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APPENDIX 16

AQUATIC ASSESSMENT

Aquatic Assessment for the proposed

Adit and Open Cast Mining Area at the

Zululand Anthracite Colliery (ZAC)

Zululand District Municipality,

KwaZulu-Natal

April 2019

Reference

17-1186

CLIENT

Prepared for:

GCS Water & Environmental Consultants

4a Old Main Road, Judges Walk, Kloof, 3610,

KwaZulu-Natal, South Africa

Prepared by:

The Biodiversity Company

420 Vale Ave. Ferndale, 2194

Cell: +27 81 319 1225

Fax: +27 86 527 1965

[email protected]

www.thebiodiversitycompanycom

mailto:[email protected]

Aquatic Ecology Assessment 2018 ZAC New Mngeni Adit and Deep E Open Cast Mine

www.thebiodiversitycompany.com

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Flood conditions at Site BM2 on the Black Mfolozi River (March 2018)

Report Name Aquatic Assessment for the proposed Adit and Open Cast

Mining Area at the Zululand Anthracite Colliery (ZAC)

Submitted to GCS (Pty) Ltd

Report

Dale Kindler (Pr. Sci. Nat. 114743)

Dale Kindler is Pr. Sci. Nat. registered (114743) in the Aquatic Science field of practice and is an experienced aquatic ecologist. He has over 5 years of experience conducting aquatic assessments across southern Africa, Guinea and Mozambique. Dale Kindler has a good technical understanding on the variable conditions within Southern African rivers as well as their biological compositions. This has allowed Dale Kindler to gain knowledge of a diversity of freshwater ecoregions within Africa.

Review Christian Fry

(Pr. Sci. Nat. 119082)

Declaration

The Biodiversity Company and its associates operate as independent consultants under the auspice of the South African Council for Natural Scientific Professions. We declare that we have no affiliation with or vested financial interests in the proponent, other than for work performed under the Ecological Assessment Regulations, 2017. We have no conflicting interests in the undertaking of this activity and have no interests in secondary developments resulting from the authorisation of this project. We have no vested interest in the project, other than to provide a professional service within the constraints of the project (timing, time and budget) based on the principals of science.



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EXECUTIVE SUMMARY

Specialist Opinion

Considering the status of the aquatic ecosystems, and furthermore the nature and requirements of

the project, the proposed project has the potential to negatively affect local riverine ecology in the

long term. In light of the above mentioned, it is the opinion of the specialist that provided the new adit

Alternative 2 is chosen and adequate mitigation measures implemented for all project related

activities, the potential negative impacts can be addressed and minimized.

The Biodiversity Company was commissioned to conduct an aquatic baseline assessment for

the development of a new opencast coal mining pit and an underground coal extraction shaft

at the existing Zululand Anthracite Colliery (ZAC) located in Emakhalathini, KwaZulu-Natal,

South Africa. These developments are to take place within the existing mineral rights area of

ZAC Colliery.

The proposed project will trigger several environmental conditions and therefore requires an

Environmental Impact Assessment (EIA) and Water Use Licence Application (WULA) before

the project can commence.

To complete the EIA and WULA, environmental specialist studies were required. Considering

this, The Biodiversity Company was commissioned by GCS Water & Environmental

Consultants to conduct aquatic ecology specialist studies to supplement the abovementioned

application. This report presents the results of a baseline aquatic ecological study on the

riverine environments associated with the proposed project area.

The proposed project is located approximately 6.5 km north-east of existing operations at ZAC.

The project area is further situated approximately 4.4 km north-west of the Hluhluwe-Imfolozi

Game Reserve. The proposed project is located in the Pongola-Mtamvuna Water

Management Area (WMA), within the W22J quaternary catchment. The watercourses within

the project area drain into the Black Mfolozi River which flows in an easterly direction into the

Indian Ocean. The water course comprises of three Sub Quaternary Reaches (SQR); the

W22J-2942 SQR is a reach of the Mvalo River; the W22J-2910 and W22J-2817 SQR’s are

reaches of the Black Mfolozi Rivers, respectively. According to the National Freshwater

Ecological Priority Areas (NFEPA’s) all three quaternary catchments are listed as Upstream

management areas which need to be actively managed to maintain water quality for

downstream river FEPA’s (Nel et al., 2011).

Standard methodologies were used to determine the Present Ecological Status (PES),

Ecological Importance and Sensitivity for the aquatic ecology components of this study.

The results of the PES assessment derived largely modified (class D) conditions in the Black

Mfolozi river reach considered in this assessment. It is noted that flood conditions have likely

lowered the respective ecological categories due to the underestimation of aquatic biota

present under normal flow conditions. Instream habitat modification has resulted in modified

biological responses. Instream habitat modification can be attributed to largescale catchment



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erosion and sedimentation including local agricultural activities, which has inundated much of

the instream habitat.

Similarly, the PES assessment derived largely modified (class D) conditions in the Mvalo River

reach. Limited instream habitat diversity and water quality impairment have resulted in

modified aquatic ecology. The modification of the watercourse is likely attributed to catchment

related activities and the naturally low habitat availability at the sample site.

The results of the PES assessment derived largely modified (class D) conditions in the Mngeni

River reach considered in this assessment. Post flood conditions have contributed towards an

underestimation of aquatic biota. Modified biological responses in the river reach are indicative

of instream and riparian habitat modifications. The modifications can be attributed to

landscape level impacts associated with agricultural activities higher up in the river reach.

A single red listed fish species is expected within the river reaches in the study area

Oreochromis mossambicus (Near Threatened {NT}). O. mossambicus is threatened by

hybridisation with O. niloticus and therefore the proposed project does not pose a threat to

this species.

It is noted that flood conditions have skewed the baseline assessment results with an

underestimation of aquatic biota present under normal flow conditions. This was reflected by

the low representation of fish species sampled. In order to address this gap, data from desktop

sources were utilised to establish ecological sensitivity. It is however recommended that an

additional survey is conducted to obtain defined ecological conditions in the watercourses

directly associated with the proposed project. This proposed survey should be conducted in

during the initiation of the construction phase along with standard continuous (Life of Mine) bi-

annual aquatic biomonitoring.

The results of the risk assessment derived moderate to high risks with a single low risk for the

proposed project. Majority of the risks can be lowered in risk status through the implementation

of appropriate mitigation. The proposed open cast pit and new adit Alternative 2 areas lay

outside of aquatic areas and therefore will not require any excavations within aquatic areas or

river diversions. The project needs to pay special attention to and cater for the funding and

management of Acid Mine Drainage associated with the closure and post-closure phases as

this poses the greatest threat to aquatic ecology extending from the local ZAC project area to

further downstream areas (Black Mfolozi River to the coast - regionally).



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DOCUMENT GUIDE

The table below provides the NEMA (2014) Requirements for Ecological Assessments, and

the relevant sections in the reports where these requirements are addressed:

GNR 326 Description Section in the

Report

Specialist Report

Appendix 6

(a)

A specialist report prepared in terms of these Regulations must contain—

details of—

i. the specialist who prepared the report; and

ii. the expertise of that specialist to compile a specialist report including a

curriculum vitae;

Page i

Appendix 6

(b)

A declaration that the specialist is independent in a form as may be specified by

the competent authority; Page vi

Appendix 6

(c) An indication of the scope of, and the purpose for which, the report was prepared; Section 1

Appendix 6

(cA) An indication of the quality and age of base data used for the specialist report; Section 5

Appendix 6

(cB) A description of existing impacts on the site, cumulative impacts of the proposed development and levels of acceptable change; Section 8

Appendix 6

(d) The duration, date and season of the site investigation and the relevance of the season to the outcome of the assessment; Section 3

Appendix 6

(e) A description of the methodology adopted in preparing the report or carrying out the specialised process inclusive of equipment and modelling used; Section 3

Appendix 6 (f) Details of an assessment of the specific identified sensitivity of the site related to the proposed activity or activities and its associated structures and infrastructure, inclusive of a, site plan identifying site alternatives;

Section 7

Appendix 6

(g) An identification of any areas to be avoided, including buffers; Section 7

Appendix 6

(h)

A map superimposing the activity including the associated structures and infrastructure on the environmental sensitivities of the site including areas to be avoided, including buffers;

Section 7

Appendix 6 (i) A description of any assumptions made and any uncertainties or gaps in knowledge; Section 5

Appendix 6 (j) A description of the findings and potential implications of such findings on the impact of the proposed activity [including identified alternatives on the environment] or activities;

Section 8

Appendix 6

(k) Any mitigation measures for inclusion in the EMPr; Section 8

Appendix 6 (l) Any conditions for inclusion in the environmental authorisation; Section 9

Appendix 6

(m) Any monitoring requirements for inclusion in the EMPr or environmental authorisation; Section 8



v

GNR 326 Description Section in the

Report

Appendix 6

(n)

A reasoned opinion— i. [as to] whether the proposed activity, activities or portions thereof

should be authorised; (iA) regarding the acceptability of the proposed activity or activities; and

ii. if the opinion is that the proposed activity, activities or portions thereof should be authorised, any avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan;

Section 9

Appendix 6

(o) A description of any consultation process that was undertaken during the course of preparing the specialist report; Not applicable

Appendix 6

(p)

A summary and copies of any comments received during any consultation

process and where applicable all responses thereto; and Not applicable

Appendix 6

(q) Any other information requested by the competent authority. None



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Declaration

I, Dale Kindler declare that:

I act as the independent specialist in this application;

I will perform the work relating to the application in an objective manner, even if this

results in views and findings that are not favourable to the applicant;

I declare that there are no circumstances that may compromise my objectivity in

performing such work;

I have expertise in conducting the specialist report relevant to this application, including

knowledge of the Act, regulations and any guidelines that have relevance to the

proposed activity;

I will comply with the Act, regulations and all other applicable legislation;

I have no, and will not engage in, conflicting interests in the undertaking of the activity;

I undertake to disclose to the applicant and the competent authority all material

information in my possession that reasonably has or may have the potential of

influencing any decision to be taken with respect to the application by the competent

authority; and the objectivity of any report, plan or document to be prepared by myself

for submission to the competent authority;

All the particulars furnished by me in this form are true and correct; and

I realise that a false declaration is an offence in terms of Regulation 71 and is

punishable in terms of Section 24F of the Act.

Dale Kindler

Aquatic Specialist

The Biodiversity Company

10/04/2019



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Table of Contents

1 Introduction and Project Background ............................................................................. 1

2 Description of the Project Area ....................................................................................... 2

2.1 The Watercourses of the Pongola-Mtamvuna Water Management Area ................. 3

3 Methodology .................................................................................................................. 6

3.1 Aquatic Assessment and Survey ............................................................................. 6

3.1.1 Sampling Points ............................................................................................... 6

3.1.2 Water Quality ................................................................................................... 2

3.1.3 Aquatic Habitat Integrity ................................................................................... 2

3.1.4 Aquatic Macroinvertebrate Assessment ........................................................... 3

3.1.5 Fish Community Assessment ........................................................................... 5

3.1.6 Present Ecological Status ................................................................................ 5

3.2 Impact Assessment ................................................................................................. 5

4 Key Legislative Requirements ........................................................................................ 7

4.1 National Water Act (NWA, 1998) ............................................................................. 7

4.2 National Environmental Management Act (NEMA, 1998) ........................................ 7

5 Limitations and Assumptions.......................................................................................... 7

6 Results and Discussion .................................................................................................. 9

6.1 Water Quality .......................................................................................................... 9

6.2 Intermediate Habitat Integrity Assessment ............................................................ 10

6.3 Aquatic Macroinvertebrate Assessment ................................................................ 13

6.3.1 Macroinvertebrate Habitat .............................................................................. 13

6.3.2 Macroinvertebrate Community Assessment ................................................... 14

6.4 Fish Community .................................................................................................... 17

6.5 Overall Aquatic Ecology Present Ecological Status ............................................... 20

7 Aquatic Ecological Importance and Sensitivity (No-Go Area’s) ..................................... 21

7.1 Ecological Importance and Sensitivity ................................................................... 21

Spatial Sensitivity Assessment ........................................................................................ 22

8 Impact Assessment and Recommendations ................................................................ 26

8.1 Existing impacts .................................................................................................... 26

8.2 Proposed Project Activities ................................................................................... 27



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8.3 Potential Impacts .................................................................................................. 27

