3 PROJECT ALTERNATIVES

Transcription

1 3 PROJECT ALTERNATIVES In terms of the National Environmental Management Act (NEMA) Section 21(3) and Appendix 2 of the EIA Regulations (2014), due consideration must be given to project alternatives during the EIA process. The EIA Regulations (December, 2014) defines alternatives as: In relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to : (a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity (the no-go option). Section 31 (2) (g) of the EIA Regulations (2010) requires a description of feasible and reasonable alternatives to be considered in the EIA Report. In part, the purpose of the Scoping Report is to review and screen alternatives to determine reasonable and feasible alternatives that need to be assessed in further detail in the EIA Report. In terms of the EIA Regulations (2010), alternatives could include, amongst others, the following: Activity alternatives also referred to as project alternatives. This requires a change in the nature of the proposed activity. This category of alternatives is most appropriate at a strategic decision making level. This includes the no-go option. Location alternatives alternative locations for the Project, or for components of the Project proposal (i.e. on-site location alternatives). Process alternatives also referred to as technological or equipment alternatives. The purpose of considering such alternatives is to include the option of achieving the same goal by using a different method or process. Site layout alternatives site layout alternatives permit consideration of different spatial configurations of an activity on a particular site. The alternatives assessed for each of the Project components are detailed in the following sections. 3.1 MAQUASA WEST EXTENSION UNDERGROUND WORKS The majority of the extractable coal reserves in the study area are located at depths of approximately 100m below the surface. This depth along with other geotechnical considerations determines that the mining will be underground. 3-45

2 It is not economically feasible to extract coal at such depth using opencast methods. Existing infrastructure will be used to transport and beneficiate the coal and no other alternatives were considered, as these facilities are operational and available. The proposed Project is an expansion of an existing mine, which will prolong the social benefits, such as employment associated with the current mining activities. The "No Go" option will result in a loss of the social benefits but will reduce the period of existing negative environmental impacts from mining Alternative Land Use Mining of the additional reserves will have no impact on the land use of the overlying area, which will continue as grazing land Alternative Mining Method The majority of the extractable coal is located at depths of approximately 100m below the surface. This, in combination with the geotechnical considerations of the ore, has determined that mining will be by means of underground board and pillar methods. Opencast mining has not been considered as a feasible option due to the depth of the coal reserves making it uneconomic Mineral Processing Method Coal beneficiation will occur at the existing Maquasa East plant. Consequently, a processing plant at Maquasa West was not considered. 3.2 ADIT 5, OVERLAND CONVEYOR AND SERVICE ROAD The following studies have been conducted to identify alternative adit locations, adit configurations and/or overland conveyor routes: Engineering Concept Study and Pre-Feasibility Study by Hatch Goba (Pty) Ltd (Hatch) (2009); Ecological and Social Site Screening Assessment by Environmental Resources Management (Pty) Ltd (ERM) (October, 2011); and Site Screening Assessment within MR133 by Kangra Coal (Pty) Ltd. (February, 2015). The alternatives investigated and outcomes of these studies are described in the sections that follow. 3-46

3 3.2.1 Alternative Locations for the Adit to Access Underground Coal Reserves Engineering Concept Study and Pre-Feasibility Study - Hatch In 2009, Hatch undertook an engineering Concept Study to evaluate business opportunities associated with expanding or extending Kangra Coal s mining operations. Following the Concept Study, the Hatch technical team began the Pre-Feasibility Study during which time potential points (i.e. adits) to access coal reserves within Kangra Coal s existing mining (MR133) and prospecting right areas were identified. This study was based on variables such as geotechnical stability, access to the coal seam, coal quality, environmental and social sensitivities, health and safety requirements, site accessibility, etc. Table 3.1 summarises the alternatives that were assessed in this pre-feasibility study: 3-47

