FINAL SCOPING REPORT - · PDF fileFOR LISTED ACTIVITIES ASSOCIATED WITH MINING RIGHT ... 6...

FINAL

SCOPING REPORT

FOR LISTED ACTIVITIES ASSOCIATED WITH MINING RIGHT

AND/OR BULK SAMPLING ACTIVITIES

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)

This document is the final version and incorporates comments from

Interested and Affected Parties on the draft document which was

available for review from 1st June to 1st July 2016.

NAME OF APPLICANT: Roelan Trading 173 (Pty) Ltd

TEL NO: +27 11 234 7976

FAX NO: +27 86 600 8224

POSTAL ADDRESS: Postnet Suite 211 Private Bag X51, Rivonia

PHYSICAL ADDRESS: 6 Rietfontein Road, Edenburg, Rivonia, 2128.

FILE REFERENCE NO. SAMRAD:

LP 30/5/1/2/2/12732 PR

REPORT NUMBER: ROE-MOOK_001-16

REPORT COMPILED BY: Greg Coates and Andrew Nicholson

Umhlaba Environmental Consulting CC

Tell: (011) 791 3389 P.O. Box 731504

Fax: (011) 791 3384 Fairland, 2030

E-mail: [email protected]

ACKNOWLEDGEMENTS: Umhlaba would like to acknowledge the following people who assisted in providing the information required for the compilation of the report:

Robert Russell

COPYRIGHT: Unless otherwise stated, the copyright in all text and other matter (including the manner of presentation) is the exclusive property of Umhlaba Environmental Consulting CC. It is a criminal offence to reproduce and / or use, any matter, technical procedure and / or technique contained in this document, without written consent, unless it is being reproduced for the purpose in which it was intended.

mailto:[email protected]

Roelan Trading 173 (Pty) Ltd Final Scoping Report July 2016 Page i

TABLE OF CONTENTS

1. IMPORTANT NOTICE 4

2. OBJECTIVE OF THE SCOPING PROCESS 4

SCOPING REPORT 1

3. CONTACT PERSON AND CORRESPONDENCE ADDRESS 1

a) Details of 1

(i) The EAP who prepared the report 1

(ii) Expertise of the EAP 1

(1) The qualifications of the EAP 1

(2) Summary of the EAP’s past experience 1

b) Location of the activity 1

c) Locality Map 2

d) Description of the Scope of the Proposed Overall Activity 4

(i) Listed and specified activities 4

(ii) Description of the activities to be undertaken 5

e) Policy and Legislative Context 8

f) Need and Desirability of the Proposed Activities 13

g) Period for which the environmental authorisation is required 13

h) Description of the process followed to reach the proposed preferred site 13

(i) Details of all alternatives considered 14

(ii) Details of the public participation process followed 14

(iii) Summary of issues raised by I&APs 16

(iv) The environmental attributes associated with the sites 19

(1) Baseline Environment 19

(v) Impacts identified 34

(vi) Method used to identify impacts 34

(vii) The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected 36

(viii) The possible mitigation measures that could be applied and the level of risk 37

(ix) The outcome of the site selection Matrix. Final Site Layout Plan 38

(x) Motivation where no alternative sites were considered 38

(xi) Statement motivating the preferred site. 38

i) Plan of study for Environmental Impacts Assessment process 38

(i) Description of alternatives to be considered including the option of not going ahead with the activity 38

(ii) Description of the aspects to be assessed as part of the environmental impact assessment process 38

(iii) Description of aspects to be assessed by specialists 38

(iv) Proposed methods of asessing the environmental aspects including the proposed method of assessing alternatives 39

(i) the proposed method of assessing duration signficance 39

(ii) the stages at which the competent authority will be consulted 44

(iii) Particulars of the public participation process with regard to the impact Assessment process that will be conducted 44

Roelan Trading 173 (Pty) Ltd Final Scoping Report July 2016 Page ii

(viii) Description of the tasks that will be undertaken during the environmental impact assessment process 47

(ix) 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. 47

j) Other Information Required by the Competent Authority 48

(i) Compliance with the provisions of sections 24(4)(a) and (b) read with section 24(3)(a) and (7) of the National Environmental Management Act (Act 107 of 1998), the EIA report must include the:- 48

(1) Impact on the socio-economic conditions of any directly affected person 48

(2) Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act 48

k) Other Matters Required in Terms of Section 24(4)(a) and (b) of the Act 48

l) UNDERTAKING REGARDING CORRECTNESS OF INFORMATION 49

m) UNDERTAKING REGARDING LEVEL OF AGREEMENT 49

APPENDICES FOR PART A ERROR! BOOKMARK NOT DEFINED.

1. APPENDIX A.1: EAP QUALIFICATIONS ERROR! BOOKMARK NOT DEFINED.

2. APPENDIX A.2: PREFERRED SITE LAYOUT PLANS ERROR! BOOKMARK NOT

DEFINED.

3. APPENDIX A.3: PUBLIC PARTICIPATION INFORMATION ERROR! BOOKMARK

NOT DEFINED.

4. APPENDIX 4: HISTORIC EXPLORATION ERROR! BOOKMARK NOT DEFINED.

LIST OF TABLES Table 1: Farm name, portion numbers and surveyor general code. ....................................................................2 Table 2: Summary of activities to be undertaken. ................................................................................................5 Table 3: Summary of key statistics for the Modimolle Local Municipality in Limpopo. ...................................... 25 Table 4: Identified Impacts (resulting from a screening level assessment) ....................................................... 35 Table 5: Impact assessment scoring. ............................................................................................................... 41 Table 6: Significance classification. .................................................................................................................. 42 Table 7: Summary of controls to reduce significance. ...................................................................................... 43

LIST OF FIGURES Figure 1: Map showing the location of the proposed prospecting right area within the Province of Limpopo. ....2 Figure 2: Google earth image of the proposed extent of the prospecting right area and location in relation to major towns and roads. ........................................................................................................................................3 Figure 3: Location of the proposed prospecting area in relation tot regional geology. ..................................... 20 Figure 4: Regional geology surrounding the proposed prospecting area. ........................................................ 20 Figure 5: Site specific geology for the proposed prospecting area. .................................................................. 21 Figure 6: Example of the mineralized vein outcropping on the surface. ........................................................... 22 Figure 7: Land-cover map indicating the current land uses within and surrounding the proposed prospecting right area. ........................................................................................................................................................... 31 Figure 8: Conservation plan showing the environmental sensitivity within and surrounding the proposed prospecting right area. ....................................................................................................................................... 32 Figure 9: Mining and Biodiversity Guidelines showing the sensitivity within and surrounding the proposed prospecting right area. ....................................................................................................................................... 33

Roelan Trading 173 (Pty) Ltd Final Scoping Report July 2016 Page iii

ABBREVIATIONS

BGIS Biodiversity Geographical Information

BID Background information document

DMR: Department of Minerals and Resources

DWS: Department of Water and Sanitation

EIA: Enviromental Impact Assessment

EMP Environmental Impact Assessment

I&AP Interested and Affected Party

LUDS Land Use Decision Support tool

NEMA National Environmental Management Act

PR: Prospecting Right

SANBI South African National Biodiversity Institute

SRP Surface Right Permit

Roelan Trading 173 (Pty) Ltd Final Scoping Report July 2016 Page iv

1. IMPORTANT NOTICE

In terms of the Mineral and Petroleum Resources Development Act (MPRDA), No. 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 (EIA) and an Environmental Management Programme (EMP) report in terms of the National Environmental Management Act (No. 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 Regulation 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 Reglation 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 a permit are submitted in the exact format of, and provide all the information required in terms of, this template.

Furthermore please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the Environmental 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 below, and ensure that the report is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.

2. OBJECTIVE OF THE SCOPING PROCESS

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 preffered location c) identify and confirm the preffered 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 apects 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 futher 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.

Roelan Trading 173 (Pty) Ltd Final Scoping Report July 2016 Page 1

SCOPING REPORT

This application is for a prospecting right (with bulk sampling). The overall objective of the prospecting programme is to identify whether there are economically exploitable concentrations of platinum bearing and other economic minerals within regional geological structures located on the properties as listed in Table 1 below. The area applied for has been listed in historical literature as known sites of platinum mineralization associated with faulting. The specific areas were historically explored for their platinum content on surface with varying degrees of success, although no workable surface deposits were ever exploited. Evidence of historic exploration is clearly evident as limited trenches and small adits. It is therefore evident that a degree of mineralization has been previously recognized in this area. The prospecting activities proposed will be in the form of both non-invasive and invasive methods including trench sampling, drilling of exploration boreholes and the excavation of bulk samples. These activities will be assisted by the use of aerial geophysical detection methodologies such as aeromagnetics and radiometrics. While the proposed prospecting right extends over an area of 3510 Ha, the physical impact of invasive prospecting is expected to be on less than 3 Ha.

3. CONTACT PERSON AND CORRESPONDENCE ADDRESS

a) DETAILS OF

(i) The EAP who prepared the report

Name of the Practitioner: Greg Coates

Tel No.: 011 791 3389

Fax No.: 011 791 3384

E-mail Address: [email protected]

(ii) Expertise of the EAP

(1) The qualifications of the EAP

MSc Zoology, BSc Agric Wildlife Science

See Appendix A1 for a CV of the EAP

(2) Summary of the EAP’s past experience

Three years of experience of environmental management for the mining industry of South Africa

See Appendix A1 for a CV of the EAP

b) LOCATION OF THE ACTIVITY

Farm Name: Various (See Table below)

Application Area (Ha); 3510 Ha

Magisterial District: Modimolle

Distance and Direction from Nearest Town:

30km north of Modimolle and 25km west of Mookgopong in the province of Limpopo. See Locality Map in Figure 1.

21 Digit Surveyor General Code for each Farm Portion:

See Table below.

mailto:[email protected]


Table 1: Farm name, portion numbers and surveyor general code.

c) LOCALITY MAP

Figure 1 below provides the location within the Province of Limpopo of the proposed prospecting right area . Figure 2 provides a google earth image of the proposed extent of the prospecting right area and location in relation to major towns and roads.

Figure 1: Map showing the location of the proposed prospecting right area within the Province of Limpopo.


Figure 2: Google earth image of the proposed extent of the prospecting right area and location in relation to major towns and roads.


d)DESCRIPTION OF THE SCOPE OF THE PROPOSED OVERALL ACTIVITY

(i) Listed and specified activities

NAME OF ACTIVITY

AERIAL EXTENT OF THE ACTIVITY

LISTED

ACTIVITY

APPLICABLE LISTING NOTICE

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

Ha or m² (Mark with an X where applicable or affected).

(GNR 983, GNR 984, GNR 985)

Prospecting Right Application in terms of Section 16 and Regulation 7(1) of the Mineral and Petroleum Resources Development Act.

3510 Ha X GNR 983: Activity 20

Non-invasive Preparation

Literature review and desktop studies

Surface Mapping

Airborne surveys and geophysical prospecting

Determining sampling locations

3510 Ha

Invasive prospecting

Clearing of indigenous vegetation for access roads, drilling and trenching/bulk sampling 3 Ha X GNR 983: Activity 27

o Establishing access roads wider than 4m (5km) 2 Ha

X GNR 985: Activity 4(a)11(ee)

o Drilling of exploration boreholes 0.64 Ha

o Excavation of surface trenches and bulk sampling pits 0.16 Ha

X GNR 984: Activity 19

Concurrent rehabilitation

Removal of alien vegetation

Loosening compacted ground, sloping pitwalls

Encouragement of indigenous vegetation

3 Ha

Supporting Services

Waste management

Sanitation

Emergency maintenance

0.16 Ha

Non-invasive Documentation

Prefeasibility study

Bankable feasibility study

Preparation for Mining Authorisation

3510 Ha


(ii) Description of the activities to be undertaken

The intent is to identify whether there are economically exploitable concentrations of of platinum bearing and other economic minerals within regional geological structures located on the application area.

