BASIC ASSESSMENT REPORT – DRAFT 1

MINING PERMIT
Application to mine sand over a 4,98ha section of the Remainder of Farm Manor Grange 16593 situated within the
Ugu District Municipality, Southern KwaZulu-Natal.

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL

ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL
MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN
TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES
DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).

Prepared for Prepared by

The Snyman Family Trust

Representative: Mr. Pieter

Snyman FMI House,
2 Heleza Blvd,
Sibaya

031 566 2858

[email protected]

DMRE EIA Reference Number: KZN 30/5/1/3/2/10754 MP

March 2021
 1. IMPORTANT NOTICE

In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), the Minister
must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution,
ecological degradation or damage to the environment”.

Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact
Assessment and an Environmental Management Programme report in terms of the National Environmental
Management Act (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in
unacceptable pollution, ecological degradation or damage to the environment.

In terms of section 16(3) (b) of the EIA Regulations, 2014, any report submitted as part of an application must
be prepared in a format that may be determined by the Competent Authority and in terms of section 17 (1) (c)
the Competent Authority must check whether the application has taken into account any minimum
requirements applicable or instructions or guidance provided by the competent authority to the submission of
applications.

It is therefore an instruction that the prescribed reports required in respect of applications for an environmental
authorisation for listed activities triggered by an application for a right or a permit are submitted in the exact
format of, and provide all the information required in terms of, this template. Furthermore please be advised
that failure to submit the information required in the format provided in this template will be regarded as a
failure to meet the requirements of the Regulation and will lead to the Environmental Authorisation being
refused.

It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret
his/her research and analysis and use the findings thereof to compile the information required herein.
(Unprocessed supporting information may be attached as appendices). The EAP must ensure that the
information required is placed correctly in the relevant sections of the Report, in the order, and under the
provided headings as set out below, and ensure that the report is not cluttered with un-interpreted information
and that it unambiguously represents the interpretation of the applicant.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 2. Objective of the Basic Assessment process

The objective of the basic assessment process is to, through a consultative process

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

(b) Identify the alternatives considered, including the activity, location, and technology alternatives;

(c) Describe the need and desirability of the proposed alternatives,

(d) Through the undertaking of an impact and risk assessment process inclusive of cumulative impacts
which focused on determining the geographical, physical, biological, social, economic, heritage , and
cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity
and technology alternatives on the these aspects to determine:

(i) The nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and
(ii) The degree to which these impacts—
(aa) Can be reversed;
(bb) May cause irreplaceable loss of resources; and
(cc) Can be managed, avoided or mitigated;

(e) Through a ranking of the site sensitivities and possible impacts the activity and technology alternatives
will impose on the sites and location identified through the life of the activity to—

(i) Identify and motivate a preferred site, activity and technology alternative;
(ii) Identify suitable measures to manage, avoid or mitigate identified impacts; and
(iii) Identify residual risks that need to be managed and monitored.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
DETAILS OF THE INDEP ENDENT ENVIRONMENTAL ASSESSMENT
PRACTITIONER (EAP)

Compiled by:

EAP: Mr. Justin Pietro Ellero (EAPASA Registration Number:2019/178)

Qualifications: MSc (Geography) (UKZN) • BSSH (Environmental Science – Cum

Laude) (UKZN) • BSS (Geography and Environmental Management)
(UKZN) • Advanced Course (Environmental Law) (UNISA)

Work Experience: Justin Ellero is an Environmental Assessment Practitioner with six

years’ experience in conducting Environmental Impact Assessments,
Water Use License Applications, Mining applications and Waste
Management Licensing. His project experience list includes municipal
pipelines, Eskom powerlines, Eco-Lodge developments, residential
estates, industrial parks, mining permits and development at the King
Shaka International Airport. As of the 30th of November 2019, Justin is
a fully registered Environmental Assessment Practitioner with The
Environmental Assessment Practitioners Association of South Africa.

I, Justin Pietro Ellero (9001305086083) confirm:

 The correctness of all information within the BAR and EMP;

 All I&APs comments and inputs have been included in this Report;

 The inclusion of inputs and recommendations from the specialist reports where relevant;
and

 I do not have and will not have any vested interest (either business, financial, personal
or other) in the proposed activity proceeding other than remuneration for work
performed in terms of the NEMA Regulations.

An undertaking of oath can be found at the end of this application.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Project Team for the proposed Snyman Family Trust Mine Permit:

Name Role Company Qualifications

IDM Environmental Project Team
Mr. Justin Ellero Environmental IDM Environmental MSc Geography (UKZN)
Assessment – EAP
Practitioner EAPASA Registration
(2019/178)
Mr. Karl Internal Reviewer of Managing Director of Masters in Environmental,
Wiggishoff all Reports IDM Environmental Planning and Development
Law (Stel)
Environmental Specialist
Ms. Louise Botanical and Managing Director of BSC Honours Botany (UCT)
Zdanaw Freshwater EnviroSwift KZN
Specialist (Pty) Ltd. SACNASP Registered
(114072)

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
TABLE OF CONTENTS

1 BACKGRO UND INF ORMATI ON .......................................................................... 12

1.1 INTRODUCTION ............................................................................................... 12

1.2 LOCATION OF THE PROJECT ........................................................................ 12

1.3 EIA REGULATIONS OF 2014 (AS AMENDED) TRIGGERED ACTIVITIES ...... 16

1.4 TERMS OF REFERENCE ................................................................................. 16

1.5 APPROACH AND METHODOLOGY................................................................. 16

1.6 REPORT STRUCTURE ..................................................................................... 17

1.7 APPLICABLE LEGISLATION, POLICIES AND GUIDELINES.......................... 17

2 DESCRIPTION OF PROPO SED MINING RELATED A CTIVITIES ............. 23

2.1 ACTIVITY DESCRIPTION ................................................................................. 23

Extent of the Snyman family Trust Mine ........................................................................... 23
Site Planning ..................................................................................................................... 23
Site preparation and establishment .................................................................................. 23
Operation .......................................................................................................................... 24
Duration of Activity ............................................................................................................ 24
Mine Closure and Rehabilitation ....................................................................................... 24

2.2 SERVICE PROVISION ...................................................................................... 25

2.3 ACCESS TO THE MINING SITE ....................................................................... 25

2.4 NEED AND DESIRABILITY OF THE SNYMAN FAMILY TRUST MINE ............ 26

2.5 CONSIDERATION OF ALTERNATIVES ........................................................... 27

Activity alternatives ........................................................................................................... 27
Locational alternatives ...................................................................................................... 27
Layout Alternatives............................................................................................................ 27
Scheduling Alternatives .................................................................................................... 28

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Infrastructure alternatives ................................................................................................. 28
“No-go” alternative ............................................................................................................ 28

3 PUBLIC PARTICPATION (CURRENTLY UNDERWAY) ................................ 29

3.1 REQUIREMENTS OF THE ENVIRONMENTAL IMPACT ASSESSMENT

REGULATIONS OF 2014 (AS AMENDED) ....................................................... 29

3.2 COMMENTS AND RESPONSE REPORT ......................................................... 30

4 BASELINE ENVIRONMENT AL CONDITIONS OF THE PROPOSED

MINING SITE ....................................................................................................................... 32

4.1 DEFF SCREENING ASSESSMENT .................................................................. 32

4.2 CLIMATE ........................................................................................................... 32

4.3 LANDSCAPE CHARACTERISTICS/EXISTING SITUATION ............................ 32

4.4 GEOLOGY AND SOILS .................................................................................... 32

4.5 VEGETATION COMMUNITY OF THE PROPOSED SNYMAN FAMILY TRUST

MINE.................................................................................................................. 32

4.6 VEGETATION FOUND ON SITE ....................................................................... 33

4.7 FAUNA .............................................................................................................. 35

4.8 FRESHWATER CHARACTERISTICS ............................................................... 35

4.9 THE PRESENT ECOLOGICAL STATE AND ECOLOGICAL IMPORTANCE

AND SENSITIVITY SCORES ............................................................................ 39
The PES of all impacted watercourses ............................................................................. 39
EIS of all impacted watercourses ...................................................................................... 40

4.10 SITES WITH ARCHAEOLOGICAL INTEREST ................................................. 41

4.11 SOCIAL-ECONOMIC ENVIRONMENT ............................................................. 41

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
5 IMPACT ASSESSMENT .......................................................................................... 43

5.1 INTRODUCTION ............................................................................................... 43

5.2 IMPACT ASSESSMENT CRITERIA .................................................................. 43

Nature of impact ................................................................................................................ 43
Extent/Scale ...................................................................................................................... 43
Duration ............................................................................................................................. 43
Intensity ............................................................................................................................. 44
Probability ......................................................................................................................... 44
5.2.5.1 DETERMINATION OF SIGNIFICANCE ............................................................ 45

5.3 IMPACT HIERARCHY ....................................................................................... 45

5.4 IMPACTS FROM SIMILAR TYPES OF DEVELOPMENT/MINING

OPERATIONS ................................................................................................... 46

5.5 ENVIRONMENTAL IMPACTS OF THE PROPOSED PREFERRED

ALTERNATIVE .................................................................................................. 46
Soil Erosion, loss of topsoil and contamination ................................................................ 47
Freshwater Impacts........................................................................................................... 49
Flora and Fauna ................................................................................................................ 53
Noise Impacts ................................................................................................................... 55
Air quality .......................................................................................................................... 55
Light .................................................................................................................................. 56
Visual ................................................................................................................................ 56
Solid waste disposal.......................................................................................................... 56
Traffic ................................................................................................................................ 57
Social ................................................................................................................................ 57

5.6 IMPACTS PER THE DIFFERENT PHASES OF THE MINE LIFECYCLE .......... 58

5.7 ALTERNATIVES IMPACT ASSESSMENT........................................................ 59

5.8 ENVIRONMENTAL IMPACT STATEMENT AND SUMMARY ON NEED AND

DESIRABILITY .................................................................................................. 59
Environmental Impact Statement ...................................................................................... 59

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 5.9 THE WATERCOURSE BUFFER ....................................................................... 60

5.10 FINANCIAL PROVISION ................................................................................... 61

Explain how the financial provision was obtained ............................................................. 61

5.11 UNCERTAINTIES/GAPS IN KNOWLEDGE ...................................................... 61

5.12 PROPOSED CONDITIONS TO INCLUDE IN THE ENVIRONMENTAL

AUTHORISATION (IF GRANTED) .................................................................... 61

5.13 PROPOSED IMPACT MANAGEMENT OBJECTIVES AND THE IMPACT

MANAGEMENT OUTCOMES FOR INCLUSION IN THE EMP ......................... 62

6 SUMMARY OF RECOMMEND ATIONS AND CONCLUSIO N ........................ 63

LIST OF ANNEXURES:

Annexure A: Locality Map

Annexure B: Schematic Mining Sketch Plan

LIST OF APPENDICES:

Appendix 1: Environmental Management Plan

Appendix 2: Public Participation Report (Report to be provided in final submission)

