vegetation assessment for the closure project … of borrow pit...vegetation assessment for the...

VEGETATION ASSESSMENT FOR THE CLOSURE PROJECT OF THE BORROW PIT ASSOCIATED WITH THE NR6, SECTION 4 AT PENHOEK PASS.

Prepared for:

Prepared by:

SANRAL Southern Region EOH Coastal & Environmental Services

P O Box 27230 Greenacres, 6057

P.O. Box 934 Grahamstown, 6140

South Africa South Africa

October 2015

Vegetation Assessment

Coastal & Environmental Services SANRAL ii

This Report should be cited as follows: Coastal & Environmental Services, 2015. Vegetation Assessment for the Closure Project of the Borrow Pit associated with the NR6, Section 4 at Penhoek Pass: EOH CES, Grahamstown


Coastal & Environmental Services SANRAL iii

REVISIONS TRACKING TABLE

EOH Coastal and Environmental Services

Report Title: Vegetation Assessment of borrow pit

Report Version: Draft Report

Project Number: 175

Name Responsibility Signature Date

Ayanda Zide Report Writer

Prof. Roy Lubke Ecological Specialist

Tarryn Martin Report Reviewer

Copyright

This document contains intellectual property and propriety information that are protected by

copyright in favour of EOH Coastal & Environmental Services (CES) and the specialist consultants.

The document may therefore not be reproduced, used or distributed to any third party without the

prior written consent of CES. The document is prepared exclusively for submission to SANRAL in

the Republic of South Africa, and is subject to all confidentiality, copyright and trade secrets, rules

intellectual property law and practices of South Africa.


Coastal & Environmental Services SANRAL iv

THE PROJECT TEAM

Ms Ayanda Zide, Environmental Consultant

Ayanda holds a BSc in Botany, Microbiology and Chemistry and a BSc (Hons) in Botany where her thesis focused on identifying and characterising galls and gall forming insects and associated pathogens (Fungi) on the mangrove species Avicennia marina. Courses in her honours year included Diversity Rarity and Endemism (DRE), Pollination Biology, Estuarine Ecology, Rehabilitation Ecology, a Stats course and a short GIS course. Her research interests lie in biological invasion, conservation, rehabilitation ecology, plant biotechnology and water research. Ayanda conducts vegetation and impact assessments that guide proposed developments to reduce their impacts on sensitive vegetation. As part of these surveys she identifies and maps the vegetation communities and areas of high sensitivity. She has worked as a botanical assistant on the Lesotho Highlands Development Authority botanical baseline survey and has conducted groundtruthing surveys for developments in the Eastern Cape. Professor Roy Lubke, Ecological Specialist

Professor Roy Lubke is a retired Associate Professor in the Department of Botany, Rhodes University, and retired Director of Coastal & Environmental Services. He contributed to the preparation of the SA Association of Botanists vegetation map of southern Africa, by mapping the vegetation in a large part of the Eastern Cape. Professor Lubke has been involved in numerous EIAs and has extensive experience in ecological and vegetation studies and the identification of indicator species. He has been involved in environmental consulting for the last 20 years, specialising in vegetation assessment, ecological restoration and management of sensitive environments. He has worked in the Eastern, Western Cape and Kwa-Zulu Natal and thus has a fuller understanding of South African environmental conditions. He has also has carried out environmental assessments in Mozambique, Kenya, Madagascar, Malawi and Angola. Professor Lubke has had extensive experience in general environmental projects especially ecological impacts and sensitivity of the environment, due to biodiversity and species rarity and vegetation and habitat sensitivity.

Ms Tarryn Martin, Senior Environmental Ecological Specialist (Pri Sci Nat), Report reviewer

Tarryn holds a BSc (Botany and Zoology), a BSc (Hons) in African Vertebrate Biodiversity and an

MSc with distinction in Botany from Rhodes University. Tarryn’s Master’s thesis examined the

impact of fire on the recovery of C3 and C4 Panicoid and non-Panicoid grasses within the context of

climate change for which she won the Junior Captain Scott-Medal (Plant Science) for producing

the top MSc of 2010 from the South African Academy of Science and Art as well as an Award for

Outstanding Academic Achievement in Range and Forage Science from the Grassland Society of

Southern Africa. She conducts vegetation assessments including vegetation and sensitivity

mapping to guide developments and thereby minimise their impacts on sensitive vegetation. Tarryn

has conducted a number of vegetation and impact assessments in Mozambique (to IFC standards)

which include the Lurio Forestry Project in Nampula, the Syrah Graphite Mine in Cabo dDelgado

and the Baobab Iron Ore Mine in Tete, Mozambique. Tarryn has also co-designed and

implemented the Terrestrial Monitoring Program for Kenmare, MOMA, a heavy minerals mine in

Mozambique. This monitoring program includes an assessment of forest health. She has also

worked on the Lesotho Highlands Development Authority botanical baseline survey for phase 2 of

the Lesotho Highlands Water Project.

KEY TERMS Ecological Succession: refers to more or less predictable and orderly changes in the composition or structure of an ecological community. Succession may be initiated either by formation of new, unoccupied habitat (e.g., a severe landslide) or by some form of disturbance (e.g. fire, severe wind , logging) of an existing community. Succession that begins in areas where no soil is initially present is called primary succession, whereas succession that begins in areas where soil is already present is called secondary succession. Environmental Control Officer: A suitably qualified person contracted by the developer tasked with monitoring the environmental performance and compliance of Contractors involved in the construction of the development. The ECO’s duties shall include inter alia:

Monitoring all activities relating to the project, on a monthly basis (or as agreed), for

compliance with the provisions of environmental legislation and recommendations of the

rehabilitation plan;

Conducting environmental performance audits in respect of the activities undertaken

relating to the project.

