 and 15h00 (with a total of 335 vehicles travelling

through the intersection) and between 16h45 and 17h45 (with a total of 397 vehicles travelling

through the intersection).

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Figure 20: Roads and intersections associated with the transport route

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xiv) Visual Aesthetics

The following information was obtained from the visual study which is currently underway.

Sense of Place

In terms of land use the character of the landscape can be defined as mostly residential and

current and historical mining. The noise character at the site is typical of a suburban area

dominated by noise primarily from pedestrians, animals, birds, and local road and air traffic. The

area generally experiences the low ambient noise levels typical of suburban and semi-rural

environments. The area is predominantly residential, open veld and worked out mining areas with

no excessively noisy industries or similar sources of noise in the vicinity. The shaft areas are not

considered significant in terms of cultural heritage value. There are distinct mining related features

that allow for a wide spectrum of users or viewers to recognise the areas, indicating that the areas

have a strong mining sense of place.

Landscape Quality

The landscape quality of the proposed shaft areas (sites proposed for surface infrastructure, as it is

currently, prior to any new development) is considered Low and the wider area in general is

considered Moderate. The proposed shaft areas, prior to development, had a lower landscape

quality score compared with that of the wider area in general.

Viewshed Analysis

Visibility was determined by means of a viewshed analysis for the mine components with the

greatest potential visibility (headgear of the shafts). From the analyses it was determined that due

to the undulating topography, visibility will be irregular.

Visual Absorption Capacity

Field verification confirmed a degree of visual absorption capacity in terms of vegetation, mine

dumps and infrastructure. Therefore, the landscape offers significant visual absorption qualities in

terms of screening features which will obstruct the view of the proposed infrastructure from the

surrounding sensitive visual receptors to varying degrees.

Sensitive Visual Receptors

Visual receptors were determined using the viewshed analysis and field verification. Residential

areas, businesses and recreational facilities within a 1.5 km radius were identified as having a

potential view of the development depending on the level of screening by topography, vegetation

and buildings. Receptor sensitivity was also determined. The receptors with the highest sensitivity

include occupiers of residential properties with views affected by the development. The residents of

the residential areas of Sherwood Gardens and Huntingdon in Brakpan North (as well as residents

of the informal community near 10# are considered to be the most sensitive visual receptors (refer

to Figure 21). Receptors with moderate sensitivity include people engaged in outdoor sport or

recreation (other than appreciation of the landscape where the landscape is of acknowledged

importance or value) which would include golfers utilising the State Mines Country Club adjacent to

7# (refer to Figure 21). The least sensitive receptors include people at their place of work, or

engaged in similar activities, whose attention may be focused on their work or activity and who

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therefore may be potentially less susceptible to changes in the view. Sensitive receptors of this

nature include employees of Manhattan Corporation and State Mines Country Club adjacent to 7#,

and Scoops adjacent to 10#. Roads through urban and industrial areas are also considered to be

least sensitive due to the temporary view of travellers, Hospital Road (M56) and Main Reef Road

(R29) were identified as the affected roads (refer to Figure 21).

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Figure 21: 1.5 km visual buffer area for the Cons Modder shafts showing areas of sensitive visual receptors

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xv) Wetlands

The following information was obtained from the wetland study dated December 2016 (attached as

Appendix 7).

Two natural wetland features were identified by the National Freshwater Ecosystem Priority Area

(NFEPA) database (desktop study) to be located within the proposed underground mining area: a

channelled valley bottom wetland, located approximately 340 m south-east of 7# and a depression

wetland located within approximately 115 m south-east of 7#.

Due to the surrounding modifications to the proposed underground mining area and subsequent

disturbed natural environment, it was determined via a site visit that only the channelled valley

bottom wetland can be considered a natural wetland feature. Even though the depression wetland

was identified by the NFEPA database to be natural, during the site visit it was confirmed that the

depression wetland had no wetland indicators.

The channelled valley bottom wetland was identified within the central portion of the proposed

underground mining area associated with the Jan Smuts Stream (refer to Figure 23). This wetland

has been classified by the NFEPA database as an unchannelled valley bottom wetland, but it should

be considered a channelled valley bottom wetland due to a furrow running through it.

The channelled valley bottom wetland was determined to be largely modified, with a Present

Ecological State (PES) Category D, as surrounding mining activities have influenced the sediment

balance of the wetland and have reduced the catchment surface runoff entering into the wetland.

Modifications to this wetland include soil disturbance due to excavations, construction of mining

infrastructure, disposal of building material and the invasion of alien vegetation species. The

Recommended Ecological Category (REC) is Category D, which indicates that present levels of

ecological services and functioning of the wetland should be retained and not permitted to

deteriorate further, so as to possibly reinstate habitat and increase ecosystem service delivery.

Despite the significantly decreased ecological integrity of this wetland, functioning remains at an

intermediate level, particularly in terms of ecosystem services (refer to Figure 22) such as stream

flow regulation, flood attenuation and toxicant assimilation. Socio-cultural service provision is

deemed to be low, largely as a result of the historical mining activities and urbanised nature of the

area.