8.4 Detailed Potential Impacts Anticipated for the Proposed Project ........................... 29

8.4.1 Construction Phase........................................................................................ 29

8.4.2 Operation Phase ............................................................................................ 29

8.4.3 Decommissioning and Closure Phase ........................................................... 29

8.4.4 Post Closure .................................................................................................. 30

8.4.5 Unplanned Events ......................................................................................... 30

8.5 Assessment of Significance .................................................................................. 30

8.6 Mitigation Actions for Potential Impacts ................................................................. 38

8.7 Recommendations and Environmental Management Plan .................................... 40

9 Conclusion ................................................................................................................... 42

9.1 Baseline Ecology .................................................................................................. 42

9.2 Risk Assessment .................................................................................................. 42

9.3 Specialist Recommendation .................................................................................. 43

10 References ............................................................................................................... 44



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Tables

Table 1: The desktop information pertaining to the W22J-2817 and W22J-2910 Sub

Quaternary Reaches (DWS, 2018) ........................................................................................ 3

Table 2: The desktop information pertaining to the W22J-2942 Sub Quaternary Reach (DWS,

2018) .................................................................................................................................... 3

Table 3: Location of the Aquatic Sampling Points ................................................................. 6

Table 4: Criteria used in the assessment of habitat integrity (Kleynhans, 1996) .................... 2

Table 5: Descriptions used for the ratings of the various habitat criteria ................................ 3

Table 6: Impact methodology ranking scales ........................................................................ 6

Table 7: Impact significance ratings ...................................................................................... 6

Table 8: Water Quality Results March 2018 .......................................................................... 9

Table 9: Instream Intermediate Habitat Integrity Assessment for the Black Mfolozi River .... 10

Table 10: Instream Intermediate Habitat Integrity Assessment for the Mvalo River ............. 11

Table 11: Instream Intermediate Habitat Integrity Assessment for the Mngeni River ........... 12

Table 12: Biotope Scores recorded during the March 2018 Survey ..................................... 13

Table 13: Macroinvertebrate Assessment Results Recorded in the Project Area (March 2018)

........................................................................................................................................... 14

Table 14: Macroinvertebrate Response Assessment Index for the Black Mfolozi River based

on results obtained in March 2018 ...................................................................................... 16

Table 15: Macroinvertebrate Response Assessment Index for the Mvalo River based on

results obtained in March 2018 ........................................................................................... 16

Table 16: Macroinvertebrate Response Assessment Index for the Mngeni River based on

results obtained in March 2018 ........................................................................................... 17

Table 17: Fish Community Assessment for the Watercourses in the Project Area .............. 18

Table 18: Fish Species Observed during the March 2018 Survey ....................................... 19

Table 19: Fish Response Assessment Index for the Black Mfolozi River............................. 19

Table 20: Fish Response Assessment Index for the Mvalo River ........................................ 19

Table 21: Fish Response Assessment Index for the Mngeni River ...................................... 20

Table 22: Present Ecological Status of the Black Mfolozi River reach ................................. 20

Table 23: Present Ecological Status of the Mvalo River reach ............................................ 20

Table 24: Present Ecological Status of the Mngeni River reach .......................................... 21

Table 25: Ecological Importance and Sensitivity Ratings for the Watercourses in the Study

Area .................................................................................................................................... 21



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Table 26: Unplanned Events, Low Risks and their Management Measures ........................ 30

Table 27:Impact significance summary Construction Phase ................................................ 32

Table 28: Impact significance summary Operational Phase ................................................ 34

Table 29: Impact significance summary Closure Phase ...................................................... 36

Table 30: Impact significance summary Cumulative impacts ............................................... 37

Table 31: Environmental Monitoring Programme ................................................................ 41

Table 32: Proposed Resource Management Objectives for Instream Habitat and Biota in the

Project Area ........................................................................................................................ 41

Figures

Figure 1: Locality map of the proposed project ...................................................................... 2

Figure 2: Freshwater Fish Species Richness of the Freshwater Ecoregions of the World ..... 4

Figure 3: NFEPA Upstream management areas 2910 and 2817 in close proximity to River

NFEPAs. Red arrow indicates location of Open Cast area, green arrow indicates New Adit

and Purple arrows indicates existing ZAC operation (Nel et al., 2011) .................................. 5

Figure 4: Location of Aquatic Sampling Points in Relation to Project Infrastructure ............... 1

Figure 5: Guidelines used for the interpretation and classification of the SASS5 scores (Dallas,

2007) .................................................................................................................................... 4

Figure 6: pH and Electrical Conductivity spatial results for the baseline survey ..................... 9

Figure 7 : Bank incision and colapsing banks, loss of riparian habitat in Mngeni River ........ 13

Figure 8: Aquatic Habitat: A) Mvalo River @ MV1; B) Black Mfolozi River @ BM2 (March 2018)

........................................................................................................................................... 14

Figure 9: Oligoneuridae (Small minnow flies) example found at BM2 (March 2018) ............ 15

Figure 10: Fast flowing water over the stone habitat found at BM2 (March 2018) ............... 15

Figure 11: Leptophlebiidae (Prongills) example found at MG1 and MV1 (March 2018) ....... 15

Figure 12: Tricorythidae (Stout Crawlers) example found at BM1 and BM2 (March 2018) .. 16

Figure 13: Sensitive Aquatic Habitats associated with the Deep E open cast area .............. 23

Figure 14: Sensitive Aquatic Habitats associated with the New Adit Alternative 1 ............... 24

Figure 15: Sensitive Aquatic Habitats associated with the New Adit Alternative 2 ............... 25

Figure 16: The mitigation hierarchy as described by the DEA (2013) .................................. 26



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1 Introduction and Project Background

The modification of land use within a river catchment has the potential to degrade local water

resources (Wepener et al., 2005). Proposed developments thus have the potential to

negatively impact on local water resources and ecosystem services. To holistically manage

water resources in South Africa, the use of standard water quality sampling methods is

considered in-effective. Non-point and point source pollutants are dynamic and can fluctuate

according to various factors such as rainfall and human error. Aquatic ecology is permanently

exposed to the dynamic conditions within waterbodies and can therefore be an effective

reflection of the environmental conditions within a management area. Considering this, the

monitoring of aquatic ecology is regarded as an effective tool in water management strategies.

The Biodiversity Company was commissioned by GCS Water & Environmental Consultants to

conduct an aquatic baseline assessment as part of the environmental authorisation process,

Environmental Impact Assessment (EIA) and Water Use Licence Application (WULA) process

for the development of the Deep E Open Cast Mine and the New Mngeni Adit associated with

the Zululand Anthracite Colliery (ZAC). The project area is located in the Emakhalathini area,

KwaZulu-Natal, South Africa.

The ZAC is proposing the development of a new opencast pit mining area for the abstraction

of a shallow body of anthracite (between 25 – 40 m deep) to the west of the existing Deep-E

shaft, and a new underground decline shaft (Mngeni Adit), located approximately 5,82 km to

the east of the opencast pit, all within ZACs existing mineral rights area. The ZAC mining area

is large and scattered as a number of shafts form part of the current mining operation.

Opencast pit mining area:

The pit will be approximately 380 x 145 m in extent. The combined footprint of the pit and

laydown areas (i.e. overburden & topsoil stockpiles) will be approximately 5 ha. The anthracite

body will be mined by using a roll-over open pit truck and shovel operation, commencing with

a box cut.

Supporting infrastructure will include stormwater management structures, security fencing,

site offices, hazardous chemical storage areas, ablution facilities and roads.

Mngeni shaft mining area:

The Mngeni shaft area comprised two (2) infrastructure layout alternatives:

Alternative 1 will include the development of an underground decline shaft, office block,

ablution block, workshop, pollution control dam (PCD), roads and pipelines. The total

development footprint will be approximately 7.9 ha in extent.

Alternative 2 will include the development of an underground decline shaft, salvage yard,

boundary berm, stockpile, security huts, break test ramps, parking bays, explosives delivery

bay, diesel bay, wash bay, storerooms, various office blocks, ablution block, sub-station,

conveyor, water reservoirs, workshop, silt trap, pollution control dam (PCD), roads and

pipelines. The total development footprint including underground areas will be approximately

15.8 ha in extent.



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This report, after taking into consideration the findings and recommendations provided by the

specialist herein, should inform and guide the Environmental Assessment Practitioner (EAP)

and regulatory authorities, enabling informed decision making, as to the ecological viability of

the proposed project.

The aim of the assessment was to provide information to guide the construction and operation

of the proposed development with respect to the current ecological state of the aquatic

ecosystems in the study area. As part of this assessment, the following objectives were

established:

Aquatic Ecology Studies Scope:

The determination of the baseline Present Ecological Status (PES) of the local river

systems;

Selection of infrastructure layout alternatives;

The evaluation of the extent of site-related impacts;

A risk assessment for the proposed development; and

The prescription of mitigation measures and recommendations for identified risks.

2 Description of the Project Area

The proposed new Mngeni Adit is situated approximately 6.5 km north-east and the Deep E

Open Cast Mine is approximately 4.2 km north-west of existing operations at ZAC with the

sites separated by Black Mfolozi, Mngeni and Mvalo rivers, KwaZulu-Natal Province, South

Africa. The project area is further situated approximately 4.4 km north-west of the Hluhluwe-

Imfolozi Game Reserve (Figure 1).

Figure 1: Locality map of the proposed project



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2.1 The Watercourses of the Pongola-Mtamvuna Water Management Area

The project area is located in the Pongola-Mtamvuna Water Management Area (WMA 4)

(NWA, 2016). The new Mngeni Adit and Deep E Open Cast Mine project areas are located in

the W22J quaternary catchment. The watercourses within the project area drain into the Black

Mfolozi River, an affluent of the Mfolozi River, which flows in an easterly direction into the

Indian Ocean. The watercourse comprises of three Sub Quaternary Reaches (SQR); the

W22J-2942 SQR is a reach of the Mvalo River; the W22J-2910 and W22J-2817 SQR’s are

reaches of the Black Mfolozi Rivers, respectively. Land use in the considered catchments

consists predominantly of dryland agriculture, rural settlements and mining.

For the purposes of this study, the desktop information on the potentially directly affected river

reaches are presented in Table 1 and Table 2.

Table 1: The desktop information pertaining to the W22J-2817 and W22J-2910 Sub Quaternary Reaches (DWS, 2018)

Component/Catchment W22J-2817 (Black Mfolozi)

Present Ecological Status Largely natural

Ecological Importance Class High

Ecological Sensitivity High

Default Ecological Category Largely natural

Component/Catchment W22J-2910 (Black Mfolozi)

Present Ecological Status Moderately modified




The desktop information for the W22J quaternary catchment indicated that the river reach

W22J-2817 SQR was in a largely natural status (class B) (DWS, 2018). The Ecological

Importance class for the river reach was defined as high with a high Ecological Sensitivity.

The default ecological category for the river reach was defined as largely natural. The Mngeni

River falls under the W22J-2817 SQR, therefore, desktop information would apply accordingly.

The PES of the W22J-2910 SQR was defined as moderately modified (class C) at a desktop

level. The Ecological Importance of the river reach was high with high ecological sensitivity.

The default ecological category for the SQR was derived to be largely natural.

Table 2: The desktop information pertaining to the W22J-2942 Sub Quaternary Reach (DWS, 2018)

Component/Catchment W22J-2942 (Mvalo)

Present Ecological Status Moderately modified






4

The PES of the W22J-2942 SQR was defined as moderately modified (class C) at a desktop

level. The Ecological Importance of the river reach was high with high ecological sensitivity.

The default ecological category for the SQR was derived to be largely natural.

The river reach considered in this project is situated in the lower reaches of the Black Mfolozi

River Basin. In light of the overall longitudinal river profile, as well as the specific gradients of

the Black Mfolozi River Basin and associated tributaries, the portion of rivers considered in

this assessment conforms to the geomorphological river zonation of upper and lower foothills

zone rivers (slope class D and E, respectively) (Rowntree et al. 2000; Rowntree and Ziervogel,

1999). These geoclasses represent lowland river systems based on their gentle gradients.

Characteristic features of this river system are gentle gradients with associated floodplain

structures. Considering this, marginal and aquatic vegetation are key components of the river

reach. The study area considered in this assessment is located within the Zambezian Lowveld

Freshwater Ecoregion. In comparison to more northern African river systems, the aquatic

fauna of the considered ecoregion is “lacking in diversity” (Scott et al., 2018). This ecoregion

is known to contain approximately 102-151 freshwater fish species of which 1-11 are known

to be endemic (Figure 2). The ecoregion is known to have increased flow rates during the

spring and summer seasons (September to March) and most of the indigenous fish species

breed during this period.