Habitat: An ecological or environmental area that is inhabited by a particular animal and plant species. It is the natural environment in which an organism lives, or the physical environment that surrounds (influences and is utilized by) a species population. Indigenous vegetation: Plants native to the locale in question. Species originating in a particular area are said to be indigenous plants for that area. Monitor: To monitor or monitoring generally means to be aware of the state of a system. The rehabilitation monitoring methodology is usually a standard and simple procedure that can be easily replicated over any vegetation community or rehabilitation area. Re-vegetation: re-vegetation implies restoration without the objective of reinstating a particular native ecosystem. In re-vegetation, any plant species is acceptable (for instance, sowing a mixture of commercially available grasses for soil rehabilitation) although a commercial crop or timber producing trees are often used. Replacement: is the establishment of a different type of vegetation on the degraded environment following construction, for example agriculture. Restoration: is the process of reconstituting a degraded system to its original state. Rehabilitation: is a general term that encompasses the replacement, restoration and re-vegetation, and is the process or programme implemented to achieve restoration or replacement.

http://en.wikipedia.org/wiki/Community_(ecology)

http://en.wikipedia.org/wiki/Landslide

http://en.wikipedia.org/wiki/Disturbance

http://en.wikipedia.org/wiki/Fire

http://en.wikipedia.org/wiki/Windthrow

http://en.wikipedia.org/wiki/Windthrow

http://en.wikipedia.org/wiki/Logging

http://en.wikipedia.org/wiki/Soil

http://en.wikipedia.org/wiki/Primary_succession

http://en.wikipedia.org/wiki/Secondary_succession


Coastal & Environmental Services I SANRAL

TABLE OF CONTENTS 1 INTRODUCTION ..................................................................................................................... 2

1.1. Project background and locality ..................................................................................... 2 1.2. Objectives and Terms of Reference............................................................................... 4

2 APPROACH ............................................................................................................................ 5 2 . 1 Limitations and assumptions ......................................................................................... 5

3 LEGISLATION......................................................................................................................... 6 4 DESCRIPTION OF THE BIOPHYSICAL SETTING ............................................................... 11 5 DESCRIPTION OF THE BIOLOGICAL SETTING ................................................................. 15 6 DESCRIPTION OF IMPACTS ............................................................................................... 24 7 IMPACT STATEMENT, CONCLUSION AND RECOMMENDATION ..................................... 28

7 . 1 Conclusions ................................................................................................................ 2 8 7 . 2 Recommendations ...................................................................................................... 2 8 7.2.1 Rehabilitation .............................................................................................................. 2 8 7.2.2 Invasion of alien species ............................................................................................. 2 8

REFERENCES ............................................................................................................................. 30 APPENDIX A – MINE PLAN ......................................................................................................... 31 APPENDIX B: SPECIES LIST....................................................................................................... 33

LIST OF TABLES Table 5-2: Species of special concern found to occur in the project area according to PNCO, SANBI, IUCN

,DAFF’s tree list and NEM:BA ....................................................................................................................... 22 Table 7-1: Summary of impacts associated with the Borrow pit pre and post mitigation. ................................. 28

LIST OF FIGURES Figure 1.1: Locality map for the Borrow Pit associated with the NR6, Section 4 at Penhoek Pass. Project

area is located in Sterkstroom, near Dordrecht within the Eastern Cape. ................................................... 3 Figure 4.1: NFEPA River and Drainage lines occurring in the farm portion and wetlands occurring in the

surrounding areas of the Borrow pit location. .............................................................................................. 12 Figure 4.2: Underlying geology of the project area. ............................................................................................. 13 Figure 5.1: Two vegetation types are said to occur in the project area (whole farm portion).The Borrow pit

occurs within the Tsomo Grassland (Mucina and Rutherford, 2006). ........................................................ 16 Figure 5-2: ECBCP map of the project area ......................................................................................................... 17

LIST OF PLATES

Plate 4-1: Photograph illustrating the general topography of the area ............................................................... 11 Plate 4-2: Photograph (A-B) illustrating grazing occurring on adjacent land. .................................................... 14 Plate 5-1: Site Photographs of the Borrow Pit area ............................................................................................. 18 Plate 5-2: Photographs illustrates species Selago densiflora (A) and Gomphocarpus fruticosus (B) found to

occur in the grassland vegetation. ................................................................................................................ 19 Plate 5-3: Grassland vegetation found in the Southern (upper area) of the Site ............................................... 19 Plate 5-4: Acacia karroo trees found to occur in the top corner of the borrow pit area. .................................... 20 Plate 5-5: Grassland vegetation found to occur in the North (low lying area) of the Site, showing the disturbed

area near the fence line. ................................................................................................................................ 20 Plate 5-6: Grassland vegetation starting to grow on the borrow pit area, when hydroseeding had not yet

occurred. ......................................................................................................................................................... 21 Plate 5-7: Grassland vegetation starting to grow on the borrow pit area ........................................................... 21 Plate 5-8: Photograph of alien invasive species Argemone ochroleuca ............................................................ 23


Coastal & Environmental Services 2 SANRAL

1 INTRODUCTION

1.1. Project background and locality The road upgrade of the National Route 6 section 4, Penhoek Pass (between Kilometers 52.0 and 66.2), between Queenstown and Jamestown in the Eastern Cape Province resulted in the extension of an existing borrow pit to provide building material for the road upgrade. The borrow pit is situated on Remaining Extent of Farm Valschfontein No.180 (Figure 1.1). This borrow pit was mined for weathered dolerite to a depth of 2 - 5 metres and had a foot print of 5.3 ha. The mining of the borrow pit ceased in February 2015. Rehabilitation in this area has been on-going. Rehabilitation of the area included the filling of the borrow pit with overburden, soil and crushed concrete aggregate. Based on information supplied by the client, hazardous waste such as contaminated soils were safely removed and disposed of at an appropriate hazardous waste facility. The ground at the borrow pit site was levelled and re-shaped. Alien vegetation from the stockpiles and surrounding areas was removed. The area was re-seeded to allow for the establishment of vegetation on the disturbed area. Structures and storage units on the site have been dismantled and removed. Rehabilitation has been finalised and the applicant is requesting a closure certificate for the borrow pit to be granted. The South African National Roads Agency (SANRAL) has requested EOH Coastal and Environmental services to conduct a vegetation assessment for the borrow pit associated with the road upgrade of the National Route 6, Section 4 at Penhoek Pass.



Figure 1.1: Locality map for the Borrow Pit associated with the NR6, Section 4 at Penhoek Pass. Project area is located in Sterkstroom, near Dordrecht within the Eastern Cape.



1.2. Objectives and Terms of Reference

The following terms of reference were used for the objectives of this study:

Describe the study area in terms of the type of vegetation present.

Review relevant legislation, policies, guidelines and standards and relate this back to the project.

Assess the direct and indirect impacts resulting from the mining activity that took place.

Provide a detailed description of appropriate mitigation measures that can be adopted to reduce negative impacts for the post-closure phase of the project.



