EIA of Virginia Gas Production Project

ENVIRONMENTAL IMPACT ASSESSMENT
REPORT
TETRA4 CLUSTER 2 VIRGINIA GAS PRODUCTION PROJECT
PASA Ref: 12/4/007

DOCUMENT DETAILS
EIMS REFERENCE: 1473
DOCUMENT TITLE: EIA Report: Tetra4 Cluster 2 Virginia Gas Production Project
DOCUMENT CONTROL
NAME SIGNATURE DATE
COMPILED: Brian Whitfield 2022/11/29
CHECKED: Liam Whitlow 2022/11/29
AUTHORIZED: Liam Whitlow 2022/11/29
REVISION AND AMENDMENTS
REVISION DATE: REV # DESCRIPTION
2022/11/29 ORIGINAL DOCUMENT Report for Public Review
2023/02/01 FINAL DOCUMENT Final Report for Competent Authority Decision

Making
This document contains information proprietary to Environmental Impact Management Services (Pty) Ltd. and
as such should be treated as confidential unless specifically identified as a public document by law. The
document may not be copied, reproduced, or used for any manner without prior written consent from EIMS.
Copyright is specifically reserved.
Table of Contents
1 Executive Summary (Non-Technical) ............................................................................................................. 1
1.1 Project Overview ................................................................................................................................... 1
1.2 Need for the Project .............................................................................................................................. 1
1.3 Project Description and Infrastructure ................................................................................................. 2
Drilling ............................................................................................................................................... 2
Pipelines ............................................................................................................................................ 2
Gas Inline Stations ............................................................................................................................ 2
LNG and Helium Plant ....................................................................................................................... 3
1.4 Specialist Studies ................................................................................................................................... 3
1.5 Impacts Identified and summary of Impact Assessment ...................................................................... 4
1.6 Public Participation ............................................................................................................................. 11
1.7 Impact Statement ............................................................................................................................... 14
2 Introduction ................................................................................................................................................. 15
2.1 Report Structure ................................................................................................................................. 16
2.2 Details of the EAP ................................................................................................................................ 21
2.3 Specialists ............................................................................................................................................ 21
3 Description of the Property ......................................................................................................................... 23
4 Description and Scope of the Proposed Activity .......................................................................................... 35
4.1 Project Description .............................................................................................................................. 35
Proposed Cluster 2 Project ............................................................................................................. 35
The Gas Resource............................................................................................................................ 38
Gas Production Method .................................................................................................................. 38
Surface Infrastructure ..................................................................................................................... 50
Contractors’ Laydown Areas, Offices and Ablution Facility ............................................................ 50
Site Access Control.......................................................................................................................... 51
Roads .............................................................................................................................................. 51
Power Supply .................................................................................................................................. 52
Water Management ....................................................................................................................... 53
Waste Management ................................................................................................................... 56
Project Scheduling ...................................................................................................................... 56
4.2 Listed and Specified Activities Triggered ............................................................................................. 57
5 Policy and Legislative Context ...................................................................................................................... 71
5.1 Constitution of the Republic of South Africa ...................................................................................... 71
5.2 The Mineral and Petroleum Resources Development Act (MPRDA) .................................................. 71
5.3 The National Environmental Management Act (NEMA) ..................................................................... 71
5.4 The National Water Act (NWA) ........................................................................................................... 73
Catchment Management Strategies ............................................................................................... 75
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5.5 The National Environmental Management Waste Act (NEMWA) ...................................................... 75
5.6 The National Environmental Management Air Quality Act (NEMAQA) .............................................. 78
National Dust Control Regulations ................................................................................................. 78
5.7 The National Heritage Resources Act (NHRA) ..................................................................................... 79
5.8 National Environmental Management Biodiversity Act (NEMBA) ...................................................... 79
5.9 The Conservation of Agricultural Resources Act (CARA) ..................................................................... 80
5.10 Environment Conservation Act (ECA).................................................................................................. 81
Noise Control Regulations, 1992 (GN R.154) .............................................................................. 81
Noise Standards.......................................................................................................................... 82
5.11 The Spatial Planning and Land Use Management Act (SPLUMA) ....................................................... 82
5.12 Occupational Health and Safety Act.................................................................................................... 82
5.13 Basic Conditions of Employment Act .................................................................................................. 83
5.14 Labour Relations Act ........................................................................................................................... 84
5.15 Employment Equity Act ....................................................................................................................... 84
5.16 Promotion of Equality and Prevention of Unfair Discrimination ........................................................ 84
5.17 Firearms Control Act ........................................................................................................................... 84
5.18 National Energy Act ............................................................................................................................. 84
5.19 Gas Act ................................................................................................................................................ 86
5.20 Gas Master Plan and Integrated Resource Plan .................................................................................. 86
5.21 Other Applicable Acts and Local or International Guidelines or standards ........................................ 87
IFC Performance Standards ........................................................................................................ 87
World Bank (WB) and International Finance Corporation (IFC) Guidelines ............................... 94
GHG and Climate Change ........................................................................................................... 96
6 Need and Desirability of the Proposed Activity ......................................................................................... 102
6.1 Potential Project Benefits ................................................................................................................. 105
6.2 Economic Factors in Favour of the Project ....................................................................................... 105
Positive Economic Impacts ........................................................................................................... 105
Demand for Helium ...................................................................................................................... 106
Demand for Natural Gas ............................................................................................................... 108
A Sustainable and Competitive Local Gas and Helium Industry in South Africa ........................... 109
6.3 Arguments Neutral or Against the Project. ....................................................................................... 110
Natural gas .................................................................................................................................... 110
Helium ........................................................................................................................................... 111
6.4 Need and Desirability Analysis .......................................................................................................... 111
7 Project Alternatives ................................................................................................................................... 122
7.1 Activity Alternatives .......................................................................................................................... 122
7.2 Location Alternatives ........................................................................................................................ 122
Well Sites ...................................................................................................................................... 124
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Pipeline Routes (servitudes and inline infrastructure) ................................................................. 124
Compressor Stations ..................................................................................................................... 125
LNG/LHe Plant............................................................................................................................... 125
7.3 Design and Layout Alternatives ......................................................................................................... 125
7.4 Process Alternatives .......................................................................................................................... 126
7.5 Technology Alternatives .................................................................................................................... 126
7.6 No Go Alternative.............................................................................................................................. 126
7.7 Sensitivity Planning Approach ........................................................................................................... 126
8 Stakeholder Engagement ........................................................................................................................... 127
8.1 General Approach to Public Participation ......................................................................................... 127
8.2 Initial Notification.............................................................................................................................. 129
Registered Letters, Faxes and Emails ............................................................................................ 129
Newspaper Advertisements / Government Gazette .................................................................... 129
Site Notice Placement ................................................................................................................... 129
Poster Placement .......................................................................................................................... 130
8.3 Availability of Scoping Report .................................................................Error! Bookmark not defined.
8.4 Public Participation Progress............................................................................................................. 131
9 Environmental Attributes and Baseline Environment ............................................................................... 135
9.1 Topography ....................................................................................................................................... 135
9.2 Drainage and Catchment .................................................................................................................. 136
9.3 Climate .............................................................................................................................................. 137
9.4 Social ................................................................................................................................................. 137
Description of the Area ................................................................................................................. 138
Lejweleputswa District Municipality ............................................................................................. 139
Matjhabeng Local Municipality..................................................................................................... 139
Masilonyana Local Municipality.................................................................................................... 139
Description of the Population ....................................................................................................... 140
Population and Household Sizes ................................................................................................... 140
Population Composition, Age, Gender and Home Language........................................................ 142
Gender .......................................................................................................................................... 144
Language ....................................................................................................................................... 144
Education .................................................................................................................................. 145
Employment ............................................................................................................................. 146
Household Income.................................................................................................................... 147
Housing ..................................................................................................................................... 147
Household Size ......................................................................................................................... 150
Access to Water and Sanitation ............................................................................................... 150
Energy ....................................................................................................................................... 153
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Refuse Removal ........................................................................................................................ 154
9.5 Economic Environment ..................................................................................................................... 154
National Economy ......................................................................................................................... 155
Local Economy .............................................................................................................................. 155
9.6 Cultural and Heritage Resources ....................................................................................................... 158
9.7 Soils and Land Capability ................................................................................................................... 171
9.8 Hydrology and Floodlines .................................................................................................................. 179
9.9 Geology ............................................................................................................................................. 180
Regional geology ........................................................................................................................... 180
Local geology ................................................................................................................................ 181
Structural geology ......................................................................................................................... 181
9.10 Groundwater (Geohydrology) ........................................................................................................... 181
Hydrocensus ............................................................................................................................. 182
Groundwater Flow.................................................................................................................... 183
Groundwater Quality ................................................................................................................ 190
Groundwater Contamination Risk Assessment ........................................................................ 190
Numerical Groundwater Flow and Contaminant Transport Model ......................................... 191
Hydrogeological Sensitivity ...................................................................................................... 212
9.11 Terrestrial Biodiversity ...................................................................................................................... 215
Ecologically Important Landscape Features ............................................................................. 215
Biodiversity Spatial Plan (BSP) .................................................................................................. 215
The National Biodiversity Assessment ..................................................................................... 216
Protected Areas ........................................................................................................................ 218
Important Bird and Biodiversity Areas (IBAs) ........................................................................... 220
Hydrological Setting ................................................................................................................. 220
Vegetation Types ...................................................................................................................... 222
Flora Assessment ...................................................................................................................... 223
Fauna Assessment .................................................................................................................... 228
Habitat Assessment and Site Ecological Importance................................................................ 233
9.12 Aquatic and Wetlands ....................................................................................................................... 238
Wetland Delineation and Description ...................................................................................... 238
Ecological Functional Assessment ............................................................................................ 239
The Ecological Health Assessment ........................................................................................... 240
Buffer Requirements ................................................................................................................ 241
9.13 Air Quality and Health ....................................................................................................................... 242
Surface Wind Field .................................................................................................................... 242
Ambient Air Quality within the Region ..................................................................................... 244
9.14 Climate Change ................................................................................................................................. 247
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Physical Risks of Climate Change on the Region ...................................................................... 247
Water Stress and Extreme Events ............................................................................................ 248
Scope 1 GHG Emission Sources ................................................................................................ 249
Scope 2 GHG Emission Sources ................................................................................................ 250
Summary of Scope 1 and Scope 2 GHG Emissions ................................................................... 251
Scope 3 GHG Emissions ............................................................................................................ 252
The Project’s GHG Emissions Impact ........................................................................................ 253
Project adaptation and mitigation measures ........................................................................... 254
9.15 Noise Receptors ................................................................................................................................ 255
Noise Sensitive Receptors ........................................................................................................ 255
Noise Propagation and Simulation ........................................................................................... 256
9.16 Visual Receptors ................................................................................................................................ 257
Landscape Character Areas and Visual Absorption Capacity (VAC) ......................................... 257
Visual Sensitivity ....................................................................................................................... 261
10 Environmental Impact Assessment ............................................................................................................ 264
10.1 Impact Assessment Methodology ..................................................................................................... 264
Determination of environmental risk ....................................................................................... 264
Impact Prioritisation ................................................................................................................. 266
10.2 Identification and Assessment of Impacts ........................................................................................ 268
Construction Phase Impacts ..................................................................................................... 268
Operational Phase Impacts ...................................................................................................... 286
Decommissioning Rehabilitation and Closure Phase Impacts .................................................. 300
No-Go Alternative..................................................................................................................... 309
10.3 Summary of Impact Assessment ....................................................................................................... 309
11 Final Sensitivity Analysis ............................................................................................................................ 329
12 Decommissioning Rehabilitation and Closure ........................................................................................... 352
13 Conclusion and Recommendations............................................................................................................ 352
13.1 Conclusions from Specialist Studies .................................................................................................. 352
Air Quality Study Conclusions................................................................................................... 352
Climate Change Study Conclusions .......................................................................................... 353
Noise Study Conclusions........................................................................................................... 354
Economic Study Conclusions .................................................................................................... 355
Geohydrology Study Conclusions ............................................................................................. 356
Hydrology Study Conclusions ................................................................................................... 362
Terrestrial Biodiversity Study Conclusions ............................................................................... 362
Aquatic Study Conclusions ....................................................................................................... 363
Wetland Study Conclusions ...................................................................................................... 364
Soil and Agriculture Study Conclusions .................................................................................... 364
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Visual Study Conclusions .......................................................................................................... 365
13.2 Preferred Alternatives ....................................................................................................................... 365
Location Alternatives ................................................................................................................ 365
Layout Alternatives................................................................................................................... 365
No-Go Alternative..................................................................................................................... 365
13.3 Environmental Impact Statement ..................................................................................................... 365
13.4 Recommendations for Inclusion in Integrated Decision ................................................................... 366
14 Assumptions and Limitations ..................................................................................................................... 370
14.1 General .............................................................................................................................................. 370
14.2 Soils and Land Capability (Agriculture).............................................................................................. 370
14.3 Air Quality and Health Risk................................................................................................................ 370
14.4 Climate Change ................................................................................................................................. 371
14.5 Economic ........................................................................................................................................... 372
14.6 Geohydrology .................................................................................................................................... 372
14.7 Heritage and Palaeontology .............................................................................................................. 373
14.8 Noise ................................................................................................................................................. 374
14.9 Social ................................................................................................................................................. 374
14.10 Terrestrial Biodiversity ...................................................................................................................... 375
14.11 Aquatic and Wetlands ....................................................................................................................... 375
14.12 Visual ................................................................................................................................................. 375
15 Undertaking Regarding Correctness of Information .................................................................................. 377
16 Undertaking Regarding Level of Agreement .............................................................................................. 377
17 References ................................................................................................................................................. 378
List of Figures
Figure 1: Parent farms included in the application area. ..................................................................................... 31