Appendix 3: Freshwater and Vegetation Assessment

Appendix 4: Mining Operational Plan

Appendix 5: Mine Closure and Rehabilitation Report

LIST OF TABLES
Table 1.1: Summary of the proposed property details for the Snyman Family Trust Mine......................................... 12
Table 1.2: Triggered Activities for the proposed Snyman Family Trust Mine ............................................................ 16
Table 1.3: Other Applicable Legislation for the proposed Snyman Family Trust Mine .............................................. 17
Table 3.1: Public Participation Comments and EAP Responses ................................................................................ 31
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Table 5.1: Summary of impacts per the different phases of the mine lifecycle ......................................................... 58
Table 5.2: Advantages and Disadvantages of the proposed Snyman Family Trust Mine .......................................... 60

LIST OF FIGURES
Figure 1.1: Regional location of the proposed Snyman Family Trust Mine ................................................................ 14
Figure 1.2: Locality map of the proposed Snyman Family Trust Mine ....................................................................... 15
Figure 2.1: Adjacent access roads and access points ................................................................................................... 26
Figure 4.1: Location of the mine extent within an area which is indicated as 100% transformed ............................... 34
Figure 4.2: The site is completely transformed (facing east) ....................................................................................... 34
Figure 4.3: The site is completely transformed (facing south) .................................................................................... 35
Figure 4.4: Locality of the adjacent wetland feature ................................................................................................... 37
Figure 4.5: Significantly degraded wetland habitat restricted to drainage channels (a) ............................................. 37
Figure 4.6: Significantly degraded wetland habitat restricted to drainage channels (b) ............................................. 38
Figure 4.7: Additional watercourses identified within the DWS 500m regulated zone ............................................... 39
Figure 5.1: Proposed Mining buffer for the proposed Snyman Family Trust Mine .................................................... 61

ABBREVIATIONS
BA Basic Assessment
BAR Basic Assessment Report
C Construction
CA Competent Authority
CBA Critical Biodiversity Area
DAFF Department of Agriculture, Forestry and Fisheries
DEA Department of Environmental Affairs
DMRE Department of Mineral Resources and Energy
EA Environmental Authorisation
EAP Environmental Assessment Practitioner
EDTEA Department of Economic Development, Tourism and Environmental Affairs (KZN)
EIA Environmental Impact Assessment
EKZNW Ezemvelo KwaZulu-Natal Wildlife
EMP Environmental Management Plan
ESA Ecological Support Area
ETo Potential Evaporation
FEPA Freshwater Ecosystem Priority Area
GA General Authorisation
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
I&APs Interested and Affected Parties
IDM Integrated Development Management Consultants
IDME Integrated Development Management Consultants Environmental
LM Local Municipality
KZN KwaZulu-Natal
NBA National Biodiversity Assessment
NDP National Development Plan
NEMPAA National Environmental Management: Protected Areas Act (57 of 2003)
NFEPA National Freshwater Ecosystem Priority Area
O Operational
PGDP KZN Provincial Growth and Development Plan
PP Public Participation
PPP Public Participation Process
PSDF KZN Provincial Spatial Development Framework
SCC Species of Conservation Concern
SANBI South African National Biodiversity Institute
WM With Mitigation
WMA Water Management Area
WOM Without Mitigation
WUL Water Use License

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
1 BACKGROUND INFORMATION

1.1 I N TR O D U C T I O N
An application to mine sand along a 4,98ha section of the Manor Grange Farm 16593 has been submitted
to the Department of Mineral Resources and Energy (DMRE) under reference (KZN 30/5/1/3/2/10754 MP)
on behalf of the Snyman Family Trust. IDM Environmental (IDME) has been appointed as the independent
Environmental Assessment Practitioner (EAP) by Snyman Family Trust (the Applicant) to conduct a Basic
Assessment (BA) for the proposed new mining permit which will replace an existing mine operated on the
same property currently undergoing rehabilitation.

The mineral proposed to be mined is sand. The method to be implemented is a very basic form of Open
Cast Mining on agricultural cultivated land. Extraction of sand will be facilitated through the use of an
excavator and/or front end loader. An area of less than 5ha (In accordance with Appendix 4 – The Mining
Operational Plan) will be demarcated for mining and will not compromise of any infrastructure,
watercourses or indigenous vegetation. The sand will be deposited onto the stockpile area within the permit
site and loaded onto tip trucks by the front end loader for transport off the site and for sale at the local
market. The sand will therefore not be processed on site.

1.2 LOCATION OF THE PROJECT

The proposed mining site is situated on disturbed/transformed farm land currently utilised as pasture on the
KwaZulu-Natal south coast (Figure 1.1 and 1.2). The farm is situated a kilometre west of the town of
Hibberdene and located adjacent to the N2 freeway, running perpendicular to the coast. The proposed sand
mining operation falls within the Ugu (district) and Ray Nkonyeni (Local) Municipalities respectively. A
more in-depth locality map is provided in Annexure A. Table 1.1 below contains a summary of the location
description.

Table 1.1: Summary of the proposed property details for the Snyman Family Trust Mine

Farm Name Manor Grange Farm 16593

Property Owners Snyman Family Trust
Representative: Mr. Pieter Snyman
Title Deed Number T18263/08
SG Number N0ET00000001659300000
Magisterial District Ray Nkonyeni Local and the Ugu District Municipalities

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Distance and Direction to nearest town A kilometre west of the town of Hibberdene
Coordinates 30°35'14.93"S
30°33'1.36"E
Property Zoning Agriculture
Current Activities South, East and West – under sugarcane cultivation or
macadamia orchard; and
North (top of the ridge) – pasture for cattle grazing.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Figure 1.1: Regional location of proposed Snyman Family Trust Mine

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Figure 1.2: Locality map of the proposed Snyman Family Trust Mine

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 1.3 EIA R E G U L A T I O N S O F 2014 ( AS A M E N D E D ) T R I G G E R E D A C TI V I T I E S
The Environmental Impact Assessment Regulations of 2014 (As amended), requires Environmental
Authorisation from the competent authority (The Department of Mineral Resources and Energy – The
Regional KwaZulu-Natal Branch) for activities listed in Government Notice R327 which pertain to mining.
Table 1.2 below identifies the activity in the Environmental Impact Assessment Regulations of 2014 (as
amended) that has been triggered for the proposed mining permit application.

Table 1.2: Triggered Activities for the proposed Snyman Family Trust Mine

Activity Number Description Impact on the proposed project

Any activity including the operation of that activity The proposed activity will
which requires a mining permit in terms of section require a mining permit (area
27 of the Mineral and Petroleum Resources under 5ha) from DMRE as it
GNR Development Act (No. 28 of 2002), including involves a basic method of
327/Listing associated infrastructure, structures and earthworks open cast mining of sand on
Notice 1 – directly related to the extraction of a mineral the Manor Grange Farm 16593.
Activity 21 resource, including activities for which an
exemption has been issued in terms of section 106
of the Mineral and Petroleum Resources
Development Act (No. 28 of 2002).

The triggered activities for the proposed Snyman Family Trust Mine is Activity 21 of GNR 327 (Listing
Notice 1). Listing Notice 1 requires a BA process to be conducted as per the EIA Regulations of 2014 (as
amended).

1.4 TE R M S O F R E F E R E N C E
Regulation 19 of the EIA Regulations of 2014 (as amended), determines that a BA procedure must be
followed for all activities listed in Government Notice R327 and R324. IDM Environmental has been
appointed as the independent Environmental Consultant by the Applicant and will therefore be responsible
for the BA procedures concerned with the proposed mining development. This includes formulating of the
BAR, Environmental Management Plan (EMP), appointing experts in their respective fields to undertake
specialist studies and the undertaking of a detailed stakeholder engagement process as per the EIA
Regulations of 2014 (as amended) requirements.

1.5 AP P R O AC H A N D M E TH O D O L O G Y
The overall approach to this assessment includes the following activities:
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
  Apply for Environmental Authorisation from DMRE for the proposed Snyman Family Trust Mine.
 Provide a detailed analysis of the proposed mining development, site and region sensitivity and the
identification of potential impacts and associated mitigation and management measures.
 Conduct a detailed Public Participation Process.
 Comply with all legislative requirements in terms of the EIA Regulations and to provide the DMRE
with sufficient information to make an informed decision regarding the proposed mining
development.

1.6 R E P O R T S TR U C T U R E
Appendix 1 and 4 of GN326 of the EIA Regulations of 2014 (as amended) were used in the formulating of
the content and structure of the BA and EMP Reports.

The BAR is structured as follows:

 Section 2 consists of a summary of the proposed mining methods to be utilised, the different
phases of the mine lifecycle, the services required, the need and desirability of the proposed
mine, as well as all alternatives considered as part of the application process.
 Section 3 describes the Public Participation Process to be followed for the BA process.
 Section 4 provides a description of the receiving environment (baseline environmental
conditions) that may be impacted by the activities to be authorised.
 Section 5 consists of a detailed assessment of all the potential impacts of the proposed Snyman
Family Trust Mine. Mitigation and management measures for possible impacts are further
provided.
 Section 6 provides a Summary of the recommendations and conclusion.

1.7 AP P LI C A B L E LE G I S L A T I O N , P O LI C I E S A N D G U I D E LI N E S
In addition to the EIA Regulations of 2014 (as amended), Table 1.3 below indicates all other applicable
legislation and guideline documents that have been considered in the preparation of this Draft BAR.

Table 1.3: Other Applicable Legislation for the proposed Snyman Family Trust Mine

Legislation Relevance to the development

The Constitution
The Constitution of the Republic The Constitution stipulates that everyone has the right to an
of South Africa environment that is not harmful to their health or well-being; and the
right to have the environment protected, for the benefit of the present

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Section 24 and future generations, through reasonable legislative and other
measures. The Constitution has thus paved the way for environmental
legislation and NEMA in South Africa post-1994 and the need to find
a new approach to protecting the environment in an integrated and
sustainable manner. This BAR embodies the principals of the
Constitution in its formulation.
Applicable Legislation
Minerals and Petroleum The Minerals and Petroleum Resources Development Act (No. 28 of
Resources Development Act 2002) was developed to ensure that provision is made for equitable
(No. 28 of 2002) access to, and sustainable development of, South Africa’s mineral and
petroleum resources and to provide insight, guidance and control for
matters connected thereto. It seeks to provide management tools that
ensure that all mining operations are undertaken in an environmentally
sound manner according to government approved documents that hold
the applicant responsible for any environmental degradation that their
mining actions might cause.

