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Page 1: APPENDIX 25 - gcs-sa.bizLeopard Court Building, 1st Floor, South Wing 56 Jerome Street, Lynnwood Glen, Pretoria, South Africa Tel: +27 (0) 12 348 1114 Fax: +27 (0) 12 348 1180 Web:

APPENDIX 25

PUBLIC PARTICIPATION

Page 2: APPENDIX 25 - gcs-sa.bizLeopard Court Building, 1st Floor, South Wing 56 Jerome Street, Lynnwood Glen, Pretoria, South Africa Tel: +27 (0) 12 348 1114 Fax: +27 (0) 12 348 1180 Web:

Leopard Court Building, 1st Floor, South Wing 56 Jerome Street, Lynnwood Glen, Pretoria, South Africa Tel: +27 (0) 12 348 1114 Fax: +27 (0) 12 348 1180 Web: www.gcs-sa.biz

GCS (Pty) Ltd. Reg No: 2004/000765/07 Est. 1987

Offices: Durban Gaborone Johannesburg Lusaka Maseru Ostrava Pretoria Windhoek

Directors: AC Johnstone (Managing) PF Labuschagne AWC Marais S Napier W Sherriff (Financial)

Non-Executive Director: B Wilson-Jones

www.gcs-sa.biz

4a Old Main Road, Judges Walk, Kloof, Kwazulu-Natal, South Africa, 3610 PO Box 819, Gillitts, 3603, South Africa Tel: +27 (0) 31 764 7130 Fax: +27 (0) 31 764 7140 Web: www.gcs-sa.biz

Proof of Public Participation Report:

Aviemore North Adit and Access Road, Dundee,

KwaZulu-Natal

Version: Final

20 August 2018

GCS Project Number: 18-0553

Prepared for: Zinoju Coal (Pty) Ltd

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18-0553 20 August 2018 Page ii

Proof of Public Participation Report: Aviemore North Adit and Access Road, Dundee, KwaZulu-

Natal

Version – Final

20 August 2018

Zinoju Coal (Pty) Ltd

DOCUMENT ISSUE STATUS

Report Issue Final

GCS Reference Number 18-0553

Title Proof of Public Participation Report: Aviemore North Adit and

Access Road, Dundee, KwaZulu-Natal

Name Signature Date

Author Nakéla Naidoo

20 August 2018

Document Reviewer Brendan Smith 20 August 2018

Director Pieter Labuschagne

20 August 2018

LEGAL NOTICE This report or any portion thereof and any associated documentation remain the property of GCS until the mandatory effects payment of all fees and disbursements due to GCS in terms of the GCS Conditions of Contract and Project Acceptance Form. Notwithstanding the aforesaid, any reproduction, duplication, copying, adaptation, editing, change, disclosure, publication, distribution, incorporation, modification, lending, transfer, sending, delivering, serving or broadcasting must be authorised in writing by GCS.

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 13 November 2018 Page 1

CONTENTS PAGE

1 INTRODUCTION .......................................................................................................................... 2

2 AUTHORITY CONSULTATION ....................................................................................................... 2

2.1 PRE-APPLICATION MEETING ........................................................................................................................... 2 2.2 SITE VISIT ................................................................................................................................................... 3

3 NOTIFICATION OF INTERESTED AND AFFECTED PARTIES............................................................. 3

3.1 PHASE 1: PROJECT ANNOUNCEMENT ............................................................................................................... 3 3.2 PHASE 2: INFORMATION REVIEW .................................................................................................................... 4 3.3 PHASE 3: UPDATE ON IWULA ....................................................................................................................... 4 3.4 LANDOWNER CONSULTATIONS ........................................................................................................................ 4

4 STAKEHOLDER DATABASE .......................................................................................................... 5

5 ISSUES AND RESPONSE SUMMARY ............................................................................................. 5

6 ENVIRONMENTAL IMPACT ASSESSMENT (EIA) APPLICATION ..................................................... 6

7 ADDITIONAL PPP ........................................................................................................................ 6

8 CONCLUSION .............................................................................................................................. 6

LIST OF TABLES

Table 3-2: Landowner Consultation Undertaken by Buffalo Coal......................................................... 4 Table 5-1 Comments received from I&APs................................................................................... 5

LIST OF APPENDICES

APPENDIX A: 19 JUNE 2017 PRE-APPLICATION MEETING ................................................................... 7

APPENDIX A1: MEETING MINUTES ..................................................................................................... 8

APPENDIX A2: ATTENDANCE REGISTER .............................................................................................. 9

APPENDIX B: 02 OCTOBER 2017 PRE-APPLICATION MEETING .......................................................... 10

APPENDIX B1: MEETING MINUTES ................................................................................................... 11

APPENDIX C: PHASE 1 PPP ................................................................................................................ 12

APPENDIX C1: SITE NOTICE ............................................................................................................... 13

APPENDIX C2: ADVERTISEMENT ....................................................................................................... 14

APPENDIX C3: BACKGROUND INFORMATION DOCUMENT .............................................................. 15

APPENDIX D: PHASE 2 PPP ............................................................................................................... 16

APPENDIX D1: SITE NOTICE .............................................................................................................. 17

APPENDIX D2: BACKGROUND INFORMATION DOCUMENT .............................................................. 18

APPENDIX E: STAKEHOLDER DATABASE ........................................................................................... 19

APPENDIX F: SUBMISSIONS FROM I&APS AND STAKEHOLDERS ....................................................... 20

APPENDIX G: I&AP MEETING – ATTENDANCE REGISTER ................................................................... 21

APPENDIX H: EIA APPLICATION - ACKNOWLEDGEMENT OF RECEIPT ................................................ 22

APPENDIX I: NOTIFICATION EMAIL FOR IWULA UPDATE .................................................................. 23

APPENDIX J: LETTER ADDRESSING CONCERNS REGARDING DEWATERING AND UNDERGROUND DUST SUPPRESSION AT AVIEMORE COLLIERY ............................................................................................ 24

APPENDIX K: BUFFALO COAL AFFIDAVITS ......................................................................................... 25

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1 INTRODUCTION

Aviemore Colliery (Aviemore) is an existing operational anthracite mine that is operated by Buffalo

Coal (Pty) Ltd (Buffalo), located 8 kilometres (km) north-west of the town of Dundee and east-

northeast of the City of Durban, in the northern KwaZulu-Natal (KZN) Province of South Africa.

Aviemore’s mining rights (MRs) are held by Zinoju Coal (Pty) Ltd (Zinoju). A new access road and adit

is required to optimally and efficiently exploit the full extent of the Aviemore coal reserve. Thus, the

proposed project includes the development of a North Adit and Eastern Access Road, hereafter

referred to as the Aviemore North Adit.

The application for Environmental Authorisation (EA) and an Integrated Water Use Licence Application

(IWULA) has been undertaken on behalf of Zinoju. The EA application to undertake the relevant listed

activities was submitted to the relevant Competent Authority (CA) that is, the Department of Mineral

Resources (DMR) on the 13th of February 2018. The application was finalised and submitted to the DMR

for decision on the 16th of May 2018. The relevant CA for the IWULA is the Department of Water and

Sanitation (DWS), as such, the IWULA will be submitted to DWS.

In terms of Regulation 17 (2) of the National Water Act, 1998 (NWA) Regulations regarding the

procedural requirements for Water Use License Applications and Appeals (GNR 267, 24 March 2017),

where a Public Participation Process (PPP) has already been undertaken through the Environmental

Impact Assessment (EIA) processes or any other public consultation process, and that PPP contains

and covers all issues pertaining to water use activities, then that PPP report may, subject to approval

by the responsible authority, be submitted for the requirements of the IWULA. As such, the PPP

conducted during the Basic Assessment (BA) process will be submitted to fulfil the requirements of

the current IWULA.