Figure 2: Overview of parent farms and portions included in the application area. ............................................ 32
Figure 3: Inset 1 map of parent farms and portions included in the application area. ........................................ 33
Figure 4: Inset 2 map of parent farms and portions included in the application area. ........................................ 34
Figure 5: Project history and mineral tenure. ....................................................................................................... 36
Figure 6: Cluster 2 study area and proposed infrastructure footprint transects. ................................................ 37
Figure 7: Schematic section depicting typical well construction. ......................................................................... 40
Figure 8: Typical pipeline servitude and pipe marker........................................................................................... 41
Figure 9: Typical example of a pre-cast well chamber. ........................................................................................ 42
Figure 10: View of an existing pigging station constructed as part of Cluster 1. .................................................. 43
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Figure 11: View of an existing low point drain constructed as part of Cluster 1. ................................................. 43
Figure 12: Example of Compressor Station just recently constructed as part of Cluster 1. ................................. 44
Figure 13: Area to be impacted by the LNG/LHe Plant (green filled area) and laydown areas (clear white outline).
..................................................................................................................................................................... 45
Figure 14: Preliminary layout of the Cluster 2 Plant extension to Cluster 1 Plant ............................................... 46
Figure 15: Typical subterranean precast well chamber layout ............................................................................. 47
Figure 16: Typical booster station layout ............................................................................................................. 48
Figure 17: Typical compressor station layout ....................................................................................................... 49
Figure 18: Typical transmission tower outline drawing. ....................................................................................... 52
Figure 19: Typical schematic of the proposed sewage water treatment works. .................................................. 54
Figure 20: Typical schematic of the proposed reverse osmosis treatment works. .............................................. 54
Figure 21: Water balance showing the potential amount of waste water produced during gas production and
processing. ................................................................................................................................................... 55
Figure 22: EIA process diagram. ........................................................................................................................... 73
Figure 23: Authorisation processes for new water uses ...................................................................................... 74
Figure 24: Uses of Helium. .................................................................................................................................. 107
Figure 25: Global demand and supply of Helium in Billion Cubic Feet. .............................................................. 108
Figure 26: South Africa natural gas sector overview. ......................................................................................... 110
Figure 27: Topographical cross-sections of the greater application area. ......................................................... 136
Figure 28: Study area in relation to quaternary catchments and drainage areas. ............................................. 137
Figure 29: Location of the proposed Cluster 2 Project in relation to Municipal Wards. .................................... 138
Figure 30: Broad overview of land cover in the study area. ............................................................................... 139
Figure 31: Population distribution (shown in percentage, source: Census 2011). ............................................. 143
Figure 32: Age distribution (shown in percentage, source: Census 2011). ........................................................ 144
Figure 33: Gender distribution (shown in percentage, source: Census 2011). .................................................. 144
Figure 34: Language distribution (shown in percentage, source: Census 2011). ............................................... 145
Figure 35: Education profiles (those aged 20 years or older, shown in percentage, source: Census 2011). ..... 145
Figure 36: Labour status (those aged between 15 - 65 years, shown in percentage, source: Census 2011). .... 146
Figure 37: Employment sector (those aged between 15 - 65 years, shown in percentage, source: Census 2011).
................................................................................................................................................................... 146
Figure 38: Annual household income (shown in percentage, source: Census 2011). ........................................ 147
Figure 39: Enumeration area types (persons, shown in percentage, source: Census 2011). ............................. 148
Figure 40: Dwelling types (shown in percentage, source: Census 2011)............................................................ 149
Figure 41: Tenure status (shown in percentage, source: Census 2011). ............................................................ 150
Figure 42: Household size (shown in percentage, source: Census 2011). .......................................................... 150
Figure 43: Water source (shown in percentage, source: Census 2011). ............................................................ 151
Figure 44: Piped water (shown in percentage, source: Census 2011). ............................................................... 152
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Figure 45: Sanitation (shown in percentage, source: Census 2011). .................................................................. 153
Figure 46: Energy source for lighting (shown in percentage, source: Census 2011). ......................................... 154
Figure 47: Refuse removal (shown in percentage, source: Census 2011). ......................................................... 154
Figure 48: Key economic graphs. ........................................................................................................................ 156
Figure 49: Structure of Matjhabeng economy by economic output 2014 – sector specific. .............................. 156
Figure 50: Structure of Matjhabeng economy by economic output 2014 – overall output. .............................. 157
Figure 51: South African gold production. .......................................................................................................... 157
Figure 52: Map showing heritage sensitivity rating of identified heritage resources. ....................................... 160
Figure 53: Heritage sensitivity rating of identified heritage resources - Inset A. ............................................... 161
Figure 54: Heritage sensitivity rating of identified heritage resources - Inset B. ............................................... 162
Figure 55: Heritage sensitivity rating of identified heritage resources - Inset C. ............................................... 163
Figure 56: Heritage sensitivity rating of identified heritage resources - Inset D. ............................................... 164
Figure 57: Heritage sensitivity rating of identified heritage resources - Inset E................................................. 165
Figure 58: Heritage sensitivity rating of identified heritage resources - Inset F. ................................................ 166
Figure 59: Heritage sensitivity rating of identified heritage resources - Inset G. ............................................... 167
Figure 60: Heritage sensitivity rating of identified heritage resources - Inset H. ............................................... 168
Figure 61: Heritage sensitivity rating of identified heritage resources - Inset I. ................................................ 169
Figure 62: Heritage sensitivity rating of identified heritage resources - Inset J. ................................................ 170
Figure 63: Illustration of land type Ae40 terrain unit (Land Type Survey Staff, 1972 - 2006). ........................... 171
Figure 64: Illustration of land type Bd 20 terrain unit (Land Type Survey Staff, 1972 - 2006). .......................... 172
Figure 65: Illustration of land type Dc 8 terrain unit (Land Type Survey Staff, 1972 - 2006). ............................ 172
Figure 66: Illustration of land type Dc 9 terrain unit (Land Type Survey Staff, 1972 - 2006). ............................ 173
Figure 67: Illustration of land type Dc 12 terrain unit (Land Type Survey Staff, 1972 - 2006). .......................... 173
Figure 68: Slope percentage map for the assessment area. .............................................................................. 175
Figure 69: Elevation map for the assessment area. ............................................................................................ 176
Figure 70: Land Capability Sensitivity (DAFF, 2017)............................................................................................ 177
Figure 71: Farming Field crop Sensitivity (DEA, 2022). ....................................................................................... 178
Figure 72: Catchment areas. ............................................................................................................................... 179
Figure 73: 1:100-year floodlines. ........................................................................................................................ 180
Figure 74: Hydrocensus user survey: Groundwater application. ....................................................................... 182
Figure 75: Hydrocensus user survey: Equipment type. ...................................................................................... 183
Figure 76: Spatial distribution of hydrocensus user survey geosites.................................................................. 188
Figure 77: Regional groundwater flow direction and depth to groundwater. ................................................... 189
Figure 78: Steady state hydraulic heads and groundwater flow direction. ........................................................ 192
Figure 79: Scenario 02a: Time-series graph indicating the TDS mass load contribution of deeper, fractured and
saline aquifer on observation boreholes targetting the potable shallow, intergranular aquifer (Operational
phase). ....................................................................................................................................................... 194
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Figure 80: Scenario 02: Simulated particle tracking of contaminants originating from the deeper, fractured
aquifer migrating from leaking boreholes within the intergranular aquifer (Operational phase). ........... 195
Figure 81: Scenario 02a: TDS pollution plume migration of contaminants originating from the deeper, fractured
aquifer migrating through the intergranular aquifer (Operational phase). ............................................... 196
Figure 82: Scenario 02b: Time-series graph indicating the CH4 mass load contribution of deeper, fractured
aquifer on observation boreholes targetting the potable shallow, intergranular aquifer (Operational
phase). ....................................................................................................................................................... 197
Figure 83: Scenario 02b: CH4 pollution plume migration of contaminants originating from the deeper, fractured
aquifer migrating through the intergranular aquifer (Operational phase). ............................................... 198
Figure 84: Scenario 03: Time-series graph indicating the TDS mass load emanating from the plant footprint on
down-gradient observation boreholes targeting the potable shallow, intergranular aquifer (Operational
phase). ....................................................................................................................................................... 199
Figure 85: Scenario 03: Model domain 3-D FEM mesh view (cross sectional view southwest-northeast orientation
A-A’) of the TDS pollution plume originating at the plant footprint (Operational phase). ........................ 200
Figure 86: Scenario 03: TDS pollution plume migration of contaminants originating from the plant footprint
within the intergranular aquifer (Operational phase). .............................................................................. 201
saline aquifer on observation boreholes targeting the potable shallow, intergranular aquifer (post-closure
phase). ....................................................................................................................................................... 202
Figure 88: Scenario 04: Simulated particle tracking of contaminants originating from the deeper, fractured
aquifer migrating from leaking boreholes within the intergranular aquifer (post-closure phase)............ 203
Figure 89: Scenario 04a: TDS pollution plume migration of contaminants originating from the deeper, fractured
aquifer migrating through the intergranular aquifer (post-closure phase). .............................................. 204
Figure 90: Scenario 04b: Time-series graph indicating the CH4 mass load contribution of waste facilities on down-
gradient receptors. .................................................................................................................................... 205
Figure 91: Scenario 04b: CH4 pollution plume migration of contaminants originating from the deeper, fractured
aquifer migrating through the intergranular aquifer (post-closure phase). .............................................. 206
down-gradient observation boreholes targeting the potable shallow, intergranular aquifer (post-closure
phase). ....................................................................................................................................................... 207
down-gradient river receptors expressed as the percentage change in salt load (post-closure phase). .. 208
Figure 94: Scenario 05: Simulated particle tracking of contaminants originating from the plant footprint within
the intergranular aquifer (50-years post-closure). .................................................................................... 209
Figure 95: Scenario 05: Simulated particle tracking of contaminants originating from the plant footprint within
the intergranular aquifer (100-years post-closure). .................................................................................. 210
Figure 96: Scenario 05: TDS pollution plume migration of contaminants originating from the plant footprint
within the intergranular aquifer (post-closure phase)............................................................................... 211
Figure 97: Hydrogeological sensitivity map. ....................................................................................................... 214
Figure 98: Application area superimposed on the Free State BSP. .................................................................... 216
Figure 99: The application area showing the regional ecosystem threat status of the associated terrestrial
ecosystems (NBA, 2018). ........................................................................................................................... 217
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Figure 100: The application area showing the regional level of protection of terrestrial ecosystems (NBA, 2018).
................................................................................................................................................................... 218
Figure 101: Map illustrating the location of protected areas proximal to the assessment area. ...................... 219
Figure 102: Map illustrating the location of NPAES proximal to the assessment area. ..................................... 219
Figure 103: Location of Important Bird and Biodiversity Areas (IBAs) in relation to the assessment area. ....... 220
Figure 104: Hydrological context of the assessment area based on the NBA spatial dataset (2018). ............... 221
Figure 105: Hydrological context of the assessment area based on the NFEPA spatial dataset (2011). ........... 222
Figure 106: The application area showing the vegetation type based on the Vegetation Map of South Africa,
Lesotho & Swaziland (BGIS, 2018). ............................................................................................................ 223
Figure 107: Habitats identified within the application area (northern section). ................................................ 233
Figure 108: Habitats identified within the application area (southern section)................................................. 234
Figure 109: The study area superimposed over the sensitivities in the northern section of the study area. .... 237
Figure 110: The study area superimposed over the sensitivities in the southern section of the study area. .... 238
Figure 111: Delineation of wetlands within the study area. .............................................................................. 239
Figure 112: Average ecosystem service scores for the delineated wetland systems. ........................................ 240
Figure 113: Overall present ecological state of delineated wetlands. ............................................................... 241
Figure 114: Extent of recommended buffer zones. ............................................................................................ 242
Figure 115: Period, day- and night-time wind roses (SAWS Welkom Data, 2019 to 2021). ............................... 243
Figure 116: Seasonal wind roses (SAWS Welkom Data, 2019 to 2021). ............................................................. 244
Figure 117: Tetra4 passive sampling locations. .................................................................................................. 247
Figure 118: Sensitive noise receptors within the study area. ............................................................................. 256
Figure 119: Landscape character areas and visual receptors. ............................................................................ 259
Figure 120: Visual receptors within and near the study area. ............................................................................ 260
Figure 121: Landscape visual sensitivity rating for the study area. .................................................................... 263
Figure 122: Example of combined sensitivity mapping approach. ..................................................................... 331
Figure 123: Soils and Agricultural Sensitivity Map.............................................................................................. 332
Figure 124: Social Sensitivity Map. ..................................................................................................................... 333
Figure 125: Hydrology sensitivity map (1:100-year floodlines). ......................................................................... 334
Figure 126: Geohydrology sensitivity map. ........................................................................................................ 335
Figure 127: Biodiversity (ecology, aquatic and wetlands) sensitivity map. ........................................................ 336
Figure 128: Air quality sensitivity map. .............................................................................................................. 337
Figure 129: Noise sensitivity map. ...................................................................................................................... 338
Figure 130: Visual sensitivity map. ..................................................................................................................... 339
Figure 131: Map showing heritage sensitivity rating of identified heritage resources. See insets below. ........ 340
Figure 132: Heritage sensitivity rating of identified heritage resources. Inset A. .............................................. 341
Figure 133: Heritage sensitivity rating of identified heritage resources. Inset B. .............................................. 342
Figure 134: Heritage sensitivity rating of identified heritage resources. Inset C. .............................................. 343
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Figure 135: Heritage sensitivity rating of identified heritage resources. Inset D. .............................................. 344
Figure 136: Heritage sensitivity rating of identified heritage resources. Inset E. ............................................... 345
Figure 137: Heritage sensitivity rating of identified heritage resources. Inset F. ............................................... 346
Figure 138: Heritage sensitivity rating of identified heritage resources. Inset G. .............................................. 347
Figure 139: Heritage sensitivity rating of identified heritage resources. Inset H. .............................................. 348
Figure 140: Heritage sensitivity rating of identified heritage resources. Inset I. ................................................ 349
Figure 141: Heritage sensitivity rating of identified heritage resources. Inset J. ............................................... 350
Figure 142: Combined sensitivity map. .............................................................................................................. 351
List of Tables
Table 1: Summary of comments received to date and how comments were addressed. ................................... 12
Table 2: Report structure in terms of Appendix 3 of the NEMA EIA Regulations ................................................. 16
Table 3: EAP Details. ............................................................................................................................................. 21
Table 4: List of specialist studies to inform this EIA application. .......................................................................... 22
Table 5: Locality details. ....................................................................................................................................... 23
Table 6: Approximate LNG/LHe Plant and laydown area. .................................................................................... 44
Table 7: Applicable Listed Activities ..................................................................................................................... 58
Table 8: IFC Performance Standards applicability to this project. ........................................................................ 88
Table 9: IFC noise level guidelines. ....................................................................................................................... 96
Table 10: South Africa's NCD mitigation targets. ................................................................................................. 99
Table 11: Helium and LNG properties and uses. ................................................................................................ 102
Table 12: Potential economic benefits as calculated by the economic specialist and Tetra4. ........................... 106
Table 13: Needs and desirability analysis for the proposed Cluster 2 Gas Production Project. ......................... 112
Table 14: Summary of comments received to date and how comments were addressed. ............................... 131
Table 15: Population density and growth estimates (sources: Census 2011, Community Survey 2016). .......... 141
Table 16: Household sizes and growth estimates (sources: Census 2011, Community Survey 2016). .............. 141
Table 17: Dependency ratios (source: Census 2011). ......................................................................................... 142
Table 18: Poverty and SAMPI scores (sources: Census 2011 and Community Survey 2016). ............................ 142
Table 19: Average age (source: Census 2011). ................................................................................................... 143
Table 20: Geotypes (source: Census 2011, households). ................................................................................... 147
Table 21: Soils expected at the respective terrain units within the Ae 40 land type (Land Type Survey Staff, 1972
- 2006). ....................................................................................................................................................... 171
Table 22: Soils expected at the respective terrain units within the Bd 20 land type (Land Type Survey Staff, 1972
- 2006). ....................................................................................................................................................... 172
Table 23: Soils expected at the respective terrain units within the Dc 8 land type (Land Type Survey Staff, 1972 -
2006). ......................................................................................................................................................... 172
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2006). ......................................................................................................................................................... 173
Table 25: Soils expected at the respective terrain units within the Dc 12 land type (Land Type Survey Staff, 1972
- 2006). ....................................................................................................................................................... 173
Table 26: Catchment Area Physical Properties. .................................................................................................. 180
Table 27: Hydrocensus user survey: relevant geosite information. ................................................................... 185
Table 28: Summary of model stress-periods. ..................................................................................................... 193
Table 29: Hydrogeological sensitivity rating. ...................................................................................................... 212
Table 30: Desktop spatial features examined. ................................................................................................... 215
Table 31: Trees, shrub and herbaceous plant species recorded in the application area. .................................. 223
Table 32: A list of avifaunal species recorded for the application area. ............................................................. 228
Table 33: Summary of mammal species recorded within the application area. ................................................ 231
Table 34: Summary of reptile species recorded within the application area. .................................................... 232
Table 35: Summary of amphibian species recorded within the application area. ............................................. 233
Table 36: Summary of habitat types delineated within the field assessment area of the application area. ..... 236
Table 37: Guidelines for interpreting Site Ecological Importance in the context of the proposed development
activities. .................................................................................................................................................... 236
Table 38: Sampling site coordinates, elevation, and classification..................................................................... 246
Table 39: Tetra4 Cluster 2 land clearance during construction. ......................................................................... 249
Table 40: Tetra4 Cluster 2 construction fuel combustion. ................................................................................. 250
Table 41: Tetra4 Cluster 2 operational phase fuel combustion per year. .......................................................... 250
Table 42: Tetra4 Cluster 2 gas processing during an operational year. .............................................................. 250
Table 43: Tetra4 Cluster 2 transmission (pipeline fugitives and venting) and storage during an operational year.
................................................................................................................................................................... 250
Table 44: Tetra4 Cluster 2 ESKOM electricity supply during construction and operations. ............................... 251
Table 45: Tetra4 Cluster 2 Scope 1 and 2 GHG emission summary. ................................................................... 251
Table 46: Tetra4 Cluster 2 GHG Scope 3 emission summary. ............................................................................. 252
Table 47: Tetra4 Cluster 2 GHG scope 3 use of sold products to replace other fuels currently in use. ............. 253
Table 48: Noise simulation (IFC day- and night-time) against construction and operational aspects. .............. 257
Table 49: Criteria for Determining Impact Consequence. .................................................................................. 264
Table 50: Probability Scoring. ............................................................................................................................. 265
Table 51: Determination of Environmental Risk. ................................................................................................ 265
Table 52: Significance Classes. ............................................................................................................................ 266
Table 53: Criteria for Determining Prioritisation. ............................................................................................... 266
Table 54: Determination of Prioritisation Factor. ............................................................................................... 267
Table 55: Final Environmental Significance Rating. ............................................................................................ 267
Table 56: GHG and Climate in EIAs - Elements to consider. ............................................................................... 288
Table 57: EIA Phase Impact Assessment. ............................................................................................................ 310
1473 EIA Report xii