2 APPROACH The study area, which is defined as the borrow pit and adjacent impacted areas and the project area, defined as the farm portion, were described using a two-phased approach. Firstly, a desktop assessment of the site was conducted in terms of current vegetation classifications and biodiversity programmes and plans. This included the consideration of:

The South African Vegetation Map (Mucina and Rutherford, 2006);

NFEPA wetlands and rivers

ECBCP A site visit was conducted on the 22 October 2015. The purpose of the site visit was to assess the current status of the borrow pit, to determine the rehabilitation requirement for mine closure and assess the area for any possible risks that may be present or could be potential risks in the future. This phase also considered environmental audits and previous ecological studies that were conducted for the Basic Assessment of the Road upgrade (NR6, Section 4 at Penhoek Pass), which the borrow pit is associated with. 2.1 Limitations and assumptions This report is based on currently available information and, as a result, the following limitations and assumptions are implicit:–

1. The report is based on the project description; 2. Species of conservation concern are difficult to find and difficult to identify, thus species

described in this report do not comprise an exhaustive list. 3. Sampling could only be carried out at one stage in the annual or seasonal cycle.

Consequently, some plant species may therefore have gone undetected. However, the time available in the field was sufficient to determine the status of the study area.



3 LEGISLATION Environmental legislation relevant to the closure of the borrow pit is summarised below. Biodiversity Plans and Programmes are discussed in Chapter 4 where they are used to describe the desktop ecological conditions.

3.1 National Environmental Management Act (No. 107 of 1998) Relevant Sections of the Act: Section 2, 23, 24, 24-1, 28 -33 Applications for the SANRAL Borrow Pit:

Application of the NEMA principles (e.g. need to avoid or minimise impacts, use of the precautionary principle, polluter pays principle, etc.)

Application of fair decision-making and conflict management procedures are provided for in NEMA.

Application of the principles of Integrated Environmental Management and the consideration, investigation and assessment of the potential impact of existing and planned activities on the environment; socio-economic conditions; and the cultural heritage.

Implications for the borrow pit: In terms of Section 28, every person who causes; has caused, or may cause significant pollution or degradation of the environment must take reasonable measures to prevent pollution or rectify the damage caused. The borrow pit must therefore be rehabilitated to rectify the damage caused by the mining activity and to obtain a closure certificate.

3.2 National Environmental Management: Biodiversity Act (No. 10 of 2004) Relevant Sections of the Act: Section 50-62, 63-77, 75 Objectives of the Act The objectives of the Act include inter alia: To provide for:

The management and conservation of biological diversity within the Republic and of the components of such biological diversity;

o The use of indigenous biological resources in a suitable manner; o The fair and equitable sharing of benefits arising from bio-prospecting of genetic

material derived from indigenous biological resources; and o To give effect to ratified international agreements relating to biodiversity which are

binding on the Republic.

To provide for co-operative governance in biodiversity management and conservation; and

To provide for a South African National Biodiversity Institute to assist in achieving the objectives of the Act.

Threatened or protected ecosystems and species Sections 50-62 provide details relating to the protection of threatened or protected ecosystems and species. A person may not carry out a restricted activity involving a specimen of a listed threatened or protected species without a permit (Section 56-1). Refer to the Eastern Cape Provincial Nature and Conservation Ordinance (No 19 of 1974) and the list of protected ToPS species which are applicable on a national level).

Implications for the borrow pit:

Activities associated with the closure of the borrow pit may not cause a threat to any



endangered ecosystems and must provide and promote biodiversity.

No protected species may be damaged or removed without a permit.

3.2.1 National Environmental Management: Biodiversity Act (NEM:BA) 2004 (Act NO, 10

of 2004)- Alien and Invasive Species (AIS) (2014) Alien and invasive species The National Environmental Management: Biodiversity Act, 2004 (Act no. 10 of 2004) – Alien and

Invasive Species (AIS) Regulations which became law on 1 October 2014 provide details relating

to the alien and invasive species with the purpose of preventing the introduction and spread,

managing and controlling, and eradicating alien and invasive species.

Category 1b weeds are: 1) Are those species listed as such by notice in terms of section 70(1)(a) of the Act as species

which must be contained.

2) A landowner upon whose land a Category 1 b Listed Invasive Species occurs and which species is under the landowner's control must:

(a) comply with the provisions of section 73(2) of the Act; and

(b) contain the listed invasive species in compliance with section 75 (1), (2) and (3) of the Act;

3) If an Invasive Species Management Programme has been developed in terms of regulation 7, a landowner must control the listed invasive species in accordance with such programme.

4) A landowner contemplated in sub-regulation (2) must allow an authorised official from the Department to enter onto the land to monitor, assist with or implement the containment of the listed invasive species, or compliance with the Invasive Species Management Programme contemplated in regulation 7.

Category 2 weeds are: 1) Category 2 Listed Invasive Species are those species listed by notice in terms of section 70(1)

(a) of the Act as species which require a permit to carry out a restricted activity within an area specified in the Notice, the Fish Sanctuary Areas, within National Parks Provincial Reserves, Mountain Catchment areas or Forestry Reserves specified in the Protected Areas Act, or in the Permit as the case may be.

2) Unless otherwise indicated in the Notice, no person may carry out a restricted activity in respect of a Category 2 Listed Invasive Species without a permit.

3) A landowner on whose land a Category 2 Listed Invasive Species occurs must ensure that the specimens of the species do not spread outside of the land or the area specified in the permit.

4) Unless otherwise specified in the List, any species listed as a Category 2 Listed Invasive Species that occurs outside the specified area contemplated in subregulation (1), must, for purposes of these Regulations, be considered to be a Category 1 b Listed Invasive Species and must be managed according to regulation 3.

5) Individual specimens of listed invasive plant species that are declared as National Heritage Trees or National Monuments, in terms of the National Heritage Act 1999, (Act No. 25 of 1999), are Category 2 specimens.