The purpose of this Proof of Public Participation Report is to provide details on the PPP which was

conducted during the BA process, although no comments from stakeholders were received.

2 AUTHORITY CONSULTATION

2.1 Pre-application Meeting

An initial pre-application meeting was held with representatives of GCS (Pty) Ltd (Brendan Smith),

DMR (Karoon Moodley) and the DWS (Lindiwe Dladla), on 19 June 2017, to introduce the proposed

project, explain the project details and obtain input and clarity regarding the required legislative

processes to be followed. Minutes for this pre-application meeting and a copy of the attendance

register can be found in Appendix A1 and Appendix A2 of this report.

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A second pre-application meeting was held with representatives of GCS (Brendan Smith) and DWS

(Colleen Moonsamy, Thulani Mbokodo and Ayanda), on 02 October 2017, to obtain clarity from the

authorities regarding the required IWULA legislative processes to be followed for the new water uses.

Minutes for this pre-application meeting can be found in Appendix B1.

2.2 Site Visit

A site visit to confirm the water used applied for in the IWULA has not been conducted at this stage.

3 NOTIFICATION OF INTERESTED AND AFFECTED PARTIES

Key stakeholders were identified for inclusion in the PPP, such as municipal authorities, surrounding

landowners, government departments and environmental groups that have jurisdiction over, or

potential interest in, the activity.

The Interested and Affected Party (I&AP) Notifications proceeded in three phases. The first phase

involved a project announcement phase, notifying and identifying all potential I&AP’s of the project,

which was still at the design phase and included two adit and access route alternatives. The second

phase included notification to all I&APs identified during phase one, and presented the finalised plans

incorporating the North Adit and Eastern Access Route. The third phase of notifications to all I&APs

included the notification of the finalisation and submission of the IWULA process, and informed the

I&APs of the availability of the final documentation and report, on the GCS website. The phases

proceeded as follows:

3.1 Phase 1: Project Announcement

The following methods were used to notify the public and potential I&APs of the project:

Two (2) A2, laminated site notices (attached in Appendix C1) were placed at the following locations

on the 18th October 2017:

Dundee Local Library; and

Along the P272 Provincial Road, in close proximity to the proposed North Adit access road’s

intersection with the P272.

An initial advertisement regarding the project and application processes being undertaken was placed

in the Northern Natal Courier Newspaper on 20 October 2017 (Refer to Appendix C2). Background

Information Documents (BIDs), which contained a brief project description, locality map, description

of the application processes and public participation process, as well as registration forms were

produced in English and distributed to registered I&APs via fax, email and registered mail on the 18th

October 2017. This document is attached in Appendix C3 of this report. The phase 1 PPP ran from the

18th October 2017 to the 18th November 2017.

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3.2 Phase 2: Information Review

The following methods were used to notify the public and registered I&APs of the project:

Three (3) A2, laminated site notices (attached in Appendix D1) were placed at the following locations

on the 23rd February 2018:

Dundee Local Library;

Entrance to Dundee Sewende Dag Adventure Kerk & Vulindlela Bush Camp; and

Along the P272 Provincial Road, in close proximity to the North Adit’s access road intersection

with the P272.

BIDs, which contained a brief project description, locality map, description of the application

processes and public participation process, as well as registration forms, were produced in English

and distributed to registered I&APs via fax, email and registered mail on the 23rd February 2018 (Refer

to Appendix D2). All I&APs were notified regarding the availability of further information (draft

reports) for their review. The second phase of the PPP ran from the 23rd February 2018 to the 26th

March 2018.

3.3 Phase 3: Update on IWULA

All I&APs were updated on the status of the IWULA via email on the 20th August 2018. The purpose of

this notification was to ensure that all I&APs were aware of the intended date of submission of the

IWULA, the water uses being applied for and the availability of the final IWWMP Report on the GCS

company website. The notification email included a list of all water uses and the final master layout

plan. Furthermore, the I&APs were invited to review the final documentation and submit comments

regarding the report, which will be forwarded to the DWS assessing officer. Copies of the notification

emails can be found in Appendix I of this report.

3.4 Landowner Consultations

Zinoju Coal engaged with all affected landowners with regards to the proposed water use activities.

The landowners and persons occupying the property were consulted, informed and updated with

regards to the proposed activities on their properties, and were requested to sign the DW902 and

DW755 forms. A diary was maintained with regards to all consultations/visits to landowners that were

undertaken by Buffalo. The landowners and tenants that were consulted and the corresponding dates

are listed in Table 3-1.

Table 3-1: Landowner Consultation Undertaken by Buffalo Coal Date Landowner Consulted

31 May 2018 Johnson, Holiday

1 June 2018 Emslie, Mkhize, Mohammed

21 June 2018 Goetch

26 June 2018 Emslie, Mohammed, Goetch, Maree

27 June 2018 Johnson, Long Ismail

28 June 2018 Emslie, Long, Johnson

29 June 2018 Holiday, Emslie

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2 July 2018 Mohammed

3 July 2018 Maree

6 July 2018 Ismail, Goetch, Emslie, Johnson, Mkhize

10 July 2018 Ismail

31 July 2018 Goetch, Maree, Mkhize

3 August 2018 Karim

7 August 2018 Goetch

16 August 2018 Goetch

17 August 2018 Goetch

4 STAKEHOLDER DATABASE

According to Regulation 18 of GNR 267 (2017), the applicant is required to create and maintain a

register containing the names, contact details and addresses of all persons that register as an I&AP

during the BA and IWULA process. A copy of this register can be found in Appendix E.

5 ISSUES AND RESPONSE SUMMARY

During Phase 1 of the PPP, a comment was received from one of the I&APs. This comment has been

summarised in Table 5-1 below. The original copy of the received submission from the I&AP is included

in Appendix F.

Table 5-1 Comments received from I&APs

NAME FORMAT OF

COMMENT

ISSUE/COMMENT RAISED RESPONSE

Eskom

Michelle Nicol Email received on 18 Oct 2017

Eskom has infrastructure in place in the proposed study area thus, will need to be registered as an I&AP.

Eskom was registered as an I&AP

No comments from the I&Aps were received during Phase 2 of the PPP.

Zinoju Coal engaged with residents in close proximity to the proposed site (namely the owner of the

Joubert Farm and the residents of the homestead in close proximity to the intersection of the P272

and proposed access road). The attendance register of the homestead meeting is provided in Appendix

G of this report. Neither of these I&AP’s commented on the proposed project.

During the process of obtaining landowner consent for the applicable water uses, several landowners

were unwilling to sign the landowner consent forms (please refer to the Affidavits in Appendix K).

The following landowners were unwilling to give their consent:

Mr. Karrim (Wild Duck Vlei A No. 7871)

Mr Ferreira (Woodlands No.8485 Ptn 2)

Mr. Mchunu (Cleveland No.15597 Ptn 1)

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The underlying reason for this was that the landowners who rely on spring water and borehole water

were concerned that the mines proposed water usage originating from the underground mine

activities will impact on the water quality and quantity of their springs and boreholes. To address this

issue, GCS as an impartial third party, drafted a letter indicating that the underground dust

suppression activities will have no significant effect on the groundwater quality and that the volume

of water used for this process is considered as negligible. This letter was based on the findings of

routine monitoring undertaken surrounding the Aviemore Colliery dating back to 1998, and anticipated

impacts assessed during this North Adit application. Furthermore, the letter indicated that any land

user within the predicted zone of impact, provide their coordinates to Buffalo Coal so that the springs

can be included in the routine quarterly monitoring programme. A copy of this letter can be found in

Appendix J.