Table 58: Sensitivity rating system. .................................................................................................................... 330
Appendices
Appendix 1: EAP Curriculum Vitae
Appendix 2: Maps
Appendix 3: Public Participation Report
Appendix 4: Specialist Reports
Appendix 5: Environmental Management Programme
Appendix 6: Financial Provision Report
Appendix 7: Tetra4 Well Closure and Rehabilitation Guideline
Appendix 8: Major Hazardous Installation Reports
Appendix 9: Application Form Revision and PASA correspondence
1473 EIA Report xiii

1 EXECUTIVE SUMMARY (NON-TECHNICAL)
This non-technical executive summary provides a high-level overview of this Environmental Impact Assessment
Report. The reader is urged to consult later sections of this report should more specific information or detail be
required on various aspects.
1.1 PROJECT OVERVIEW

Tetra4 (Pty) Ltd (a wholly owned subsidiary of Renergen) holds a Gas Production Right (Ref: 12/4/1/07/2/2) that
was granted in 2012 which spans approximately 187 000 hectares for the development of natural gas production
operations near the town of Virginia in the Free State Province. Within the approval of the Production Right, the
2010 Environmental Management Programme (EMPr) was approved which was applicable to a large portion of
the Production Right area.
On 21 September 2017, the Department of Mineral Resources and Energy (DMRE) issued an integrated
environmental authorisation (“Cluster 1 EA” – reference number 12/04/07) to Tetra4 in terms of the National
Environmental Management Act (Act 107 of 1998 – NEMA) and the National Environmental Management Waste
Act (Act 59 of 2008 – NEMWA). The Cluster 1 EA authorises the development of “Cluster 1” of the Project. In this
EA approval, various new wells and pipelines, booster and compressor stations, a Helium and Liquid Natural Gas
(LNG) Facility and associated infrastructure was approved which comprises the first gas field for development
within the approved Production Right area.
Following the successful commencement of Cluster 1, Tetra4 wishes to expand the natural gas operations, to be
located within the approved production right area and overlapping with the Cluster 1 project. The Cluster 2
application area covers a total of ~27 500 hectares. This planned expansion to the existing approved production
activities will involve up to 300 new production wells, ~480km of gas transmission pipelines and associated
infrastructure, 3 compressor stations and an additional new combined LNG and Liquid Helium (LHe) plant
(“LNG/LHe Plant”) and associated infrastructure as part of the “Cluster 2” expansion of the Project to meet the
future production requirements. This Environmental Impact Assessment Report follows on from the Scoping
Report and is prepared as part of an integrated environmental authorisation and waste management licence for
the Cluster 2 development.
The proposed development infrastructure triggers various listed activities in terms of the NEMA Listing Notices
1, 2 and 3 as well as the National Environmental Management Waste Act (Act 59 of 2008 – NEMWA) and a full
Scoping and Environmental Impact Assessment process is being undertaken. The relevant WUL and AEL
applications are being / will be submitted for the licencing requirements under the NWA and NEMAQA
respectively. As part of this EIA Report, certain amendments have been made to the approved EMPr existing
approved Environmental Management Programme (EMPr) to include the Cluster 2 project as well as required
amendments to mitigation measures that were identified during this assessment process. This amended EMPr
would replace the current approved EMPr for the Production Right and Cluster 1.
1.2 NEED FOR THE PROJECT

Tetra4 has successfully commenced operation of the Cluster 1 Helium and Methane gas production operations
with proven resources gas (Helium and Methane). Helium is one of the most sought-after products to be
produced and processed by the proposed Cluster 2 gas production development. Helium has numerous uses
other than making balloons float which includes medical applications, manufacturing and cryogenics as well as
space travel. Liquid Natural Gas (LNG - Methane) is produced both worldwide and domestically at relatively low
cost and is cleaner burning with lower CO2 emissions than coal, petrol, diesel or propane fuels which currently
dominate the energy production sector in South Africa and many other countries. As Helium and Methane occur
together in the underground reserves, the project will produce both products simultaneously and therefore it is
not possible to target either gas individually.
1473 EIA Report 1

1.3 PROJECT DESCRIPTION AND INFRASTRUCTURE
The Tetra4 Production Right is located within the Virginia Gas Field. Within the Virginia Gas Field geological
profile, major fault systems associated with closely spaced zones of fractures and joints provide for preferential
pathways for gas to reach the surface. Once the gas target areas are intersected by drilling the feed gas will flow
passively out of the wells at a low pressure of ~0.4 psi (pounds per square inch) and with a temperature in the
range between 10 º and 30 ºC. For comparison, the atmospheric pressure at sea level is 14.7 psi which is far
greater than the gas being passively released from this gas field. Due to the very low gas pressure in the wells, a
group of ~10 wells will be linked via underground pipelines to a surface booster station which provides a suction
pressure on the wells to enhance flow. The booster stations then boost the pressure in main underground
transmission pipelines to the compressor stations where the pressure is again increased to transfer the gas via
underground trunklines to the gas processing, storage and distribution plant (LNG/LHe Plant).
DRILLING
Exploration wells will be drilled and, if successful, converted into production wells. As the exact location of
exploration well drilling cannot be identified at this stage owing to the nature of exploration models being
continually refined, this study has followed the approach of assessing well corridors (600 m wide or 300 m on
either side of known target fault lines). Exploration drilling entails the use of a truck, trailer or skid mounted drill
rig to drill to varying depths (~380 m to ~880 m) along known fault lines in order to strike the gas reserve.
Drill rigs typically require temporary clearance or disturbance of an area of 50 m x 50 m to set up the rig and
begin drilling activities which take approximately 3 to 4 months per well. Immediately after the drilling, testing
of the gas volumes and compositions is undertaken which takes approximately 7 to 14 days. All exploration
boreholes must be drilled and cased in accordance with applicable international standards and best practice
guidelines and will be sealed with a combination of steel casing and grouting (cement) to ensure there is no
mixing of gas or deep saline water with the shallower freshwater aquifers.
The drilling of exploration boreholes is a temporary and short-lived activity and the equipment to be used during
drilling activities includes a truck/trailer or skid mounted drill rig, excavator, dozer, grader, water cart, light
motor vehicle for transport of personnel and chemical toilets. Exploration boreholes that are successful (gas
producing) will be turned into production wells by installing a valve within an underground concrete bunker with
a manhole surface area of ~1.5 m2. Unsuccessful exploration wells will be safely decommissioned and
rehabilitated. All wells that are drilled and used for production purposes are strengthened with a combination
of casing and grouting to average depths of 300 m to prevent any interplay between deep and shallow
groundwater resources.
PIPELINES
~480 km of underground gas pipelines will be constructed to link the ~300 production wells to the compressor
stations and LNG/LHe Plant. Pipelines will be a combination of high-pressure steel as well as low-pressure high-
density polyethylene (HDPE) and will be installed at a minimum depth of 1.5 m below surface level. The pipeline
will be installed using a back-actor and TLB. Pipeline servitude corridors (10 m wide) will be maintained free of
woody plants to prevent disturbance of the pipeline by root growth and ensure access by Tetra4 personnel for
regular inspection and infrequent maintenance. Pipelines will be marked with concrete markers and adhere to
industry standards and will have low point drains at strategic locations for testing and pipeline maintenance.
GAS INLINE STATIONS

To transport gas via pipelines from the production wells to the LNG/LHe Plant, various inline infrastructure is
required to monitor, measure and control gas flow through the pipelines and this includes booster stations,
pigging stations, low point drains and compressor stations.
The booster stations will occupy an area of ~10 m x 14 m and a total of 28 booster stations may be constructed.
Inline pigging stations are installed to allow for regular cleaning and inspection of the pipelines near river
crossings. The pigging stations allow for insertion of probes or cleaning “pigs” (plugs) at regular intervals to
perform regular maintenance and in total approximately 14 pig launcher/receiver pairs may be constructed.
1473 EIA Report 2

Raw gas received at the compressor stations will be filtered to remove dust and moisture. Once filtered, the gas
from the compressors will be piped for final processing to the LNG/LHe Plant. A total of 3 compressor stations
will be constructed and the footprint for a compressor station will be approximately 60 m x 60 m.
LNG AND HELIUM PLANT

The LNG/LHe facility is a facility to convert the Helium and Methane into a liquid form for storage before being
transported by road tankers to offtake suppliers. The Cluster 2 LNG/LHe Plant will be constructed directly
adjacent to the existing Cluster 1 plant which is currently under construction on the remaining extent of the
farm Mond Van Doornrivier 38 and adjacent to the R30 Road and the Sandrivier bridge. A Major Hazardous
Installation (MHI) study has been undertaken on the pipelines and plant which concluded that an accidental
release of methane will not impact on any residential area or sensitive receptor.
The LNG/LHe plant comprises of the following process units:
• Gas Treatment and Boosting System;
• Helium Separation Unit;
• Gas Liquefaction System;
• LHe Storage (~2x100 m3);
• LNG Storage (~11x300 m3); and
• LHe and LNG road tanker loading bays.
The area to be occupied by the proposed Cluster 2 LNG/LHe plant in the operational phase is ~9.6 hectares while
an additional ~15.8 hectare area directly adjacent to the Plant will be cleared during the construction phase for
various contractor laydown areas, offices, parking, waste storage, etc. This latter area will be rehabilitated
following construction.
1.4 SPECIALIST STUDIES

