Gannabosch Vlakte 51 Mining Rights Application...2017/01/04 · GANNABOSCH CLAY MINE (Pty) Ltd....

Gannabosch Vlakte 51 Mining Rights Application

NAME OF APPLICANT: GANNABOSCH CLAY MINE (Pty ) Ltd.DMR REFERENCE NUMBER: WC30/5/1/2/2/10082MRUMVOTO REFERENCE NUMBER: 856/06/03/2016FARM NAMES: Gannabosch Vlakte 51PROVINCE: Western CapeDATE: 6 January 2017

COMPILED IN TERMS OF APPENDIX 3 AND APPENDIX 4 OF THE ENVIRONMENTALIMPACT ASSESSMENT REGULATIONS, 2014 (GOVERNMENT NOTICE NO. R 982) (EIAREGULATIONS, 2014) AND SUBMITTED AS CONTEMPLATED IN REGULATION 23 OF

CHAPTER 4 OF THE EIA REGULATIONS, 2014)

Final EIA and EMP Report

Prepared for:

Gannabosch Clay Mine(Pty) Ltd

Volume 1Prepared by:

December2016

GANNABOSCH CLAY MINE (Pty) Ltd.

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Reference

This report is to be referred to in bibliographies as:

Umvoto Africa. (2016). Gannabosch Vlakte 51: Mining Rights Application – Final EIA andEMP Report. Prepared by P. Lee and G Molzen of Umvoto Africa (Pty) Ltd for GannaboschClay Mine (Pty) Ltd. Report No. 856/06/02/2016, December 2016, 144 pp.

Report Status

Report No. Status Reviewed by Date

856/06/03/2016 Final ReportReady for Submission

K Riemann 4-01-2016

Distribution List

Report No. Status Name Institution Date

856/06/03/2016 Final Morne Swanepoel Gannabosch Clay Mine(Pty) Ltd

6-01-2017

856/06/03/2016 Final Sonia Mothodidi Department of MineralResources

6-01-2017


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TABLE OF CONTENTS

Chapter Description Page

1. INTRODUCTION 11.1 Details and Expertise of the Environmental Assessment Practitioner 11.2 Contact Information and Location of the Operation 11.3 Property Details 11.4 History and Background Information of the Mining Operation 31.5 Purpose of Report 51.6 Structure of this Report 51.7 Content of Report 61.8 Assumptions and Limitation 11

2 GOVERNANCE FRAMEWORK AND ENVIRONMENTAL PROCESS 122.1 Legal Requirement 12

2.1.1 National Environmental Management Act 107 of 1998 (NEMA); 122.1.2 EIA Regulations, promulgated in terms of NEMA; 132.1.3 National Water Act 36 of 1998 (NWA); 142.1.4 National Heritage Resources Act 25 of 1999 (NHRA) 152.1.5 National Environmental Management: Biodiversity Act 10 of 2004

(NEMBA); 162.1.6 National Environmental Management: Air Quality Act 39 of 2004 16

2.2 Planning Policy Framework 172.2.1 Western Cape Provincial Spatial Development Framework (2014) 172.2.2 Cape Winelands District Municipality Integrated Development Plan (IDP) 182.2.3 Cape Winelands District Municipality Spatial Development Framework

(SDF) 192.2.4 Langeberg Local Municipality Integrated Development Plan (IDP) 192.2.5 Langeberg Local Municipality Spatial Development Framework (SPDF) 192.2.6 Western Cape Road Access Guidelines Ed-2 September 2002 202.2.7 Guideline for Involving Visual and Aesthetic Specialists in EIA Process 202.2.8 Mining and Biodiversity Guideline 21

2.3 Environmental Process 212.3.1 Submission of Application 222.3.2 S&EIR Process and Phasing 23

3 BASELINE ENVIRONMENT 243.1 Climate 25

3.1.1 Temperature 253.1.2 Wind 253.1.3 Rainfall 26

3.2 Topography and Landform Visual Impact 273.2.1 Visual Character 273.2.2 View Catchment 293.2.3 Zone of Visual Influence 293.2.4 Receptors 313.2.5 Visual Sensitivity Absorption Capacity and Intrusion 32

3.3 Geology 32


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3.4 Hydrogeology 353.5 Soil, Land Use and Land Capability 353.6 Biodiversity 36

3.6.1 Habitat 363.6.2 Freshwater Ecology 473.6.3 Fauna 53

3.7 Noise 543.8 Socio-economic Environment 58

3.8.1 Demographics 583.8.2 Education 593.8.3 Economy 603.8.4 Employment and Income 623.8.5 Health 633.8.6 Service Delivery 63

3.9 Heritage Environment 643.9.1 Landscape and natural features of cultural significance 683.9.2 Archaeological resources 693.9.3 Paleontological resources 693.9.4 Amended NID 70

3.10 Description of the Specific Land Uses on the Site and Neighbouringproperties 71

3.10.1 Current on Site Land Use 713.10.2 Surrounding Land Use 713.10.3 Nearby Business/Tourism 733.10.4 Residential 753.10.5 Alternate land use 75

3.11 Air Quality 764 PROJECT DESCRIPTION 78

4.1 Project Design: 784.1.1 Layout, road network and infrastructure 784.1.2 Mining Method 794.1.3 Stormwater Management Plan 824.1.4 Volume and production forecast 834.1.5 Project description of the Associated Brick Making Facility 844.1.6 Waste Management 86

4.2 Project Management 864.3 Proponents Project Motivation 87

4.3.1 Suitability of the ore for beneficiation 874.3.2 Market supply and demand 88

4.4 Exploration results 895 STAKEHOLDER ENGAGEMENT 92

5.1 Objectives of the Stakeholder Engagement Process 925.2 Interested and Affected Parties Consultation Process 92

5.2.1 Identification of Key Stakeholders 955.2.2 Notification of the EIA Process 955.2.3 Release of Draft Scoping Report 965.2.4 Issues and Concerns Raised by IAP’s during Scoping 965.2.5 Release of first Draft EIA Report 985.2.6 Issues and Concerns Raised by IAP’s on first Draft EIA Report 985.2.7 Release of second Draft EIA Report 98


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5.2.8 Issues and Concerns Raised by IAP’s on Second Draft EIA Report 995.2.9 Finalising the EIA Report 99

6 ENVIRONMENTAL IMPACT ASSESSMENT 1006.1 Introduction 100

6.1.1 Identified Environments of Impact 1006.1.2 Specialist Studies Undertaken 100

6.2 Impact Rating Method 1016.3 Listed Potential Environmental Impacts 104

6.3.1 Freshwater Ecology/Hydrology 1046.3.2 Flora and Fauna 1066.3.3 Soils 1086.3.4 Heritage Impacts 1096.3.5 Socio-economic Impacts 1096.3.6 Air Quality 1106.3.7 Noise 1116.3.8 Visual Impact 1116.3.9 Traffic Impact 112

6.4 Cumulative Impacts 1137 ALTERNATIVE LAND USE AND DEVELOPMENTS CONSIDERED 114

7.1 Alternate Land Use 1147.2 Alternative Clay Resource 1147.3 Alternative Mining Options 117

7.3.1 Alternate mine footprint 1177.3.2 The No Go Alternative 118

7.4 Related Developments 1188 ENVIRONMENTAL MANAGEMENT AND MONITORING PROGRAMME 119

8.1 Environmental Objectives 1198.2 Environmental Management Programme 120

8.2.1 Soil 1208.2.2 Water 1228.2.3 Fauna and Flora 1248.2.4 Heritage 1268.2.5 Air Quality and Dust Suppression 1268.2.6 Mine Waste 1288.2.7 Noise Emission 1288.2.8 Visual Impact Control 1298.2.9 Traffic Impact 130

8.3 Monitoring and Performance Assessment 1318.4 Monitoring Compliance and the Performance Assessment against the

Environmental Management Program and Reporting thereof 1338.5 Management measures for concurrent rehabilitation and closure 133

9 FINANCIAL PROVISION ESTIMATION 1349.1 Quantum of Financial Provision for Rehabilitation 1349.2 Quantum of Financial Provision for Social Development 1379.3 Method of Providing Financial Provision 138

10 CONCLUSION AND RECOMMENDATION 13810.1 Principal Findings 139


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10.2 Conclusions 14010.3 Recommendations 141

11 REFERENCES 143APPENDIX A – MAPS IAPPENDIX B- INTERESTED AND AFFECTED PARTIES REGISTER IXAPPENDIX C- SUMMARY OF RAISED CONCERNS XVI

C-1: Tabulated IAP Responses on Scoping Document XVIC-2: Tabulated Responses on First Draft EIA and EMPr Document XVIIIC-3: Original Correspondence of Comments on Scoping and or First Draft EIA

Report XLVIIC-4: Tabulated Responses on Second Draft of EIA and EMPr Docment XLVIIIC-5: Original Correspondence of Comments to Second Draft of EIA and EMPr

Document LVAPPENDIX D: COMMUNICATIONS WITH AUTHORITY LVI

D-1: Heritage Western Cape LVID-2: Department of Environmental Affairs and Development Planning LVIID-3: Commission of Restitution of Land Rights LVIIID-4: Department of Mineral Resources LIX

APPENDIX E: MINUTES OF FIRST PUBLIC PARTICIPATION MEETING LXE-1: Minutes of First Public Participation Meeting LXIE-2: Minutes of Second Public Participation Meeting LXII

APPENDIX F: EAP CURRICULUM VITAE LXIIIANNEXURE A: ENVIRONMENTAL AUTHORISATION AANNEXURE B: BACKGROUND INFORMATION DOCUMENT BANNEXURE C: SCOPING REPORT CANNEXURE D-1: FIRST NOTICE OF INTENT TO DEVELOP DANNEXURE D-2: AMENDED NOTICE OF INTENT TO DEVELOP EANNEXURE E-1: FIRST BOTANICAL SPECIALIST REPORT FANNEXURE E-2: AMENDED BOTANICAL SPECIALIST REPORT GANNEXURE F-1: FIRST FRESHWATER SPECIALIST REPORT HANNEXURE F-2: AMENDED FRESHWATER SPECIALIST REPORT IANNEXURE G: VISUAL IMPACT SPECIALIST REPORT JANNEXURE H: ATMOSPHERIC IMPACT ASSESSMENT KANNEXURE I: TRAFFIC IMPACT STATEMENT LANNEXURE J: ALTERNATIVE RESOURCE SURVEY REPORT MANNEXURE K: ECONOMIC IMPACT STUDY NANNEXURE L: STORM WATER MANAGEMENT PLAN O


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LIST OF FIGURES

Figure 1-1: Locality of the farm Gannabosch Vlakte 51 on which the proposed clay mine wouldbe situated (see Figure A-0-1 for larger view). ................................................... 2

Figure 1-2: Zoomed in location of Gannabosch Clay Mine (See Figure A-0-2 for larger view)........................................................................................................................... 2

Figure 1-3: Mine layout as required by regulation 2(2) plan of Gannabosch Clay Mine (seeFigure A-0-7 for larger view). ............................................................................. 3

Figure 1-4: Original Mine Layout Plan as per submission in February 2016.......................... 4

Figure 3-1: Average, maximum and minimum daily temperatures throughout the day, with thehorizontal axis representing months of the year, starting with January (1) andending with December (12). ............................................................................ 25

Figure 3-2: Wind direction summary rose chart with wind speed in km/h. ........................... 26

Figure 3-3: Composite climate diagram of the Breede-Alluvium Renosterveld vegetation typerainfall. Blue bars show the median monthly precipitation. The upper and lowerred lines show the mean daily maximum and minimum temperatures respectively(After Mucina and Rutherford, 2006). .............................................................. 27

Figure 3-4: View to the north east from the position of Figure 3-5 across the Vink River showingmassive Langeberge and rolling hills in the background. The proposed site areawill be visible from the R60 as indicated with the dashed-white line................. 28

Figure 3-5: Red arrow depicts fixed photo point from which Figure 3.4 is taken as a view fromthe SW of the proposed mining area. .............................................................. 29

Figure 3-6: Viewshed of the proposed Gannabosch Vlakte Clay Mine ................................ 30

Figure 3-7: Zone of Visual Influence of the proposed Gannabosch Vlakte Clay Mine ......... 30

Figure 3-8: Receptors of the proposed Gannabosch Vlakte Clay Mine. .............................. 31

Figure 3-9: Geological cross section through the centre of mining property (Umvoto,2016c)........................................................................................................................ 33

Figure 3-10: Extract from the CAPE Fine Scale Project: Critical Biodiversity Areas Map for theLangeberg Municipality, showing farm boundaries, mining application and brickprocessing area Krige,2016)............................................................................ 39

Figure 3-11: Critical Biodiversity Map illustrating position of the target area and the farmGannabosch Vlakte 51 within the upland-lowland corridor between theLangeberg Mountains and the Breede River. Also shown is the EcosystemStatus as Vulnerable. ...................................................................................... 40

Figure 3-12: Broad overview of Critical Biodiversity areas regionally. Illustrating position ofthe target area and the farm Gannabosch Vlakte 51 within the upland-lowlandcorridor between the Langeberg Mountains and the Breede River. ................. 41

Figure 3-13: Extract from the SA Vegetation Map (Mucina & Rutherford 2006) indicating themining site and available area for the brick factory. (Krige, 2016). ................... 43

Figure 3-14: Extract from the CAPE Fine Scale Project: Integrated Vegetation Map, showingthe mining site and available area for the brick factory. ................................... 44


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Figure 3-15: Revised mine plan. While the proposed target area impacts drainage line 2, theeast and west boundary drainage lines remain intact and preserve biodiversity......................................................................................................................... 46

Figure 3-16: Photograph of the river channel along potentially affected reach of the Vink River[taken on 11/07/2016] (Ollis et.al., 2016). ........................................................ 48

Figure 3-17: Photograph of the historical flood terrace, located above the flood terraceadjacent to the Vink River [taken on 11/07/2016] (Ollis et.al., 2016). ............... 49

Figure 3-18: Photograph of sections of “Drainage line 2” showing a lack of distinct channelfeatures [taken on 14/10/2016]]( Ollis et.al. , 2016). ........................................ 51

Figure 3-19: Photograph of “Drainage line 3”, showing a section of the stream with a relativelyprominent and sparsely vegetated channel [taken on 11/07/2016] (Ollis et.al.,2016)............................................................................................................... 52

Figure 3-20: Localities of residents and tourism facilities within immediate area of operation.The yellow circle indicates the zone of noise extent. Dark red indicates the 1kmfugitive dust fallout and light red indicates 2 km fugitive dust fallout. Both areplotted along the prevailing wind direction (bottom right corner). ..................... 55

Figure 3-21: Level of sound intensity with increasing distance from source. ....................... 57

Figure 3-22: Cape Winelands District Municipality population projection (WCGPT, 2015) .. 58

Figure 3-23: Distribution of age for the given population ..................................................... 59

Figure 3-24: Education level for Langeberg LM (statsSA,2011). ......................................... 59

Figure 3-25: Average Household Income (Stats SA, 2011). ................................................ 62

Figure 3-26: 1942 aerial photograph showing the farm (black polygon) and two dams(turquoise ovals).............................................................................................. 65

Figure 3-27: The site was still largely undeveloped in 1949 aside from the dam in the east withFarm 51 outlined in black. ............................................................................... 66

Figure 3-28: 1973 aerial photography of the broader area showing the limestone minedeveloped in the northeast and the factory in the southwest alongside the R60(red arrow). Farm 51 is outlined in black. Both dams appear to be in use........ 67

Figure 3-29: 1993 aerial photography of the broader area showing the limestone mineexpanded in the northeast. The factory site is arrowed and Farm 51 outlined inblack. Both dams are still evident. ................................................................... 68

Figure 3-30: Extract from the SAHRIS Palaeosensitivity map showing the local geologicalunits to be of moderate sensitivity (green shading). The site is indicated by thered polygon. .................................................................................................... 70

Figure 3-31: Neighbouring farms to Gannabosch Vlakte 51. ............................................... 72

Figure 3-32: The Langeberg-West Mountain Catchment Conservation and Doringkloof PrivateNature Reserve that are in close proximity to Gannabosch Vlakte 51.............. 72

Figure 3-33: Land units associated with the Rooiberg Breede River Conservancy, 13 550 haof land of which Gannabosch Vlakte 51 is shown in central position................ 73

Figure 3-34: The Rooiberg Mountain Bike Trail seen to be running adjacent to the southernborder of the mine concession......................................................................... 74


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Figure 3-35: Alternative sites along the R60. Note the much closer proximity as well as thelarger extent. ................................................................................................... 75

Figure 3-36: Residential dwellings shown within approximately three kilometres ofGannabosch Vlakte 51, mostly located in the south and east along the Vink andNoree Rivers. .................................................................................................. 76

Figure 3-37: Human habitations in the vicinity of the proposed Gannabosch Clay Mine andRobertson Brick Factory. The dots represent established homesteads. Thediameter of the circle is 2 km, centred on the site of the quarry. Green starindicates Manager’s residence, blue cross indicates Cape Lime Works offices77

Figure 4-1: Offsite provision of services showing water and electrical source and air emissionmonitoring points. ............................................................................................ 79

Figure 4-2: On site infrastructure showing proposed trenching methodology. ..................... 80

Figure 4-3: Shows the traditional bench mining practiced at clay quarries. The proposed quarryon Gannabosch Vlakte will likely be mined in a similar fashion with the storagesump being located on the lowest level in the southern corner. ....................... 81

Figure 4-4: Conceptual storm water management plan....................................................... 83

Figure 4-5: Simplified flowchart of brick making process..................................................... 85

Figure 4-6: Locality of clay mine sites and brick manufacturing plants, showing a paucity ofmanufactures in close proximity to Robertson. ................................................ 89

Figure 4-7: Prospecting test pits drilled at 29 sites to determine depth of clay ore. ............. 90

Figure 4-8: A cross sectional view of the western sector showing a 51 % yield ratio. .......... 91

Figure 4-9: A cross sectional view of the eastern sector showing a 72 % yield ratio. .......... 91

Figure 5-1: Advertisements posted in local and regional newspapers and on the affectedproperty of the EIA and PPP process. ............................................................. 97

Figure 7-1: Mineral Resources map of the Western Cape (Cole, 2014). ........................... 114

Figure 7-2: Positions of additional potential brick clay resource sites in the region surroundingthe proposed Gannabosch clay mine. Pink, orange and yellow areas representTierberg, Gydo and Waboomberg Formation sites respectively, maroon polygonsrepresent associated farms, and the red polygon represents Gannabosch Vlakte51.................................................................................................................. 116

Figure A-0-1: Regional Topographic Map .............................................................................. II

Figure A-0-2: Locality Map.................................................................................................... III

Figure A-0-3: Geology Map...................................................................................................IV

Figure A-0-4: Land type/soil cover Map .................................................................................V

Figure A-0-5: Vegetation Map ...............................................................................................VI

Figure A-0-6: Biodiversity Map.............................................................................................VII

Figure A-0-7: Mine Layout Map...........................................................................................VIII


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LIST OF TABLES

Table 1-1: EAP and Company details .................................................................................... 1

Table 1-2: Applicant Details ................................................................................................... 1

Table 1-3: Property Details .................................................................................................... 1

Table 1-4: Content of the EIA Report as required by the EIA Regulation, 2014...................... 6

Table 1-5: Content of the Environmental Management Programme (EMPr) report as requiredby the EMPr Regulation, 2014........................................................................... 9

Table 2-1 : Listing Notice 1 (No. R. 983) Triggers in terms of 24 (2) and 24D ...................... 13



Table 2-4: WCPSDF policies ............................................................................................... 18

Table 2-5: Environmental Authorisations, Possible Permits and Licences Required ............ 22

Table 3-1: Specialist Studies............................................................................................... 24

Table 3-2: Stratigraphy ........................................................................................................ 33

Table 3-3: Localities of residents and tourism facilities within immediate area of operation. 54

Table 3-4 : Noise limits per sector (SANS-10103:2003) ....................................................... 56

Table 3-5: Level of sound intensity with increasing distance from source............................ 57

Table 3-6: Economic activity by sector for Cape Winelands District Municipality (CWDM, 2015)........................................................................................................................ 60

Table 3-7: GDP vs net employment ..................................................................................... 60

Table 3-8: Current Brick Suppliers ..................................................................................... 61

Table 3-9: Future developments and estimated brick demand ............................................ 61

Table 3-10: Employment per skill sector (2005 – 2013) in Langeberg LM........................... 62

Table 3-11 - HIV, AIDS & Tuberculosis prevalence and care (2015).................................... 63

Table 3-12: Toilet availability for Langeberg Local Municipality (WCGPT, 2015).................. 63

Table 3-13 Types of Housing Structure within Langeberg Local Municipality (WCGPT, 2015)........................................................................................................................ 64

Table 3-14: Neighbouring property land use ........................................................................ 71

Table 4-1: Gantt chart for planned project management phases.......................................... 87

Table 4-2: Clay Composition................................................................................................ 88

Table 5-1: Stakeholder engagement activities undertaken during the Scoping Phase......... 93

Table 6-1: Determination of the consequence of an impact............................................... 102

Table 6-2: Methodology to determine the overall Consequence Rating............................. 102

Table 6-3: Probability Classification .................................................................................. 102

Table 6-4: Impact Significance Rating................................................................................ 103


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Table 6-5: Freshwater ecology/hydrological impacts.......................................................... 104

Table 6-6: Flora and Fauna impacts .................................................................................. 106

Table 6-7: Impact on soils.................................................................................................. 108

Table 6-8: Heritage impacts ............................................................................................... 109

Table 6-9: Socio-economic impacts ................................................................................... 109

Table 6-10: Air Quality ...................................................................................................... 110

Table 6-11: Noise ............................................................................................................. 111

Table 6-12: Visual Impact ................................................................................................. 111

Table 6-13: Traffic impact ................................................................................................. 112

Table 7-1: Details of potential additional brick clay resource sites in the region surrounding theproposed Gannabosch clay mine (Site ID refers to Figure 7-2). .................... 116

Table 8-1: Soils EMPr ........................................................................................................ 120

Table 8-2: Water EMPr ...................................................................................................... 122

Table 8-3: Fauna and Flora EMPr...................................................................................... 124

Table 8-4: Heritage EMPr .................................................................................................. 126

Table 8-5: Air Quality and Dust Suppression EMPr............................................................ 126

Table 8-6: Mine Waste EMPr ............................................................................................ 128

Table 8-7: Noise Emission EMPr ...................................................................................... 128

Table 8-8: Visual Control EMPr......................................................................................... 129

Table 8-9: Traffic Management EMPr ................................................................................ 130

Table 8-10: Environmental Monitoring programmes........................................................... 131

Table 9-1: Determination of the quantum for the financial provision of final rehabilitation... 135

Table 9-2: Progressive forecast of Environmental Cost for the first ten years .................... 136

Table 9-3: Social development financial quantum.............................................................. 137

Table B-0-1: Interested and Affected Parties .........................................................................X


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LIST OF ABBREVIATIONS° - degrees°C - Degrees Celsius% - percentage~ - ApproximatelyAFF - Agricultural Forestry and FishingARC - Agricultural Research CouncilCBA - Critical Biodiversity AreaBA - Basic AssessmentBGCMA - Breede Gourtiz Catchment Management AgencyBID - Background Information Documentcm - centimetresDEA&DP - Department of Environmental Affairs and Development Planning (DEADP)DMR - Department of Minerals and ResourcesDWA - Department of Water Affairs (now DWS)DWS - Department of Water and SanitationEA - Environmental AuthorisationEAP - Environmental Assessment PractitionerEIA - Environmental Impact AssessmentEIR - Environmental Impact ReportEMP - Environmental Management PlanEMPr - Environmental Management ProgramEIS - Environmental Impact StudyESA - Ecological Support AreaFSBP - Fine Scale biodiversity plansGCM - Gannabosch Clay MineGDP - Gross Domestic ProductGN - General Notice (w.r.t Legal Acts)HIA - Heritage Impact AssessmentHWC - Heritage Western Capeha - HectaresIAP - Interested and Affected PartiesIDP - Integrated Development Planm - metreskm - kilometreKm2 - Square kilometreKm/h - kilometers an hourLM - Local MunicipalityLoM - Life of Minem2 - Square metresm3 - Cubic metresm/s - Metres per secondmS/m - Millisiemens per metreMa - Million Yearsmamsl - Metres above mean sea levelMAP - Mean annual precipitationMAPE - Mean annual precipitation-evaporation indexMASMS - Mean annual soil measurement stressMAT - Mean annual temperaturembgl - Metres below ground levelmm - millimetersMPRDA - Mineral and Petroleum Resources Development ActMt - Million Tons

NEMA - National Environmental Management ActNEMBA - National Environmental Management Biodiversity ActNHRA - National Heritage Resource AgencyNID - Notice of Intent to Develop


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NWA - National Water ActPPP - Public Participation ProcessSABAP2 - South African Bird Atlas Project 2SAHRA - South African Heritage Resource AgencySAMRAD - South African Mineral Resources Administration SystemSANBI - South African National Biodiversity InstituteS&EIR - Scoping and Environmental Impact ReportTMG - Table Mountain GroupToC - Theory of ConstraintToR - Terms of ReferenceWCDM - West Coast District MunicipalityWCPSDF - Western Cape Provincial Spatial Development FrameworkWUA - Water Use AuthorisationWUL - Water Use Licencew.r.t - With reference toUA - Umvoto AfricaVU - Vulnerable (Species status)


Final EIA and EMP Report Page 1

1. INTRODUCTION

1.1 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER

Table 1-1: EAP and Company details

Company Details:Company: Umvoto Africa (Pty) Ltd.Postal Address: PO Box 61

Muizenberg, 7945Phone: +27(0)21 709 6700Email: [email protected]

Details and Expertise of the EAP:Name: Paul LeeQualifications: BSc Honours Environmental and Geographical SciencesExperience: See CV in Appendix EProfessional Registration EAPSA & SACNASP 400124/09

1.2 CONTACT INFORMATION AND LOCATION OF THE OPERATION

Table 1-2: Applicant Details

Company Details:Company: Gannabosch Clay Mine (Pty) Ltd.Registration No. 2015/446995/07Contact persons Morne SwanepoelPostal Address: P O Box 234

Robertson, 6705Phone: +27 (0)82 374 6949Email [email protected]

1.3 PROPERTY DETAILS

The proposed clay mine is located on a portion of the farm Gannabosch Vlakte 51,approximately 14 km west of the town centre of Robertson in the Western Cape, SouthAfrica. The property lies ~700 m to the northeast of the R60 national road, and can beaccessed via the Agter-Vinkrivier turnoff. See Figure 1-1, Figure 1-2 and Figure 1-3below for a graphical indication of the location and property boundary. Figure 1-3represents the planned mine layout as per MPRDA Regulation 2(2) plan.

Table 1-3: Property Details

Company Details:Farm Name GANNABOSCH VLAKTE 51Farm Number 51Portion N/aLocal Authority Langeberg MunicipalityRegistration Division N/aExtent 117.5119 hectaresSG 21-digit code C06500000000005100000Landowner H R Grobbelaar Family TrustTitle Deed T 4135995



Figure 1-1: Locality of the farm Gannabosch Vlakte 51 on which the proposed clay minewould be situated (see Figure A-0-1 for larger view).

Figure 1-2: Zoomed in location of Gannabosch Clay Mine (See Figure A-0-2 for larger view).



Figure 1-3: Mine layout as required by regulation 2(2) plan of Gannabosch Clay Mine (seeFigure A-0-7 for larger view).

1.4 HISTORY AND BACKGROUND INFORMATION OF THE MINING OPERATION

An application by Gannabosch Clay Mine (Pty) Ltd (GCM) for the mining of brick/shaleclay over a portion of the farm Gannabosch Vlakte, portion 51 was submitted to the DMRin February 2016. The application was accepted by the DMR (WC 10082 MR) on 2016-02-28 and GCM were instructed to complete the required environmental managementprogramme report (EMP).

The proposed development of the GCM clay mine and an associated brick manufacturingfacility by Robertson Bakstene (Pty) Ltd intends to allow the manufacture of clay bricks forthe regional supply to the construction industry within the surrounding towns.

Numerous specialist studies were commissioned and a 30 day public consultation processwas undertaken. Recommendations from the various specialists and the feedback fromthe consultation process were utilised in the compilation of a Draft EIA Report and EMP,which was circulated to registered Interested and Affected Parties (IAPs) andStakeholders for comment on 2016-07-22. A public meeting was convened in theRobertson Municipal Library on 2016-08-10.

Following the public meeting and in response to the comment and feedback from the IAPsand Stakeholders, it was decided to alter the position, orientation and size of theconcession to accommodate concerns over environmental sensitivities that wereidentified in the scoping process. The DMR, as the decision making authority, dulyrequested an amended EIA Report, additional specialist studies and a further round ofPublic Participation.



To allow for the preparation of this documentation, the authority granted an extension oftime for the hand in of the Final EIA Report until the 6 January 2017, under Regulation 3-(7) and 23-(1) (b) of the National Environmental Management Act (107 of 1998). Theoriginal mine concession area is shown in Figure 1-4, while the amended and expandedfootprint is shown in Figure 1-3.

Figure 1-4: Original Mine Layout Plan as per submission in February 2016.

The intent of this EIA and EMP report is to:

Compile a document that aligns to the requirements of the Mineral and PetroleumResources Development Act, (MPRDA) Act No. 28 or 2002 and the NationalEnvironmental Management Act (NEMA), Act No. 107 of 1998, as amended.

Provide up to date, baseline information on the mining area as determined byvarious specialists;

Document the intended mining activities over the area; Undertake an impact assessment based on the intended mining activities; and Provide realistic and attainable management measures for the future mining

operations.

The scope of the EMP aims to cover the impacts and the management measures of themining activities only. The transportation of the mined products from the proposed mineto the brick manufacturing facility and the manufacture of bricks are covered under aseparate EA application that is submitted to the DEA & DP. Notwithstanding thisseparation, an overview of the process of the brick making facility is described underSection 4.1.5 of this report in order to provide the IAP’s with an understanding of how thetwo process will interact and to address the issue of cumulative impact.



1.5 PURPOSE OF REPORT

(As described in Appendix 3 and 4 of Government Notice R982 of 4 December 2014)

The objective of the environmental impact assessment process is to;

a) Determine the policy and legislative context within which the activity is located anddocument how the proposed activity complies with, and responds to, the policyand legislative context;

b) Describe the need and desirability of the proposed activity, including the need anddesirability of the activity in the context of the preferred location;

c) Identify the location of the development footprint within the preferred site based onan impact and risk assessment process inclusive of cumulative impacts and aranking process of all the identified development footprint alternatives focusing onthe geographical, physical, biological, social, economic, heritage and culturalaspects of the environment;

d) Determine the:i) Nature, significance, consequence, extent, duration and probability of the

impacts occurring and to inform identified preferred alternatives; andii) Degree to which these impacts-

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

e) Identify the most ideal location for the activity within the preferred site based onthe lowest level of environmental sensitivity identified during the assessment;

f) Identify, assess, and rank the impacts the activity will impose on the preferredlocation through the life of the activity;

g) Identify suitable measures to avoid, manage or mitigate identified impacts; and;h) Identify residual risks that need to be managed and monitored.

1.6 STRUCTURE OF THIS REPORT

An overview of how the report is laid out in terms of the TOC is given below

Section 1: Introduction

Provides an introduction and background to the proposed project.

Section 2: Governance Framework and Environmental Process

Provides a brief summary and interpretation of the relevant legislation.

Section 3: Baseline Assessment

Biophysical and socio-economic characteristics of the affected environmentagainst which impacts are assessed.

Section 4: Project Description

Location and current status of the project area, summary of the surrounding landuses, motivation, desirability and need for, and description of, the proposedproject.



Section 5: Stakeholder Engagement

Details the stakeholder engagement summarises stakeholder comments.

Section 6: Environmental Impact Assessment (EIA)

Describes the specialist studies and assesses the potential impacts of the project.

Section 7: Alternate Land Use and Development

Describes the specialist studies and assesses the potential of developing the mineon alternative clay resources.

Section 8: Environmental Management and Monitoring Programme (EMPr)

Provides an Environmental Impact Statement and methods of mitigation andresponsibility and compliance of the proponent.

Section 9: Financial Provision Estimations

Provides a quantum for the rehabilitation and closure of the mine, a quantum forthe provision of a Social and Labour Plan and how these will be financed.

Section 10: Conclusions and Recommendations

Provides a summary of the key findings of the report, outlines the options andmakes informed recommendations to the decision making authority, the DMR.

1.7 CONTENT OF REPORT

Stipulated below in Table 1-4 and Table 1-5 is the required content and the respectivelocations within the EIA and EMPr report as required per Section 3 of Appendix 3 andSection 1 of Appendix 4 of Government Notice No 982 of the EIA Regulations, 2014.