6 ENVIRONMENTAL IMPACT ASSESSMENT (EIA) APPLICATION

The EIA application to undertake the listed activities was submitted to the DMR on the 13th of February

2018. GCS received the acknowledgement of the application form from DMR. A copy of the

acknowledgement of receipt is included in Appendix H. The Report was made available for I&AP’s to

review at public venues for a 30 day comment period from the 18th of October until the 20th of

November 2017. Due to low interest in the project from the public, a public meeting was not deemed

necessary. The final report was submitted to the DMR for decision on 16 May 2018.

7 ADDITIONAL PPP

Following the submission and subsequent rejection of the IWULA by the DWS, an additional PPP of 60

days is required following the updating and finalisation of the IWULA. This PPP commenced on the

14th November 2018 and will end on the 5th February 2019. At the cessation of the PPP, the Proof of

Public Participation report will be updated to include the comments and responses received during

the 60 day period. The updated report will be submitted to the DWS assessing officer as part of the

IWULA.

8 CONCLUSION

This report forms part of the Integrated Water and Waste Management (IWWMP) Report for the

proposed Aviemore North Adit and Access Road project. The report aimed to summarize the comments

received through the Basic Assessment and IWULA process, in line with the reporting requirements in

regulation 44 of the EIA regulations, 2014 as amended. To date, there has been a low level of public

interest in the proposed project.

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APPENDIX A: 19 JUNE 2017 PRE-APPLICATION MEETING

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APPENDIX A1: MEETING MINUTES

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16-1447 11 July 2017 Page 1

4a Old Main Road, Judges Walk, Kloof, Kwazulu-Natal, South Africa, 3610 PO Box 819, Gillitts, 3603, South Africa Tel: +27 (0) 31 764 7130 Fax: +27 (0) 31 764 7140 Web: www.gcs-sa.biz

Our Reference 16-1447

Your Reference Aviemore New Adit and Access Road

Meeting Minutes

The purpose of this meeting was to meet with the authorities to introduce the proposed

project, explain the project details and obtain input and clarity from the authorities

regarding the required legilsateive processes to be followed (IWULA and EIA).

This memo includes brief minutes of this meeting.

Subject: Aviemore New Adit and Access Road Pre-Application Meeting

Venue: Department of Mineral Resources (Durban Bay House, 333 Anton

Lembede Street, Durban), Boardroom

Date:

Time:

19/06/2017

14:00

Attendance: Brendan Smith (GCS) (BS)

Karoon Moodley (DMR) (KM)

Lindiwe Dladla (DWS) (LD)

Apologies: n/a

Distribution: Attendees, Zinoju Coal

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ITEM ACTION

Project Background and Introduction

Brendan Smith (BS) explained that a need has been identified to construct

an additional adit to ensure mining operations can continue and that the

available mineral resources can be more efficiently extracted by Zinoju

Coal. The proposed project entails the construction of the main North Adit,

an Alternate Eastern Adit and Raise Bore, and an access route from the P272

Road to the North Adit. Coal will be hauled from the North adit, along the

new access road to the P272 where existing haul routes will be followed to

Coalfields Processing Facility. The alternate eastern adit will be used for

employee access only, and no coal will be transported from this adit. As

such, existing farm roads will be used to access the Alternate Eastern Adit

site. This proposed project does not entail an expansion to the current

mining operations at Aviemore, but is a relocation of existing surface

infrastructure from the current adit site. The new adit site is situated on

the Remainder of Morgenstond No 3347. The proposed access road traverses

the Remainder of Morgenstond No 3347 and Alletta No. 4350, Portion 3, from

the proposed North Adit to the P727 Road.

Karoon Moodley (KM) enquired whether the application is on an existing MR

(MR174). BS confirmed. KM requested BS to enquire with Mine Economics

to confirm, KM to provide contact details.

KM

2. Legislative Requirements

Lindiwe Dladla (LD) does not believe the application warrants a new IWULA

or an amendment, she will need to obtain clarification from Licensing

Department (Shaun Naidoo). BS to send KMZ files to LD. LD to provide

feedback on way forward with regards to IWULA.

BS listed the triggered activities identified by GCS, which necessitate a Basic

Assessment (BA) Process to be undertaken. KM agreed but will only confirm

on submission of application form by GCS.

BS, LD

BS

3. Specialist Studies

BS listed the specialist studies currently being undertaken, which include

the following:

1. Heritage;

2. Fauna;

3. Flora;

4. Traffic;

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ITEM ACTION

5. Surface Water; and

6. Ground Water.

KM did not see the need for any additional specialist studies.

Due to the stream crossings of the access road, LD thinks a wetland study

should be undertaken. LD to provide confirmation of this.

LD

4. Open Discussion

KM noted Buffalo Coal’s shortfalls/underfunding with regards to mine

closure costs, DMR will withhold all approvals/applications if this is not

sorted out. BS to inform Buffalo Coal of this.

Once the EA is drafted, DMR will request first year liability costs, once this

is provided the EA will be granted. EA will be withheld until this is provided.

BS

5. Conclusion

DMR to confirm legislative process upon receipt of an application form

LD to provide confirmation on IWULA requirements

LD to provide confirmation on specialist study requirements

Meeting end 14:32

BS

LD

LD

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22 June 2017 Page 4

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APPENDIX A2: ATTENDANCE REGISTER

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APPENDIX B: 02 OCTOBER 2017 PRE-APPLICATION MEETING

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APPENDIX B1: MEETING MINUTES

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16-1447 5 October 2017 Page 1

4a Old Main Road, Judges Walk, Kloof, Kwazulu-Natal, South Africa, 3610

PO Box 819, Gillitts, 3603, South Africa

Tel: +27 (0) 31 764 7130 Fax: +27 (0) 31 764 7140 Web: www.gcs-sa.biz

Our Reference 16-1447

Your Reference Aviemore New Adit and Access Road

Meeting Minutes

The purpose of this meeting was to meet with the authorities to introduce the proposed

project, explain the project details and obtain input and clarity from the authorities

regarding the required IWULA legislative processes to be followed.

This memo includes brief minutes of this meeting.

Subject: Aviemore New Adit and Access Road Pre-Application Meeting

Venue: Department of Water and Sanitation

Date:

Time:

02/10/2017

10:00

Attendance:

Brendan Smith (GCS) (BS)

Colleen Moonsammy (DWS) (CM)

Thulani Mbokodo (DWS) (TM)

Ayanda (DWS)

Apologies: n/a

Distribution: Attendees, Zinoju Coal

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ITEM ACTION

• Project Background and Introduction

• Brendan Smith (BS) explained that a need has been identified to construct

an additional adit to ensure mining operations can continue and that the

available mineral resources can be extracted by Zinoju Coal. The proposed

project entails the construction of the main North Adit, an Alternate Eastern

Adit and Raise Bore, and an access route from the P272 Road to the North

Adit. Coal will be hauled from the North adit, along the new access road to

the P272 where existing haul routes will be followed to Coalfields Processing

Facility. The alternate eastern adit will be used for employee access only,

and no coal will be transported from this adit. As such, existing farm roads

will be used to access the Alternate Eastern Adit site. The new adit site is

situated on the Remainder of Morgenstond No 3347.

• Colleen Moonsamy (CM) stated that this would be a new IWULA.

• CM enquired regarding the processing of the coal, disposal of the discard,

and if the respective facilities are licensed.

• BS explained Buffalo’s three operations, and that coal is processed at

Coalfields in Dundee and all discard disposed of at Magdalena Colliery.

• Coalfields IWULA was submitted in 2013 but not yet approved.

• Magdalena has an approved IWUL.

• CM stated that Aviemore’s IWULA cannot be approved if Coalfields is not

licensed. Additionally, if Aviemore will result in increased volumes at

Coalfield’s and Magdalena Discard Dump, this will need to be reflected in

their respective IWULA’s.