This BA and EMP has been compiled in accordance with this Act. An
application will be submitted to DMRE for a Mining Permit and
subsequent Environmental Authorization.
National Environmental The BA is being undertaken as per the requirements of this Act. The
Management Act (No. 107 of triggered activities for the proposed Snyman Family Trust Mine is
1998) Activity 21 of GN 327 of Listing Notice 1.

and All possible impacts from the mining activity have been assessed and
appropriate mitigation measures as per the impact hierarchy tool have
The Environmental Impact been identified. This to ensure the impacts from the mining activities
Regulations of 2014 (as amended) are reduced to acceptable sustainable levels.
National Water Act (No. 36 of A General Authorisation (GA) is in the process of being applied for
1998) from the Department of Water and Sanitation (DWS) due to the risk
posed by the mining operations on adjacent watercourses. Section 21
C (related to impeding or diverting the flow of water in a watercourse)
and I (related to altering the bed, banks, course or characteristics of a

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 watercourse) Water Uses will be applied for authorisation from DWS.
No mining will take place within any watercourse or the 50m
freshwater protection buffer.
National Environmental The objectives of this Act are (within the framework of NEMA) are to
Management: Biodiversity Act provide for:
(No. 10 of 2004)  The management and conservation of biological diversity within
the Republic of South Africa and of the components of such
diversity;
 The use of indigenous biological resources in a sustainable
manner; and
 The fair and equitable sharing among stakeholders of the benefits
arising from bio-prospecting involving indigenous biological
resources.

Furthermore, NEMBA stipulates that a person may not carry out a

restricted activity involving either:
a) A specimen of a listed threatened or protected species;
b) A specimen of an alien species; or
c) A specimen of a listed invasive species without a permit.

Accordingly, no nationally protected species were located on site.

Alien plant species will be required to be removed from the site as per
the alien management plan contained in the EMP (Appendix 1).
National Environmental The Applicant is required to minimize the generation of waste created.
Management: Waste Act (No. 59 All waste generated on site will need to be dealt with according to the
of 2008) EMP (Appendix 1). Limited waste volumes will be generated during
the different phases of the proposed Mine lifecycle, which will be
disposed of at a registered landfill site. Key to the limiting of waste is
appropriate training programmes being implemented and enforced.
Environmental Management: Air Mitigation measures to control air and dust pollution will be
Quality Act (No. 39 of 2004) implemented during the different phases of the mine lifecycle as per
the EMP (Appendix 1) to ensure compliance with this Act.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
National Forests Act (No. 84 of In terms of section 15(1) of the National Forests Act (NFA), no person
1998) may cut, disturb, damage or destroy any protected tree or possess,
collect, remove, transport, export, purchase, sell, donate or in any other
manner acquire or dispose of any protected tree or any product derived
from a protected tree, except under a licence or exemption granted by
the Minister to an applicant and subject to such period and conditions
as may be stipulated.
National Veld and Forest Act (No. The purpose of this Act is to prevent and combat veld, forest and
101 of 1998) mountain fires throughout the Republic. The Act provides for a variety
of institutions, methods and practices for achieving this purpose.
Firefighting equipment will be available during the operational
process. This will be stored at the Applicants nearby shed.
Conservation of Agricultural To provide for control over the utilization of the natural agricultural
Resources Act (No. 43 of 1983) resources of the Republic in order to promote the conservation of the
soil, water sources and vegetation. The Act further requires the
combating of weeds and invader plants.
Mine Health and Safety Act The Mine Health and Safety Act provides for the protection of the
(No. 26 of 1996) health and safety of employees and other persons at mines and serves
-
 To promote a culture of health and safety;
 To provide for the enforcement of health and safety measures;
 To provide for appropriate systems for employee, employer
and state participating in health and safety matters;
 To provide effective monitoring systems and inspections,
investigations and inquiries to improve health and safety;
 To promote training and human resource development;
 To regulate employers’ and employees’ duties to identify
hazards and eliminate, control and minimise the risk to health
and safety; and
 To entrench the right to refuse to work in dangerous
conditions.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Occupational Health and Safety The employer needs to manage his/her staff and crew in strict
Act (No. 85 of 1993) accordance with the Occupational Health and Safety Act in order to
prevent injuries to the staff.
National Heritage Resources Act This Act has been put into place to protect and conserve heritage
(No. 25 of 1999) resources. If anything of heritage importance is found on the proposed
site, the operational process will be halted and a suitably qualified
specialist will be contacted. In consultation with the Applicant, no
heritage resources were located on site. The site is completely
transformed and has been cultivated with sugarcane for decades. The
site is now used as pasture for grazing cattle. The immediate
surrounding land uses also consist of transformed cultivated land.
Taking all this into consideration, the EAP determined that no Heritage
Impact Assessment was required as part of the Basic Assessment
process.
KwaZulu-Natal Heritage Act (No. This Act has been put into place to conserve and protect heritage
4 of 1998) resources in the KZN province. If anything of archaeological
significance is uncovered, a specialist will be contacted. In
consultation with the Applicant no heritage resources were located on
site.
Development Framework and Plans
KZN Provincial Spatial Alignment of the proposed mine to the KZN Provincial Spatial
Development Framework Development Framework (PSDF) has been made. The PSDF is a long
term (i.e. > 5 year) spatial framework from which various plans will
be implemented. It is informed by the National Development Plan and
related spatial policies, and takes its strategic direction from the KZN’s
development strategy and related policy frameworks. It conveys the
KZN’s spatial agenda to National and Provincial departments, as well
as state owned enterprises (SOEs) so that their sector plans and
programmes are grounded in a sound and common spatial logic. Part
of this plan is development and growth and the promotion of
sustainable job creation and local economic development in rural
underdeveloped areas.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
KZN Provincial Growth and The proposed development is aligned with the PGDP, as it addresses
Development Plan the first goal of the PGDP which is that of job creation and local
economic development.
Guideline Documents
Public Participation Guideline in Guideline document for Public Participation Process for all EIAs. This
terms of National Environmental document was used to guide the Public Participation Process for the
Management Act, 1998 - proposed application and ensure the stakeholder engagement process
Department of Environmental is inclusive. The aim is to communicate as early as possible, with as
Affairs, 2017. many people as possible and through as many different avenues as
possible.
Guideline on Need and This Guideline was utilised in the formulation of the needs and
Desirability - Department of desirability of the proposed Snyman Family Trust Mine application.
Environmental Affairs, 2017.
Mining and Biodiversity The Guideline interprets the best available biodiversity knowledge and
Guideline: Mainstreaming science in terms of the implications and risks for mining in a practical
biodiversity into the mining sector guideline and user-friendly decision support tool for both industry and
– regulators to ensure that biodiversity issues are consistently
Department of Environmental incorporated into the decision making processes for mining projects.
Affairs, Department of Mineral The Guideline was used to ensure the proposed Snyman Family Trust
Resources, Chamber of Mines, Mine embodies the principals of sustainability and integrated
South African Mining and environmental management.
Biodiversity Forum, and South
African National Biodiversity
Institute, 2013.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
2 DESCR IPTION OF PROPOSED MINING RELATED ACTIVITIES

2.1 A C TI V I T Y D E S C R I P TI O N
The application is for a proposed new sand mine on agricultural land (no indigenous vegetation to be
removed) which will replace an existing sand mine on the same property. The existing mine is located on
the southern portion of the applicants property. A Closure and Rehabilitation Plan for the existing mine is
currently being implemented.

E X TE N T O F TH E S N Y MA N FA M I LY T R US T M IN E
The total extent of the proposed mining permit area is a 4,98ha section over the Manor Grange Farm 16593.
The site will include a mining area, stockpiling area and all the necessary erosion and stormwater measures.

S ITE P LA N N IN G
Before the mine site establishment, operation and closure can commence, careful planning must take place
which will lay the foundations for the abovementioned phases. This will ensure that impacts can be
identified at the earliest possible stage and appropriate mitigation measures employed. This in order to
prevent/ minimise impacts to acceptable/low levels. The Basic Assessment Report (BAR) and associated
Appendices, forms one part of this planning process. Before site establishment and operation can occur, it
is of the utmost importance that the Applicant and Mine Manager must ensure plans are in place to
implement mitigation measures in the EMP (Appendix 1) and that rehabilitation is an on-going process,
which is not solely defined to the Closure phase of the mine lifecycle.

S ITE P R E P A R A TIO N A N D ES TA B LIS H ME N T

No permeant infrastructure will be constructed on site, however the site will be prepared for mining
commencement. These activities will include:
 Environmental training and awareness for all employees;
 The demarcation of the mining site and strict ‘no-go’ areas. This includes clearly marking the mining
site boundaries by the placing of painted white rocks, orange tape and/or the usage of pegs;
 The erecting of signage warning the public that mining activities are taking place on the property and
the provision of a contactable number on this sign in the event of an emergency situation. Signage from
the existing mine will be utilised;
 The placement of a portable toilet (to the north of site away from the adjacent wetland), bins (this must
be secured and emptied regularly), spill kits and first aid kits. There must be a dedicated first aider on
site at all times;
 The stockpiling of fertile topsoil for use in rehabilitation of the mining area;
 Preparing the existing track for movement of heavy vehicles;

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Preparing equipment and vehicles for operation. Ensuring all equipment and vehicles are serviced and
that there are no leaks or mechanical faults;
 Ensuring that there are no protected species or endangered vegetation species on site (It has been
confirmed that no protected species or endangered vegetation species occur on site); and
 Implementing erosion and stormwater control on site. This includes strategically installing a series of
silt traps and berms on the southern periphery of the proposed new mine (the lowest point/s). These
measures will prevent uncontrolled runoff from entering the nearby watercourse. It must be stressed
that a 3 block mining principal will be utilised. This will ensure that the vegetation will only be cleared
when that section is to be mined. The majority of the permit area will thus remain vegetated until it is
time to mine that section of the permit area. Therefore runoff is not envisioned to be a significant issue
and will be controlled via the silt traps and berms. Furthermore, it is highly unlikely that chemicals will
be bought to site and machinery and equipment will be maintained and checked daily for leaks or faults.

O P ER A T IO N
This section should be read in conjunction with the Mining Operational Plan in Appendix 4
The mineral proposed to be mined is sand. The method to be implemented is a very basic form of Open
Cast Mining. Extraction of sand will be facilitated through the use of an excavator and/or front end loader.
An area less than 5ha will be demarcated for mining and will not compromise of any infrastructure,
watercourses or indigenous vegetation. The proposed mine site will be divided into a series of operations
blocks, and systematically approached, whereby the first block will be rehabilitated, the second block will
be mined and the third block will be prepared for mining. This will circumvent and preclude the need to
expose the entire site to mining at any one point. The sand will be deposited onto the stockpile area within
the permit site and loaded onto tip trucks by the front end loader for transport off the site and for sale to the
local market. The sand will therefore not be processed on site. The method of mining will be considered
dry mining in every respect and that no significant water runoff and subsequent siltation to occur as a result.
Dust suppression management will be effected (if and when necessary) and monitored by the mine manager
using a sporadic sprinkling of rain harvested water which will be transported in a mobile tank at the back
of the mine managers pick-up truck.

D U R A TIO N OF A C TIV I TY
The mine will operate for a period of two years from the time of the issuing of a mining permit, and
thereafter will become renewable for three further consecutive one-year periods, which totals a maximum
five year operational period.