Figure 2: Freshwater Fish Species Richness of the Freshwater Ecoregions of the World

According to Nel et al., (2011) the Mvalo W22J-2942 SQR forms two National Freshwater

Priority Areas (NFEPA). The two River ecosystem type FEPAs are: Ephemeral - North Eastern

Uplands - Lowland river; and Ephemeral - North Eastern Uplands – Upper foothill. Additionally,

the two Black Mfolozi River SQRs (W22J-2910 and W22J-2817) are considered Upstream



5

Management Areas. These areas need to be managed to maintain water quality for

downstream river FEPA’s.

Figure 3: NFEPA Upstream management areas 2910 and 2817 in close proximity to River NFEPAs. Red arrow indicates location of Open Cast area, green arrow indicates

New Adit and Purple arrows indicates existing ZAC operation (Nel et al., 2011)

The project area river reaches form important upstream management areas for the Black

Mfolozi River and associated River FEPA (2916) located downstream, aiding in the protection

of riverine habitat supporting fish species potentially occurring within the reach. This

downstream River FEPA houses the Hluhluwe-Imfolozi Game Reserve.



6

3 Methodology

3.1 Aquatic Assessment and Survey

A single aquatic sampling survey was conducted on the 29th of March 2018. The sampling

during this period would constitute a late high flow assessment.

3.1.1 Sampling Points

The sampling points selected in this study were completed according to the proposed

infrastructure layout. Larger river systems were assessed to characterise the aquatic ecology

within the project area. The layout of the sampling points and details of the points are provided

in Table 3 and Figure 4.

Table 3: Location of the Aquatic Sampling Points

BM1

Upstream Downstream

GPS 28°12'1.39"S

31°40'32.97"E

Site description

Site BM1 was located upstream of ZAC and adjacent to the Open Cast Mine on the perennial Black Mfolozi River. The site presents the most upstream monitoring point. In situ water quality, SASS5, and fish community analyses were conducted at this site. The site was in spate during the survey.

MV1

Upstream Downstream

GPS 28°12'10.19"S 31°40'57.62"E



7

Site description

Site MV1 was located downstream of ZAC on the non-perennial Mvalo River. The Mvalo River is a tributary of the Black Mfolozi River. In situ water quality, SASS5, and fish community analyses were conducted at this site.

MG1

Upstream Downstream

GPS 28°10'47.67"S 31°42'52.72"E

Site description

Site MG1 was located downstream of ZAC on the perennial Mngeni River. The Mngeni River is a tributary of the Black Mfolozi River. The site was located upstream and adjacent to the New Adit. In situ water quality, SASS5, and fish community analyses were conducted at this site. The site was in spate prior to the survey.

BM2

Upstream Downstream

GPS 28°11'28.83"S 31°44'2.70"E

Site description

Site BM2 was located downstream of ZAC and the New Adit on the perennial Black Mfolozi River. The site presents the most downstream monitoring point. In situ water quality, SASS5, and fish community analyses were conducted at this site. The site was in spate during the survey.



1

Figure 4: Location of Aquatic Sampling Points in Relation to Project Infrastructure



2

3.1.2 Water Quality

Water quality was measured in situ using a handheld calibrated Extech ExStik II meter. The

constituents considered that were measured included: pH, electrical conductivity (µS/cm),

temperature (°C) and Dissolved Oxygen (DO) in mg/l.

3.1.3 Aquatic Habitat Integrity

The Intermediate Habitat Assessment Index (IHIA) as described in the Procedure for Rapid

Determination of Resource Directed Measures for River Ecosystems (Section D), (1999) was

used to define the ecological status of the river reach.

The area covered in this component of the study is outlined as follows. In the Pongola-

Mtamvuna WMA, the following river reaches were assessed individually according to their

location in an SQR:

1. W22J-2910 and W22J-2817 (Black Mfolozi River)

2. W22J-2942 (Mvalo)

3. Mngeni River

The IHIA model was used to assess the integrity of the habitats from a riparian and instream

perspective. The habitat integrity of a river refers to the maintenance of a balanced

composition of physico-chemical and habitat characteristics on a temporal and spatial scale

that are comparable to the characteristics of natural habitats of the region (Kleynhans, 1996).

The criteria and ratings utilised in the assessment of habitat integrity in the current study are

presented in Table 4 and Table 5 respectively.

Table 4: Criteria used in the assessment of habitat integrity (Kleynhans, 1996)

Criterion Relevance

Water abstraction Direct impact on habitat type, abundance and size. Also implicated in flow, bed, channel and water quality characteristics. Riparian vegetation may be influenced by a decrease in the supply of water.

Flow modification

Consequence of abstraction or regulation by impoundments. Changes in temporal and spatial characteristics of flow can have an impact on habitat attributes such as an increase in duration of low flow season, resulting in low availability of certain habitat types or water at the start of the breeding, flowering or growing season.

Bed modification

Regarded as the result of increased input of sediment from the catchment or a decrease in the ability of the river to transport sediment. Indirect indications of sedimentation are stream bank and catchment erosion. Purposeful alteration of the stream bed, e.g. the removal of rapids for navigation is also included.

Channel modification May be the result of a change in flow, which may alter channel characteristics causing a change in marginal instream and riparian habitat. Purposeful channel modification to improve drainage is also included.

Water quality modification

Originates from point and diffuse point sources. Measured directly or alternatively agricultural activities, human settlements and industrial activities may indicate the likelihood of modification. Aggravated by a decrease in the volume of water during low or no flow conditions.

Inundation Destruction of riffle, rapid and riparian zone habitat. Obstruction to the movement of aquatic fauna and influences water quality and the movement of sediments.

Exotic macrophytes Alteration of habitat by obstruction of flow and may influence water quality. Dependent upon the species involved and scale of infestation.

Exotic aquatic fauna The disturbance of the stream bottom during feeding may influence the water quality and increase turbidity. Dependent upon the species involved and their abundance.

Solid waste disposal A direct anthropogenic impact which may alter habitat structurally. Also, a general indication of the misuse and mismanagement of the river.



3

Criterion Relevance

Indigenous vegetation removal

Impairment of the buffer the vegetation forms to the movement of sediment and other catchment runoff products into the river. Refers to physical removal for farming, firewood and overgrazing.

Exotic vegetation encroachment

Excludes natural vegetation due to vigorous growth, causing bank instability and decreasing the buffering function of the riparian zone. Allochtonous organic matter input will also be changed. Riparian zone habitat diversity is also reduced.

Bank erosion

Decrease in bank stability will cause sedimentation and possible collapse of the river bank resulting in a loss or modification of both instream and riparian habitats. Increased erosion can be the result of natural vegetation removal, overgrazing or exotic vegetation encroachment.

Table 5: Descriptions used for the ratings of the various habitat criteria

Impact

Category Description Score

None No discernible impact or the modification is located in such a way that it has

no impact on habitat quality, diversity, size and variability. 0

Small The modification is limited to very few localities and the impact on habitat

quality, diversity, size and variability are also very small. 1-5

Moderate The modifications are present at a small number of localities and the impact

on habitat quality, diversity, size and variability are also limited. 6-10

Large

The modification is generally present with a clearly detrimental impact on

habitat quality, diversity, size and variability. Large areas are, however, not

influenced.

11-15

Serious

The modification is frequently present and the habitat quality, diversity, size

and variability in almost the whole of the defined area are affected. Only

small areas are not influenced.

16-20

Critical

The modification is present overall with a high intensity. The habitat quality,

diversity, size and variability in almost the whole of the defined section are

influenced detrimentally.

21-25

3.1.4 Aquatic Macroinvertebrate Assessment

Macroinvertebrate assemblages are good indicators of localised conditions because many

benthic macroinvertebrates have limited migration patterns or a sessile mode of life. They are

particularly well-suited for assessing site-specific impacts (upstream and downstream studies)

(Barbour et al., 1999). Benthic macroinvertebrate assemblages are made up of species that

constitute a broad range of trophic levels and pollution tolerances, thus providing strong

information for interpreting cumulative effects (Barbour et al., 1999). The assessment and

monitoring of benthic macroinvertebrate communities forms an integral part of the monitoring

of the health of an aquatic ecosystem.

3.1.4.1 South African Scoring System

The South African Scoring System version 5 (SASS5) is the current index being used to

assess the status of riverine macroinvertebrates in South Africa. According to Dickens and

Graham (2002), the index is based on the presence of aquatic invertebrate families and the

perceived sensitivity to water quality changes of these families. Different families exhibit

different sensitivities to pollution, these sensitivities range from highly tolerant families (e.g.



4

Chironomidae) to highly sensitive families (e.g. Perlidae). SASS results are expressed both

as an index score (SASS score) and the Average Score Per recorded Taxon (ASPT value).

Sampled invertebrates were identified using the “Aquatic Invertebrates of South African

Rivers” Illustrations book, by Gerber and Gabriel (2002). Identification of organisms was made

to family level (Thirion et al., 1995; Dickens and Graham, 2002; Gerber and Gabriel, 2002).

All SASS5 and ASPT scores are compared with the SASS5 Data Interpretation Guidelines

(Dallas, 2007) for the Lowveld Lower ecoregion. This method seeks to develop biological

bands depicting the various ecological states and is derived from data contained within the

Rivers Database and supplemented with other data not yet in the database.

Figure 5: Guidelines used for the interpretation and classification of the SASS5 scores (Dallas, 2007)

3.1.4.2 Macroinvertebrate Response Assessment Index

The Macroinvertebrate Response Assessment Index (MIRAI) was used to provide a habitat-

based cause-and-effect foundation to interpret the deviation of the aquatic invertebrate

community from the calculated reference conditions for the SQR. This does not preclude the

calculation of SASS5 scores if required (Thirion, 2007). The four major components of a

stream system that determine productivity for aquatic macroinvertebrates are as follows:

Flow regime;

Physical habitat structure;

Water quality; and

Energy inputs from the watershed Riparian vegetation assessment.

The results of the MIRAI will provide an indication of the current ecological category and

therefore assist in the determination of the PES.



5

3.1.5 Fish Community Assessment

The information gained using the Fish Response Assessment Index (FRAI) gives an indication

of the PES of the river based on the fish assemblage structures observed. Fish were captured

through electroshocking. All fish were identified in the field and released at the point of capture.

Fish species were identified using the guide Freshwater Fishes of Southern Africa (Skelton,

2001). The identified fish species were compared to those expected to be present for the

quaternary catchment. The expected fish species list was developed from a literature survey

and included sources such as (Kleynhans et al., 2007), Skelton (2001) and DWS (2018). The

conservation status of the indigenous fish species was assessed in terms of the IUCN Red

List of Threatened Species (IUCN, 2018). It is noted that the FRAI Frequency of Occurrence

(FROC) ratings were calculated based on the habitat present at the sites.

3.1.6 Present Ecological Status

Ecological classification refers to the determination and categorisation of the integrity of the

various selected biophysical attributes of ecosystems compared to the natural or close to

natural reference conditions (Kleynhans and Louw, 2007). For the purpose of this study,

ecological classifications have been determined for biophysical attributes for the associated

water course. This was completed using the river ecoclassification manual by Kleynhans and

Louw (2007). The areas considered in the PES assessment are outlined in the IHIA section

above.

3.2 Impact Assessment

The risk assessment was completed according to the rating system provided by GCS Water

& Environmental Consultants (2018). Each impact identified must be assessed in terms of

probability (likelihood of occurring), scale (spatial scale), magnitude (severity) and duration

(temporal scale). To enable a scientific approach to the determination of the environmental

significance (importance), a numerical value is linked to each rating scale.

The following criteria must be applied:

Occurrence

Probability of occurrence (how likely is it that the impact may occur?); and

Duration of occurrence (how long the impact may last).

Severity

Magnitude (severity) of impact (will the impact be of high, moderate or low severity?);

and

Scale/extent of impact (will the impact affect the national, regional or local environment,

or only that of the site?).