This wetland is considered to be ecologically important, largely due to the fact that it falls within a

CBA, and the conservation and protection status of the applicable Wetland Vegetation (Wet Veg)

group. However, the ecological importance and sensitivity is considered Category C, due to the

significantly impaired ecological integrity of the wetland (mainly due to historical mining activities).

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Figure 22: Ecosystem services provided by the wetland in the project area

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Figure 23: Delineated wetland within the project area

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b) Description of the current land uses

i) Description of specific environmental features and infrastructure on the site

The majority of the land associated with the study area is classified as mining / municipal open

space according to spatial data obtained from the City of Ekurhuleni Geographical Information

Systems (GIS) Land Use Map. Refer to Figure 24.

The proposed shaft areas are located north of Brakpan North. The proposed underground mining

area and two proposed shaft areas are traversed by Hospital Road and the Jan Smuts Stream.

The surface footprint areas at Cons Modder have been disturbed by previous mining activities as

well as illegal mining activities.

A site visit was conducted in April 2017 and the following land uses were identified within the

proposed site and surrounds: old mining remains, golf course, industry, residences, roads and

electricity infrastructure (refer to photos 1 to 12).

Photo 1: Unrehabilitated opencast pit from

previous mining activities adjacent to 10#

Photo 2: 10# sealed with rubble with the adjacent

opencast pit from previous mining activities in the background to the left

Photo 3: View of existing mine dumps from the 10# location

Photo 4: Remains of old mine infrastructure in proximity to 10#

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Photo 5: Pfuhl Street running adjacent to the 10# area

Photo 6: Power lines running adjacent to Hospital Road

Photo 7: Golf course (State Mines Country Club) adjacent to 7#

Photo 8: Remains of old mine infrastructure in proximity to 7#

Photo 9: Structure in proximity to 7# used by the Zion Christian Church as a church building

Photo 10: Remains of old mine infrastructure in proximity to 7# with industry (Manhattan Corporation) in the background

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Photo 11: Remains of old mine infrastructure in proximity to 7# with the view of Hospital Road

from the shaft location in the background

Photo 12: Rubble at the open 7# with the view of the golf course (State Mines Country Club) in the

background

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ii) Environmental and current land use map (Show all environmental, and current land use features)

Figure 24: Current land use (City of Ekurhuleni)

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c) Impacts identified (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)

The initial site layouts are reflected in Figure 3 and Figure 4.

The potential positive and negative impacts, including cumulative impacts, of the Cons Modder Project

will be assessed during the EIA phase. From an initial high level assessment, the impacts (prior to

mitigation) and associated significance, probability and duration are identified in Table 7 below.

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Table 7: Potential impacts of the Cons Modder Project

Activity Potential impact Magnitude Scale Duration Probability Significance

Shafts, winders at 7# and 10# and 500T headgear

bin at 10#

Nuisance noise from hoisting and loading activities at 10#

8 2 4 4 56 Medium

Stormwater runoff may be contaminated by ore spilled during loading

6 2 4 3 36 Medium

Impact on air quality by dust and fine particulates generated from ore

handling at 10#

6 2 4 3 36 Medium

Compressors Nuisance noise from compressors 2 2 4 2 16 Low

Drop set operating tower,

concrete bank areas and covered loading areas

Nuisance noise from materials

loading 4 2 4 2 20 Low

Railway loops None foreseen - - - - - -

Administration buildings (including change houses)

None foreseen - - - - - -

Ablutions (conservancy) Pollution of the environment from inadequate handling of sewage

2 1 1 3 12 Low

General waste storage areas, workshops, stores, laydown areas, boot wash, pollution control

infrastructure at both

shafts and grout plant at 10#

Pollution of the environment from inadequate handling and temporary storage of waste and water containing waste

6 1 5 3 36 Medium

Power lines, substations and gensets

None foreseen - - - - - -

Topsoil stockpile Erosion of stockpiled soil from stormwater runoff

6 1 4 3 33 Medium

Stormwater diversion infrastructure

Erosion from diverted stormwater runoff

6 1 4 2 22 Low

Explosives delivery area at 10#

Soils may be contaminated by spills 6 1 4 2 22 Low

On site roads for employee transport to 7# and hauling from 10#

Impact on air quality by dust and fine particulates generated from

vehicle entrainment on unpaved

roads

4 2 4 2 20 Low

Nuisance noise from taxis transporting employees at 7# and hauling at 10#

2 2 4 2 16 Low

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Activity Potential impact Magnitude Scale Duration Probability Significance

Soils may be contaminated by hydrocarbon spills

4 1 5 3 30 Medium

Introduction of alien and invasive vegetation through disturbance of the area

2 2 5 3 27 Low

Additional increased heavy vehicle

traffic on the transport route may damage road surfaces and decrease road safety

6 2 4 4 48 Medium

Surface infrastructure areas

Impact to buried resources of cultural and heritage significance during clearing (unlikely due to the

disturbed character of the sites)

8 1 5 1 28 Low

Introduction of alien and invasive vegetation through clearing and disturbance of the area

2 2 5 3 27 Low

Visual intrusion of tall infrastructure such as shaft headgear (including lighting at night)