M IN E C LO S U R E AND R EH AB IL I TA T IO N

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
After the five year period has been completed, the Applicant is required to implement a Mine Closure and
Rehabilitation phase. This involves:
 Removing of all temporary infrastructure (Portable toilets and bins), equipment (mining vehicles),
signage, fencing and demarcation beacons;
 The rehabilitation of the stockpiling areas and access points to the proposed mine. This includes
the planting of grasses and removal of invasive alien species;
 Implementing of continual erosion control if required; and
 The monitoring of the rehabilitation process to ensure successful revegetation (where necessary),
the prevention of erosion and spread of invasive alien plants.
The proposed mining site will be planted with macadamias post mining.

2.2 SERVICE PROVISION

Limited services are required for the proposed Snyman Family Trust Mine. These include:
Water: Drinking water for consumption will be provided to all workers on site. This will be sourced from
the local municipal supply. Limited water will be required for dust control. This will be sourced from jo-jo
tanks on the property. It must be stressed only a small portion of the mine site will be exposed at one time.
This will create low volumes of dust during very dry and windy conditions. Therefore only small quantities
of water is required. Bottled water will be provided to workers for personal consumption.
Electricity: To be provided by a generator if required.
Sewage: The provision of a portable toilet. The toilet will be regularly serviced.
Solid waste disposal: Waste management mitigation measures has been specified in the EMP. Due to the
small scale of the mining operation, large amounts of waste will not be generated. As per the EMP all waste
will be disposed of in a sustainable manner. No waste will be disposed of through burning or be buried on
site. Furthermore, waste bins will be available on site. There will be a separation of general and hazardous
waste and all waste will be disposed of at a registered landfill site.

2.3 A C C E S S TO T H E M I N I N G S I TE
Access and haulage of the sand will involve the entry of vehicles for the collection of sand. The proposed
mine site is located on the applicant’s own property and is easily accessible from the existing farm road
(Figure 2.1). Access to the proposed mine site will use existing roads. Roads will have to be maintained to
ensure no degradation of roads occur due to the mining activity. An existing access path from the existing
farm road onto site (5 meter distance) will serve as an access ramp.

Due to local By-Laws limiting tonnage passing through Hibberdene, the sand will be transported along the
P198, which bypasses the town of Hibberdene.
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Figure 2.1: Adjacent access roads and access points

2.4 N E E D A N D D E S I R A B I LI T Y O F T H E S N Y M A N F A M I L Y T R U S T M I N E
 The need for the proposed mining activities
There is a need for the provision of sand for the construction industry in Hibberdene and surrounding areas.
The provision of sand will result in broader socio-economic benefits including job creation and local
economic development through the availability and affordability of building sand in the area and the
creation of secondary economic opportunities. The sand mining will further aid the Applicant in converting
the greater portion of his farm to a macadamia plantation once mining activities have ceased. This through
the shaping of the contours of the property.
 The desirability of the proposed site
The site is desirable for a number of reasons:
 The site has existing well established farm roads that are in good condition.
 The mine has easy access to the N2 freeway and other regional roads.
 The site is located adjacent to the Applicant’s farm house whereby machinery, vehicles, chemicals
(if required) and fuel can be safely stored away from the elements.
 No indigenous vegetation will be removed due to mining activities. The Mine site is situated on a
sugarcane plantation/pasture.
 The proposed site does not contain any protected flora and fauna.
 The mine site is situated away from large settlements and is surrounded by farms.
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
  The mining site is located nearby to large labour pool.
 The mining site is located close to a large growing market requiring building sand.
 The applicant has successful experience of mining on the property.

2.5 CONSIDERATION OF ALTERNATIVES

Alternatives are seen as different means of meeting the general purpose and need of a proposed activity.
Alternatives could include, amongst others, the following:
 Activity Alternatives: This requires a change in the nature of the proposed activity. This alternative
is most appropriate at a strategic decision-making level.
 Locational Alternatives: Alternative locations for the entire project proposal, or for components
of the project proposal.
 Layout Alternatives: This alternative allows different spatial configurations of an activity on a
specific site.
 Scheduling Alternatives: Also referred to alternative phasing options for the development. This
alternative considers different phasing options during the implementation of the development.
 Infrastructure/ Input Alternatives: Also referred to as technological or equipment alternatives.
This option considers various alternatives that will result in the same end result.

A C TIV I TY A L TER N A T I V E S
Activity alternatives refer to the consideration of alternatives requiring a change in the nature of the
proposed activity to be undertaken. No further activity alternatives were considered. The Applicant is
planning to mine the new section of the farm before converting the section into a macadamia orchid. Mining
further aids the Applicant in diversifying economic opportunities in the backdrop of a declining sugar
industry. It must be further noted that other sections of the farm have been already converted to macadamia
plantation. These trees take 8 years to mature and thus mining helps to supplement income during this
period.

L O C A TIO N A L A LTE R N A TIV ES

Only portions of the Applicants own property were considered for mining. The Applicant has an existing
mine in the southern portion of the property which is currently undergoing rehabilitation and closure. No
further sections were considered due to the existence of watercourses.

L A Y O U T A LTE R N A TIV E S
The proposal layout for the sand mining activity will be as per the sketch plan (Annexure B hereto). No
site office is required. A portable toilet will be placed away from the vegetation and surrounding

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
watercourses, which will be utilised by the mine’s employees only. The final layout was determined by the
wetlands located below the mine. It was ensured that the Mine was located outside the freshwater buffer.

S C H E D U L IN G A L TE R N A TIV ES
The sand mining activity will commence as soon as the DMRE issues the necessary mining permit and any
and all other associated statutory authorisations are secured. No scheduling alternatives were therefore
considered. The sand mining intensity will be based on the demand for sand in the area, and subject to
weather conditions. Mining will take place Monday to Friday during specified work hours. No mining may
take place outside these specified times and after sunset. Mining will be avoided in heavy rains.

I N FR A S TR U C TU R E A LTE R N A TIV E S
Other than bins and a portable toilet, no other infrastructure is required.

“N O - G O ” A LTE R N A TI V E
The “no-go” alternative should, in all instances, be considered as part of the EIA process. This scenario
assumes that the activity does not proceed, implying a continuation of the current situation. Should this
permit not be granted, there will be no socio-economic benefits i.e. no job creation and no local economic
development. Furthermore, failure to issue the mining permit will compromise the Applicant’s future plans
to convert the site to a macadamia plantation in the face of a rapidly declining sugar industry.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
3 PUBLIC PARTICPATION (CURRENTLY UNDERWAY)

3.1 R E Q U I R E M E N TS O F TH E E N V I R O N M E N T A L I M P AC T AS S E S S M E N T R E G U L A T I O N S
O F 2014 ( A S AM E N D E D )
The following section contains the DMRE approved Public Participation Process (PPP). The PPP has been
aligned with the National Department of Environment, Forestry and Fisheries (DEFF) Gazette 43412
published on the 5th June 2020 detailing measures to address, prevent and combat the spread of COVID-
19 relating to national environmental management permits and licencing processes. The proposed PPP to
be followed for the Snyman Family Trust Mine Basic Assessment includes:
 Identifying and compiling a comprehensive list of potential Interested and Affected Parties including:
 The Competent Authority;
 Relevant National and Provincial government authorities;
 Local Municipal authorities (both district and local);
 The local councillors;
 Quasi-government institutions;
 Neighbouring property owners;
 Neighbouring communities;
 Conservation organisations; and
 3rd party stakeholders
 Potential Interested and Affected Parties will be notified of the proposed Mining Permit Application
through:
 Notification emails and a BID will be forwarded to all identified stakeholders;
 Site notices will be placed on the proposed mining site, proposed access track and outside the local
Hibberdene Library. These site notices will be printed on A3 paper and will also be laminated and
sprayed with sanitizer;
 An advert will be published in a local community newspaper; and
 If a stakeholder does not have access to email, the EAP will firstly try to contact the stakeholder
via telecom (phone call and then sms). If this does not work, as a last resort the stakeholder will be
sent details of the PPP via Fast Mail. However, this will be avoided if necessary.
 A copy of the BAR: Draft 1 and all appendices will be made available on IDM Consultants website for
download and review. A link to the website will be provided via email notification.
 A copy of the BAR: Draft 1 and all appendices will be sent via ‘Dropbox’ or ‘Wetransfer’ to
stakeholders were requested.
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 A copy of the BAR: Draft 1 and all appendices will be sent via email if requested.
 A copy of the BAR: Draft 1 will be sent via WhatsApp where requested. The document size will be
minimized to be no larger than 5mb.
 In some instances government authorities cannot download documents. If this is the case, a CD will be
couriered to the relevant Official. Special precautions will be undertaken to prevent the spread of
COVID-19. These include the EAP sanitizing his hands before touching the CD, sanitizing the CD case
with a spray and the utilising of a courier company that will undertake special measures to prevent the
spread of COVID-19.
 A Full copy of the BAR will be available at the local Hibberdene Library for review. Stakeholders will
be encouraged to access the documents electronically before seeking out the hardcopy.
 Stakeholders will be able to provide commentary via:
 Email (the preferred option);
 Telephonically (SMS/WhatsApp/Voice call);
 Public Open Day Meeting (at the Stick Farm Community Hall on the 26th of March 2021 between
13h00 to 14h00); and
 Post (the last option. Will be avoided at all costs, unless absolutely necessary).
 All comments and responses will be included in a Public Participation Report for review. Evidence of
the PPP being conducted will further be provided as annexures to the Report. This will be provided to
DMRE with the final submission of the BAR.
 As per the NEMA requirements, a PPP of at least 30 days will be conducted after the application for
environmental authorisation form has been submitted to DMRE. Furthermore, the DEA Public
Participation Guideline will be used to guide the PPP.

3.2 C O M M E N TS A N D R E S P O N S E R E P O R T
Please see below Table 3.1 of the example of the comments and response table to be populated after the
PPP has been concluded.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Public Participation Comments and EAP Responses

Interested Represented Date Comments received Response and action provided by the EAP Inclusion in BAR or EMP
and Affected individual/offi comment/s
Section
Party cial were received

NB: To be populated after PPP is completed.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 4 BASELINE ENVIRONMENT AL CONDITIONS OF THE PROPOSED
MINING SITE

4.1 DEFF S C R E E N I N G AS S E S S M E N T
The Snyman Family Trust Sand Mine project details were uploaded onto the DEFF screening tool in 2020.
The results of which helped to aid the EAP in not only determining what Specialist studies to conduct, but
also influence the assessment of the Mines predicted impacts on the surrounding environment. It must
however be noted that while the DEFF tool plays an important part in determining the baseline
environmental conditions, it does not replace ground truthing. The following chapter contains the results of
the specialist investigations into the baseline conditions that might be impacted upon.

4.2 C LI M A T E
The climate in Hibberdene can be characterized as being warm and temperate. Hibberdene receives about
781mm of rain per year, with most rainfall occurring during summer. It receives the lowest rainfall (15mm)
in July and the highest (105mm) in March. The monthly distribution of average daily maximum
temperatures shows that the average midday temperatures for Hibberdene range from 22.3°C in July to
27.3°C in February.