Prospecting activities are expected to take place in the form of both non-invasive and invasive methods. A summary of the proposed activities is given in Table 2 below and expanded upon in the text thereafter.

Table 2: Summary of activities to be undertaken.

PHASE ACTIVITY TIMEFRAME OUTCOME DUE DATE FOR OUTCOME

1a

Non-invasive: Desktop study/literature search

Month 1-6

Analytical results of historic boreholes, old bulletins and Geological Reports

Month 6

1b

Non-invasive: Surface mapping, Airborne survey and exploration (aero-magnetic and radiometric)

Month 1-12 Detailed Surface Digital terrain models and regional anomaly maps

Month 12

2a Invasive: Surface trenching and sampling

Month 13-18 Surface Geological and Surface value Maps and Report

Month 18

2b Invasive: Exploration drilling, initial Resource determination

Month 13-24 Analytical results of new boreholes, Resource Estimation Report

Month 24

3

Invasive: Infill drilling to increase the classification of the mineral resources

Month 25-36 Analytical results of new boreholes, Scoping Report

Month 36

4a

Invasive: Excavation of Bulk Samples

Month 37 - 42

Representative Sample to conduct Metallurgical tests and initial financial analyses

Month 42

4b

Non-invasive: Detailed metallurgical test work for plant design/ 3

rd

party toll refining requirements

Month 43 - 48 Completion of Metallurgical Report

Month 48

5

Non-invasive: Completion of feasibility studies and applications for mining authorisation

Month 49-60 Definitive Feasibility Report

Month 60

Phase 1a: Desktop studies, beginning with data acquisition. As much information as possible, related to the local geology and historical mining on the property, will be sourced (this includes published results). In addition, results in the public domain pertaining to adjacent properties, will be sourced. All such data will be compiled and researched by competent experienced staff that will complete an interim report on the results.

Phase 1b: Should the data obtained in the previous phase indicate prospectivity over the property, a field visit will be undertaken to confirm any geological occurrence or evidence of previous mining as well as the state of any prior rehabilitation. Airborne surveys will be undertaken in the form of a fixed wing craft completing a flight pattern over the exploration area, in which a number of survey and geophysical readings will be taken. This data will be converted into various digital terrain models and anomaly maps, indicative of potential sub-surface mineralization, which will be used to guide further invasive prospecting in later phases.

Phase 2a: Using the data from the previous phases, the area will be mapped in detail and suitable locations for trenching identified. Trenching will be by way of shallow digging and exposing of the surface outcrop position of known mineralized fault positions and only where a degree of prospectivity is exhibited (0.5m deep trench across the vein at regular 20m intervals). Thereafter the vein rock will be sampled by means of


chip sampling techniques, and then the trench will be filled in and levelled to its pre-exploration state. Due to access constraints, this work is expected to be done by manual labour, and thus there will be no need to construct access roads to each trench site. From the combined results, a further report will be generated which will indicate and recommend future action.

See Appendix A.2 for a map showing the estimated location of the mineralised veins which will be the areas of interest when considering the positioning of trench sites. Please note that the final positioning of trenching activities will only be confirmed once the relevant landowner has been consulted and the necessary information gathered during previous phases of the prospecting work programme.

Phase 2b: An initial phase of hard rock drilling using conventional drilling rigs is planned for this phase on targets previously discovered by means of the airborne geophysical work and associated trenching. Such drilling will target the vein deposit at depth, giving information both about its structure, geology and extent of mineralization at depth. Once the initial assay results from the drill samples have been received, geological modelling will be utilised to determine if further drilling is required to determine a resource. For budget purposes, each potential anomaly as determined by surface values and geophysical anomalies will be subject to a minimum of 3 shallow (50m) and 1 deeper (100m) hole. The total minimum metres budgeted for this stage per target area will be 250 meters. If one assumes a 10% payability over the entire zone, this may provide at least 5 separate target anomalies Cores will be sampled at 30cm intervals through the mineralized zone, resulting in a minimum of 10 samples for a 3m wide intersection.

Phase 3: Planned infill drilling programme based on previous positive drilling results. This final drilling and sampling phase will provide the data which will be utilised to produce a code compliant resource. One can assume that a minimum of two target anomalies will result in planned infill drilling. In such a case, a factor of 5 has been applied for the increased drilling, resulting in an expected minimum 1 250m of drilling per target in this phase. Drilling will consider all identified sensitive areas. Standard precautions will be observed to prevent environmental degradation as per the EMP. Each drill site will be confined to an area of approximately 20m x 20m, comprising a drilling team operating a conventional drill rig and associated temporary structures. The area will be temporarily demarcated with danger tape or fencing as and when drilling is occurring. Minimal water is required for the drilling process, and as such will be sourced by the drilling contractor appointed to undertake the drilling.

Roelan has a strict drilling policy outlining site security, the protocols required to minimize any spillage on site during drilling that may adversely affect the environment, access and safety protocols, as well as a strict audit process once each site has been completed and rehabilitated.When drilling is undertaken, the following generic procedure will be followed:

The final drill position will be confirmed between a geologist and the landowner. The drill position will adhere to the restrictions contained within the EMP such as applying appropriate restrictions on location.

Photographs will be taken of the area prior to any physical impact.

An area of approximately 20 x 20m will be scraped and levelled and demarcated with a fence. The topsoil will be stored adjacent to the drill site

A single access road will be utilized to the borehole sites and rehabilitated after drilling is completed

Two sumps will be dug and lined

A temporary storage area will be demarcated within the drill pad location

Diamond drilling will be implemented

Core and rock samples will be sent to an approved laboratory for analysis

Once drilling is completed, all equipment will be removed. The plastic lining taken out of the sump and the sump refilled. The borehole will be capped at least 0.5 m below the ground and covered. The area will be covered with any soil removed. Photographs will be taken of the rehabilitated sites

Landowner acceptance of the rehabilitation will be obtained.

Core and rock samples from the boreholes will be taken to identify the properties for the minerals applied for. A Minimum total of 40 samples per target area will be budgeted for, for the initial drilling and 400 samples per target area for the infill drilling phases. Sampling expenses include assay costs, mineralogical costs and other physical tests to determine the grades and ore characteristics essential to identify the suitability of the


reserves for future mining. Sampling and analysis will be undertaken by an accredited professional laboratory (such as SGS Labs).

See Appendix A.2 for a map showing the estimated location of the mineralised veins which will be the areas of interest when considering the positioning of drill sites. Please note that the final positioning of drilling activities will only be confirmed once the relevant landowner has been consulted and the necessary information gathered during previous phases of the prospecting work programme.

Phase 4a: If a suitable economic target is uncovered by geophysical work and trenching, and confirmed by drilling, then it is anticipated that a bulk sample is necessary to unlock the complexities of the metallurgical processes associated with treating this type of ore. As the deposit outcrops on the surface and the proposed bulk sampling exercise is based on an area that has already been historically disturbed, it is envisaged that the bulk sampling exercise will be a simple load and haul exercise, taken from surface exposures. No blasting is envisaged to gain the bulk samples.

Equipment required will be 1 X excavator, 1 X loader and 2 X haul trucks.

Number of excavations is anticipated to be two (2) with dimensions of each excavation being approximately 40m (length) X 10m (breadth) X 1.5m (depth).

Bulk sampling excavations will be rehabilitated as per the EMP.

Phase 4b: Metallurgical test work of the bulk samples will be done off-site at a recognized testing facility. No on site metallurgical test work is envisaged.

See Appendix A.2 for an indication of the estimated location of the mineralised veins which form the areas of interest for bulk sampling. Please note that the final positioning of bulk sampling activities will only be confirmed once the relevant landowner has been consulted and the necessary information gathered during previous phases of the prospecting work programme.

Phase 5: The data obtained in the previous phases, will be compiled and integrated, at each step, into a geological model utilising the most appropriate software. This will include, but is not limited to, DataMine and a suitable GIS programme. At the conclusion of each phase, the data and geological model will be interrogated and a decision will be taken as to what further action is required, the objective being a code-compliant resource. At this point, a decision will be taken whether to embark on a pre-feasibility study or not.

All of the information obtained through the prospecting activities will be evaluated by a geologist to obtain a geological resource. Economically viable resources will then be subjected to a pre-feasibility study followed by a definitive feasibility study.

The feasibility study will contain the following information:

Mine design based on actual exploration results

Three principal alternatives examined

Preliminary siting, geotechnical and environmental studies complete

Bench scale metallurgical tests

Equipment factor cost estimate, written quotations

Contingency level 15-25%

Best alternative selected

Basis for final feasibility developed.

The bankable feasibility document will aim to indicate the feasibility of a future mine in the area. Should future mining be economically viable, an application for a mining authorisation will be compiled and submitted to the DMR.


e) POLICY AND LEGISLATIVE CONTEXT

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE

THE REPORT REFERENCE WHERE

APPLIED

Legislation

Constitution of the Republic of South Africa, 1996

Everyone has the right: a. to an environment that is not harmful to their health or well-being; and b. to have the environment protected, for the benefit of present and future

generations, through reasonable legislative and other measures that i. prevent pollution and ecological degradation; ii. promote conservation; and iii. secure ecologically sustainable development and use of

natural resources while promoting justifiable economic and social

This basic environmental right contained in the bill of rights is preserved throughout the environmental legislation. The particulars regarding the impact assessment process is described in Section (h)(v) – (viii) and Section (i)(i) – (v) of this report. To give effect to Section 24 of the Constitution, an application for environmental authorisation is being made in terms of reasonable legislative and other measures.

Minerals and Petroleum Development Resources Act, Act 28 of 2002 (MPRDA) and the MPRDA Amendment Act, Act 49 of 2008. The MPRDA makes provision for equitable access to and sustainable development of the nation’s mineral and petroleum resources. The recent amendment MPRDA resulted in changes to align specific environmental legislation associated with mining activities and aligned sections of NEMA and MPRDA to provide for one environmental management system.

The application is undertaken in line with Section 16 of the MPRDA

The DMR is the competent authority overseeing the environmental authorisation process.

This application is for a prospecting right with bulk sampling.

National Environmental Management Act, Act 107 of 1998 (as amended)(NEMA)

The principles set out in Section 2 of NEMA guide the environmental requirements of the application.

2. Principles.—(1) The principles set out in this section apply throughout the Republic to the actions of all organs of state that may significantly affect the environment and—

a. shall apply alongside all other appropriate and relevant considerations, including the State´s responsibility to respect, protect, promote and fulfil the social and economic rights in Chapter 2 of the Constitution and in particular the basic needs of categories of persons disadvantaged by unfair discrimination;

b. serve as the general framework within which environmental management and implementation plans must be formulated;

c. serve as guidelines by reference to which any organ of state must exercise any function when taking any decision in terms of this Act or any statutory provision concerning the protection of the environment;

d. serve as principles by reference to which a conciliator appointed under this Act must make recommendations; and

e. guide the interpretation, administration and implementation of this Act, and any other law concerned with the protection or management of the environment.