6 4 2 4 48 Medium

Erosion from cleared areas 6 1 4 3 33 Medium

Rehabilitation may be unsuccessful should rehabilitation measures not be implemented adequately leading to permanent loss of habitat and

species diversity and altered surface

flow

6 1 5 3 36 Medium

Underground mining

Hydrocarbons from underground mining activities polluting groundwater

6 2 4 3 36 Medium

Underground mining may result in subsidence impacting surface landowners (unlikely as the rock and supports were found to be competent and stable)

2 2 4 2 16 Low

Underground blasting may result in damage to surface structures

(unlikely due to the blast design)

2 2 4 2 16 Low

Provide employment as well as local economic development initiatives and contribute to the GDP

6 2 4 5 60 High+

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Activity Potential impact Magnitude Scale Duration Probability Significance

Possible in-migration of job seekers into the area resulting in growth of existing informal settlements or the formation of new ones as well as secondary impacts of in-migration including pressure on existing infrastructure and an increase in

crime and social ills

8 2 5 4 60 High

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i) Methodology used in determining the significance of environmental impacts

(Describe how the significance, probability, and duration of the aforesaid identified impacts that

were identified through the consultation process was determined in order to decide the extent to

which the initial site layout needs revision)

The Prime Resources (Pty) Ltd Impact Assessment Methodology and rationale was used to assess the

significance of the potential impacts of the initial layouts on the surrounding biophysical and socio-

economic environment.

The methodology encompasses an assessment of the nature, extent, duration, probability and

significance of the identified potential environmental, social and cultural impacts of the mining

operation. The significance of both positive and negative potential impacts will be determined through

the evaluation of impact consequence and likelihood of occurrence.

The following risk assessment model has been used for determination of the significance of impacts.

SIGNIFICANCE = (MAGNITUDE + DURATION + SCALE) X PROBABILITY

The maximum potential value for significance of an impact is 100 points. Environmental impacts can

therefore be rated as high, medium or low significance on the following basis:

High environmental significance 60 – 100 points

Medium environmental significance 30 – 59 points

Low environmental significance 0 – 29 points

MAGNITUDE (M) DURATION (D)

10 – Very high (or unknown) 5 – Permanent

8 – High 4 – Long-term (ceases at the end of operation)

6 – Moderate 3 – Medium-term (2-8 years)

4 – Low 2 – Short-term (0-1 years)

2 – Minor 1 – Immediate

SCALE (S) PROBABILITY (P)

5 – International 5 – Definite (or unknown)

4 – National 4 – High probability

3 – Regional 3 – Medium probability

2 – Local 2 – Low probability

1 – Site 1 – Improbable

0 – None 0 – None

ii) The positive and negative impacts that the proposed activity (in terms of the

initial site layout) and alternatives will have on the environment and the

community that may be affected (Provide a discussion in terms of advantages and

disadvantages of the initial site layout compared to alternative layout options to accommodate

concerns raised by affected parties)

The initial layouts of the footprint areas associated with the Cons Modder Project are reflected in

Figure 3 and Figure 4. If any concerns are raised during the public participation process, site layout

alternatives may be presented as necessary.

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The advantages of the current Cons Modder Project layout and site include:

The site is likely to have the least impact on the surrounding environment as the footprint of

the proposed surface infrastructure is confined to areas previously transformed by mining

activities.

There are no surface water resources within proximity to the proposed surface infrastructure

footprint and the groundwater level is below the reef to be mined due to current dewatering

activities.

No sites of archaeological or palaeontological significance were identified within the footprint of

the proposed surface infrastructure.

Existing infrastructure, mine dumps and vegetation offer a degree of screening between

sensitive receptors and proposed infrastructure which will mitigate negative visual impacts.

Illegal mining activities currently take place at the proposed shaft areas; the construction of

formal mine shaft areas and associated security measures will restrict these activities at these

shaft areas.

Disadvantages of the current Cons Modder Project layout and site include:

The proximity of formal and informal residential areas to the shafts means that they may be

exposed to noise, dust, visual and impacts of the project, as well as potential indirect impacts

associated with in-migration of job seekers into the area.

The surrounding communities will be exposed to increased heavy vehicle traffic on the

transport route which may result in decreased road safety and damage to road surfaces.

iii) 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)

Refer to Figure 3 and Figure 4 for the initial layout plans which were provided to relevant State

Departments and IAPs during the Scoping Phase public participation process. An issues register (of

concerns raised by affected parties) will be compiled during the process and included in the final

Scoping Report to be submitted to the DMR.

Mitigation measures for the impacts of the initial layouts identified thus far are detailed in Section

12)g) below. Potential impacts of the final site layout will be assessed during the EIA phase.

d) The outcome of the site selection Matrix. Final Site Layout Plan (Provide a final site

layout plan as informed by the process of consultation with interested and affected parties)

If issues and concerns are raised during public consultation, which require the revision of the layouts,

this will be undertaken prior to the submission of the Scoping Report to the DMR. If there is no need

for the layouts to be revised following public participation, the initial layouts will be considered as the

final layouts to be further assessed during the EIA phase.

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i) Motivation where no alternative sites were considered

No alternative site locations were assessed as the access shafts are existing shafts to be refurbished.

The location of associated infrastructure is based on the access shaft locations and limited to areas

previously transformed by mining activities, and has been kept to the minimum extent possible.

