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Robertson Bakstene (Pty) Ltd

Brick Making Facility

Environmental Authorisation

NAME OF APPLICANT: ROBERTSON BAKSTENE (Pty ) Ltd.

DEA&DP REFERENCE NUMBER: 16/3/3/6/7/1/B1/14/1326/16

UMVOTO REFERENCE NUMBER: 856/25/02/2017

FARM NAMES: GANNABOSCH VLAKTE 51

PROVINCE: WESTERN CAPE

DATE: 20 MARCH 2017

COMPILED IN TERMS OF GOVERNMENT NOTICE R. 982 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (ACT 107 OF 1998) ENVIRONMENTAL IMPACT ASSESSMENT

REGULATIONS, 2014.

FINAL SCOPING REPORT

Prepared for:


Prepared by:

March 2017

ROBERTSON BAKSTENE (Pty) Ltd.

Umvoto Africa (Pty) Ltd . Earth . Water . Science . Life P.O. Box 61 Muizenberg 7950. Telephone: (021) 709 6700. Fax: 086 685 5725

E-mail: [email protected] Internet: www.umvoto.com Reg. No.: 2001/013609/07

Directors: E R Hay, C J H Hartnady, K Riemann Associates: D.Blake, R T Wonnacott, F S Botha, W J Gouws

REPORT TITLE : Final Scoping Report

CLIENT : Robertson Bakstene (Pty) Ltd

PROJECT : Robertson Bakstene (Pty) Ltd

Brick Making Facility Environmental

Authorisation

AUTHORS : Paul Lee

Magen Munnik

Kristian Gerstner

REPORT STATUS : Final Report

REPORT NUMBER : 856/25/02/2017

DATE : March 2017

APPROVED BY :

Umvoto Africa (Pty) Ltd Umvoto Africa (Pty) Ltd

Director Project Manager

Kornelius Riemann Paul Lee


Director

Morne Swanepoel

http://www.umvoto.com/


Table of Contents Page ii

Reference

This report is to be referred to in bibliographies as:

Umvoto Africa. (2017). Robertson Bakstene (Pty) Ltd Brick Making Facility Environmental

Authorisation – Final Scoping Report. Prepared by P. Lee, M.C. Munnik and K. Gerstner of

Umvoto Africa (Pty) Ltd for Robertson Bakstene (Pty) Ltd. Report No. 856/25/02/2017,

March 2017, 103 pp.

Report Status

Report No. Status Reviewed by Date

856/25/02/2017 Final Report K Riemann 18-03-2017

Distribution List

Report No. Status Name Institution Date

856/25/02/2017 Final Loretta Osborne Department of

Environmental Affairs

and Development

Planning

20-03-2017


Table of Contents Page iii

TABLE OF CONTENTS

Chapter Description Page

1. INTRODUCTION 12

1.1 Details and Expertise of the Environmental Assessment Practitioner 12

1.2 Contact Information and Location of the Operation 12

1.3 Property Details 12

1.4 History and Background Information of the Brick Making Factory Operation 13

1.5 Purpose of Report 14

1.6 Structure of this Report 15

1.7 Content of Report 16

1.8 Assumptions and Limitations 18

2 GOVERNANCE FRAMEWORK AND ENVIRONMENTAL PROCESS 19

2.1 Legal Requirement 19 2.1.1 National Environmental Management Act 107 of 1998 (NEMA); 19 2.1.2 EIA Regulations, promulgated in terms of NEMA; 20 2.1.3 National Water Act 36 of 1998 (NWA); 22 2.1.4 National Heritage Resources Act 25 of 1999 (NHRA) 23 2.1.5 National Environmental Management: Biodiversity Act 10 of 2004

(NEMBA); 23 2.1.6 National Environmental Management: Air Quality Act 39 of 2004 24

2.2 Planning Policy Framework 25 2.2.1 Western Cape Provincial Spatial Development Framework (2014) 25 2.2.2 Cape Winelands District Municipality Integrated Development Plan (IDP) 26 2.2.3 Cape Winelands District Municipality Spatial Development Framework

(SDF) 26 2.2.4 Langeberg Local Municipality Integrated Development Plan (IDP) 27 2.2.5 Langeberg Local Municipality Spatial Development Framework (SPDF) 27

2.3 Environmental Process 28 2.3.1 Submission of Environmental Authorisation and other Relevant

Applications 29 2.3.2 S&EIR Process and Phasing 29

3 BASELINE ENVIRONMENT 31

3.1 Description Residential, Socio-Economic and Cultural Receiving Environment 32

3.1.1 Community Ownership and Traditional Authorities 32 3.1.2 Landowners and Title Deed Owners 32 3.1.3 Departure of Zoning to Land for Industrial Purpose 32 3.1.4 The Local Municipality 33 3.1.5 Existing Status of the Cultural and Heritage Environment that may be

Affected 33 3.1.6 Current on Site Land Use 33 3.1.7 Surrounding Land Use 33 3.1.8 Regional Land Conservation Units 37 3.1.9 Nearby Residences and Dwellings 37 3.1.10 Nearby businesses/ tourist places 39


Table of Contents Page iv

3.2 Description of the Biophysical Receiving Environment 40 3.2.1 Topography 40 3.2.2 Drainage 41 3.2.3 Noise 42 3.2.4 Air Quality: Emissions and Fugitive Dust 45 3.2.5 Soils 45 3.2.6 Geology 46 3.2.7 Climate 48 3.2.8 Biodiversity, Flora & Fauna 51 3.2.9 Surface water 52 3.2.10 Groundwater 53

4 PROJECT DESCRIPTION 54

4.1 Project Design: 54 4.1.1 Layout, road network and infrastructure 54 4.1.2 The Brick Making Process 54 4.1.3 Site & Service and Equipment Description 56 4.1.4 The conceptual brick factory layout 57 4.1.5 Stormwater Management Plan 57

5 STAKEHOLDER ENGAGEMENT 60

5.1 Objectives of the Stakeholder Engagement Process 60

5.2 Interested and Affected Parties Consultation Process 61 5.2.1 Identification of Key Stakeholders 63 5.2.2 Notification of the EIA Process 64 5.2.3 Release of Draft Scoping Report 64 5.2.4 Issues and Concerns Raised by IAP’s during Scoping 65 5.2.5 Finalising the Scoping Report 66

6 ENVIRONMENTAL IMPACT ASSESSMENT 67

6.1 Introduction 67 6.1.1 Identified Environments of Impact 67 6.1.2 Specialist Studies Undertaken 67

6.2 Impact Rating Method 68

6.3 Listed Potential Environmental Impacts 71 6.3.1 Freshwater Ecology/Hydrology 71 6.3.2 Biota / Flora and Fauna 75 6.3.3 Soils 78 6.3.4 Heritage Impacts 81 6.3.5 Socio-economic Impacts 82 6.3.6 Air Quality 84 6.3.7 Noise Impact 85 6.3.8 Visual Impacts 86 6.3.9 Traffic Impacts 87

6.4 Cumulative Impacts 89

7 ALTERNATIVE LAND USE AND DEVELOPMENTS CONSIDERED 90

7.1 Alternative Clay Resource that could provide other localities for the factory 90

7.2 Southwestern Alternative For Locality of The Factory 91

7.3 Robertson Town Alternative Sites 92

7.4 Ashton Town Alternative Sites 93

7.5 Reduced Size of Brick Making Factory 93


Table of Contents Page v

7.6 Alternative brick firing Technologies 94

7.7 The No Go Alternative 94

8 CONCLUSION AND RECOMMENDATION 96

9 UNDERTAKING AND AFFIRMATION BY THE EAP 97

REFERENCES 99

APPENDIX A – CURRICULUM VITAE OF EAP 1

APPENDIX B – COMPANY REGISTRATION CERTIFICATE (ROBERTSON BAKSTENE (PTY) LTD.) 2

APPENDIX C – HERITAGE WESTERN CAPE 3

APPENDIX D – LUPA TEMPORARY ZONE DEPARTURE APPLICATION 4

APPENDIX E – INTERESTED AND AFFECTED PARTIES REGISTER 5

APPENDIX F – IAP & STAKEHOLDER CONCERNS RAISED 6

F-1: Collated Comments and Concerns 6

F-2: All IAP Responses 6

F-3: IAP Signed Petitions 6

F-4: Documented Lawyer Letters 6

APPENDIX G – LAND AFFAIRS RESPONSE 7

APPENDIX H – TITLE DEED (GANNABOSCH VLAKTE 51) 8

APPENDIX I – MAPS 9

ANNEXURE A-1: FIRST NOTICE OF INTENT TO DEVELOP 1

ANNEXURE A-2: AMENDED NOTICE OF INTENT 2

ANNEXURE B-1: FIRST BOTANICAL SPECIALIST REPORT 3

ANNEXURE B-2: AMENDED FIRST BOTANICAL SPECIALIST REPORT 4

ANNEXURE C: ATMOSPHERIC EMISSION LICENSE APPLICATION 5

ANNEXURE D: STORM WATER MANAGEMENT PLAN (SWMP) 6

ANNEXURE E1: FIRST FRESHWATER SPECIALIST REPORT 7

ANNEXURE E2: AMENDED FRESHWATER SPECIALIST REPORT 8

ANNEXURE F: VISUAL IMPACT SPECIALIST REPORT 9

ANNEXURE G: ATMOSPHERIC IMPACT ASSESSMENT 10

ANNEXURE H: TRAFFIC IMPACT STATEMENT 11

ANNEXURE I: ALTERNATIVE RESOURCE SURVEY REPORT 12

ANNEXURE J: ECONOMIC IMPACT STUDY 13


Table of Contents Page vi

LIST OF FIGURES

Figure 3-1: Neighbouring farms to Gannabosch Vlakte 51 ................................................... 36

Figure 3-2: Langeberg-West Mountain Catchment Conservation and Doringkloof Private Nature Reserve that are in close proximity to Gannabosch Vlakte 51 .................................. 37

Figure 3-3: Land units of the Rooiberg Breede Conservancy are indicated in yellow, of which Gannabosch Vlakte 51 is shown in the centre of the conservancy. ...................................... 38

Figure 3-4: Habitations in the vicinity of the proposed Robertson Brick Factory. The dots represent established homesteads. The diameter of the circle is 2 km, centred on the site of the quarry. Green star indicates Manager’s residence, blue cross indicates Cape .............. 38

Figure 3-5: Localities of residents and tourism facilities within immediate area of the proposed development. The yellow circle indicates the zone of noise extent. Dark red indicates the 1km fugitive dust fallout and light red indicates 2 km fugitive dust fallout. Both are plotted along the prevailing wind direction (bottom right corner). ..................................................................... 39

Figure 3-6: The Rooiberg Mountain Bike Trail shown to be running south of the brick factory ............................................................................................................................................ 40

Figure 3-7: Brick Factory footprint shown overlaying the mine concession and a portion to the northwest border outside of concession area. While the proposed development area impacts drainage line 2, the east and west boundary drainage lines remain intact and preserve biodiversity. .......................................................................................................................... 41

Figure 3-8: Graphical representation of predicted sound level in decibel (dB) across a specific distance in meters (m). ........................................................................................................ 43

Figure 3-9: Composite climate diagram of the Robertson region. Blue bars show the median monthly precipitation. The upper and lower red lines show the mean daily maximum and minimum temperatures respectively (After Mucina and Rutherford, 2006). .......................... 49

Figure 3-10: Average, maximum and minimum daily temperatures throughout the day, with the horizontal axis representing months of the year, starting with January (1) and ending with December (12). .................................................................................................................... 50

Figure 3-11: Wind rose of the Worcester region ................................................................... 51

Figure 4-1: Simplified flowchart of the brick making process. ............................................... 54

Figure 4-2: Conceptual storm water management plan. ....................................................... 59

Figure 5-1: Advertisements posted in local and regional newspapers and on the affected property of the EIA and PPP process. .................................................................................. 65

Figure 7-1: Positions of additional potential brick clay resource sites in the region surrounding the proposed Gannabosch clay mine. Pink, (Pt-01 02 and 03) orange (Dg-01) and yellow (Dw-01) areas represent Tierberg, Gydo and Waboomberg Formation sites respective respectively, maroon polygons represent associated farms, and the red polygon represents Gannabosch Vlakte 51. ............................................................................................................................. 91


Table of Contents Page vii

Figure 7-2: Initial locality of the brick factory was planned to be southwest of the proposed mine footprint, between the proposed mine concession area and the Vink River on southwest corner of map. ................................................................................................................................ 92

Figure 7-3: Showing the possible alternative location for the factory at the Old Quarry Site to the northwest of the town. Also shown is the unsuitable Town Industrial Zone. ................... 93


Table of Contents Page viii

LIST OF TABLES

Table 1-1: EAP and Company details .................................................................................. 12

Table 1-2: Applicant Details ................................................................................................. 12

Table 1-3: Property details ................................................................................................... 13

Table 1-4: Coordinates of the boundary of the target property, Gannabosch Vlakte 51 ....... 13

Table 1-5: Coordinates of the boundary of the brick factory ................................................ 13

Table 1-6: Content of the Scoping Report as required by the EIA Regulation, 2014 ............ 16

Table 2-1: Listing Notice 1 (No. GN. 983). Triggers in terms of 24 (2) and 24D .................... 21

Table 2-2: Listing Notice 2 (No. GN. 984) Triggers in terms of 24 (2) and 24D .................... 22

Table 2-3: WCPSDF policies ............................................................................................... 25

Table 2-4: Environmental Authorisations, Possible Permits and Licences Required ............ 29

Table 3-1: Specialist Studies ................................................................................................ 31

Table 3-2: Surrounding property land use ............................................................................ 35

Table 3-3: Predicted sound level per decibel (dB) across a distance in meters (m). ............. 43

Table 3-4: Listing of possible noise receptors in the surrounding area of the Brick making facility. Localities of these receptors are shown in Figure 3-5. ............................................. 44

Table 3-5: Noise limits per sector ......................................................................................... 44

Table 3-6: Stratigraphy ........................................................................................................ 46

Table 5-1: Stakeholder engagement activities undertaken during the Scoping Phase. ........ 62

Table 6-1: Determination of the consequence of an impact ................................................. 69

Table 6-2: Methodology to determine the overall Consequence Rating............................... 69

Table 6-3: Probability Classification .................................................................................... 69

Table 6-4: Impact Significance Rating .................................................................................. 70

Table 6-5: Freshwater ecological / hydrological impacts ...................................................... 71

Table 6-6: Flora and Fauna impacts .................................................................................... 75

Table 6-7: Impact on soils .................................................................................................... 78

Table 6-8: Heritage impacts ................................................................................................. 81

Table 6-9: Socio-economic impacts ..................................................................................... 82


Table of Contents Page ix

Table 6-10: Air Quality ......................................................................................................... 84

Table 6-11: Noise ................................................................................................................ 85

Table 6-12: Visual Impact .................................................................................................... 86

Table 6-13: Traffic impact .................................................................................................... 87


Table of Contents Page x

LIST OF ABBREVIATIONS

° - degrees

°C - Degrees Celsius

% - percentage

~ - Approximately

AFF - Agricultural Forestry and Fishing

ARC - Agricultural Research Council

CBA - Critical Biodiversity Area

BA - Basic Assessment

BGCMA - Breede Gourtiz Catchment Management Agency

BID - Background Information Document

cm - centimetres

DEA&DP - Department of Environmental Affairs and Development Planning (DEA&DP)

DMR - Department of Minerals and Resources

DWA - Department of Water Affairs (now DWS)

DWS - Department of Water and Sanitation

EA - Environmental Authorisation

EAP - Environmental Assessment Practitioner

EIA - Environmental Impact Assessment

EIR - Environmental Impact Report

EMP - Environmental Management Plan

EMPr - Environmental Management Program

EIS - Environmental Impact Study

ESA - Ecological Support Area

FSBP - Fine Scale biodiversity plans

GCM - Gannabosch Clay Mine

GDP - Gross Domestic Product

GN - General Notice (w.r.t Legal Acts)

HIA - Heritage Impact Assessment

HWC - Heritage Western Cape

ha - Hectares

IAP - Interested and Affected Parties

IDP - Integrated Development Plan

m - metres

km - kilometre

Km2 - Square kilometre

Km/h - kilometers an hour

LM - Local Municipality

LoM - Life of Mine

m2 - Square metres

m3 - Cubic metres

m/s - Metres per second

mS/m - Millisiemens per metre

Ma - Million Years

mamsl - Metres above mean sea level

MAP - Mean annual precipitation

MAPE - Mean annual precipitation-evaporation index

MASMS - Mean annual soil measurement stress

MAT - Mean annual temperature

mbgl - Metres below ground level


Table of Contents Page xi

mm - millimeters

MPRDA - Mineral and Petroleum Resources Development Act

Mt - Million Tons

EMA - National Environmental Management Act

NEMBA - National Environmental Management Biodiversity Act

NHRA - National Heritage Resource Agency

NID - Notice of Intent to Develop

NWA - National Water Act

PPP - Public Participation Process

SABAP2 - South African Bird Atlas Project 2

SAHRA - South African Heritage Resource Agency

SAMRAD - South African Mineral Resources Administration System

SANBI - South African National Biodiversity Institute

S&EIR - Scoping and Environmental Impact Report

TMG - Table Mountain Group

ToC - Theory of Constraint

ToR - Terms of Reference

WCDM - West Coast District Municipality

WCPSDF - Western Cape Provincial Spatial Development Framework

WUA - Water Use Authorisation

WUL - Water Use Licence

w.r.t - With reference to

UA - Umvoto Africa

VU - Vulnerable (Species status)


Final Scoping Report Page 12

1. INTRODUCTION

1.1 DETAILS AND EXPERTISE OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER

GN 982, Appendix 2 Section 2 (a) of the NEMA requires that the Scoping Report include

details and expertise of the EAP who prepares the report. This is provided in Table 1-1

and curriculum vitae that is available to read in Appendix A – Curriculum Vitae of EAP.

Table 1-1: EAP and Company details

Company Details:

Company: Umvoto Africa (Pty) Ltd.

Postal Address: PO Box 61

Muizenberg, 7945

Phone: 021 709 6700

Email: [email protected]

Details and Expertise of the EAP:

Name: Paul Lee

Qualifications: BSc Honours Environmental and Geographical Sciences

Experience: See CV in Appendix A – Curriculum Vitae of EAP

Professional Registration EAPSA & SACNASP 400124/09

1.2 CONTACT INFORMATION AND LOCATION OF THE OPERATION

The applicant for the proposed brick making facility is a newly registered entity Robertson

Bakstene (Pty) Ltd (see Table 1-2). The company registration certificate is provided in

Appendix B – Company Registration Certificate (Robertson Bakstene (Pty) Ltd.).

Table 1-2: Applicant Details

Company Details:

Company: Robertson Bakstene (Pty.) Ltd

Registration No. 2015/446998/07

Contact persons Morne Swanepoel

Postal Address: P O Box 234

Robertson, 6705

Phone: 082 374 6949

Email [email protected]

1.3 PROPERTY DETAILS

Appendix 2 Section 2 (b) of GN 982 requires that the locality of the activity is provided.

The proposed brick factory is located on a portion of the farm Gannabosch Vlakte 51,

approximately 14 km west of the town centre of Robertson in the Western Cape, South

Africa. The property lies ~700 m to the northeast of the TR 31/1, R60 national road, and

can be accessed via the Agter-Vinkrivier turnoff. Property details are provided in Table

1-3. Figure I 1, Figure I 2, Figure I 3 and Figure I 4 shows increasingly zoomed in maps

of the location. Table 1-4 and Table 1-5 provide coordinates of both the target property

and the proposed development footprint in latitude and longitude.



Table 1-3: Property details

Table 1-4: Coordinates of the boundary of the target property, Gannabosch Vlakte 51

Boundary Point Latitude, Longitude

A 19.739798; -33.753348

B 19.744565; -33.758357

C 19.746775; -33.746393

D 19.758984; -33.750613

Table 1-5: Coordinates of the boundary of the brick factory

Boundary Point Latitude, Longitude

BF1 19.747220; -33.754160

BF2 19.746500; -33.755310

BF3 19.743695; -33.752404

BF4 19.744820; -33.751671

GN 982, Appendix 2 Section 2 (c) of the NEMA requires that the Scoping Report include

a layout plan indicating the associated structure and infrastructure. This is shown

conceptually in Figure I 5.

1.4 HISTORY AND BACKGROUND INFORMATION OF THE BRICK MAKING FACTORY

OPERATION

Gannabosch Clay Mine (Pty) Ltd (GCM) has made an application in February 2016 to the

Department of Mineral Resources (DMR) for a Mine Right on the property Gannabosch

Vlakte 51. This pending application, MR 10082, is for the exploitation of clay ore for

providing a resource for brick manufacturing. Robertson Bakstene (Pty.) Ltd (RB) is the

enterprise that will be beneficiating the clay ore into the brick product, this process is

intended to take place on and close to the mine concession area of the Gannabosch

Vlakte property, which is situated approximately 15 km due west of the town of Robertson

along the R 60 (Trunk Road 31/1). The proposed development of the brick manufacturing

facility by Robertson Bakstene (Pty) Ltd intends to allow the manufacture of clay bricks for

the regional supply to the construction industry within the surrounding towns.