Several specialist studies have been commissioned to investigate key issues and impacts and findings from these
studies are included in this report. The specialist study reports are included in Appendix 4. A list of the specialist
studies conducted to inform this EIA process is included below:
• Soils and Agriculture
• Air Quality and Health Risk
• Climate Change and Green House Gas
• Economic
• Financial Provision for Rehabilitation, Decommissioning and Closure
• Geohydrology
• Heritage and Palaeontology
• Hydrology
• Noise
• Social
• Terrestrial Biodiversity
• Visual
• Wetland and Aquatic
1473 EIA Report 3

1.5 IMPACTS IDENTIFIED AND SUMMARY OF IMPACT ASSESSMENT
A list of biophysical and socio-economic impacts that have been identified and assessed during this EIA phase as
well as the pre-mitigation environmental risk, post mitigation environmental risk and final significance when
applying a priority factor is presented below.
Discipline Impact Phase Pre-mitigation ER Post-mitigation ER Final Significance
Air Quality - Increase in air
quality impacts due to
Construction -9 -6.8 -8
construction of the
road/pipeline
construction of the wells and
booster stations
construction of the plant and
compressor stations
Air Quality
quality impacts due to the
Operation -12 -7.5 -8
operation of vehicles on
unpaved roads
operation of the booster
stations
quality impacts due to Operation -7.5 -7.5 -8
operation of the plant
quality impacts due to Decommissioning -11 -7.5 -8
decommissioning and closure
Climate Change risk due to
Construction -8 -7 -9
Climate Scope 1 & 2 construction
Change Climate Change risk due to
Operation -12 -11 -15
Scope 1 & 2 construction
Noise - Increase in noise levels
due to construction of the Construction -11 -7.5 -8
pipeline
due to construction of the Construction -12 -8.3 -8
wells and Blower Stations
due to construction of the
Construction -8.3 -7.5 -8
Noise Plant and Compressor
Stations
due to Blower Station Operation -9 -6 -6
operation
due to Plant and Compressor Operation -9 -6 -6
Station operation
Noise - Increase in noise levels Decommissioning -11 -7.5 -8
Groundwater deterioration
and siltation due to
contaminated stormwater Construction -4 -1.8 -2
run-off from the construction
area.
Poor quality leachate may
emanate from the
Geohydrology construction camp which may Construction -8.3 -4.5 -6
have a negative impact on
groundwater quality.
Mobilisation and maintenance
of heavy vehicle and
machinery on-site may cause Construction -12 -7.5 -9
hydrocarbon contamination of
1473 EIA Report 4

Poor storage and
management of hazardous
chemical substances on-site Construction -8.3 -4.5 -6
may cause groundwater
pollution.
Migration of saline
groundwater from the deep,
fractured aquifer to the
overlying, potable aquifer(s)
during the gas production
phase.
Migration of stray gas from
the deep, fractured aquifer to
the overlying, potable Operation -18 -12 -15
aquifer(s) during the gas
production phase.
Groundwater pollution as a
result of wastewater spills and
seepage from the evaporation
dams.
emanate from the plant
footprint area which may Operation -12 -7.5 -9
Mobilisation and maintenance
of heavy vehicle and
machinery on-site may cause Operation -8.3 -4.5 -6
Poor storage and
management of hazardous
chemical substances on-site Operation -12 -7.5 -9
pollution.
Leakage of harmful
substances from tanks,
pipelines or other equipment Operation -12 -7.5 -9
pollution.
Migration of saline
groundwater from the deep,
fractured aquifer to the
Decommissioning -16 -9 -11
overlying, potable aquifer(s)
during the borehole closure
and decommissioning phase.
Migration of stray gas from
the deep, fractured aquifer to
the overlying, potable Decommissioning -16 -9 -11
aquifer(s) borehole closure
and decommissioning phase.
Groundwater pollution as a
result of wastewater spills and
Decommissioning -6.5 -2.3 -3
seepage from the evaporation
dams.
emanate from the plant
footprint area which may Decommissioning -6.5 -2.3 -3
De-mobilisation of heavy
vehicle and machinery as part
of the decommissioning phase
on-site may cause
Hydrology - Loss of
Hydrology watercourse vegetation
Erosion Construction -6 -3 -3
1473 EIA Report 5

Stormwater contamination Construction -7 -3 -3
Alien and/or Invasive
Vegetation
Alterations of the river banks
and river bed
Erosion Operation -5.5 -2.8 -3
Stormwater contamination Operation -9 -3.5 -4
Operation -9.8 -4 -5
Vegetation
Erosion Decommissioning -5 -2.5 -3
Stromwater contamination Decommissioning -9 -3.5 -4
Vegetation
Impact on unidentified
heritage resources
Impact on burial grounds and
graves
Heritage &
Impact on historic to recent
Palaeontology Construction -11 -6 -8
sites with possible graves
Impact on structures of
Construction 10.5 -5 -6
medium heritage significance
Impact on palaeontology Construction -18 -8 -11
Impact on livelihoods Construction -15 -11 -14
Impact on livelihoods Operation -18 -15 -21
Impact of servitudes on land
values
Uncertainty in terms of land
Planning -16 -8.3 -10
tenure, access control, etc.
Nuisance factor due to
increase in ambient dust and Construction -13 -10 -11
noise levels
Changes in travel patterns Construction -13 -9 -10
Damage to farm roads,
existing services, and Construction -15 -10 -11
infrastructure
Damage to farm roads,
existing services, and Operation -14 -13 -16
infrastructure
Impacts on livelihoods due to
behaviour of contractors
Impacts on safety and security
of local residents
Impacts on safety and security
Social of local residents
impacts on sense and spirit of
place
impacts on sense and spirit of
place
Impacts on the social licence
Construction -12 11 14
to operate
Impacts on the social licence
Operation -15 13 16
to operate
Increase in social pathologies Construction -11 -10 -11
Public perceptions about
safety associated with gas Operation -12 -6.8 -7
production
Contribution to economy of
Operation 22.5 23.8 27
South Africa
Secondary economic
Construction 11 17.5 20
opportunities
Secondary economic
Operation 13 18.8 21
opportunities
Potential opportunity for
education, skills development, Operation 13 18.8 21
and training
Impact on Existing Agricultural
Visual Construction -8 -8 -9
Landscape Character
1473 EIA Report 6

Operation -4 -4 -5
Landscape Character
Landscape Character
Impact on Existing Natural
Landscape Character
Operation -7.5 -3.5 -4
Landscape Character
Decommissioning -5.3 -2 -2
Landscape Character
The visual impact on views
from local roads
from local roads
from local roads
Change of Natural of Views
from Homesteads
Operation -6 -4 -5
from Homesteads
from Homesteads
from local homesteads due to Construction -8 -1 -1
Lighting
from local homesteads due to Operation -11 -1.8 -2
Lighting
from local homesteads due to Decommissioning -8 -1 -1
Lighting
Temporary disturbance of
wildlife due to increased
human presence and possible Planning -3.5 -2 -2
use of machinery and/or
vehicles.
Destruction, further loss and
fragmentation of the Construction -11 -9 -11
vegetation community
Introduction of alien species,
Construction -7.5 -6 -7
especially plants
Erosion due to storm water
runoff and wind
Displacement of faunal
community due to habitat
loss, direct mortalities and
disturbance (road collisions,
noise, light, dust, vibration
and poaching).
Environmental pollution due
Terrestrial
to potential leaks, discharges,
pollutant leaching into the
surrounding environment
Continued fragmentation,
further loss and
fragmentation of the
vegetation community
Vegetation loss due to erosion
and encroachment by alien Operation -8.3 -4.5 -5
invasive plant species
Potential leaks, discharges,
pollutant from activities
leaching into the surrounding
environment
Continued displacement and
fragmentation of the faunal
community (including Operation -12 -5.5 -6
threatened or protected
species) due to ongoing
1473 EIA Report 7

anthropogenic disturbances
(noise, dust and vibrations)
and habitat degradation/loss
(litter, road mortalities and/or
poaching).
Continued encroachment of
vegetation community by
alien invasive plant species as Decommissioning -7.5 -4.5 -5
well as erosion due to
disturbed soils
Continued displacement and
fragmentation of the faunal
community (including
potential threatened or
protected species) due to Decommissioning -7.5 -4.5 -5
ongoing habitat
degradation/loss
(infringement, litter, road
mortalities and/or poaching).
Construction of compressors
and wells
Construction of pipelines and
transmission loop
Operation of Compressor and
Wells
Hydropedology
Operation of pipelines and
transmission loop
Decommissioning of
Compressors and Wells
Decommissioning of pipelines
and transmission loop
Exploration Wells - Habitat Planning -4 -2.3 -3
Exploration Wells - Water
Planning -4 -2.3 -2
Quality
Exploration Wells - Flow Planning -3 -1.5 -2
Pipelines and Transmission
loop - Habitat
loop - Water Quality
loop - Flow
Compressors Station CS1 -
Habitat
Water Quality
Flow
Habitat
Wetlands Compressors Station CS1 -
Water Quality
Flow
Compressors CS2 - Habitat Construction -4 -4 -5
Compressors CS2 - Water
Quality
Compressors CS2 - Flow Construction -3 -3 -3
Compressors CS3 - Habitat Construction -3.8 -3 -3
Quality
Compressors CS3 - Habitat Construction -4 -4 -5
Quality
Powerlines - Habitat Construction -5.5 -3 -3
Powerlines - Water Quality Construction -2 -1.3 -1
Powerlines - Flow Construction -2.5 -1.3 -1
1473 EIA Report 8

Access Roads - Habitat Construction -4.5 -3 -3
Access Roads - Water Quality Construction -6.8 -4 -4
Access Roads - Flow Construction -3.5 -2 -2
LNG/LHe Plant - Habitat Construction -4 -3 -3
LNG/LHe Plant - Water Quality Construction -3.5 -2.5 -3
LNG/LHe Plant - Flow Construction -3 -2.5 -3
loop - Habitat
Operation -3 -1 -1
loop - Flow
Habitat
Water Quality
Operation -4 -4 -4
Flow
Habitat
Water Quality
Operation -3 -1 -1
Flow
Compressors CS2 - Habitat Operation -8.3 -3 -3
Operation -3 -2 -2
Quality
Compressors CS2 - Flow Operation -4.5 -2 -2
Quality
Compressors CS3 - Flow Operation -4 -4 -4
Quality
Compressors CS3 - Flow Operation -4 -4 -4
Powerlines - Habitat Operation -5 -3.5 -4
Powerlines - Water Quality Operation -1 -1 -1
Powerlines - Flow Operation -1 -1.3 -1
Access Roads - Habitat Operation -9 -4.5 -5
Access Roads - Water Quality Operation -5 -4 -4
Access Roads - Flow Operation -5 -3.5 -4
LNG/LHe Plant - Habitat Operation -4.5 -4 -4
LNG/LHe Plant - Water Quality Operation -3.5 -3.5 -4
LNG/LHe Plant - Flow Operation -3 -3.5 -4
loop - Habitat
loop - Flow
Habitat
Water Quality
Flow
Habitat
Water Quality
Decommissioning -3 -2.5 -3
Flow
Compressors CS2 - Habitat Decommissioning -4 -4 -5
Quality
Compressors CS2 - Flow Decommissioning -3 -3 -3
Compressors CS3 - Habitat Decommissioning -3.8 -3 -3
1473 EIA Report 9

Quality
Compressors CS3 - Habitat Decommissioning -4 -4 -5
Quality
Powerlines - Habitat Decommissioning -5 -3 -3
Powerlines - Water Quality Decommissioning -2 -1.3 -1
Powerlines - Flow Decommissioning -2.5 -1.3 -1
Access Roads - Habitat Decommissioning -4.5 -3 -3
Access Roads - Water Quality Decommissioning -6 -4 -4
Access Roads - Flow Decommissioning -3.5 -2 -2
LNG/LHe Plant - Habitat Decommissioning -4 -3 -3
LNG/LHe Plant - Water Quality Decommissioning -3.5 -2.5 -3
LNG/LHe Plant - Flow Decommissioning -3 -2.5 -3
GGP Impact Construction 16 16 18
Employment Impacts Construction 13 13 15
Forex savings Construction -9.8 -9.8 -11
Fiscal Income Construction 12 12 14
Economic development per
Construction 15 15 17
capita
Country and Industry
Competitiveness
Black Economic
Transformation
Alternative Land-use Construction 8.75 8.75 10
Need and Desirability Construction 15 15 17
Impact on individual farmland
values
GGP Impact Operation 23.8 23.8 33
Employment Impacts Operation 17 17 23
Forex savings Operation 18 18 25
Fiscal Income Operation 17 17 23
Operation 17 17 23
capita
Operation 20 20 28
Competitiveness
Black Economic
Operation 16 16 22
Transformation
Alternative Land-use Operation 11.3 11.3 15
Economic
Need and Desirability Operation 20 20 28
Operation -9 -9 -12
values
GGP Impact Decommissioning -13 -13 -13
Employment Impacts Decommissioning -13 -13 -13
Forex savings Decommissioning -23 -23 -23
Fiscal Income Decommissioning -23 -23 -23
capita
Competitiveness
Black Economic
Transformation
Alternative Land-use Decommissioning -15 -15 -15
Need and Desirability Decommissioning -15 -15 -15
Decommissioning 8.25 8.25 8
values
GGP Impact Rehab and closure -23 -23 -23
Employment Impacts Rehab and closure -23 -23 -23
Forex savings Rehab and closure -23 -23 -23
Fiscal Income Rehab and closure -23 -23 -23
Rehab and closure -23 -23 -23
capita
Competitiveness
1473 EIA Report 10

Black Economic
Transformation
Alternative Land-use Rehab and closure -19 -19 -19
Need and Desirability Rehab and closure -18 -18 -18
Rehab and closure 8.25 8.25 8
values
1.6 PUBLIC PARTICIPATION

