Proposed establishment of a quarry in the Ngquza Hill Local Municipality, Eastern Cape

Transcription

1 Final and Environmental Management Programme Report SLR Project No.: Report No.: 5 South African National Roads Agency SOC Ltd

2 Final and Environmental Management Programme Report SLR Project No.: Report No.: 5 South African National Roads Agency SOC Ltd

3 ENVIRONMENTAL IMPACT ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED). NAME OF APPLICANT: South African National Roads Agency SOC Ltd (SANRAL) TEL NO: FAX NO: POSTAL ADDRESS: PHYSICAL ADDRESS: FILE REFERENCE NUMBER SAMRAD: 20 Shoreward Drive (Adjacent Bay West Mall Entrance 4a), Bay West, Port Elizabeth, Shoreward Drive (Adjacent Bay West Mall Entrance 4a), Bay West, Port Elizabeth, EC 30/5/1/3/3/2/1/00066 BPEM

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5 SLR Consulting (South Africa) (Pty) Ltd Page ii EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER NAME: RESPONSIBILITY ON PROJECT: QUALIFICATIONS: PROFESSIONAL REGISTRATION: EXPERIENCE IN YEARS: 17 EXPERIENCE: Mr Fuad Fredericks Project management and quality control M.Sc. (Botany), HDE Pr.Sci.Nat., CEAPSA Fuad Fredericks has been involved in environmental consulting since 1999 and is currently a Director of SLR Consulting (South Africa) (Pty) Ltd. He has experience in a wide range of environmental disciplines, including Environmental Impact Assessments, Environmental Management Programmes, Environmental Monitoring and Auditing, Environmental Education and Public Consultation. He has been responsible for management and quality control of environmental assessments dealing with a number of highly complex and controversial projects, such as the proposed toll roads on the national routes in the Western Cape and the proposed toll road between the Eastern Cape and KwaZulu-Natal. He also has extensive experience in the environmental assessment, monitoring and auditing of projects related to railway facilities, landfill sites, wastewater treatment facilities, and water and sewage pipelines. NAME: Nicholas Arnott RESPONSIBILITY ON PROJECT: Project consultant and report writing QUALIFICATIONS: B.Sc. Hons (Earth and Geographical Science) PROFESSIONAL Pr.Sci.Nat. REGISTRATION: EXPERIENCE IN YEARS: 10 Nicholas Arnott has worked as an environmental assessment practitioner since 2006 and has been involved in a number of projects covering a range of environmental disciplines, including Basic Assessments, Environmental Impact Assessments and EXPERIENCE: Environmental Management Programmes. He has gained experience in a wide range of projects relating to mining, infrastructure projects (e.g. roads), housing and industrial developments.

6 SLR Consulting (South Africa) (Pty) Ltd Page iii EXECUTIVE SUMMARY 1. INTRODUCTION This Executive Summary provides a comprehensive synopsis of the Final (EIR) and Environmental Management Programme Report (EMPR) prepared as part of the Scoping and Environmental Impact Assessment (EIA) process that has been undertaken for the proposal by the South African National Roads Agency SOC Ltd (SANRAL) to develop a quarry within the Ngquza Hill Local Municipality in the Eastern Cape Province (see Figure 1). The proposed quarry would act as a local source of the necessary materials for construction of the Mthentu and Msikaba river bridges and other required works on the N2 Wild Coast Toll Highway. 1.1 PURPOSE OF THIS REPORT This report summarises the Scoping and EIA process undertaken, provides an overview of the proposed project, describes the affected environment, presents the findings of the specialist studies and provides an assessment of the potential impacts of the proposed project. It should be noted that all substantive changes to the draft report are underlined and in a different font (Times New Roman) to the rest of the text. This report is submitted to the Department of Mineral Resources (DMR) for consideration as part of the Application for Environmental Authorisation in terms of Chapter 5 of the National Environmental Management Act, 1998 (No. 107 of 1998) (NEMA), as amended. 1.2 PROJECT BACKGROUND SANRAL has commenced with preparations for construction of the greenfields sections of the N2 Wild Coast Toll Highway project. Such preparations include the identification of potential quarry site locations for the sourcing of the necessary construction materials for the Mthentu and Msikaba river bridges and other required works on the N2 Wild Coast Toll Highway. Based on the outcomes of preliminary geotechnical investigations, a suitable site for the establishment of a quarry has been identified within the Ngquza Hill Local Municipality in the Eastern Cape Province. Accordingly, SANRAL is now proposing to establish a quarry at this site. On 5 September 2016, SANRAL lodged an application for Environmental Authorisation with the DMR in terms of Section 24 of NEMA, as amended. The application was accepted by DMR on 10 October LEGISLATIVE FRAMEWORK In terms of the Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002) (MPRDA), a Mining Right must be issued prior to the commencement of any quarrying activities. In terms of Section 106 of the MPRDA, SANRAL is exempted from applying for a Mining Right for the purposes of sourcing road building material. However, SANRAL is still required to submit the relevant environmental reports in terms of Chapter 5 of the NEMA to obtain an environmental authorisation.

7 SLR Consulting (South Africa) (Pty) Ltd Figure 1: Page iv Regional setting of the proposed quarry site.

8 SLR Consulting (South Africa) (Pty) Ltd Page v The EIA Regulations 2014 promulgated in terms of Chapter 5 of the NEMA, and published in Government Notice (GN) No. R982 (as amended), provides for the control of certain listed activities. The proposed project triggers various activities contained in Listing Notices 1, 2 and 3 (as amended), thus a full Scoping and EIA process must be undertaken in order for the DMR to consider an application for environmental authorisation 1. In terms of the National Water Act, 1998 (No. 36 of 1998) (NWA), a Water Use Licence Application for the following water use activities, at a minimum, would be required for the proposed quarry: Section 21(c) - Impeding and diverting the flow of water in a watercourse; and Section 21(i) - Altering the bed, banks, course or characteristics of a watercourse. It is noted that in terms of the General Authorisation (GA) Regulations (GN No. 509 of 26 August 2016), SANRAL would not be required to apply for a WULA for the proposed access road over the KwaDlambu River, as it would be authorised under the GA, subject to compliance with the necessary conditions. Furthermore, the Contractor(s) to be appointed for the operation of the quarry would be responsible for determining suitable water sources and obtaining any permits, licence and/or authorisations which may also be applicable for the abstraction of water from these sources, as appropriate. The proposed quarry will also require authorisation in terms of the National Heritage Resources Act, 1999 (No. 25 of 1999) (NHRA). The NHRA stipulates that no person may disturb any grave or burial ground older than 60 years without a permit. Human remains that are less than 60 years old are subject to provisions of the Human Tissue Act, 1983 (No. 65 of 1983) and any other applicable local regulations. The relocation of graves would require a permit issued by the Eastern Cape Provincial Heritage Resources Authority (ECPHRA). 2. EIA PROCESS 2.1 SCOPING PHASE The Scoping Phase complied with the requirements of NEMA and the EIA Regulations 2014, as set out in GN No. R982 (as amended). This involved a process of notifying Interested and Affected Parties (I&APs) of the proposed project and EIA process in order to ensure that all potential key environmental impacts, including those requiring further investigation, were identified. The Scoping Report, which was prepared in compliance with Appendix 2 of the EIA Regulations 2014, was accepted by DMR on 14 December DMR s acceptance of the Scoping Report stated that the next phase of the EIA may proceed as outlined in the Plan of Study for EIA, which was appended to the Scoping Report. 2.2 EIA PHASE Specialist studies Three specialist studies were undertaken to address following aspects: (1) potential impacts on terrestrial and freshwater ecosystems; (2) potential blasting impacts; and (3) potential impacts on cultural heritage 1 Subsequent to the distribution of the Draft EIA and EMPR Report for comment, the EIA Regulations 2014, Listing Notices 1, 2 and 3 were amended by GN No. R.326, R.327, R.325, and R.324 of 7, respectively. These amendments have been duly taken into account in the compilation of this final report.