6

Table 6: Impact methodology ranking scales

Probability - P Duration - D

5 - Definite/ don’t know 5 - Permanent

4 – Highly probable 4 – Long term (ceases with the life of operation)

3 – Medium probability 3 – Medium-term (5-15 years)

2 – Low probability 2 – Short-term (0-5 years)

1 – Improbable 1 – Immediate

0 – None

Scale - S Magnitude - M

5 - International 10 – Very high/ don’t know

4 – National 8 – High

3 – Regional 6 – Moderate

2 – Local 4 – Low

1 – Site only 2 – Minor

0 – None

Status of Impact

+ : Positive - : Negative N: Neutral

The following formula was applied to calculate the impact significance after the factors were

ranked for each impact:

SP = (magnitude + duration + scale) x probability

The status of the impact is positive, negative or neutral (no impact):

Table 7: Impact significance ratings

Significance Environmental Significance Points (SP) Colour Code

High (positive) >60 H

Medium (positive) 30 to 60 M

Low (positive) <30 L

Neutral 0 N

Low (negative) >-30 L

Medium (negative) -30 to -60 M

High (negative) <-60 (max = 100) H



7

4 Key Legislative Requirements

4.1 National Water Act (NWA, 1998)

The DWS is the custodian of South Africa’s water resources and therefore assumes public

trusteeship of water resources, which includes watercourses, surface water, estuaries, or

aquifers. The National Water Act (Act No. 36 of 1998) (NWA) allows for the protection of water

resources, which includes:

The maintenance of the quality of the water resource to the extent that the water

resources may be used in an ecologically sustainable way;

The prevention of the degradation of the water resource;

The rehabilitation of the water resource;

A watercourse means:

A river or spring.

A natural channel in which water flows regularly or intermittently.

A wetland, lake or dam into which, or from which, water flows.

Any collection of water which the Minister may, by notice in the Gazette, declare to be

a watercourse, and a reference to a watercourse includes, where relevant, its bed and

banks.

The NWA recognises that the entire ecosystem and not just the water itself, and any given

water resource constitutes the resource and as such needs to be conserved. No activity may

therefore take place within a watercourse unless it is authorised by the DWS. Any area within

a wetland or riparian zone is therefore excluded from development unless authorisation is

obtained from the DWS in terms of Section 21 (c) and (i).

4.2 National Environmental Management Act (NEMA, 1998)

The National Environmental Management Act (NEMA) (Act 107 of 1998) and the associated

Regulations as amended in December 2014, states that prior to any development taking place

within a wetland or riparian area, an environmental authorisation process needs to be followed.

This could follow either the Basic Assessment Report (BAR) process or the Environmental

Impact Assessment (EIA) process depending on the scale of the impact.

5 Limitations and Assumptions

A single aquatic ecology survey was completed for this assessment. Thus, temporal

trends were not investigated.

No baseline biomonitoring data/report(s) was received for the project area. Therefore,

information presents the findings of the single aquatic survey.

Although every effort was made to sample each potentially effected watercourse, lower

order watercourses and drainage lines were not considered in this assessment.

No wetlands were considered in this aquatic study.

Due to the rapid nature of the assessment and the survey methods applied, fish

diversity and abundance was likely to be under estimated.



8

Invertebrates were only considered to the Family level and thus a defined species list

for aquatic invertebrates was not completed.

The depths of the proposed mining operation were not defined at the time of writing

this report. Considering this, the potential and risk for subsidence is unknown. Thus,

based on the precautionary principle, it is assumed that mining will be shallow and

there is a risk for subsidence to occur.

The proposed activities listed in this study are based on the assessment of several

existing underground coal mine activities. A number of assumptions have been made

through the compilation of the activity list.

The river systems were in flood at the time of the survey, limiting sampling efforts and

access to greater habitat diversity. Flood conditions are known to skew results through

the displacement and dispersal of aquatic fauna. Aquatic communities are likely

underestimated during flood conditions.



9

6 Results and Discussion

6.1 Water Quality

In situ water quality analysis results from the March 2018 survey are provided in Table 8.

Table 8: Water Quality Results March 2018

*TWQR – Target Water Quality Range; ** Expert Opinion for Range

The water quality assessment derived pH values ranging from 6.79 at MG1 (adjacent to New

Adit) to 8.53 at MV1 (downstream of ZAC). The levels of pH were determined to be within the

Target Water Quality (TWQR) according to Department of Water Affairs and Forestry (DWAF)

(1996). Levels of conductivity were found to range from 200 µS/cm at BM2 (most downstream

site) to 1020 µS/cm at MV1 (tributary draining ZAC mine). The levels of dissolved solids at

MV1 indicated modified water quality (Figure 6). Land-use in the catchment, which includes

the existing ZAC mine, has likely contributed dissolved solids and modified water quality in the

considered Mvalo River reach. The lower conductivity measured at the downstream BM2 site

is likely a result of heavy rains and runoff from the smaller Mngeni tributary. Rain water typically

displays low conductivity of 100 µS/cm.

Figure 6: pH and Electrical Conductivity spatial results for the baseline survey

The concentrations of Dissolved Oxygen (DO) were found to range from 7.20 mg/l at MV1 to

7.50 mg/l at sites BM1 and BM2 during the March 2018 survey. The levels of DO within the

project area were found to be above threshold effect concentrations.

5

6

7

8

9

10

BM1 MV1 MG1 BM2

pH

pH TWQR TWQR

0

200

400

600

800

1000

1200

BM1 MV1 MG1 BM2

Electrical Conductivity

EC (µS/cm) TWQR

Site pH Conductivity

(µS/cm) DO (mg/l) Temperature (°C)

TWQR* 6.5-9.0 700** >5.00 5-30 /

< 10% variation

BM1 7.41 500 7.50 25.6

MV1 8.53 1020 7.20 28.8

MG1 6.79 290 7.44 21.1

BM2 7.76 200 7.50 25.4



10

Water temperatures within the considered river reaches were found to range from 21.1°C at

MG1 to 28.8°C at MV1. The average temperature (background levels) in the Black Mfolozi

was 25.5°C. The 28.8°C recorded at MV1 is a result of the shallow nature of this stream

exposed to the sun, warming the water as the day progresses. The water temperature at all

four sites was determined to be natural.

The water quality was considered adequate for aquatic biota and ecosystem function,

however, site MV1 showed modified water quality forming a limiting factor to aquatic life.

Future water quality impairment is of great concern as the Black Mfolozi River supports the

Hluhluwe-Imfolozi Game Reserve located approximately 3.5 km downstream of the New Adit.

It is important to factor in the presence of floods during the sampling period. Flood waters

likely dilute impacted water, masking any water quality impacts stemming from the ZAC mine

activities, if impacts are present. Resampling in situ water quality during normal flow conditions

is recommended to better reflect water quality conditions in the project area.

6.2 Intermediate Habitat Integrity Assessment

The IHIA was completed on a reach basis as described in the IHIA methodology component

of this study. The results of the IHIA for the Black Mfolozi River are presented in Table 9.

Table 9: Instream Intermediate Habitat Integrity Assessment for the Black Mfolozi River

Criterion Average Score Score

Instream

Water abstraction 5 2.8

Flow modification 7 3.64

Bed modification 17 8.84

Channel modification 5 2.6

Water quality 6 3.36

Inundation 12 4.8

Exotic macrophytes 4 1.44

Exotic fauna 0 0

Solid waste disposal 6 1.44

Total Instream Score 71.08

Instream Category class C

Riparian

Indigenous vegetation removal 16 8.32

Exotic vegetation encroachment 12 5.76

Bank erosion 18 10.08



Inundation 6 2.64





11

The results of the instream integrity assessment class C or moderately modified status for the

Black Mfolozi River reach in this assessment. The level of modification stems from largescale

catchment erosion and sedimentation which has inundated much instream habitat. The

riparian habitats are largely modified (class D). The large modification in the riparian habitat

can be largely attributed to the modification to the riparian zones for agriculture, exotic

vegetation encroachment, catchment scale erosion and sedimentation. The results of the IHIA

for the Mvalo River system are provided in the table below (Table 10).

Table 10: Instream Intermediate Habitat Integrity Assessment for the Mvalo River

The results of the instream integrity assessment class C or moderately modified status for the

considered river reach in this assessment. Limited habitat level perturbations are present

within the considered reach of this assessment with impacts largely attributed to cumulative

low rated impacts. The riparian habitat derived a class D (largely modified) which can largely

be attributed to alterations for road access and agriculture. The river shows modification in

Total Riparian Score 56.48

Riparian Category class D


Instream






Inundation 2 0.8

Exotic macrophytes 0 0

Exotic fauna 0 0

Solid waste disposal 0 0



Riparian






Inundation 8 3.52




Riparian Category class D



12

close proximity to the ZAC mine. The results of the IHIA for the Mngeni River are presented

in Table 11.

Table 11: Instream Intermediate Habitat Integrity Assessment for the Mngeni River

The results of the IHIA for the Mngeni River catchment considered in this assessment derived

class C or moderately modified instream and riparian habitat. Limited habitat level

perturbations are present within the considered reach of this assessment with impacts largely

attributed to bank erosion and channel modification impacts (Figure 7). An instream weir has

influenced flow within the river system.


Instream

Water abstraction 0 0





Inundation 6 2.4

Exotic macrophytes 0 0

Exotic fauna 0 0

Solid waste disposal 0 0



Riparian






Inundation 6 2.64




Riparian Category class C



13

Figure 7 : Bank incision and colapsing banks, loss of riparian habitat in Mngeni River

6.3 Aquatic Macroinvertebrate Assessment

6.3.1 Macroinvertebrate Habitat

Biological assessments were completed at representative sites in the considered river

reaches. The invertebrate habitat at each site was assessed using the South African Scoring

System version 5 (SASS5) biotope rating assessment as applied in Tate and Husted (2015).

The results of the biotope assessment are provided below (Table 12). A rating system of 0 to

5 was applied, 0 being not available.

Table 12: Biotope Scores recorded during the March 2018 Survey

Biotope Weighting BM1 MV1 MG1 BM2

Stones in current 10 2 3 2 5

Stones out of current 10 0 5 0 0

Bedrock 3 0 5 5 0

Aquatic Vegetation 5 0 0 0 0

Marginal Vegetation In Current 5 5 3 0 5

Marginal Vegetation Out of Current 5 5 2 3 2

Gravel 4 5 5 5 5

Sand 2 5 5 5 5

Mud 1 5 5 5 5

Biotope Score 27 33 25 27

Weighted Biotope Score (%) 47 69 38 53

Biotope Category (Tate and Husted, 2015) D B E C

Habitat availability within the Black Mfolozi River improved in a downstream direction from a

D category to a C category due to a greater diversity of the stones in current habitat at the



14

downstream site (BM2). The moderate biotope scores at sites BM1 and BM2 can be attributed

to the moderate to high diversity/abundance of the vegetation and gravel, sand and mud

(GSM) biotopes (Figure 8). The biotope results indicate that habitat availability would not be a

limiting factor to the macroinvertebrate assemblage in the Black Mfolozi River. The Mvalo

River showed similarity to the Black Mfolozi River with a high diversity/abundance of biotopes

present, promoting diverse macroinvertebrate assemblages at site MV1 (class B).

Habitat availability within the Mngeni River (MG1) was rated as poor (class E). The low biotope

score can be attributed to a low diversity/abundance of both the stones and vegetation

biotopes (Figure 8). The biotope results indicate that habitat availability would be a limiting

factor to the macroinvertebrate assemblage in the Mngeni River.

Figure 8: Aquatic Habitat: A) Mvalo River @ MV1; B) Black Mfolozi River @ BM2 (March 2018)

6.3.2 Macroinvertebrate Community Assessment

6.3.2.1 South African Scoring System

The aquatic macroinvertebrate results for the sampled sites are presented in Table 13.

According to the ASPT, the results indicate that taxa collected during the survey ranged from

tolerant (<5 sensitivity score) to moderately intolerant (6 - 10 sensitivity score).

Table 13: Macroinvertebrate Assessment Results Recorded in the Project Area (March 2018)

Site SASS5 Taxa ASPT *Class (Dallas,

2007)

BM1 67 12 5.6 D

MV1 72 14 5.1 D

MG1 86 16 5.4 D

BM2 84 15 5.6 D

* Lowveld Lower Ecoregion

The results of the SASS5 assessment derived SASS5 scores that ranged from 67 at BM1 to

86 at MG1. The amount of taxa obtained ranged from 12 at BM1 to 16 at MG1. The Average

Score Per Taxon (ASPT) was found to range from 5.1 at MV1 to 5.6 at sites BM1 and BM2.



15

Ecological classes based on the interpretation guidelines were derived to be class D (largely

modified) at BM1, MV1, MG1 and BM2.