Table 1-4: Content of the EIA Report as required by the EIA Regulation, 2014

GN 982,Appendix 3:EIA

Item DocumentReference:

(3) (a) (i) Details of the EAP who prepared the report(ii) The expertise of the EAP to carry out an environmental

impact assessment

Table 1-1

Table 1-1(3) (b) The location of the activity, including:

(i) the 21 digit Surveyor General code of each cadastral landparcel;

(ii) Where available, the physical address and farm name;and

(iii) Where the required information in items (i) and (ii) is notavailable, the coordinates of the boundary of the propertyor properties;

Table 1-3

Table 1-3

Figure A-0-7

(3) (c) A plan which locates the proposed activity or activitiesapplied for as well as the associated structures andinfrastructure at an appropriate scale, or, if it is-(i) a linear activity, a description and coordinates of the

corridor in which the proposed activity or activities is to beundertaken; n/a





(ii) on land where the property has not been defined, thecoordinates within which the activity is to be undertaken; Figure A-0-7

(3) (d) a description of the scope of the proposed activity, including:(i) All listed and specified activities triggered and being

applied for; and(ii) A description of the associated structures and

infrastructure related to the development;

Table 2-1

Table 2-2

Table 2-3n/a

(3) (e) A description of the policy and legislative context within whichthe development is located and an explanation of how theproposed development complies with and responds to thelegislation and policy context;

Section 2

(3) (f) a motivation for the need and desirability for the proposeddevelopment, including the need and desirability of theactivity in the context of the preferred location;

Section 4.3

(3) (g) a motivation for the preferred development footprint within theapproved site; Section 7.3.1

(3) (h) A full description of the process followed to reach theproposed development footprint within the approved site,including:(i) details of the development footprint alternatives

considered;(ii) details of the public participation process undertaken in

terms of regulation 41 of the Regulations, includingcopies of the supporting documents and inputs;

(iii) a summary of the issues raised by interested andaffected parties, and an indication of the manner inwhich the issues were incorporated, or the reasons fornot including them;

(iv) the environmental attributes associated with thedevelopment footprint alternatives focusing on thegeographical, physical, biological, social, economic,heritage and cultural aspects;

(v) the impacts and risks identified including the nature,significance, consequence, extent, duration andprobability of the impacts, including the degree to whichthese impacts

a) can be reversed;b) may cause irreplaceable loss of resources; andc) can be avoided, managed or mitigated;

(vi) the methodology used in determining and ranking thenature, significance,

(vii) positive and negative impacts that the proposed activityand alternatives will have on the environment and onthe community that may be affected focusing on thegeographical, physical, biological, social, economic,heritage and cultural aspects; consequences, extent,duration and probability of potential environmentalimpacts and risks;

(viii) the possible mitigation measures that could be appliedand level of residual risk;

(ix) if no alternative development locations for the activitywere investigated, the motivation for not consideringsuch; and

Section 7.3.1Section 5 andAppendix C-Summary ofRaised ConcernAppendix C-Summary ofRaised ConcernSection 6

Section 3 andSection 6

Section 8.2

Section 6.2

Section 6

Section 6

Section 7.2





(x) a concluding statement indicating the preferredalternative development location within the approvedsite;

Section 10

(3) (i) a full description of the process undertaken to identify,assess and rank the impacts the activity and associatedstructures and infrastructure will impose on the preferredlocation through the life of the activity, including:(i) a description of all environmental issues and risks that

were identified during the environmental impactassessment process; and

(ii) an assessment of the significance of each issue and riskand an indication of the extent to which the issue andrisk could be avoided or addressed by the adoption ofmitigation measures;

Section 6.1.1

Section 6

Section 6

(3) (j) An assessment of each identified potentially significantimpact and risk, including(i) cumulative impacts;(ii) the nature, significance and consequences of the impact

and risk;(iii) the extent and duration of the impact and risk;(iv) the probability of the impact and risk occurring;(v) the degree to which the impact and risk can be

reversed;(vi) the degree to which the impact and risk may cause

irreplaceable loss of resources; and(vii) the degree to which the impact and risk can be

mitigated;

Section 6.3.9

Section 6.3.9

Section 6.3.9Section 6.3.9Section 6.3.9

Section 6.3.9

Section 6.3.9

(3) (k) Where applicable, a summary of the findings andrecommendations of any specialist report complying withAppendix 6 to these Regulations and an indication as to howthese findings and recommendations have been included inthe final assessment report;

Section 7.3.1

(3) (l) An environmental impact statement which contains:(i) a summary of the key findings of the environmental

impact assessment:(ii) a map at an appropriate scale which superimposes the

proposed activity and it associated structures andinfrastructure on the environmental sensitivities of thepreferred site indicating any areas that should beavoided, including buffers; and

(iii) a summary of the positive and negative impacts andrisks of the proposed activity and identified alternatives;

Section 6.3.9

Section 4Figure 4-1 andFigure 4-2

Section 6.3.9

(3) (m) based on the assessment, and where applicable,recommendations from specialist reports, the recording ofproposed impact management objectives, and the impactmanagement outcomes for the development for inclusion inthe EMPr as well as for inclusion as conditions ofauthorisation;

Section 8.3

(3) (n) the final proposed alternatives which respond to the impactmanagement measures, avoidance, and mitigation measuresidentified through the assessment;

Section 7.3.1

(3) (o) any aspects which were conditional to the findings of theassessment either by the EAP or specialist which are to beincluded as conditions of authorisation n/a





(3) (p) a description of any assumptions, uncertainties and gaps inknowledge which relate to the assessment and mitigationmeasures proposed;

Section 1.8

(3) (q) a reasoned opinion as to whether the proposed activityshould or should not be authorised, and if the opinion is that itshould be authorised, any conditions that should be made inrespect of that authorisation;

Section 10

(3) (r) where the proposed activity does not include operationalaspects, the period for which the environmental authorisationis required and the date on which the activity will beconcluded and the post construction monitoring requirementsfinalised;

Section 4.1.4 andSection 8.4

(3) (s) An undertaking under oath or affirmation by the EAP inrelation to:(i) the correctness of the information provided in the reports;(ii) the inclusion of comments and inputs from stakeholders

and l&APs;(iii) the inclusion of inputs and recommendations from the

specialist reports where relevant; and(iv) any information provided by the EAP to interested and

affected parties and any responses by the EAP tocomments or inputs made by interested or affectedparties;

Section 1.1

(3) (t) where applicable, details of any financial provisions for therehabilitation, closure, and ongoing post decommissioningmanagement of negative environmental impacts;

Section 9.1 andSection 9.2

(3) (u) an indication of any deviation from the approved scopingreport, including the plan of study, including:(i) any deviation from the methodology used in determining

the significance of potential environmental impacts andrisks; and

(ii) a motivation for the deviation;

n/a

(3) (v) any specific information that may be required by thecompetent authority; and n/a

(3) (w) any other matters required in terms of section 24(4)(a) and(b) of the Act. n/a

Table 1-5: Content of the Environmental Management Programme (EMPr) report as requiredby the EMPr Regulation, 2014

GN 982,Appendix 4:EMPr


(1) (a) details of:(i) the EAP who prepared the EMPr; and(ii) the expertise of that EAP to prepare an EMPr,

including a curriculum vitae;

Table 1-1

(1) (b) a detailed description of the aspects of the activity that arecovered by the EMPr as identified by the project description; Section 8.1

(1) (c) a map at an appropriate scale which superimposes theproposed activity, its associated structures, and infrastructureon the environmental sensitivities of the preferred site,indicating any areas that any areas that should be avoided,including buffers;

Figure 4-1 andFigure 4-2



GN 982,Appendix 4:EMPr


(1) (d) a description of the impact management objectives, includingmanagement statements, identifying the impacts and risksthat need to be avoided, managed and mitigated as identifiedthrough the environmental impact assessment process for allphases of the development including:(i) planning and design;(ii) pre-construction activities;(iii) construction activities;(iv) rehabilitation of the environment after construction and

where applicable post closure; and(v) where relevant, operation activities;

Section 8.2

(1) (e) a description and identification of impact managementoutcomes required for the aspects contemplated inparagraph (d);

Table 8-10

(1) (f) a description of proposed impact management actions,identifying the manner in which the impact managementobjectives and outcomes contemplated in paragraphs (d) and(e) will be achieved, and must, where applicable, includeactions to:(i) avoid, modify, remedy, control or stop any action,

activity or process which causes pollution orenvironmental degradation;

(ii) comply with any prescribed environmental managementstandards or practices;

(iii) comply with any applicable provisions of the Actregarding closure, where applicable; and

(iv) comply with any provisions of the Act regarding financialprovisions for rehabilitation, where applicable;

Section 8.2

Table 9-2

(1) (g) the method of monitoring the implementation of the impactmanagement actions contemplated in paragraph (f); Table 8-10

(1) (h) the frequency of monitoring the implementation of the impactmanagement actions contemplated in paragraph (f); Section 8.2

(1) (i) an indication of the persons who will be responsible for theimplementation of the impact management actions; Section 8.2

(1) (j) the time periods within which the impact management actionscontemplated in paragraph (f) must be implemented; Section 8.2

(1) (k) the mechanism for monitoring compliance with the impactmanagement actions contemplated in paragraph (f); Section 8.3

(1) (l) a program for reporting on compliance, taking into accountthe requirements as prescribed by the Regulations; Section 8.4

(1) (m) an environmental awareness plan describing the manner inwhich:(i) the applicant intends to inform his or her employees of

any environmental risk which may result from their work;and

(ii) risks must be dealt with in order to avoid pollution or thedegradation of the environment; and

Section 8.2

(1) (n) any specific information that may be required by thecompetent authority n/a



1.8 ASSUMPTIONS AND LIMITATION

As is standard, the report is based on a number of assumptions and is subject to certainlimitations. These are as follows:

Information provided by the consultants and specialists is assumed to be accurateand correct;

Assessment of the significance of impacts of the mining on the affectedenvironment has been based on the assumption that the mine activities will beconfined to those described in this EIA Report;

Where detailed design information is not available, the precautionary principle, tooverstates negative impacts and understates benefits, has been adopted;

It is assumed that the stakeholder engagement process undertaken, during theS&EIR process, has identified all relevant concerns of stakeholders; and

GCM will in good faith implement the agreed mitigation measures identified in thisreport, commit sufficient resources and employ suitably qualified personnel toensure compliance.

Notwithstanding the above, Umvoto Africa is confident that these assumptions andlimitations do not compromise the overall findings of the report.



2 GOVERNANCE FRAMEWORK AND ENVIRONMENTALPROCESS

2.1 LEGAL REQUIREMENT

There are a number of regulatory requirements at local, provincial and national level withwhich the proposed development will have to conform. Some of the key legal requirementsinclude the following:

National Environmental Management Act 107 of 1998, as amended (NEMA); EIA Regulations, promulgated in terms of NEMA (Notice R.982, 2014); National Water Act 36 of 1998 (NWA); National Heritage Resources Act 25 of 1999 (NHRA); National Environmental Management: Biodiversity Act 10 of 2004 (NEM:BA) and National Environmental Management: Air Quality Act 39 of 2004, as amended

2014 (NEM:AQA).

A brief summary of the relevant Acts and Regulations that are applicable to this study isprovided below. Note that other legislative requirements may also pertain to the proposedproject. As such, the summary provided below is not intended to be definitive orexhaustive, and serves only to highlight key environmental legislation and obligations.

2.1.1 National Environmental Management Act 107 of 1998 (NEMA);NEMA establishes a set of principles that all authorities have to consider when exercisingtheir powers. These include the following:

Development must be sustainable; Pollution must be avoided or minimised and remedied; Waste must be avoided or minimised, reused or recycled; Negative impacts must be minimised; and Responsibility for the environmental consequences of a policy, project, product or

service applies throughout its life cycle.

Section 28(1) states that “every person who causes, has caused or may cause significantpollution or degradation of the environment must take reasonable measures to preventsuch pollution or degradation from occurring, continuing or recurring”. If suchdegradation/pollution cannot be prevented, then appropriate measures must be taken tominimise or rectify such pollution. These measures may include:

Assessing the impact on the environment; Informing and educating employees about the environmental risks of their work

and ways of minimising these risks; Ceasing, modifying or controlling actions which cause pollution/degradation; Containing pollutants or preventing movement of pollutants; Eliminating the source of pollution; and Remedying the effects of the pollution.

Legal requirements for the Gannabosch Clay Mine:

The proponent is obligated towards and has the responsibility to ensure that the proposedactivities conform the principles of NEMA as described above and is obliged to take pre-emptive action to ensure that the impacts associated with the mining development aretaken into account and where possible mitigated.



2.1.2 EIA Regulations, promulgated in terms of NEMA;Sections 24 and 44 of NEMA make provision for the promulgation of regulations thatidentify activities, which may not commence without an Environmental Authorisation (EA)issued by the competent authority (DEA&DP, or DMR). In this context, the EIARegulations, 2014 (GN R.982, which came into effect on 8 December 2014), promulgatedin terms of NEMA, govern the process, methodologies and requirements for theundertaking of EIAs in support of EA applications. The EIA Regulations are accompaniedby Listing Notices 1-3 that list activities that require EA, these are termed “NEMA listedactivities”.

There are two alternative authorisation processes and depending on the type of activitythat is proposed, either a Basic Assessment (BA) process or a Scoping and EnvironmentalImpact Report (S&EIR) process is required to obtain EA. Listing Notice 1 (GN 983 of2014) lists activities that require a BA process, while Listing Notice 2 (GN 984 of 2014)lists activities that require S&EIR. Listing Notice 3 (GN 985 of 2014) lists activities incertain sensitive geographic areas that require a BA process. The regulations for bothprocesses – BA and S&EIR – stipulate that:

Public participation must be undertaken at various stages of the assessmentprocess;

The assessment must be conducted by an independent EAP; The relevant authorities must respond to applications and submissions within

stipulated time frames; Decisions taken by the authorities can be appealed by the proponent or any other

Interested and Affected Party (IAP) and A draft Environmental Management Programme (EMP) must be compiled and

released for public comment.

The Gannabosch Clay Mine project is obliged to apply for EA for listed activities in termsof Listing Notices 1, & 2 (R.983 and R.984 as per NEMA Regulations R.982, 2014) interms of sections 24(4) and 24(D) of NEMA 107/1998 (Table 2-1 and Table 2-2) andundertake a Scoping and EIA process in support of said application. No activities in ListingNotice 3 (R. 985) are triggered (see Table 2-3).

Table 2-1 : Listing Notice 1 (No. R. 983) Triggers in terms of 24 (2) and 24D

ActivityNumber

Activity description Identification of CompetentAuthority

12 The development of(ii) channels exceeding 100 m2 in size,(xii) infrastructure and structures with a physicalfootprint of 100 m2 or more;where such development occurs(a) within a watercourse

Minister responsible formineral resources (DMR),as activity is linked toextraction of a mineralresource

19 The infilling or depositing of any material of morethan 5 cubic metres into, or the dredging,excavation, removal or moving of soil, sand,shells, shell grit, pebbles or rock of more than 5cubic metres from(i) a watercourse;


22 The decommissioning of any activity requiring-(i) A closure certificate in terms of section 43 ofthe Mineral and Petroleum ResourcesDevelopment Act, 2002 (Act No. 28 of 2002):

Minister responsible formineral resources (DMR)



ActivityNumber


27 The clearance of an area of 1 hectare or more,but less than 20 hectares of indigenousvegetation,


28 Residential, mixed, retail, commercial, industrialor institutional developments where such landwas used for agriculture or afforestation on orafter 01 April 1998 and where suchdevelopment:(ii) will occur outside an urban area, where thetotal land to be developed is bigger than 1hectare;



ActivityNumber


17 Activity which requires a mining right ascontemplated in section 22 of the Mineral andPetroleum Resources Development Act, 2002:The abstraction of shale/brick clay.

Minister responsible formineral resources (DMR)


ActivityNumber


None Bioregional plans have not been adopted in theWestern Cape

2.1.3 National Water Act 36 of 1998 (NWA);Water use in South Africa is controlled by the NWA. The executive authority is theDepartment of Water & Sanitation (DWS). The NWA recognises that water is a limitedresource, which is limited and unevenly distributed throughout South Africa. The Actempowers the DWS to put measures in place to achieve sustainable and equitable use ofwater to the benefit of all users and to ensure protection of the aquatic ecosystemsassociated with South Africa’s water resources. The provisions of the Act are aimed atdiscouraging pollution and wastage of water resources. In terms of the Act, a land user,occupier or owner of land where an activity that causes or has the potential to causepollution of a water resource has a duty to take measures to prevent pollution fromoccurring. If these measures are not taken, the responsible authority may do whatever isnecessary to prevent the pollution or remedy its effects, and to recover all reasonablecosts from the responsible party.

Section 21 of the NWA No 36 of 1998 specifies a number of water uses. Relevant for themining activity might be the following:

(c) Impeding or diverting the flow of water in a watercourse;(f) Discharging waste or water containing waste into a water resource;(i) Altering the bed, banks, course or characteristics of a watercourse and(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



Activities that modify the bed, banks or characteristics of a watercourse, or which impedeor divert the flow of water in a watercourse, are considered water use under Section 21and would require an authorisation from the Department of Water & Sanitation (DWS) interms of the National Water Act (Act No. 36 of 1998) (NWA). If it can be demonstratedthat the proposed activities will not have significant environmental impacts, are located>500 m from any wetlands, will have no detrimental effect on biota, and that adequateprovision has been made for environmental management and rehabilitation, a GeneralAuthorisation as per Section 39 of the NWA would be possible. Failing that, a Water UseLicence for Section 21(c) and (i) “water uses” would be required and it would be necessaryto initiate the WULA process with the Breede Gouritz Catchment Management Agency(BGCMA).

The requirements for Section 21 (f) and (j) would depend on the stormwater and ingresswater management on the mine. It is envisaged that these authorisations are not required(see Section 4.1.3).

2.1.4 National Heritage Resources Act 25 of 1999 (NHRA)The protection and management of South Africa’s heritage resources are controlled bythe Natural Heritage Resources Act no.25 of 1998 (NHRA). The enforcing authority forthis act is the South African National Heritage Resources Agency (SAHRA) and in theWestern Cape, SAHRA has delegated this authority to Heritage Western Cape (HWC).In terms of the Act, historically important features such as graves, trees, archaeologicalartefacts/sites and fossil beds are protected. Similarly, culturally significant symbols,spaces and landscapes are also provided protection.

Section 38 of the NHRA requires that any person who intends to undertake certaincategories of development must notify SAHRA and/or HWC at the very earliest stage ofinitiating such a development and must furnish details of the location, nature and extentof the proposed development. HWC has designed a Notification of Intent to Develop (NID)to assist the developer in providing the necessary information to enable HWC to decidewhether a Heritage Impact Assessment (HIA) will be required.

Section 38 also makes provision for the assessment of heritage impacts as part of an EIAprocess and indicates that, if such an assessment is deemed adequate, a separate HIAis not required. There is however the requirement in terms of Section 38 (8) for theconsenting authority (in this case the DMR) to ensure that the evaluation of impacts onthe heritage resources fulfils the requirements of the relevant heritage resources authority(in this case HWC), and that the comments and recommendations of the heritageresources authority are considered prior to the granting of the consent.

Section 38(1) of the National Heritage Resources Act 25 of 1999 (NHRA) specifiesactivities that trigger the need for a Notice of Intent to Develop (NID). The proposed projecttriggers several activities, including:

a) Construction of a road/ linear structure exceeding 300m in lengthc) Any development or other activity which will change the character of a site

(i) exceeding 5000 m2 in extentd) The re-zoning of a site exceeding 10 000m2 in extente) Any other category of development provided for in the regulations by SAHARA

or a provincial heritage resources authority (i.e. Mining)

An archaeological specialist NID report listing the activities was submitted on behalf ofGCM to Heritage Western Cape in 5 May 2016 by Asha Consulting (Pty) Ltd (AnnexureD-1: First Notice of Intent to Develop). The recommendation was that a Heritage Impact



Assessment (HIA) is not required since the site was deemed to have low historical value.A response confirming that was received on 13 May 2016 (Appendix D-1: HeritageWestern Cape).

2.1.5 National Environmental Management: Biodiversity Act 10 of 2004 (NEMBA);The purpose of the NEMBA is to provide for the management and conservation of SouthAfrica’s biodiversity and the protection of species and ecosystems that warrant nationalprotection. The NEMBA makes provision for the publication of bioregional plans and thelisting of ecosystems and species that are threatened or in need of protection. Threatenedor Protected Species Regulations (2007), Guidelines for the determination of bioregionsand the preparation and publication of bioregional plans (2009) and a National List ofEcosystems that are Threatened and in Need of Protection (2011) have been promulgatedin terms of NEMBA.

A published bioregional plan is a spatial plan indicating terrestrial and aquatic features inthe landscape that are critical for conserving biodiversity and maintaining ecosystemfunctioning. These areas are referred to as Critical Biodiversity Areas (CBAs) in terms ofNEMBA. Bioregional plans provide guidelines for avoiding the loss or degradation ofnatural habitat in CBAs with the aim of informing, EIAs.

Permits to carry out a restricted activity involving listed threatened or protected species oralien species may only be issued after an assessment of risks and potential impacts onbiodiversity has been undertaken, which is the purpose of this EIA.

The Gannabosch Clay mine has a responsibility to provide for the protection ofecosystems that are threatened or in need of protection to ensure the maintenance of theirecological integrity. The proposed mine footprint falls within a critical biodiversity area(CBA) which form a natural corridor between the Langeberg Mountains and Breede riverand includes plant species of the Breede alluvium Renosterveld (Vulnerable) andRobertson Karoo (Least Threatened) as noted and discussed in the Specialist BotanicalReport (Annexure E-1: First Botanical Specialist Report).

2.1.6 National Environmental Management: Air Quality Act 39 of 2004The Air Quality Act aligns itself with the National Environmental Management Act (section2) and section 24(b) of the Constitution by promoting ecologically sustainabledevelopment, whilst promoting justifiable economic and social development. This is donethrough the protection and enhancement of the air quality on a national scale, as well asthe prevention of air pollution and ecological degradation.

Sections 9 to 11 deal with national, provincial, and local air quality standards, and makesprovisions for the minister, MEC, or municipality, to establish standards for air qualitywithin their relevant spheres of governance. The Gannabosch clay mine, falling within theLangeberg Municipalities scope of governance, would need to apply to any air qualitystandards laid out by the Municipality. If the Municipality does not have relevantstandards, then the provincial standards will apply.

Section 21 of the act states that the minister must publish a list of activities which result inatmospheric emissions that may have a detrimental effect on the environment. This listhas been published and amended as per GN R551 of 2015 “List of activities which resultin atmospheric emissions which have or may have a significant effect on the environment,including health, social conditions, economic conditions, ecological conditions, or culturalheritage”. Any listing under this notice requires an atmospheric emissions licence.



Whilst the mining activity itself does not trigger any of the listings, the planned brick makingfactory on the same property does, and thus as part of the cumulative impacts of thisreport is being included. Furthermore, sections 32 to 34 of the Air Quality Act apply to themine and thus the mine must establish a dust monitoring process as per section 32,rehabilitation as per section 33, and control the impact of noise as per section 34. Thelicencing authority for the Gannabosch Vlakte development is the Cape Winelands DistrictMunicipality.

Section 51 of the act outlines punishable offences under the act. These offences are listedin section 51 of the act and if committed may result in a fine of five million rand orimprisonment of no more than 5 years. If an offence is committed a second time, thepenalty is doubled.

2.2 PLANNING POLICY FRAMEWORK

Several planning policies and spatial development plans are relevant to the GannaboschMine development, which needs to be consistent with the plans as listed below.

The Western Cape Provincial, Cape Winelands District Municipality andLangeberg Local Municipality Spatial Development Frameworks;

Integrated Development Plans (IDP’s) for the Cape Winelands District Municipalityand the Langeberg Local Municipality;

Western Cape Road Access Guidelines, Second Edition 2002 and Western Cape Department of Environmental Affairs and Development Planning,

Guideline for Involving Visual and Aesthetic Specialists in the EIA process.

Spatial development frameworks translate the aims of the IDP’s into a spatial dimensionand, together with the IDP’s, aim to give effect of the national priority of increasingeconomic growth and promoting social inclusion, whilst ensuring that such growth isenvironmentally sustainable for the particular region (WCDEA&DP,2015)

This section implicitly examines the extent to which the proposed project is consistent withrelevant plans, supported by an explicit analysis of need and desirability in Section 4 andSection 7 of this EIA Report.

2.2.1 Western Cape Provincial Spatial Development Framework (2014)The Western Cape PSDF (2014) is a spatial instrument that seeks to integrate the spatialagenda of all Provincial departments and is informed by (and in turn informs)complementary national, provincial and municipal planning processes (e.g. IDPs andSDFs). The PSDF seeks to “improve the effectiveness of public investment in the WesternCape’s built and natural environments by:

Adopting credible spatial planning principles to underpin all capital investmentprogrammes,

Spatially targeting and aligning the various investment programs, and Opening up opportunities for community and business development in targeted

areas.”

The PSDF identifies three interrelated themes for provincial spatial planning within whichseveral policies for dealing with the province’s key development challenges are identified,as set out below (Table 2-4):



Table 2-4: WCPSDF policies

Spatial Framework PoliciesResources:Sustainable use of theWestern Cape’s spatialassets

Protect biodiversity and ecosystem services Safeguard inland and coastal water resources, and

manage the sustainable use of water Safeguard the Western Cape’s agricultural and mineral

resources, and manage their sustainable use Recycle and recover waste, deliver clean sources of

energy to urban consumers, shift from private to publictransport, and adapt to and mitigate against climatechange

Safeguard cultural and scenic assetsSpace Economy:Opening-up opportunities inthe Provincial space-economy

Use regional infrastructure investment to leverageeconomic growth

Diversify and strengthen the rural economy Revitalize and strengthen urban space-economies as the

engine of growthSettlement:Developing integrated andsustainable settlements

Protect, manage and enhance sense of place, cultural andscenic landscapes

Improve inter and intraregional accessibility Promote compact, mixed use and integrated settlements Balance and coordinate the delivery of facilities and social

services Promote sustainable, integrated and inclusive housing in

formal and informal markets

The PSDF highlights that the continued extraction of construction materials in closeproximity is inevitable and necessary to facilitate economic growth and reduce transportcosts and carbon emissions. It notes than management challenges arise from the threatto remnant natural landscapes and ecosystem services from the expansion of agriculturaland mining activates, and that tradeoffs between these often-competing land uses areinevitable.

The PSDF identifies the Robertson area as a Regional Centre in terms of growing theProvincial economy and situated within a rural development corridor, which stretchesbetween Ceres and Swellendam.

2.2.2 Cape Winelands District Municipality Integrated Development Plan (IDP)The (2012/2016) Cape Winelands District Municipality IDP’s vision is “A unified CapeWinelands of Excellence” and envisages the co-operation of all structures of the CapeWinelands for the effective, efficient and economically sustainable development throughthe following strategic objectives:

To create an environment and forge partnerships that ensures the health, safety,social and economic development of all communities including the empowermentof the poor in the Cape Winelands District through economic, environmental andsocial infrastructure investment.

Promoting sustainable infrastructure services and transport system, which fosterssocial and economic opportunities.

To provide an effective and efficient financial and strategic support services to theCape Winelands District Municipality.



2.2.3 Cape Winelands District Municipality Spatial Development Framework (SDF)The Cape Winelands District Municipality Spatial Development Framework of 2007consists of several policies listed below:

sustainable management of and use of the built and natural resources in a mannerthat ensure that the need of the present generation is met without compromisingthe ability of future generations to meet their respective needs;

everyone affected by spatial planning, land use management and landdevelopment actions or decisions enjoy equitable protection and benefits;

the desired results of land use planning are produced with the minimumexpenditure of resources; and

separate and diverse elements involved in the development planning and land useare linked and coordinated into a harmonious whole. These represent theprinciples of sustainability, equality, efficiency and integration.

It is noted that the SDF strategic directions noted that growth and intensive activities (ofwhich mining falls part) within the District Municipality should be focused in the proximityof public transport facilities and where existing services are available, so to prevent anyfurther impact on the land in areas where neither agriculture nor development issustainable with the currently available technology and knowledge.

2.2.4 Langeberg Local Municipality Integrated Development Plan (IDP)The (2016/2017) Langeberg Local Municipality IDP’s vision is “To create a stable livingenvironment and sustainable living conditions for all citizens” By providing cost effectivequality services to the Citizens, exercise good leadership, ensuring sound governanceand financial management.” Via the following strategic objectives:

Sustainable Integrated Human Settlements Sustainable Civil Engineering Infrastructure Services Energy efficiency for a sustainable future Provision of a safe and efficient road network Promotion of public safety Provision of a clean environment Social Community Development Growth and Economic Development Sound Financial Management Institutional Development and Corporate Governance Good Governance

2.2.5 Langeberg Local Municipality Spatial Development Framework (SPDF)The Langeberg Local Municipality SDF’s visions is to ensure the municipality’s physicalattributes including the Riviersonderend, Langeberg and Waboom mountains, Breederiver with its tributaries and fertile land, the large heritage building stock, factories andinfrastructure, including the R60 and R62, are sustainably exploited to continue to provideand enhance the livelihoods of its residents (CNdV, 2014); The implications of this visionare as follows:

The water quality and quantity of the rivers must be improved, especially in theBreede, Touw, Keisies, Poesjenels, Houtbaais and Riviersonderend Rivers;

There should be no further urban development of existing or potential arable land;



The use of the rail system for freight traffic should be promoted to free up the useof the road network for commuter and tourist private motor vehicle, bus and coachand non-motorised traffic;

The visual impact of buildings, e.g. large resorts, factories and sheds, andinfrastructure, power lines, renewable energy facilities and roads should becarefully assessed; and

Highly accessible and visually exposed sites should also be accessible to SMMEbusinesses.

2.2.6 Western Cape Road Access Guidelines Ed-2 September 2002The movement of traffic on and off the mine will impact on the Provincial, Divisional andTruck roads and the associated brick factory will cumulatively add to this impact. The RoadAccess Guidelines state that it attempts to find a balance between the demand for access,with the need to protect the rights of the wider community for sustainable transportation,while at the same time ensuring adequate mobility in support of accessibility to economicopportunities. The development will need to take the standards of this guideline intoaccount when utilising access roads and constructing internal boundary roads. A TrafficImpact Study (TIS) has been commissioned in accordance with the National Departmentsof Transport’s “Manual for Traffic Impact Studies” PR93/635 (1995) as promulgated in theNational Road Traffic Act (NRTA) (Act 93 of 1996).

2.2.7 Guideline for Involving Visual and Aesthetic Specialists in EIA ProcessThe guidelines provide guidance towards the involvement of a Visual and AestheticSpecialist, and identifies the type of activities that triggers the need for such input into theEIA Report. Part B of the guidelines; chapter 5, offers guidance as to the scope of thespecialists’ involvement, their approach to the study, and what skills and qualificationsthey require. The guidelines attempt to deal with visual impact issues often raised anddetermined by residents, the local authority, or on recommendation of the EIAP. Theguidelines provide for both the receiving environment and the nature of the project, ofwhich the following may be of relevance to mine development and the cumulative impactassociated with developing a brick factory with clamp kilns:

The nature of the receiving environment:

Areas with intact wilderness qualities, or pristine ecosystems; Areas with intact or outstanding rural or townscape qualities; Areas with a recognized special character or sense of place; Areas lying outside a defined urban edge line; Areas of important tourism or recreation value; Areas with important vistas or scenic corridors;

The nature of the project:

A change in land use from the prevailing use; A use that conflicts with an adopted plan or vision for the area; A significant change to the fabric and character of the area; Possible visual intrusion in the landscape;

A Visual Impact Study (VIA) has been commissioned in accordance with the Guideline forInvolving Visual and Aesthetic Specialists in EIA Processes Edition 01, 2005.



2.2.8 Mining and Biodiversity GuidelineAccording to the Mining and Biodiversity Guideline (2013), proactive planning utilizes themitigation hierarchy of

avoid or prevent, minimize, rehabilitate and offset.

Any development within a CBA may only commence, if it cannot be avoided andaddresses the other mitigation measures. However, it is noted that the bioregional planscontaining the CBAs have not been adopted in the Western Cape yet.

The fourth and last option in the mitigation hierarchy is to provide for a Biodiversity Offset.Offsets are “conservation actions intended for the residual, unavoidable harm tobiodiversity caused by development projects”.

The principles of the offset would require that a legal framework or stewardshiparrangement is to be set up to offer a parcel of land in perpetuity as a protected area andfor the land unit to be rezoned accordingly to Open Space or Protected Area. It isincumbent on the proponent to negotiate with landowners to provide a like-for-likeecosystem/vegetation alternative within a CBA.

According to the Provincial Guideline on Biodiversity Offsets (2007) a maximum offsetratio of 10:1 (10 ha protected area for 1 ha developed area) is anticipated, as thevegetation type and ecosystem is classified as Vulnerable. A specialist with a botanicalbackground will be required to provide input and guidance for this process to accuratelyevaluate the offset ratio and to assess the land offered for the stewardship.

2.3 ENVIRONMENTAL PROCESS

Section 2 of NEMA lists several principles most relevant to the environmental impactassessment processes and projects for which authorisation is required. This EIA Reportis guided by such principles as follows

Principles relevant to the EIA process:

Adopt a risk-averse and cautious approach; Anticipate and prevent or minimise negative impacts; Pursue integrated environmental management; Involve stakeholders in the process; and Consider the social, economic and environmental impacts of activities.

Principles relevant to the project:

Place people and their needs at the forefront of concern and serve their needsequitably;

Ensure development is sustainable; Ensure development minimises disturbance of ecosystems, and landscapes, and

reduces pollution and waste; Ensure development achieves responsible use of non-renewable resources and

sustainable exploitation of renewable resources;



Assume responsibility for project impacts throughout its life cycle and Polluter bears remediation costs.

The S&EIR process complies with the above principles through its adherence to the EIARegulations, 2014 and the associated guidelines, which set out clear requirements for,impact assessment and stakeholder involvement as follows

Principles of the S&EIR process

Informed decision making; Accountability for information on which decisions are made; A broad interpretation of the term “environment”; An open participatory approach in the planning of proposals; Consultation with interested and affected parties; Due consideration of alternatives; An attempt to mitigate negative impacts and enhance positive impacts of

proposals; An attempt to ensure that the social costs of development proposals are

outweighed by the social benefits; Democratic regard for individual rights and obligations; Compliance with these principles during all stages of the planning, implementation

and decommissioning of proposals and The opportunity for public and specialist input in the decision-making process.

Although other environmental authorisations, permits or licences may be required beforethe proposed project may proceed, the regulatory authorities are committed to theprinciple of cooperative governance between competent authorities. This means that asingle S&EIR process is required to inform all applications and therefore this single EIAReport has been compiled for submission to the DEA&DP in support of the application forenvironmental authorisation of NEMA listed activities.

2.3.1 Submission of ApplicationNEMA lists several principles that apply to the actions of stakeholders / organs of statethat serve as reference for the interpretation of environmental legislation andadministration. The environmental authorisations that are required before the proposedproject may proceed are listed in Table 2-5 below.

Table 2-5: Environmental Authorisations, Possible Permits and Licences Required

Application CompetentAuthority Current Standing

EnvironmentalAuthorisation DMR Ref. WC30/5/1/2/2/10082MR – 12 February 2016

HeritageApplication / Noticeof Intent to Develop

HWCHeritage Western Cape Ref No (16041402WD0504E).Annexure D-1: First Notice of Intent to Develop andAnnexure D-2: Amended Notice of Intent to Develop

Water Use Licence DWS A WULA for Section 21(c) and (i) water use is inpreparation, to be submitted to BG CMA

In addition, a Notice of Intent has been submitted to the DEA & DP for the environmentalauthorisation of the brick making facility, and an associated application for an atmosphericemission licence is drafted and will be submitted to the Cape Winelands DM for approval.



2.3.2 S&EIR Process and PhasingThe S&EIR process consists of two phases, namely the Scoping Phase and an ImpactAssessment Phase.

The objectives of the Scoping Phase:

Identify stakeholders and IAP’s and inform them of the proposed activity, possiblealternatives and the S&EIR procedure;

Describe the affected environment and present an analysis of the possibleenvironmental issues and the positive benefits that may arise from the project;

Develop ToR for specialist studies to be undertaken and to appoint practitioners; Provide stakeholders and IAP’s the formal opportunity to participate fully and

effectively in the process and raise any issues and concerns that may beassociated with the proposed activity and

Produce a Scoping Report for submission to the relevant authorities, which is theDMR.

The objectives of the Impact Assessment Phase:

Obtain Contributions and ensure meaningful participation from stakeholders andIAP’s and address their relevant concerns and issues;

Record and document the biophysical baseline conditions of the immediate minezone and the socio-economic conditions of the neighbouring and affected region;

Provide a detailed assessment of the potential environmental and socio-economicimpacts of the proposed development;

Identify mitigation measures to avoid or address the impacts and Develop an environmental and social management plan based on the mitigation

measures developed in the EIA report and the EMP.



3 BASELINE ENVIRONMENT

This section presents an overview of the biophysical and socio-economic environment inwhich the proposed Gannabosch Clay Mine and brick factory is located. The intention isto:

Understand the general sensitivity of and pressures on the affected environment; Inform the identification of potential issues and impacts associated with the

proposed project; Inform the comparative assessment of the project alternatives in order to identify

the preferred alternative; and Start conceptualizing possible and practical mitigation measures.