4 Table 3.1 Adit Location Alternatives Assessment (Hatch, 2009) Alternative Socio-environmental and Financial Advantages Socio-environmental and Financial Disadvantages Pre-feasibility Study Outcome Alternative 1 Adit at Site A The Preferred Option will have a smaller footprint (due to the length of the conveyor route) when compared to Alternative 2. The Preferred Option has lower occupational health and safety risks as compared to Alternative 3 (where all mining services take place underground). The Preferred Option has an overland conveyor, which is technically and financially more feasible than Alternatives 3 and 4. The Preferred Option is technically feasible due to geotechnical stability (roof support and ground discontinuities) and access to mineable coal. This alternative presents the most favourable conditions from a technical, mine design view with regards to the shaft site selection. This is based on the fact that at the critical point for shaft access, where the overburden thickness equals 20m above the coal seam, is satisfied. From a cultural and heritage perspective, the Preferred Option is more favourable than Alternative 2. The quality of coal is suitable unlike coal quality at Site B. Due to the thickness of the coal seam at Site A, the Preferred Option is deemed to be the most financially feasible. Alternative 2 Adit at Site B Relative to the Preferred Option and Alternatives 2 to 4, there are no social and/or ecological advantages associated with Alternative 2. Alternative 2 has lower occupational health and safety risks than Alternative 3. Alternative 2 has an overland conveyor and is thus, from a technical, engineering and financial perspective, more feasible than Alternatives 3 and 4. The main mine access road for Alternative 2 does not seem to be frequented by the public as intensely as the Preferred Option. It is not expected that public perceptions about noise, visual and dust impacts would differ between the Preferred Option and Alternative 2. It is also not possible to, at this stage, to determine with confidence whether the number of people exposed to these potential impacts would be higher for the Preferred Option or Alternative 2; however, it is estimated that less people will be exposed along the length of the conveyor belt for Alternative 2 when compared to the Preferred Option. There are more ecologically disturbed areas at Site A than at the other sites. This project option has a larger footprint than Alternatives 2, 3 and 4. Having the mine Adit at Site A triggers significant traffic related health and safety concerns (if not mitigated) due to the fact that this road is a well-used public road, carrying pedestrians, horses and vehicles. It is not expected that public perceptions about noise, visual and dust impacts would differ between the Preferred Option and Alternative 2. It is also not possible to, at this stage, determine with confidence whether the number of people exposed to these potential impacts would be higher for the Preferred Option or Alternative 2; however, it is estimated that more people will be exposed along the length of the conveyor belt for the Preferred Option when compared to Alternative 2. Due to the higher concentration of people along the length of the conveyor belt, the Preferred Option is not preferred from a safety perspective. In addition, a conveyor belt from Site A is more likely to impact on the movement patterns of people compared to if the conveyor belt came from Site B (Alternative 2). Although it would be possible to avoid the displacement and relocation of people, the resettlement of households (approx. 20) will be necessary. The conveyor route from Site B through to Maquasa West will need to be longer than the conveyor route in the Preferred Option. Ecologically, this is not favourable. Due to the overland conveyor in Alternative 2 having a longer distance than the Preferred Option, financially, Alternative 2 is not as feasible as the Preferred Option. Although it would be possible to avoid the displacement and relocation of people, it would be necessary for Alternative 2. From a cultural and heritage perspective, Alternative 2 is less favourable than the Preferred Option, as there are more cultural and heritage resources at Site B. The low quality coal at Site B means that the first few million tons of coal mined will not be regarded as marketable. This means this alternative would require a larger coal discard dump (to be located on the existing Maquasa East mining license). Although it is not clear at this stage of the process as to the exact number of people that will most likely need to be relocated (estimated 20 households), there are fewer safety and inconvenience concerns associated with Alternative 2. As both sites are not hydrogeologically different from each other, considering that Site A is in closer proximity to an already impacted area (Maquasa West operations), it was preferred over the more pristine environment at Site B. From a cultural and heritage perspective the Preferred Option is preferred in comparison to Alternative 2. In relation to Alternative 3, the Preferred Option has lower occupational health and safety risks, as it is always preferable to transport personnel above ground as opposed to underground. From a technical engineering and financial perspective, the Preferred Option (together with the adit option at Site B, and underground mining) is considered to be more feasible than Alternatives 3 and 4, mainly due to the possibility of using a horizontal shaft, as opposed to a vertical shaft or incline shaft type. This Project option (having the main mine adit at Site A) was the preferred option in the ERM site screening assessment. As such, this option has been selected as the preferred project option. Environmentally, the Preferred Option is more favourable than Alternative 2. Although it is not clear at this stage of the process as to the number of people that will most likely need to be relocated, there are fewer safety and inconvenience concerns associated with this alternative. From a cultural and heritage perspective the Preferred Option is preferred in comparison to Alternative 2. In relation to Alternative 3, Alternative 2 has lower occupational health and safety risks. From a technical engineering and financial perspective Alternative 2 is considered more feasible than Alternatives 3 and 4. Due to lower quality coal at Site B, this alternative would require a larger coal discard dump, with associated environmental risks, when compared to the Alternative 1. This alternative is more reasonable and feasible when compared to Alternative 3, 3 and 4; however, environmentally and financially is less favourable than the Preferred Option. As such, this Alternative will not be considered further in the study. 3-48