9 SLR Consulting (South Africa) (Pty) Ltd Page vi resources. The specialist studies involved the gathering of data relevant to identifying and assessing environmental impacts that may occur as a result of the proposed project. These impacts were then assessed according to pre-defined rating scales. Specialists also recommended appropriate mitigation or optimisation measures to minimise potential negative impacts or enhance potential benefits, respectively Integration and Assessment The EIR and EMPR has been prepared in compliance with Appendix 3 of the EIA Regulations The specialist assessments and other relevant information have been integrated into the report. The Draft EIR and EMPR was distributed for a 30-day comment period from 17 March to 19 (taking into account the three public holidays during this period) in order to provide I&APs with an opportunity to comment on any aspect of the proposed project and the findings of the EIA process. One verbal and two written submissions were received during the review and comment period. The following steps are envisaged for the remainder of the EIA process: After the Minister of Mineral Resources (or delegated authority) has reached a decision, all I&APs on the project database will be notified of the outcome of the application and the reasons for the decision; and A statutory appeal period in terms of the National Appeal Regulations (GN No. R993) will follow the issuing of the decision. 3. PROPOSED PROJECT DESCRIPTION As noted above, SANRAL is proposing to establish a quarry to provide the necessary materials for the construction of the Mthentu and Msikaba river bridges and other works on the N2 Wild Coast Toll Highway. Based on the initial results of preliminary geotechnical investigations, a suitable site for the establishment of a quarry has been identified within the Ngquza Hill Local Municipality in the Eastern Cape Province. The proposed project would entail the establishment of a quarry, various associated stockpiles, a contractor s camp and an access road (see Figure 2). The total footprint of the area to be developed is anticipated to be approximately 50 ha, with the proposed quarry being about 25 ha in extent. The following key facilities associated with the contractor s camp are currently planned: Offices; Ablution facilities; Workshop; Stores; Fuel storage; Concrete batching; and Crushing and processing plant. The paragraphs overleaf provide a more detailed description of the proposed operations.

10 SLR Consulting (South Africa) (Pty) Ltd Page vii SECONDARY STOCKPILE CRUSHING PLANT SECONDARY QUARRY CONTRACTOR CAMP PRIMARY QUARRY PRIMARY STOCKPILE AREA BACKUP STOCKPILE Figure 2: Site plan of the proposed quarry.

11 SLR Consulting (South Africa) (Pty) Ltd Page viii 3.1 QUARRY LAYOUT AND DEVELOPMENT The proposed quarry could be either operated by a single operator or two operators simultaneously, thus the site layout has been designed to make provision for two separate quarrying areas (Primary Quarry and Secondary Quarry) that could be worked independently of each other. In the scenario that two operators are involved, the Primary Quarry area would be worked by one operator along the east-west face and the second operator would independently work the Secondary Quarry along the south-north face. The excavated material from each quarry area would then be processed by the crushing plant located on the site. The processed material would be stockpiled and then loaded onto haul vehicles for transport to the construction sites. Material that is not suitable for use in the construction works would be stockpiled separately for use in the reshaping of the site during rehabilitation. Where two operators are involved at the site, each operator would be responsible for the rehabilitation of their respective operational areas (i.e. the separate Primary and Secondary quarry areas), as well as their portion of the overall site. 3.2 WASTE MANAGEMENT Domestic waste generated during the course of the quarry operations would be collected and stored in suitable receptacles on-site for collection and disposal at an appropriately licensed municipal waste site or acceptable disposal facility. 3.3 WATER MANAGEMENT It is anticipated that water would be required for dust suppression (on stockpiles and the access road) and ancillary activities associated with the quarry operations (e.g. washing of vehicles and equipment). The proposed source(s) and anticipated volumes required for the proposed project are not known at this stage. The Contractor(s) to be appointed for the operation of the quarry would be responsible for determining suitable water sources and obtaining any permits, licence and/or authorisations which may also be applicable for the abstraction of water from these sources, as appropriate. 3.4 TRANSPORT It is proposed that an access road would be established to link the proposed quarry site with the Holy Cross - Mkambati Road. The proposed access road would cross a watercourse. The project engineer has recommended that the proposed water crossing be a low-level river crossing structure comprising five box culverts and positioned at the centre of the river. It was further recommended that the road section located to the east of the river crossing be surfaced with concrete, while the road section to the west of the river could be a gravel surface. The proposed access road would facilitate the transport of material by truck from the site to the bridge construction and other areas. 4. AFFECTED ENVIRONMENT 4.1 BIOPHYSICAL ENVIRONMENT The topography of the broader study area is very rugged and mountainous with deep and steep-sided river valleys. The proposed quarry site itself is positioned on a hill and is bounded by two watercourses to

12 SLR Consulting (South Africa) (Pty) Ltd Page ix the west, south and east of the site perimeter. The majority of the rivers in the region are considered to have a high Ecological Importance and Sensitivity. The natural vegetation of the study area is mapped as Ngongoni Veld, which is considered to be a Vulnerable vegetation type. The proposed quarry site is located within an area identified as a terrestrial Critical Biodiversity Area (CBA) 2 and an aquatic CBA2 estuary in terms of the Eastern Cape Biodiversity Conservation Plan Mapping. Eight plant species of conservation concern were considered to potentially occur within the study area. Of the eight species identified, two were confirmed to be present within the proposed quarry site, namely Hypoxis hemerocallidea (Declining status) and Senecio umgeniensis (Threatened status), while further verification is required to confirm the presence of a third species, Helichrysum cf. pannosum (Endangered status). With respect to fauna, two mammal species (Cape Clawless Otter and Reddish-grey Musk Shrew), three bird species (African Marsh-Harrier, Black Harrier and Black-Winged Lapwing) and twelve endemic or near-endemic reptile species are thought to potentially occur within the project area. 4.2 CULTURAL HERITAGE ENVIRONMENT Later Iron Age and two Early Iron Age sites have been historically identified in the broader study area. From a cultural perspective, social capital is held in homesteads and graves, with grave sites often associated with abandoned homesteads. The heritage specialist did not identify any archaeological sites within the footprint of the proposed project and associated access road. However, a grave associated with an old abandoned homestead was located in the eastern section of the project footprint. 4.3 SOCIO-ECONOMIC ENVIRONMENT The Ngquza Hill Local Municipality (LM) is bordered by the Bizana LM to the north, the Port St John s LM to the south and the Ntabankulu LM to the northwest. The total population of the Ngquza Hill LM is , which is 20.4% of the total population of the O.R. Tambo District Municipality. Scattered rural subsistence settlements predominate with some villages being fairly inaccessible. Approximately 95% of the population of the municipality is recorded as living in traditional dwellings. The vast majority of the population are not considered economically active ( people) with only people being employed (Stats SA, 2011). The proposed quarry site is largely undeveloped and sparsely populated with small dwellings (generally comprising one to four structures). The remaining open areas are used for limited subsistence farming or grazing. Road infrastructure in the area is poorly developed. 5. IMPACT ASSESSMENT CONCLUSIONS A summary of the assessment of potential environmental impacts associated with the proposed project activities and No-Go Alternative is provided in Table 5.1. The majority of the impacts associated with the establishment and operation of the proposed quarry would be largely localised, of long-term duration and of low intensity, and are considered to be of LOW significance after mitigation. Key mitigation includes ensuring that the area of disturbance is limited to what is absolutely necessary for the proposed operation, a detailed stormwater management plan is developed and implemented, on-site pollution prevention measures are implemented and any complaints received from third parties are addressed in accordance with a formal complaints procedure.

13 SLR Consulting (South Africa) (Pty) Ltd Page x One of the key issues associated with the proposed quarry operation relates to the loss of vegetation and the related impacts on fauna and associated biodiversity. All vegetation within the quarry footprint would be lost during the course of the operations. Approximately 22 ha of Degraded Primary Grassland and 29 ha of Secondary Grassland (of the Vulnerable Ngongoni vegetation type) would be lost. Furthermore, conservation-important plant species may be destroyed/damaged if measures are not taken to preserve these plants. The loss of Ngongoni Veld and conservation-important species is considered to be a high intensity impact, localised over the duration of the proposed quarry operations. As the loss of Ngongoni Veld due to quarry establishment is accommodated in the approved Biodiversity Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015), the requisite biodiversity offset would compensate for the loss of the vegetation type. The residual impact is assessed to be of MEDIUM to HIGH significance. With respect to noise impacts, it is anticipated that the proposed quarry would exceed the SANS guidelines with respect to increasing ambient background noise levels in excess of 3 to 5 dba. However, as it is recommended that the homesteads closest to the quarry operations (i.e. within the project footprint and associated 600m blast zone see below) should be relocated, the closest receptors would be located further away from noise sources associated with the proposed operations. The residual noise impact of the proposed project is deemed to be of local extent, long-term duration, medium intensity and MEDIUM significance. The relocation of a single unmarked grave site located within the project footprint will be required, as well as any graves which may be associated with homesteads to be relocated in the adjacent area. As human remains have high heritage significance for their social value, the potential permanent, localised impact is assessed to be of high intensity. By ensuring that all applicable legislative requirements, guidelines and regulations applicable to the removal of human remains are implemented for the relocation of graves, it is anticipated that the residual impact would be of MEDIUM significance. Where basting activities associated with the proposed quarry operations lead to the damage of third party property or injury of people or animals, the impact would be of high intensity at a local level and endure in the medium term and is deemed to be of medium significance without mitigation. The blasting specialist has indicated that the human response to the modelled ground vibration levels would be at an unpleasant level up to 592 m of the boundary of the quarry footprint. Consequently, it is recommended that the relocation of households within 600 m of the quarry boundary be considered. By relocating thirdparties outside of the project footprint and the blasting zone (a distance of 600 m, as recommended by the blasting specialist), the significance of the residual impact would reduce to LOW. Not going ahead with the proposed quarry operations (No-Go Alternative) would result in the maintenance of the status quo. No change to the current impacts experienced on the site would be expected for terrestrial and freshwater ecosystems, ambient air quality, noise, heritage and cultural resources, traffic and land uses. Furthermore, NO IMPACT with respect to blasting hazards and the influx of job seekers would be anticipated. However, not proceeding with the proposed project would result in the loss of direct and indirect socio-economic benefits of the proposed project and lost economic opportunities related to costs already incurred in the initial planning phase. This is considered to be of HIGH significance.