(2) Environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably.

(3) Development must be socially, environmentally and economically sustainable.

The principles of NEMA have been considered through out the report




APPLIED

(4) (a) Sustainable development requires the consideration of all relevant factors including the following:

i. That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied;

ii. that pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied;

iii. that the disturbance of landscapes and sites that constitute the nation´s cultural heritage is avoided, or where it cannot be altogether avoided, is minimised and remedied;

iv. that waste is avoided, or where it cannot be altogether avoided, minimised and reused or recycled where possible and otherwise disposed of in a responsible manner;

v. that the use and exploitation of nonrenewable natural resources is responsible and equitable, and takes into account the consequences of the depletion of the resource;

vi. that the development, use and exploitation of renewable resources and the ecosystems of which they are part do not exceed the level beyond which their integrity is jeopardised;

vii. that a risk averse and cautious approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions; and

viii. that negative impacts on the environment and on people´s environmental rights be anticipated and prevented, and where they cannot be altogether prevented, are minimised and remedied.

(b) Environmental management must be integrated, acknowledging that all elements of the environment are linked and interrelated, and it must take into account the effects of decisions on all aspects of the environment and all people in the environment by pursuing the selection of the best practicable environmental option.

(c) Environmental justice must be pursued so that adverse environmental impacts shall not be distributed in such a manner as to unfairly discriminate against any person, particularly vulnerable and disadvantaged persons.

(d) Equitable access to environmental resources, benefits and services to meet basic human needs and ensure human wellbeing must be pursued and special measures may be taken to ensure access thereto by categories of persons disadvantaged by unfair discrimination.

(e) Responsibility for the environmental health and safety consequences of a policy, programme, project, product, process, service or activity exists throughout its life cycle.

( f ) The participation of all interested and affected parties in environmental governance must be promoted, and all people must have the opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured.

(g) Decisions must take into account the interests, needs and values of all interested and affected parties, and this includes recognising all forms of knowledge, including traditional and ordinary knowledge.

(h) Community wellbeing and empowerment must be promoted through environmental education, the raising of environmental awareness, the sharing of knowledge and experience and other appropriate means.

(i) The social, economic and environmental impacts of activities, including disadvantages and benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment.




APPLIED

( j) The right of workers to refuse work that is harmful to human health or the environment and to be informed of dangers must be respected and protected.

(k) Decisions must be taken in an open and transparent manner, and access to information must be provided in accordance with the law.

(l) There must be intergovernmental coordination and harmonisation of policies, legislation and actions relating to the environment.

(m) Actual or potential conflicts of interest between organs of state should be resolved through conflict resolution procedures.

(n) Global and international responsibilities relating to the environment must be discharged in the national interest.

(o) The environment is held in public trust for the people, the beneficial use of environmental resources must serve the public interest and the environment must be protected as the people´s common heritage.

(p) The costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment.

(q) The vital role of women and youth in environmental management and development must be recognised and their full participation therein must be promoted.

(r) Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands, and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

Section 28 of NEMA imposes a duty on any person who causes, has caused or may cause significant pollution or degradation to take reasonable measures to prevent, minimise and rectify significant pollution and environmental degradation. Non-compliance with the duty of care allows a competent authority to require that specified measures be taken (and if not taken, the competent authority may take those steps itself and recover the costs from various parties). Liability is retrospective.

EIA Regulations 2014, 982-985 in terms of NEMA.

Environmental Impact Assessment Regulations, GN R 982 of 4 December 2014, Regulation 21 – 26 and Regulation 39 to 44.

These regulations set out the process required to undertake the scoping and EIA process including the public participation process that must be undertaken as part of the EIA.

A scoping and EIA process is being followed in terms of the EIA Regulations (2014)

This report forms part of the scoping phase of the EIA being undertaken.

National Water Act, Act 36 of 1998 (NWA): The NWA provides for fundamental reform of the law relating to water resources, where the ultimate aim of water resource management is to achieve the sustainable use of water for the benefit of all users. Specific water use of concern includes disposing of waste in a manner which may detrimentally impact on a water resource.

The purpose of this Act is to ensure that the nation's water resources are

protected, used, developed, conserved, managed and controlled in ways

which take into account -

(i) meeting the basic human needs of present and future generations;

(ii) promoting equitable access to water;

(iii) redressing the results of past racial and gender discrimination;

(iv) promoting the efficient, sustainable and beneficial use of water in

the public interest;

No water use license will be required for the activities covered under this application. The principles of the NWA will be applied to all physicial activities implemented as part of ongoing drilling.




APPLIED

(v) facilitating social and economic development;

(vi) providing for growing demand for water use;

(vii) protecting aquatic and associated ecosystems and their biological

diversity;

(viii) reducing and preventing pollution and degradation of water

resources;

(ix) meeting international obligations;

(x) promoting dam safety;

(xi) managing floods and droughts, and

(xii) for achieving this purpose, to establish suitable institutions and to

ensure that they have appropriate community, racial and gender

representation.

Chapter 4 of the NWA requires the licensing of a variety of activities concerning water uses which is captured in Section 21 and includes;

(a) taking water from a water resource;

(b) storing water;

(c) impeding or diverting the flow of water in a watercourse;

(d) engaging in a stream flow reduction activity contemplated in section 36;

(e) engaging in a controlled activity identified as such in section 37(1) or

declared under section 38(1);

(f) discharging waste or water containing waste into a water resource

through a pipe, canal, sewer, sea outfall or other conduit;

(g) disposing of waste in a manner which may detrimentally impact on a

water resource;

(h) disposing in any manner of water which contains waste from, or which

has been heated in, any industrial or power generation process;

(i) altering the bed, banks, course or characteristics of a watercourse;

(j) removing, discharging or disposing of water found underground if it is

necessary for the efficient continuation of an activity or for the safety of

people; and

(k) using water for recreational purposes.

Regulation 704 (GN704) (Government Gazette 20118, 4 June 1999) was drawn up to address these issues in relation to mining activities. Compliance to the requirements of GN704 is a legal requirement for all mining operations.

The requirements of GN 704 have been considered on all water requirements. No drilling activities will take place within 100m of a recongised water course or wetland

No new access tracks will be created which cross a water course. (existing roads / tracks will be used where possible).

National Environmental Management: Waste Act, Act 59 of 2008 (NEM:WA) The Act was established to regulate waste management for the protection of human health and the environment by providing reasonable measures for:

Minimising the consumption of natural resources

Avoiding and minimising the generation of waste

Reducing, reusing, recycling and recovering waste

Treating and safely disposing of waste as a last resort

Prevention pollution and ecological degradation

Securing ecologically sustainable development while promoting justifiable economic and social development;

The principles of the NWA will be applied to all aspects of the activities covered by this application. No waste license is required.




APPLIED

Promoting and ensuring the effective delivery of waste services;

Remediating land where contamination presents, or may present, a significant risk of harm to health or the environment.

Achieving integrated waste management reporting and planning No person may commence with, undertake or conduct a waste management activity, except in accordance with a waste management licence. The DMR is the applicable licencing authority for waste management activities associated with mining activities.

National Environmental Management: Air Quality Act, Act 39 of 2004 (NEM:AQA) NEM:AQA 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 licensing is required in terms of Chapter 5 of the Act. This notice further establishes minimum emission standards for the listed activities.

The principles of the NEM:AQA will be applied to the future activities covered by this application.

National Heritage Resources Act, 25 of 1999 (“NHRA”) 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): 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 resources authority.

All activities covered by this application will avoid any identified heritage resource.

The National Environmental Management: Biodiversity Act, 2004 (NEM:BA) NEM:BA is to provide for the management and conservation of South Africa’s biodiversity within the framework of the NEMA. This includes: the protection of species and ecosystems; the sustainable use of indigenous biological resources; the fair and equitable sharing of benefits arising from bioprospecting involving indigenous biological resources; and the establishment of a South African National Biodiversity Institute (SANBI). 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

BGIS LUDS has been consulted when determining the baseline environmental conditions for the areas impacted by proposed suface activities.




APPLIED

South African Vegetation Map, national forest types and priority areas identified in a national systematic biodiversity plan.

Guidelines

BGIS (www.bgis.sanbi.org)

Used to determine sensitive environmental features of the areas where surface impacts will take place.

Considered when completing the baseline environmental conditions.

Limpopo Integrated Development Plan Considered when completing the socio economic baseline environmental conditions.

SANS 10103:2008 The Measurement and Rating of Environmental Noise with Respect to Land Use, Health, Annoyance and to Speech Communication

Considered when proposing appropriate mitigation targets.

SANS 1929:2005 Edition 1.1 – Ambient Air Quality Limits for Common Pollutants; SANS 1929:2005: Ambient Air Quality – Limits for common pollutants; SANS 1929:2011: Ambient Air Quality – Limits for common pollutants and SANS D113:2012: Standard Test Method for Collection and Measurement of Dust fall (Settleable Particulate Matter).

Considered when proposing appropriate mitigation targets.

f) NEED AND DESIRABILITY OF THE PROPOSED ACTIVITIES

Propsecting activities are needed to: A) Confirm the historical information and obtain additional information concerning the resource through

additional invasive prospecting methods. B) Confirm if the resource can be extracted through future mining in an environmentally, socially and

economically viable manner.

Should prospecting activities prove that there are feasible minerals to allow for mining, a new mine may be developed which would have the potential to contribute to the national economy and generate employment opportunities in an area where employment is desperately required.

g) PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED

The environmental authorisation will be required for the duration of the prospecting right which is for 5 years

with the option to renew the authorisation thereafter.

h) DESCRIPTION OF THE PROCESS FOLLOWED TO REACH THE PROPOSED PREFERRED SITE

The non invasive activities will apply to the entire prospecting right area covered by the application. The preferred locations for invasive prospecting by way of trenching, drilling and bulk sampling will be identified during the non-invasive phase 1 of the prospecting programme.

Preferred sites: The area applied for has been listed in historical literature as known sites of platinum mineralization associated with faulting. The specific areas were historically explored for their platinum content on the surface with varying degrees of success, although no workable surface deposits were ever exploited. Evidence of historic exploration is clearly evident as visible trenches and small adits. It is therefore evident that a degree of mineralization has already been previously recognized to exist in this area. The preferred locations for invasive prospecting by way of trenching, drilling and bulk sampling will be identified during the non-invasive phase 1 of the prospecting programme.

Preferred Activities: The preferred / only manner of identifying a possibly viable resource is to obtain samples. Invasive methods are required to obtain these samples where trenching, drilling and bulk sampling are recognised methods of prospecting for the particular minerals applied for.


Technology Alternatives: There are no technological alternatives to the proposed prospecting activities. Trenching, drilling and bulk sampling are the recognised methods of prospecting for the particular minerals applied for.

(i) Details of all alternatives considered

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

Until such time that the information gathering of Phase 1 of the prospecting programme has been completed the exact location of the invasive sites cannot be confirmed. No prospecting activities will take place without having consulted the landowner first.

(b) The type of activity to be undertaken

There is no alternative to the prospecitng activities proposed. Trenching, drilling and bulk sampling are the recognised methods of prospecting for the particular minerals applied for.

