ASAPA	Association of South African Professional Archaeologists
BP	Borrow Pit
CARA	Conservation of Agricultural Resources Act 43 of 1983
CBA	Critical Biodiversity Area
CRM	Cultural Resource Management
DEA	Department of Environmental Affairs (National)
DEDEAT	Department of Economic Development, Environmental Affairs and Tourism
DEMC	Desired Ecological Management Class
DMR	Department of Mineral Resources
DWA	Department of Water Affairs
DWAF	Department of Water Affairs and Forestry (former department name)
EA	Environmental Authorisation
ECO	Environmental Control Officer
EIA	Environmental Impact Assessment
EIR	Environmental Impact Report
EIS	Ecological Importance and Sensitivity Classification
EMC	Ecological Management Class
EMP	Environmental Management Plan
EMPr	Environmental Management Programme report
ER	Environmental Representative
ESS	Ecosystem Services
IAP’s	Interested and Affected Parties
IEM	Integrated Environmental Management
LHS	Left Hand Side
LM	Local Municipality
LoM	Life of Mine
masl	meters above sea level
MIA	Mining Infrastructure Area
MPRDA	Mineral and Petroleum Resources Development Act 28 of 2002
NBA	National Biodiversity Assessment
NEMA	National Environmental Management Act 107 of 1998
NEMBA	National Environmental Management: Biodiversity Act 10 of 2004
NFA	National Forest Act 84 of 1998
NOMR	New Order Mining Right
PEMC	Present Ecological Management Class
PES	Present Ecological State
RDL	Red Data List
RHS	Right Hand Side
RoD	Record of Decision
RoM	Run of Mine
SAHRA	South African Heritage Resources Agency
SANBI	South African Biodiversity Institute
SARTM	South African Rural Traffic Model
SDF	Spatial Development Framework
SoER	State of the Environment Report
SSC	Species of Special Concern
TOPS	Threatened of Protected Species
ToR	Terms of Reference
+ve	Positive
-ve	Negative

Corridors:	Have important functions as strips of a particular type of landscape differing from adjacent land on both sides. Habitat, ecosystems or undeveloped areas that physically connect habitat patches. Smaller, intervening patches of surviving habitat can also serve as "stepping stones" that link fragmented ecosystems by ensuring that certain ecological processes are maintained within and between groups of habitat fragments.
Degraded habitat/land	Land that has been impacted upon by mans activities (including introduction of invasive alien plants, light to moderate overgrazing, accelerated soil erosion, dumping of waste), but still retains a degree of its original structure amd species composition (although some species loss would have occurred) and where ecological processes still occur (albeit in an altered way). Degraded land is capable of being restored to a near-natural state with appropriate ecological management.
ECO/ESO:	Environmental Site/Control Officer – person responsible for the Day-to-Day Environmental Management on-site during construction.
Ecological Processes:	Ecological processes typically only function well where natural vegetation remains, and in particular where the remaining vegetation is well-connected with other nearby patches of natural vegetation. Loss and fragmentation of natural habitat severely threatens the integrity of ecological processes. Where basic processes are intact, ecosystems are likely to recover more easily from disturbances or inappropriate actions if the actions themselves are not permanent. Conversely, the more interference there has been with basic processes, the greater the severity (and longevity) of effects. Natural processes are complex and interdependent, and it is not possible to predict all the consequences of loss of biodiversity or ecosystem integrity. When a region’s natural or historic level of diversity and integrity is maintained, higher levels of system productivity are supported in the long run and the overall effects of disturbances may be dampened
Isisivane	Isisivane consist of large piles of stones of different sizes and heights. They are usually near rivers and mountain crossings. Their purpose and meaning is not fully understood, however some are thought to represent burial cairns while others may have symbolic value
Ecosystem status:	Ecosystem status of terrestrial ecosystems is based on the degree of habitat loss that has occurred in each ecosystem, relative to two thresholds: one for maintaining healthy ecosystem functioning, and one for conserving the majority of species associated with the ecosystem. As natural habitat is lost in an ecosystem, its functioning is increasingly compromised, leading eventually to the collapse of the ecosystem and to loss of species associated with that ecosystem.
Ecosystem:	All of the organisms of a particular habitat, such as a lake or forest, together with the physical environment in which they live
Endangered:	Endangered terrestrial ecosystems have lost significant amounts (more than 60 % lost) of their original natural habitat, so their functioning is compromised.
Endemic:	A plant or animal species, or a vegetation type, which is naturally restricted to a particular defined region. It is often confused with indigenous, which means ‘native, occurring naturally in a defined area’.
Environment:	The external circumstances, conditions and objects that affect the existence and development of an individual, organism or group. These circumstances include biophysical, social, economic, historical and cultural aspects.
Environmental Impact Assessment (EIA):	A study of the environmental consequences of a proposed course of action
Exotic:	Non-indigenous; introduced from elsewhere, may also be a weed or alien invasive species. Exotic species may be invasive or non-invasive.
Fragmentation (habitat):	Causes land transformation, an important current process in landscapes as more and more development occurs.
Habitat:	The home of a plant or animal species. Generally those features of an area inhabited by animal or plant which are essential to its survival.
Indigenous:	Native; occurring naturally in a defined area.
Least threatened terrestrial ecosystems:	These ecosystems have lost only a small proportion (more than 80 % remains) of their original natural habitat, and are largely intact (although they may be degraded to varying degrees, for example by invasive alien species, overgrazing, or overharvesting from the wild).
Method statement (construction):	A method statement is prepared for each task on a particular site by the contractor; the group of work method statements are then packaged and included in the overall Construction Plan.
Off-sets:	Compensation for biodiversity loss resulting from authorized changes in land use. Can include assigning stewardship or protected area status to remaining conservation-worthy land or making a financial bequest for purposes of biodiversity conservation.
Riparian:	Pertaining to, situated on or associated with a river bank.
River corridors:	River corridors perform a number of ecological functions such as modulating stream flow, storing water, removing harmful materials from water, and providing habitat for aquatic and terrestrial plants and animals. These corridors also have vegetation and soil characteristics distinctly different from surrounding uplands and support higher levels of species diversity, species densities, and rates of biological productivity than most other landscape elements. Rivers provide for migration and exchange between inland and coastal biotas.
Scoping	A procedure to consult with stakeholders to determine issues and concerns and for determining the extent of and approach to the EIS, used to focus the EIA
Scoping Report	A written report describing the issues identified to date for inclusion in an EIA.
Transformation:	In ecology, transformation refers to adverse changes to biodiversity, typically habitats or ecosystems, through processes such as cultivation, forestry, drainage of wetlands, urban development or invasion by alien plants or animals. Transformation results in habitat fragmentation – the breaking up of a continuous habitat, ecosystem, or land-use type into smaller fragments.
Transformed Habitat/Land	Land that has been significantly impacted upon by mans activities (Such as cultivation, urban development, mining, landscaping, severe overgrazing), and where the original structure, species composition and functioning of ecological processes have been irreversibly altered. Transformed habitats are not capable of being restored to their original states.
Tributary/ Drainage line:	A small stream or river flowing into a larger one.
Untransformed habitat/land	Land that has not been significantly impacted upon by mans activities. These are ecosystems that are in a near-pristine condition in terms of structure, species composition and functioning of ecological processes.
Vulnerable:	Vulnerable terrestrial ecosystems have lost some (more than 60 % remains) of their original natural habitat, and their functioning will be compromised if they continue to lose natural habitat.
Weed:	An indigenous or non-indigenous plant that grows and reproduces aggressively, usually a ruderal pioneer of disturbed areas. Weeds may be unwanted because they are unsightly, or they limit the growth of other plants by blocking light or using up nutrients from the soil. They also can harbour and spread plant pathogens.
Wetlands:	A collective term used to describe lands that are sometimes or always covered by shallow water or have saturated soils, and where plants adapted for life in wet conditions usually grow.