4.3 L A N D S C AP E C H A R AC T E R I S TI C S /E X I S TI N G S I T U A TI O N
The proposed mining site is located on a gentle sloping hill, approximately 105m above sea level. The
proposed site is situated on transformed/disturbed land currently under cattle pasture and previously farmed
with sugarcane up to 2019. The proposed mine property is surrounded by farms consisting of sugarcane
and macadamia plantations. The proposed mine site is located adjacent to the applicants farmhouse and
farm workhouse. The Applicant’s farm is located adjacent to the N2 freeway, and a kilometre west of the
coastal town of Hibberdene. The Applicant has an existing mine further south that is currently being
decommissioned.

4.4 G E O L O G Y A N D S O I LS
The mine extent is underlain by the Margate Granite which is characterised by gneissose leucogranites and
leucocharnockites. The soils associated with the mine extent are imperfectly drained sandy soils with
favourable water holding properties. These soils may be highly erodable (SA Soil Map, South African
National Biodiversity Institute Biodiversity Geographic Information System (SANBI BGIS)).

4.5 V E GE T A T I O N C O M M U N I T Y O F TH E P R O P O S E D S N Y M A N F AM I LY T R U S T M I N E
Please note, this section should be read in conjunction with the Vegetation specialist Report in Appendix
3 of this application.
According to the Vegetation Specialist, the proposed Snyman Family Trust Mine is not located within a
formally or informally protected area, or within a focus area for protection (NBA, 2011 and the NPAES,
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
2010). However, the mine extent is located within a Critically Endangered Ecosystem as listed by the
National List of Threatened Terrestrial Ecosystems. It should be noted that mapping data for threatened
terrestrial ecosystems represents the original extent of listed ecosystems in 2004 or earlier; in other words,
natural areas which have subsequently been converted to agriculture, mining and urban areas have been
excluded. The mine extent is therefore not necessarily presently representative of the natural habitat
associated with this listed ecosystem.

According to Mucina and Rutherford (2006), the mine extent is located within the Indian Ocean Coastal
Belt Biome and Bioregion, and, according to the vegetation type map for KZN, the mine extent is located
within the KwaZulu-Natal Coastal Belt Grassland vegetation type (Scott-Shaw and Escott, 2011). The
KwaZulu-Natal Coastal Belt Grasslands is characterised by highly dissected undulating coastal plains
which presumably used to be covered to a great extent with various types of subtropical coastal forest.
Some primary grassland dominated by Themeda triandra still occurs in hilly, high-rainfall areas where
pressure from natural fire and grazing regimes prevail. At present the KwaZulu-Natal Coastal Belt is
impacted by an intricate mosaic of very extensive sugarcane fields, timber plantations and coastal holiday
resorts, with interspersed secondary Aristida grasslands, thickets and patches of coastal thornveld present
(Scott-Shaw and Escott, 2011).

The mine extent is not indicated to fall within a Critical Biodiversity Area (CBA) or an Ecological Support
Area (ESA) by the KZN TSCP (2010). The mine extent is indicated to fall within a transformed area by the
KZN TSCP as per Figure 4.1.

4.6 V E GE T A T I O N F O U N D O N S I TE
Terrestrial vegetation associated with the mine extent has been completely transformed (Figure 4.2 and
4.3) as a result of historical and current cultivation and earth moving activities and can no longer be
considered representative of the Critically Endangered KwaZulu-Natal Coastal Belt Grassland vegetation
type. The mine extent is presently covered in its entirety by sugarcane with scattered individuals of alien
species including Pennisetum purpureum (Napier Grass), Bidens pilnosa and Conyza sp. identified in
between the sugarcane. Since the Specialist visit, the sugarcane has been removed and the mine site is used
for cattle pasture. No SCC or protected species were encountered within the mine extent at the time of the
assessment, and due to the transformed nature of the current vegetation community as well as natural
habitat, the probability of occurrence (POC) of SCC is considered to be very low.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Figure 4.1: The location of the mine extent within an area which is indicated as 100% transformed
by the KZN TSCP

Figure 4.2: The site is completely transformed (facing east)

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Figure 4.3: The site is completely transformed (facing south)

4.7 F AU N A
While the proposed mining site is completely transformed, the fields and surrounding pockets of indigenous
forests support fauna. The mine falls under the south coast birding route with over 300 species of birds have
been recorded on this route. Some species include (as per the Birdlife South African site): Narina Trogon,
Spotted Ground-Thrush, Yellow-rumped Tinkerbird, Scaly-throated Honeyguide, Olive Woodpecker,
Square-tailed Drongo, Grey Cuckooshrike, Terrestrial Brownbul, Yellow-bellied Greenbul, Red-capped
Robin-Chat, Brown Scrub-Robin, Cape Batis, Ashy Flycatcher, Blue-mantled Crested Flycatcher, Black
Sparrowhawk, Little Sparrowhawk, African Goshawk, Tambourine Dove, Lemon Dove, Knysna Turaco,
Purple-crested Turaco, African Emerald Cuckoo, Green Malkoha, Narina Trogon, Trumpeter Hornbill,
Black-breasted Snake Eagle and African Black Duck.

The farms in the regional will further host small mammal species such as duiker, cane rats, mangoose and
ververt monkey.

4.8 F R E S H W A T E R C H A R AC TE R I S TI C S
Please note, this section should be read in conjunction with the specialist Report in Appendix 3 of this
application.
The proposed Snyman Family Trust Mine falls within the North Eastern Coastal Belt Ecoregion, within the
Mvoti to Mzimkulu Water Management Area (WMA) and within the Coastal Mvoti sub-Water
Management Area (sub-WMA) as defined by NFEPA (2011). The quaternary catchment indicated for the

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
mine extent is U80D and the Wetland Vegetation Group for the area is the Indian Ocean Coastal Belt Group
2 which is listed as Critically Endangered within the region.

No watercourses are located within the proposed mining site, but a wetland is located approximately 52m
downslope of the mine extent and is considered to be at risk as a result of the proposed mining activities.
The Freshwater specialist has classified this wetland as an unchannelled valley bottom wetland due to its
topography, however it must be noted due to commercial agriculture; the hydrology, geomorphology and
vegetation characteristics of the wetland have been altered significantly. The wetland has been cultivated
with sugarcane, and an extensive network of drainage channels has been excavated within the feature in
order to drain excess water from the soil. Wetland vegetation is currently restricted to these drainage
channels and to immediately adjacent areas. Alien and invasive species such as Ageratum conyzoides
(Ageratum), Chromolaena odorata (Triffid Weed), Lantana camara (Common Lantana), Bidens pillosa
(Black Jack), Conyza sp (Fleabane) and Solanum mauritianum (Bugweed) were found to dominate the
drainage channels running through the wetland at the time of the assessment. However, common, pioneer
obligate and facultative wetland species including Typha capensis (Bulrush), Cyperus sp., Cyperus prolifer
(Dwarf Papyrus), Ludwigia octovalvis (Mexican Primrose-willow), Pteridium aquilinum (Bracken Fern)
and Centella asiatica (Asiatic Pennywort) were also identified within the drainage channels, and, upon
hand augering, mottling and gleying was encountered within soils sampled within the drainage channels
and on the banks of the drainage channels.

The location of the wetland is presented in the Figure 4.4 below, while Figure 4.5 and Figure 4.6 are
representative images of the significantly degraded wetland habitat restricted to drainage channels created
to improve soil conditions for agriculture.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Figure 4.4: Locality of the adjacent wetland feature

Figure 4.5: Significantly degraded wetland habitat restricted to drainage channels (a)

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Figure 4.6: Significantly degraded wetland habitat restricted to drainage channels ( b)

Additional watercourses identified within the DWS 500m regulated zone were desktop delineated and the
risk to these features as a result of the proposed mining related activities was considered (Figure 4.7). The
following factors were taken into consideration when determining the risk to these watercourses,
specifically:

 Watercourses 1 and 2 are located within a separate micro-catchment to the mine extent and are
located approximately 180m and 360m away from the mine extent, respectively. These
watercourses are therefore not considered to be at risk of impact.

 Watercourse 3 is located more than 300m away from the mine extent and is separated from the
mine extent by areas which are well vegetated with sugarcane and Napier grass. These vegetated
areas will intercept runoff and sediment before it reaches this watercourse and it is therefore not
considered to be at risk of impact.

 Watercourse 4 is an artificial drainage channel located more than 400m away from the mine extent.
This feature is separated from the mine extent by areas which are well vegetated with sugarcane
and Napier grass as well as by watercourse 3. These vegetated areas will intercept runoff and
sediment before it reaches this watercourse and it is therefore not considered to be at risk of impact.
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
In summary, additional watercourses within 500m of the mine extent are located within a separate micro-
catchment to the mine extent or are located a considerable distance away from the mine extent, and it is
therefore the opinion of the specialist that negligible risk is posed to these features provided that the
mitigation measures are strictly adhered to.

Figure 4.7: Additional watercourses identified within the DWS 500m regulated zone

4.9 T H E P R E S E N T E C O LO G I C A L S T A T E A N D E C O L O GI C A L I M P O R T A N C E A N D
S E N S I T I V I TY S C O R E S
Please note, this section should be read in conjunction with the specialist Report in Appendix 3 of this
application.

T H E PES O F A LL IM P A C TE D WA TE R C O UR S E S
The PES of the unchannelled valley bottom was determined with the use of the WET-Health Tool
(Macfarlane et al. 2007). This technique attempts to assess the deviation of a wetland from its natural /
reference state and takes into consideration the hydrological, geomorphological and vegetation health of
wetlands in three separate modules.

The key findings of the assessment are summarised below:

 Sugarcane is cultivated within the wetland’s catchment and within the wetland itself. Sugarcane
abstracts a greater volume of water when compared to naturally occurring vegetation which has
reduced natural flows into the wetland. However, the presence of hardened roadways and

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 compacted soils in the catchment of the feature has also resulted in a slight increase in runoff from
the catchment and in a slight increase in flood peaks.
 Deep drainage channels have been excavated within the wetland in order to drain water away from
the wetland and to improve soil conditions for cultivation activities.
 The cultivation of the wetland with sugarcane and the excavation of drainage channels through the
wetland has resulted in the transformation of the natural wetland vegetation community and in the
proliferation of alien and invasive vegetation.
Therefore the overall wetland health score calculated for the unchannelled valley bottom falls within PES
Category E (Seriously modified - the change in ecosystem processes and loss of natural habitat and biota is
great but some remaining natural habitat features are still recognizable). The PES of the wetland is likely
to remain stable over the next five years should the current sugarcane cultivation activities continue.

EIS O F A LL IM P A C TE D WA TE R C O UR S ES
The EIS method applied to the unchannelled valley bottom is based on the assessment tool developed by
Rountree et al. (2014) and was used in order to determine the EIS of wetland habitat, incorporating the
traditionally examined criteria used in EIS assessments of other water resources by DWA and thus enabling
consistent assessment approaches across water resource types.