5 Alternative Socio-environmental and Financial Advantages Socio-environmental and Financial Disadvantages Pre-feasibility Study Outcome Alternative 3 Adit at Site A and no overland conveyor Alternative 4 Adit at Site B and no overland conveyor Socially and ecologically Alternative 4 is more favourable than the Preferred Option and Alternative 2, as the above ground footprint for this alternative will be smaller (as there will be no overland conveyor). Alternative 4 is less costly than Alternative 5, as the underground conveyor route will be shorter in distance for Alternative 4. Alternative 4 is more advantageous in comparison to Alternative 3, as it reduces the health and safety risk to mining personnel associated with travelling through the potentially unstable, old workings of the existing Maquasa West and Maquasa West Extension mine. This alternative reduces the amount of unproductive travelling time that personnel need to access the working areas as required in option 2 (58 minutes per shift). The main mine access road for Alternative 2 does not seem to be frequented by the public as intensely as the Preferred Option. Relative to the Alternative 4, there are no social/environmental advantages associated with Alternative 5. Alternative 5 is more advantageous when compared to Alternative 3, as it reduces the health and safety risk to mining personnel associated with travelling through the potentially unstable, old workings of the existing Maquasa West and Maquasa West Extension mine. This alternative reduces the amount of unproductive travelling time that personnel need to access the working areas as required in option 2 (58 minutes per shift). Having the main mine adit at Site A triggers significant traffic related health and safety concerns. These are discussed in the socio-environmental and financial disadvantages for the Preferred Option above. Financially, due to having the conveyor route underground in this alternative, Alternative 4 will be more costly than the Preferred Option and Alternative 2. This additional cost would compromise the feasibility of this alternative. The Life of Mine in this alternative would be reduced, as the underground conveyor will result in a loss of coal product. From an engineering point of view, the technicalities associated with having an underground conveyor for the transportation of coal to the existing Maquasa West Adit are not favourable (as described in Alternative 3 above). Site B is more ecologically sensitive than Site A. From an engineering point of view, the technicalities associated with having an underground conveyor for the transportation of coal to the existing Maquasa West Adit are not favourable (as described in Alternative 3 above). Furthermore as the underground conveyor system will need to be greater in length than Alternative 4, the costs associated with Alternative 5 will be greater. The low quality coal at Site B means that the first few million tons of coal mined will not be regarded as marketable. This means this alternative would require a larger coal discard dump (to be located on the existing Maquasa East mining license). There are fewer safety and inconvenience concerns associated with Alternative 5 when compared to Alternative 4. Although having an underground conveyor system is socially and environmentally more feasible, from a financial and technical perspective it is not deemed favourable. As such, this alternative will not be considered further in the Study. Alternative 5 has fewer public safety and inconvenience concerns when compared to Alternative 4. Although having an underground conveyor is socially and environmentally more feasible, from a financial and technical perspective it is not deemed favourable. Furthermore, Alternative 4 is more favourable ecologically and financially than Alternative 5. As such, this alternative is not considered to be either reasonable or feasible and will not be considered further in the study. 3-49

6 Environmental and Social Site Screening Assessment - ERM Following the Hatch pre-feasibility study ERM conducted a site screening assessment based on environmental and social aspects of three possible development sites (Figure 3.1) for the Adit 5. The three possible development sites identified were based on high level mine planning where access to the coal seam was deemed feasible. With reference to Figure 3.1 the three possible development sites were referred to as Site A (purple block), Site B (green block), and Site C (orange block). Following this study, and based on environmental considerations and potential impacts, a new alternative position for the Adit 5 was considered, taking into account all outcomes from the previous studies and the screening assessment. 3-50

