2019-07-17 Issues and Response table - EIA Report.xlsx

Date comments received Issues raised EAPs response to issues as mandated by the applicant and as updated

for the EIA Report

Scoping Public Review Comments

A Nicolson (on behalf of Rand

Leases)

X E-mail received on 31

August 2018

Rand Leases Properties (Pty) Ltd is an interested and affected party for

this application by virtue of the fact of ownership of the following

properties which are intersected by the mining right application:

• Portions 407, 408, 409 & 429 of the Farm Roodepoort 237 IQ

Rand Leases (Pty) Ltd has been identified and registered as an

Interested and/or Affected Party (I&AP) on the West Wits project

database.

Although all of these mentioned farm portions of the Farm Roodepoort

237 IQ are included in the proposed mining right application area ('mine

site'), only portion 429 (proclaimed for township development) would

be directly affected by one of the proposed opencast mining areas,

namely the Roodepoort Main Reef Pit.


Leases)


August 2018

Rand Leases Securitisation (Pty) Ltd is an interested and affected party

for this application by virtue of the fact of ownership of the following

properties which are intersected by the mining right application:

• Remainder of Portion 161 of the Farm Vogelstruisfontein 231 IQ

Rand Leases Securitisation (Pty) Ltd has been identified and registered

as an I&AP on the West Wits project database.

Although this farm portion is included in the proposed mine site, this

farm portion would not be directly affected by any of the proposed

mining activities.

Interested and Affected Parties

List the names of persons consulted

in this column, and mark with an X

where those who must be consulted

were in fact consulted.

West Wits Issues and Response Table July 2019 of 170


for the EIA Report







Leases)


August 2018

RE-SUBMISSION:

The fact that the application can change so significantly in the space of

three months is a serious concern about the overall planning of the

proposed future mine. Based on my comparison of the original and

resubmission of the Scoping report, the following main changes have

been made;

During the public participation process (PPP) of the original mining right

application process, issues and concerns were raised by I&APs. The

project team are trying to consider these comments received. However,

in order to incorporate these comments, changes to the scope of the

project were required which lead to the need to re-apply for the mining

right and supporting environmental authorisation applications.

The changes indicated to the open cast pits are correct: Based on the

Farm portions mentioned above, the only direct impact as a result of

mining related activities is the Roodepoort Pit.

The changes indicated to the infrastructure complexes are correct: The

inclusion of the Bird Reef Central Underground Workings does not

directly impact Rand Leases, and is a target area under Dino Properties

(Pty) Ltd and DJL Inv (Pty) Ltd as the registered landowners.

The changes in wording regarding processing are correct.

The change to West Wits' empowerment is correct.

No change to the total mineable resource is correct.


Leases)


August 2018

Please provide evidence of a pre-feasibility and feasibility report to

prove the viability of the proposed mining project. The fact that a 40

hectare underground area can be excluded and a new 52 hectare

underground mining area be included in the space of 3 months, (with

no implication on the total minable reserve) raises significant concerns

about the resource statement and the applicants technical ability for

the proposed project. As requested during the previous application,

please provide a copy of the prospecting results and mine works

programme to prove the viability of the future mine.

All identified resources have been included and referred to however not

all are going to be considered.

A copy of the resource statement was provided to Rand Leases

Properties (see proof in Appendix B of the EIA Report dated May 2019).

A redacted version of the Mining Work Programme will be supplied for

these areas, and the technical team will continue to engage with Rand

Leases.



for the EIA Report







Leases)


August 2018

Please provide evidence of a Proven Reserve as signed off by a

suitable qualified person.

The mineral resource as submitted to the Department of Mineral

Resources (DMR) is as per the DMR requirements. A copy of the

resource statement was provided to Rand Leases Properties (see proof

in Appendix B of the EIA Report dated May 2019).


Leases)


August 2018

Please explain how in the space of 3 months the area for the Mona

Lisa pit can increase from 3 hectares to 20 hectares (with no alteration

to the minable resource).

The layout of the surface infrastructure associated with the Mona Lisa

Pit was amended to include associated structures and infrastructure

such as the waste rock dump, topsoil berm and haul road.


Leases)


August 2018

During the previous consultation process for the original scoping

report, we were informed that no underground mining would be

implemented from the Bird Reef Central infrastructure area. The fact

that in less than 3 months a re-submission of the application indicates

that underground mining will take place from the Bird Reef Central

infrastructure implies that we were completely misinformed.

During the PPP of the original mining right application process, issues

and concerns were raised by I&APs. The project team are trying to

consider these comments received. However, in order to incorporate

these comments, changes to the scope of the project were required

which lead to the need to re-apply for the mining right and supporting

environmental authorisation applications. Therefore to inform you

adequately the application was re-submitted and a new Scoping Report

went out for public review.


Leases)


August 2018

The following comment contained within the alternative section of the

re-submitted application highlights our concerns around the planning

of the project:

"The property on which the actual open pit and underground mining

related activities takes place is dependent on the location of the target

mineral resource. It follows that no alternatives could be considered

for the mine site. "

This comment is provided despite the fact that 3 month prior to the

submission of this application a completely different underground

resource was targeted for exploitation.






environmental authorisation applications. The proposed Main/South

Reef West Infrastructure Complex and Underground Workings had to be

excluded from the Mining Right Application as the project team became

aware that the surface area had been proclaimed a new township,

which will require rezoning. This resulted in the inclusion of the

proposed Bird Reef Central Underground Workings. Therefore to inform

you adequately the application was re-submitted and a new Scoping

Report went out for public review.



for the EIA Report







Leases)


August 2018

Upon querying with the EAP for a brief explanation of the reason for

the reapplication and the main differences between the original and

this new application. The response received was;

"The applicant felt the need to re-apply in order to:

• Include the consideration of design/layout alternatives for the

opencast mine pits; and

• Exclude the Main/South Reef Infrastructure Complex and

underground mine workings which would have been located towards

the north-western side within the proposed mining right

application area next to Witpoortjie. "

The above is a serious understatement of the changes that have taken

place between the original and resubmitted application raising

concern about the EAP’s ability to communicate effectively with

interested and affected parties."

The changes as mentioned above were as a result of the changes to the

design/layout of the opencast mining areas and the Bird Reef Central

Infrastructure Complex.










Leases)


August 2018

For all interested and affected parties who have dedicated time and

effort to comment on this application, it is only fair that all differences

between the 2 projects are clearly highlighted and explained. Without

this it would be very hard to trust information provided in future

about the proposed project.

Changes between draft and final reports within the same application

process will be clearly highlighted. However, changes to the scope of the

project was required which lead to the need to re-apply for the mining

right and supporting environmental authorisation applications.

Therefore to inform you adequately the application was re-submitted

and a new Scoping Report went out for public review.



for the EIA Report







Leases)


August 2018

Roodepoort Main Reef Pit

Previous correspondence with West Wits and an independent

professional opinion obtained during the township development

application indicated that the reef close to the surface has already

been mined out to a point where future exploitation was not

economically viable. Please provide evidence that an economically

viable gold resource within this area remains available for

exploitation. The need for this evidence is become more crucial based

on the amendments made to the application in the space of 3 months.

The letter provided by West Wits to Rand Leases was given at a time

prior to the quantification of the mineral resource.

Reference is made to the statement in the last paragraph on page 2 of

the Rand Lease comments: "In terms of timelines, Rand Leases believe a

reasonable timeframe for the commencement of the Cresswell Park

Extension 3 development is 3 to 5 years from 2018."

These timelines mean that the proposed opencast mining of 6 months

and 2 month rehabilitation period at the Roodepoort Main Reef Pit can

take place and be completed prior to Rand Leases' 2020 to 2023

timelines. Portion 407 of the Farm Roodepoort 237 has not been

proclaimed for township development.



Leases.


Leases)


August 2018


During the time mining is being planned and is taking place, it will

effectively sterilise Rand Leases opportunity to develop the land. The

mine must enter into a lease agreement with Rand Leases in order to

access and use the land. This agreement is to be in place for the

duration that proceeding with the residential development is not

possible due to the proposed mining activities.

West Wits is in agreement with this request. A lease agreement

between West Wits, Rand Leases and MAXAM Dantex is required in

order to address commitments accordingly.


the Rand Leases comments: "In terms of timelines, Rand Leases believe

a reasonable timeframe for the commencement of the Cresswell Park

Extension 3 development is 3 to 5 years from 2018. "


and 2 months rehabilitation period at the Roodepoort Main Reef Pit can

take place and be completed prior to the 2020 to 2023 timelines for the

Creswell Park Extension 3 development.



for the EIA Report







Leases)


August 2018


Known servitudes which occur on the property include, electrical

servitudes, pipeline servitudes and cable servitudes. Please ensure all

existing servitudes are shown on future plans. Should these servitudes

be affected by future mining, then either they should be avoided or

appropriate authorisations must be acquired to move the servitude

and the related infrastructure.

West Wits is in agreement that should these servitudes be affected,

authorisation will be obtained.

Meetings were held between the applicant and the respective

infrastructure owners and site visits along the servitudes as well as risk

assessments were conducted. Ongoing consultation will take place.

Although the pipeline routes were made available to the applicant, the

respective infrastructure owners requested these routes not to be put

out in the public domain.


Leases)


August 2018

Roodepoort Main Reef Pit, 11 Shaft Main Reef Pit

Guarantees must be given concerning the maximum proposed depth

and length of the mining activities and the timeline proposed.





Leases)


August 2018


A study is required to define the compaction levels required to

facilitate future residential and industrial development. Once

determined, these compaction levels need to be stated in the closure

objectives for this specific project.





Leases)


August 2018


Final closure to facilitate the development activities must be

documented in the closure plan and must consider the requirements

of Cresswell Park Extension 3 project and Rand Leases Extension 15

Industrial Project.

This issue has been noted and has been considered by the Closure

specialist in Appendix S to the EIA Report.


Leases)


August 2018

11 Shaft Main Reef Pit

Sections of the pit falls within the blasting zone of Maxem Dantex.

Conditions of Dantex blasting permit need to be adhered to. Rand

Leases will only support this project if Maxam Dantex have indicated

in writing their acceptance for the project.






for the EIA Report







Leases)


August 2018


The following land occupiers on the Remainder of Portion 161 of the

Farm Vogelstruisfontein 231 IQ must be consulted and given the

opportunity to provide input into the Environmental Authorisation

Process (Contacts details of land occupiers are available on request):

a. Maxam Dantex

b. EnviroServ

c. Much Asphalt

d. B and V Mining and Slabs

e. Natures Dream Bread

f. SCK Fuel Distributors CC

g. High Flame (Pty) Ltd

h. AC Signs and Marking (Pty) Ltd

i. Mlilo Projects (Pty) Ltd

The land occupiers were registered as I&APs on the West Wits project

database and will be included in future correspondence regarding the

regulatory process. Please refer to Appendix B of the EIA Report for a

copy of the I&AP Database.


Leases)


August 2018


Guarantees need to be made that existing tenant holders will not be

restricted in terms of “business as usual” during the mining

operations.





Leases)


August 2018


During the time mining is being planned and is taking place, it will

effectively sterilise Rand Leases opportunity to develop the remainder

of Rand Leases Extension 15 Industrial Project, which is

imminent. The mine must enter into a lease agreement with Rand

Leases in order to access and use the land. This agreement is to be in

place for the duration that proceeding with the industrial

development is not possible due to the proposed mining activities.





the Rand Lease comments: "In terms of timelines, Rand Leases believe a

reasonable timeframe for the commencement of the Rand Leases

Extension 15 Industrial Project within 1 to 2 years from 2018 ."


and 2 month rehabilitation period at the 11 Shaft Main Reef Pit can take

place and be completed prior to the 2019 to 2020 timelines for the Rand

Leases Extension 15 Industrial Project.



for the EIA Report







Leases)


August 2018


Please ensure all existing servitudes (sewage lines, water pipe lines

and electrical lines) covering the property are shown on future plans.

Should these servitudes be affected by future mining, then either they

should be avoided or appropriate authorisations must be acquired to

move the servitude and the related infrastructure.

West Wits agrees that should these servitudes be affected,

authorisation will be obtained.

Meetings have been held between the applicant and the respective

infrastructure owners and site visits along the servitudes and risk

assessments were conducted. Ongoing consultation will take place.

Although the pipeline routes were made available to the applicant, the

respective infrastructure owners requested that these routes not be put

out in the public domain.


Leases)


August 2018


Services to tenants will be affected by the open cast mining such as

the bulk outfall sewer, water lines, and overhead electrical lines,

provision needs to be made that alternate services are provided so

that the businesses are not impacted.





Leases)


August 2018


A critical access road is been mined through blocking access for

Dantex to access the factory site. An alternative access road (which is

similar in distance) need to be planned for and provided. Uninhibited

access from the Dantex office complete to the factory site must be

provided.

This issue has been noted and has been considered by the Traffic

specialist (Appendix O). Relevant impacts including mitigation and

monitoring measures have been assessed and included in Appendix D of

the EIA Report.


Leases)


August 2018


All impacts must be considered cumulatively with the existing impacts

within the area.

A cumulative impact assessment has been included in Appendix D of the

EIA Report.


Leases)


August 2018

Kimberley East Pit Activity

This pit is planned within the blasting zone of Dantex. Rand Leases will

only support this project if Dantex have indicated in writing their

acceptance for the project.





Leases)


August 2018

Kimberley East Pit Activity

Conditions of Dantex blasting permit need to be adhered to.






for the EIA Report







Leases)


August 2018

Kimberley Reef East Underground Activity

This shaft complex is planned within the blasting zone of Dantex.

Conditions of Dantex blasting permit need to be adhered to. Rand

Leases will only support this project if Dantex have indicated in writing

their acceptance for the project.





Leases)


August 2018


The Dantex explosive factory is planned to be undermined. Stability

studies undertaken by a qualified rock mechanic is required to prove

that no surface subsidence will take place as a result of mining.

This issue has been noted and relevant impacts including mitigation and


the EIA Report.


Leases)


August 2018


Dantex will blast continue to blast on a daily basis. Conditions of their

explosive permit must be adhered to.





Leases)


August 2018


Rand Leases has a long term rolling lease with Dantex, and any action

which has an affect to this lease, will be a considerable amount.





Leases)


August 2018

Bird Reef Underground Activity

As this project currently stands (as described in the Scoping Report)

there will be no direct impact from the infrastructure development or

the underground mining activities on any Rand Leases properties.

However the impact on services within the area (electricity /traffic /

water etc.) will effect Rand Leases proposed developments.

West Wits is in agreement that should these services be affected,

alternate services should be provided.



for the EIA Report







Leases)


August 2018

Bird Reef Underground Activity

Guarantees need to be provided concerning the extent of the

underground mining area. What is stopping the mine expanding on

the application area covered by the Scoping Report.



order to address commitments accordingly. In the event that the

applicant would like to expand underground mining areas within the

mine site that is not included in the current mining right application

process, an EIA amendment process will have to be followed.

The boundaries of the proposed mining right application area has also

been amended significantly reducing the size of the application area.

This has been included in the EIA Report dated May 2019.


Leases)


August 2018

A copy of the mine works programme for the application. The reason

for the request of this document is to be able to fully understand the

future planning intentions of the mine as these

plans have a direct impact on the future landowner development

plans. Understanding planning and time horizons is critical for the

landowner.



Leases.


Leases)


August 2018

Details of all existing servitudes dissecting our properties must be

shown on a plan and overlaid by the proposed projects.

Meetings between the applicant and the respective infrastructure

owners and site visits along the servitudes and risk assessments have

been held. Ongoing consultation will take place. Although the pipeline

routes were made available to the applicant, the respective

infrastructure owners requested that these routes not be put out in the

public domain.


Leases)


August 2018

Details of all proposed roads / pipelines / channels / all other

“supporting infrastructure” (as defined in the Scoping Report) to be

installed to access the various mining activities contained

within the proposed project.

Details of access to required services have been discussed in Section 3.2

of the EIA Report.


Leases)


August 2018

Details of access to required services (potable water / electricity /

sewage)

Details of access to required services have been discussed in Section 3.2

of the EIA Report.


Leases)


August 2018

A plan showing the exact proposed depth of mining in the

underground section affecting our property. This is critical to plan for

the future development activities.






for the EIA Report







Leases)


August 2018

Detailed site layout plans for each project area. Detailed site layout plans of the opencast mining areas are provided in

the Scoping Report and EIA Report. Detailed site layout plans of the

infrastructure complexes have been provided in Section 3.2 of the EIA

Report.


Leases)


August 2018

Detail about the scheduling of the proposed open cast mining

activities.

The opencast mining schedule depends on the ongoing consultation

with landowners in terms of agreements. Details of the open pit mining

schedule have been discussed in Section 3.2.2 of the EIA Report.


Leases)


August 2018

A detailed closure plan and associated financial provision costing for

the implementing of closure activities (when completed). When

developing the closure plans they must take cognisance of the

requirements of the existing developments planned.

This issue has been noted and has been considered by the Closure

specialist in Appendix S of the EIA Report.


Leases)


August 2018

Confirmation that the required compaction levels to facilitate future

residential housing development (up to 240 units per hectare) /

industrial development can be achieved after rehabilitation of the pits.





Leases)


August 2018

A full surface subsidence specialist study must be commissioned. It is

critical to confirm that surface subsidence will not be a concern, as

confirmed by a qualified independent rock engineer. Terms of

reference for this study should be provided in the Scoping Report.



the EIA Report.


Leases)


August 2018

Please investigate the likelihood of mine induced seismic activities as a

result of the proposed underground mining activities.



the EIA Report.


Leases)


August 2018

Additional information is requested in terms of the implications of

mining for Uranium.

a. Where will Uranium minerals be extracted from and processed?

b. What is the current and proposed residual radiation levels?

c. Residual radiation levels must be acceptable for future

developmental activities.

This issue has been noted and has been considered by the Radiological

specialist (Appendix K). Relevant impacts including mitigation and


the EIA Report.



for the EIA Report







Leases)


August 2018

During the EIA phase of the application a town planner must provide

evidence that the existing services within the area can handle the

additional requirements in terms of;

a. Road networks / traffic impact

b. Electricity

c. Water

d. Sewage.

Details on access and transport, power supply and use, water supply

and management and sewage management required by the project

have been discussed in Section 3.2 of the EIA Report.

West Wits will apply and obtain legal connection from the relevant

service providers.


Leases)


August 2018

Expand on where dewatering and associated treatment of such water

will occur.

This issue has been noted and has been considered by the Groundwater

and Surface Water specialists (Appendix G and Appendix H) and

potential impacts on surface water and groundwater have been

assessed in Appendix D of the EIA Report.


Leases)


August 2018

The Scoping Report indicates that blasting activities may take place

from year 6 onward, implying that no blasting will be implemented for

the open cast activities. This is contradicted with Table 18 of the

report which indicates blasting impacts could be experienced for both

open cast and underground mining activities. Details concerning

blasting needs to be expanded upon,

a. Will there be any blasting associated with the open cast activities?

b. If yes, how frequent is occasional?

c. what blasting zone will be implemented?

d. What restrictions will this impose on our developmental plans?

This issue has been noted and has been considered by the Blasting and

Vibration specialist (Appendix M). Relevant impacts including mitigation

and monitoring measures have been assessed and included in Appendix

D of the EIA Report.


Leases)


August 2018

The outline of the pits needs to be defined by coordinates which can

be audited and included in any future lease agreement.

Centre coordinates of the open pit mining and underground mining

have been included in Section 3.2 of the EIA Report.


Leases)


August 2018

The mine needs to guarantee that the landowner can proceed with

development as soon as rehabilitation of the pits is completed. The

mine must in conjunction with the DMR guarantee that the land is not

sterilised for the duration of the proposed underground activities (i.e.

25 years). The landowner needs to be compensated until such time a

partial closure certificate in terms of the MPRDA (for the pits) is

obtained.






for the EIA Report







Leases)


August 2018

No restriction / objection on any application to facilitate future

developmental activities by the mine.





Leases)


August 2018

Update the surrounding land use table to accurately reflect

surrounding land users / occupiers.

The land use table is based on available information regarding

surrounding land users and/or occupiers, and has been included in

Section 6.4.2 of the EIA Report.


Leases)


August 2018

Based on studies completed for Rand Leases there are known heritage

resources located on the various properties.

This issue has been noted and has been considered by the Heritage

specialist (Appendix P). Relevant impacts including mitigation and


the EIA Report.


Leases)


August 2018

Please investigate if there is any chance of acid mine drainage

resulting from mining activities, which may impact future

implementation of piping for services required for future

development?


specialist (Appendix H). Relevant impacts including mitigation and


the EIA Report.


Leases)


August 2018

Please provide a storm water management plan for each specific

project site to be implemented both during and post mining in the

areas. Final slope of rehabilitated land must be free flowing and

compliment the needs of the future developmental activities.

A Surface Water specialist study including storm water management

plans, has been conducted to address these comments. The storm

water management plans are included in Section 3.2 and Appendix G of

the EIA Report. Relevant impacts including mitigation and monitoring

measures have been assessed and included in Appendix D of the EIA

Report.


Leases)


August 2018

Will the mining activities result in increased radiation levels within the

vicinity of the pits and dumps?




the EIA Report.


Leases)


August 2018

Provide detail concerning the proposed security arrangement in terms

of access control and ensuring trespassing of future mine employees

is prevented.

Details regarding the proposed security arrangements for the project

have been discussed in Section 3.2.15 of the EIA Report.



for the EIA Report







Leases)


August 2018

Please explain why the re-submitted report has amended the dealing

with waste within the footprint of the areas affected by the proposed

mining from;

a. Original Report: “The proposed project would require the

bulldozing, sorting and disposal of this waste.” To;

b. Re-submitted report: “The final management of this waste is yet to

be determined”

Illegally dumped general and hazardous waste exists within the project

footprint. The final management of this waste is yet to be determined.

The proposed project would require the bulldozing, sorting and disposal

of this waste on site. A waste management procedure will be developed

for the project.


Leases)


August 2018

Rand Leases look forward to evidence that all the above concerns /

queries will be addressed during the EIA phase of the application.

As per the above responses, more detail has been provided in the EIA

phase.

Handri Storberg-Nel -

MAXAM Dantex South Africa

(Pty) Ltd

X E-mail (with attachments)

received on 7 August 2018

Open Pit Activities - 11 Shaft Pit Activity

According the OSH-ACT #85, Explosives regulation which stipulated

the safety distance, the 11 Shaft Pit Activities are situated within the

outer/public safety distance of one of the magazines. Bearing in mind

that the safety distances are calculated to minimize the casualties and

dame of people and property during an incident, allowing mining

activities within the safety zone will contravene the legal requirement

for operation. In addition, it will also endanger the livers of +/-50

people working in the area including the fleet as indicated in the

report.

The waste rock dump and ROM ore stockpile crusher area for the

proposed 11 Shaft opencast pit falls within the MAXAM Dantex safety

distance.






(Pty) Ltd



Open Pit Activities - 11 Shaft Pit Activity

The proposed open cast mining activities is situated directly on the

access road to the Dantex Factory facility which will affect the

business' operations as all transportation of raw material, products

and personnel to and from the factory will be hindered.




the EIA Report.



for the EIA Report








(Pty) Ltd



Under Ground - Kimberley Reef East Pit Activity

The proposed underground mining activities as per the scoping report

indicates that the activities will occur directly underneath the factory.

The factory included storage magazines housing approximately 100

tonnes of explosives at any given time. The underground operations

that shall be taking place such as blasting and drilling pose a high risk

of structural integrity deterioration which will compromise the safety

of the magazines resulting in incidents such as explosion.







(Pty) Ltd




The portion of the proposed Kimberley Reef East Infrastructure

Complex is situated within the leased buffer zone.

As per Figure D5 of the Scoping Report dated December 2018, the

proposed Kimberley Reef East Infrastructure Complex will not be

located in the MAXAM Dantex safety distance.



(Pty) Ltd




The past mining activities have resulted in unstable ground which

currently is resulting in sinkholes within the factory. As such, further

underground mining activities pose a major threat of more sinkholes

occurring jeopardising the safety of the facility and personnel within.



the EIA Report.



(Pty) Ltd




The factory conducts blasting activities on a daily basis as part of the

Product Quality tests. Thus, a combination of blasting activities on the

surface and underground poses a threat of ground instability leading

to collapse and sinkholes.







(Pty) Ltd




Increased traffic of personnel around the factory will compromise the

security and thus increase the chances of theft of explosives

particularly in view of the escalating cash in transit heists involving

explosives.

This issue has been noted and has been considered by the Socio-

economic specialist (Appendix Q). Relevant impacts including mitigation



Public open day attendee X Public open day held on 22

August 2018

(Braamfischerville MPC)

What are the timeframes of when mining will commence? The commencement of mining is subject to the competent authority's

decision on the proposed project. Mining may only commence following

the granting of the environmental authorisation by the DMR.



for the EIA Report







August 2018


What is the situation with the mining forum and when will it be

established?

A mining forum will be established upon approval of the mining right.


August 2018


What will West Wits do in terms of SMMEs? Details on promoting justifiable economic and social development have

been discussed in Section 5.5 of the EIA Report.


August 2018


I would like to know how West Wits is going to benefit the actual

primary, pioneer, elderly, NPO organizations and indigenous

inhabitants of the land that they will be mining.

Details on promoting justifiable economic and social development have



August 2018


How are the SMMEs going to benefit from this project from start to

finish so as to economically emancipate the people who live there.




August 2018


We want SMMEs to benefit. Details on promoting justifiable economic and social development have



August 2018


My interests are the beneficiation of the elderlies' soup kitchen in my

ward that is feeding more than 150 elderly people.




August 2018


Will the houses crack? This issue has been noted and has been considered by the Blasting and





August 2018


Will West Wits be liable if anything happens to the houses? This issue has been noted and has been considered by the Blasting and





August 2018


Will dust be created by the operations? This issue has been noted and has been considered by the Air Quality

specialist (Appendix J). Relevant impacts including mitigation and


the EIA Report.


August 2018


I am an operation management graduate looking for opportunities. Should the proposed project be approved it is recommended that you

contact the applicant directly.



for the EIA Report







August 2018


Will there be job opportunities? Details on workforce required by the project have been discussed in



August 2018


Unemployment is an issue and the mine must continue in order to

create job opportunities.

Details on workforce required by the project have been discussed in



August 2018


The mine will create job opportunities and it will reduce criminal

activities. We don't gain of our own resources due to the export

thereof.

These issues have been noted and have been considered by the Socio-





August 2018


Skills development and training in mining is important especially for

our youth.




August 2018


Proper consultation with the community will ensure a successful

process. No ward councillors.

The Public participation process (PPP) undertaken to date is in line with

Chapter 6 of the EIA Regulations (2014), as amended and have been

discussed in Section 6.2 of the EIA Report.


August 2018


The affected wards within the Mining Right Application area are 127,

49, 50, 129, 48, 44 and 70. CPA assistance not required.

This point is noted.


August 2018


A legitimate forum and West Wits must meet. The West Wits Community Forum has been established in Roodepoort.

All proposals and requests for meetings can be sent to the forum's

secretary Mduduzi Jack at the following contact details:

Mobile - 073 388 6803; and

Email - [email protected]




for the EIA Report







August 2018


The forum doesn’t represent everyone in Braamfischerville. A proper

forum must be developed. A starting point is the Ward Councillor for

representation.

The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and




August 2018


Electricity supply is a concern. Details on power supply and use required by the project have been

discussed in Section 3.2.10 of the EIA Report.


August 2018


Baseline studies of historical mining must be conducted. Specialist studies have taken into account current baseline conditions

which includes existing impacts.

However, baseline studies of historical mining falls outside the scope of

this Scoping and EIA process.


August 2018


Earth shakes/ land trembles West of Johannesburg cause trauma for

people.



the EIA Report.


August 2018


How sure are you that there won't be any problems regarding the

earth shaking.



the EIA Report.


August 2018


Carbon credits. Communities have to reduce their carbon footprint. This issue has been noted and has been considered by the Climate

Change specialist (Appendix I). Relevant impacts including mitigation




August 2018


Community projects have to identify projects which affect them. The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and




for the EIA Report







August 2018


We have water issues, what are the effects on the water table. This issue has been noted and has been considered by the Groundwater

and Surface Water specialists (Appendix G and Appendix H). Relevant

impacts including mitigation and monitoring measures have been

assessed and included in Appendix D of the EIA Report.