Alternatives to the site layouts will be assessed if required based on the outcome of the Scoping Phase

public participation process.

ii) Statement motivating the preferred site (Provide a statement motivation the final site

layout that is proposed)

The site selection is based on the location of the existing shafts to be refurbished. The footprint of

supporting infrastructure has been kept to a minimum, and disturbed areas are to be utilised,

minimising the environmental impact.

12) PLAN OF STUDY FOR THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

a) Description of alternatives to be considered including the option of not going

ahead with the activity

Technological and design alternatives were considered for the project, as well as the option of not

going ahead with the Cons Modder Project. Refer to Section 9). Layout and further technological and

design alternatives may be recommended based on the outcome of the public participation process

and the specialist impact assessments.

b) Description of the aspects to be assessed as part of the environmental impact

assessment process (The EAP must undertake to assess the aspects affected by each

individual mining activity whether listed or not, including activities such as blasting, Loading,

hauling and transport, and mining activities such as Excavations, stockpiles, discard dumps or

dams, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops,

processing plant, storm water control, berms, roads, pipelines, power lines, conveyors,

etc…etc…etc.)

The project activities to be assessed include:

Underground mining;

Construction and operation of surface infrastructure associated with the underground mining

including: shafts, winders, headgear bin and grout plant at 10#, compressors, drop set

operating tower, concrete bank areas and covered loading areas, railway loops, administration

buildings, general waste storage areas, workshops, stores, laydown areas, boot wash, power

lines, substations and gensets, topsoil stockpile at 10#, stormwater diversion infrastructure,

pollution control infrastructure, explosives delivery area at 10#, on-site roads and employee

transport to 7# and hauling from 10#.

The findings of the EIA process will provide a detailed overview of the potential impacts (including

direct, indirect, cumulative and latent impacts) of the proposed project on the biophysical and social

environments.

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c) Description of aspects to be assessed by specialists

A brief description of each specialist scope is provided below:

Specialist study Aspects addressed during

Scoping Phase

Aspects still to be

addressed during the EIA phase

Air quality (July 2017) Baseline and impact assessment None

Aquatic ecology (December 2016) Specialist opinion None

Archaeology (April 2017) Phase 1 HIA None

Blasting (May 2017) Specialist opinion None

Geohydrology (May 2017) Specialist opinion Updated opinion

Hydrology (December 2016) Baseline and impact assessment None

Noise (May 2017) Baseline and impact assessment None

Palaeontology (April 2017) Phase 1 PIA None

Socio-economic Baseline Impact assessment

Soil (May 2017 and July 2017) Baseline and impact assessment None

Subsidence (April 2017) Specialist opinion None

Terrestrial ecology (May 2017) Baseline and impact assessment None

Traffic (June 2017) Baseline and impact assessment None

Visual Baseline Impact assessment

Wetlands (December 2016) Baseline and impact assessment None

Some of the specialist studies attached as appendices for the Cons Modder Project refer to the Gedex

Project. These specialist studies were commissioned early in the planning process, and since then the

name of the project has changed from the Gedex Project to the Cons Modder Project. The underground

mining area and surface areas associated with the Gedex Project have not changed. The operational

phase has increased from three years to eight years as a result of additional resource areas being

confirmed within the delineated underground mining area. The change in the LoM does not affect the

specialist’s impact assessments as the duration value in the impact assessment rating methodology

remains long term.

d) Proposed method of assessing the environmental aspects including the

proposed method of assessing alternatives

The environmental aspects have been assessed in terms of the methodology described in Section

11)c)i). Alternatives have been assessed to date, refer to Section 9). Transport route alternatives, as

well as any alternatives (as suggested or raised during the Scoping Phase public participation process,

informed by specialist recommendations), will be assessed during the EIA phase, in terms of the

methodology described in Section 11)c)i).

i) The proposed method of assessing duration significance

The Prime Resources (Pty) Ltd Impact Assessment Methodology and rationale as described in Section

11)c)i) above will be used to assess the significance of the potential impacts of the Cons Modder

Project on the surrounding biophysical and social environment.

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As per the methodology, duration will be assessed as follows:

DURATION (D)

5 – Permanent

4 – Long-term (ceases at the end of operation)

3 – Medium-term (2-8 years)

2 – Short-term (0-1 years)

1 – Immediate

Duration will play a role in determining the significance of an impact as follows:

SIGNIFICANCE = (MAGNITUDE + DURATION + SCALE) X PROBABILITY

ii) The stages at which the competent authority will be consulted

The Competent Authority (DMR) was formally notified of the project upon submission of the

application for a Mining Right and Environmental Authorisation, via the online SAMRAD system on

4 October 2017.

This Scoping Report was made available to the Competent Authority (DMR) during the 30 day

commenting period (13 October 2017 to 13 November 2017). The Scoping Report will be further

updated with any comments received and submitted to the Competent Authority by 17 November

2017.