Notable families observed in the macroinvertebrate assemblage include Oligoneuridae (Small

minnow flies) (Figure 9), which were found at BM2 (Figure 10). Further families included

Leptophlebiidae (Prongills) and Tricorythidae (Stout Crawlers) observed at the sites BM1,

BM2, MG1 and MV1 (Figure 9). The aforementioned species are sensitive to water quality

modification with a requirement for moderate to fast flowing water over the stones in current

habitat. The presence of these species provides an indication of fair water quality and suitable

habitat.

Figure 9: Oligoneuridae (Small minnow flies) example found at BM2 (March 2018)

Figure 10: Fast flowing water over the stone habitat found at BM2 (March 2018)

Figure 11: Leptophlebiidae (Prongills) example found at MG1 and MV1 (March 2018)



16

Figure 12: Tricorythidae (Stout Crawlers) example found at BM1 and BM2 (March 2018)

6.3.2.2 Macroinvertebrate Response Assessment Index

The MIRAI methodology was conducted according to Thirion (2007). Data collected from the

SASS5 method was applied to the MIRAI model. The MIRAI model provides a habitat-based

cause-and-effect foundation to interpret the deviation of the aquatic invertebrate community

(assemblage) from the reference condition (unmodified river). The results of the MIRAI for the

Black Mfolozi River are provided in Table 14, the Mvalo River in Table 15, and the Mngeni

River in Table 16.

Table 14: Macroinvertebrate Response Assessment Index for the Black Mfolozi River based on results obtained in March 2018

Invertebrate Metric Group Score Calculated

Flow Modification 22.6

Habitat 38.7

Water Quality 29.1

Ecological Score 30.4

Invertebrate Category class E

Biotic integrity according to SASS5 results at the sampling sites BM1 and BM2 were

categorised as largely modified (class D). The results of the MIRAI derived a lower however

more robust ecological category of class E or seriously modified for the Black Mfolozi River

invertebrate community, while highlighting the factors responsible for the presence/absence

of taxa within the project area. The modified macroinvertebrate assemblage was attributed to

cumulative factors of flow, water quality and to a lesser degree habitat modification resulting

in the lowered ecological category.

Table 15: Macroinvertebrate Response Assessment Index for the Mvalo River based on results obtained in March 2018



Habitat 17.6

Water Quality 23.6




17



Invertebrate Category class E/F

Biotic integrity according to SASS5 results at the sampling site MV1 was categorised as largely

modified (class D). The results of the MIRAI derived a lower however more robust ecological

category of class E/F or seriously modified for the Mvalo River invertebrate community, while

highlighting the factors responsible for the presence/absence of taxa within the project area.

The modified macroinvertebrate assemblage was attributed to cumulative factors of habitat,

flow and water quality modification resulting in the lowered ecological category.

Table 16: Macroinvertebrate Response Assessment Index for the Mngeni River based on results obtained in March 2018



Habitat 38.9

Water Quality 22.0


Invertebrate Category class E

Biotic integrity according to SASS5 results at the sampling site MG1 was categorised as

largely modified (class D) within the Mngeni River. The results of the MIRAI show that the

macroinvertebrate community was categorised as seriously modified (class E). The modified

macroinvertebrate assemblage was attributed to cumulative factors of flow, water quality and

to a lesser degree habitat modification resulting in the lowered ecological category.

The flooding experienced in the project area during (Black Mfolozi) and prior to the survey

(Mngeni River) should be taken into account when interpreting macroinvertebrate results. It is

likely that many taxa had dislodged and washed away due to high flows, resulting in lower

invertebrate diversities and abundances, influencing SASS and MIRAI scores. High flows

(flooding) further influences habitat availability, erosion and sedimentation.

6.4 Fish Community

The anticipated fish community and the results of the qualitative fish assessment are

presented in Table 17, while recorded fish species photographs are presented in Table 18.



18

Table 17: Fish Community Assessment for the Watercourses in the Project Area

Species/Site IUCN Status BM1 MV1 MG1 BM2

Anguilla marmorata LC 0 0 0 0

Anguilla mossambica LC 0 0 0 0

Amphilius natalensis LC 0 0 0 0

Awaous aeneofuscus LC 0 0 0 0

Brycinus lateralis LC 0 0 0 0

Clarias gariepinus LC 0 1 1 1

Ctenopoma intermedium LC 0 0 0 0

Enteromius anoplus LC 0 0 0 0

Enteromius crocodilensis LC 0 0 0 0

Enteromius paludinosus LC 0 0 0 0

Enteromius trimaculatus LC 1 1 1 1

Enteromius unitaeniatus LC 0 0 0 0

Enteromius viviparus LC 0 0 0 0

Glossogobius callidus LC 0 0 0 0

Labeobarbus natalensis LC 1 0 0 0

Labeo molybdinus LC 1 1 1 1

Marcusenius pongolensis LC 0 0 0 0

Mesobola brevianalis LC 0 0 0 0

Micralestes acutidens LC 0 0 0 0

Micropanchax katangae LC 0 0 0 0

Nothobranchius orthonotus LC 0 0 0 0

Oreochromis mossambicus NT 1 1 1 1

Oreochromis placidus LC 0 0 0 0

Tilapia sparrmanii LC 0 0 0 0

Total Native Species 4 4 4 4

Total Expected Native Species (per site) 24 24 24 24

% Fish Community Sampled 17 17 17 17

LC = Least Concern; NT = Near Threatened; 1 = Observed; 0 = Absent

A total of five native fish species were captured during this study (Table 17). A single red listed

species, Oreochromis mossambicus (NT), is expected directly within the river reaches in the

study area. O. mossambicus is threatened by hybridisation and therefore the proposed project

does not pose a threat to this species.



19

Table 18: Fish Species Observed during the March 2018 Survey

Clarias gariepinus Enteromius trimaculatus

Labeobarbus natalensis Labeo molybdinus

Oreochromis mossambicus (NT)

The results of the FRAI for the Black Mfolozi River are provided in Table 19.

Table 19: Fish Response Assessment Index for the Black Mfolozi River

FRAI% (Automated) 59.2

EC FRAI class C/D

The results of the FRAI derived a moderately to largely modified (class C/D) fish community.

The absence of key species from the survey site in this river reach resulted in the modified

fish community. Absent key fish species included Anguilla sp. (Eels), Enteromius sp. (Barbs)

and Tilapia sparrmanii (Banded tilapia). It should be noted that a small portion of the expected

fish species are uncommon (low frequency of occurrence) and likely present in specific habitat

areas, making their capture difficult. Habitat at the two sites (BM1 and BM2) was capable of

supporting taxa which were not sampled. The floods experienced at the time of the survey

made sampling a diversity of habitats difficult and unsafe, resulting in an underestimate of the

fish community present in the Black Mfolozi River. The larger fish community was expected in

this larger river system, therefore their absence is indicative of flood conditions together with

modification of habitat within the system. The results of the FRAI for the Mvalo River is

presented in Table 20.

Table 20: Fish Response Assessment Index for the Mvalo River


EC FRAI class D

The results of the FRAI derived a largely modified (class D) in the Mvalo River. Absent key

fish species included Anguilla sp. (Eels), Enteromius sp. (Barbs), Labeobarbus natalensis

(KwaZulu-Natal yellowfish) and Tilapia sparrmanii (Banded tilapia). The absence of widely



20

distributed species indicated modification of habitat and water quality (Table 8) in the

watercourse. The Mvalo was seen as a shallow river with limited refugia areas for fish in times

of low water levels. The non-perennial status of the Mvalo River is likely a role player in the

absence of the larger fish community in comparison to the larger Black Mfolozi River. The

results of the Mngeni River FRAI are presented in Table 21.

Table 21: Fish Response Assessment Index for the Mngeni River


EC FRAI class D

The results of the FRAI in the Mngeni River indicated a largely modified fish community. The

Mngeni showed similarity to the Mvalo with a non-perennial status and the same species

sampled. However, an instream weir was present in the Mngeni River acting as a migration

barrier to aquatic biota. Bank incision and sedimentation were observed, highlighting habitat

modification within the system.

6.5 Overall Aquatic Ecology Present Ecological Status

The results of the PES for the Black Mfolozi River assessment are provided in Table 22.

Table 22: Present Ecological Status of the Black Mfolozi River reach

Aspect Assessed Ecological Category

Instream Ecological Category 71.1

Riparian Ecological Category 56.5

Aquatic Invertebrate Ecological Category 30.4

Fish Ecological Category 59.2

Ecostatus class D


Mfolozi River reach considered in this assessment. It is noted that flood conditions have likely



biological responses. Instream habitat modification can be attributed to largescale catchment


the instream habitat. The results of the PES for the Mvalo River assessment are provided in

Table 23.

Table 23: Present Ecological Status of the Mvalo River reach








21


Ecostatus class D

The PES assessment derived largely modified (class D) conditions in the Mvalo River reach

considered in this assessment. Instream habitat limitations and water quality impairment have

resulted in modified aquatic ecology. The modification of the watercourse is likely attributed to

activities associated with the existing ZAC operation and the natural habitat availability at the

sample site. The results of the PES assessment for the Mngeni River reach are provided in

Table 24.

Table 24: Present Ecological Status of the Mngeni River reach






Ecostatus class D


River reach considered in this assessment. It is noted that post flood conditions have likely


present under normal flow conditions. Modified biological responses in this river reach are

indicative of instream and riparian habitat modification. The modification can be attributed to


7 Aquatic Ecological Importance and Sensitivity (No-Go Area’s)

7.1 Ecological Importance and Sensitivity

The overall Ecological Importance and Sensitivity (EIS) of the river reaches in this study were

assessed according to Kleynhans (1996). The results of the EIS assessment are provided in

the table below (Table 25).

Table 25: Ecological Importance and Sensitivity Ratings for the Watercourses in the Study Area

Biological Determinants

Determinant Rating Comment

Rare and endangered biota 3 More than one taxon rare or

endangered at a national scale

Unique biota 4 Several aquatic taxa are

considered unique with limited distributions

Intolerant biota 3 Lower reach KZN river system

with large portion of flow intolerant taxa.

Species richness 4 On a National scale the species richness is high



22

Biological Determinants

Determinant Rating Comment

Habitat Determinants

Diversity of aquatic habitat 3 Lower reach river system with diverse habitat considering its

lower reach status

Refuge value of habitat types 2 Although diverse, the river is

largely uniform offering moderate refuge areas

Sensitivity of habitat to flow modification

1.5 Large river system with low

sensitivity to flow modification

Sensitivity to flow related water quality changes

2 Large river system with

moderate dilution capacity to water quality modification

Migration route corridor for instream and riparian biota

3

The watercourses are in the lower reaches of the river

systems with no weirs or dams present

National parks and wilderness areas 4

NFEPA listing and Hluhluwe-Imfolozi nature reserve

associated with the watercourses.

Mean 2.95

EIS class High

The results of the EIS assessment derived a high EIS for the Black Mfolozi River reach.

Spatial Sensitivity Assessment

The layout of sensitive environments in respect to aquatic ecology is presented in Figure 13

for the Deep E open cast area, and Figure 14 and Figure 15 for the New Adit Alternative 1 and

Alternative 2, respectively. It is noted that a 44 m buffer has been presented in these figures

based on the delineated watercourses in the project area. The buffer value stems from those

specified for the construction and operational phases in the wetland report for the current study

(TBC, 2018). In addition, it was noted that infrastructure within the layout of the project area is

in direct proximity to unnamed drainage lines (ephemeral streams). The particular

infrastructure that is in proximity to the watercourses are the proposed new Deep E open cast

pit (Figure 13), and the ventilation fan, office block, buried pipelines and stockpile associated

with the New Adit Alternative 1 (Figure 14). This proposed infrastructure is within the proposed

44 m buffer zone for surface infrastructure. Furthermore, underground mining activities are

proposed to undermine watercourses at an unknown depth. These activities therefore pose a

direct threat to sensitive aquatic ecological habitats. Based on this, Alternative 2 is the

preferred infrastructure layout for the New Adit as it is located outside of watercourse areas.

Alternative 2 does however have an access road which will traverse an ephemeral drainage

line, requiring mitigation actions to prevent potential environmental degradation.