August 2018


We want to communicate directly with mine. The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and

Email - [email protected].


August 2018


The rehabilitation fund must be available as a kitty for the community

to start benefitting.

Details of the financial provision prepared for the project, including

rehabilitation costs has been discussed in sections 18, 28 and Appendix

S of the EIA Report.


August 2018


Mining charter compliance is important, not just promises. The 9 legs

of the charter must be complied with deadlines. Existing mine forum is

only with political parties and three wards.




August 2018


Division of the benefits in the community must be developed. Details on promoting justifiable social and economic development have





Mobile - 073 388 6803; and



August 2018


West Wits is in Australia and signed agreements are only with

consultants.




for the EIA Report







August 2018


The mine is far from us. Digging on a rock will impact on people. Should the proposed project be approved, the nearest pit would be 3.5

km from this community. Details of the proposed project layout is

included in Section 3 of the EIA Report.






August 2018


Ward 49 will be affected. Health and houses will be affected. These issues have been noted and has been considered by the Blasting

and Vibration and Human Health specialists (Appendix M and Appendix

R). Relevant impacts including mitigation and monitoring measures have

been assessed and included in Appendix D of the EIA Report.


August 2018


Trucks are a concern. Details of project related traffic volumes have been included in Section

3.2.6 of the EIA Report. This issue has been noted and has been

considered by the Traffic specialist (Appendix O). Relevant impacts

including mitigation and monitoring measures have been assessed and

included in Appendix D of the EIA Report.


August 2018


Please provide a breakdown of the job opportunities. Details on workforce required by the project have been discussed in



August 2018


We want shareholding opportunities. This will be as per the approved SLP.


August 2018


How can I be a shareholder of the company? The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and



August 2018


You must consult on a ward basis to work together as an area. The Public participation process (PPP) undertaken to date is in line with

Chapter 6 of the EIA Regulations (2014), as amended and has discussed

in Section 6.2 of the EIA Report.



for the EIA Report







August 2018


What is the progress with the WML and WUL application process? The Scoping and EIA process that is currently in progress is an integrated

environmental authorisation application process which includes listed

activities triggered in terms of the National Environmental

Management: Waste Act, 2008 for a Waste Management License.

A water use license application (WULA) process has commenced.


August 2018


For the SLP, local NGOs must give input. The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and




August 2018


Sol Plaatjie rehabilitation and forum is separate from the Mining Right

Application process.

This EIA Report does not deal with the existing Solplaatjie mining

operation or the two separate mining permit application processes for

Creswell Park and Kimberley West as these do not form part of the EIA.




Mobile - 073 388 6803; and




August 2018


Meetings should be consolidated in one central meeting venue. The Public participation process (PPP) undertaken to date is in line with

Chapter 6 of the EIA Regulations (2014), as amended and has been



August 2018


You must comply with the mining charter. Details on promoting justifiable economic and social development have




for the EIA Report







August 2018


5% of the turnover every month to communities, who's receiving

that?

Funds will be allocated as per commitments made in the SLP, to be

approved by the DMR.


August 2018


Where is the soup kitchen? The physical address is 29 Kimberley Close, Roodepoort.


August 2018


They have a prospecting right but mining is in progress. This EIA Report does not deal with the existing Solplaatjie mining




August 2018


People have no title deeds so can't complain if houses are damaged. This issue has been noted and has been considered by the Blasting and





August 2018


Health issues are a concern. This issue has been noted and has been considered by the Human

Health specialist (Appendix R). Relevant impacts including mitigation and


the EIA Report.


August 2018


Ward councillors must not be allowed to be hands-on in the project. The Public participation process (PPP) undertaken to date is in line with




August 2018


We will fight for our children. This issue has been noted and has been considered by the various

environmental specialists (Appendix E to Appendix S). Relevant impacts




August 2018


Who do we contact if we have machinery and tipper trucks of 10m3

and 34m3?

This will be as per the approved SLP.


August 2018


We have NGOs in our community that provide some of the skills which

can help mining.


Details on promoting justifiable social and economic development have




for the EIA Report







August 2018


As part of Discovery, we are interested in coming to West Wits and

advising all your employees on their full financial analysis. Please

contact me and set up a date as soon as you have employed workers.



August 2018


Let Sol Plaatjie mines be transparent. This EIA Report does not deal with the existing Solplaatjie mining



Asanda Ncanda X Public open day held on 23

August 2018 (City Hall)

Will dust be a problem? This issue has been noted and has been considered by the Air Quality



the EIA Report.



We are concerned about the health of workers in the mine and the

residents around the mine.

This issue has been noted and has been considered by the Human



the EIA Report.



Will the existing health facilities have the ability and capacity to treat

people with illnesses caused as a result of mining?




the EIA Report.



Will there be job opportunities? Details on workforce required by the project have been discussed in


Regina Tshangana X Public open day held on 23


What must we do with the letters we have received via post? The letters sent to I&APs are notifications from the project team relating

to the public participation as part of the Environmental Impact

Assessment Process.

Brian Mashigo X Public open day held on 23


I am interested in equity. As included in the SLP, West Wits is fully committed to implementing

development plans and projects that will facilitate local community

development in the area surrounding its project in line with the

provisions of the Broad-Based Socio-Economic Empowerment Charter

for the South African Mining Industry.



for the EIA Report






Bradley X Public open day held on 23


I am a resident of Goudrand and I am worried about my house which I

would like to renovate.


Vibration and Socio-economic specialists (Appendix M and Appendix Q).

Relevant impacts including mitigation and monitoring measures have


Group (8) X Public open day held on 23


Where will the office of the mining forum be? A mining forum will be established upon approval of the mining right.

Group (8) X Public open day held on 23


What is the timeline of the BARs and when will mining commence? This EIA Report does not deal with the existing Solplaatjie mining



Mining will only commence if the proposed project received a positive

Environmental Authorisation from the DMR.

Lydia Maotoe X Public open day held on 23


We are concerned about the sand trucks travelling in the morning

between Goudrand and Braamfischerville. Community is not involved

in the mining.

Details of project related traffic volumes are included in Section 3.2.6 of

the EIA Report. This issue has been noted and has been considered by

the Traffic specialist (Appendix O). Relevant impacts including mitigation



Teboho Hlalele X Public open day held on 23


Fleurhof houses are cracking. I have concerns about the

environmental impacts and dust. How will SMMEs get opportunities?

These issues have been noted and have been considered by the various

environmental specialists (Appendix M, Appendix J). Relevant impacts







The Fleurhof Community Forum has not been consulted and wishes to

meet with the mine owners to table concerns as a community and

business initiatives representing over 1 000 businesses in the area.






We are concerned about the process going on without consultation in

the Fleurhof area.






for the EIA Report








We are concerned about the dust (Uranium), water usage and we

want local businesses to be promoted.

These issues have been noted and have been considered by the Air

Quality, Radiological, Surface Water and Groundwater specialists

(Appendix G, Appendix H, Appendix J and Appendix K). Relevant impacts







I represent the community and it must be involved in CSI. Details on promoting justifiable social and economic development have




What will the mine do to ensure Health and Safety? Although permits or approvals in terms of health and safety regulations

by West Wits fall outside the scope of the EIA process, the layout of the

various operations will have to comply with the requirements of all

relevant legislation e.g. the Mine Health and Safety Act, 1996 (No. 29 of

1996) (MHSA).



Skills development is taking place in the community. Ward C is not

taking part in the process.






Mobile - 073 388 6803; and





We want you to establish a functional link between mine

representatives and the community.




Mobile - 073 388 6803; and





for the EIA Report








CPA: Communal Property Association needs to find a way to represent

each community.




Mobile - 073 388 6803; and




Assistance with CPA: West Wits must help with selection/election of a

forum and help to take the process forward.




Mobile - 073 388 6803; and




A CPA must be created for the Ward 49. The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and




Ward C must call a public meeting where a forum is selected. The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and




The new forum needs to be established apart from old forum. The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and





for the EIA Report








The mining must be Mining Charter compliant. Regulations must be

adhered to with set deadlines to comply.





Is there an existing Forum? The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and





What are the community benefits and who are the BEE Partners?. This will be as per the approved SLP.

Details on the applicant have been discussed in Section 1.1 of the EIA

Report.





Where are West Wits in the process. (Mining Right and Mining

Permit).

West Wits currently holds a Prospecting Right and is in the process of

applying for a Mining Right.






Where are West Wits in the process (Prospecting, Mining Right and

Mining Permit)?

West Wits currently holds a Prospecting Right and is in the process of

applying for a Mining Right.






We are concerned about the impact of dust pollution. This issue has been noted and has been considered by the Air Quality



the EIA Report.



for the EIA Report








The ward will be affected by health impacts and how will our property

be affected?

These issues have been noted and have been considered by the Human

Health and Socio-economic specialists (Appendix Q and Appendix R).





Traffic: the number of trucks and routes concern us. Details of project related traffic volumes have been included in Section







How will the dumping impact the wards? Details on management of mineralised and non-mineralised waste

required by the project have been discussed in Section 3.2 of the EIA

Report.



What are the community benefits? This will be as per the approved SLP.





How will SMMEs be developed? Details on promoting justifiable economic and social development have




The community must be called area based and not ward based. This point is noted.



Compliance with the mining charter is important. The owners and all

communities must meet in one meeting, and venue.






Mobile - 073 388 6803; and





Where does the money earned by West Wits go to? The money will be allocated back into the operation to grow as per the

Mining Work Programme (MWP) and to honour the SLP commitments.



for the EIA Report








I am concerned about land shakes/tremors. This issue has been noted and relevant impacts including mitigation and


the EIA Report.



Carbon credits: Project in community to reduce cabon footprint. This issue has been noted and has been considered by the Climate

Change specialist (Appendix I). Relevant impacts including mitigation





Community benefit: A portal must be established to register CVs and

SMMEs.






Water Quality: We are concerned about AMD. This issue has been noted and has been considered by the Groundwater






Rehabilitation and Fund: Can the rehabilitation fund be used to

benefit the community?


rehabilitation costs have been discussed in sections 18, 28 and Appendix




We want to be shareholders, we want jobs and have SMME

development.








Can you give us a breakdown of jobs that will be available and what

skills are required?

This will be as per the approved SLP





What are the operating hours? Details on the project timeline, including operating hours for the project




How much electricity and water will be utilised. Details on water supply and management and power supply and use

required by the project have been discussed in Section 3.2 of the EIA

Report.



for the EIA Report








What diesel will be used by equipment? Details of other support services including fuel storage facilities required

by the project have been discussed in Section 3.2.13 of the EIA Report.



Historical mining is underground mining that took place in the area. This point is noted.



Rehabilitation of the mine must be done. Details of the financial provision prepared for the project, including



Gill Stewart X Public open day held on 23


Trucks: What route is being used? Structures have been weakened. Details of project related access and transport have been included in

Section 3.2.6 of the EIA Report. This issue has been noted and has been






Oscillation: houses will crack. This issue has been noted and has been considered by the Blasting and






We are scared our houses will go down. This issue has been noted and relevant impacts including mitigation and


the EIA Report.



Dust will be created due to excessive mining. We understand that

West Wits is trying to be legislatively compliant.

This issue has been noted and has been considered by the Air Quality



the EIA Report.



What is the compensation potential if it is proven that West Wits is

the source of impacts?

West Wits is committed to undertake its activities in an environmentally

and socially responsible manner.



What if the houses are on the fault line? This issue has been noted and relevant impacts including mitigation and


the EIA Report.



Tornado Crescent: Regular gunshot are heard on a Friday night. This issue has been noted and have been considered by the Socio-

economic specialists (Appendix Q). Relevant impacts including

mitigation and monitoring measures have been assessed and included in

Appendix D of the EIA Report.



for the EIA Report








Where would you get the seedlings for rehabilitation? Grassland

biodiversity.






What type of development can take place over old underground

mine?



the EIA Report.



Calculate the volume of water needed for dust suppression and where

it gets sourced from?







Will the Xcentric ripper affect a house when there is a fault? This issue has been noted and have been considered by the Blasting and

Vibration specialist (Appendix Q). Relevant impacts including mitigation





Open pit: Bowsers should only be used. Details on water supply and management required by the project have




Underground: Will closed reticulation be used? Details on water supply and management required by the project have




Major issues with current electricity grid. Nothing about upgrades.

Wards 84, 127, 70 and 71 have infrastructural concerns.

Noted, these issues should be raised with the Local Municipality.



Where are the powerlines? What is the risk? Details on the baseline land uses including power lines have been

discussed in Section 6.4.2 of the EIA Report.

Tebogo Sekonya X Public open day held on 23


Issue about 24 hours- operation. I refuse to believe that the Xcentric

ripper will be used and blasting will not be done and noise will occur.

Details on the open pit and underground mining methods for the

project have been discussed in Section 3.2.4 of the EIA Report.

This issue has been noted and have been considered by the Noise and

Blasting and Vibration specialists (Appendix L and Appendix Q). Relevant





for the EIA Report








Concerned about the noise and vibration of the impact. These issues have been noted and have been considered by the Noise

and Blasting and Vibration specialists (Appendix L and Appendix M).





Brown Envelopes: Accused that bribery occurs. Who is Mlungisi Kwini? This point is noted.



We request a copy of the report. The public participation process undertaken and still to be undertaken

including the availability of the relevant reports for public review has




How was the BEE Partner appointed? Through a selection process of potential partners willing to invest in the

company.



I am concerned about noise and dust. These issues have been noted and have been considered by the Air

Quality and Noise specialists (Appendix J and Appendix L). Relevant





I have questions about Corporate Social Investment and Integrated

Development Strategy.





In the event that there is a damage to property, how will the people

be compensated?





How would you address issues like cracked houses due to mining? This issue has been noted and have been considered by the Blasting and

Vibration specialists (Appendix M). Relevant impacts including



Bongani X Public open day held on 23


Community benefits vs impacts experienced. West Wits is committed to undertake its activities in an environmentally


Bongani X Public open day held on 23


Will there be relocation of Goudrand residents? No resettlement of residents would be required as part of the project.

Richard X Public open day held on 23


This is just a paper exercise, it is not practical. Retrenchment vs

employment.







for the EIA Report








Investment in houses have been made. Will people be bought out or

relocated?







Political issues are concerning. This point is noted.

Aubrey X Public open day held on 23


The uranium in the slimes dams are a concern and must be

rehabilitated.




the EIA Report.



I am concerned about blasting and vibration. This issues needs to be

investigated.

This issue has been noted and have been considered by the Blasting and

Vibration specialists (Appendix M). Relevant impacts including





Cracked houses and stability are concerns. This issue has been noted and have been considered by the Blasting and

Vibration specialist (Appendix Q). Relevant impacts including mitigation





Community meeting with Fleurhof (Friday, Saturday and Sunday). The Public participation process (PPP) undertaken to date is in line with





The Fleurhof Community and Business Initiative represents 1 000

businesses and must be engaged with.


Victor X Public open day held on 23


Chest pains are concerning. These issues have been noted and have been considered by the Human



the EIA Report.

Victor X Public open day held on 23


The area was rezoned from housing to mining. This point is noted.



for the EIA Report








We have a lot of dust issues. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Reginah Tshangane X Public open day held on 23


Forum members are unknown. The West Wits Community Forum has been established in Roodepoort.



Mobile - 073 388 6803; and





What is the year plan for project to be funded? The funding is as per the MWP submitted for approval to the DMR.



We need skills and education opportunities in Ward 127. This will be as per the approved SLP.





What can the community do to assist West Wits' application? Partake in a constructive manner in the PPP, which has been undertaken

to date in line with Chapter 6 of the EIA Regulations (2014), as amended

and has been discussed in Section 6.2 of the EIA Report.



Application is put in for mining. Revenue for the community must be

developed.






EIA: What is the role of community in the EIA? To partake in a constructive manner in the PPP, which has been

undertaken to date in line with Chapter 6 of the EIA Regulations (2014),

as amended and has been discussed in Section 6.2 of the EIA Report.



Where will the water come from? Details on the water supply and management required by the project

have been discussed in Section 3.2 of the EIA Report.



for the EIA Report






Mrs Erasmus X Public open day held on 23


What will happen to the animals? Small mammals, birds etc. This issue has been noted and has been considered by the Biodiversity

specialist (Appendix F). Relevant impacts including mitigation and


the EIA Report.



The company is disrespectful to legal components. The company adheres to all legal requirements.



Who is the board of the BEE partners and who is the main

shareholders?

Details of the applicant including shareholding and empowerment have




Community involvement in the project is required. The Public participation process (PPP) undertaken to date is in line with








Mobile - 073 388 6803; and




The percentage of the SLP. Is it in-line with the community

requirements?

This will be as per the approved SLP,





If the environmental risk is not mitigated (if it cannot be managed)-

How will the community be compensated?





The responsibility of dust control must be by the community. This issue has been noted and has been considered by the Air Quality



the EIA Report.



for the EIA Report






Victor Vuyani X Public open day held on 23


Representation of communities in Ward 127: Forum and councillors

do not inform the community.




Mobile - 073 388 6803; and




Property Impacts: Dino Properties put RDP housing in this area. It

brings the promise of residential development and mining.







There must be a public meting in Goudrand next to car-wash. The Public participation process (PPP) undertaken to date is in line with





Informal complex- township creep of Matholesville is a concern. This issue has been noted and has been considered by the Socio-




Siyabonga X Public open day held on 23


Forum member in Ward 127? Doesn’t know when/where/how things

happen regarding the mine. Problem is Councillor.




Mobile - 073 388 6803; and




What is the procedure for selecting the Councillor? A Memorandum of Understanding will be drafted for the mining forum

which will dictate how the chairman of the mining forum will be

selected



Not sufficient info regarding the jobs. This will be as per the approved SLP





for the EIA Report








I would like to have an oversight visit around the mines opencasts and

so forth. So I can learn and understand the mining industry personally

and practically besides the information and knowledge I hear from the

general public.




Mobile - 073 388 6803; and




As a young and aspiring young person I would like to meet you/your

management personally on any given day and time that will be

suitable and convenient to you and your company. The purpose of the

meeting is to know deeper and understand mining operations and

other technicalities surrounding the mining industry. More like doing

an oversight that is safe and secured. I would like to do this tour

around your mining areas as to learn, to know and understand mining

operations.




Mobile - 073 388 6803; and




Now that West Wits has been going around doing public consultation

at our community, how many community members are very well

informed and knowledgeable about what you are talking about in

these public meetings?







Mobile - 073 388 6803; and




How many people have you properly workshopped and educated

about this technical information and terms of references that you are

using? As most of us are not very well informed and knowledgeable

about the mining industry and everything that you are talking about is

very new and confusing to many of us, we are not sure if what you are

telling us is true or false.







Mobile - 073 388 6803; and




for the EIA Report








We all know that you want to get rid of the illegal mining activities of

the Zama-zamas, what exact plan do you have in place for these

people besides just closing down the open casts mine shafts? What

are you going to do/ say about these people's illegal activities because

wherever you shut down the holes they go and open somewhere else.

For example, since West Wits Mining has been around these people

are moving to nearby places next to our living society/yards. So what's

your long-term plan with these people besides protecting your

interest?







What safety and security measures are put in place by West Wits

mining company project in terms of our ordinary citizens who are not

so interested and aware of what is going on around their

environment? E.g. You brought a good job creation for many

unemployed and disadvantaged people- but what are you going to

do/say when illegal protests and violence revokes from your unhappy

clients/ employees? With that said, how are you going to protect and

ensure our safety and security is protected against such unforeseen

circumstances because we're very well informed and knowledgeable

about what is going to happen in the near future?









How about you prepare an open and honest training workshop that

can educate interested individuals who would like to learn more about

mining without having to work at the mine. More especially to enable

the community to differentiate the lies spread by your opposition

parties that are against your company/project because everything

that we ever heard and read from the workshops completely doesn't

make sense comparing to the information/threats written by the

opposing individuals/companies in the newspapers.

Noted, perhaps this can be done through the mining forum.



for the EIA Report






Mathole Youth Safety and

Development Forum

X Public open day held on 23


(Comment sheet)

As a Community based Non-Profit Organization, write this letter to

kindly request you to please help us take our youth and children to

attend a computer courses to computer basics, even if you can help

appoint/take us to your preferred learning institute. Reason is

because in our living society there are major needs for such skills and

we so believe if we can afford to go and learn such skills we can come

back and pass on the knowledge to other youth and children within

the community. Your assistance in this regard would be highly

appreciated.




Mathole Youth Safety and

Development Forum



(Comment sheet)

We would kindly like to request for funding/sponsorship from West

Wits mining. Our Objective as an NPO is to ensure that our youth and

children are included and actively participate in our community

development. Our Vision is to stand as a shining example in the young

and upcoming generation in action against unemployment, inequality

and crime in our living society.




Ayanda Ncanda X Public open day held on 23


(Comment sheet)

Can the mine provide clarity as to their intended programs for skills? Details on promoting justifiable social and economic development have




(Comment sheet)

How can NGOs submit their proposals for projects and programs? This will be as per the approved SLP.



(Comment sheet)

Can the mine educate the community about health hazards and

environmental impact?






(Comment sheet)

Have you followed proper procedures prior to securing of a mining

license?

Yes, as required by the relevant legislation.



(Comment sheet)

We won't part with our properties for a pittance. No resettlement of residents would be required as part of the project.



(Comment sheet)

I won't move from my property unless I have had a one on one

engagement with whomever is behind the acquisition.

No resettlement of residents would be required as part of the project.



for the EIA Report








(Comment sheet)

We need shareholding. This will be as per the approved SLP.

Josephine Mohlomi and

Portia Magare



(Comment sheet)

I'm asking for information to be transparent please. The Public participation process (PPP) undertaken to date is in line with



Noel Geber X Public open day held on 23


(Comment sheet)

The risk is too big to our physical health, truck noise, collapsing of

homes. Are we serving the God of Money?

These issues have been noted and have been considered by the various




Bradley Tlabiyane X Public open day held on 23


(Comment sheet)

I am interested in buying shares and be part of your professional staff

in mining.


Bradley Tlabiyane X Public open day held on 23


(Comment sheet)

May you please send me all relevant documents regarding the project. You have been registered as an I&AP and will receive all future

communication and information regarding the availability of reports for

public review.

Brian Mashigo X Public open day held on 23


(Comment sheet)

I want to purchase equity shares. I need to know how much I must

bring to get three percent (3%) equity shares.


Mpho Tlatsi X Public open day held on 23


(Comment sheet)

We want the company that seeks to mine in our communities to not

just run SLP projects that will benefit the company, but to also ensure

that businesses are developed by this. For example, the company

may form joint ventures between experienced companies and

companies from the community that may not necessarily have

required experience.






(Comment sheet)

Should business opportunities arise we would suggest that the

company contact us directly instead of going through community

Councillors.




(Comment sheet)

I have a company that is interested in providing the water tank for the

mine.






for the EIA Report








(Comment sheet)

We also hope that the mine will source these kinds of contracts from

people in the affected areas as opposed to big companies not affected

by the mine.




Walter Tlatsi (Tshepisong

Primary School Principal)



(Comment sheet)

The school was built in 2005, and due to poor workmanship, the

building needs to be refurbished. The school's classroom floors now

have potholes and they need to be renovated. Tiling in the classrooms

need to be removed and replaced as most tiles are damaged.

Classrooms are overcrowded since learner enrolment is at 1 567 and

four more brick and mortar classrooms are needed. All classrooms

and toilets need to be repainted. Classroom ceiling are collapsing and

need to be replaced. Installation of an intercom system in all

classrooms. The school was built without a school hall, therefore a hall

is desperately needed. Tshepisong community will greatly benefit if all

these can be done and our pass rate can improve.




Thandi Portia Mkhonza X Public open day held on 23


(Comment sheet)

In our community there is no one who shares the information with

residents, everything happens without our knowledge.




(Comment sheet)

We can be happy if we can have our own choice Councillor not the

current one, he failed us dismally.




(Comment sheet)

I wish the next meeting can be held during the weekend and

flyers/pamphlets need to be distributed to our houses. I stay in Ward

127 and we are so worried about this mining issue thing.






(Comment sheet)

My comments is my house, I'm scared that its going to collapse, crack

or lose its value.


economic and Vibration and Blasting specialists (Appendix M and

Appendix Q). Relevant impacts including mitigation and monitoring


Report.



(Comment sheet)

If this project becomes successful, are our children going to be part of

the workforce?




for the EIA Report








(Comment sheet)

Please do not allow Councillors to take decisions for us especially

Ward 127, the Councillor does not even engage us. We want our own

representative to work hand in hand with the West Wits project.







Mobile - 073 388 6803; and


Leonard Moshwana X Public Open-day held on 24

August 2018 (Moses

Kotane)

The contractors are not local people. This issue has been noted and has been considered by the Socio-





August 2018 (Moses

Kotane)

There are no community benefits. This will be as per the approved SLP.




August 2018 (Moses

Kotane)

Mitigation measures for water resources must be put in place. This issue has been noted and has been considered by the Groundwater





August 2018 (Moses

Kotane)

The mine must promote local SMMEs. Details on promoting justifiable economic and social development have



August 2018 (Moses

Kotane)

Dust is a problem. This issue has been noted and has been considered by the Air Quality



the EIA Report.


August 2018 (Moses

Kotane)

People are starving and must get jobs. Details on workforce required by the project have been discussed in




for the EIA Report






Disky Matsheleja X Public Open-day held on 24

August 2018 (Moses

Kotane)




the EIA Report.

Melodys Radebe and Mokgadi

Seabela

X Public Open-day held on 24

August 2018 (Moses

Kotane)

Dust is a problem especially for people staying less than 500m from

the mine.




the EIA Report.


Seabela


August 2018 (Moses

Kotane)

What will happen to Property Values? This issue has been noted and has been considered by the Socio-





Seabela


August 2018 (Moses

Kotane)

High noise levels are a concern. This issue has been noted and has been considered by the Noise

specialist (Appendix L). Relevant impacts including mitigation and


the EIA Report.

Nicky Mbombo X Public Open-day held on 24

August 2018 (Moses

Kotane)

The mine is very close to houses. This issue has been noted and has been considered by the Socio-





August 2018 (Moses

Kotane)




the EIA Report.


August 2018 (Moses

Kotane)

No clinic is located close to the affected people. Details on promoting justifiable economic and social development have



August 2018 (Moses

Kotane)

Safety barricades must be put in place. Details regarding the proposed security arrangements for the project


Jethro X Public Open-day held on 24

August 2018 (Moses

Kotane)

A loud-hailer must be used to advertise meetings. The Public participation process (PPP) undertaken to date is in line with





for the EIA Report






Thabiso, Lydia and Bashia X Public Open-day held on 24

August 2018 (Moses

Kotane)

Employment opportunities must be created. Details on workforce required by the project have been discussed in


Stephina Raphela X Public Open-day held on 24

August 2018 (Moses

Kotane)

Mining is causing dust fallout in Braamfischerville. This issue has been noted and has been considered by the Air Quality



the EIA Report.


August 2018 (Moses

Kotane)

Dust is a problem especially for people staying on the border of the

mine.




the EIA Report.


August 2018 (Moses

Kotane)

We have no water sometimes during the day due to the illegal

connections from zama-zamas.

Details on water supply and management required for the project have







August 2018 (Moses

Kotane)

Trucks driving through Braamfischerville with minerals will cause

traffic issues.

Details of project related access and transport required by the project

have been included in Section 3.2.6 of the EIA Report. This issue has

been noted and has been considered by the Traffic specialist (Appendix

O). Relevant impacts including mitigation and monitoring measures have


Paul X Public Open-day held on 24

August 2018 (Moses

Kotane)

An environmental body must be established in Braamfischerville. This point is noted.


August 2018 (Moses

Kotane)

Looking at water as it will be affected. Details on water supply and management required by the project have








for the EIA Report







August 2018 (Moses

Kotane)

We are poor middle-class people, what is the criteria for

employment?


Prudence X Public Open-day held on 24

August 2018 (Moses

Kotane)

Community houses are close to the mine. This issue has been noted and has been considered by the various





August 2018 (Moses

Kotane)

Noise from blasting is a concern. This issue has been noted and has been considered by the Noise



the EIA Report.