Implications for the borrow pit area:

Only a single species was found to occur in the NEM:BA alien invasive species list

During the aftercare period, alien species should be monitored and removed from the site



as per the existing Environmental Management Plan

3.3 National Water Act (No.36 of 1998) Purpose of the Act (Section 2) The purpose of the Act is to ensure that the Nation’s water resources are protected, used, developed, conserved and controlled in ways which take into account: a) Promoting sustainable use of water. b) Protect aquatic and associated ecosystems and their biological diversity. c) Reducing and preventing pollution and degradation of water resources. Protection of water resources (Section 12-20) Provides details of measures intended to ensure the comprehensive protection of all water resources, including the water reserve and water quality. With respect to the establishment of water quality objectives, objectives may relate to (Section 13):

The presence and concentration of particular substances in the water;

The characteristics and quality of the water resource and the in-stream and riparian habitat;

The characteristics and distribution of aquatic biota; and

The regulation and prohibition of in-stream and land-based activities which may affect the quantity and quality of the water resource.

Section 19 deals with Pollution Prevention (Part 4) The person (including a municipality) who owns, controls occupies or uses the land in question, is responsible for taking reasonable measures to prevent pollution of water resources. If the measures are not taken, the catchment management agency concerned, may itself do whatever is necessary to prevent the pollution or remedy its effects and recover all reasonable costs from the persons responsible for the pollution. The ‘reasonable measures’ which have to be taken may include measures to:

a) Cease, modify or control any act or process causing the pollution; b) Comply with any prescribed waste standard or management practice; c) Contain or prevent the movement of pollutants; d) Eliminate any source of the pollution; e) Remedy the effects of the pollution; and f) Remedy the effect of any disturbance to the bed and banks of a watercourse.

With respect to pollution of rivers, the following definition is relevant when considering the potential impacts of development on water resources. Pollution may be deemed to occur when the following are affected:

a) The quality, pattern, timing, water level and assurance of instream flow; b) The water quality, including the physical, chemical and biological characteristics of the

water; c) The character and condition of the in-stream and riparian habitat; d) The characteristics, condition and distribution of the aquatic biota.

The Act defines ‘instream habitat’ as including the physical structure of a watercourse and the associated vegetation in relation to the bed of the watercourse. Riparian ecosystems ‘Riparian habitat’ includes the physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterised by alluvial soils, and which are inundated or flooded to an extent and with a frequency sufficient to support vegetation of species and physical structure distinct from those of adjacent land areas.



Section 21 deals with the Use of Water Section 21 (a-k) describes activities defined as a water use under the act. These activities may only be undertaken subject to the application for, and issue of, a water use licence.


There is no watercourse that was affected by the borrow pit or which was in the proximity of the borrow pit.

3.4 National Forest Act (No.84 of 1998) Any area that has vegetation which is characterised by a closed and contiguous canopy and under storey plant establishment is defined as a ‘forest’ and as a result falls under the authority of the Department of Agriculture, Forestry and Fisheries (DAFF): Forestry sector. A clause in Chapter 3, Part 1 covers: Prohibition on destruction of trees in natural forests. Section 7 (1) No person may cut, disturb, damage or destroy any indigenous living tree in, or remove or receive any such tree from, a natural forest except in terms of (a) A licence issued under subsection (4) or section 23. Prohibition on destruction of protected trees Section 15 (1) No person may cut, disturb, damage or destroy any protected tree or possess, collect, remove, transport, export, purchase, sell, donate, or in any other manner acquire or dispose of any protected tree or any product derived from a protected tree except under a licence or exemption granted by Minister to an applicant and subject to such period and conditions as may be stipulated. Effect of setting aside protected areas Section 10 (1) No person may cut, disturb, damage or destroy any forest produce in, or remove or receive any forest produce from, a protected area, except—

a) In terms of the rules made for the proper management of the area in terms of section 11(2)(b);

b) In the course of the management of the protected area by the responsible organ of State or person;

c) In terms of a right of servitude: d) In terms of the authority of a licence granted under section 7(4) or 23; e) In terms of an exemption under section 7(1)(b) or 24(6); or f) In the case of a protected area on land outside a State forest, with the consent of the

registered owner or by reason of another right which allows the person concerned to do so, subject to the prohibition in section 7(1).


No natural forest was found to occur within the proposed project area or near the area.

No protected tree species were found to occur in the project area.

3.5 Species of Conservation Concern

3.5.1 National Environmental Management: Biodiversity Act (No. 10 of 2004)-Threatened or Protected Species Regulations

This act aims to establish national norms and standards for the management of biodiversity across all sectors and by different management authorities. Chapter 4, Part 2 of the Biodiversity Act provides for listing of species as threatened or protected. If a species is listed as threatened, it must be further classified as critically endangered, endangered



or vulnerable. The Act defines these classes as per the table below (Table 3-1) and permits are required for the removal and/or destruction of any species listed under this Act. Table 3-1: NEMBA classes and explanations

Critically endangered species Any indigenous species facing an extremely high risk of extinction in the wild in the immediate future.

Endangered species Any indigenous species facing a high risk of extinction in the wild in the near future, although it is not a critically endangered species.

Vulnerable species Any indigenous species facing an extremely high risk of extinction in the wild in the medium-term future; although it is not a critically endangered species or an endangered species.

Protected species

Any species which is of such high conservation value or national importance that it requires national protection”. Species listed in this category will include, among others, species listed in terms of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

1.2.1. Endangered and Protected Flora in the 1974 Provincial Nature Conservation

Ordinance (PNCO): The Provincial Nature Conservation Ordinance (PNCO) protects the endangered and protected flora outside of protected areas. Species classified as Schedule 3 are endangered species. Species classified as schedule 4 are protected species. A permit from DEDEAT is required for the removal or destruction of species protected by the PNCO 1.2.2. 1976 List of Protected Trees (Government Gazette No. 9542 Schedule A) in the 1998

National Forest Act (NFA): No person may cut, disturb, damage or destroy any protected tree or possess, collect, remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose of any protected tree or any forest product derived from a protected tree, unless a permit has been acquired.

Implications for the Borrow Pit:

During the clearing of alien vegetation, these species should not be removed or if they need to be removed, relevant permits will be required.


Coastal & Environmental Services SANRAL 11

4 DESCRIPTION OF THE BIOPHYSICAL SETTING

4.1 Topography and hydrology

4.1.1 Topography According to the Environmental Management Plan (Klages, 2013), the borrow pit lies in a wide flat valley at a mean altitude of 1585 metres falling slightly from 1594 m in the southwestern corner to 1578 m in the northeastern corner. In the north and in the east, the Salpeterberg and the Penhoekberg rise to 1937 m and 2019 m, respectively. Plate 4-1 illustrates the general topography of the area

Plate 4-1: Photograph illustrating the general topography of the area

4.1.2 Water supply A number of wetlands surround the borrow pit and there is a river to the west of the borrow pit, near the boundary of the farm portion (RE/180). However, none of these were affected by the mining activities of the borrow pit, and none triggered a WULA prior to the construction of the borrow pit.