Company Details:

Farm Name GANNABOSCH VLAKTE 51

Farm Number 51

Portion N/a

Local Authority Langeberg Municipality

Registration Division N/a

Extent 117.5119 hectares

SG 21-digit code C06500000000005100000

Landowner H R Grobbelaar Family Trust

Title Deed T 4135995



Field studies, prospecting and a resource evaluation has confirmed the presence of ore

in sufficient volume and proximity to the surface to warrant exploitation. Chemical analysis

has confirmed the resource to be of a grade and quality that will support the production of

a high-quality clay-face brick with superior compressional strength. The existence of

infrastructure to support mining and manufacturing which includes water, electricity and

proximity to market has supported the proponent’s endeavours to make the application.

The support of the land owner (Grobbelaar Family Trust), and the imminent and urgent

demand for bricks regionally, have further backed the application.

Umvoto Africa (Pty) Ltd has been appointed by RB as the lead consultants to undertake

the Scoping and Environmental Impact Assessment process. This report, the Scoping

Report, is the outcome of a legislated Public Participation Process (PPP) in which all

registered Interested and Affected Parties (IAPs) and Stakeholders were consulted and

offered opportunity to provide input to the report in order to ensure that the environmental

authorisation process is transparent, serves the region socio-economically and

safeguards the biodiversity of the environment, while also representing the proponents

needs, goals and objectives.

1.5 PURPOSE OF REPORT

The objectives of the Scoping Process are listed below as defined in Appendix 2 Section

1 of Government Notice R982 of 4 December 2014:

The objective of the scoping process is to, through a consultative process:

a) identify the relevant policies and legislation relevant to the activity;

b) motivate the need and desirability of the proposed activity, including the need and

desirability of the activity in the context of the preferred location;

c) identify and confirm the preferred activity and technology alternative through an

impact and risk assessment and ranking process;

d) identify and confirm the preferred site, through a detailed site selection process,

which includes an impact and risk assessment process inclusive of cumulative

impacts and a ranking process of all the identified alternatives focusing on

geographical, physical, biological, social, economic and cultural aspects of the

environment;

e) identify the key issue to be addressed in the assessment phase;

f) agree on the level of assessment to be undertaken, including the methodology to

be applied, the expertise required as well as the extent of further consultation to

be undertaken to determine the impacts and risks the activity will impose on the

preferred site through the life of the activity, including the nature, significance,

consequence, extent, duration and probability of the impacts to inform the location

of the development footprint within the preferred site; and

g) identify suitable measures to avoid, manage or mitigate identified impacts and to

determine the extent of the residual risks that need to be managed and monitored.



1.6 STRUCTURE OF THIS REPORT

An overview of how the report is laid out in terms of the TOC is given below

Section 1: Introduction

Provides an introduction and background to the proposed project.

Section 2: Governance Framework and Environmental Process

Provides a brief summary and interpretation of the relevant legislation.

Section 3: Baseline Assessment

Biophysical and socio-economic characteristics of the affected environment

against which impacts are assessed.

Section 4: Project Description

Location and current status of the project area, summary of the surrounding land

uses, motivation, desirability and need for, and description of, the proposed

project.

Section 5: Stakeholder Engagement

Details the stakeholder engagement summarises stakeholder comments.

Section 6: Environmental Impact Assessment (EIA)

Describes the specialist studies and assesses the potential impacts of the project.

Section 7: Alternate Land Use and Development

Describes the specialist studies and assesses the potential of developing the brick

factory on alternative site.

Section 8: Conclusion

Provides a brief summary of the report.

Section 9: Undertaking and Affirmation by the EAP



1.7 CONTENT OF REPORT

Stipulated below in Table 1-6 is the required content and the respective locations within

the EIA report as required per Section 3 of Appendix 2 and Section 1 of Appendix 4 of

Government Notice No 982 of the EIA Regulations, 2014.

Table 1-6: Content of the Scoping Report as required by the EIA Regulation, 2014

GN 982,

Appendix

2: Scoping

Item Document

Reference:

(2) (a) (i) Details of the EAP who prepared the report

(ii) The expertise of the EAP to carry out an environmental

impact assessment

Table 1-1

Table 1-1

(2) (b) The location of the activity, including:

(i) the 21 digit Surveyor General code of each cadastral land

parcel;

(ii) Where available, the physical address and farm name; and

(iii) Where the required information in items (i) and (ii) is not

available, the coordinates of the boundary of the property or

properties;

Table 1-3

Table 1-3

Figure I 2

(2) (c) A plan which locates the proposed activity or activities applied

for at an appropriate scale, or, if it is-

(i) a linear activity, a description and coordinates of the corridor

in which the proposed activity or activities is to be

undertaken;

(ii) on land where the property has not been defined, the

coordinates within which the activity is to be undertaken;

n/a

Figure I 3

(2) (d) a description of the scope of the proposed activity, including:

(i) All listed and specified activities triggered

(ii) A description of the activities to be undertaken, including

associated structures and infrastructure;

Table 2-1

Table 2-2

Section 4

(2) (e) A description of the policy and legislative context within which

the development is proposed including an identification of all

legislation, policies, plans, guidelines, spatial tools, municipal

development planning frameworks and instruments that are

applicable to this activity and are to be considered in the

assessment process;

Section 2

(2) (f) a motivation for the need and desirability for the proposed

development, including the need and desirability of the activity

in the context of the preferred location;

Annexure J:

Economic Impact

Study

(2) (h) A full description of the process followed to reach the proposed

preferred activity, site and location within the site, including:

(i) details of the alternatives considered;

(ii) details of the public participation process undertaken in

terms of regulation 41 of the Regulations, including copies

of the supporting documents and inputs;

(iii) a summary of the issues raised by interested and affected

parties, and an indication of the manner in which the issues

were incorporated, or the reasons for not including them;

Section 7

Section 5 and

Appendix E –

Interested and

Affected Parties

Register &

Appendix F – IAP

& Stakeholder

concerns Raised



GN 982,

Appendix

2: Scoping

Item Document

Reference:

(iv) the environmental attributes associated with the

development footprint alternatives focusing on the

geographical, physical, biological, social, economic,

heritage and cultural aspects;

(v) the impacts and risks identified including the nature,

significance, consequence, extent, duration and probability

of the impacts, including the degree to which these impacts

a) can be reversed;

b) may cause irreplaceable loss of resources; and

c) can be avoided, managed or mitigated;

(vi) the methodology used in determining and ranking the

nature, significance, consequences, extent, duration and

probability of potential environmental impacts and risks

associated with the alternatives;

(vii) positive and negative impacts that the proposed activity

and alternatives will have on the environment and on the

community that may be affected focusing on the

geographical, physical, biological, social, economic,

heritage and cultural aspects;

(viii) the possible mitigation measures that could be applied and

level of residual risk;

(ix) the outcome of the site selection matrix

(x) if no alternatives, including alternative locations for the

activity were investigated, the motivation for not

considering such; and

(xi) a concluding statement indicating the preferred

alternatives, including preferred location of the activity;

Section 3

Section 6

Section 6.2

Section 6.3

Section 6.3

Section 7

Section 8

(2) (i) A plan of study for undertaking the environmental impact

assessment process to be undertaken, including:

(i) a description of the alternatives to be considered and

assessed within the preferred site, including the option of

not proceeding with the activity;

(ii) description of the aspects to be assessed as part of the

environmental impact assessment process;

(iii) aspects to be assessed by specialists;

(iv) a description of the proposed method of assessing the

environmental aspects, including a description of the

proposed method of assessing the environmental aspects

to be assessed by specialists;

(v) a description of the proposed method of assessing

duration and significance;

(vi) an indication of the stages at which the competent

authority will be consulted;

(vii) particulars of the public participation process that will be

conducted during the environmental impact assessment

process; and

(viii) a description of the tasks that will be undertaken as part of

the environmental impact assessment process;

Section 7

Section 6

Table 3-1

Section 6.2

Section 6.2

Section 2

Section 5

Section 6



GN 982,

Appendix

2: Scoping

Item Document

Reference:

(ix) identify suitable measures to avoid, reverse, mitigate or

manage identified impacts and to determine the extent of

the residual risks that need to be managed and monitored.

(2) (j) an undertaking under oath or affirmation by the EAP in relation

to:

(i) the correctness of the information provided in the reports;

(ii) the inclusion of comments and inputs from stakeholders and

l&APs;

(iii) any information provided by the EAP to interested and

affected parties and any responses by the EAP to comments

or inputs made by interested or affected parties;

Section 9

(2) (k) an undertaking under oath or affirmation by the EAP in relation

to the level of agreement between the EAP and interested and

affect parties on the plan of study for undertaking the

environmental impact assessment;

Section 9

(2) (l) where applicable, any specific information that may be required

by the competent authority; and n/a

(2) (m) any other matters required in terms of section 24(4)(a) and (b)

of the Act. n/a

1.8 ASSUMPTIONS AND LIMITATIONS

As is standard, the report is based on a number of assumptions and is subject to certain

limitations. These are as follows:

Information provided by the consultants and specialists is assumed to be accurate

and correct;

Assessment of the significance of impacts of the brick factory on the affected

environment has been based on the assumption that the factory activities will be

confined to those described in this EIA Report;

Where detailed design information is not available, the precautionary principle, to

overstates negative impacts and understates benefits, has been adopted;

It is assumed that the stakeholder engagement process undertaken, during the

S&EIR process, has identified all relevant concerns of stakeholders; and

Robertson Bakstene (Pty) Ltd will in good faith implement the agreed mitigation

measures identified in this report, commit sufficient resources, employ suitably

qualified personnel to ensure compliance. RB will also follow the guidelines and

abide by the rules as defined in the MMP

Notwithstanding the above, Umvoto Africa is confident that these assumptions and

limitations do not compromise the overall findings of the report.



2 GOVERNANCE FRAMEWORK AND ENVIRONMENTAL

PROCESS

2.1 LEGAL REQUIREMENT

Appendix 2 Section 2 (e) of GN 982 requires that a description of the policy and legislative

context within which the development is proposed is provided. There are a number of

regulatory requirements at local, provincial and national level with which the proposed

development will have to conform. Some of the key legal requirements include the

following:

National Environmental Management Act 107 of 1998, as amended (NEMA);

EIA Regulations, promulgated in terms of NEMA (Notice R.982, 2014);

National Water Act 36 of 1998 (NWA);

National Heritage Resources Act 25 of 1999 (NHRA);

National Environmental Management: Biodiversity Act 10 of 2004 (NEM:BA) and

National Environmental Management: Air Quality Act 39 of 2004, as amended

2014 (NEM:AQA).

A brief summary of the relevant Acts and Regulations that are applicable to this study is

provided below. Note that other legislative requirements may also pertain to the proposed

project. As such, the summary provided below is not intended to be definitive or

exhaustive, and serves only to highlight key environmental legislation and obligations.

2.1.1 National Environmental Management Act 107 of 1998 (NEMA);

NEMA establishes a set of principles that all authorities have to consider when exercising

their powers. These include the following:

Development must be sustainable;

Pollution must be avoided or minimised and remedied;

Waste must be avoided or minimised, reused or recycled;

Negative impacts must be minimised; and

Responsibility for the environmental consequences of a policy, project, product or

service applies throughout its life cycle.

Section 28(1) states that “every person who causes, has caused or may cause significant

pollution or degradation of the environment must take reasonable measures to prevent

such pollution or degradation from occurring, continuing or recurring”. If such

degradation/pollution cannot be prevented, then appropriate measures must be taken to

minimise or rectify such pollution. These measures may include:

Assessing the impact on the environment;

Informing and educating employees about the environmental risks of their work

and ways of minimising these risks;

Ceasing, modifying or controlling actions which cause pollution/degradation;

Containing pollutants or preventing movement of pollutants;

Eliminating the source of pollution; and



Remedying the effects of the pollution.

Legal requirements for the Robertson Bakstene Brick Making Facility:

The proponent is obligated towards and has the responsibility to ensure that the proposed

activities conform to the principles of NEMA as described above and is obliged to take

pre-emptive action to ensure that the impacts associated with the brick factory

development are taken into account and where possible mitigated.

2.1.2 EIA Regulations, promulgated in terms of NEMA;

Sections 24 and 44 of NEMA make provision for the promulgation of regulations that

identify activities, which may not commence without an Environmental Authorisation (EA)

issued by the competent authority (DEA&DP,). In this context, the EIA Regulations, 2014

(GN R.982, which came into effect on 8 December 2014), promulgated in terms of NEMA,

govern the process, methodologies and requirements for the undertaking of EIAs in

support of EA applications. The EIA Regulations are accompanied by Listing Notices 1-

3 (GN R 983/4/5) that list activities that require EA, these are termed “NEMA listed

activities”.

There are two alternative authorisation processes and depending on the type of activity

that is proposed, either a Basic Assessment (BA) process or a Scoping and Environmental

Impact Report (S&EIR) process is required to obtain an EA. Listing Notice 1 (GN 983 of

2014) lists activities that require a BA process, while Listing Notice 2 (GN 984 of 2014)

lists activities that require S&EIR. Listing Notice 3 (GN 985 of 2014) lists activities in

certain sensitive geographic areas that require a BA process. The regulations for both

processes – BA and S&EIR – stipulate that:

Public participation must be undertaken at various stages of the assessment

process;

The assessment must be conducted by an independent EAP;

The relevant authorities must respond to applications and submissions within

stipulated time frames;

Decisions taken by the authorities can be appealed by the proponent or any other

Interested and Affected Party (IAP) and

A draft Environmental Management Programme (EMP) must be compiled and

released for public comment.

Appendix 2 Section 2 (d) of GN 982 requires that all listed and specified activities triggered

and being applied for are clearly listed. The RB project is obliged to apply for EA for listed

activities in terms of Listing Notices 1, & 2 (R.983 and R.984 as per NEMA Regulations

R.982, 2014) in terms of sections 24(4) and 24(D) of NEMA 107/1998 (Table 2-1 and

Table 2-2) and undertake a Scoping and EIA process in support of said application. No

activities in Listing Notice 3 (R. 985) are triggered.



Table 2-1: Listing Notice 1 (No. GN. 983). Triggers in terms of 24 (2) and 24D

Activity

Number

Activity description Portion of the proposed

project to which the

applicable listed activity

relates.

12 The development of

(ii) channels exceeding 100 m2 in size,

(x) building exceeding 100 m2 in size

(xii) infrastructure and structures with a physical

footprint of 100 m2 or more;

where such development occurs

(a) within a watercourse,

(c) if no development setback exists, within 32

metres of a water course, measured from the

edge of a watercourse.

The development will partly

occur on in close vicinity to an

ephemeral water course.

Hence, the drainage line will be

diverted and building and or

infrastructure erected within the

buffer zone of the water course.

The diversion of the water

course is covered under the

environmental authorization

process and WULA by the

Gannabosch Clay Mine.

19 The infilling or depositing of any material of more

than 5 cubic metres into, or the dredging,

excavation, removal or moving of soil, sand,

shells, shell grit, pebbles or rock of more than 5

cubic metres from

(i) a watercourse;

It is expected that the water

course will be filled up with

material from the surrounding to

provide the platform and

foundation for the infrastructure

referred to above.

27 The clearance of an area of 1 hectare or more,

but less than 20 hectares of indigenous

vegetation.

Clearance of vegetation is

required in preparation at the

ground on which to build and

place the Factory and the

associated infrastructure.

28 Residential, mixed, retail, commercial, industrial

or institutional developments where such land

was used for agriculture on or after 01 April 1998

and where such development:

(ii) will occur outside an urban area,

where total land to be developed is

bigger than 1 hectare.

The property is zoned

agriculture, but will be used for

commercial and industrial

purposes.

A temporary departure for the

land zoning has been applied

for.



Table 2-2: Listing Notice 2 (No. GN. 984) Triggers in terms of 24 (2) and 24D

Activity

Number

Activity description Portion of the proposed

project to which the

applicable listed activity

relates.

6 The development of facilities or infrastructure for any

process or activity which requires a permit or licence

in terms of national or provincial legislation governing

the generation or release of emissions, pollution or

effluent.

The brick making facility will

produce more than 100 000

bricks per month, and thus

in terms of GN 551 of 2015,

which promulgates

amendments to the listed

activities in terms of section

21 of the Air Quality Act, is

required to apply for an

Atmospheric Emissions

Licence.

28 Commencing of an activity, which requires an

atmospheric emission license in terms of section 21

of the National Environmental Management: Air

Quality Act, 2004 (Act No. 39 of 2004).

See above

2.1.3 National Water Act 36 of 1998 (NWA);

Water use in South Africa is controlled by the NWA. The executive authority is the

Department of Water & Sanitation (DWS). The NWA recognises that water is a limited

resource, which is limited and unevenly distributed throughout South Africa. The Act

empowers the DWS to put measures in place to achieve sustainable and equitable use of

water to the benefit of all users and to ensure protection of the aquatic ecosystems

associated with South Africa’s water resources. The provisions of the Act are aimed at

discouraging pollution and wastage of water resources. In terms of the Act, a land user,

occupier or owner of land where an activity that causes or has the potential to cause

pollution of a water resource has a duty to take measures to prevent pollution from

occurring. If these measures are not taken, the responsible authority may do whatever is

necessary to prevent the pollution or remedy its effects, and to recover all reasonable

costs from the responsible party.

Section 21 of the NWA No 36 of 1998 specifies a number of water uses. Relevant for the

brick factory development might be the following:

(a) Taking of water from a water resource;

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

(f) Discharging waste or water containing waste into a water resource; and

(i) Altering the bed, banks, course or characteristics of a watercourse.

Activities that modify the bed, banks or characteristics of a watercourse, or which impede

or divert the flow of water in a watercourse, are considered water use under Section 21

and would require an authorisation from the Department of Water & Sanitation (DWS) in

terms of the National Water Act (Act No. 36 of 1998) (NWA).



The Gannabosch Clay Mine (Pty) Ltd will submit a registration for a General Authorisation

of the water use as per Section 21(c) and (i) above “to the Breede Gouritz Catchment

Management Agency (BGCMA). This registration covers for these water uses. The

Robertson Bakstene (Pty) Ltd will submit registration forms for the General Authorisation

of the groundwater abstraction for utilisation within the brick making facility.

2.1.4 National Heritage Resources Act 25 of 1999 (NHRA)

The protection and management of South Africa’s heritage resources are controlled by

the Natural Heritage Resources Act no.25 of 1998 (NHRA). The enforcing authority for

this act is the South African National Heritage Resources Agency (SAHRA) and in the

Western Cape, SAHRA has delegated this authority to Heritage Western Cape (HWC).

In terms of the Act, historically important features such as graves, trees, archaeological

artefacts/sites and fossil beds are protected. Similarly, culturally significant symbols,

spaces and landscapes are also provided protection.

Section 38 of the NHRA requires that any person who intends to undertake certain

categories of development must notify SAHRA and/or HWC at the very earliest stage of

initiating such a development and must furnish details of the location, nature and extent

of the proposed development. HWC has designed a Notification of Intent to Develop (NID)

to assist the developer in providing the necessary information to enable HWC to decide

whether a Heritage Impact Assessment (HIA) will be required.

Section 38 also makes provision for the assessment of heritage impacts as part of an EIA

process and indicates that, if such an assessment is deemed adequate, a separate HIA

is not required. There is however the requirement in terms of Section 38 (8) for the

consenting authority (in this case the DEA&DP) to ensure that the evaluation of impacts

on the heritage resources fulfils the requirements of the relevant heritage resources

authority (in this case HWC), and that the comments and recommendations of the heritage

resources authority are considered prior to the granting of the consent.

An archaeological specialist NID report listing the activities was submitted on behalf of

Gannabosch Clay Mine to Heritage Western Cape in 5 May 2016 by Asha Consulting

(Pty) Ltd (Annexure A-1: First Notice of Intent to Develop). The recommendation was

that a Heritage Impact Assessment (HIA) is not required since the site was deemed to

have low historical value. A response, in confirmation of this was received on 13 May

2016 (Appendix C – Heritage Western Cape). The same recommendation may be

applied to the proposed brick factory facility as it will be devolved on and close to the same

property as the proposed clay mine and that the field survey conducted by the consultant

encompassed and reported on the full extent of the Gannabosch Vlakte 51 property.

2.1.5 National Environmental Management: Biodiversity Act 10 of 2004 (NEMBA);

The purpose of the NEMBA is to provide for the management and conservation of South

Africa’s biodiversity and the protection of species and ecosystems that warrant national

protection. The NEMBA makes provision for the publication of bioregional plans and the

listing of ecosystems and species that are threatened or in need of protection. Threatened

or Protected Species Regulations (2007), Guidelines for the determination of bioregions

and the preparation and publication of bioregional plans (2009) and a National List of



Ecosystems that are Threatened and in Need of Protection (2011) have been promulgated

in terms of NEMBA.

A published bioregional plan is a spatial plan indicating terrestrial and aquatic features in

the landscape that are critical for conserving biodiversity and maintaining ecosystem

functioning. These areas are referred to as Critical Biodiversity Areas (CBAs) in terms of

NEMBA. Bioregional plans provide guidelines for avoiding the loss or degradation of

natural habitat in CBAs with the aim of informing, EIAs.