During the Scoping phase and as a consequence of the initial Draft EIA Report, a numberof key natural environments were identified through engagement with governingstakeholders, various organisations and private IAP’s (Table B-0-1, Appendix C-Summary of Raised Concern). Independent specialists were appointed to investigate thecurrent status of these identified key natural environments and to indicate the possibleimpact of mining and to suggest alternatives to reduce the identified impacts. The followingspecialist studies (Table 3-1) were the outcome of the scoping phase:

Table 3-1: Specialist Studies

Specialist Study Specialist Organisation AnnexuresHeritage Specialist Study Jason Orton ASHA Consulting (Pty) Ltd D1 & D2Botanical ImpactAssessment

Johlene Krige Private E1 & E2

Fresh Water EcologyImpact Assessment

Dean Ollis The Freshwater ConsultingGroup F1 & F2

Visual Impact Assessment Megan Anderson Megan Anderson LandscapeArchitects G

Dust Emission Study Dr Harold Annegarn Private HTraffic Impact Study Eric Foster EFG Engineers (Pty) Ltd IAlternative ResourceStudy

Dylan Blake Umvoto Africa (Pty) Ltd J

Economic Impact Study John Steenkamp Bauhaus Simple PropertyGrowth K

Storm Water ManagementPlan and Diversions

Kornelius Riemann,Luke Wiles & MarkBollaert

Umvoto Africa (Pty) Ltd. &Highlands Hydrology (Pty)Ltd

L

Final specialist study reports are attached as Annexures D, E, F, G, H, I, J, K and L.

Additional investigation into socio-economic setting of the area was compiled ascontemplated in Regulation 46 of the MPRDA, Act 28 of 2002 and was incorporated intoSection 3.8. A more thorough review of the social-economic environment is provided inthe Social and Labour Plan. Baseline studies and literature reviews that have beenconducted up to this point have been incorporated in this section.



3.1 CLIMATE

3.1.1 TemperatureHigh interior temperatures are moderated by proximity to the Cape Fold mountain systemwhich induces lower temperatures due to adiabatic cooling (0.60 C per 100 m) as well asthe occasional influx of cooler maritime air from south of the mountain divide. Meanannual temperature (MAT) for the region is recorded as 16.80 C (Mucina & Rutherford,2006). Mean daily maximums and minimums are 29.80 C and 4.70 C in summer and winterrespectively (Figure 3-1). It is noted that the MAP is only 12 % of the Mean AnnualPotential Evaporation (MAPE), which is 1605 mm, leading to a high Soil Moisture StressIndex (MASMS) of 76% which renders surface clays dry (WRC 2008).

Figure 3-1: Average, maximum and minimum daily temperatures throughout the day, withthe horizontal axis representing months of the year, starting with January (1)and ending with December (12).

3.1.2 WindWind data was obtained from the Agricultural Resource Council (ARC) for the period 2000to 2015, as shown in the wind rose in Figure 3-2. The influence of the South Atlantic andSouth Indian High Pressure Systems, promotes a predominant regional wind directionfrom the east/south-east and from the west/northwest. The ARC data is more robust asit ranges over a 15-year average, and shows equal axis wind directions of approximately15% duration from the east and the west. Wind speeds are notably stronger from thewest, in the 4 to 7 m/s category while the easterly winds are generally lighter in the 1 to 3m/s category. The two-year period internet data shows that east and south east windsdominate for 40% of the time while the second influential wind direction from the westmakes up 18 % of the total wind direction duration. The average two year, January 2014to December 2015, wind speed is observed as 7.3 km/h (2 m/s) (Figure 3-2). Alsoimportant is to note that calms account for approximately 40% of the time duration asrecorded by the ARC.



Figure 3-2: Wind direction summary rose chart with wind speed in km/h.

3.1.3 RainfallThe proposed mining right area and the region as a whole falls within the Mediterraneanclimate zone of the south-western region of South Africa but is also influenced by thetemperate interior climate zones of the Klein Karoo. The climate of the study area can bereferred to as a local steppe climate and classified as BSk” (cold semi-arid climate) withlittle rainfall throughout the year, according to Köppen-Geiger system (after Schultze2006). Winter rainfall dominates the area but the added impact of inland summer rainfallover the Karoo and the eastern regions of the Cape generate a more even monthly rainfalldistribution than the Western Cape. Mean annual precipitation (MAP) is recorded as 461mm (WRC,2008), while monthly rainfall can vary from 8 mm in summer up to 35 mm inwinter (Figure 3-3). Mean Annual Runoff (MAR) of 15.7 million m3 (WRC 2008). The MAPassociated with the Robertson Karoo vegetation type (297 mm) is similar to that of BreedeAlluvium Renosterveld (according to the figures given by Mucina & Rutherford 2006)(Figure 3-3), in both cases being significantly lower than the MAP of the QuaternaryCatchment (H40H) within which the site is located.

Further analysis of rainfall pattern is provided in the Storm Water management Plan(Annexure L).



Figure 3-3: Composite climate diagram of the Breede-Alluvium Renosterveld vegetationtype rainfall. Blue bars show the median monthly precipitation. The upper andlower red lines show the mean daily maximum and minimum temperaturesrespectively (After Mucina and Rutherford, 2006).

3.2 TOPOGRAPHY AND LANDFORM VISUAL IMPACT

Locally, the proposed mining property is situated in the Vink River valley, a northerntributary of the Breede River, 15,5 km north east of Robertson. Elevations of the miningright area lie between approximately 260 and 280 mamsl and is visible from the R60National Road which is located ~600 m to the southeast of the property (Figure 3-4 andFigure A-0-1: Regional Topographic Map) (Umvoto, 2016a).

From the southeast, the visual impact from the road is more limited due to screening bythe hills towards the southeast. A full visual impact study has been conducted by MeganAnderson Landscape Architects and is attached as Annexure G: Visual Impact SpecialistReport.

The key findings from this report indicate:

3.2.1 Visual CharacterThe scenic resources of the Gannabosch Vlakte 51 proposed Clay Mine area can bedescribed as rural and industrial, on a plain surrounded by hills at the foot of massivemountains providing a scene that is rated as a moderate scenic and visual resource(Anderson, M. 2016).

The following extract is taken from the Visual Impact Assessment Report (Anderson, M.2016).

The scenic resources of the area can be described as predominantly rural and arerated as moderate. The Zone of Visual Influence of the proposed development islocal, limited to an area within 3 km’s of the site. Receptors are highly to minimallysensitive. The highest and most sensitive receptors will be the R60 scenic touristroute and residents to the south. The inherent visual sensitivity of the site is highto low, with the southern section of the site, i.e. just north of the Vink River andCape Lime Works having a moderate to low visually sensitive and that further north



and east being moderate to highly visually sensitive. The Visual AbsorptionCapacity of the site to the proposed development is moderate i.e. there will bepartial screening by topography and vegetation. The Visual Intrusion will bemoderate, as it partially blends in but will still be clearly noticeable.

Gannabosch Vlakte 51 and the proposed site of the clay mine are found along the middlereach of the Vink River where it traverses a semi-arid plain. This plain is surrounded bylow gently rounded foothills and has the rugged, fynbos covered Langeberg sandstonemountains as a spectacular backdrop in the north.

The area is predominantly rural, mostly grazed natural vegetation but with some cultivatedcrops and vineyards on the edges of the plains near foothills. The Cape Lime works in thesouth east and the Langvlei Quarry in the north east are industrial activities occurring inthis rural area.

The R60, a scenic tourist route and a primary transport route between Robertson andWorcester, crosses the plain, from west to east, at the toe of the southern foothills. Therailway line runs alongside the R60 with the Langvlei siding at the Cape Lime works.

A tarred road runs north from the R60/Cape Lime to the quarry from where it becomes agravel road that services farms to the north east. This road intersects the south east –north west aligned Agtervink gravel road, which services farms to the northwest. It joinsthe R60 east of the study area. The character of the area is predominantly covered bysemi-arid natural vegetation, rural, vineyards, annual crops, sheds and the industrial(Cape Lime works). The proposed site for the clay mine is seen in Figure 3-4 and Figure3-5.

Figure 3-4: View to the north east from the position of Figure 3-5 across the Vink Rivershowing massive Langeberge and rolling hills in the background. The proposedsite area will be visible from the R60 as indicated with the dashed-white line.



Figure 3-5: Red arrow depicts fixed photo point from which Figure 3.4 is taken as a viewfrom the SW of the proposed mining area.

3.2.2 View CatchmentThe Langeberg forms the viewshed in the north. This continues in the west alongridgelines to Mowershoogte and southwards to Aasvoelberg in the south west. From hereit runs along the higher ridgeline to Rooiberg in the south east where it returns to theLangeberg via Spitskop Bakenskop and Tierberg. The extent is approximately 10kms tothe north west, 5 km south and 8 km to the east. (See Figure 3-6).

3.2.3 Zone of Visual InfluenceThe Zone of Visual Influence of the proposed project is the actual area from where theproject will be seen. Topography (minor ridges), vegetation (trees and hedges), buildingsand distance will reduce the area from which the site and proposed project is visible,(viewshed) particularly due to the relatively low elevation of the site and its flatness. Thetrees along the river and around the neighbouring Cape Lime works will reduce the extentof the area from which the project will be seen from the surrounding areas. The ZVI willbe a maximum of 3 km from the surrounding areas. The extent of the ZVI is local (seeFigure 3-7).



Figure 3-6: Viewshed of the proposed Gannabosch Vlakte Clay Mine

Figure 3-7: Zone of Visual Influence of the proposed Gannabosch Vlakte Clay Mine



3.2.4 Receptors Highly sensitive receptors:

There may be glimpses from residential dwellings; namely a dwelling onBuitenskloof, which faces north, therefore away from the mine, a couple ofdwellings immediately south of the R60 whose views of the proposed mine will bescreened by the lime works and associated large trees, and dwellings on the lowerslopes of Rooiberg south of the R60 which are elevated and will have good viewsacross the Gannabosch Vlakte.

The R60 is a scenic tourist route and will be exposed to the proposed clay minefor approximately 4kms as it passes by the proposed site. The R60 is slightlyelevated above the plain and although the mining is below the surrounding area,some scarring and activity, as well as the brick making facility, will be seen.Tourists and visitors to the local area using the R60 will see mining and the brickmaking facilities as they pass by. (See Figure 3-8).

Moderately sensitivity receptors:

Persons working on farms and at Cape Lime adjacent to the proposed site anddevelopment

Low sensitivity receptors:

The Cape Lime and Langvlei Quarry works.

Figure 3-8: Receptors of the proposed Gannabosch Vlakte Clay Mine.



3.2.5 Visual Sensitivity Absorption Capacity and IntrusionThe site is a low-lying plain adjacent to the Vink River. This topography and landform isan area, which is minimally visible in the landscape and therefore has a low visualsensitivity.

The vegetation adjacent to the site is for the most part low in height resulting in the sitebeing highly visible and potentially a sensitive area in the landscape. The large trees alongthe Vink River to the south of the site provide some screening which results in theimmediately adjacent mining area being a moderately visible area in the landscape andmoderately visually sensitive. So the site is moderately to highly visually sensitive as aresult of the vegetation.

Adjacent landuse is for the main part rural with Cape Lime works being industrial. Thisresults in the site being highly to moderately visible and having a high to moderate visualsensitivity.

The site is on a low-lying plain, bordered by hills to the east, which provide screening fromthe east. The large trees to the south provide screening from this area. The site willtherefore be screened from the east and south, but not south east, and will be visible froma greater area to the west and north although hills and mountains here provide screeningfrom the greater area. The potential of the sites’ and surrounding landscape to visuallyabsorb the development is therefore moderate.

The proposed site is currently a naturally vegetated, albeit grazed, parcel of land within alarger rural area, adjacent to a vineyards and the Cape Lime works, an industrialoperation. The proposed clay mining operation will resemble rural activities such as farmdams or cultivating lands for crops and vineyards, with clearing the vegetation and thenre-planting it. The form and shape of the operation is not unlike that of farming with thebrick making facility resembling a farm shed.

3.3 GEOLOGY

The resistant to weathering rocks of the Table Mountain Group (TMG) sandstones of theCape Supergroup define and form the peaks of the Cape Fold Belt Mountains(Umvoto,2016a).

To the north of the proposed mining property, the south-westerly dipping normalWorcester Fault has downthrown the southern, younger, Karoo Supergroup rocksjuxtapose those of the older basement Malmesbury Group and intrusive RobertsonGranite Suite, upon which the rocks of the unconformable overlying TMG form the~1400 mamsl Langeberg Mountain range. To the south of the property, the steep (~50°)northward steeply dipping Karoo Supergroup sediments transition into the conformableand older stratigraphically underlying rocks of the Cape Supergroup, which rise up to formthe ~1300 mamsl elevation Riviersonderend Mountain Range (Figure 3-9 and FigureA-0-3) (Umvoto, 2016a).



Figure 3-9: Geological cross section through the centre of mining property (Umvoto,2016c)

On site, the property is underlain by Quaternary sediments deposited in the flood plainsof river courses controlled by the bounding mountain ranges of the Riviersonderend andLangeberg Mountain ranges, which form the Breede Valley. Rock units of the Ecca Groupof the Karoo Supergroup underlay the overlying Quaternary sediments and can be seenoutcropping throughout the surrounding landscape and in nearby digging (Umvoto,2016a).

Table 3-2: Stratigraphy

Age Supergroup Group Formation LithologyQuaternary(~2.5-0 Ma) Undifferentiated sediments Alluvium

Early to Mid-Permian

(~299-270 Ma) KarooEcca

Waterford Feldspathic sandstone,siltstone, shale

Tierberg Shale, mudstone, siltstone

Collingham Shale, Mudstone/tuff,siltstone, chert

Whitehill Carbonaceous shales chertysiltstone layers

Prince Albert Shale, siltstoneCarboniferous(~359-299 Ma) Dwyka Tillite, Diamictite, shale

Cambrian-Ordovician

(~510-350 Ma

Cape SuperGroup

TableMountain

Group

Skurweberg Quartzitic sandstone, pebblestringers

Peninsula Quartzitic sandstoneLate

Precambrian(~575-540 Ma)

Malmesbury Greywacke, sandstone, slate

LateNeoproterozoi

c(~600-540 Ma)

Cape GraniteSuite Granite



Prince Albert Formation

Outcrops of this formation are generally poor. It consists mainly of thinly laminated, darkbluish-grey shale, which weathers to an olive or red brown colour. In the cold Bokkeveldand Ceres-Karoo thin (3-5 cm), silty to cherty layers occur intermittently. On exposure,they disintegrate into small yellow-brown angular chips.

Between Worcester and Robertson, the formation is only intermittently exposed, withgood, fairly accessible outcrops occurring along the flanks of Aasvoelberg, north of Eiland.According to De Villiers et al. (1964) the formation attains a thickness of approximately200 m south of Worcester, but more recently 120 m was measured just east of the minesite on farm Scherpen Heuvel no.481. As elsewhere, a transitional contact exists betweenthe Prince Albert Formation and the overlying Whitehill Formation.

Whitehill Formation

The Whitehill formation consists of thinly laminated, pyritic, carbon-bearing black shaleand measures about 30 m in thickness. The formation weathers characteristically to aconspicuous greyish-white, gypsiferous to lime rich zone. Thin, grey to yellow-colouredcherty lenses are often also apparent.

Collingham Formation

The Collingham formation, which concordantly overlies the Whitehill shales, is poorlyexposed in the Ceres-Karoo but in the Worcester-Robertson outlier, it is exposed in theabove-mentioned quarry sites as well as in road cutting. Here it is about 45 m thick,compared to the generally accepted thickness of 30 m to the north. The Collinghamformation here consists of a rhythmically interbedded sequence of thin tabular beds ofdark grey shale, yellowish-coloured soft claystone, siltstone and cherty mudstone.Bedding thickness varies from 20 to 40 mm, with some of the siltstone horizons somewhatthicker in places. Parallel lamination is dominant. No trace fossils have been found asyet.

A yellow weathering, illite-rich claystone (K-bentonite) typifies the Collingham Formationand has a wide distribution throughout the Karoo Basin. These claystones and chertifiedbeds contain devitrified and replace glass shards, and have been interpreted as air falltuffs (Lock and Wilson 1975). Analyses have shown the potassium content of these ashbeds to vary from 4 to 10 % K2O (Verwoerd et al. 1990).

Tierberg Formation

The conformably overlying Tierberg Formation consists of grey-black (fresh) to olivegreen(weathered), well laminated shale, mudstone and siltstone. The formation is extensivelyweathered and poorly exposed in the Ceres-Karoo. Occasional thin, silty horizons aresometimes ripple marked and biogenic trails occur on Witte Wal 171, along the GrootRiver.

Outcrops are somewhat in the Worcester-Robertson outlier, where the most completesection across the Tierberg Formation in this area occurs between Aasvoelberg andMowershoogte, west of the Worcester-Robertson divisional boundary. From the Tierberg-Collingham contact up to Mowers Siding the sequence is mainly composed of mudstone,shale and siltstone. North of the railway line however, there is a gradually increasingnumber of arenaceous layers. This latter succession is tentatively connected with theWaterford Formation, the uppermost unit of the Ecca Group.



Waterford Formation

In the low range of hills, Mowershoogte, between Worcester and Robertson, numerousfine-to medium grained sandstone beds are intercalated with politic units. Thesearenaceous beds are generally massive or sometimes parallel laminated, and wave ripplemarks, clay-pellet conglomerate and brownish lime-rich lenses occur.

3.4 HYDROGEOLOGY

The fractured Table Mountain Superaquifer forms the dominant aquifer in the greaterWestern Cape region, specifically the Peninsula and Nardouw (Skurweberg and Rietvlei)Aquifers within it. These two Table Mountain Group (TMG) aquifers are separated by theWinterhoek Mega-aquitard (Pakhuis, Cederberg and Goudini Aquitards) which totallyisolates them from one another. The upper Nardouw Aquifer is targeted by privateSchedule 1 users and farmers because of its accessibility and shallower drilling depth,which reduces drilling costs. The Peninsula Aquifer is mainly used for large-scalemunicipal groundwater developments (e.g. Oudtshoorn Groundwater Project, HermanusWellfield and Cape Town’s TMG Feasibility Study) because of its large quantity and goodwater quality. In general, groundwater quality of both the Peninsula and Nardouw Aquifersis good (i.e. fresh and potable), with low electrical conductivity (EC), low solute content,acidic pH, however high iron and manganese concentrations are characteristic.

The Bokkeveld Group is made up of fine-grained shales, mudstones and siltstones, whichhave low hydraulic potential. For this reason the Bokkeveld Group is known as the GydoMega-aquitard. The high residence time of groundwater within the clay rich shales andlow transmissivity parent rock usually results in relatively poor groundwater quality (e.g.high electrical conductivities and high metal concentrations) due to its marine depositionalenvironment.

The Witteberg Group consists of alternating units of micaceous shale/siltstone andquartzitic sandstone. The hard, fractured sandstone units (Blinkberg, Witpoort andFloriskraal Formations) form the aquifers of the Witteberg Group, which are separatedfrom one another by the shale rich (low hydraulic permeability) aquitards (Wagen Drift,Swartruggen, Kweekvlei, Waaipoort Formations). The three fractured sandstone aquifersform relatively good yielding aquifers provided the right structure is targeted, with yieldsof between 2-5 l/s. The Witpoort Aquifer is the thickest and most likely the highest yieldingaquifer within the Witteberg Group. Groundwater quality is likely to be relatively good(electrical conductivities of <100 milliSiemens/metre [mS/m]), although high iron andmanganese concentrations are possible. The proposed mining site is directly aboveKaroo sequence rocks, (Section 3.3) which are of little significance with regard togroundwater in the area.

3.5 SOIL, LAND USE AND LAND CAPABILITY

The region consists of soils derived from transported material, which includes the sandyand loamy alluvial soil, as well as the red clay loam, and clay Karoo soils. As well asresidual soils which include the shale soils of the Malmesbury and Bokkeveld soil families.The red clay loam and clay Karoo soils are the most dominant soil types in the area ofinterest and are often very calcareous (Umvoto, 2016a).

The proposed mining property overlies soils of a Eutric Brunisol (EB) nature, as classifiedby the Canadian System of Soil Classification, with an approximate depth of < 450 mm(CFM, 2016). These soils exhibit minimal development and are usual of shallow soilsoverlying on hard or weathering rock. Lime is generally present in part or most of the



landscape as is shown by the relatively high degree of base saturation as indicated bytheir pH and lack a well-developed mineral-organic surface horizon. These soils arecommon of parent material of high base status (clay/lime) and under forest or shrubvegetation in a wide range of climates (Umvoto, 2016a).

Further classification via the ENPAT broad soil classification shows soils of Fc718category. The Glenrosa soil form have a strong structure and high clay content subsoiland are not suitable for irrigation, being host to short shrub and bush. The Mispah formis indicative of soil horizons overlying hard rock formed in alluvium, derived from mixedrocks over residuum that has weathered from siltstone. These soils are generally veryshallow, have a variable fertility and water holding capacity, depending on the rock typefrom which they are derived (P. le Roux, 2012; CFM, 2016).

3.6 BIODIVERSITY

3.6.1 HabitatThe target area on Farm 51 currently consists of natural vegetation, which is in goodcondition and lies within a Critical Biodiversity Area. Disturbance levels are low and limitedto a few old farm tracks and furrows across the entire property. A small patch (0.35 ha)located within the proposed mining site is currently transformed and comprises thefootprint of an old ammunition storage shed utilised by the Cape Lime mining operation.The mine footprint is separated into an east and west portion by a tar road that links theCape Lime processing plant to the open cast lime quarry 3 km to the northeast. Threedrainage lines cross through the target area. Drainage line 1 towards the west being ofsignificant ecological importance has been excluded from the amended target area andleft intact as a corridor to support biodiversity and linkage within the CBA. Drainage line2 is of lowest significance, with no distinct channel and no noted vegetation difference tothe surrounds. Drainage line 3 towards the east has, like drainage line 1, being excludedfrom the target area.

These drainage lines are classified as both Ecological Support Areas and as an AquaticCBA (see Figure 3-10). Overall, the natural habitat within the target area is in a goodcondition, well connected to adjacent natural areas and is positioned within a CBA. Thesite thus has a high ecological integrity.

The study area falls within the Southern Folded Mountains Ecoregion (after Kleynhans etal. 2005), near the transition to the Western Folded Mountains Ecoregion (to west) andthe Southern Coastal Belt Ecoregion (to south). More specifically, the study area formspart of the lowlands of the Langeberg Mountains, situated relatively close to theLangeberg-West Mountain Catchment conservation area (Ollis et al, 2016) and serves tolink the mountain catchment area in the north to the Breede River Valley in the south viaseveral ESA corridors. The physiographical characteristics of the Southern FoldedMountains Ecoregion, in terms of terrain morphology, are typically characterised by adiverse topography of closed hills and mountains with a moderate to high relief (slopeswith a gradient of >5% are predominant within the Ecoregion). The study area for theproposed mine is thus somewhat atypical of the Ecoregion within which it falls, beinglocated in a relatively non-mountainous part of the landscape. The rainfall seasonality andthe vegetation types that occur within the Southern Folded Mountains Ecoregion arehighly variable (Ollis et al, 2016).



Strategic Biodiversity SignificanceFigure 3-10 represent aquatic and terrestrial Critical Biodiversity Areas (CBAs) andEcological Support Areas identified through the systematic assessment conducted by theC.A.P.E. Fine-Scale Biodiversity Planning (FSBP) project. These areas requiresafeguarding to ensure the continued existence of biodiversity, its ecological processes(e.g. animal migration, pollination) and its ecosystem services e.g. water supply. The mapalso delineates Other Natural Areas and No Natural Remaining/Developed areas (Mareeand Vromans 2010).

The network of CBAs reflected on the CBA Map indicates the most efficient (i.e. least land-hungry) selection and classification of land portions requiring safeguarding in order tomeet national biodiversity thresholds. The overall aim is to avoid the loss of natural habitatin Critical Biodiversity Areas (CBAs) and prevent the degradation of Ecological SupportAreas (ESA), while encouraging sustainable development in Other Natural Areas.

The following criteria were used to identify terrestrial CBAs:

all remaining patches of Critical Endangered vegetation all known point localities of Species of Special Concerns (e.g. Rare/Endangered

plant or animal species) Endangered, Vulnerable / Least Threatened vegetation required to meet national

thresholds Important ecological process areas (e.g. landscape corridors required for habitat

connectivity, upland-lowland corridors, edaphic interfaces, sub-quaternarycatchments, coastal-and-sand movement corridors, etc.)

Terrestrial CBA’s and corridorsThe proposed mining application area and the adjacent area targeted for the brick factoryare classified as terrestrial CBAs (Figure 3-11). This CBA is identified under the criteriafor vegetation type thresholds.

The site thus forms part of a selected area that should ideally be safeguarded inorder to protect a target area of a specific vegetation type. It is noted that theecosystem status of the Breede River Renosterveld vegetation type is classifiedas Vulnerable.

In addition, the CBA forms part of a natural corridor, specifically an upland-lowland corridorbetween the Langeberg Mountains and the Breede River.

These corridors are important to ensure habitat connectivity, for plant and animalmigration

No CBA’s (as identified in the biodiversity plans) have yet been adopted in the bioregionalplan by the competent authority (DEA&DP). Nevertheless we respect the comment andinput made by Cape Nature Conservation, a commenting authority who advises DEA&DPand who act as custodian of all CBA’s, and acknowledge that this area may play a role inimportant ecological processes. Thus during the planning phase special focus was put onthe layout of the proposed development. An alternative footprint for the mine was agreedupon (see Figure 1-3). The new, north-south, orientation of mine concession contrastswith original east-west layout which blocked the corridor and fragmented the vegetationand biodiversity. (See Figure 1-4).



Figure 3-12 additionally gives a regional overview of the biodiversity areas, suggestingthat the development area is not the only CBA linking the upland to valley.

Ecological support areasThree ephemeral drainage lines are evident in the vicinity of the proposed mining area aswell as the area targeted for the brick factory. These non-seasonal, episodic water coursesare recognized as Ecological Support Areas and aquatic CBAs (Figure 3-10). Prominentdrainage lines are characterized by denser vegetation, comprising tall shrubs (typicalKaroo elements). Less prominent drainage lines are open and shallow with no structuraldifferences to adjacent karooveld.

Drainage line 1 towards the west being of significant ecological importance hasnow been excluded from the amended target area and left intact as a corridor tosupport biodiversity and linkage within the CBA.

Drainage line 2 is of lowest significance, with no distinct channel and no notedvegetation difference to the surrounds. It is intended to be diverted.

Drainage line 3 towards the east has, like drainage line 1, being excluded from thetarget area.

The significance of the drainage lines is more fully discussed in the Specialist Report fromthe botanical and fresh water ecological consultants. (See Annexure E-1: First BotanicalSpecialist Report, Annexure E-2: Amended Botanical Specialist Report Annexure F-1:First Freshwater Specialist Report and Annexure F-2: Amended Freshwater SpecialistReport).



Figure 3-10: Extract from the CAPE Fine Scale Project: Critical Biodiversity Areas Map forthe Langeberg Municipality, showing farm boundaries, mining application andbrick processing area Krige,2016)



Figure 3-11: Critical Biodiversity Map illustrating position of the target area and the farmGannabosch Vlakte 51 within the upland-lowland corridor between theLangeberg Mountains and the Breede River. Also shown is the EcosystemStatus as Vulnerable.



Figure 3-12: Broad overview of Critical Biodiversity areas regionally. Illustrating positionof the target area and the farm Gannabosch Vlakte 51 within the upland-lowlandcorridor between the Langeberg Mountains and the Breede River.

A Botanical Ecological Specialist was appointed to undertake an Impact Assessment ofthe relevant portion of the Farm Gannabosch Vlakte 51 (Krige, 2016 a). The first reportwas completed in July 2016 and was subsequently amended and updated in September2016 to include additional spring flowering species that may not have been apparent inthe winter survey, due to seasonal constraints to annuals and geophytes. The secondreport also includes the additional area to the north and east of the originally proposedsite. According to Krige, the farm on which the proposed mining right is located is largelyundeveloped and is covered predominantly with natural vegetation in good condition,except for the footprint of a since removed structure. Standard South African NationalBiodiversity Institute (SANBI) Terms of Reference for biodiversity assessment were used.

Vegetation Map of South Africa (2006)According to the SA Vegetation Map (Mucina and Rutherford 2006), the proposed miningarea comprises of Breede Alluvium Renosterveld vegetation. Breede AlluviumRenosterveld is listed as a Vulnerable (VU) ecosystem, under the criterion A1, in theNational List of Threatened Ecosystems 2011 (G 34809, GN 1002). Robertson Karoovegetation, which is Least Threatened (LT) is evident within the surrounding areas. Abroad description of the botanical environment and an overview of the some of the keyspecies from both vegetation components is extracted from the Krige Report and shownbelow: (a more detailed description is available under Annexure E-1: First BotanicalSpecialist Report and Annexure E-2: Amended Botanical Specialist Report).



Worcester Renosterveld Karoo (LT)Corresponds closely to the Robertson Karoo ecosystem identified in the Vegetation Map of SA(2006) which is Least Threatened. This is a widespread and fairly homogeneous vegetation unitwhich comprises Renosterveld and Succulent Karoo elements with some Thicket elementsalways present. Heuweltjies are an important feature, with a distinct plant community dominatedby annuals (especially Oncosiphon) and succulents (Tylecodon, Euphorbia).

Thicket elements include:Carissa haematocarpa, Gloveria integrifolia, Rhus glauca, Rhus undulata, Rhus pallens, Rhuslongispina, Rhus incisa, Euclea undulata, and Buddleja saligna. The general shrub matrix ismade up of Pteronia paniculata, P. incana, P. pallens, Elytropappus rhinocerotis, Aloemicrostigma, Euclea undulata, Eriocephalus africanus, Crassula rupestris, Tylecodonpaniculatus, T. wallichii, Euphorbia mauritanica, E. burmanii, and Ruschia caroli.

Breede Alluvium Renosterveld (VU)Occurs on flat alluvial fans and valley bottoms supporting short grassy cupressoid-leavedshrubland, usually dominated by renosterbos. It occurs on fine loamy sand with high gravel andcobble contents of alluvial fans and river terraces. Two endemic plant species and 10 Red DataList plant species occur in the ecosystem

Robertson Karoo (LT)Occurs on undulating flats and adjacent hills (sometimes with very steep flanks) supporting dwarfsucculent shrubland to succulent thicket of medium height dominated by succulent species ofEuphorbia, Crassula (and related genera) and vygies (Drosanthemum and Ruschia the majorstructural players). Euphorbia mauritanica is usually dominant on heuweltjies, which are animportant element of the landscape and vegetation of the Robertson Karoo. The shale derivedsoils are deep, red, apedal and loamy to loamy-sandy with a high clay and sodium content

Vulnerable (VU) - ecosystems that have a high risk of undergoing significant degradation ofecological structure, function or composition as a result of human intervention, although they arenot critically endangered ecosystems or endangered ecosystems.

A1 - Irreversible loss of natural habitat - Remaining natural habitat ≤ 60% of original area ofecosystemAbstract from Krige, 2016



Figure 3-13: Extract from the SA Vegetation Map (Mucina & Rutherford 2006) indicating themining site and available area for the brick factory. (Krige, 2016).

CAPE Fine Scale Integrated Vegetation Map (2007)Recent more detailed mapping of the area was conducted in 2007 as part of the “CAPEFine Scale Integrated Vegetation Map (2007)”, and at a fine scale, the proposed site wasclassified entirely as ”Worcester Renosterveld Karoo” which is considered LeastThreatened (Krige, 2016 a).



Figure 3-14: Extract from the CAPE Fine Scale Project: Integrated Vegetation Map, showingthe mining site and available area for the brick factory.

Plant communities on siteThe field survey confirmed that the site corresponds more closely to the Robertson Karooecosystem which is Least Threatened than to Breede Alluvium Renosterveld as indicatedon the Vegetation Map of SA (2006) (Figure A-0-5).

The vegetation on site clearly resembles the CAPE Fine Scale vegetation unit RobertsonGannabos Thicket, described by Helme (2007) but currently not mapped for this specificsite.

The target areas comprise deep, silty clay soil with typical sparse vegetation coverevident in some places throughout the site. Sparse cover can be attributed to highsalt content.

The habitat is homogeneous over the target site and across most of the Farm 51. The vegetation predominantly comprises an open, karoid shrubland matrix

including dwarf and medium-tall shrubs with a low density of thicket elements, ahigh concentration of succulents (many vygies) and a few geophytes. Salsolaaphylla (gannabos) is prominent throughout the site.



The most prominent elements include the following:

Dominant shrubs: Eriocephalus ericoides (kapokbos), Pentzia incana(ankerkaroo), Pteronia incana (asbossie), Pteronia paniculata (gombossie) andRuschia caroli.

Sub-dominants: Elytropappus rhinocerotis (renosterbos), Felicia filifolia (draaibos),Osteospermum sinuatum (karoobietou) and Salsola aphylla (gannabos).

Thicket elements are sparse and include scattered individuals of Carissahaematocarpa (noem-noem), Rhus longispina (doringtaaibos) and Lyciumoxycarpum (wolwedoring).

Prominent succulents include Cotyledon orbiculata (plakkie), Crassula spp.,Gasteria brachyphylla (beestong), Euphorbia spp. and Tylecodon paniculatus(botterboom). Drosanthemum, Lampranthus and Ruschia spp. andMesembryanthemum longistylum, Psilocaulon junceum (asbos) and Seneciosarcoides (soetkop dikblaar) are common succulent shrubs.

Geophytes were not common by the time of the first site visit but a follow-up surveywas conducted in September 2016, and 24 additional species of geophytes wererecorded on site.

Vegetation within the drainage channels mainly resembles that of the surroundingvegetation with Acacia karoo (soetdoring) and Rhus longispina (doringtaaibos) themain structural differences.

Worcester Renosterveld Karoo, as indicated in the Fine Scale vegetation map, is evidentalong the easternmost portions of Farm 51, typically on shale (shallower and rockierareas). Salsola aphylla (gannabos) is absent from this section of the farm and there is ahigher concentration of succulents especially Aloe microstigma. One particular plantspecies of special concern (Euphorbi nesemani (NT)) was found to be present within theproperty boundary of Gannabosch Vlakte 51 within two isolated gravelly patches whichwas typically found to be associated with the Worcester Renosterveld Karoo vegetationwhich grows on gravelly shale-type soils. It is noted that none of these species types, northe soil conditions associated with them were found to be present within the proposedmining right area. More than 70 plant species were recorded. For a detailed list of allspecies recorded on site refer to Annexure E-1: First Botanical Specialist Report (Krige2016 a).

Follow-Up Botanical SurveyA follow up survey was conducted in September 2016. (See Annexure E-2: AmendedBotanical Specialist Report). The aim of this survey, conducted during spring, was toestablish if any additional plant species of conservation concern occurs within theproposed mining area, due to seasonal constraints to annuals and geophytes in the initialbotanical assessment, undertaken in June 2016. A second reason for the follow up surveywas to incorporate the additional area directly east of the originally proposed site.

A number of additional herbs and geophytes (24 additional species) were recorded duringthe follow-up spring survey of which Bulbine succulenta, Ornithogalum dubium(chincherinchee) and Moraea spp. were most prominent. For a full record of the additionalplant species recorded during the follow-up survey refer to Annexure E-2 of the attachedKrige (2016) Follow up Botanical Survey. Krige (2016 b). No additional plant species ofconservation concern or any Rare or Endangered plant species were recorded during theSeptember site visit. No individuals of Euphorbia nesemanii, which is considered NearThreatened, are evident within the proposed mining areas / brickyard location.