(c) The design or layout of the activity

Final site selection will consider the following buffers;

No trenching/drilling/bulk sampling site will be positioned within 50m of a structure

No trenching/drilling/bulk sampling site will be positioned within 50m of a heritage site

No trenching/drilling/bulk sampling site will be positioned within 100m of a water course or wetland

Where possible existing access roads will be utilised to access the trenching/drilling/bulk sampling sites

(d) The technology to be used in the activity

No alternative technology has been considered for the prospecting activities.

(e) The operational aspects of the activity

There is no alternative to the operational aspects proposed. Trenching, drilling and bulk sampling are the recognised methods of prospecting for the particular minerals applied for.

(f) The option of not implementing the activity

Prospecting, including invasive methods of sampling in this case, is required in order to generate a SAMREC compliance mineral resource. There is no potential for any future investment in a mine without the confirmation of the mineral resources which can only be obtained from prospecting / exploration activities.

Should the prospecting right be refused, effectively a potential platinum (and other precious metals) resource will be sterilised.

(ii) Details of the public participation process followed

This section describes the process implemented to consult with interested and affected parties. Details of the documentation provided and evidence of implementation of the consultation process is presented in Appendix A3.

Identified interested and affected parties were notified and consulted through the following means:

Hand delivery of background information documents (BID):

Background information documents were hand delivered to the premises of direct and adjacent landowners on 30

th May 2016.

Newspaper advertisement:

An advert was placed in the local newspaper (Die Pos) on 27th May 2016


Site notices: Site notices were erected at the following locations:

At the municipal offices of Modimolle

At the municipal offices of Mookgopong

At latitude -24.5821 and longitude 28.3282 (along the R33)

At latitude -24.5078 and longitude 28.5054 (along the D2665)

Emails

Emails (including a background information document) were sent to all identified interested and affected parties where email addresses were available.

Registered letters

Registered letters including the background information document were sent to all relevant organs of state.

Telephonic conversations

Where necessary, telephonic conversations were held prior to sending out information.

Public meeting:

A public meeting was held at the Weesgerus Holiday Resort on 14th June 2016.

Distribution and review of the Draft Scoping Report:

All interested and affected parties who received notification as per the above were informed of the availability of a draft Scoping Report for review and comment by means of:

Hard copies at the offices of Umhlaba Environmental Consulting

Electronic copies on the Umhlaba website (www.umhlaba.co.za)

Electronic copies by email on request

A 30 day commenting period for the Draft Scoping Report was run from 1st

June 2016 to 1st

July 2016.

The list of the I&AP’s identified and a record of notification and responses is given in Appendix A3.


(iii) Summary of issues raised by I&APs

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

INTERESTED AND AFFECTED PARTIES

DATE ISSUES RAISED EAPS RESPONSE TO ISSUES AS MANDATED

BY THE APPLICANT

SECTION AND PARAGRAPH

REFERENCE IN THIS REPORT WHERE THE

ISSUES AND OR RESPONSE WERE INCORPORATED

List the names of persons consulted in this column, and

Those who must be consulted were in fact consulted, marked as RM=Registered mail, E=Email, M=Meeting TC= Telephonic call PM= Public Meeting

AFFECTED PARTIES

Direct Landowners / Occupiers

Republic of South Africa RM+E No comments received

Steilpoort Boerdery (Pty) Ltd RM No comments received

Elbie Isabel van Staden RM+E 29-Jun-16 Mr van Staden wants to be kept informed at all times of the progress of the application and stipulates that no persons are allowed on his property without prior consent. He is concerned about prospecting camps being established as there is no water or facilities available. He is also concerned about security issues and the potential for crime to be attracted to the area.

Explained that no prospecting teams would enter a property without prior consent. Prospecting camps might be required for drilling and bulk sampling however wrokers would not reside on the property. Security measures would be put in place to secure equipment and resources at the camps. Water would be brought to site and a chemical toilet used.

Section 3(h)(vii)

Gerhardus Schoeman Lombard RM+E+TC No comments received According to Mr Lombard there is no way to stop the process and he is not interested to provide his comments as he believes the prospecting activities will just commence

Explained the application process and role of an I&AP. Suggested he register and participate in the process.

Section 3(I)(iii)(2)

BA-Radpidelo Farmers (Pty) Ltd

RM+TC 30-May-16 Mr Mahupja is not interested in selling his property and did not afford the opportunity to explain the process. He will only respond to a letter directly from the Minister

Explained the application process and role of an I&AP. Suggested he register and participate in the process.

Section 3(I)(iii)(2)

Jacob Stephanus De Beer RM+E+TC No comments received Mr De Beer resides in Pretoria and could not attend the 1st meeting. He requested a visit to his farm on a Sunday to be consulted

Explained that a one on one meeting was possible during the working week in PTA or there will be another opportunity to attend a public meeting during the EIA phase.

Stoniy River Poperty 91 CC/ Bullion Hunting Enterprises

RM+E+TC No comments received

Flamingo Moon Trading 77 (Pty) Ltd

RM+TC No comments received

C W van Emmenes (Pty) Ltd RM No comments received

Unetsie Boerdery (Pty) Ltd RM No comments received

Jan Hendrik Engelbrecht RM No comments received

Hermanus Carel du Preez RM No comments received

Hendrina Maria du Preez RM No comments received

Jacobus Johannes van Tonder RM+E+TC No comments received

Johannes Jacobus Dippenaar RM No comments received

Petrus Johannes Horn RM No comments received

Twin Cities Trading 131 (Pty) Ltd /Waterberg Wellnes Lodge (Pty) Ltd

RM No comments received


Villa He Trust RM+TC+E 24-Jun-16 Mr Cornelius represented a number of landowners and stated that previous mining made a mess of the area near Mookgopong. Frikkie Geyser dam has high concentrates of heavy metals which is not suitable for human consumption. The municipality had to on their own cost construct a high cost pipe line and they should also object to the application. Water is currently being bottled on Kromkloof and is of high quality. Mining can influence the nature and tranquility of the area, such as air quality, animal life, etc. Worker jobs will be in jeopordy if mining takes place.

Explained the current application is for prospecting only and therefore the potential impact on water quality is unlikely. Prospecting activities are far less invasive and the invasive activities proposed will be short compared with mining. Mitigation measures are available to either control, mitigate, avoid or prevent certain impacts. The prospecting activities will not require additional employment or displacement of current workers. .

Section 3(h)(viii)

Davis Abraham du Toit RM+TC+E 24-Jun-16

Unicorn Security Services (Pty) Ltd

RM+TC+E 24-Jun-16

Mita Susanna Magdelena Cornelius

RM+TC+E 24-Jun-16

Frederick Cornelius RM+TC+E 24-Jun-16

Adjacent Landowners / Occupiers

Duikel Belleggings (Pty) Ltd RM No comments received

Hebrecht Magrietha du Toit RM+TC+M 14-Jun-16

Frederick Jacobus Pienaar RM+TC+M No comments received During the meeting Mr Piennar said he has no objection to the proposed activities

Ester Aletta Jacomina van Staden


Christian Roedolf Klingenberg 30th June 2016 Concerns over lack of notification. Raised issues of pollution, noise and security. Stated that landowners should be adequately compensated for negaive impacts. Requested to be registered as an I&AP and to be sent the minutes of the public meeting.

Explained that where landowners did not reside on the property to receive the hand delivered notice, registered letters were sent. Inidicated that other means of notification such as newspaper notice and site notices had also been used. Inidicated that consultation initiated in scoping phase and carried throught o EIA phase which will include another public meeting. Registered Mr Klingenberg as an I&AP and sent minutes.

Section 3(h)(viii)

Susara Aletta Petronella de Beer

RM+M+E No comments received

Paul Jacobus Venter RM No comments received

Anna Maria Magreta Swart Venter


Louis Stephanus Maritz No comments received

Municipal Ward councillor

Modimolle LM Ward RM+E No comments received

Modimolle Local Municipality RM+E No comments received

Organs of State

(Responsible for infrastructure that may be affected Eg. Roads Department, Eskom, Telkom, DWA)

Eskom RM+E 01-Jun-16 Interest in the project regarding Eskoms distribution network on the affected properties, and future power supply projects for the area.

Registered Eskom as an I&AP as requested.

Telkom SA SOC Ltd RM 29-Jun-16 Request for time extention to provide comments Expained that comments can still be provided during the second round of consutlation (EIA phase)

S A National Roads Agency Ltd RM No comments received

Communities

None


Dept. of Land Affairs

Land Claims Commissioner RM+E 03-Jun-16 Letter confirming no current cases of land claims over the concerned properties.

Traditional Leaders

None

Dept. of Environmental Affairs

Department: Economic Development, Environment and Tourism

RM 28-Jun-16 Aknowledged notification of the application and their intent to comment upon receiving the application from internal processes.

Limpopo Department of Agriculture


Other Competent Authorities Affected

Department of Mineral Resources (DMR): Mine Health and Safety


Department of Water & Sanitation (DWS)


Roads Agency Limpopo (RAL) RM No comments received

South African Heritage Resource Agency


OTHER INTERESTED PARTIES

H J Pretorius Snr & Jnr M 14-Jun-16 Concerned about safety of annimals and people living on the property, provide security at camp sites as equipment and diesel may be stolen

No emplyees will reside within the prospeting camps unless otherwise agreed upon

Section 3(h)(viii)

Johann Ungerer E 29-Jun-16 Objection to application. No specifiic environmental concerns were provided

Noted the objection and ensured the I&AP that it would be included in the scoping report. Requested that further comments from I&APs include more detail on their objections explaining why they object i.e. how will the proposed activities affect them, or their concerns about specific aspects of the natural environment within and surrounding the application area. This ensures that all potential impacts associated with the proposed activities are evaluated.

Dinaka Game Reserve E 23-Jun-16 Objection to application. Stated that they enjoy the natural environment as it is however no specifiic environmental concerns were provided

Zwartkloof Exclusive Wildlife producer

E 24-Jun-16 Objection to application. No specifiic environmental concerns were provided

Acasia Wild (Pty) Ltd E 30-Jun-16 Objection to application. No specifiic environmental concerns were provided