This Report has been prepared by Engineering Advice and Services, with all reasonable skill, care and diligence within the terms of the contract with the client, incorporating our standard terms and conditions of business and taking into account the resources devoted to it by agreement with the client. EAS disclaims any responsibility to the client and others in respect of any matters outside of the scope of the above.

This report is exclusive to the client and the described project. EAS accepts no responsibility of whatsoever nature to third parties to whom this Background Information Document, or any part thereof, is made known. Any such persons or parties rely on the report at their own risk.

Release Notes

Report Version	Date
Public Draft	16 January 2015
Final Report	16 February 2015

1 Introduction & Overview

The Eastern Cape Department of Roads and Public works (DRPW) require material for general maintenance of provincial roads, in particular gravel roads. There are numerous existing borrow pits (BP’s) that have been historically used to maintain these roads, however these are not formally registered with the Department of Mineral Resources (DMR).

EAS was appointed as the independent consultants to assess the environmental impacts and requirements in terms of the Mineral and Petroleum Resources Development Act (MPRDA, Act 28 of 2002). This includes submitting an application for a mining right (this document), to the DMR, for the sourcing of material for re-gravelling of roads in the area from 5 existing unlicensed borrow pits. This EMP is prepared in accordance with the requirements of the MPRDA and DMR

Applicants for mining permits, are herewith, in terms of the provisions of Section 29 (a) and in terms of section 39 (5) of the Mineral and Petroleum Resources Development Act, directed to submit an Environmental Management Plan strictly in accordance with the subject headings, and to compile the content according to all the sub items to the said subject headings referred to in the guideline published on the Departments website, within 60 days of notification by the Regional Manager of the acceptance of such application. This EMP document adheres to the standard format provided by the Department in terms of Regulation 52 (2).

1.1 Legal and Administrative Requirements

The permitting will be undertaken in accordance with the Mineral and Petroleum Resources Development Act (MPRDA; No. 28 of 2002). As an organ of state, the Department of Roads and Public Works (DRPW) has obtained exemption from the provisions of sections 16, 20, 22 and 27 (application process) of the MPRDA in respect of any activity to remove any material for the construction and maintenance of dams, harbours, roads and railway lines and for the purposes incidental thereto, as allowed by the said act in section 106 (1). As such the utilisation of resources is subject only to the preparation, submission and approval of an EMP, compiled in accordance with the requirements of the MPRDA.

The purpose of the EMP is to identify and assess potential impacts associated with the project through a process of environmental investigations, stakeholder and public consultation, and to provide sufficient detail on the project to the Department of Mineral Resources (DMR), in order to allow DMR to make an informed decision on the project.

1.1.1 MPRDA Section 106 (1)

Exemptions from certain provisions of Act

106. (1) The Minister may by notice in the Gazette, exempt any organ of state from the provisions of sections 16, 20, 22 and 27 in respect of any activity to remove any mineral for road construction, building of dams or other purpose which may be identiﬁed in such notice.

(2) Despite subsection (1), the organ of state so exempted must submit an environmental management programme for approval in terms of section 39(4).

(3) Any landowner or lawful occupier of land who lawfully, takes sand, stone, rock, gravel or clay for farming or for effecting improvements in connection with such land or community development purposes, is exempted from the provisions of in subsection (1) as long as the sand, stone, rock, gravel or clay is not sold or disposed of.

With regard to the environment, Section 37(1) of the MPRDA provides that the environmental management principles listed in Section 2 of the National Environmental Management Act (No. 107 of 1998) (NEMA) must guide the interpretation, administration and implementation of the environmental requirements of the MPRDA, and makes those principles applicable to all prospecting and mining operations. The NEMA principles apply throughout South Africa to the actions of all organs of state that may significantly affect the environment, and thus to decision making on mining applications. These principles require that impacts on biodiversity and ecological integrity are avoided, and if they cannot altogether be avoided, are minimised and remedied. They also specify that the costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment. Moreover the responsibility for the environmental health and safety consequences of a policy, programme, project, product, process, service or activity exists throughout its life cycle.

Furthermore, Section 37(2) of the MPRDA states that “any prospecting or mining operation must be conducted in accordance with generally accepted principles of sustainable development by integrating social, economic and environmental factors into the planning and implementation of prospecting and mining projects in order to ensure that exploitation of mineral resources serves present and future generations”.

To ensure this, the MPRDA stipulates that:

· the NEMA principles apply to all mining and serve as guidelines for the interpretation, administration and implementation of the environmental requirements of the MPRDA (Section 37(1)).

· the holder of a permission/right/permit (Section 38):

· must consider, investigate, assess and communicate the impact of his or her prospecting or mining on the environment

· must manage all environmental impacts

· must – as far as is reasonably practicable, rehabilitate the environment to its natural or predetermined state, or to a land use which conforms to the generally accepted principle of sustainable development

· is responsible for environmental damage, pollution or ecological degradation as a result of reconnaissance, prospecting or mining operations which may occur inside and outside the boundaries of the areas to which such right, permission or permit relates.

· the permission/right/permit may be issued if the Minister is satisfied that it will take place within the framework of national environmental management policies, norms and standards (Section 48(2)).

The MPRDA includes some key legal and regulatory mechanisms:

· EMP: this is the main tool used to mitigate and manage environmental impacts, detailing the proposed measures to be undertaken. The requirements of an EMP in the MPRDA (and dependent on the permission/right/permit to which it will be applied) are slightly different to those prescribed in Section 24N of NEMA (Amendment Act 62 of 2008), but generally both are giving effect to similar general objectives of integrated environmental management laid down in Section 23 of NEMA. The MPRDA requires mining operators to obtain environmental approval in advance of operations. It also imposes on-going environmental management and mitigation obligations throughout the mining life cycle. The EMP requires the applicant to undertake an EIA (see section 3.4 for more detail) and to set out the applicant’s financial provision for mitigation. The MPRDA (Regulation 51(a)(i)) also requires that environmental objectives and goals for closure are included in the EMP, highlighting the need to plan with closure in mind.

· MPRDA Pollution Control and Waste Management Regulations: provide that water management and pollution control comply with the provisions of the National Water Act. It further provides that control of erosion and soil pollution control comply with applicable legislative requirements.

· Prohibition or restriction of mining or prospecting: in terms of Section 49 of the MPRDA, the Minister of Mineral Resources may completely prohibit or restrict the granting of any permission/permit/right if the land is residential area, public road, railway or cemetery, being used for public or government purposes or reserved in terms of any other law. This provision allows the Minister, in consultation with other relevant Departments, to prohibit or restrict granting permission/right/permit in certain areas of critical biodiversity, heritage and hydrological importance.

· In addition to the MPRDA, mining companies also need to comply with a range of other laws which regulate mining impacts on the environment. These include:

· Constitution of Republic of South Africa, 1996: Section 24(a) of the Constitution states that everyone has the right ‘to an environment that is not harmful to their health or well-being’. Mines must comply with South African constitutional law by conducting their activities with due diligence and care for the rights of others.