The key aspects considered during this EIS assessment are summarised below and in the table to follow:

 Vegetation associated with the wetland has been transformed as a result of the cultivation of
sugarcane. It is therefore considered highly unlikely that the feature will support rare and
endangered species, or populations of unique species.
 The wetland itself is not located within a formally protected nature reserve and therefore does not
have any protection status, however, the wetland vegetation group for the area, the Indian Ocean
Coastal Belt Group 2 vegetation group, is considered to be Critically Endangered.
 The ecological integrity of the feature (PES) has been seriously modified.
 Drainage channels excavated through the wetland have significantly altered the natural hydrology
of the feature. Furthermore, the wetland is dominated by sugarcane, alien and invasive vegetation
and common indigenous pioneer species. The sensitivity of the feature to changes in floods and
changes in low flows/dry season is therefore considered to be low.
Therefore the unchannelled valley bottom wetland is considered to be of a low EIS (wetlands that are not
ecologically important and sensitive at any scale. The biodiversity of these systems is ubiquitous and not
sensitive to flow and habitat modifications. They play an insignificant role in moderating the quantity and
quality of water of major rivers).
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 4.10 S I TE S W I TH A R C H A E O L O G I C A L I N T E R E S T
The proposed mining site is completely transformed due to commercial sugarcane farming and pasture and
contains no archaeological or heritage features. This has been confirmed by the EAP who has walked the
entire mining site, as well as having discussions with the Applicant. If anything of heritage importance is
found on site (highly unlikely), the Applicant will immediately halt mining operations and a suitably
qualified heritage specialist will be contacted. Therefore, no Phase 1 Heritage assessment was undertaken.

4.11 SOCIAL-ECONOMIC ENVIRONMENT

The proposed sand mine occurs 1 kilometre away from the small coastal town of Hibberdene, and is located
within the jurisdiction of the Ray Nkonyeni Local Municipality and the Ugu District Municipality in the
KwaZulu-Natal province of South Africa. Hibberdene is considered as the gateway to the Hibiscus Coast
and is situated about 97 km south of Durban, located nearly halfway between Scottburgh in the north and
Margate in the south. Hibberdene is a popular tourist attraction due to it being located on the warm Indian
Ocean.

According to the 2016/2017 Ray Nkonyeni Municipality IDP, the administrative seat is located in Port
Shepstone. The Ray Nkonyeni Municipality stretches from Hibberdene in the south to Port Edward on the
Eastern Cape border. The Municipality is in total approximately 837km² in geographic area. The
Municipality consists of twenty nine wards which vary in size and population, with a total population of
256 135 for the whole municipal area.

The Ray Nkonyeni Municipality serves as an economic hub of the Ugu District and is the most developed
and densely populated. Most business activities take place along the coastal belt. In as much as the
Municipality is the economic hub for the entire district, there is a high rate of unemployment due to a
number of social factors. The main features of the local economy are tourism, commercial agriculture and
some limited manufacturing centred around Port Shepstone/Marburg and Margate/Manaba. Other
economic activities include services, fishing, and craft.

Through its Extended Public Works Programme (EPWP), the Municipality provides gap job opportunities
to many unskilled young people and this is implemented mainly through its infrastructure development and
services programme. This creates the need for sand to meet the Local Municipality’s infrastructure and
services development programmes.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
As mentioned already the proposed mine site is surrounded by farms and it is not envisioned to have
significant impacts on local communities. It must however be ensured that mining activities do not
compromise surrounding farming activities of the Applicants neighbours.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
5 IMPACT ASSESSMENT

5.1 I N T R O D U C TI O N
The impact assessment aims at identifying potential environmental impacts (both positive and negative
impacts) and evaluating these impacts in terms of its significance. This assessment is provided in the form
of a systematic analysis framework to evaluate the nature, extent, duration, intensity, probability and
significance of the various impacts considered both without and with mitigation and management measures.
The impact assessment assesses both the impacts of the preferred alternative, as well as the other alternative
options considered in the development proposal and unforeseen cumulative impacts. The mitigation
hierarchy was applied during the BA process and contains steps to mitigate potential impacts of the
proposed mine. The aim of the mitigation hierarchy is to avoid/minimize impacts over rehabilitation and
offsetting.

5.2 I M P AC T A S S E S S M E N T C R I TE R I A
The assessment of the potential impacts of the envisaged development is undertaken in accordance with the
broad criteria required by the integrated environmental management procedure and includes the following:

N A TU R E O F IM P A C T
A brief description of the type of impact the proposed development will have on the affected environment.

E X TE N T /S C A LE
The physical extent of the impact.
i. Footprint
The impacted area extends only as far as the actual footprint of the activity.
ii. Site
The impact will affect the entire or substantial portion of the site/property.
iii. Local
The impact could affect the area including neighbouring properties and transport routes.
iv. Regional
Impact could be widespread with regional implication.
v. National
Impact could have a widespread national level implication.

D U R A TIO N
The duration of the impact.
i. Short term
The impact is quickly reversible within a period of one year, or limited to the construction
phase, or immediate upon the commencement of floods.
ii. Medium term

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 The impact will have a short-term lifespan (project lifespan 1 – 10 years).
iii. Long term
The impact will have a long-term lifespan (project lifespan > 10 years).
iv. Permanent
The impact will be permanent beyond the lifespan of the development.

I N TE N S I TY
This criteria evaluates intensity of the impact and are rated as follows:
i. Minor
The activity will only have a minor impact on the affected environment in such a way that
the natural processes or functions are not affected.
ii. Low
The activity will have a low impact on the affected environment.
iii. Medium
The activity will have a medium impact on the affected environment, but function and
process continue, albeit in a modified way.
iv. High
The activity will have a high impact on the affected environment which may be disturbed
to the extent where it temporarily or permanently ceases.
v. Very high
The activity will have a very high impact on the affected environment which may be
disturbed to the extent where it temporarily or permanently ceases.

P R O B A B I LI TY
This describes the likelihood of the impacts actually occurring.
i. Improbable
The possibility of the impact occurring is highly improbable (less than 5% of impact
occurring).
ii. Low
The possibility of the impact occurring is very low, due either to the circumstances, design
or experience (between 5% to 20% of impact occurring).
iii. Medium
There is a possibility that the impact will occur to the extent that provision must be made
therefore (between 20% to 80% of impact occurring).
iv. High
There is a high possibility that the impact will occur to the extent that provision must be made
therefore (between 80% to 95% of impact occurring).
v. Definite

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 The impact will definitely take place regardless of any prevention plans, and there can only
be relied on migratory actions or contingency plans to contain the effect (between 95% to
100% of impact occurring).

5.2.5.1 DETERMINATION OF SIGNIFICANCE

Significance is determined through a synthesis of the various impact characteristics and represents the
combined effect of the extent, duration, intensity and probability of the impacts.
i. No significance
The impact is not substantial and does not require any mitigatory action.
ii. Low
The impact is of little importance, but may require limited mitigation.
iii. Medium
The impact is of importance and therefore considered to have a negative impact. Mitigation
is required to reduce the negative impacts to acceptable levels.
iv. High
The impact is of great importance. Failure to mitigate, with the objective of reducing the
impact to acceptable levels, could render the entire development option or entire project
proposal unacceptable. Mitigation and management is essential.

The following assessment scale is used to determine the significance of the identified potential
impacts on the environment.

Significance = (probability + duration + scale) x intensity

Probability: 1–5
Extent: 1–5
Duration: 1–4
Intensity: 1 – 10

Significance rating criteria

>75 High environmental significance
50 – 75 Medium environmental significance
<50 Low environmental significance

5.3 IMPACT HIERARCHY

The mitigation hierarchy tool was used to guide the process in dealing with potential impacts of the
proposed Mine and the formulating of the various mitigating and management measures specified in the
section below and the Draft EMP (Appendix 1). The mitigation hierarchy is typically used when planning

45
Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
and implementing development projects in order to provide a systematic, logical and sustainable approach
in dealing with possible impacts associated with the development. This to ensure the positive impacts are
amplified and negative impacts have the lowest possible effect on the receiving environment.

The following steps/hierarchy was utilised as the core in dealing with possible impacts. When mitigation
measures were being formulated to deal with potential impacts, the below measures in the table were used.
The favoured mitigation option was the avoidance of impacts and the least preferred option is offsetting

Avoidance The first step of the mitigation hierarchy comprises of measures taken to avoid
creating impacts from the outset. This is the most environmentally sustainable and
cost effective option.
Minimization The second preferred option involves measures taken to reduce the duration,
intensity and/or extent of impacts that cannot be completely avoided.
Restoration The third preferred option is restoration measures which aim to rehabilitate
degraded or removed ecosystems following exposure to impacts that cannot be
completely avoided or minimised.
Offsetting The least preferred option is offsetting. This involves implementing measures taken
to compensate for any residual, adverse impacts after full implementation of the
previous three steps of the mitigation hierarchy.

5.4 I M P A C TS F R O M S I M I L A R TY P E S O F D E V E LO P M E N T / M I N I N G O P E R A T I O N S
As part of the impact assessment process, impacts from similar types of developments/sand mining
applications were analysed and used to help guide the assessment process for the current Basic Assessment.
While the EAP notes that all projects are unique depending upon local environmental conditions and
engineering designs; examining previously undertaken Basic Assessments of similar types of projects can
assist the EAP in the Impact Assessment process. This to strengthen the quality of the EIA.

5.5 E N V I R O N M E N T A L I M P A C TS O F T H E P R O P O S E D P R E F E R R E D A L T E R N A T I V E
Below contains a description of the anticipated impacts of the proposed preferred alternative as discussed
in Section 2.6 of this Report.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 S O IL E R O S IO N , LO S S O F TO P S O I L A N D C O N TA M IN A TIO N
Soil erosion, contamination, compaction and loss of top soil are significant impacts that may occur during
the site establishment, mine operation and the decommissioning phases of the proposed Mine. This as once
soil is disturbed by mining related activities (EG: mining site set up, the stockpiling of sand and the
indiscriminate and uncontrolled movement of vehicles and equipment) the soil becomes far more
susceptible to erosion, compaction, soil loss and an overall decrease in quality. This makes ongoing
rehabilitation significantly more difficult and favours the spread of invasive alien plants.

Erosion of the soil surface greatly increases the risk of losing topsoil to erosion and impairing the soils
ability to support vegetation growth. Nutrients and seed banks are lost to sun baking and humus content
will often be reduced (oxidised).

A further concern is soil contamination due to chemical spills (Waste, sewage, herbicides and hydrocarbon
spills/leaks/breakdowns from mining equipment etc). This may pose serious hazard to not only the
surrounding environment, but also to human health. Soil contamination can also compromise future
rehabilitation of the site.

Lastly, compaction of soil due to unrestricted vehicle movement on site can potentially occur resulting in
impacts on soil structure which determines the ability of soil to hold water, nutrients, and air.

While all the above impacts must be viewed seriously, it must be noted that these impacts can all easily be
avoided or at the very least be mitigated to acceptable levels with the implementation of strict mitigation
measures as specified in the EMP. Furthermore, mitigation measures will need to be continued during the
Mine Closure and Rehabilitation phase to ensure the abovementioned impacts do not continue post-mining.