August 2018 (Moses

Kotane)




the EIA Report.

Katleho X Public Open-day held on 24

August 2018 (Moses

Kotane)

There is a tank behind Solplaatjies. This point is noted.

Katleho X Public Open-day held on 24

August 2018 (Moses

Kotane)

Health of people is a concern. This issue has been noted and has been considered by the Human

Health specialists (Appendix R). Relevant impacts including mitigation



Thembisile X Public Open-day held on 24

August 2018 (Moses

Kotane)

Alternative land uses must be considered. Details on alternative land uses have been discussed in Section 6.4.2 of

the EIA Report.

Thembisile X Public Open-day held on 24

August 2018 (Moses

Kotane)

Blasting and vibrations are experienced due to illegal mining. This issue has been noted and has been considered by the Blasting and






for the EIA Report






Charles X Public Open-day held on 24

August 2018 (Moses

Kotane)

We are already affected by dust due to trucks and minerals. This issue has been noted and has been considered by the Air Quality



the EIA Report.


August 2018 (Moses

Kotane)

Noise from trucks and equipment will be experienced. This issue has been noted and has been considered by the Noise



the EIA Report.


August 2018 (Moses

Kotane)

Blasting and vibrations will be causing tremors. This issue has been noted and has been considered by the Blasting and




Tiisetso X Public Open-day held on 24

August 2018 (Moses

Kotane)

Houses will crack due to mining. This issue has been noted and has been considered by the Blasting and




Alice X Public Open-day held on 24

August 2018 (Moses

Kotane)

What are the benefits to the people? Details on promoting justifiable social and economic development have


Anonymous X Public Open-day held on 24

August 2018 (Moses

Kotane)

No one from local SMMEs are benefiting at all. Details on promoting justifiable social and economic development have


Anonymous X Public Open-day held on 24

August 2018 (Moses

Kotane)

There are only two water trucks for dust suppression. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Zukisa Mbusi X Public Open-day held on 24

August 2018 (Moses

Kotane)

What opportunities are there for the youth? Details on promoting justifiable social and economic development have




for the EIA Report






Zukisa Mbusi X Public Open-day held on 24

August 2018 (Moses

Kotane)

Dust is a problem for children. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Matlhogonolo Moroke X Public Open-day held on 24

August 2018 (Moses

Kotane)

Dust is a problem for children. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Matlhogonolo Moroke X Public Open-day held on 24

August 2018 (Moses

Kotane)

Zama-zamas are becoming burglars because their job is taken away. This issue has been noted and has been considered by the Socio-




Constance Khomy X Public Open-day held on 24

August 2018 (Moses

Kotane)

Dust from the mines is a problem. Can West Wits please intervene. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Mavis Mzangwa X Public Open-day held on 24

August 2018 (Moses

Kotane)

Dust is an issue. West Wits must come visit our homes and experience

this concern first-hand.




the EIA Report.

Kgomotso Motsemme X Public Open-day held on 24

August 2018 (Moses

Kotane)

Hire people from the impacted communities. Details on promoting justifiable economic and social development have


Viktoria Mkhaele X Public Open-day held on 24

August 2018 (Moses

Kotane)

We are concerned with dust. Health of people (coughing) is a concern. These issues have been noted and have been considered by the Air

Quality and Human Health specialists (Appendix J and Appendix R).



Viktoria Mkhaele X Public Open-day held on 24

August 2018 (Moses

Kotane)

There are no clinics in the area. This point is noted.



for the EIA Report






EFF Youth (Group) X Public Open-day held on 24

August 2018 (Moses

Kotane)

How will the mine benefit the youth and eradicate employment

issues?




August 2018 (Moses

Kotane)

Current mining is affecting the health of people living next to it. This issue has been noted and has been considered by the Human





August 2018 (Moses

Kotane)

Dust is being experienced since early this year. We hardly see any

water trucks.




the EIA Report.


August 2018 (Moses

Kotane)

Explosions and vibrations are a concern. This issue has been noted and has been considered by the Blasting and





August 2018 (Moses

Kotane)

Illegal mining activities is a problem. This point is noted.


August 2018 (Moses

Kotane)

Walk for food (supply food to existing employees). Details on promoting justifiable social and economic development have



August 2018 (Moses

Kotane)

Preference must be given to locals to mine (SMMEs and employ local

individuals).



T. Douglas X Public Open-day held on 24

August 2018 (Moses

Kotane)

Human health risks: How will the risks be minimized? This issue has been noted and has been considered by the Human





August 2018 (Moses

Kotane)

Agriculture: How will the mine stimulate subsistence farming and

markets?





for the EIA Report







August 2018 (Moses

Kotane)

Job opportunities: Will the mine employ high school graduates? This will be as per the approved SLP.



James Magongwa X Public Open-day held on 24

August 2018 (Moses

Kotane)

Zama-zamas must be stopped. This point is noted.

James Magongwa X Public Open-day held on 24

August 2018 (Moses

Kotane)

The project will help our children's future and they will learn the skills

to work in the mine.


Matshepiso Kgampe X Public Open-day held on 24

August 2018 (Moses

Kotane)

The safety of the community will be negatively affected due to the

possible increase of crime.

This issue has been noted and have been considered by the Socio-

economic specialists (Appendix Q). Relevant impacts including



Matshepiso Kgampe X Public Open-day held on 24

August 2018 (Moses

Kotane)

What's going to happen to the community once the mining has

stopped?




Peter Msibi X Public Open-day held on 24

August 2018 (Moses

Kotane)

Cracking of the houses will be experienced in the area where you will

be mining.






August 2018 (Moses

Kotane)

Our health in regards to dust will be compromise. These issues have been noted and have been considered by the Air





August 2018 (Moses

Kotane)

The noise from blasting will cause an impact. This issue has been noted and has been considered by the Noise and

Blasting and Vibration specialists (Appendix L and Appendix M). Relevant





for the EIA Report






Samuel Sello Pandelane X Public Open-day held on 24

August 2018 (Moses

Kotane)

My concern is the Zama-zama because they are mining illegally.

Sometimes during the night we hear people fighting for productions

that were mined illegally.


Samuel Sello Pandelane X Public Open-day held on 24

August 2018 (Moses

Kotane)

Minimize the dust so it does not affect the children and adults. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Lindile Mbotho X Public Open-day held on 24

August 2018 (Moses

Kotane)

When hiring, please give preference to the people of Soweto. Details on promoting justifiable economic and social development have


Zusiphe Dlaba X Public Open-day held on 24

August 2018 (Moses

Kotane)

What qualifications are required to work in this project? This will be as per the approved SLP.

Violet Salomane and Victoria

Mkhabela


August 2018 (Moses

Kotane)

We are going to be affected by the mining due to dusts and absence

of clinics. Our lives must come first.





Violet Salomane and Victoria

Mkhabela


August 2018 (Moses

Kotane)

Our houses have weak foundations, we don't need mining near us. This issue has been noted and has been considered by the Blasting and




Patricia Thandiwe Maseko X Public Open-day held on 24

August 2018 (Moses

Kotane)

How will this project benefit the community? This will be as per the approved SLP.



Patricia Thandiwe Maseko X Public Open-day held on 24

August 2018 (Moses

Kotane)

What is the solution to the associated health problems? This issue has been noted and has been considered by the Human






for the EIA Report






Innocent Dlamini X Public Open-day held on 24

August 2018 (Moses

Kotane)

You must tell us about the dust because it is a threat to our health. We

need clinics for the sake of our health if you are to consider the

project.






August 2018 (Moses

Kotane)

My house is sometimes shaking, we were supposed to be consulted

before mining had commenced.






August 2018 (Moses

Kotane)

If you need to go further, you must remove us and give us money. The

mining in Solplaatjies affects us already.





Tozi Ngwadla X Public Open-day held on 24

August 2018 (Moses

Kotane)

Can they move the houses that are nearer to the mine and provide

them with houses further away from the mine.


Tozi Ngwadla X Public Open-day held on 24

August 2018 (Moses

Kotane)

Is it possible that they exceed the anticipated 500-1 000 employees

because they is a high number of unemployed people in the

communities.



Tryphina Nkgudi X Public Open-day held on 24

August 2018 (Moses

Kotane)

I have a problem with the dust coming to my house. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Tryphina Nkgudi X Public Open-day held on 24

August 2018 (Moses

Kotane)

We have water problems since this project started. The project will only commence upon receipt of environmental

authorisation from the DMR.






for the EIA Report






Bashin Motloutsi X Public Open-day held on 24

August 2018 (Moses

Kotane)

Young individuals are unemployed, we suggest that unemployment

may be reduced.




August 2018 (Moses

Kotane)

How are you going to hire people? This will be as per the approved SLP.


August 2018 (Moses

Kotane)

How are you going to deal with the issue of people affected by dust,

vibration, floods, soil erosion?


Quality, Vibration and Blasting, Surface Water and Soil and Land

Capability specialists (Appendix E, Appendix G, Appendix J and Appendix

M). Relevant impacts including mitigation and monitoring measures

have been assessed and included in Appendix D of the EIA Report.


August 2018 (Moses

Kotane)

How are you going to deal with the issue of illegal miners who are still

in process?

Through continuous stakeholder engagement.


August 2018 (Moses

Kotane)

There is mining taking place already, how are you going to address the

people?





August 2018 (Moses

Kotane)

What is going to happen to the people who are affected by vibration

and dust?

These issues have been noted and have been considered by the Blasting

and Vibration and Air Quality specialists (Appendix J and Appendix M).




August 2018 (Moses

Kotane)

West Wits claims they have not started mining, who is then operating

at Ward 44 (Braamfischerville)?





August 2018 (Moses

Kotane)

We don't have water during the day, it is only available during the

night, are you going to add to that problem?







for the EIA Report







August 2018 (Moses

Kotane)

How are you going to deal with the zama-zamas because since the

mining is happening there has been an influx of zama-zamas and we

are affected.





Mandla X Public Open Day held on 25

August 2018 (Matholesville)

Will the mine not interfere with the housing development proposed

after mining?

West Wits is in consultation and negotiations with the relevant

developers and land owners.

Mandla X Public Open Day held on 25


What are the job requirements in terms of skills? This will be as per the approved SLP.



Rodney Tladi X Public Open Day held on 25


Please comment on the role of the project and how do we get

involved in subcontracting to the project? I own my own company.




Rodney Tladi X Public Open Day held on 25


(Comment sheet)

What is the economic and spacial development plan? Details on promoting justifiable economic and social development have


Khayelihle Nkwelo X Public Open Day held on 25


Must employ people who are older and can teach the young ones

about mine safety.


Catherine Raphela X Public Open Day held on 25


What is being done about the illegal miners? Continuous engagement will be undertaken with the South African

Police Service (SAPS) to assist with this matter.

Catherine Raphela X Public Open Day held on 25


Will there be any vacancies besides underground mining? This will be as per the approved SLP.

Thendo Masindi X Public Open Day held on 25


Are you going to teach people about mining machinery and skills? Details on promoting justifiable economic and social development have




How long will mining take place? The project will only commence upon receipt of environmental


Details on the project timeline have been included in Section 3.2.2 of

the EIA Report.



for the EIA Report






Michael Maforvane X Public Open Day held on 25


The project looks very transparent and information is encouragingly

accessive. I am generally encouraged and impressed.


David Bame X Public Open Day held on 25


My interest is to gain knowledge and skills development in the mining

sector and to work to become a better person of tomorrow. I am

interested in available learner ships.



David Bame X Public Open Day held on 25


My comments are to implement safety and security and the

development of youth skills.



Although permits or approvals in terms of health and safety regulations




1996) (MHSA).



M. Nondabula X Public Open Day held on 25


We are worried about illegal mining because it creates dangers to our

environment. I would like to see more legal mines that are safe and

closed mines must be barricaded and guarded for our safety.




I am interested in being part of the mining project. I will be happy if

you will consider me as well to join the project.




Mphato X Public Open-Day held on 29

August 2018

(Meadowlands)

How will the youth and graduates benefit? Details on promoting justifiable social and economic development have



August 2018

(Meadowlands)

How will the people with health problems from historic mining benefit

from the project?

Specialist studies have taken into account current baseline conditions





August 2018

(Meadowlands)

We want our people in top management positions. This will be as per the approved SLP.



for the EIA Report






Tshepo Abrams X Public Open-Day held on 29

August 2018

(Meadowlands)

When and where will we know about employment? This will be as per the approved SLP.

Sylvia Mahlangu X Public Open-Day held on 29

August 2018

(Meadowlands)

Houses will be cracked, how will we be compensated? West Wits is committed to undertake its activities in an environmentally


Tshepiso X Public Open-Day held on 29

August 2018

(Meadowlands)

How are we going to benefit from this? Details on promoting justifiable social and economic development have


Philemon X Public Open-Day held on 29

August 2018

(Meadowlands)

We are not going to gain anything from this project. Details on promoting justifiable social and economic development have



August 2018

(Meadowlands)

Why are you consulting with us? In order to provide an opportunity for you to partake in a constructive

manner in the PPP, which has been undertaken to date in line with

Chapter 6 of the EIA Regulations (2014), as amended.


August 2018

(Meadowlands)

The mine will be in close vicinity, will dust affect us? This issue has been noted and has been considered by the Air Quality



the EIA Report.

Guidsi X Public Open-Day held on 29

August 2018

(Meadowlands)

What type of Community outreach, CSI Projects and LED Projects will

you have?




Guidsi X Public Open-Day held on 29

August 2018

(Meadowlands)

Where do we lodge any complaints we have? The mine will provide an effective method of communication whereby

community members can lodge any complaints. This may take the form

of a help line.

Public open day attendee X Public Open-Day held on 29

August 2018

(Meadowlands)

Dust due current mining activities is a concern to us. This issue has been noted and has been considered by the Air Quality



the EIA Report.



for the EIA Report







August 2018

(Meadowlands)

Houses are cracking. This issue has been noted and has been considered by the Blasting and





August 2018

(Meadowlands)

The mines come with so many promises, but no benefits. Details on promoting justifiable social and economic development have



August 2018

(Meadowlands)

We need employment. Details on workforce required by the project have been discussed in


Bafidile X Public Open-Day held on 29

August 2018

(Meadowlands)

Demarcation between Fleurhof and Meadowlands excludes

Meadowlands from any benefits from the project. How are going to

include and service Meadowlands community?




Kabelo X Public Open-Day held on 29

August 2018

(Meadowlands)

Concerned about houses and subsidence in close vicinity to the mine? This issue has been noted and has been considered by the Blasting and




Patty X Public Open-Day held on 29

August 2018

(Meadowlands)

Schools and houses are very close to the mine. This issue has been noted and has been considered by the Human





August 2018

(Meadowlands)

When you come mine you must take ownership of the damage left by

other historical mines. You need to rehabilitate whats been left

before.





August 2018

(Meadowlands)

We will complain at the DG from the DMR. This point is noted.


August 2018

(Meadowlands)

It’s the community's project. Engage with communities through

newspapers (Meadowlands, Sowetan and Star).






for the EIA Report







August 2018

(Meadowlands)

We've been affected by mining. The community needs to benefit. Details on promoting justifiable social and economic development have


Bongani X Public Open-Day held on 29

August 2018

(Meadowlands)

How much radio-active material will be transported on the roads?

What effect will this have on the people?




the EIA Report.


August 2018

(Meadowlands)

What is the negatives of radiation on people, based on other mining

areas?




the EIA Report.

Gilbert X Public Open-Day held on 29

August 2018

(Meadowlands)

What equipment will be used for underground mining? Will they use

bombs on dolomitic land?

Details on the mining methods for the project have been\ included in

Section 3.2 of the EIA Report.

Gilbert X Public Open-Day held on 29

August 2018

(Meadowlands)

When dynamite is blasted our houses crack/shake. This issue has been noted and has been considered by the Blasting and




Thabiso X Public Open-Day held on 29

August 2018

(Meadowlands)

Old mine holes and existing mines if opened won't they affect our

houses?






August 2018

(Meadowlands)

Trucks transporting material will damage roads. Details of project related access and transport are included in Section







for the EIA Report







August 2018

(Meadowlands)

Employment opportunities, skills development and education is

required.



Siphiwe X Public Open-Day held on 29

August 2018

(Meadowlands)

I am not happy, I feel ambushed by having a meeting in the week. The public participation process undertaken and still to be undertaken



Siphiwe X Public Open-Day held on 29

August 2018

(Meadowlands)

How will the community benefit? This will be as per the approved SLP.



Sthembiso X Public Open-Day held on 29

August 2018

(Meadowlands)

Sinkholes forming in Tshepisong. If sinkholes occur, how will it affect

our houses?



Given X Public Open-Day held on 29

August 2018

(Meadowlands)

This is an already affected area. Why do they target these areas for

mining?

The underlying geology of the area contains minerals that are desirable

for the applicant company.

Nomusa X Public Open-Day held on 29

August 2018

(Meadowlands)

What will the effects be on children or grandchildren in 100 years? This issue has been noted and has been considered by the various





August 2018

(Meadowlands)

We are living in an already affected area in terms of cracked houses. This issue has been noted and has been considered by the Blasting and





August 2018

(Meadowlands)

What is the purpose of vibration study if cracks are already there?

DMR has to come here to assist with existing issues.





Hunasa X Public Open-Day held on 29

August 2018

(Meadowlands)

Why are these areas chosen for mining? The underlying geology of the area contains minerals that are desirable

for the applicant company.



for the EIA Report







August 2018

(Meadowlands)

Previous owners left without rehabilitation. Specialist studies have taken into account current baseline conditions





August 2018

(Meadowlands)

Carbon dioxide smoke can affect our health. This issue has been noted and has been considered by the Air Quality



the EIA Report.


August 2018

(Meadowlands)

Right now they burn waste close to the mining area and this affects

our health and gives us headaches, sinus, nausea.






August 2018

(Meadowlands)

No benefit to community. This will be as per the approved SLP.




August 2018

(Meadowlands)

You must properly inform the community and properly consult. The Public participation process (PPP) undertaken to date is in line with




August 2018

(Meadowlands)

The community needs to identify their own needs. This will be as per the approved SLP.




August 2018

(Meadowlands)

Mineral water (springs) have been polluted by historic mining. Specialist studies have taken into account current baseline conditions





August 2018

(Meadowlands)

The area is toxic by mining through the years. Specialist studies have taken into account current baseline conditions





August 2018

(Meadowlands)

Do you have sufficient budget for rehabilitation after mining? Details of the financial provision prepared for the project, including





for the EIA Report






Anonymous X Public Open-Day held on 29

August 2018

(Meadowlands)

What are the benefits vs. impacts for communities? This issue has been noted and has been considered by the Socio-





August 2018

(Meadowlands)

Local/indigenous people to be employed. Details on promoting justifiable economic and social development have



August 2018

(Meadowlands)

Enforcement of legislation in terms of Health and safety. Although permits or approvals in terms of health and safety regulations




1996) (MHSA).


August 2018

(Meadowlands)

Safety of our people must come first. Although permits or approvals in terms of health and safety regulations




1996) (MHSA).

Godfrey X Public Open-Day held on 29

August 2018

(Meadowlands)

Dumps belong to Mintails who has been liquidated. Will the dumps be

remained or rehabilitated in terms of this project?

No, this remains the responsibility of another company.


August 2018

(Meadowlands)

What is the distance between mines and residents? Details on land use have been discussed in Section 6.4.2 of the EIA

Report.


August 2018

(Meadowlands)

Employment opportunities to be clarified. Please elaborate on the

SLP.




Lovemore X Public Open-Day held on 29

August 2018

(Meadowlands)

What employment structures and qualifications are required? This will be as per the approved SLP.

Lovemore X Public Open-Day held on 29

August 2018

(Meadowlands)

When will the mine commence? The project will only commence upon receipt of environmental




for the EIA Report







August 2018

(Meadowlands)

Will there be any Acid Mine Drainage? This issue has been noted and has been considered by the Groundwater

specialist (Appendix H). Relevant impacts including mitigation and


the EIA Report.

David X Public Open-Day held on 29

August 2018

(Meadowlands)

What job opportunities will be available? This will be as per the approved SLP.

Thabo Mohapeloa X Public Open-Day held on 29

August 2018

(Meadowlands)

What is the mine going to do in the meantime to ensure that the

unskilled youth get trained before authorization is granted?


Mxolisi Vikilahle X Public Open-Day held on 29

August 2018

(Meadowlands)

When is the next gathering in Ward 43 (Meadowlands)? The public participation process undertaken and still to be undertaken




August 2018

(Meadowlands)

We request young people and women are made a priority in the

process.



August 2018

(Meadowlands)

As businessmen, we hope that we shall get growth and also contribute

to the local economic growth.




August 2018

(Meadowlands)

I need you to disclose your Social and Labour Plan. You are welcome to approach the DMR for a copy of the SLP.


August 2018

(Meadowlands)

We hope for transparency of the whole process to avoid unnecessary

hiccups.

The public participation process undertaken and still to be undertaken



Henry Mathole X Public Open-Day held on 29

August 2018

(Meadowlands)

Joint participation of the Meadowlands community, the mining

company and the Florida community is required, reason being the

demarcation problem that Meadowlands community raised questions

on.





August 2018

(Meadowlands)

CSI: what requirements will be needed for one to be employed and

participate or to provide services required to the mine?




for the EIA Report







August 2018

(Meadowlands)

What can one do for you to bring communal support for the

implementation of the mining program?

We are driven by the SLP to engage local business to assist

implementing the mining program.


August 2018

(Meadowlands)

I am available in developing and making business with you. Contact

me.







August 2018

(Meadowlands)

I am very interested in this business program and seek to form part in

it, and play a vital role in the company and community development.






David Mabele X Public Open-Day held on 29

August 2018

(Meadowlands)

Does the project have an age limit? This will be as per the approved SLP.


August 2018

(Meadowlands)

How many people with disability does your company have? The company will grow the workforce as per the commitments in the

SLP.


August 2018

(Meadowlands)

We grew up near a mine that affected us and we were not

compensated, why?

This should best be discussed with the DMR.


August 2018

(Meadowlands)

What are you assisting SMMEs with? This will be as per the approved SLP.




August 2018

(Meadowlands)

We suggest we form a forum that is going to help our children not

only with work but also education and entertainment in both schools

and local.






for the EIA Report







August 2018

(Meadowlands)

May we create an office around our area that is going to make sure

that things are happening.






Mobile - 073 388 6803; and



August 2018

(Meadowlands)

Remember your policy of safety first in the mining industry. Although permits or approvals in terms of health and safety regulations




1996) (MHSA).


August 2018

(Meadowlands)

Lets not have favourites and work together and see if we both balance

the equation and obey rules and regulations.


Paulous Bame X Public Open-Day held on 29

August 2018

(Meadowlands)

I would like the project to be transparent and fruitful in every stage

that occurs etc. and the vital issue is I am interested on the political

parties not to hi-jack the project as it’s a norm for our leaders.



August 2018

(Meadowlands)

Please revisit the media and be interviewed by stations and for the

community to engage online. You can do that by buying radio airtime

as part of luring people.





August 2018

(Meadowlands)

How much percentage is the community going to get? This will be as per the approved SLP.



for the EIA Report







August 2018

(Meadowlands)

We will definitely want workshops, are you going to offer that? The Public participation process (PPP) undertaken to date is in line with






Mobile - 073 388 6803; and


Goitsemang Lucas Mogaki X Public Open-Day held on 29

August 2018

(Meadowlands)

How will this project benefit my community since West Wits inform

me that the mining area doesn't fall under my demarcation?





August 2018

(Meadowlands)

Should "as has been the case with other past mining projects" there

be a negative impact from your mining operations, how will I know

whom to complain to? Who is directly involved with your company?




Mobile - 073 388 6803; and



August 2018

(Meadowlands)

With regards to community outreach programmes, how will you

engage the existing community based organisations and how will such

organisations qualify (criteria of selection).





August 2018

(Meadowlands)

As a community we are always hopeful when such projects come to

be. And most importantly when there is open communications

between all stakeholders relationship becomes harmonious. Thank

you.


Alfred Leshoboma X 19-08-2018 by Comment

Sheet

I like the mine to be opened, we want employment in our area. Details on workforce required by the project have been discussed in


Yanga Sigidi X 17-07-2018 by Comment

Sheet

I need a job I'm unemployed. I have five children and its difficult to live

without a job. So I would like the mine to be opened and create jobs.

This could decrease high levels of crime and drug users








for the EIA Report






Shirley Hendrietta Nkosi X 16-08-2018 by Comment

Sheet

We really need jobs please they have to consider us when this project

is open as we are not working and anything can help. How are we

going to benefit if this mine is open?






Mduduzi Nxumalo X 17-08-2018 by Comment

Sheet

Job is the life. We need jobs to feed our children and pay school fees. Details on workforce required by the project have been discussed in


Mohato Phusudi and Thabiso

Monyane

X 15-08-2018 by Comment

Sheet

I'm unemployed and would appreciate any kind of job I can get

because I'm a hard worker and fast learner.






Zandile Kubheka X 15-08-2018 by Comment

Sheet

I need a job because I want to support my family. This will be as per the approved SLP.





William Mervin Vermeulen X 15-08-2018 by Comment

Sheet

I am a plumber and builder. This will be as per the approved SLP.





Zolani Matholengwe X 15-08-2018 by Comment

Sheet

Are there any general worker jobs in this project? How much money

do they get a month? Are there any jobs for plumbers in mining or

not? If there are, I am willing to work there.






Frans Mashaba X As the men safety promoters, we want to know whether our

community is safe when the mine start operating, we want to know

whether your mine will blast rocks underground?

These issues have been noted and has been considered by the Blasting

and Vibration and Human Health specialists (Appendix M and Appendix

R). Relevant impacts including mitigation and monitoring measures have


13-08-2018 by Comment

Sheet



for the EIA Report






Frans Mashaba X We also want our members to get jobs when mine opens. We fully

support the opening of the mine.






I really need a job if they are interested I'm in. This will be as per the approved SLP.





Assist the community in terms of safety. Although permits or approvals in terms of health and safety regulations




1996) (MHSA).

Air pollution is a problem. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Will we move out of our homes? No resettlement of residents would be required as part of the project.

The project must proceed and workers must be paid immediately.

How much are we going to earn?


Is the mineral not going to affect us? This issue has been noted and has been considered by the various




Will you give us Learner ships? Details on promoting justifiable economic and social development have


Will there be various tests before placements? This will be as per the approved SLP.


Sheet

Victory Magadla, Elizabeth

Mokoena, Sandile Mokoena,

Julia Louw and Ofentse

Mashiloane


Sheet

Simphiwe Leornado Xayiya

X

X



for the EIA Report






I hope job opportunities will be created also for the youth if the mine

will be re-opened.






Where was the mining forum elected? When? How? Dissolve it before

we come to you.


Makgotso Mohapi X 15-08-2018 by Comment

Sheet

I have a company registered in my name and would like to open up a

catering business and would like to be assisted in getting funds to

open my business.




Lolo Kondlo and Bulelani

Mangaliso


Sheet

Who is the owner of the mine? West Wits MLI (Proprietary) Limited.

Details of the applicant have been discussed in Section 1.1 of the EIA

Report.

Zakhele Mbense, Fundisiwe

Ngwekazi and Nonhlanhla

Nomvalo


Sheet

When are you going to open the mine? The project will only commence upon receipt of environmental


Lindah Mokgalane X 30-08-2018 by Comment

Sheet

Which minerals are you extracting from that mine? Gold is the target resource but within the geological composition of the

gold reef there are small amounts of silver and very small amounts of

uranium as well that will be mined with the gold ore.

Create projects for women like sewing projects, bakery projects,

chicken farming, empower youth, create projects for elderly people

and also give bursaries to top students.




We need job creation for our children, play-grounds, libraries, halls

must be fixed for cultural dances and so forth. We also need 10% for

the community.






When and where are you going to start mining? The project will only commence upon receipt of environmental



Sheet

Thandeka James


Sheet

Siphelo Njana and Leonerd

Thisani

X

X



for the EIA Report






The current forum must be dissolved as we do not recognise it. The Public participation process (PPP) undertaken to date is in line with






Mobile - 073 388 6803; and



What does the mine intend doing for the community? What are the

benefits to society?