Figure 4.1: NFEPA River and Drainage lines occurring in the farm portion and wetlands occurring in the surrounding areas of the Borrow pit location.

4.2 Climate The Eastern Cape Province of South Africa has a complex climate due to its location at the confluence of two climatic regimes, namely temperate and subtropical. As a result there are wide variations in temperature, rainfall and wind patterns, mainly as a result of movements of air masses, altitude, mountain orientation and the proximity of the Indian Ocean. The climate description is based on data from the Sterkstroom weather station which is the closest weather station to the site and climatic conditions in which the Tsomo vegetation occurs. The area where the Tsomo vegetation occurs is characterised by late summer rainfall but some rain is experienced during other periods in the year (Mucina and Rutherford, 2006). Mean annual precipitation for the area ranges between 430- 790 mm, frost occurrence is variable ranging between 7 and 65 days a year (Mucina and Rutherford, 2006). The weather data for Sterkstroom shows that it receives an average of 391 mm of rain per year (SA explorer, 2015). The average temperature is 21˚ C with the hottest month occurring in January with an average high of 28˚ C and the coldest month occurring in July where the average temperature is said to drop below 0.1˚C during the night (SA explorer, 2015).

4.3 Geology and Soils According to Mucina and Rutherford (2006), the borrow pit occurs on the Tsomo Grassland vegetation type. The underlying geology prevalent in this area is characterised by red to yellow sandy soils found on mudstones of the Tarkastad Subgroup (Beaufort Group in Karoo Supergroup). These land types are of moderate depth.



The Beaufort Group sediments mainly consist of Arenite, Mudstone and Siltstones (Turner, 1981). Of these only the Mudstone formation and the Arenite formation occur within the farm portion (RE/180).The Mudstone formation only occurs in a small area in the northern section of the farm, whilst the Arenite formation occurs in most of the farm portion and where the borrow pit is found (Figure 4.2). Arenite is medium sized sedimentary rocks which are sandy (sandstone).

Figure 4.2: Underlying geology of the project area.

4.4 Current Land use The study area is currently being rehabilitated and there is currently little to no vegetation cover yet. The project area in which the borrow pit lies has grassland vegetation which is used as grazing pasture (as seen in Plate 4-2). The aim of the rehabilitation is to establish a cover of grasses so that the landowner may use this land for grazing.



Plate 4-2: Photograph (A-B) illustrating grazing occurring on adjacent land.

A

B



5 DESCRIPTION OF THE BIOLOGICAL SETTING

5.1 Regional Context The project area falls within the Grassland biome, one of the seven occurring in South Africa, Lesotho and Swaziland (Mucina & Rutherford 2006). The Grassland Biome is made up by “The warm-temperate and cool-temperate grasslands (and shrublands embedded within these) of the Highveld, Drakensberg and its northern continuation in the form of the Northern Escarpment, a whole suite of sub-escarpment grasslands, and small pockets of (most) summit sourveld composed of grasslands and savannoid bushveld” (Mucina & Rutherford,2006). Mucina and Rutherford (2006) defines the grassland vegetation as: “herbaceous vegetation of relatively short and simple structure that is dominated by graminoids, usually of the family Poaceae. Woody plants are rare (usually low or medium-sized shrubs) or absent or are confined to specific habitats, such as smaller escarpments or koppies. Core grassland areas usually have deep, fertile soils although a wide spectrum of soil types occurs. Precipitation is strongly seasonal and the growing season lasts approximately half the year.” 5.1.1 Vegetation : Tsomo Grassland and Southern Drakensberg Highland Grassland The Tsomo Grassland is found to occur in Eastern Cape Province of South Africa. It occurs on undulating lowland plains between mountain peaks and ridges where its eastern boundaries are found to occur in villages of Tsomo, Cala and Engcobo and its western boundaries occurs in Cathcart, Queenstown and Sterkstroom. This vegetation types comprises of a number of gramnoids, herbaceous species, small trees and tall shrubs. This vegetation type is classified as “Vulnerable” and about 23% of this vegetation is targeted for conservation, only 1% is conserved in private reserves and none is statutorily conserved. About 27 % has already been transformed by cultivation and by dense concentrations of rural settlements (Mucina and Rutherford, 2006). According to the EMP (Environmental Management Plan), the grasses of the genera Aristida, Cynodon, Digitaria, Eragrostis, Heteropogon, Hyparrhenia and Themeda, typical for Tsomo grassland, were found on the site. The herbs Argyrolobium, Aster, Berkheya, Commelina, Cyanotis, Gazania, Helichrysum, Oxalis and Pelargonium were also present and low shrubs of the species Felicia muricata, Helichrysum odoratissimum, Senecio burchellii, Sutera pinnatifida and Tephrosia capensis, as well as Euryops floribundus were present during the previous assessment. However, the previous assessment found the study area to be degraded.



Figure 5.1: Two vegetation types are said to occur in the project area (whole farm portion).The Borrow pit occurs within the Tsomo Grassland (Mucina and Rutherford, 2006).

5.1.2 Critical Biodiversity Areas

Eastern Cape Biodiversity Conservation Plan The ECBCP is a first attempt at detailed, low-level conservation mapping for land-use planning purposes. Specifically, the aims of the Plan were to map critical biodiversity areas through a systematic conservation planning process. The current biodiversity plan includes the mapping of priority aquatic features, land-use pressures, critical biodiversity areas and develops guidelines for land and resource-use planning and decision-making. The main outputs of the ECBCP are “critical biodiversity areas” or CBAs, which are allocated the following management categories:

1. CBA 1 = Maintain in a natural state 2. CBA 2 = Maintain in a near-natural state

The ECBCP map (Figure 5.2) for the project area shows that the entire project area is categorised as a CBA 2. The recommended land use management for areas classified as CBA 2 is described in Table 5-1: Table 5-1: Recommended land uses for the Class categories that fall within the project area (Farm portion) where the borrow pit occurs

Land use Class 2: (CBA 2) Transformed/ Degraded

Conservation Yes Yes

Game farming Yes Yes



Communal livestock Yes Yes

Commercial livestock ranching No Yes

Dry land cropping No Yes

Irrigated cropping No Yes

Dairy farming No Yes

Timber No Yes

Low density rural settlement No Yes

Low density urban settlement No Yes

High density urban settlement No Yes

*Conditional on environmental authorisation and catchment transformation thresholds CBA 2 areas should be managed to maintain the environment in a near-natural state. The borrow pit occurs in an area classified as a CBA 2 (i.e. in a near natural state).Since the area has already been transformed by the mining activities, a number of future land uses are applicable to the area, including livestock grazing which has been proposed by the proponent. Rehabilitation is important in this area and it is anticipated from the site visit that after good summer rains, the vegetation in the study area will re-establish itself and the current status will be improved

Figure 5-2: ECBCP map of the project area .