23

Figure 13: Sensitive Aquatic Habitats associated with the Deep E open cast area



24

Figure 14: Sensitive Aquatic Habitats associated with the New Adit Alternative 1



25

Figure 15: Sensitive Aquatic Habitats associated with the New Adit Alternative 2



26

8 Impact Assessment and Recommendations

The impact assessment considered both direct and indirect impacts, if any, to the aquatic

systems. The area to be developed will consist of access roads, access shafts to the

underground mining area, opencast mining area, conveyor belts, disposal discard dumps,

mining infrastructure, salvage yard, boundary berms, security huts, break test ramps, parking

bays, explosives delivery bay, diesel bay, wash bay, storerooms, various office blocks,

ablution block, sub-station, water reservoirs, workshop, silt trap, pipelines, pollution control

dams, product stockpiles, Run of Mine (RoM) stockpiles, top soil dumps and waste dumps.

The mitigation hierarchy as discussed by the Department of Environmental Affairs (2013) will

be considered for this component of the study, (Figure 16). In accordance with the mitigation

hierarchy, the preferred mitigatory measure is to avoid impacts by considering options in

project location, sitting, scale, layout, technology and phasing to avoid impacts.

Figure 16: The mitigation hierarchy as described by the DEA (2013)

8.1 Existing impacts

The following existing impacts were observed in or adjacent to the proposed project area:

The project area is prone to erosion and as a result sedimentation has been observed

in the entire catchment;

The catchments within the project are have been subjected to dryland agriculture, rural

settlements and mining;

The Mvalo River system reflected modified water quality with high dissolved solids

present;

The Mvalo River has shown bank incision and collapse. Furthermore, the road bridge

has partially collapsed; and



27

An abstraction pipe located at the Mvalo River Bridge has been exposed by erosion

and is broken. Possible water quality impairment may occur when pipe is in use.

8.2 Proposed Project Activities

A specific list of proposed project activities has not been provided for the compilation of this

report. However, based on previous assessments and the study of active underground and

opencast coal mining activities, as well as the proposed infrastructure layout of this project,

the following activities are expected.

1. Construction Phase:

Site clearing for surface infrastructure;

Construction of surface infrastructure and road network;

Construction of underground access portals (shafts & Adits);

Construction of impoundments/Pollution Control Dam’s (PCD’s); and

The placement of waste (overburden) and topsoil stockpiles.

2. Operation Phase:

Operation of surface infrastructure (roads, conveyors, offices, various bays, coal wash

plants and workshops);

Storage of Run of Mine (RoM) Coal;

Storage of coal mineral discard;

Storage of contaminated ground and surface water in PCD’s; and

Active underground mining.

3. Decommission and Closure Phase:

Removal of infrastructure;

Rehabilitation of waste stockpiles and PCD’s;

4. Post Closure Phase

Acid Mine Drainage decant;

Seepage from permanent waste stockpiles;

Subsidence of undermined areas.

8.3 Potential Impacts

The following list provides a broad framework for the anticipated impacts associated with the

project. These impacts stem from the construction to post closure phases of the mine.

1. Environmental pollution due to increased sedimentation and erosion of watercourses

a. Project activities that can cause pollution in watercourses:

i. Erosion

ii. Sedimentation

iii. Clearing of vegetation

iv. Earth moving (removal and storage of soil)

v. Blasting and excavations

vi. Infrastructure development including culverts/bridges, construction

camps & laydown areas



28

b. Secondary impacts associated with pollution in watercourses:

i. Water pollution

ii. Ephemeral streams exposed to contaminated runoff, erosion and solid

waste

iii. Change/deterioration of the ecological status of rivers/streams

iv. Loss of aquatic biota

2. Impaired water quality (surface and groundwater)

a. Project activities that can cause impaired water quality in watercourses:

i. Clearing of vegetation, erosion of exposed areas

ii. Chemical (organic/inorganic) spills

iii. Untreated runoff or effluent

iv. Soil dust depression (spraying of roads & exposed areas)

v. Produce stockpiles and storage

vi. Discharge of contaminated groundwater from shafts & voids

vii. Elevated water temperatures from discharged water

viii. Runoff from ROM and opencast stockpiles

ix. Seepage from mine infrastructure, waste and stockpile areas

x. Leaks, breaches, overtopping and subsurface leaking of PCD’s

xi. Loading of coal onto trucks with transport to the existing ZAC

processing Plant

xii. Sewage from ablutions

xiii. Mismanagement of dirty water systems

b. Secondary impacts associated with impaired water quality in watercourses:

i. Metal leaching and mobilisation of salts during operation

ii. Contamination of surface water runoff (rain water)

iii. Contamination of groundwater through infiltration

iv. Acid Mine Drainage altering physico-chemical conditions of

watercourses post closure

v. Change in aquatic fauna communities

vi. Change/deterioration of the ecological status of rivers/streams

3. Alterations in hydrological regime (flow of surface and sub-surface water)

a. Project activities that can cause alterations in hydrological regime:

i. Vegetation removal

ii. Excavations and infrastructure development

iii. Road network creation including culverts/bridges

iv. River crossing infrastructure development

v. Alterations to surface topography (due to voids and surface structures)

vi. Dewatering of working areas

vii. Infrastructure associated with the New Adit in drainage lines

viii. Abstraction of water for use in mine operational phase

ix. Decant of water at new Adit and Open cast area

b. Secondary impacts associated with alterations in hydrological regime:



29

i. Increased or reduced runoff dependent on system manipulation

ii. Scouring and erosion of river bed and banks

iii. Change in aquatic fauna communities

iv. Worsening of the ecological status of rivers/streams

v. Change in water availability in rivers following abstraction for use by

ZAC

4. Alterations in surface topography

a. Project activities that can cause alterations to surface topography:

i. Underground mining

b. Secondary impacts associated with alterations to surface topography:

i. Subsidence resulting from void collapse

8.4 Detailed Potential Impacts Anticipated for the Proposed Project

8.4.1 Construction Phase

The activities listed above during the construction phase have the potential to degrade water

and habitat quality within the considered river systems. Water quality impacts may include

increased dissolved/suspended solids, as well as potential persistent pollutants within the

water column and sediments of the associated watercourse. Considering this, general water

chemistry modification may occur as a result of changed salt balances stemming from the

influx of runoff from a modified catchment.

Habitat quality impacts are likely to include reduced water volumes, sedimentation, bed,

channel and flow modification, as well as the specific loss of aquatic habitat through direct

modification during the construction of watercourse crossings, infrastructure, and open cast

pit. There will be the loss of the ephemeral stream during the construction of the open cast pit.

Although the PES (baseline) of the river reaches assessed were derived to be largely modified

from reference conditions, further deterioration is possible and thus a potential decline in the

PES could be observed. Thus, impacts described above will result in reduced biodiversity on

a catchment scale.

8.4.2 Operation Phase

As discussed in the construction phase, the activities and interactions listed above have the

potential to degrade water and habitat quality within the associated river systems. The storage,

transport and processing of carboniferous material presents a risk to contaminate the

downstream river reaches. During rainfall events runoff which has been in contact with this

material may enter local aquatic ecosystems. Once rainwater is in contact with the

carboniferous material, dissolved substances will alter downstream water chemistry resulting

in the loss of sensitive aquatic biota.

8.4.3 Decommissioning and Closure Phase

Similarly to the construction phase, the removal of infrastructure and rehabilitation activities

will be a large scale operation and thus has the potential to contaminate surface water.

Particular areas which will require attention includes the RoM stockpiles, screening areas and



30

pollution control facilities. The rehabilitation of these areas will require special attention to

avoid contamination of the surrounding aquatic ecosystems.

8.4.4 Post Closure

Typically, following the cessation of underground mining activities groundwater returns to the

voids created by the mining process. This process results in the contamination of the

groundwater resource. Following this influx of groundwater, seepage and decant at specific

locations can result in the ingress of contaminated water in downstream river systems, thus

severely degrading the local PES.

In addition, in line with the precautionary principle, it is anticipated that the undermining of

wetlands and river systems within the study area will result in the subsidence of the surface.

The resultant potential impacts include serious changes to hydrology resulting in the significant

alteration of catchment areas and subsequent habitat levels impacts.

8.4.5 Unplanned Events

The planned activities will have known impacts as discussed above; however, unplanned

events may occur on any project and may have potential impacts which will need mitigation

and management. Table 26 is a summary of the findings from an aquatic ecology perspective.

Please note not all potential unplanned events may be captured herein and this must therefore

be managed throughout all phases of the project lifecycle.

Table 26: Unplanned Events, Low Risks and their Management Measures

Unplanned Event Potential Impact Mitigation

Hydrocarbon spill into riverine habitat

Contamination of sediments and water resources associated

with the spillage.

A spill response kit must be available at all times. The incident must be reported on and if necessary a wetland specialist must investigate the extent of the impact and provide rehabilitation recommendations.

Uncontrolled erosion Sedimentation of

downstream river reach. Erosion control measures must be put in place.

PCD overflow The degradation of downstream water

quality.

The overflow must be stopped immediately, and the impacted area remediated. Spill protection berms must be in place as well.

8.5 Assessment of Significance

The tables below illustrate the significance of potential impacts associated with the proposed

project before and after implementation of mitigation measures. The impacts have been

assessed for the Construction, Operation, and Closure phases. A cumulative impact

assessment was also completed.

The project phases and aspects were assessed for the following;

Increased runoff, erosion and sedimentation of the ephemeral, non-perennial and

perennial systems.



31

Contamination risk and impaired water quality.

Change in hydrodynamics of the systems and project area.

The proposed project activities were determined to have two primary impacts to the associated

aquatic ecology. The first was determined to be related to the conditions within the physical

make-up of the considered river reaches. This includes the riverine substrates, banks, riparian

vegetation and water column. These physical components of a water course determine the

quality of the aquatic habitats. Therefore, modification of these physical components would

result in a habitat quality impact.

The second impact was determined to be related to the chemical properties of water.

Considering aquatic biota have requirements for habitat, as well as sensitivity to changes in

water chemistry, an overall impact for a change to water quality was completed.

The potential environmental impacts expected for the construction phase ranged from low to

high. The soil excavation and infrastructure development activities are regarded as high,

however, if the buffer zones and other recommended mitigation measures are applied the

impacts could be reduced to medium level risks. Medium risk level activities included road

network construction/upgrades including drainage line crossings, storage of chemicals, fuels

& materials, waste management and stormwater. Following mitigation their individual risk

levels can be lowered to varying degrees.

During the operational phase high level risks are expected excavations, blasting and earth

moving (removal and storage of overburden and coal), operation of access roads & servitudes

and storm & dirty water management (includes dewatering of shafts, voids and working areas).

Following the application of mitigation measures, these can be lowered to moderate levels of

risk. Medium risk level activities included storage of chemicals, fuels & materials, waste

management and abstraction of water from river systems, of which waste management can

be mitigated to a low risk level, while storage and water abstraction remains a medium risk

following mitigation.

The closure phase will have negative impacts on the surrounding water resources ranging

from low to high risk despite the successful completion of rehabilitation. The receiving aquatic

systems are subject to physico-chemical alterations stemming from contaminated

groundwater that requires ongoing management. Despite management, the level of risk

remains high.

The results of the cumulative impact assessment has considered the baseline conditions

established in this study. An important consideration for cumulative regional scale impacts

includes the assessment of the salt loading potential of the anticipated Acid Mine Drainage

should it enter into the Pongola-Mtamvuna Water Management Area. It is likely salt loads in

the watercourses will be altered with pumping of water from underground areas. This

modification will have an influence on the management decisions for water resource

objectives.

Findings for the impacts from construction phase through to closure (including cumulative

impacts) are shown in Table 27 to Table 30. See Table 6 for impact ratings.



32

Table 27:Impact significance summary Construction Phase

Dale Kindler (Pr. Sci. Nat. 114743)

ACTIVITY APPLICABL

E AREA POTENTIAL

ENVIRONMENTAL IMPACT

ENVIRONMENTAL SIGNIFICANCE BEFORE MITIGATION

RECOMMENDED MITIGATION MEASURES

ENVIRONMENTAL SIGNIFICANCE AFTER MITIGATION

M D S P

TO

TA

L

ST

AT

US

SP

M D S P

TO

TA

L

ST

AT

US

SP

Clearing of vegetation Opencast

area & Adit

Increased runoff, erosion and sedimentation of the downslope aquatic systems. Loss / degradation of instream habitat and aquatic biota. Impaired water quality.