14 SLR Consulting (South Africa) (Pty) Ltd Page xi Table 5.1: Summary of the significance of the potential impacts associated with the proposed mining operations and No-Go Alternative. Significance Potential impact Without With mitigation mitigation POTENTIAL BIOPHYSICAL IMPACTS Soil and land capability M L Fauna and Flora Loss of vegetation H M - H Loss of fauna and alteration of habitats L L Hydrology (Surface Water) M L - M Air Quality L L Noise M M POTENTIAL SOCIO-ECONOMIC IMPACTS Heritage and Cultural Resources Unmarked grave site H M Archaeological sites M L Impacts on roads by project-related traffic M H L - M Blasting Hazards M L Land Use L L Creation of employment and business opportunities L (+ve) L (+ve) Influx of job seekers to the area M L NO-GO ALTERNATIVE No-Go Alternative Soil and land capability L N/A Fauna and Flora L N/A Hydrology (Surface Water) L N/A Air Quality Noise Heritage and Cultural Resources Impacts on traffic Land Use Blasting Hazards Influx of job seekers NO CHANGE TO CURRENT IMPACTS NO IMPACT Lost Economic Opportunities H N/A VH=Very High H=High M=Medium L=Low VL=Very low Insig = insignificant N/A= Not applicable 5.1 REASONED OPINION OF ENVIRONMENTAL ASSESSMENT PRACTITIONER The key principles of sustainability, including ecological integrity, economic efficiency, and equity and social justice, are integrated below as part of the supporting rationale for recommending an opinion on whether the proposed project should or should not be approved. Ecological integrity 2 The potential disturbance of Ngongoni Veld and associated biodiversity is considered to be of high intensity as all vegetation (and associated available habitat) within the quarry footprint would be lost during the course of quarry operations. The area of disturbance (approximately 70 ha including the proposed project footprint and associated access road) is considered to be relatively substantial in comparison to the remaining intact area of this Vulnerable vegetation type. Furthermore, there are numerous conservation-important species present within the grassland 2 Ecological integrity is the abundance and diversity of organisms at all levels, and the ecological patterns, processes and structural attributes responsible for that biological diversity and for ecosystem resilience.

15 SLR Consulting (South Africa) (Pty) Ltd Page xii ecosystem at the site which may be destroyed/damaged if measures are not taken to preserve these plants. By undertaking a plant search and rescue operation prior to the clearing of the site, the impact on conservation-important species would be mitigated. As the loss of Ngongoni Veld due to quarry establishment is accommodated in the approved Biodiversity Offset Report for the N2 Wild Coast Toll Highway (Botha & Brownlie, 2015), the loss of the vegetation type within the project footprint would be compensated for and the overall significance of the project impact on the conservation status of the vegetation type would be reduced. Economic efficiency The area surrounding the proposed quarry site is generally undeveloped with very limited socioeconomic opportunities. The proposed project would create local employment and business opportunities. These potential benefits to the local economy would extend over the operational lifespan of the proposed project. It is anticipated that a large number of the low- and semi-skilled employment opportunities could be sourced from the local labour force, especially during the site establishment phase. In terms of business opportunities for local companies, contract procurement requirements would create business opportunities for the regional and local economy. A percentage of the monthly wage bill earned by permanent staff would be spent in the regional and local economy, which would benefit local businesses. In light of the above, the proposed project is considered to be economically efficient, as it would provide an opportunity to utilise natural resources within the Eastern Cape with associated socioeconomic benefits. With the recommended enhancement measures, any possible negative impact associated with inward migration would be further reduced. Equity and social justice While the proposed project would require the relocation of people residing within the project footprint and the associated blasting zone (600m from the boundary of the quarry footprint), the relocation would be undertaken by the appointed land management specialist in accordance with the requirements of, amongst others, the Constitution of South Africa Act, 1996 (Act No. 108 of 1996) and the Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996), as applicable. These legislative provisions ensure, amongst others, that directly affected parties receive fair and equitable treatment and that no person shall be worse off when compared to their current situation. It is the opinion of SLR that, in terms of the sustainability criteria described above and the nature and extent of the proposed quarry activities, the generally LOW to MEDIUM significance residual impacts should support a positive decision being made by the Minister of Mineral Resources (or delegated authority) in this regard. 5.2 RECOMMENDATIONS It is recommended that the following conditions should be included in the Environmental Authorisation (EA), if a decision to grant an EA is issued: An Environmental Management Programme (EMP) for the construction and operational phases must be implemented for the duration of the proposed project (refer to the EMP attached as Appendix 6).

16 SLR Consulting (South Africa) (Pty) Ltd Page xiii Ensure that the existing Biodiversity Offset Agreement for the N2 Wild Coast Toll Highway, which accommodates the potential loss of primary Ngongoni Veld due to stockpiling and/or the establishment of borrow pits/quarries, is implemented effectively. A protected plant survey must be undertaken within the primary terrestrial Ngongoni grassland within the project footprint, in order to confirm the presence and abundance of threatened and protected plant species. This survey must be undertaken by a suitably qualified botanist, prior to the commencement of construction, during the summer growing season (between November and March). The protected plant survey must be used to develop a detailed protected plant rescue and translocation protocol for threatened and protected plants (based on the preliminary guidelines provided in Section 5.4 of the specialist terrestrial ecological report, attached as Appendix 4.1). Undertake a Baseline Water Quality Monitoring Survey prior to the commencement of construction activities in order to collect baseline data for the monitoring of water quality impacts associated with construction and operation of the quarry. Develop a detailed Stormwater Management Plan that describes how the design measures of surface and near-surface water management facilities will be designed, constructed and operated so that contaminated water is kept separate from clean water run-off through a system of berms, channels, trenches, flood and erosion protection measures. Relocate all households within the quarry footprint and 600 m from the quarry boundary. Monitor ground vibration and air blast to ensure that the generated levels of ground vibration and air blast comply with recommendations. The monitoring of ground vibration must qualify the expected ground vibration and air blast levels and assist in mitigating these aspects properly. Ten monitoring positions have been proposed by the blasting specialist (see Figure 18 and Table 17 of Appendix 4.3). Develop a comprehensive Rehabilitation and Closure Plan prior to the decommissioning and closure of the proposed quarry operation.

17 SLR Consulting (South Africa) (Pty) Ltd Page xiv TABLE OF CONTENTS DOCUMENT INFORMATION... i EXPERTISE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER... ii EXECUTIVE SUMMARY... iii TABLE OF CONTENTS... xiv ACRONYMS AND ABBREVIATIONS... xx PART A - FINAL ENVIRONMENTAL IMPACT REPORT 1. CONTACT PERSON AND CORRESPONDENCE ADDRESS DETAILS OF THE EAP WHO PREPARED THE REPORT EXPERTISE OF THE EAP DESCRIPTION OF THE PROPERTY LOCALITY MAP DESCRIPTION OF THE SCOPE OF THE PROPOSED OVERALL ACTIVITY LISTED AND SPECIFIED ACTIVITIES DESCRIPTION OF THE ACTIVITIES TO BE UNDERTAKEN PROJECT OVERVIEW QUARRY LAYOUT AND DEVELOPMENT WASTE MANAGEMENT WATER MANAGEMENT TRANSPORT POLICY AND LEGISLATIVE CONTEXT LEGISLATIVE REQUIREMENTS OVERVIEW OF THE ONE ENVIRONMENTAL SYSTEM MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (NEMA) NATIONAL WATER ACT, 1998 (NWA) NATIONAL HERITAGE RESOURCES ACT, 1999 (NHRA) NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT, 2004 (NEM:BA) GUIDELINES AND POLICIES NEED AND DESIRABILITY OF THE PROPOSED PROJECT MOTIVATION FOR THE PREFERRED DEVELOPMENT FOOTPRINT WITHIN THE APPROVED SITE INCLUDING THE PROCESS FOLLOWED TO DEFINE THE PREFERRED DEVELOPMENT ALTERNATIVES DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED PROPERTY ON WHICH OR LOCATION WHERE IT IS PROPOSED TO UNDERTAKE THE ACTIVITY TYPE OF ACTIVITY TO BE UNDERTAKEN DESIGN OR LAYOUT OF THE ACTIVITY TECHNOLOGY TO BE USED IN THE ACTIVITY OPERATIONAL ASPECTS OF THE ACTIVITY OPTION OF NOT IMPLEMENTING THE ACTIVITY... 17