Permits to carry out a restricted activity involving listed threatened or protected species or

alien species may only be issued after an assessment of risks and potential impacts on

biodiversity has been undertaken, which is the purpose of any EIA.

The Robertson Bakstene (Pty) Ltd has a responsibility to provide for the protection of

ecosystems that are threatened or in need of protection to ensure the maintenance of their

ecological integrity. The proposed brick factory footprint falls within a Critical Biodiversity

Area (CBA) which form a natural corridor between the Langeberg Mountains and Breede

river and includes plant species of the Breede alluvium Renosterveld (Vulnerable) and

Robertson Karoo (Least Threatened) as noted and discussed in the Specialist Botanical

Report (Annexure B-1: First Botanical Specialist Report).

2.1.6 National Environmental Management: Air Quality Act 39 of 2004

The Air Quality Act aligns itself with the National Environmental Management Act (section

2) and section 24(b) of the Constitution by promoting ecologically sustainable

development, whilst promoting justifiable economic and social development. This is done

through the protection and enhancement of the air quality on a national scale, as well as

the prevention of air pollution and ecological degradation.

Sections 9 to 11 deal with National, Provincial, and local air quality standards, and makes

provisions for the minister, MEC, or municipality, to establish standards for air quality

within their relevant spheres of governance. The Robertson Bakstene brick factory, falling

within the Langeberg Municipalities scope of governance, would need to conform to any

air quality standards laid out by the Municipality. If the Municipality does not have relevant

standards, then the provincial standards will apply.

Section 21 of the Act states that the Minister must publish a list of activities which result

in atmospheric emissions that may have a detrimental effect on the environment. This list

has been published and amended as per GN R551 of 2015 “List of activities which result

in atmospheric emissions which have or may have a significant effect on the environment,

including health, social conditions, economic conditions, ecological conditions, or cultural

heritage”. Any listing under this notice requires an Atmospheric Emissions Licence (AEL).

The activities associated with the planned brick making factory facility fall under the above-

mentioned listings, therefore making the application for an AEL imperative. The licencing

authority for the Gannabosch Vlakte development is the Cape Winelands District

Municipality.



2.2 PLANNING POLICY FRAMEWORK

Two significant planning policies and spatial development plans relevant to the Robertson

Bakstene Brick Making Facility development, are identified. It is incumbent on the

S&EIAR to demonstrate that the proposed development should, as far as possible, be

consistent with these plans.

Spatial Development Plans (SDF) for the Western Cape Province, Cape

Winelands District Municipality and Langeberg Local Municipality;

Integrated Development Plans (IDP) for the Cape Winelands District Municipality

and the Langeberg Local Municipality;

Spatial development frameworks translate the aims of the IDP’s into a spatial dimension

and, together with the IDP’s, aim to give effect of the national priority of increasing

economic growth and promoting social inclusion, whilst ensuring that such growth is

environmentally sustainable for the particular region (WCDEA&DP,2015)

This section implicitly examines the extent to which the proposed project is consistent with

relevant plans, supported by an explicit analysis of need and desirability in Section 4 and

Section 7 of this EIA Report. The key elements of each SDF and IDP are listed below.

The Robertson area is identified as a regional center in terms of growing the provincial

economy and its geographic situation within a rural development corridor, which stretches

between Ceres and Swellendam is highlighted. Conflicting management challenges arise

from the threat to remnant natural landscapes, biodiversity and ecosystem services due

to, in part, the expansion of economic development initiatives. The central theme of the

S&EIAR is to manage the trade-offs between these often-competing land uses.

2.2.1 Western Cape Provincial Spatial Development Framework (2014)

The Western Cape PSDF (2014) is a spatial instrument that seeks to integrate the spatial

agenda of all Provincial departments and is informed by (and in turn informs)

complementary National, Provincial and Municipal IDPs. The PSDF seeks to “improve

the effectiveness of public investment in the Western Cape’s built and natural

environments by:

Adopting credible spatial planning principles to underpin all capital investment

programs;

Spatially targeting and aligning the various investment programs, and

Opening up opportunities for community and business development in targeted

areas.”

The PSDF identifies three interrelated themes for provincial spatial planning within which

several policies for dealing with the Province’s key development challenges are identified,

as set out below (Table 2-3):

Table 2-3: WCPSDF policies

Spatial Framework Policies

Resources: Protect biodiversity and ecosystem services;



Sustainable use of the

Western Cape’s spatial

assets

Safeguard inland and coastal water resources, and

manage the sustainable use of water;

Safeguard the Western Cape’s agricultural and mineral

resources, and manage their sustainable use;

Recycle and recover waste, deliver clean sources of

energy to urban consumers, shift from private to public

transport, and adapt to and mitigate against climate

change, and

Safeguard cultural and scenic assets.

Space Economy:

Opening-up opportunities in

the provincial space-

economy

Use regional infrastructure investment to leverage

economic growth;

Diversify and strengthen the rural economy, and

Revitalize and strengthen urban space-economies as the

engine of growth.

Settlement:

Developing integrated and

sustainable settlements

Protect, manage and enhance sense of place, cultural and

scenic landscapes;

Improve inter and intraregional accessibility;

Promote compact, mixed use and integrated settlements;

Balance and coordinate the delivery of facilities and social

services, and

Promote sustainable, integrated and inclusive housing in

formal and informal markets

2.2.2 Cape Winelands District Municipality Integrated Development Plan (IDP)

The (2012/2016) Cape Winelands District Municipality IDP’s vision is “A unified Cape

Winelands of Excellence” and envisages the co-operation of all structures of the Cape

Winelands for the effective, efficient and economically sustainable development through

the following strategic objectives:

To create an environment and forge partnerships that ensures the health, safety,

social and economic development of all communities including the empowerment

of the poor in the Cape Winelands District through economic, environmental and

social infrastructure investment;

Promoting sustainable infrastructure services and transport system, which fosters

social and economic opportunities, and

To provide an effective and efficient financial and strategic support services to the

Cape Winelands District Municipality.

2.2.3 Cape Winelands District Municipality Spatial Development Framework (SDF)

The Cape Winelands District Municipality Spatial Development Framework of 2007

consists of several policies listed below:

Sustainable management of and use of the built and natural resources in a manner

that ensure that the need of the present generation is met without compromising

the ability of future generations to meet their respective needs;

Everyone affected by spatial planning, land use management and land

development actions or decisions enjoy equitable protection and benefits;



The desired results of land use planning are produced with the minimum

expenditure of resources; and

Separate and diverse elements involved in the development planning and land use

are linked and coordinated into a harmonious whole. These represent the

principles of sustainability, equality, efficiency and integration.

2.2.4 Langeberg Local Municipality Integrated Development Plan (IDP)

The (2016/2017) Langeberg Local Municipality IDP’s vision is “To create a stable living

environment and sustainable living conditions for all citizens” by providing cost effective

quality services to the citizens, exercise good leadership, ensuring sound governance and

financial management.” Via the following strategic objectives:

Sustainable integrated human settlements;

Sustainable civil engineering infrastructure services;

Energy efficiency for a sustainable future;

Provision of a safe and efficient road network;

Promotion of public safety;

Provision of a clean environment;

Social community development;

Growth and economic development;

Sound financial management;

Institutional development and corporate governance, and

Good governance.

2.2.5 Langeberg Local Municipality Spatial Development Framework (SPDF)

The Langeberg Local Municipality SDF’s vision is to ensure the Municipality’s physical

attributes including the Riviersonderend, Langeberg and Waboom mountains, Breede

river with its tributaries and fertile land, the large heritage building stock, factories and

infrastructure, including the R60 and R62, are sustainably exploited to continue to provide

and enhance the livelihoods of its residents (CNdV, 2014); The implications of this vision

are as follows:

The water quality and quantity of the rivers must be improved, especially in the

Breede, Touw, Keisies, Poesjenels, Houtbaais and Riviersonderend Rivers;

There should be no further urban development of existing or potential arable land;

The use of the rail system for freight traffic should be promoted to free up the use

of the road network for commuter and tourist private motor vehicle, bus and coach

and non-motorised traffic;

The visual impact of buildings, e.g. large resorts, factories and sheds, and

infrastructure, power lines, renewable energy facilities and roads should be

carefully assessed, and

Highly accessible and visually exposed sites should also be accessible to SMME

businesses.



2.3 ENVIRONMENTAL PROCESS

Chapter 1 of NEMA (Act 107 of 1998) lists several principles most relevant to the

environmental impact assessment processes. This EIA Report is guided by such

principles as follows:

Principles relevant to the EIA process:

The following key principles of the EIA process bear relevance to the project and the

S&EIR process should comply with these principles through its adherence to the EIA

Regulations, 2014 and the associated guidelines, which set out clear requirements for,

impact assessment and stakeholder involvement as follows

Place people and their needs at the forefront of concern and serve their needs

equitably;

Ensure that development is socially, environmentally and economically

sustainable.

Ensure that development avoids, minimises or remediates disturbance of

ecosystems, loss of biodiversity, pollution and waste of environment and culturally

significant heritage landscapes;

Ensure development achieves responsible use of non-renewable resources and

takes into account the depletion of the resource;

Adopt a risk-averse and cautious approach, taking into account the limits of current

knowledge;

Anticipate and prevent or minimise negative impacts on both the environment and

people’s environmental rights;

Pursue integrated environmental management Involve stakeholders in the process

Decision making to be informed along with the opportunity for public and specialist

input in the decision-making process;

Accountability to be held for information on which decisions are made;

Adopt a broad interpretation of the term “environment”;

Pursue an open participatory approach in the planning of proposals;

Hold ongoing consultation with interested and affected parties;

Take into account due consideration of alternatives;

Ensure that an attempt is made to mitigate negative impacts and enhance positive

impacts of proposals;

Ensure that an attempt is made to ensure that the social costs of development

proposals are outweighed by the social benefits;

Consider the democratic regard for individual rights and obligations;

Assume responsibility for project impacts throughout its life cycle and compliance

with these principles during all stages of the planning, implementation and

decommissioning of proposals, and

Polluter bears remediation costs.

Although other environmental authorisations, permits or licences may be required before

the proposed project may proceed, the regulatory authorities are committed to the



principle of cooperative governance between competent authorities. This means that a

single S&EIR process is required to inform all applications and therefore this single S &

EIA Report has been compiled for submission to the DEA&DP in support of the application

for environmental authorisation of NEMA listed activities.

2.3.1 Submission of Environmental Authorisation and other Relevant

Applications

The environmental authorisations that are required before the proposed project may

proceed are listed in Table 2-4 below.

Table 2-4: Environmental Authorisations, Possible Permits and Licences Required

Application Competent Authority Current Standing

Environmental

Authorisation

DEA&DP Western

Cape

Application for Environmental Authorisation was

submitted on the 2017-02-02.

Heritage

Application /

Notice of Intent to

Develop

Heritage Western

Cape Ref No

(16041402WD0504E).

Complete (Annexure A-1: First Notice of Intent

to Develop and Annexure A-2: Amended Notice

of Intentt)

Water Use Licence

DWS & Breede

Gouritz Catchment

Management Agency

(BGCMA).

A registration for General Authorisation of

Section 21(c) and (i) water use, and for General

Authorisation of Section 21(a), will be submitted

to BGCMA.

Air Emission

License

Cape Winelands

District Municipality

(CWDM). Municipal

Health Services

AEL was submitted on 2017-02-14 (Annexure C:

Atmospheric Emission License Application)

LUPA Temporary

Zone Departure

Application

Langeberg Local

Municipality (LLM)

A LUPA was submitted on 2016-05-04

(Appendix D – LUPA Temporary Zone

Departure Application)

2.3.2 S&EIR Process and Phasing

The S&EIR process consists of two phases, namely the Scoping Phase and an Impact

Assessment Phase.

The objectives of the Scoping Phase:

Identify stakeholders and IAP’s and inform them of the proposed activity, possible

alternatives and the S&EIR procedure;

Describe the affected environment and present an analysis of the possible

environmental issues and the positive benefits that may arise from the project;

Develop ToR for specialist studies to be undertaken and to appoint practitioners;

Provide stakeholders and IAP’s the formal opportunity to participate fully and

effectively in the process and raise any issues and concerns that may be

associated with the proposed activity, and

Produce a Scoping Report for submission to the decision making authority, which

is the DEA&DP.



The objectives of the Impact Assessment Phase:

Obtain Contributions and ensure meaningful participation from stakeholders and

IAP’s and address their relevant concerns and issues;

Record and document the biophysical baseline conditions of the immediate mine

zone and the socio-economic conditions of the neighbouring and affected region;

Provide a detailed assessment of the potential environmental and socio-economic

impacts of the proposed development;

Identify mitigation measures to avoid or address the impacts and

Develop an environmental, financial and social Maintenance and Management

plan (MMP) based on the mitigation measures developed in the EIA report.



3 BASELINE ENVIRONMENT

This section presents an overview of the biophysical and socio-economic environment in

which the proposed brick making facility is located. The intention is to:

Understand the general sensitivity of and pressures on the affected environment;

Inform the identification of potential issues and impacts associated with the

proposed project;

Inform the comparative assessment of the project alternatives in order to identify

the preferred alternative; and

Start conceptualizing possible and practical mitigation measures.

During the Scoping phase, a number of key natural environments were identified through

engagement with governing stakeholders, various organisations and private IAP’s

(Appendix F – IAP & Stakeholder concerns Raised). Independent specialists were

appointed to investigate the current status of these identified key natural environments

and to indicate the possible impact of the development of the brick making facility and to

suggest alternatives to reduce the identified impacts. The following specialist studies

(Table 3-1) were the outcome of the scoping phase, which was also prepared for

Gannabosch Clay Mine.

Table 3-1: Specialist Studies

Specialist Study Specialist Organisation Annexures

Heritage Specialist Study Jason Orton ASHA Consulting (Pty) Ltd A1 & A2

Botanical Impact

Assessment

Johlene Krige Private B1 & B2

Fresh Water Ecology

Impact Assessment

Dean Ollis The Freshwater Consulting

Group E1 & E2

Visual Impact Assessment Megan Anderson Megan Anderson Landscape

Architects F

Dust Emission Study Dr Harold Annegarn Private G

Traffic Impact Study Eric Foster EFG Engineers (Pty) Ltd H

Alternative Resource

Study

Dylan Blake Umvoto Africa (Pty) Ltd I

Economic Impact Study John Steenkamp Bauhaus Simple Property

Growth J

Storm Water Management

Plan and Diversions

Kornelius Riemann,

Luke Wiles & Mark

Bollaert

Umvoto Africa (Pty) Ltd. &

Highlands Hydrology (Pty)

Ltd

D

Final specialist study reports are attached as Annexures A, B, D, E, F, G, H, I and J.



3.1 DESCRIPTION RESIDENTIAL, SOCIO-ECONOMIC AND CULTURAL RECEIVING

ENVIRONMENT

This section fulfils requirements Paragraph 2 (h) (iv) of Appendix 2, GN 982 and has been

compiled by means of a desktop baseline study using sources from various specialists,

site visits and available information. Further input and/or amendments will be included

once the PPP is completed should any additional information be forthcoming. The

baseline information is aimed at giving the reader perspective on the existing status of the

non-developed receiving environment and specifically focuses on the social, economic,

heritage and cultural attributes.

3.1.1 Community Ownership and Traditional Authorities

There are no HDSA communities, or occupants on the proposed brick factory site on the

farm Gannabosch Vlakte No. 51 within Ward 6 of the Langeberg Local Municipality of the

Cape Winelands District Municipality. The landowner H R Grobbelaar Family Trust

confirmed that no persons occupy the land, permanently or temporarily.

The Department of Rural Development and Land Reform (DRDLR) has been identified as

one of the Interested and Affected Parties. During the Gannabosch Clay Mine application

process, a letter was sent informing the DRDLR of the intended application (see

Appendix E – Interested and Affected Parties Register). An enquiry was made on 30

November 2015 to the Commission on Restitution of Land Rights within the DRDLR

concerning any possible restitution claims against the property of Gannabosch Vlakte No.

51. The department confirmed that there are no current claims on this property (Appendix

G – Land Affairs Response).

Traditional Authorities are recognised in terms of section 211 of the 1996 Constitution of

South Africa. The Robertson office of the Langeberg Local Municipality has confirmed

that no Traditional Authority is present in the area and that the LM is the sole civic decision

making authority on the region.

3.1.2 Landowners and Title Deed Owners

The portion of Gannabosch Vlakte No. 51 is lawfully owned by the H R Grobbelaar Family

Trust (Title Deed Reference Number: T 41359-95 issued on the 22nd of March 1995)

(Appendix H – Title Deed (Gannabosch Vlakte 51)).

3.1.3 Departure of Zoning to Land for Industrial Purpose

The application site is zoned Agricultural Zone 1 in terms of the Section 8 Zoning Scheme

Regulations. The primary use permitted is agriculture, which means “(a) the cultivation of

land or (b) the breeding of animals, or (c) natural veld, and comprises only of those

activities and buildings that directly relate to the main farming activities on the farm”. The

proposed brick factory activities do not fall within the above definition and application has

been made to the Langeberg Municipality in terms of the Langeberg Land Use Planning

Bylaws PN 264/2-15, for a departure from the zoning provisions. Proof of such application

is included in Appendix D – LUPA Temporary Zone Departure Application. It is an internal

policy of the municipality to initially only consider a temporary departure for a five-year

period (previously for 20 years), after which the proponent will need to apply for a rezoning.



The approval of both the temporary departure and rezoning is officiated and, depending

upon objections, decided by the Langeberg Planning Tribunal. The rezoning will be

subject to the track record of the applicant and consideration will be given to how the

operation was run and if there were any valid complaints.

3.1.4 The Local Municipality

The proposed Brick Factory site is located within Ward 6 of the Langeberg Local

Municipality, Robertson Magisterial / Administrative District in the Western Cape Province.

They have been included as Registered Interested and Affected Parties and have been

alerted to the application by email and registered post. Councilors of Ward 6 have also

been individually contacted by email and registered letter. The Local Municipality has

been contacted and an application submitted for Temporary Departure from Agriculture to

Industrial land use as per requirements of Land Use Planning Ordinance (LUPO) executed

on 4 May 2016. See Appendix D – LUPA Temporary Zone Departure Application.

3.1.5 Existing Status of the Cultural and Heritage Environment that may be

affected

Multiple site visits on 30th, 31st October 2015, 6 November 2015 and 10 August 2016, by

both the EAP and a specialist heritage consultant, established there is no cultural, heritage

or archaeologically significant environment on the land unit or within the immediate

surrounds. The Notice of Intent to Develop / Heritage Western Cape Report in respect of

the Gannabosch Vlakte 51 farm, by Asha Consulting concurs that there is no historical

evidence of any cultivated or cleared lands within the proposed target area, nor any

presence of archaeological artefacts of significance. Correspondence from Heritage

Western Cape (2016-10-10) in Appendix C – Heritage Western Cape, concluded that

there is no reason to believe that the proposed brick factory development will impact on

heritage resources, and that there is no requirement for a Heritage Impact Assessment

under Section 38 of the National Heritage Resources Act (Act 25 of 1999).

3.1.6 Current on Site Land Use

The proposed development land is currently unutilised and exists in a natural state of

indigenous vegetation. The Vink and Norrie rivers flow adjacent to the project area, along

with three prominent ephemeral drainage lines, one of which bisects the proposed

development area. Several farm dams surround the areas, though none lie within the

development zone. The land in the application area (still in its original state) consists of

indigenous Breede Alluvium Renosterveld, which is classified as Vulnerable. Multiple

EAP site visits on 30th, 31st October 2015, 6 November 2015 and 10 August 2016 and the

Botanical Specialist Report by Krige, confirm that there are no cultivated fields, no stock

farming or grazing on the land.

3.1.7 Surrounding Land Use

The project area lies on a portion of the farm Gannabosch Vlakte 51. The area is bordered

to the south west by the Vink River and is located ~600 m north east of the TR 31/1 R60

national road, which runs through the Cape Winelands district, joining Worcester and

Robertson.



There is no current on-site land use and there are no residents living on the current

proposed land for the brick factory. The proposed land portion therefore has no socio-

economic sensitivity to the development plans. Gannabosch Vlakte No.51 is situated

within a rural farming area. The primary land usage of surrounding properties consists of

cultivation of wine grapes, minor stone fruit (peaches), as well as small scale grain

cultivation to supply fodder for the non-intensive livestock farming occurring on adjacent

and non-adjacent properties. On a non-adjacent property, ~2km to the North, a limestone

quarry (Cape Lime) operates to supply limestone to the processing plant which is located

on the adjacent property, Lange Vallei 5/52, just to the south of Gannabosch No.51

property. Associated in particular with the viticulture industry is related tourism in the form

of guest houses, wine tasting and purchase and restaurant.

Table 3-2 and Figure 3-1 indicate the neighbouring (physically adjacent) farm units and

their land uses that may be affected by the proposed development.