(iv) The environmental attributes associated with the sites

(1) Baseline Environment

(a) Type of environment affected by the proposed activity

General overview The climate of the region is temperate with moderate summer rainfall with the highest concentration during January and February in the form of thunderstorms, allowing year round exploration activities. Typical vegetation is African savannah grassland with acacia and other African hardwood species. The landscape in the immediate area of the project comprises low hills and sweeping valleys. The project area is elevated some 1 300m above mean see level. Immediately to the north of the properties, the Swaershoek Mountains rise up to approximately 1890m above mean sea level. The regional centre of Mookgopong is a small-sized town with good infrastructure and medical facilities, serving an extensive agricultural community. Ground transport is along well maintained gravel roads and the regional electricity grid runs sub-parallel to these gravel roads. There are landline telephone connections and cellular signal does cover the area, but signal strength varies. The information below provides a more detailed description of the receiving environment of the general area within which the proposed prospecting right is situated. Locality - See Figure 1 for an indication of the location of the proposed prospecting area. Geology Regional Geology In the Mookghopong area, remnants of the Karoo sediments cover older sedimentary rocks of the Waterberg Group and the Lebowa Granite Suite. The Lebowa Granites represent the upper unit of the Bushveld Igneous Complex, at which base the world renowned Merensky and UG2 platinum bearing reefs are mined extensively and which is considered to be the source of the platinum mineralization of the proposed prospecting area. The area is structurally complex and a prominent east-west fault zone that includes the Welgevonden fault, which, together with the Zebedelia and the Ysterberg-Planknek Faults forms a major component of the regional Thabazimbi-Murchison Lineament that is the southern boundary of the northern limb of the Bushveld Complex (see Figure 3 and Figure 4). Platinum concentrations have historically been reported in a suite of veins on every farm within the proposed prospecting area, and on adjoining farms. Local Geology From early mapping done by Goldfields in the 1970;s the area is covered by fine-grained red to cream coloured sandstone of the Clarens Formation, part of the Karoo Sequence and is of Triassic age. The young sediments lie unconformable on coarse grained grey to pink granite, red in places, representing the lower unit of the Lebowa Granite Suite, and porphyritic spherulitic and amygaloidal rhyolite, both part of the Bushveld Complex, also present is older unclassified rhyolite and subordinate andesite, tuff, volcanic breccias and in places, ignimbrite at the top. The deposit, located some 20km northwest of Mookgopong in the Limpopo Province of south Africa, is perhaps the most striking example of a vein hosted and PGE-dominant (Pt+Pd>Au) hydrothermal deposit known to date. The deposit is a quartz vein system that dips southeast at 70°-85° and occupies a fault between folded igneous and horizontally bedded sandstones. In hand samples, it is common to find brecciated centimeter-sized fragments of relict felsites (quartz, oligoclase, orthoclase) and sandstone which are extensively replaced by muscovite or fine-grained specularite and veined by quartz or chalcedony. Platinum is generally confined to areas with widespread hematite replacement and development of specularite veins. Younger veins of coarse, barren quartz with occasional development of specularite cut the earlier veinwork. Quartz frequently shows crustiform or colloform banding and late generations show delicate medium to fine grained vuggy textures, with evidence of open space filling. In hand specimens, using a hand lens, platinum is associated with monazite on a microscopic scale. See Figure 5 for an indication of the site specific geology for the proposed prospecting area.


Figure 3: Location of the proposed prospecting area in relation tot regional geology.

Figure 4: Regional geology surrounding the proposed prospecting area.


Figure 5: Site specific geology for the proposed prospecting area.


Mineralization The mineralogy of the veins is remarkably simple with the most veins composed of brecciated blocks or slivers of felsites and sandstone, surrounded and veined by quarts and chalcedony. McDonald (1995) reports at least six different generations of quartz within the suite of samples studied. The development of platinum and specular hematite (specularite) appears to be confined to early phases of intensive brecciation and veining, whereas in the latest observable stages, large rafts of previously brecciated and cemented felsites were cut by mainly thick veins of coarse barren quartz. The green phase of “chromiferous chlrorite” by Wagner 1929, is actually a mixture of muscovite, roscelite, lopezite and chromatite. The CR bearing minerals are dispersed throughout the rock and may account for the greenish colour. Coarse specularite is most commonly present as thin elongate stringers and cuspate masses on the margins of earlier quartz crystals which precipitated around fragments of felsites and sandstone, but larger rounded vugs of hematite are also present. In both the stringers and vugs, the acicular specularite grew as interlocking fans of needles anchored on the edges of country fragments or on individual quartz, monazite, sphene or platinum crystals. The length of individual specularite stringers varies from a few mm to up to 8cm. McDonald also reports rare crystals of monazites, sphene, rutile and highly altered pyrite. As outlined by Wager (1929), the platinum mineralogy in the quartz veins is dominated by native platinum (defined here as an alloy containing >90% Pt) and Pt-Pd alloys. The native platinum is most commonly found as rounded masses of metal. The most angular or crystalline masses are homogenous platinum, with thin rims of zoned platinum and Pt-Pd alloy, whereas the more reniform masses are complex mixtures of the Pt_Pd alloy. Analyses have shown that apart from Pd and Au, all other noble metals are below the limit of detection. The lack of Fe or Ni in the platinum is notable compared to other localities, and it would appear that the veins contain some of the purest natural platinum ever studied. Wagner (1929) noted that the precipitation and growth of platinum crystals occurred over several generations and in various sections of the vein. Observed textures suggest that the precipitation of platinum took place over a period of time in a variety of associations, and was not controlled by a single vent such as the crystallization of specularite. Genesis of the deposit appears most likely to be that of a hydrothermal deposit, where the metals were introduced via a fluid phase and that the metal distribution reflects the nature and evolution of that fluid (Wagner 1929, and Mc Donald 2005). Figure 6 gives an example of a typical outcropping of the mineralized vein on the surface.

Figure 6: Example of the mineralized vein outcropping on the surface.


Soils There are limited sols with arable potential in the area, because of the rugged nature of the area and the shallow rock, and these are confined to the lower slopes of the ridges and valley floors. A number of old termite mounds (termitaria) occur on the lower slopes of the hills below the outcropping mineralized vein. These are occurrences of fertile deep soils and have resulted in the establishment of dense copses of trees. Within some of the local streams draining the undulating area, the alluvial gravel has become extremely ferrugenized and occurs as a ‘hardpan’ ferricrete. McDonald et al, 1999, indicated that in terms of the chemistry, the mineralizing fluid had a low salinity and reacted extensively with K-feldspar in the felsites wallrocks. The fluid was sufficiently oxidized to stabilize Fe

3+ and precipitate it as haematite, and sufficiently Sulphur-poor to inhibit Sulphur formation and relegate

Sulphur to the role of as minor component of the Pt-Pd alloys. This is important to note as there is a very low potential for development of acid mine drainage. The hot springs further to the east are thought to represent the final stages of hydrothermal activity in the area. Climate The site falls within the northern Transvaal climatic zone as defined by Schulze (1974) where the rainfall varies between 380mm and 700mm, the annual average at Mokopane weather station is 583mm, with most of this rainfall occurring in the summer months of November to February. Rainfall is mostly in the form thunderstorms with hail occurring occasionally. Frost is rare and may occur during June or July. The average daily temperature as recorded at the Mokopane weather station is 29.7⁰C in summer and

21.0⁰C in winter, with extremes of 38.5⁰C and -1.3⁰C in summer and winter respectively. The prevailing wind direction in the area is generally from the south-south westerly or south-south easterly direction, with a southerly wind vector being the dominant wind prevailing approximately 21% of the time. Calm wind conditions occur on average 10.5% of the time and occur mostly at night. Vegetation According to Acocks (1988) the site falls into the Sour Bushveld Biome. It is open savannah of tall Faurea saligna trees in a tall, tufted, wiry, sour grassveld in the less rocky parts, becoming a dense mixed bushveld in the rugged parts. Tall trees and shrubs include: Faurea saligna, Acacia caffra, Protea caffra, Dombeya rotundofolia, Lannea discolor, Combretum molle, Combretum apiculatum, Euclea crispa, Burkea Africana, Ficus species, Rhus species, Ziziphus mucronata. Due to the disturbance of activities in the area such as farming there are various alien plants ansd ttrees that have established, the most notable being wattle and gum species. The photos below give an indication of randomly selected examples of the status of the natural vegetation within the proposed prospecting area as of the site visit conducted on the 29

th April 2016.


Animal Life Local knowledge and land uses of the area suggest that there is a considerable amount of small game that occurs naturally, such as duiker and steenbok, as well as various foxes, hares, tortoises and rodents. Some portions of the proposed area exists as professional game farms where commercial hunting is undertaken, and they have been stocked with a variety of large game including kudu, impala, zebra and ostrich. The presence of possible red data species is not currently known and will be investigated during the EIA phase of the application. Water There are numerous small ephemeral streams that rise in the area and flow north-eastwards to the Sterkrivier which eventually flows into the Doorndraai dam situated approximately 12km northeast of the project area. No potential wetlands have been identified although the existence of wetlands cannot be ruled out as no wetland specialist study has been conducted. Good supplies of groundwater in the area are rare, but the water quality is good. Water levels vary from 60m to 135m below the ground level, depending on the topography and proximity to faulting. Groundwater in the area is likely to occur in the fracture rock aquifer with larger strikes in the fracture zones associated with faulting.


Socio-economic structure The prospecting right application area is situated within the Modimolle Local Municipality (MLM). The information provided below provides a background into the socio-economic structure of MLM as per the census data available from 2011 on the Stats SA website

1. The closest towns are Modimolle and

Mookgopong and the information provided below is considered representative of this community.

MLM has a total population of 68 513 people. The majority of the population (88,1%) is black African, followed by whites at 10,8%. The other population groups make up the remaining 1,1%. Amongst those aged 20 years and older, 23,9 completed/have some primary education, 34,7 have secondary education, 22,0% have completed matric, 8,7% have some form of higher education. Of the 17 525 households, 50,2% have piped water in their yards. 35,7% of households have piped water in the dwelling, and 3,7% have no access to piped water. Of the 25 353 economically active (employed or unemployed and looking for work) people in the municipality, 22,2% are unemployed. 28,9% of the 11 094 economically active youth (15 – 34 years) in the area are unemployed. Agricultural commodities include grapes, sheep and cattle, game, nuts, vegetables, and grain. Table 3 and the various graphs thereafter present a further summary of the key statistics for the Modimolle Local Municipality.

Table 3: Summary of key statistics for the Modimolle Local Municipality in Limpopo.

Key Statistics 2011 2001

Total population 68 513 69 027

Young (0-14) 30.8% 32%

Working age (16-54) 63.8% 63.8%

Elderly (65+) 5.4% 5.6%

Dependency ratio 56.8 60.3%

Sex ratio 102.5 99.3

Growth rate (from previous census) -0.07% 7.81%

Population density 15 persons/km2 15 persons/km

2

Unemployment rate 22.2% 25.1%

Youth unemployment rate 28.9% 32.2%

No schooling age 20+ 10.6% 22.6%

Higher education age 20+ 8.7% 6.7%

Matric aged 20+ 22% 15.3%

Number of households 17 525 16 964

Number of agricultural households 2 792 ?

Average household size 3.6 3.4

Female headed households 39.5% 34.5%

Formal dwellings 87.5% 50.6%

Housing owned/paying off 54.9% 39%

Flush toilet 66.1% 37.6%

Weekly refuse removal 73.3% 39.7%

Piped water inside dwelling 35.7% 26.6%

Electricity for lighting 83.3% 543%

1 http://www.statssa.gov.za/?page_id=993&id=modimolle-municipality

http://www.statssa.gov.za/?page_id=993&id=modimolle-municipality





Sites of cultural heritage importance A number of farms contain private family grave sites, some graves being over 100 years old. A specialist study may be required as part of the overall environmental impact assessment (EIA), to investigate the presence and implications of any sites of cultural significance. The area is largely a farming community and the farmers’ work forces are housed on the farms. A detailed investigation of possible land claims in this area will have to be completed as part of the overall EIA. The history of the discovery of platinum in the area dates back to 1923 when the Waterberg platinum deposit was first discovered, and as opposed to the large Bushveld Complex hosted deposits of the Merensky and UG2 Reefs, it is hosted in steeply dipping quartz veins, occurring along a fault plane on the Thabazimbi-Murchison Limeament, separating felsic rocks and sandstone of Jurassic age. The discovery of the Waterberg deposit marked the first discovery of potentially economic PGE deposits in South Africa and preceded the discovery of the Merensky Reef by a year. The deposit was mined between 1923 and 1926 by Transvaal Platinum Ltd. A combination of erratic grades, metallurgical recovery problems, over-capitalizing of a plant, and under-development, forced the mine to close in 1926. During the same period, various prospecting companies explored for platinum over all the farms currently proposed for this prospecting right. Evidence of such exploration includes remanants of shallow exploration trenches (see photo below), old dumps and small box-cuts. More information on the history of platinum mining in the area is given in Appendix 4.