· NEMA: Environmental management principles set out in NEMA, and other Specific Environmental Management Acts (SEMAs) should guide decision making throughout the mining life cycle to reflect the objective of sustainable development25. Mining is prohibited in protected areas defined in the National Environmental Management Protected Areas Act (No. 57 of 2003; hereafter referred to as Protected Areas Act).

· One of the most important and relevant principles is that disturbance of ecosystems, loss of biodiversity, pollution and degradation of environment and sites that constitute the nation’s cultural heritage should be avoided, minimised or as a last option remedied. This is supported by the Biodiversity Act as it relates to loss of biodiversity.

· EIA Regulations (GN No. R. 543) published in terms of NEMA trigger the need for applicants to undertake either a Basic Assessment or Scoping and Environmental Impact Assessment if the proposed activity is included in one or more of the three Listing Notices; and Listing Notice 3 (listing activities and sensitive areas per province, for which a Basic Assessment process must be conducted) (GN No. R. 546).

· In some cases both the MPRDA and NEMA require the identification, assessment and evaluation of impacts, and the determination of appropriate mitigation measures. An EMP may be required for activities subject to an EIA under NEMA.

· Water Use Authorisations: the National Water Act (No. 36 of 1998) requires that provision is made both in terms of water quantity and quality for ‘the reserve’, namely to meet the ecological requirements of freshwater systems and basic human needs of downstream communities. It is essential in preparing an EMP that any impacts on water resources, be they surface water or groundwater resources, and/ or impacts on water quality or flow, are carefully assessed and evaluated against both the reserve requirement and information on biodiversity priorities. This information will be required in applications for water use licenses or permits and/or in relation to waste disposal authorisations.

· Mine-water regulations (Government Notice (GN) No. R. 704) are aimed at ensuring the protection of water resources through restrictions on locality, material, and the design, construction, maintenance and operation of separate clean and dirty water systems. Detailed regulations on the use of water for mine-related activities were issued in 1999 under the National Water Act framework.

· Liability for any environmental damage, pollution, or ecological degradation: arising from any and all mining-related activities occurring inside or outside the area to which the permission/right/permit relates is the responsibility of the rights holder. This liability continues until such time as a closure certificate is issued by the Minister of Mineral Resources. Company directors or members of a close corporation are jointly and individually liable for any unacceptable impact on the environment, regardless of whether it was caused intentionally or through negligence. The National Water Act and NEMA both oblige any person to take all reasonable measures to prevent pollution or degradation from occurring, continuing or reoccurring (polluter pays principle). Where a person/company fails to take such measures, a relevant authority may direct specific measures to be taken and, failing that, may carry out such measures and recover costs from the person responsible.

· Public participation: Public consultation and participation processes prior to granting licences or authorisations can be an effective way of ensuring that the range of ways in which mining’s impact on the environment, social and economic conditions are addressed, and taken into account when the administrative discretion to grant or refuse the licence is made. Further, under Section 10 of the MPRDA, which requires that interested and affected parties be made aware that an application has been accepted and are given 30 days to submit comments, any objections should initiate the establishment of a Regional Mining Development and Environmental Committee (RMDEC).

· Provincial legislation, such as the Land Use Planning Ordinance (No. 15 of 1985) (LUPO) the Orange Free State’s Townships Ordinance (No. 9 of 1969), and the Transvaal Province’s Town-Planning and Townships Ordinance (No. 15 of 1986) which applies in Gauteng, Limpopo and Mpumalanga: to regulate land use and to provide for matters incidental thereto. Zoning schemes may have implications for mining and mining associated activities. Where mining is not permitted within a zoning scheme, the holder of a mining right or permit will need to apply for these areas to be rezoned in order to allow mining.

· National Heritage Resources Act (No. 25 of 1999): describes the importance of heritage in the South African context, and designates the South African Heritage Resource Agency (SAHRA) as guardian of the national estate which may include heritage resources of cultural significance that link to biodiversity, such as places to which oral traditions are attached or which are associated with living heritage, historical settlements, landscapes and natural features of cultural significance, archaeological and paleontological sites, graves and burial grounds, or movable objects associated with living heritage. Further, formal protections under the Natural Heritage Resources Act include: national heritage sites and provincial heritage sites (some recognized globally under the World Heritage Convention), and protected areas amongst others.

A detailed list of Biodiversity and mining related legislation includes the following:

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

· National Environmental Management Act (No. 107 of 1998), as amended 2008

· National Environmental Management Biodiversity Act (No. 10 of 2004)

· National Environmental Management Protected Areas Act (No. 57 of 2003)

· National Environmental Management Waste Act (No. 59 of 2008)

· National Environmental Management EIA Regulations (GN No. R. 543) and Listing Notices 1,2 and 3 (GN No. 544, 545 and 546 respectively)

· National Forest Act (No. 84 of 1998)

· National Veld and Forest Fire Act (No. 101 of 1998)

· Mountain Catchment Act (No. 63 of 1970)

· National Water Act (No. 36 of 1998)

· Mine-water regulations (GN No. R. 704)

· Promotion of Administrative Justice Act (No. 3 of 2000)

· Promotion of Access to Information Act (No. 2 of 2000)

· Land Use Planning Ordinance (No. 15 of 1985)

· National Heritage Resources Act (No. 25 of 1999)

· World Heritage Convention Act (No. 49 of 1999)

· Municipal Systems Act (No. 32 of 2000)

· Integrated Coastal Management Act (No. 24 of 2008)

· Marine Living Resources Act (No. 18 of 1998)

· Conservation of Agricultural Resources Act (CARA; No 43 of 1983) (as amended 2001)

1.2 NEMA principles of particular relevance to biodiversity:

· Section 2(4)(a)(i): the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied.

· Section 2(4)(a)(ii): pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied.

· Section 2(4)(a)(vi): the development, use and exploitation of renewable resources and the ecosystems of which they are part do not exceed the level beyond which their integrity is jeopardised.

· Section 2(4)(a)(vii): a risk-averse and cautious approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions.

· Section 2(4)(e): responsibility for the environmental health and safety consequences of a policy, programme, project, product, process, service or activity exists throughout its life cycle.

· Section 2(4)(o): The environment is held in public trust for the people, the beneficial use of environmental resources must serve the public interest and the environment must be protected as the people's common heritage.

· Section 2(4)(p): The costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment.

· Section 2(4)(r): Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal habitats including dunes, beaches and estuaries, reefs, wetlands, and similar ecosystems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

1.3 Responsibilities of Role Players

1.3.1 Developer

The Developer (DRPW) remains ultimately responsible for ensuring that the development is implemented according to the requirements of the EMP. The developer is responsible for ensuring that sufficient resources (time, financial, human, equipment, etc0 are available to the other role players (e.g. the ECO, CLO and contractor) to efficiently and effectively perform their tasks in terms of the EMP. The Developer is liable for restoring the environment in the event of negligence leading to damage to the environment. The developer shall endure that the EMP is included in the tender documentation so that the contractor who is appointed is bound to the conditions of the EMP. The developer is responsible for appointing an Environmental Control Officer (ECO) to oversee all the environmental aspects relating to the development.

1.3.2 Consulting Engineer

The Consulting Engineer, is bound to the EMP conditions through his/her contract with the developer, and is responsible for ensuring the she/he adheres to all the conditions of the EMP. The Consulting Engineer shall thoroughly familiarise him/her-self with the EMP requirements before coming onto site and shall request clarification on any aspects of these documents, should they be unclear.