7 Figure 3.1 ERM Site Screening Study Areas to position the new Adit 5

8 Site Screening Assessment on MR133 Kangra Coal A further site screening assessment was undertaken by Kangra Coal in 2015 based on environmental, social and design considerations. Based on the previous studies and discussions between Kangra Coal, the Department of Mineral Resources (DMR) and the Department of Water and Sanitation (DWS), in October 2014, three different sites were assessed within the MR133 mining right area, as depicted in Figure 3.2. Environmental Screening Assessment A quantification of the environmental sensitivity of each site was determined by assigning each environmental parameter with a score as per Table 3.2. The parameters are ranked from 1 to 4, with 1 signifying a high sensitivity and 4 the lowest sensitivity and therefore an environmentally preferable site. According to this assessment, Site A is the preferred alternative. Table 3.2 Environmental Sensitivity of Alternative Adit Sites Parameter Site A Site B Site C Streams and rivers Wetlands Flora, fauna and vegetation Homesteads Farming Overburden Coal quality Coal thickness Topography and access Discontinuities* Score * Discontinuities refer to abnormalities in geology such as faults and dykes. Based on current borehole information, Site A is the preferable alternative. Design Considerations The structural suitability of the three alternative sites was also assessed. An overburden (the average thickness of the weathered material) of 20 to 40 m is usually considered ideal for the construction of an inclined shaft. Topography is thus considered a constraint in the focus area of the three sites. Site A, however, has a relatively easier access potential due to the flatter topography as well as being in the near vicinity of an existing access road (currently being used by local inhabitants). Summary of Alternative Locations on MR133 for the Adit The assessment of the three sites on MR133 pointed to Site A being the preferred site in terms of environmental, social and technical considerations. 3-52

9 Figure 3.2 Three Alternative Adit Sites Assessed within MR133

10 3.2.2 Alternative Overland Conveyor Routes Two alternative conveyor routes were initially assessed in addition to the preferred alternative for the proposed transport of coal from the main adit through to the existing Maquasa West adit based on the initial adit positions considered (Figure 3.3). Initially Kangra Coal proposed these two alternative routes for the conveyor system through to the Maquasa West adit; however, it became evident that this area would potentially be developed by Kangra Coal as part of future mine expansion projects which would include open cast mining. As such, these alternatives were not considered viable and a further option was considered which would link the preferred main adit location to the existing Maquasa West adit Adit 5 and Overland Conveyor Preferred Alternative Based on the alternatives analysis the preferred location for the main adit and new overland conveyor route is shown in Figure 3.4. It is proposed to develop and operate the Adit 5, overland conveyor and servitude road within the Maquasa West Extension operational area (MR133). This proposed infrastructure will be located on the properties as described in Table 3.3. Table 3.3 Properties Intersected by the Overland Conveyor Property Surveyor General Cadastral Code Title Number Deed Adit 5 Kransbank 15HT, Portion 2 T0HT T21311/ Overland Conveyor Kransbank 15HT, Portion 2 T0HT T21311/ Kransbank 15HT, Portion 1 T0HT T139369/2000 Rooikop 18HT, Portion Re T0HT T78816/2004 Infrastructure Development Footprint (Ha) The parameters taken into account to select the site for the main adit and overland conveyor included: Environmental Streams and rivers; Wetlands; Flora, fauna and vegetation; Social Homesteads; Farming; Technical Topography; and Access 3-54

11 Figure 3.3 Conveyor Route Alternatives

12 Figure 3.4 Overland Conveyor Route - Preferred Alternative

13 3.2.4 Conclusion This alternative is now the preferred alternative and will be assessed in the EIA phase. As discussed, various studies were carried out by Kangra Coal, Hatch and ERM, through which various alternatives for the layout of the Adit 5 locations and the overland conveyor have been investigated. Through these studies a preferred alternative for the Adit 5 location and overland conveyor route have been identified and will be assessed in the EIA phase in terms of potential environmental and social impacts. The No-Go alternative assessed would not provide for any additional economic benefits or further employment, and is therefore not considered a feasible alternative. 3.3 CENTRAL DISCARD DUMP GCS undertook an assessment of the viable alternatives for the Central Discard Dump in These alternatives are detailed in this section. Three options were considered to accommodate the additional discard: The expansion of the current Maquasa East Discard Dump; The construction of a new disposal facility; and The no-go alternative. These are discussed in the following sections Expansion of Existing Maquasa East Discard Dump The existing Maquasa East Discard Dump is located to the north-west of the beneficiation plant. According to the Maquasa West 2009 EMPr Amendment, the existing discard facility has a maximum calculated capacity of 12,000,000 tonnes (this estimate is currently being confirmed through an assessment of the dump). The current boundary of the existing discard dump is less than 500m from boundary fence which separates the mining area from the Driefontein community. The expansion of the dump was not considered feasible because the available area would not provide sufficient capacity for the additional discard disposal required for the extended life of mine (LoM) for the Kangra Coal operations and the proposed Kusipongo expansion Development of a New Central Discard Dump (Preferred Option) This option was identified as the preferred alternative because the current discard dump does not have sufficient space for expansion. In order to 3-57