5.2 Site description Approximately 5.3 ha has been impacted on by activities associated with the borrow pit and the activities associated with the extension of the borrow pit for the NR6, Section 4 at Penhoek Pass road upgrade. Most of this area (5.3 ha) is still undergoing rehabilitation. Below are photographs showing an overview of the area disturbed due to the mining activities.

Plate 5-1: Site Photographs of the Rehabilitated Borrow Pit area The vegetation that was found in the surrounding areas of the borrow pit was grassland vegetation (Figure 5-2). In the Southern (upper) parts of the borrow pit, this vegetation was dominated by Themeda triandra (rooigras) which forms an almost continuous sward of almost 50% cover in this region (Figure 5-3). This area was somewhat disturbed which has resulted in more species being found. An increase in the number of species over time after a large scale disturbance event especially one that is caused by human activities is an attribute of ecological succession (Cadotte 2007). Whilst in the North (bottom) end of the site, undisturbed Themeda triandra (rooigras) occurred as a solid sward or mat with the only other species present being Felicia filifolia, Eragrostis curvula and Wahlenbergia stellariodes (Figure 5-4). Along the fence line the grass had been disturbed. In the top corner of the borrow pit area there were four Acacia karroo trees with the following grasses below the trees: Cynodon dactylon and Bromus catharticus. There were also the following weeds present Lepidium africanum, Solanum nigrum and Raphanus raphanisrum.

N W E S 31°28'47.3"S; 26°42'45.5"E



Plate 5-2: Photographs illustrates species Selago densiflora (A) and Gomphocarpus fruticosus (B) found to occur in the grassland vegetation.

Plate 5-3: Grassland vegetation found in the Southern (upper area) of the Site

A B



Plate 5-4: Acacia karroo trees found to occur in the top corner of the borrow pit area.

Plate 5-5: Grassland vegetation found to occur in the North (low lying area) of the Site, showing the disturbed area near the fence line.



Plate 5-6: Grassland vegetation starting to grow on the borrow pit area, when hydroseeding had not yet occurred.

Plate 5-7: Grassland vegetation starting to grow on the borrow pit area The borrow pit had resulted in the loss of vegetation, which has left a large portion of this area bare. The site visit (22 October 2015) revealed that some species have returned as a result of applying the topsoil. The site visit indicated that the area had been reshaped and levelled but hydro-seeding of this area had not yet taken place.

5.3 Species of special concern The species list from the site survey was assessed against the South African Red Data List, the National Environmental Management Biodiversity Act (NEM:BA) list of protected species, DAFF’s list of protected tree species, the IUCN and the PNCO. Only a single SCC species (Gomphocarpus fruticosus) was found to occur in the surrounding areas. This species is listed as Least Concern on the South African Red Data List and as a schedule 4 species on the PNCO list. Permits from DEDEAT will need to be obtained should this species be disturbed or removed during the rehabilitation of the borrow pit.



Table 5-2: Species of special concern found to occur in the project area according to PNCO, SANBI, IUCN ,DAFF’s tree list and NEM:BA

Family Scientific Name

SA Red list IUCN PNCO NEM:BA

APOCYNACEAE Gomphocarpus fruticosus

Least Concern

- - Schedule 4

5.4 Alien Species A number of alien and weedy species were found to occur in the patches of grass surrounding the bare areas. Alien species and their category were assessed according to the Alien and Invasive Species Regulations (published 1 August 2014) (as seen in Table 5-3). However previous environmental audits of the site and the current site visit indicate that there has been active management in dealing with alien and invasive species. The removal of alien species should be an on-going process. The surrounding area had Agave spp and Pinus spp, these do not form part of the EMP or study area. Table 5-3: Alien invasive species found in the borrow pit area according to NEM:BA

Species Category Comment

Argemone ochroleuca 1b According to the National Environmental Management: Biodiversity Act, 2004 control and eradication of a listed invasive species must be carried out by means and methods appropriate for the species concerned and the environment in which it occurs. This must be done in a way that causes the least possible harm to the environment and surrounding biodiversity. The methods used to eradicate these species must also be directed at the offspring, propagating material and re-growth of invasive species in order to prevent such species from regenerating and re-establishing themselves.



Plate 5-8: Photograph of alien invasive species Argemone ochroleuca According to Mucina and Rutherford (2006) “increased occurrence of alien Schkuhiria pinnata and Tagetes minuta indicates heavy disturbance”. Thus the establishment of certain species such as the above which are not on the NEM:BA list should also be avoided in the area. The species which occur in the area will also be an indication of the stage of rehabilitation, thus it is not only about the establishment of vegetation on the affected area, but also what is occurring in the area.



6 DESCRIPTION OF IMPACTS

6.1 Decommissioning / Post-closure Phase This phase assesses the impacts associated with the post-closure phase of the Penhoek Borrow Pit. The “No Go” option was not considered, as it would result in the same results as the “Without mitigation” option as the impacts are already present in the project area. Impact 1: Invasion of alien invasive plant species Cause and Comment: A single alien invasive species (Argemone ochroleuca) was found to occur in the borrow pit and surrounding areas. A number of species such as Tagetes minuta and Schkuhria pinnata which are considered weeds and are undesirable but are not listed as an alien invasive species by the Alien and Invasive Species Regulations (2014) were also found. All these should be monitored and removed from the area, to ensure that only indigenous species establish in the borrow pit area. In the areas outside of the study area, Agave and Pinus species were found. These species should be controlled by the respective landowners. Environmental audits indicate that there has been active management of alien species on the study area and that there were strategies implemented for the control of alien invasive species on site. However, controlling for alien species is an ongoing task as seedlings continuously emerge from the seedbank. For this reason, it is recommended that this borrow pit is monitored for the next two years.