2. Legislative Requirements

• CM confirmed that a new IWULA is required, as the following proposed

activities triggers the following:

• Section 21 (a): Abstraction

• Section 21 (c) and (i): Adit and access Road (to be determined by specialist

study)

• Section 21 (g): Dust Suppression, PCD and temporary stockpiling of ROM

• Section 21 (j): Dewatering of underground workings

3. Specialist Studies

• BS listed the specialist studies currently being undertaken, which include

the following:

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Zinoju Coal Aviemore New Adit and Access Road

16-1447 5 October 2018 Page 3

ITEM ACTION

1. Heritage;

2. Fauna;

3. Flora;

4. Traffic;

5. Surface Water; and

6. Ground Water.

• Due to the stream crossings of the access road, section 21 (c) and (i) is

triggered, and based on the March 2017 legislation requirements a wetland

delineation and aquatic specialist assessment is required.

• BS stated that the area is located on a northern slope in Dundee, it is

extremely dry and the only water courses present are donga systems. No

wetlands are evident. CM stated that a wetland specialist will need to

determine that.

• The March 2017 IWULA legislation states that a hydropedology study is

required for all mining applications.

4. Open Discussion

• The road designs need to be finalised, DWS are only interested in the

portions of the road that affect water resources. Coordinates of each

crossing (culvert, pipes, bridge etc) needs to be provided.

• GN 704 application will cover both adits in one application

• CM enquired about closure/rehabilitation requirements for Aviemore under

the existing IWUL. BS to provide feedback

• 500m buffer from any wetland identified by the wetland specialist.

BS

5. Conclusion

• Hydropedological, aquatic and wetland studies to be undertaken

• Designs to be finalised

• Once designs finalised, application can be submitted

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 20 August 2018 Page 12

APPENDIX C: PHASE 1 PPP

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 20 August 2018 Page 13

APPENDIX C1: SITE NOTICE

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Notice is hereby given in terms of Regulation 40 of the Environmental Impact Regulations published in

Government Notice R 326 in Government Gazette No. 40772 of 7 April 2017, under Section 24(5) of the

National Environmental Management Act, 1998 (Act No.107 of 1998) (NEMA) and in terms of the National

Water Act,1998 (Act No. 36 of 1998) (NWA) of the Basic Assessment (BA) and Water Use Licencing

Application (WULA) processes for the proposed construction of a new adit and associated access road at the

Aviemore Colliery in Dundee, KwaZulu-Natal.

The following authorisations are required:

• Environmental Authorisation in terms of section 24 (2) the National Environmental Management

Act, 1998 (Act No. 107 of 1998) (NEMA);

• Water Use Licence in terms of the National Water Act, 1998 (Act No. 36 of 1998) (NWA).

The NEMA activities which are triggered by the proposed construction of the new adit and associated access

road are listed under Listing Notice 1 of Regulations GNR 327, and as such require an application for an

Environmental Authorisation in the form of a Basic Assessment process.

NOTIFICATION OF AN ENVIRONMENTAL

AUTHORISATION PROCESS:

CONSTRUCTION OF A NEW ADIT AND ACCESS ROAD AT

AVIEMORE, DUNDEE, KWAZULU-NATAL

You are invited to participate in the stakeholder engagement process by registering as an Interested and

Affected Party (I&AP) as well as to raise any issues or concerns about the proposed environmental

authorisation and Water Use License applications, or to submit suggestions regarding the project. As a

registered I&AP, you will receive further information and will be kept informed of the decisions taken by the

competent authorities.

Should you wish to register as an I&AP or to receive a background information document with additional

details on the project, please contact us at the details below by 21 July 2017 :

Brendan Smith GCS (Pty) Ltd

Tel: 031 764 7130

Fax: 031 764 7140

E-mail: [email protected]

or Post: PO Box 819, Gillits, 3603

Publication Date: 21 June 2017

GCS REFERENCE NO: 16-1447

Locality Map

The new adit site is

situated on the Remainder

of Morgenstond No 3347.

The proposed access road

traverses the Remainder of

Morgenstond No 3347 and

Alletta No. 4350, Portion 3,

from the proposed North

Adit to the P727 Road.

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 20 August 2018 Page 14

APPENDIX C2: ADVERTISEMENT

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 20 August 2018 Page 15

APPENDIX C3: BACKGROUND INFORMATION DOCUMENT

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1.

Purpose of this Document

The purpose of this document is to provide all Interested and Affected parties (I&APs)

with information about the proposed construction of a new Adit and Access Road at the

Aviemore Colliery, and to explain the Basic Assessment (BA) and Integrated Water Use

License Application (IWULA) process. This Background Information Document (BID)

also aims to explain the public participation process that is prescribed by the National

Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) which now governs

the Environmental Authorisation (EA) process for mining applications and invites all

I&AP’s to comment on issues and concerns related to the project.

The proposed new adit and access road at Aviemore is located

along the northern flanks of the Impati Mountain, approximately

4 to 8 km north-northwest of the town of Dundee, in the northern

parts of KwaZulu-Natal Province. The site is situated in the

V32E quaternary catchment, within the Thukela Water

Management Area (DWA, 2010).

The new adit site is situated on the Remainder of Morgenstond

No 3347. The proposed access road traverses the Remainder

of Morgenstond No 3347 and Alletta No. 4350, Portion 3, from

the proposed North Adit to the P727 Road.

Location of the Development

Project Description

Aviemore Colliery is a working anthracite mine that is operated by Buffalo Coal (Pty) Ltd (Buffalo), with

mining rights held by Zinoju Coal (Pty) Ltd (Zinoju). Current workings are accessed through an adit located

on Farm Morgenstond No 3347 on the eastern flanks of the Impati Mountain. A need has been identified to

construct an additional adit to ensure mining operations can continue and that the available mineral

resources can be efficiently accessed and extracted. The proposed project entails the construction of the

main North Adit, an alternate Eastern Adit, a Raise Bore, and an access road (western and eastern

alternatives) from the P272 Road to the North Adit. Existing farm roads will be used to access the Alternate

Eastern Adit site. This proposed activity will require an EA due to the potential impacts on the environment,

as well as the undertaking of an IWULA process.

GCS Water and Environment Pty Ltd (GCS) has been appointed to undertake the required EA and IWULA

processes required for the new adit and associated access road.

Background Information Document:

Environmental Authorisation and IWULA for

the proposed construction of the new Adit

and Access Road at Aviemore, Dundee, KZN

Water Use License Application Process

An IWULA is required for this project in terms of the National Water Act, 1998 (Act No. 36 of 1998) due to

the following Section 21 water uses being triggered:

(a) Abstraction of water

(c) Impeding or diverting the flow of water in a watercourse as a result of roads crossing watercourses

(g) Disposing of waste in a manner that may detrimentally impact a water resource

(i) Engaging in a streamflow reduction activity

(j) Removing, discharging or disposing of water found underground

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2 .

Basic Assessment Process

Section 24 of NEMA requires that certain listed activities, which may have an impact on the environment,

trigger the need for environmental authorization from a relevant authority before commencing with the

activities. In terms of the proposed project, the Department of Mineral Resources (DMR) is the competent

authority for this EA. Such activities are listed under Regulations GNR 326 Listing Notice 1 GNR 327, Listing

Notice 2 GNR 325 and Listing Notice 3 GNR 324 (Dated 7 April 2017) of NEMA. The proposed project only

triggers activities from Listing Notice 1 and therefore requires that a BA process be undertaken.