Nature Phase Type Extent Duration Intensity Probability WOM WM

Mitigation
1. Soil pollution 1. Clearly demarcate
and the mine extent and
contamination strictly prohibit the
 Hydrocarbon Site movement of
leaks/spills prepar vehicles and
Low
 Chemical spills ation personnel outside of
Negative Site Medium High Medium Medium
 Sewage and the demarcated areas.
leaks/spills Operat 2. Machine and
 Herbicides ion equipment
maintenance must as
far as possible be
undertaken off site.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 3. Inspect all storage
facilities, machinery
and vehicles daily for
the early detection of
deterioration or leaks
4. Fuel, chemicals and
other hazardous
substances must be
stored offsite, or as
far away as possible
from the no-go areas.
These substances
must be stored in
suitable secure
weather proof
containers with
impermeable and
bunded floors.
5. Dispose of used oils
and other pollutants
at an appropriate
licensed landfill site.
6. Provide portable
toilets where work is
being undertaken.
These toilets must be
located outside of the
no-go areas and must
be located on level
ground. Portable
toilets must be
regularly serviced
and maintained.
7. Train employees and
contractors in spill
management and
provide them with
absorbent spill kits
and disposal
containers to handle
spillages.

Site 1. Where roads or soil

2. Compaction of
prepar have become
soils
ation Negative Site Medium Medium Definite Medium compacted, they must Low
and be ploughed, ripped
Operat and re-vegetated.
ion
Site 1. On any areas where
prepar the risk of erosion is
3. Soil Erosion
ation evident, appropriate
Negative Site Long High Definite High Low
and temporary or
Operat permanent works and
ion water energy

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 dispersion structures
must be installed.
2. Schedule the mining
related activities to
minimise the total
amount of soil
exposed at any given
time. In this regard
vegetation must be
cleared and sand
excavated in a phased
approach as
Deco mentioned in the
mmiss Negative Site Long High Definite High Mining Operational Low
ioning Plan (3 block mining
approach).
3. Rehabilitation must
be undertaken
concurrently with
mining activities in
order to reduce the
duration of exposure
of bare soils. The
removal of
vegetation and
exposing of soils
must be phased.
1. Topsoil stripped from
Site
the footprint must not
prepar
be spoiled, but
ation
Negative Site Medium Medium Medium Low stockpiled and Low
and
preserved for later
Operat
use in rehabilitation.
ion
2. Stockpiled topsoil
must be used as the
final cover for all
disturbed areas where
4. Loss of Topsoil re-vegetation is
required.
3. All stockpiles must
Deco
Medium Medium be protected from
mmiss Negative Site Medium Low Low
windy conditions or
ioning
heavy rain. This
includes cloth or
vegetation.
4. All stockpiles must
be kept neat and tidy
and free of weeds.

F R ES H WA TE R I M P A C T S
The impacts on watercourses during the different phases of the Mine lifecycle can be divided into four
categories. These are:
 Disturbance of wetland habitat;
 Erosion and sedimentation of wetland habitat;
 Water quality impairment; and
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
  Alteration of the hydrological regime.

Impact 1: Disturbance of wetland habitat – The Unchannelled Valley Bottom Wetland

The mining related activities is likely to have an impact on the surrounding watercourse. The indiscriminate
movement of vehicles and personnel during the different phases of the mine lifecycle as well as the
inappropriate, storage, handling and dumping of sand and soil may impact on the wetland. This disturbance
may in turn result in the proliferation of alien and invasive species within the wetland. However, the mine
extent is located more than 50m away from the boundary of the unchannelled valley bottom wetland which
reduces the probability of disturbance. Furthermore, the habitat associated with the wetland has already
been transformed as a result of the agricultural activities and the excavation of drainage channels through
the feature.

Impact 2: Erosion and sedimentation of wetland habitat

The removal of vegetation from the mine extent will result in the exposure of soils to erosive elements. The
bare, compacted soils associated with mine pit areas will result in an increase in the volume and velocity of
stormwater runoff when compared to the current scenario. This increase may result in the erosion of the
downslope unchannelled valley bottom wetland. An increase in bare surfaces associated with soil side
slopes and overburden stockpiles, as well as the steep side slopes of stockpiles is also likely to result in an
increase in the movement of eroded sediments into the adjacent wetland with stormwater runoff.

Impact 3: Alteration of the hydrological regime

The interception of water moving through the catchment by the mining pit area, and the subsequent
diversion and discharge of this water as concentrated stormwater flow may result in the alteration of the
hydrology of the downslope unchannelled valley bottom wetland. However, the hydrology of the wetland
has already been transformed as a result of the excavation of an extensive network of drains through the
feature, and as a result of the cultivation of sugarcane within the feature.

Impact 4: Water quality impairment

The movement of vehicles and machinery within the mine extent during the excavation of sand increases
the possibility of the contamination of the downslope wetland area by hydrocarbons, oils and grease which
may leak from the vehicles/machinery or spill during poor dispensing practices and enter into the wetland
with stormwater runoff. Furthermore, contamination of the wetland by sewage may occur as a result of

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 leakages from portable chemical toilet facilities, or the informal use of the wetland area by workers.
Additional impacts to wetlands as a result of the disposal of solid waste including litter may also occur.

Nature Phase Type Extent Duration Intensity Probability WOM WM

Mitigation
1. Pollution of 1. Same measures as
groundwater Section 5.5.1: Soil
and surface pollution and
water – Impact contamination.
on Water 2. The 50m freshwater
Operat
Quality Negative Local Long High Definite High wetland buffer must Low
ion
be strictly enforced.
 Hydrocarbon 3. No water may be
leaks/spills abstracted from any
 Chemical spills surrounding
 Sewage watercourses without
leaks/spills receiving
 Increase in authorisation from
sediments from Deco DWS.
dredging by the mmiss Negative Local Long High Definite High Low
floating barge ioning
and suction pipe

2. Disturbance of 1. Clearly demarcate

the the Mining site with
Unchannelled tape or with white
valley bottom painted pegs/rocks.
wetland Site Mining activities
prepar Negative Local Long Medium Medium Medium must be strictly Low
ation confined to this
demarcated area.
This must be
monitored by the
independent ECO.
2. Appropriate action
must be taken due to
any disturbance of
the Unchannelled
valley bottom
wetland.
Rehabilitation must
Operat be immediately
Negative Local Long Medium Medium Medium implemented and Low
ion
reported to DWS.
3. Strictly control the
spread of invasive
alien plants as per the
Alien Management
Plan in the EMP
(Appendix 1)

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
3. Alteration of the 1. Implement the
hydrological stormwater
regime management
measures as specified
in the Mining
Operational Plan
(Appendix 4). This
includes the
installing of silt traps
Operat and berms.
Negative Local Permeant High High High 2. Strategically divert Low
ion
stormwater runoff
from cleared areas
into sediment
trapping devices.
3. Divert stormwater
away from areas
susceptible to
erosion.
4. Stormwater must
then be discharged at
multiple points, as
diffuse flow into well
vegetated areas
outside of the no-go
areas. Silt must be
removed from the
sediment trap
devices.
5. Energy dissipaters
(such as areas of rock
riprap grassed with
indigenous
vegetation) must be
constructed where
stormwater is
released in order to
reduce the water
Deco velocity and
mmiss Local Permeant High High High therefore erosion. Low
Negative 6. The Mining pit areas
ioning
must be rehabilitated
concurrently with
mining activities.
Rehabilitation must
include the
reprofiling of
disturbed areas to
resemble pre-
disturbance terrain
units, avoiding steep
slopes and
concentrated flow
paths; and must
ensure that the
interception and
ponding of
stormwater is
prevented.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
4. Erosion and Mitigation measures are
sedimentation the same as Alteration of
of watercourses the hydrological regime
and Erosion.
Site Negative Local Long High Medium Medium
prepar Low
ation

Operat Negative Local Long High Medium Medium

Low
ion

Deco Negative Local Long High Medium Medium

mmiss Low
ioning

F LO R A AND FAUNA
The proposed mining related activities will have limited impacts on both the flora and to a smaller degree
fauna of the area. Alien vegetation is likely to proliferate in areas disturbed. An increase in stormwater
runoff from the hardened surface of the access routes and the concentration of runoff from the pit itself
could potentially result in erosion damage to adjacent areas and in the associated disturbance of vegetation.
Minor impacts on fauna may further occur. This due the presence of human activities and movement of
vehicles. However, there is significant fauna habitat surrounding the site, which fauna may move into
during mining activities. Smaller fauna species such as snakes, small mammals can be moved to the adjacent
areas under the supervision of the ECO.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Nature Phase Type Extent Duration Intensity Probability WOM WM
Mitigation
1. No trapping, snaring,
1. Impact on hunting, fishing or
faunal activity killing of any animal
must occur on the
site.
2. Any malicious
damage to any fauna
species present on
site will be
Site
considered a
prepar
punishable offence,
ation Negative Local Medium High High Medium
and the appropriate Low
and
measures will be
Operat
followed.
ion
3. Limit the clearing of
vegetation, removal
of logs, rocks etc.
4. Contact an
appropriate
professional when
smaller animals need
to be removed from
the mining site.
2. Spread of Site 1. Invasive alien plants
invasive alien prepar must be immediately
plants ation Negative Site Long Medium High Medium removed from the
Low
and mining site.
Operat 2. Alien species
ion removal is to take
place manually, by
hand as far as
possible. The use of
herbicides must be
avoided. Should the
use of herbicides be
required, only
herbicides which
have been certified
safe for use in aquatic
environments by an
independent testing
authority must be
considered.
Deco
Negative Site Long Medium High Medium 3. Dispose of removed
mmiss Low
alien plant material at
ioning
a registered waste
disposal site.
4. Remove vegetation
before seed is set and
released.
5. Cover the removed
alien plant material
properly when
transported, to
prevent it from being
blown from vehicles.
6. Rehabilitation
measures must be
undertaken
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 concurrently with
mining activities and
must ensure that
post-mining land use
requirements are met.

N O IS E I M P A C TS
Mining activities are likely to result in the creation of increased noise levels. This due to the operation of
machinery essential for the mining process. Due to the small nature of the mining activities, this impact
will be low.
Probabili
Nature Phase Type Extent Duration Intensity WOM Mitigation WM
ty
1. Noise levels must
be kept within
acceptable limits.
Site 2. Noise suppression
prepar measures must be
1. Noise impacts applied to all
ation Low
Negative Local Medium Medium Definite Medium phases of the mine
and
Operat lifecycle.
ion 3. Mining activities
must not occur on
weekends and
afterhours.

A IR Q U A LI TY
Dust is likely to be created due to the movement of mining equipment along the existing dirt access track
and the stockpiling of sand. Dust can be a nuisance but can, to a large extent, be controlled (especially due
to the project footprint being small).