The public participation process for this application has been undertaken in accordance with the requirements
of the NEMA EIA Regulations, and in line with the principles of Integrated Environmental Management (IEM).
IEM implies an open and transparent participatory process, whereby stakeholders and other I&APs are afforded
an opportunity to comment on the project and have their views considered and included as part of project
planning.
The PPP commenced on 20 May 2022 with an initial notification and call to register for a minimum period of 30
days. The initial notification was undertaken in English, Afrikaans and Sesotho and was given in the following
manner:
• Registered letters, faxes, emails and sms’s: Notification were distributed to all pre-identified I&APs
including government organisations, NGOs, relevant municipalities, ward councillors, landowners and
other organisations that may be interested or affected.
• Advertisements describing the proposed project and EIA process were published in the Vista
Newspaper with circulation in the vicinity of the study area. The initial advertisements were placed in
the Vista newspaper in English, Afrikaans and Sesotho on the 19 May 2022 with a government gazette
published (also in 3 languages) on 1 July 2022.
• A1 Correx site notices in English, Afrikaans and Sesotho were placed at 78 locations within and around
the application area from 16 May 2022 to 19 May 2022.
• A3 posters in English, Afrikaans and Sesotho were placed at local public gathering places in Welkom,
Theunissen and Virginia (Welkom Public Library, Retail Spar, Retail Pick n Pay, Virginia Public Library,
Theunissen Magistrates Court and Masilo (Theunissen) Public Library).
Subsequent to the call to register notification, the scoping report was made available to registered I&APs in the
following manner:
• Registered letters with details on where the scoping report can be obtained and/or reviewed, public
meeting date and time, EIMS contact details as well as the public review comment period;
• Facsimile notifications with information similar to that in the registered letter described above;
• Email notifications with a letter attachment containing the information described above; and/or
• SMS notifications to inform I&APs of the Scoping Report availability and where additional information
could be obtained in order to participate.
The scoping report was made available for public review from 29 July 2022 to 30 August 2022 for a period of at
least 30 days. During the Scoping Report public review period open days and meetings were held with I&AP’s as
follows:
• Tuesday 23 August 2022: Community Meeting (Stilte Primary School) 12H00-14H00
• Tuesday 23 August 2022: Community Meeting (Adamsons Vley Primary School) 16H00-18H00
• Wednesday 24 August 2022: Farmers Focus Group Open Day (Goldfields Game Ranch) 10H00-16H00
• Wednesday 24 August 2022: Farmers Focus Group Public Meeting (Goldfields Game Ranch) 17H00-
19H00
1473 EIA Report 11

• Thursday 25 August 2022: Public Open Day (NG Church Virginia) 10H00-17H00
A summary of the comments received to date as well as how these comments were addressed is provided below.
Table 1: Summary of comments received to date and how comments were addressed.
Comment Summary How comment was addressed
Concerns of water availability and quality to farmers The geohydrological specialist and air quality
and air quality impacts of the proposed project. specialist reports have assessed the impact on water
quality and availability as well as the air quality
impacts (including health risks).
I&AP deregistration requests. I&APs who formally requested to be registered were

removed from the database.
I&AP registration requests. I&APs who formally requested to be registered were

added to the database for further notifications during
upcoming application comment periods.
Eskom Holdings SOC Limited (Transmission) The requested information was shared with Eskom.
requested a Google Earth (.kmz) file.
Notification of ongoing Oryx Solar Power Plant PV Tetra4 and EIMS have taken note of this application
Authorization application from another EAP for a PV project within the Cluster 2 application area
(Environamics) within Cluster 2 project area, locality and note that there is minimal impact on the project
map sharing and BID documents, Scoping Report as a whole.
and recently EIA report for comment.
Some individuals as well as contractors have Work seekers (be it individual jobs or contractors)
expressed their interest in potential employment have been directed to the Tetra4 website which
and business opportunities from the proposed contains a link for interested vendors etc. Community
development. members seeking employment (jobs) were informed
of the Tetra4 personnel who are responsible for
collecting CV’s, ID’s etc to ensure that their interest is
captured. All job or contract seekers were informed
that the application is still underway and that the
project commencement is dependent on the final
decision from the PASA/DMRE.
Transnet commented that the proposed No further actions required.

development does not affect their pipeline
servitudes in the region.
SAHRA provided an interim comment that a The HIA and EIA report will be uploaded to the
comment is to be provided once a HIA and draft EIA SAHRIS website once the EIA comment period
Report are made available for comment. commences.
Note: this has been uploaded.
Query regarding website document accessibility. EIMS provided the needed assistance with obtaining
the relevant documentation which was resolved
satisfactorily.
Requests by certain members of the local These comments were raised during the community
community for jobs as well as other specific services focus group meeting with the Adamsons Vley
such as electricity, skills upliftment, etc. community. The community was informed that
Tetra4 is currently in the process of providing certain
1473 EIA Report 12

basic services such as water and electricity to the
community as part of the Social and Labour Plan
commitments. This is an ongoing process throughout
the project implementation and would be extended
to other communities in due course. The community
acknowledged that the water and solar electricity
project was currently underway in their community.
Concerns by a local NGOs - Vaal Environmental It was confirmed that Tetra4 was aware of the poor
Justice Alliance (VEJA) and Gold and Uranium Belt living standards of some communities and therefore
Impact Sensoring Organisation – GUBICO about the as part of the SLP commitments, certain upliftment
living standards of the community members. programs had been initiated and were ongoing.
NGO - Vaal Environmental Justice Alliance (VEJA) Clarification was provided that Tetra4 is a wholly
highlighted the possible confusion regarding Tetra4 owned subsidiary of Renergen and whilst the
vs Renergen and how the two companies relate to applicant in this application is Tetra4, this does not
this project as the sign outside the existing plant pose any legal constraints on the project. This report
says Renergen however the applicant in the includes a clear statement that Tetra4 is a wholly
application is Tetra4. owned subsidiary of Renergen.
Concerns that impact on landowners seem to have All specialists have been provided with this comment
been underestimated. and have considered this comment in light of their
preliminary impact assessment findings. This has
been thoroughly considered and assessed by the
relevant specialists as well as the EAP in this EIA
Report with minor amendments to certain impacts.
Additional mitigation measures have been put
forward to fully address the impact findings.
Concerns regarding the project’s impacts on the These safety, livelihoods and land value concerns
safety, livelihoods and land value for landowners. have been given specific attention in this EIA report
and detailed mitigation measures to address these
concerns have been included. In addition, specific
conditions have been put forward for inclusion in the
decision to ensure that priority is given to impacts on
safety, livelihoods and land value. Lastly, Tetra4 has
revised the landowner contract terms to provide
more specific attention to these concerns including
annual compensation for the life of the project (per
hectare rate), commitments to hold specific
negotiations with each affected landowner to ensure
infrastructure is sited in such a manner so as to
minimise impacts on existing land use and lastly to
ensure that all reasonable safety measures are
continually in place.
Access road degradation concerns from Degradation of access roads has been thoroughly
landowners. considered and mitigated in this report and
associated EMPr. This includes a pre-construction
survey by the landowner and Tetra4 of all private
access roads to be utilised by the project including
photographic and video documentation of the pre-
construction state. A similar post construction survey
will be undertaken to document any degradation of
1473 EIA Report 13

access roads which if identified, will be to Tetra4s
account. It is acknowledged that each landowner has
a specific access road construction methodology and
this will be documented and complied with if any
repairs are required.
Request by a landowner for more detail on Where possible, infrastructure specific locations or at
infrastructure specific location and timing of the least limitations to where infrastructure will not be
project aspects. located has been provided in the Scoping Report and
this EIA Report. The project description has been
reviewed and updated where possible to include
more information on location and timing of certain
activities.
Request by a landowner for more detail on logistics Following this concern relating to the initial
regarding access and maintenance of Tetra4 landowner contract, Tetra4 have undertaken a
infrastructure on farmlands as well as contractual revision of the contract to be more specific in
concerns. addressing the various landowner concerns. Tetra4
shall share a copy of the revised contract with the
relevant landowners.
In terms of access for inspections and maintenance
during the operational phase, the expected
frequency is as follows:
• Production wells: Monthly (worst case)
• Pipeline Servitude: Annually for inspections unless
landowner raises concerns or there is an
emergency (leak detected).
• Booster Station: Monthly
• Low Point Drains: Monthly
• Pigging Stations: Six monthly (bi-annually)
• Compressor Stations: Daily security inspections.
Concerns from a landowner that this project would Whilst EIMS was not able to engage this landowner
negatively impact on his farm which is his primary further during the scoping phase, attempts will be
investment for his future as well as his descendants. made to have further engagement during the EIA Commented [BW1]: Update?
This landowner did not wish to discuss anything and phase to discuss how the project would be
wished to state that he is opposed to the project. implemented in direct consultation and negotiations
with the landowner.
1.7 IMPACT STATEMENT

The findings of the specialist studies conclude that there are no environmental fatal flaws that should prevent
the proposed project from proceeding, provided that the recommended mitigation and management measures
are implemented. Based on the nature and extent of the proposed project, the limited level of disturbance
predicted as a result of the production activities, the findings of the specialist studies, and the understanding of
the significance level of potential environmental impacts, it is the opinion of the EIA project team and the EAP
that the significance levels of the majority of identified negative impacts can generally be reduced to an
acceptable level by implementing the recommended mitigation measures and the project should be authorized
and that compliance with the EMPr must be strictly adhered to.
1473 EIA Report 14

2 INTRODUCTION
Tetra4 (Pty) Ltd holds a Gas Production Right (Ref: 12/4/1/07/2/2) that was granted in 2012 which spans
approximately 187 000 hectares for the development of natural gas production operations around the town of
Virginia in the Free State Province. Within the approval of the Production Right, the 2010 Environmental
Management Programme (EMPr) was approved and was applicable to a large portion of the Production Right
area.
On 21 September 2017, the Department of Mineral Resources and Energy (DMRE) issued an integrated
environmental authorisation (“Cluster 1 EA” – reference number 12/04/07) to Tetra4 in terms of the National
Environmental Management Act (Act 107 of 1998 – NEMA). The Cluster 1 EA (amended on 26 August 2019 and
1 September 2020) authorises the development of “Cluster 1” of the Project. In this EA approval, various new
production wells and pipelines, booster and compressor stations, a Helium and LNG Facility and associated
infrastructure was approved which comprises the first gas field for development within the approved Production
Right area. The Cluster 1 EA also authorises certain waste management activities as per the List of Waste
Management Activities (Government Notice 921, as amended) published under the National Environmental
Management: Waste Act 59 of 2008 (NEMWA).
Furthermore, the following licences have been issued to Tetra4 in respect of Cluster 1 of the Project:
• Atmospheric Emission Licence (AEL) dated 15 July 2022 (reference: LDM/AEL/YMK/014) for the Storage
and Handling of Petroleum Products [Category 2: Subcategory 2.4 of the Listed Activities (Government
Notice 893, as amended) published under the National Environmental Management: Air Quality Act 39
of 2004 (NEMAQA)] by the Lejweleputswa District Municipality; and
• Water Use Licence (WUL) dated 22 January 2019 (reference: 08/C42K/CI/8861) for the construction of
pipelines for the Project in terms of section 21(c&i) water uses of the National Water Act 36 of 1998
(NWA) by the Department of Water and Sanitation (DWS).
Following the successful commencement of Cluster 1 (which is now operational in 2022), Tetra4 aim to expand
the natural gas operations, to be located within the approved production right area and around the Cluster 1
project, to be designated as ‘Cluster 2’. This Cluster 2 application area covers a total of ~27 500 hectares which
overlaps with a large part of the Cluster 1 area. This planned expansion to the existing approved production
activities will involve up to 300 new production wells, ~480km of gas transmission pipelines and associated
infrastructure, 3 compressor stations, and an additional new combined Liquid Natural Gas (LNG) and Liquid
Helium (LHe) plant (“LNG/LHe Plant”) and associated infrastructure as part of the “Cluster 2” expansion of the
Project in order to meet the future production requirements. This EIA Report is prepared as part of an integrated
environmental authorisation and waste management licence for the Cluster 2 development.
The proposed development infrastructure triggers various listed activities in terms of the NEMA Listing Notices
1, 2 and 3 as well as the National Environmental Management Waste Act (Act 59 of 2008 – NEMWA) and a full
Scoping and Environmental Impact Assessment process is required. The relevant WUL and AEL applications are
being submitted for the triggers under the NWA and NEMAQA respectively. The culmination of this study and
application process is an amendment to the existing approved Environmental Management Programme (EMPr)
to include the Cluster 2 activities and relevant updates to the impact management actions. This will provide for
a single environmental management plan that covers the previously approved Production Right activities
(exploration), Cluster 1 activities and now also Cluster 2 activities. An MPRDA Section 102 amendment of the
EMPr will be applied for on completion of the NEMA and NEMWA integrated application process.
1473 EIA Report 15

2.1 REPORT STRUCTURE
This report has been compiled in accordance with the 2014 NEMA EIA Regulations, as amended. An overview of the report legislative requirements for this report and the
specific sections that correspond to the applicable requirements, is provided in Table 2 below.
Table 2: Report structure in terms of Appendix 3 of the NEMA EIA Regulations
Environmental Regulation Description – NEMA Regulation 982 (2014) as amended Section in Report
Appendix 3(1)(a): Details of – Section 2.2

i. The EAP who prepared the report; and Appendix 1
ii. The expertise of the EAP, including a curriculum vitae;
Appendix 3(1)(b): The location of the development footprint of the activity on the approved site as contemplated in the Section 3 and 4
accepted scoping report, including:
i. The 21-digit Surveyor General code of each cadastral land parcel;
ii. Where available, the physical address and farm name;
iii. Where the required information in items (i) and (ii) is not available, the coordinates of the
boundary of the property or properties;
Appendix 3(1)(c): A plan which locates the proposed activity or activities applied for as well as the associated structures Section 4
and infrastructure at an appropriate scale, or, if it is-
i. A linear activity, a description and coordinates of the corridor in which the proposed activity
or activities is to be undertaken; or
ii. On a land where the property has not been defined, the coordinates within which the activity
is to be undertaken;
Appendix 3(1)(d): A description of the scope of the proposed activity, including – Section 4 and 4.2
i. All listed and specified activities triggered and being applied for; and
ii. A description of the associated structures and infrastructure related to the development;
Appendix 3(1)(e): A description of the policy and legislative context within which the development is located and an Section 5
explanation of how the proposed development complies with and responds to the legislation and policy
context;
1473 EIA Report 16