The EIAR and EMPr will be made available to the Competent Authority (DMR) during the 30 day

commenting period for the EIA phase. The EIAR and EMPr will further be updated with any comments

received and will be submitted to the Competent Authority at the end of the commenting period for

consideration.

e) Particulars of the public participation process with regard to the Impact

Assessment process that will be conducted

i) Steps to be taken to notify interested and affected parties (These steps must include

the steps that will be taken to ensure consultation with the affected parties identified in (h) (ii) herein)

IAPs were notified about the project during the Scoping Phase public participation process detailed

under Section 10) above, including:

Landowner notification was provided in writing to the current landowner of the farm where the

proposed surface infrastructure is to be located;

A media notice was published in a newspaper circulating in the area;

Site notices were posted on site and at conspicuous locations within the surrounding

communities;

An IAP register has been opened and representatives from all of the relevant State

Departments, as well as any IAPs requesting to register, will be added to the database;

BIDs were made available to State Departments (including the Competent Authority) via email

and to adjacent landowners and occupiers by hand, email or registered mail (based on the

contact details available);

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The Scoping Report has been made available for comment to State Departments (including the

Competent Authority) via email or hard copy as requested and placed within the public domain

for review during the 30 day commenting period; and

IAPs will be notified via sms or email (based on the contact details available) of the details of

any meetings to be held.

IAPs will be further engaged during the EIA phase as per the process described below.

ii) Details of the engagement process to be followed (Describe the process to be

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 and records of such consultation will be required in the EIA at a later stage)

During the Scoping Phase, IAPs were notified via media notice, site notices, and BIDs (via email,

registered mail, or delivered by hand). The Scoping Report was made available for comment and IAPs

will be notified via sms of the details of any meetings to be held.

During the EIA phase further public participation will be conducted. The EIA phase public participation

process will comprise of the following:

An EIAR and an EMPr will be compiled and made available for comment, in the public domain at the

same locations as the Scoping Report, as well as made available to State Departments (including the

Competent Authority) for a period of 30 calendar days.

An SMS will be sent out to all registered IAPs notifying them of the localities where the EIAR and EMPr

can be viewed, the commenting period, as well as providing the details of any meetings to be held.

IAPs will be given the opportunity to raise issues and concerns. The IAP database and Comments and

Responses Report will be updated throughout the EIA phase public participation process and

submitted, together with the EIAR and EMPr, to the Competent Authority for consideration after the

30 day commenting period has ended.

iii) Description of the information to be provided to Interested and Affected Parties (Information to be provided must include the initial site plan and sufficient detail of the intended operation and the typical impacts of each activity, to enable them to assess what impact the activities will have on them or on the use of their land)

Scoping Phase - Public Participation Process

The information provided will consist of details of the project, including the layout and description of

project components; specialist information relating to the existing / baseline information of the site;

potential impacts of the project to be assessed during the EIA; the process to be followed for the

Scoping Phase; opportunities to participate; and where to obtain further information.

EIA Phase – Feedback Public Participation Process

The information provided will consist of details of the project, including the layout and description of

project components; specialist information relating to the existing / baseline information of the site;

potential impacts of the project as identified and assessed by the specialists and the EAP; proposed

mitigation and management measures to avoid or reduce the impact; concerns / issues raised during

the Scoping Phase and responses thereto which will have been incorporated into a Comments and

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Responses Report; the process to be followed for the EIA; opportunities to participate; and where to

obtain further information.

f) Description of the tasks that will be undertaken during the environmental impact

assessment process

The tasks to be undertaken during the EIA phase are graphically represented in the following flow

diagram:

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g) Measures to avoid, reverse, mitigate, or manage identified impacts and to determine the extent of the residual risks that need

to be managed and monitored

Activity Potential impact Mitigation type Potential for residual risk

Shafts, winders at 7# and 10# and 500T headgear bin at 10#

Nuisance noise from hoisting and loading activities at 10#

Monitor noise levels and implement noise reduction measures (i.e. use of non-resonating materials in the bin, reduction in drop heights and enclosing noisy

infrastructure components where possible)

None foreseen as mining activities will cease at the end of operations and the infrastructure is to be removed during decommissioning

Stormwater runoff may be contaminated by ore spilled during

loading

Avoid overloading to prevent spills and any spilled material will be swept up and loaded

into the haul truck after each load

None foreseen as mining activities will

cease at the end of operations

Impact on air quality by dust and fine particulates generated from ore handling at 10#

Implement dust suppression measures and monitor dust and fine particulate levels to ensure standards are being met

None foreseen as mining activities will cease at the end of operations

Compressors Nuisance noise from compressors Monitor noise levels and implement noise reduction measures (enclosing compressors if necessary) None foreseen as mining activities will

cease at the end of operations Drop set operating tower, concrete bank areas and covered loading areas

Nuisance noise from materials loading Monitor noise levels and implement noise reduction measures (constructing noise barriers if necessary)

Railway loops None foreseen - -

Administration buildings

(including change houses) None foreseen - -

Ablutions (conservancy) Pollution of the environment from inadequate handling of sewage

Ensure adequate handling to prevent spills

None foreseen as a conservancy may only be used temporarily during construction until the connection to the

municipal sewage system is established or if no municipal connection is established the conservancy will be removed during decommissioning