Comments on proposed new layout plans with respect to botanicalassessment:

The proposed amended layout does not allow for the diversion of drainage line 2 intodrainage line 3. From a purely botanical perspective, the mining of additional areasdirectly towards the east of the originally proposed mining area and the proposed newbrickyard location directly north of the originally proposed mining area will have noadditional impacts, if an adequate natural buffer (at least 30 m) is being maintained alongthe prominent drainage line east of the site (drainage line 3). It should however be notedthat a significantly larger portion of drainage line 2 will be transformed / permanently lostto mining activities. If the originally proposed no-go areas (western section of the originalsite, drainage line 1) were to be protected from any development or disturbances, thediversion of a less important ephemeral drainage line (drainage line 2) around theproposed mining area is acceptable. The modified Storm Water Management Plan (seeSection 4.1.3) differs from Figure 3-15. The divert culvert which was originally plannedto run alongside the Langvlei Quarry Road servitude and exit into the Vink River has nowbeen re-aligned to assume the existing under road culvert and then drain into the south-eastern sump. A sump overflow has been provided to direct water excesses back into theoriginal drainage line. Further detail can be reviewed in Section 4.1.3 and Appendix L.

Figure 3-15: Revised mine plan. While the proposed target area impacts drainage line 2, theeast and west boundary drainage lines remain intact and preserve biodiversity.



The follow-up botanical survey confirmed that the amended layout plan is:

Acceptable from a biodiversity perspective, although located within an importantCBA;

Allows for a significant natural corridor towards the west of the mining activities.The CBA corridor will thus remain functional, as recommended in the initial survey;

Allows for adequate natural buffers along the prominent drainage lines towards thewest (drainage line 1) and east (drainage line 3) of the development;

Excludes the Vinkriver floodplain area (aquatic CBA) from any development /disturbances.

Will not result in isolated vegetation fragments.

It further confirms that Drainage line 2 is one of the less prominent drainage lines whichare open and shallow, with no structural differences to adjacent karooveld. By ensuringthe protection of the more significant water courses towards the west and further east, aswell as a significant natural terrestrial corridor towards the west, transformation of thissmall drainage line is acceptable in terms of biodiversity.

3.6.2 Freshwater EcologyThe region of the proposed mining area falls into the H40H Quaternary Catchment withinthe Breede-Gouritz Water Management Area (WMA),. The main river of the region is theBreede River, which the Vink-Noree River system is a tributary of (Ollis et al, 2016).

The property is located within the H40H quaternary catchment of the Breede-GouritzWater Management Area (WMA), but more specifically within the Upper Breede sub-Water Management Area (sub- WMA). The Breede River is the most significant perennialriver in the region, while the perennial Vink River, located south of the property, feeds intothe Breede River. Due to the low permeability of the clay soils, the property experiencesa significant amount of surface water run-off, which drains into the non-perennial streamon the property and/or feeds into the Vink River.

There are no Freshwater Ecosystem Priority Areas (FEPAs) or Fish Sanctuary Areas(FSAs) along the Vink River, but a Floodplain Wetland is shown to be present along thelength near the mining area, as per the procedures for the identification and delineation ofwetlands (after DWAF 2005). A “wetland” is defined in the National Water Act (Act No. 36of 1998) as “land which is transitional between terrestrial and aquatic systems, where thewater table is usually at, or near the surface, or the land is periodically covered withshallow water and which land in normal circumstances supports, or would support,vegetation adapted to life in saturated soil.” Following this definition and the standardwetland delineation protocols, no wetlands were identified to be present on or adjacent tothe proposed sites for mining and the establishment of a brickmaking facility (Ollis et al,2016).

A few outdated drainage furrows / canals, which no longer appear to carry water, crossthrough portions of the sites. As previously indicated, the Vink River (a tributary of theBreede River) is located relatively close to the sites for the proposed mining activities,flowing in a south-easterly direction to the south-west of the subject property (see FigureA-0-2). The potentially affected reach of the Vink River falls within the Upper Foothillszone of the river (following the geomorphological river zonation scheme of Rowntree &Wadeson 2000). Rivers in this longitudinal zone are typically characterised by amoderately steep, cobble-bed or mixed bedrock-cobble bed channel, with a narrowfloodplain of sand, gravel or cobble often present adjacent to the river channel (Ollis et al,2016).



Several drainage channels cut through the proposed mining footprint, and it is presumedthat these drainage lines have a naturally ephemeral (episodic) flow regime, only flowingfor a short time after relatively major rainfall events (Krige, 2016).

Vink River and adjacent floodplainThe section of the Vink River located to the south-west of the proposed site was notflowing at the time of the site visits by FCG (in July and October 2016). This section of theriver is thus clearly not a perennial system in its current state, although it is presumed thatthe river would have had a perennial flow regime in its natural state. The potentiallyaffected reach is characterised by a fairly incised single channel, approximately 10 to 20 mwide, which has a bed comprising mostly cobbles and sand (Figure 3-16). Patches ofvegetation are evident in the channel, mostly on sand bars, consisting of a mix ofindigenous plant species (including Cyperus sp. and Juncus sp.) and alien invasivespecies (most notably juvenile stands of Spanish reed, Arundo donax). On the somewhateroded banks of the river, the riparian zone is dominated by dense stands of alien invasiveplant species, mostly gum trees (Eucalyptus sp.) and Port Jackson willow (Acacia saligna)(Ollis et al, 2016).

Figure 3-16: Photograph of the river channel along potentially affected reach of the VinkRiver [taken on 11/07/2016] (Ollis et.al., 2016).

Adjacent to the main channel of the potentially affected reach of the Vink River, there is afloodplain area approximately 30 m in width. This floodplain area is also dominated byalien invasive trees (Eucalyptus sp., Acacia saligna), but there are more indigenousspecies than in the case of the riparian zone (including Acacia karoo and Searsialongispina).



From the relatively dense growth of shrubs within the floodplain, it is evident that thefloodplain does not get inundated nearly as frequently as it would have under naturalconditions. At the outside edge of the floodplain area, there is a relatively high (~3 m)berm that is presumed to be a historical flood terrace. (Figure 3-16 and Figure 3-17).

Figure 3-17: Photograph of the historical flood terrace, located above the flood terraceadjacent to the Vink River [taken on 11/07/2016] (Ollis et.al., 2016).

Present Ecological StateOverall, the Vink River is in a poor ecological condition, as it is “largely modified” for boththe instream and riparian components of the river systems (Ollis et al, 2016). The mainimpacts on the present ecological condition of the Vink River are relatively severe channeland flow modifications, together with water abstraction for agricultural use in thecatchment and the encroachment of agricultural land-use and alien invasive vegetationinto the riparian zone of the river. In its natural state, the relevant reach of the Vink Riverwould have consisted of a complex channel form, with multiple braided channels thatwould have shifted around in response to flooding events (Reinecke et al. 2014). Throughagricultural development and water abstraction from the river, the river now has a single-channel form and its flow regime has become non-perennial. This has changed sedimenttransport and deposition patterns within the river, affecting the characteristics of the bedand decreasing the ability of the channel to convey floodwaters. The dense stands of alienvegetation in the riparian zone of the river have exacerbated the erosion of the river banks(Ollis et al, 2016).



Ecological importance and sensitivity.The section of the Vink River is considered to have low-to-moderate ecological importanceand sensitivity “r”, as rated using the River EIS tool of DWAF (1999). It is important tobear in mind that the floodplain along this river has been recognised as an Aquatic CBAin the WCBPF and the C.A.P.E. Fine Scale Planning initiative for the Upper Breede Valley(Section 3.6.1.5). This elevates the conservation importance of the river corridor andimplies that it should be protected from any further degradation (Ollis et al, 2016)

Ephemeral drainage lines.Two ephemeral drainage systems were confirmed to be present by FCG within theoriginally proposed development areas, one in the western portion (“Drainage line 1”) andanother one (“Drainage line 2”) in the north-eastern portion of the proposed mining areas.

In the revised mine plan (Figure 3-15), “Drainage line 1” and a 30 m buffer around thisephemeral river system will be left out of the newly proposed locations for mining andbrickmaking activities. This was based on the recommendations of the freshwater andbotanical specialist studies (Ollis et al. 2016 and Krige 2016a, respectively) that thewestern portion of the proposed site should be conserved as an ecological corridor.“Drainage line 1” was rated by FCG to be in natural to near-natural ecological condition(Ecological Category A to A/B) and of low-to-moderate overall ecological importance andsensitivity with a moderate EIS for habitat criteria. These factors, together with the locationof the river system within a broader terrestrial CBA corridor identified to be of highconservation importance by the botanical specialist (Krige 2016a), highlight why, from anecological perspective, this drainage line should be protected from mining and brick-making activities.

“Drainage line 2”, which was rated by FCG (Ollis et al. 2016) to be largely natural with fewmodifications (Ecological Category B) in terms of its PES but of low ecological importanceand sensitivity, is a less prominent ephemeral river system than “Drainage line 1”. It willstill be affected by the revised mine plan; in particular, this drainage line would becompromised due to the northward shifting of the proposed brick-making facility to avoidencroachment into the buffer area of the Vink River floodplain.

There is an additional ephemeral river system that could be affected by the revised mineplan, which was not assessed by FCG in the initial Freshwater Ecosystems ImpactAssessment (Ollis et al. 2016). This system, which lies in the eastern portion of theproposed mining area, is referred to as “Drainage line 3”. A map showing the alignmentof the river, as delineated by FCG during the October 2016 fieldwork, is presented inFigure 3-15. This map also shows the buffer area of 30 m in width along the edges of thedrainage line, which is the recommended minimum buffer size determined by FCG for theprotection of drainage lines on the subject property from the proposed mining and brick-making activities during the initial assessment (Ollis et al. 2016). The recommendedbuffer width of 30 m for the ephemeral drainage lines on the subject property wasdetermined through application of the WRC Buffer Tool (Macfarlane et al. 2014), with theassumption that certain mitigation measures would be implemented (in addition to theprotective buffer) to reduce the risk of sedimentation. These mitigation measures will befurther discussed in Section 6 of the report and will also form an integral part of the EMPReport. As the characteristics of “Drainage line 3” are similar to those of the ephemeralstreams that were previously assessed, and because this stream would be subject tosimilar land-use impacts (clay mining-related activities), the same buffer width isconsidered by FCG to be appropriate.



The additional sections of “Drainage line 2” that would be affected by the revised mineplan are very similar to the sections of this drainage line that would have been affected bythe originally proposed mining plan. Most of the drainage line is very indistinct, resemblingthe surrounding terrestrial vegetation and not having a distinct channel (Figure 3-18), withthe exception of the upper reaches of this to the north of the proposed mining and brick-making areas (as shown on the map in Figure 3-15) and very short sections immediatelyadjacent to tar road that this drainage feature runs under (via a culvert).

Figure 3-18: Photograph of sections of “Drainage line 2” showing a lack of distinct channelfeatures [taken on 14/10/2016]]( Ollis et.al. , 2016).

“Drainage line 3” is a more prominent system than “Drainage line 2”, with a distinct channelclearly observable along sections of the drainage line (See Figure 3-19). This drainageline is similar to “Drainage line 1” in that it is largely characterised by a dense vegetationassemblage of medium to tall shrubs, with an observable structural difference to thesurrounding terrestrial landscape. The riparian zone of “Drainage line 3” is dominated bydense stands of Acacia karroo, together with other shrub species such as Searsialongispina, Lycium oxycarpum, Salsola aphylla and Asclepias fruticosa. The herbaceouscomponent within the drainage line and its riparian zone includes species such asEragrostis curvula, Bromus sp., Atriplex lindleyi subsp. inflata, Trifolium angustifolium andJuncus sp.

“Drainage line 3” was assessed by FCG to be in relatively good ecological condition, withoverall ratings of Ecological Category B (i.e. largely natural with few modifications) for boththe instream and riparian components. Most of the impacts on this system relate torelatively low levels of water abstraction and diversion within the catchment, the presenceof roads, and localised disturbances (including a breached off-channel dam adjacent to



the river), which have led to flow and channel modifications, and the a localised decreaseof indigenous vegetation in certain sections.

The results of the EIS assessment for “Drainage line 3” were very similar to those for“Drainage line 1” from the previous assessment by FCG. This drainage line was alsorated to be of low/marginal ecological importance and sensitivity in terms of biotic criteria,but once again with a low level of confidence due to the absence of biotic data. It is, asin the case of “Drainage line 1”, considered by FCG to be of at least moderate importancein terms of providing refugia for fauna and forms an important ecological corridor betweenthe Vink River and the up-slope areas, thus rated to be of moderate EIS in terms of habitatcriteria. “Drainage line 3”, like Drainage lines 1 and 2, flows through a relativelyundisturbed natural area that has been identified as a terrestrial CBA. This drainage linehas also been identified as an ESA for which the management objective should be themaintenance of ecological processes.

Figure 3-19: Photograph of “Drainage line 3”, showing a section of the stream with arelatively prominent and sparsely vegetated channel [taken on 11/07/2016] (Olliset.al., 2016).



Comments on proposed new layout plans with respect to fresh waterecological

The potentially negative impacts on river ecosystems that could result from the proposedmining activities, relate to the potential for the direct, permanent loss of sections of naturalephemeral rivers, and the habitat and biota associated with these systems. The proposedamended Mine Plan would pose a risk of this by mining through portions of the naturalcourse of “Drainage line 2”. The impact of mining directly adjacent to “Drainage line 3”canbe mitigated by the provision of terrestrial buffer areas along the edges of the potentiallyaffected drainage lines, within which limited or no development activities are carried out.The recommended 30 m buffer areas are shown on the map in Figure 3-15. In the caseof “Drainage line 2”, although a significantly larger portion of this drainage line would betransformed or permanently lost to mining activities with the Revised Mine Plan comparedto the originally proposed plans, the diversion of this less prominent and importantdrainage line around the newly proposed mining and brick-making areas is considered tobe acceptable from a freshwater ecological perspective if the previously recommended“no-go” area (along “Drainage line 1”) and the recommended buffer areas for “Drainageline 3” and the Vink River floodplain were to be protected from mining and brick-makingactivities. Furthermore, under such mitigating circumstances, it is anticipated that nocumulative impacts of significance to freshwater ecosystems would be applicable to theproposed mining activities.

3.6.3 FaunaThe Western Cape has a relatively low concentration of large terrestrial mammals.However, the smaller fauna such as rodents, reptiles, insectivores and birds are prolific inthe mine zone. As most of the project area is an agriculturally transformed habitat, littleof the region’s historical / natural fauna is likely to occur. The wetland / drainage areasprobably supports a number of species by providing refugia associated with these typesof habitats.

Reptiles that may occur in the project area include various lizards and skinks as well assnakes, such as the venomous Cape Cobra (Naja nivea). Various indigenous tortoisesmay occur in the project area. The Endangered Geometric tortoise (Psammobatesgeometricus) is restricted to low-lying Renosterveld shrubland in the Western CapeProvince, but is not expected to occur in the project area.

According to the South African Bird Atlas Project 2 (SABAP2, 2016), approximatelybetween 136 and 231 avifaunal species (64 km2 vs 576 km2 area) surrounding theproposed mine right area have been recorded (SABAP2 2016). Of these, one species islisted as being a conservation concern, the Blue Crane (Anthropoides paradiseus), whichis listed as Endangered in terms of NEMBA (Regulation Notice R.389).

Although large game such as mountain zebra, eland and bontebok once roamed theregion, no large mammals occur in the area at present. Smaller mammal species that arestill likely to occur in the region include baboons (Papio ursinus), as well as porcupine(Hystrix africaeaustalis - the largest rodent in southern Africa) and the endemic Capegrysbok (Raphicerus melanotis) (CK Rumboll & Partners, 2012). Both the porcupine andthe grysbok are active at night and may occur in the project area. No mammal species ofconservation concern are expected to occur in the project area.



3.7 NOISE

Noise can be defined as "unwanted sound". Response to noise is not an empiricalabsolute, it is often a psychological concept and does not need to be loud to be considered“disturbing”. Depending on their activities, people generally are tolerant to noise up to acertain absolute level, e.g. 65 dBA. Anything above this level will be consideredunacceptable.

The major noise generating activities will be the development, mining, closure andrehabilitation of the proposed opencast trenches and the development, and operation andclosure of the ancillary brick making facilities. Potentially sensitive receptors wereidentified using Google Earth and topographical maps, supported by a site visitinformation. These are listed in Table 3-3 and illustrated in Figure 3-20. Receptors withintwo kilometers of the opencast trench are identified as relevant, all others are consideredbeyond the range of influence. The “Coffee and Wine Shoppe” is therefore a potentialreceptor.

Table 3-3: Localities of residents and tourism facilities within immediate area of operation.

Noise Receptor Lat & Long Approx. distancefrom operation

Saggy Stone Micro Brewery and Restaurant 33°41'37.74"S19°43'6.11"E

7.49 Km

Tierhoek Cottages — Orange Grove Cottages 33°42'44.03"S19°47'21.56"E

6.48 Km

Buitenstekloof Mountain Cottages 33°44'16.25"S19°44'43.65"

2.10 Km

Coffee Shoppe Cafe @ Le Roux & FourieVignerons (on directly Adjacent Property)

33°45'40.79"S19°44'22.86"E

0.67 Km

Wine Shoppe — Le Roux & Fourie Vignerons(on directly Adjacent Property)

33°45'40.79"S19°44'22.86"E

0.67 Km

Rooiberg Cellar & Wine Shoppe, Bistro, Shop 33°46'37.26"S19°45'43.09"E

2.83 Km

Increased noise levels are directly linked with the various activities associated with theconstruction of the mining area and related infrastructure, the operational as well asclosure phase of the activity. The following noise generation activities are considered:

Construction of access/haul roads; Surface preparation activities in front of the opencast pit; Removal of vegetation; Topsoil stripping and stockpiling; Boxcut (trench) development; Rehabilitation activities, such as the loading of topsoil, transport to the area to be

rehabilitated, levelling of area, levelling of topsoil and Other maintenance (wetting of roads, support and maintenance vehicles, light

LDVs) traffic.



Figure 3-20: Localities of residents and tourism facilities within immediate area ofoperation. The yellow circle indicates the zone of noise extent. Dark redindicates the 1km fugitive dust fallout and light red indicates 2 km fugitive dustfallout. Both are plotted along the prevailing wind direction (bottom rightcorner).

In general, closure activities have a significant lower noise impact than the operationalphase. Therefore closure activities will not be considered in this report, however, a closureEMPr must be developed by the mining operation at the end of the mining operation, whichis more specific and accurate and noise could be addressed in this document.

Ambient noise levels are required to be within the range of 0dBA and 45dBA/ 35dBAduring the daytime and nighttime respectively according to the SANS-10103:2003 (SouthAfrican National Standards)1 for noise within a rural setting (see Table 3-4). However,local noise levels could be higher, due to the close proximity of the R60 National Roadand the operation of the Cape-Lime processing facility.

1 In South Africa the document that addresses the issues concerning environmental noise is SANS 10103. Itprovides the maximum average ambient noise levels, LReq,d and LReq,n, during the day and nightrespectively to which different types of developments may be exposed. While the area where the mining willbe taking place is considered rural, the Zone Sound Levels used in this report are:

• Day (06:00 to 22:00) - LReq,d = 45 dBA, and • Night (22:00 to 06:00) - LReq,n = 35 dBA.



The mine equipment will include: a Komatsu PC 200 Excavator, a Bell B17B 15 m3

capacity dump truck, and a 4WD service vehicle. Typical sound power levels from suchequipment is in the order of 77 to 110 dBA (A-weighted decibels) at 15 m.

A Noise Impact Assessment Report is not considered necessary based on the fact thatthe mine operates limited machinery. However, given the proximity of the nearby noisereceptors a simplistic model was undertaken.

Assumptions:

1. The excavator runs at 100 dBA2. Baseline measurement is at 1 meter3. The effect of reverberation and the topography is ignored.

Model:

1. Convert decibel level to sound intensity using: 100 dBA= 10-2 W/m2

2. Baseline intensity X (distance 12 / distance 22)3. This showed a drop-off of 6.02 dB at a doubling of the distance.

Table 3-4 : Noise limits per sector (SANS-10103:2003)

Type of District

Equivalent Continuous Rating Level For Noise (dBA)

Outdoors Indoors with open windows

Daytime Night-time Daytime Night-time

RESIDENTIAL DISTRICTS

Rural Districts 45 35 35 25Suburban districts(little road traffic) 50 40 40 30

Urban districts 55 45 45 35

NON-RESIDENTIAL DISTRICTSUrban districts

(workshops,business premises

and main roads)60 50 50 40

Central businessdistricts 65 55 55 45

Industrial districts 70 60 60 50

Based on the accepted sound level drop of 6 dB per doubling of distance; simple modelingpredicts sound levels to approximate 45 dBA at 500 m from source as shown in Table 3-5and Figure 3-21. This is below the 65 dBA level considered to be acceptable and withinthe 45 dBA requirement for rural districts according to the SANS-10103:2003 regulationlimits. (See Table 3-4).



Table 3-5: Level of sound intensity with increasing distance from source.

Figure 3-21: Level of sound intensity with increasing distance from source.

Additional reduction of noise from trench activity will be ensured by the fact that theoperational level of the excavator is below surface and vegetated berms will be builtaround the trench providing additional sound barriers. The extruders and kilns of the brickmaking facility are low noise and will not present an impact. There are various ways inwhich the noise impact of the mining activities toward the single receptor can be furthermitigated.

Allowing a setback (buffer zone) of at least 500 meters (even with the berm inplace) between the closest mining activities and sensitive receptors;

Ensuring no night time operation of plant; Ensuring that all equipment and machinery are well maintained and equipped with

silencers (where possible); Considering the noise emission characteristics of equipment when selecting

equipment for a project/operation.

Distance from source (m) Intensity (W/m2) Decibel reading (Db) DB Drop-off2 2.50E-03 93.97940009 6.0205999134 6.25E-04 87.95880017 6.0205999138 1.56E-04 81.93820026 6.02059991316 3.91E-05 75.91760035 6.02059991332 9.77E-06 69.89700043 6.02059991364 2.44E-06 63.87640052 6.020599913128 6.10E-07 57.85580061 6.020599913256 1.53E-07 51.83520069 6.020599913512 3.81E-08 45.81460078 6.0205999131024 9.54E-09 39.79400087

0

10

20

30

40

50

60

70

80

90

100

1 40 80 120 160 200 240 280 320 360 400 440 480 520

Decib

el

Distance from source (m)

Decibel reading (Db)

Decibel reading (Db)



3.8 SOCIO-ECONOMIC ENVIRONMENT

Cape Winelands District Municipality (CWDM) has rich historical heritage, wine routes andnatural beauty and boast the longest wine route in the world, Route 62, which gives thetourism sector significant growth potential.

The Langeberg area is one of the largest wine producing regions in South Africa.Langeberg Local Municipality covers a total area of approximately 4 517 km2. Major townsin the municipality include Ashton, Bonnievale, McGregor, Montagu and Robertson(Umvoto, 2016b).

3.8.1 DemographicsCWDM is one of six district municipalities in the Western Cape. It consist of five localmunicipalities namely Stellenbosch, Drakenstein, Witzenberg, Breede Valley andLangeberg. The district covers a geographical area of approximately 22 300 km2 (CWDM,2014). Accurate population projections were estimated by the Western Cape Departmentof Social Development for each local municipality in the CWDM (Figure 3-22). The totalpopulation for 2016 was estimated to be 842,638 (WCGPT, 2015).

Figure 3-22: Cape Winelands District Municipality population projection (WCGPT, 2015)

Langeberg population was estimated to be 102 472 in 2016 and is estimated to grow to106 016 by 2020 (WCGPT, 2015), (see Figure 3-22). The coloured community is thedominant population group in the Langeberg Municipality accounting for 70 % of thepopulation. 16 % are black and the white population accounts for 12 %. The dominantlanguage is Afrikaans, with 81% of the population speaking Afrikaans as a first language,10 % of the population speaks isiXhosa and 3% are English first-language speakers.Approximately 66% of the population fall within the age 15 – 64 and are in the workingage category. (Figure 3-23) (Stats SA, 2011).

Witzenberg Drakenstein Stellenbosch Breede Valley Langeberg2015 124 492 263 912 167 572 174 198 101 5432016 126 573 267 013 170 572 176 008 102 4722017 128 614 270 070 173 557 177 793 103 3892018 130 605 273 068 176 519 179 548 104 2872019 132 546 275 984 179 463 181 262 105 1602020 134 440 278 794 182 373 182 938 106 016

-

50 000

100 000

150 000

200 000

250 000

300 000

Popu

latio

n

Cape Winelands District Municipality:Population projection (2015 - 2020)



Figure 3-23: Distribution of age for the given population

Robertson is the closest town in proximity to Gannabosch Vlakte 51 and is the largesttown in Langeberg LM. According to the Water Reconciliation Strategy for Robertson2014, the population of Robertson was estimated to be 31 366 (DWS, 2014).

3.8.2 EducationThe Matric Pass rate in 2014 was at 84.2 % in 2014, while the 2011 total literacy rate inwas 75.3%, thus making Langeberg LM, the lowest ranking LM for literacy rates in theCWDM (Figure 3-24)(WCGPT, 2015).

Figure 3-24: Education level for Langeberg LM (statsSA,2011).

Aged(65+ years)

7%

Children(0 - 14 years)

27%Working Age(15 - 64 years)

66%

Population - Age Distibution

No Schooling3%

Some Primary46%Completed Primary

8%

Some Secondary32%

CompletedSecondary

9%

Higher Education1%

Not Applicable1%

Education Level of the Langeberg LM



3.8.3 EconomyThe Langeberg LM is the 2nd fastest growing economy in the CWDM. The industriesresponsible for this growth, from 2005 to 2013, are the Commercial services andConstruction industry with GDPR growth at 7.9 % and 7.8 % respectively (Table 3-7). TheLangeberg economy generated R 5.8 billion of the districts R50.2 billion gross valueadded. The GDP growth rate from 2005 – 2013 for Langeberg LM was 4.3%. The threelargest sectors are Manufacturing (31.6 %), Agriculture, Forestry & Fishing (18.3 %) andwholesale and Retail trade, Catering and Accommodation services (13.1 %) (WCGPT,2015). Details of this are provided in Table 3-6.

Table 3-6: Economic activity by sector for Cape Winelands District Municipality (CWDM,2015)

Economic activity by sector gross value added (R’000)

Sector 2011 2012 2013Agriculture 5 368 652 5 491 433 5 703 900

Mining 43 485 46 698 50 017Manufacturing 6 892 365 7 536 979 7 950 378

Electricity 704 199 850 829 945 261Construction 1 520 543 1 670 249 1 973 711

Trade 4 739 416 4 609 242 5 078 004Transport 2 395 830 2 679 522 2 778 014

Finance 6 789 252 7 485 500 7 575 350Community Services 8 689 803 9 431 274 10 319 518

Total 37 143 545 39 801 726 42 374 153Taxes less subsidies on products 4 891 617 5 333 178 5 896 423

Total (GDP) 42 035 162 45 134 904 48 270576Source: IHS Global Insight Regional Explorer, 2015

Table 3-7: GDP vs net employment

GDPR growth vs net employment (2005 - 2013)Industry GDPR trend Net Employment

Agriculture, forestry & fishing 0.30% -6313Manufacturing 3.50% 55Construction 7.80% -191Commercial services 7.90% 2922General government and Community, social &personal services

5.10% 1659

Other -0.40% 81Total 4.30% -1337

Economic drivers of Robertson are agriculture, with it notably being the largest pear-production region in the country, while including extensive apple and apricot productionas well. The wine route experience attracts many tourist to Robertson and its surroundsas R62 passes through Robertson. There is also a Limestone mine near the town ofRobertson (DWS, 2014).



South Africa ranks 9th in the world in terms of wine productions and contributes 4% of theworlds production. The Western Cape accounts for 95 % of the total planted area in SouthAfrica. Robertson is a major wine producing area with 14 676 hectares of vineyards(SAWIS, 2014) (WCDA & WCDEA&DP, 2015).

The Agriculture, forestry and fishing (AFF) sector in the Western Cape has experienced2% job losses per annum from 2000 to 2013. The CWDM has been worst affected. Thejob losses can be partially linked to the economic downturn of 2008-2009. The servicessector has absorbed many of those retrenched from the AFF sector and there has beena shift from a primary agriculture-based economy to secondary and tertiary sectors(WCDA & WCDEA&DP, 2015).

The agriculture industry is the largest employer and is what drives the CWDM economyand closely linked to agro-processing (manufacturing sector), finance and businessservices sector. The GDP of the CWDM in 2013 was R 48 Billion. Exports of agriculturaland agro-processing product has been key for growth in the district (CWDM, 2015).

The Building and Construction sector experienced the highest GDPR growth of all sectorswith 9.7 % year on year over the last ten years. (Steenkamp, J. 2016). The sector isearmarked for continued growth as SMME investors are noting the potential of the region.This growth may be restricted into the future by a shortfall in the brick supply. Existingdemand for brick is approximately 1 000 000 (Steenkamp, J. 2016) and the current supplyof approximately 640 000 per annum is unable to meet this demand (see Table 3-8). Theclosure of the Montagu Klein Karoo Bricks in 2016-07-31 has further exasperated theproblem.

Table 3-8: Current Brick Suppliers

Brick suppliers to the Regions Estimated volume bricks per annum

A H Marais Building Supplies 460 000

Montagu Build It 31 000

Independent Builders 150 000

Future escalation in demand will rise to between 2 000 000 to 3 000 000 per annum.Support for this data is provided in Table 3-9 which lists the proposed new projects duefor development in the next five years.

Table 3-9: Future developments and estimated brick demand

New construction projects earmarked forfuture development

Estimated volume bricks forproject

Timeframe

Village Square [ Shoprite Mini Development]2200 m ²

200 000 – 300 000 6 months

Shoprite Checkers Development 6500 m ² 700 000 – 900 000 12months

Protea Hotel 700 000 – 900 000 12months

Retirement Village 9000 m ² 2 000 000 – 8 000 000 5 years



3.8.4 Employment and IncomeThe CWDM consist of 198 265 households of which only 131 546 are classified as formalresidential households. The unemployment rate was up to 16.11 in 2013. 9.7% ofhousehold have no income (Figure 3-25) (Stats SA, 2011).

Figure 3-25: Average Household Income (Stats SA, 2011).

Employment growth rate was -0.4% from 2005-2013, with commercial services,agriculture , forestry and fishing, and “general government & community, social andpersonal services” being the major employers in the Langeberg LM, employing 30%, 27%and 22% respectively in 2013. Table 3-7 indicates net employment growth per industryhighlighting that there has been 1337 job losses overall and that the Agriculture, forestryand fishing has had a net loss of 6313 between 2005 and 2013, likely due to the 2008financial recession and a shift from agriculture-based economy to secondary and tertiarysectors, mechanization and less labour intensive practices. The sector responsible for themost job creation was that of the commercial sector, noting small business as the keydriver for employment (WCGPT, 2015). It is noted that the majority of the local labour forceare employed in the “semi to unskilled” labour force accounting for 41% of localemployment, while also being the only labour force to show a decrease in employmentopportunities between 2005 and 2013 (Table 3-10), (CWDM, 2015).

Table 3-10: Employment per skill sector (2005 – 2013) in Langeberg LM

Sector composition Number Growth p.a 2005 - 2013

Highly skilled 3 038 2.6 %

Skilled 7 526 1.7 %

Semi- and unskilled 12 050 -4.3 %

Informal 6 778 6.1 %

Total employment 29 392 -0.4 %

0% 5% 10% 15% 20% 25% 30%

No incomeR1 - R4,800

R4,801 - R9,600R9,601 - R19,600

R19,601 - R38,200R38,201 - R76,4000R76,401 - R153,800

R153,801 - R307,600R307,601 - R614,400

R614,001 - R1,228,800R1,228,801 - R2,457,600

R2,457,601+



3.8.5 HealthIn 2015 there were 16 health care facilities in Langeberg LM of which 8 were fixed clinics,6 mobile /satellite clinics and 2 district hospitals but no regional hospital. CWDM is notedas having the highest ambulance coverage area due to the great distances betweentowns. Anti-Retroviral treatment clinics were numbered at 7 and TB treatment clinics/sitewere number at 16 in 2015 (WCGPT,2015). Langeberg LM patient load increased to 1 858(Table 3-11). Teenage Pregnancies delivery rate to woman under 18 was 9.8% (WCGPT,2015).

Table 3-11 - HIV, AIDS & Tuberculosis prevalence and care (2015)

Illness Medical Situation Number

HIV –Antiretroviral

treatment

RT Patient load March 2013 1 237

ART patient load March 2014 1 579

ART patient load March 2015 1 858

Mother-to-child transmission rate 0.0 %

Number of ART clinics/treatment sites 2015 7

Tuberculosis

Number of TB patients 2012/13 1 006

Number of TB patients 2012/13 998

Number of TB patients 2012/13 1 039

Number of TB clinics/ treatment sites 2012/13 16

3.8.6 Service DeliveryLangeberg LM has 27566 households, of which 84.7% are considered a free standinghouse or brick structure (Table 3-13). Of the 27566 households, 79.9 % of have accessto water within their dwelling, 14.2 % within their yard, and 3.7 % within 200 m of theirdwelling (WCGPT, 2015). The housing backlog was reported to be 3 898 units. Backyarddwellers estimated to be 1055 (DWS, 2014).In 2011 94.2 % of households used electricityfor lighting and 89.3 % used electricity for cooking. Wood and Gas is also a significantenergy source for heating and cooking (Stats SA, 2011). While not necessarily within onesdwelling, 83% of individuals have access to a flushing toilet (Table 3-12).

Table 3-12: Toilet availability for Langeberg Local Municipality (WCGPT, 2015)

Toilet Facility PercentageNone 3,3%Flush toilet (connected to sewerage system) 83%Flush toilet (with septic tank) 6,1%Chemical toilet 0,2%Pit toilet with ventilation 0,2%Pit toilet without ventilation 0,4%Bucket toilet 2,5%Other 4,3%



Table 3-13 Types of Housing Structure within Langeberg Local Municipality (WCGPT, 2015)

Dwelling Type PercentageHouse or brick structure on a separate stand or yard 84.7 %Traditional dwelling 0.4 %Flat in a block of flats 1.4 %Town/ cluster/semi-detached house (simplex, duplex or triplex) 3.2 %House/ flat/ room in backyard 0.9 %Informal dwelling/ shack in backyard 6.0 %Informal dwelling/ shack NOT in backyard, e.g. in an informal/ squattersettlement

2.3 %

Room/ flatlet not in backyard but on a shared property 0.2 %Other 0.8 %

3.9 HERITAGE ENVIRONMENT

The farm's survey diagram dates to 1871 and it was originally referred to as Lot 45. Itappears to have never been subdivided. The 1942 aerial photograph shows the site to beundeveloped except for two dams in the eastern and south-eastern parts of the farm. Twopatches of arable land lay alongside the river (areas that are uncultivated today) (Figure3-26).

The R60 followed a different alignment and the cement factory was not yet present. Thesite was still largely undeveloped in 1949 aside from the dam in the east (see Figure3-27). In 1960 a servitude was surveyed from the northern corner of the farm towards thesouth. By 1963 there was more arable land along the river but the site remainedundeveloped. In the 1973 aerial photography (Figure 3-28) we see that a clearing alongthe south-western boundary is evident and the limestone mine to the north is already inoperation. The strip of land between the site and the river appears to be entirely cultivated,but the site remains undeveloped aside from the clearing. The cement factory is probablyin operation, although this is difficult to tell for certain given the resolution of the imagery.In 1993 the mine has expanded considerably. (Figure 3-29).