18 SLR Consulting (South Africa) (Pty) Ltd Page xv 7.2. DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED SCOPING PHASE SUMMARY OF ISSUES RAISED BY I&APS THE ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE DEVELOPMENT FOOTPRINT ALTERNATIVES BASELINE ENVIRONMENT CLIMATE TOPOGRAPHY GEOLOGY AND SOILS BIODIVERSITY CULTURAL/HERITAGE ENVIRONMENT REGIONAL SOCIO-ECONOMIC ENVIRONMENT CURRENT LAND USES IMPACTS AND RISKS IDENTIFIED INCLUDING THE NATURE, SIGNIFICANCE, CONSEQUENCE, EXTENT, DURATION AND PROBABILITY OF THE IMPACTS POTENTIAL BIOPHYSICAL IMPACTS POTENTIAL SOCIO-ECONOMIC IMPACTS NO-GO ALTERNATIVE METHODOLOGY USED IN DETERMINING AND RANKING THE NATURE, SIGNIFICANCE, CONSEQUENCES, EXTENT, DURATION AND PROBABILITY OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS EXTENT DURATION INTENSITY SIGNIFICANCE STATUS OF IMPACT PROBABILITY DEGREE OF CONFIDENCE LOSS OF RESOURCES DEGREE TO WHICH IMPACT CAN BE MITIGATED REVERSIBILITY OF AN IMPACT THE POSITIVE AND NEGATIVE IMPACTS THAT THE PROPOSED ACTIVITY (IN TERMS OF THE INITIAL SITE LAYOUT) AND ALTERNATIVES WILL HAVE ON THE ENVIRONMENT AND THE COMMUNITY THAT MAY BE AFFECTED THE POSSIBLE MITIGATION MEASURES THAT COULD BE APPLIED AND THE LEVEL OF RISK MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED STATEMENT MOTIVATING THE ALTERNATIVE DEVELOPMENT LOCATION WITHIN THE OVERALL SITE FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED SITE ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK SUMMARY OF SPECIALIST REPORTS ENVIRONMENTAL IMPACT STATEMENT... 63

19 SLR Consulting (South Africa) (Pty) Ltd Page xvi SUMMARY OF THE KEY FINDINGS OF THE ENVIRONMENTAL IMPACT ASSESSMENT FINAL SITE MAP SUMMARY OF THE POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS OF THE PROPOSED ACTIVITY AND IDENTIFIED ALTERNATIVES PROPOSED IMPACT MANAGEMENT OBJECTIVES AND THE IMPACT MANAGEMENT OUTCOMES FOR INCLUSION IN THE EMPR FINAL PROPOSED ALTERNATIVES ASPECTS FOR INCLUSION AS CONDITIONS OF AUTHORISATION DESCRIPTION OF ANY ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY SHOULD OR SHOULD NOT BE AUTHORISED REASONS WHY THE ACTIVITY SHOULD BE AUTHORISED OR NOT CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION SPECIFIC CONDITIONS TO BE INCLUDED INTO THE COMPILATION AND APPROVAL OF EMPR REHABILITATION REQUIREMENTS PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED UNDERTAKING FINANCIAL PROVISION EXPLAIN HOW THE AFORESAID AMOUNT WAS DERIVED CONFIRM THAT THIS AMOUNT CAN BE PROVIDED FOR FROM OPERATING EXPENDITURE DEVIATIONS FROM THE APPROVED SCOPING REPORT AND PLAN OF STUDY DEVIATIONS FROM THE METHODOLOGY USED IN DETERMINING THE SIGNIFICANCE OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS MOTIVATION FOR THE DEVIATION OTHER INFORMATION REQUIRED BY THE COMPETENT AUTHORITY IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY AFFECTED PERSON IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF THE NATIONAL HERITAGE RESOURCES ACT OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT PART B - FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT 1. FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT DETAILS OF THE EAP DESCRIPTION OF THE ASPECTS OF THE ACTIVITY COMPOSITE MAP DESCRIPTION OF IMPACT MANAGEMENT OBJECTIVES DETERMINATION OF CLOSURE OBJECTIVES THE PROCESS FOR MANAGING ANY ENVIRONMENTAL DAMAGE, POLLUTION, PUMPING AND TREATMENT OF EXTRANEOUS WATER OR ECOLOGICAL DEGRADATION AS A RESULT OF UNDERTAKING A LISTED ACTIVITY POTENTIAL RISK OF ACID MINE DRAINAGE... 2

20 SLR Consulting (South Africa) (Pty) Ltd Page xvii INDICATE WHETHER OR NOT THE MINING CAN RESULT IN ACID MINE DRAINAGE STEPS TAKEN TO INVESTIGATE, ASSESS, AND EVALUATE THE IMPACT OF ACID MINE DRAINAGE ENGINEERING OR MINE DESIGN SOLUTIONS TO BE IMPLEMENTED TO AVOID OR REMEDY ACID MINE DRAINAGE MEASURES THAT WILL BE PUT IN PLACE TO REMEDY ANY RESIDUAL OR CUMULATIVE IMPACT THAT MAY RESULT FROM ACID MINE DRAINAGE VOLUMES AND RATE OF WATER USE REQUIRED FOR THE MINING, TRENCHING OR BULK SAMPLING OPERATION HAS A WATER USE LICENCE HAS BEEN APPLIED FOR? IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES IMPACT MANAGEMENT OUTCOMES IMPACT MANAGEMENT ACTIONS FINANCIAL PROVISION DETERMINATION OF THE AMOUNT OF FINANCIAL PROVISION DESCRIBE THE CLOSURE OBJECTIVES AND THE EXTENT TO WHICH THEY HAVE BEEN ALIGNED TO THE BASELINE ENVIRONMENT DESCRIBED UNDER REGULATION 22 (2) (D) CONFIRM SPECIFICALLY THAT THE ENVIRONMENTAL OBJECTIVES IN RELATION TO CLOSURE HAVE BEEN CONSULTED WITH LANDOWNER AND INTERESTED AND AFFECTED PARTIES PROVIDE A REHABILITATION PLAN THAT DESCRIBES AND SHOWS THE SCALE AND AERIAL EXTENT OF THE MAIN MINING ACTIVITIES, INCLUDING THE ANTICIPATED MINING AREA AT THE TIME OF CLOSURE COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE OBJECTIVES CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION REQUIRED TO MANAGE AND REHABILITATE THE ENVIRONMENT IN ACCORDANCE WITH THE APPLICABLE GUIDELINE CONFIRM THAT THE FINANCIAL PROVISION WILL BE PROVIDED AS DETERMINED MECHANISMS FOR MONITORING COMPLIANCE WITH AND PERFORMANCE ASSESSMENT AGAINST THE ENVIRONMENTAL MANAGEMENT PROGRAMME AND REPORTING INDICATE THE FREQUENCY OF THE SUBMISSION OF THE PERFORMANCE ASSESSMENT REPORT ENVIRONMENTAL AWARENESS PLAN MANNER IN WHICH THE APPLICANT INTENDS TO INFORM HIS OR HER EMPLOYEES OF ANY ENVIRONMENTAL RISK WHICH MAY RESULT FROM THEIR WORK MANNER IN WHICH RISKS WILL BE DEALT WITH IN ORDER TO AVOID POLLUTION OR THE DEGRADATION OF THE ENVIRONMENT SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY UNDERTAKING... 15