General waste storage

areas, workshops, stores, laydown areas, boot wash, pollution control

infrastructure at both shafts and grout plant at 10#

Pollution of the environment from inadequate handling and temporary storage of waste and water

containing waste

Ensure adequate handling and storage of waste and wastewater and these are

contained

If waste and wastewater is not adequately managed and/or removed and disposed of off-site during

decommissioning, waste may pollute the

environment post-closure

Power lines, substations and

gensets None foreseen - -

Topsoil stockpile Erosion of stockpiled soil from Implement erosion monitoring, prevention None foreseen as stockpiled topsoil will

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Activity Potential impact Mitigation type Potential for residual risk

stormwater runoff and maintenance measures to be implemented and limit erosion of the

stockpiled soil material through vegetation and the construction of stormwater management infrastructure

be used for rehabilitation and there will therefore be no topsoil stockpile post-

closure

Stormwater diversion

infrastructure

Erosion from diverted stormwater

runoff

Implement erosion monitoring, erosion prevention infrastructure to be constructed

and maintenance measures to be implemented if any erosion occurs

None foreseen infrastructure is to be removed during decommissioning and the area rehabilitated

Explosives delivery area 10#

Soils may be contaminated by spills Adequately bund facilities and clean spills timeously using spill kits which should be on hand

None foreseen infrastructure is to be removed during decommissioning

On site roads for employee

transport to 7# and hauling from 10#

Impact on air quality by dust generation from vehicle entrainment on unpaved roads

Implement dust suppression measures to be implemented; monitoring of dust levels to ensure standards are met

None foreseen as mining activities will cease at the end of operations and the roads rehabilitated after decommissioning

Nuisance noise from taxis transporting employees at 7# and

hauling at 10#

Monitor noise levels and implement noise reduction measures (i.e. adequate vehicle

maintenance, limit reversing and idling)

Soils may be contaminated by hydrocarbon spills

Spills must be cleaned timeously using spill kits which should be on hand

Introduction of alien and invasive vegetation through disturbance of the area

Implement alien and invasive vegetation

monitoring and eradication

Establishment of alien and invasive vegetation in the rehabilitated area and

surrounds should eradication not be undertaken adequately

Additional increased heavy vehicle traffic on the transport route may damage road surfaces and decrease

road safety

Maintain the transport route in collaboration with road authority and implement road safety measures as recommended by the

traffic specialist

None foreseen as mining activities, including hauling, will cease at the end of operations

Surface infrastructure areas

Impact to buried resources of cultural

and heritage significance during clearing

Implement the chance finds procedure should buried resources be unearthed

None foreseen as the potential impact of unearthing buried resources are most likely to occur during the construction phase

Introduction of alien and invasive vegetation through clearing and

disturbance of the area

Implement alien and invasive vegetation monitoring and eradication

Establishment of alien and invasive vegetation in the rehabilitated area and surrounds should eradication not be

undertaken adequately

Visual intrusion of tall infrastructure such as shaft headgear (including lighting at night)

Employ camouflaging measures such as

earthy paint colours, install lighting types that reduce light spill and keep the trees along the project boundary in place in order to conceal the development

None foreseen as infrastructure is to be removed during decommissioning

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Activity Potential impact Mitigation type Potential for residual risk

Erosion from cleared areas Erosion monitoring, prevention and maintenance measures to be implemented

Erosion may be a permanent problem should rehabilitation be inadequate

Rehabilitation may be unsuccessful should rehabilitation measures not be implemented adequately leading to permanent loss of habitat and species

diversity and altered surface flow

Implement adequate rehabilitation measures including contouring to allow for free drainage

Unsuccessful rehabilitation may lead to altered stormwater drainage patterns post-closure which may result in damming and steep slopes and

compacted areas could encourage flash floods

Successfully rehabilitate the disturbed area with indigenous species

Unsuccessful rehabilitation may lead to further transformation of natural habitat and permanent loss of ecological functioning and species diversity

Underground mining

Hydrocarbons from underground mining activities polluting groundwater

Allocate dedicated underground areas where oil and diesel are refuelled, with contamination prevention measures such as oil sumps, bund walls to prevent free flow of spilled product on the mine floor, clean

spilled product and monitor return water quality

None foreseen as mining activities will cease at the end of operations

Underground mining may result in subsidence impacting surface landowners (unlikely as the rock and supports were found to be competent

and stable)

Ensure that adequate supports are in place None foreseen as adequate supports will be left in place post-closure

Underground blasting may result in damage to surface structures (unlikely due to the blast design)

Amend blasting methodology if necessary to ensure that blasting does not impact surrounding surface infrastructure

None foreseen as mining activities will cease at the end of operations

Provide employment as well as local economic development initiatives and contribute to the GDP

Positive impact which does not require mitigation measures to enhance positive impacts will be investigated

Local economic development initiatives should be self-sustaining which will provide a positive residual impact

Possible in-migration of job seekers into the area resulting in growth of existing informal settlements or the

formation of new ones as well as secondary impacts of in-migration including pressure on existing

infrastructure and an increase in crime and social ills

Difficult to manage; collaboration between the Mine and the Municipality is required

Settled job seekers may remain in the

area permanently therefore impacts on infrastructure, crime and social ills may persist post-closure

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13) OTHER INFORMATION REQUIRED BY THE COMPETENT AUTHORITY

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

(3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998).

the EIA report must include the:-

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

the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as an Appendix and confirm that the applicable mitigation is reflected herein)

A socio-economic study is currently underway to confirm and assess the impacts. Mitigation measures

for identified impacts will be included in the EMPr and refers to the relevant legislation. Possible

mitigation measures for the potential impacts identified during the high level impact assessment have

been included in Section 11)c)iii).