Figure 3-26: 1942 aerial photograph showing the farm (black polygon) and two dams(turquoise ovals).



Figure 3-27: The site was still largely undeveloped in 1949 aside from the dam in the eastwith Farm 51 outlined in black.



Figure 3-28: 1973 aerial photography of the broader area showing the limestone minedeveloped in the northeast and the factory in the southwest alongside the R60(red arrow). Farm 51 is outlined in black. Both dams appear to be in use.



Figure 3-29: 1993 aerial photography of the broader area showing the limestone mineexpanded in the northeast. The factory site is arrowed and Farm 51 outlined inblack. Both dams are still evident.

3.9.1 Landscape and natural features of cultural significanceThe agricultural nature of the project area is typical of the Klein Karoo region. Theindigenous vegetation has largely been converted and only very small remnant pocketsof indigenous vegetation remain. The landscape mainly comprises, livestock farming,orchards and vineyards (add comment on actual cultivated crops) and has beenextensively farmed for the last 200 years and vast tracks of landscape have beentransformed for crop cultivation (Umvoto, 2016a).

The landscape is known for its scenic qualities and historical scenic routes. The R 60 isa lead-in road to the well branded Route 66.which functions as an inland alternative, oradd-on to the world famous and internationally renowned, Garden Route along the N2.The route provides travelers with broad expansive vistas over undulating agricultural hills,in a viticultural milieu and is one of the Western Cape’s key wine routes. Distinctivetopographical mountain peaks like Towerkop and vistas into the distance over theSwartberg and the Cape Fold Mountains, provide excellent summer touring, hiking and



snow possibilities in the winter. Sense and identity of place is primarily correlated withagriculture and movement routes that have reacted to the natural and physicalenvironment over specific land patterns of the region, combined with climate andhydrology, and have given rise to a cultivated farmland mosaic against a backdrop of theLangeberg Mountain belt to the north and the smaller Riviersonderend Mountains to thesouth, both of which form part of the Cape Fold Mountain chain. Lying in the Klein Karoovalley lowland between these two quarzitic mountain ranges, the Breede valley lies in amicro-climate and well-watered environment. Vineyards are the most notable form ofagricultural cultivation in the region. Wine estates of regional importance have beenestablished around the towns of Worcester and Robertson. Farming has diversified in theregion which is also known for sheep and cattle farming, horse husbandry, fruit cultivation,flower growing and wine making, each of these activities creating its own landscapetypology (Umvoto, 2016a). The impact of mining on this environment will be more fullydiscusses under Section 6 of the EIA. However it is worth noting that due to the plannedphased nature of the mining (where smaller sectors will be mined at a time) it is expectedthat the present Cape Lime Factory and the trucks using the haul road to the north willprovide a greater visual impact than the proposed new mine which will not have as manystructures on site. The site lies some 700 to 1500 m from the R60 and, because of thegenerally subsurface nature of the mining, the visual impacts to the landscape are ratedas moderate (refer to Visual Impact Assessment, Section 3.2 for further detail). The brick-making facility would be located 1 km from the R60. Emissions from the facility will bepresent at firing times and further information on this is under Section 4.1.4.

3.9.2 Archaeological resourcesDuring the original heritage site assessment (Annexure D-1: First Notice of Intent toDevelop), a number of isolated stone artefacts were noted scattered across the site withthe majority being in the western half of the property. Only in one instance were twoartefacts found together, the rest were all single finds (appendix of Annexure D-1: FirstNotice of Intent to Develop). They appeared to be a mix of Early, Middle and Later StoneAge artefacts with quartzite being favoured for Early and Middle Stone Age artefacts andquartz for Later Stone Age artefacts and of no great cultural significance (Orton, 2016). Inone location near the western corner of the site there were two refined earthenwareceramic fragments, two glass fragments and a used shotgun cartridge. Although thesematerials (with the possible exception of the shot gun cartridge) are certainlyarchaeological (being greater than 60 years of age), they are of no significance on theirown. Although the site had heuweltjies (ancient termite mounds) present on it, there wasno evidence of artefacts being more closely associated with them than anywhere else ashas sometimes been found in the western parts of the country (e.g. Knersvlakte) (Orton,2016).

During mine development of the site, the stripping of topsoil’s would result in any presentartefacts being moved around when the topsoil is cleared and stockpiled and thenredistributed during rehabilitation. Because of their very low value, no significant heritageimpacts are expected.

3.9.3 Paleontological resourcesThe SAHRIS Palaeo-sensitivity map (see Figure 3-30) shows the site to be shaded ingreen indicating medium sensitivity, and while this typically requires a desktop study (Seelegend below), during the site visit it was noted the underlying geology (visible thoughexcavation on site) has become weathered to the degree that the hard rocks has turnedto clay with no chance of fossils being preserved (Orton, 2016). There is always a verysmall chance of intersecting unmarked human remains dating to the Later Stone Age but



the chances are very small. Such finds can never be predicted, and if a grave was foundit would be disturbed but the chances of this happening are very small (Orton, 2016).

Figure 3-30: Extract from the SAHRIS Palaeosensitivity map showing the local geologicalunits to be of moderate sensitivity (green shading). The site is indicated by thered polygon.

3.9.4 Amended NIDAn amended Notification of Intent to Develop has been submitted to Heritage WesternCape due to change in the position of the mine excavation trench and the change in sizefrom 14 ha to 23.06 ha. This amendment mainly concerns additional areas to the northand east of the existing application zone. The specialist report concludes that; “There isno reason to believe that any more significant archaeological remains would occur in theextra portions of land now under consideration for the present application. (Orton, J.2016). Heritage Western Cape confirmed that no further studies are required.



3.10 DESCRIPTION OF THE SPECIFIC LAND USES ON THE SITE AND NEIGHBOURINGPROPERTIES

3.10.1 Current on Site Land UseThe Vink and Norries rivers flow adjacent to the project region, along with several drainagelines that bisect the proposed mine area. Several farm dams surround the areas, thoughnone lie within the zone (note from Heritage NID that two disused dams were situated inthe target area). The land in the mine application area is still in its original state consistingof indigenous vegetation (Breede Alluvium Renosterveld). Multiple EAP site visits on 30th,31st October 2015, 6 November 2015 and 10 August 2016 and the Botanical SpecialistReport by Krige, confirm that there are no cultivated fields, no stock farming or grazing onthe land. The Heritage Report by Asha Consulting concurs that there is no historicalevidence of any cultivated or cleared lands within the proposed target area. The HeritageReport indicates a 1960 servitude from the northern corner of the farm towards the south,the same servitude links in to a concrete slab, indicative of the remains of a building,presumed to be a store. Two historical, and now overgrown dams, were situated in theeastern and south-eastern parts of the farm.

3.10.2 Surrounding Land UseThe project area lies on a portion of the farm Gannabosch Vlakte 51. The area is borderedto the south west by the Vink River and is located ~500 m north east of the R60 nationalroad, which runs through the Cape Winelands district, joining Worcester and Robertson.

Gannabosch Vlakte No.51 is situated within a rural farming area. The primary land usageconsists of cultivation of wine grapes, minor stone fruit (peaches), as well as small scalegrain cultivation to supply fodder for the minor non-intensive livestock farming occurringon adjacent and non-adjacent properties. On a non-adjacent property, ~2km to the North,a limestone quarry (Cape Lime) operates to supply the limestone to the processing plantwhich is located on the adjacent property, Lange Vallei 5/52, just to the south ofGannabosch No.51 property.

Table 3-14 and Figure 3-31 indicate the surrounding farm units and their land uses thatmay be affected by the proposed mining.

Table 3-14: Neighbouring property land use

Farm Portion Land Use ActivitiesMiddelburg

9/10Thicket / Dense bush & Shrubland Fynbos – Land Cover (DEA,2014)

MiddelburgRE/10 Enterprises: Fruit - Wine grapes (Crop Census, 2013)

Alwynbos VlakteNo.299 Shrubland Fynbos – Land Cover (DEA, 2014)

Noree No.300Shrubland Fynbos – Land Cover (DEA, 2014)

De Hex Rivier18/50 Enterprises: Fruit - Wine grapes (Crop Census, 2013)

Lange Vallei5/52

Enterprises:Fruit – Mostly wine grapes and some peach (CropCensus, 2013)



Figure 3-31: Neighbouring farms to Gannabosch Vlakte 51.

The farm property lies at its closest, ~3 km from the Langeberg-West Mountain Catchmentconservation area which forms part of the Mountain Catchment Conservation. Asubsection of this area is shown in Figure 3-32 below. The smaller Dooringkloof PrivateNature Reserve is located ~4 km to the north.

Figure 3-32: The Langeberg-West Mountain Catchment Conservation and DoringkloofPrivate Nature Reserve that are in close proximity to Gannabosch Vlakte 51.



3.10.3 Nearby Business/TourismThree of the six adjacent properties have agricultural enterprises on their property. Theimpact of the proposed mining activity and brick making factory on these properties willbe assessed in Section 6, Environmental Impact Assessment. Aside from agriculture, themain economic activity in the area consists of the limestone quarry mine and the CapeLime processing plant.

The proposed mining site is part of the Rooiberg Breede River Conservancy. TheConservancy currently has 27 member landowners (not including Friends of theConservancy) – who manage, farm or own approximately 13 500 ha land around theGannabosch area.

Figure 3-33: Land units associated with the Rooiberg Breede River Conservancy, 13 550 haof land of which Gannabosch Vlakte 51 is shown in central position.

The target area falls within the Breede River Valley wine route, which is a feeder road intothe R66 Klein Karoo tourist route, which serves as an alternative to the highly popular N2Garden Route. Viticulture and related tourist interest is a noted activity in the region. TheMap in Figure 3-20 and Table 3-3 show the locality of the most proximate tourism venuesthat may be affected by the proposed development of the Gannabosch mine.

The Rooiberg Mountain Bike Trail (see Figure 3-34) is offered by the conservancy and ispart of the tourism initiatives that are currently being developed for the area. The MTBtrail runs directly along the southern border of the proposed mine. The merging of tourismactivites and mining need not be seen as conflictual, both are means and methods ofadding value to a region. The mine will interact with a small section of the total length of

Mine Site



the trail. With the appropriate mitigations of windrows along the southern border of themine concession, it is envisaged that the two activities can be accommodated.Alternatively a minor deviation of the existing MTB trail to the north could be proposed asanother mitigation opportunity.

Figure 3-34: The Rooiberg Mountain Bike Trail seen to be running adjacent to the southernborder of the mine concession.

There will be a visual impact to drivers/tourists along the R60 route. However from acumulative impact perspective, it may be preferable to consolidate the visual impact intoone area, alongside the Cape Lime Plant. Alternative clay resources are shown in Figure3-35 and all three of these sites are equally visible to the road users. The siting of themine along these sites, removed from Cape Lime, would have had a greater cumulativeimpact with repeated visual impacts, than is currently predicted in the proposed position.

Associated with and positioned on the concession area will be a brick manufacturingfacility. Although the brick making factory is not an integral part of this EIA Report, it willbe discussed at an elementary level so as to aid decision makers in making informedanalysis of the impact. This will be further addressed in Section 6, Environmental ImpactAssessment. Noise generated from mining activities and its impact on residential andtourist neighbours has been discussed under Section 3.7 of this report.



Figure 3-35: Alternative sites along the R60. Note the much closer proximity as well as thelarger extent.

3.10.4 ResidentialThe closest residential settlements and housing developments to the proposed miningsite are found in the town of Robertson, which includes the town suburbs and the outlyingNkqubela Settlement. These are located 14 km to the east and will remain unaffected bythe proposed development. Closer to site, the nearby residential dwellings are of lowerdensities and home to residents predominantly associated with the rural agriculturalpractices of the area. Utilising the GIS tool (Cape Farm Mapper:http://gis.elsenburg.com/apps/cfm/), a ~5 km search radius was undertaken. This searchrevealed 19 dwellings. These dwellings were primarily located along the banks of theNoree River, ~3 km to the east of the proposed mine property, and further SE of theconfluence of the Noree and Vink River (See Figure 3-36). Fewer dwellings were locatedto the north and north-west. Properties which lie in the south east of the proposeddevelopment will be in the fugitive dust fallout zone which is orientated along the prevailingwind axis. (Figure 3-20).

3.10.5 Alternate land useAs the land unit lies within a CBA, there will be restrictions imposed on the landowner interm of agricultural, cultivation and grazing rights. Should the proposed mining operatingnot go ahead, the land will be left untouched and remain as un-utilised land within theCBA. In the untouched state it will benefit the region through the provision of a landscapecorridor required for habitat connectivity and an upland-lowland corridor between theLangeberg Mountains and the Breede River . An alternate, suggested by Cape NatureConservation, is additional mitigation in the form of a biodiversity offset. Such an offsetshould be obtained according to the Western Cape’s Draft Provincial Guidelines onBiodiversity Offsets and a suitably selected botanical specialist will need to be appointedto conduct the study. The offset will need to identify a suitable area with a comparative“like for like” vegetative value and the determination of a multiplication factor for land size.

Mine Site



It would further need to set out the most appropriate regulatory mechanism for securingstewardship of the area for conservation in the long term.

The proposed mining method is open cast trenching. Alternatives to this are not an option,there is no other feasible manner to extract the clay. Consideration has been given toexcavating in sections and part rehabilitating simultaneously and concurrently with miningso as to minimise and manage the impact to the environment, however this will be morefully discussed in Section 8.5 of this report.

Figure 3-36: Residential dwellings shown within approximately three kilometres ofGannabosch Vlakte 51, mostly located in the south and east along the Vink andNoree Rivers.

3.11 AIR QUALITY

Dustfall and suspended particulate matter (PM10 and PM2.5) are emitted due to materialhandling, vehicle entrainment, material processing, coal combustion within the clampkilns, and wind erosion of stockpiles. There are two potentially sensitive sites within a twokilometre zone (see Figure 3-37):

(a) The offices and factory of the adjacent lime works; and

(b) A roadside trading store (wine retailing) and restaurant. The owner of the facility hashis home on these premises



Figure 3-37: Human habitations in the vicinity of the proposed Gannabosch Clay Mine andRobertson Brick Factory. The dots represent established homesteads. Thediameter of the circle is 2 km, centred on the site of the quarry. Green starindicates Manager’s residence, blue cross indicates Cape Lime Works offices

Both these sites are off axis of the along-valley prevailing wind directions (south west tonorth east), so are unlikely to be adversely affected by particulate matter (dust) emissionsfrom the proposed facility. The range of impacts is limited to 1 to 2 km from source, dueto the rapid loss of particles from the airstream by gravitational settling and dilution (seeFigure 3-20). The lime works and the proposed brick factory are off set from each otheralong the prevailing wind directions, so their dust impacts are not likely to be cumulative.

The anticipated dust impacts are moderate to slight, and. Adverse environmental impactswith mitigation are limited to possible soiling of indigenous vegetation within maximum 1km from the boundary, with slight probability of reducing photosynthetic activity of thevegetation. Dust in the size range 20 to 100 µm diameter, originating from unenclosedmaterial handling and processing, and from wind erosion of unconsolidated stockpiles,will result in fallout dust (vertical deposition onto horizontal surfaces) and impaction dust(horizontal deposition onto vertical surfaces). This will be most apparent in strong wind ofgreater than 15 km/h. Below this wind speed of 15 km/h, particles in this size rangegenerated by mechanical handling will deposit within the site boundaries, and the windhas insufficient energy to generate dust from unconsolidated surfaces.

With regard to emission from the clamp kilns, it is noted that passive monitoring studiesof SO2 along the boundary lines of other brick works in South Africa have not yielded anyinstances in which the concentrations approached the national DEA limit values. Sulphurdioxide concentrations beyond the boundary will be within the National Ambient Air QualityGuidelines. There are no other activities emitting SO2 within a 5 km radius, so there areno cumulative concentrations that could raise the ambient SO2 levels towards the limit.



4 PROJECT DESCRIPTION

4.1 PROJECT DESIGN:

4.1.1 Layout, road network and infrastructureThe spatial locality and GIS data of the amended project may be seen in the Mine LayoutMap in Figure A-0-7. This layout plan is drawn in accordance with regulation 2(2) of theMPRDA (Act 28 of 2002). Existing road infrustructure will be utilised to gain access to theproposed mining property (See Figure 1-1 and Figure 1-2). The property is located alongthe Divisional Road (DR 1384) (Langvlei Quarry Road) off the R60 Trunk Road (TR 31/1).Traffic movement in relation to the western portion of the mine will not impact on DR 1384,as the mine and facorty are located on the same land parcel. In respect of movment ofclay ore from the eastern portion of the mine to the brick factory; there will be crossing ofthe Langvlei Quarry road in one place only, but no travel along the road. Three inbound(mine to factory) truckloads and three outbound truck trips per hour crossing DR 1384 willoccur between the proposed mining area on the eastern side of the road and the brickmaking facility. The brick factory will impart a higher useage to the road (four interlinktruck trips per day) with the transport of bricks off the plant. A Traffic Impact Statementprepared by a specialist and will be included as part of the Environemtnal Authorisationfor the Brick Factory and is also attached to this EIA as Annexure I.

Earthworks and boxcutThe positioning of earthworks are not fixed, and relocate in accordance with the northwardmovment of the trenching process includes:

Overburden storage area, as water deflecting berms on outside of trenches; Topsoil storage area to be temporarily stored on un-mined sections; Trenches and bench sidewalls of the boxcut;

InfrastructureOffsite provision of services and monitoring is shown in Figure 4-1 and includes:

Three phase electrical provision kiosk; Locality of two boreholes and proposed pipeline providing factory processing

water. Exact route of pipeline is yet to be finalised and Air monitoring collection points along prevaling wind axis;

On site infrastructure is shown in Figure 4-2:

Brick Making Factory /Processing plant; Office, stores, ablution and workshops; Clay delivery stockpile; Clamp kilns; Brick drying yard; Access road internal and external; Windrows of indigenous trees as dust and visual barrier; Divert culvert and furrows for managing stormwater and Berms for directing and managing storm water flow



Figure 4-1: Offsite provision of services showing water and electrical source and airemission monitoring points.

4.1.2 Mining MethodThe proposed mining method (open pit mining) will require the use of an excavator toopen the box cut and load into a tipper/dump truck for transporting the clay to the brickmaking factory. The process starts with the removal and safe storage of topsoil and isfollowed by the stripping of the overburden to an estimated depth of 15-30 cm, to exposethe clay ore. The ore will be mined in a series of box cuts, allowing for a 3 meter horizontalbench between one meter vertical meter layers. Benches will be tilted 150 from verticalinto the face to channel runoff water towards the sump. Extracted clay is moved to astockpile central point within the trench by the excavator and transported by tipper truckto the brick factory. A 20 ton excavator will be rented from Robertson Bakstene (Pty) Ltd,for the mining process. Robertson Bakstene will upload the raw clay for transport to thebrick production facility by making use of a single 15 ton tip truck.

To allow access for the excavator and dump-truck, and allow for passing space, a four-meter boundary road will be constructed around the trench and mine footprint.



Figure 4-2: On site infrastructure showing proposed trenching methodology.

Topsoil StorageThe open pit trench methodology for the clay mine is to strip and store the topsoil, andoverburden. Both are stored separately for later replacement. Depending on the depthof overburden it may be used as berms for storm water management. Topsoil will beinitially stored on unmined portions of the concession. Topsoil stockpiles will be not morethan two meters in height to minimise seed and organic compression and will be protectedby shadecloth to avoid dessication and wind erosion. The exposed ore body is thenabstracted by excavator. The intention is to ensure that rehabilitation takes place almostconcurrently with the mining process. This is done for several reasons, most importantly;to ensure the topsoil and seed stock storage time is minimised; to reduce the trench sizeand hence drainage and ingress water management; and thirdly to mitigate the visualimpact by reducing the trench footprint.



BoxcutsThe proposed way forward is therefore to mine in sectional trenches starting in at thelowest point in the south of the concession area and moving nortward. The mine area willbe subdivided into a number of trenches, (see Figure 4-2). Each trench is minedseperately and to completion. Ideally the concurrent mine rehabilitation technique willensure that topsoil is not stored for longer than 3 months.

For the purposes of the Mine Work Program and in order to formulate a theoretical modelthe boxcuts are intended to be 100 m along the north south axis and vary along an eastwest axis. The mined trenches will then be filled as the adjacent new trench is openedconcurrently. Figure 4-2, displays the pattern showing mining areas with shifting topsoilstorage. The process described will minimise travel distance between topsoil / overburdenstorage and the trench.

A step by step example of how this will work follows:

1. Sump dams are located as the initial trench at the southern point;2. Mining will commence on the western portion of the concession;3. A starter trench , No 1, is opened and the topsoil is placed on the area to the north

that is yet to be mined, trench No 3.4. Trench No 2 is opened, whilst trench 1 is refilled with the topsoil from storage on

trench 3.5. Topsoil from trench 2 is placed on an area to the north that is yet to be mined

demarcated for trench 4.6. Trench 2 is is refilled with the topsoil from storage on trench 4.7. The process repeats moving northward.8. On completion of the western portion of the mine concession a similar process will

follow on the eastern portion.

The final benched trench may look approximate to a concpetual photo shown in Figure4-3.

Figure 4-3: Shows the traditional bench mining practiced at clay quarries. The proposedquarry on Gannabosch Vlakte will likely be mined in a similar fashion with thestorage sump being located on the lowest level in the southern corner.

Concurrent RehabilitationThe methodology of mining in sectional trenches, as described above, will mitigate thevisual and cumulative impacts on the property. The sectional trenches allow for a shorterturnaround time of the topsoil for rehabilitation purposes once the pit has been fully minedto an approximate depth of 6 to 10 m below ground level. Ideally, no topsoil should be instorage for longer than three months. The slopes of the pit will be profiled to a 1:3 gradient,



before the rehabilitation of the pit takes place. The opening of trenches will commence inthe south and move northwards to allow for a sump to be positioned at the lowest point(see Section 4.1.3 below).

It is estimated from the Mine Work Model that the clay material will be extracted from thepit to a depth of approximately six meters on average throughout the entire mine area.Assuming a 1-meter overburden and topsoil replacement, this will result in the trenchbeing approximately 5 m below ground level post filling.

4.1.3 Stormwater Management PlanThe aim of the storm water management plan (SWMP) is to fulfil the requirementspresented in Government Notice 704 (Government Gazette 20118 of June 1999) whichdeals with the separation of clean and dirty water. It also complies with the principlespresented in the DWAF Best Practice Guideline G1 Storm Water Management (2006).

The hardened surfaces around the mine and factory will result in an increase in stormwater runoff and an elevated concentration of suspended clay particles. The SWMPensures that all surface flows from the mine area are captured and deflected by bermsand channels and directed into sump ponds situated in the southern, lowest portion of themine trench areas. This is considered dirty water and will not be allowed to enter theephemeral drainage lines or the Vink River as direct flow.

The attenuation of storm water flow in these sumps will be of sufficient capacity to allowfor the containment of a 1:50 year flood event. It is intended that the captured water willbe recycled via bowser or sprinklers for dust suppression. In the unlikely event that flowsexceed the sump storage capacity, the overflow will be discharged into drainage line 2below the mining area. This overflow will be directed through a vegetated swale prior toreaching the receiving water body to ensure it is turbulent free with reduced velocities.

Surface run-off from the clean areas upstream of the mining area will be directed aroundthe mining areas either towards drainage line 1 or back into drainage line 2 by means ofgravity. To achieve this, two berms with associated channels are to be erected along thenorthern boundary of the proposed brick manufacturing facility. The larger of the twoberms will intercept drainage line 2 further north and redirect the run-off around thewestern corner of the mining area and into drainage line 1. To avoid sedimentation at theentry point a row of swales will be constructed upstream of entering drainage line 1 to trapany sediment transported in the diversion.

A second berm will be constructed directly at the northern boundary of the mining area todivert the remaining part of drainage line 2 (Clean area B) towards and along the road.The diversion will end at the existing culvert, which initially channels the flows under thestreet back into drainage line 2. Once mining occurs in the south-eastern area (southerncorner of Dirty area B), the diverted water will be temporarily diverted into the sump of themining pit.

A strategically placed sump at the north-eastern edge of the proposed manufacturingfacility following the natural gradient and course of drainage line 2 allows for slowing downthe storm water and causing some of the excess suspended clay particles to be removedvia settling.

This approach allows for the incremental development of the storm water managementsystem and infrastructure as mining progresses from the western area (Dirty A) to theeastern are (Dirty B). This would further reduce the impact of diverting drainage line 2, asa significant volume is diverted back into the lower parts of drainage line 2.



Stormwater management infrastructure has been conceptually designed as per therequirements of GN 704 with the layout presented in Figure 4-4.

Figure 4-4: Conceptual storm water management plan.

4.1.4 Volume and production forecastIt is envisaged at start up to produce about 45 000 m3 clay per annum, (approx. 67 500Tons, @ 1 500 kg per m3) which would equate to 225 m3 per day or 27 m3 per hour, whichcan be accomplished by a single 20 Ton excavator in an open pit mining process. The15 m3 dump truck will require approximately 15 loads per working day which isaccomplished within a 20 minute round trip between trench and the Robertson Bakstene’sbrick manufacturing facility. Production is expected to reach peak by year 3 at 360 m3 perday. This load can still be managed by the single 20 Ton excavator and the dump truckwhich will increase delivery up to 24 trips per 8 hour working day.

The estimated mineral resource on the property is approximately 1.2 and 1.3 million m3

(1.8 and 1.95 million Tons) of clay for the production of brick. This is according toprospecting drilling done by the proponent and a resource evaluation study undertakenby Umvoto Africa (see Section 4.4). Assuming a 10 year extraction of up to 670 000 m3;



this is sufficiently large to justify a mining right for a period of ~18 years. Following thisconcept there is no “decline period” anticipated within the first 10 years.

4.1.5 Project description of the Associated Brick Making FacilityThis EIAR does not intend to provide a detailed account of the brick making process asthis will be dealt with in its entirety under the Environmental Authorisation procedures withthe DEA & DP. The regulatory Atmospheric Emission License in respect of NEM: AQA,2004 (Act No.39 of 2004) will likewise be handled in the factory environmentalauthorisation process. However, in order to provide stakeholders with an understandingof the process and an understanding of likely air emissions, a brief project descriptionfollows:

The proposed brick making facility, Robertson Bakstene (Pty) Ltd will source clay from theadjacent clay mine on Gannabosch Vlakte 51. The material will be transported from themine stockpile to the offload point at the brick making facility. Mined clay ore is a material,all of which is used in brick making, and not a mineral that needs to be extracted or won(as in the term “winnings”) from a host rock by primary processing of crushing, washing,screening. At the brick factory stockpile, the material will then be reclaimed using a front-end loader and transferred onto the production line, where the beneficiation process isbegun. See flowchart in Figure 4-5.

To supply the needs of the brick factory at start up, operating at a production rate of2 million units per month*, an extraction rate of 60 000 to 70 000 tons, or approximately45 000 m3, of ore per annum is required. This is demonstrated and explained as follows:

1 m3 dry clay excavated = 1073 kg; 1 m3 wet lump clay excavated = 1602 kg; Assume a mix of dry and wet and use 1 500 kg (std industry norm); Excavate 27.6 m3 per hour = 41.4 tons per hour = 331.2 tons per day, assuming 8-hour working day = 66 240 tons per year, assuming 200 working days per year = 60 500 – 70 000 tons per annum = 40 000 – 47 000 m3 per annum Assume a mined volume of 45 000 m3 per annum for start-up, to be

increased gradually as demand and capacity of BMF increases

*1 m3 = 500 bricks

45 000 m3 = 22 500 000 brick per annum

Hence, approximately 40 tons of raw material per hour, is tipped into a feed hopper to becrushed, ground and screened, via two crushers, a Fine Crusher and a Roller Crusher.The coarser mixture, from the Roller Crusher is mixed with the finer crushed material tothe desired blend. Body fuel in the form of coal dust called duff coal is then added to thedry mix in a 15 % by mass ratio, this provides the fuel for the firing process. Approximately3500 to 4000 litres of water is mixed into the raw material. This implies the water demandof the processing plant is a maximum 4000 litres per hour.



Figure 4-5: Simplified flowchart of brick making process.

The raw materials and water are mixed together in a process called “pugmilling”. Theresultant mix is sent through an extruder where the bricks are cut to size and shape.Extruded green (wet) bricks are transported using a fork lift to a drying area where theyare air dried for approximately two to three weeks, dependent on weather conditions. Thedrying area is roughly two hectares in size. The bricks are then transported to the clampkilns where they are fired into the finished hardened clay brick product. The clamp furnaceis charged with small nut coal for ignition (2.6% of the clay mass). The cooling processtakes a week after which the product is ready for palleting and transferred to the finalproduct stock yard for despatch.

The firing process is expected to produce some atmospheric air emissions from the kilns.Particulate Matter (PM10 and PM2.5), Sulphur Dioxide (SO2), Sulphur trioxide (SO3), andNitrogen Oxides (NOx) are the main types of emission expected. There will be Carbonemissions from the usage of duff and small nut coal in the brick body and kilnsrespectively. PM emissions may be reduced via a variety of techniques, such as using ahigh water content in the manufacturing process to keep dust levels down. Further fugitiveemissions from storage piles and unpaved roads can be controlled using wet suppressiontechniques.

The management of the brick making factory and specific mitigation measures fall outsideof the scope of this mine right application EIA report. The design of the facility, themanagement practices and the proposed mitigation of emission can be referred to in theEnvironmental Authorisation application and Notice of Intent to Develop that is submittedto the Western Province Department of Environment Affairs and Development Planning(DEA & DP).



4.1.6 Waste ManagementThe National Environmental Management Act: Waste Act, 2008 (Act No. 59 of 2008), andthe corresponding list of waste management activities that have, or are likely to have, adetrimental effect on the environment (GNR 921, 2013), are set out in three categories.Category A, requiring a BAR, and Category B, requiring a full S&EIR will not apply as themine will not trigger any listed activities in either category. Category C, does not requirea Waste License but does require that activities are compliant with the relevant norms andstandards determined by the minister. Again, the mine does not contravene any suchnorms viz.

Storage of waste:

No hazardous waste will be stored on site that exceeds 80m3

Recycling and recovery of waste:

No activities that relate to landfill gas, or the scrapping and recovery ofmotor vehicles will take place on the site.

By taking the above into consideration, the proposed activities on Gannabosch Vlakte 51do not trigger the requirement for a waste licence, nor compliance with any norms orstandards as listed in Category C. However, should any new activities arise, over thecourse of the duration of the proposed activities, that trigger any of the listings in categoryA, B, or C, the proponents will take the necessary steps to ensure that the NationalEnvironmental Management: Waste Act, 2008 (Act No. 59 of 2008) will be complied withbefore commencing any triggering activities.

Domestic waste will be removed on an ongoing basis to the Worcester municipal wastefill site and discarded. A strict re-cycling program will be followed to ensure the separationof appropriate materials. No waste materials will be reintroduced into the open pit area.Broken bricks will be sold off, as seconds, at the mine gate. Ablution facilities with an on-site septic tank will be provided.

4.2 PROJECT MANAGEMENT

A Record of Decision (ROD) is expected by the end of April 2017. Following granting oflicence the applicant will proceed to develop mine infrastructure and procurement ofequipment and hiring of personnel. This process is anticipated to run through until end ofthe second quarter of 2017. A three to six month build-up period is anticipated to iron outinitial problems and the mine is expected to be in full production by the start of 2018. Theconcurrent rehabilitation process will be in process by the same time. As indicated inSection 4.1.3 the life of mine is predicted to run for 12 to 15 years possibly up to 2032.The decline period and final rehabilitation with closure is expected to be after 2032. Theplanned mine development is noted by the Gantt chart in Table 4-1 below.

The mine manager will be appointed in terms of Section 3 (1) of the Mine Health & SafetyAct, 1996 (Act 29 of 1996). The machine operator will be appointed in accordance withrequired skills and trained as and where necessary to ensure competency and legalcompliance. Skills training is more fully covered in the Social and Labour Plan which hasbeen submitted to the DMR.



Due to the small scale operation of the mine and the abstraction of a low value industrialcommodity, it is considered too small to justify a full-time Health and Safety andEnvironmental Control Office. The basic tasks will be conducted by the mine mangerappointed by Gannabosch Clay Mine and the staff working on site. The professionalcapacity of a HSO and ECO function will be outsourced to a service provider if and whenrequired.

Table 4-1: Gantt chart for planned project management phases

4.3 PROPONENTS PROJECT MOTIVATION

4.3.1 Suitability of the ore for beneficiationThe sole commodity to be abstracted from the proposed Gannabosch Clay Mine wouldbe that of shale brick clay. In 2015, a sample was sent to the Cermalab department of theCSIR in Pretoria. A summary of the report follows and the entire report is available as anannexure to the MWP.

The Mix clay (blend of clay samples taken from property) showed good workability /extrudability, has good green strength and showed good resistance to dog-earing duringextrusion. The clay is not sensitive to fast drying and showed no cracks during rapiddrying. Normal air drying is good for the first 24 hours after which it can be put into thedryer. The clay has a medium plasticity index of 20.3. The material has a critical moisturecontent of 20%. The Mix clay has high breaking and good crushing strengths when firedto temperatures between 950°C and 1100°C. In comparison, plaster bricks require acrushing strength of 7 MPa and face bricks 17 MPa (Cermalab, 2015).

The Mix clay is a coarse-grained material which has good extrudability properties and canbe used on its own to produce good red burning face bricks. The Mix clay contains suitablematerial to enable shaping by extrusion after little souring (See Table 4 2). There aresufficient inert minerals in the clay to enable stacking after shaping without deformation.The mix clay has an optimum firing temperature of just over 1100 °C and even when usedon its own is suitable for producing face bricks with suitable strength from 1000 °Cupwards. (Cermalab, 2015).



Table 4-2: Clay Composition

While the primary constituent of raw clay for brick-making is SiO2 (sand), should it bepresent in large quantities, it lowers the green and fired strength of clay. Thus the reasonthat the raw clay (minimal sand) is preferred for solid brick manufacture. A sufficientamount of primary fluxes (Na2O + K2O) are present in the raw material to producesufficient strengths at economical temperatures. The Mix clay contains a fair amount,3.59%, iron oxide which will act as a flux at higher temperatures (> 1000 °C). The ironoxide will produce fired colours ranging from red and brown under oxidizing conditions toblue and black under reducing conditions (Cermalab, 2015)

4.3.2 Market supply and demandWith the majority of brick manufacturing facilities in the Western Cape being locatedbetween Stellenbosch, Paarl, Malmesbury, Atlantis and Durbanville (Perold, 2006), theprospect of the brick manufacture within the Cape Winelands region gives good possibilityfor being one of the sole suppliers for the local market.