Table 3-2: Surrounding property land use

Neighouring Farm

Portion Land Use Activities

Middelburg 9/10 Thicket / Dense bush & Shrubland Fynbos – Land Cover (DEA,

2014)

Middelburg RE/10 Enterprises: Fruit - Wine grapes (Crop Census, 2013)

Alwynbos Vlakte No.299 Shrubland Fynbos – Land Cover (DEA, 2014)

Noree No.300 Shrubland Fynbos – Land Cover (DEA, 2014)

De Hex Rivier 18/50 Enterprises: Fruit - Wine grapes (Crop Census, 2013)

Lange Vallei 5/52 Enterprises:Fruit – Mostly wine grapes and some peach (Crop

Census, 2013)

Proximate farm

portions Land Use Activities

Lange Vallei 15/52 Thicket /dense bush- Land Cover (DEA,2014)

Lange Vallei 16/52 Thicket/dense bush -Land Cover (DEA,2014)

Lange Vallei 17/52 Succulent Karoo-Cultivated Vines (high) – Land Cover (DEA,2014)

Lange Vellei 2/52 Succulent Karoo- Thicket /dense bush – land Cover (DEA,2014)

Lange Vellei 6/52 Succulent Karoo- Woodlan /open bush -Land Cover (DEA,2014)

Lange Vellei 18/52 Succulent Karoo-Thicket/dense bush -Land Cover (DEA,2014)

DE Hex Rivier RE/50

Succulent Karoo-Thicket/dense bush-Land Cover (DEA,2014)

Wine grapes – (Crop Census,2013)

Middleburg 4/10 Succulent Karoo- Irrigated land, Stone Fruit, Peach -Land Cover

(DEA,2014)

Noree 300 RE 4/50 Fynbos – Shrubland fynbos-Land Cover (DEA,2014)

Noree 300 RE 20/13 Fynbos- Shrubland fynbos-Land Cover (DEA,2014)



Figure 3-1: Neighbouring farms to Gannabosch Vlakte 51



3.1.8 Regional Land Conservation Units

The farm property lies at its closest, ~3 km from the Langeberg-West Mountain Catchment

conservation area which forms part of the Mountain Catchment Conservation. A

subsection of this area is shown in Figure 3-2 below. The smaller Dooringkloof Private

Nature Reserve is located ~4 km to the north of the development area.

Figure 3-2: Langeberg-West Mountain Catchment Conservation and Doringkloof Private Nature Reserve that are in close proximity to Gannabosch Vlakte 51

The proposed development site is part of the Rooiberg Breede River Conservancy. (See

Figure 3-3) The Conservancy currently has 27 member landowners, not including Friends

of the Conservancy, who manage, farm or own approximately 13 500 ha land around the

Gannabosch area.

3.1.9 Nearby Residences and Dwellings

Utilising the GIS tool “Cape Farm Mapper http://gis.elsenburg.com/apps/cfm/, a ~5 km

search radius was undertaken, and 19 dwellings were located. These dwellings were

primarily located along the banks of the Noree River, ~3 km to the east of the proposed

brick making factory, and further SE of the confluence of the Noree and Vink River (See

Figure 3-4) and serve as dwellings for individuals living/working on the respective

properties.

http://gis.elsenburg.com/apps/cfm/



Figure 3-3: Land units of the Rooiberg Breede Conservancy are indicated in yellow, of which Gannabosch Vlakte 51 is shown in the centre of the conservancy.

Figure 3-4: Habitations in the vicinity of the proposed Robertson Brick Factory. The dots

represent established homesteads. The diameter of the circle is 2 km, centred

on the site of the quarry. Green star indicates Manager’s residence, blue cross

indicates Cape



3.1.10 Nearby businesses/ tourist places

Aside from agricultural activities, other key economic activity in the area consists of the

Cape Lime processing plant and the associated limestone quarry mine as well as several

tourist related industries. The proposed brick factory site falls within the Breede River

Valley wine route, and is a feeder road into the R66 Klein Karoo tourist route which serves

as an alternative to the highly popular N2 Garden Route. Viticulture and related tourist

interest are noted activity in the region and a number of guest houses are within the

locality. (See Figure 3-5). The Rooiberg Mountain Bike Trail is offered by the

conservancy and is part of the tourism initiatives that are currently being developed for

the area. (See Figure 3-6).

Figure 3-5: Localities of residents and tourism facilities within immediate area of the

proposed development. The yellow circle indicates the zone of noise extent.

Dark red indicates the 1km fugitive dust fallout and light red indicates 2 km

fugitive dust fallout. Both are plotted along the prevailing wind direction

(bottom right corner).



Figure 3-6: The Rooiberg Mountain Bike Trail shown to be running south of the brick factory

3.2 DESCRIPTION OF THE BIOPHYSICAL RECEIVING ENVIRONMENT

Paragraph 2 (h) (iv) of Appendix 2, GN 982 requires a description of the biophysical

attributes associated with the development footprint Section 3.2 focuses on the

geographical, physical and biological aspects of the receiving environment.

3.2.1 Topography

The project site is situated in the low lying foothills of the Langeberg range which slope

gently toward the Vink River south of the site.

The proposed property is located within the Cape Winelands District (previously known

as the Boland region). This area is located in the middle-upper courses of the Breede

River, situated within the central Cape Fold Belt Mountains and within the Breede Valley.

It is bordered between the Langeberg ~1400 mamsl and Riviersonderend ~ 1300 mamsl

mountain ranges to the north and south respectively high. (See Figure I 1). Locally, the

property is situated on slightly southward sloping, lower lying and level shrub lands,

(indigenous Breede Alluvium Renosterveld ), within closed hills with a moderate to high

relief of ~265 to 275 mamsl (slopes with a gradient of >5% are predominant within the

region.



3.2.2 Drainage

The property is located within the H40H quaternary catchment of the Breede-Gouritz

Catchment Management Area (BGCMA). The Breede River is the most significant

perennial river in the region. The non-perennial Vink River is located south of the property

and feeds the Breede River. Due to the low permeability of the clay soils, the property

experiences a significant amount of surface water run-off, which drains into the non-

perennial stream on the property and/or feeds into the Vink River.

Three drainage lines cross through the target area (see Figure 3-7). Drainage line 1

towards the west being of significant ecological importance has been excluded from the

amended target area and left intact as a corridor to support biodiversity and linkage within

the CBA. Drainage line 2 is of lowest significance, with no distinct channel and no noted

vegetation difference to the surrounding area. It will be compromised, via a diversion, in

the proposed development. Drainage line 3 towards the east has, like drainage line 1, is

being excluded from the target area.

These drainage lines are classified as both Ecological Support Areas and as an Aquatic

CBA. Overall, the natural habitat within the target area is in a good condition, well

connected to adjacent natural areas and is positioned within a CBA. The site accordingly

has a high ecological integrity.

Figure 3-7: Brick Factory footprint shown overlaying the mine concession and a portion to

the northwest border outside of concession area. While the proposed

development area impacts drainage line 2, the east and west boundary drainage

lines remain intact and preserve biodiversity.



3.2.3 Noise

Noise can be defined as "unwanted sound". Response to noise is not an empirical

absolute; it is often a psychological concept and does not need to be loud to be considered

“disturbing”. Depending on their activities, people generally are tolerant to noise up to a

certain absolute level, e.g. 65 dBA. Anything above this level is considered unacceptable.

The major noise generating activities will result from the operation of vehicles and tippers

associated with brick making facilities and the running of the plant, in particular the

crushers, and conveyor belts. The main noise generators in the brick factory system will

be the roller crushers (100 dBA), Cutting machines (90 dBA), and conveyors systems (100

to 120 dBA). Decibels are measured using a logarithmic scale1, meaning the cumulative

noise level expected from the factory in full production mode will approximate 103 dBA.

Noise levels at receptor location are compelled to be < 45dBA / 35dBA during the daytime

and nighttime respectively, in accordance with SANS-10103:2003 (South African National

Standards) (See Table 3-5). At this stage of the scoping process, a Noise Impact

Assessment Report is not considered necessary; however, given the proximity of the

nearby noise receptors a simplistic model was undertaken.

Assumptions:

1. The factory in full production mode is assumed to run at ~100 dBA

2. Baseline measurement is at 1 meter

3. The effect of reverberation and the topography is ignored.

Model:

1. Convert decibel level to sound intensity using: 100 dBA= 10-2 W/m2

2. Baseline intensity X (distance 12 / distance 22)

3. This showed a drop-off of 6.02 dB at a doubling of the distance.

Based on the accepted sound level drop of 6 dB per doubling of distance; simple modeling

predicts sound levels to approximate 45 dB at 500 m from source as shown in Table 3-3

and Figure 3-8. This is below the 65 dBA level considered to be acceptable and within

the 45 dBA requirement for rural districts according to the SANS-10103:2003 regulation

limits. (See Table 3-5).

1 The following logarithmic equation is used to calculate the sum of sound power levels: Total L = 10 x log10(Σ1n 10Ln/10), where n1 = 90, n2 = 100 , n3 = 100.



Table 3-3: Predicted sound level per decibel (dB) across a distance in meters (m).

Figure 3-8: Graphical representation of predicted sound level in decibel (dB) across a

specific distance in meters (m).

Potentially sensitive receptors were identified using Google Earth and topographical

maps, supported by site visit information. These are listed in Table 3-4 and illustrated in

Figure 3-5. Receptors within two kilometers of the factory are listed in this table as

relevant, all others may be considered beyond the range of influence. Within the critical

500 m radius, The “Coffee and Wine Shoppe” is a likely receptor, however due to position

off the main wind axis and the intervening Cape Lime Factory, the impact of noise

disturbance is likely to be attenuated. Buitenstekloof Mountain Cottages and the Rooiberg

Cellar & Wine, Bistro, Shop are a cause for concern, again they are not directly downwind

of the factory and the distance from source is significantly beyond the 500 critical radius.



Table 3-4: Listing of possible noise receptors in the surrounding area of the Brick making

facility. Localities of these receptors are shown in Figure 3-5.

Noise Receptor Latitude &

Longitude

Approx. distance

from operation

Saggy Stone Micro Brewery and Restaurant 33°41'37.74"S

19°43'6.11"E 7.49 Km

Tierhoek Cottages — Orange Grove Cottages 33°42'44.03"S

19°47'21.56"E 6.48 Km

Buitenstekloof Mountain Cottages 33°44'16.25"S

19°44'43.65" 2.10 Km

Coffee & Wine Shoppe Cafe @ Le Roux &

Fourie Vignerons (on directly Adjacent

Property)

33°45'40.79"S

19°44'22.86"E 0.67 Km

Rooiberg Cellar & Wine Shoppe, Bistro, Shop 33°46'37.26"S

19°45'43.09"E 2.83 Km

Rooiberg Private Residential dwelling 33°47'6.95"S

19°45'21.28"E 3.72 Km

Additional reduction of noise from the factory activity will be ensured by the fact that the

vegetated berms and windrows can be built around the trench providing additional sound

barriers. Additionally the factory could be built closed with brick walls which will further

reduce ambient sound levels. The extruders and kilns of the brick making facility are low

noise and will not present an impact. There are various ways in which the noise impact of

the factory activities toward the single receptor can be further mitigated.

Allowing a setback (buffer zone) of at least 500 meters (even with the berm in

place) between the factory and sensitive receptors;

Ensuring no night time operation of plant;

Ensuring that all equipment and machinery are well maintained and equipped with

silencers (where possible);

Considering the noise emission characteristics of equipment when selecting

equipment for a project/operation.

It is noted that the Wine Shoppe facility will be shielded from direct noise impact

from the brick factory by the intervening Cape Lime Production facility.

Specialist analysis provided, of the ambient noise levels of the factory may still be

required, for the final EIA report.

Table 3-5: Noise limits per sector

Equivalent Continuous Rating Leven For Noise (dBA)



Type of District Outdoors Indoors with open windows

Daytime Night-time Daytime Night-time

RESIDENTIAL DISTRICTS

Rural Districts 45 35 35 25

Suburban districts (little

road traffic) 50 40 40 30

Urban districts 55 45 45 35

NON-RESIDENTIAL DISTRICTS

Urban districts

(workshops, business

premises and main

roads)

60 50 50 40

Central business

districts 65 55 55 45

Industrial districts 70 60 60 50

3.2.4 Air Quality: Emissions and Fugitive Dust

Sulphur dioxide is emitted due to combustion of sulphur contained in the coal fuel used to

energise the clamp kilns. There are two potentially sensitive sites within a three kilometre

zone: (a) the offices and factory of the adjacent Cape Lime works; and (b) a roadside

trading store (wine retailing) and restaurant. Both these sites are off axis of the along-

valley prevailing south west to north east wind directions). (See Figure 3-5).

Dustfall and suspended particulate matter (PM10 and PM2.5) are emitted due to material

handling, vehicle entrainment, material processing, coal combustion within the clamp

kilns, and wind erosion of stockpiles. There are two potentially sensitive sites within a

three kilometre zone: (a) the offices and factory of the adjacent lime works; and (b) the

roadside trading store (wine retailing) and restaurant. Both these sites are off axis of the

along-valley prevailing wind directions (south west to north east), so are unlikely to be

adversely affected by particulate matter (dust) emissions from the proposed facility. (See

Figure 3-5).

3.2.5 Soils

The surrounding area is underlain by sandy, loamy alluvial, red clay loam and clay Karoo

soils. The sand and loamy alluvial soils originate from the weathering of the quartzitic

Table Mountain Group (Langeberg Mountains) to the north of the property and have been

deposited by sheet flow off of the mountain. The Gannabosch property itself is situated on

lime rich clayey soils which are derived from the weathering of the underlying shales (clay

rich rocks) of the Karoo Supergroup and Malmesbury Group. This is in agreement with

the Canadian System of Soil Classification which classifies it as Eutric Brunisol (EB);

therefore originating from weathering and occurring on top of their parent material. (CFM,

2017).



3.2.6 Geology

The resistant to weathering rocks of the Table Mountain Group (TMG) sandstones of the

Cape Supergroup define and form the peaks of the Cape Fold Belt Mountains.

To the north of the proposed development site, the south-westerly dipping normal

Worcester Fault has downthrown the southern, younger, Karoo Supergroup rocks

juxtapose those of the older basement Malmesbury Group and intrusive Robertson

Granite Suite, upon which the rocks of the unconformable overlying TMG form the ~1400

mamsl Langeberg Mountain range. To the south of the property, the steep (~50°)

northward steeply dipping Karoo Supergroup sediments transition into the conformable

and older stratigraphically underlying rocks of the Cape Supergroup, which rise up to form

the ~1300 mamsl elevation Riviersonderend Mountain Range. The stratigraphy in the

region is shown in Table 3-6.

Table 3-6: Stratigraphy

Age Supergroup Group Sub

group Formation Lithology

Quaternary

(~2.5-0

Ma)

Undifferentiated sediments Alluvium

Early to

Mid-

Permian

(~299-270

Ma) Karoo

Ecca

Waterford Feldspathic sandstone,

siltstone, shale

Tierberg Shale, mudstone, siltstone

Collingham Shale, Mudstone/tuff,

siltstone, chert

Whitehill Carbonaceous shales

cherty siltstone layers

Prince Albert Shale, siltstone

Carbonifer

ous

(~359-299

Ma)

Dwyka Tillite, Diamictite, shale

Cambrian-

Ordovician

(~510-350

Ma

Cape Super

Group

Table

Mountain

Group

Skurweberg Quartzitic sandstone,

pebble stringers

Peninsula Quartzitic sandstone

Late

Precambria

n

(~575-540

Ma)

Malmesbury Greywacke, sandstone,

slate

Late

Neoprotero

zoic

Cape

Granite

Suite

Granite



Age Supergroup Group Sub

group Formation Lithology

(~600-540

Ma)

On site, the property is underlain by Quaternary sediments deposited in the flood plains

of river courses controlled by the bounding mountain ranges of the Riviersonderend and

Langeberg Mountain ranges, which form the Breede Valley (see Figure I 6). Rock units

of the Ecca Group of the Karoo Supergroup underlay the overlying Quaternary sediments

and can be seen outcropping throughout the surrounding landscape and in nearby

diggings. The proposed development site will be concentrating on these underlying clay

sediments. The clays contain high amounts of Quartz and smaller amounts of mica and

feldspar. The feldspar is present in the form of plagioclase series which is a group of

related feldspar minerals that essentially have the same formula but vary in their

percentage of sodium and calcium content. Also present are traces of Kaolinite and

Smectite clay minerals.

Prince Albert Formation

Outcrops of this formation are generally poor. It consists mainly of thinly laminated, dark

bluish-grey shale which weathers to an olive or red brown colour. In the cold Bokkeveld

and Ceres-Karoo thin (3-5 cm), silty to cherty layers occur intermittently. On exposure

they disintegrate into small yellow-brown angular chips.

Between Worcester and Robertson the formation is only intermittently exposed, with good,

fairly accessible outcrops occurring along the flanks of Aasvoelberg, north of Eiland.

According to De Villiers et al. (1964) the formation attains a thickness of approximately

200 m south of Worcester, but more recently 120 m was measured just east of the

development site on farm Scherpen Heuvel no.481. As elsewhere, a transitional contact

exists between the Prince Albert Formation and the overlying Whitehill Formation.

Whitehill Formation

The Whitehill formation consists of thinly laminated, pyritic, carbon-bearing black shale

and measures about 30 m in thickness. The formation weathers characteristically to a

conspicuous greyish-white, gypsiferous to lime rich zone. Thin, grey to yellow-coloured

cherty lenses are often also apparent.

Collingham Formation

The Collingham formation, which concordantly overlies the Whitehill shales, is poorly

exposed in the Ceres-Karoo but in the Worcester-Robertson outlier, it is exposed in the

above-mentioned quarry sites as well as in road cutting. Here it is about 45 m thick,

compared to the generally accepted thickness of 30 m to the north. The Collingham

formation here consists of a rhythmically interbedded sequence of thin tabular beds of

dark grey shale, yellowish-coloured soft claystone, siltstone and cherty mudstone.

Bedding thickness varies from 20 to 40 mm, with some of the siltstone horizons somewhat



thicker in places. Paragraph 2llel lamination is dominant. No trace fossils have been

found as yet.

A yellow weathering, illite-rich claystone (K-bentonite) typifies the Collingham Formation

and has a wide distribution throughout the Karoo Basin. These claystones and chertified

beds contain devitrified and replace glass shards, and have been interpreted as air fall

tuffs (Lock and Wilson 1975). Analyses have shown the potassium content of these ash

beds to vary from 4 to 10 % K2O (Verwoerd et al. 1990).

Tierberg Formation

The conformably overlying Tierberg Formation consists of grey-black (fresh) to olive-

green (weathered), well laminated shale, mudstone and siltstone. The formation is

extensively weathered and poorly exposed in the Ceres-Karoo. Occasional thin, silty

horizons are sometimes ripple marked and biogenic trails occur on Witte Wal 171, along

the Groot River.

Outcrops are somewhat in the Worcester-Robertson outlier, where the most complete

section across the Tierberg Formation in this area occurs between Aasvoelberg and

Mowershoogte, west of the Worcester-Robertson divisional boundary. From the Tierberg-

Collingham contact up to Mowers Siding the sequence is mainly composed of mudstone,

shale and siltstone. North of the railway line however, there is a gradually increasing

number of arenaceous layers. This latter succession is tentatively connected with the

Waterford Formation, the uppermost unit of the Ecca Group.

Waterford Formation

In the low range of hills, Mowershoogte, between Worcester and Robertson, numerous

fine-to medium grained sandstone beds are intercalated with politic units. These

arenaceous beds are generally massive or sometimes Paragraph 2llel laminated, and

wave ripple marks, clay-pellet conglomerate and brownish lime-rich lenses occur.

3.2.7 Climate

Globally, the climate of the study area is classified as the BWk category according to the

Köppen and Geiger classification system (B = Arid, W = Desert, k = Hot, MAT < 18OC).

The development site falls within the Mediterranean climate zone of the south-western

region of South Africa but is also influenced by the temperate interior climate zones of the

Klein Karoo. Winter rainfall dominates the area the mean annual precipitation (MAP) is

recorded as 265 mm (Mucina & Rutherford, 2006), while monthly rainfall can vary from 8

mm in summer up to 35 mm in winter (See Figure 3-9).

High summer interior temperatures are moderated by proximity to the Cape Fold mountain

system which induces lower temperatures due to adiabatic cooling (0.60 C per 100m) as

well as the occasional influx of cooler maritime air from south of the mountain divide.

Mean annual temperature (MAT) for the region is recorded as 16.80 C (Mucina &

Rutherford, 2006). Mean daily maximums and minimums are 29.80 C and 4.70 C in

summer and winter respectively (see Figure 3-10). It is noted that the MAP is only 12 %



of the Mean Annual Potential Evaporation (MAPE) which is 2192 mm, leading to a high

Soil Moisture Stress Index (MASMS) of 76% which renders surface clays dry.

Figure 3-9: Composite climate diagram of the Robertson region. Blue bars show the median

monthly precipitation. The upper and lower red lines show the mean daily

maximum and minimum temperatures respectively (After Mucina and

Rutherford, 2006).



Figure 3-10: Average, maximum and minimum daily temperatures throughout the day, with

the horizontal axis representing months of the year, starting with January (1)

and ending with December (12).