Appendix 3(1)(f): A motivation for the need and desirability for the proposed development, including the need and Section 6
desirability of the activity in the context of the preferred development footprint within the approved
site as contemplated in the accepted scoping report;
Appendix 3(1)(g): A motivation for the preferred development footprint within the approved site as contemplated in the Section 4, 7 and 10, 13.2
accepted scoping report;
Appendix 3(1)(h): A full description of the process followed to reach the proposed development footprint within the Section 7, 8, 9 and 10
approved site as contemplated in the accepted scoping report, including–
i. Details of the development footprint alternatives considered;
ii. Details of the public participation process undertaken in terms of regulation 41 of the
Regulations, including copies of the supporting documents and inputs;
iii. A summary of the issues raised by interested and affected parties, and an indication of the
manner in which the issues were incorporated, or the reasons for not including them;
iv. The environmental attributes associated with the development footprint alternatives focusing
on the geographical, physical, biological, social, economic, heritage and cultural aspects;
v. The impacts and risks identified including the nature, significance, consequence, extent,
duration and probability of the impacts, including the degree to which these impacts –
a. Can be reversed;
b. May cause irreplaceable loss or resources; and
c. Can be avoided, managed or mitigated;
vi. The methodology used in determining and ranking the nature, significance, consequences,
extent, duration and probability of potential environmental impacts and risks;
vii. Positive and negative impacts that the proposed activity and alternatives will have on the
environment and on the community that may be affected focusing on the geographical,
physical, biological, social, economic, heritage and cultural aspects;
viii. The possible mitigation measures that could be applied and level of residual risk;
ix. If no alternative development footprints for the activity were investigated, the motivation for
not considering such; and
x. A concluding statement indicating the location of the preferred alternative development
footprint within the approved site as contemplated in the accepted scoping report;
1473 EIA Report 17

Appendix 3(1)(i): A full description of the process undertaken to identify, assess and rank the impacts the activity and Section 7, 8, 9 and 10
associated structures and infrastructure will impose on the preferred development footprint on the
approved site as contemplated in the accepted scoping report through the life of the activity, including-
i. A description of all environmental issues and risks that were identified during the
environmental impact assessment process; and
ii. An assessment of the significance of each issue and risk and an indication of the extent to
which the issue and risk could be avoided or addressed by the adoption of mitigation
measures;
Appendix 3(1)(j): An assessment of each identified potentially significant impact and risk, including- Section 10
i. Cumulative impacts;
ii. The nature, significance and consequences of the impact and risk;
iii. The extent and duration of the impact and risk;
iv. The probability of the impact and risk occurring;
v. The degree to which the impact and risk can be reversed;
vi. The degree to which the impact and risk may cause irreplaceable loss of resources; and
vii. The degree to which the impact and risk can be mitigated;
Appendix 3(1)(k): Where applicable, a summary of the findings and recommendations of any specialist report complying Section 13
with Appendix 6 to these Regulations and an indication as to how these findings and recommendations
have been included in the final assessment report
Appendix 3(1)(l): An environmental impact statement which contains- Section 13.3

i. A summary of the key findings of the environmental impact assessment:
ii. A map at an appropriate scale which superimposes the proposed activity and its associated
structures and infrastructure on the environmental sensitivities of the preferred development
footprint on the approved site as contemplated in the accepted scoping report indicating any
areas that should be avoided, including buffers; and
iii. A summary of the positive and negative impacts and risks of the proposed activity and
identified alternatives.
1473 EIA Report 18

Appendix 3(1)(m): Based on the assessment, and where applicable, recommendations from specialist reports, the Section 13.4
recording of proposed impact management outcomes for the development for inclusion in the EMPr
as well as for inclusion as conditions of authorisation;
Appendix 3(1)(n): The final proposed alternatives which respond to the impact management measures, avoidance, and Section 13.2
mitigation measures identified through the assessment;
Appendix 3(1)(o): Any aspects which were conditional to the findings of the assessment either by the EAP or specialist Section 13
which are to be included as conditions of authorisation;
Appendix 3(1)(p): A description of any assumptions, uncertainties and gaps in knowledge which relate to the assessment Section 14
and mitigation measures proposed;
Appendix 3(1)(q): A reasoned opinion as to whether the proposed activity should or should not be authorised, and if the Section 13
opinion is that it should be authorised, any conditions that should be made in respect of that
authorisation;
Appendix 3(1)(r): Where the proposed activity does not include operational aspects, the period for which the N/A
environmental authorisation is required and the date on which the activity will be concluded and the
(Operational phase is anticipated
post construction monitoring requirements finalised;
to be 20 years)
Appendix 3(1)(s) An undertaking under oath or affirmation by the EAP in relation to- Section 15
i. The correctness of the information provided in the reports; Section 16
ii. The inclusion of comments and inputs from stakeholders and I&APs;
iii. The inclusion of inputs and recommendations from the specialist reports where relevant; and
iv. Any information provided by the EAP to interested and affected parties and any responses by
the EAP to comments or inputs made by interested or affected parties;
Appendix 3(1)(t): [Para. (t) substituted by GN 326/2017 and deleted by GN 517/2021] N/A
Appendix 3(1)(u): An indication of any deviation from the approved scoping report, including the plan of study, including- N/A - No deviations from the
approved Scoping Report.
1473 EIA Report 19

i. Any deviation from the methodology used in determining the significance of potential
environmental impacts and risks; and
ii. A motivation for the deviation;
Appendix 3(1)(v): Any specific information that may be required by the competent authority; and In terms of the Scoping Report
approval letter from DMRE:
1. Financial provision to be
determined according to the
Regulations Pertaining to
Financial Provisions for
Prospecting, Exploration,
Mining or Production
Operations (2015); and
2. The Provincial Department of
Environmental Affairs must be
included in the Public
Participation process to solicit
comment.
The Financial Provision Report is
included in Appendix 6 and effort
will be made to obtain comment
from the Provincial Department of
Environmental Affairs during the
PPP.
Appendix 3(1)(w): Any other matters required in terms of section 24(4)(a) and (b) of the Act. N/A – no further matters to those
already listed above and included
in this report.
1473 EIA Report 20

2.2 DETAILS OF THE EAP
EIMS is appointed by Tetra4 to assist in preparing and submitting the integrated EA and WML application,
Scoping and EIA Reports, and undertaking a Public Participation Process (PPP) in support of the proposed Cluster
2 Gas Production EA Application. EIMS is a private and independent environmental management-consulting firm
that was founded in 1993. EIMS has in excess of 28 years’ experience in conducting EIA’s, including EIA’s relating
to gas exploration and production operations.
In terms of Regulation 13 of the EIA Regulations (GNR 982) as amended, an independent EAP, must be appointed
by the applicant to manage the application. EIMS and the compiler of this report are compliant with the
definition of an EAP as defined in Regulations 1 and 13 of the EIA Regulations, as well as Section 1 of the NEMA.
This includes, inter alia, the requirement that EIMS is:
• Objective and independent;
• Has expertise in conducting EIA’s;
• Comply with the NEMA, the environmental regulations and all other applicable legislation;
• Considers all relevant factors relating to the application; and
• Provides full disclosure to the applicant and the relevant environmental authority.
The details of the EIMS consultant (EAP) who compiled this Report are as follows:
Table 3: EAP Details.
Name Brian Whitfield
Tel No: +27 11 789 7170
Fax No: +27 86 571 9047
E-mail: Tetracluster2@eims.co.za
• Professional Natural Scientist with the South African Council for Natural Scientific
Professional
Professions - SACNASP (400447/13).
Registrations:
• Registered EAP with the Environmental Assessment Practitioners Association of
South Africa - EAPASA (2022/4496).
Brian is a senior project manager at EIMS and has over 18 years of experience in environmental consulting. He
holds a BSc (Botany and Zoology) and a BSc Honours degree in Botany from the University of the Witwatersrand.
Brian’s broad range of experience includes managing and/or undertaking projects in various sectors, including
Energy, Mining, Oil & Gas, Water and Infrastructure. He is conversant with the South African environmental
legislation as well as sustainability auditing, including Equator Principles, IFC Performance Standards and World
Bank EHS guidelines. Brian’s other experience includes Site Assessments, Water-use licensing, Environmental
Monitoring and Auditing, Due Diligence Assessments, Competent Persons Reporting, Environmental
Management Plans and Strategic Environmental Assessments. The Curriculum Vitae of the EAP included in
Appendix 1.
2.3 SPECIALISTS
As part of this EIA application, several specialist studies have been commissioned to investigate key impacts that
require further investigation. A list of the specialist studies is included in Table 4.
1473 EIA Report 21

Table 4: List of specialist studies to inform this EIA application.
Specialist Discipline Company/Organisation
Agriculture and Hydropedology The Biodiversity Company
Air Quality & Health Risk & GHG/Climate Change Airshed Planning Professionals
Economic Strategy4Good
Financial Provision update MineLock Environmental Engineers
Geohydrology Gradient Groundwater Consulting
Heritage and Palaeontology PGS Heritage
Hydrology SMEC South Africa
Noise Airshed Planning Professionals
Social Equispectives Research and Consulting Services
Terrestrial Biodiversity The Biodiversity Company
Visual Environmental Planning and Design
Wetland and Aquatic The Biodiversity Company
The specialist studies involved the gathering of data relevant to identifying and assessing environmental impacts
that may occur as a result of the proposed project. These impacts were assessed according to pre-defined impact
rating methodology detailed in Section 10.1. Mitigation / management measures to minimise potential negative
impacts or enhance potential benefits are put forward in this EIA Report and have considered the public input
and specialist final considerations of all available information to date. The specialist reports are included in
Appendix 4.
1473 EIA Report 22

3 DESCRIPTION OF THE PROPERTY
Details of the application area, the location as well as the properties are included in Table 5 below.
Table 5: Locality details.
Farm Names The application area covers a number of farm portions and whilst not all portions of
parent farms are necessarily included in this application a summary of the parent farm
names is presented below for ease of reference:
Adamsons Vley No. 655, Annex Glen Ross No. 562, Annex Grusde No. 474, Annex
Mooivlakte No. 208, Blaauwdrift No. 188, Bloemhoek No. 509, Boschluis Spruit No.
278, Braklaagte No. 41, Brakspruit No. 121, Bruintjies Hoogte No. 367, Bryan No. 561,
Cabriere No. 215, Carlo No. 596, Damplaats No. 341, Dankbaarheid No. 16, De Klerks
Kraal No. 231, Die Mond No. 479, Digito No. 642, Doorn River No. 330, Doorndeel No.
236, Enkeldoorn No. 360, Frisgewaag No. 550, Glen Ross No. 734, Grusde No. 229,
Hakkies No. 695, Hakkies No. 742, Harmonie No. 579, Helpmekaar No. 47, Jonkers
Rust No. 72, Jordaan No. 1, Jordaans Rust No. 59, Kaalpan No. 65, Kalkoenkrans No.
225, Klein Palmiet Kuil No. 407, Klein Pan No. 320, Kleinbegin No. 134, Kovno No. 235,
Langlaagte No. 110, Leeuwaarden No. 171, Leeuwbult No. 52, Leeuwbult No. 580,
Lekkerlewe No. 643, Middelplaas No. 583, Mond Van Doornrivier No. 38, Mooifontein
No. 639, Mooivlakte No. 199, Mooivlei No. 357, Nortier No. 361, Palmietkuil No. 548,
Palmietkuil No. 328, Paulina No. 470, Richelieu No. 135, Rondehoek No. 200, Siberia
No. 464, Spoorleggerswoning 54 No. 167, Stille Woning No. 703, Terra Blanda No. 155,
Toulon No. 368, Vaalbank No. 190, Vlakpan No. 358, Welgelegen No. 382, Weltevrede
No. 638, Weltevreden No. 443, Zoetendal No. 243, Zonderzorg No. 342, Zonderzorg
No. 640
Application Area The Cluster 2 application area covers a total of ~27 500 hectares.
(Ha)
Magisterial District The proposed project falls within the Masilonyana and Matjhabeng Local
Municipalities, in the Lejweleputswa District Municipality, Free State Province.
Distance and The site boundary is ~5km south west of the town of Virginia, ~9km south the town
direction from of Welkom and ~16km north of the town of Theunissen. The geographic coordinates
nearest towns
at the approximate centre of the application area are 28°10'20.47"S and
26°43'50.79"E.
Farm Name, Farm Name, Number and Portion 21 Digit Surveyor General Code
Number and Portion Adamsons Vley 655 (Portion 0) F03500000000065500000
as well as 21-digit Adamsons Vley 655 (Portion 1) F03500000000065500001
Surveyor General Adamsons Vley 655 (Portion 2) F03500000000065500002
Code Annex 3 No 478 (Portion 0) F03300000000047800000
Annex Glen Ross 562 (Portion 0) F03300000000056200000
1473 EIA Report 23