1.3.3 Contractor

The Contractor, as the developer’s agent on site, is bound to the EMP conditions through his/her contract to the developer, and is responsible for ensuring that she/he adheres to all the conditions of the EMP. The Contractor shall thoroughly familiarise him/her-self with the EMP requirements before coming onto site and shall request clarification on any aspects of these documents, should they be unclear. The contractor shall ensure that he/she has provided sufficient budget for complying with all EMP conditions at the tender stage. The Contractor shall comply with all orders (whether verbal or written) given by the ECO/Contract Engineer in terms of the EMP.

1.3.4 Environmental Control Officer

The ECO is appointed by the developer as an independent monitor of the implementation of the EMP. He/she shall form part of the project team and shall be involved in all aspects of project planning that can influence environmental conditions on the site. The ECO shall attend relevant project meetings, conduct inspections to assess compliance with the EMP and be responsible for providing feedback on potential environmental problems associated with the development. In addition, the ECO is responsible for:

Liaison with relevant authorities;
Liaison with contractors regarding environmental management;
Undertaking routine monitoring and appointing a competent person/institution to be responsible for specialist monitoring, if necessary;
The ECO has the right to enter the site and undertake monitoring, auditing and assessment at any time, with the agreement of the Contractor, which agreement shall not be unreasonably withheld.

1.3.5 Environmental Liaison Officer

The contractor shall appoint an Environmental Liaison Officer (ELO) to assist with the day-to-day monitoring of activities on site. Any issue raised by the ECO shall be routed to the ELO for the contractor’s attention. The ELO shall be permanently on site during the construction phase to ensure daily environmental compliance. With the EMP and shall be ideally a senior member of the contractors management team. The ELO shall be responsible for ensuring that all staff members are adequately trained and aware of the EMP. The ELO shall be responsible for undertaking weekly environmental inspections and accompany the ECO during site visits, audits or assessments.

1.4 Approach

This report incorporates all the information required by the Department of Minerals and Petroleum Resources Development regulations for Environmental Management Plans, namely:

A description of the environment likely to be affected by the proposed prospecting or mining operation.

• Assessment of the potential impacts of the proposed prospecting or mining operation on the environment, socio- economic conditions and cultural heritage.

• Summary of the assessment of the significance of the potential impacts and the proposed mitigation measures to minimize adverse impacts.

• Planned monitoring and performance assessment of the environmental management plan.

• Closure and environmental objectives.

• Record of the public participation and the results thereof.

• Environmental awareness plan.

• Proof of financial provision.

• Capacity to rehabilitate and manage negative impacts on the environment.

• Undertaking to execute the environmental management plan.

1.5 Limitations

EAS has prepared this report for the sole use of the Department of Roads and Public Works (DRPW) in accordance with generally accepted consulting practices and for the intended purposes as stated in the agreement under which this work was completed. This report may not be relied upon by any other party without the explicit written agreement of the Department of Roads and Public Works and EAS. No other warranty, expressed or implied, is made as to the professional advice included in this report.

The conclusions and recommendations contained in this report are based upon information provided by others and the assumption that all relevant information has been provided by those bodies from whom it has been requested. Where field investigations have been carried out, they have been restricted to a level of detail required to achieve the stated objective of the work.

All items listed in EAS Standard Terms and Conditions of Business are applicable to this report.

This report was compiled from information obtained from the following sources:

Numerous site visits and assessments.

• Public participation

• Information on the biophysical environment (Mr Jamie Pote)

• Geotechnical Testing of Borrow Pit material (Outeniqua Lab EC cc.)

1.6 Applicant and Consultant Details

Table 1: Details of Applicant

ITEM	APPLICANT CONTACT DETAILS
Name	Eastern Cape Department of Roads & Public Works
Tel No:	(040) 602 4000
Fax No:	(040) 602 4001
Call centre:	0800 864 951
Postal Address	Private Bag X0022, Bhisho, 5605

Table 2: Details of Consultant

ITEM	CONSULTANT CONTACT DETAILS
Name	Engineering Advice & Services (Pty) Ltd
Tel No:	041 581 2421
Fax No:	086 683 9899
Cellular No:	082 850 9440
E-mail Address:	jamiep@easpe.co.za
Postal Address	P.O. BOX 13867, Humewood, Port Elizabeth, 6013

1.7 Report Structure

This report is divided into 9 chapters:

Chapter 1:

Consists of the project introduction, background and Regional Context of the mining application and the area in which the Borrow Pits are located.

Chapter 2:

Specific Information relating to the individual Borrow Pits, grouped per borrow pit, addressing the following sections of the MPRDA:

· REGULATION 52 (2): Description of the environment likely to be affected by the proposed prospecting or mining operation

a) The environment on site relative to the environment in the surrounding area.

b) The specific environmental features on the site applied for which may require protection, remediation, management or avoidance.

c) Map showing the spatial locality of all environmental, cultural/heritage and current land use features identified on site.

d) Confirmation that the description of the environment has been compiled with the participation of the community, the landowner and interested and affected parties,

Chapter 3:

· REGULATION 52 (2) (b): Assessment of the potential impacts of the proposed prospecting or mining operation on the environment, socio- economic conditions and cultural heritage.

a) Description of the proposed prospecting or mining operation.

i. The main prospecting activities (e.g. access roads, topsoil storage sites and any other basic prospecting design features )

ii. Plan of the main activities with dimensions

iii. Description of construction, operational, and decommissioning phases.

iv. Listed activities (in terms of the NEMA EIA regulations)

b) Identification of potential impacts (Refer to the guideline)

c) Potential impacts per activity and listed activities.

i. Potential cumulative impacts.

ii. Potential impact on heritage resources

iii. Potential impacts on communities, individuals or competing land uses in close proximity. (If no such impacts are identified this must be specifically stated together with a clear explanation why this is not the case.)

iv. Confirmation that the list of potential impacts has been compiled with the participation of the landowner and interested and affected parties,

v. Confirmation of specialist report appended (Refer to guideline)

· REGULATION 52 (2) (c): Summary of the assessment of the significance of the potential impacts and the proposed mitigation measures to minimise adverse impacts.

a) Assessment of the significance of the potential impacts

i. Criteria of assigning significance to potential impacts

ii. Potential impact of each main activity in each phase, and corresponding significance assessment

iii. Assessment of potential cumulative impacts.

Chapter 4:

3. REGULATION 52 (2) (c): Summary of the assessment of the significance of the potential impacts and the proposed mitigation measures to minimise adverse impacts.

a) Proposed mitigation measures to minimise adverse impacts.

i. List of actions, activities, or processes that have sufficiently significant impacts to require mitigation.

ii. Concomitant list of appropriate technical or management options (Chosen to modify, remedy, control or stop any action, activity, or process which will cause significant impacts on the environment, socio-economic conditions and historical and cultural aspects as identified. Attach detail of each technical or management option as appendices)

iii. Review the significance of the identified impacts (After bringing the proposed mitigation measures into consideration).

Chapter 5:

4. REGULATION 52 (2) (e): Planned monitoring and performance assessment of the environmental management plan.

a) List of identified impacts requiring monitoring programmes.

b) Functional requirements for monitoring programmes.

c) Roles and responsibilities for the execution of monitoring programmes.

d) Committed time frames for monitoring and reporting.

5. REGULATION 52 (2) (f): Closure and environmental objectives.

a) Rehabilitation plan (Show the areas and aerial extent of the main prospecting activities, including the anticipated prospected area at the time of closure).

b) Closure objectives and their extent of alignment to the pre-mining environment.

c) Confirmation of consultation (Confirm specifically that the environmental objectives in relation to closure have been consulted with landowner and interested and affected parties).