How is the mining company planning to empower women, SMMEs,

and the youth?


Details on the applicant including empowerment have been discussed in






What are the environmental impacts of the project? This issue has been noted and has been considered by the various




What is the share percentage of the profits that the society is going to

have?


If the project ignores the needs and interests of the society it should

therefore be rejected, as we cannot be penny wise and pound foolish.

This issue has been noted and has been considered by the various




Bandile Mjontolo 13-08-2018 by Comment

Sheet

X



for the EIA Report






The proposed mining in our community poses various risks to the

community, currently it is minimal interest as beneficiation to the

people involved.





The people who reside at this affected area should be at the forefront

of the development of community.




The community must by all means be properly consulted and taken

seriously. This proposed project must create long term solutions for

the challenges affecting young people in the area, failure to do this

then the mine must not be allowed to operate in this area.





Elvis Nkwanyana X 13-08-2018 by Comment

Sheet

I would like the mine to be opened so that the people of Durban Deep

can be helped. This could assist in decreasing crime levels in Durban

Deep.


KC Letselebe and Phillipine

Ledwaba


Sheet

We need the mine to create job and we need a school (Primary and

High School) for our children to get good education. Also a park and

church for our community.


Sustain lives of women and youth, give community percentages of

shares, empower SMMEs, empower community stakeholders, create

projects and jobs.








You must keep the promises when the mine starts operating, people

mustn't be taken to hospitals because of the mining.


Health specialists (Appendix M and Appendix R). Relevant impacts



Students must given bursaries. Details on promoting justifiable economic and social development have



Sheet

Xolisa Sikelenge


Sheet

Elizabeth Sibanda

X

X



for the EIA Report






What about our houses and the environment? This issue has been noted and has been considered by the various




Finish the remaining work in the soup kitchen. This will be as per the approved SLP.

Dismantle the mining forum because they were not officially elected

by the community.







Mobile - 073 388 6803; and



Give community percentages of shares, empower SMMEs, empower

community Stakeholders, create projects that will sustain lives of

women and youth, roll out bursaries, create jobs. Build sports

facilities, employ people with disabilities, fund co-operations and

NPOs, build a computer-lab. Build houses for orphans and the poor,

declare your black economic partner, finish the remaining work in the

soup kitchen. If that is going to happen, then we fully support the

mine to open.









Sheet

Stanley Maemela and Zovuyo

Madikane

X



for the EIA Report






Dismantle the mining forum because they were not officially elected

by the community.







Mobile - 073 388 6803; and



Neliswa Gcityama X 14-08-2018 by Comment

Sheet

What are the benefits for the community or youth? This will be as per the approved SLP.



Walter Maake X 15-08-2018 by Comment

Sheet

The mine must commence for job opportunities. Please provide

learner ships to improve the society.






Nontombi Maphikana X 18-08-2018 by Comment

Sheet

I need you as the mine to create some jobs and capacitate the

community, NPOs and SMMEs etc. We also need ABED Schools.






Women are always left behind, please empower them. We need skills,

trainings and workshops.



We are tired of people who employ only from 18-35, can you also

include 36-59. Take our grievances seriously.




Xola Poni X 22-08-2018 by Comment

Sheet

As the youth we need job opportunities, sport facilities and library. This will be as per the approved SLP.




Sheet

Mmabatho Mokwena X



for the EIA Report






Mabel Malepa X 22-08-2018 by Comment

Sheet

Job creation, women empowerment, trainings, provide skills and also

assist in other assets that the women need.






Simon Makhoba X 21-08-2018 by Comment

Sheet

Job creation, help our community especially NPOs and SMMEs. This will be as per the approved SLP.





As youth we need job creation, implementation of skills, trainings,

workshops and employment for young women. We also need sports

facilities, community park, technical centres, NPOs must be assisted,

capacitated and libraries.






Our environment is surrounded by big trees and bushes that needs to

be cut in terms of our safety.


Dudu Tryphina Nkosi X 24-07-2018 by Comment

Sheet

Empowering of the community. Create jobs. Empowerment of

disabilities, build an old-age home and an orphanage. As the women

safety at Solplaatjie need some trainings, to be capacitated, sports

facilities, youth trainings and a library. We are the elderly structure.






Millicent Balincwadi X 15-08-2018 by Comment

Sheet

I would like to be assisted in extending our day care centre (ECD) so

we can help more community children. When can we expect an

answer from you in this request?




Bheki Radebe X 24-08-2018 by Comment

Sheet

We are fully behind the opening of those shafts as that will reduce

poverty and high unemployment rates.


Thabang Mokone X 21-08-2018 by Comment

Sheet

We hope the mine will bring jobs, new hospitals and school in Ward

129. Reduce poverty







Sheet

Sinovuyo Innocentia Thisani X



for the EIA Report






Monica Moloto X 24-06-2018 by Comment

Sheet

I am happy about the opening of the mine. I will be much more happy

if you could assist the kids in terms of doing a park for them and a play-

grounds.




I am interested in the re-opening of the mine because it will create

jobs and change lives. The youth must also be empowered by means

of job opportunities and skills trainings. Clean or destroy bushes so

that it can be safe for kids and adults when passing through to school

or work. Fix the community halls as they are used for funerals and

weddings.






Clean or destroy bushes so that it can be safe for kids and adults when

passing through to school or work.




We ask for gender equality in terms of employability, and that people

from 36-59 be employed.




We want jobs in our community because a lot of the youth in the

community are unemployed. May mining help our youth and

community to build their future.






We want scholarships and libraries, and schools. This will be as per the approved SLP.



We want to see people from the community being employed. This will be as per the approved SLP.



We need scholarship for the youth, high school and primary school,

libraries, parks for our children.





Sheet

France Mashaba

Siphokazi Matshinyane

Musa Dlamini


Sheet


Sheet

X

X

X



for the EIA Report






Women and young women empowerment, youth empowerment, job

creation, empowerment of NPOs, arts and cultural groups.






Can you please dissolve the mining forum as we are not aware of it. The Public participation process (PPP) undertaken to date is in line with






Mobile - 073 388 6803; and



Women as safety promoters need to be assisted as we are busy

assisting the community in terms of safety.




We would like you to assist the elderly women and women by

constructing sports facilities as we play netball, soccer and dance.




I would like the project to give us as the community at least 30%. This will be as per the approved SLP.



The project must employ the youth and community members. This will be as per the approved SLP.



Support through funding and needs we have as the center in the

community regarding children (ECD).




Nothemba Innocentia Thisani

Tembekazi Sotuku


Sheet

Linda Dube


Sheet


Sheet

X

X

X



for the EIA Report






I would appreciate if your company can empower the children by

ensuring they are educated, especially those who are not in creche

because of incapacity. The aim of this organization is to identify the

need of children and formulate programmes that will provide quality

responses in their lives.




Julia Mbulaleni X 13-08-2018 by Comment

Sheet

What minerals are you dealing with? Gold is the target resource but within the geological composition of the



I would like to learn and grow more knowledge through an

apprenticeship program, and to gain experience and understanding of

mining.



What does the West Wits mine produce? Gold is the target resource but within the geological composition of the



How is our community going to benefit through the mine? This will be as per the approved SLP.



Will West Wits mining be able to accommodate non-experience

workers?




When are you going to open the mine? The project will only commence upon receipt of environmental


How are you going to communicate with us? Phone or email? This will be as per the approved SLP.

Will I be notified if my application is not approved? This will be as per the approved SLP.

Portia Simomophana X 13-08-2018 by Comment

Sheet

What will the community benefit from the mine? We hope you will

employ the youth from our community to reduce to much crime and

using of drugs. I would also like to be a part of the mine.




When will this project take place? The project will only commence upon receipt of environmental


How is it going to benefit the community? This will be as per the approved SLP.



Sisanda Zikhathile

Bernard Nthulane

Arnold Phasha, Sibongile

Khumalo, Andisiwe Tomose,

Vuyokaz, Sibusiso Memani,

Thozeka Khumalo


Sheet


Sheet


Sheet

X

X

X



for the EIA Report






I would like the mine to employ the youth as artisans. We have a large

number of youth with Grade 10 and 11 but lack work experience.




The company must open an artisan school for our community and

support other small SMMEs.




How will the mine assist the community? This will be as per the approved SLP.



Which minerals are you extracting from that mine? Gold is the target resource but within the geological composition of the



How does the mining operate? Details on the mining operations of the project have been included in


Won't the mine affect the health of the people (e.g. silicosis). This issue has been noted and has been considered by the Human






Report.

How will the mine benefit the community? This will be as per the approved SLP.





Details on the project locality has been included in Section 2.2 of the EIA

Report.

Please do this in a proper way because people are struggling to find

jobs.






Nomalungisa Mqontshane,

Portia Noncedo

Odwa Nompetsheni,

Avhantodi Tshinyani,

Avhapfani Mercy Tshilikwa,

Thapelo Mphobala, Andrew,

Thato Gaaname, Beauty

Moima, Yonela Chiliza,

Nomakwezi MabhadeniselaMduduzi Maseko,


Sheet


Sheet


Sheet

X

X

X



for the EIA Report






When will the mine be opened? Who is the owner of the mine? The project will only commence upon receipt of environmental


West Wits MLI (Proprietary) Limited.

How will the elderly people and community benefit from this? This will be as per the approved SLP.



If ever the mine is opened will people who stay in Durban Deep be

relocated?


Lerato Jabane X 13-08-2018 by Comment

Sheet

We are happy because of the job opportunities that the mine comes

with. This will reduce crime-rates.


Mphumeleli X 13-08-2018 by Comment

Sheet

How safe is the mine when I work underground? Although permits or approvals in terms of health and safety regulations




1996) (MHSA).

Rosabalha Xayiya X 13-08-2018 by Comment

Sheet

I want the mine to educate our community. This will be as per the approved SLP.



Phumeza Nodyiwana X 13-08-2018 by Comment

Sheet

Concern is dust from the mining. Both as a nuisance and pollutant. This issue has been noted and has been considered by the Air Quality



the EIA Report.

Moses Saka, Zodwa,

Murendeni Singo, Thembisa

Nyangase, Thobela Ntlabezi,

Rethabile Moedie,

Noluthando Thetyana


Sheet



Details on the project locality has been included in Section 2.2 of the EIA

Report.

Ephraim Netshisaulu, Eunice

Netshisaulu and Tebogo

Mohlala


Sheet



Report.


Sheet

Kagoentle Gomba X



for the EIA Report






When will the mine be opened? Who is the owner of the mine? The project will only commence upon receipt of environmental


West Wits MLI (Proprietary) Limited.


Report.

How will the elderly people and community benefit from this? This will be as per the approved SLP.



Vuyokazi Magengenene and

Thozeka Khumalo


Sheet

How long will the Environmental Application process take? The environmental authorisation application process is a 300 calendar

day process from the date of submission of the application.

Seliyenda Bomela, Nhlamulo

Mathye, Smangele Ntombela,

Vuyokazi Nogangala, Funeka

Celaiso Ziyanda Mkhwambi,

Bongiwe Gudla and Buseka

Nompetsheni, Phokuhle

Maqakelana


Sheet

I would like West Wits to provide the youth with jobs so that they can

provide for their families and stay away from drugs and alcohol abuse,

reduce poverty and reduce teenage pregnancy.




Kagiso Moholo X 13-08-2018 by Comment

Sheet

I have always been interested in working at a mine and learning more

about it. How long will this project run? When will it start? Is it a long

or short term project?

The project will only commence upon receipt of environmental


Details on the project timeline has been included in Section 3.2.2 of the

EIA Report.

Zintle Vesele X 13-08-2018 by Comment

Sheet

How long will the Environmental Application process take? I would like

to be part of working underground.

The environmental authorisation application process is a 300 calendar


Ntombizanele Khuzwayo X Please open an artisan school This will be as per the approved SLP.



Lufuno Roselet Tshilukwa,

Masidiri Pfano, Thabo

Mosimaneng, Mabala

Khodani, Deborah Banda,

Mokgadi Emelda, James

Seokoma, Portia Mayila,

Nduduzo Sibiya, Lydia Jongile


Sheet


Sheet

X



for the EIA Report






Ntombizanele Khuzwayo,

Funeka Celaiso, Bongiwe

Gudla, Buseka Nompetsheni,

Tebogo Mohlala

X How are we going to benefit from this mine? Details on promoting justifiable economic and social development have


Ntombizanele Khuzwayo and

Nosibusiso Kiva

X In the event that the mine employees get sick or injured, is the Mine

going to take care of the hospital costs?


Ntombizanele Khuzwayo X When an employee dies, are there any benefits to the family? This will be as per the approved SLP.



for the EIA Report






Desry Selemane Please open an artisan school. This will be as per the approved SLP.



Desry Selemane Is the mine not going to affect us? This issue has been noted and has been considered by the various




Desry Selemane, Tebogo

Mohlala, Katleho Sebezo

How many people are going to be employed and how many working

hours?

Details on workforce required by the project and project timeline have


Mary Penyenye X 13-08-2018 by Comment

Sheet

As a community member of Solplaatjie, how do I stop illegal

underground miners?

Through engagement with the SAPS.

Bonga Zikhathile, Noncando

Komati, Katleho Sebezo

There is plenty of unemployed youth at Solplaatjie and some have

matric. We would like to see change in our community in terms of

youth empowerment programmes to counteract challenges that the

youth are faced with.




Bonga Zikhathile Won't the mining affect the health of the residents? This issue has been noted and has been considered by the Human




Ndivhudzannyi Shandukani

and Nomaza Ndabeni

When are you going to start operating? The project will only commence upon receipt of environmental


Ndivhudzannyi Shandukani,

Linda Mathimba

Is it safe to work on that mine? Although permits or approvals in terms of health and safety regulations




1996) (MHSA).


Sheet


Sheet


Sheet

X

X

X



for the EIA Report






Noluthando Gwadiso,

Nomaza Ndabeni, Thozeka

Khumalo, Xola Mokweni and

Nomathemba Ntlhokoa

Please give all the community members of various ages an

opportunity to work and take care of their families.




Noluthando Gwadiso Are women going to be employed? This will be as per the approved SLP.

Tshepo Tshobeng How will the community be affected? This issue has been noted and has been considered by the Socio-




Tshepo Tshobeng Will there be any opportunities for those with FET (N6) in Business

/Marketing Management?


Tshepo Tshobeng Should the project be approved, what kind of jobs will be available

and what are the requirements / qualifications required for the

opportunities that will be available?


Radzimbado Ndizulafhi I would like to know about my safety when working? Although permits or approvals in terms of health and safety regulations




1996) (MHSA).

Radzimbado Ndizulafhi I would like to know whether this post is permanent or part-time?

How much will be earning?

Details on project timeline and workforce required by the project have


Radzimbado Ndizulafhi Who is the owner of the mine? West Wits MLI (Proprietary) Limited.


Report.

Linda Mathimba X 13-08-2018 by Comment

Sheet

How will the information pertaining to how to join the mine be

communicated?


Boniswa Siko and Itumeleng

Thongwane


Sheet

Where is the project going to be? Details of other support services including fuel storage facilities required

by the project have been discussed in Section 3.2.13 of the EIA Report.


Sheet


Sheet


Sheet

X

X

X



for the EIA Report






Onke Gwaza X 13-08-2018 by Comment

Sheet

Will the mine hire only Ward 129 people or other people from other

areas?




Ncebakazi Mzinzeni When will the mine be open? The project will only commence upon receipt of environmental


Ncebakazi Mzinzeni and

Nosibusiso Kiva

How does the mine affect community? This issue has been noted and has been considered by the Socio-




Ncebakazi Mzinzeni How long will it take? The environmental authorisation application process is a 300 calendar


Ncebakazi Mzinzeni How much is the salary? This will be as per the approved SLP.

Unathi Ndwebisa X 13-08-2018 by Comment

Sheet

Will the mine affect us in a negative way because we have double

storey houses, will the mining not lead to our houses collapsing?





Fezeka Mthembu and

Nosibusiso Kiva


Sheet

Who is the owner of this company / mine? West Wits MLI (Proprietary) Limited.


Report.

Fezeka Mthembu X 13-08-2018 by Comment

Sheet

How are we as community going to gain from this? This will be as per the approved SLP.




Sheet

What is the purpose of doing this? In order to provide an opportunity for you to partake in a constructive

manner in the PPP, which has been undertaken to date in line with

Chapter 6 of the EIA Regulations (2014), as amended.


Sheet

What effect are we going to face as community? This issue has been noted and has been considered by the Socio-





Sheet

X



for the EIA Report






Sinovuyo Innocentia Thisani X 13-08-2018 by Comment

Sheet

How will the project take place once authorisation is granted? Details on the project timeline and mining activities of the project have


Sinovuyo Innocentia Thisani X 13-08-2018 by Comment

Sheet

Will people who apply be all hired/fired? This will be as per the approved SLP.



Nosibusiso Kiva X 13-08-2018 by Comment

Sheet

What minerals do they mine? Gold is the target resource but within the geological composition of the



Mametlwe Sebei - Lawyers

for Human Rights acting for

Communities Against Mining


received on 3 September

2018

We act on behalf of Communities Against Mining, a registered

Interested and Affected Party (“I&AP”) for the environmental impact

assessment (“EIA”) process being undertaken for the West Wits

Mining Project proposed by West Wits MLI (Pty) Ltd (“West Wits” or

“the applicant”).

These comments are separate to our submission to the Department of

Mineral Resources (“DMR”) (which is copied to you) regarding the

applicant’s non-compliance with Regulation 11(2) requiring the

submission of a single application where there is an intended

undertaking of more than one activity as part of the same

development. If we are correct in our submission, the current Scoping

process is fundamentally flawed, as it does not include the proposed

Kimberley West and Creswell Park mining activities that are part of the

applicant’s same development.

For the proposed Kimberley West and Creswell Park opencast pits, two

separate Mining Permit (MP) applications have been applied for over

two separate farms . The MP areas have been removed from the

Prospecting Right (PR) area via a Section 102 in terms of the Mineral and

Petroleum Resources Development Act, 2002 (No. 28 of 2002)

(MPRDA). The chief motives for beginning mining under a MP were

based on: the directive received from the DMR to mine the ore close to

surface, thereby also discouraging artisanal/illegal miners in the area,

and to commence rehabilitation of the opencast pits; a shorter

timeframe is also required for a MP to be approved by the DMR.



for the EIA Report











2018

Non-compliance with Appendix 2 of the Regulations: Scoping

Process and Report

We note at the outset our dissatisfaction that comments submitted by

I&APs during the public participation process that commenced in late

March 2018, and which included a public review of the Scoping Report

prepared in support of the original application for a mining right and

environmental authorisation, have not been included in this Scoping

Report. I&APs were also not informed that the comments they had

submitted previously would not be included.

The PPP followed as part of the original mining right and environmental

application that was lodged in April 2018 was included in the Scoping

Report submitted to the DMR in June 2018. However, due to the

submission of the revised mining right and environmental application

followed by the revised Scoping Report, a new public participation

process had to commence. Due to the scope change between the

original and revised applications and Scoping Reports, comments and

issues received during the original process were not all relevant to that

of the revised process. Therefore, the following reason was provided for

not including the comments from the original process and was stated in

the Executive Summary of the Scoping Report dated August 2018 which

was made available for public review as the reason for not including

them:

"A PPP was undertaken to inform the original mining right and

environmental application that was lodged in April 2018. The PPP

included notification of I&APs through distribution of a Background

Information Document (BID), placement of a series of newspaper

advertisements, placement of site notices over several occasions,

distribution of flyers, radio announcements, focussed engagement and

meetings with community structures, public scoping meetings and

review of the original Scoping Report and/or summary. Although a new

PPP is being undertaken in support of the current application, a detailed

understanding of the I&AP groups and related concerns and issues was

gleaned from this process. The nature of the project (that is, open pit

and underground mining) and overall project location has not changed

and therefore this knowledge is deemed relevant to the current

application ."



for the EIA Report











2018


Process and Report

It is unacceptable to simply state that these I&APs comments have

been used to inform the Scoping Report currently under review but

not formally record them therein, especially as it is acknowledged in

Section 6.2 of the Scoping Report that, “the nature of the project (that

is, open pit and underground mining) and overall project location has

not changed and therefore this knowledge [i.e. a detailed

understanding of the I&AP groups and related concerns and issues] is

deemed relevant to the current application ”













them:














application ."



for the EIA Report











2018


Process and Report

I&APs spent considerable time and effort preparing and submitting

comments, attending the first and second round of meetings, and

reviewing and commenting on the previous version of the draft

Scoping Report. They had a legitimate expectation that these

comments would be included in the current Scoping Report and

accompanied by an indication of which issues were incorporated,

alternatively the reasons for not including them, as per the

requirements of Appendix 2 of the Regulations.













them:














application ." Mametlwe Sebei - Lawyers





2018


Process and Report

Of equal concern is the Scoping Report’s lack of locality plans and

descriptions of all listed activities for which environmental

authorisation and a waste management licence are being sought, as

Appendix 2 of the Regulations requires.

As per Section 2. (1) (c) of Appendix 2 of the National Environmental

Management Act, 1998 (No. 107 of 1998) (NEMA) and Environmental

Impact Assessment Regulations (EIA Regulations) published in

Government Notice (GN) No. 982 of 4 December 2014, as amended, an

infrastructure plan of the project showing the location and extent of all

activities applied for at an appropriate scale is provided in Section 3.2 of

the EIA Report.



for the EIA Report











2018


Process and Report

Apart from the mining activities, the access and haul roads, residue

stockpiles (waste rock dumps and topsoil berms) and primary

processing facilities, there is no such plan or proper description

included of inter alia bulk water, sewage and wastewater pipelines;

sewage and wastewater treatment plants; bioremediation plant;

water storage dams; hazardous waste storage lagoons; fuel storage

facilities; watercourse crossings; and notice boards, despite these

triggering listed activities in their own right.

As per Section 2. (1) (c) of Appendix 2 of the NEMA and EIA Regulations

(2014), as amended, an infrastructure plan of the project showing the

location and extent of all activities applied for at an appropriate scale is

provided in Section 3.2 of the EIA Report.

Detailed site layout plans of the infrastructure complexes have been

provided in Section 3.2 of the EIA Report.






2018


Process and Report

There is also no description or assessment of site alternatives for

these other listed activities. There is also no description of design and

layout alternatives for the two underground mining activities and their

respective aboveground infrastructure complexes.

Access route alternatives have been identified by the Traffic specialist

(Appendix O) and have been discussed in Section 6.1.4 of the EIA

Report.

Due to the reasons provided in the Scoping Report, design and layout

alternatives do not currently exist for the infrastructure complexes and

underground workings, however alternatives will be identified and

described during the EIA phase based on the outcomes of the PPP and

findings of the specialist studies (see Section 6.1.2 and 6.1.3 of the

Scoping Report dated August 2018).






2018


Process and Report

Apart from the statements in the Scoping Report that “[a]ll run-of

mine material will be transported to an existing processing plant off-

site for concentrating of minerals ”, there is no further description

about the project impacts off-site, including those in respect of the

tailings generated by the mining activities.

The processing plant and related tailings facility(s)(s) are already in

existence, is located off site and have an approved authorisation to

receive run-of mine material. Therefore the processing plant and its

related impacts does not form part of the West Wits mining right and

environmental application.



for the EIA Report











2018


Process and Report

If any of the information mentioned above is not yet available, we

submit that the applicant has been premature in submitting its

application. Without such information, there can be no compliance

with Appendix 2 of the EIA regulations; no meaningful identification

and assessment of impacts or public participation; no acceptance of

the Scoping Report by DMR and no therefore, no granting of an

environmental authorisation or waste management licence.

As mentioned above, all information as required by Appendix 2 of the

EIA Regulations (2014) has been provided in the Scoping Report dated

August 2018).






2018


Process and Report

For these reasons we submit that the DMR should reject the Scoping

Report outright as this flaw cannot be remedied by simply including

the requisite information in the Final Scoping report to DMR (as this

would defy the requirements of public participation), or as is the EAP’s

recorded intention, to address gaps in the EIA phase.



August 2018).






2018


Process and Report

We also submit that the applicant is not entitled to an extension under

Regulation 3(7) in order to address the flaws in the Scoping Report as

the absence of this mandatory information cannot be viewed as an

unanticipated expansion of scope or an exceptional circumstance.

To date no extensions have been requested or granted by the DMR.






2018

Plan of study for undertaking the EIA process

As set out above, we submit that the Scoping Report as it currently

stands is fatally flawed in a number of respects, such that the DMR is

required to reject submission of the Scoping Report in its entirety.

However, should the DMR accept this document, we submit that

proposed plan of study for undertaking the EIA process is also

fundamentally flawed, as follows.



August 2018).



for the EIA Report











2018


Our comments on the plan of study for undertaking the EIA as set out

in Section 7 of the Scoping Report pertain to the proposed:

- alternatives (Section 7.1);

- specialists studies (Sections 7.2 – 7.4); and

- public participation process (Section 7.7).

The plan of study for undertaking the EIA process requires the

description of the alternatives to be considered and assessed within

the preferred site. Except for the opencast mining activities, there is

no such description of alternatives in Section 7.1, or Section 6.1 to

which Section 7.1 refers.

Access route alternatives have been identified by the Traffic specialist

(Appendix O) and have been discussed in Section 6.1.4 of the EIA

Report.

Due to the reasons provided in the Scoping Report, design and layout

alternatives do not currently exist for the infrastructure complexes and

underground workings, however alternatives will be identified and

described during the EIA phase based on the outcomes of the PPP and

findings of the specialist studies (see Section 6.1.2 and 6.1.3 of the

Scoping Report dated August 2018).






2018


In respect of the specialist studies:

We note that no provision has been made for a specialist to assess the

impact of the proposed project on the planning framework or

proposed developments not yet commenced. This is considered

essential for a project of this nature, which has a lifespan of over 30

years and will sterilise the use of such land until and unless land is

successfully rehabilitated after mining has concluded.

A town planner has been identified as part of the technical project team

to provide guidance and advice.






2018



We also do not support the proposal for there not be a specialist

study for assessing the impacts on geology. This is a key issue that has

been raised by I&APs, particular because of the prevalence of sink

holes in the area as a result of mining activities, and the questionable

stability of the land post closure.



the EIA Report.



for the EIA Report











2018



As per the 2017 Public Participation Guidelines, we request that

extensive consultation is had with I&APs within the project area with

the express purpose of gathering more information on the existing

socio-economic and environmental problems that local residents

already suffer from in the area. This information should then be

provided to the respective specialists to consider and address in their

specialist reports.

This issue has been noted and has been addressed by the Socio-









2018



Apart from assessing the on-site impacts, we request that the

biodiversity specialist also identifies and assesses the impact of the

proposed development on the regional ecological linkages (current

and planned) as well as the ability of the land to regenerate and

support biodiversity after the respective areas have been mined.

This issue has been noted and has been considered by the Biodiversity

specialist (Appendix F). Relevant impacts including mitigation and


the EIA Report.






2018



We request that the socio-economic specialist and the vibration and

blasting specialist include in their assessments the impacts of blasting

on low-cost and informal dwellings, as these buildings and structures

are likely to be of lower building standards, and therefore, less robust.


Vibration and Socio-economic specialists (Appendix M and Appendix Q).








2018


In respect of the proposed public participation process, we do not

agree that a 30-day I&AP comment period on the EIA Report, the

Environmental Management Programme (“EMPr”) and specialist

reports meets the objective of Integrated Environmental Management

in Section 23 of NEMA to “ensure adequate and appropriate

opportunity for public participation ”.

Extensive PPP has been conducted as part of the revised application

process (see Section 6.2 of the scoping Report dated August 2018).

Although this is not a stipulated requirement, the NEMA EIA Regulations

(2014) as amended, does state that the EIA Report has to be subjected

to a PPP of at least 30 days.



for the EIA Report











2018


The prescribed 30 days in the Regulations is the minimum number of

days required for public review of reports; it is not a fixed or

maximum number. As per the 2017 Public Participation Guideline,

“the minimum requirements for public participation outlined in the

EIA Regulations will not necessarily be sufficient for all applications …..

and it may be necessary in some situations to incorporate extra

steps”.