An Economic Impact Study by Bauhaus Simple Property Growth suggests the buildingand construction sector experienced the highest GDPR growth of all sectors within theLangeberg LM at 9.7 % year on year over the last ten years, resulting in an estimated onemillion shortfall of Bricks to the region (Steenkamp, 2016). To offset the shortfall thewholesale suppliers of brick, AH Marais, Independent Builders and Build It, have resortedto importing stock from the surrounding regions of Cape Town, Stellenbosch, Paarl,Malmesbury, Atlantis, Durbanville, Oudtshoorn and Bredasdorp. (Perold, 2006). Figure4-6 shows the locality of clay mine sites and brick manufacturing plants and demonstratesa paucity of manufactures in close proximity to Robertson. The situation was furtherexasperated by the closure of Montagu Klein Karoo Bricks. The raw clay is seldom traded,thus proximity to a brick plant is essential. It is exclusively used for the manufacturing ofclay brick products and must derive its value from the sales revenue generated from thebeneficiated product. Bricks are high mass, low profit items and the transportation costshave pushed local prices upwards and increased road traffic, road maintenance costs androad safety, calling for a solution to satisfy a growing demand.

Since 2002, a steady growth of above 15% in the use of clay brick has been realizednationally in the building and construction sector, especially in the residential componentof this sector, representing an increase of some 200 million bricks year on year (Martin,2004). The entire Western Cape production only accounts for 0.33 (11.2 %) billion bricksout of South Africa’s total 2.8 billion in production (Perold, 2006), thus an increase in localmarket demand is forecast. A more detailed account of the local Robertson demand isprovided in Section 3.8.3.



It should be noted that no beneficiation of the raw clay will be undertaken by GannaboschClay Mine (Pty) Ltd. The product as extracted and stockpiled will be sold to RobertsonBakstene (Pty) Ltd. for the manufacture of bricks. The manufacturing plant will be situatedon the mine right area and Section 4.1.4 in the EIA Report provides a brief overview ofthe manufacturing process and associated environmental impact.

Figure 4-6: Locality of clay mine sites and brick manufacturing plants, showing a paucityof manufactures in close proximity to Robertson.

4.4 EXPLORATION RESULTS

The proposed mine area covers an area of 28.67 ha, divided into a western and easternsector that is separated by the Langvlei Quarry Road. The clay ore is present within 0.5 mbelow the surface of the proposed mining area at varying depths in the QuaternarySediments. These sediments consist of eroded Malmesbury Group shales, as well asweathered regolith of the Whitehill and Collingham Formation of the Enon Group. Referto Section 3.3 for a more in depth analysis of the geology of the mine area.

The prospecting of trial pits has proven yields of between 75 and 100 % by volume in theupper 5 metres below ground level (mbgl). The ore is proven to a depth of 5 to 10 mbglat lower yields of between 3 and 30 %. Figure 4-8 models a cross sectional view of thewestern sector illustrating a total open pit extract volume of 1 053 866 m3 which will bemined with 3 x 1 benched pits to an average depth of 6 mbgl and a maximum depth of10 m in isolated areas, delivering an estimated 538 255 m3 of clay ore which is a 51 %yield ratio. Figure 4-9 models a cross sectional view of the eastern sector illustrating atotal open pit extract volume of 956 334 m3, delivering an estimated 690 307 m3 of clayore which is a 72 % yield ratio. Topsoil and overburden material is present to an averagedepth of 0.4 mbgl, totalling ~87 856 m3. The 29 prospecting trial pits, GB-TH 01 to GBTH29 positions are shown in Figure 4-7.



Figure 4-7: Prospecting test pits drilled at 29 sites to determine depth of clay ore.



Figure 4-8: A cross sectional view of the western sector showing a 51 % yield ratio.

Figure 4-9: A cross sectional view of the eastern sector showing a 72 % yield ratio.



5 STAKEHOLDER ENGAGEMENT

A public participation process (PPP) was undertaken for the EIA for the development ofthe proposed mining right area by GCM. This process was managed by Umvoto Africaas follows.

- Application submitted to DMR 2016-02-28 (10082MR)- BID published 2016-03-07- Newspaper adverts 2016-03-07- Signs set up on proposed mine area 2016-03-07- Draft EIA Report circulated to IAPs for comment 2016-07-22.- Public meeting convened Robertson Municipal Library 2016-08-10.- Application to DMR for extension of time 2016-09-20- Amended Draft EIA Report sent to IAPs 2016-11-14- Adverts Cape Time and Die Burger 2016-11-14- New signs set up on proposed mine area 2016-11-14- 2nd PPP 2016-12-08- Commenting period on Amended Draft EIA Report closed 2016-12-15- Deadline submission of EIA and EMP report to DMR 2017-01-06

The first draft EIA and EMP Report was sent to all Registered IAP’s and Organs of Statefor review. A decision to extend the IAP consultation process from 8 September 2016 to6 January 2017 was agreed upon between the DMR and the applicant to allow for theadditional specialist studies to be concluded and incorporated, and to facilitate theadditional public participation process, as requested by DMR. Accordingly, an amendedsecond draft of the EIA and EMP Report was prepared for review. Comments from asecond round of a PPP have now been incorporated into the Final EIA and EMP Report.

5.1 OBJECTIVES OF THE STAKEHOLDER ENGAGEMENT PROCESS

The overall aim of stakeholder engagement is to ensure that all IAPs have adequateopportunity to provide input into the process and raise their comments and concerns. Morespecifically, the objectives of stakeholder engagement are to:

Identify IAPs and inform them about the proposed development and S&EIRprocess;

Offer IAPs the opportunity to participate effectively in the process and identifyrelevant issues and concerns; and

Offer IAPs the opportunity to review documentation and assist in identifyingmitigation and management options to address potential environmental issues.

Note:It is important to recognize that an IAP is a general term used to describe any person ororganisation (private or governmental) with concerns and interest in the project, while thestakeholder is a more specific term used to describe persons or organisation who have vestedinterest or legislated authority over the land or an aspect of the project. We use the broaderterm of the IAP to cover both parties.

5.2 INTERESTED AND AFFECTED PARTIES CONSULTATION PROCESS

Below (See Table 5-1) is the summary of the consultation of the process that has beenfollowed from the beginning of the EIA process being followed to facilitate the decision onthe EA application by GCM.



Table 5-1: Stakeholder engagement activities undertaken during the Scoping Phase.Task Objective Reference Dates

Initial discussions withaffected landowners *

To notify affected landowner Grobbelaar of the proposed project and obtain initialcomments and permissions to apply for a mining Right on his property N/A November 2015

Submission of Forms toDMR DEA&DP Register the application for EA and confirm authority requirements.

EA Application SAMRAD ref:

WC30/5/1/2/2/10082MR14/02/2106

Release of BackgroundInformation Document (BID);

Publication of newspaperadvertisements;

Erection of signage onproposed site.

To notify stakeholders of the proposed project and the commencement of the EIAprocess, and to request registration as IAPs

UA BID Report No:

856/03/02/2016 07/03/2016

Initial IAP registration period To provide stakeholders with the opportunity to register as IAPs for the project 07/03/2016

Release of draft ScopingReport for stakeholdercomment

To provide stakeholders with a description of the proposed project and the affectedenvironment, as well as a description of potential environmental issues, and the Planof Study for the Impact Assessment Phase

UA Draft Scoping Report No.

856/03/01/2016 07/03/2016

1st public comment period To provide IAPs with the opportunity to review and comment on the planneddevelopment as laid out in the BID document.. 07/03/2016

Release of Final ScopingReport to registered IAPs

To update the Scoping Report in response to comments made and to present theshortlisted footprint alternatives.

UA Final Scoping Report No.

856/03/03/201607/04/2016

Submission of Final ScopingReport to DMR & DEA&DP To provide authorities with information for decision-making

UA Final Scoping Report no:

856/03/03/201607/04/2016

Release of the first Draft EIRand EMPr to all registeredIAP’s and relevant Organs ofState for comment

To provide stakeholders and IAP’s a thorough description of the proposed project , theaffected environment, a description of potential environmental issues, a broad scopeon an EMPr,

UA Project No 856

Draft EIR and EMPr Reportno: 856/06/01/2016

22/07/2016

Public meeting No 1 Engage with public and IAP’s and allow for any clarification on any topics/processesrelating to the project

Appendix E: Minutes of firstpublic participation meeting 10/08/2016



Task Objective Reference Dates

Application to DMR forextension of deadline

In response to comments arising from the PPP an extension was requested to allowfor additional specialist studies. Extension granted to 6 Jan 2017. 20/09/2016

Publication of newspaperadvertisements regardingthe 2nd Draft EIR and EMPr.

Erection of amendedsignage on proposed site.

Provide an opportunity for existing and potentially new IAP’s to provide comments onthe second draft of the EIA and EMPr. Figure 5-1 14/11/2016

Release of the second DraftEIR and EMPr to allStakeholders and IAP’s forcomment

To provide stakeholders and IAP’s a chance to review the second draft of the EIR andEMPr which has been amended to include issues brought up in the initial draft reviewphase. It includes a thorough description of the proposed project , the affectedenvironment, a description of potential environmental issues, a broad scope on anEMPr.

UA Project No 856

Draft EIR and EMPr Reportno: 856/06/02/2016

14/11/2016

Public meeting No 2 Engage with public and IAP’s and allow for any clarification on any topics/processesrelating to the amended project.

Appendix E: Minutes of firstpublic participation meeting 08/12/2016

Final Submission of EIA andEMPr.

Submit three copies to DMR, one copy to Roberson Public Library, provide copy atUmvoto Africa offices, upload electronically to the Umvoto Africa Website and toSAMRAD.

06/01/2017



The approach adopted for the initiation of the EIA and associated Public ParticipationProcess (PPP) was to identify and contact as many potential Interested and affectedparties (IAPs) as possible through a number of activities outlined below:

5.2.1 Identification of Key StakeholdersEIA Regulations (December 2014), require that all relevant local, provincial and nationalauthorities, conservation bodies, local forums and representatives and affectedlandowners and occupants are notified of the EIA process and the release of the ScopingReport for comment. As specified in GN R982: 42(a), all persons who submitted writtencomments, or requested in writing to be placed on the register, were registered as IAPsand were notified of opportunities to comment on the project and the EIA process. Inaddition, the relevant Competent Authority (DMR) and Commenting Authorities (Organsof State) were automatically registered as IAPs.The proposed Mine Right application site is located within Ward 6 of the Langeberg LocalMunicipality, Robertson Magisterial / Administrative District in the Western Cape Province.They have been included as Registered Interested and Affected Parties and have beenalerted to the application by email and registered post. Ward Councillors of Ward 6 havealso been individually contacted by email and registered letter. The Local Municipality hasbeen contacted and an application submitted for land use change as per requirements ofLand Use Planning Ordinance (LUPO).A list of the stakeholders currently registered on the IAP database is provided in(Appendix B- Interested and Affected Parties Register). These include:

Organs of State, provincial departments and institutions: Department of Mineral Resources (DMR) Department of Environmental Affairs and Development Planning (DEA&DP) Department of Water and Sanitation (DWS) Breede-Gouritz Catchment Management Agency (BG CMA) Heritage Western Cape Department of Rural Development and Land Reform (DRDLR) Regional Land Claims Commission: Western Cape Cape Nature Department of Transport

Local authorities: Cape Winelands District Municipality Langeberg Local Municipality (Robertson) Ward councillor: Ward 6

Parastatals: Eskom Transnet PRASA

5.2.2 Notification of the EIA ProcessA Background Information Document (BID) (See Annexure B: Background InformationDocument) containing information about the proposed mine and the EIA process wascompiled and distributed to the initial list of registered IAP’s by post and/or email (seeAppendix B- Interested and Affected Parties Register).



Two newspaper advertisements announcing the commencement of the S&EIR process,the availability of the BID and inviting members of the public to register on the IAPdatabase were placed in both a regional paper, the Cape Times and the “Die Burger (KaapPlatteland)” on 7 March 2016. A second notice is issued on the 14 November 2016 in boththe Cape Times and the “Die Burger (Kaap Platteland)”. The notice made aware to allexisting and potentially new IAP’s that a second Draft EIA and EMPr is available for publicreview (See Figure 5-1). A Notice Board has been erected at the original site of theproposed mine. A second board will be placed at the new site east of the Langvlei QuarryRoad.

5.2.3 Release of Draft Scoping ReportThe release of the draft Scoping Report for public review coincided with the release of theBID. The BID was sent to all identified and registered IAPs by post and/or email andindicated the availability of the Scoping Report from the EAP upon request. Hard copiesof the full report were placed at the following venues for public review:

Umvoto Africa office in Muizenberg.Site notices (posters) announcing the availability of the draft Scoping Report for publiccomment were placed (in Afrikaans and English) at:

Offices of the Langeberg Local Municipality in Robertson;

Robertson Public Library;These posters announced the availability of the draft Scoping Report for comment,contained details of the proposed project and EIA process and provided the contact detailsof the EAP.Hard copies of the complete draft Scoping Report were sent to the following governmentdepartments for comment:

WCDM (Municipal Manger, Environmental Officer, Town Planning, CorporateServices and Landcare);

Langeberg LM (Municipal Manager, Development Services and Town Planning,Building Control and Valuations);

CapeNature (Land Use Advice);

The Department of Mineral Resources

5.2.4 Issues and Concerns Raised by IAP’s during ScopingWritten submissions were received from registered IAPs during the Scoping Phase.These comments and concerns are incorporated and considered in Section 6 of this EIRand addressed by including mitigating procedures as contemplated in the EMPr inSection 8. A summary of the comments is provided in Appendix C-1: Tabulated IAPResponses on Scoping Document.Stakeholder engagement activities during the Impact Assessment Phase are aimed atensuring that the specialist studies and the assessment of potential impacts by the EIAproject team address the issues and concerns raised during the Scoping Phase.Opportunities to raise further issues for consideration are also provided to stakeholders.



Cape Times newspaper article (7 March2016)

Die Burger (Kaap Platteland) newspaperarticle (7 March 2016)

Cape Times newspaper article (14November 2016)

Die Burger (Kaap Platteland) newspaperarticle (14 November 2016)

Site advertisement posted on the proposed mining property (7 March 2016).

Figure 5-1: Advertisements posted in local and regional newspapers and on the affectedproperty of the EIA and PPP process.



5.2.5 Release of first Draft EIA ReportAll registered IAPs were notified of the release of the first draft EIR and EMPr for comment.Notifications, including copies of the Executive Summary were posted, or e-mailed to allregistered IAPs on the 22nd of July 2016 and hard copies of the report were made availablefor review at the following venues for a period of 30days:

Robertson Public Library(30 Van Reenen Street, Robertson, Western Cape, 6705; Tel 023 626 2972)

Robertson Local Municipality(52 Church Street, Robertson, Western Cape, 6705; Tel 023626 8200)

Umvoto Africa office(8 Beach Road, Muizenberg, Western Cape, 7945; Tel. 021 788 8031)

Hard copies of the complete first Draft EIA and EMPr were sent to various governmentaldepartments and institutions at their requirement and/or request, including but not limitedto the DMR, Cape Nature and DEA & DP.A public meeting was held on 10 August 2016 between 14h00 and 17h00 as a questionand answer session with any stakeholders, IAP’s and general interested parties/public(Appendix E: Minutes of first public participation meeting) for discussions and answeringof any questions related to the project and mine application process.5.2.6 Issues and Concerns Raised by IAP’s on first Draft EIA ReportWritten submissions of comments and concerns were received from a range of registeredIAPs on the Draft EIA Report. These comments and concerns are incorporated andconsidered in this 2nd Draft EIR and addressed in several sections of this report. Asummary of the comments is provided in Appendix C-1: Tabulated IAP Responses onScoping Document.5.2.7 Release of second Draft EIA ReportAfter the release of the first Draft EIA and EMP, it was concluded that a resubmission ofan amended second Draft EIA and EMPr for public review would be required throughengagement between the client and relevant authorities (DMR) due to the followingreasons:

The applicant requested permission from the DMR to expand the proposed miningfootprint while still keeping it within the property boundary of Gannabosch Vlakte51, but to provide a more suitable ecological approach;

Further specialist studies were required to support the application and A significant number of comments and concerns raised during the first IAP and

stakeholder engagement required to be addressed.

Due to the timeframes required for public consultation and the compilation of the secondDraft EIA and EMPr, the submission date of the Final EIA and EMPr was extended toearly 6 January 2017 (See Appendix D-4: Department of Mineral Resources).All registered IAPs and Organs of State were notified on 14 November 2016 of the releaseof the second draft EIA and EMPr for comment via post or e-mail, as well as notices putin the two most important regional newspapers; The Cape Times and Die Burger on thesame date.An electronic version was made available online on the Umvoto Africa websitewww.umvoto.com at the following link http://www.umvoto.com/projects/. Hard copies ofthe report were made available for review at the following venues:



Robertson Public Library(30 Van Reenen Street, Robertson, Western Cape, 6705; Tel 023 626 2972)

Robertson Local Municipality(52 Church Street, Robertson, Western Cape, 6705; Tel 023626 8200)


Hard copies of the complete second Draft EIA and EMP were sent to variousgovernmental departments and Organs of State at their requirement and/or request,including but not limited to Cape Nature and DEA & DP.5.2.8 Issues and Concerns Raised by IAP’s on Second Draft EIA ReportSubmissions of comments and concerns were received by email up to the closing date of2016-12-15 and at the public meeting held in Robertson on 2016-12-08. These commentsand concerns are incorporated into the Final EIR. A summary of the comments is providedin Appendix C-4: Responses to Amended 2nd Draft EIA and EMPr Document. Originalcopies of the same comments are provided in Appendix C-5: Original Correspondenceto Amended Second Draft of EIA And EMPr Document.5.2.9 Finalising the EIA ReportThree copies of the final EIR and EMPr are to be submitted to the DMR on 2017-01-06.The report will be uploaded onto the SAMRAD Website and also available to view onlineon the Umvoto Africa website www.umvoto.com at the following linkhttp://www.umvoto.com/projects/. A hard copy of the same will be available to view at the

Robertson Public Library(30 Van Reenen Street, Robertson, Western Cape, 6705; Tel 023 626 2972) and




6 ENVIRONMENTAL IMPACT ASSESSMENT

6.1 INTRODUCTION

6.1.1 Identified Environments of ImpactBased on the professional experience of the EIA team (Section 1.1), legal requirements(Section 2), the nature of the receiving environment (Section 3), the nature of theproposed activity (Section 4), and issues raised in the stakeholder engagement process(Section 5), the following environmental areas of potential impact were identified:

Freshwater ecology (wetlands) – the potential loss of and impact on wetland areas,which include ephemeral drainage lines and the Vink River;

Flora and Fauna – the potential loss of and impact on threatened vegetation typesand species;

Heritage (archaeology) – possible impacts on heritage (archaeological) resourcesin the project area;

Soils – potential impact of stripping the topsoil and subsurface overburden; Socio-economic – the possible socio-economic costs and benefits of the proposed

development to the wider community in the form of job creation, improvement oflocal infrastructure owing to LED project;

The economic impact of a loss of agricultural land; Air quality – the potential impact of brick yard emissions on nearby Cape Lime

Plant, and potential smoke / visual affect to R 60 traffic route; Visual and sense of place – the potential loss of the current sense of place and

potential visual impacts resulting from the trenching in the undulating agriculturallandscape and

The impact of the visual impression on the tourism potential of the area.

The above potential impacts of the project are directly linked to the sensitivity of thereceiving biophysical and social environment and proximity of receptors, the extent orfootprint and nature of the development, and stakeholder perceptions.

6.1.2 Specialist Studies UndertakenSpecialist studies listed in Table 3-1 were undertaken as part of the Impact AssessmentPhase to inform the EIA Report of all the impacts (negative and positive) as identified bythe EIA Team and stakeholders during the Scoping phase. These specialist impactstudies include:

Heritage Specialist Study (in form of an NID investigation, Annexure D-1: FirstNotice of Intent to Develop and Annexure D-2: Amended Notice of Intent toDevelop);

Botanical Impact Assessment (Annexure E-1: First Botanical Specialist Reportand Annexure E-2: Amended Botanical Specialist Report);

Freshwater Ecology Impact Assessment (Annexure F-1: First FreshwaterSpecialist Report and Annexure F-2: Amended Freshwater Specialist Report);

Visual Impact Assessment (Annexure G: Visual Impact Specialist Report); Dust Emission Study (Annexure H: Atmospheric Impact Assessment) as part of

the Air Emission License Application; Traffic Impact Assessment (Annexure I: Traffic Impact Statement); Alternative Resource Study (Annexure J: Alternative Resource Survey Report); Economic Impact Study (Annexure K: Economic Impact Study); and Storm Water Management Plan (Annexure L: Storm Water Management Plan)



Their findings have been incorporated into this EIA Report. The Dust Emission Study andTraffic Impact Assessment will be included in the Environmental Authorisation for the BrickFactory, however certain relevant findings of these two reports, will be incorporated intothe mine EIA as supportive information to aid decision making. The findings of eachspecialist study were evaluated to provide an overall and integrated assessment of thepotential impacts of the project. Specialists have made recommendations for themanagement of impacts, and this EIA has evaluated the recommendations at the end ofthe section addressing each discipline.

6.2 IMPACT RATINGMETHOD

The assessment of impacts was based on specialists’ expertise, the Umvoto Africa EIAteam’s professional judgement, field observations and desk-top analysis. Thesignificance of potential impacts that may result from the proposed project was determinedin order to assist decision-makers, specifically the DMR and other relevant authorities, butto some extent also the proponent. The EIA process utilises a consequence – probabilitymatrix to quantify the impact the respective activities might have on the receivingenvironment. This is to allow for a practical means to assess the various impacts and allowthe identification and mitigation of negative environmental activities.

A number of variables are taken into consideration, namely, the extent, duration, severityand probability of a potential impact. These impact attributes are given values dependingon the scale of each attribute and computed to allow for an impact significance as follows:

Significance = Consequence x Probability

whereConsequence = Extent + Severity + Duration

andProbability = Likelihood of an impact occurring

The standard method for determining the significance of an impact is to combine theconsequence of the impact occurring with the probability that the impact will occur. Thecriteria used to determine the consequence of the impacts assessed for the proposedproject are listed in Table 6-1 below, along with the ratings and rating definitionsapplicable to each consequence criterion.



Table 6-1: Determination of the consequence of an impact

Rating Definition of Rating Score

Extent– the area over which the impact will be experienced

A.

Local Confined to project area 1

RegionalDefined by regional context of study area, i.e. theCape Winelands DM and/or quaternary catchment(H40H)

2

National South African context 3

Intensity or Severity– the magnitude of the impact in relation to the sensitivity of the receivingenvironment, taking into account the degree to which the impact may cause irreplaceable lossof resources

B.

Low Site-specific and wider environmental and/or socialfunctions and processes are negligibly altered 1

MediumSite-specific and wider environmental and/or socialfunctions and processes continue albeit in a modifiedway

2

High Site-specific and wider environmental and/or socialfunctions or processes are severely altered 3

Duration– the timeframe over which the impact will be experienced and its reversibility

C.Short Term Up to 2 years and reversible 1Medium Term 2 to 15 years and reversible 2Long Term More than 15 years and irreversible 3

The combined score of these three criteria, A, B and C corresponds to a consequencerating, as set out in Table 6-2

Table 6-2: Methodology to determine the overall Consequence Rating

A + B + C 3 – 4 5 6 7 8 - 9

ConsequenceRating Very low Low Medium High Very High

The probability score is then assigned according to percentage ratings as defined in TableTable 6-3 below.

Table 6-3: Probability Classification

Probability or the likelihood of the impact occurring

Improbable < 40% chance of occurring

Possible 40 to 70 % chance of occurring

Probable > 70% chance of occurring

Definite > 90% chance of occurring



The overall significance of an impact is determined by considering the consequencerating (Table 6-2) and the probability classification (Table 6-3) using the rating systemprescribed in Table 6-4 below.

Table 6-4: Impact Significance Rating

Probability

Improbable Possible Probable Definite

Con

sequ

ence

Very Low Insignificant Insignificant Very Low Very Low

Low Very Low Very Low Low Low

Medium Low Low Medium Medium

High Medium Medium High High

Very High High High Very High Very High

The impact significance rating should be considered by authorities in their decision-making process based on the implications of ratings ascribed below:

INSIGNIFICANT: the potential impact is negligible and will not have an influenceon the decision regarding the proposed activity/development.

VERY LOW: the potential impact is very small and should not have any meaningfulinfluence on the decision regarding the proposed activity/development.

LOW: the potential impact may not have any meaningful influence on the decisionregarding the proposed activity/development.

MEDIUM: the potential impact should influence the decision regarding theproposed activity/development.

HIGH: the potential impact will affect the decision regarding the proposedactivity/development.

VERY HIGH: The proposed activity should only be approved under specialcircumstances.

Practicable mitigation measures are suggested and impacts are rated both without andwith the recommended mitigation measures. The impact assessment for the EIA reportwill be conducted as above. Any impacts identified through the PPP process and throughspecialists studies will be included within an assessment table which shall look at thesignificance of potential impacts, their extent, duration, as well as mitigating proceduresto reduce possible negative impacts. This table will be utilised as the basis for theEnvironmental Management Plan (EMP).



6.3 LISTED POTENTIAL ENVIRONMENTAL IMPACTS

6.3.1 Freshwater Ecology/HydrologyThe assessment of potential impacts on freshwater ecology/hydrology is provided below:

Table 6-5: Freshwater ecology/hydrological impacts

Criteria Details/Discussion

Impact 1

Description ofimpact Entrapment of free surface water by pit mining operations

Mitigation required

Divert free surface water flow around the mining footprint to avoid infill of the mine pit; Using swales and berms containing gravels and/or vegetative filters as a stormwater control

measure and Utilising the mined out trench portions as a settling pond to act as silt trap to remove

sediment. Construct drainage ponds at lowest portion of trench (south end) to capture siltrunoff form site and compacted surfaces into a settling pond.

Empty silt at regular intervals. (90 % of silt will runoff in first 10 minutes of rainfall event.Remaining runoff will be largely silt free).

Accumulated water will be allowed to settle out sediment and thereafter will be pumped tothe brick factory to be used in the brick making production process. The water may also bepumped out into the sprinkler systems for road dowsing.

Parameters Extent Duration Severity Probability Significance

Pre-Mitigation 1 2 2 70 Low

Post-Mitigation 1 2 1 70 Very Low

Impact 2

Description ofimpact

Potential contamination of water from hydrocarbons from diesel, oil and lubricants used inmachinery at the workshops and fuel tanks.

Mitigation required

Re-fueling, fuel storage areas, and areas used for the servicing or parking of vehicles andmachinery, should only take place in the designated workshop areas and should belocated on impervious bases with adequate protective bund walls to ensure that all thefuel kept in the area will be captured in the event of spillage;

Oil spills to be cleaned immediately and affected ground to be uplifted and bagged forremoval off site to approved dump facility for hydro carbons;

An incidence report of any hydro carbon spill must be filed on the mines incident ReportForms for inspection by the Mine ECO.

All vehicles are to be serviced and maintained on a scheduled basis to minimise leakingmotors

Parameters Spatial Duration Severity Probability Significance

Pre-Mitigation 1 1 3 > 70 Low

Post-Mitigation 1 1 1 < 30 Very Low

Impact 3


Potential water contamination from erosion impacts on receiving storm water quality from theerosion of destabilised soils on stockpiles and roads.

Mitigation required

Ensure that the haul road verges are allowed to vegetate to ensure that erosion of these isminimised;

Install water sprays along haul roads to maintain dampness and suppress dust; Ensure that all stockpiles, i.e. Topsoil, overburden, clay ore, coal storage are enclosed

within three sided bund walls; Design bund walls to prevent wind erosion with orientation such that open end is at right

angles to prevailing NW-SE winds; The side-slopes of the mining pits should be graded or reshaped to reduce steepness

(without encroaching into the recommended “no-go” areas) and/or the slopes should bestabilised using appropriate methods (e.g. geotextile blankets or rock gabions).



Post-Mitigation 1 2 1 40 to 70 Insignificant



Impact 4


Potential contamination at the proposed site and the impact of proposed mining operation onthe local aquifer systems and existing groundwater is possible. Impact during operations ispossible but unlikely because mining is being conducted in the weathered shales of the Eccagroup with low surface infiltration to surface clay soils and underlying shales which serves asaquitard. While no real mitigation is possible the impact after mining is improbable.

Mitigation required Management of hydro-carbon spills and Storm water management.


Pre-Mitigation 1 2 2 40 to 70 Very Low

Post-Mitigation 1 2 2 < 40 Very Low


Impact 5


Direct, permanent loss of freshwater ecosystems, and the habitat and biota associated withthese systems by developing across natural drainage lines

Mitigation required

Capture and divert flow from Drainage Line 2 into a specifically constructed storm waterculvert to run along the Lime Quarry road, adjacent to the property with discharge intoVink River;

Culvert/Stormwater system to be planned and implemented under the supervision of aspecialist and

Avoid development in drainage zones by staying outside of demarcated 30 meter bufferzones.


Pre-Mitigation 1 3 2 > 90 Medium

Post-Mitigation 1 1 3 1 > 90 Low

Impact 6

Description ofimpact Increased disturbance to aquatic and semi-aquatic fauna

Mitigation required Avoid development in drainage zones by staying outside of demarcated 30 meter bufferzones.




Impact 7

Description ofimpact Construction related sedimentation of the river systems during land clearing

Mitigation required No stockpiles of mined material, topsoil or overburden should be placed withinrecommended “no-go” areas




Impact 8


Ongoing sedimentation and pollution of the nearby river systems as a result of runoff from thefacility

Mitigation required Swales and berms should be used to slow down, temporarily retain and filter the runoff

from the mining pits Enables settlement of most of the silt within the runoff water






6.3.2 Flora and FaunaThe assessment of potential impacts on flora and fauna is provided below:

Table 6-6: Flora and Fauna impacts


Impact 1

Description ofimpact Loss of habitat

Mitigation required Sectoral trenching followed by immediate and concurrent rehabilitation of trenched sectorto reduce cumulative impact of open pit mining the entire footprint.



Post-Mitigation 1 2 2 40 to 70 Low

Impact 2

Description ofimpact Loss of vegetation classified as a Vulnerable Ecosystem

Mitigation required

Effort should be made to set no-go areas within the mine footprint where unnecessaryvegetation damage can be avoided or reduced;

Rehabilitation methodology should be implemented to re-generate pre mining vegetationcomponent through seed planting and alien removal;

Mining area should be clearly demarcated with boundary fencing in order to preventdisturbances to adjacent natural areas;

Overburden, debris, topsoil or mining material should not be dumped onto adjacent naturalvegetation, outside the proposed mining areas and

Topsoil should be stockpiled at designated stockpile areas, protected by bund walls andcovered by shade cloth or geo fabric for preservation of seed stock.

The excavation floor area should be ripped and filled with topsoil in order to allow the re-establishment of natural plant species from the replaced soil seedbank and adjacent sourcepopulations of natural vegetation.


Pre-Mitigation 1 3 2 < 70 Low

Post-Mitigation 1 3 2 > 40 Low

Impact 3

Description ofimpact Loss of general biodiversity by developing in a CBA and across ESA’s.

Mitigation required

Seek alternative location for the mine away from ecologically sensitive regions; Realign the footprint area from east-west axis to north-south axis to permit natural

corridors within the CBA and Realign the footprint to reduce fragmentation of the vegetation, minimise edge effect and

avoidance of drainage lines and ESA’s



Post-Mitigation 1 2 2 to 3 < 70 Medium

Impact 4

Description ofimpact Loss of floral Species of Special Concern (SSC) and indigenous plant species

Mitigation required Avoid mining in areas containing SSC as identified by Botanical Specialist.





Post-Mitigation 1 2 2 < 40 Low

Impact 5

Description ofimpact Impact on ecological processes

Mitigation required

Realign the footprint area from east-west axis to north-south axis to permit naturalcorridors and reduce fragmentation of the vegetation;

Avoidance of drainage lines and ESA’s and staying outside of defined buffer zones and Sectoral trenching and concurrent rehabilitation processes to reduce cumulative impact on

target area and to reduce exposure of topsoil and indigenous seed stock to degradation.




Impact 6Description ofimpact Influx of alien invasive species

Mitigation required

Cleared areas should be monitored for colonisation by alien species (Acacia saligna (PortJackson) and Eucalyptus (bloekom);

A proactive approach should be undertaken to control alien species as soon as they areestablished, all alien seedlings and saplings should be removed from rehabilitated areason an ongoing basis, biannually

Monitoring and eradication of alien species is part of the mine’s responsibility and failureto do so in the early stages will result in greater investments of resources to remove themat a later stage.


Pre-Mitigation 2 3 3 > 70 Very High

Post-Mitigation 2 2 1 40 to 70 Very Low

Impact 7Description ofimpact Loss of seed bank via the disturbance of topsoil

Mitigation required Reduced total topsoil storage time by reducing mine footprint and reducing turnover time

between soil stripping and rehabilitation and Topsoil should be stockpiled at designated stockpile areas, protected by bund walls and

covered by shade cloth or geo fabric for preservation of seed stock.Parameters Spatial Duration Severity Probability Significance

Pre-Mitigation 1 3 2 100 Medium


Impact 8Description ofimpact Impact on aquatic CBAs

Mitigation required Avoidance of drainage lines and ESA’s Staying outside of defined buffer zones and concurrent rehabilitation


Pre-Mitigation 1 3 2 >70 Medium




6.3.3 SoilsThe assessment of potential impacts on soils is provided below:

Table 6-7: Impact on soils


Impact 1


When topsoil is removed from a soil profile and stored for later re-introduction; the profile losesrooting depth and heat and moisture storage capacity. The integrity of the stored seed stock iscompromised lowering the regenerative capacity of the soil.

Mitigation required

The topsoil will be stripped by means of an excavator bucket, and loaded onto dump trucks; Topsoil is to be stripped when the soil is dry and not wet, as to reduce compaction; To be stripped in limited sector portions as per the management plan; To be stockpiled no higher than 2 m; Stockpiles to be protected by bund wall on three sides to prevent wash away and wind

erosion and bedded down by shade cloth; Design bund walls to prevent wind erosion with orientation such that open end is at right

angles to prevailing NW-SE winds; Stockpiles are to be maintained in a fertile and erosion free state and to be reintroduced

back into rehabilitated trench as soon as possible to reduce storage time which leads toseed stock deterioration and die-off;

The handling of the stripped topsoil must be minimised to ensure the soil’s structure doesnot deteriorate;

Compaction of the removed topsoil must be avoided; Construct drainage ponds to capture silt runoff form site and compacted surfaces into a

settling pond. Empty silt at regular intervals; and The excavation floor area should be ripped and filled with topsoil in order to allow the re-

establishment of natural plant species from the replaced soil seedbank and adjacent sourcepopulations of natural vegetation.




Impact 2


Repeated movement of heavy mine vehicles over clay soils will generate compaction. Erosionis grouped with compaction due to dust loss, reduced vegetation cover and increased rainfallrunoff.

Mitigation required

Limit haul roads and internal access tracks to least required; Demarcate turning circles and parking areas with fencing to limit overspill of vehicles into

no-go zones; Ensure proper storm water berms are in place along roads to deflect runoff; Set up water sprayers along haul roads to dampen dust and minimise dust loading to

surrounding vegetation; Limit width of haul roads and access tracks to maximum 4 meters to allow sprayers to

reach full width of road; Scarify compacted areas after construction or mining to allow for natural vegetation

regrowth In areas where compaction will occur but topsoil or overburden will not be removed; do

not cut or remove vegetation. Allow vegetation to be compacted but leave root andsubsurface vegetation in situ.