The influence of the South Atlantic and South Indian High Pressure Systems, promotes a

predominant regional wind direction from the east/south-east and from the west/south-

west. Wind data was obtained from the Agricultural Resource Council (ARC) for the

period 2000 to 2015, for the Worcester wind station (See Figure 3-11). The ARC data for

Worcester is robust, ranging over a 15 year average, and shows equal axis wind directions

of approximately 15% duration from the east and the west. Wind speeds are notably

stronger from the west, in the 4 to 7 m/s category while the easterly winds are generally

lighter in the 1 to 3 m/s category. Onsite inspection of dust fallout from the nearby Cape

Lime Plant show that the local site specific wind is more south east and north west, which

is a response to the local topography and the valley orientation.



Figure 3-11: Wind rose of the Worcester region

3.2.8 Biodiversity, Flora & Fauna

The study area falls within the Southern Folded Mountains Ecoregion (after Kleynhans et

al. 2005), near the transition to the Western Folded Mountains Ecoregion (to west) and

the Southern Coastal Belt Ecoregion (to south). More specifically, the study area forms

part of the lowlands of the Langeberg Mountains, situated relatively close to the

Langeberg-West Mountain Catchment conservation area (Ollis et al, 2016) and serves to

link the mountain catchment area in the north to the Breede River Valley in the south via

several ESA corridors. The physiographical characteristics of the Southern Folded

Mountains Ecoregion, in terms of terrain morphology, are typically characterised by a

diverse topography of closed hills and mountains with a moderate to high relief (slopes

with a gradient of >5% are predominant within the Ecoregion). The study area for the

proposed brick factory is thus somewhat atypical of the Ecoregion within which it falls,

being located in a relatively non-mountainous part of the landscape. The rainfall

seasonality and the vegetation types that occur within the Southern Folded Mountains

Ecoregion are highly variable (Ollis et al, 2016).

The proposed Brick Factory falls within an ecosystem that is listed as Endangered (EN),

as defined by the South African National Botanical Institute (SANBI). The vegetation in



the proposed area consists of Breede Alluvium Renosterveld (see Figure I 7) which

consists of a species poor, short, open shrub land with dwarf succulent shrubs and

grasses in the gaps, dominated by Renosterbos, Athanasia trifurcata, Pentzia incana,

Ruschia caroli and Aspalathus spinosa, amongst others. The grasses are represented by

Ehrharta longiflora, E. villosa and Themeda triandra whilst Crassula expansa is the most

commonly encountered succulent shrublet (Jacobs and Jangle, 2008).

The proposed Brick Factory further falls within an area defined as a Critical Biodiversity

Area (CBA) (see Figure I 8), which is described as an area required to meet biodiversity

targets for ecosystems, species and ecological processes, as identified in a systematic

Biodiversity Plan as per the National Environmental Management: Biodiversity Act (Act

No. 10 of 2004).

In addition to the CBA several Terrestrial and Aquatic Ecological Support Areas are in

proximity and in one instance bisects the development area. (Drainage Line 2). Specialist

fresh water aquatic and botanical studies have been embark on in the Gannabosch Clay

Mine EIA report which cover the topic thoroughly and may be referenced in the EIA report

(Umvoto Africa, 2017).

The Western Cape has a relatively low concentration of large terrestrial mammals, which

have largely been eradicated. However, the smaller fauna such as rodents, reptiles,

insectivores and birds will be present in the target area. In summary, the area is home to

a variety of insects, rodents, reptiles, birds and small mammals that naturally reside in this

type of habitat, while the larger natural fauna is not present on the property. Livestock

from neighbouring properties could transgress onto the factory zone if fencing is

inadequate. Small feral mammals, insects and reptiles would be disturbed during brick

making process and would relocate.

3.2.9 Surface water

The farm Gannabosch Vlakte 51 falls within the H40H quaternary catchment. The land

use on site is natural veld, while there are vineyards and other agricultural utilised areas

in the wider area. Any surface run-off would naturally drain towards the Vink River in the

south, owing to the slight slope of the land surface. The property earmarked for

development is drained by three north-south orientated ephemeral drainage lines, which

are denoted drainage line 1, 2 and 3 from west to east. Drainage line 2 crosses through

the proposed mining area (see Figure 3-7) before curving to the south-east and feeding

into the Vink River.

Surface runoff over the proposed brick factory site will be induced by hard surfaces, the

low permeability of the clays soils in the area and the upper drainage area that is situated

at a higher elevation than the development site. The surface water generated on site as

runoff will need to be deflected by berms, separated into clean and dirty water, stored in

sumps situated in the southern, lowest portion of the mine trench areas and managed so

as not to be allowed not be allowed to enter the ephemeral drainage lines or the Vink

River as direct flow. This attenuation of storm water flow must be of sufficient capacity to

allow for the containment of a 1:50 year flood event.



3.2.10 Groundwater

No boreholes have been drilled on Gannabosch Vlakte 51 or within similar Ecca Group

shale geology within 3 km of the proposed brick factory site, therefore local groundwater

levels are currently unavailable. Drilling for the resource evaluation, carried out on the

property for the Clay Mine Rights Application, did not encounter groundwater. Due to the

low transmissivity intergranular and fractured, or weathered regolith/saprolite nature of the

Karoo Aquifers underlying the proposed brick making facility site, groundwater levels are

likely to be below 5-30 metres below ground level, and generally follow topography i.e.

flow from a general NE to SW direction at depth. The Vink River may act as a zone of

recharge to the regolith Karoo Aquifers during periods of high runoff, and groundwater

flow direction may be reversed periodically during these recharge periods. The only

recorded water levels within similar geology/hydrogeology are from NGA boreholes

3319DC00048 (~29 mbgl) and 3319DC00049 (~6 mbgl), measured in 1988 and situated

in Tierberg Formation shales ~3.5 km WSW of the proposed brick factory site.



4 PROJECT DESCRIPTION

4.1 PROJECT DESIGN:

4.1.1 Layout, road network and infrastructure

Appendix 2 Paragraph 2 (d) of GN 982 requests layout plans at various level of detail and

scale describing the associated locality, structures and infrastructure of the proposed

development. These can be found in Appendix I – Maps of this report. Figure I 1 shows

the regional setting of the farm on which the development is proposed. Figure I 2 is

locality map showing the more immediate surroundings as well as the footprint of the mine

concession area within the farm Gannabosch Vlakte 51. Figure I 3, Figure I 4 and Figure

I 5 illustrate support services and detailed conceptual infrastructure respectively. The

coordinates within which the activity is proposed are shown in Table 1-4.

4.1.2 The Brick Making Process

The proposed brick making facility, Robertson Bakstene (Pty) Ltd will source clay from the

clay mine on Gannabosch Vlakte 51. The material will be transported from the mine

stockpile to the offload point at the brick making facility. Mined clay ore is a material, all

of which is used in brick making, and not a mineral that needs to be extracted or won (as

in the term “winnings”) from a host rock by primary processing of crushing, washing,

screening. At the brick factory stockpile, the material will then be reclaimed using a front-

end loader and transferred onto the production line, where the beneficiation process is

begun. See flowchart in Figure 4-1.

Figure 4-1: Simplified flowchart of the brick making process.



To supply the needs of the brick factory at start up, operating at a production rate of

2 million units per month*, an extraction rate of 60 000 to 70 000 tons, or approximately

45 000 m3, of ore per annum is required. This is demonstrated and explained as follows:

1 m3 dry clay excavated = 1073 kg;

1 m3 wet lump clay excavated = 1602 kg;

Assume a mix of dry and wet and use 1 500 kg (std industry norm);

Excavate 27.6 m3 per hour = 41.4 tons per hour

= 331.2 tons per day, assuming 8-hour working day

= 66 240 tons per year, assuming 200 working days per year

= 60 500 – 70 000 tons per annum

= 40 000 – 47 000 m3 per annum

Assume a mined volume of 45 000 m3 per annum for start-up, to be

increased gradually as demand and capacity of BMF increases and within

limits defined by the Air Emission License.

*1 m3 = 500 bricks

45 000 m3 = 22 500 000 brick per annum

Hence, approximately 40 tons of raw material per hour, is tipped into a feed hopper to be

crushed, ground and screened, via two crushers, a fine crusher and a roller crusher. The

coarser mixture, from the roller crusher is mixed with the finer crushed material to the

desired blend. Body fuel in the form of coal dust called duff coal is then added to the dry

mix in a 15 % by mass ratio, this provides the fuel for the firing process. Approximately

3500 to 4000 litres of water is mixed into the raw material. This implies the water demand

of the processing plant is a maximum 4000 litres per hour.

The raw material and water are mixed together in a process called “pugmilling”. The

resultant mix is sent through an extruder where the bricks are extruded in a sausage. The

extruded sausage is fed into conveyer for cutting to final shape. Green bricks are

transported to a drying area where they are air dried for approximately two to three weeks,

dependent on weather conditions. The bricks are then transported to the clamp kilns

where they are fired into the finished hardened clay brick product. The clamp furnace is

charged with small nut coal for ignition (2.6% of the clay mass). After firing, the cooling

process takes a week after which the product is ready for palleting and transferred to the

final product stock yard for despatch.



The estimated 40 tons of clay per hour will produce roughly 10 000 to 12 000 bricks an

hour. Assuming an eight-hour work day, and a five-day work week, this will equate to 1.6

to 2.0 million bricks a month. The drying yard will be 2-3 hectares and has adequate

space for the amount of bricks coming out from the factory. The drying process as

specified above takes 2-3 weeks. Each kiln has the capacity to fire 500 000 bricks. The

kilns are powered by coal that is previously added to the bricks as duff, as well as a thin

layer of ignition nugget coal between the first and second layer of bricks to get the oven

started. Not all four kilns will be fired together, one to two will burn simultaneously while

the third is cooling and the fourth is unpacked for sales. The firing process takes one to

two weeks and each kiln will be fired up as bricks become available from the drying yard.

4.1.3 Site & Service and Equipment Description

Gannabosch Clay Mine plans to abstract groundwater from boreholes on Farm RE/52 (2.3

km south of Gannabosch Vlakte 51, main supply borehole) and Farm 2/11 (adjacent north

of Gannabosch Vlakte 51, backup supply borehole), with water transfer being permitted

without the need for a water use licence (WUL) under “Specific Conditions for taking of

Groundwater 4.1.2” (newly gazetted “Revision of General Authorisation for the Taking and

Storing of Water Notice 538 of 2016 Government Gazette No. 40243”).

Farm RE/52 (396 ha in size) straddles the H40F and H40H quaternary catchments,

whereas Farm 2/11 (62 ha in size) occurs within the H40H quaternary catchment – both

H40F and H40H have a National Water Act Section 21(a) groundwater abstraction

General Authorisation (GA) of 150 m3/ha/a. This equates to a:

farm GA for Farm RE/52 of 59 400 m3/a (396 ha x 150 m3/ha/a), although this

would be capped at 40 000 m3/a under the newly gazetted GAs;

farm GA for Farm 2/11 of 9 300 m3/a (62 ha x 150 m3/ha/a).

Gannabosch Clay Mine requires ~4 m3/hour (~4 000 litres/hour) during operation – based

on a 9 hour operational day, 20 day operational month and 12 months per annum, this

equates to ~8 640 m3/a. This volume is within the GAs of both Farm RE/52 and Farm

2/11, and therefore only a Section 21(a) groundwater registration will be required for

groundwater abstraction from both farms (a separate registration for each farm portion),

and not a Section 21(a) WUL application.

~4 000 litres/hour (~1.1 litres/second) equates to a ~0.5-0.6 l/s borehole on each farm

property, and the minor abstraction volume of ~8 640 m3/a will not deplete or damage the

regolith Karoo Supergroup aquifer in the vicinity of the proposed mine.

Electrical supply source for the factory is provided by the 480 kva transformer feedpoint

(marked power supply kiosk) as illustrated in Figure I 3. This in turn is supplied from the

Hex/Noree 166kV Overhead Line. An underground cable will provide the power via the

Langvlei road servitude to the entry point of the factory. Water will be provided from a

borehole located on the farm Lange Vallei Remainder 52 to the south of the R60. A

conceptual routing of the pipeline is shown in Figure I 3, which avoids crossing of drainage

lines, road and railways. A backup supply borehole is to be positioned at a point to the

northwest of the mine, on the neighbouring farm Alwynbos Vlakte No 299. Supplementary

water supply will be provided by stormwater reticulation; further detail of this is provided



in the Stormwater Management Plan of the Gannabosch Mine (Umvoto Africa, 2017).

Rainwater harvesting from factory roof surface with tank storage will further supplement

supply.

4.1.4 The conceptual brick factory layout

The total land unit required for the production facility is~ 51 000 m2 (5.1 ha). (See Figure

I 4). A conceptual layout plan showing the positioning of all processing equipment,

approximate sizes of individual areas, as well as stages in production is shown in Figure

I 5. A storage area for the receiving and stockpiling of clay and coal will be surrounded

by berms for storm-water erosion control and shielded with netting on the windward sides

to manage dust blowout. This area is envisaged at approximately 1 600 ha in extent. The

raw clay will be then be loaded onto the conveyer system and transported into the

processing plant. The processing plant will be housed in a covered shed area

approximately 5 300 m2 in extent. Extruded green brick will be laid out in a drying yard

area ~ 12 600 m2. Clamp kiln ovens will be built from brick product; these are to be

positioned on the western extent of the factory area. It is envisaged that at any one stage

there will be a maximum of four kilns in operation each ~15 by 20 meters in size and the

total area envisaged for ovens is ~ 5 300 m2. Cooling and curing of the fired brick takes

place in the cooling area, ~ 12 000 m2, and the final product is loaded onto pallets and

moved to the despatch area ~ 14 000 m2 in extent for collection. The various areas will

be connected via a network of internal roads. The parking and despatch area is sufficiently

large to allow large double trailer links to turn on site and will be hard surfaced to limit

dust. Access to/from the development site will be off DR 1384 that intersects TR 31/1 to

the south. DR 1384 also provides access to Langvlei train station and Cape Lime factory.

Figure I 4 shows that there is sufficient shoulder sight distance both to the left and right

along DR 1384 at the position of the proposed access to the development to deem the

entry/exit point safe.

4.1.5 Stormwater Management Plan

The storm water management plan (SWMP) has been dealt with to a large extent within

the Gannabosch Clay Mine EIA and EMP Report (Annexure D: Storm Water

Management Plan (SWMP)). However, for the sake of thoroughness it has been added to

this report as well.

The aim of the storm water management plan (SWMP) is to fulfil the requirements

presented in Government Notice 704 (Government Gazette 20118 of June 1999) which

deals with the separation of clean and dirty water. It also complies with the principles

presented in the DWAF Best Practice Guideline G1 Storm Water Management (2006).

The hardened surfaces around the mine and factory will result in an increase in storm

water runoff and an elevated concentration of suspended clay particles. The SWMP

ensures that all surface flows from the mine area are captured and deflected by berms

and channels and directed into sump ponds situated in the southern, lowest portion of the

mine trench areas. This is considered dirty water and will not be allowed to enter the

ephemeral drainage lines or the Vink River as direct flow.



The attenuation of storm water flow in these sumps will be of sufficient capacity to allow

for the containment of a 1:50 year flood event. It is intended that the captured water will

be recycled via bowser or sprinklers for dust suppression. In the unlikely event that flows

exceed the sump storage capacity; the overflow will be discharged into drainage line 2

below the mining area. This overflow will be directed through a vegetated swale prior to

reaching the receiving water body to ensure it is turbulent free with reduced velocities.

Surface run-off from the clean areas upstream of the mining and factory area will be

directed around the developement areas either towards drainage line 1 or back into

drainage line 2 by means of gravity. To achieve this, two berms with associated channels

are to be erected along the northern boundary of the proposed brick manufacturing facility.

The larger of the two berms will intercept drainage line 2 further north and redirect the run-

off around the western corner of the mining area and into drainage line 1. To avoid

sedimentation at the entry point a row of swales will be constructed upstream of entering

drainage line 1 to trap any sediment transported in the diversion.

A second berm will be constructed directly at the northern boundary of the mining area to

divert the remaining part of drainage line 2 (Clean area B) towards and along the road.

The diversion will end at the existing culvert, which initially channels the flows under the

street back into drainage line 2. Once mining occurs in the south-eastern area (southern

corner of Dirty area B), the diverted water will be temporarily diverted into the sump of the

mining pit.

A strategically placed sump at the north-eastern edge of the proposed manufacturing

facility following the natural gradient and course of drainage line 2 allows for slowing down

the storm water and causing some of the excess suspended clay particles to be removed

via settling.

This approach allows for the incremental development of the storm water management

system and infrastructure as mining progresses from the western area (Dirty A) to the

eastern are (Dirty B). This would further reduce the impact of diverting drainage line 2, as

a significant volume is diverted back into the lower parts of drainage line 2.

Storm water management infrastructure has been conceptually designed as per the

requirements of GN 704 with the layout presented in Figure 4-2. The full Stormwater

Management Plan, applicable to both the Gannabosch Clay Mine and the Robertson Brick

Factory are provided in Annexure D: Storm Water Management Plan (SWMP)of this

report.



Figure 4-2: Conceptual storm water management plan.



5 STAKEHOLDER ENGAGEMENT

Paragraph 2 (h) (ii) of Appendix 2, GN 982 requires details of the Public Participation

Process (PPP) undertaken in terms of regulation 41 of the Regulations, including copies

of the supporting documents and inputs, to be included in the final scoping report. This

also involves the inclusion of a summary of the issues raised by Interested and Affected

Parties (IAPs), as well as the methodology for including or excluding issues. Thus, a public

participation process (PPP) was undertaken for the final scoping report for the

development of the proposed brick making factory. This process was managed by

Umvoto Africa as follows.

- Publish Adverts, inform Reg IAP/Stakeholders of the Clay Mine Mining Rights

Application process, and erect notice on property done on 2017-01-25.

- Application for Environmental Authorisation submitted to DEA&DP on 2017-02-02

(16/3/3/6/71/B1/14/1326/16)

- Draft Scoping Report distributed to DEA&DP and put online. Beginning of 30 day

PPP 2017-08-02

- Closure of comment period 2017-03-10

- Deadline submission of Final Scoping report to DEA&DP 2017-03-20

The first draft Scoping Report was sent to all Registered IAP’s and Organs of State for

review. After the closure of the PPP, an amended second draft of the Scoping Report

was prepared for review, which has included the comments raised during the PPP and

addressed them.

5.1 OBJECTIVES OF THE STAKEHOLDER ENGAGEMENT PROCESS

The overall aim of stakeholder engagement is to ensure that all IAPs have adequate

opportunity to provide input into the process and raise their comments and concerns. More

specifically, the objectives of stakeholder engagement are to:

Identify IAPs and inform them about the proposed development and S&EIR

process;

Offer IAPs the opportunity to participate effectively in the process and identify

relevant issues and concerns; and

Offer IAPs the opportunity to review documentation and assist in identifying

mitigation and management options to address potential environmental issues.

Note:

It is important to recognize that an IAP is a general term used to describe any person or

organisation (private or governmental) with concerns and interest in the project, while the

stakeholder is a more specific term used to describe persons or organisation who have vested

interest or legislated authority over the land or an aspect of the project. We use the broader

term of the IAP to cover both parties.



5.2 INTERESTED AND AFFECTED PARTIES CONSULTATION PROCESS

Below (See Table 5-1) is the summary of the consultation of the process that has been

followed from the beginning of the EIA process being followed to facilitate the decision on

the EA application by Robertson Bakstene (Pty) Ltd.



Table 5-1: Stakeholder engagement activities undertaken during the Scoping Phase.

Task Objective Reference Dates

Initial discussions with

affected landowners

To notify affected landowner Grobbelaar of the proposed project and obtain initial

comments and permissions to apply for a environmental authorisation to develop on

his property.

N/A November 2016

Inform Key Stakeholders Inform key Interested and Affected Parties identified through the Clay Mine

Environmental Authorisation EIA process. 25/01/2017

Publication of newspaper

advertisements;

Erection of signage on

proposed site.

Initial IAP registration period

To notify additional stakeholders of the proposed project and the commencement of

the S&EIR process, and to request registration as IAPs.

N/A

25/01/2017

Submission of Forms to

DEA&DP

Register the application for EA and confirm authority requirements. Beginning of 44

days for submission of scoping report to competent authority.

EA Application ref at DEA&DP:

16/3/3/6/71/1/B1/14/1326/16 02/02/2017

Release of Draft Scoping

Report for Stakeholder

comment

To provide stakeholders with a description of the proposed project and the affected

environment, as well as a description of potential environmental issues, and the Plan

of Study for the Impact Assessment Phase

UA Draft Scoping Report No.

856/25/01/2017 08/02/2017

1st Public comment period To provide IAPs with the opportunity to review and comment on the planned

development as laid out in the draft scoping document

UA Draft Scoping Report No.

856/25/01/2017 08/02/2017

End of first comment/public

participation period

Closure of first public participation process. Compilation of comments into final

scoping report N/A 10/03/2016

Release of Final Scoping

Report to registered IAPs

To update the Scoping Report in response to comments made and to present the

shortlisted footprint alternatives.