Impact

Effect Risk or

Likelihood Overall Significance Temporal

Scale Spatial Scale

Severity of Impact

Impact 1: Invasion of alien invasive plant species

Without Mitigation

Permanent Study Area Severe Definite HIGH-

With Mitigation

Short Term Study Area Low Beneficial Definite LOW+

Mitigation Measures:

o Monitoring and Maintenance of the area to ensure that there is control of alien species

on site. o Vegetation which has been cleared should be removed from the site and disposed of as

waste. o Removal of alien invasive species and weeds as they appear. o The establishment of indigenous species will assist with curbing the emergence of

undesirable species from the existing seedbank.

Impact 2: Wind Erosion caused by large unvegetated areas Cause and Comment: The mining activities associated with the borrow pit has resulted in the clearance of natural vegetation. This has resulted in a large area of unvegetated, bare soil that is susceptible to wind erosion. Even though the area has been recently seeded, a cover crop that will bind the soil has not yet been established on the site The condition of the soil and the current state of this area suggests that a cover crop can be established under favourable conditions. Significance Statement:

Impact Effect Risk or

Likelihood Overall Significance

Temporal Spatial Scale Severity of



Scale Impact

Impact 2: wind erosion caused by large areas of unvegetated soil

Without Mitigation

Short Term Study Area Moderate Probable MODERATE-

With Mitigation

Short Term Study Area Slight Unlikely LOW-


Should a cover crop not establish other methods should be employed such as using cuttings of indigenous plants from the surrounding area and mulch.

Seeds should be planted during the rainy season to give them the best chance of survival.

During the dry season, bare areas should be watered to allow for germination of the planted seeds.

Impact 3: Pollution of nearby streams Cause and Comment: Without vegetation to bind the soil in the borrow pit area, heavy rainfall events will result in the topsoil eroding and washing away into nearby rivers causing an increase in turbidity. The pollution of watercourses will affect the quality of these systems (including aquatic fish such as amphibians and fish). However, this impact is considered to be minor due to the distance of nearby watercourses from the borrow pit. Significance Statement:

Impact

Effect Risk or


Scale Spatial Scale

Severity of Impact

Impact 3: Pollution of nearby streams

Without Mitigation

Long Term Study Area Moderate May Occur MODERATE-

With Mitigation



Encourage the establishment of indigenous vegetation in the area.

Should a cover crop not establish other methods must be employed such as using cuttings of indigenous plants from the surrounding area and mulch.

Seeds should be planted during the rainy season to give them the best chance of survival.

During the dry season, bare areas should be watered to allow for germination of the planted seeds.

Impact 4: Generation of dust as a nuisance factor Cause and Comment: Some dust may be generated as a result of the exposed ground. The generation of dust may be higher during windy, dry periods. Dust may be a nuisance to the neighbours and also people who use the NR6 Road which is adjacent to the borrow pit. It is therefore imperative that the borrow pit is re-vegetated as soon as possible. Significance Statement:



Impact

Effect Risk or


Scale Spatial Scale

Severity of Impact

Impact 4: Generation of dust as a nuisance factor

Without Mitigation

Long Term Study Area Moderate Probable MODERATE-

With Mitigation



Employ dust suppression measures such as wetting of the study area during dry, windy periods.

Encourage the establishment of vegetation in the area

Impact 5: Lack of establishment of vegetation due to soil compaction Cause and Comment: The soil has been compacted by construction vehicles during the operation phase of the borrow pit and during rehabilitation (clearing of the site, removal of storage units etc.). Sowing in soil that is compacted or soil with a ‘crust’ will result in the seed being washed away after the first rains. The site visit indicated that during rehabilitation of this area, soil has been loosened in some areas but not in other areas (as per Site visit on 22 October 2015, and Audit report 21 (16 October 2015)). Re-vegetation is unlikely to occur in compacted areas resulting in erosion, dust and run-off. Significance Statement:

Impact

Effect Risk or


Scale Spatial Scale

Severity of Impact

Impact 5: Lack of establishment of vegetation due to soil compaction

Without Mitigation

Short Term Localised Slight Definite LOW-

With Mitigation

Short Term Localised Slight Unlikely LOW-


Loosening of compacted soil; this may include using rakes or sharp-pointed hoes.

No machinery or heavy vehicles should be allowed on the area after it has been sown as this may lead to further compaction of the soil.

Impact 6: Lack of establishment of vegetation due to poor soil properties Cause and Comment: Due to the mining activity which has occurred at the borrow pit, the soil properties may have been altered and may therefore not be ideal for the establishment of indigenous pioneer species. It is important that there are nutrients and moisture (water) available in the soil for plant establishment in the area. During the rehabilitation activity, soil in this area has been improved by application of Superphosphate (fertilizer containing plant-available sulphur and phosphate), topsoil and mulch to improve the soil properties and encourage the establishment of indigenous vegetation in this area.



Significance Statement:

Impact

Effect Risk or


Scale Spatial Scale

Severity of Impact

Impact 6: Lack of establishment of vegetation due to poor soil properties

Without Mitigation

Short Term Study Area Moderate Definite MODERATE-

With Mitigation

Short Term Localised Moderate May Occur LOW-


Improvement of soil properties will encourage the establishment of vegetation in this area.

The Applicant has applied rehabilitation measures to improve the soil properties, monitoring of the area will help determine if there is any establishment of vegetation in the area

Impact 7: Low Aesthetic Appeal Cause and Comment: The area does not currently look like the surrounding areas as it remains devoid of vegetation and is therefore not aesthetically pleasing to the neighbouring landowners and motorists that use the NR6. However, it has been levelled out and this will be compatible with the surrounding area once it has been rehabilitated. Significance Statement:

Impact

Effect

Risk or Likelihood

Overall Significance Temporal Scale

Spatial Scale Severity of

Impact

Impact 7: Low Aesthetic Appeal

Without Mitigation

Long Term Study Area Moderate Definite MODERATE-

With Mitigation



The establishment of vegetation and the area being integrated to the surrounding areas will reduce this impact.