6 2 1 3 27 - L

Adhere to the wetland and watercourse buffers. Keep impact footprint as small as possible. Avoid unnecessary vegetation clearing, and avoid preferential surface flow paths., Construct cut-off berms downslope of working areas, demarcate footprint areas to be cleared to avoid unnecessary clearing, Exposed areas must be ripped and vegetated to increase surface roughness, Create energy dissipation at discharge areas to prevent scouring, Temporary and permanent erosion control methods may include silt fences, retention basins, detention ponds, interceptor ditches, seeding and sodding, riprap of exposed areas, erosion mats, and mulching.

4 2 1 2 14 - L

Soil excavations, blasting and earth moving (removal and storage of soil)

Opencast area & Adit

Loss of soils from stock piles. Erosion and sedimentation of the downslope aquatic systems. Loss / degradation of instream habitat and aquatic biota. Impaired water quality. Loss of ephemeral stream at open cast area.

10 5 2 5 85 - H

Adhere to the wetland and watercourse buffers. Keep impact footprint as small as possible. Compile a suitable stormwater management plan. Construct cut-off berms downslope of working areas. Demarcate footprint areas to be excavated to avoid unnecessary digging. Exposed areas must be ripped and vegetated to increase surface roughness. Create energy dissipation at discharge areas to prevent scouring, Temporary and permanent erosion control methods may include silt fences, retention basins, detention ponds, interceptor ditches, seeding and sodding, riprap of exposed areas, erosion mats, and mulching. All voids must be backfilled, and temporary surface infrastructure must be removed from the site. Compacted areas must be ripped (perpendicularly) to a depth of 300 mm. A seed mix must be applied to rehabilitated and bare areas. Any gullies or dongas must also be backfilled. The area must be shaped to a natural topography. Soil management plans must be in place which will include the use of correct stockpiling methods. Berms must be placed around soil stockpiles to secure them. Flow in the ephemeral stream must be diverted around the construction areas

8 3 1 4 48 - M



33

Construction / upgrade of access roads and servitudes


Increased runoff, erosion and sedimentation of the aquatic systems. Change in hydrodynamics of the project area and flow within the watercourses at crossing points. Loss / degradation of instream habitat and aquatic biota. Impaired water quality. Solid waste production

6 5 2 4 52 - M

Use exiting road networks and crossing before constructing new infrastructure. Adhere to the wetland and watercourse buffers. Make use of box culverts over pipe culverts at watercourse crossing points such as for access road to Alternative 2. Keep impact footprint as small as possible. Compile a suitable stormwater management plan, Construct cut-off berms downslope of working areas, demarcate footprint areas to be cleared to avoid unnecessary clearing, Exposed areas must be ripped and vegetated to increase surface roughness, Create energy dissipation in road margins to prevent scouring and degradation of roads, Temporary and permanent erosion control methods may include, gabion walls, mattresses and bars, silt fences, retention basins, detention ponds, interceptor ditches, seeding and sodding, riprap of exposed areas, erosion mats, and mulching.

4 4 1 3 27 - L

Infrastructure development including, offices, ventilation shafts, construction camps & laydown areas


Increased runoff, erosion and sedimentation of the aquatic systems. Change in hydrodynamics of the project area. Loss / degradation of instream habitat and aquatic biota. Impaired water quality. Solid waste production. Loss of ephemeral streams

10 5 2 5 85 - H

Adhere to the wetland and watercourse buffers. The proposed infrastructure such as the new Deep E open cast pit, and the ventilation fan, office block, buried pipelines and stockpile associated with the New Adit (Alternative 1) must be relocated outside of the proposed buffers described in this assessment. Alternative 2 is the preferred option. Keep impact footprint as small as possible. Compile a suitable stormwater management plan, Construct cut-off berms downslope of working areas, demarcate footprint areas to be cleared to avoid unnecessary clearing, Exposed areas must be ripped and vegetated to increase surface roughness. Temporary and permanent erosion control methods may include: gabion walls, mattresses and bars, silt fences, retention basins, detention ponds, interceptor ditches, seeding and sodding, riprap of exposed areas, erosion mats, and mulching.

8 5 1 4 56 - M

Storage of chemicals, fuels & materials


Contamination risk if spills occur. Impaired water quality. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

10 2 3 4 60 - M

No cleaning of vehicles, machines and equipment in water resources. No servicing of machines, vehicles and equipment on site. Storage of potential contaminants in bunded areas. All contractors must have spill kits available and be trained in the correct use thereof.

6 2 2 3 30 - M

Waste management (including ablutions)


Indiscriminate dumping in aquatic areas, changes instream habitat. Contamination risk if spills occur. Impaired water quality. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

6 2 2 4 40 - M

All contractors and employees must undergo induction which is to include a component of environmental awareness. The induction is to include aspects such as the need to avoid littering, the reporting and cleaning of spills and leaks and general good “housekeeping”, Adequate sanitary facilities and ablutions must be provided for all personnel throughout the project area, Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the aquatic systems; All waste generated on-site must be adequately managed. Separation and recycling of different waste materials must be supported

6 1 1 3 24 - L



34

Stormwater system construction.


Increased runoff, erosion and sedimentation of the aquatic systems. Change in hydrodynamics of the project area and aquatic systems.

8 4 2 4 56 - M

All surface water must be managed to avoid scouring and erosion of the receiving systems. Clean and dirty water must be separated. Contaminated water must not be discharged into the watercourses. Contain waste water in a PCD. This water could be looked at for treatment and then re-introduced to mitigate losses to the catchment water hydro-dynamics. Alternatively, this water can be reused as process water for both construction and during operation. A silt trap must be installed at the PCD.

6 4 2 3 36 - M

Table 28: Impact significance summary Operational Phase

ACTIVITY APPLICABL

E AREA POTENTIAL





M D S P

TO

TA

L

ST

AT

US

SP

M D S P

TO

TA

L

ST

AT

US

SP

Excavations, blasting and earth moving (removal and storage of overburden and coal)


Loss of material from stock piles (overburden and coal). Erosion and sedimentation of the downslope aquatic systems. Loss / degradation of instream habitat and aquatic biota. Impaired water quality. Contamination through leaching and infiltration. Change/deterioration of the ecological status of rivers/streams.

10 5 2 4 68 - H

Adhere to the wetland and watercourse buffers. Keep impact footprint as small as possible. Demarcate footprint areas to be cleared to avoid unnecessary clearing, Temporary and permanent erosion control methods may include silt fences, retention basins, detention ponds, interceptor ditches, seeding and sodding, riprap of exposed areas, erosion mats, and mulching. All voids must be backfilled. Compacted areas where work is completed must be ripped (perpendicularly) to a depth of 300 mm. A seed mix must be applied to rehabilitated and bare areas. Any gullies or dongas must also be backfilled. The area must be shaped to a natural topography. Stockpile management plans must be in place which will include the use of correct stockpiling methods. Berms must be placed around stockpiles (overburden and coal) to secure them from erosion and contaminating surrounding areas. Stockpiles can be lined to prevent contamination through infiltration

8 3 2 4 52 - M

Operation of access roads and servitudes

Road network and

Coal transport

routes

Loss / degradation of instream habitat through sedimentation and spilled coal. Contamination through coal falling from trucks during transport. Impaired water quality. Change/deterioration of the ecological status of

8 5 2 5 75 - H

Create energy dissipation in road reserve. Adapt stormwater management plan to conditions in the project area. Address erosion along roads immediately through the use of gabion bars, paving roads with permeable paving and similar methods in key areas. Make use of tarpaulin or cargo covers to prevent loss of coal during transport. Make use of a suitable coal clean-up management plan for spilled coal along road network. Ensure designated transport routes are utilised. Instream energy dissipation must be installed at new box culvert for Alternative 2 access road.

6 5 2 3 39 - M



35

rivers/streams. Scouring of riverbed and banks at watercourse crossings

Storage of chemicals, fuels & materials


Contamination risk if spills occur. Impaired water quality. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

10 2 3 4 60 - M

No cleaning of vehicles, machines and equipment in water resources. No servicing of machines, vehicles and equipment on site. Storage of potential contaminants in bunded areas. All contractors must have spill kits available and be trained in the correct use thereof.

6 2 2 3 30 - M

Waste management (including ablutions)


Indiscriminate dumping in aquatic areas, changes instream habitat. Contamination risk if spills occur. Impaired water quality. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

6 2 2 4 40 - M

All contractors and employees must undergo induction which is to include a component of environmental awareness. The induction is to include aspects such as the need to avoid littering, the reporting and cleaning of spills and leaks and general good “housekeeping”, Adequate sanitary facilities and ablutions must be provided for all personnel throughout the project area, Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the aquatic systems; All waste generated on-site must be adequately managed. Separation and recycling of different waste materials must be supported

6 2 1 3 27 - L

Storm and dirty water management (includes dewatering of shafts, voids and working areas)


Increased runoff, erosion and sedimentation of the aquatic systems. Change in hydrodynamics of the project area and aquatic systems. Contamination risk if spills occur. Impaired water quality. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

10 5 3 4 72 - H

All surface water must be managed to avoid scouring and erosion of the receiving systems. Clean and dirty water must be separated. Divert clean water (rain) from active working (RoM) and storage areas (stockpiles). Clean water can be used for process water or if clean enough, be directed into nearby watercourses. Contaminated water must not be discharged into the watercourses. Contain waste and contaminated water in a PCD. PCD's must be lined and surrounded by spill protection berms. Install an oil and grease trap at the discharge into the PCD/Sump. This dirty water could be looked at for treatment (possibly phytoremediation in combination with other methods) and then re-introduced to mitigate losses to the catchment water hydro-dynamics. Alternatively, this water can be reused as process water during operation.

8 5 2 4 60 - M



36

Abstraction of water from river systems

Opencast area

Lower flow volumes in donor aquatic system, Change in hydrodynamics of the project area and aquatic systems. Impaired water quality. Change in aquatic habitat and fauna communities. Change/deterioration of the ecological status of rivers/streams

8 3 3 4 56 - M

Flow volumes must be monitored so as to not over abstract. Water must be allocated and used responsibly to minimise wastage. Unlawful abstraction must be reported and ceased immediately.

6 3 3 3 36 - M

Table 29: Impact significance summary Closure Phase

ACTIVITY APPLICABL

E AREA POTENTIAL





M D S P

TO

TA

L

ST

AT

US

SP

M D S P

TO

TA

L

ST

AT

US

SP

Closing of pit areas, removal of infrastructure and rehabilitation

Opencast & Adit

Increased runoff, erosion and sedimentation of the aquatic systems. Change in hydrodynamics of the project area and aquatic systems. Contamination risk if spills occur. Impaired water quality. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

8 3 2 4 52 - M

All voids must be backfilled, and surface infrastructure must be removed from the site. Any gullies or dongas must also be backfilled. Compacted areas must be ripped (perpendicularly) to a depth of 300mm. A seed mix must be applied to rehabilitated and bare areas. The area must be shaped to a natural topography. Trees (or vegetation stands) removed must be replaced. No grazing must be permitted to allow for the recovery of the area. Attenuation ponds may be created in channels to retain water in the catchment. Rehabilitation must occur in the sequence that the soil was removed according to stockpile management plan. These measures would need to be addressed in a Rehabilitation Plan.

8 3 2 3 39 - M

Waste management from removed infrastructure


Indiscriminate dumping in aquatic areas, changes instream habitat. Contamination risk if spills occur. Impaired water quality. Change in aquatic fauna communities. Change/ deterioration of the

6 2 2 4 40 - M

All contractors and employees must undergo induction which is to include environmental awareness. The induction is to include aspects such as the need to avoid littering, the reporting and cleaning of spills and leaks and general good “housekeeping”, Adequate sanitary facilities and ablutions must be provided for all personnel throughout the project area, Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the aquatic systems; All waste generated on-site must be adequately managed. Separation and recycling of different waste materials must be supported

4 2 1 4 28 - L



37

ecological status of rivers/streams

Groundwater management


Contamination (acid & metal) of groundwater in shafts and voids, Acid Mine Drainage, decant from underground, Change in hydrodynamics of the project area, impaired water quality. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

10 5 3 5 90 - H

Management plan for long term seepage from coal discard tailings and Acid Mine Drainage. Water treatment for potential AMD would involve limiting sulphide oxidation through the following categories: (1) physical barriers, (2) bacterial inhibition, (3) chemical passivation, (4) electrochemical, and (5) desulfurization. The categories should be used in combination as this proves more effective than a single technique. Minimise infiltration through disturbed areas. Establishment of vegetation for heavy metal assimilation. Make use of cut off trenches, seepage pumps.