The proposed project triggers the following listed activities under Listing Notice 1 GNR 327:

• Activity 24:

The development of:

(i) A road for which an environmental authorization was obtained for the route determination in terms of

activity 5 in Government Notice 387 of 2008 or activity 18 in Government Notice 545 of 2010; or

(ii) A road with a reserve wider than 13.5 meters, or where no reserve exists where the road is wider than 8

meters;

But excluding

(a) Roads which are identified and included in activity 27 in Listing Notice 2 of 2014;

(b) Roads where the entire road falls within an urban area; or

(c) Which is 1 kilometer or shorter

• Activity 27:

The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation, except

where such clearance of indigenous vegetation is required for:

(i) The undertaking of a linear activity; or

(ii) Maintenance purposes undertaken in accordance with a maintenance management plan

• Activity 56:

The widening of a road by more than 6 meters, or the lengthening of a road by more than 1 kilometer:

(i) Where the existing reserve is wider than 13.5 meters; or

(ii) Where no reserve exists, where the existing reserve is wider than 8 meters;

excluding where widening or lengthening occur inside urban areas.

Potential Listed Activities:

• Activity 14:

The development and related operation of facilities or infrastructure, for the storage, or for the storage and

handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80

cubic meters or more but not exceeding 500 cubic meters.

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3.

Copies of the Draft BA Report will be

made available at the local public libraries

in the area (to be confirmed) and on the

GCS website (www.gcs-sa.biz).

STEP 3: Final BA Report

Include comments received from I&APs

during the review process in the

compilation of the Final BA Report and

EMPr before it is submitted to the DMR

for a decision.

Notify registered I&APs of the submission

of the Final BA Report and EMPr to the

DMR.

STEP 1: Notify I&APs and Identify Issues

Notify I&APs of the proposed project.

Identify any issues / concerns of I&APs.

Provide I&APs with Background

Information Documents (BID) on the

Project, including a locality map.

Request I&APs to register their interests

in the project to receive further project

information.

Coordinate an open day to allow I&APs to

obtain additional information and discuss

their issues with the project team.

STEP 2: I&AP Review of Draft BA

Report

Prepare a comments and response

report which includes issues and concern

raised by I&APs for inclusion in the Draft

BA Report and draft Environmental

Management Program (EMPr).

Notify all registered I&APs on the project

database of the release of the Draft BA

Report and EMPr for a 30 day comment

period.

Public Participation Process (PPP)

I&AP’s may forward their written comments by 18 November 2017 along with their name,

organization, contact details, the project managers name, project name and reference number and

an indication of any direct business, financial, personal or other interest which they have in the

application by post, fax or email to:

GCS Pty Ltd Postal Address:

Brendan Smith PO Box 819

Tel: 031 764 7130 Gillitts

Fax: 031 764 7140 3603

Email [email protected] South Africa

Environmental Assessment Practitioner: GCS (PTY ) LTD

The public participation process is an integral part of the BA process, and continues throughout

the life of the project. The key objective of public participation during a BA is to identify issues of

concern to the community and proposed suggestions for enhanced benefits. Steps are as follows:

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Decision and Communication

to Applicant

Acknowledgement of receipt of

application from DWS

Acceptance or Rejection of

WULA report by DWS

2 .

Application to DWS

10 day

Authority

Review

Compilation, consultation

and Submission of WULA

technical report

Pre-Application PhaseAdvertise WULA in Newspaper

Placement of Site Notices

Distribute BID

Initiate specialist studies

Pre-application meetings

Notify I&AP’s of the

WULA and request

them to register – 60

days

10 days

Confirm arrangements for site

inspection with allocated case

officer

Confirmation of water uses;

determine information

requirements

Assessment of WULA Report

by DWS

Basic Assessment and Water Use Licence Process Flow Diagram

20 days

5 days

105 days

139 days

Request

I&AP’s

To comment

on the WULA

technical

report – 60

days

Application to DMR

Consultation Basic

Assessment Report

Final Basic Assessment Report

107 days

Acceptance of Application

Acceptance of Application from

DMR

Public review od

Consultation Basic

Assessment Report

Within 90 days

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4.

Aviemore new Adit and Access Road Locality Map

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Comments/Response FormEnvironmental Authorisation for the proposed construction of the new Adit and

associated Access road at the Aviemore Colliery, Dundee, Kwazulu-Natal

Stakeholder Registration/Comment Form

Date

Full Name

Organisation and Role

Postal Address

Postal Code

Work/Day Tel Work/Day Fax No

Cell Phone No. E-Mail Address

I would like to receive further information and notifications during this process and request

that you please register me on your database as an interested and affected party.Yes

No

Please give us your comments on the Environmental Authorisation and IWULA for the proposed new adit and

access road at Aviemore and any issues or concerns you may have which you think should be considered

during the Basic Assessment and IWULA process.

Please clearly state any interest (business, financial, personal or other) you may have in the proposed project

and/or the application for Environmental Authorisation.

Please provide details of any other individuals or organisations that should be registered as I&APs.

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 20 August 2018 Page 16

APPENDIX D: PHASE 2 PPP

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 20 August 2018 Page 17

APPENDIX D1: SITE NOTICE

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Notice is hereby given in terms of Regulation 40 of the 2014 Environmental Impact Regulations under Section

24(5) of the National Environmental Management Act, 1998 (Act No.107 of 1998) (NEMA) and in terms of the

National Water Act,1998 (Act No. 36 of 1998) (NWA), of the Basic Assessment (BA) and Integrated Water

Use Licencing Application (IWULA) processes for the proposed construction of a new adit (North Adit) and

associated access road at the Aviemore Colliery in Dundee, KwaZulu-Natal. The following authorisations are

required:

1. Environmental Authorisation (EA) in terms of section 24 (2) of NEMA;

The NEMA activities which are triggered by the proposed activities are listed under Listing Notice 1 of the

2014 EIA and as such require an application for an EA in the form of a BA process.

2. Water Use Licence in terms of Section 21 of the NWA:

(a) Abstraction of water; (c) Impeding or diverting the flow of water in a watercourse;

(g) Disposing of waste in a manner that may detrimentally impact a water resource; (i) Streamflow reduction;

(j) Removing, discharging or disposing of water found underground

NOTIFICATION OF AN ENVIRONMENTAL

AUTHORISATION PROCESS:

CONSTRUCTION OF A NEW ADIT AND ACCESS ROAD AT

AVIEMORE COLLIERY, DUNDEE, KWAZULU-NATAL

You are invited to participate in the stakeholder engagement process by registering as an Interested and

Affected Party (I&AP) as well as to raise any issues or concerns about the proposed environmental

authorisation and Water Use License applications, or to submit suggestions regarding the project. As a

registered I&AP, you will receive further information and will be kept informed of the decisions taken by the

competent authorities. Should you wish to register as an I&AP or to receive a background information

document with additional details on the project, please contact us at the details below, specifying the project

name and reference number, by 26 March 2018:

Brendan Smith GCS (Pty) Ltd

Tel: 031 764 7130

Fax: 031 764 7140

E-mail: [email protected]

or Post: PO Box 819, Gillits, 3603

Publication Date: 23 February 2018

GCS REFERENCE NO: 16-1447

Locality Map

The new adit site is situated on

the Remainder of Morgenstond

No 3347. The proposed access

road traverses the Remainder

of Morgenstond No 3347 and

Alletta No. 4350, Portion 3,

from the proposed North Adit to

the P727 Road.

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Zinoju Coal (Pty) Ltd Aviemore North Adit and Access Road PPP

18-0553 20 August 2018 Page 18

APPENDIX D2: BACKGROUND INFORMATION DOCUMENT

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1.

Purpose of this Document

The purpose of this document is to provide all Interested and Affected parties (I&APs)

with information about the proposed construction of a new Adit and Access Road at the

Aviemore Colliery, and to explain the Basic Assessment (BA) and Integrated Water Use

License Application (IWULA) process. This Background Information Document (BID)

also aims to explain the public participation process that is prescribed by the National

Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) which governs the

Environmental Authorisation (EA) process for mining applications and invites all I&AP’s

to comment on issues and concerns related to the project.