Directly affected persons include:

Landowner

The property to be impacted (i.e. RE of Portion 3 of Modderfontein 76IR) is owned by Mr Meyer. It is

anticipated that a suitable lease / purchase / compensation agreement will be drawn up between Mr

Meyer and Newshelf for the use of this land.

Adjacent Landowners and Occupiers (including State Mines Country Club, Manhattan

Corporation, Scoops, residents of Sherwood Gardens, Huntingdon and the State Mines /

Emagaleni Community)

Potential negative impacts on adjacent landowners and occupiers include:

Dust and fine particulates may be generated as a result of construction, operation and

decommissioning activities which may result in nuisance and health impacts (if standards are

exceeded).

Surrounding ambient noise levels may increase as a result of construction, operation and

decommissioning activities which may result in nuisance.

The proposed shafts may have negative visual impacts. Golf course users, employees at

surrounding businesses and vehicles travelling on surrounding roads will have temporary

partially obstructed views of the shaft areas.

In-migration of job seekers may result in the expansion of informal settlements in the

surrounding area or the establishment of new informal settlements. Secondary impacts may

include conflict between new and existing residents, increase in social pathologies such as

communicable diseases and crime, and increased pressure on already limited local

infrastructure and services.

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Surrounding Communities (including Brakpan North, Dersley, Eastvale, Skoonplaas,

Kingsway and Presidents Dam)

Potential negative impacts on surrounding communities include:

There will be additional increased heavy vehicle traffic along the transport route (portions of

Hospital Road, Main Road, Orpiment Avenue and Cloverfield Weg) as a result of hauling

activities during operations which may result in nuisance, decreased road safety and damage

to road surfaces.

In-migration of job seekers may result in the expansion of informal settlements in the

surrounding area or the establishment of new informal settlements. Secondary impacts may

include conflict between new and existing residents, increase in social pathologies such as

communicable diseases and crime, and increased pressure on already limited local

infrastructure and services.

Negative impacts on the visual landscape character may occur within a 1.5 km radius of the

shafts.

Potential positive impacts on surrounding communities include:

Construction activities will stimulate the local manufacturing and service sectors, providing

new business opportunities.

Potential employment for local skills offered from the region (i.e. mining and quarrying is a

major industry in the region).

Job creation and social investment in vulnerable communities through local economic

development initiatives.

Land Claimants

A land claim enquiry was submitted to the Office of the Regional Land Claims Commissioner: Gauteng

Province in April 2017 and no land claims appear on their database in respect of RE of Portion 3 of

Modderfontein 76IR.

ii) Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act (Provide the results of Investigation, assessment, and evaluation of the impact

of the mining, bulk sampling or alluvial diamond prospecting on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act, attach the investigation report as an Appendix and confirm that the applicable mitigation is reflected herein)

According to the archaeology study, dated April 2017 (attached as Appendix 8), no sites of

archaeological significance were identified within the footprint of the proposed surface infrastructure

and surrounds. According to the palaeontology study, dated April 2017 (attached as Appendix 13), no

sites of palaeontological significance are expected to occur within the footprint of the proposed surface

infrastructure and surrounds. Mitigation measures for chance finds have been included in Section

11)c)iii) and will also be included in the EMPr.

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b) Other matters required in terms of sections 24(4)(a) and (b) of the Act (the EAP managing the application must provide the competent

authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible

alternatives, as contemplated in sub-regulation 22(2)(h), exist. The EAP must attach such motivation as an Appendix)

Alternatives have been assessed for the project thus far (refer to Section 9). The initial layouts have been provided to IAPs for comment, and are currently

considered to be the most suitable for development (refer to Figure 3 and Figure 4 in Section 11)c)). The EIAR will address the following requirements in

terms of sections 24(4)(a) and (b) of the Act:

Section

of NEMA Contents

Description of how the aspect has been addressed thus far

and will be further addressed during the EIA

Section 24(4)(a)

24(4)(a)

Procedures for the investigation, assessment and communication of

the potential consequences or impacts of activities on the

environment –

must ensure, with respect to every application for an environmental

authorisation—

Refer to Section 12) for the plan of study for the EIA process.

24(4)(a)(i)

Coordination and cooperation between organs of state in the

consideration of assessments where an activity falls under the

jurisdiction of more than one organ of state;

The Scoping Report and EIAR will be made available to all the

relevant organs of state: the City of Ekurhuleni as the relevant

municipality; DAFF as the authority for agricultural land and

forestry; DWS for the activities requiring a WUL; GDARD as the

authority regarding environmental matters; PHRAG (via SAHRIS)

as the authority regarding cultural heritage matters; Gauteng

Department of Rural Development and Land Reform (DRDLR) as

the authority regarding land affairs; Gauteng Department of Roads

and Transport (Gautrans) as the road authority; Eskom as the

authority relating to electricity infrastructure; and Department of

Cooperative Governance and Traditional Affairs (COGTA) as the

authority regarding traditional affairs - for comment during public

participation processes. The DMR remains the Competent

Authority. Refer to Section 10).