Chapter 6:

6. REGULATION 52 (2) (g): Record of the public participation and the results thereof.

a) Identification of interested and affected parties. (Provide the information referred to in the guideline)

b) The details of the engagement process.

i. Description of the information provided to the community, landowners, and interested and affected parties.

ii. List of which parties identified in 7.1 above that were in fact consulted, and which were not consulted.

iii. List of views raised by consulted parties regarding the existing cultural, socio-economic or biophysical environment.

iv. List of views raised by consulted parties on how their existing cultural, socio-economic or biophysical environment potentially will be impacted on by the proposed prospecting or mining operation.

v. Other concerns raised by the aforesaid parties.

vi. Confirmation that minutes and records of the consultations are appended.

vii. Information regarding objections received.

c) The manner in which the issues raised were addressed.

Chapter 7

7. SECTION 39 (3) (c ) of the Act: Environmental awareness plan.

a) Employee communication process (Describe how the applicant intends to inform his or her employees of any environmental risk which may result from their work).

b) Description of solutions to risks (Describe the manner in which the risk must be dealt with in order to avoid pollution or degradation of the environment)t.

c) Environmental awareness training (Describe the general environmental awareness training and training on dealing with emergency situations and remediation measures for such emergencies).

Chapter 8:

8. REGULATION 52 (2) (d): Financial provision. The applicant is required to-

a) Plans for quantum calculation purposes (Show the location and aerial extent of the aforesaid main mining actions, activities, or processes, for each of the construction operational and closure phases of the operation).

b) Alignment of rehabilitation with the closure objectives (Describe and ensure that the rehabilitation plan is compatible with the closure objectives determined in accordance with the baseline study as prescribed).

c) Quantum calculations (Provide a calculation of the quantum of the financial provision required to manage and rehabilitate the environment, in accordance with the guideline prescribed in terms of regulation 54 (1) in respect of each of the phases referred to).

d) Undertaking to provide financial provision (Indicate that the required amount will be provided should the right be granted).

Chapter 9

9. SECTION 39 (4) (a) (iii) of the Act: Capacity to rehabilitate and manage negative impacts on the environment.

a) The annual amount required to manage and rehabilitate the environment (Provide a detailed explanation as to how the amount was derived)

b) Confirmation that the stated amount correctly reflected in the Prospecting Work Programme as required

10. REGULATION 52 (2) (h): Undertaking to execute the environmental management plan.

2 Proposed Project Description

2.1 Motivation

Existing gravel roads subject to the proposed project in the Tsolwana Local Municipality have been identified by the department of Roads and Public Works as being in need of maintenance and re-gravelling. The specific roads in the abovementioned Local Municipal Areas is the MR00638 (R344).

Gravel roads weather over relatively short periods of time and require periodical re-gravelling. The gravel roads identified for re-gravelling display defects such as corrugation, ravelling, and exposed oversized stones. The roads to be re-gravelled provide access to remote villages and the poor quality of the roads have a significant impact on the lives of the local residents as alternative routes to nearby towns are often too far to travel and add extra costs to travel for individuals.

In order to re-gravel the specified roads, large amounts of material is deeded for mostly the wearing course of the road. In some cases the material is of such a nature that is can be grid rolled to the appropriate size, and in others the material would be crushed due to the physical properties of the material. Quality control of material would include blending harder materials with fines to obtain an optimal material quality. The extensions of existing borrow pits for the collection of materials for the specified roads is being proposed.

2.2 Activity Description

After a preliminary screening of borrow pits along the MR00638 road 5 borrow pits were selected subject to criteria including material type, location, access, surrounding land use, slope, erosion, hydrology and overall sensitivity. Five sites were selected along the MR00638 road. The borrow pits will be used exclusively for the upgrade/re-gravelling of the road they are situated adjacent to.

If approved, this EMP will be used as guidelines for the excavation of material from the proposed borrow pits and the rehabilitation thereof.

2.3 Activity Location

The locations of all the proposed borrow pits and the road section they are to be used for are shown in figure 1. The affected roads are situated north of Tarkastad along the MR00638.

2.4 Borrow Pit Locations

Table 3: Locality of proposed borrow pits.

Road	BP	Coordinates	LMA	Comment
DR02581	11.1	31.91967 S 26.30005 E	Tsolwana

	16.7	31.87199 S 26.28068 E	Tsolwana

	22.4	31.82505 S 26.26876 E	Tsolwana

	29.8	31.74533 S 26.26727 E	Tsolwana

	33.4	31.73713 S 26.3306 E	Tsolwana

2.5 Description of the Existing Environment

2.5.1 Introduction

A screening of Regional Biodiversity Features was undertaken, based on a model developed that included the following features:

· Protected areas

· World Heritage Sites and their legally proclaimed buffers

· Critically Endangered and Endangered ecosystems

· Critical Biodiversity Areas

· River and wetland Freshwater Ecosystem Priority Areas (FEPAs), and

· 100 m Buffer of rivers and wetlands

· RAMSAR Sites

· Protected area buffers

· Trans-frontier Conservation Areas (remaining areas outside of formally proclaimed PAs)

· High water yield areas

· Coastal Protection Zone

· Estuarine functional zones

· Ecological support areas

· Vulnerable ecosystems

· Focus areas for land-based protected area expansion and focus areas.

A summary of these features (illustrated in Figure 4 to Figure 6) is provided in Table 4 below.

Table 4: Summary of Biodiversity features for the Borrow Pit sites.

Borrow Pit	Vegetation Type:	Status	Present land use:	CBA
11.1	Queenstown Thornveld	Least Threatened	Natural/Grazing
16.7	Queenstown Thornveld	Least Threatened	Natural/Grazing
22.4	Queenstown Thornveld	Least Threatened	Natural/Grazing	CBA 2
29.8	Queenstown Thornveld	Least Threatened	Natural/Grazing	CBA 2
33.4	Queenstown Thornveld	Least Threatened	Natural/Grazing	CBA 2

2.5.2 Site Locality

The locations of all the proposed borrow pits and the road sections they are to be used for are shown in Social and economic environment

The Borrow Pits will be utilised for routine maintenance of gravel roads in the area. These roads connect the villages and urban areas, thus if they are not maintained there will be a negative impact on the people, their health (safety) and their livelihoods. Furthermore vehicular ‘wear and tear’ results in higher living costs. Formalisation of the Borrow Pits will allow for regular routine maintenance of the roads that will benefit not only local communities and residents but also all road users.

No people will be directly affected by the proposed mining of Borrow Pits, but there may be a temporary noise and dust increase on nearby residents. Potential Impacts will be assessed on an individual Borrow Pit basis in the following sections.

2.5.3 Health and Safety

There are certain risks posed to human health and safety via exposure to high noise and dust levels, as well as steep and/or unstable faces formed during mining activities. Pools of standing water can also pose a risk to livestock and people in rural areas. Community health and safety risks should be controlled through the implementation of a Health and Safety Management Plan to be implemented by the Contractor. Existing unsafe excavations (with vertical faces) and deep excavations where standing water can accumulate should be “made safe” on closure using unused and stockpiled overburden and topsoil.

2.6 Maps

Figure 1. The affected roads are situated South-East of Cala and North-West of Engcobo. Queenstown is located 140 km West of Engcobo and 100 km south-west of Cala (Sakhisizwe).

2.6.1 Topography

The surrounding area can generally be described as flat or gentle undulating lowland plains intersected by moderately rolling hills and mountains, much incised by river gorges. Drainage of the region is mainly in a southerly direction.