We submit that this is precisely such a situation, and that extra steps

are necessary if the EIA process is to fulfil Section 23 and the Section 2

principles of NEMA, in particular the principle that requires the

promotion of “[t]he participation of all interested and affected parties

in environmental governance …… and all people must have the

opportunity to develop the understanding, skills and capacity

necessary for achieving equitable and effective participation, and

participation by vulnerable and disadvantaged persons must be

ensured”.






for the EIA Report











2018


Some of these extra steps described in the Guideline include:

4.8.1. addressing the perceptions of unrealistic expectations of the

project (e.g. job creation) through consultation;

4.8.2. making the executive summary of reports available in two other

regional languages (we suggest three additional languages given the

project context – see below);

4.8.3. addressing the high social diversity (socio-economic status,

language and cultural) in the area through proper consultation; and

4.8.4. including mechanisms that will ensure full participation by

people with special needs (e.g. illiteracy, differently abled, etc.).

We therefore submit that the following public participation steps in

the EIA phase, particularly in view of the voluminous and highly

technical reports that are anticipated should be included:

A 60-day comment period for the draft EIA Report, inclusive of

specialist studies and EMPr.









2018





A full day workshop or open day to be held with specialists at an easily

accessible venue and suitable day and time, with translation services

available, to allow I&APs to engage verbally with the specialists over

their findings.

This is not a requirement by the NEMA EIA Regulations (2014) as

amended.



for the EIA Report











2018





An executive summary of the draft EIA report in Afrikaans, isiZulu and

Sesotho, in addition to English.

The executive summary has been communicated in the most

appropriate language spoken in the area.






2018





Full, objective disclosure with respect to the numbers of jobs for the

local community expected to be created, a description of the type of

skills that will be required for those jobs, and the approximate

timeline within which such jobs will be created.







2018





Full, objective disclosure of business opportunities for the local

community expected to be created, a detailed description of the type

of the business opportunities and requirements for access of those

opportunities and approximate timelines within which those

opportunities will be created.




for the EIA Report











2018


Unless the plan is revised to address the inadequacies described

above, we place on record that we do not agree with the plan of study

for undertaking the EIA as currently proposed.



August 2018).






2018

Request for additional information

In addition to our comments on the Scoping Report, we request the

following material information:

A copy of the new application for environmental authorisation lodged

with DMR on 24 July 2018 or thereabouts;

A copy of the application for Environmental Authorisation in support of

the Mining Right Application was provided (see proof included in

Appendix F of the Scoping Report dated December 2018).






2018




The reason/s why West Wits submitted a new application for a mining

right to DMR;







adequately that the application was re-submitted and a new Scoping

Report went out for public review.






2018




Details regarding West Wits’ intentions in respect of Main/South Reef

West that has been excluded from the current application;

In the event that the applicant would like to expand underground

mining areas within the mine site e.g. Main/South Reef West that is not

included in the current mining right application process, an EIA

amendment process will have to be followed.






2018




Detailed information of the processing of the ore off-site, including

the name of the facility, the volumes of tailings that will be generated

from ore mined as part of the West Wits Mining Project, the licences

the facility holds and the measures that it has in place to prevent

pollution and environmental degradation;

According to West Wits, the off-site processing plant that has been

identified for the concentrating of minerals is located approximately 40

km from the proposed West Wits project area.



for the EIA Report











2018




Detailed terms of reference for each of the specialists. The

summarised paragraphs in the Scoping Report are insufficiently

detailed and do not allow I&APs a full understanding of what the

studies will entail;

As per the Appendix 2 of the NEMA EIA Regulations (2014) as amended,

the specialists' terms of reference as included in Section 7 of the

Scoping Report includes the environmental aspects, as well as a

description of the proposed method of assessing the environmental

aspects and the aspects to be assessed. The detailed terms of reference

of each specialist study has been included in the respective specialist

reports included as Appendix E to S of the EIA Report.



for the EIA Report











2018




Notification of any extension that is requested, and granted in terms

of Regulation 3(7), including copies of correspondence submitted to

DMR motivating for such an extension and the communications from

DMR containing its decision in response thereto; and

To date no extensions have been requested or granted by the DMR.






2018




An electronic copy of the Final Scoping Report submitted to DMR,

should the applicant proceed with the submission of a final Scoping

Report despite its shortcomings, in which the changes to the current

draft version are highlighted for ease of reference.

We reserve the right to comment further on issues raised in this

submission as well as those not raised, should the Scoping Report be

accepted, and environmental authorisation ultimately granted, and

should we choose to exercise our right to appeal.

All registered I&APs were provided access to the electronic copy of the

Scoping Report as submitted to the DMR highlighting the changes since

the public review period.






2018

Lastly, we remind the EAP of her obligations prescribed by Regulation

13 to be objective, even if this results in views and findings that are

not favourable to the application, and to disclose all material

information to I&APs that reasonably has or may have the potential of

influencing any decision to be taken by DMR and the objectivity of any

report. We do so because we have been extremely concerned about

the apparent lack of independence and objectivity in the Kimberley

West and Creswell Park EIA application processes and basic

assessment reports, and as such, have requested that the DMR

investigate these allegations in terms of Regulation 14.

Please refer to the undertaking by the Environmental Assessment

Practitioner (EAP) (see Sections 17 and 32 of the EIA Report).



for the EIA Report






Musa Zwane X E-mail received on 06

August 2018

Will the proposed activities need an Atmospheric Emission Licence

(AEL)? If so, have you started with the application process it?

None of the project activities will require an AEL.

Avinash Ramsaywok X E-mail received on 07

August 2018

Will there be any baseline PM10 and PM2.5 studies done before the

project commences??




the EIA Report.

Adelaide Sehlolo X E-mail received on 08

August 2018

I have concern regarding the mining. Is it not going to affect our health

and environment?







for the EIA Report






Nyanda Khanyile X Focussed meeting held on 6

March 2019 (Communities

Against Mining (CAM))

Is Creswell Park getting a park? The City of Joburg is the owner of that land and would like to create a

park.


March 2019 (CAM)

Will it be done in accordance with the IDP of the city? The City of Joburg is the owner of that land and would like to create a

park.


March 2019 (CAM)

It is a community project and the city has nothing to do with it. The City of Joburg is the owner of that land and would like to create a

park.

John Kirsten X Focussed meeting held on 6

March 2019 (CAM)

What is the zoning of the area? Kimberley West has not been rezoned as yet. Creswell Park has not

been rezoned but an application was submitted to the CoJ.


March 2019 (CAM)

You mentioned that it would be more beneficial to the community if

the area is mined quicker. How can that be?

The duration of any impacts due to the mining will be shorter and the

exposure of the communities will be over a shorter period.

Gregg Palm X Focussed meeting held on 6

March 2019 (CAM)

You are not affected by the mining like us residents who are exposed

to the impacts.






March 2019 (CAM)

What is the distance from the mining to the nearest residents in

Creswell Park?

The distance is approximately 50 m.


March 2019 (CAM)

Would you agree to mining taking place 50 m from your house? It is not as clear cut as that and that if there was mining taking place 50

m from his home that he would want the mining company to mine

responsibly in terms of their environmental and social commitments.


March 2019 (CAM)

What will you do with the zamazamas? By mining and removing the resource the presence of the illegal miners

will be controlled.


March 2019 (CAM)

Since you started exploring and mining in the area the illegal mining

and crime has increased. Your presence and activities have alerted the

illegal miners that there is a resource to be mined.






March 2019 (CAM)

You are okay with affecting other people’s lives. This issue has been noted and has been considered by the various






for the EIA Report







March 2019 (CAM)

You want to control dust with water. Do you have a water use licence

(WUL)? If you reach the water table you will pollute the environment

and the community.

A WUL application (WULA) process has commenced.


March 2019 (CAM)

In your WULA, must the community be consulted? The consultation was part of the PPP to date and the consultation

process is ongoing.


March 2019 (CAM)

Have you consulted directly with the community in Creswell Park? Yes.


March 2019 (CAM)

Do you have evidence that notification of the community in Creswell

Park was halted or stopped?

Yes.

Mametlwe Sebei X Focussed meeting held on 6

March 2019 (CAM)

In Creswell Park there was prospecting and the community called the

police. The zamazamas noticed that there are minerals and now they

are mining there illegally. Now we have an influx of zamazamas.






March 2019 (CAM)

Where in the law is it stated that the DMR will not approve

development of an area where there is a resource?

There is a prospecting right over that area and that the DMR will not

approve any development over that area if there is a prospecting right

over the area and if a development could potentially lock up or sterilise

a resource because that would mean that the country would forfeit

taxes, royalties and opportunities related to that resource.


March 2019 (CAM)

During your consultation process you have consulted with soft

communities where the carrot of job opportunities were dangled in

front of their noses but you will need skilled people in your operations

and there are not many skilled people in those communities where

you have consulted.





March 2019 (CAM)

What resources are you after? Gold is the target resource but within the geological composition of the




March 2019 (CAM)

How will there be no radiation if you are mining uranium as well? Radiation is a product of the processing of the ore and that any radiation

will only be in the tailings. Primary mineral processing will take place on

site, where ore will be crushed prior to transportation off-site. All run-of

mine material will be transported to an existing off-site processing plant

including a tailings facility for concentrating of minerals.



for the EIA Report







March 2019 (CAM)

Please send us the radiation specialist’s details. Please refer to the Radiological specialist report in Appendix K of the EIA

Report.


March 2019 (CAM)

Will you create radiation? Radiation will only be created if uranium is present in the ore and with

the processing of the uranium.


March 2019 (CAM)

If I buy the land where you intend to mine, will I not be able to

develop that land?

The DMR will not approve any development that will sterilise a resource

of which they are the custodians of.


March 2019 (CAM)

To date we are not aware of any closure certificates issued to a mine

following the rehabilitation of the land. Where has any development

taken place on rehabilitated land. What developments will take place

on the rehabilitated land following the mining?

The owners of the land have specific development plans and end uses

for the land following mining. The rehabilitation of the mining areas

must be done according to a rehabilitation plan which must specify the

methods and standards to be applied to ensure that the end use can be

achieved. The cost of the rehabilitation will be offset against the grade

of the resource to determine whether it is still profitable to mine that

resource.


March 2019 (CAM)

Your benefit is to my detriment. Why would you want to mine where

people live? I bear the brunt of the bad part of mining. You are here to

make money at my expense.






March 2019 (CAM)

You are doing it at the behest of the landowner. What development

can happen in Creswell Park?

The planned end use for the Creswell Park area is mixed industrial.


March 2019 (CAM)

Nothing can happen there. That is a wet area and no development can

take place there.

A wetland specialist investigation was conducted over the area and the

specialist report did not indicate that the area is a wetland.


March 2019 (CAM)

The vegetation of that area shows that it is a wetland and during

prospecting the water table was also intercepted at shallow depths.

A wetland specialist investigation was conducted over the area and the

specialist report did not indicate that the area is a wetland.


March 2019 (CAM)

The Creswell Park area is owned by the CoJ. Did you approach the CoJ

or did the CoJ approach you about developing the area?

We request the records of that meeting with the CoJ.

The CoJ was approached as the landowner in terms of the legislative

requirements for a mining permit application. The CoJ then expressed

their end use requirements for that area.

The CoJ was approached to notify them of the proposed project and to

obtain objections and or comments and concerns. They were not

approached to inform them that there is a benefit to the city.



for the EIA Report







March 2019 (CAM)

Has any housing or other development taken place on an area that

has been rehabilitated following mining?

I will not use that land for housing development if I were you. If the

community can influence the city not to use that land for housing, we

will do it.

There is an example thereof in Rustenburg but that the rehabilitation

and compaction of the area must be done very well. It is a very costly

exercise to compact and rehabilitate an open pit.

The grade of the resource will determine whether it will be feasible for

the mining to continue because if the cost of the rehabilitation exceeds

the value of the resource it may not wish to continue with the project.


March 2019 (CAM)

If you dig the pit and it is not cost effective to rehabilitate the pit, what

will happen then?

The financial provision must be made for the rehabilitation of the mine

as part of the mining right or permit requirements.


March 2019 (CAM)

The community will not benefit. Your goal is to mine on my doorstep

and make profit.






March 2019 (CAM)

There are people who will be affected and they have spent their life

savings to live there. The geology in Gauteng is the same everywhere.

Why do they only mine and prospect in poor areas and not in rich

areas?

The geology is not the same everywhere. The gold reef is situated in this

area and not in other places.


March 2019 (CAM)

I am harmed because of the area where I stay. I couldn’t choose

where I wanted to live because of the previous dispensation but now I

will be negatively affected by mining because of that.

West Wits has improved their mining methods to have a minimal impact

on people in the proximity of the mining. No blasting will take place and

excentric rippers reducing the noise from the operations.


March 2019 (CAM)

The EAP must consider alternative land uses for that area. West Wits has improved their mining methods to have a minimal impact




March 2019 (CAM)

No matter how you mine, it will affect me. West Wits has improved their mining methods to have a minimal impact




March 2019 (CAM)

I ask of you that as you continue with this process, that you leave a

legacy and a positive contribution to the country.

West Wits has made specific commitments in the EIA with regards to

community development and rehabilitation which are binding on them

and must be complied with.



for the EIA Report







March 2019 (CAM)

Eddie Milne still works for you and he used to work for Mintails and he

was involved with projects where they broke the law. We do not trust

the process.



March 2019 (CAM)

You are saying that black communities must suffer and die. This point is noted.


March 2019 (CAM)

What will you rehabilitate? West Wits will rehabilitate what we they have disturbed.


March 2019 (CAM)

Will you use water for dust suppression? Where will you source the

water from?

Details on water supply and management required by the project have



March 2019 (CAM)

Will you use clean borehole water? The groundwater will be mine water from old underground workings.


March 2019 (CAM)

The opencast pits will be approximately 30 m deep. Will you

encounter holings from old workings? Will the dirty water return

underground? Will there be ponding or damming of water?

Holings from old workings will be encountered and water will return

underground via these holings but the water that returns underground

will not affect the quality of the groundwater. No ponding of surface

water will take place.

Details on water supply and management required by the project have



March 2019 (CAM)

Your specialists have conducted their research and studies and found

that it is in order to proceed with the mining because they are paid by

you.

Independent specialists have already appointed for the project and that

they are objective in their assessments and that the mine will not pay

for a second set of specialists.


March 2019 (CAM)

Can the community appoint its own specialists to conduct their own

investigations but the mine pays for these specialists?

Independent specialists have already appointed for the project and that

they are objective in their assessments and that the mine will not pay

for a second set of specialists.


March 2019 (CAM)

Can you give us the assurance that no dams will be affected by the

operations?





West Wits suggested that a follow up meeting be held with the

specialists who have conducted the assessments, who would provide

better clarity on the matters.



for the EIA Report







March 2019 (CAM)

In terms of communication we have had very little communication

with regards to the current mining operations. Where are they mining

currently?





March 2019 (CAM)

Will that area also be rehabilitated and for what use? This EIA Report does not deal with the existing Solplaatjie mining




March 2019 (CAM)

That area is mined under a DMR directive. May we have a copy of that

directive?





March 2019 (CAM)

Why don’t you just mine under a directive similar to what you are

doing at Sol Plaatjie? Why go through the whole mining right and

mining permit application process? You are asking us to trust you

when you can just get a directive to mine without a mining right.

West Wits wants to mine under a mining right and do not want to

circumvent the legislative process. That is why they are conducting this

whole process.


March 2019 (CAM)

When an issue is raised in a meeting and via email, there is no

response from the EAP. Why not?

The process was not at a stage where detailed information was available

at the time or responses to questions could be given for which there

were no answers at the time. Individual responses would be required

for the issues that were raised during the process.

All submissions from the meetings and via correspondence are

answered in the different reports distributed for public review.

Stakeholders can review the reports and verify whether their comments

have been recorded and sufficiently addressed as part of the comments

and response report.


March 2019 (CAM)

You are mining already and then afterwards you start the consultation

process.






for the EIA Report







March 2019 (CAM)

The communities need to be capacitated to understand the process

and the complex studies undertaken because we do not have the

knowledge of the people who have compiled the studies.

West Wits suggested that a follow up meeting be held with the

specialists who have conducted the assessments, who would provide

better clarity on the matters.


March 2019 (CAM)

Executive summaries of the reports must be distributed because a

two thousand page document will take too long to review in 30 days.

The executive summaries of the Scoping Reports were distributed

during the public review periods. The executive summary of the EIA

Report has also been distributed during the public review period.


March 2019 (CAM)

The attendance registers at the meetings imply that if you sign it you

support the mining.

At the public meetings the attendance registers had a note at the

bottom which stated that the attendance register is merely to obtain

the contact details of interested and affected parties to update the I&AP

database for future correspondence and does not imply support or

condoning the proposed mining.


March 2019 (CAM)

The perception is that if you attend the meeting you are in support of

the mining.

At the public meetings the attendance registers had a note at the

bottom which stated that the attendance register is merely to obtain

the contact details of interested and affected parties to update the I&AP

database for future correspondence and does not imply support or

condoning the proposed mining.


March 2019 (CAM)

We saw a list of people in an email to the DMR in support of the

mining. Why was a list not included of the people opposing the

mining?

West Wits is not aware of such an email or such a list.


March 2019 (CAM)

You said in the Roodepoort Record that you felt threatened at the

public meeting in the Roodepoort City Hall, why did you feel

threatened?

She felt threatened when she was surrounded be a number of men

pointing fingers and shouting at her.


March 2019 (CAM)

The people at the meetings felt frustrated that their questions were

not answered at the meetings.

The purpose of the scoping phase is to provide stakeholders with the

project background and available information and to receive

information from the stakeholders to formulate the scope for the

impact assessment to be conducted. Not all questions could be

answered because the assessments of the potential impacts have not

been conducted. The questions would all be answered in the EIA phase

of the project.



for the EIA Report







March 2019 (CAM)

What benefit does the community get out of this project? Can we get

reports that specify employment numbers?







March 2019 (CAM)

Who funds the school and clinic? This will be as per the approved SLP.




March 2019 (CAM)

Can you refrain from stating that you are the solution to the

zamazama problem?

West Wits is part of a solution to a bigger problem.

Rand Leases Property (RLP) X Focussed meeting held on 6

November 2018 (RLP)

RLP requested access to the Resource statement. This is available on the West Wits website and a copy has been provided

to RLP on 20 November 2018.


November 2018 (RLP)

Implementation of the Mining Right (MR) will have potentially

extreme economic consequences.






November 2018 (RLP)

RLP requests assurance that the land will be appropriately

rehabilitated.





November 2018 (RLP)

It was requested that RLP be notified once the scoping report has

been accepted by the DMR, in order for RLP to plan for when the

Environmental Impact Assessment Report will be complete and

available for scrutiny. The reason for this is that the report is typically

extensive and can take a long time to review.

RLP has been notified that the DMR has accepted the Scoping Report on

9 April 2019.


November 2018 (RLP)

RLP strongly recommends that West Wits comes to an agreement

with MAXAM Dantex South Africa (Pty) Ltd (MAXAM Dantex).

According to City of Johannesburg (COJ) MAXAM Dantex do not have all

the required permits in place.

MAXAM Dantex holds a 20 year rolling lease with RLP.

A circular buffer zone exists where an agreement is required to

undermine the surface area, as mining will commence 50 m from

surface.



for the EIA Report







November 2018 (RLP)

RLP considers the 10 year MWP insufficient as it only details 10 years’

of mine planning.

RLP request a 30 year mining plan as they need to strategise their land

use appropriately, particularly with regard to:

- The 20 year rolling lease with Dantex; and

- The housing developments, comprising of in excess of 1 000 units,

which require long term planning in terms of water and electrical

infrastructure.

It was proposed that a mining related scoping report, bearing in mind

the full 30 years life of mine, is considered. Among others, the following

aspects may feed into the scoping report:

- The K9B resource and model; and

- The K9A resource and model, which is yet to be completed.


November 2018 (RLP)

RLP enquired who is responsible for the rehabilitation of the tailings

dams, with particular reference to the DRD main dump.

It was stated that, according to the MPRDA the responsibility lies with

the MR holder; unless:

- An agreement was reached during surface right ownership transfer

that the surface right owner would take on the rehabilitation

responsibility;

- Furthermore, it was indicated that according to NEMA regulations, the

responsibility lies with the surface right holder.


November 2018 (RLP)

RLP stated that they have lost confidence in the MR applicant as the

details of the MR application, and the extent of the MR area, has

changed several times over the entire process:

The reason for the changes were due to:

- Many interested and affected parties (I&APs) being involved as the

MR application covers a densely populated area within the City of

Johannesburg;

- An agreement, or lack thereof, being made with surface rights owners;

- Compliance with law with respect to zoning;

- Existing infrastructure (e.g. the water supply pipelines).


November 2018 (RLP)

It was further commented by RLP that:

- Initially, they were told the Circular Shaft would not be utilised as

infrastructure for the mine;

- Two weeks later the statement was revoked and it was

communicated that Circular Shaft will be utilised;

The Circular Shaft was always present in the long term mine plan.

However, it did not feature in the initial 10 year MWP;

Celokuhle Nkosi X Comment Received on 23

May 2019 by comment

sheet

I would be happy if your project can employ skilled and unskilled

workers in Ward 40 and also business opportunities




for the EIA Report






Alwyn Nortje X Comment Received on 24

May 2019 by Email

I take it that this is still in line with our settlement agreement and that

there are no deviations which might affect some other of our

properties/developments?

I see for example, that the open cast near Witpoortjie (the Mona Lise

Bird Reef) now seems to be away from our proposed Witpoortjie

Extension 71?

There are no deviations. The Mona Lisa has always been on Living Africa

land. Kimberley West I on the Extension 71, but that was part of the

Mining Permit and the Basic Assessment and therefore it is not reflected

in the SR/EIR as part of the Mining Right.

Kgarametsane - resident of

Grobler Park

X Comment Received on 30

May 2019 by Email

Are they still going to give us another chance to oppose these or they

just making it a formality?

The Scoping Report was accepted by the DMR on 25 March 2019. Upon

approval of the Final Scoping Report the EIA was then undertaken. The

EIA will be finalised taking all comments received into consideration and

will then be submitted to the DMR for decision making.

The public comment period for the Draft Scoping Report (August -

September 2018) and Draft EIA (May - June 2019) is now complete.

However, the EIA can still be reviewed online at:

https://slrconsulting.com/za/slr-documents/ and any final comments

submitted.

The DMR decision is expected within 107 calendar days from the July

2019 submission of the EIA Report (inclusive of public comments) to

DMR.

After the DMR has issued a decision

(a) all registered interested and affected parties are provided with

access to the decision and the reasons for such decision; and

(b) the attention of all registered interested and affected parties is

drawn to the fact that an appeal may be lodged against the decision.



for the EIA Report






SolarReserve South Africa

(Pty) Ltd - Azminah Mayet on

behalf of Jason Gerber


June 2019 by Email

1. What does this document relate to?

a. Is it a for a Mining right to DMR or is this to be included in the EIA?

b. If this is for an application to DMR why are we commenting on the

Environmental and not the Mining Application?

c. Has your Scoping Report and EIA been awarded?

d. Please may we review your Scoping Report and EIA to understand

the impacts it may have on our Solar Site.

a. The Environmental Impact Assessment Report summary was sent out

to all I&APs on 22 May 2019. This document is a summary of the full EIA

that was produced as part of the Mining Right Application process. The

full EIA document was also available for review by I&APs at various

locations. Do we want to say where these were here? Comments on the

Draft EIA will be compiled into a Comments & Responses Report (this

document) and included in the Final EIA to be submitted to the DMR for

decision making.

b. The DMR is the Competent Authority for the EIA process for mining

operations.

c. The Scoping Report was accepted by the DMR on 25 March 2019.

Upon approval of the Final Scoping Report the EIA was then undertaken.

The EIA will be finalised taking all comments received into consideration

and will then be submitted to the DMR for decision making.

d. The public comment period for the Draft Scoping Report (August -

September 2018) and Draft EIA (May - June 2019) is now complete.

However, the EIA can still be reviewed online at:

https://slrconsulting.com/za/slr-documents/ and any final comments

submitted. The full public participation process undertaken for the

Scoping Phase can be seen in Section 6.2.1 of the EIA Report.



for the EIA Report










June 2019 by Email

2. Have you submitted your application for a mining right?

a. Is the mining right application for the entire area?

b. When was the application submitted?

c. Is the application available to the public for comments?

d. Is it under consideration?

e. When will it be awarded?

The EIA process is just one of the requirements of the Mining Right

Application and is undertaken as a separate process by an independent

Environmental Assessment Practitioner, in this case SLR Consulting.

a. The MRA area is indicated in Figure 0-1 and Figure 0-2 of the EIA

Report.

b. The Scoping Report was submitted to the DMR for consideration on

11 December 2018 and was accepted on 25 March 2019. The EIA Report

is planned to be submitted to the DMR for decision making in July 2019.

The Mining Right Application Form was submitted directly by West Wits

to the DMR as a separate process to the EIA.

c. Both the Scoping Report and the EIA documents have been out for a

30 day public comment period. All registered I&APs were sent details of

where and when the documents were available for comment.

d & e. Once the Final EIA Report is submitted to the DMR they have 107

days to make a decision.



for the EIA Report










June 2019 by Email

3. You mentioned that the open cast mining with require 5-9 months

for mining and rehabilitation, however this may only occur within the

next 3 years

a. When do you predict you will commence with the open pit mining

at Mona Lisa?

b. How long will it take to mine and rehabilitate at Mona Lisa?

c. Can we see a schedule on the mining plan for Mona Lisa?

d. Would it be possible to change your mining schedule to ensure

Mona Lisa is mined first? – this may lessen the impact on our

development timeline and prevent any issues with any expirations on

our permits and agreements – we have a number of permits and

agreements already approved and signed

e. What protocols are put in place to assist other development

prospects which will now be impacted by this mining process –

extending permits or agreements which are already approved

The issue has been noted. A settlement agreement is in place with the

landowner to in turn coexist with their lessees.





June 2019 by Email

4. What visual impacts do you expect?

a. How much dust will be released from the open pit mining

b. How will this affect the surrounding area?

c. Have you done a Air Quality Assessment and Dust simulation to

determine the quantity and directionality of the dust released during

the mining process?

d. If the solar plant and mining occurs simultaneously - do you believe

that dust will impact on the air quality and solar radiation (dust may

settle on the solar panels)?


Quality and Visual specialists (Appendix J and Appendix N). Relevant







June 2019 by Email

5. Will any blasting occur at Mona Lisa?

a. If so, how will this impact on the soil and ground stability of the

surrounding area?

b. How will the soil be rehabilitated to ensure its stability thereafter? –

the ground will need to be stable to prevent the solar panels from

sinking or tilting once it has been constructed

Blasting will only occur during the underground mining phase, there will

be no blasting for the open cast mining (ie no blasting for Mona Lisa pit).



for the EIA Report










June 2019 by Email

6. What rehabilitation protocols are put in place post open cast

mining?

West Wits commits to rehabilitate the area in accordance with the

relevant legislation and the settlement agreement with the land owner.

Calgro M3 X Comment Received on 20

June 2019 at Focus meeting

With regards to the monitoring of dust and water, how frequent will

this be? Will you be open to share the report with us? And how does

this affect Calgro's compliance?

The issue has been noted. Surface water and Groundwater monitoring

will be conducted on a monthly basis, while Air Quality monitoring will

be ongoing for the duration of open pit mining activities and

rehabilitation.

A settlement agreement is in place with the landowner.



What is "appropriate design" ? Appropriate designs will be implemented to avoid or minimise

environmental impacts and pollution. Details on appropriate design e.g.

ventilation shaft outlet face away from any residential areas have been

discusssed in Appendix D of the EIA Report.



With regards to dust monitoring,we're supposed to notify the

department when we surpass a certain threshold. How will we

account for this jointly because you guys are also adding to it?

The issue has been noted. Air Quality monitoring will be conducted prior

to construction to establish the baseline, and for the duration of open

pit mining activities and rehabilitation.



What is "appropriate equipment" for noise management? Details on appropriate noise equipment e.g. equipment with

specifications with lower sound power levels have been discussed under

Issue 12 of Appendix D of the EIA Report.