21 SLR Consulting (South Africa) (Pty) Ltd Page xviii List of Appendices Appendix 1: CVs and Proof of Registration of the EAP Appendix 2: DMR Acceptance of the Scoping Report Appendix 3: Public Participation Process Appendix 3.1: I&AP Database Appendix 3.2: I&AP Notification letters Appendix 3.3: I&AP Correspondence Appendix 3.4: Comments and Responses Report Appendix 4: Specialist Reports Appendix 4.1: Terrestrial and Aquatic Ecosystems Appendix 4.2: Blasting Impact Appendix 4.3: Cultural Heritage Appendix 5: Undertaking Appendix 6: EMP List of Figures FIGURE 3-1: REGIONAL SETTING OF THE PROPOSED QUARRY SITE... 3 FIGURE 4-1: SITE PLAN OF THE PROPOSED QUARRY FIGURE 7-1: GOOGLE EARTH IMAGE OF THE IDENTIFIED ALTERNATIVE SITES FOR THE PROPOSED QUARRY (THE PREFERRED ALTERNATIVE IS SHADED RED) FIGURE 8-1: CRITICAL BIODIVERSITY AREAS IN THE BROADER STUDY AREA. THE PROPOSED QUARRY LOCATION IS INDICATED AS A BLUE DOT (SOURCE: SANBI BIODIVERSITY GIS, 2016) FIGURE 8-2: IDENTIFIED VEGETATION COMMUNITIES WITHIN THE STUDY AREA FIGURE 8-3: MAPPED WATERCOURSE UNITS WITHIN 500 M OF THE PROPOSED QUARRY FOOTPRINT AREA FIGURE 8-4: IDENTIFIED SCHOOLS, POLICE STATIONS AND HEALTH CARE FACILITIES WITHIN THE BROADER STUDY AREA List of Tables TABLE 4-1: LIST OF ACTIVITIES/INFRASTRUCTURE ASSOCIATED WITH THE PROPOSED PROJECT... 4 TABLE 5-1: LIST OF POSSIBLE WATER USE ACTIVITIES IN TERMS OF THE NWA TABLE 5-2: GUIDELINES AND POLICIES RELEVANT TO THE PROPOSED PROJECT TABLE 7-1: POTENTIAL ALTERNATIVE QUARRY SITES INITIALLY INVESTIGATED FOR DEVELOPMENT (THE PREFERRED SITE IS SHADED) TABLE 8-1: ASSESSMENT OF THE POTENTIAL IMPACT ON SOIL AND LAND CAPABILITY TABLE 8-2: ASSESSMENT OF THE POTENTIAL IMPACT ASSOCIATED WITH THE LOSS OF VEGETATION. 37 TABLE 8-3: ASSESSMENT OF THE POTENTIAL IMPACT ASSOCIATED WITH THE LOSS OF FAUNA AND ALTERATION OF FAUNAL HABITAT TABLE 8-4: ASSESSMENT OF THE POTENTIAL IMPACTS ON SURFACE WATER FEATURES TABLE 8-5: ASSESSMENT OF THE POTENTIAL IMPACTS ON AIR QUALITY TABLE 8-6: ASSESSMENT OF THE POTENTIAL IMPACTS ON AMBIENT NOISE LEVELS TABLE 8-7: ASSESSMENT OF THE POTENTIAL IMPACT ON HERITAGE RESOURCES TABLE 8-8: ASSESSMENT OF THE POTENTIAL IMPACT ON ROAD TRAFFIC TABLE 8-9: ASSESSMENT OF THE POTENTIAL BLASTING IMPACTS TABLE 8-10: ASSESSMENT OF THE POTENTIAL IMPACT ON LAND USE TABLE 8-11: ASSESSMENT OF THE POTENTIAL SOCIAL IMPACT RELATED TO EMPLOYMENT AND THE CREATION OF BUSINESS OPPORTUNITIES DURING OPERATION

22 SLR Consulting (South Africa) (Pty) Ltd Page xix TABLE 8-12: ASSESSMENT OF THE POTENTIAL SOCIAL IMPACT RELATED TO THE INFLUX OF OPERATION WORKERS TABLE 8-13: ASSESSMENT OF THE POTENTIAL IMPACTS RELATED TO THE NO-GO ALTERNATIVE TABLE 10-1: SUMMARY OF THE SIGNIFICANCE OF THE POTENTIAL IMPACTS ASSOCIATED WITH THE PROPOSED QUARRY OPERATIONS AND NO-GO ALTERNATIVE

23 SLR Consulting (South Africa) (Pty) Ltd Page xx ACRONYMS AND ABBREVIATIONS Below a list of acronyms and abbreviations used in this report. Acronyms / Meaning Abbreviations CBA Critical Biodiversity Area DMR Department of Mineral Resources DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner ECPHRA Eastern Cape Provincial Heritage Resources Authority EIR EMP Environmental Management Programme EMPR Environmental Management Programme Report GN Government Notice I&AP Interested and Affected Party IEM Integrated Environmental Management MPRDA Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002) NEMA National Environmental Management Act, 1998 (No. 107 of 1998) NEM:BA National Environmental Management: Biodiversity Act, 2004 (No. 10 of 2004) NWA National Water Act, 1998 (No. 36 of 1998) SANRAL South African National Roads Agency SOC Ltd SLR SLR Consulting (South Africa) (Pty) Ltd

24 PART A FINAL ENVIRONMENTAL IMPACT REPORT

25 SLR Consulting (South Africa) (Pty) Ltd Page 1 1. CONTACT PERSON AND CORRESPONDENCE ADDRESS 1.1. DETAILS OF THE EAP WHO PREPARED THE REPORT The contact details of the Environmental Assessment Practitioner (EAP) who prepared this Final (EIR) and Environmental Management Programme Report (EMPR) are provided below. Neither SLR Consulting (South Africa) (Pty) Ltd (SLR) nor any of the specialists involved in the environmental assessment process have any interest in the proposed project other than fair remuneration for consulting services rendered as part of the environmental assessment process. EAP: Contact Person: SLR Consulting (South Africa) (Pty) Ltd Fuad Fredericks Postal Address PO Box Caledon Square Postal Code: 7905 Telephone Cell: - ffredericks@slrconsulting.com Fax: EXPERTISE OF THE EAP The expertise of the individuals who were involved in the preparation of this Final EIR and EMPR are provided on Page ii. The relevant curricula vitae and proof of registrations of the EAP are provided in Appendix DESCRIPTION OF THE PROPERTY The South African National Roads Agency SOC Ltd (SANRAL) is proposing to develop a quarry within the Ngquza Hill Local Municipality in the Eastern Cape Province. Details regarding the location of the proposed quarry are provided below. Farm Name Corner of property point coordinates Un-alienated state land. A 31 11' 43.09" S 29 49' 3.78" E B 31 11' 43.89" S 29 49' 9.42" E C 31 11' 47.18" S 29 49' 14.08" E D 31 12' 7.31" S 29 49' 31.33" E E 31 12' 11.95" S 29 49' 27.92" E F 31 12' 12.98" S 29 49' 26.70" E G 31 12' 13.22" S 29 49' 24.32" E H 31 12' 12.95" S 29 49' 21.18" E I 31 12' 12.37" S 29 49' 18.14" E J 31 12' 12.22" S 29 49' 15.30" E K 31 12' 12.81" S 29 49' 12.03" E L 31 12' 14.95" S 29 49' 9.81" E M 31 12' 9.51" S 29 49' 5.33" E

26 SLR Consulting (South Africa) (Pty) Ltd Page 2 Corner of property point coordinates Application area (ha) Magisterial district Tribal Authority Distance and direction from nearest town 21 digit Surveyor General Code for each farm portion N 31 12' 3.62" S 29 49' 1.00" E O 31 12' 0.07" S 29 48' 59.92" E P 31 11' 57.32" S 29 49' 3.34" E Q 31 11' 52.72" S 29 49' 3.46" E R 31 11' 48.23" S 29 49' 2.20" E 50 hectares (ha) Flagstaff Sipaqeni Traditional Authority Flagstaff (located approximately 34 km to the north-west) is the nearest town. Not applicable. 3. LOCALITY MAP The regional setting of the study area indicating the locality of the proposed quarry site is provided in Figure 3-1 overleaf. 4. DESCRIPTION OF THE SCOPE OF THE PROPOSED OVERALL ACTIVITY Provide a plan drawn to a scale acceptable to the competent authority but not less than 1: that shows the location, and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site. SANRAL has commenced with preparations for construction of the greenfields sections of the N2 Wild Coast Toll Highway project. Such preparations include the identification of potential quarry site locations for the sourcing of the necessary construction materials for the Mthentu and Msikaba river bridges and other required works on the N2 Wild Coast Toll Highway. Based on the outcomes of preliminary geotechnical investigations, a suitable site for the establishment of a quarry has been identified within the Ngquza Hill Local Municipality in the Eastern Cape Province. Accordingly, SANRAL is now proposing to establish a quarry at this site. A description of the proposed quarry and associated activities is provided in Section 4.2 below LISTED AND SPECIFIED ACTIVITIES The EIA Regulations 2014 promulgated in terms of Chapter 5 of National Environmental Management Act (NEMA), 1998 (Act 107 of 1998), and published in Government Notice (GN) No. R982, provides for the control of certain listed activities 1. These activities are listed in GN No. R983 (Listing Notice 1), R984 (Listing Notice 2) and R985 (Listing Notice 3) of 4 December 2014, and are prohibited until Environmental Authorisation has been obtained from the competent authority. The Minister of Mineral Resources remains responsible for the granting of Environmental Authorisation for Mining Right Applications in terms of NEMA. Such Environmental Authorisation, which may be granted subject to conditions, will only be considered once there has been compliance with GN No. R982 (as amended). 1 Subsequent to the distribution of the Draft EIA and EMPR Report for comment, the EIA Regulations 2014, Listing Notices 1, 2 and 3 were amended by GN No. R.326, R.327, R 325, and R.324 of 7, respectively. These amendments have been duly taken into account in the compilation of this final report.