UA Final Scoping Report No.

856/25/02/2017 20/03/2016

Submission of Final Scoping

Report to DEA&DP To provide authorities with information for decision-making

UA Final Scoping Report no:

856/25/02/2017 20/03/2017



The approach adopted for the initiation of the scoping report and associated Public

Participation Process (PPP) was to identify and contact as many potential Interested and

affected parties (IAPs) as possible through a number of activities outlined below:

5.2.1 Identification of Key Stakeholders

EIA Regulations (December 2014), require that all relevant local, provincial and national

authorities, conservation bodies, local forums and representatives and affected

landowners and occupants are notified of the EIA process and the release of the Scoping

Report for comment. As specified in GN R982: 42(a), all persons who submitted written

comments, or requested in writing to be placed on the register, were registered as IAPs

and were notified of opportunities to comment on the project and the S&EIR process. In

addition, the relevant Competent Authority (DEA&DP) and Commenting Authorities

(Organs of State) were automatically registered as IAPs. Furthermore, a notification letter

was sent on 25th January 2017 via post to all existing registered stakeholders and IAP’s

from the Gannabosch Clay Mine application for a Mine Right. This letter served to inform

these IAP’s that they would be automatically included as an IAP in the brick factory

development and need not re-register.

The proposed Brick Making Factory site is located within Ward 6 of the Langeberg Local

Municipality, Robertson Magisterial / Administrative District in the Western Cape Province.

They have been included as Registered Interested and Affected Parties and have been

alerted to the application by email and registered post. Ward Councillors of Ward 6 have

also been individually contacted by email and registered letter. The Local Municipality has

been contacted and an application submitted for land use change as per requirements of

Land Use Planning Ordinance (LUPO).

A list of the stakeholders currently registered on the IAP database is provided in

(Appendix E – Interested and Affected Parties Register). These include:

Organs of State, provincial departments and institutions:

Department of Mineral Resources (DMR)

Department of Environmental Affairs and Development Planning (DEA&DP)

Department of Water and Sanitation (DWS)

Western Cape Government: Waste Management

Breede-Gouritz Catchment Management Agency (BG CMA)

Heritage Western Cape

Department of Rural Development and Land Reform (DRDLR)

Regional Land Claims Commission: Western Cape

Cape Nature

Department of Transport and Public Works

Wildlife and Environmental Society of South Africa

Council for Geoscience South Africa

Department of Agriculture

Department of Public Works

Local authorities:

Cape Winelands District Municipality



Langeberg Local Municipality (Robertson)

Ward councillor: Ward 6

Parastatals:

Eskom

Transnet

PRASA

5.2.2 Notification of the EIA Process

A draft scoping report, containing information about the proposed Brick Making Factory

and the S&EIR process was compiled and distributed to the initial list of registered IAP’s

by post and/or email (see Appendix E – Interested and Affected Parties Register) on the

eighth of February 2017. The identified key stakeholders were additionally sent a letter on

the 25th of January 2017, informing them of their pre-registration as IAPs for the

Environmental Authorisation for the Robertson Bakstene (Pty.) Ltd. development.

Two newspaper advertisements announcing the commencement of the S&EIR process,

and inviting members of the public to register on the IAP database were placed in both

the Cape Times and the “Die Burger” on 25th of January 2017. The notice made aware to

all existing and potentially new IAP’s that a Draft Scoping Report is available for public

review (See Figure 5-1).

5.2.3 Release of Draft Scoping Report

The release of the draft Scoping Report for public review coincided with an e-mail, or letter

sent by post, to all identified IAPs of the Gannabosch Clay Mine Environmental

Authosiation. This indicated the availability of the Scoping Report from the EAP upon

request or on the link attached to the e-mail. Hard copies of the full report were placed at

the following venues for public review:

Umvoto Africa office in Muizenberg.

Offices of the Langeberg Local Municipality in Robertson;

Robertson Public Library;

Hard copies of the complete draft Scoping Report were sent to the following government

departments for comment:

Department of Agriculture

Department of Environmental Affairs and Development Planning

Langeberg Municipality (Municipal Manager, Development Services and Town

Planning, Building Control and Valuations);

Cape Nature Conservation



5.2.4 Issues and Concerns Raised by IAP’s during Scoping

Written submissions were received from registered IAPs during the Draft Scoping phase.

These comments and concerns are incorporated and considered in Section 6 of this

Scoping Report and addressed by including mitigating procedures as contemplated in

Section 6.3. A summary of the comments is provided in Appendix F-1:

Stakeholder engagement activities during the Impact Assessment Phase are aimed at

ensuring that the specialist studies and the assessment of potential impacts by the S&EIR

project team address the issues and concerns raised during the Scoping Phase.

Opportunities to raise further issues for consideration are also provided to stakeholders.

Cape Times newspaper article (25th of

January 2017)

Die Burger newspaper article (25th of

January 2017)

Figure 5-1: Advertisements posted in local and regional newspapers and on the affected

property of the EIA and PPP process.



5.2.5 Finalising the Scoping Report

Two printed hard copies of the final Scoping report are to be submitted to the DEA&DP

on 2017-03-20, as well as two electronic PDF copies. The report will be uploaded onto

the SAMRAD Website and also available to view online on the Umvoto Africa website

www.umvoto.com at the following link http://www.umvoto.com/projects/. A hard copy of

the same will be available to view at the:

Robertson Public Library

(30 Van Reenen Street, Robertson, Western Cape, 6705; Tel 023 626 2972) and

Umvoto Africa office

(8 Beach Road, Muizenberg, Western Cape, 7945; Tel. 021 788 8031)

All IAPs and Stakeholders will be informed via e-mail on the 20th of March 2017 that the

final Scoping Report has been submitted to DEA&DP. They will also be informed that the

report and all related reports are available to view on our website (a link to be attached),

and should any IAP or Stakeholder require a hard copy of the document, they are to

contact UA.

http://www.umvoto.com/



6 ENVIRONMENTAL IMPACT ASSESSMENT

6.1 INTRODUCTION

6.1.1 Identified Environments of Impact

Based on the professional experience of the EIA team (Section 1.1), legal requirements

(Section 2), the nature of the receiving environment (Section 3), the nature of the

proposed activity (Section 4), and issues raised in the stakeholder engagement process

(Section 5), the following environmental areas of potential impact were identified:

Freshwater ecology (wetlands) – the potential loss of and impact on wetland areas,

which include ephemeral drainage lines and the Vink River;

Flora and Fauna – the potential loss of and impact on threatened vegetation types

and species;

Heritage (archaeology) – possible impacts on heritage (archaeological) resources

in the project area;

Soils – potential impact of stripping the topsoil and subsurface overburden;

Socio-economic – the possible socio-economic costs and benefits of the proposed

development to the wider community in the form of job creation, improvement of

local infrastructure owing to LED project;

The economic impact of a loss of agricultural land;

Air quality – the potential impact of brick yard emissions on nearby Cape Lime

Plant, and potential smoke / visual affect to R 60 traffic route;

Visual and sense of place – the potential loss of the current sense of place and

potential visual impacts resulting from the trenching in the undulating agricultural

landscape and

The impact of the visual impression on the tourism potential of the area.

The above potential impacts of the project are directly linked to the sensitivity of the

receiving biophysical and social environment and proximity of receptors, the extent or

footprint and nature of the development, and stakeholder perceptions.

6.1.2 Specialist Studies Undertaken

Specialist studies listed in Table 3-1 were undertaken as part of the Impact Assessment

Phase to inform the EIA Report of all the impacts (negative and positive) as identified by

the EIA Team and stakeholders during the Scoping phase. These specialist impact

studies include:

Heritage Specialist Study (in form of an NID investigation, Annexure A-1: First

Notice of Intent to Develop and Annexure A-2: Amended Notice of Intent);

Botanical Impact Assessment (Annexure B-1: First Botanical Specialist Report

and Annexure B-2: Amended First Botanical Specialist Report);

Freshwater Ecology Impact Assessment (Annexure E1: First Freshwater

Specialist Report and Annexure E2: Amended Freshwater Specialist Report);

Visual Impact Assessment (Annexure F: Visual Impact Specialist Report);

Dust Emission Study (Annexure G: Atmospheric Impact Assessment) as part of

the Air Emission License Application;



Traffic Impact Assessment (Annexure H: Traffic Impact Statement);

Alternative Resource Study (Annexure I: Alternative Resource Survey Report);

Economic Impact Study (Annexure J: Economic Impact Study); and

Storm Water Management Plan (Annexure D: Storm Water Management Plan

(SWMP).)

Their findings have been incorporated into this EIA Report. The Dust Emission Study and

Traffic Impact Assessment will be included in the Environmental Authorisation for the Brick

Factory, however certain relevant findings of these two reports, will be incorporated into

the mine EIA as supportive information to aid decision making. The findings of each

specialist study were evaluated to provide an overall and integrated assessment of the

potential impacts of the project. Specialists have made recommendations for the

management of impacts, and this EIA has evaluated the recommendations at the end of

the section addressing each discipline.

6.2 IMPACT RATING METHOD

The assessment of impacts was based on specialists’ expertise, the Umvoto Africa EIA

team’s professional judgement, field observations and desk-top analysis. The

significance of potential impacts that may result from the proposed project was determined

in order to assist decision-makers, specifically the DMR and other relevant authorities, but

to some extent also the proponent. The EIA process utilises a consequence – probability

matrix to quantify the impact the respective activities might have on the receiving

environment. This is to allow for a practical means to assess the various impacts and allow

the identification and mitigation of negative environmental activities.

A number of variables are taken into consideration, namely, the extent, duration, severity

and probability of a potential impact. These impact attributes are given values depending

on the scale of each attribute and computed to allow for an impact significance as follows:

Significance = Consequence x Probability

where

Consequence = Extent + Severity + Duration

and

Probability = Likelihood of an impact occurring

The standard method for determining the significance of an impact is to combine the

consequence of the impact occurring with the probability that the impact will occur. The

criteria used to determine the consequence of the impacts assessed for the proposed

project are listed in Table 6-1 below, along with the ratings and rating definitions

applicable to each consequence criterion.



Table 6-1: Determination of the consequence of an impact

Rating Definition of Rating Score

Extent– the area over which the impact will be experienced

A.

Local Confined to project area 1

Regional

Defined by regional context of study area, i.e. the

Cape Winelands DM and/or quaternary catchment

(H40H)

2

National South African context 3

Intensity or Severity– the magnitude of the impact in relation to the sensitivity of the receiving

environment, taking into account the degree to which the impact may cause irreplaceable loss

of resources

B.

Low Site-specific and wider environmental and/or social

functions and processes are negligibly altered 1

Medium

Site-specific and wider environmental and/or social

functions and processes continue albeit in a modified

way

2

High Site-specific and wider environmental and/or social

functions or processes are severely altered 3

Duration– the timeframe over which the impact will be experienced and its reversibility

C.

Short Term Up to 2 years and reversible 1

Medium Term 2 to 15 years and reversible 2

Long Term More than 15 years and irreversible 3

The combined score of these three criteria, A, B and C corresponds to a consequence

rating, as set out in Table 6-2.

Table 6-2: Methodology to determine the overall Consequence Rating

A + B + C 3 – 4 5 6 7 8 - 9

Consequence

Rating Very low Low Medium High Very High

The probability score is then assigned according to percentage ratings as defined in Table

Table 6-3 below.

Table 6-3: Probability Classification

Probability or the likelihood of the impact occurring

Improbable < 40% chance of occurring

Possible 40 to 70 % chance of occurring

Probable > 70% chance of occurring

Definite > 90% chance of occurring



The overall significance of an impact is determined by considering the consequence

rating (Table 6-2) and the probability classification (Table 6-3) using the rating system

prescribed in Table 6-4 below.

Table 6-4: Impact Significance Rating

Probability

Improbable Possible Probable Definite

Conseq

uence

Very Low Insignificant Insignificant Very Low Very Low

Low Very Low Very Low Low Low

Medium Low Low Medium Medium

High Medium Medium High High

Very High High High Very High Very High

The impact significance rating should be considered by authorities in their decision-

making process based on the implications of ratings ascribed below:

INSIGNIFICANT: the potential impact is negligible and will not have an influence

on the decision regarding the proposed activity/development.

VERY LOW: the potential impact is very small and should not have any meaningful

influence on the decision regarding the proposed activity/development.

LOW: the potential impact may not have any meaningful influence on the decision

regarding the proposed activity/development.

MEDIUM: the potential impact should influence the decision regarding the

proposed activity/development.

HIGH: the potential impact will affect the decision regarding the proposed

activity/development.

VERY HIGH: The proposed activity should only be approved under special

circumstances.

Practicable mitigation measures are suggested and impacts are rated both without and

with the recommended mitigation measures. The impact assessment for the EIA report

will be conducted as above. Any impacts identified through the PPP process and through

specialists studies will be included within an assessment table which shall look at the

significance of potential impacts, their extent, duration, as well as mitigating procedures

to reduce possible negative impacts. This table will be utilised as the basis for the

Environmental Management Plan (EMP).



6.3 LISTED POTENTIAL ENVIRONMENTAL IMPACTS

6.3.1 Freshwater Ecology/Hydrology

The assessment of potential impacts on freshwater ecology/hydrology is provided below:

Table 6-5: Freshwater ecological / hydrological impacts

Criteria Details/Discussion

Impact 1

Description of

impact

Potential contamination of downstream water from hydrocarbons from diesel,

oil and lubricants and hazardous chemicals used in machinery at the brick

making plant.

Mitigation

required

Plant design to ensure adequate sumps are in place for collection of

fugitive hydrocarbons and chemicals resultant from leaks, spills and

overfills of plant equipment;

Regular de-tanking of sumps and disposal of hydrocarbons at waste

management center with provision to accept the waste;

Re-fueling, fuel storage areas, and areas used for the servicing or parking

of vehicles and machinery, should only take place in the designated

workshop areas and should be located on impervious bases with

adequate protective bund walls to ensure that all the fuel kept in the area

will be captured in the event of spillage;

Fuel safe storage depots to be provided above ground for storage of all

hydrocarbons. This to include bunded side walls and impervious floor.

Bunded area to be 110% capacity of fuel tank;

Movement of fuels around plant to be conducted in secure containers with

avoidance of spillage;

All plant equipment and vehicles are to be serviced and maintained on a

scheduled basis to minimise leaking motors;

Any vehicles that stand in one place for an excessive length of time must

have drip trays placed beneath oil sumps;

Codes of practice and standard operating procedures must be developed

to deal with hydrocarbon and chemical spillage in the plant area – the

source of spillage must be immediately contained with the correct control

measures, the contaminated soil must be uplifted, removed and disposed

at an approved landfill facility for hydrocarbons;

An incidence report of any hydrocarbon or chemical spill must be filed on

the plant’s incident Report Forms for inspection by the Environmental

Control Officer (ECO) for the proposed brick making facility. All incidents

of spillage must be reported to DWS and DEA&DP as an environmental

incident and follow the correct procedure as laid out by NEM:WA and

DEA&DP: Waste Management;

A designated area containing spill kits must be made available on the

plant and

Nearby river systems should be inspected on a regular basis by an

Environmental Control Officer (ECO) for signs of disturbance,

sedimentation and pollution. If signs of disturbance, sedimentation or



pollution are noted, immediate action should be taken to remedy the

situation and, if necessary, a freshwater ecologist should be consulted for

advice on the most suitable remediation measures.

Parameters Spatial Duration Severity Probability Significance

Pre-Mitigation 1 3 3 40-70 Medium

Post-Mitigation 1 1 1 40-70 Insignificant

Impact 2

Description of

impact

Potential downstream water contamination from erosion impacts on receiving

storm water quality from the erosion of destabilised soils on stockpiles and

roads.

Mitigation

required

A storm water management plan (SWMP) has been implemented to

separate clean and dirty storm water;

The SWMP is designed to ensure that all dirty water surface flows from

the factory footprint area are captured and deflected by berms and

channels and directed into sump ponds situated in the southern, lowest

portion of the mine trench areas for later consumption in plant. Sumps

must be designed to cater for 1:50 year 24 hour precipitation event.

Sumps do not need to be lined due to fact that they are clay based and

therefore relatively impervious to seepage;

Clean water from catchment areas up-gradient of the factory footprint

area must be diverted around the factory footprint area using berms and

channels keeping clean water out of the factory area and redirected back

into drainage lines below the factory footprint. Vegetated swales must be

used to guide channeled water back into drainage lines to reduce

turbulence, velocities and drop silt load;

The side slopes for all berms and channels will be kept constant at 1

vertical: 3 horizontal and sized to meet the requirements of the 1:50 year

flood;

The base of the trench and lower part of the berm should be covered with

gabions or stone packing, and planted with grass and other small

vegetation to slow down water movement and reduce turbulence and

erosion. The trench could possibly be vegetated to resemble a natural

drainage line and thereby create a substitute habitat for aquatic and semi-

aquatic fauna associated with these

Ensure that the internal factory roads have erosion humps to deflect

rainwater and reduce erosion of road surface;

Install water sprays along internal factory roads to maintain dampness

and suppress dust;

Ensure that all stockpiles, i.e. clay ore, coal storage are enclosed within

three sided bund walls;

Design bund walls to prevent wind erosion with orientation such that open

end is at right angles to prevailing NW-SE winds;

Toe seepage from the stockpiles can be expected to arise following heavy

rainfall events. Stockpile floor is to be inclined off-horizontal by at last five

degree with slope toward backwall, such that toe seepage will be retained



inside of the bund walls and not flow out onto the factory footprint area,

nor contaminate the main sumps in the mine pit. Each stockpile area to

be underlain with a waste sump to capture contaminated water. The

sump should be accessible for insertion of a bilge pump should excessive

rain create an overflow situation and



sedimentation and pollution.


Pre-Mitigation 1 2 2 > 90 Low

Post-Mitigation 1 2 1 40 to 70 Insignificant

Impact 3

Description of

impact

Direct permanent loss of freshwater ecosystems, and the habitat and biota

(aquatic and semi aquatic fauna and flora) associated with these systems by

developing across natural drainage lines

Mitigation

required

Drainage line 1 and 3 will not be affected and these areas are to be

cordoned off as ‘No-Go” areas with respect to the factory activities;

Capture (using berms) and divert flow (using channels) from clean water

area upstream of the factory either towards Drainage line 1 or back into

Drainage Line 2;

The currently available storm water infrastructure (old furrow) on

Gannabosch Vlakte is to be rehabilitated and utilised;

Culvert/Stormwater system, in accordance with the SWMP is to be

implemented under the supervision of a specialist;

Avoid development in drainage zones 1 and 2 by staying outside of

demarcated 30 meter buffer zones and






Post-Mitigation

1 1 2 1 > 90 Very Low

Impact 4

Description of

impact

Construction related sedimentation of the river systems during land clearing

and factory development.

Mitigation

required

No stockpiles of construction material, should be placed outside of

prescribed factory footprint;

No construction is to move into recommended “No-Go” areas, which must

be cordoned off during the construction phase;



Dust and debris from construction needs to be contained by shade cloth,

swales etc. to prevent it reaching the fresh water systems and / or dust

loading surrounding vegetation;

Swales and berms should be used to slow down, temporarily retain and

filter the runoff from the brick factory and






Post-Mitigation 1 3 1 40 - 70 Very Low



6.3.2 Biota / Flora and Fauna

The assessment of potential impacts on flora and fauna is provided below:

Table 6-6: Flora and Fauna impacts


Impact 1

Description of

impact Loss of faunal habitat

Mitigation

required

Construction and placement of factory footprint has been considered in

order to ensure it takes place in an area of lessor concern and that

drainage line 1 and 3 will be avoided, therefore ensuring no impact to

aquatic, fauna and flora species in such areas;

Buffer zones to be established along drainage lines 1 and 3 to enforce a

“No-Go” zone;

Agricultural livestock from neighbouring properties will be actively

managed, so as to not be directly affected by the brick factory;

Brick factory area to be fenced to ensure livestock cannot enter the

operational plant area;

Staff of brick factory must be trained to understand the importance of not

interfering with agricultural livestock and not to trap, capture or harm

resident wild fauna and

There are no large wild fauna remnants in the area. Small wild fauna,

insects and reptiles that would be disturbed during brick making process

are likely to relocate and will also naturally re-enter the area post

rehabilitation.


Pre-Mitigation 1 3 2 > 90 Medium

Post-Mitigation 1 2 2 40 to 70 Very Low

Impact 2

Description of

impact

Loss of indigenous vegetation classified as Least Threatened within

Vulnerable ecosystem

Mitigation

required

According to the vegetation / ecosystem maps the vegetation unit is

Breede Alluvium Renosterveld, which is considered Vulnerable. The

botanical specialist has ground truthed the site and confirms that the

actual on-site vegetation unit is Robertson Karoo which is classified as

Least Threatened vegetation according to the NEMBA. Neither

classification will trigger Activity 12 of Listing 3 as defined in terms of the

NEMA EIA Regulations 2014, which is only triggered in the case of

Endangered or Critically Endangered systems. Nonetheless the

following mitigations measures should be enforced as best practice:

The brick making factory should be clearly demarcated with boundary

fencing in order to prevent disturbances to adjacent natural areas;



Zone off “No-go” areas within the brick factory footprint where

unnecessary vegetation damage can be avoided or reduced;

In situations and areas where vegetation removal is required for the

construction of hard surfaces and buildings; the root stock and topsoil

should be removed and stockpiled for later use as a rehabilitation

medium. Such usage should not exceed three months duration to avoid

desiccation and seed decay. Stockpiles of stored topsoil must not be

higher than 2 meters to avoid compaction;

In situations and areas where vegetation is required to be flattened but

not entirely removed, i.e. roads, parking and areas where hard surfaces

will not be required, the standard operating procedure shall be to brush

cut vegetation to surface level, leaving and retaining rootstock in situ.