Will the underground fuel storage tanks be inspected? If so, how

often?

Fuel storage tanks would be located on surface within the Bird Reef

Central and Kimberley Reef East Infrastructure Complexes.



Which Greenhouse Gas strategies are in place? A greenhouse reduction strategy will be implemented during all mine

phases as described under Issue 10 of Appendix D of the EIA Report.



What will be done with the medical waste? Medical waste will be stored in sealed containers in a bunded store until

it can be removed by a reputable waste contractor on a regular basis for

disposal at a licensed facility (Holfontein Disposal Site for hazardous

waste) (Section 3.2.12 of the EIA Report).



for the EIA Report








In terms of regulatory for the monitoring, would that be something

the EIA covers? Would it be information you have to give the DMR in

order for them to reach a decision? That Granted we're doing

monitoring, this is the regulatory we're looking at.

A detailed monitoring programme is included in the EMPr section of the

report which is legally binding. It outlines the requirements for

monitoring, roles and responsibilities and monitoring and reporting

frequency and time period. The monitoring programme covers all

aspects requiring monitoring including performance against the EMPr,

biodiversity, surface water, groundwater, air, noise and heritage (see

section 29 of the EIA Report).



Since you do your submission after your public participation, will you

come back to us and give us the final version of the EIA and the

monitoring regularities and timeframes?

The EIA Report (inclusive of responses to public comments received) will

be available online at: https://slrconsulting.com/za/slr-documents/.



With the underground mining that will be taking place, none of it is

happening under the houses?

Underground mining activities will not take place beneath any existing

houses.



What about the formation of sinkholes? The areas south of the proposed mining right application area are

located directly on the dolomite and have therefore been excluded from

the mining right application area as mining cannot take place in those

areas.



In terms of social effects, are they looking at implementing offsets or

some sort of awareness on how best the public can protect

themselves?






Mobile - 073 388 6803; and





for the EIA Report








How will traffic congestion be managed? This issue has been noted. Existing roads will be ugraded and a new road

has been suggested by the Traffic specialist. Details of project related

traffic volumes have been included in Section 3.2.6 of the EIA Report.

These have been considered by the Traffic specialist and the Traffic

Impact Assessment has been included in Appendix O of the EIA Report.





Are security measures accounted for in the EMP? Details regarding the proposed security arrangements for the project






Tshepo Nawane- Ward 48

Councillor

X Comment received at

Focussed Meeting on 06

June 2019

Why were other Ward Councillors not consulted since the beginning

of this process? There is a whatsapp group with all the leaders in this

region.

Meeting discussion were held with many ward councillors who referred

us to various people within the wards.


Councillor



June 2019

Alternatively, you could have called the Region C and Region D

Councillors together in one meeting through the Regional Director

and hence depoliticise the process. .

We have previously attempted to do so through MMC Leah Knott,

however the attendance was low and not all Councillors engaged.


Councillor



June 2019

What are the timelines associated with applying for a Mining Right?

And how far is the process now?

The entire application process is 300 calendar days. We are currently in

the last 30 day public commenting period which will end on 25 June

2019. After the review period, all comments received will be

incorporated in the Final EIA Report which will be submitted to the DMR

for decision.


Councillor



June 2019

What makes Ward 48 an affected Ward? Ward 48 is an adjacent ward to the proposed mining right application

area.


Councillor



June 2019

Who in the West Wits Forum is representing Ward 48? We have Ward

Committee members, and can select someone from this ward who

has more knowledge on mining and the environment

Ward 48 has no representation in the forum. A mining forum will be

established upon approval of the mining right. There will be a new

voting process for the new forum.



for the EIA Report







Councillor



June 2019

The community does not want handouts. Instead they want business

opportunities so they too can create jobs in their communities. Also

invest in community initiatives like farming and computer hubs so that

we teach young people how to use a PC from a young age. Also the

mine must consult the communities and understand the real

community needs- this will improve efficiency.






Mobile - 073 388 6803; and




Councillor



June 2019

How are you going to contain illegal mining? Continuous engagement will be undertaken with the South African

Police Service (SAPS) to assist with this matter.

Sabelo Ncana- Ward 127

Councillor



June 2019

The forum must be dissolved and re-voted in. How were the people in

the forum selected?


There will be a new voting process for the new forum.



for the EIA Report






Sabelo Ncana- Ward 127

Councillor



June 2019

Please send me a copy of the Summary in English, Zulu and Sotho so I

can share it with the community during the planned community

meetings in ward 127. Please include the plans for the forum in the

summary as well.

The public participation process has been conducted as stipulated in

Chapter 6 of the EIA Regulations and the applicable Public Participation

guideline in terms of NEMA EIA Regulations, Department of

Environmental Affairs, 2017 has been considered. The EIA summary

letter was written in English which is a primary language of South Africa

that Interested and/or Affect Parties in the area would understand.

However please note the applicant have requested experts to translate

this for you and will make it

available.




Mobile - 073 388 6803; and





for the EIA Report






Sphiwe Mbongo- Ward 41

Councillor



June 2019

Dantex blasting and mine-blasting affects the surrounding homes. The blasting specialist gave guidelines of the explosive charge mass

below surface to be used, and West Wits endeavour to follow the

guidelines to have zero impact on surface and the Maxam Dantex

operation.

The Blasting and Vibration specialist (Appendix M) has made mention of

the potential areas of concern which are the production and magazine

facilities of Maxam Dantex South Africa, and that a section of the

underground workings will pass underneath these facilities. The

specialist also made mention that Maxam Dantex has indicated their

concerns related to the possible structural integrity deterioration of

surface infrastructure that is related to underground mining and that

their biggest concern appears to be ground instability and sinkhole

development. The specialist has therefore recommended that the direct

impact of blasting on the MaxamDantex infrastructure should be

quantified through measurement when the underground operations are

underway.

Happyboy Molobye- Ward 43

Councillor



June 2019

We request a community feedback meeting so the EIA feedback can

also be shared with the community.

An extensive Public Participation Process has been conducted and

numerous public open day sessions and focussed

group meetings were held in the Scoping Phase. Therefore, no

additional public meetings are being planned during

the EIA phase.


Councillor



June 2019

We see everyone receives the same information- is this necessary? The Public participation process (PPP) undertaken to date is in line with


discussed in Section 6.2 of the EIA Report. The PPP must provide access

to all information that reasonably has or may have the potential to

influence any decision with regard to an application and must include

consultation with all I&APs.



for the EIA Report







Councillor



June 2019

I would like to request a focussed meeting with the Ward Executive

Committee.




Mobile - 073 388 6803; and



Sylvia Monakale- Ward 128

Councillor



June 2019

Won’t the community be affected by any underground blasting

activities?

This issue has been noted and has been considered by the Vibration and

Blasting specialist (Appendix M). Relevant impacts including mitigation



The blasting specialist gave guidelines of the explosive charge mass


guidelines to have zero impact on surface.

Mandla Mlangeni- Ward 44

and 49 Councillor



June 2019

Will DMR make a decision by this year? The DMR decision is expected within 107 calendar days from July 2019

submission of EIA Report (inclusive of public comments) to DMR.

Mandla Mlangeni- Ward 44

and 49 Councillor



June 2019

Has the Water Use License Application commenced yet? A WULA has commenced for the proposed mining activities. A

notification of West Wits intention to submit an application was

submitted to the Department (Appendix B of the EIA Report). The WULA

would be initiated towards the end of the EIA process once the technical Katlego Kale from City of

Johannesburg



June 2019

Not everyone understands the terms used in report, how do you

ensure the community understands the finer details?


process (see Section 6.2 of the EIA Report). Numerous public open day

sessions were held as part of the Scoping phase, and ongoing

community engagement and training are taking place through the West

Wits Community Forum established in Roodepoort.



for the EIA Report






Katlego Kale from City of

Johannesburg



June 2019

Concern is given to the blasting associated with mining due to the

presence of informal housing around the mining area.

This issue has been noted and has been considered by the Vibration and







Katlego Kale from City of

Johannesburg



June 2019

Won’t the mining affect surface water? This issue has been noted and has been considered by the Surface

Water specialist (Appendix G) and potential impacts on surface water

has been assessed in Appendix D of the EIA Report.

Khomotjo Ledwaba of Maxam

Dantex



June 2019

Maxam objected to the Kimberley Reef mining site because it is right

under our explosives factory. No guarantees can be given that it won’t

be affected by blasting.

West Wits endeavour to have a settlement agreement in place with

Rand Leases soonest, which will include a Stability Study.


Dantex



June 2019

We rejected Shaft 11 as well. It is within our blasting area and Maxam

takes full responsibility for any injuries in this area. With the proposed

mining, this will compromise the safety of employees because they

will be in Maxam’s blasting zone.


Rand Leases soonest.


Dantex



June 2019

Maxam deals with blasting, even if the Mine’s boundary line is 5

metres from our site, with the blasting it will always put the lives in

danger.



Tarino Mutenha of Maxam

Dantex



June 2019

Maxam blasts daily, imagine if the mine blasts as well, it will be a

seismic disaster.



Tarino Mutenha of Maxam

Dantex



June 2019

Should an incident occur at our site above ground, the safety measure

Maxam has in place is that the explosives magazines are designed to

blast in a downward direction. These are tonnes of explosives. How

will the mineworkers under our factory be safe from this?





for the EIA Report






Alpheus Motloung of Maxam

Dantex



June 2019

What type of charges will the mine use? This issue has been noted and has been considered by the Vibration and








Dantex



June 2019

Is there an available blasting plan? This issue has been noted and has been considered by the Vibration and








Dantex



June 2019

Is there an independent body that can appoint a Geotechnical

Specialist for Geotech studies? The results may be biased and not a

true reflection of what is happening if they are appointed and paid by

the mine.




Dantex



June 2019

Should all our concerns and comments be neglected, what steps can

Maxam take?



Umhlaba Environmental

Consulting CC on behalf of

Rand Leases Properties (Pty)

Ltd


June 2019 by Email

The EAP’s response to the issues raised during the Scoping phase

highlights the complete lack of understanding of the impact on Rand

Leases properties. The Cresswell Park Extension 3 township will be

developed over portions 407 and 408 and another development will

take place over portion 409. Portion 429 is developed and will not be

impacted by the proposed mining operations.

The issue has been noted. The relevant impacts to the farm portions on

which the open pit mining areas would be located which includes these

farm portions, have been assessed and included in the EIA Report.



for the EIA Report









Ltd


June 2019 by Email

Two thirds of the proposed 11 shaft open pit intersects the Remainder

of Portion 161 of the Farm Vogelstruisfontein 231 IQ, and the planned

underground mining will also undermine the said portion of land. For

the EAP to respond by saying it will not be directly affected again

highlights the EAP’s complete disregard of the impact on Rand Leases.

The issue has been noted. The relevant impacts to the farm portions on

which the open pit and underground mining areas would be located

which include this farm portion, have been assessed and included in the

EIA Report.




Ltd


June 2019 by Email

Re-submission Concerns

Should this project be approved, it will significantly impact all of Rand

Leases properties.

The issue has been noted.




Ltd


June 2019 by Email


Rand Leases has not been provided with any of the documents

requested during the scoping phase including:

1. Pre-feasibility and feasibility report

2. Prospecting results

3. Mine Works Programme

This project will have a significant impact on Rand Leases, yet the EAP

/ applicant is not willing to share information which should show the

viability of the proposed mine and allow Rand Leases to fully

participate in the consultation process.

A copy of the resource statement was provided to Rand Leases

Properties (see proof in Appendix B of the EIA Report dated May 2019).

The resource and reserve statement is available on the West Wits

company website. A redacted version of the Mining Work Programme

will be supplied for these areas, and the technical team will continue to

engage with Rand Leases.




Ltd


June 2019 by Email


A copy of a resource statement was provided, however the viability of

the proposed mine has not been provided.

The resource and reserve statement is available on the West Wits

company website. A redacted version of the Mining Work Programme

will be supplied for these areas, and the technical team will continue to

engage with Rand Leases.




Ltd


June 2019 by Email


Scoping phase comment: Please explain how in the space of 3 months

the area for the Mona Lisa pit can increase from 3 hectares to 20

hectares (with no alteration to the minable resource).

EIA phase comment: The extreme changes between the first and

second application have not been justified sufficiently.

The level of project detail available for the first application process was

incomplete, however it was rectified in the second application process.



for the EIA Report









Ltd


June 2019 by Email


Scoping phase comment: During the previous consultation process for

the original scoping report, we were informed that no underground

mining would be implemented from the Bird Reef Central

infrastructure area. The fact that in less than 3 months a resubmission

of the application indicates that underground mining will take place

from the Bird Reef Central infrastructure implies that we were

completely misinformed.



Based on outcomes from landowner consultation, the applicant became

aware that the farm portions on which the Main/South Reef West

infrastructure complex and underground mining area would be located

were proclaimed a township. Therefor the Main/South Reef West

Infrastructure Complex and underground mining area were excluded

from the second application process and replaced by the Bird Reef

Central underground mining area.




Ltd


June 2019 by Email


Scoping phase comment: The following comment contained within the

alternative section of the re-submitted application highlights our

concerns around the planning of the project; “The property on which

the actual open pit and underground mining related activities takes

place is dependent on the location of the target mineral resource. It

follows that no alternatives could be considered for the mine site.”

This comment is provided despite the fact that 3 month prior to the

submission of this application a completely different underground

resource was targeted.



Based on outcomes from landowner consultation, the applicant became

aware that the farm portions on which the Main/South Reef West

infrastructure complex and underground mining area would be located

were proclaimed a township. Therefor the Main/South Reef West

Infrastructure Complex and underground mining area were excluded

from the second application process and replaced by the Bird Reef

Central underground mining area.



for the EIA Report









Ltd


June 2019 by Email


Scoping phase comment: Upon querying with the EAP for a brief

explanation of the reason for the reapplication & the differences

between the original and this new application. The response received

was; The applicant felt the need to re-apply in order

to: Include the consideration of design/layout alternatives for the

opencast mine pits; & Exclude the Main/South Reef Infrastructure

complex & underground mine workings which would have been

located towards the northwestern side within the proposed mining

right pplication area next to Witpoortjie. The above is a serious

understatement of the changes that have taken place between the

original & resubmitted application raising concern about the EAP’s

ability to communicate effectively with I&AP’s.



As per the response provided in the EIA Report dated May 2019:

The changes mentioned were as a result of the changes to the

design/layout of the opencast mining areas and the Bird Reef Central

Infrastructure Complex.












Ltd


June 2019 by Email


Upon review of the draft EIA report it appears that new changes,

which again have not been highlighted by the EAP has occurred. For

example; in the Final Scoping Report the proposed depth of

underground mining was from 100m to 3km. In the EIAr, the

proposed depth is now 50m to 3km. This is a significant deviation with

implications to Rand Leases which has not even been highlighted in

Section 19.2 of the EIAr which is supposed to highlight the deviations

between the Scoping an EIA Report.

Based on new project information the working depth to interception of

the reef for both the Kimberley Reef East and the Bird Reef Central

underground mining areas was reviewed and updated in the EIA Report

dated May 2019. Please refer to Table 19-1 of the EIA Report dated July

2019 where the change in working depth of the underground mining

areas has been included as a deviation from the Scoping Report.



for the EIA Report









Ltd


June 2019 by Email

Roodepoort Main Reef Pit Activity

Rand Leases was provided a letter from the mining house stating that

there was no viable resource under the property in question. On the

back of this Rand Leases have planned for the future development of

the land (Cresswell Park Ext 3). Instead of providing prospecting /

technical proof that the original letter is wrong, the adjacent one liner

is provided. Rand Leases insists that proof in support of the viability of

the proposed mining of this pit is presented.

According to page 3 of the Draft EIAr the Water Use License

application will be submitted once the EIA and EMPr has been

submitted. Best (unlikely) case scenario is that the WUL is processed

within a 1 year period. Therefore based on the current delays and lack

of obtaining the required legal authorisation, West Wits will not be in

a position to commence with any mining until 2021 (which in itself is

very unlikely). Based on these timeframes Creswell Park Ext 3

residential project will be in development. West Wits will need to

compensate Rand Lease for any delay they may cause to the

development of Creswell Park Ext 3. A redacted version of the Mine

Work Programme has still not been provided to Rand Leases.

This will be addressed in the settlement agreement. West Wits is also

committed to complete mining in an appropriate time frame not to

delay Rand Leases.



Leases.




Ltd


June 2019 by Email


Verbally Rand Leases have been informed that other affected

landowners have reached “settlement agreements” with West Wits.

No such efforts have been made by West Wits to come to an

agreement with Rand Lease. Therefore there is currently no

agreement in place and Rand Lease will strongly protect their property

rights and object to this application until an amicable agreement has

been reached.

See previous comment regarding timeframes.

West Wits will engage with Rand Leases soonest to sign-off a settlement

agreement.



for the EIA Report









Ltd


June 2019 by Email


Rand Leases requests the feedback obtained by the EAP on the risk

assessments conducted for servitudes and infrastructure on Rand

Leases properties.

The adjacent commitment should be included within the management

plan. (commitment: West Wits is in agreement that should servitudes

be affected, authorisation will be obtained.)

West Wits will make available the servitude plans in close proximity to

the open pit mining areas.




Ltd


June 2019 by Email


No guarantees have been provided concerning the proposed length

and depth and timelines associated with the proposed Roodepoort

pit. The EAP’s response ignores the request made during the Scoping

phase.

Please refer to Section 3.2 of the EIA Report dated May 2019, where

information has been provided regarding the proposed size, depth and

timeline of the Roodepoort Main Reef Pit. Guarantees can only be

provided as part of the settlement agreement entered into by West

Wits and Rand Leases. West Wits will engage with Rand Leases soonest

to sign-off a settlement agreement.




Ltd


June 2019 by Email


No compaction study has been provided to confirm that compaction

requirements to allow for the future development of the property.

Compaction requirements do not form part of the closure

commitments or costed for within the proposed financial provision.

The EAP’s response ignores the request made during the Scoping

phase.


relevant legislation and the settlement agreement to be entered into by

Rand Leases and West Wits.




Ltd


June 2019 by Email


Appendix S does not even mention Cresswell Park Extension 3. There

is no evidence that it has been considered by the closure specialist.

This response by the EAP is misleading. The original concerns have not

been addressed.

The issue has been noted. Although mention hasn't been made of the

specific names of the various residential, commerical and industrial

developments that are proposed within the mining right application

area, the relevant impacts (including mitigation and monitoring

measures) due to the Roodepoort Main Reef open pit mining area have

been assessed and included in the EIA Report and various specialists.



for the EIA Report









Ltd


June 2019 by Email

11 Shaft Pit Activity

As above, there has to date been no attempt by the applicant to reach

an agreement with the noted parties and therefore there is currently

no lease agreement in place. No effort has been made by the

applicant to amend their 11 shaft pit footprint to avoid the legally

required blasting zone of Maxam Dantex. Rand Leases will not support

mining activities that impact on the existing operations of Maxam

Dantex.

The issue has been noted. It is the intention of West Wits to sign an

agreement with Rand Leases to in turn coexist with their lessees.




Ltd


June 2019 by Email


The EAP must engage with ALL land occupiers currently operating on

Rand Leases land. (Contacts details of land occupiers are available on

request) (changes since Scoping phase):

a. Maxam Dantex

b. EC Incinerator Services (EnviroServ)

c. Much Asphalt

d. B and V Mining and Slabs

e. Isaiah Fuels (Pty) Ltd

f. MRB Designs (pty) Ltd

g. High Flame (Pty) Ltd

h. Q&A Gas (Pty) Ltd

i. Mlilo Projects (Pty) Ltd

The issue has been noted. The contact details of the additional land

occupiers have been requested from Rand Leases. Upon receipt of the

contact details the land occupiers will be engaged with and added to the

I&AP Database for future correspondence.




Ltd


June 2019 by Email


An agreement needs to be in place with each existing tenant holder,

not just Rand Lease and Maxam Dantex. It appears that there has

been no consideration to the existing industrial activities taking place

at the intended 11 shaft pit development area.





for the EIA Report









Ltd


June 2019 by Email




no lease agreement in place. Based on the fact that West Wits have

not even applied for the WUL yet, it is more than likely that the full

extent of the Rand Leases Ext 15 industrial project will be complete

prior to the commencement of mining. See prior

comment on timeframes.






Ltd


June 2019 by Email


No plans have been provided which show existing servitudes on the

Rand Leases property. Rand Leases requests the feedback obtained by

the EAP on the risk assessments conducted for servitudes and

infrastructure on Rand Leases properties.






Ltd


June 2019 by Email


There are many more tenants than just Maxam Dantex. All tenants in

Rand Lease Ext 15 industrial area must be consulted and their

servitudes must not be impacted by the proposed 11 shaft pit.

The issue has been noted. The contact details of the additional land

occupiers have been requested from Rand Leases. Upon receipt of the

contact details the additional land occupiers will be engaged with and

added to the I&AP Database for future correspondence. West Wits will

make available the servitude plans in close proximity to the open pit

mining areas.

It is the intention of West Wits to sign an agreement with Rand Leases

to in turn coexist with their lessees.



for the EIA Report









Ltd


June 2019 by Email


Scoping Phase comment: A critical access road is been mined through

blocking access for Dantex to access the factory site. An alternative

access road (which is similar in distance) need to be planned for and

provided. Uninhibited access from the Dantex

office complete to the factory site must be provided.

EIA phase comment: This specific issue has NOT been addressed (not

even mentioned) in the Traffic specialist report (Appendix O), only the

access to the proposed pit area was assessed. The traffic impact

assessment has a section concerning “land owners concerns

(Appendix E of the report)”, which does not even mention the

adjacent concern raised by Rand Leases.

West Wits is in discussions with Rand Leases, a suitable access road will

be constructed.




Ltd


June 2019 by Email


The impact assessment in Appendix D simply makes a generailised

statement that all impacts have been considered cumulatively.

The impacts are assessed cumulatively where the potential impacts

assessed represent the cumulative impact of the proposed project in

the context of the baseline environment, i.e. with existing impacts

(Appendix D of the EIA Report).




Ltd


June 2019 by Email


No guarantees have been provided concerning the proposed length

and depth and timeline associated with the proposed 11 shaft pit. The

EAP’s does not even consider the request made during the Scoping

phase



timeline of the 11 Shaft Main Reef Pit. Guarantees can only be provided

as part of the settlement agreement entered into by West Wits and

Rand Leases. West Wits will engage with Rand Leases soonest to sign-off

a settlement agreement.




Ltd


June 2019 by Email


No compaction study has been provided to confirm that compaction

requirements to allow for the future development of the property.

Compaction requirements do not form part of the closure

commitments or costed for within the proposed financial provision.

The EAP’s lack of response ignores the request made during the

Scoping phase.






for the EIA Report









Ltd


June 2019 by Email


Appendix S does not even mention Rand Leases Extension 15

Industrial project. There is no evidence that it has been considered by

the closure specialist.




area, the relevant impacts due to the 11 Shaft Main Reef open pit

mining area have been assessed and included in the EIA Report and

various specialists.




Ltd


June 2019 by Email

Kimberley Reef Pit Activity

No unauthorised people (i.e employees associated with the proposed

mine) can operate within the Maxam Dantex blast zone. This needs to

form part of the requested agreement which has not been completed.

It is the intention of West Wits to sign an agreement with Rand Leases

to in turn coexist with their lessees.




Ltd


June 2019 by Email

Kimberley Reef Pit Activity



no lease agreement in place.






Ltd


June 2019 by Email




no lease agreement in place.






Ltd


June 2019 by Email


No stability study undertaken by a rock engineer has been provided.

Stability studies have not been mentioned as a knowledge gap.

Appendix D does not include mitigation measure for potential surface

subsidence. The risk has been made even greater from altering the

depth of mining from 100 m below the surface to now 50 m below the

surface. The EAP is providing a misleading response to the authorities.





for the EIA Report









Ltd


June 2019 by Email


No agreement is in place. It appears that the blasting specialist study

did not take into consideration the impact of the daily blasting

activities by Maxam Dantex on the proposed underground workings.






operation.












underway.




Ltd


June 2019 by Email


Rand Leases has a long term rolling lease with Dantex, and any action

which has an effect to this lease, will be a considerable financial

amount. No agreement is in place. Should the existing lease between

Maxam Dantex and Rand Leases be jepordised in any way by the

proposed mine, Rand Lease will suffer substantial income losses.






Ltd


June 2019 by Email

Bird Reef Central Underground Activity

No evidence has been provided that an assessment of availability of

municipal services within the area has been made.

Ongoing engagement with the City of Johannesburg to provide services

will take place.



for the EIA Report









Ltd


June 2019 by Email

Bird Reef Central Underground Activity

No guarantees have been provided concerning the proposed depth

and extent of the proposed underground mining activities from the

Bird Reef shaft. While the boundary has been amended, the result has

not altered the potential impact on Rand Leases properties.



timeline of the Bird Reef Central Underground workings. Guarantees

can only be provided as part of the settlement agreement entered into

by West Wits and Rand Leases. West Wits will engage with Rand Leases

soonest to sign-off a settlement agreement.




Ltd


June 2019 by Email

A redacted version of the Mine Work Programme has not been

provided to Rand Leases. This information is therefore still

outstanding. Rand Leases still feels inadequately informed concerning

the detail around the various proposed projects associated with the

mining right application.



Leases.




Ltd


June 2019 by Email

No plans showing the servitudes covering Rand Leases properties has

been provided. Rand Leases requires feedback on the risk

assessments conducted for servitudes and infrastructure on Rand

Leases properties.






Ltd


June 2019 by Email

With regards to road access, the EIA report states that “further

investigation and collaboration with the relevant road authority is

required to finalise access routes during the detailed design phase for

the project”.

It is concerning that West Wits is applying to implement various

mining projects which will impact on Rand Leases properties yet,

based on the EIA comment above, they have no completed Details of

access to required services (potable any detailed designs.

All roads and intersections to be used to gain access to and from these

sites are existing roads and intersections (Section 3.2.6 of the EIA Report

dated May 2019).




Ltd


June 2019 by Email

The requested plan showing the proposed depth of underground

mining in relation to the surface has not been provided.


the open pit mining areas. This will be addressed in the settlement

agreement. West Wits is also committed to complete mining in an

appropriate time frame not to delay Rand Leases.



for the EIA Report









Ltd


June 2019 by Email

None of the plans show detail such as servitudes on the properties.

Large plans of the exact mining impact are required by Rand Lease to

fully understand the potential implication on their properties.








Ltd


June 2019 by Email

Due to the number of outstanding authorisations (i.e the WUL

application has not even been submitted) proposed scheduling of the

mining project appears to be unknown to the applicant. Scheduling of

the proposed activities is critical to Rand Leases planning.

This will be addressed in the settlement agreement. West Wits is also


delay Rand Leases.




Ltd


June 2019 by Email

The closure report and associated financial provision calculation

provided in Appendix S does not even mention the Rand Leases

developments (namely Cresswell Park Ext 3 and Industrial Park Ext 15)

let alone consider the requirements of Rand Leases future

developments.





measures) due to the open pit and underground mining areas have

been assessed and included in the EIA Report and various specialist

reports.




Ltd


June 2019 by Email

No specific specialist input has been provided for this particular aspect

(compaction levels). Neither is a commitment to undertake the

required compaction studies for the future development made in the

draft EMP or closure report.







Ltd


June 2019 by Email

No surface subsidence report has been provided. Verbally Rand

Leases was informed that this specialist study was still pending,

however this has not been acknowledged in the EIA report. The EAP

should have acknowledged the lack of the specialist study as a

knowledge gap.





for the EIA Report









Ltd


June 2019 by Email

The Blasting specialist report indicates that if any vibrations are felt on

the surface, they will be too low to cause damage to structures on the

surface. The report does not refer specifically to the possibility of

induced seismic activity due to cumulative blasting effects from

existing surrounding activities such as Maxam Dantex. It also does not

consider the blasting activities taking place on surface (Maxam

Dantex) which may cause underground vibrations and therefore

present risks for underground operations of the proposed project.






operation.












underway.




Ltd


June 2019 by Email

According to the management measures in Appendix D there are no

radiation concerns and no management measures are required.