27 SLR Consulting (South Africa) (Pty) Ltd Figure 3-1: Page 3 Regional setting of the proposed quarry site.

28 SLR Consulting (South Africa) (Pty) Ltd Page 4 GN No. R982 (as amended) sets out the procedures and documentation that need to be complied with when applying for Environmental Authorisation. A Basic Assessment process must be applied to an application if the authorisation applied for is in respect of an activity(ies) listed in Listing Notice 1 and / or 3 (as amended) and a Scoping and Environmental Impact Assessment (EIA) process must be applied to an application if the authorisation applied for is in respect of an activity(ies) listed in Listing Notice 2 (as amended). The proposed project triggers various activities contained in Listing Notices 1, 2 and 3, as amended (see Table 4-1), thus a full Scoping and EIA process must be undertaken in order for the Department of Mineral Resources (DMR) to consider the application in terms of NEMA and make a decision as to whether to grant or refuse Environmental Authorisation. Where applicable, the listed activities described in Table 4-1 have been updated to incorporate the amendments included in GN No. R.327, R. 325, and R.324 of 7. Table 4-1: List of activities/infrastructure associated with the proposed project NAME OF ACTIVITY Construction of proposed access road to the quarry site. APPROXIMATE AERIAL EXTENT OF THE ACTIVITY LISTED ACTIVITY NUMBER AND LISTING NOTICE, AS AMENDED The development of - (ii) infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs - (a) within a watercourse The development of a road wider than 4 metres with a reserve less than 13.5 metres: (a) In Eastern Cape: ii. Within critical biodiversity areas identified in bioregional plans The development of - (ii) infrastructure or structures with a physical footprint of 10 square metres or more; where such development occurs - (a) within a watercourse (a) In Eastern Cape: i. Outside urban areas, in: (ff) Critical biodiversity areas or ecosystem service areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans Fuel storage. Greater than 100 m 2 GNR 983 (Activity 12 of Listing Notice 1) Approximately 0.4 ha GNR 985 (Activity 4 of Listing Notice 3) Greater than GNR 985 (Activity m 2 of Listing Notice 3) The development of facilities or infrastructure, for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 cubic metres or more but not exceeding 500 cubic metres. The development of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres: (a) In Eastern Cape: i. Outside urban areas, in: (ee) Critical biodiversity areas as identified in systematic Approximately 2 ha GNR 983 (Activity 14 of Listing Notice 1) GNR 985 (Activity 10 of Listing Notice 3)

29 SLR Consulting (South Africa) (Pty) Ltd Page 5 NAME OF ACTIVITY biodiversity plans adopted by the competent authority or in bioregional plans; (ii) Areas on the watercourse side of the development setback line or within 100 metres from the edge of a watercourse where no such setback line has been determined Establishment of the contractor s camp and stockpiles. APPROXIMATE AERIAL EXTENT OF THE ACTIVITY LISTED ACTIVITY NUMBER AND LISTING NOTICE, AS AMENDED The infilling or depositing of any material of more than 10 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 cubic metres from - (i) a watercourse Site clearance for the establishment of the proposed quarry and associated infrastructure. The clearance of an area of 20 hectares or more of indigenous vegetation The clearance of an area of 300 square metres or more of indigenous vegetation (a) In Eastern Cape: ii. Within critical biodiversity areas identified in bioregional plans Operation of the proposed quarry. Approximately 2 ha 50 ha GNR 983 (Activity 19 of Listing Notice 1) GNR 983 (Activity 15 of Listing Notice 2) GNR 985 (Activity 12 of Listing Notice 3) Any activity including the operation of that activity which requires a mining right as contemplated in Section 22 of the Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002), including (a) associated infrastructure, structures and earthworks, directly related to the extraction of a mineral resource; or (b) the primary processing of a mineral resource including winning, extraction, classifying, concentrating, crushing, screening or washing; Decommissioning of the mining activities following the completion of mine operations. 50 ha GNR 984 (Activity 17 Listing Notice 2) The decommissioning of any activity requiring - (i) a closure certificate in terms of section 43 of the Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002); or (ii) a mining right where the throughput of the activity has reduced by 90% or more over a period of 5 years excluding where the competent authority has in writing agreed that such reduction in throughput does not constitute closure. 50 ha GNR 983 (Activity 22 of Listing Notice 1)

30 SLR Consulting (South Africa) (Pty) Ltd Page DESCRIPTION OF THE ACTIVITIES TO BE UNDERTAKEN Describe methodology or technology to be employed, including the type of commodity to be prospected/mined and for a linear activity, a description of the route of the activity. Including associated structures and infrastructure PROJECT OVERVIEW As noted above, SANRAL is proposing to establish a quarry to provide the necessary construction materials for the Mthentu and Msikaba river bridges and other works on the N2 Wild Coast Toll Highway. The proposed project would entail the establishment of a quarry, various associated stockpiles, a contractor s camp and an access road (see Figure 4-1). The total footprint of the area to be developed is anticipated to be approximately 50 ha, with the proposed quarry being about 25 ha in extent. The following key facilities associated with the contractor s camp are currently planned: Offices: Ablution facilities; Workshop; Stores; Fuel storage; Concrete batching; and; Crushing and processing plant. In addition to the required road within the confines of the quarry site, the proposed access road would link the quarry to the Holy Cross Mkambati road situated on the south-eastern boundary of the site QUARRY LAYOUT AND DEVELOPMENT The proposed quarry could be either operated by a single operator or two operators simultaneously, thus the site layout has been designed to make provision for two separate quarrying areas (Primary Quarry and Secondary Quarry) that could be worked independently of each other. In the scenario that two operators are involved, the Primary Quarry area would be worked by one operator along the east-west face and the second operator would independently work the Secondary Quarry along the south-north face. The excavated material from each quarry area would then be processed by the crushing plant located on the site. The processed material would be stockpiled and then loaded onto haul vehicles for transport to the bridge construction and other sites. Material that is not suitable for use in the construction of the bridges or other works would be stockpiled separately for use in the reshaping of the site during rehabilitation. Where two operators are involved at the site, each operator would be responsible for the rehabilitation of their respective operational areas (i.e. the separate Primary and Secondary quarry areas, respectively), as well as their portion of the overall site. Vegetation would be cleared from the site as the quarry is developed, with any seed-bearing material to be kept separate for use during rehabilitation or preferably mulched into the topsoil. Topsoil would, where possible, be stripped to an appropriate depth and stockpiled separately from other soil layers in piles not exceeding 2 m in height. To minimise any impacts on the surrounding land, the extent of the area disturbed during the operations would be limited as far as possible. In this regard, the quarry and associated activities and infrastructure would be carefully planned to ensure that the footprint is kept to a minimum and remains within the confines of the site.

31 SLR Consulting (South Africa) (Pty) Ltd Page 7 SECONDARY STOCKPILE CRUSHING PLANT SECONDARY QUARRY CONTRACTOR CAMP PRIMARY QUARRY PRIMARY STOCKPILE AREA BACKUP STOCKPILE Figure 4-1: Site plan of the proposed quarry.