24(4)(a)(ii)

That the findings and recommendations flowing from an

investigation, the general objectives of integrated environmental

management laid down in this Act and the principles of

environmental management set out in section 2 are taken into

account in any decision made by an organ of state in relation to any

The findings and recommendations of specialist investigations, and

general objectives and the principles of environmental

management, will be addressed in the EIAR and EMPr.

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Section

of NEMA Contents

Description of how the aspect has been addressed thus far

and will be further addressed during the EIA

proposed policy, programme, process, plan or project;

24(4)(a)(iii) That a description of the environment likely to be significantly

affected by the proposed activity is contained in such application;

Refer to Section 11)a) for a detailed description of the baseline

environment likely to be affected by the project.

24(4)(a)(iv)

Investigation of the potential consequences for or impacts on the

environment of the activity and assessment of the significance of

those potential consequences or impacts; and

Refer to Section 11)c) for an initial identification and assessment of

the potential impacts.

A detailed impact assessment will form part of the EIAR.

24(4)(a)(v)

Public information and participation procedures which provide all

interested and affected parties, including all organs of state in all

spheres of government that may have jurisdiction over any aspect of

the activity, with a reasonable opportunity to participate in those

information and participation procedures; and

Refer to Section 10) which details the Scoping Phase public

participation process followed. Further public participation will be

conducted during the EIA phase. Refer to Section 12).

24(4)(A)

Where environmental impact assessment has been identified as the

environmental instrument to be utilised in informing an application

for environmental authorisation, subsection (4)(b) is applicable

Environmental impact assessment has been identified as the

environmental instrument therefore (4)(b) is applicable.

Section 24(4)(b)

24(4)(b) Must include, with respect to every application for an environmental

authorisation and where applicable—

24(4)(b)(i)

Investigation of the potential consequences or impacts of the

alternatives to the activity on the environment and assessment of the

significance of those potential consequences or impacts, including the

option of not implementing the activity;

Alternatives have been investigated and assessed for the project

thus far, including the option of not implementing the activity.

Refer to Section 9). The final layouts will be assessed during the

EIA phase and, based on the outcome, recommendations will be

made in terms of layout alternatives or further technological and

design alternatives which may be required.

24(4)(b)(ii) Investigation of mitigation measures to keep adverse consequences

or impacts to a minimum;

Mitigation measures for potential impacts identified during the

initial assessment have been identified. Refer to Section 11)c)iii).

A detailed impact assessment will form part of the EIAR. Refer to

Section 12) for the plan of study for the EIA process. Mitigation

measures will also be recommended accordingly.

24(4)(b)(iii)

Investigation, assessment and evaluation of the impact of any

proposed listed or specified activity on any national estate referred to

in section 3(2) of the National Heritage Resources Act, 1999 (Act No.

25 of 1999), excluding the national estate contemplated in section

3(2)(i)(vi) and (vii) of that Act;

The NHRA has been taken into account, and a heritage assessment

has been undertaken. Refer to Section 5).

24(4)(b)(iv)

Reporting on gaps in knowledge, the adequacy of predictive methods

and underlying assumptions, and uncertainties encountered in

compiling the required information;

These have already been addressed to some extent in the specialist

studies conducted (refer to various appendices). These will be

further addressed and consolidated in the EIAR.

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Section

of NEMA Contents

Description of how the aspect has been addressed thus far

and will be further addressed during the EIA

24(4)(b)(v)

Investigation and formulation of arrangements for the monitoring

and management of consequences for or impacts on the

environment, and the assessment of the effectiveness of such

arrangements after their implementation;

Management and monitoring measures will be specified in the

EMPr. Implementation and suitability of the EMPr will be audited

every second year as required by Regulation 55 of the MPRDA as

well as per the frequency indicated in the Record of Decision (ROD)

as per Regulation 34 of the NEMA EIA Regulations, 2014.

24(4)(b)(vi)

Consideration of environmental attributes identified in the

compilation of information and maps contemplated in subsection (3);

and Refer to Section 11)a) for maps indicating geographical areas,

including the sensitivity, extent, interrelationship and significance

of such attributes informed by maps compiled by relevant

departments. 24(3)

The Minister, or an MEC with the concurrence of the Minister, may

compile information and maps that specify the attributes of the

environment in particular geographical areas, including the

sensitivity, extent, interrelationship and significance of such

attributes which must be taken into account by every competent

authority.

24(4)(b)(vii)

Provision for the adherence to requirements that are prescribed in a

specific environmental management Act relevant to the listed or

specified activity in question.

Listed activities for the Cons Modder Project have been identified.

Refer to Section 4)a). Environmental impact assessment has been

identified as the environmental instrument in terms of NEMA. An

AEL is not required as per NEMAQA. A WML is not required as per

NEMWA. Permits may be required as per NEMBA in the unlikely

event that species of conservation concern are identified. The area

does not fall within a protected area as per NEMPAA. A WUL is

required because of the location of 7# within 500 m from a

wetland; and for the containment of domestic wastewater, storage

of contaminated water, and establishment of infrastructure for the

management of stormwater at both shafts.

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