14 implement this option, a location needed to be selected as well as the disposal method. These alternatives are assessed in the following sections. Alternative Locations for New Central Discard Dump Six (6) potential sites were identified by Hatch during their 2011 Concept Study, which included an assessment of the sites as well as the potential disposal methods. The following sites were assessed (Figure 3.5): Site A: situated to the east of the coal washing plant; Site B: situated to the north of the coal washing plant; Site C: situated to the north west of the coal washing plant and includes the existing Maquasa East Discard Dump site; Site D: situated to the west of the current wash plant position and is located on the coal reserves in the area known as Maquasa West; Site E: opencast excavation situated approximately 2.4km to the west of the current wash plant position in the Maquasa West Open Cast section; and Site F: The site is situated approximately 3.2km to the west of the current wash plant position. A fatal flaw assessment was also undertaken by Hatch in According to the assessment, fatal flaws are those factors which eliminate the use of the sites for discard disposal because they do not adhere to the environmental and/or safety objectives (Hatch, 2011). The fatal flaw assessment table extracted from the Site Selection Report is presented in Table 3.4. This table shows that Site E was eliminated due to the potential difficulty of controlling the Acid Mine Drainage (AMD) in the open cast excavation Table 3.4 Fatal Flaw Assessment of Potential Sites Site Fatal Flaw Comment A No No Comment B No Steep zone C No Above old mined out area including existing Discard Dump D No Acid Mine Drainage (AMD) could exclude this site E Yes Unlikely to be able to control AMD and opencast operation not guaranteed F No No comment Source: Hatch,

15 The remaining sites were ranked subjectively by considering: Safety classification; Environmental classification; Design and operation; and Economics. Critical factors were then weighted out of 10, with 1 having the least important and 10 being of critical importance. According to the Site Selection Report, Critical Factors are those factors that do not adhere to the environmental and/or safety objectives, but can effectively be mitigated by engineering solutions (Hatch, 2011). Although Site C was identified as the preferred site in the Site Selection Report, Kangra rejected this site because it is located above an old mined out area. Site F is therefore selected as the preferred site. The advantages and disadvantages of each site are presented in Table 3.4. Disposal Alternatives Four disposal alternatives were considered during the 2011 Concept Study. These are discussed in the following sections and include: Integrated Discard Dry ; Co-disposal Wet and Dry ; Integrated Discard Wet ; and Separate Disposal Wet Site 1 and Dry Site 2. Integrated Discard Dry (Preferred Alternative) Integrated discard dry process involves dumping coarse discard material the conventional way in layers and mixing the low moisture filter cake fine discard material in layers with the coarse discard. The integrated discard dry technique will reduce the permeability of the coarse discard and therefore result in a reduction in AMD. Although the expected AMD is significantly less than that for co-disposal AMD is expected to continue after closure. Co-disposal Wet and Dry Co-disposal involves the impoundment of slurry within the body of the coarse discard, which will lead to AMD during the operating life and a considerable period after closure. Integrated Discard Wet Integrated discard involves the mixing of slurry and the coarse discard which will be deposited like conventional tailings. The tailings will beach, with the 3-59

16 coarse product being deposited first followed by the fine product which will accumulate at the pool centre. The integrated discard technique will reduce the permeability of the coarse discard and therefore a reduction in AMD is expected. Although the expected AMD is significantly less than that for co-disposal, AMD is expected to continue after closure. However, this disposal technique is relatively new and unproven technology. Separate Disposal Wet Site 1 and Dry Site 2 Separate disposal involves the deposition of the slurry into the underground workings or a separate above ground fines slurry pond, and the impoundment of the coarse discard above the ground surface. This reduces the AMD potential of the coarse discard, and the control and containment of AMD from the slurry if it is placed below ground. In the case of Maquasa the fines could be transported and deposited in the form of a slurry back into the underground workings. These areas of disposal would be prepared using the appropriate preplanning and mining methods. The slurry would then be deposited at an elevation below the expected working level and remains flooded thereby excluding or limiting the supply of oxygen. However, a decision has been made to stop this operation and to dry the slurry and dispose of the filter cake on the coarse discard dump. This is the process being followed currently at the existing Enprotec plants. 3-60