32 SLR Consulting (South Africa) (Pty) Ltd Page WASTE MANAGEMENT Domestic waste generated during the course of the quarry operations would be collected and stored in suitable receptacles on-site for collection and disposal at an appropriately licensed municipal waste site or acceptable disposal facility WATER MANAGEMENT It is anticipated that water would be required for dust suppression (on stockpiles and the access road) and ancillary activities associated with the quarry operations (e.g. washing of vehicles and equipment). The proposed source(s) and anticipated volumes required for the proposed project are not known at this stage. The Contractor(s) to be appointed for the operation of the quarry would be responsible for determining suitable water sources and obtaining any permits, licence and/or authorisations which may also be applicable for the abstraction of water from these sources, as appropriate TRANSPORT As mentioned above, it is proposed that an access road would be established to link the proposed quarry site with the Holy Cross - Mkambati Road. The proposed access road would cross a watercourse. The project engineer has recommended that the proposed water crossing be a low-level river crossing structure comprising five box culverts and positioned at the centre of the river. It was further recommended that the road section located to the east of the river crossing be surfaced with concrete, while the road section to the west of the river could be a gravel surface. The proposed access road would facilitate the transport of material by truck from the site to the bridge construction and other areas. 5. POLICY AND LEGISLATIVE CONTEXT An overview of the key legislative requirements applicable to the proposed project is provided below LEGISLATIVE REQUIREMENTS OVERVIEW OF THE ONE ENVIRONMENTAL SYSTEM The One Environmental System commenced on 8 December 2014, removing the environmental regulation of prospecting, mining, exploration and production and related activities from the Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002) (MPRDA) and transferring it to NEMA. Under the One Environmental System, the Minister of Mineral Resources (or delegated authority) is the competent authority responsible for issuing Environmental Authorisations in terms of NEMA for mining and petroleum related activities. The Minister of Environmental Affairs, however, remains the appeal authority for these authorisations MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) In terms of the MPRDA, a Mining Right must be obtained prior to the commencement of any mining activities.

33 SLR Consulting (South Africa) (Pty) Ltd Page 9 A requirement for obtaining a Mining Right is that an applicant must submit an application in terms of Section 22(1) of the MPRDA to the Regional Manager, who must accept the application within 14 days if, inter alia, no other person holds a Prospecting Right, Mining Right, Mining Permit or Retention Permit for the same mineral and land. If the application for a Mining Right is accepted, the Regional Manager must request that the applicant comply with Chapter 5 of NEMA with regards to consultation and reporting (see Section below). It is noted that in terms of Section 106 of the MPRDA, SANRAL is exempted from applying for a Mining Right to develop a quarry for the purposes of sourcing road building material. However, SANRAL is still required to obtain Environmental Authorisation in terms of NEMA. In this regard, SANRAL lodged an Application for Environmental Authorisation with the DMR on 5 September DMR accepted the application on 10 October 2016 (see Appendix 2) NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (NEMA) Section 2 of NEMA sets out a range of environmental principles that are to be applied by all organs of state when taking decisions that significantly affect the environment. Included amongst the key principles is that all development must be socially, economically and environmentally sustainable and that environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably. NEMA also provides for the participation of Interested and Affected Parties (I&APs) and stipulates that decisions must take into account the interests, needs and values of all I&APs. Chapter 5 of NEMA outlines the general objectives and implementation of Integrated Environmental Management (IEM), which provides a framework for the integration of environmental issues into the planning, design, decision-making and implementation of plans and development proposals. Section 24 provides a framework for granting of Environmental Authorisations. In order to give effect to the general objectives of IEM, the potential impacts on the environment of listed activities must be considered, investigated, assessed and reported on to the competent authority. Section 24(4) provides the minimum requirements for procedures for the investigation, assessment and communication of the potential impact of activities. A summary of the EIA Regulations 2014, as amended, and an outline of the identified listed activities which are triggered in terms of these regulations are provided in Section 4.1 above NATIONAL WATER ACT, 1998 (NWA) The National Water Act, 1998 (No. 36 of 1998) (NWA) provides a legal framework for the effective and sustainable management of water resources 4 in South Africa. It serves to protect, use, develop, conserve, manage and control water resources as a whole, promoting the integrated management of water resources with the participation of all stakeholders. In terms of this Act, all water resources are the property of the State and the Scoping and EIA process is used as a fundamental management tool. A Water Use Licence is required for any new water use that is not listed in Schedule 1 or that is not covered by a General Authorisation. Water uses that may require Water Use Licensing or General Authorisation are listed in Table 5-1. A Water Use Licence Application (WULA) would need to be submitted to the Department of Water and Sanitation (DWS) Eastern Cape Regional Office for approval, if these activities are not considered to be Generally Authorised. 4 A water resource includes a watercourse, surface water, estuary or aquifer, and, where relevant, its bed and banks. A watercourse means a river or spring; a natural channel in which water flows regularly or intermittently; a wetland, lake or dam, into which or from which water flows; and any collection of water that the Minister may declare to be a watercourse.

34 SLR Consulting (South Africa) (Pty) Ltd Page 10 The terrestrial and aquatic ecosystems specialist deems that a WULA for the water use activities specified in Table 5-1 below, at a minimum, would be required for the proposed quarry as the risk of altering the characteristics of downstream watercourses may be deemed Moderate (even with appropriate mitigation) according to the DWS Risk Matrix/Assessment method applied to the project. In terms of the recent General Authorisation (GA) Regulations (GN No. 509 of 26 August 2016), published in terms of Section 39 of the NWA for Section 21(c) and/or (i) water use, a number of activities are Generally Authorised for State Owned Companies (SOC s) and institutions. These activities are then subject only to compliance with the conditions of the GA, including all maintenance of bridges over rivers, streams and wetlands and the new construction of bridges done according to the SANRAL Drainage Manual or similar norms and standards. Thus, it is deemed that SANRAL would not be required to apply for a WULA for the proposed access road over the KwaDlambu River, as it would be authorised under the GA, subject to compliance with the necessary conditions. Furthermore, as mentioned in Section above, the Contractor(s) to be appointed for the operation of the quarry would be responsible for determining suitable water sources and obtaining any permits, licence and/or authorisations which may also be applicable for the abstraction of water from these sources, as appropriate. Table 5-1: List of possible water use activities in terms of the NWA. Water Use No. 21(c) 21(i) Water Use Description Impeding and diverting the flow of water in a watercourse Altering the bed, banks, course or characteristics of a watercourse Description of the water use in relation to the proposed project The establishment of the proposed quarry may impact on water resources within the project site and surrounds. In addition, the proposed access road would pass through a watercourse located on the eastern boundary of the site. These project components may require the impeding of water and / or altering of the bed and banks of the watercourse NATIONAL HERITAGE RESOURCES ACT, 1999 (NHRA) Section 38(1) of the National Heritage Resources Act (NHRA) (No. 25 of 1999) lists development activities that would require authorisation by the responsible heritage resources authority. The activity applicable to the proposed project is the following: (c) Any development or other activity which will change the character of a site: (i) exceeding m 2 in extent. The NHRA requires that a person who intends to undertake a listed activity must notify the relevant heritage authority at the very earliest stages of initiating such a development. The relevant heritage authority would then, in turn, notify the person whether a Heritage Impact Assessment Report should be submitted. However, according to Section 38(8) of the NHRA, a separate report would not be necessary if an evaluation of the impact of such development on heritage resources is required in terms of any other applicable legislation. The decision-making authority should, however, ensure that the heritage evaluation fulfils the requirements of the NHRA and take into account in its decision-making any comments and recommendations made by the relevant heritage resources authority. In terms of Section 34(1) of the Act, no person may, without a permit issued by the responsible heritage resources authority, alter or demolish any structure or part of a structure which is older than 60 years.

35 SLR Consulting (South Africa) (Pty) Ltd Page 11 Also, in terms of Section 35(4) of the Act, no person may, without a permit issued by the responsible heritage resources authority, destroy, damage, excavate, alter or remove from its original position, or collect, any archaeological material or object. Furthermore, some grave sites are associated with existing residences within the proposed quarry site. In terms of Section 36(3) of the Act, no person may, without a permit issued by the responsible heritage resources authority, destroy, damage, alter, exhume or remove from its original position or otherwise disturb any grave or burial ground older than 60 years, which is situated outside a formal cemetery administered by a local authority. Human remains that are less than 60 years old are subject to provisions of the Human Tissue Act 1983 (No. 65 of 1983) and any other applicable local regulations. The specialist heritage study has been undertaken in compliance with the NHRA as required and will be lodged with the Eastern Cape Provincial Heritage Resources Authority (ECPHRA) as the competent heritage authority NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY ACT, 2004 (NEM:BA) The National Environmental Management: Biodiversity Act, 2004 (No. 10 of 2004) (NEM:BA) provides for the management and conservation of South Africa s biodiversity and the protection of species and ecosystems that warrant national protection. NEM:BA regulates the carrying out of restricted activities that may harm listed threatened or protected species or activities that encourage the spread of alien or invasive species subject to a permit. The list of restricted activities relate to the keeping, moving, having in possession, importing, exporting and selling of species. NEM:BA also makes provision for the publication of bioregional plans and the listing of ecosystems and species that are threatened or in need of protection. Threatened or Protected Species Regulations (2007), Guidelines for the Determination of Bioregions and the Preparation and Publication of Bioregional Plans (2009) and a National List of Ecosystems that are Threatened and in Need of Protection (2011) have been promulgated in terms of NEM:BA. Within the published bioregional (spatial) plans, terrestrial and aquatic features that are critical for conserving biodiversity and maintaining ecosystem functioning are indicated as Critical Biodiversity Areas (CBAs). Bioregional plans thus provide the guidelines for avoiding the loss or degradation of natural habitat in CBAs with the aim of informing EIA processes and land-use planning (including Environmental Management Frameworks (EMFs), Spatial Development Frameworks (SDFs), and Integrated Development Plans (IDPs)). CBAs mapped in terms of the Eastern Cape Biodiversity Conservation Plan are discussed in Section GUIDELINES AND POLICIES The guidelines and policies listed in Table 5-2 have been taken into account during the Scoping and EIA process.