Pre-Mitigation 1 3 3 > 90 High


Impact 3Description ofimpact Hydrocarbon spills due to leaking equipment, spillage at refill or on site repairs

Mitigation required

Re-fueling, fuel storage areas, and areas used for the servicing or parking of vehicles andmachinery, should only takes place in the designated workshop areas and should belocated on impervious bases with adequate protective bund walls to ensure that all thefuel kept in the area will be captured in the event of spillage;

Oil spills to be cleaned immediately and affected ground to be uplifted and bagged forremoval off site to approved dump facility for hydro carbons;



An incidence report of any hydro carbon spill must be filed on the mines incident ReportForms for inspection by the Mine ECO.

All vehicles are to be serviced and maintained on a scheduled basis to minimise leakingmotors




6.3.4 Heritage ImpactsThe assessment of potential impacts on heritage sites is provided below:

Table 6-8: Heritage impacts


Impact 1


Loss of heritage resources through the exploitation of the clay body. These may include:historical structures, graves, culturally significant landscape features, geological features,archaeological resources and paleontological resources.

Mitigation required

Education of the mine workers to identify historical artifacts so that they may stop mining inorder to alert the mine manager;

Most artefacts will occur in upper layers in overburden and soils and will be moved aroundwhen the topsoil is cleared and stockpiled and then redistributed during rehabilitation.Because of their very low value, no significant impacts are expected and

Placement of berms using overburden and planting of windrows of rapid developing trees(e.g. Searsia Karee, Searsia pendulia, Vachellia karoo) to screen both the pit andinfrastructure; so as to retain the cultural milieu of the landscape.


Pre-Mitigation 1 2 2 < 40 Low

Post-Mitigation 1 2 1 < 40 Insignificant

6.3.5 Socio-economic ImpactsThe assessment of potential socio-economic impacts is provided below:

Table 6-9: Socio-economic impacts


Impact 1


Local labour from adjacent farm communities or Robertson will be employed by the mine. Thiswill have a positive impact on the wellbeing of employees with a multiplier effect on householdsof the employed.

Mitigation required No mitigation required


Impact 2 3 1 > 90 Medium(Positive)

Impact 2


Tourism, will be negatively impacted;’ this includes visits to wine farms, mountain bike trail andpassing road traffic using R60/62 scenic tourism route

Mitigation required

Visual screening of the mine and infrastructure must be undertaken to ameliorate the impact totourists. This must be undertaken by the placement of berms using overburden and planting ofwindrows of rapid developing trees (e.g. Searsia Karee, Searsia pendulia, Vachellia karoo) toscreen both the pit and infrastructure; so as to retain the cultural milieu of the landscape.




Impact 2 3 1 > 90 Medium


Impact 3


Agricultural activities, may be negatively impacted;’ due to possible fugitive dust loading fromexcavation process.

Mitigation required

Several mitigation measures have been discussed under flora, fauna, aquatic, soils and heritageimpacts which if correctly applied will lessen the impact to agriculture as an economic activity.These include: Stormwater management Runoff and surface flow strategies Management of stockpiles of topsoil, overburden, coal fuel Road maintenance Control of alien vegetation Construction of screening via berms and windrows


Impact 2 3 2 > 90 High


6.3.6 Air QualityThe assessment of potential impacts on air quality is provided below:

Table 6-10: Air Quality


Impact 1


Dust generated from site clearing, soil transportation, stockpiling, construction and excavationmay be windblown as fugitive dust and settle on surrounding, residential, agricultural andenvironmental receptors.

Mitigation required

The disturbed areas must be kept to a minimum; Do not clear vegetation cover unnecessarily; Limit haul roads and internal access tracks to least required; Demarcate turning circles, haul road and parking areas with fencing to limit overspill of

vehicles into no-go zones; Set up water sprayers along haul roads to dampen dust and minimise dust loading to

surrounding vegetation; Limit width of haul roads and access tracks to maximum 4 meters to allow sprayers to reach

full width of road; Scarify compacted areas after construction or mining to allow for natural vegetation

regrowth; Ensure that all stockpiles, i.e. topsoil, overburden, clay ore, coal storage are enclosed within

three sided protection walls and a low bund wall on fourth side to limit spillage onto loadingapron;

Limit maximum height of stockpiles to 2 m and orientate long axis along SE-NW prevailingwind direction

Design bund walls to prevent wind erosion with orientation such that open end is at rightangles to prevailing NW-SE winds;

Hard pave and reinforce first 15 m leading off the Langvlei Quarry public road so that heavytrucks do not damage tarred road edges and create pot holes due to the turning motion ofthe truck, and possible spillage from the load bed of coal delivery trucks;

Sweeping of all aprons surrounding tip points and stockpiles; Speed control for all mine roads to limit dust generation Set up windbreaks or windrows at boundary of sit working areas to the windward side and Regular twice weekly) visual checking and recording of visible dust emissions from all

identified dust sources and emission points. These check lists to be signed off andpermanently retained for analysis of dust emission points and opportunities for continuousimprovement and



In order to establish a baseline dust fall; site-representative dust fall monitoring, in terms ofthe National Dust Control; Regulations, will be undertaken prior to the commencement ofactivities.




Impact 2

Description ofimpact Sulphur dioxide (SO emission (Related to Brick Factory not the Mine)

Mitigation required Continuous monitoring of SO2 emission at four points along the main wind axis (NW-SE)



Post-Mitigation 2 3 1 > 70 Medium

6.3.7 NoiseThe assessment of potential impacts on noise levels is provided below:

Table 6-11: Noise


Impact 1


The major noise generating activities will be the development, mining, closure and rehabilitationof the proposed opencast trenches and the hauling of ore between mine and factory. Theoperation of a single excavator and dump truck will increase noise pollution in the area duringdaylight working hours on the mine. Potentially sensitive receptors within two kilometers of theopencast trench are identified as relevant, all others are considered beyond the range ofinfluence.

Mitigation required

Operating hours kept to during 08h00 to 17h00 during week days, and 08h00 to 14h00 onSaturdays;

Berms and windrows will be constructed around the excavation area which will aid blocksound emission and

Mine vehicles will be regularly services and exhaust systems will be maintained in goodorder in compliance with limiting noise emissions.


Pre-Mitigation 1 2 1 > 90 Very Low

Post-Mitigation 1 2 1 > 90 Very Low

6.3.8 Visual ImpactThe assessment of potential visual impacts is provided below:

Table 6-12: Visual Impact


Impact 1


The Zone of Visual Influence has a maximum radius of 3 km. During the operation of the mine,the development will be visible. On completion of mining, removal of infrastructure and re-vegetation, the mine will not be acutely visible although a shallow 4m depression will exist forperpetuity.



Mitigation required

The proposed mining activity includes the revegetation of the excavated area which willmitigate the long term potential negative visual impact;

The incremental mining method will provide some mitigation avoiding a large cleared areaover the full period of the mine;

On completion of the mine sections, the shaping of the sides of the mine should be gentle(1:3 – 1:5), undulating slopes that resemble the natural landforms and not man-made dams;

Plant windrows of quick growing, preferably indigenous, trees, around the mine site toscreen the mining operation and

Over burden from the first phase of trenching can be used as a berm on which windrow canbe planted, increase the height of the screening effect.



Post-Mitigation 2 2 1 > 90 Medium

Impact 2Description ofimpact Nature of Impact: Change from naturally vegetated site to a clay mined pit

Mitigation required Land will be rehabilitated for agricultural use and natural vegetation




Impact 3Description ofimpact Visibility from sensitive receptors

Mitigation required Additional indigenous trees to be planted along the Vink River.




6.3.9 Traffic ImpactThe assessment of potential traffic impacts is provided below:

Table 6-13: Traffic impact


Impact 1Description ofimpact Impact on traffic on both DR 1384 and TR 31/1

Mitigation required For both roads safe access points will be emplaced; Vegetation will be trimmed to the left of DR 1384 along TR 31/1 to clear the sight line for

passenger cars.Parameters Spatial Duration Severity Probability Significance





6.4 CUMULATIVE IMPACTS

Cumulative impacts are the direct and indirect impacts that act together with existing andfuture potential impacts of other activities,, or proposed activities in the region that affectthe same resources and receptors. With respect to this project, potential cumulativeimpacts are:

Industrial processing activities of the Cape Lime factory within the floodplain of theVink River are leading towards degradation of the drainage lines, ESA andimpinging on the integrity of the CBA. Any development within a CBA isundesirable as it will result in the cumulative impact of a reduction of a network ofnatural sites identified to meet biodiversity pattern and process thresholds. Thedevelopment of the Gannabosch Mine and Robertson Brick Factory will implyadditional pressure to the environment. Mitigation and management controlmeasures as stipulated in the EMP report (Section 8.2) and guided by both theFresh Water Ecologist and the Botanical Specialist, will need to be strictly enforcedto limit such cumulative impact. The north-south orientation of the developmentwill ensure that sufficient ecological corridors are left intact for biodiversity needs.

The visual impact of the Cape Lime factory is a noted deterrent to tourism activitiesthat are on the Breede River Wine Route on the R60. Additional developments ofthe Gannabosch Mine and Robertson Brick Factory add some moderate(Anderson, M. 2016) level of cumulative impact which can be mitigated ifrecommendations of the specialist are followed.

The cumulative effect from mining, current activities at the Cape Lime plant andfuture brick manufacturing could increase the levels of fugitive dust. This maynegatively affect agriculture, viticulture, scenic milieu and the health of residentsin the fallout zone. Control and management measures are described in the EMP(Section 8.2) to limit this impact.

Noise is not evaluated to be a cumulative impact if activities are confined tostandard daytime operational practice.

Cumulative impact must also consider the positive impact of the presence of businessactivity in the Langeberg region and the input of social upliftment programs that form anessential aspect of the mine and factory development program. The supply of essentialservices and meeting the demand for bricks of the construction industry are alsoconsidered a positive cumulative impact.



7 ALTERNATIVE LAND USE AND DEVELOPMENTSCONSIDERED

The EIA Regulations, 2014, require that all S&EIR processes must identify and describe‘alternatives to the proposed activity that are feasible and reasonable’. The different typesor categories of alternatives for this project include: location alternatives, type of activity,design or layout alternatives, and operational alternatives. The ‘No Go’ or ’No Project’alternative must also be considered.

7.1 ALTERNATE LAND USE

If the current proposed mine, as contemplated in Section 4, does not proceed, the mostlikely alternate land use is that of agricultural activities (livestock or produce) which in itsown manner would negatively affect the current natural biophysical environment andimpact on the CBA. No activity on the target area will preserve the integrity of the CBAand maintain ecological support areas which link the mountain catchment area in the northto the Breede River Valley in the south via several ESA corridors.

7.2 ALTERNATIVE CLAY RESOURCE

Clays suitable for brick-making must contain essential minerals kaolinite, quartz and illite(Heckroodt, 1991). Kaolinite has good sintering characteristics, while quartz acts as astabilizer and illite produces plasticity (Van Strijp, 1998). While other locations around theWestern Cape Province are available (Figure 7-1), suitable deposits within the Robertsonarea have yet to be identified. The development of the proposed clay mine and theresultant brick manufacturing facilities within the Robertson region would allow theproponent to become a local supplier to the construction industry.

Figure 7-1: Mineral Resources map of the Western Cape (Cole, 2014).



Since the mine target area, and the Gannabosch Vlakte 51 occurs within a CBA, a desktopassessment of potential additional brick clay resources in the region within ~15-30 km ofthe proposed Gannabosch clay mine was undertaken. A full copy of this report (Blake,D. 2016) is available as Annexure I: , however the salient points for consideration arediscussed below.

The objective of an alternate resource evaluation is to determine if viable alternatives toexploit brick making shale clay exist within the proximity of Robertson but outside of theCBA. To be considered as alternative resource, the potential site must comply with thefollowing criteria:

Has a similar reserve potential. As demonstrated in Section 4.4, the Gannaboschproposed site has a potential reserve of approximately 540 000 m3;

Produces clay with the qualities to provide bricks with comparable qualities to theGannabosch proposed site as specified in the 2015, CSIR/Cermalab Report. Thisis more fully covered in the Mine Work Plan, however the key factor states; “TheMix clay has high breaking strength (approx.7.4 MPa) and good crushing strengths(approx.. 28.4 MPa) when fired to temperatures between 950°C and 1100°C.Market specification for a plaster bricks require a crushing strength of 7 MPa andface bricks 17 MPa (Cermalab, 2015) proving that the Gannabosch clay is of asuperior strength.

Is in an area where infrastructure is available to set up a brick making facility, whichincludes proximity to water (4000 litre per hour) and electricity (Three Phase440 V) and access to road infrastructure that avoids the need to construct roadsand apply for servitude rights.

Literature reviews contend that raw materials with properties adequate to producecommon bricks are widespread and limitless in the Western Cape. However, there areextensive variation in the clay deposits due to varying geology/lithology and mineralcomposition, which results in variations in clay firing behaviour and hence a wide range ofclay brick products can often be produced and the quality may vary. The following shale-rich geological formations in the southwestern Cape were identified from the 1:250 000geological maps and literature as having brick clay resource potential if deeply weathered:Malmesbury, Bokkeveld, Witteberg, lower Ecca, Uitenhage and Sandveld Groups, andthe Cape Granite Suite. These were mapped at a 1:250 000 scale. A specific set oftopographic and land use parameters were overlaid on the geology to determine potentialadditional brick clay resources within ~15-30 km of the proposed Gannabosch clay mine.These parameters included:

Areas with less than 10° slope (i.e. areas with the potential for, or representing,deep weathering);

Areas where no cultivated land is present; Areas outside of towns/residential zones/infrastructure (e.g. roads, railways etc.);

and Areas outside of all Critical Biodiversity Areas (CBAs), Ecological Support Areas

(ESAs) and nature reserves (whether CapeNature, SANParks or private).

Through a GIS process of exclusion using the above criteria, five potential brick clayresource sites were identified (see Table 7-1 and Figure 7-2) in the vicinity ofGannabosch.



Figure 7-2: Positions of additional potential brick clay resource sites in the regionsurrounding the proposed Gannabosch clay mine. Pink, orange and yellowareas represent Tierberg, Gydo and Waboomberg Formation sites respectively,maroon polygons represent associated farms, and the red polygon representsGannabosch Vlakte 51.

Table 7-1: Details of potential additional brick clay resource sites in the region surroundingthe proposed Gannabosch clay mine (Site ID refers to Figure 7-2).

The three Tierberg Formation sites (Pt-01, Pt-02 and Pt-03) may contain high quality brickclay resources based on the similarity of the geology, (lower Ecca Group), to theGannabosch Mine geology, although the weathered zone and resource extent may beshallower due to slightly steeper and more undulating topography at the three sites (incomparison to the proposed Gannabosch clay mine site).

Site ID Site Name Area (ha) Geology Distancefrom GCM Farms

Pt-01 Rivier Plaas 258 11 km WNW Rooilandia RE/472 andDoornlaagte RE/461

Pt-02 Koelefontein 137 6 km WNW Koelefontein RE/458and Langevallei RE/52

Pt-03 Karoo 84 11 km NW Karoo RE/453

Dg-01 Zandbergfontein 467 Gydo Formation(Bokkeveld Group)

13 km SE Zandbergfontein 4/97,RE/97 and 194

Dw-01 Wandsbeck 261Waboomberg

Formation(Witteberg Group)

15 km SWWandsbeck 2/138,3/138 and RE/138

Tierberg Formation(Ecca Group)



Field verification was carried out by the proponent and indicate the following limitations

Pt-01: Site does not have ready water supply and borehole water is high in salts andvery low quantity. Site also has no Eskom power supply. Road access for truckswould be directly off the R60 and not from a subsidiary road.

Pt-02: The clay deposition is shallower in the north towards Mowers Hoogte, hence thesite will not provide sufficient clay recourse. Site does not have ready watersupply and borehole water is high in salts and very low quantity. Site also hasno Eskom power supply. There is no ready built road access for trucks.

Pt-03: There is no ready access for trucks, and the site is prohibitively far from the R60for road construction. The clay deposit is shallow due to its close proximity to thesurrounding mountain towards the north. Site does not have ready water supplyand borehole water is high in salts and very low in quantity. Site also has noEskom power supply.

Clay thickness and brick clay quality from potential weathered shales at the Dg-01 andDw-01 sites is expected to differ from Gannabosch due to the differing geology (Gydo andWaboomberg Formations respectively). These sites had been considered by theproponent, but were not found to be suitable.

Dg-01: Drilling results confirm that the clay deposit are much too shallow and covered inboulders. Eskom power will be a problem to supply.

Dw-01: The site is very close to the mountain, hence the clay will be shallow. There is nowater and power supply in the vicinity.

In summary, the alternative resource study suggests several theoretical alternatives tomining outside of a CBA. These alternatives have been visited and surveyed by theproponent to more fully evaluate the potential of the resource. Consideration has alsobeen given to infrastructure (water, power and road access) needs as well as the landowner relationship. The proponent has found none of these mentioned sites will providea comparable opportunity for mining:

7.3 ALTERNATIVE MINING OPTIONS

The raw brick clay resource identified within the Gannabosch Vlakte 51 property is suitablyhigh quality high strength face brick production at a resource volume and magnitudesuffice to provide raw material for the manufacture of bricks for the construction industryfor the next 20+ years. GCM have not indicated an interest to prospect elsewhere for theresource but have restructured the footprint of the concession area to take into accountthe environmental sensitivities raised by the stakeholders. Should GCM not exploit theresource, or the mine right not be granted, it would likely be sought after by other playersin the market due to the nature of the clay quality.

7.3.1 Alternate mine footprintThe terrestrial and aquatic environment as described in the specialist studies (AnnexureE-1: First Botanical Specialist Report, Annexure E-2: Amended Botanical SpecialistReport, Annexure F-1: First Freshwater Specialist Report and Annexure F-2: AmendedFreshwater Specialist Report) were assessed for impact by the proposed mine (Section6). This process identified the proposed property to be located within a CBA corridor(Figure A-0-6), which facilitates maintaining a biodiversity link between the Breede Riverlowlands in the south and the Langeberg Mountains in the north.



It was further noted that episodic drainage channels, classified as Ecological SupportAreas (ESA’s), act as vital faunal refuge areas and are an important component to thefunctioning of this natural corridor. The development of the original full area applied forwould have resulted in the transformation of this area that forms a vital part of theterrestrial and aquatic CBA corridor identified (Figure A-0-6). It was in this context thatthe original application was amended to a more environmentally accommodating footprintin which the east-west orientation of the mine footprint was altered to a north-southorientation and moved off a prominent drainage line

7.3.2 The No Go AlternativeThe No Go alternative is considered in the EIA in accordance with the requirements of theEIA Regulations, 2014 (as per Appendix 3 of Notice R.982, 2014). The No-Go alternativeentails no change in existing status quo, of the land use on Gannabosch Vlakte 51. Thisimplies the mine will not proceed and land use will remain, as zoned, for use as agriculturalland.

It can be argued that the No Go Alternative will benefit the region through the provision ofa landscape corridor required for habitat connectivity and an upland-lowland corridorbetween the Langeberg Mountains and the Breede River. An alternate, suggested byCape Nature Conservation, is additional mitigation in the form of a biodiversity offset.Such an offset should be obtained according to the Western Cape’s Draft ProvincialGuidelines on Biodiversity Offsets and a suitably selected botanical specialist will need tobe appointed to conduct the study. The offset will need to identify a suitable area with acomparative “like for like” vegetative value and the determination of a multiplication factorfor land size. It would further need to set out the most appropriate regulatory mechanismfor securing stewardship of the area for conservation in the long term.

If the proposed operation were not to proceed, the land may or may not be utilised forgrazing of livestock in the future. As much as the no go option may result in the protectionof the environment in situ; however, the consequences of not proceeding with theproposed operation will include the forfeiture of a mining opportunity and therefore theloss of support towards the Langeberg Municipality for attaining some of the objectives asper their SDF goals. It is expected that an alternate party is likely to apply for the miningright with the DMR. It would further suggest that no new employment opportunities wouldbe created nor would the Social and Labour Plan upliftment and development programstake place.

7.4 RELATED DEVELOPMENTS

It is the intention of a separate entity (Robertson Bakstene (Pty) Ltd) to apply for theEnvironmental authorisation for the development of a brick manufacturing plant on themine right concession zone of the proposed clay mine (see Section 4). This applicationwill be sought out via the DEA&DP and follow the necessary process for authorisation.



8 ENVIRONMENTAL MANAGEMENT AND MONITORINGPROGRAMME

8.1 ENVIRONMENTAL OBJECTIVES

The impact assessment for the EIA report is provided in Section 6 of this report. Impactsidentified through the PPP process and through specialists studies have been includedwithin the Assessment Tables 6.5 to 6.12 which shall look at the significance of potentialimpacts, their extent, duration, as well as mitigating procedures to reduce possiblenegative impacts. These tables will be utilised as the basis for the EnvironmentalManagement Plan (EMP). The environmental objectives have already been described inthis EIA and are repeated below:

Objective 1: To ensure effective rehabilitation of the mining permit area and return theland as far as possible to its pre-mining use.

Objective 2: To minimise pollution or degradation of the physical and naturalenvironment.

Objective 3: To minimise negative socio-economic impacts and enhance benefits on andto community.

Closure Objectives

The current closure objective of Gannabosch Clay Mine is to develop a landform suitableto be returned to its present land use. The mine has enough reserves to continue miningoperations for ~15 years, therefore a detailed closure plan has yet to be formulated.During the operational phase of the mine, the goal of the mine is optimal exploitation ofmineral resources without compromising the final land use. When compiling the detailedclosure plan, the following goals and objectives will be incorporated:

To comply with the relevant legislation of the time; Ensure the safety and health of humans and animals are safeguarded from

hazards resulting from the post-mining operations; Align with the IDP and the SDF at the time of closure; Incorporate views raised by the I&AP’s and Stakeholders; Rehabilitate the land to, as far as is practicable, to a state where by it can

complement surrounding land use activities at the time of closure and does notrepresent a source of pollution, nor negative environmental legacy and does notpresent a negative visual impact to the scenic nature of the area;

The mine will be closed efficiently and cost effectively. Limit any negative socio-economic consequences resulting from the mine closure.



8.2 ENVIRONMENTAL MANAGEMENT PROGRAMME

8.2.1 SoilTable 8-1: Soils EMPr

Topsoil ManagementDescription of impact When topsoil is removed from a soil profile and stored, the profile loses rooting depth and heat and moisture storage

capacity. The integrity of the stored seed stock is compromised lowering the regenerative capacity of the soil.Receiving Environment Topsoil on stripped mine trench.Objectives To provide management systems that supervise the stripping and storage of topsoil to prevent the deterioration.Mitigation and ManagementMeasures

Topsoil is to be stripped when the soil is dry and not wet, as to reduce compaction; To be stripped in limited sector portions as per the management plan; To be stockpiled no higher than 2 m; Stockpiles to be protected by bund wall on three sides to prevent wash away and wind erosion and bedded down by

shade cloth; open end of bund walls at right angles to prevailing NW-SE winds; Stockpiles are to be maintained in a fertile and erosion free state and to be reintroduced back into rehabilitated trench

as soon as possible (preferably < three months) to reduce storage time which leads to seed stock deterioration and die-off and loss of fertility;

The handling of the stripped topsoil must be minimised to ensure the soil’s structure does not deteriorate; Compaction of the removed topsoil must be avoided; Construct drainage ponds to capture silt runoff form site and compacted surfaces into a settling pond. Empty silt at

regular intervals. (90 % of silt will runoff in first 10 minutes of rainfall event. Remaining runoff will be largely silt free); Preparation of excavation pit and sidewalls prior to reintroduction of topsoil to include: profile benches to a gradual incline

of 1:3 to 1: 5 slope; scarify any compacted areas such as the lower trench floor; Dig in swales and berms to final profile to aid reintroduction of water into subsurface layers; Laydown geo-fabric erosion fencing to slow water flow, trap seed and minimise dust blow out and Hydroseed final topsoil with seed/mulch slurry to protect from desiccation and speed up pioneer grass regrowth.

Frequency of Maintenance ContinuousLegal Requirements National Environmental Management Act 1998 (Act No. 107 of 1998)Recommended Action Plans Topsoil Monitoring Programme. ECO to monitor and assess in the Standard Mine Management Monitoring Performance

AssessmentDuration LoM + five year post rehabilitation monitoring programResponsible Person Mine Manager



Compaction ManagementDescription of impact Repeated movement of heavy mine vehicles over clay soils will generate compaction. Erosion is grouped with compaction

due to dust loss, reduced vegetation cover and increased rainfall runoff.Receiving Environment Surface soils in mine area.Objectives To provide management systems that prevents or minimises soil compaction and to ensure that all compacted areas are

returned as far as practical to an acceptable standard that is capable of ensuring natural environmental process will continue.Mitigation and ManagementMeasures

Limit haul roads and internal access tracks to least required; Demarcate turning circles and parking areas with fencing to limit overspill of vehicles into no-go zones; Ensure proper storm water berms are in place along roads to deflect runoff; Set up water sprayers along haul roads to dampen dust and minimise dust loading to surrounding vegetation; Limit width of haul roads and access tracks to maximum 4 meters to allow sprayers to reach full width of road; Scarify compacted areas after construction or mining to allow for natural vegetation regrowth and In areas where compaction will occur but topsoil or overburden will not be removed; do not cut or remove vegetation but

allow vegetation to be compacted and retain root and subsurface vegetation in situ.Frequency of Maintenance ContinuousLegal Requirements National Environmental Management Act 1998 (Act No. 107 of 1998)Recommended Action Plans Topsoil Monitoring ProgrammeDuration LoMResponsible Person Environmental Control Officer/ Mine Manager

Hydrocarbon SpillsDescription of impact Hydrocarbon spills due to leaking equipment, spillage at refill or on site repairs.Receiving Environment SoilObjectives To provide management systems that prevents or minimises spills from occurring and offers fast and practicle solutions to

restore soils to clean status. Ensure that vehicles on site are well maintainedMitigation and ManagementMeasures

Re-fueling, fuel storage areas, and areas used for the servicing or parking of vehicles and machinery, should only takesplace in the designated workshop areas and should be located on impervious bases with adequate protective bund wallsto ensure that all the fuel kept in the area will be captured in the event of spillage;

Oil spills to be cleaned immediately and affected ground to be uplifted and bagged for removal off site to approved dumpfacility for hydro carbons;

An incidence report of any hydro carbon spill must be filed on the mines incident Report Forms for inspection by the MineECO.

Significant spills with the potential to pollute beyond mine area will be reported to the appropriate authorities All vehicles are to be serviced and maintained on a scheduled basis to minimise leaking motors.

Frequency of Maintenance Daily



Legal Requirements National Environmental Management Act 1998 (Act No. 107 of 1998)Recommended Action Plans Machinery Monitoring ProgrammeDuration LoMResponsible Person Environmental Control Officer/ Mine Manager

8.2.2 WaterTable 8-2: Water EMPr

Impediment of Surface FlowDescription of impact Impeding free surface water flow from the constructed receiving environments and damming of free surface water by pit

mining operations.Receiving Environment Surface Water flows on and around mine zone.Objectives To provide Stormwater management systems that ensure that water flow is not impeded and provide for removal of surface

water flows and pit water.Mitigation and ManagementMeasures

Divert free surface water flow around the mining footprint to avoid infill of the mine pit; Run-off will be gathered in a two sumps at the southern end of the quarry to collect and store the run-off water. Collected run-off water will be used as dust suppression and / or recycled into production; Using swales and berms containing gravels and/or vegetative filters at inlet and outlet points as a stormwater control

measure; Utilising the mined out trench portions at lowest point as a settling pond to act as silt trap to remove sediment. Empty silt at regular intervals. (90 % of silt will runoff in first 10 minutes of rainfall event. Remaining runoff will be largely

silt free). Accumulated water will be allowed to settle out sediment and thereafter will be pumped up to the brick factory to be

stored in on site tanks after filtration. Thereafter it will be re-used in the brick making production process. The watermay also be pumped out into the sprinkler systems for road dowsing. and

Ensure that the culverts and drainage canals are cleaned and debris free to ensure water is free flowing.Frequency of Maintenance ContinuouslyLegal Requirements National Water Act, 1998 (Act No. 36 of 1998)Recommended Action Plans Storm Water Management Plan. ECO to monitor and assess in the Standard Mine Management Monitoring Performance

AssessmentDuration LoM + five year post rehabilitation monitoring programResponsible Person Environmental Control Officer/ Mine Manager



Hydrocarbon ContaminationDescription of impact Potential contamination of water from hydrocarbons.Receiving Environment Surface WaterObjectives To provide stormwater management systems that prevent and immediately manage hydrocarbon spillages from heavy

machinery and vehicles on site.Mitigation and ManagementMeasures

Do not infringe on buffer zones that surround defined drainage lines; Re-fueling, fuel storage areas, and areas used for the servicing or parking of vehicles and machinery, should only takes

place in the designated workshop areas and should be located on impervious bases with adequate protective bund wallsto ensure that all the fuel kept in the area will be captured in the event of spillage;

Oil spills that may impact on surface water to be cleaned immediately and affected ground to be uplifted and bagged forremoval off site to approved dump facility for hydro carbons;

An incidence report of any hydro carbon spill must be filed on the mines incident Report Forms for inspection by the MineECO;

Significant spills with the potential to pollute river systems beyond mine area will be reported to the appropriate authoritiesof the CWDM and

All vehicles are to be serviced and maintained on a scheduled basis to minimise leaking motorsFrequency of Maintenance ContinuouslyLegal Requirements National Water Act, 1998 (Act No. 36 of 1998)Recommended Action Plans Report any large hydrocarbon spillages and remediate soils immediately.Duration LoMResponsible Person Environmental Control Officer/ Mine Manager

Loss of Freshwater ecology zoneDescription of impact Direct, permanent loss of freshwater ecosystems, and the habitat and biota associated with the ephemeral drainage channel

systems, by infringement on natural drainage lines;Receiving Environment Surface Water Ecology within Ecological Support Areas and Drainage Lines.Objectives Reduce impact on and avoid infringement into critical areas of concern (i.e. the drainage channels)Mitigation and ManagementMeasures

The recommended “no-go” area for the protection of Drainage line 1, Drainage line 3, the Vink River and its riparianzone/floodplain should be enforced and this area should be demarcated before any mining operations begin. Access to theseareas must be fenced off and no access should be allowed to reduce disturbance. . Avoid development in drainage zonesby staying outside of demarcated 30 meter buffer zones.

Frequency of Maintenance OngoingLegal Requirements National Environmental Management: Biodiversity Act, 2004 (Act No 10 of 2004).

National Water Act, 1998 (Act No. 36 of 1998)Recommended Action Plans ECO to monitor and assess in the Standard Mine Management Monitoring Performance Assessment



Duration LoMResponsible Person Environmental Control Officer/ Mine Manager

8.2.3 Fauna and FloraTable 8-3: Fauna and Flora EMPr

Loss of VegetationDescription of impact Loss of vegetation, habitat, species of concern, fragmentation and edge effects and ecological processes.Receiving Environment Flora of the mine and surrounding area.Objectives To provide management systems that restrict avoidable damage to flora on non-mined sections of the concession area.Mitigation and ManagementMeasures

Avoid no-go areas within the mine footprint where unnecessary vegetation damage can be avoided or reduced; Rehabilitation methodology should be implemented to re-generate pre mining vegetation component through seed

planting and alien removal; Mining trench area should be clearly demarcated with boundary fencing in order to prevent disturbances to adjacent

natural areas; Overburden, debris, topsoil or mining material should not be dumped onto adjacent natural vegetation, outside the

proposed mining areas; Topsoil should be stockpiled at designated stockpile areas, protected by bund walls and covered by shade cloth or geo

fabric for preservation of seed stock; Sectoral trenching followed by immediate and concurrent rehabilitation of trenched sector to reduce cumulative impact

loss of vegetation caused by open pit mining the entire footprint; Limit haul roads and internal access tracks to least required; Demarcate turning circles and parking areas with fencing to limit overspill of vehicles into no-go zones; Set up water sprayers along haul roads to dampen dust and minimise dust loading to surrounding vegetation; Limit width of haul roads and access tracks to maximum 4 meters to allow sprayers to reach full width of road; Scarify compacted areas after construction or mining to allow for natural vegetation regrowth and In areas where compaction will occur but topsoil or overburden will not be removed; do not cut or remove vegetation but

allow vegetation to be compacted and retain root and subsurface vegetation in situ. A Mine Environmental Awareness Program (MEAWP) run by the appointed Ecological Control Officer (ECO) will be set

up for all mine staff to educate and inform on rules and regulations regarding protection of indigenous vegetation and No bush clearing for firewood will be permitted on the mine and the surrounding farm area.

Frequency of Maintenance OngoingLegal Requirements National Environmental Management: Biodiversity Act, 2004 (Act No 10 of 2004).



Recommended Action Plans Biodiversity Action Management Plan. ECO to monitor and assess in the Standard Mine Management MonitoringPerformance Assessment

Duration LoMResponsible Person Environmental Control Officer/ Mine Manager

Alien Vegetation InfluxDescription of impact Influx of Alien Invasive Vegetation on disturbed areas.Receiving Environment Fauna and FloraObjectives Prevent the establishment of alien invasive speciesMitigation and ManagementMeasures

Cleared areas must be monitored for colonisation by alien invasive vegetation and control measures implemented as soonas the vegetation becomes established. A proactive approach should be undertaken to control alien species as soon as theyare established, all alien seedlings and saplings should be removed from rehabilitated areas on an ongoing basis, biannually.

Frequency of Maintenance MonthlyLegal Requirements National Environmental Management: Biodiversity Act, 2004 (Act No 10 of 2004).Recommended Action Plans Biodiversity Action Management Plan, Alien Invasive Management Plan. ECO to monitor and assess in the Standard Mine

Management Monitoring Performance AssessmentDuration LoM + five year post rehabilitation monitoring programResponsible Person Environmental Control Officer/ Mine Manager

Disturbance to FaunaDescription of impact Disturbance to wildlife and domestic stock on concession area and in immediate surrounds.Receiving Environment Aquatic and terrestrial faunaObjectives Prevent disturbance or harm to any faunaMitigation and ManagementMeasures

A Mine Environmental Awareness Program (MEAWP) run by the appointed Ecological Control Officer (ECO) will be setup for all mine staff to educate and inform on rules and regulations regarding wildlife and domestic stock;

No hunting, snaring or trapping will be permitted and The mine will operate daytime hours only and no night noise or light disturbances is permitted on site.

Frequency of Maintenance MonthlyLegal Requirements National Environmental Management: Biodiversity Act, 2004 (Act No 10 of 2004).Recommended Action Plans Biodiversity Action Management Plan, Alien Invasive Management Plan. ECO to monitor and assess in the Standard Mine

Management Monitoring Performance AssessmentDuration LoMResponsible Person Environmental Control Officer/ Mine Manager



8.2.4 HeritageTable 8-4: Heritage EMPr

Heritage ArtefactsDescription of impact Impact and loss to surface and sub-surface heritage resources through the exploitation of the clay body. These may include:

historical structures, graves, culturally significant landscape features, geological features, archaeological resources andpaleontological resources.