17 Figure 3.5 Alternative Discard Dump Locations

18 Table 3.5 Assessment of Alternative Sites SITE ID ADVANTAGES DISADVANTAGES Site A The relatively flat topography. The close proximity (±0.2 km) to the proposed plant position. The dump cannot sterilise any coal reserves. The close proximity (± 0.6 km) to the Heyshope Dam. The collected seepage must be handled by a pumping system that must operate after mine closure. The visible impact of the dump. The polluted surface water and storm water runoff must be handled by a pumping system during operation. Site B Site C Site D Site F (Preferred Option) The close proximity (± 0.5 km) to the proposed plant. The dump can blend in with the natural topography to reduce the visible impact. The polluted surface water and storm water run-off can be handled by a gravity system (passive). The seepage can be handled by a gravity system (passive). The dump can blend in with the natural topography to reduce the visible impact. The polluted surface water and storm water run-off be handled by a gravity system (passive). The seepage can be handled by a gravity system (passive). The dump can blend in with the natural topography to reduce the visible impact. The polluted surface water and storm water runoff can be handled by a gravity system (passive). The seepage can be handled by a gravity system (passive). The dump is on a slope which faces away from the Heyshope dam and Driefontein and therefore the visual impact is reduced. The two naturally occurring clay layers within the soil profile, and the elevation of the ground water is below the second layer. The dump cannot sterilise any coal reserves. The major seep zone that will require significant engineering design to overcome, and will have a low confidence level of success. The site is located partially above the old mined out area and the correct as mined out survey should be sourced to establish how many pillars have been left after mining activities stopped. The depth to underground workings is approximately 30 m. That it is (± 1.2 km) from the existing washing area. The site is located directly above the old mined out area and the correct as mined out survey should be sourced to establish how many pillars have been left after mining activities stopped. The difficulty in containing seepage. The distance (± 1.9 km) from the plant position. The site is located partially above the old mined out area and the correct as mined out survey should be sourced to establish how many pillars have been left after mining activities stopped. The distance from the current washing plant position (3.2km). The introduction of a pumping system to, return the seepage to the plant during the operational life.

19 Coarse Discard disposal involves impounding the coarse discard on a selected site above natural ground. The coarse discard is then compacted to minimise the risk of spontaneous combustion by limiting the ingress of air and water into the waste dump. The AMD that could be generated from the coarse discard during operations would then be captured and contained within the mine property and once the dump has been encapsulated, the amount of seepage is likely to cease after a short period of time Land Use Alternatives It is important to consider if there are any viable alternative uses of the land over which the development is proposed. The proposed development area is located within an existing mining right area (MRA), on land owned by the applicant. Tourism The proposed discard dump area is located within an existing MRA (133 MR), adjacent to a rehabilitated opencast pit and to the north-east of the Maquasa West current and proposed pits. The use of this land for tourism is therefore not feasible. Residential As discussed previously, the proposed discard dump area is located within an existing MRA, in close proximity to the existing and proposed opencast pits of Maquasa East and West. The surrounding land uses therefore precludes the use of this land for residential developments. Grazing of Cultivated Land The location of the proposed discard dump is within a MRA, immediately adjacent to the rehabilitated Maquasa East Pit D. The use of this land for grazing and cultivation is not feasible during the LoM. Mining No viable ore reserves are located beneath the proposed discard dump site and therefore the use of the area for mining is not feasible. 3.4 NO GO OPTION Should the proposed MWE underground works and the new Adit 5 and overland conveyor not be approved, the No-Go option would mean that Kangra Coal would not be able to exploit this extensive coal reserve. With the existing mine life of only approximately another 3 years, the No-Go option would result in the mine ceasing operations in approximately 3 years. Further, the No-Go option would have a considerable opportunity cost, for the following reasons: 3-63

20 It would potentially result in the loss of employment (within the next 3) for 745 employees that are currently working at the Savmore Colliery and approximately 900 direct jobs (contractors); It would significantly impact on the local community that indirectly rely on Kangra Coal; and It would negatively affect the supply of coal to both international and local markets. This alternative would prevent the proposed expansions from being implemented, as there would be no facility for the disposal of additional discard. This in turn would shorten the LoM and prevent the exploitation of important coal resources and the retention of employment in the long term. 3.5 CONCLUSION As discussed, various studies were carried out by Kangra Coal, Hatch and GCS, through which various alternatives for the new Central Discard Dump have been investigated. Through these studies a preferred alternative (Site F) for the discard dump has been identified and will be assessed in the EIA phase in terms of potential environmental and social impacts. The No-Go option assessed would not provide for any additional mining to occur due to insufficient discard potential and limited additional economic benefits and employment, and is therefore not considered a feasible alternative. 3-64