The proposed new adit and access road at Aviemore is located along the northern flanks of the Impati

Mountain, approximately 4 to 8 km north-northwest of the town of Dundee, in the northern parts of

KwaZulu-Natal Province. The site is situated in the V32E quaternary catchment, within the Thukela Water

Management Area (DWA, 2010).

The new adit site is situated on the Remainder of Morgenstond No 3347. The proposed access road

traverses the Remainder of Morgenstond No 3347 and Alletta No. 4350, Portion 3, from the proposed

North Adit to the P727 Road. See site layout plan attached.

Location of the Development

Project Description

Aviemore Colliery is a working anthracite mine that is operated by Buffalo Coal (Pty) Ltd (Buffalo), with

mining rights held by Zinoju Coal (Pty) Ltd (Zinoju). Current workings are accessed through an adit located

on Farm Morgenstond No 3347 on the eastern flanks of the Impati Mountain. Due to a geotechnical

discontinuity (fault) having been identified, a need has been identified to construct an additional adit to ensure

mining operations can continue and that the available mineral resources can be efficiently accessed and

extracted. The proposed project entails the construction of the main North Adit and an access road from the

P272 Road to the North Adit. This proposed activity will require an EA due to the potential impacts on the

environment, as well as the undertaking of an IWULA process.

GCS Water and Environment Pty Ltd (GCS) has been appointed to undertake the required EA and IWULA

processes required for the new adit and associated access road.

Background Information Document:

Basic Assessment and Water Use License

Process for the proposed construction of the new

Adit and Access Road, Aviemore Colliery,

Dundee, KZN

Water Use License Application Process

An IWULA is required for this project in terms of the National Water Act, 1998 (Act No. 36 of 1998) due to

the following Section 21 water uses being triggered:

(a) Abstraction of water

(c) Impeding or diverting the flow of water in a watercourse as a result of roads crossing watercourses

(g) Disposing of waste in a manner that may detrimentally impact a water resource

(i) Engaging in a streamflow reduction activity

(j) Removing, discharging or disposing of water found underground

Page 40: APPENDIX 25 - gcs-sa.bizLeopard Court Building, 1st Floor, South Wing 56 Jerome Street, Lynnwood Glen, Pretoria, South Africa Tel: +27 (0) 12 348 1114 Fax: +27 (0) 12 348 1180 Web:

2 .

Basic Assessment Process

Section 24 of NEMA requires that certain listed activities, which may have an impact on the environment,

trigger the need for environmental authorization from a relevant authority before commencing with the

activities. In terms of the proposed project, the Department of Mineral Resources (DMR) is the competent

authority for this EA. Such activities are listed under the 2017 EIA Regulations Listing Notice 1, Listing Notice

2 and Listing Notice 3 of NEMA. The proposed project only triggers activities from Listing Notice 1 and

therefore requires that a BA process be undertaken.

The proposed project triggers the following listed activities under Listing Notice 1:

• Activity 24:

The development of:

(i) A road for which an environmental authorization was obtained for the route determination in terms of

activity 5 in Government Notice 387 of 2008 or activity 18 in Government Notice 545 of 2010; or

(ii) A road with a reserve wider than 13.5 meters, or where no reserve exists where the road is wider than 8

meters;

But excluding

(a) Roads which are identified and included in activity 27 in Listing Notice 2 of 2014;

(b) Roads where the entire road falls within an urban area; or

(c) Which is 1 kilometer or shorter

• Activity 27:

The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation, except

where such clearance of indigenous vegetation is required for:

(i) The undertaking of a linear activity; or

(ii) Maintenance purposes undertaken in accordance with a maintenance management plan

• Activity 56:

The widening of a road by more than 6 meters, or the lengthening of a road by more than 1 kilometer:

(i) Where the existing reserve is wider than 13.5 meters; or

(ii) Where no reserve exists, where the existing reserve is wider than 8 meters;

excluding where widening or lengthening occur inside urban areas.

Potential Listed Activities:

• Activity 14:

The development and related operation of facilities or infrastructure, for the storage, or for the storage and

handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80

cubic meters or more but not exceeding 500 cubic meters.

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3.

Copies of the Draft BA Report will be

made available at the local public libraries

in the area (to be confirmed) and on the

GCS website (www.gcs-sa.biz).

STEP 3: Final BA Report

Include comments received from I&APs

during the review process in the

compilation of the Final BA Report and

EMPr before it is submitted to the DMR

for a decision.

Notify registered I&APs of the submission

of the Final BA Report and EMPr to the

DMR.

STEP 1: Notify I&APs and Identify Issues

Notify I&APs of the proposed project.

Identify any issues / concerns of I&APs.

Provide I&APs with Background

Information Documents (BID) on the

Project, including a locality map.

Request I&APs to register their interests

in the project to receive further project

information.

Coordinate an open day to allow I&APs to

obtain additional information and discuss

their issues with the project team.

STEP 2: I&AP Review of Draft BA

Report

Prepare a comments and response

report which includes issues and concern

raised by I&APs for inclusion in the Draft

BA Report and draft Environmental

Management Program (EMPr).

Notify all registered I&APs on the project

database of the release of the Draft BA

Report and EMPr for a 30 day comment

period.

Public Participation Process (PPP)

I&AP’s may forward their written comments by 26 March 2018 along with their name,

organization, contact details, the project managers name, project name and reference number and

an indication of any direct business, financial, personal or other interest which they have in the

application by post, fax or email to:

GCS Pty Ltd Postal Address:

Brendan Smith PO Box 819

Tel: 031 764 7130 Gillitts

Fax: 031 764 7140 3603

Email [email protected] South Africa

Environmental Assessment Practitioner: GCS (PTY ) LTD

The public participation process is an integral part of the BA process, and continues throughout

the life of the project. The key objective of public participation during a BA is to identify issues of

concern to the community and proposed suggestions for enhanced benefits. Steps are as follows:

Page 42: APPENDIX 25 - gcs-sa.bizLeopard Court Building, 1st Floor, South Wing 56 Jerome Street, Lynnwood Glen, Pretoria, South Africa Tel: +27 (0) 12 348 1114 Fax: +27 (0) 12 348 1180 Web:

Decision and Communication

to Applicant

Acknowledgement of receipt of

application from DWS

Acceptance or Rejection of

WULA report by DWS

2 .

Application to DWS

10 day

Authority

Review

Compilation, consultation

and Submission of WULA

technical report

Pre-Application PhaseAdvertise WULA in Newspaper

Placement of Site Notices

Distribute BID

Initiate specialist studies

Pre-application meetings

Notify I&AP’s of the

WULA and request

them to register – 60

days

10 days

Confirm arrangements for site

inspection with allocated case

officer

Confirmation of water uses;

determine information

requirements

Assessment of WULA Report

by DWS

Basic Assessment and Water Use License Process Flow Diagram

20 days

5 days

105 days

139 days

Request

I&AP’s

To comment

on the WULA

technical

report – 60

days

Application to DMR

Consultation Basic

Assessment Report

Final Basic Assessment Report

Acceptance of Application

Acceptance of Application from

DMR

Public review of

Consultation Basic

Assessment Report

Within 90 days

We are here

Assessment/ review of FBAR

by DMR

107 days

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4.

Aviemore new Adit and Access Road Locality Map

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Comments/Response FormEnvironmental Authorisation for the proposed construction of the new Adit and Access

road at the Aviemore Colliery, Dundee, Kwazulu-Natal

Stakeholder Registration/Comment Form

Date

Full Name

Organisation and Role

Postal Address

Postal Code

Work/Day Tel Work/Day Fax No

Cell Phone No. E-Mail Address

I would like to receive further information and notifications during this process and request

that you please register me on your database as an interested and affected party.Yes

No

Please give us your comments on the Environmental Authorisation and IWULA for the proposed new adit and

access road at Aviemore and any issues or concerns you may have which you think should be considered

during the Basic Assessment and IWULA process.