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM

1. During windy or dry
periods, dust
suppression techniques
must be implemented.
2. Vehicles and
1. Air Site
equipment must be
pollution preparat
properly maintained to
and creation ion and Negative Local Medium Low High Low Low
limit the release of
of dust Operatio
harmful gases.
n
3. Exhaust emission
control devices are to
be installed on vehicles
and/or machinery
where practical.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 L IG H T
Light pollution may be created during the operational phase of the mine.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM

1. Operational hours
during mining will be
Site
restricted from
1. Light preparat
Monday to Friday
pollution ion and Negative Site Short Minor Definite Low Low
07h00 to 17h00.
Operatio
2. Implement light
n
suppression
techniques.

V IS U A L
The proposed mining area, stockpiling area and the usage of mining related equipment will impact on the
aesthetic value of the surrounding area.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM

1. The site must be kept
neat and tidy at all
times.
2. Implement the three
Site block approach as
prepar specified in the Mining
1. Visual
ation Operational Plan Low
Impact Negative Site Long Medium High Medium
and (Appendix 4).
Operat Therefore only a small
ion portion of the mining
site will be cleared at
any one time and will
be more aesthetically
appealing.

S O LID W A S TE D IS P O S A L
Inappropriate location of solid waste storage and disposal services may lead to litter, pollution and general
nuisances and health hazards. This solid waste may enter into the surrounding wetland and further degrade
this feature. Solid waste may further blow into surrounding farms.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM

1. Ensure sustainable waste
Site management practises
1. Waste prepar are in place.
disposal ation 2. Bins must be provided on
Negative Local Medium Medium Medium Medium
and site and coded. Low
Operat 3. Hazardous waste must be
ion separated from the
normal waste flow.
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 4. Littering by the workers
must not be allowed.
5. All waste must be
disposed of at a
registered landfill site.

T R A F F IC
Limited traffic volumes will be created during the site preparation phase and the hauling of sand to the
market during mine operation. Due to the small size of the proposed mine, this impact will be low.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM

1. Vehicle access must be

strictly contained onsite.
Vehicles may only use
designated routes and
access points as
Site
determined by the ECO
1. Increase in prepar
and Mine Manager
Traffic ation Negative Local Short Low Low Low
before operations
and Low
commence.
Operat
2. Access road and loading
ion
area will be properly
maintained, and this
includes appropriate
stormwater management
and dust control.

S O C IA L
The proposed mining related activities will have positive impacts on the local economy, which will in turn
have numerous social benefits. The operational phase will result in employment opportunities being created
for the surrounding communities. Sand for the local building industry will further be available.

Nature Phase Type Extent Duration Intensity Probability WOM Mitigation WM

Positive Regional Long Long Long N/A N/A N/A

1. Access to the mining

site will be
Site restricted.
prepar 2. All workers must
1. Social
ation wear identifiable
impacts
and clothing at all times
Operat Negativ
Local Long Low Medium Low while on the Low
ion e
property.
3. All workers must be
provided with safety
equipment as
required
(respirators, masks,
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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 helmets, safety
boots, safety gloves,
aprons, goggles etc.).
4. A dedicated first
aider must be
available at all times
during mine
operation.

5.6 I M P A C TS P E R TH E D I F F E R E N T P H AS E S O F T H E M I N E L I F E C Y C LE
Table 5.1: Summary of impacts per the different phases of the mine lifecycle
Activities Phases Impacts
Demarcation of mining site and Site Establishment Soil erosion, soil compaction, soil
mining site Set up. and Preparation contamination, loss of fertile top soil,
disturbance of wetland habitat, Erosion
and sedimentation of wetland habitat,
flora and fauna impacts, noise impacts,
air pollution, impact on traffic, creation
of waste and visual impacts.
Mining of the sand Operation Soil erosion, soil compaction, soil
contamination, loss of fertile top soil,
impact on water quality, Alteration of the
hydrological regime, disturbance of
wetland habitat, Erosion and
sedimentation of wetland habitat, flora
and fauna impacts, noise impacts, waste
creation and air pollution.
Stockpiling of the sand Operation Soil erosion, soil compaction, soil
contamination, loss of fertile top soil,
impact on water quality, disturbance of
wetland habitat, Alteration of the
hydrological regime, Erosion and
sedimentation of wetland habitat, flora
and fauna impacts, noise impacts air
pollution, impact on traffic, creation of
waste and visual impacts.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Transportation of sand to the Operation Soil erosion, soil compaction, soil
market for sale contamination, loss of fertile top soil,
impact on water quality, disturbance of
wetland habitat, flora and fauna impacts,
noise impacts air pollution, impact on
traffic and creation of waste.
Decommissioning of the sand mine Site Closure and Soil erosion, soil compaction, soil
and the implementation of a Rehabilitation contamination, loss of fertile top soil,
Closure and Rehabilitation Plan impact on water quality, Erosion and
sedimentation of wetland habitat,
Alteration of the hydrological regime,
flora and fauna impacts, noise impacts air
pollution and visual impacts.

5.7 A L TE R N A T I V E S I M P AC T A S S E S S M E N T
Due to the limited alternative options available, no impact assessment of these alternatives were required.
The EAP determined that impacts assessed for the preferred alternative would not be any different to
alternative options considered as part of the application.

5.8 ENVIRONMENTAL IMPACT STATEMENT AN D SUMMARY ON NEED AN D

D E S I R A B I LI T Y

E N V IR O N M EN TA L I M P A C T S TA TE M E N T
The impact assessment for the proposed Snyman Family Trust Mine illustrates that there is a potential for
both positive and negative impacts. However, it is further noted by the EAP that the proposed Mine is to
be developed upon farmland currently under pasture, with the site being completely transformed and
containing no watercourses or indigenous vegetation. With the strict implementation of the 50m freshwater
buffer and the various recommendation measures stipulated in this Report and EMP (Appendix 1) all
impacts can be mitigated to a Low significance. Therefore the proposed Snyman Family Trust Mine is
recommended by the EAP.

Table 5.2 below considers both the advantages and disadvantages of the proposed Snyman Family Trust
Mine:

Table 5.2: Advantages and Disadvantages of the proposed Snyman Family Trust Mine

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Advantages Disadvantages
Provides sand for the building industry. May impact on the already degraded
Unchannelled Valley Bottom Wetland.
Aids the Applicant (a farmer) diversify Noise impacts due to mining activities.
income generation opportunities.
Creation of employment opportunities. -
Local economic development. -

5.9 THE WATERCOURSE BUFFER

Buffer zones protect aquatic resources from the effects of adjacent development and/or land use changes.
The Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016) was utilised
in order to determine an appropriate buffer area for the unchannelled valley bottom wetland. Factors such
as the proposed activity as well as the PES and EIS of the wetland were considered during the calculation
of the appropriate buffer area. The slope, vegetation characteristics, soil permeability and micro-topography
of the buffer were also considered when determining the width of the buffer area.

Considering the mitigation measures which will be implemented in order to avoid disturbance to the
wetland, a buffer zone of 20m was calculated for the wetland for both the site preparation and operational
phase of the mining activities. However, according to Macfarlane and Bredin (2016), the buffer zone
guidelines do not specifically address impacts of mining on groundwater and hillslope hydrological
processes which are important aspects to consider when establishing set-back requirements. It is therefore
the opinion of the specialist that a larger buffer area is applied to the wetland in order to protect the feature
from groundwater and hydrological related impacts. It is therefore recommended that all areas to the south
of the proposed mine extent, within a 50m buffer of the wetland, are allocated as no-go zones wherein
mining related activities must be strictly prohibited as per Figure 5.1 below

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
5.1: Proposed Mining buffer for the proposed Snyman Family Trust Mine

5.10 FINANCIAL PROVISION

In the event of environmental damage, an amount must be made available for premature closure, as
facilitated through the DMRE and its own internal policy and permit application processing procedures.
The rehabilitation fee amount will be provided in the final report, following consultation with the DMRE.

E X P LA IN H O W TH E F I N A N C IA L P R OV IS IO N W AS O B TA IN ED
The amount allocated for Financial Provision was calculated according to the guideline for the Calculation
of the Quantum for Rehabilitation as provided by DMRE. The rehabilitation fee is thus calculated based on
the size of a mining operation less than 5 ha.

5.11 U N C E R T A I N T I E S /G AP S I N K N O W L E D G E
As far as possible, the Environmental Impact Assessment has attempted to assess all potential
environmental impacts and provide suitable mitigation measures to ensure impacts are kept to a minimal.
No gaps or uncertainties were noted by the EAP.

5.12 P R O P O S E D C O N D I T I O N S T O I N C L U D E I N TH E E N V I R O N M E N T A L A U TH O R I S A T I O N
( I F GR A N TE D )
All mitigation measures specified in this BA Report and in the EMP (Appendix 1) are legally binding and
must be implemented.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 5.13 PROPOSED IMPACT MANAGEMENT OBJECTIVES AND THE IMPACT
MANAGEMENT OUTCOMES FOR INCLUSION IN THE EMP
The EMP addresses the environmental impacts associated with the project during its entire lifecycle. The
objective is to provide guidance to the Applicant to ensure identified impacts are either avoided or mitigated
to acceptable levels. Accordingly, the following environmental management objectives are recommended
for the proposed Snyman Family Trust Sand Mine:
• The Mining site must be clearly demarcated and operations confined to the designated areas
only;
• Implement the strict pollution control measures to prevent environmental damage to the
surrounding watercourses, land and wetland vegetation;
• Implement mitigation measures specified in the various specialist reports undertaken;
• Implement the proposed Freshwater Buffers;
• Ensure strict erosion control and stormwater management measures are in place;
• Rehabilitate and restore the surrounding environment; and
• Appoint an independent ECO to monitor the implementation of the EMP.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
6 SUMMARY OF RECOMMENDATIONS AND CONC LUS ION

It is the opinion of the EAP that the mining project can be supported on condition that the Mitigation and
Management measures described in Section 5 hereof and in the EMPr (Appendix 1 hereto) should be
strictly adhered to by the Applicant.

A variety of mitigation measures have been identified that will serve to mitigate the scale, intensity, duration
and significance of the impacts of the proposed Snyman Family Trust Sand Mine. The proposed mitigatory
measures, if implemented, will reduce the significance of the identified impacts and allow for the proposed
Mine to proceed with minimal effect to the environment, local community and surrounding land use
practices.

IDM Environmental recommends the following (must be included in the EMP):

 Implement pollution control measures;
 Implement the 50m freshwater buffer;
 Implement mitigation measures specified in the various specialist reports undertaken;
 Limit the removal of vegetation as far as possible;
 Ensure strict erosion control and stormwater management measures are in place; and
 Rehabilitate and restore any transgressions into the surrounding environment.

It is the opinion of the EAP that the information contained in the Basic Assessment Report, and the specialist
studies, have been compiled to address specific areas of concern, and provide sufficient information to
undertake a sound assessment of the proposal and provide an informed recommendation with a sufficient
degree of confidence.

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
 Annexure A: Regional Locality Map

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application
Annexure B: Schematic Mining Sketch Layout Plan

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Basic Assessment Report (Draft 1): The Snyman Family Trust Mining Permit Application