36 SLR Consulting (South Africa) (Pty) Ltd Page 12 Table 5-2: Guidelines and policies relevant to the proposed project. Guideline Scoping, Integrated Environmental Management, Information Series 2 (2002) Stakeholder Engagement, Integrated Environmental Management, Information Series 3 (2002) IEM Guideline Series (Guideline 7): Public participation in the EIA process (2012) Specialist Studies, Integrated Environmental Management, Information Series 4 (2002) Impact significance, Integrated Environmental Management, Information Series 5 (2002) Cumulative Effects Assessment, Integrated Environmental Management, Information Series 7 (2004) Criteria for determining Alternatives in EIA, Integrated Environmental Management, Information Series 11 (2004) Environmental Management Plans, Integrated Environmental Management, Information Series 12 (2004) IEM Guideline Series (Guideline 9): Guideline on Need and Desirability (2014) Governing body DEA DEA DEA DEA DEA DEA DEA DEA Applicability This guideline was consulted to obtain guidance on how to implement scoping. These public participation guidelines were consulted to ensure that an adequate public participation process was undertaken. This guideline was consulted to ensure adequate development of terms of reference for specialist studies. This guideline was consulted to inform the assessment of significance of impacts of the proposed project. This guideline was consulted to inform the consideration of potential cumulative effects of the proposed project. This guideline was consulted to inform the consideration of alternatives. This guideline was consulted to ensure that the Environmental Management Programme (EMPR) has been adequately compiled. This guideline was consulted to inform the need and desirability aspects of the proposed project. 6. NEED AND DESIRABILITY OF THE PROPOSED PROJECT Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location As noted previously, the proposed quarry is required for the sourcing of materials to facilitate the construction of the Mthentu and Msikaba river bridges and other works associated with the proposed N2 Wild Coast Toll Highway. The rationale for the N2 Wild Coast Toll Highway project is to provide an improved, shorter and safer road link between the Eastern Cape/Western Cape and KwaZulu-Natal and is considered of strategic importance to the region and the country as a whole. Given that large volumes of construction materials would be required for the project, the development of a local source for this material is considered to be highly beneficial. It is deemed that obtaining the required quality of material from commercial sources would be expensive, as the closest commercial sources are located a considerable distance (up to 200 km away) from the bridge construction areas. Substantial cost savings would accrue to the project by eliminating the cost of transportation of large volumes of material from existing commercial sources. Added advantages for the establishment of a local source of material include avoiding negative impacts on road safety of the surrounding road network by the presence of haul vehicles and reducing air pollution emissions from haul trucks by reducing haul distances. On completion of the N2 Wild Coast Highway construction, it is possible that the local community may take ownership of the quarry site. The final use of the quarry site, and the related closure objectives, will be determined in consultation with the local communities via the SANRAL-appointed land management specialist.

37 SLR Consulting (South Africa) (Pty) Ltd Page MOTIVATION FOR THE PREFERRED DEVELOPMENT FOOTPRINT WITHIN THE APPROVED SITE INCLUDING THE PROCESS FOLLOWED TO DEFINE THE PREFERRED DEVELOPMENT ALTERNATIVES 7.1. DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED PROPERTY ON WHICH OR LOCATION WHERE IT IS PROPOSED TO UNDERTAKE THE ACTIVITY According to the design engineer, the primary rationale behind the selection of the preferred site alternative relate to the area available to establish the proposed quarry, topography, level of existing development, and availability and quantity of suitable material. The locality of the identified alternative quarry sites which were investigated by the design engineer are illustrated in Figure 7-1 overleaf. The preferred site alternative is considered to be sufficiently large to allow for the stockpiling of material, as well as the establishment of the contractor s camp and placement of crushing equipment (previous experience has shown that for a project of this nature, an area in excess of 40 ha is required). Secondly, the site has a topography suitable for quarry development and is relatively undeveloped (in comparison to other potential quarry sites identified). Lastly, the laboratory test results undertaken have indicated that the Dwyka Formation tillite underlying the site is considered suitable for use as fine and coarse concrete aggregate. The rationale for the exclusion of other possible alternative sites which were investigated is provided in Table 7-1. Table 7-1: Potential alternative quarry sites initially investigated for development (the preferred site is shaded). Site SQ1 SQ2 Material Source Dwyka Formation Tillite Dwyka Formation Tillite Latitude Longitude Suitability 31 11'51.06"S 29 49'7.83"E 31 12'7.36"S This site is considered to be the most suitable for the following reasons: The site is relatively undeveloped; There is a large enough area to undertake the proposed quarry operations; There is sufficient quantities of unweathered rock available; The site is relatively close to both bridge construction sites (within 15km) and other works '31.91"E While the site is possibly suitable (given it is located close to both bridge construction sites and suitable material is present) it is currently not preferred due to: Insufficient space to incorporate all activities associated with the quarry operations; and The topography of the site would make quarrying difficult and costly. However, it is possible that SANRAL may wish to establish an additional quarry at this site in the future. A separate environmental authorisation

38 SLR Consulting (South Africa) (Pty) Ltd Page 14 Site NQ6 Flagstaff Holy Cross Mtonjeni Mtentu South Approach Mtentu North Approach Msikaba South Approach Msikaba North Approach Mahana Makwateni Mpetsheni Telawayeka Mtontsasa Material Source Dwyka Formation Tillite Karoo Dolerite Karoo Dolerite Msikaba Formation Sandstone Msikaba Formation Sandstone Msikaba Formation Sandstone Msikaba Formation Sandstone Msikaba Formation Sandstone Msikaba Formation Sandstone Msikaba Formation Sandstone Karoo Dolerite Dwyka Formation Tillite Karoo Dolerite Latitude Longitude Suitability process will then be undertaken in this regard. 31 4'22.59"S 29 57'0.32"E Establishing a quarry on this site is not considered feasible due to: Space constrains; and Close proximity to a school. 31 4'9.83"S 29 32'56.11"E Establishing a quarry on this site is not considered possible due to: The large haul distance to the bridge construction sites (greater than 50 km); and An Eskom substation has recently been constructed on the site. 31 7'22.47"S 29 34'26.45"E Establishing a quarry on this site is not considered possible due to: The large haul distance to the bridge construction sites (greater than 50 km); and An extensive layer (30 m deep) of poor quality overburden overlaying the required source materials '15.42"S 29 51'35.17"E The availability of suitable materials has not yet been confirmed at this site. Thus, the site cannot be considered at this stage '18.67"S 29 55'43.85"E Establishing a quarry on this site is not considered possible as the quality of the source material is substandard. 31 9'57.51"S 29 56'7.58"E Establishing a quarry on this site is not considered possible as the quality of the source material is substandard '49.64"S 29 47'24.30"E Establishing a quarry on this site is not considered possible as the quality of the source material is substandard and not available in sufficient quantities '18.08"S 29 48'4.60"E Establishing a quarry on this site is not considered possible as the quality of the source material is substandard. 31 9'29.55"S 30 1'32.15"E Establishing a quarry on this site is not considered possible as the quality of the source material is substandard. 31 7'47.62"S 29 59'34.91"E Establishing a quarry on this site is not considered possible as the quality of the source material is substandard. 31 0'20.30"S 29 48'15.82"E Establishing a quarry on this site is not considered possible due to: The presence of excessive overburden; and The quantity of available material is inadequate '9.49"S 29 44'44.71"E Establishing a quarry on this site is not considered possible as the local communities denied access to the site for physical testing '32.40"S 29 41'24.05"E The availability of suitable materials has not yet been confirmed at this site. Thus, the site cannot be considered at this stage.

39 SLR Consulting (South Africa) (Pty) Ltd Page 15 Figure 7-1: Google Earth Image of the identified alternative sites for the proposed quarry (the preferred alternative is shaded red).