Please clearly state any interest (business, financial, personal or other) you may have in the proposed project

and/or the application for Environmental Authorisation.

Please provide details of any other individuals or organisations that should be registered as I&APs.

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APPENDIX E: STAKEHOLDER DATABASE

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Sector Title Name Surname Company Tel Fax Mobile E-mail Address1 Address2 City Code

National Government

Provincial Authority Karoon Moodley DMR 031 - 335 9600 +27828575803 [email protected] Private Bag X54307 Durban 4000

Provincial Authority Kraigen Govindasamy EDTEA 034 - 299 9672 [email protected] PO Box 1290 Dundee 3000

Provincial Authority Gerald Wi l l i s smith EDTEA 031 - 336 2846 +27828080208 [email protected]

Provincial Authority Mr Dominic Wieners Ezemvelo KZN Wi ldl i fe 033 - 845 1458 wienersd@kznwi ldl i fe.com Queen El i zabeth Park Peter Brown Drive, Montrose, PMB PO Box 13053 / P.O. BOX 13069 Cascades 3202

Provincial AuthorityMs Thoko Buthelezi

Department of Agricul ture, Forestry and

Fisheries : Head Of [email protected]

Provincial Authority Mr Peter Woolf Department of Human Settlements 0313365145 0712980210 peter.woolf@kzndhs .gov.za Pravate Bag X54367, Durban ,4000

Provincial Authority Mr Weziwe Tshabala la Amafa 033 394 6543 [email protected] PO Box 2685, Pietermari tzburg, 3200

Provincial Authority Mr Sibus iso Mathons i Department of Water and Sanitation 031 - 336 2730 0825102958/ [email protected]

Provincial Authority Ms Col leen Moonsammy Department of Water and Sanitation [email protected]

Provincial Authority Ms Mavis Padayachee EDTEA +27332642572 [email protected] Private Bag X9152 PMB 3200

Provincial Authority Mr Robert Lindsay Department of Transport 033 - 3558600 [email protected] 172 Burger Street Private Bag X9043 Pietermari tzburg 3200

Provincial Authority 275 Anton Lembede s treet Private Bag X 54375 Durban 4000

Provincial Authority Ms Phumi Ngclobo Department of Health +27333952111 [email protected] Natal ia 330 Langal iba lele (Longmarket)Street Pietermari tzburg 3201 P/Bag X9051 PMB 3200

Provincial AuthorityMs Michel le Nicol Eskom

343 708 445 [email protected] 36 Voortrekker Street PO Box 63 Newcastle 2940

Local Authority (Municipality) Mr Siyabonga Kumalo Dannhauser Local Municipa l i ty 346 212 666 346 213 114 +27833328243 [email protected] 8 Chruch Street Private Bag x1011 Dannhauser 3080

District Authority (Municipality) Nothi le Mthinkhulu Amajuba Dis trict Municipa l i ty +27343297323 +27829085764 nothi [email protected] Private Bag 6615 Newcastle 2940

District Authority (Municipality) Ms Mohau Mokhantso Umzinyathi Dis trict Municiapl i ty +27342191500 +27796935359 [email protected] Princess Magogo bui lding PO Box 1965 Dundee 3000

Local Authority (Municipality) Ms Ayanda Dlungwana Endumeni Loca l Municiapl i ty 034 - 212 2121 [email protected] Civic Centre, 64 Victoria Street Private Bag 2024 Dundee 3000

Parastatal/Service Provider

Parastatal/Service Provider

Adjacent Landowner Mr George Henry Comins Portion 0 St George 4248 +27833155520

Adjacent Landowner Mr George Henry Comins Portion 0 Al letta 4350 +27833155520

Adjacent Landowner Mr George Henry Comins Portion 3 Al letta 4350 +27833155520

Adjacent Landowner Mr George Henry Comins Portion 0 St Cuthberts 12444 +27833155520

Adjacent Landowner RSA Government Portion 2 Al letta 4350

Adjacent Landowner RSA Government Portion 4

Adjacent Landowner Mr Coenraad Torlage Avemore Trust Portion 7 Al letta 4350 +27342121129 +27837026096 [email protected] PO Box 78 Dundee 3000

Adjacent Landowner Mr Coenraad Torlage Avemore Trust Portion 5 Morgenstond 3347 +27342121129 +27837026096 [email protected] PO Box 78 Dundee 3000

Adjacent Landowner Mr Coenraad Torlage Avemore trust Portion 4 Morgenstond 3347 +27342121129 +27837026096 [email protected] PO Box 78 Dundee 3000

Adjacent Landowner Mr Coenraad Torlage Avemore trust Portion 7 Morgenstond 3347 +27342121129 +27837026096 [email protected] PO Box 78 Dundee 3000

Adjacent Landowner Mr Ido Friedrich Schroeder Portion 1 Morgenstond 3347 +27342123726 +27828947219 [email protected]

Adjacent Landowner Mr Ido Friedrich Schroeder Portion 0 Impati Heights 9950 +27342123726 +27828947219 ischroeder@is imoengineers .co.za

Adjacent Landowner Mr Ido Friedrich Schroeder Portion 0 Morgenstond 3347 +27342123726 +27828947219 ischroeder@is imoengineers .co.za

Adjacent Landowner Mr Linor Trust Portion 0 Gordons Luck 12072  0342121697 +27845821697

Adjacent Landowner Ms Susara Johanna Susanna Joubert Portion 0 Seelandkop 16199 +27848191266 +27848191226 fin@dundeejs .co.za

Adjacent Landowner Mr Cornel ius Johannes Ferreria Portion 1 Lincoln 9693  0816532145  0844910014 [email protected]

Adjacent Landowner Mr Cornel ius Johannes Ferreria Portion 0 Solmar 16680  0816532145  0844910014 [email protected]

Businesses Mr Mark Bradbury Buffa lo Coal 0342121455 0845845511 marc.bradbury@buffa locoal .co.za PO Box 804 Dundee

Businesses

Businesses

Businesses

Interested and Affected Parties Mr Norman Leveridge Balgray Farm 0342121697 [email protected] PO Box 1886 Dundee

Interested and Affected Parties Mr Ben Stein 0736731870 [email protected]

Interested and Affected Parties Mr Mike Hol l iday Joylands Farm (Cleveland) 0342181367 0824670988 [email protected] P.O Box 411 Dundee 3000

Interested and Affected Parties Mr Shaun De Jager Lanysaan/Cl ipsham 0342123674 0828776023 [email protected]

Interested and Affected Parties Mr L.K Wichmann Joylands Farm 0342121935 0829279485 ignisdale@gmai l .com PO Box 14 Hattingspruit 3081

Interested and Affected Parties Mr Toger Haupt Avoca Farm 0343122051 0825679091 [email protected] Dundee

Interested and Affected Parties Sibuyiselo Mthembu Craigs ide Community 0713614144

Interested and Affected Parties Mr H Van Niekerk Rusplaas 0342181697 0845181697 [email protected]

Interested and Affected Parties Edgar Rudolph Torlage Morris tein (Forfar No 4473) 0845607846 [email protected]

Interested and Affected Parties Mr Graham Engelbrecht Linor Trust (gordons Luck 12072) 0342121697 0845821697 PO Box 1886 Dundee

Interested and Affected Parties Mr Phi l ip Caldecott Cra igs ide (Portion 93) 0826559737 [email protected] PO Box 1290 Dundee

Interested and Affected Parties G. Slater Cra igs ide and Stonny Braes 0828025682 [email protected] P.O. Box 687 Dundee