Yet one of the minerals that West Wits are applying to mine is

uranium ore. Surely this triggers management measures in a

precautionary manner (even if impact assessment suggests low

significance) given the nature of the mineral and the associated

known negative impacts of mining this mineral?

Water monitoring as recommended by the Surface Water and

Groundwater specialists will include uranium as a parameter for

analyses which will be sufficient to cover uranium.

Where uranium levels have been found to be extremely low (with doses

below 10 uSv), the National Nuclear Regulator requires limited

monitoring, but this applies when the operations are bound to the NNR

Act and not the fact that uranium is present. According to the Radiation

specialist (Appendix K) this is not the case for the West Wits Project,

therefore additional monitoring is not needed.



for the EIA Report









Ltd


June 2019 by Email

Based on Section 3.2 of the EIA report, the following is applicable;

Traffic; “further investigation and collaboration with the relevant road

authority is required to finalise access routes during the detailed

designed phase for the project ”.

Power supply; “The operations are expected to require approximately

8.5 MW of power. It is planned to source this power from Eskom. ”

Water; “Potable water will be sourced from the local municipality

during all phases and stored in above ground potable tank(s).

Approximately 50 000 litre of potable water will be required for

domestic use per day. Service water would be sourced from the local

municipality and from treated dewatering water from the

underground workings.”

Sewage: “No sewage treatment plants would be established as part of

the project to treat sewage. The sewage collection and pump stations

would be connected to the municipal bulk sewage treatment

infrastructure .”

There is no evidence that a town planner has been consulted in order

to confirm that the relevant authorities can / has the capacity to

provide power, water and sewage services to the proposed mine.

Ongoing engagement with the City of Johannesburg to provide services

will take place.



for the EIA Report









Ltd


June 2019 by Email

According to page 41 of the EIA report; “A waste water treatment

plant would be required for the project to treat

dewatering from the underground mine. Brine and gypsum would

need to be stored (depending on treatment technology) until it can be

removed by a waste contractor for disposal at a licensed facility.”

Page 55 reconfirms dewatering and treatment is required.

This statement is contradicted on page 49 which essentially indicates

that any water collected underground would be pumped into

historical underground workings / voids. This method of dewatering is

re-confirmed in Appendix D.

These contradictory statements must be explained. Where will the

waste water treatment plant be located?

When reading the statement in its entirety, Page 49 of the EIA report

states that “Dewatering activities might be required to allow for safe

mining operations. Mining will occur above the water table as far as

practically possible. Where dirty water is collected in the underground

workings it will be pumped into historical underground workings/voids.

A water pillar will remain between the project and the historical

underground workings to prevent continuous dirty water from flowing.”

The groundwater study predicts the potential for groundwater inflows

into the underground mine but also states that “depending on whether

structures are intersected underground, this [predicted] volume could

increase or decrease. Therefore these [predicted] volumes should be

used as a guide for planning and management purposes.” The EIA has

made provision for this by including a water treatment plant. The water

treatment plant would be located within the shaft infrastructure

complex.

The acid base accounting and geochemical modelling undertaken by a

specialist have indicated that, due to the absence of iron sulphide

minerals, the risk of the development of acid mine drainage conditions

in the waste rock environment is negligible (see Sections 6.4.1 and 25 of

the EIA Report). Potential groundwater impacts have been assessed

using analysis of materials and scientific quantitative modelling to

understand and predict the potential contamination risk.




Ltd


June 2019 by Email

The Blasting specialist report indicates that no blasting will be

required for any of the open pit operations. Only Xcentric rippers will

be used. It is therefore expected that no blasting will be undertaken

for the proposed open pit operations.

The comment has been noted.



for the EIA Report









Ltd


June 2019 by Email

A request for coordinates demarcating the outline of the pits was

requested, not the center coordinates. The information requested

must be provided to Rand Leases without delay so that the exact

extent of the pits can be mapped for Rand Leases consideration.

The extents of the open pits will form part of the settlement

agreements to be entered into by Rand Leases and West Wits.




Ltd


June 2019 by Email

No agreement is in place. Rand Leases will experience substaintial

losses should this mining project proceed without the necessary

agreements being in place before mining commences.

Based on the information provided in the EIA report and the fact that

no effort has been made by West Wits to reach an agreement, Rand

Leases strongly object to the application and possible granting of the

environmental authorisation.

Various meetings have taken place between Rand Leases and West

Wits, and West Wits endeavours to sign a settlement agreement with





Ltd


June 2019 by Email

No restriction / objection on any application to facilitate future

developmental activities by the mine. No agreement is in place.

Various meetings have taken place between Rand Leases and West

Wits, and West Wits endeavours to sign a settlement agreement with





Ltd


June 2019 by Email

Table 6.4.2 which describes the surrounding land uses to the various

projects does not even mention Maxam Dantex explosive testing

which will be impacted by the 11 shaft open cast pit and the

Kimberley East pit and underground activities.

The EAP has failed to accurately reflect the surrounding landusers and

occupiers based on information provided during the Scoping phase.





measures) due to the open pit and underground mining areas have

been assessed and included in the EIA Report and various specialist

reports.




Ltd


June 2019 by Email

The Heritage specialist study identified 24 heritage sites, 18 of which

are within the project footprint. The report provides alternative layout

options and yet these have not been considered in the draft EIAr.

The alternatives included in the Heritage Specialist report were based

on the alternatives as identified, considered and discussed in Section 6.1

of the Scoping Report dated August 2018.




Ltd


June 2019 by Email

The Groundwater specialist study indicates that there is a negligible

risk of AMD. This is expected to be monitored should mining

commence to ensure there is in fact no risk.

The comment has been noted.



for the EIA Report









Ltd


June 2019 by Email

Storm water management plans for each proposed open pit have

been developed and are included in the Surface Water specialist

study. Some of the design principles are included in the specialist

report (but not captured within the EIA report or Appendix D)

include;

“At the open cast mining pits, the stormwater is collected in a sump

mixing with groundwater ingress into the pit and will be dewatered /

pumped to a PCD and then through a water treatment plant before

reuse or discharge. ”

“In addition to the PCD’s, a series of water treatment plants are

proposed which will treat water pumped out of the shafts and pits

prior to the commencing of mining and during mining and reused with

the stormwater.. ”

The recomendations from the specialist study should be included

within the EIA report and associated management measures. There is

no evidence that post closure stormwater requirements have been

considered for the proposed open cast operations.

Stormwater management and design principles has been included in

Section 3.2 of the EIA Report dated May 2019.

The post closure stormwater management will be dependent on the

end land use requirements as stated in the settlement agreements.




Ltd


June 2019 by Email

Radiation specialist study indicates that associated risks are very low

where all the individual radionuclide activity concentrations for all the

samples were well below the regulatory limit which means that the

proposed operation does not fall under the NNR Act. Rand Leases still

feels that some sort of precautionary monitoring should be

implemented to ensure that this risk does in fact not develop during

mining given the future intended land use of residential and industrial.












for the EIA Report









Ltd


June 2019 by Email

The detail provided in Section 3.2.15 is as follows;

“Perimeter fencing is planned around the two infrastructure

complexes. These fences would be maintained for the duration of the

project. Access control and a security office would be established at

the entrance to each of the infrastructure complexes. Between 1 and

1.5 m high safety berms would be placed arounf the perimeter of the

open pit mining areas .”

A safety berm around the open pits will not control trespassing. A full

security management plan is required.

The issue has been noted.




Ltd


June 2019 by Email

It is assumed that given the advanced stage of the application the

waste management procedure would have already been developed

and included within the draft EIA report. This is an aspect that I&AP,

especially landowners need to be able to comment on.

Waste management and other procedures will be developed during the

project phase which is normal practice.




Ltd


June 2019 by Email

Section 25.8 includes “A water use license is required for the proposed

project. The DWS has been notified that a water use license

application will be submitted as part of the proposed project. In this

regard a copy of the notice of intent letter submitted to the DWS in

included in Appendix E .” Appendix E

provided for review is a soil and land use capacity assessment and

does not have any reference to informing DWS of the water use

license application. Please indicate where this information is in fact

presented.

Refer to Appendix B of the EIA Report dated July 2019 for a copy of the

notice of intent letter submitted to the DWS.




Ltd


June 2019 by Email

Currently the draft EIA report notes the following concerning

knowledge gaps in Section 14; “Assumptions, uncertainties and

limitations have been discussed throughout the EIA and EMPr. Specific

reference to these are included in the specialist reports attached as

appendicies”. Knowledge gaps should be summerised within the EIA

report so that I&AP reviewing the report don’t have to go searching

for them through numerous lengthy specialist reports.

All the assumptions, uncertainties and limitations provided in the

specialist reports have been considered during the assessment of the

environmental impact assessment as included in the EIA Report.



for the EIA Report









Ltd


June 2019 by Email

Rand Leases highlights the following knowledge gaps;

- The lack of detailed designs of the proposed stormwater

management measures, including the lack of knowledge concerning

hydraulic gradients and channel sizes required to manage stormwater

and the specifications for the lining of channels and the PCD’s.

- The lack of understanding of groundwater that will be encounted by

the underground mining activities and the potential need for

dewatering and a water treatment plant. This is highlighted by the

following comments contained in Section 10.4.3 the groundwater

specialist report;

The issues have been noted. These are requirements that will be fulfilled

as part of the Water Use License Application (WULA).




Ltd


June 2019 by Email

The following information (which was requested by Rand Leases

during the Scoping phase) has not even been mentioned as

knowledge gaps;

- Compaction requirements for the pits to facilitate future

development

- Subsidence potential / mine induced siemicity potential from

underground mining activities

- Town planning input to determine whether the Municipality has the

capacity to offer the services (potable water, electricity, sewage

connection, road infrastructure) required for the proposed project.

- West Wits commits to rehabilitate the area in accordance with the



- West Wits endeavour to have a settlement agreements in place with


- Ongoing engagement with the City of Johannesburg to provide

services will take place.




Ltd


June 2019 by Email

Section 6.1.3 of the draft EIAr does not consider / discuss the

alternative layout options presented within the Heritage specialist

reports.

The alternatives included in the Heritage Specialist report were based

on the alternatives as identified, considered and discussed in Section 6.1

of the Scoping Report dated August 2018.



for the EIA Report









Ltd


June 2019 by Email

The following concerns are noted with the Geochemical Assessment

for the proposed project (Appendix H)

- The waste rock has been assessed as a Type 3 waste, thus requiring a

Class C engineered barrier system, yet the author of the study and the

EAP both motivate that the waste rock is reclassified as Type 4, which

is inert and therefore not requiring a liner. Rand Leases believe the

authorities should uphold and impose the legal requirements for a

Type 3 waste to be

precautionary given the future intended land uses for the area.

Although the Geochemistry specialist has recommended that the waste

material class be reduced to a Class D barrier system (stripping topsoil

and base preparation) due to the stability of the waste rock material as

well as the negligible risk of the formation of acid mine drainage

conditions, this is subject to approval by the Competent Authority.




Ltd


June 2019 by Email

The following concerns are noted with the Geochemical Assessment

for the proposed project (Appendix H)

- It is noted that the analysis of the waste rock for 11 shaft (Table 2.2

of the Geochemical report) and the waste rock at Mona Liza (Tabe 2.6)

is exactly the same. This is repeated for Roodepoort waste rock

presented in Table 2.8 and the Rugby Club waste rock presented in

Table 3.2. It is highly unlikely that the results would be identicial. If this

is in fact an error then it presents serious doubt around the credibility

of the report as provided.

The results of the waste rock sample analyses are exactly the same due

to samples that were taken from the proposed 11 Shaft and Mona Lisa

open pit mining areas, and the proposed Roodepoort and Rugbly Club

open pit mining areas which would be located on the same reef

horizons respectively.




Ltd


June 2019 by Email

A number of the specialist reports don’t consider the concerns raised

by Rand Leases, such as the traffic assessment and the socio-economic

assessment, which in turn have not been addressed in the draft EIAr.

This is deemed unacceptable by Rand Leases as a directly affected

landowner.


agreement in order to address many of the concerns raised by Rand

Leases.




Ltd


June 2019 by Email

While verbally it has been confirmed that West Wits has reached

“settlement agreements” with other affected parties, no agreement

has been reached with Rand Leases. There has been no effort on

behalf of West Wits to even try and accommodate Rand Leases.


agreement.




Ltd


June 2019 by Email

It is clear that the critical concerns around the Maxam Dantex

(blasting zone, access road from the office to the factory site, security

requirements etc) have not been considered.


be constructed. West Wits will engage with Rand Leases soonest to sign-

off a settlement agreement.



for the EIA Report









Ltd


June 2019 by Email

There is no evidence that other current industrial occupiers of Rand

Leases land have had meaniful input into the proposed mining

operation.


agreement with Rand Leases to in turn coexist with their lessees. The

I&AP Database have been updated with the contact details of the land

occupiers received from Rand Leases. The additional contact details of

the land occupiers recently received from Rand Leases have been added

to the database for future correspondence, and the land occupiers will

be engaged with.




Ltd


June 2019 by Email

Many of the concerns raised by Rand Leases during the Scoping Phase

have not been considered and the EAPs response in the comment and

response section of the draft EIAr is inadequate, or in some cases

blatantly wrong.


agreement in order to address many of the concerns raised by Rand

Leases.




Ltd


June 2019 by Email

Information which has been requested (on many occasions) has not

been provided. It is not possible for Rand Leases to fully participate in

the environmental application process when critical information is not

being provided such as (but not limited to);

- mine works programme,

- detailed scheduling of the various mining projects,

- plans showing the depth of intended underground mining,

- plans showing existing pipes and services which may be impacted by

open pits

- A redacted version of the Mining Work Programme will be supplied

for these areas, and the technical team will continue to engage with

Rand Leases.

- Please refer to Section 3.2 of the EIA Report dated May 2019, where


timeline of the various open pit and underground workings.

- This will be addressed in the settlement agreement. West Wits is also


delay Rand Leases.

- West Wits will make available the servitude plans in close proximity to







Ltd


June 2019 by Email

It is clear from the EIA report and various specialist studies (traffic,

surface water, groundwater), that detailed design work has not been

completed and there are numerous knowledge gaps, yet the project is

close to a point where a decision will be made on whether it is

authorised or not.

Detailed design work will follow during the WULA and project

implementation phase.



for the EIA Report









Ltd


June 2019 by Email

Based on the current status of the application and the fact that a

water use license application has yet to be submitted, it is highly

unlikely that this project will ready to commence prior to the

development of Creswell Park Extension 3 and the Rand Leases

Industrial Project Ext 15. The lease / compensation agreement in this

regard therefore needs to be in place before any mining

authorisations are authorised.

The issue has been noted. This will be addressed in the settlement


appropriate time frame not to delay Rand Leases. It is the intention of

West Wits to sign an agreement with Rand Leases to in turn coexist with

their lessees.




Ltd


June 2019 by Email

It is extremely concerning that a change of proposed minimum mining

depth from 100m (as indicated in the Scoping report) to 50m as

indicated in the EIA report is not highlighted in Section 19.2 which

covers deviations from the Scoping report.

Please refer to Section 19.2 of the EIA Report dated July 2019.




Ltd


June 2019 by Email

Over 23 documents were provided to I&AP for review. To expect an

I&AP to provide effective feedback within a 30 day period is

unrealistic. An email requesting additional time for Rand Leases to

provide feedback has gone unanswered by the EAP.




Mariette Liefferink - CEO:

FEDERATION FOR A

SUSTAINABLE ENVIRONMENT

X E-mail received on 22 May

2019

As you may recollect, I, on behalf of the FSE, have engaged on a

number of occasions with Messrs Michael Quinert and Eddie Milne

regarding this project. I have also submitted a number of e-mails

regarding the project. I attach some of these hereto. None of these

comments were included in the Issues and Response Table. May I

kindly request the reason why?

Your comments and issues have been addressed in the Environmental

Impact Assessment and Environmental Management Programme

although these are not reflected in the Issues and Response (IRR) table.

The IRR table included in the draft EIA Report only reflected those

comments that were received post re-submission of the application to

the Department of Mineral Resources.

We will however send through to you specific responses to your

comments indicating how your comments have been addressed in the

report. Once you’ve received this and had a chance to look through it

we would gladly meet with you to discuss any aspects. We will aim to

get the specific responses to your comments during the course of next

week.



for the EIA Report







FEDERATION FOR A



2019

The proposed open cast mining falls within a vulnerable eco system

area with numerous wetlands (National Freshwater Ecosystem Priority

Areas (NFEPA)) and within endangered grassland vegetation areas.

The NEM:BA and Mining and Biodiversity Guideline are of relevance in

this regard.

These legislation on biodiversity have been considered in the EIA Report

(Sections 4 and 6.4.1.5) and by the Biodiversity specialist (Appendix G).




FEDERATION FOR A



2019

The life of mine for the open cast mining is 5 years and for the

Kimberley and Creswell open cast mining the life of mine will be 2

years. The post closure socio-economic and environmental costs (the

near certainty of contaminated water; sulphate, metal and NORM

contamination of soils and sediments; the concomitant loss of

genetic/biodiversity and potentially ecosystem goods and services on

disturbed, fragmented and polluted properties; the potential for

bioaccumulation of some metals and NORMs by flora and fauna and

the potential for exposure of fauna and humans to bio-accumulated

pollutants) must be assessed to motivate the economic and

environmental sustainability of the project and to determine the

financial provisions.

The motivation for the application is, according to the BID “depending

on the price and profitability the project will allow for the generation

of jobs.” We request that the motivation be assessed in accordance

with the Best Practicable Environmental Option (BPEO) principle of the

NEMA and the 2015 National Environmental Management Act

(107/1998): Regulations pertaining to the Financial Provision for

Prospecting, Exploration, Mining or Production Operations which

dictate that:

5. An applicant or holder of right or permit must make financial

provision for—

(a) rehabilitation and remediation;

(b) decommissioning and closure activities at the end of prospecting,

exploration, mining or production operations; and

(c) remediation and management of latent or residual environmental

impacts which may






for the EIA Report







FEDERATION FOR A



2019

There is no reference made to an application for a Certificate of

Registration (CoR) in terms of the National Nuclear Regulator Act (47

of 1999) in the BID. This is a serious omission since it is common

cause that the gold ore in the West Rand co-occurs with uranium and

its progeny.

Additional permits or licenses that may be required for the project

include a Certificate of registration or exemption in terms of the

National Nuclear Regulator Act, 1999 (No. 47 of 1999) (NNR) for the

handling and management of gold and uranium containing material as

identified in the Introduction to the EIA Report.


FEDERATION FOR A



2019

The BID proposes that once mined areas are rehabilitated and

stabilised it will be made available for housing development and

agricultural purposes. Residential townships, edible crop production

and livestock grazing are considered high risk land uses for these areas

and areas within the aqueous and aerial zone of influence. These

proposed land uses are incompatible with the safety and fragile status

of lands under rehabilitation and could exacerbate the liabilities for

mining and the State post closure. We also advise that mined areas

are required in terms of the EIA Regulations to be rehabilitated to a

natural or predetermined state or to a land use which conforms to the

generally accepted principle of sustainable development.

The environmental objective for closure is to minimise the impacts

associated with the closure and decommissioning of the mine and to

restore the land to a useful land use not dissimilar to the pre-mining

land use. With regards to the open pit, the post-closure land use has

been informed through discussions and agreement with the relevant

landowners (see Section 28 of the EIA report).

It should be noted that information presented in the EIA Report

supersedes information presented in the BID, given that the EIA has

been informed by specialist studies and public participation.



for the EIA Report







FEDERATION FOR A



2019

The open pit operations are in very close proximity (a few meters) to

Bram Fischerville and Sol Plaatjies communities. I understand from

our discussions that West Wits Mining is operating on behalf of the

land owner who was issued with a directive from the Department of

Mineral Resources to close and seal the open shafts in order to

prevent unlawful mining. This resulted in the open pits. In the

process West Wits Mining is mining the gold from the exposed reef. I

rest confident you will draw the correct inference regarding the risks

of these open pit mining activities in close proximity to communities

and the foreseen hostility of these communities.

I was invited to present to the Government Task Team (GTT) on

Mining and Water on the 19th of April. During the presentation the

Chairperson of the GTT, Mr Max Madubane confirmed that the DMR

issues directives to mining companies to close and seal these open

shafts in order to curtail the unregulated mining activities and at the

same time to allow mining companies to mine the outcrop to cover

their costs. As you may recall, Mintails has done exactly what West

Wits Mining is currently doing and lamentably left us with

unrehabilitated open pits, which were not backfilled, with no access

control, no erosion or stormwater control, unvegetated and eroding

overburden, etc. Mintails is now in business rescue with

environmental liabilities of R336.5 million and a rehabilitation fund of

between R17 and R25 million. Its life of mine is until 2020.

[Powerpoint presentation which adduces sufficient evidence of the

deplorable situation was attached to the comments and is included in

Appendix D].

In view of the aforesaid and in order to ripen our judgement regarding





FEDERATION FOR A



2019

The numerous open pits in the West Rand Goldfield have been

identified as a source of ingress of acid mine water, by a study

commissioned by the mining industry estimating that they contribute

approximately 30% of the total ingress. It can therefore be logically

inferred that the pits created by the proposed open cast mining will

contribute significantly to the ingress of acid mine water into the West

Rand Basin/Void.

The acid base accounting and geochemical modelling have indicated

that due to the absence of iron sulphide minerals the risk of the

development of acid mine drainage conditions in the waste rock

environment is negligible.



for the EIA Report







FEDERATION FOR A



2019

The open pits and underground voids will be backfilled with waste

rock. The EIA must address the acid producing potential of the waste

rock and impact on groundwater since the waste rock contains large

inventories of pyritic material.


FEDERATION FOR A



2019

The open pit operations are in very close proximity (a few meters) to

Bram Fischerville and Sol Plaatjies communities. I understand from

our discussions that West Wits Mining is operating on behalf of the

land owner who was issued with a directive from the Department of

Mineral Resources to close and seal the open shafts in order to

prevent unlawful mining. This resulted in the open pits. In the

process West Wits Mining is mining the gold from the exposed reef. I

rest confident you will draw the correct inference regarding the risks

of these open pit mining activities in close proximity to communities

and the foreseen hostility of these communities.

I was invited to present to the Government Task Team (GTT) on

Mining and Water on the 19th of April. During the presentation the

Chairperson of the GTT, Mr Max Madubane confirmed that the DMR

issues directives to mining companies to close and seal these open

shafts in order to curtail the unregulated mining activities and at the

same time to allow mining companies to mine the outcrop to cover

their costs.

As you may recall, Mintails has done exactly what West Wits Mining is

currently doing and lamentably left us with unrehabilitated open pits,

which were not backfilled, with no access control, no erosion or

stormwater control, unvegetated and eroding overburden, etc.

Mintails is now in business rescue with environmental liabilities of

R336.5 million and a rehabilitation fund of between R17 and R25

million. Its life of mine is until 2020. See attached powerpoint

presentation which adduces sufficient evidence of the deplorable

situation.






for the EIA Report







FEDERATION FOR A



2019

May we kindly request:

1. To be involved in the project’s public participation process as

registered interested and affected

party and as key stakeholder in the West Rand gold fields;

The FSE was registered as I&APs on the West Wits project database and

will be included in future correspondence regarding the regulatory

process. Please refer to Appendix B of the EIA Report for a copy of the

I&AP Database.


FEDERATION FOR A



2019

May we kindly request:

2. A copy of your rehabilitation plan for the open pits where you are

currently mining;

3. A copy of the Environmental Management Plan/Programme Report

for the open pits where you are currently mining or alternatively for a

copy of the Directive of the Department of Mineral Resources;

4. Your rehabilitation funds for the open pits operations.





FEDERATION FOR A



2019

We were informed that West Wits MLI (Pty) Ltd (West Wits)

appointed Malan Scholes Consulting (Pty) Ltd (MSC) to facilitate the

necessary regulatory processes that are required to form part of two

(2) Mining Permit Applications and one (1) Mining Right Application.

Please clarify the relationship of Hulme Scholes to Malan Scholes

Consulting and whether there may be a conflict of interest.

Details on the applicant have been discussed in Section 1.1 of the EIA

Report.


FEDERATION FOR A



2019

Will the footprints of the ore stockpiles and waste rock dumps be

lined to prevent acid rock drainage and will the footprints be

rehabilitated to a sustainable future land use since the secondary

source of contaminants remain in the soil after a rock dump has been

removed.

It should also be noted that there may be residual radioactivity in the

footprints after the rock dumps have been removed since the gold ore

co-occurs with uranium.




in the waste rock environment is negligible. Based on the waste

classification of the material, the specialist has recommended a Class D

barrier system due to the stability of the waste rock material as well as

the negligible risk of the formation of acid mine drainage conditions (see

Sections 6.4.1 and 25 of the EIA report).



for the EIA Report







FEDERATION FOR A



2019

The open pits and underground workings will be exposed to the inflow

of extraneous water. Waste rocks have very large inventories of fine

pyritic material and waste rock is permeable to oxygen. Backfilling the

open pits with waste rock containing acid producing minerals and

metals will result in the formation of Acid Rock/Mine Drainage (AMD).

It is widely accepted that the waste from gold mines constitutes the

largest single source of waste and pollution in South Africa. AMD is

responsible for the most costly environmental and socio-economic

impacts. Production of AMD may continue for many years after mines

are closed and tailings dams decommissioned. AMD is not only

associated with surface and groundwater pollution, degradation of

soil quality, for harming aquatic sediments and fauna, and for allowing

heavy metals to seep into the environment but long-term exposure to

AMD polluted drinking water may lead to increased rates of cancer,

decreased cognitive function and appearance of skin lesions. Heavy

metals in drinking water could compromise the neural development

of the fetus, which can result in mental retardation.

In view of the aforesaid, it is necessary for the Applicant to determine

the status of the geo-hydrological regime, the extent of

contamination, preferential pathways and predictions regarding long

– term migration in order to manage and mitigate the

containment/rehabilitation of contaminated groundwater.

The potential impact on the groundwater from other surface

contaminant sources such as the metallurgical plants, domestic and

industrial waste sites must be described and assessed.







for the EIA Report







FEDERATION FOR A



2019

Gold mines are characterized in terms of the DWS’ Mine Water

Management Policy as “Category A” mines because of their acid

producing potential.

The numerous open pits in the West Rand Goldfield have been

identified as a source of ingress, by a study commissioned by the

mining industry estimating that they contribute approximately 30% of

the total ingress of acid mine water. (Ref. DME. RMCS for the West

Rand Goldfield. 2008)

It can logically be inferred that these proposed open pits will generate

acid mine water in the short, medium and long term.

It is necessary for the Applicant to demonstrate the adequacy of its

financial provision to, in terms of the 2015 Regulations pertaining to

the Financial Provisions for Prospecting, Exploration, Mining or

Production operations, remedy and manage its operations’ latent

and residual environmental impacts which will become known in the

future including the pumping and treatment of polluted or extraneous

water.

It is necessary for the Applicant to determine the treatment it

proposes for polluted water in the short, medium and long term (and

disclose it in its EMPR) since there is the near certainty that the water

will be acidic with high sulphate values, and a broad spectrum of

metals in toxic concentrations, including radioactive metals such as

uranium.

In terms of the proposed Regulations pertaining to the Financial

Provisions for Prospecting, Exploration, Mining or Production

Operations a financial guarantee cannot be used for residual impacts.

Progressive or concurrent rehabilitation must take place and such







for the EIA Report







FEDERATION FOR A



2019

Since it common cause that the deposits, which will be mined include

uranium, the following facts have relevance:

• Uranium is both chemically toxic and radioactive.

• There is the near certainty that the open pit- and underground

mining will introduce risks not only limited to the physical dangers

inherent to mining sites but risks of:

- direct external gamma radiation,

- inhalation and ingestion of radionuclides and chemotoxic

metals

• The major primary pathways by which contamination can enter the

environment from a mine site have been identified :

- the airborne pathway, where radon gas and windblown dust

disperse outwards from mine sites,

- the waterborne pathway, either via ground or surface water or

due to direct access, where people are contaminated,

- or externally irradiated after unauthorized entry to a mine

site,

- by living in settlements directly adjacent to mines or in some

cases, living in settlements on the contaminated footprints of

abandoned mines.