(b) Description of the current land uses

The area is essentially that of a farming community with the most prevalent land uses being cattle ranching and game farming. Limited patches of crop cultivation also occur on a number of farms. The presence of hot water springs in the area has also led to the development of a growing tourist industry and various lodges offering tourst accommodation and activities have been developed in the area. The nearest town and commercial centre is Mookgopong, some 25km to the east. The town of Modimolle is approximately 30km to the south. There are no informal settlements in the immediate area of the proposed site.

The Land Cover Map in Figure 7 (SANBI BGIS LUDS tool) gives a visual indication of the various land uses within and surrounding the proposed prospecting area.

(c) Description of specific environmental features and infrastructure on the site

There are numerous small ephemeral streams that rise in the area and flow north-eastwards to the Sterkrivier which eventually flows into the Doorndraai dam situated approximately 12km northeast of the project area. No potential wetlands have been identified although the existence of wetlands cannot be ruled out as no wetland specialist study has been conducted. While wetlands are not anticipated to be encountered on the higher topography where the mineralised veins occur (and therefore where the anticipated prospecting sites will be positioned), the access routes established to the prospecting sites will need to consider the possibility of weltands occurring.

Infrastructure within the proposed prospecting area is mostly that associated with farming. A fairly extensive network of roads exists throughout the area however these exist mainly on private land. Roads are all of a well-maintained gravel surface nature. Powerline and telephone line infrastructure is present and services the various farming and tourism establishments throughout the area. Water is obtained from boreholes and storage dams.

Figure 8 presents the Limpopo Conservation Plan (SANBI BGIS LUDS tool) which indicates that the proposed prospecting area comprises:

Protected areas (0%)

Critical biodiversity area 1 (±40%)

Critical biodiversity area 2 (±50%)

Ecological support area 1 (±8%)

Ecological support area 2 (±1%)

Other natural (±1%)

Critical Biodiversity Areas are areas required to meet biodiversity targets for ecosystems, species and ecological processes, as identified in a systematic biodiversity plan. Ecological Support Areas are not essential for meeting biodiversity targets but play an important role in supporting the ecological functioning of Critical Biodiversity Areas and/or in delivering ecosystem services.

The primary purpose of a map of Critical Biodiversity Areas and Ecological Support Areas is to guide decision-making about where best to locate development. It should inform land-use planning, environmental assessment and authorisations, and natural resource management, by a range of sectors whose policies and decisions impact on biodiversity. It is the biodiversity sector’s input into multi-sectoral planning and decision-making processes.

Figure 9 presents the Mining and Biodiversity Guidelines (SANBI BGIS LUDS tool) indicating that virtually 100% of the proposed prospecting area falls within category B: Highest biodiversity importance – highest risk for mining. The Mining and Biodiversity Guideline was developed to facilitate informed decisions about land-use planning and environmental authorisation for mining development. It provides the mining sector with a practical, user-friendly manual for integrating biodiversity considerations into the planning processes and managing biodiversity during all phases of the mining life cycle from exploration through to closure.


(d) Environmental and current land use map

Figure 7: Land-cover map indicating the current land uses within and surrounding the proposed prospecting right area.


Figure 8: Conservation plan showing the environmental sensitivity within and surrounding the proposed prospecting right area.


Figure 9: Mining and Biodiversity Guidelines showing the sensitivity within and surrounding the proposed prospecting right area.


(v) Impacts identified

&

(vi) Method used to identify impacts

The following methodology was followed for a screening level impact assessment in order to determine the potential impacts of the proposed activities that will need to be assessed in more detail during the EIA phase of the application.

Considering the baseline environment, the proposed activities were evaluated against all environmental attributes to identify potential impacts / risks.

Environmental Attributes (presented alphabetically):

Aesthetics / Visual affects Sites of heritage & cultural interest

Air Quality / Dust Soil

Ecology / Fauna and Flora Land use

Geological features / subsidence Surface water

Ground water Topography

Noise / Sound levels Vibration

Sensitive receptors Crime and security

All potential impacts were then categorised as follows: The “informed by” section in the table below, were categorised into;

Known impact (an impact that is known by experience)

Identified by I&AP’s

Identified by Specialist (if applicable) The probability of the impacts were then categorised into;

Improbable

Probable and

Definite The duration of the impact were then categorised into;

Short term (impact will cease within 6 months)

Medium term (impact will cease within 5 years)

Permanant Using the above definitions, the identified impacts were classified as either potentialy significant or insignificant;

Insignificant impacts / risks will be described during the EIA phase and not assessed any further.

Potentially significant impacts / risks will be subjected to further assessment during the EIA phase to determine the significance of the impact / risk in order to assign the appropriate management measures.


Table 4: Identified Impacts (resulting from a screening level assessment)

ACTIVITY POSSIBLE IMPACTS INFORMED BY PROBABILI

TY OF

IMPACT

DURATION

OF IMPACT SIGNIFICANCE

PR Application in terms of Section 16 and Regulation 7(1) of the Mineral and Petroleum Resources Development Act.

None - - - -

Non-invasive Preparation

Literature review and desktop studies

Surface Mapping

Airborne surveys and geophysical prospecting

Determining sampling locations Invasive prospecting

Establishing access routes to the sampling sites

Establishing the sampling camp (stores / ablution / security)

Drilling of exploration boreholes

Excavation of surface trenches and bulk sampling pits

Samples transported to recognised laboratory for analysis

Concurrent rehabilitation

Supporting services (waste/water/emergency maintenance) Non-invasive Documentation

Prefeasibility study

Bankable feasibility study

Preparation for Mining Authorisation

Aesthetics / Visual Known / I&AP Definite Short Potentially Significant

Air Quality / Dust Known Probable Short Potentially Significant

Fauna and Flora Known / I&AP Definite Medium Potentially Significant

Geology Known Definite Permanent Insignificant

Ground water Known Improbable Short Insignificant

Noise / Sound levels Known / I&AP Probable Short Potentially Significant

Cultural & Heritage Known Improbable Permanent Potentially Significant

Soil Known Definite Medium Potentially Significant

Crime and security Known / I&AP Probable Short Potentially Significant

Surface water Known Improbable Short Insignificant

Topography Known Improbable Short Insignificant

Land use Known / I&AP Probable Short Potentially Significant


(vii) The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected

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

The possible positive and negative impacts associated with the proposed prospecting activities are given below. The most likely persons to be affected will be the landowners and residents of the properties within and adajacent to the proposed prospecting area. This community consists of mainly game farming and agricultural enterprises.

Aspect

Description

Mineral resource Optimal planning of final invasive site locations P+ No Medium

Once the ideal position from a geological point of view is determined

apply appropriate environmental buffers;

100m from a water course

50m from any infrastrucutre

50m from any heritage site

Where possible close to existing access tracks

Noise nuisance Low flying aircraft during aerial surveying N- No Med-Low

Aerial surveying to be undertaken by a qualified and experienced

pilot. Low flying only to occur within the prospecting area, and during

hours that have been determined to have the least probability of

causing disturbance. Landowners will be notified in advance before

any aerial surveys are conducted over their properties.

Air qualityDust entrainment from vehicle / equipment, Windblown dust

from exposed surfacesN- Yes Medium

Ensure that the (drill) equipment used has appropriate dust

suppresion systems. Do not undertake invasive activities if high

winds taking dust offsite.

Noise nuisance Noise generated from vehicle / equipment operations N- Yes MediumEnsure all equipment is well maintained.

If necessary restrict invasive activities to daytime hours only

SoilCompaction from equipment, Degradation from hydrocarbon

spills, ErosionN- No Medium

Restrict invasive activities to the designated area. Use existing

access roads where possible. Vehicle inspection checklist to be

used daily

Use of drip trays for standing equipment

Clean up minor spills promptly

Surface waterAlteration of surface water flow by changing the topography

(trenching and bulk sampling)N- No Med-Low Restrict bulk sampling to the designated area.

Ground waterHydrocarbon spills and other contaminants infiltrating the

groundwaterN- No Low

Vehicle inspection checklist to be used daily



Cultural / heritage Destruction of a cultural / heritage artefact N- No Low Maintain a 50m buffer from any identified heritage site.

Fauna & FloraLoss of flora by clearing / trampling, Loss of habitats for

faunaN- Yes High

Consult an ecologist on the suitability of the proposed sampling site

before establishing the site or access roads. Restrict invasive

activities to the designated areas.

Land useAlteration of the land and its capacity to support current land

usesN- Yes Medium

Restrict invasive activities to the designated areas. Implement

concurrent rehabilitation.

Crime and security

The presence of equipment and resources such as fuel at

the sampling sites may attract would be thieves. A

prospectiing team will need to access private land and

temporary camps will need to be erected at some sampling

sites (drilling and bulk sampling)

N- Yes Medium

Equipment and resources will be secured within the camps using

fencing and padlocks. Additional flood lighting can be installed and a

security guard employed if necessary.

Visual Presence of equipment being unsightly N- Yes Medium Implement good housekeeping at each sampling site.

Concurrent

rehabilitation

Restoration of the

areas impacted by

invasive prospecting

Removal of alien vegetation and promotion of establishment

of indigenous species P+ No Medium

As and when a sample site is completed, the land and access road

must be subjected to rehabiliation activities.

Visual Poor waste management and housekeeping being unsightly N- No Low Implement good housekeeping at each sampling site.

Soil Degradation from hydrocarbon spills and other contaminants N- No Med-LowClean up minor spills

Use drip trays where necessary


groundwaterN- No Med-Low

Clean up minor spills

Use drip trays where necessary

Non invasive

feasibility studyN/A N/A

I&AP

Non invasive

investigations:

Desktop studies

Literature research

Aerial surveying


activites:

Trenching

Drilling

Bulk sampling

Analysis

Supporting services

Waste management

Sanitation

Emergency vehicle

maintenance

Sig W/O

MitigationMitigation typeActivity Impact Description Type


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

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

Below is a preliminary assessment of the possible mitigation measures that could be applied and the level of risk in terms of significance before and after mitigation. A complete assessment will be conducted during the EIA phase.

Aspect

Description

Mineral resource Optimal planning of final invasive site locations P+ No Medium

Once the ideal position from a geological point of view is determined

apply appropriate environmental buffers;

100m from a water course

50m from any infrastrucutre

50m from any heritage site

Where possible close to existing access tracks

Medium

Noise nuisance Low flying aircraft during aerial surveying N- No Med-Low

Aerial surveying to be undertaken by a qualified and experienced

pilot. Low flying only to occur within the prospecting area, and during

hours that have been determined to have the least probability of

causing disturbance. Landowners will be notified in advance before

any aerial surveys are conducted over their properties.

Low

Air qualityDust entrainment from vehicle / equipment, Windblown dust

from exposed surfacesN- Yes Medium

Ensure that the (drill) equipment used has appropriate dust

suppresion systems. Do not undertake invasive activities if high

winds taking dust offsite.

Low

Noise nuisance Noise generated from vehicle / equipment operations N- Yes MediumEnsure all equipment is well maintained.