7 IMPACT STATEMENT, CONCLUSION AND RECOMMENDATION

7.1 Conclusions SANRAL plans to obtain a closure certificate for the borrow pit associated with the NR6, Section 4 at Penhoek Pass which occurred on a section of remaining extent of Farm Valschfontein No.180, in the Sterkstroom area. Three impacts have been identified as a result of the mining activity which occurred on site and are summarised in Table 7-1. These impacts need to be mitigated to ensure that the area left is environmentally sustainable. Associated impacts identified with the Borrow Pit area were not deemed insurmountable. Table 7-1: Summary of impacts associated with the Borrow pit pre and post mitigation.

Impact Pre-Mitigation Post-Mitigation

Post closure Phase

Impact 1: Invasion of alien invasive plant species HIGH - LOW+

Impact 2: Wind Erosion caused by large unvegetated areas

MOD- LOW-

Impact 3: Pollution of nearby streams MOD- LOW-

Impact 4: Generation of dust as a nuisance factor MOD- LOW-

Impact 5: Lack of establishment of vegetation due to soil compaction

LOW- LOW-

Impact 6: Lack of establishment of vegetation due to poor soil properties

MOD- LOW-

Impact 7: Low Aesthetic Appeal MOD- LOW-

7.2 Recommendations

It is essential that rehabilitation continues on the site and that the recommendations provided are applied, to ensure that the area returns in a natural state or near natural state. Alien invasive species should be managed effectively to prevent them becoming problematic in the study area and greater project area. For this reason the following is recommended:

7.2.1 Rehabilitation

Since the rehabilitation of an area is a process that requires a number of years before the area returns to the desired state, it is recommended that the success of the rehabilitation is monitored for the next two years to

Determine if the rehabilitation was a success

Determine if there is a return of indigenous species in the area

Determine areas the rehabilitation is not working and implement other strategies to improve the disturbed area.

Ensure that there is removal of invasive alien species in this area.

Determine erosion potential of the area

Assess general site condition

7.2.2 Invasion of alien species Any form of disturbance to the natural vegetation provides a gateway for alien species to invade the site of disturbance. In this regard, a single alien invasive species (Argemone ochroleuca) was found onsite which could hinder the progress of rehabilitation on site and if infestation were



significant, may result in the project not being given a closure certificate. It is recommended that a monitoring plan be implemented to monitor the additional spread and the removal of alien species already present on site is continued as per the recommendations set out in the Environmental Management Plan.



REFERENCES Cadotte M.W., (2007) Competition–Colonization trade –offs and disturbance effects at multiple scales. Ecology, 88[4] 823–829pp. Mucina, L. & Rutherford, M.C. (eds) 2006. The vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria. Klages, 2013: Environmental Management Plan for the Use of a Hard Rock Quarry and a Borrow Pit in Upgrading the National Route 6, section 4, south of and at Penhoek Pass between kilometres 52.0 and 66.2. Turner, B. R. (1981). Revised stratigraphy of the Beaufort Group in the southern Karoo Basin.


Coastal & Environmental Services 31 ` SANRAL

APPENDIX A – MINE PLAN


Coastal & Environmental Services 32 ` SANRAL



APPENDIX B: SPECIES LIST

Family Scientific Name SA Red list IUCN NEM:BA PNCO CITES Protected Tree List

Alien and Invasive Species

APOCYNACEAE Gomphocarpus fruticosus

Least Concern

- - Schedule 4 - - -

ASCLEPIADACEAE Schizoglossum sp. - - - - - - -

ASPHODELACEAE Trachyandra sp. - - - - - - -

ASTERACEAE Arctotis arctotoides Least Concern

- - - - - -

ASTERACEAE Berkheya decurrens Least Concern

- - - - - -

ASTERACEAE Chrysocoma ciliata Least Concern

- - - - - -

ASTERACEAE Conyza canadensis Not Evaluated

- - - - - -

ASTERACEAE Felicia filifolia Least Concern

- - - - - -

ASTERACEAE Gazania krebsiana Least Concern

- - - - - -

ASTERACEAE Helichrysium sp.1 - - - - - - -

ASTERACEAE Helichrysum sp. - - - - - - -

ASTERACEAE Helichrysum nudifolium

Least Concern

- - - - - -

ASTERACEAE Nidorella sp. - - - - - - -

ASTERACEAE Schkuhria pinnata Not Evaluated

- - - - - -

ASTERACEAE Senecio sp. - - - - - - -

ASTERACEAE Tagetes minuta Not Evaluated

- - - - - -

ASTERACEAE Xanthium spinosum Not Evaluated

- - - - - -

BRASSICACEAE Lepidium africanum Least - - - - - -



Concern

BRASSICACEAE Raphanus raphanistrum

Not Evaluated

- - - - - -

CAMPANULACEAE Wahlenbergia stellariodes

- - - - - - -

CONVOLVULACEAE Convolvulus natalensis

Least Concern

- - - - - -

CYPERACEAE Cyperus esculentus Least Concern

Least Concern

- - - - -

DIPSACACEAE Scabiosa columbaria Least Concern

- - - - - -

FABACEAE Acacia karroo Least Concern

- - - - - -

FABACEAE Sutherlandia sp. - - - - - - -

GERANIACEAE Pelargonium sp. - - - - - - -

MALVACEAE Hermannia sp. - - - - - - -

ONAGRACEAE Oenothera stricta Not Evaluated

- - - - - -

PAPAVERACEAE Argemone ochroleuca Not Evaluated

- - - - - 1B

PLANTAGINACEAE Plantago lanceolata Least Concern

Vulnerable - - - - -

POACEAE Bromus catharticus Not Evaluated

- - - - - -

POACEAE Cymbopogon sp. - - - - - - -

POACEAE Digitaria eriantha Least Concern

- - - - - -

POACEAE Eragrostis chloromelas

Least Concern

- - - - - -

POACEAE Eragrostis curvula Least Concern

- - - - - -

POACEAE Eragrostis racemosa Least Concern

- - - - - -

POACEAE Heteropogon contortus

Least Concern

- - - - - -



POACEAE Pentaschistis microphylla

Least Concern

- - - - - -

POACEAE Sporobolis sp. - - - - - - -

POACEAE Themeda triandra Least Concern

- - - - - -

POLYGALACEAE Polygala hottentotta Least Concern

- - - - - -

SCROPHULARIACEAE Selago densiflora Least Concern

- - - - - -

SOLANACEAE Solanum nigrum Not Evaluated

- - - - - -

THYMELEACEAE Gnida anthylloides - - - - - - -

vegetation assessment for the closure project … of borrow pit...vegetation assessment for the...

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