Interested and Affected PartiesAlko Goettsch

"Wi ld Duck Vlei" Farming Woodlands Portion

5 0342123679 0720909989 PO Box 1884 Dundee

Interested and Affected Parties N. De. Jager Part of Langsaan (Barleda 304cc) 0342123674 0828212602 P.O. Box 1874 Dundee

Interested and Affected Parties Mr Vernon Emsl ie Langsaan/ Bordouax +27343931991 O82 873 0110 [email protected] P.O. Box 21 Glencoe 2930

Interested and Affected Parties Mr Doug Johnstone Woodlands 8485 08208750479 0827702846 djwoodlandsfarm@gmai l .com

Interested and Affected Parties El izabeth Violet Pickett Cleveland 15597, Woodlands 8485 Portion 4 0824752542 +27 beth.toadhi l l@gmai l .com PO Box 1580 dundee

Non Governmental Organisation

Community Based Organisations

Ward Councillor Mr Vincent Ndaba Ward 3 Dannhauser Local Municipa l i ty +27724545322 [email protected]

Ward Councillor Mr Makhaba Ward 6 Endumeni Local Muncipal i ty +27733970258

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APPENDIX F: SUBMISSIONS FROM I&APS AND STAKEHOLDERS

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Good day Simone

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As can be seen from the above GIS Extract, Eskom does have infrastructure in the area.

We Do need to register as an Interested and Affected Party.

Regards

Michelle Land and Rights Section, KZN OU Eastern Region Land Development Department Ikhwezi Building 25 Valley View Road P O Box 66, New Germany, 3620. Tel: 031-7105404 Pax 8321-5404 Fax to e-mail + 27 (0)086 667 2564 E-mail [email protected]

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APPENDIX G: I&AP MEETING – ATTENDANCE REGISTER

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APPENDIX H: EIA APPLICATION - ACKNOWLEDGEMENT OF RECEIPT

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APPENDIX I: NOTIFICATION EMAIL FOR IWULA UPDATE

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APPENDIX J: LETTER ADDRESSING CONCERNS REGARDING DEWATERING AND UNDERGROUND DUST SUPPRESSION AT AVIEMORE COLLIERY

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L

GCS (Pty) Ltd. Reg No: 2004/000765/07 Est. 1987

Offices: Durban Gaborone Johannesburg Lusaka Maseru Ostrava Pretoria Windhoek

Directors: AC Johnstone (Managing) PF Labuschagne AWC Marais S Napier W Sherriff (Financial)

Non-Executive Director: B Wilson-Jones

4a Old Main Road, Judges Walk, Kloof, Kwazulu-Natal, South Africa, 3610 PO Box 819, Gillitts, 3603, South Africa Tel: +27 (0) 31 764 7130 Fax: +27 (0) 31 764 7140 Web: www.gcs-sa.biz

www.gcs-sa.biz

Letter to address concerns regarding dewatering and underground dust suppression at Aviemore Colliery

To Whom It May Concern,

GCS (Pty) Ltd has conducted several hydrogeological investigations for Aviemore Colliery and also

currently conducts the water monitoring at the site.

GCS is an impartial third party, our responsibility is to collect and analyse hydrogeological data for

submission to the environmental authorities (Department of Water and Sanitation and Department of

Minerals Resources). This data is meant to assist the mine and the authorities with decision making.

All reporting and data analysis is carried out by SACNASP registered Professional Natural Scientists.

This letter is meant to address concerns from the local community, specifically farmers that rely on

spring water and borehole water, regarding the potential impact to water quality and water quantity

as a result of mine water usage originating from underground mine activities within the deeper

fractured rock aquifer.

1. Water Quality

The following points are made with regards to the springs:

Most springs identified during previous hydrocensus surveys and through monitoring are

situated above the highest mine elevation (1300 mamsl). The average spring elevation is

approximately 1396 mamsl. Only two springs were identified below 1300 mamsl, namely GK

Spring 2 and GK Spring 6 (refer to map in Figure 2 for the localities of these springs).

o Both GK Spring 2 and 6 are included in the current monitoring programme. GK Spring

6 is typically dry but GK Spring 2 is sampled quarterly. The results show neutral pH,

currently at 7.8, with low Total Dissolved Solids at 100 mg/l (well below the SANS

drinking water quality standard of 1200 mg/l) and a sulphate concentration of 1.8mg/l

(well below the SANS drinking water quality standard of 250mg/l). This spring

currently shows no impact from the mine workings.

As the groundwater in this area will flow away from Impati Mountain (from topographical and

hydraulically higher elevated areas to lower elevated areas), any springs situated on the upper

slopes of the mountain, specifically above the highest mine elevation, will not be impacted

on by any potential seepages from the mine workings.

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The following points are made with regards to the groundwater quality and potential impact to

boreholes:

A mathematical groundwater flow and mass transport model was applied to assist with the

current status and future predictions of groundwater flow and potential contaminant

transport. Available information indicates that the underground workings will have an impact

on groundwater quality around the mine workings over time. However, model predictions

indicate that the zone of impact will be predominantly limited to the mine workings area.

The predicted zone of impact of the mine 100 years after mine closure, based on scientific

numerical modelling, is provided in Figure 2. This model will be calibrated every 2 years as

per the mine’s commitment in the IWULA.

o Note: the area of the mine workings has been reduced significantly since the model

was created. The predicted sulphate impact area will therefore be significantly

smaller than is shown in Figure 2.

The underground dust suppression activities will have no significant effect on the groundwater

quality. The volume of water used during this process is considered negligible.

2. Water Quantity

It is understood that several local farmers and small communities rely on groundwater and spring

water for drinking water purposes, domestic supply and/or livestock watering and that the supply of

water is critical to their livelihood.

In terms of the predicted impact to springs:

As stated above, most of the springs are situated above the mine workings which suggest a

theoretical risk to the springs. However, the impact of mining on spring flow will depend

largely on the connectivity between the aquifers above the mine and the mine workings which

is situated within the deeper fractured rock system. It is likely that layers of shale may protect

the upper aquifer from mining activities in the deeper fractured aquifer system.

The available data suggests some connectivity with the upper aquifer which may impact spring

flow in some areas. However, based on the monitoring conducted at springs in the existing

mining areas, no significant impact to spring flow has been observed.

o It should also be noted that seasonal variations, dry cycles and changes in climate

may also affect spring flow. Reduced rainfall recharge to shallow aquifers in the upper

slopes of the mountains may result in dry springs over time. It is not the intention

of the mine to have any surface infrastructure that can influence the recharge zones

of these springs, mining will be within the deeper geological formations.

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It is highly recommended that any land user within the predicted zone of impact, particularly

with springs daylighting along Impati Mountain, provide the co-ordinates to Buffalo Coal so

that the springs can be included in the routine quarterly monitoring programme. It is

important to gather baseline flow data so that concerns regarding change in flow can be

addressed based on pre-mining flow data.

o It should be noted that it is a requirement of the mine to supplement any affected

land user with water, should it be shown that the mine has impacted water volumes

over time.

In terms of impact to groundwater levels, the following information is provided:

Based on borehole drilling conducted in this area, the local aquifer is typically intercepted at

about 25-30 mbgl (metres below ground level). Water levels in the region of 30 mbgl are

therefore considered normal for this area, depending on the topographical setting of the

borehole, ie boreholes situated higher on the slopes of Impati Mountain will most likely have

deeper water levels.

Water level monitoring is currently conducted at the site every three months. Most boreholes

have shown stable water levels over time with no significant impact as a result of mine

dewatering.

o Fluctuations in water levels are observed at several boreholes however no long term

drawdown has been observed.

Figure 1: Water level time trend graph

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Figure 2: Predicted zone of influence 100 years post closure

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APPENDIX K: BUFFALO COAL AFFIDAVITS

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