This will hold and bind soil and retain moisture and aid toward natural

long term rehabilitation;

Rehabilitation methodology should be implemented to re-generate pre

development vegetation through appropriate seed planting (species

specific) and supported by ongoing alien removal;

Staff of the brick making facility must be trained to understand the

importance of not removing natural bush and vegetation for collection of

firewood

Maintain buffer of 30 meters as per specialist report along prominent

drainage line 1 and 3.



Post-Mitigation 1 3 2 < 40 Low

Impact 3

Description of

impact

Loss of general biodiversity and Impact on ecological processes by

developing in a CBA and across ESA’s.

Mitigation

required

Alternative considerations of the factory position have been considered

with the express purpose to realign the footprint area away from an east-

west orientation to north-south axis to permit the opening of natural

corridors within the CBA;

Realignment of the factory footprint will also reduce fragmentation of the

vegetation, minimise edge effect;

Realignment of the factory footprint will ensure the best possible

avoidance of drainage lines, in particular drainage lines 1 and 3, and

The alternative location of the factory as recommended by the Fresh

Water Specialist to the northern end of the mine, as opposed to the

original position to the south of the mine has moved the footprint outside

of the Vink River ESA zone.


Pre-Mitigation 1 3 3 > 90 High

Post-Mitigation 1 2 2 40-70 Very Low



Impact 4

Description of

impact Loss of floral Species of Special Concern (SSC) and indigenous plant species

Mitigation

required

The rare Gazania lanata was rediscovered by Dr Robert McKenzie who

stated in his findings that: ”The site is on the edge of the northern face of

the mine pit, so will be obliterated if the mine pit face is extended to the

north and is otherwise at risk from future erosion of the pit face”;

The IAP is referring to the Cape Lime quarry. The brick factory position

is determined and will not extend northwards to impinge on the zone of

occurrence of the Gazania lanata;

One species of conservation concern were recorded by the botanical

specialist in the survey area, outside the proposed development site,

namely Euphorbia nesemanii which is considered Near Threatened (NT)

(Raimondo et. al. 2009). In the follow up site inspection conducted in

September 2016, no individuals of Euphorbia nesemanii were evident

within the proposed mining areas / brickyard location;

The brick factory position is determined and will not extend northwards to

impinge on the zone of occurrence of the Euphorbia nesemanii and

The orientation of the brick factory development has been realigned as

part of the Clay Mine positioning to ensure least impact on the CBA. The

factory’s footprint is minimised across drainage lines and allows for an

ecological corridor through the CBA which permits a biodiversity route

between the Langeberg Mountain highland zone and the Breede River

lowland zone, as identified by Botanical Specialist.



Post-Mitigation 1 2 2 < 40 Very Low

Impact 5

Description of

impact Influx of alien invasive species

Mitigation

required

Cleared areas should be monitored for colonisation by alien species:

Acacia saligna (Port Jackson on the dry ground areas and particularly in

areas of disturbance. Eucalyptus saligna (Bluegum) particularly close to

the existing plantations along the Vink River and Proposis glandulosa

(Mesquite) along the drainage lines;


to deal alien control. A proactive approach should be undertaken to

control alien species as soon as they are established, all alien seedlings

and saplings should be removed from rehabilitated areas on an ongoing

basis, biannually;

Monitoring and eradication of alien species is part of the brick factory

facility’s responsibility and failure to do so in the early stages will result in

greater investments of resources to remove them at a later stage and



Education of workers must include the control of aliens.


Pre-Mitigation 2 3 3 > 70 Very High


Impact 6

Description of

impact Loss of seed bank via the disturbance of topsoil

Mitigation

required

In situations and areas where vegetation removal is required for the

construction of hard surfaces and buildings; the root stock and topsoil

should be removed and stockpiled for later use as a rehabilitation

medium. Such usage should not exceed three months duration to avoid

desiccation and seed decay;

In situations and areas where vegetation is required to be flattened but

not entirely removed, i.e. roads, parking and areas where hard surfaces

will not be required, the standard operating procedure shall be to brush

cut vegetation to surface level, leaving and retaining rootstock in situ.

This will hold and bind soil and retain moisture and aid toward natural

long term rehabilitation;

Topsoil should be stockpiled at designated stockpile areas, protected by

bund walls and covered by shade cloth or geo fabric for preservation of

seed stock and.

Stockpiles of stored topsoil must not be higher than 2 meters to avoid

compaction


Pre-Mitigation 1 3 2 >90 Medium


6.3.3 Soils

The assessment of potential impacts on soils is provided below:

Table 6-7: Impact on soils


Impact 1

Description of

impact

When topsoil is removed from a soil profile and stored for later re-introduction;

the profile loses rooting depth and heat and moisture storage capacity. The

integrity of the stored seed stock is compromised lowering the regenerative

capacity of the soil.

Mitigation

required

Topsoil will need to be stripped in particular areas of the plant where solid

structure will be constructed. In situations and areas where topsoil

removal is required for the construction of hard surfaces and buildings;

such topsoil should be removed and stockpiled for later use as a



rehabilitation medium. Such usage should not exceed three months

duration to avoid desiccation and seed decay;

In situations and areas where topsoil will be compressed due to factory

activities but it is not required to strip and remove; i.e. roads, parking and

areas, the standard operating procedure shall be, to leave in situ. This

will hold and bind soil and retain moisture and aid toward natural long

term rehabilitation;

Scarification of compressed topsoil can be effected at the rehabilitation

phase;

Topsoil storage to be stockpiled no higher than 2 m to prevent

compression;

Stockpiles to be protected by bund wall on three sides to prevent wash

away and wind erosion and bedded down by shade cloth;

Stockpiles are to be maintained in a fertile and erosion free state and to

be reintroduced back into nearby areas as soon as possible to reduce

storage time which leads to seed stock deterioration and die-off;

The handling of the stripped topsoil must be minimised to ensure the

soil’s structure does not deteriorate and

Compaction of the removed topsoil must be avoided




Impact 2

Description of

impact

Repeated movement of heavy vehicles over clay soils will generate

compaction. Erosion is grouped with compaction due to dust loss, reduced

vegetation cover and increased rainfall runoff.

Mitigation

required

Limit width of all factory roads to < 4 meter width so as not to trigger

Activity 4 of Listing 3 of the NEMA EIA Regulations 2014;

Limit haul roads and internal access tracks to least required;

Demarcate turning circles and parking areas with fencing to limit overspill

of vehicles into no-go zones;

Ensure that the internal factory roads have erosion humps to deflect

rainwater and reduce erosion of road surface as well as to ensure proper

storm water berms are in place along roads to deflect runoff;

Set up water sprayers along haul roads to dampen dust and minimise

dust loading to surrounding vegetation;

Limit width of haul roads and access tracks to maximum 4 meters to allow

sprayers to reach full width of road and

Scarify compacted areas during rehabilitation and closure to aid and

allow for natural vegetation regrowth

In areas where compaction will occur but topsoil or overburden will not

be removed; do not cut or remove vegetation. Allow vegetation to be

compacted but leave root and subsurface vegetation in situ.






Impact 3

Description of

impact

Hydrocarbon and chemical spills due to leaking equipment, spillage at refill

or on site repairs

Mitigation

required

To avoid contamination of soils, re-fueling, fuel storage areas, and areas

used for the servicing or parking of vehicles and machinery, should only

takes place in the designated workshop areas and should be located on

impervious bases with adequate protective bund walls to ensure that all

the fuel kept in the area will be captured in the event of spillage. Bunded

area to be 110% capacity of fuel tank;


to deal with hydrocarbon and chemical spillage in the plant area – the

source of spillage must be immediately contained with the correct control

measures, the contaminated soil must be uplifted, removed and disposed

at an approved landfill facility for hydrocarbons and / or malicious

chemicals;

An incidence report of any hydrocarbon or chemical spill must be filed on

the facility’s incident Report Forms for inspection by the ECO for the brick

making facility. All incidents of spillage must be reported to DWS and

DEA&DP as an environmental incident and follow the correct procedure

as laid out by NEM:WA and DEA&DP: Waste Management;

All vehicles are to be serviced and maintained on a scheduled basis to

minimise leaking motors;

Any vehicles that stand in one place for an excessive length of time must

have drip trays placed beneath oil sumps;

Ensure regular de-tanking of sumps and disposal of hydrocarbons at

waste management center with provision to accept the waste;

Fuel safe storage depots to be provided above ground for storage of all

hydrocarbons. This to include bunded side walls and impervious floor;

Movement of fuels around plant to be conducted in secure containers with

avoidance of spillage;

All plant equipment and vehicles are to be serviced and maintained on a

scheduled basis to minimise leaking motors;

A designated area containing spill kits must be made available on the

plant and

Regular soil sample inspection by an Environmental Control Officer

(ECO) for signs of contamination. If signs of pollution are noted,

immediate action should be taken to remedy the situation and, if

necessary, an ECO should be consulted for advice on the most suitable

remediation measures.






6.3.4 Heritage Impacts

The assessment of potential impacts on heritage sites is provided below:

Table 6-8: Heritage impacts


Impact 1

Description of

impact

Loss of heritage resources by the development of the brick making facility on

the property. These may include: historical structures, graves, culturally

significant landscape features, geological features, archaeological resources

and paleontological resources.

Mitigation

required

There is always a small chance of intersecting unmarked human remains

dating to the Later Stone Age but according the heritage specialist, the

chances are very small. Such finds can never be predicted;

As a mitigation, the education of the factory workers should be effected

to identify historical artefacts so that they may stop processes in order to

alert the factory manager;

Most artefacts will occur in upper layers in overburden and soils and will

be moved around when the topsoil is cleared and stockpiled and then

redistributed during rehabilitation. Because of their very low value, no

significant impacts are expected;

A number of isolated stone artefacts were noted scattered across the site

with the majority being in the western half. They appeared to be a mix of

Early (ESA), Middle (MSA) and Later Stone Age (LSA) artefacts. None

of these artefacts is considered of cultural significance according the

heritage consultant;

The R60 can be considered a scenic route and the visual impression of

a factory would be considered a cultural and visual impact as well as

deterrent to tourism;

To some extent the existing Cape Lime buildings and the large bluegum

trees within the Vink River riparian zone will provide visual screening and

can be used to mitigate the impact of the new brick factory buildings;

The impact of both the Cape Lime and the brick plant will add to a

cumulative visual impact and

Placement of berms using overburden and planting of windrows of rapid

developing trees (e.g. Searsia Karee, Searsia pendulia, Vachellia karoo)

can be used to screen the infrastructure; so as to retain the visual /

cultural milieu of the landscape.




Pre-Mitigation 1 2 2 < 40 Very Low

Post-Mitigation 1 2 1 < 40 Insignificant

6.3.5 Socio-economic Impacts

The assessment of potential socio-economic impacts is provided below:

Table 6-9: Socio-economic impacts


Impact 1

Description of

impact

The biggest provider of jobs in the area is the agricultural sector and in

particular the viticulture industry along with associated vineyards, wine cellars

and tourism. Concern is raised that any negative environmental impact from

the development of the factory could affect far more jobs than the positive

gain achieved from the smaller workforce of the factory.

Mitigation

required

Negative environmental impacts will be mitigated as best possible by

following the guidelines that will be written in the EMPr and the MMP.

Should these practices be diligently followed, impact to the agricultural

sector can be minimised.


Impact 2 2 3 >70 High

Post-Mitigation 2 2 2 40 to 70 Low

Impact 2

Description of

Impact

Local labour from adjacent farm communities or Robertson will be employed

by the mine. This will have a positive impact on the wellbeing of employees

with a multiplier effect on households of the employed.

Mitigation

required No mitigation required.


Impact 2 3 1 >90 Medium

(Positive)

Impact 3

Description of

impact

Tourism, may be negatively impacted;’ this includes visits to wine farms,

mountain bike trail and passing road traffic using R60/62 scenic tourism route

Mitigation

required

Visual screening of the infrastructure must be undertaken to ameliorate

the impact to tourists. This must be undertaken by the placement of

berms using overburden and planting of windrows of rapid developing

trees (e.g. Searsia Karee, Searsia pendulia, Vachellia karoo) to screen

the infrastructure; so as to retain the visual and cultural milieu of the

landscape.




Impact 2 3 1 > 90 Medium

Post-Mitigation 2 2 1 > 70 Low

Impact 4

Description of

impact

Agricultural activities, may be negatively impacted; due to possible fugitive

dust loading from the plant. Dust prevents crop growth and will also have

health impacts on the labourers and residents, potentially impacting

agricultural production. Dust in the size range 20 to 100 µm diameter,

originating from unenclosed material handling and processing, and from wind

erosion of unconsolidated stockpiles, will result in fallout dust (vertical

deposition onto horizontal surfaces) and impaction dust (horizontal deposition

onto vertical surfaces) during wind conditions of greater than 15 km/h. Below

this wind speed of 15 km/h, particles in this size range generated by

mechanical handling will deposit within the site boundaries, and the wind has

insufficient energy to generate dust from unconsolidated surfaces

Mitigation

required

Recommended mitigation measures proposed by the air emission specialist

include:

Confine vehicle movements on unpaved roads to demarcated areas only

Hard pave all turning circles and material discharge and stock pile reclaim

areas

Enclose coal and clay stockpiles with three sided concrete bins, with

opening facing SW or NE (at right angles to prevailing winds).

Erect wind fences or plant indigenous trees as wind breaks at strategic

locations (e.g. upwind of stock piles and turning circles).

Ensure that site drainage carries spillage of clay or coal fines away from

traffic movement zones (and directed to lined sumps or at a minimum into

settling ponds to prevent loss beyond the boundary);

Spraying of clay or coal stockpiles if wind erosion is observed;

Hard paving of turn-off point from tarred road onto site access road for 10

to 15 meters to reduce spillage and carry-over of material from unpaved

to paved road.


Impact 2 3 2 > 90 High


Impact 5

Description of

impact

Loss of value of neighbouring properties resultant from change of land from

Agriculture to Temporary Industry

Mitigation

required A specialist report by a Professional Appraiser needs to be undertaken.


Impact 2 3 2 > 90 High




6.3.6 Air Quality

The assessment of potential impacts on air quality is provided below:

Table 6-10: Air Quality


Impact 1

Description of impact

Dust generated from site clearing, soil transportation, stockpiling, construction may be windblown as fugitive dust and settle on surrounding, residential, agricultural and environmental receptors. Unsightly brick dust and coal dust staining may occur on nearby infrastructure.

Mitigation required

Recommended mitigation measures proposed by the air emission specialist include:

Confine vehicle movements on unpaved roads to demarcated areas only;

Hard pave all turning circles and material discharge and stock pile reclaim areas;

Enclose coal and clay stockpiles with three sided concrete bins, with opening facing SW or NE (at right angles to prevailing winds);

Erect wind fences or plant indigenous trees as wind breaks at strategic locations (e.g. upwind of stock piles and turning circles);

Ensure that site drainage carries spillage of clay or coal fines away from traffic movement zones (and directed to lined sumps or at a minimum into settling ponds to prevent loss beyond the boundary);

Spraying of clay or coal stockpiles if wind erosion is observed;

Hard pave and reinforce first 15 m leading off the Langvlei Quarry public road so that heavy trucks do not damage tarred road edges and create pot holes due to the turning motion of the truck, and possible spillage from the load bed of coal delivery trucks;

Demarcate turning circles, haul road and parking areas with fencing to limit overspill of vehicles into no-go zones;

Set up water sprayers along haul roads to dampen dust and minimise dust loading to surrounding vegetation;

Limit width of haul roads and access tracks to maximum 4 meters to allow sprayers to reach full width of road;

Ensure that all stockpiles, i.e. topsoil, overburden, clay ore, coal storage are enclosed within three sided protection walls and a low bund wall on fourth side to limit spillage onto loading apron;

Limit maximum height of stockpiles to 2 m and orientate long axis along SE-NW prevailing wind direction;

Design bund walls to prevent wind erosion with orientation such that open end is at right angles to prevailing NW-SE winds;

Sweeping of all aprons surrounding tip points and stockpiles;

Speed control for all roads to limit dust generation;

Scarify compacted areas after construction or mining to allow for natural vegetation regrowth and



Regular twice weekly visual checking and recording of visible dust emissions from all identified dust sources and emission points. These check lists to be signed off and permanently retained for analysis of dust emission points and opportunities for continuous improvement and

In order to establish a baseline dust fall; site-representative dust fall monitoring, in terms of the National Dust Control; Regulations, will be undertaken prior to the commencement of activities.



Post-Mitigation 1 2 1 > 70 Very Low

Impact 2

Description of impact

Sulphur dioxide (SO2 emission). Sulphur dioxide is emitted due to combustion of sulphur contained in the coal fuel used to energise the clamp kilns.

Mitigation required

There are no mitigation measures that can be applied to the clamp kiln brick making technology;

Passive monitoring of SO2 along the boundary lines of brick works in South Africa have not yielded any instances in which the concentrations approached the national DEA limit values.

Continuous monitoring of SO2 emission must be carried out at four points along the main wind axis (NW-SE);

Recommended that these monitoring sites be located on the NE, SE, SW and NW boundaries, to take into account the higher frequency of wind along the SE-NW and NW to SE axis;

Special attention to be given under meteorological conditions leading to an inversion whereby temperatures increase with height above ground. A cooler trapped layer at surface is prevented from rising above the warmed capping inversion, thus trapping any pollutants that are present. This is usually prevalent during windless cold early morning and late evening times. During such meteorological conditions, Sulphur levels may rise above acceptable levels and may drift off the main wind axis (NW-SE) and

Cumulative impacts: There are no other activities emitting SO2 within a 5 km radius, so there are no cumulative concentrations that could raise the ambient SO2 levels towards the limit.




6.3.7 Noise Impact

The assessment of potential impacts on noise levels is provided below:

Table 6-11: Noise




Impact 1

Description of

impact

The major noise generating activities will result from the operation of vehicles

and tippers associated with brick making facilities and the running of the plant,

the crushers, and conveyor belts.

Mitigation

required

Operating hours kept to during 08h00 to 17h00 during week days, and

08h00 to 14h00 on Saturdays;

Berms and windrows will be constructed around the brick facility area

which will aid block sound emission and

Factory vehicles will be regularly services and exhaust systems will be

maintained in good order in compliance with limiting noise emissions.




6.3.8 Visual Impacts

The assessment of potential visual impacts is provided below:

Table 6-12: Visual Impact


Impact 1

Description of

impact

The geographical area from which the project will theoretically be visible,

known as the View Catchment Area (VCA), is dictated primarily by

topography. The extent is approximately 10km to the north west bounded by

the Langeberg, 5km south to Aasvoelberg and 8km to the east and south east

bounded by the higher ridgeline of Rooiberg. Of more significance is the Zone

of Visual Influence (ZVI) of the proposed project, i.e. the actual area from

where the project will be seen. Topography (minor ridges), vegetation (trees

and hedges), buildings and distance will reduce the area from which the site

and proposed project will be seen, particularly due to the relatively low

elevation of the site and its flatness. Hence the ZVI will be less than the VCA.

Mitigation

required

During the operation of the brick factory, the development will be visible.

On completion of mining, and with the removal of the factory infrastructure

and re-vegetation, the remnant impact will not be acutely visible and

Plant windrows of quick growing, preferably indigenous, trees, around the

brick factory site to screen the operation.




Impact 2



Description of

impact Change from naturally vegetated site to a brick factory

Mitigation

required


site to screen the brick factory and

The over burden from the first phase could be used as a berm on which

these trees can be planted, increase the screening effect from early days




Impact 3

Description of

impact

The proposed development will be visible from receptors within the ZVI.

These include: The R60 scenic tourist route and some dwellings

Mitigation

required


site to screen the brick factory and

The over burden from the first phase could be used as a berm on which

these trees can be planted, increase the screening effect from early days



6.3.9 Traffic Impacts

The assessment of potential traffic impacts is provided below:

Table 6-13: Traffic impact


Impact 1

Description of

impact Impact on traffic on Worcester – Robertson Trunk Road TR 31/1

Mitigation

required

The Shoulder Sight Distance to the left along TR 31/1 from DR 1384 is

limited by vegetation that is obscuring the sight line at an eye height of

1.05 m for passenger cars. However, at an eye height of 1.80 m (for all

design vehicles other than passenger cars, the shoulder sight distance is

sufficient. The Shoulder Sight Distance should be improved for

passenger cars by trimming the vegetation along TR 31/1 to the left of

DR 1384.