Annex Grusde 474 (Portion 0) F03300000000047400000
Annex Mooivlakte 208 (Portion 0) F03300000000020800000
Annex Welgelegen No 76 (Portion 0) F03300000000007600000
Bethel No 96 (Portion 0) F03300000000009600000
Blaauwdrift 188 (Portion 2) F03300000000018800002
Blaauwdrift 188 (Portion 3) F03300000000018800003
Bloemhoek 509 (Portion 0) F03300000000050900000
Boschkop No 227 (Portion 4) F03300000000022700004
Boschkop No 227 (Portion 5) F03300000000022700005
Boschluis Spruit 278 (Portion 0) F03300000000027800000
Braklaagte 41 (Portion 0) F03300000000004100000
Braklaagte 41 (Portion 1) F03300000000004100001
Brakspruit 121 (Portion 0) F03300000000012100000
Bruintjes Hoogte 367 (Portion 0) F03300000000036700000
Bryan 561 (Portion 0) F03300000000056100000
Bryan 561 (Portion 1) F03300000000056100001
Bryan 561 (Portion 10) F03300000000056100010
Bryan 561 (Portion 11) F03300000000056100011
Bryan 561 (Portion 18) F03300000000056100018
Bryan 561 (Portion 19) F03300000000056100019
Bryan 561 (Portion 21) F03300000000056100021
Bryan 561 (Portion 22) F03300000000056100022
Bryan 561 (Portion 23) F03300000000056100023
Bryan 561 (Portion 26) F03300000000056100026
Bryan 561 (Portion 27) F03300000000056100027
Bryan 561 (Portion 28) F03300000000056100028
Bryan 561 (Portion 29) F03300000000056100029
1473 EIA Report 24

Bryan 561 (Portion 32) F03300000000056100032
Bryan 561 (Portion 33) F03300000000056100033
Bryan 561 (Portion 34) F03300000000056100034
Bryan 561 (Portion 35) F03300000000056100035
Bryan 561 (Portion 36) F03300000000056100036
Bryan 561 (Portion 37) F03300000000056100037
Bryan 561 (Portion 38) F03300000000056100038
Bryan 561 (Portion 39) F03300000000056100039
Bryan 561 (Portion 40) F03300000000056100040
Bryan 561 (Portion 41) F03300000000056100041
Bryan 561 (Portion 46) F03300000000056100046
Bryan 561 (Portion 6) F03300000000056100006
Cabriere 215 (Portion 0) F03300000000021500000
Carlo 596 (Portion 0) F03300000000059600000
Clewer No 104 (Portion 1) F03300000000010400001
Commericia No 430 (Portion 0) F03300000000043000000
Damplaats 341 (Portion 0) F03300000000034100000
Dankbaarheid 16 (Portion 0) F03300000000001600000
Dayton No 560 (Portion 0) F03300000000056000000
De Klerks Kraal 231 (Portion 0) F03300000000023100000
Die Mond 479 (Portion 0) F03300000000047900000
Die Mond 479 (Portion 1) F03300000000047900001
Digito 642 (Portion 0) F03300000000064200000
Doorn River 330 (Portion 0) F03300000000033000000
1473 EIA Report 25

Doorndeel 236 (Portion 0) F03300000000023600000
Doorndeel 236 (Portion 1) F03300000000023600001
Driekoppies No 422 (Portion 0) F03300000000042200000
Du Preez Leger No324 (Portion 0) F03500000000032400000
Enkeldoorn 360 (Portion 0) F03300000000036000000
Excelsior No 147 (Portion 0) F03300000000014700000
Excelsior No 147 (Portion 1) F03300000000014700001
Fairview No 532 (Portion 0) F03300000000053200000
Farm Annex 2 30 (Portion 0) F03300000000003000000
Farm Blijdschap 17 (Portion 0) F03300000000001700000
Farm Byran No 49 (Portion 1) F03300000000004900001
Farm Byran No 49 (Portion 4) F03300000000004900004
Farm Lekkerlewe 13 (Portion 0) F03500000000001300000
Farm Lekkerlewe 14 (Portion 1) F03900000000001300001
Farm Shalom 24 (Portion 0) F03300000000002400000
Farm Welgelegen Station No 64 (Portion 0) F03300000000006400000
Frisgewaag 550 (Portion 0) F03300000000055000000
Glen Ross 734 (Portion 0) F03500000000073400000
1473 EIA Report 26

Goedemoed No 143 (Portion 0) F03300000000014300000
Grasdeel No 586 (Portion 0) F03300000000058600000
Grusde 229 (Portion 0) F03300000000022900000
Hakkies 695 (Portion 1) F03500000000069500001
Harmonie 579 (Portion 0) F03300000000057900000
Harmonie 579 (Portion 1) F03300000000057900001
Helpmekaar 47 (Portion 0) F03300000000004700000
Helpmijvoort No 472 (Portion 0) F03300000000047200000
Houmoed No 326 (Portion 0) F03300000000032600000
Jonkers Rust 72 (Portion 0) F03500000000007200000
Jonkers Rust 72 (Portion 1) F03500000000007200001
Jordaan 1 (Portion 0) F03300000000000100000
Jordaan 1 (Portion 1) F03300000000000100001
Jordaans Rust 59 (Portion 0) F03300000000005900000
Kaalpan 65 (Portion 0) F03900000000006500000
Kalkoenkrans 225 (Portion 0) F03300000000022500000
Keimoes No 170 (Portion 0) F03300000000017000000
1473 EIA Report 27

Klein Palmiet Kuil 407 (Portion 0) F03300000000040700000
Klein Pan 320 (Portion 0) F03300000000032000000
Kleinbegin 134 (Portion 0) F03300000000013400000
Kovno 235 (Portion 0) F03300000000023500000
Langlaagte 110 (Portion 1) F03300000000011000001
Langlaagte 110 (Portion 2) F03300000000011000002
Leeuwaarden 171 (Portion 0) F03300000000017100000
Leeuwaarden 171 (Portion 1) F03300000000017100001
Leeuwbult 52 (Portion 0) F03300000000005200000
Leeuwfontein No 256 (Portion 0) F03300000000025600000
Leeuwvlei No 115 (Portion 0) F03300000000011500000
Leeuwvlei No 115 (Portion 1) F03300000000011500001
Lekkerlewe 643 (Portion 0) F03300000000064300000
Leliesdal No 242 (Portion 0) F03300000000024200000
Metz No 295 (Portion 4) F03300000000029500004
Middelplaas 583 (Portion 0) F03300000000058300000
Middenin No 126 (Portion 0) F03900000000012600000
Mond Van Doornrivier 38 (Portion 0) F03300000000003800000
Mond Van Doornrivier 38 (Portion 2) F03300000000003800002
Mooifontein 639 (Portion 0) F03300000000063900000
Mooifontein No 158 (Portion 0) F03300000000015800000
Mooivlakte 199 (Portion 0) F03300000000019900000
Mooivlei 357 (Portion 0) F03300000000035700000
Nortier 361 (Portion 0) F03300000000036100000
Nortier 361 (Portion 1) F03300000000036100001
Palmietkuil 328 (Portion 0) F03300000000032800000
Paulina 470 (Portion 0) F03300000000047000000
Pleasant View No 169 (Portion 0) F03300000000016900000
Plecy No 82 (Portion 0) F03300000000008200000
1473 EIA Report 28

Richelieu 135 (Portion 0) F03300000000013500000
Rondehoek 200 (Portion 0) F03300000000020000000
School Site No 178 (Portion 0) F03300000000017800000
Semper Idem No 588 (Portion 0) F03300000000058800000
Spoorleggerswoning 167 (Portion 0) F03300000000016700000
Stille Woning 703 (Portion 0) F03500000000070300000
Teacher's Residence No 286 (Portion 0) F03300000000028600000
Terra Blanda 155 (Portion 0) F03300000000015500000
The Prairie No 93 (Portion 1) F03900000000009300001
The Prairie No 93 (Portion 2) F03900000000009300002
Toulon 368 (Portion 0) F03300000000036800000
Vaalbank 190 (Portion 1) F03300000000019000001
Vermeulenskraal No 223 (Portion 2) F03500000000022300002
Vierhoek No 630 (Portion 0) F03300000000063000000
Vlakpan 358 (Portion 0) F03300000000035800000
Walkersvlei No 133 (Portion 0) F03900000000013300000
Welgelegen 382 (Portion 0) F03300000000038200000
Weltevrede 638 (Portion 0) F03300000000063800000
Weltevreden 443 (Portion 14) F03300000000044300014
Werda No 587 (Portion 0) F03300000000058700000
Wolvepan No 85 (Portion 7) F03900000000008500007
Wolvepan No 85 (Portion 9) F03900000000008500009
Yatala No 73 (Portion 0) F03500000000007300000
Zoetendal 243 (Portion 0) F03300000000024300000
Zoetendal 243 (Portion 1) F03300000000024300001
1473 EIA Report 29

Zonderzorg 342 (Portion 0) F03300000000034200000
Zonderzorg 640 (Portion 0) F03300000000064000000
The farms and portions included within the application area are depicted in Figure 1 to Figure 4 overleaf.
1473 EIA Report 30

Figure 1: Parent farms included in the application area.
1473 EIA Report 31

Figure 2: Overview of parent farms and portions included in the application area.
1473 EIA Report 32

Figure 3: Inset 1 map of parent farms and portions included in the application area.
1473 EIA Report 33

Figure 4: Inset 2 map of parent farms and portions included in the application area.
1473 EIA Report 34

4 DESCRIPTION AND SCOPE OF THE PROPOSED ACTIVITY
This section contains a detailed description of the proposed Cluster 2 Gas Production Project with its associated
infrastructure. At the end of this section, the applicable listed activities relating to the project are presented.
4.1 PROJECT DESCRIPTION

This section provides a description of the proposed Tetra4 Cluster 2 gas production activities which is aimed at
facilitating the readers understanding of the proposed project related activities, their spatial and temporal
extent and contextualise the resultant impacts, where relevant.
PROPOSED CLUSTER 2 PROJECT

Tetra4 wish to expand the natural gas (LNG/LHe) production operations, to be located within the approved
production right area and around the Cluster 1 project (Figure 5). It is important to note that Figure 5 shows the
full extent of the 2010 Production Right area (blue outline) while the 2011 accompanying EMPr to the Production
Right was prepared based on a detailed assessment of the reduced area (green outline). The 2011 approved
EMPr allows for exploration activities within the area of assessment (green outline). Cluster 1 and Cluster 2 both
fall within the Production Right boundary as well as the area assessed in preparation of the Production Right
EMPr.
The Cluster 2 application area covers a total of ~27 500 hectares. This planned expansion to the existing
approved production activities will involve:
• Up to 300 new production wells;
• Gas transmission pipelines and associated infrastructure (such as booster stations, low point drains,
pigging stations, etc.);
• 3 compressor stations; and
• An additional new combined Liquid Natural Gas (LNG) and Liquid Helium (LHe) plant (“LNG/LHe Plant”)
and associated infrastructure.
It is not possible at this time to identify specific locations of the production wells due to the nature of the
exploration phase. During the exploration drilling campaign, gas composition, geology etc is assessed at each
exploration well and this data is continually reassessed (modelled) to guide the future exploration campaign (i.e.
location of future exploration wells). Only when viable gas reserves are found at a particular exploration well,
can the exploration wells be converted into production wells and thereafter, the exact placement of pipelines
and associated infrastructure can be determined. It is for this reason that 600m wide well transects have been
identified along the targeted geological fractures, fissures and/or faults where gas is more likely to be
encountered. Similarly, 300m wide pipeline transects have also been identified to connect the various well
transects to the LNG/LHe plant area. These 600m and 300m wide transects will allow for detailed assessments
of any sensitivities therein so that deviations to the proposed wells and pipelines can be made. The Cluster 2
study area and associated transects within which infrastructure will be positioned are presented in Figure 6.
1473 EIA Report 35

Figure 5: Project history and mineral tenure.
1473 EIA Report 36

Figure 6: Cluster 2 study area and proposed infrastructure footprint transects.
1473 EIA Report 37

THE GAS RESOURCE
The Tetra4 Production Right is located within the Sand River Play or Virginia Gas Field. Despite not being clearly
defined, the field is composed predominantly of Karoo, Ventersdorp and Witwatersrand Supergroup lithologies
complete with younger dolerite intrusions. Major fault systems associated with closely spaced zones of fractures
and joints provide for preferential pathways for a combination of abiogenic and biogenic gas to reach the
surface.
As such, the resulting gas at the surface is a direct emission from the major fault or from minor secondary faults
linked to a major fault. In this regard, it is thought that the primary source of gas originates from the
Witwatersrand Supergroup or shallower Karoo. The gas is presumed to be a mix of both abiogenic gas from the
mantle, and biogenic gas originating from ancient fissure waters, coal beds of the Ecca Group of the Karoo
Supergroup as well as ancient algal mats within the shallow marine/lacustrine Witwatersrand Supergroup
deposits.
Once the gas target areas are intersected, the feed gas will flow passively out of the wells at a low pressure of
~0.4 barg1 (gauge pressure) and with a temperature in the range between 10 º and 30 ºC. The feed gas will be
compressed upstream of the helium process units by 3 inline compressor stations (designated as ‘CS’ in the maps
in this report) which will be located at strategic points along the gas pipeline routes as shown in Figure 6. A gas
pre-treatment will remove condensate (water) as well as traces of sulfur, mercury and C3+ gas components (e.g.
propanes, butanes, pentanes) which could cause possible damage to the downstream process equipment. The
hydrogen sulphide and CO2 are washed out in the amine process. The process causes these acid gases to be
absorbed in the amine solution. The amine solution then goes through a regenerator to produce a lean amine
mixture and an associated waste stream which is flared and is of a minimal volume owing to the fact that the
gas is very sweet in general and not sour. Mercury removal is also a precaution and happens in the process to
protect downstream equipment. The mercury removal is a regenerative adsorption process which will require
specialist waste removal offsite once the beds become saturated and the waste will be disposed of at a suitably
registered waste disposal facility. The gas extraction and processing are discussed further in Section 4.1.3 below.
GAS PRODUCTION METHOD