If necessary restrict invasive activities to daytime hours onlyLow

SoilCompaction from equipment, Degradation from hydrocarbon

spills, ErosionN- No Medium

Restrict invasive activities to the designated area. Use existing

access roads where possible. Vehicle inspection checklist to be

used daily



Med-Low

Surface waterAlteration of surface water flow by changing the topography

(trenching and bulk sampling)N- No Med-Low Restrict bulk sampling to the designated area. Low


groundwaterN- No Low

Vehicle inspection checklist to be used daily



Low

Cultural / heritage Destruction of a cultural / heritage artefact N- No Low Maintain a 50m buffer from any identified heritage site. Low

Fauna & FloraLoss of flora by clearing / trampling, Loss of habitats for

faunaN- Yes High

Consult an ecologist on the suitability of the proposed sampling site

before establishing the site or access roads. Restrict invasive

activities to the designated areas. Implement concurrent

rehabilitation.

Medium

Land useAlteration of the land and its capacity to support current land

usesN- Yes Medium

Restrict invasive activities to the designated areas. Implement

concurrent rehabilitation.Med-Low

Crime and security

The presence of equipment and resources such as fuel at

the sampling sites may attract would be thieves. A

prospectiing team will need to access private land and

temporary camps will need to be erected at some sampling

sites (drilling and bulk sampling)

N- Yes Medium

Equipment and resources will be secured within the camps using

fencing and padlocks. Additional flood lighting can be installed and a

security guard employed if necessary.

Med-Low

Visual Presence of equipment being unsightly N- Yes Medium Implement good housekeeping at each sampling site. Med-Low

Concurrent

rehabilitation

Restoration of the

areas impacted by

invasive prospecting

Removal of alien vegetation and promotion of establishment

of indigenous species P+ No Medium

As and when a sample site is completed, the land and access road

must be subjected to rehabiliation activities.Medium

Visual Poor waste management and housekeeping being unsightly N- No Low Implement good housekeeping at each sampling site. Low

Soil Degradation from hydrocarbon spills and other contaminants N- No Med-LowClean up minor spills

Use drip trays where necessaryLow


groundwaterN- No Med-Low

Clean up minor spills

Use drip trays where necessaryLow

Non invasive

feasibility studyN/A N/A

Non invasive

investigations:

Desktop studies

Literature research

Aerial surveying


activites:

Trenching

Drilling

Bulk sampling

Analysis

Supporting services

Waste management

Sanitation

Emergency vehicle

maintenance

Sig W/O

MitigationMitigation typeActivity Impact Description Type I&AP

Sig after

mitigation


(ix) The outcome of the site selection Matrix. Final Site Layout Plan

The final positioning of a trench/drill/bulk sampling site can however be altered to accommodate landowner requirements or to avoid sensitive environmental features. See Appendix A.2 for an indication of the areas of interest for potential sampling sites. The final positioning of invasive activities will only be confirmed once the relevant landowner has been consulted and the surveying and mapping excercises of the preparation phase have been completed.

(x) Motivation where no alternative sites were considered

The final positioning of a trench/drill/bulk sampling site can however be altered to accommodate landowner requirements or to avoid sensitive environmental features. See Appendix A.2 for an indication of the areas of interest for potential sampling sites. The final positioning of invasive activities will only be confirmed once the relevant landowner has been consulted and the surveying and mapping excercises of the preparation phase have been completed.

(xi) Statement motivating the preferred site.

The area applied for has been listed in historical literature as known sites of platinum mineralization associated with faulting. The specific areas were historically explored for their platinum content on the surface with varying degrees of success, although no workable surface deposits were ever exploited. Evidence of historic exploration is clearly evident as visible trenches and small adits. It is therefore evident that a degree of mineralization has already been previously recognized to exist in this area. The preferred locations for invasive prospecting by way of trenching, drilling and bulk sampling will be identified during the non-invasive phase 1 of the prospecting programme.

i) PLAN OF STUDY FOR ENVIRONMENTAL IMPACTS ASSESSMENT PROCESS

(i) Description of alternatives to be considered including the option of not going ahead with the activity

There are no alternatives considered to the prospecting methods proposed in order to establish if a viable resource exists. The implications of not going ahead with the prospecting activity is that the potential resource will remain unkown and therefore steralised. Should the results of prospecting indicate a viable resource this could lead to a viable mining operation being established which could attract possible positive impacts such as job creation and boosting the regional economy. However, these and all other impacts (positive and negative) would only become known through the assessment process undertaken as part of an application for a mining authorisation.

(ii) 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 asExcavations, 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.)

A list of the aspects to be assessed per activity is given in Section 3(h)(viii).

(iii) Description of aspects to be assessed by specialists

Due to the limited nature of the impacts expected with the prospecting activities and the flexibility of a prospecting campaign (i.e sampling sites can be moved within reason to avoid sensitive environmental features), specialist studies are not perceived to be required at this stage. Should results from the Environmental Impact Assessment phase or information gathered during Phase 1 of the prospecting works programme suggest that specialist studies are required, these will be duly commissioned.


(iv) Proposed methods of asessing the environmental aspects including the proposed method of assessing alternatives

&

(i) the proposed method of assessing duration signficance

The Umhlaba impact assessment tool will be used during the EIA phase of the application in order to determine the significant impacts of the drilling activities on the baseline environment. Below is a description of the Umhlaba impact assessment tool; Definitions: The following technical terms are used in the context of the impact assessment:

Environment: The surroundings within which humans exist and that are made up of: - the land, water and atmosphere of the earth. - micro-organisms, plant and animal life. - any part or combination of the above, and the interrelationships among and between them. - the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that

influence human health and wellbeing.

Activity: A specific deed, action or function, that takes place at an operation. - E.g. Stripping of topsoil or mining of clay.

Aspect: Considered to be a direct effect of an activity, which has an influence on the environment. It is neither categorised as positive or negative.

- E.g. Mining of clay (an activity) causes dust fallout and noise (both are aspects of the activity).

Impact: The end-result of an aspect that occurred due to an activity, resulting in an influence (change) on the environment. The influence is either positive or negative. The determination as to whether an impact is positive or negative is subjective. For example:

- E.g. Dust, an aspect of mining (an activity), cause a nuisance to neighbouring houses (an impact – negative from the perspective of the homeowner).

Cumulative Impacts: Cumulative Impacts will be considered where off-site activities (not related to the operation being evaluated) will result in the same impact at the receptors being considered.

- E.g. dust will be considered cumulatively for a mine located adjacent to a field which is ploughed. The spatial extent for the consideration of off-site impacts will be determined individually for each impact depending on factors such as the medium of dispersal of the pollutant causing the impact.

Environmental Impact Assessment: A formal or informal procedure producing a quantitative estimate of the environmental impact resulting from an activity.

Significance: A determination of the importance of a particular impact and in doing so incorporates extent, frequency and severity. The criteria for determining this significance is described below.

Criteria to Consider when Determining the Significance The ranking of impacts / determination of significance is estimated using two criteria, namely Consequence and Probability. These consider the contributing factors / criteria listed in the legislation. The definitions of each are provided below. The Consequence of an impact resulting from an aspect is expressed as a combination of:

Nature of impact: An indication of the extent of the damage (negative impacts) or benefit (positive impacts) the impact inflicts on natural, cultural, and/or social functions (environment).

Extent of impact: A spatial indication of the area impacted (i.e. how far from activity the impact is realized) or spatial extent of the importance of the potential impact (i.e. if a heritage site of national importance will be impacted on site, then the extent is regarded as “national” and not “onsite”).

Duration of impact: A temporal indication of the how long the effects of the impact will persist, assuming the activity creating the impact ceases. For example, the impact of noise is short lived (impact ceases when activity ceases) whereas the impact of removing topsoil exists for a much longer period of time.

Frequency of the aspect occurring: An indication of how often an aspect, as a result of a particular activity, is likely to occur. Note that this does not assess how often the impact occurs


as it applies only to the aspect. For example mining takes place daily while the resultant frequency of the impacts occurring will vary based on a number of factors.

The Probability of an impact resulting from an aspect is expressed as: Probability of impact occurring: An estimated indication of the potential for an impact to occur. For example if there is a small overburden dump, what is the probability of adjacent landowners regarding the dump as a visual impact? Probability is based on the author’s experience with the known activities of the operation. Determining Significance for Controls The Significance of an impact: Using the criteria explanation above, scores are assigned to each the criteria, as outlined in Table 5. The scoring range has been selected to represent the scale in which varying impacts can occur. The combination of scores is then used to determine the Consequence and Probability.

Consequence is expressed as the sum of all criteria in order to get a score out of 100.

Probability of the impact occurring is expressed as a score out varying from 1 to 10. Multiplying the consequence score against the probability score provides for an initial significance ranking. The lowest potential score is 4 and the highest possible impact score is 1000. Scoring Range Table 5 provides an indication of the scoring given to each category associated with the impact assessment.


Table 5: Impact assessment scoring.

Low Impacts affect the environment in such a way that natural, cultural and / or

social functions and processes are affected insignificantly.1

Low-MediumImpacts affect the environment in such a way that natural, cultural and / or

social functions and processes are altered in a minor way. 5

MediumImpacts affect the environment in such a way that natural, cultural and / or

social functions and processes are altered. 10

Medium-HighImpacts affect the environment in such a way that natural, cultural and / or

social functions and processes are severely altered. 15

HighImpacts affect the environment in such a way that natural, cultural and / or

social functions and processes will be irreversibly changed. 25

On-site Impact occurs within a functional area. 1

Neighbouring Impact occurs on neighbouring properties 5

Local Impact occurs within a 10km radius of the site. 10

RegionalImpact occurs within a 100km radius of the site.(or environmental attribute of

regional importance)15

NationalImpact occurs within South Africa. (or environmental attribute of national

importance)25

Very Short-term The impact will cease within 1 week if the activity is stopped. 1

Short-term The impact will cease within 1 year if the activity is stopped. 5

Medium-term The impact will cease within 5 years if the activity is stopped. 10

Long-term After the operational life of the operation. 15

Permanent

Where mitigation either by natural process or by human intervention will not

occur in such a way or in such a time span that the impact can be considered

transient.

25

Annually or less Activity occurs at least once in a year or less frequently. 1

6 months Activity occurs at least once in 6 months. 5

Monthly Activity occurs at least weekly to once a month. 10

Weekly Activity occurs on operational days. 15

Daily Activity occurs daily. 25

Improbable The possibility of the impact materialising is very low either because of design

or historic experience. 1

Low The possibility of the impact materialising is low either because of design or

historic experience. 3

Medium There is a possibility that the impact will occur. 6

High There is a distinct possibility that the impact will occur. 8

Definite The impact will occur regardless of any prevention measures. 10

Effective Engineering 40%

Efective Maintenance 5%

Implementing of procedural controls 25%

Training 10%

Are you legally compliant (Yes / No) 200

Unresolved concern by an I&AP 100

Needs to be recongised cumulatively with other extenal impacts 50

External factors that influence significance outside the control of the operation

Significance Score (After controls, including external factors)

Significance Score (Before controls) 1 = applicable; 0 = not applicable

Nature of the potential Impact

Extent of the potential impact

Duration of the potential impact

Frequency of the activity causing the potential impact

Total Consequence

Total Probability

Probability

Significance Score (After controls)


The Final Significance ranking of an impact will also take cognizance of:

Activities resulting in legal triggers: If there is an activity (as contained within the aspect and impact register) which (potentially) triggers a legal authorization process, then this activity and associated impact needs to be recognized at minimum as a medium impact to ensure that appropriate management measures are assigned.