The Shoulder Sight Distance to the right of DR 1384 along TR 31/1 is

sufficient for passenger cars and other design vehicles. And

There are existing passing lanes in both directions along TR 31/1 on both

approaches to DR 1384 that separate decelerating turning from the

faster, straight through traffic along TR 31/1. This contributes to safety at

the intersection.






Impact 2

Description of

impact Impact on traffic on the Langvlei Quarry Divisional Road DR 1384

Mitigation

required

Access to / from the development site will be off the Langvlei Quarry

Divisional Road, DR 1384 that intersects TR 31/1 to the south. DR 1384

also provides access to Langvlei train station and Cape Lime. The traffic

impact specialist comments that there is sufficient Shoulder Sight

Distance both to the left and right along DR 1384 at the position of the

proposed access to the development. The proposed access point along

DR 1384 is therefore deemed safe.

Road Network Management have nonetheless issued precise

instructions on the position and construction of the access point. This will

mitigate any possible impact to road safety. The exiting access at ~ 0.92

km off DR 1384 must be permanently closed. The Road Network

Management have approved a new access at ~ 1.21 km off the DR 1384.

Access must be built according to Main Farm Access regulations and be

hard surfaced.






6.4 CUMULATIVE IMPACTS

Cumulative impacts are the direct and indirect impacts that act together with existing and

future potential impacts of other activities, or proposed activities in the region that affect

the same resources and receptors. With respect to this project, potential cumulative

impacts are:

Industrial processing activities of the Cape Lime factory within the floodplain of the

Vink River are leading towards degradation of the drainage lines, ESA and

impinging on the integrity of the CBA. Any development within a CBA is

undesirable as it will result in the cumulative impact of a reduction of a network of

natural sites identified to meet biodiversity pattern and process thresholds. The

development of the Robertson Brick Factory will imply additional pressure to the

environment. The geographical orientation of the associated mine development

and the position of the factory to least impact on major drainage lines, has gone

someway ensure that sufficient ecological corridors are left intact for biodiversity

needs.

The visual impact of the Cape Lime factory is a noted deterrent to tourism activities

that are on the Breede River Wine Route on the R60. Additional developments of

the Gannabosch Mine and Robertson Brick Factory add some “moderate”

(Anderson, M. 2016) level of cumulative impact which can be mitigated if

recommendations of the specialist are followed.

The cumulative effect from mining, current activities at the Cape Lime plant and

future brick manufacturing could increase the levels of fugitive dust. This may

negatively affect agriculture, viticulture, scenic milieu and the health of residents

in the fallout zone. Control and management measures will be described in the

EIA/EMP.

Noise is not evaluated to be a cumulative impact if activities are confined to

standard daytime operational practice.

Cumulative impact must also consider the positive impact of the presence of business

activity in the Langeberg region and the input of social upliftment programs that form an

essential aspect of the factory development program. The supply of essential services

and meeting the demand for bricks of the construction industry are also considered a

positive cumulative impact.



7 ALTERNATIVE LAND USE AND DEVELOPMENTS

CONSIDERED

Appendix 2 of the GN 982 Paragraph 2 (h) (ix) to (xi) of the NEMA EIA Regulations, 2014,

concerns the site choice and alternatives to the preferred option. The EIA Regulations

require that all S&EIR processes must identify and describe ‘alternatives to the proposed

activity that are feasible and reasonable’. The different types or categories of alternatives

for this project include: location alternatives, type of activity, design or layout alternatives,

and operational alternatives. The ‘No Go’ or ’No Project’ alternative must also be

considered.

7.1 ALTERNATIVE CLAY RESOURCE THAT COULD PROVIDE OTHER LOCALITIES FOR THE

FACTORY

Ideally the brick making factory should be linked to the Gannabosch Clay Mine.

Processing and manufacture of the finished product needs to take place as close to, or

preferably at the mine location. This therefore eliminates the possibility or rationale of

establishing the brick factory at an alternative site to the clay mine. Transport of raw clay

to an offsite process plant may not be economically viable nor logistically efficient.

A desktop study to seek viable alternative sites for the mine was undertaken by UA, which

was followed up by site specific visits by the proponent. This was specifically in response

to a need to establish the mine outside of the CBA. While clay deposits were found to be

in existence in the area, (see Figure 7-1), the following limiting factors had to be

considered.

• Ground truthing by the proponent indicated that none of these alternative sites had

a similar reserve potential who claim that the thickness and depth of the clay

deposits is not comparable to that found on Gannabosch Vlakte 51;

• None of the sites provided similar ease of access to adequate site and service

infrastructure required to support a brick factory: Proximity to water (4000 liters

per hour) and electricity (Three Phase 440 V) and access to road infrastructure

are minimum requirements and a failure to provide for this will mean the need to

construct roads, and apply for servitude rights;

• The proponent has established co-operation with the surface owner which lacking

at alternative localities and

• The alternative sites would need to produce clay with the qualities to provide bricks

of comparable qualities to the Gannabosch proposed site as specified in the 2015,

CSIR/Cermalab Report.

Further detail of the alternative resource study is available to read in Annexure I:

Alternative Resource Survey Report (Umvoto Africa, 2017).



Figure 7-1: Positions of additional potential brick clay resource sites in the region surrounding the proposed Gannabosch clay mine. Pink, (Pt-01 02 and 03)

orange (Dg-01) and yellow (Dw-01) areas represent Tierberg, Gydo and Waboomberg Formation sites respective respectively, maroon polygons represent associated farms, and the red polygon represents Gannabosch

Vlakte 51.

7.2 SOUTHWESTERN ALTERNATIVE FOR LOCALITY OF THE FACTORY

The position of the brick factory was initially proposed to be on the southwestern extent of

the mine concession area. At this stage in the scoping process the proposed Gannabosch

mine was ~ 14 ha and placed on the western side of the Langvlei Quarry road (see Figure

7-2). Following recommendations of both the fresh water ecologists and the botanical

specialist, it was decided to reposition the factory to the northern extent of the mine area.

This had important repercussions; in so far as leaving the Vink River Aquatic Buffer zone

intact and avoiding the ecologically sensitive drainage line 1B. It also suited the proponent

because exploration drilling had shown the clay is thinner to non-existent towards the

north, therefore less resource is lost to the factory footprint.



Figure 7-2: Initial locality of the brick factory was planned to be southwest of the proposed mine footprint, between the proposed mine concession area and the Vink

River on southwest corner of map.

7.3 THE CAPE LIME PROPERTY ALTERNATIVE

The Cape Lime factory is located just south of the proposed clay mine and could possibly

host the brick making facility. The onsite provision of site and service (electricity, water,

waste management) make this a practicable alternative. Utilising existing disturbed land

is a key advantage according to the policies of the Town Planning Department of the

Langeberg Local Municipality. This will be evaluated in discussions between Afrimet as

operator of the Cape Lime and the brick factory proponent.

7.4 ROBERTSON TOWN ALTERNATIVE SITES

In seeking alternative sites for the factory it is relevant to attempt to find alternative

locations that are outside of the CBA. Industrial and previously disturbed sites within

Robertson could be a viable target area with the understanding that the main

disadvantages will be in the transport of raw material from the mine to factory. The

industrial zone of Robertson (See Figure 7-3) is not a good alternative due to its proximity

to town and already limited capacity with no possibility to expand. The old quarry site to

the northwest of the Robertson (northwest of the Droeheuvel area) (See Figure 7-3), was

considered as an alternative location. The land was previously disturbed and in need of

rehabilitation. It is positioned off the main wind axis, thereby unlikely to impact directly on

the air quality of the town. However the land is not available and is currently in use by

Afrimet. Both alternatives for Robertson were therefore rejected.



Figure 7-3: Showing the possible alternative location for the factory at the Old Quarry Site to the northwest of the town. Also shown is the unsuitable Town Industrial

Zone.

7.5 MONTAGU AND ASHTON TOWN ALTERNATIVE SITES

The town of Ashton has an industrial zone that is less constricted than Robertson and

could be considered as a receptor of a brick factory plant. This option was not considered

as viable given the transport distance from mine to factory. The Klein Karoo Brick factory

site in Montagu also has the constraints of transport distance and further investigation

would also be required to assess why the old plant was closed. Opinions of stakeholders

in the Montagu area would need to be evaluated.

7.6 REDUCED SIZE OF BRICK MAKING FACTORY

The Klein Karoo Bricks factory that was based in Montagu closed in June of 2016. The

closure of this production facility has no doubt left a need for bricks in the region. In

discussions with the Langeberg LM it was established that Klein Karoo Bricks produced

between 500 000 to 600 000 brick per month. The Bauhaus Economic Impact Study has

suggested that “The Current estimated shortfall of Bricks in this Region is 1 000 000 bricks



per month (Steenkamp, 2016). Consideration therefore needs to be given that the scale

of the proposed Robertson Bakstene operation allows for more than the current local

market. The Bauhaus economic study should ideally provide reasons for the closure of

the Montagu based operation and also consider suitable technology options, alternative

to bricks, as a construction material to meet the needs and desirability of the local market

shortfall.

The current design of the plant is scaled to operating at a production rate of ~ 2 million

units per month. This will require a plant footprint size of ~ 5 ha which will accommodate

the extrusion plant, the proposed four clamp kilns and miscellaneous storage and

despatch areas. A reduced size of operation at ~ 1 million units per month will be

evaluated as part of the Draft Environmental Impact Assessment Report that will undergo

a PPP. Reducing the production capacity of the factory could enable a reduced footprint.

This approach may present an acceptable mitigation to comments from IAP’s and

stakeholders in terms of cumulative socio-economic impacts and the biodiversity impact

on the CBA.

7.7 ALTERNATIVE BRICK FIRING TECHNOLOGIES

The current approach put forward in this Scoping Report is toward firing of the bricks using

clamp kilns. In the view of some IAP’s, this can be considered outdated with high

emissions and could have implications on the wellbeing of neighbouring inhabitants and

ecological health of the environment. Alternative technologies exist that provide more

acceptable environmental solutions. Tunnel kilns, and the Habla oven were considered

initially by the proponent and disregarded due to the fact that night time noise levels from

fans and heaters would be a disturbance given the 24 hour cycle of the firing process.

Nonetheless it is conceded that further investigation need to be explored and evaluated

as part of the Draft Environmental Impact Assessment Report that will undergo a PPP.

7.8 THE NO GO ALTERNATIVE

The No Go alternative for manufacturing bricks is considered in accordance with the

requirements of the EIA Regulations, 2014 (as per Appendix 2. Section 2 (i) (i) of Notice

R.982, 2014). The No-Go alternative entails no change in existing status quo, of the land

use on Gannabosch Vlakte 51. If this carries a knock-on effect implicating the mine also

as a No Go, it further suggests the land use will remain, as zoned, for use as agricultural

land.

Protection and environmental custody of the CBA: It can be argued that the No Go

Alternative will benefit the region through the provision of a landscape corridor required

for habitat connectivity and an upland-lowland corridor between the Langeberg Mountains

and the Breede River. An alternate, suggested by Cape Nature Conservation, is

additional mitigation in the form of a biodiversity offset. Such an offset should be obtained

according to the Western Cape’s Draft Provincial Guidelines on Biodiversity Offsets and

a suitably selected botanical specialist will need to be appointed to conduct the study. The

offset will need to identify a suitable area with a comparative “like for like” vegetative value

and the determination of a multiplication factor for land size. It would further need to set



out the most appropriate regulatory mechanism for securing stewardship of the area for

conservation in the long term.

Comparatives between agricultural and industrial sector socio-economic influence:

The No Go option ensures that the status quo of agricultural employment remains

unaffected. IAP’s have strongly argued that should the mine and factory have an

environmental impact leading to a decline in agricultural productivity of the area; the

impact of both the mine and the factory will be disadvantageous to employment

statistics. Given that the agricultural sector currently employs large numbers of people

and this will clearly exceed any proposed benefit to be achieved by the mine/factory where

the volume of labour will be significantly lower, it can be argued that the No Go option has

a positive socio-economic benefit.

If the proposed operation were not to proceed, the land may or may not be utilised for

grazing of livestock in the future. As much as the no go option may result in the protection

of the environment in situ; however, the consequences of not proceeding with the

proposed operation will include the forfeiture of a mining and factory development

opportunity and therefore the loss of support towards the Langeberg Municipality for

attaining some of the objectives as per their SDF goals. It is expected that an alternate

party is likely to apply for the mining right with the DMR. It would further suggest that no

new employment opportunities would be created nor would the Social and Labour Plan

upliftment and development programs take place.



8 CONCLUSIONS

This Final Scoping Report concludes the Public Participation Process and provides an initial

environmental impact assessment for the proposed Robertson Brick Factory. The intent of

the scoping process was to encourage participative dialogue between the proponent and

interested and affected persons and to ensure that the application process is transparent,

serves the region socio-economically and safeguards the biodiversity of the environment. The

process has endeavoured to involve the public as IAP’s and institutional organisations as

commenting authorities and elicit from all stakeholders the concerns and comments with

regard to the proposed development. Some of these concerns have been discussed in this

Scoping Report, while others remain to be examined more thoroughly in the Draft EIA

Report. The Scoping Report has also endeavoured to draw out all impacts and to suggest

mitigating and optimisation interventions. A decision making matrix has been used to evaluate

the significance of the impact in both the pre and post mitigation scenarios. Due to the fact

that not all concerns are thoroughly discussed, the significance ratings may be amended as

the process proceeds into the draft EIA phase. Finally the Scoping Report provides an

assessment of alternatives in locality, size, technology, and business approach and to align

these alternatives to critical environmental and socio-economic objectives. It is common

practice in an S&EIA study to provide a number of alternatives to the proposed development

that will allow the decision-making authority to make preferred choices. The assessment of

the alternatives is not completed for the scoping phase and further studies and considerations

will need to be included in the Draft EIA Report.

We trust that adequate scoping and public participation has followed correct protocol and will

allow the DEA&DP to make an informed decision and promote the process forward towards

the preparation of the Draft EIA Report.



9 UNDERTAKING AND AFFIRMATION BY THE EAP

Paragraph 2 (j) requires an undertaking by the Environmental Assessment Practitioner to state

his/her independence from the proponent, the correctness of information contained in the

report and the completeness and thoroughness to include all comments from stakeholders

and IAPs.

9.1 DECLARATION BY ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

I Paul Lee, as the appointed environmental assessment practitioner (“EAP”) hereby

declare/affirm the correctness of the information provided or to be provided as part of the

application, and that I:

in terms of the general requirement to be independent:

o other than fair remuneration for work performed/to be performed in terms of this

application, have no business, financial, personal or other interest in the activity or

application and that there are no circumstances that may compromise my objectivity;

in terms of the remainder of the general requirements for an EAP, am fully aware of and

meet all of the requirements and that failure to comply with any the requirements may

result in disqualification;

have disclosed/will disclose, to the applicant, the specialist (if any), the Department and

registered interested and affected parties, all material information that have or may have

the potential to influence the decision of the Department or the objectivity of any report,

plan or document prepared or to be prepared as part of the application;

have ensured/will ensure that information containing all relevant facts in respect of the

application was/will be distributed or was/will be made available to registered interested

and affected parties and that participation will be facilitated in such a manner that all

interested and affected parties were/will be provided with a reasonable opportunity to

participate and to provide comments;

have ensured/will ensure that the comments of all interested and affected parties were/will

be considered, recorded and submitted to the Department in respect of the application;

have ensured/will ensure the inclusion of inputs and recommendations from the specialist

reports in respect of the application, where relevant;

have kept/will keep a register of all interested and affected parties that participate/d in the

public participation process; and

am aware that a false declaration is an offence in terms of regulation 48 of the NEMA EIA

Regulations, 2014.



2017-03-17

Signature of the environmental assessment practitioner: Date:



REFERENCES Cole, D.I., Ngcofe, L., Halenyane, K. (2014) Mineral Commodities in the Western Cape

Province, South Africa, Council of Geoscience: Report Number:2014-0012,

Western Cape Regional Office. February 2014

CFM, (2017), Elsenberg GIS: ArcGIS Services Directory, Western Cape Government:

Agriculture [accessed 2017 March 10]. http://gis.elsenburg.com/app/cfm.

CNdV, (2014): Langeberg Municipality: Spatial Development Framework (Draft): prepared for

DEA&DP and Langeberg Municipality. , November 2014

CWDM, (2014), 2014/2015 Annual Report: Cape Winelands District Municipality, 203 pp

CWDM, (2012): Cape Winelands District Municipality: Integrated Development Plan

(2012/13-2016/17)

CWDM, (2015) Cape Winelands District Municipality: Annual Report 2014/2015)

CWDM, (2012): Cape Winelands District Municipality: Integrated Development Plan

(2012/13-2016/17)

DEA&DP, (2014): Western Cape Provincial Spatial Development Framework. Produced by

Environmental & Spatial Planning division of Western Cape Department of

Environmental Affairs and Development Planning, November 2014.

Department of Water and Sanitation, DWS (2014). Reconciliation Strategy for Robertson.

Development of Reconciliation Strategies for Selected Towns in the Southern

Planning-Region. Prepared by Umvoto Africa (Pty) Ltd in association with

WorleyParsons (Pty) Ltd. on behalf of the Department of Water and Sanitation,

South Africa. Directorate : National Water Resource Planning. 18 pp

DEA&DP, (2014).: Western Cape Provincial Spatial Development Framework. Produced by

Environmental & Spatial Planning division of Western Cape Department of

Environmental Affairs and Development Planning, November 2014.

Enviro Dinamik, (2007), Spatial Development Framework: District Management Area (Draft),

February 2007

Elsenberg GIS: ArcGIS Services Directory, Western Cape Government: Agriculture [accessed

2015 Dec 05]. http://gis.elsenburg.com/app/cfm.

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Unpublished, The Nature Conservation Corporation, Cape Town

Krige, J. (2016) Botanical impact assessment for the Gannabosch Clay Mine, Farms 51 &

5/52, Robertson

Langeberg ,(2016) Integrated Development Plan(Reviewed for 2016/207)

http://gis.elsenburg.com/app/cfm



Mucina, L., & Rutherford, M.C. (eds). (2006). The Vegetation of South Africa, Lesotho and

Swaziland. Strelitzia 19. South African Biodiversity Institute, Pretoria. ISBN: 978-

1919976-21-1

Ollis, D; Ngobela, T.Olsen,T.(2016)-Freshwater Ecology Impact Assessment Report for

proposed Gannabosch Clay mine on Farm 51 and 5/51, Robertson, 32pp

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of the development of a Solar Farm on the soils of Valleydora Solar Farm

Springfontein, CSIR, pp10.

Reinecke K, Rountree M and Crowther J (2014). Noree/Vink River Maintenance Management

Plan. Prepared by Southern Waters Ecological Research and Consulting cc in

association with Fluvius Environmental Consultants and CCA Environmental,

June 2014.

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(http://sabap2.adu.org.za/)

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africa/climate/robertson 2000-2014

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Prepared by G. Molzen, P. Lee, L. Towers and E. Wise of Umvoto Africa (Pty) Ltd

for Gannabosch Clay Mine (Pty) Ltd. Report No. 856/03/01/2016, April 2016, 45pp.

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21pp.

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APPENDIX A – CURRICULUM VITAE OF EAP



APPENDIX B – COMPANY REGISTRATION CERTIFICATE

(ROBERTSON BAKSTENE (PTY) LTD.)



APPENDIX C – HERITAGE WESTERN CAPE



APPENDIX D – LUPA TEMPORARY ZONE DEPARTURE

APPLICATION



APPENDIX E – INTERESTED AND AFFECTED PARTIES REGISTER



APPENDIX F – IAP & STAKEHOLDER CONCERNS RAISED

F-1: COLLATED COMMENTS AND CONCERNS

F-2: ALL IAP RESPONSES

F-3: IAP SIGNED PETITIONS

F-4: DOCUMENTED LAWYER LETTERS



APPENDIX G – LAND AFFAIRS RESPONSE



APPENDIX H – TITLE DEED (GANNABOSCH VLAKTE 51)



APPENDIX I – MAPS

Figure I 1 Regional Topographic Map

Figure I 2 Locality Map

Figure I 3 Site & Services Infrastructure

Figure I 4 Layout Plan

Figure I 5 Factory Infrastructure Plan

Figure I 6 Local Geology Map

Figure I 7 Local Vegetation Map

Figure I 8 Biodiversity Map


Final Scoping Report Page X

Figure I 1: Regional Topographic Map


Final Scoping Report Page XI

Figure I 2: Locality Map including the coordinates of the target property, Gannabosch Vlakte 51 (black boundary line) are shown


Final Scoping Report Page XII

Figure I 3: Layout Plan of proposed brick factory (Black area marked BF1 to BF4) on the mine concession (red polygon), showing slight overrun on the northwest border. Also shown are service and infrastructure that is external to the boundary of both the mine and Gannabosch Vlakte 51, this incudes water and electricity supply.


Final Scoping Report Page XIII

Figure I 4: : Zoomed in layout plan showing position of the brick making factory in relation to the mine concession area as per points BF1 to BF4.


Final Scoping Report Page XIV

Figure I 5: Conceptual layout plan showing brick processing infrastructure with estimated sizes of individual areas.

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