2.6.2 Geology and soils

As per the Geological Map in Figure 2, the Geology in the region consists of the following:

Symbol	Lithology	Formation
Jd	Volcanic Rocks, gabbro, pikriet	Karroo sequence, Drakensberg Group
Jdb	Volcanic Rocks, Basaltic Lava, subordinate tuff and agglomerate	Drakensberg Group
TRm	Volcanic Rocks, Basaltic Lava, subordinate tuff and agglomerate	Karroo sequence, Drakensberg Group, Molteno Formation
TRb	Brownish Red and grey mudstone, sandstone (Sedimentary)	Karroo sequence, Beaufort Group, Tarkastad subgroup, Burgersdorp Formation
TRe	Brownish-red and grey mudstones, sandstone	Drakensberg Group, Elliot Formation
Alluvium	Alluvium

The study area is underlain mostly by sedimentary rocks of the Early Triassic Period Karoo Supergroup, which was formed under fluvial conditions when the inland Karoo Sea was drying out and wide plains were being carved by large river systems. These rivers deposited the sands and muds on broad flood plains which over time became interbedded sandstone and mudstone of the Katberg and Burgersdorp Formations (both of the Tarkastad Subgroup, Karoo Supergroup).

The Katberg Formation has been mapped in the southern and south-western part of the site and is dominated by sandstone lithologies formed by multi-channelled braided river environments. The braided river system resulted in the development of a deeply eroded landscape with few fine-grained (mud and silt) overbank deposits developing. This formation therefore consists mainly of sandstone with sub-ordinate argillaceous (rock containing clay) maroon-coloured mudstone.

A return to a meandering river system is reflected in the mudstone-dominated strata of the Burgersdorp Formation, which has been mapped in the eastern and north-eastern parts of the study area. This formation is dominated by maroon, grey and olive-coloured mudstone and is considered a distal equivalent to that of the Katberg Formation.

These Beaufort Group rocks are interrupted by doleritic dykes (vertical intrusion) and sills (horizontal intrusion) formed during the Jurassic Period. These intrusions forced their way between the sedimentary strata during the eruption phases that formed the Drakensberg Group basalts. The sedimentary rocks into which the dolerite intruded are often altered (metamorphosed) in aureoles adjacent to intrusions (e.g. Hornfels). The dolerite has a regional north-south trend around which the Sabalele Road has been constructed. This material is, therefore, likely to be intersected in outcrop in the southern part of the study area.

Geotechnical Interpretation

The Karoo Supergroup rocks generally reveal a subdued topography in the study area with a variable weathering profile. The sandstone lithologies tend to be more weathering resistant and are blanketed by a thinner soil cover than that of the softer, mudstone rocks. The completely weathered rock/ residual soil interface is commonly susceptible to dispersion and piping erosion, resulting in the development of the characteristic donga-marked landscape where sloping ground prevails.

The sandstone lithologies have a rock strength that is often considered too low for use as base course or sub base, yet it is too high (and has little binding capabilities) for use as a crushed wearing course on unsurfaced roads. This material is likely to require crushing for any aggregate application. The mudstone rocks also have a rock strength that is considered too low for use as base course or sub base. The rock is, however, often a preferred material for gravel wearing course applications, and breaks down easily on the roadway during mechanical placement. Most of the Karoo Supergroup rocks are considered suitable for select subgrade applications.

The intrusive dolerites can be highly variable in terms of rock strengths and weathering profiles. The geotechnical properties of these rocks are often affected by the cooling rates of the magma when they were formed; slow cooling magma forms larger crystals that develop into high strength rocks, whilst quickly cooling magma forms smaller crystals that can eventuate into low strength rocks. The dolerite also displays a weathering profile that can be deep (tens of metres) and dominated by fresh rock core stones of variable sizes, or shallow weathering with soil cover often less than one metre underlain by competent rock without core stones. The weathering profiles and rock strengths of dolerite are not easily ascertainable based on surface outcrop. It is common, nevertheless, for the dolerite outcrop to reveal a positively weathered landform in the study area, frequently associated with a very different vegetation cover to that of the surrounding Karoo Supergroup rocks.

The extremely weathered dolerite reveals a deep red-coloured soil cover often pock-marked with sub-rounded and well-rounded dolerite core stones. These weathered soils are often highly dispersive and erosion scours are common in areas where positive relief is not offered adequate protection from vegetation cover. Doleritic soil is frequently highly expansive and considered unsuitable for any road construction application. The materials’ construction suitability improves with depth as the highly weathered rock (Sabunga) is considered suitable for gravel wearing course use in arid environments, whilst the moderately weathered, slightly weathered and fresh rock is a well-documented source of good sub base and base course.

2.6.3 Hydrology (Ground and surface water)

The drainage of the area generally flows in a south-easterly direction (Figure 3). The Klaas Smits and Swart Kei Rivers are the main drainage systems. The minor seasonal streams in the surrounding area in proximity to the Borrow Pits are tributaries of these rivers. Where Borrow Pits are in the vicinity of drainage lines and rivers, stormwater and runoff will need to be adequately managed to prevent increased turbidity of downstream river systems. With the proper implementation of the EMP it likely that any existing impacts that are currently present will be reduced. Rivers area indicated on the close-up maps of the individual Borrow Pit descriptions.

Some wetlands (Natural and artificial) may be in proximity to seasonal wetlands. As for drainage lines above, runoff will need to be managed and will be dealt with in Borrow Pit descriptions accordingly. After rehabilitation of the Borrow Pits, some areas will probably be natural accumulation areas for runoff from surrounding areas and become small dams or artificial wetlands in the long-term.

Groundwater resources could potentially be affected by the mining of Borrow pits due to inadvertent fuel and chemical spills. If the management measure prescribed below are adhered to it is not anticipated that groundwater resources would be significantly affected by the Borrow Pits.

2.6.4 Climate

The area is a predominantly summer rainfall area. The mean annual rainfall for Encobo (809.9 mm), decreasing westwards. Mean annual temperatures in the Engcobo area is 16.7°C

2.6.5 Air quality

Air quality levels in rural areas surrounding the Borrow Pit sites are typically good. The gravel roads are however a source of dust, especially during dry windy conditions. Air quality may be temporarily affected by the mining and concomitant road surfacing operations during the routine maintenance periods.

2.6.6 Noise

The Borrow pit sites are generally situated relatively close to provincial gravel roads, which are an existing source of noise. The current ambient noise levels are assumed to be relatively high due to road traffic. Noise receptors during mining operations would typically be residents in the villages nearest to the sites.

2.6.7 Paleontological resources

The Beaufort Group is Late Permian (255 million years) to Mid Triassic (237 million years) in age. Characteristic fossils include fish, amphibians and reptiles with a dominance of mammal-like reptiles (Theraptids). In addition, characteristic fossils include plant fossils of the Glossopteris flora with occasional invertebrate fossils (freshwater bivalve molluscs). Most of the fossil specimens represent groups that are now extinct. It is estimated that less than 5 % of sites have been identified in the Eastern Cape. There is a lack of identified sites in the District.

An internationally important record of life during the early diversification of land vertebrate is provided by the floodplain of the Beaufort Group (Karoo Supergroup). Giant amphibian coexisted with diapsid reptiles (the ancestors of dinosaurs, birds and most modern reptiles), anapsids (which probably include the ancestors of tortoises) and synapsids, the dominant of the group of the time which included the diverse therapsids (including the ancestors of mammals). The rocks provide the world’s most complete record of the important transition from early reptiles to mammals.