Impacts / Issues raised by Interested and Affected Parties: For new and existing operations, I&Aps will be consulted, either during the compilation of the impact assessment (for new operations) or part of an existing / on-going consultation process (for existing operations). During this consultation process, I&AP will identify concerns relating to impacts resulting from activities associated with the operation. Impacts identified by I&Aps will be assigned additional scoring.

Cumulative Impacts: Cumulative Impacts will be considered where any off-site activities (not related to the operation being evaluated) will result in the same impact at the receptors being considered.

Below is a summary of the influence of external factors on final significance scoring:

External Factor Description Points to add

Legal Activity triggers a legal authorisation process 200

I&AP Concerns

Unresolved Impact rasied as a concern by an I&AP 100

Cumulative Impact

Impact can be considered cumulatively with off site impacts 50

The final significance ranking takes cognisance of the initial scoring plus any additional score associated with allocating an external factor. At no time can the sum total of all the scores exceed 1000.

Converting the Scores to a Significant Ranking Allocation

The significance of an impact is considered to be classified into one of the following; High, Medium-High, Medium, Low-Medium or Low. Each of the classified impacts has a scoring band into which it falls. The band has been determined by a combination of 25 years of experience of Umhlaba employees. The definition of each classification is provided in Table 6 and focuses on the need for avoidance, mitigation or management.

Table 6: Significance classification.

Significance:

Low

(4 – 60)

Management measures may not be necessary, but in some instances are encouraged to ensure that the impact remains of Low significance.

Low-Medium

(61 – 200)

Management measures are usually encouraged to ensure that the impacts remain of Low-Medium significance.

Medium

(201 – 400)

Management measures are required to ensure, at minimum, the significance of the impact does not increase.

Medium-High

(401 – 650)

Management measures are required to reduce the significance of the impact to, at least, Medium significance.

High

(>651)

Impact should be avoided, or if not possible, managed to reduce the significance of the impact to, at least, Medium significance (where possible).

Determining Significance After Controls

The Significance of an impact can be reduced through the successful implementation of appropriate controls. Table 7 provides a summary of the controls that can be implemented and the degree in which the control can effectively reduce the significance of the impact.


Table 7: Summary of controls to reduce significance.

Type of control Description % to be deducted

Engineering Isolation, re-design, Guarding, Containment, Safety Device

40%

Monitoring, Measurement and Maintenance

Continuous Monitoring, Observations, Inspections & Testing, Implementing Maitenance

5%

Procedural and Administration

Policies, Procedures & Work Instructions 25%

Training and Education Training & Competencies 10%

Where management measures are asigned, they are categorised into one of the above reference type of controls and the initial significant ranking is reduced by the appropriate percentage. In many cases more than one control can be applied. For example; should a mine require a diesel tank, the risk of a potential diesel spill from that tank needs to be considered in the initial significant ranking. Thus, if the mine commits and successfully implements the following management measures:

To bund the diesel tank.

To train employees on how to refill vehicles and what to do in case a minor spill occurs. Then, the significant after controls would be reduced by 40% (for the bunding) and 10% due to the training commitment. Additional Factors that do not contribute to the Significance of an Impact After completing the determination of significance of an impact, there are additional factors, which in terms of NEMA which need to be considered. NEMA stipulates that the impact assessment must consider the following for “each identified potentially significant impact”; namely:

“the degree to which the impact can be reversed”

“the degree to which the impact may cause irreplaceable loss of resources”

“the degree to which the impact can be mitigated The impact assessment tool regards a “significant impact” as one with an initial ranking of medium or higher. Although these factors are important in the evaluation of the impacts (particularly for new developments), they will not be applicable to all impacts and hence, may not influence the significance rating of an impact (explained below).

Degree to which the Impact can be Reversed: An indication to the degree to which the impact can be reversed will be provided. Three categories have been allocated: - Not Possible: Once the impact has occurred it will be permanent and cannot be reversed. - Potentially: With appropriate management and mitigation measures there is a potential the

impact can be reduced / reversed. - Likely: With appropriate management and mitigation measures there is a good likelihood

that the impact can be reduced / reversed.

Degree to which the Impact can be Mitigated: This requirement is essentially achieved by determining significance before consideration of controls and then the significance after the consideration of management controls. The difference between the before and after controls is an indication of the “degree to which the impact can be mitigated”.

Degree to which the Impact may cause Irreplaceable Loss of Resources: Aspects that need to be considered in terms of irreplaceable loss of resources should be discussed at the beginning of the impact assessment. An example is the removal of geological material.


(ii) the stages at which the competent authority will be consulted

The competent authority for this application is the Department of Mineral and Resources (DMR)

The DMR became aware of the proposed project upon submission of the prospecting right application in May 2016.

The final scoping report will be submitted to the DMR within 44 days of the submission of the application as per the Regulations.

The EIR report will be submitted to the DMR within 106 days of receiving DMR feedback on the scoping report, as per the Regulations.

(iii) Particulars of the public participation process with regard to the impact Assessment process that will be conducted

The consultation process to be undertaken will include;

Emailing known interested and affected parties (Governement Departments / Parastatals / NGO’s / Ward councillors etc)

Sending registered letters to all landowners where the applicable addresses can be obtained

Placing adverts in local newspapers,

Erecting site notices throughout the extended application area

Having one on one meetings with affected landowners

Having meetings with representative of the affected Municipalities

Having meetings with ward councillors

Holding advertised public meetings

1. 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)

Moving into the Impact Assessment process the following steps will be implemented to notify all registered interested and affected parties;

Immediately after submission of the final scoping report to the DMR, all registered I&AP’s will be notified of the changes to the document and of the opportunity to comment on the final scoping report. This notification will preferably take place via email. However where email is not available telephonic communication will be used.

Once the draft Environmental Impact Assessment Report and Environmental Management Plan is available all registered interested and affected parties will be notified of the availability of the report for comment. The document will be available electronically at www.umhlaba.co.za and in hard copy at the Umhlaba offices in Randparkridge, Johannesburg.

Within the 30 day consultation period, another public meeting will be held to give interested and affected parties the opportunity to raise questions or concerns.

As and when requested, one on one consultations will continue through out the EIA process.

2. 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)

The Scoping Phase engagement process as per the NEMA is provided below;

http://www.umhlaba.co.za/


The EIA phase proposed engagement process is provided below:

Draft Scoping Report provided to I&APs &

State Departments for comments for 30 days.

Final Scoping Report, inclusive of I&AP

comments, to be submitted to the DMR for

consideration and made available to I&AP's

for review

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

Scoping Phase Public Participation Process

EIA application submitted to DMR on 18 May

2016.

Site notices erected & BIDs distributed to

I&APs & State Departments

Media Notice published in local newspaper

(The Post).

Meetings held with identified interested and

affected parties.


An interested and affected parties register will be maintained through out the EIA process. Within this register there is an indication of how each and every registered interested and affected party has been notified and an indication of those that have submitted comments to date.

3. description of the information to be provided to interested and affected parties

(Information to be provited 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)

Interested and affected parties will all initially be notified of the application through letters, emails, newspaper notices and site notices. They will be provided with a background information document to provide them with an overview of the proposed project. A draft Scoping report will be compiled and made available to I&AP’s during a 30 day review period, which will include a public meeting, to gain I&AP feedback for the final Scoping Report.

Immediately after submission of the final scoping report, all registered interested and affected parties will be notified of the changes that have occurred from the draft to the final scoping report. They will also be directed to a website where copies of the final scoping report can be obtained. Once the draft environmental impact assessment report has been completed all registered interested and affected parties will be informed of the document and provided with 30 days to review and comment. During the review period a public meeting will be offered to provide an opportunity for interested and affected parties to raise any question / query. I&AP views will be incorporated in to the final EIA/EMP and I&AP’s will be notified of the submission and access to the final report (via Umhlaba website).

Final EIA/EMP Report, inclusive of I&AP

comments, to be submitted to the DMR for

consideration

Public meeting with registered I&AP's to

discuss the draft EIA/EMP and gain I&AP

feedback to be incorporated into the final

document for submission

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

EIA Phase Public Participation Process

Draft EIA/EMP Report to be completed and

provided to registered I&APs & State

Departments for comments for 30 days

Notify registered I&AP's of the submission

and availability of the final scoping report


(viii) Description of the tasks that will be undertaken during the environmental impact assessment process

The flow diagram below summerises the tasks associated with the environmental impact assessment process in full.

During the EIA/EMP phase the following tasks will be completed;

Inform registered I&AP’s of the change between the draft and final scoping report

Complete any specialist studies if required

Complete the draft reports associated with the environmental impact assessment phase of the application

Subject the draft reports to a consultation process.

Finalise and submit final reports to the authorities for a decision.

Notify registered interested and affected parties of the final decision

(ix) 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.

Possible mitigation measures have been presented in Section 3(h)(viii). These will be assessed fully during the EIA phase.


j) OTHER INFORMATION REQUIRED BY THE COMPETENT AUTHORITY

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

(1) Impact on the socio-economic conditions of any directly affected person The possible socio-economic impacts are related to current land uses and security. Land uses: The proposed prospecting activities have the potential to disturb the day to day activities taking place on the properties concerned which are mostly game farms, agricultural enterprises and tourist accommodation and facilities. Given the nature of the enterprises (i.e. dependent on the natural resources and aesthetics of the area) the disturbance of the proposed activities to flora and fauna could also have lasting impacts. There are however mitigation measures available to minimise impacts to land use as given in Section 3(h)(viii). Security: Temporary camps will need to be constructed for drilling and bulk sampling. The equipment and resources such as fuel that need to be stored at these camps may attract would be thieves and present a security risk. There are mitigation measures available to minimise the likelihood of security issues as given in Section 3(h)(viii)..

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

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

During the site inspection, evidence of heritage resources within the proposed prospecting area were identified such as graves. Positioning of the sampling sites will only be finalised after consultation with I&AP’s and the completion of phase 1 of the prospecting works programme. In order to ensure that there is no impact on a heritage site, a commitment is proposed to (i) ensure that no sampling site will be located within 50m of any identified heritage site; (ii) should any cultural or heritage artefacts be uncovered during invasive prospecting, prospecting activities will cease and the relevant authorities notified.

k) OTHER MATTERS REQUIRED IN TERMS OF SECTION 24(4)(A) AND (B) OF THE ACT (The EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist. The EAP must attach such motivation as Appendix 4).

When completing the EIA phase of the application Section 24(4)(A) and (B) will be used as a checklist to ensure that all procedural requirements for the environmental authorisation process have been achieved.


l) UNDERTAKING REGARDING CORRECTNESS OF INFORMATION

I GREG COATES HEREWITH UNDERTAKE THAT THE INFORMATION PROVIDED IN THE

FOREGOING REPORT IS CORRECT, AND THAT THE COMMENTS AND INPUTS FROM STAKEHOLDERS AND INTERESTED AND AFFECTED PARTIES HAS BEEN CORRECTLY RECORDED IN THE REPORT.

SIGNATURE OF THE EAP

DATE: 30 June 2016

m) UNDERTAKING REGARDING LEVEL OF AGREEMENT

I GREG COATES HEREWITH UNDERTAKE THAT THE INFORMATION PROVIDED IN THE

FOREGOING REPORT IS CORRECT, AND THAT THE LEVEL OF AGREEMENT WITH INTERESTED AND AFFECTED PARTIES AND STAKEHOLDERS HAS BEEN CORRECTLY RECORDED AND REPORT HEREIN

SIGNATURE OF THE EAP

DATE: 30 June 2016

-END-

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