These findings are supported by the National Nuclear Regulator.

According to the National Nuclear Regulator significant radiation

exposure can occur in the surroundings of mining legacies, due to:

• Inhalation of Rn-222 daughter nuclides from radon emissions of

desiccated water storage dams and slimes dams.

• The inhalation of contaminated dust generated by wind erosion

from these objects, and




the EIA Report.

Radiation is a product of the processing of the ore and any radiation will

only be in the tailings. Primary mineral processing will take place on site,

where ore will be crushed prior to transportation off-site. All run-of

mine material will be transported to an existing off-site processing plant

including a tailings facility for concentrating of minerals.












for the EIA Report







FEDERATION FOR A



2019

The impact of the blasting on the structural integrity of low cost and

informal housing and on the “wellbeing” (nuisance factor) of the

communities must be determined and disclosed to the affected

communities.





The impact of blasting and vibration is considered to be of negligible

significance, given the increasing depth of the mining activity and the

small charge masses being fired at any one time. It is therefore highly

unlikely that any disturbances would be felt by surface receptors around

the mining right application area.


FEDERATION FOR A



2019

The dewatering and subsequent re-watering may result in the

acceleration of sinkholes and seismicity. The project is in very close

proximity to densely populated residential townships, such as Sol

Plaatjies and Bram Fischerville.

The area has undergone historical dewatering due to mining and

sinkhole formation occur due to water movement through weathered

strata, usually the top 20-40 m below surface. The water level is well

below this in the fractured rock aquifer (in excess of 100 m below

surface) and the weathered aquifer is still functioning (i.e. shallow

recorded water levels). This will not be affected by the underground

mining.

The regional Malmani Dolomites is roughly 7.5 km south of the nearest

proposed underground mine (Central), however, a pocket of dolomite is

located closer at roughly 1.5km.

None of the proposed open pits and associated zone of influences reach

the dolomitic units.



for the EIA Report







FEDERATION FOR A



2019

The subsequent re-watering may result in the flooding of the

underground workings and acid mine drainage. The impacts may

increase when mining operations cease. Proper quantitative

assessments must be conducted to assess these impacts as well as the

extent of contaminant plumes.

When reading the statement in its entirety, Page 49 of the EIA report

states that “Dewatering activities might be required to allow for safe

mining operations. Mining will occur above the water table as far as

practically possible. Where dirty water is collected in the underground

workings it will be pumped into historical underground workings/voids.

A water pillar will remain between the project and the historical

underground workings to prevent continuous dirty water from flowing.”

The groundwater study predicts the potential for groundwater inflows

into the underground mine but also states that “depending on whether

structures are intersected underground, this [predicted] volume could

increase or decrease. Therefore these [predicted] volumes should be

used as a guide for planning and management purposes.” The EIA has

made provision for this by including a water treatment plant. The water

treatment plant would be located within the shaft infrastructure

complex.




in the waste rock environment is negligible (see Sections 6.4.1 and 25 of

the EIA Report). Potential groundwater impacts have been assessed

using analysis of materials and scientific quantitative modelling to

understand and predict the potential contamination risk.


FEDERATION FOR A



2019

If the project is authorised, we appeal to the authorities to write a

biodiversity offset into the environmental authorisation regarding this

impact. (The operations will involve the removal of peat soils.)


specialist (Appendix G). Relevant impacts including mitigation and


the EIA Report.



for the EIA Report







FEDERATION FOR A



2019

How will the brine be disposed of? Brine and gypsum generated by the wastewater treatment plant would

need to be stored until it can be removed by a reputable waste

contractor on a regular basis for disposal at a licensed facility (e.g. Marie

Louise Waste Disposal Site; and Holfontein Disposal Site for hazardous

waste) (Section 3.2.12 of the EIA Report).


FEDERATION FOR A



2019

In terms of the Regulations on Use of Water for Mining an Related

Activities aimed at the Protection of Water Resources (GN704 of 4

June 1999): “Every person in control of a mine or activity must cause

any impoundment or dam containing poisonous, toxic or injurious

substance to be effectively fenced-off so as to restrict access thereto,

and must erect warning notice boards at prominent locations so as to

warn persons of the hazardous contents thereof ”. Fencing of the

infrastructure complexes does not comply with the above regulations

and merely protects the interests of the Applicant. It does not ensure

the safety of nearby communities, in particular vulnerable persons

such as the children.

As outlined in the EMPr, to address safety risks to third parties, security

control measures in the form of manned access points, fencing, barriers

and/or warning signs (in appropriate languages or illustrations) would

be established to keep people and animals away from mining and

infrastructure areas. Dams are considered as part of the mining

infrastructure (see Appendix D, Issue 20).


FEDERATION FOR A



2019

In terms of the principles of the National Environmental Management

Act (107 of 1998) (NEMA), it is necessary for the Applicant to argue

whether the project is the Best Practicable Environmental Option

(BPEO).

The NEMA have been considered throughout the EIA Report.



for the EIA Report







FEDERATION FOR A



2019

According to the Mining and Biodiversity Guideline the importance of

the biodiversity features in these areas and the associated ecosystem

services is sufficiently high to prohibit mining in these areas. Given the

very high biodiversity importance, the Guideline states that an EIA

conducted in respect of such an area should include the strategic

assessment of optimum, sustainable land-use for a particular area

which should determine the significance of the impact on biodiversity.

The EIA must take into account the environmental sensitivity of the

area, the overall environmental and socio-economic costs and

benefits of mining as well as the potential strategic importance of the

minerals to the country.

The Guideline states that the EIA “needs to identify whether mining is

the optimal land use, whether it is in the national interest for that

deposit to the mined in that area and whether the significance of

unavoidable impacts on biodiversity are justified. It is important that a

risk averse and cautious approach is adopted. This implies strongly

avoiding these biodiversity priority areas, given the importance of the

receiving environment and the probability that the proposed activity

would have significant negative impacts”.

The Mining and Biodiversity Guideline has been considered in the EIA

Report (Sections 4 and 6.4.1.5) and by the Biodiversity specialist

(Appendix G). Relevant impacts including mitigation and monitoring


Report.

The potential mitigated impacts on the biophysical environment

including physical destruction and general disturbance of biodiversity

are assessed to range between low to medium significance.

Where the project aligns its timeline to support post-closure housing

and other property development the economic benefits of both the

mining and alternative land use can be realised.

Thus, assuming the effectively implementation of the project mitigation

in the EMP, the assessed impact significance levels are not such that

they should stop the project proceeding.



for the EIA Report







FEDERATION FOR A



2019

When considering mining these biodiversity priority areas, the

Guideline prescribes a set of filters that should be sequentially applied

and "mining should only be considered if:

a. It can be clearly shown that the biodiversity priority area coincides

with mineral or petroleum reserves that are strategically in the

national interest to exploit.

b. There are no alternative deposits or reserves that could be

exploited in areas that are not biodiversity priority areas or less

environmentally sensitive areas.

c. It can be demonstrated that they are spatial options in the

landscape that could provide substitute areas of the same habitat

conservation, to ensure that biodiversity targets would be met.

d. A full economic evaluation of mining compared with other

reasonable/feasible alternative land uses, undertaken as a necessary

component of the EIA, shows that mining would be the optimum

sustainable land use in the proposed area.

e. A detailed assessment and evaluation of the potential direct,

indirect and cumulative impacts of mining on biodiversity and

ecosystem services shows that there would be no irreplaceable loss or

irreversible deterioration, and that minimising, rehabilitating, and

offsetting or fully compensating for probable residual impacts would

be feasible and assured, taking into account associated risks and time

lags.

f. A risk averse and cautious approach, taking into account the limits of

current knowledge about the consequences of decisions and actions,

can be demonstrated both in the assessment and evaluation of

environmental impacts, and in the design of proposed mitigation and





Report.












for the EIA Report







FEDERATION FOR A



2019

The Guideline states further that:

“The above filters should form the basis for deciding on whether or

not, and how and where, to permit mining. This means that based on

the significance of the impact, some authorisations may well not be

granted. If granted, authorisation may set limits on allowed activities

and impacts, and may specify biodiversity offsets that would be

written into licence agreements and/or authorisations”.

The EIA/EMP must be compiled so as to give effect to the Guideline

and the decision makers must consider the Guideline in deciding

whether or not to grant environmental authorisation.

This includes an assessment of the opportunity costs, e.g.:

o Understanding the value of the foregone opportunity;

o The achievement of the desired aim/goal for the specific area;

o Optimising of positive impacts;

o Minimising of negative impacts;

o Equitable distribution of impacts; and

o The maintenance of ecological integrity and environmental quality.





Report.












for the EIA Report







FEDERATION FOR A



2019

Applying the “opportunity cost” principle would change the question

being asked, namely, by placing a positive duty upon the decision

maker to consider if the proposed development will constitute the

best use of the resources (i.e. the best practicable environmental

option).

It is our submission that the BPEO for the area is not for open pit or

underground mining but for the responsible reclamation of the

historic tailings storage facilities (TSFs), the consolidation of the waste

in a lined engineered regional tailing storage facility and the

rehabilitation of the footprints of the reclaimed TSFs in order to

reduce the risks and hazards to the nearby communities and to future

generations.

We furthermore do not understand the economic viability of the

project since major gold mining companies are closing or are in

decline or are not profitable.





Report.











FEDERATION FOR A



2019

It is widely accepted that mining has profound often irreversible

impacts on ecosystems.

The rivers draining gold mining areas and the associated wetlands are

an area of significant concern. Elements of concern are Al, Cr, Cu, Bi,

Sr, Sb, Au, Hg, Pb, and U.

The proposed project will impact upon the said wetlands and it is

necessary to assess the cumulative impacts of the historic gold mining

activities and the proposed project on the Klip River and the

numerous wetlands.

The functionality of these wetlands to adsorb metals may be

compromised/exceeded by the added contaminant load from the

proposed project. It may well result in the mobilisation (and

solubilation if metals if the water becomes acidic) of metals which are

currently adsorbed in the sediment of the wetlands.

The above foreseeable impacts must be assessed. We furthermore

request that the authorities specify wetland offsets that should be

written into the environmental authorisation.


and Hydrological specialists (Appendix F and Appendix G). Relevant



The valley bottom wetlands and pans within the mining right application

area are considered by the biodiversity specialist to be of intermediate

sensitivity. However, the watercourses (including wetlands) within 500

m of proposed mine infrastructure will be monitored to determine

whether contamination is leaching from the mine infrastructure. Should

contamination be detected, the mine will implement additional

management and mitigation measures to prevent further contamination

and attempt to remedy the contamination. This may include the

installation of interception boreholes to remove and treat contaminated

water.



for the EIA Report







FEDERATION FOR A



2019

The de-watering and re-watering envisioned by the project may

accelerate sinkhole formations and seismicity.

AMD is an additional risk since it may result in the increased

dissolution of dolomite which could lead to land subsidence in the

area, which is densely populated.

The impact of the de-watering and re-watering on the ground stability

and structural integrity of the houses of nearby communities must be

assessed.

A stability study will be conducted by the applicant.


FEDERATION FOR A



2019

The failure of pipelines carrying polluted water and potentially

radioactive and toxic slurry is a significant risk since these pipelines

traverse wetlands and are in close proximity to the Klip River and

densely populated communities.

Pipeline spillages must be prevented. The pipeline integrity and

design must be in accordance with the ASME B31.4 code. See

attached expert opinion from Paterson and Cooke Consulting

Engineers regarding Best Practices of Pipeline Wetland Crossings.

We call upon the decision makers to impose these best practices upon

the Applicant.

This issue has been noted and has been considered by the Hydrological

specialist (Appendix G). Regular inspections and maintenance will be

conducted of water management facilities, to inspect drainage

structures and liners for any in-channel erosion or cracks, de-silting of

silt traps/sumps and pollution control dams, and any pumps and

pipelines will be maintained according to manufacturer’s specifications;


FEDERATION FOR A



2019

The site where the hazardous substances will be stored Hazardous waste substance would be stored in designated containers

and skips in bunded work areas at the waste yards located within the

Bird Reef Central and Kimberley Reef East Infrastructure Complexes

(Figure 3-8 and 3-9 of the EIA Report).


FEDERATION FOR A



2019

The site where the sewage management facilities will be located No sewage treatment plants would be established as part of the project

to treat sewage. The sewage collection and pump stations would be

connected to the municipal bulk sewage treatment infrastructure

(Section 3.2.12 of the EIA Report). The sewage collection and pump

stations would be located within the Bird Reef Central and Kimberley

Reef East Infrastructure Complexes (Figure 3-8 and 3-9 of the EIA

Report).



for the EIA Report







FEDERATION FOR A



2019

Whether West Wits Mining has applied for a WUL and if so, a copy of

the WULA

A WULA has commenced for the proposed mining activities. A

notification of West Wits intention to submit an application was

submitted to the Department (Appendix B of the EIA Report). The WULA

would be initiated towards the end of the EIA process once the technical

design detail is available.


FEDERATION FOR A



2019

Where will the gold/uranium/silver be processed? Primary mineral processing will take place on site, where ore will be

crushed prior to transportation off-site. All run-of mine material will be

transported to an existing off-site processing plant including a tailings

facility for concentrating of minerals. According to West Wits, the off-

site processing plant that has been identified for the concentrating of

minerals is located approximately 40 km from the proposed West Wits

project area. At this stage West Wits is considering a few options. Once

this information becomes available this can be passed onto you.


FEDERATION FOR A



2019

A copy of West Wits Mining’s financial provisions in terms of the 2015

NEMA: Regulations for Financial Provisions for …Mining





FEDERATION FOR A



2019

A copy of the Traffic Impact Assessment Report Details of project related traffic volumes have been included in Section

3.2.6 of the EIA Report. These have been considered by the Traffic

specialist and the Traffic Impact Assessment has been included in

Appendix O of the EIA Report. Relevant impacts including mitigation and


the EIA Report.


FEDERATION FOR A



2019

West Wits Mining’s BBB-EE compliance status West Wits a South African subsidiary of the company is 33,3%

empowered. The empowerment company is Lilitha Resources

Proprietary Limited, previously referred to as Witpoortjie Resources

Investments Proprietary Limited (Section 1.1 of the EIA Report).


FEDERATION FOR A



2019

OHSA compliance status Please note that occupational aspects fall outside of the scope of the EIA

process.



for the EIA Report







FEDERATION FOR A



2019

A copy of the Disaster Management Plan as required by OHSA. Please note that occupational aspects fall outside of the scope of the EIA

process.

The emergency awareness plan is included in Section 30 of the EIA

Report.


FEDERATION FOR A



2019

A copy of the Corporate Responsibility programme for the current and

planned operations.

West Wits operates in line with its Corporate Governance framework.

The framework includes principles that talk to responsible management

and acting ethically, responsibly and with integrity. A copy of this

framework is available on the West Wits website.

In addition, the development and implementation of a Social and Labour

plan address aspects such as labour provision, training and skills

development as well as investment in local communities through local

economic development initiatives.


FEDERATION FOR A



2019

While the FSE wishes to thank you for including the FSE’s comments,

the responses of SLR to the FSE’s and other IAPs’ comments are

meaningless since to every issue of concern raised by IAPs, SLR

responded in the same manner.

Meaningfull responses have been included in the EIA Report based on

the various specialist studies conducted following the Scoping Report.

Nomzamo Gumede -

Provincial Heritage Resources

Authority - Gauteng (PHRA-G)

X E-mail received on 5 July

2019

It was noted that an impact on identified heritage resources was not

clear.




the EIA Report.

Nomzamo Gumede -




2019

Submit a clear/colour Heritage Impact Assessment (HIA) report, that

should amongst other things:

- clearly identify and map the heritage resources on the earmarked

property/area

- give the historical background of the area

- show how the proposed work might have an impact on heritage

resources

- outline recommendations and mitigation measures




the EIA Report.

Nomzamo Gumede -




2019

Submit a clear/colour Heritage Impact Assessment (HIA) report, that

should amongst other things:

- give a report on the public participation process followed during the

assessment phase






for the EIA Report






Nomzamo Gumede -




2019

It was noted that there were many graves identified on site. Please get

comments from the South African Heritage Resources Agency

(SAHRA)'s Burial Grounds and Graves Unit.

Upon receipt of the contact person and details, the SAHRA Burial

Grounds and Graves Unit will be contacted to comment on the EIA

Report.


Dantex

X Comment received on 9 July

2019 by email

In Summary, we as Maxam after evaluating the response on Appendix

C Issues and Response report, we noted the applicant states that the

concern raised regarding:


The referred Appendix O and D does not address the accessibility to

the Maxam Dantex factory in view of the mining activities on this

section. (Page 8 of 104)


be constructed.


Dantex


2019 by email

Kimberley East Pit Activities

All activities must be conducted at a minimum distance of 150 m away

from the safety zones – (Page 8 of 108)





for the EIA Report







Dantex


2019 by email

Kimberley Reef East Underground Activities – (Page 9 of 108)

• As noted in the last report, the proposed underground activities will

be taking place directly under the Maxam Dantex factory. Basing on

the report submitted, underground activities will begin at 50m below

the surface which poses safety concerns as there are blasting activities

that currently happen on the surface. Allowing underground blasting

activities will increase the risk of sink holes due to increased seismic

movements as currently sink holes are being noted- taking into

consideration the Lily Mine incident in Mpumalanga.

• As such, the following will be required:

1. Geological reports

2. Seismic survey reports

3. Blasting patterns

4. Type of explosives to be used and the quantity per phase

The issue has been noted. West Wits endeavour to have a settlement

agreement in place with Rand Leases soonest, which will include a

Stability Study. It is the intention of West Wits to sign an agreement with

Rand Leases to in turn coexist with their lessees.




operation.












underway.


Dantex


2019 by email

Open Pit Activities - 11 Shaft Pit Activity – (Page 14-104)

• As highlighted activities are not permitted within any safety zone

and therefore the proposal for a lease agreement is not possible.




Dantex


2019 by email

Open Pit Activities - 11 Shaft Pit Activity – (Page 14-104)

• The referred Appendix O and D does not address the accessibility to

the Maxam Dantex factory in view of the mining activities on Main

reef


be constructed.



for the EIA Report







Dantex


2019 by email


• A more detailed study is required focusing on the underground

activities under Maxam Dantex factory taking into consideration the

surface blasting activities that happen at Maxam Dantex bearing in

mind that sinkholes are already happening with the current activities.








operation.












underway.



for the EIA Report







Dantex


2019 by email


• As noted in the last report, the proposed underground activities will

be taking place directly under the Maxam Dantex factory. Basing on

the report submitted, underground activities will begin at 50m below

the surface which poses safety concerns as there are blasting activities

that currently happen on the surface. Allowing underground blasting

activities will increase the risk of sink holes due to increased seismic

movements as currently sink holes are being noted- taking into

consideration the Lily Mine incident in Mpumalanga.

As such, the following will be required:

1. Geological reports

2. Seismic survey reports

3. Blasting patterns

4. Type of explosives to be used and the quantity per phase








operation.












underway.



for the EIA Report







Dantex


2019 by email


• A more detailed study is required focusing on the underground

activities under Maxam Dantex factory taking into consideration the

surface blasting activities that happen at Maxam Dantex bearing in

mind that sinkholes are already happening with the current activities..








operation.












underway.




X E-mail received on 24 June

2019

As per our previous submissions, we wish to request for the following:

1) Extension of public review and comment period to 60 days, instead

32 days you provide.

As per the discussions between yourself and Robyn Mellett earlier today

this extension is granted. Please note that the applicant will be

submitting the Final Environmental Impact Assessment (EIA) Report to

the Department of Mineral Resources (DMR) in July 2019, however in

this submission the DMR will be informed that we are aware that your

comments are still pending and as soon as we receive your comments

we will inform the DMR and forward your comments to them with

respective responses.



for the EIA Report










2019


2) Translation of Executive Summary into Zulu, Afrikaans and Sotho.









available.





2019


3) A focused group meeting with your experts.

A Focussed Group EIA Feedback meeting will be arranged with the

Lawyers for Human Rights and the clients you are representing. During

this meeting the independent Surface Water, Groundwater and

Radiation Specialists will be present as requested by the Communities

Against Mining in the meeting held on 6 March 2019. This should assist

in addressing your requests in terms of timelines and technical support.

Could you please indicate your availability during next week in order for

us to schedule a Focussed Group

EIA Feedback Meeting?



for the EIA Report










2019

As you are well aware that our clients have no capacity to

meaningfully engage technical reports compiled by your specialists,

we are trying to get that support for them. Owing to our financial

constraints as the NGO, and since you declined our request for the

financial support for the community to procure such professional

services, we have had to appeal for pro-bono technical support. We

also have to consult adequately with our clients. Unfortunately all of

that will take much more than the allocated time, especially owing to

many areas of specialist reports we are expected to comment on and

widespread of the affected communities over the vast areas of the

mining right We therefore request this extension so that we can

assemble the team of experts able to technically support us pro bono,

adequately consult our clients and in due course organise a focused

group between our expert team, CAM leadership and your experts as

previously discussed.

As per the discussions between yourself and Robyn Mellett earlier today

this extension is granted. Please note that the applicant will be

submitting the Final Environmental Impact Assessment (EIA) Report to

the Department of Mineral Resources (DMR) in July 2019, however in

this submission the DMR will be informed that we are aware that your

comments are still pending and as soon as we receive your comments

we will inform the DMR and forward your comments to them with

respective responses.





2019

Please also reply to our request for the translation of the Executive

Summary of the EIA Report and Draft EMP in the

above-mentioned languages which are widely spoken in the affected

communities by residents who are mostly not

proficient in English as a second language.









available.





2019

Lastly, we request information regarding the logistics of public

consultation meetings, which is not provided in your

summary letter.

An extensive Public Participation Process has been conducted and

numerous public open day sessions and focussed

group meetings were held in the Scoping Phase. Therefore, no

additional public meetings are being planned during

the EIA phase.

Apie Cronje - Blueprint

Developments


2019

Are we still registered as an IAP on this matter?

If yes, who Dino Properties or Blue Print?

Both Dino Properties and Blue Print are registered as an I&AP.



for the EIA Report






Judith Taylor - Earthlife Africa

Board member


2019

The impacts on the surrounding communities and infrastructure of

these operations will be extreme. This area is already heavily impacted

by previous, unremediated mines and people are ill and dying as a

result. My strong recommendation is that the entire area be

remediated, using local people and companies.

The post-mining land uses related to the proposed five opencast pits are

described in the Golder rehabilitation and closure report (refer to

Appendix S of the EIA Report).

The final post closure land uses have been identified in consultation with

land owners and will include residential, commercial, industrial,

infrastructure, as well as green belts and parks.

Thabo Rangwaga - Proudly

Sowetan Socio-Economic

Transformation Institute


2019

When can we expect the Social Labour Plan? During your public

consultation we expressed the need and desire from the communities

for skills development to be part of permanent opportunities afforded

to our local SMMEs.

We furthermore made ourselves available for delivery of such

training, mentorship and coaching.

As an accredited institute within the community we are still waiting

for your progressive response in this regard.

You are welcome to approach the DMR for a copy of the SLP.






Mobile - 073 388 6803; and





for the EIA Report






Beauty Nobesotho X E-mail received on 23 May

2019

As far as I remember is that when we filled the forms was of work

application but now I don't understand what is this all about.

I'll take it that the people who came they gave us wrong information

which is against the law.




process (see Section 6.2 of the scoping Report dated August 2018)

which included public open day sessions. The purpose of the sessions

were to:

- provide I&APs with an opportunity to:

o raise any issues and concerns (both positive or negative);

o provide input on any environmental sensitivities and potential

impacts;

- record issues within the formal assessment process so that they can

be addressed during the course of the EIA;

- outline the way forward.

No application for employment formed part of the PPP.

Should the proposed project be approved it is recommended that you

contact the applicant directly.

Difference Chauke -

Openserve (a Division of

Telkom SA SOC Ltd)


received on 23 May 2019

Telkom has taken note of the proposed construction of Roodepoort

and we would like to point out that in the event that /construction at

the development site necessitates the deviation or removal of

Telkom’s telecommunication facilities,

- The township developer should request Telkom in good time for the

deviation or removal of the Telkom telecommunication facilities.

- The cost for such deviation or removal shall be for the account of

the township developers.

This issue has been noted.

The relevant applications will be submitted where required.

Difference Chauke -


Telkom SA SOC Ltd)



If in the township developers decide to install underground pipes for

telecommunication service purposes for practical and aesthetic

purposes, the costs for such conduit-pipes will be for the township

developer’s account. Alternatively, Telkom in its sole discretion will

determine the most suitable and cost effective means to provide the

telecommunication facilities at the proposed township.





for the EIA Report






Difference Chauke -


Telkom SA SOC Ltd)



Should the township development project be approved, the township

developer should without delay, inform the Regional Network

Engineering Department officer for Telkom to proceed with the detail

telecommunication infrastructure planning.

Please note that Telkom will only commence with the provision of

telecommunication facilities (cabling) once Telkom has determined

the demand for telecommunication services at the development and

the project has been proved to be viable.



Albert Mpehle X E-mail (with attachment)


I am concerned as to why Fleurhof is not identified as an afected area

when it actually is, please provide clarity?

Fleurhof would not be located within but adjacent to the proposed

mining right application area, and would therefore not be affected by

the open pit and underground mining activities.



The Enviromental Impact assesment is very vague and does not

provide any direct solutions or indication to your ratings. Please

provide me with a comprehensive enviromental Impact assesment.

Refer to Appendix D of the EIA Report for the assessment of relevant

impacts including mitigation and monitoring measures.

The EIA Report has been prepared in accordance with the DMR EMPr

Report template format, and was informed by the guidelines posted on

the official DMR website. This is in accordance with the requirements of

the MPRDA. This report also complies with the requirements of the

NEMA and Appendix 3 and Appendix 4 of EIA Regulations 2014 (as

amended).

Table 0-1 in the EIA Report provides a summary of the requirements,

with cross references to the report sections where these requirements

have been addressed.



Kindly please also provide the social labor plan, a comprehensive

social labor plan.

You are welcome to approach the DMR for a copy of the SLP.



On behalf of the Fleurhof Community and Business Initiative in my

capacity as Director we would like to request a meeting with the

Directors at their soonest convinience, to discuss more pressing issues

that are relevant to our community and foster a community to

business based relationship in developing a sustainable community.




Mobile - 073 388 6803; and





for the EIA Report






George Congo - Department

of Roads and Transport

X E-mail (with attachment)


Note must be taken that the Gauteng Strategic Transportation

Network namely, Provincial Road(s): PWV5, PWV12A, K198, K102,

K11 and P42-1 are affected and as such, in terms of the Gauteng

Transport Infrastructure Act, 2001 (Act No 8 of 2001), when an

application for a township establishment, change of land use

(rezoning, subdivision, consent use etc) is lodged with the relevant

authority, the said application must be lodged with this Department

for evaluation.




the EIA Report.






Future Route(s) PWV12A is affected by the application and as the said

route falls under the provision of Section 7 of Act 8 of 2001, (Gauteng

Transport Infrastructure Act), this Department must be provided with

a written report as stated in Section 7 of the said Act for evaluation. As

soon as the report has been submitted with the application, it will

received further attention, as stated in the Act.




the EIA Report.

Applications will be submitted where required.





Your attention is drawn to Section 7(5) of the Act. Notice must be

taken that the relevant provisions of Section 6 to 8 of the Act have

been enacted via Section 10 of the Act above for the above mentioned

route with the publication of Notice 2625 of 2003 (Acceptance of

routes and determination of centrelines thereof) in the Provincial

Gazette dated 20 August 2003.




the EIA Report.






Note must be also taken that an application must be submitted to this

Department for a way leave if any part of a proposed service falls

within 95,0 m (measured from the centreline of any of the

Department's existing or future road(s)/railway line or within a 500,0

m radius of any intersection on said road(s)/railway line.




the EIA Report.






Where mining operations are to be undertaken, Section 49 of the

Gauteng Transport Infrastructure Act, 2001 (Act No 8 of 2001) shall

apply.




the EIA Report.



2019-07-17 Issues and Response table - EIA Report.xlsx

Documents

Transcript of 2019-07-17 Issues and Response table - EIA Report.xlsx