8 5 3 4 64 - H

Subsidence of undermined areas


Collapse of undermined areas. Change in topography and hydrodynamics of the project area

8 5 2 4 60 - M

Voids and shafts must be filled. Correct use of pillars and roof support structures must be in place

8 5 2 3 45 - M

Table 30: Impact significance summary Cumulative impacts

ACTIVITY APPLICABL

E AREA POTENTIAL





M D S P T

OT

AL

ST

AT

US

SP

M D S P

TO

TA

L

ST

AT

US

SP

Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

Opencast & Adit area

Increased runoff, erosion and sedimentation of the aquatic systems. Change in hydrodynamics of the system. Impaired water quality. Acid Mine Drainage. Change in aquatic fauna communities. Change/deterioration of the ecological status of rivers/streams

8 5 3 4 64 - H

The PES of the project area aquatic systems is currently largely modified. If the mining is done responsibly, this PES status is likely to remain unchanged. Downstream protected areas need to be considered with regards to project impacts and rehabilitation measures. The rehabilitation of some of the areas including some drainage lines will improve the aquatic systems. 6 5 2 3 39 - M



38

8.6 Mitigation Actions for Potential Impacts

The mitigation actions provided below are important to consider with other specialist

assessments which include but are not limited to the following specialist studies: Groundwater,

Surface Water and Wetlands.

Avoiding and preventing the loss of sensitive landscapes are the first stage of the mitigation

hierarchy (Figure 16). Considering this, the layout of the proposed infrastructure within ZAC

project area layout must be moved outside the proposed buffers described in this assessment.

The particular infrastructure that is in proximity to the watercourses are the proposed new

Deep E open cast pit (Figure 13), and the Mngeni shaft Alternative 1 infrastructure (Figure

14). To combat this, Alternative 2 is the preferred option as the infrastructure lies outside of

watercourses, with the exception of the access road which traverses an ephemeral drainage

line (Figure 15). In line with the prevention component of this study, it is proposed that two

additional studies are completed for the proposed ZAC project.

It is recommended that an Erosion Risk Assessment and Management Plan is completed and

implemented to derive the areas at highest risk for erosion. These high-risk areas must then

be key points for erosion management throughout the entirety of the project lifecycle.

It is recommended that a Rock Engineering Subsidence Risk Assessment is completed to

define areas of high subsidence risk. Areas where high risk has been determined must be

completely avoided to reduce the risk for surface hydrology alterations. Should unavoidable

subsidence occur, rehabilitation actions must be implemented to avoid further effects to

downstream river reaches. This may include the implementation of a river diversion around

impacted areas. This would require additional environmental approvals and additional

specialist studies should this be required.

The establishment of a clearly marked buffer zone, which is defined as a region of natural

vegetation between the rivers/wetlands and the proposed activity, is the primary management

action that must take place. Literature suggests that a buffer zone can reduce aquatic habitat

and water quality impacts of large developments, making this management action of particular

importance (WRC, 2014). According to WRC (2014) the efficacy of a buffer is related to the

distance between the river system and the zone of disturbance. Therefore, by increasing the

length of a buffer, the potential aquatic modification related to the proposed activity is reduced.

The Wetland Ecology Study for this project defined the proposed buffer zones from delineated

wetland areas (TBC, 2018). The designated buffer zones must then be demarcated using

signage or fences.

During the various phases of the proposed project, waste generated and stored can result in

the runoff and seepage of contaminated water from the various activities which can cause

degradation of the aquatic ecosystems PES. In order to prevent this, the compilation of a

stormwater management plan is advised, this would typically form a component of the surface

water assessment. The use of diversion and containment management is of significant

importance. This can be achieved through effective groundwater and surface water

management.

Diversion trench and berm systems which diverts clean stormwater around pollution

sources and convey and contain dirty water to central pollution control impoundments;



39

Barrier systems, including synthetic, clay and geological liners or other approved

mitigation methods to minimise contaminated seepage and runoff from entering the

local aquatic systems;

Where storm water enters river systems from disturbed sites, sediment and debris

trapping, as well as energy dissipation control measures must be put in place; and

The planting of indigenous vegetation around pollution control impoundments and

structures must be completed as this has been shown to be effective in erosion and

nutrient control.

The construction of linear infrastructure such as roadways and conveyor systems must

consider the following mitigation actions when encountering wetland systems and

watercourses:

No crossings over riffle/rapid habitats. These must be avoided as these are the most

sensitive; slow deep/shallow habitats are favoured for crossings;

The crossing points must be stabilised to reduce the resulting erosion and downstream

sedimentation;

Structures must not be damaged by floods exceeding the magnitude of those which

may occur on average once in every 50 years;

The indiscriminate use of heavy vehicles and machinery within the instream and

riparian habitat will result in the compaction of soils and vegetation and must be

controlled;

Erosion prevention mechanisms such as gabions must be employed to ensure the

sustainability of all structures to prevent instream sedimentation;

The crossing points must be unobtrusive (outside riparian and instream habitat) to

prevent the obstruction and subsequent habitat modification of downstream portions;

Diversion trenches and berms must convey dirty water to temporary ditches so as to

contain runoff. These trenches and ditches can be vegetated to improve soil stability

and clean the water;

Soils adjacent to the river that have been compacted must be loosened to allow for

germination of vegetation;

Stockpiling of removed soil and sand must be done outside the 1:100 flood line or

delineated riparian habitat (whichever is greater). This will prevent solids from washing

into the river; and

A structure must be in place to capture coal spillage under the conveyor, especially

where this interacts with any watercourse.

The removal of vegetative cover, as well as the construction of roads has been recognised as

being responsible for increased runoff, sedimentation and subsequent water and habitat

quality degradation in downstream portions of river systems (WRC, 2014). As such the careful

management of vegetation removal and sedimentation control must take place. This can be

achieved through the brief points below:

Minimise the removal of vegetation in the infrastructure footprint area;

Re-vegetation of the construction footprint as soon as possible;

Where storm water enters river systems, sediment/silt and debris trapping, as well as

energy dissipation control measures must be put in place;



40

Storm water must be diverted from construction activities and managed in such a

manner to disperse runoff and prevent the concentration of storm water flow;

Sequential removal of the vegetation is preferred over stripping all vegetation at once;

and

The vegetation of unpaved roadsides.

During the operational phase of the proposed project, the storage and handling of

carboniferous material can result in the degradation of downstream aquatic ecosystems. In

order to prevent this, the use of diversion and containment management is of importance. This

can be achieved through effective groundwater and surface water management as per the

surface and groundwater studies; however important management actions are briefly listed

below:

Diversion trench and berm systems which diverts clean storm water around pollution

sources and convey and contain dirty water to central pollution control impoundments;

Barrier systems, including synthetic, clay and geological or other approved mitigation

methods to minimise contaminated seepage and runoff from stockpiles and pollution

control facilities from entering the local aquatic systems;

Where storm water enters river systems from disturbed sites, sediment and debris

trapping, as well as energy dissipation control measures must be put in place; and

The planting of indigenous vegetation around pollution control impoundments and

structures as well as along road sides on routes used to transport coal must be

completed as this has been shown to be effective in erosion and nutrient control.

As described in the potential impacts of this proposed project, there is potential for Acid Mine

Drainage to develop as a result of underground mining activities. The only mitigation possible

for potential mine water decant is the use of passive or active water treatment. This is therefore

recommended. The groundwater report (GCS, 2018) suggests that decant from the two mine

areas is highly unlikely to occur. Despite this, ZAC must cater for decant events.

8.7 Recommendations and Environmental Management Plan

Based on the outcomes of this study, the further actions are recommended.

Completion of erosion risk assessment and management plan;

Completion of Rock Engineering Subsidence Assessment;

Stormwater Management Plan; and

Bi-annual Aquatic Biomonitoring.

The bi-annual aquatic biomonitoring and environmental monitoring plan is provided in Table

31. It is noted that the mitigation actions provided in this assessment must make use of the

proposed mitigation actions as an Environmental Management Plan.



41

Table 31: Environmental Monitoring Programme

Location Monitoring objectives Frequency of

monitoring

Parameters to be

monitored

Additional sites are

recommended both

upstream and

downstream

Overall PES Bi-annual

Standard River

Ecosystem Monitoring

Programme (Ecostatus)

methods


recommended both

upstream and

downstream

Determine if water quality

deterioration is occurring. Bi-annual

SASS5 scores should

not decrease as and be

related to mining

activities.


recommended both

upstream and

downstream

Determine if water quality

deterioration is occurring. Monthly

Standard water quality

monitoring


recommended both

upstream and

downstream

Determine if

water/habitat quality

deterioration is occurring.

Bi-annual Monitor for presence of

fish.

The watercourses considered in this assessment currently have no Resource Quality

Objectives (RQO) assigned. As a management strategy, the DWS (2018) default ecological

category for the three project SQRs was derived to be largely natural (class B). A breakdown

of objectives to achieve this ecological category is presented in Table 32.

Table 32: Proposed Resource Management Objectives for Instream Habitat and Biota in the Project Area

River Management Objective Numerical Limits

Black Mfolozi

Mvalo

Mngeni

Instream habitat must be in a largely natural or better

condition to support the ecosystem.

Instream biota must be in a largely natural or better

condition.

Low and high flows must be suitable to maintain the

river habitat for the ecosystem condition or

ecotourism.

Overall salt and sulphate concentrations must be at a

level where it does not threaten aquatic ecosystem or

agricultural users.

Toxics must not negatively impact on the aquatic

ecosystem or agricultural users.

Instream IHIA ≥ B (≥79);

Fish ecological category ≥ B (≥79);

Macroinvertebrate category ≥ B (≥79)

Instream Ecostatus category ≥ B (≥79)

As defined by default ecological category for the project area watercourses, the ecological

class was not achieved during this baseline assessment. It is noted that spate conditions have

likely masked baseline conditions (outside of flood events), reflecting a lower ecological

category. The precautionary approach has been adopted, and resource management should

aim for the default ecological category going forward. Should the proposed project go-ahead,

and successfully implement mitigation and avoidance actions, the cumulative impact to the

SQR’s will be low to moderate. However, should mitigation actions not occur successfully,

there is potential for further impacts to SQR’s.



42

9 Conclusion

9.1 Baseline Ecology


Mfolozi river reach considered in this assessment. It is noted that flood conditions have likely



biological responses. Instream habitat modification can be attributed to large scale catchment


the instream habitat.

Similarly, the PES assessment derived largely modified (class D) conditions in the Mvalo River

reach. Limited instream habitat diversity and water quality impairment have resulted in

modified aquatic ecology. The modification of the watercourse is likely attributed to catchment

related activities and the naturally low habitat availability at the sample site.


River reach considered in this assessment. Post flood conditions have contributed towards an

underestimation of aquatic biota. Modified biological responses in the river reach are indicative

of instream and riparian habitat modifications. The modifications can be attributed to


A single red listed fish species is expected within the river reaches in the study area

Oreochromis mossambicus (Near Threatened {NT}). O. mossambicus is threatened by

hybridisation with O. niloticus and therefore the proposed project does not pose a threat to

this species.

It is noted that flood conditions have skewed the baseline assessment results with an

underestimation of aquatic biota present under normal flow conditions. This was reflected by

the low representation of fish species sampled. In order to address this gap, data from desktop

sources were utilised to establish ecological sensitivity. It is however recommended that an

additional survey is conducted to obtain defined ecological conditions in the watercourses

directly associated with the proposed project. This proposed survey should be conducted in

during the initiation of the construction phase along with standard continuous (Life of Mine) bi-

annual aquatic biomonitoring.

9.2 Risk Assessment

The results of the risk assessment derived moderate to high risks with a single low risk for the

proposed project. Majority of the risks can be lowered in risk status through the implementation

of appropriate mitigation. The proposed open cast pit and new adit Alternative 2 areas lay

outside of aquatic areas and therefore will not require any excavations within aquatic areas or

river diversions. The project needs to pay special attention to and cater for the funding and

management of Acid Mine Drainage associated with the closure and post-closure phases as

this poses the greatest threat to aquatic ecology extending from the local ZAC project area to

further downstream areas (Black Mfolozi River to the coast - regionally).



43

9.3 Specialist Recommendation

Considering the status of the aquatic ecosystems, and furthermore the nature and

requirements of the project, the proposed project has the potential to negatively affect local

ecology in the long term. In light of the above mentioned, it is the opinion of the specialist that

provided the new adit Alternative 2 is chosen and adequate mitigation measures implemented

for all project related activities, the project can commence.



44

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