Most plant and animals were decimated during the end-Permian extinction event with Therapsid diversity being a serious contender for the most severe extinction event to affect life on Earth. Ongoing research on the effects of this extinction event is facilitated by the detailed record (afforded by the Beaufort Group strata) of life immediately before and after the event, as well as the gradual recovery of life afterwards.

The Beaufort Group is subdivided into a series of biostratigraphic units on the basis of its faunal content. There is a marked faunal change that occurs between the Dicynodon and Lystrosaurus Assemblage Zones and approaches the tops of the Balfour Formation. This corresponds with the major extinction event associated with the Perno-triassic boundary. The Lustrosaurus Assemblage Zone spans the uppermost (Palingkloof) member of the Balfour Formation, the Katberg Formation (Tarkastad Subgroup, Beaufort Group, Karoo Supergroup) and the lower part of the Burgersdorp Formation (Tarkastad Subgroup, Beaufort Group, Karoo Supergroup).

The Lystrosaurus Assemblage Zone is dominated by a single genus of dicynodont, Lyystrosaurus, which together with the captorhinid reptile (Procolophon) characterise this zone. Biarmosuchian and gorgonopsian Therapside do not survive into the Lystrosaurus Assemblage Zone, though therocephalian and cyndontian Therapside exhibit moderate abundance. Captohinid Reptilia are reduced, however, an unprecedented diversity of giant amphibian characterises this interval.

The effect of the end Permian extinction event are also evident in the extensive and important record of fossil plants present in the rocks of the Karoo. Whereas faunas of the Pemian age are dominated by a wide range of early seed plants, the Glossopteridale (which probably include the ancestors of modern gymnosperms and ultimately angiosperms), this group appears to have gone entirely extict during the end-Permian extinction. The rocks of the Karoo provide an unrivalled sequential record of these change and the diversification of other group of plants in the aftermath of the extinction. The strata of the Karoo basin have also yielded fossils insects and insect leaf damage of a range of ages.

Though including the uppermost level of the Lystrosaurus Assemblage Zone, the Burgersdorp Formation largely corresponds to the Cynognathus Assemblage Zone. Synapsid therapsid diversity does not demonstrate recovery between the Lystrosaurus and Cynognathus assemblage zones. The Dicynodontia, Lystrosaurus and Myosaurus are replance by Kombuisia and the giant Kannemeyeria. Therocephalia exhibit a turnover of taxa at a generic level, but an overall reduction in diversity. Cynodontia (Therapsida, Synasida) alone amongst synapsids demonstrate a slight increase in genera. These include the small advance Cynodont, Cynognathus, which together with the Cynodont Diademodon and the Dicynodont Kannemeyeria, characterise this assemblage zone. Eosuchid and captorhinid Reptilia are moderately common, though showing no generic continuity with taxa of the underlying zone. Amphibia remain diverse, though they are not as generically diverse as in the Lystosaurus Assemblage Zone and likewise demonstrate no genus level continuity therewith. Fossil fish reach their greatest known Karoo Supergroup diversity in the Burgersdorp Formation (Cynognathus Assemblage Zone). Plants (Dadoxylon, Dicroidium and Schizoneura), trace fossils (including both vertebrate and invertebrate burrows) and a freshwater bivalve (Unio karooensis) have also been recovered.

As Dolerite is an intrusive igneous rock, it contains no fossils.

2.6.8 Archaeological resources

Archaeological remains can consist of the following:

1. Human remains (graves, informal graves and cemeteries)

2. Stone artefacts and tools

3. Large Stone Features (Isisivane and circular stone walls)

4. Freshwater shell middens

5. Historical artefacts and features

6. Fossil Bone

1 Human Remains

Any, and all, human remains that are exposed during all phases of construction must be reported to the archaeologist, nearest museum or relevant heritage resources authority. Construction must then be halted until the archaeologist has investigated and removed the human remains. Human remains may be exposed when a grace or informal burial has been disturbed. Remains are either buried in a flexed position on the side, or in a sitting position with a flat stone capping the location of the burial. Developer are requested to be aware of the exposing human remains.

2 Stone Artefacts

Stone artefacts can be difficult for the layman to identify. Large accumulations of flaked stones that do not appear to have been distributed naturally must be reported. If the stone artefacts are associated with bone / faunal remains or any other associated organic and material cultural artefacts, development must be halted immediately and reported to the archaeologist, nearest museum or relevant heritage resources authority.

3 Large Stone Features

Even though large stone features occur in different forms and sizes, they are relatively easy to identify. The most common features are roughly circular walls (most collapsed), usually dry packed stone, and may represent: stock enclosures, the remains of wind breaks or cooking shelters. Other features consist of large piles of stones of different sizes and height that are known as isisivane. These features generally occur near river and mountain crossings. The purpose and meaning of the isisivane are not fully understood, however, interpretations include the representation of burial cairns and symbolic value.

4 Freshwater Shell Middens

Accumulations of freshwater shell middens comprising mainly freshwater mussel occur along the muddy banks of rivers and streams and were collected by pre-colonial communities as a food resource. The freshwater shell middens generally contain; stone artefacts, pottery, bone and (sometimes) human remains. Freshwater shell middens may be of various sizes and depths. An accumulation that exceeds 1 m² in extent must be report to the archaeologist, nearest museum or relevant heritage resources authority.

5 Historical Artefact and Features

These are relatively easy to identify and include the foundations and remain of buildings, packed dry stone walling representing domestic stock kraals. Other items include historical domestic artefacts such as: ceramics, glass, metal and military artefacts and dwellings.

6 Fossil Bones

Fossil bones may be embedded in geological deposits. Any concentrations of bone (whether fossilized of not) must be reported to the archaeologist, nearest museum or relevant heritage resources authority.

2.6.9 Land Use

As indicated in Figure 6 the Borrow Pits are predominantly located within or adjacent to areas classified as Degraded, Cultivated and in some cases (Peri) Urban as per the SANBI Land Cover (2009) map.

2.6.10 Erosion Potential

The erosion potential of soils is the sensitivity of soils to the effects of wind and water on the soil structure. The erodability index is determined by combining the effects of slope and soil type, rainfall intensity and land use. A low value indicates a high erosion risk and a high value indicates a low erosion risk. The area falls within an erodability index of between 7 and 9, indicating that the area has a moderate to high susceptibility to erosion. Adequate measures must thus be implemented to minimise erosion.

2.6.11 Vegetation of Southern Africa

At a regional level, a single vegetation types are recognised within the immediate vicinity of the borrow pit sites (Mucina & Rutherford, 2006), which is namely Queenstown Thornveld (Figure 4), having a conservation status of Least Threatened (Mucina & Rutherford, 2006).

Queenstown Thornveld

Distribution ranges within the Eastern Cape from Tarkastad to Queenstown. Typical species include: Acacia karroo thornveld dominated by Aristida congesta, Cymbopogon pospischilii, Eragrostis curvula and Tragus koelerioides grasses, with scattered shrubs in places.

Present on flat bottomlands of intramontane basis with adjacent slopes. Rainfall is typically in late summer (peak in Feb – March) with MAP 280 – 720 mm p.a.

The geology is dominated by sedimentary rocks of the Tarkastad Subgroup (Beaufort Group, Karoo Supergroup), overlain with clay-loam soils typical of the Da and Fc land types.

Conservation: Least threatened. Target 23 %. Around 1 % statutorily conserved in the Tsolwana Nature Reserve. About 10 % is transformed with overgrazing and urban expansion important factors.

