Mitigation measures and precedent

An agricultural assessment of the farm Everglades affirms the catergorisations by the Natural Resources Division of the KZN Department of Agriculture and the Land Use Regulatory Unit of the Department of Environmental Affairs as High potential agricultural land. The use of the land as a Residue Storage Facility will for a period of 10 to 15 years put a hold on the current agricultural activities on the land.

The change of land use can however not be seen in isolation or considering the mitigation measures being put in place. These measures are recorded below:

31 7.3.1. Existing mining rights

The mining rights and development approval was issued in 2010 and 2014 respectively.

The need for the identification of an alternative Residue Storage Facility was as a consequence of the request the then Department of Water and Sanitation. The mining and development rights are therefore still in place – only the phase 2 Residue Storage Facility is being moved to an adjoining land parcel, in this instance an operational farm.

This application is therefore not made in isolation, or as a new activity, but as the continuation of an existing approved mining activity.

7.3.2. Comparison of Everglades option vs initial Phase 2 option

A number of reports have been actioned by Tronox to compare the implications of establishing the Phase 2 Residue Storage Facility on Everglades, as opposed to the original plan on the current Tronox approved mining site east of the N2.

These reports all reflect that whilst both options have impacts on the environment, the impact of using Everglades has less impacts.

Three of the other specialist reports have a bearing on the Everglades assessment, the most significant being Dr Garry Patterson’s Nov 2010 Volume 2: Detailed Soil Mapping Phase Report, (Table 5, page 15, map pg 30). This table illustrates that, with the exception of Hutton and Pinedene Soils, the rest of the soils found at the MSRSF site are low to moderate or low yield potential soils. The same report also finds a relatively low percentage of wetland at the MSRSF site. Page 19 of the Patterson report also makes a few very specific recommendations regarding possible impact of the MRSF on adjoining properties and the prevention thereof

In contrast, this agricultural report finds that over 90% of Everglades soils are moderate to high, to high yield potential soils.

The Wetland Report found that 92% of Everglades is wetland, a figure confirmed in this report by visual observation, photographs and 65 out of the 69 soil profiles (94%)

The Eco-Pulse report makes the point that there is an exceptionally high incidence of wetland areas of the iNyezane catchment.

7.3.3. Rehabilitation

Various rehabilitation action plans are being developed in response to the various specialist reports being developed. It is also the intension to establish a multi-sectoral committee to monitor implementation and compliance.

32 If rehabilitation is effective, and improved from my previous experiences with other mining area, the change in land use will be temporary during the duration of the mining and rehabilitation.

7.3.4. Financial and employment contribution

Whilst the change in land use per se does not attract the economic and employment benefits associated with the mining, not allowing the Phase 2 Residue Storage Facility will ultimately lead to the premature closure of the mine. The mine contributes more than a Billion Rand to the local and regional economy annually and on average 730 jobs annually.

8. CONCLUSIONS AND RECOMMENDATIONS 8.1 Conclusion

Although there has been a wetlands study by others, the experience at site required that the agricultural impact specialist draw his own conclusions on the current impact of water table levels on the soil, water, oxygen plant cycle on the Everglades sugarcane crop.

Of the 69 soil profiles that were examined, 65 profiles were those of soils that have evolved in areas with high water tables, aquifers, seepage eyes etc. in short, wetland or wetland type ecosystems. Ironically, same 65 profiles indicate a high yield potential sugarcane farm.

The wetland specialist established that 92% of Everglades is wetlands. The outcome of the 69 profiles examined in this assessment indicated that that 94% of the farm is wetland, so the outcomes of the two studies are complementary to each other.

Provided that the water table is at a minimum at minimum of 600 to 650 mm below the surface, these heavy soils will yield above average sugarcane harvests as the plant is not stressed during short and seasonal shortages of groundwater.

In this instance the ability to absorb, store and then release rainwater upwards into the rooting zone as the surface begins to dry out is enhanced by an exceptionally high mean rainfall pattern. This combination of factors places this farm and its neighbours in a situation where rainfed sugarcane crops can be grown and harvested at well above the industry average. The effect of the wetland pattern at Everglades is in many ways akin to a subsurface irrigation facility.

Apart from any impacts on the target site, both national and provincial regulations state that the agricultural specialist must assess the impact of the change of land use on adjoining properties.

Mining in general have implications for surrounding neighbours. Tronox have however undertaken a large number of studies including wetland and biodiversity, water and waste

33 water management, estuary and socio-economic and other studies to identify and mitigate impacts, such as seepage from the residue storage facility, dust and related impacts. All these studies include mitigation measures, which if carefully implemented and monitored will reduce impacts to low probability.

8.2 Recommendation

It is noted from the 2012 Environmental Management Programme that the intention is to leave the mining residue in situ and cover it with an appropriate stratum of enhanced topsoil.

In terms of this assessment, it has determined that the target site will not be restored to the current condition. On the other hand, the client has undertaken to re-establish an agricultural potential of a different form and quality at the conclusion of the useful life of the site as a mine residue storage facility.

In terms of a purely agronomic impact, an agricultural capability will be re-established in the medium to long term. Provided that the outcomes of ongoing research, as well as implementation of existing recommendations are put into effect, there is no agricultural or agronomic reason why the change of land use should not be approved, albeit the restoration is on a medium to long term basis.

Previous experience indicates that a quid pro quo will be required by the relevant authorities in the form of equivalent tonnage. This is a matter that the client will probably have to address with both the sugar industry and the regulatory authorities. This model has been successfully applied by THS.

This possibility and the manner in which it could be addressed are outside of the terms of reference for this project.

34 9. USEFUL REFERENCE PUBLICATIONS

The following reference material was utilized during the assessment and verification process:

BioResource data provided by the KZNDARD Natural Resources Directorate, Cedara

Development and Application of a Land Capability Classification System for South Africa: J L Schoeman et al, ARC-ISCW, 2002

Environmental Management Programme Report: Construction of the Fairbreeze Mine and Related Activities: Exigent, 2012.

How to make Agricultural Water work for you: John Phipson Mzansi Agriculture, March 2015 Identification and Management of the Soils of the South African Sugar Industry: SA Sugar Research Institute. (Sugar book)

KwaZulu-Natal Agricultural Land Categories: Collett A (DAFF) and Mitchell FJ (KZN DARD), Version 1, 2012 and its Appendix:

KZN Natural Resources Soil Profile Data Sheets

Land Assessment in KwaZulu-Natal: Botha et al, Natural Resources Directorate, KZN DARD;

Cedara

Natural Resources and/or Agricultural Survey Specifications, Version 2 May 2015: KZN DARD Natural Resources Directorate, Cedara.

Rehabilitation of the Hillendale Mine’s residue storage facility. Beukes, J.A; Vlok, M.L &

Khosa, F.G: Published in Paste 2019 – AJC Paterson, AB Fourie and D Reid (eds) © 2019 Australian Centre for Geomechanics, Perth, ISBN 978-0-9876389-2-2

Soil Classification: A Taxonomic System for South Africa: CN MacVicar et Al, SIRI 1991 (Blue Book). This publication was produced by a working group of 30 scientists, written primarily for scientists

Soils of South Africa: Martin Fey, Cambridge University Press

35 10. APPENDICES

Appendix 10.1: Residue Storage Facility Rehabilitation Process: Section 10.6.9.1 of the