Receiving Environment HeritageObjectives Prevent the disturbance, harm or destruction of heritage resources.Mitigation and ManagementMeasures

A Mine Environmental Awareness Program (MEAWP) run by the appointed Ecological Control Officer (ECO) will be setup for all mine staff to identify historical artifacts and inform on rules and regulations safeguarding and preservation ofany heritage resources that may be uncovered during operations and

Mine workers to discontinue mining operations in order to alert the mine manager;Frequency of Maintenance OngoingLegal Requirements National Heritage Resources Act, 1999 (Act No. 25 of 1999).Recommended Action Plans Train employees to follow the correct procedures should heritage resources be uncovered.Duration Especially during topsoil and overburden clearing phase of trenching and at all times for LoM.Responsible Person Environmental Control Officer/ Mine Manager

8.2.5 Air Quality and Dust SuppressionTable 8-5: Air Quality and Dust Suppression EMPr

DustDescription of impact Dust generated from site clearing, soil transportation, stockpiling, construction and excavation may be windblown as fugitive

dust and settle on surrounding, residential, agricultural and environmental receptors.

Sources of emissions include dust generated by mine vehicles in the trenching area, bulk earthworks and stockpiles adjacentto the trench as well as exhaust emissions from mine and other emissions related to the dust loading of vegetationsurrounding the immediate area and access road. Such emissions and dust loading will be limited as far as possible throughstabilisation of any exposed areas and dowsing / watering of unsealed surfaces when dust becomes problematic tosurrounding activities. Mine vehicles must be maintained in good working order to minimise emissions.\

Receiving Environment Vegetation and airObjectives To provide management systems to reduce dust dispersion to a minimum.



Mitigation and ManagementMeasures

The disturbed areas must be kept to a minimum; Do not clear vegetation cover unnecessarily; Confine vehicle movements on unpaved roads to demarcated areas only. Limit haul roads and internal access tracks to least required; Demarcate turning circles, haul road and parking areas with fencing to limit overspill of vehicles into no-go zones; Set up water sprayers along haul roads to dampen dust and minimise dust loading to surrounding vegetation; Spraying of clay or coal stockpiles if wind erosion occurs. Limit width of haul roads and access tracks to maximum 4 meters to allow sprayers to reach full width of road; Scarify compacted areas after construction or mining to allow for natural vegetation regrowth; Ensure that all stockpiles, i.e. topsoil, overburden, clay ore, coal storage are enclosed within three sided protection

walls and a low bund wall on fourth side to limit spillage onto loading apron; Limit maximum height of stockpiles to 2 m and orientate long axis along SE-NW prevailing wind direction Design bund walls to prevent wind erosion with orientation such that open end is at right angles to prevailing NW-SE

winds; Hard pave and reinforce first 15 m leading off the Langvlei Quarry public road so that heavy trucks do not damage

tarred road edges and create pot holes due to the turning motion of the truck, and possible spillage from the load bedof coal delivery trucks;

Ensure that site drainage carries spillage of clay or coal fines away from traffic movement zones (and directed tosettling ponds to prevent loss beyond the boundary)

Sweeping of all aprons surrounding tip points and stockpiles; Set up windbreaks or windrows at boundary of working areas to the windward side and Regular twice weekly) visual checking and recording of visible dust emissions from all identified dust sources and

emission points. These check lists to be signed off and permanently retained for analysis of dust emission points andopportunities for continuous improvement

In order to establish a baseline dust fall; site-representative dust fall monitoring, in terms of the National Dust Control;Regulations, will be undertaken prior to the commencement of activities and

Speed control for all mine roads to limit dust generation.Frequency of Maintenance Ongoing and continuousLegal Requirements National Dust Control Regulations Government Gazette no 36974 of 1 November 2013Recommended Action Plans Air Quality Monitoring. Air Emission Officer to monitor and assess in the Standard Mine Management Monitoring

Performance Assessment. Monthly monitoring at four sites.Duration LoMResponsible Person Environmental Control Officer/ Mine Manager



8.2.6 Mine WasteTable 8-6: Mine Waste EMPr

Mine WasteDescription of impact Accumulation of waste from site activities, from solid waste to toilet facilities.Receiving Environment BiophysicalObjectives Manage solid waste in compliance with regulations and requirements from CWDM.Mitigation and ManagementMeasures

Provision of an onsite septic tank will be provided as an ablution facility for human waste; All solid waste must be removed from the work areas and disposed of at approved (municipal) waste disposal facilities; Where possible, options for the reuse or recycling of waste materials must be favoured over disposal. All waste to be

separated into appropriate materials for recycling, viz. tins, glass, and plastics. Biodegradables will be placed in situ intopit;

No waste of any sort shall be buried in the trench areas and Production waste, i.e. broken bricks will be sold as second at the mine gate.

Frequency of Maintenance WeeklyLegal Requirements National Environmental Management: Waste Act (Act no.59 of 2008)Recommended Action Plans Routine site clearing of waste for disposal at municipal waste disposal facility ECO to monitor and assess in the Standard

Mine Management Monitoring Performance AssessmentDuration LoMResponsible Person Environmental Control Officer/ Mine Manager

8.2.7 Noise EmissionTable 8-7: Noise Emission EMPr

NoiseDescription of impact The major noise generating activities will be the development, mining, closure and rehabilitation of the proposed opencast

trenches and the hauling of ore between mine and factory. The operation of a single excavator and dump truck will increasenoise pollution in the area during daylight working hours on the mine.

Receiving Environment Potentially sensitive receptors within two kilometers of the opencast trench are identified as relevant, all others are consideredbeyond the range of influence.

Objectives Keep noise pollution to a minimum and do not adversely affect the surrounding



Mitigation and ManagementMeasures

Normal operating hours kept to during 07h00 to 18h00 during week days, and 08h00 to 14h00 on Saturdays, No work during night hours as defined in SANS 10103:2003; Berms and windrows will be constructed around the excavation area which will aid block sound emission, and Mine vehicles will be regularly serviced and exhaust systems will be maintained in good order in compliance with limiting

noise emissions.Frequency of Maintenance ContinuousLegal Requirements SANS 10103:2003 (South African National Standards)Recommended Action Plans ECO to monitor and assess in the Standard Mine Management Monitoring Performance Assessment.Duration LoMResponsible Person Environmental Control Officer/ Mine Manager

8.2.8 Visual Impact ControlTable 8-8: Visual Control EMPr

Visual Impact ManagementDescription of impact The viewshed extent is approximately 10kms to the north west, 5kms south and 8kms to the east. During the operation of

the mine, the development will be visible. On completion of mining, removal of infrastructure and re-vegetation, the mine willnot be acutely visible although a shallow 4m depression will exist for perpetuity

Receiving Environment Potentially sensitive receptors within the Zone of Visual Influence (ZVI) will be a maximum of 3 km from the mine areas.Objectives Attempt as far as is practically possible to screen activities from 3 km extent of ZVI.Mitigation and ManagementMeasures

The proposed mining activity includes the revegetation of the excavated area which will mitigate the long term potentialnegative visual impact;

The incremental mining method to provide some mitigation avoiding a large cleared area over the full period of the mine; On completion of the mine sections, the shaping of the sides of the mine should be gentle (1:3 – 1:5), undulating slopes

that resemble the natural landforms and not man-made dams; Plant windrows of quick growing, preferably indigenous, trees, around the mine site to screen the mining operation and Over burden from the first phase of trenching can be used as a berm on which windrow can be planted, increase the

height if the screening effect.Frequency of Maintenance ContinuousLegal Requirements Guideline for Involving Visual and Aesthetic Specialists in EIA Process.Recommended Action Plans ECO to monitor and assess in the Standard Mine Management Monitoring Performance Assessment.Duration LoM + five year post rehabilitation monitoring programResponsible Person Environmental Control Officer/ Mine Manager



8.2.9 Traffic ImpactTable 8-9: Traffic Management EMPr

TrafficDescription of impact Impact on traffic on both DR 1384 and TR 31/1Receiving Environment TrafficObjectives Minimise the impact on traffic from and to the mining siteMitigation and ManagementMeasures

For both roads safe access points will be emplaced; Vegetation will be trimmed to the left of DR 1384 along TR 31/1 to clear the sight line for passenger cars. Vegetation height to be managed ongoing for LoM.

Frequency of Maintenance ContinuousLegal Requirements National Road Traffic Act (NRTA) (Act 93 of 1996)

Western Cape Road Access Guidelines Ed-2 September 2002Recommended Action Plans ECO to monitor and assess in the Standard Mine Management Monitoring Performance Assessment.Duration LoMResponsible Person Environmental Control Officer/ Mine Manager



8.3 MONITORING AND PERFORMANCE ASSESSMENT

Table 8-10: Environmental Monitoring programmes

Impact Monitoring Plan Functional Requirements Frequency Roles /Responsibility

Project Phase

Fallout dust. Air quality / falloutdust monitoring.

Dust monitoring is to beconducted.

Monthly (Starting one month priorto the Construction Phase untilRehabilitation is complete).

MineManager/Environmental Manager

ConstructionOperationalRehabilitation &Closure

Contamination tosoil and waterdue tohydrocarbonspillages.

Monitoring of heavymachinery andvehicles.

Spill trays are to be in place andthe mining machinery to inspectfor leaks and maintenancerequirements.

Daily MineManager/Environmental Manager


Erosion andcompaction oftopsoil stockpiles.

Topsoil stockpilemonitoring.

Inspection of topsoil stockpiles toensure that erosion orcompaction is taking place.Stockpiling methods are to beimplemented as outlined in theGuidelines for the Rehabilitationof Mined Land (Chamber ofMines, 2007)

Weekly MineManager/Environmental Manager


Flora/ Fauna Fauna and Floramonitoring plan; andAlien invasivemanagement plan.

Assess the establishment ofvegetation on the site anderadicate any alien invasivevegetation.

Monthly MineManager/Environmental Managerand Floraspecialist.


Storm and otherWaterManagement

Ecological monitoring Assess the surrounding affectedsurface water drainage channelsand assess the impact currentinfrastructure and developmenthave.

Weekly MineManager/Environmental Managerand Fresh WaterSpecialist




Impact Monitoring Plan Functional Requirements Frequency Roles /Responsibility

Project Phase

Heritage Historical ArtefactIdentification Plan

Identify historical artefacts andreport presence to a specialist.Halt operations until the affectedenvironment can be assessed.

Ongoing MineManager/Environmental Managerand heritagespecialist


WasteManagement

Solid Waste andAblutionManagement Plan

Routine site clearing of waste fordisposal at municipal wastedisposal facility

Weekly MineManager/Environmental Manager


Noise Emission Noise And EmissionMonitoring Plan

Keep noise pollution to aminimum and do not adverselyaffect the surroundinginhabitants

Ongoing MineManager/Environmental Manager


Visual ImpactControl

Visual ScreeningPlan

Attempt as far as is practicallypossible to screen activities from3 km extent of ZVI.

Ongoing MineManager/Environmental Managerand VIA specialist


Traffic ImpactControl

Traffic ManagementPlan

Keep traffic impact on DR 1384and TR 31/1 to a minimum

Ongoing MineManager/Environmental Manager




8.4 MONITORING COMPLIANCE AND THE PERFORMANCE ASSESSMENT AGAINST THEENVIRONMENTAL MANAGEMENT PROGRAM AND REPORTING THEREOF

As part of the general terms and conditions for an environmental authorisation and in orderto ensure compliance with the EMPr and to assess the continued appropriateness andadequacy of the EMPr, Gannabosch Clay Mine will:

Conduct monitoring on a continuous basis; Conduct a Performance Assessment of the environmental management program

once in every two years and Compile and submit a Performance Assessment Report to the minister in which

compliance with the approved Environmental Management Program isdemonstrated.

The performance assessment report will, as a minimum, contain the following:

Information regarding the period applicable to the performance assessment; The scope of the assessment; The procedure used for the assessment; The interpreted information gained from monitoring the approved environmental

management program; The evaluation criteria used during the assessment; The results of the assessment and Recommendations on how and when non-compliance and deficiencies will be

rectified.

8.5 MANAGEMENT MEASURES FOR CONCURRENT REHABILITATION AND CLOSURE

The decommissioning of the mine will require a closure certificate in terms of section 43of the MPRDA. This is also Listed Activity 22 in Listing Notice 1 of the EIA Regulations,2014 (GN R983) and requires an application for environmental authorisation and thesubmission of an EIR. The exact details of the closure plan have not been included in thisEIR/EMPr since the life of the mine is expected to extend past a 10 year lifespan. Thisbeing considered, the mine has a concurrent mining and rehabilitation plan (Section4.1.2) which will see mining of 100 m x 100m footprint areas for an increased turnaroundtime for each pit and allowing the rehabilitation of the mined area before the degradationof the stored topsoil microclimate occurs.

Financial provision for the concurrent rehabilitation can be seen in Section 9.1.



9 FINANCIAL PROVISION ESTIMATION

9.1 QUANTUM OF FINANCIAL PROVISION FOR REHABILITATION

The “Guideline Document for the evaluation of the Quantum of closure-relatedfinancial Provision provide by the Mine” was used to determine potential rehabilitationcosts. The clay mine is a Class C mine (low risk), which allows for two options for thedetermination of costs; (1) quick assessment based on footprint, or (2) rules-basedassessment based on relevant line items. Both methods are described below:

Option 1:

As per Table B.10 in the guideline document, the rate per hectare for rehabilitation ofa mine in a medium environmental sensitive area is R50 000. The mine footprint is28.67 ha. Hence, the accepted quantum is R1 433 500 (excl. VAT). Adding 6% P&G,10% contingency and 14% VAT results in a tax-inclusive amount of R1 895 660.

Option 2:

The components considered relevant for rehabilitation of this specific mine are:

3 Rehabilitation of access roads; for direct access roads only, boundary roadswill remain for subsequent use by landowner

6 Opencast rehabilitation including final void and ramps10 General surface rehabilitation; for mine footprint outside of the opencast

areas13 Water management; for sumps with the opencast pits14 Maintenance and aftercare15 Specialist study

The master rates given in Table B.5 of the guideline document are accepted, exceptfor the Component: Opencast Rehabilitation, which has been reduced to R64 000 /ha, as the original master rate is determined for rehabilitation of open cast mines inhard rock material with vertical or near vertical walls. The clay mine will be establishedwith already terraced walls with the correct slope of 1:3. Furthermore, rehabilitation ofthe side walls of the open pit will continue throughout the lifespan of the mine.

The environmental sensitivity of the area is considered medium. Hence, multiplicationfactors of 0.52 for component 6 and of 0.25 for component 13 have been assigned.

Due to the flat nature of the terrain a weighting factor of 1 has been assigned, as perTable B.6. The weighting factor for the proximity to urban area is 1.05 for peri-urbanlocation, as per Table B.7.



Table 9-1: Determination of the quantum for the financial provision of final rehabilitation

The estimated total is similar to the determination applying option 1.

The costs for component 6 have been spread evenly over 20 years of mine operationand included in the environmental costs (see below).

No Description Unit A B C D Amount

Quantity Master rate Multi /factorWeightingfactor Rands

Step 4.5 Step 4.3 Step 4.3 Step 4.4 A*B*C*D3 Rehabilitation of access roads M2 700.00 17.00 1 1.1 13 090.00

6Opencast rehabilitation includingfinal voids and ramps. Ha 21.00 64 000.00 0.52 1.1 768 768.00

10 General surface rehabilitation. Ha 5.67 52 600.00 1 1.1 328 066.2013 Water management. Ha 2.00 20 000.00 0.25 1.1 11 000.00

142 to 3 years of maintenance andaftercare. Ha 28.67 7 000.00 1 1.1 220 759.00

15(a) Specialist study. Sum 40 000.00 40 000.00R 1 381 683

Multiply Sum by weighting factor 2 (Step 4.4) (Urban=1, Peri Urban=1.05, Remote=1.1) 1.05 1 450 767.36Preliminary and general 6% 87 046.04Contingincies 10% of Sum 1-15 10% 145 076.74Sub total R 1 682 890VAT 14% 14% 235 604.62

Grand Total R 1 918 495

Determination of the quantum for the Financial provision of final rehabilitation.



Table 9-2: Progressive forecast of Environmental Cost for the first ten years

ENVIRONMENTAL COSTCATEGORY Y1 Y2 Y3 Y4 Y5 Y6 Y7 Y8 Y9 Y10

ForecastCPI Total

Roads maintenance /dustcontrol 10.00 10.00 5.00 5.25 5.51 5.79 6.08 6.38 6.70 7.04 5% 67.75

Open Cast Rehabilitation 38.44 40.36 42.38 44.50 46.72 49.06 51.51 54.09 56.79 59.63 5% 483.47

Rehabilitation ofOverburden 2.00 2.10 2.21 2.32 2.43 2.55 2.68 2.81 2.95 3.10 5% 25.16

Surface Rehabilitation 2.00 2.10 2.21 2.32 2.43 2.55 2.68 2.81 2.95 3.10 5% 25.16

Fencing/windrows 15.00 15.00 9.00 9.45 9.92 10.42 10.94 11.49 12.06 12.66 5% 115.94

Storm water Management 25.00 25.00 2.00 2.10 2.21 2.32 2.43 2.55 2.68 2.81 5% 69.10

Practitioner Fees 2.59 2.72 2.86 3.00 3.15 3.31 3.47 3.64 3.83 4.02 5% 32.58

General 5.55 5.67 3.77 3.96 4.15 4.36 4.58 4.81 5.05 5.30 47.19

contingency 9.24 9.46 6.28 6.59 6.92 7.27 7.63 8.01 8.41 8.83 78.66

Total 109.82 112.41 75.69 79.47 83.45 87.62 92.00 96.60 101.43 106.50 945.00

Notes Progressive forecast of Environmental Cost for the first ten years

: 1. Amounts in R'000

CATEGORY COST ESTIMATE

a) Progressive total for rehabilitation R 945 000

b) Cost to mitigate socio-economic conditions of directly affected persons R 0.00

TOTAL COSTS (Transfer amount to cash flow forecast – Line 7 Year 1 only) R 945 000



9.2 QUANTUM OF FINANCIAL PROVISION FOR SOCIAL DEVELOPMENT

Table 9-3: Social development financial quantum

ITEM Y1 Y2 Y3 Y4 Y5 Y6 Y7 Y8 Y9 Y10Forecastincrease

Human ResourceDevelopment 25.47 25.47 25.47 25.47 25.47 28.02 28.02 28.02 28.02 28.02 10%/5yrsLocal Economic Development 4.00 4.00 4.00 4.00 4.00 4.40 4.40 4.40 4.40 4.40 10%/5yrsManagement of downscaling 1.62 1.70 1.78 1.87 1.96 2.06 2.16 2.27 2.39 2.51TOTALS 31.09 31.17 31.25 31.34 31.43 34.48 34.58 34.69 34.80 34.92

Notes: Progressive forecast of Social Development Cost for the first ten years1. Amounts in R'000

2. Downscaling provision is one weeks salary for every year worked (Labour Relations Act, 1995)

CATEGORY COST ESTIMATE

a) Progressive total for Socio Economic Development R 329 750

b) Cost to mitigate socio-economic conditions of directly affected persons R 0

TOTAL COSTS R 329 750



9.3 METHOD OF PROVIDING FINANCIAL PROVISION

Sufficient capital reserves are required for the mine to begin operation. From this point further,retained earnings from mining operation will be utilised for cash flow purposes. Dividends areexpected to be split on an annual basis, with 50% of the profits being split amongst theshareholders at their relative ownership percentages, while the remaining 50% of the profit isretained into the new financial year for cash flow purposes (Umvoto, 2016b)

10 CONCLUSION AND RECOMMENDATION

As concluding remarks, the principal findings are discussed for the DMR to consider and putforward an informed decision in which the outcome is aligned with the principles of sustainabledevelopment. As expected, impacts are primarily negative, due to the nature of mining andits effect on the biophysical environment; however the positive socio-economic benefit for theregion and the local community needs to be considered in the decision process. Considerationfor sensitive habitats has been contemplated in Section 3.6. The extent to which thedevelopment will impact the environment, and associated mitigation measures that attempt toreduce the impact on these areas is provided in Section 6. The EMP Report elevates themitigation to a status of enforced and measurable control which guides the management ofthe mine.

The EIA has examined both available background data and the following specialist fieldstudies to be incorporated into baseline data (Section 3) to facilitate the identification andevaluation of biophysical and socio-economic environmental impacts of the proposed mine.

Heritage Specialist Study (in form of an NID investigation, Annexure D-1: FirstNotice of Intent to Develop and Annexure D-2: Amended Notice of Intent toDevelop);

Botanical Impact Assessment (Annexure E-1: First Botanical Specialist Report andAnnexure E-2: Amended Botanical Specialist Report);

Freshwater Ecology Impact Assessment (Annexure F-1: First Freshwater SpecialistReport and Annexure F-2: Amended Freshwater Specialist Report);

Visual Impact Assessment (Annexure G: Visual Impact Specialist Report); Dust Emission Study (Annexure H: Atmospheric Impact Assessment) as part of the

Air Emission License Application; Traffic Impact Assessment (Annexure I: Traffic Impact Statement); Alternative Resource Study (Annexure J: Alternative Resource Survey Report); Economic Impact Study (Annexure K: Economic Impact Study); and Storm Water Management Plan (Annexure L: Storm Water Management Plan)

The recommendation and guidance of specialists and stakeholders has provided meaningfulinput to the process. Public participation occurred at the Scoping phase in April 2016 andagain for the presentation of the first Draft EIA in July 2016. Stakeholder feedback from theseprocesses contributed towards a reconsideration of the position of the mine footprint and asubsequent amendment to the application. The outcome of this has led to a third round ofpublic participation, conducted between 14 November and 15 December 2016.Considerations of all stakeholders and specialists studies have culminated in the Final EIAand EMP Report for submission to the DMR.



This EIA and EMPr report aims to inform decision-makers of the key considerations byproviding an objective and comprehensive review of the potential impacts and benefits of theproject and has created a platform for the formulation of mitigation measures to manage theseimpacts, presented in the EMPr.

10.1 PRINCIPAL FINDINGS

The key findings of the EIA study indicate that the development of the Gannabosch Clay Mineand the associated Robertson Bakstene brick making facility are:

1. The proposed developments are within a terrestrial and aquatic CBA providing anessential upland-lowland corridor between the Langeberg Mountains to the north andthe Breede River system to the south and is therefore considered to have a highecological viability from botanical and faunal habitat perspective.

2. The specific footprint of the mine area is positioned between two ephemeral drainagelines, which form a crucial part of a more regional ESA. A third, albeit less significantdrainage line, is truncated and diverted into a storm water culvert, due to the positioningof the mine concession area.

3. Due to the presence of Breede Alluvium Renosterveld vegetation within the concessionarea; the ecosystem status of the concession area is classified as Vulnerable (VU),under the criterion A1, in the National List of Threatened Ecosystems 2011 (G 34809,GN 1002). Robertson Karoo vegetation, which is Least Threatened (LT), is evidentwithin the surrounding areas.

4. The impact to Heritage resources was evaluated as insignificant and Heritage WesternCape have ruled that no further permissions under the National Heritage ResourcesAct are required for the developments

5. The Zone of Visual Impact imposed on the area extends to a maximum radius of 3 kmfrom the mine and the R 60 scenic tourist route is a highly sensitive receptor.

6. Fugitive dust from excavation and hauling will be dispersed along a southeast –northwest axis in alignment with the prevailing wind directions. The range of particulatematter fallout is limited to 1 to 2 km from source, due to the rapid loss of particles fromthe airstream by gravitational settling and dilution.

7. The brick manufacturing process will emit Sulphur Dioxide, Nitrogen Oxides, as wellas Carbon emissions from the usage of duff and small nut coal in the brick body andkilns respectively. The impacts of these emissions will be further evaluated in theEnvironmental Authorisation procedure for Robertson Bakstene, which has beensubmitted to the DEA&DP as part of a separate application by a different legal entity.However, the cumulative impact of the brick factory is relevant to the clay mine andhas been assessed in this EIA Report.

8. Noise from mine machinery and vehicular traffic attenuate to acceptable levels ofbelow 45 dBA within a radius of 500 m from point source. This is below the 65 dBAlevel considered to be acceptable and within the 45 dBA requirement for rural districtsaccording to the SANS-10103:2003 regulation limits.

9. The development of the mine and the factory, in association with the brick makingfactory, will provide a moderate to substantial positive socio-economic input to the localarea through the provision of work opportunities which will be elevated by a multipliereffect in the broader region of the town of Robertson. As a standalone project, themine of itself will not provide significant work opportunities, as it intends to employ veryfew staff, however the mine must be considered in its cumulative relationship to thebrick factory in this regard.



10. The development is in alignment with the socio-economic aspects of the strategic plansfor the region which are noted in various regional documents such as the CapeWinelands District Municipality and Langeberg Local Municipality Spatial DevelopmentFrameworks (SDF’s) and Integrated Development Plans (IDP’s). This clearlydemonstrates the socio-economic benefit of the development. In contrast, however, itshould be noted that the mine falls within a CBA, which is a Core-One zone of the SDF.

11. The Robertson area is reliant on receiving its brick supplies from the broader region ofthe Western Cape. The supply situation was further exasperated when the MontaguBricks closed in July of 2016. This has placed a stress on the transport and roadinfrastructure of the region due to the high volume and load of the product. It is notviable to transport clay off the mine for remote beneficiation as the two process are defacto linked. The future construction initiatives of the region will place further demandon brick supply and this will impose a perpetuating demand to the roads. Linked withthis demand – supply mismatch is the opportunity for a beneficial enterprise that willneed to be met in the long run to sustain growth.

12. The cumulative effect from mining, current activities at the Cape Lime plant and futurebrick manufacturing could escalate several impacts, the least of which will beinfringement on the integrity of the CBA and the ESA, degradation of the ephemeraldrainage lines.

13. Environmental impact from the additional fugitive dust and chemical emissions areunlikely to be cumulative as the lime works and the proposed brick factory are off setfrom each other along the prevailing wind directions.

14. From a visual cumulative impact perspective, it may be preferable to consolidate thevisual impacts into one area, alongside the Cape Lime Plant. The siting of the minealong sites, removed from Cape Lime, would have a greater cumulative impact withrepeated visual impacts, than is currently predicted in the proposed position.

15. Cumulative impact must also consider the positive impact of the presence of businessactivity in the Langeberg region.

16. To avoid development within a CBA, alternative clay resources were considered thatcould provide a like-for-like opportunity to mine clay and set up the beneficiation plant.Five alternative areas were identified based on a desk top study. Ground truthingdisproved the viability of each of the alternatives.

17. The EMPr provides mitigation measures to minimize the impacts and to rehabilitateafter operation, as far as possible.

Hence, all requirements of the Mining and Biodiversity Guideline (2013) regarding avoid orprevent, minimize and rehabilitate have been met.

10.2 CONCLUSIONS

This Final EIA and EMP Report concludes the environmental assessment and provides anenvironmental management plan for the proposed Gannabosch Clay Mine. The intent of thisreport is to provide options and alternatives for a preferred placing and sizing of the mine inalignment with critical environmental objectives, and to support these findings with essentialmitigation and optimisation interventions. In so doing, it has identified and assessed thepotential biophysical and socio-economic impacts associated with the proposed GannaboschClay Mine and to a limited degree, the associated Robertson Bakstene Factory. The finalposition and size of the proposed concession is a conclusion of specialist recommendations,consideration of stakeholder concerns and a process of due diligence and best practice putforward by the consultant, Umvoto Africa.



It is common practice in an EIA study to provide a number of alternatives to the proposeddevelopment that will allow the stakeholders and, by implication, the decision-making authorityto make preferred choices. These alternatives were adequately covered in the Initial Draft EIAReport and were therefore not re-addressed in the second submission. Suffice to say, that inthis final submission, one placement for the mine is recommended. In addition, however, thereport also provides a No-Go Alternative (Section 7.3.2).

Based on these findings, the EAP has provided the following conclusion in support of thedecision-making process. NEMA Section 31 (n) requires the consultant to provide an opinionas to whether the activity should or should not be authorised. A qualified opinion is offeredbelow:

It is recommended that the development is approved with the recognition that themining process will result in unavoidable adverse, mostly local environmental impacts,within an area and corridor of ecological importance, some of which will be longlasting. Each of these impacts can be mitigated with best practice mining methods,strict compliance with the EMP Report’s guidelines and mitigation measures thatoptimise the principles of sound environmental management. The EAP further suggestthat the DMR must reasonably consider the socio-economic benefits to the region bothin the provision of work opportunities and in the supply of a much needed resource.

The guidance from the freshwater and botanical specialist studies is to avoid mining inthe western portion of Gannabosch Vlakte 51 farm and to re-orientate the initial eastto west axis of the proposed development, into a north to south axis. This approachwill allow for a wider CBA and ESA corridor and will reduce the edge effect tovegetation avoiding isolated flora and faunal fragments. The proponent has fullyendorsed this concept and therefore taken due consideration for the opinionsexpressed by the stakeholders.

10.3 RECOMMENDATIONS

The amended approach still carries with it a raft of mitigation and optimisation protocols thatare clearly laid out in the EMPr and which will serve to minimize impact on the environment towithin tolerable limits. Compliance and conformity to these principles must be monitored byan appointed Ecological Officer (ECO) and regular audits submitted to the CompetentAuthorities.

Specific recommended mitigation measures are summarised in the EIA (Section 6). It wouldbe incumbent on the proponent to demonstrate compliance and adherence to these measuresin order to establish a best practise mining methodology. Key recommendations include:

Adhere to and implement the EMPr to guide the mining process;

Appoint an Environmental Control Officer (ECO) to oversee and supervise theimplementation of the EMP and to provide any statutory organisations with the requiredcompliances and audit reports;

Diversion of Drainage line 2, in accordance with a Storm Water Management Plan asdesigned by a competent specialist;

Restrict the footprint of the mine by avoiding the sensitive areas of drainage line 1, 3and the Vink River floodplain, with a 30 meter buffer zone;

Rehabilitate the disturbed areas in accordance with the methodology laid out in theEMPr and re-vegetate the slopes and pit surfaces concurrently with mining to minimisethe size of the footprint at any instant in time;



Stripped topsoil’s and mined material to be kept off “No-Go” zones;

Silt trapping measures to be put in place as part of land clearing procedure;

Water Conservation and Water Demand Management systems to be put in placebefore mining commences in accordance with the design of the Storm WaterManagement Plan;

Vehicular traffic to be restricted from “No-Go” zones;

External lighting to be avoided to minimise disturbance to nocturnal fauna and avifaunaand

Obtain all necessary and required permits and authorisations as may be required suchas Water Use License, Air Emissions License, permits for translocation of vegetationspecies etc. (this is not an exhaustive list).

It is recommended that these requirements become a condition of the Record of Decision bythe competent authority.



11 REFERENCESCole, D.I., Ngcofe, L., Halenyane, K. (2014) Mineral Commodities in the Western Cape

Province, South Africa, Council of Geoscience: Report Number:2014-0012,Western Cape Regional Office. February 2014

CNdV, (2014): Langeberg Municipality: Spatial Development Framework (Draft): prepared forDEA&DP and Langeberg Municipality. , November 2014

CWDM, (2014), 2014/2015 Annual Report: Cape Winelands District Municipality, 203 pp

CWDM, (2012): Cape Winelands District Municipality: Integrated Development Plan(2012/13-2016/17)

CWDM, (2015), Cape Winelands District Municipality: Annual Report 2014/2015)

CWDM, (2012): Cape Winelands District Municipality: Integrated Development Plan(2012/13-2016/17)

DEA&DP, (2014): Western Cape Provincial Spatial Development Framework. Produced byEnvironmental & Spatial Planning division of Western Cape Department ofEnvironmental Affairs and Development Planning, November 2014.

Department of Water and Sanitation, DWS (2014). Reconciliation Strategy for Robertson.Development of Reconciliation Strategies for Selected Towns in the SouthernPlanning-Region. Prepared by Umvoto Africa (Pty) Ltd in association withWorleyParsons (Pty) Ltd. on behalf of the Department of Water and Sanitation,South Africa. Directorate : National Water Resource Planning. 18 pp

DEA&DP, (2014).: Western Cape Provincial Spatial Development Framework. Produced byEnvironmental & Spatial Planning division of Western Cape Department ofEnvironmental Affairs and Development Planning, November 2014.

Enviro Dinamik, (2007), Spatial Development Framework: District Management Area (Draft),February 2007

Elsenberg GIS: ArcGIS Services Directory, Western Cape Government: Agriculture [accessed2015 Dec 05]. http://gis.elsenburg.com/app/cfm.

Jacobs, K. & Jangle, R. (2008). Renosterveld Ecosystem Management Plan: Western Cape.Unpublished, The Nature Conservation Corporation, Cape Town

Krige, J. (2016) Botanical impact assessment for the Gannabosch Clay Mine, Farms 51 &5/52, Robertson

Langeberg ,(2016) Integrated Development Plan(Reviewed for 2016/207)

Mucina, L., & Rutherford, M.C. (eds). (2006). The Vegetation of South Africa, Lesotho andSwaziland. Strelitzia 19. South African Biodiversity Institute, Pretoria. ISBN: 978-1919976-21-1

Ollis, D; Ngobela, T.Olsen,T.(2016)-Freshwater Ecology Impact Assessment Report forproposed Gannabosch Clay mine on Farm 51 and 5/51, Robertson, 32pp



P. le Roux, (2012), Report on a Soil Survey as part of an Environmental Impact Assessmentof the development of a Solar Farm on the soils of Valleydora Solar FarmSpringfontein, CSIR, pp10.

Reinecke K, Rountree M and Crowther J (2014). Noree/Vink River Maintenance ManagementPlan. Prepared by Southern Waters Ecological Research and Consulting cc inassociation with Fluvius Environmental Consultants and CCA Environmental,June 2014.

SABAP2 (2016): South African Bird Atlas Project 2 (Accessed 18/07/2016)(http://sabap2.adu.org.za/)

SA Explorer: Information by Location [assessed 2015 Nov 25] www.saexplorer.co.za/south-africa/climate/robertson 2000-2014

Stats SA (2011) Census 2011

Umvoto Africa. (2016a) Gannabosch Vlakte 51: Mining Rights Application – Scoping Report.Prepared by G. Molzen, P. Lee, L. Towers and E. Wise of Umvoto Africa (Pty) Ltdfor Gannabosch Clay Mine (Pty) Ltd. Report No. 856/03/01/2016, April 2016, 45pp.

Umvoto Africa (2016b) Gannabosch Vlakte 51: Mining Rights Application – Social and LabourPlan. Prepared by P. Lee, L. Nolakana and J. Rust of Umvoto Africa (Pty) Ltd forGannabosch Clay Mine (Pty) Ltd. Report No. 856/11/01/2016, February 2016,21pp.

Umvoto Africa. (2016c). Gannabosch Vlakte 51: Mining Rights Application – Mine WorksProgramme. Prepared by G. M. Molzen and P. Lee of Umvoto Africa (Pty) Ltd forGannabosch Clay Mine (Pty) Ltd. Report No. 856/05/01/2016, February 2016,45pp.CWDM – Annual Report 2014/2015)

WeatherOnline: Weather Online Ltd. [accessed 2015 Dec 03],www.weatheronline.co.uk/weather/maps/city, 1999-2016

Western Cape Provincial Spatial Development Framework 2014

Western Cape Government Provincial Treasury, WCGPT (2015) Municipal Economic Review& Outlook. Cape Town

Western Cape Government Provincial Treasury, WCGPT(2015) Socio-economic ProfileLangeberg Municipality. Working paper

Western Cape Department of Agriculture, WCDA & Western cape Department ofEnvironmental Affairs & Development planning, WCDEA&DP (2015) Status QuoReview of Climate Change and Agriculture in the Western Cape, Prepared bySMART Agri & African Climate & Development Initiative, ACDI

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