2.6.12 Eastern Cape Biodiversity Conservation Plan (ECBCP)

Critical biodiversity areas (CBAs) are terrestrial and aquatic features in the landscape that are critical for conserving biodiversity and maintaining ecosystem functioning (SANBI 2007). These form the key output of the conservation plan. They are used to guide protected area selection and should remain in their natural state as far as possible.

As indicated in Figure 5, the Eastern Cape Biodiversity Conservation Plan (ECBCP, 2007) the Borrow Pits are situated in areas designated a CBA 2 or no status (terrestrial). Due to the limited size of these Borrow Pits, their effect on Critical Biodiversity Areas will be minimal. Individual Borrow Pits that are within CBA 2 areas will be highlighted and appropriate measures recommended in the Impact and Mitigation sections of the report where specific measures are necessary.

No Borrow Pits are located within designated Reserves (class 1 and class 2) none are within aquatic CBA’s.

2.6.13 Implications of Regional Planning frameworks

The expansion of the borrow pits is unlikely to compromise the vegetation units significantly due to:

· The small mining footprint.

· The generally degraded state of the existing borrow pits and immediate vicinity.

· The general close proximity to the road reserves.

· The implementation of a formalized rehabilitation plan.

Loss of vegetation cover will thus tend to be highly localised and have a minimal impact (individual and cumulative) at a regional level. Furthermore it will most likely result in an overall improvement of the ecological integrity of existing sites that currently tend to be in a highly degraded state, as a result of inadequate historical remediation methods.

The impact of the expansion of existing Borrow Pits, generally located directly adjacent to roads in areas that are generally degraded is unlikely to have any significant negative impact on ecological processes occurring at a regional level. The implementation of best practice guidelines (as per the EMP) will most likely be effective management to minimise any negative consequences to being located within Critical Biodiversity Areas. In addition, since the existing Borrow Pits are currently inadequately managed, the implementation of the recommended management actions in the EMP will most likely result in an improvement to the status quo.

Any Borrow Pits that are significantly affected by the Regional Planning Frameworks will be dealt with accordingly in their relative Impact and Mitigation sections.

2.6.14 Species of Special Concern occurring in the region

Based on a desktop Assessment of existing online databases as well as field verification, the potential list of flora and fauna species that may occur in the vicinity of the Borrow Pits, is quite extensive. Common flora species such as: Aloe arborescens, Aloe ferox, Aloe maculata, Bulbine abyssinica and Boophone disticha, are common around some of the sites.

The Giant Bull Frog, may be present in wetlands, but are unlikely to be affected by the Borrow Pits, which will not likely impact on any wetlands.

Appendix E provides a detailed list of species protected in term of the P.N.C.O., for which permits may be required should they occur. However limited field assessments indicate that the majority of these species are unlikely to be present. Due to limited sampling time, Presence or absence cannot be confirmed without detailed seasonal site visits, but the risk of any Critically Endangered or Endangered species being present is Low. The limited expansion of the Borrow Pits is thus unlikely to result in any significant impact to species conservation.

No Red Listed Critically Endangered or Endangered species are recorded for the area.

Table 5: Species of Special Concern known to occur in the vicinity of the sites.

Scientific Name	Family	Common name	Status	Endemic
Flora
Albuca setosa	HYACINTHACEAE		PNCO
Aloe arborescens	ASPHODELACEAE		PNCO
Aloe ferox	ASPHODELACEAE		PNCO
Aloe maculata	ASPHODELACEAE		PNCO
Aristea anceps	IRIDACEAE		PNCO
Bergeranthus multiceps	MESEMBRYANTHEMACEAE		PNCO
Boophone disticha	AMARYLLIDACEAE		PNCO
Brunsvigia grandiflora	AMARYLLIDACEAE		PNCO
Bulbine abyssinica	ASPHODELACEAE		PNCO
Bulbine asphodeloides	ASPHODELACEAE		PNCO
Bulbine narcissifolia	ASPHODELACEAE		PNCO
Cyrtanthus macowanii	AMARYLLIDACEAE		PNCO
Delosperma repens	MESEMBRYANTHEMACEAE		PNCO
Dierama atrum	IRIDACEAE		PNCO
Dietes iridioides	IRIDACEAE		PNCO
Drimia macrocentra	HYACINTHACEAE		PNCO
Eulophia foliosa	ORCHIDACEAE		PNCO
Gasteria excelsa	ASPHODELACEAE		PNCO
Gladiolus longicollis subsp. longicollis	IRIDACEAE		PNCO
Gladiolus mortonius	IRIDACEAE		PNCO
Haemanthus humilis subsp. humilis	AMARYLLIDACEAE		PNCO
Holothrix scopularia	ORCHIDACEAE		PNCO
Hypoxis acuminata	HYPOXIDACEAE		PNCO
Hypoxis angustifolia var. buchananii	HYPOXIDACEAE		PNCO
Ledebouria cooperi	HYACINTHACEAE		PNCO
Ledebouria revoluta	HYACINTHACEAE		PNCO
Ornithogalum longibracteatum	HYACINTHACEAE		PNCO
Ornithogalum tenuifolium subsp. tenuifolium	HYACINTHACEAE		PNCO
Ruschia putterillii	MESEMBRYANTHEMACEAE		PNCO
Satyrium longicauda var. longicauda	ORCHIDACEAE		PNCO
Satyrium parviflorum	ORCHIDACEAE		PNCO
Watsonia densiflora	IRIDACEAE		PNCO
Watsonia pillansii	IRIDACEAE		PNCO
Mammals
Myotis tricolor	VESPERTILIONIDAE	Temminck's Hairy Bat	Near Threatened
Reptiles
None
Amphibians
Pyxicephalus adspersus	PYXICEPHALIDAE	Giant Bull Frog	NT
Invertebrates
Aslauga australis (Butterfly)	LYCAENIDAE	Southern Purple	Data Deficient	Yes
Chrysoritis lyncurium (Butterfly)	LYCAENIDAE	Tsomo River Opal	Vulnerable	Yes
Chrysoritis penningtoni (Butterfly)	LYCAENIDAE	Pennington's Opal	Vulnerable	Yes
Fish
Clarias gariepinus	CLARIIDAE		NEMBA (NL)

The plant and animal species of special concern listed above require permits if any individuals are to be removed, translocated or pruned according to the relevant legislation including the National Forests Act and the Provincial Nature Conservation Ordinance as well as Threatened and Protected Species (T.o.P.S.)

2.6.15 Social and economic environment

2.6.16 Health and Safety

2.7 Maps

Figure 1: Map indicating locality of borrow pits with major roads, towns, etc.

Figure 2: Geology Map.

Figure 3: Rivers and Wetlands

Figure 4: Positioning of the Borrow Pits relative to the Vegmap (2006) vegetation types (Mucina & Rutherford, 2006).

Figure 5: Critical Biodiversity Areas, as per Eastern Cape Biodiversity Conservation Plan (ECBCP, 2007). CBA 1, 2 & 3 areas as well as Forest pockets and Expert species data are shown.

Figure 6: Land Use – excluding Natural Vegetation (SANBI Landcover, 2006) indicating Plantations, Degraded, Cultivated and Urban/Per-Urban areas.

Name	Company	Email
Mr Jamie Pote	Engineering Advice & Services (Biophysical and EMP)	jamiep@easpe.co.za
Mr Dieter Bester	Engineering Advice & Services (Geotech and Engineering)	dieterb@easpe.co.za
Mr Ray Parker	Engineering Advice & Services (Engineering and Review)	ray@easpe.co.za