Gas production encompasses the exploration drilling for viable gas resources with specific focus on existing
geological fractures followed by the extraction of gas through production wells. From the production wells, a
gas gathering network of pipes, booster stations, metering stations, pigging stations and compressor stations
transports the gas to the LNG/LHe Plant where gas processing, storage and distribution is undertaken.
Gas production is accomplished by extracting gas occurring in fractures, fissures and/or faults within the
Ventersdorp and Witwatersrand supergroups located at depths of between approximately 380 to 880 meters
(m). Construction of the gas gathering pipelines for Cluster 1 is completed and the LNG/LHe processing facility
was recently commissioned and going operational now. Cluster 1 is therefore well on the way to producing up
to 50 tons of LNG and 375 kg of LHe per day. Cluster 2 of the project aims to expand upon Cluster 1 production
by increasing natural gas production. This is achieved through the expansion of the gas gathering infrastructure
and the production capacities. The project consists of two components namely, (1) gas gathering and (2) the
LNG/LHe processing plant. The targeted total feed gas flow from Cluster 2 production wells is estimated at ~45
million-standard cubic feet per day (MMSCFD) by 2026 and the aim is to produce gas at this volume for up to 20
years.
The gas is to be collected from a group of wells located in the well transects shown in Figure 6 and transported
to a single feed point whereafter it is piped to the processing plant (LNG/LHe plant). Each group of ~10-12 gas
production wells will feed into a common booster station. From the ~28 booster stations the gas will be fed into
a gas transmission pipeline (trunkline) towards a compressor station. The compressor stations’ outlets will then
be combined through a trunkline into the single tie-in feed point within the proximity of the Plant.
1
Barg: a unit of gauge pressure, i.e. pressure in bars above ambient or atmospheric pressure.
1473 EIA Report 38

The Cluster 2 project entails a total of ~ 300 production wells which, when combined, will produce a total of ~45
MMSCFD2. The wells will be located within the identified zones with the number of wells informed by the total
gas requirements and expected well gas capacity. The current plan is to drill vertical or incline wells ~300m apart
along the fault lines and within the identified and assessed well transect areas.
The Cluster 2 gas field will have 3 x ~15MMSCFD zones each with one compressor station. Approximately 10-12
production wells will be grouped and will be routed to a common booster station and thereafter feed to a
compressor station. Power to the booster stations will be provided from nearby existing Eskom power sources
or alternatively a gas engine. Should Eskom power be used, the design of the powerlines or connections would
be according to Eskom specific standards and dependent on the voltage requirements, locations, etc.
The gas gathering network will comprise primarily of HDPE pipelines buried at least 1.5 m below plough level (or
adjusted in consultation with landowners) in order to ensure minimal disruption to existing agricultural activities.
Sensitive environmental features, land-uses and infrastructure will be avoided as far as practically possible.
However, it is practically impossible to avoid all sensitive features (including tar road crossings and river
crossings). In the case where the pipeline will cross dirt roads an open cut trench technique will be used with
suitable reinstatement of the road thereafter. To ensure that the integrity of tar roads is not compromised,
horizontal directional drilling (HDD) will be used to lay the pipe underneath the road. Similarly, HDD will be used
for perennial river crossings to lay the pipeline approximately 6m underneath the riverbeds. Non-perennial
stream crossings will utilise opencut methodology during the dry season with suitable reinstatement and
rehabilitation of the river bed.
EXPLORATION DRILLING
Exploration wells will be drilled and, if successful, converted
DRILLING TIMEFRAMES:
into production wells. As the exact location of exploration
well drilling cannot be identified at this stage, this study has • Physical drilling process = ~3 to 4
followed the approach of assessing well corridors (600 m wide months
or 300 m on either side of known target fractures, fissures • Flow volumes and gas composition
and/or faults). Exploration drilling entails the use of a truck, tests = ~7 – 14 days after drilling
trailer or skid mounted drill rig to drill to varying depths (~380
m to ~880 m) along known fault lines to strike the gas reserve. Although uncommon, blowout or blowback of
water and/or gas is prevented using a blowout diverter which is installed in the drill line (on surface) and the
blowout diverter valves safely redirect any water and/or gas to a discharge line for safe disposal. In addition,
firefighting equipment and personnel are present during the drilling operation.
Drill rigs typically require temporary clearance or disturbance of an area of 50 m x 50 m in order to set up the
rig and begin drilling activities. All exploration boreholes must be drilled and cased in accordance with applicable
international standards and best practice guidelines 3, and will be sealed with a combination of casing and
grouting to ensure vertical isolation of the gas and/or any deep saline water from both the surrounding geology
and freshwater hydrological regime. In addition to the drill rig, lined sumps will be required to store and
recirculate water for the drilling process. A maximum of 6000 litres of water per day per well is required for
drilling purposes and will be sourced from the municipality and not from the surrounding environment.
If an exploration borehole proves unsuccessful (i.e. no viable gas flow) it will be concrete sealed and cased when
the depth of the boreholes intersected deeper saline aquifers and/or gas as specified in the well closure and
rehabilitation guideline (Appendix 7). All unsuccessful wells will be cut of at least 1m below surface and the area
rehabilitated to pre-drilling conditions to allow for existing land use to continue unobstructed. If an exploration
borehole proves successful (i.e. sufficient gas flow) it will be converted into a production well (as described
below) and added to the network of gas producing wells for Cluster 2. The drilling of exploration boreholes is a
temporary and short-lived activity (~3-4 months) and the equipment to be used during drilling activities includes
2
To contextualize this volume of gas, if all of the ~45 MMSCFD gas was converted to electricity in the highest
efficiency generator station, it would produce about 270 MW.
3
Internationally accepted best practice should be applied and reference should be made to the relevant British
Oil and Gas and/or the API guidelines and standards.
1473 EIA Report 39

a truck/trailer or skid mounted drill rig, excavator, dozer, grader water cart, light motor vehicle for transport of
personnel and chemical toilets.
The physical drilling process takes around 3 to 4 months to complete a single well and drilling per property will
be prioritized as far possible. Following drilling Tetra4 tests flow volumes and gas composition for a further 7 –
14 days. Planned drilling will be communicated to landowners in advance of any planned work.
If the geology allows, then the footprint of the drill site can be contained in the same exploration work area (i.e.
drilling more than one exploration well from the same drill pad disturbance area). However, should the same
site be used, it cannot be done in parallel but rather in sequence i.e. one well drilled and completed then
followed by another thereby extending the time on the property.
WELL SITE CONNECTION
All wells that are drilled and used for production purposes are strengthened with a combination of casing and
grouting to average depths of 300 m, depending on the different flow zones intersected, to prevent any interplay
between deep and shallow aquifers (Figure 7). The casing and grouting ensure that the gas is isolated from
surrounding geology and promotes the preferential flow of gas from the formation through the well and up to
the surface. As the gas is naturally lighter than air, it rises naturally to the surface and no well stimulation is
required. The combination of casing and grouting also serves to ensure that gas is isolated and prevented from
interacting with the geohydrological regime. This means that water from the deeper saline aquifer cannot
migrate into the shallower freshwater aquifer and similarly gas cannot contaminate the shallow groundwater.
The production well flange and well head will be located within the concrete well chamber which will be below
ground.
Figure 7: Schematic section depicting typical well construction.
1473 EIA Report 40

Due to low gas pressures in the wells, groups of ~10-12 wells will be included as an inlet to a booster station to
provide vacuum suction. The booster stations will be connected via ~480 km of pipelines to centralised infield
reciprocating gas compressor stations. Pipelines will consist of high-pressure steel or low-pressure HDPE
depending on site conditions and installed at a minimum depth of 1.5 m below surface level (1.5m to top of
pipe). The pipeline will be installed using a back-actor and TLB in most areas with horizontal directional drilling
in areas where roads, flowing rivers or other constraints require this method. Servitude corridors (10 m wide)
will be maintained free of woody plants to prevent disturbance of the pipeline by root growth and ensure access
by Tetra4 personnel for regular inspection and infrequent maintenance. Pipelines will be marked with concrete
markers (Figure 8) and adhere to ASME B31.8 (Section 851.7) and will have low point drains at strategic locations
for testing and pipeline maintenance. The location of low point drains will be determined in consultation with
the affected landowner to ensure minimal disturbance to the landowners’ day to day activities.
Figure 8: Typical pipeline servitude and pipe marker.
Production wells will be placed within a secured precast well chamber with manhole for access. Minimal
mechanical infrastructure will be placed within the precast well chamber other than the wellhead, connecting
pipeline, an isolation valve and sample point. The surface infrastructure for the manhole would be 1,4 m x 1,1 m
and the manhole surface height will be ~0,25 m (25 cm). Where production wells are located within agricultural
crop areas, the surface manholes will be moved outside of the crop areas to reduce impacts on farming in the
long term the surface manholes will be located on the boundaries of the crop areas in consultation with the
respective landowners. This will be accomplished by connecting a horizontal subterranean pipeline to the
production well. Figure 9 provides a typical example of the construction of a pre-cast subterranean well chamber
and Figure 15 shows the typical design drawings of the Cluster 2 precast well chambers.
1473 EIA Report 41

Figure 9: Typical example of a pre-cast well chamber.
GAS INLINE STATIONS

In order to transport gas via pipelines from the wellheads to the Plant, various inline infrastructure is required
to monitor, measure and control gas flow through the pipelines and this includes booster stations, pigging
stations and compressor stations. Localised inline gas booster stations will be installed for each cluster of 7-10
wells which will feed pressurised gas via pipelines from the production wells to the compressor stations. The
booster stations will occupy an area of 10 m x 14 m (Figure 16) and a total of 28 booster stations are expected
to be constructed.
Inline pigging stations (Figure 10) are installed near river crossings to allow for regular cleaning and inspection
of the pipelines. The pigging stations allow for insertion of probes or cleaning pigs (plugs) in order to perform
regular maintenance. There are approximately 4 major river crossings but with multiple pipe branches. In total
1473 EIA Report 42

there should be approximately 14 pig launcher/receiver pairs. Pigging stations occupy an area of approximately
5 m x 5 m (~25 m2) each.
Low Point Drains (Figure 11) are installed along the pipeline to allow periodic maintenance of the pipeline
whereby any condensate is able to be removed from the pipeline where the pipeline has a low point (gravity
collection of condensates). Approximately 240 low point drains will be installed, and each occupies an area of
~1.5 m2. Low point drains will not be positioned in arable fields or wildlife camps.
Figure 10: View of an existing pigging station constructed as part of Cluster 1.
Figure 11: View of an existing low point drain constructed as part of Cluster 1.
Raw gas received at the compressor stations will be filtered to remove dust and moisture using a combination
of a water filter and an activated carbon filter that absorbs dust and unwanted organic compounds. Once
filtered, the gas from the compressors will be dried to 7 pounds per MMSCF adjacent to the compressor stations,
and then piped for final processing to the LNG/LHe Plant. The footprint for a compressor station including the
gas drier station will be approximately 60 m x 60 m (Figure 12 and Figure 17).
1473 EIA Report 43

Figure 12: Example of Compressor Station just recently constructed as part of Cluster 1.
COMBINED HELIUM AND LIQUID NATURAL GAS PLANT

Feed gas from the centralised reciprocating infield compressor stations will be discharged into the combined
LNG/LHe Plant. The LNG/LHe facility is a modularized facility to convert the Feed Gas into LNG and LHe which
will be stored onsite before being transported by road tankers to offtake suppliers.
The Cluster 2 LNG/LHe Plant will be constructed directly adjacent to the Cluster 1 plant which is currently under
construction on the remaining extent of the farm Mond Van Doornrivier 38. A Major Hazardous Installation
(MHI) study shall inform the relevant safety measures to be implemented at the facility.
The LNG/LHe plant comprises of the following process units:
• Gas Treatment and Boosting System;
• Helium Separation Unit;
• Gas Liquefaction System;
• LHe Storage (~2x100 m3);
• LNG Storage (~11x300 m3); and
• LHe and LNG road tanker loading bays.
The area occupied by the proposed Cluster 2 LNG/LHe plant in the operational phase is ~9 hectares while
additional areas would be cleared during the construction phase for various contractor laydown areas, offices,
parking, waste storage, etc. A breakdown of the approximate area to be occupied by the LNG/LHe Plant and
temporary laydown areas is shown in Table 6 below and an overview provided in Figure 13.
Table 6: Approximate LNG/LHe Plant and laydown area.
Aspect Total Ha Total Ha
LNG/LHe Plant Cluster 2 (Permanent) ~9.6 ~25.4
1473 EIA Report 44

Aspect Total Ha Total Ha
Laydown areas for drilling contractors, gas gathering contractors, plant contractors, ~15.8
parking, offices, etc. (Temporary)
Figure 13: Area to be impacted by the LNG/LHe Plant (green filled area) and laydown areas (clear white outline).
The plant will include a small sewage treatment works as well as stormwater infrastructure to separate clean
and dirty water. Clean water will be diverted into the environment while dirty water will be diverted into an
evaporation pond of approximately 1005 m3. Treated effluent from the sewage treatment plant will also be
directed to the evaporation pond from where water will be pumped into a reverse osmosis plant and then stored
in the fire water and service water tanks for reuse. The fire water and service water tanks are linked and
therefore, recirculating to service water tank is taken off for use in the system. The fire water tank is maintained
at a minimum level to ensure fire water availability. No discharge of polluted water will take place and all waste
products from the sewage treatment works (sludge) and the reverse osmosis plant will be collected by a
registered waste contractor for offsite disposal at a suitably licenced facility.
1473 EIA Report 45

Figure 14: Preliminary layout of the Cluster 2 Plant extension to Cluster 1 Plant
1473 EIA Report 46

Figure 15: Typical subterranean precast well chamber layout
1473 EIA Report 47

Figure 16: Typical booster station layout
1473 EIA Report 48

Figure 17: Typical compressor station layout
1473 EIA Report 49

SURFACE INFRASTRUCTURE
The proposed Cluster 2 project expansion requires various surface infrastructure as listed below:
• Access roads (temporary / permanent);
• Pipelines and powerlines;
• Coalescer filter or knockout drum at each booster station;
• Pipe markers (approximately every 100 m of the pipeline, where feasible);
• Wellheads;
• Booster pumps (where required);
• Inline booster compressors or infield reciprocating compressors;
• Gas driers;
• Fencing and security (booster stations, compressor stations and LNG/LHe Plant infrastructure);
• Combined helium and LNG plant;
• LNG/LHe storage and dispensing units;
• Chemical storage;
• Temporary hazardous waste storage (including but not limited to waste water recirculation at drill sites
and waste containing hydrocarbons such as used oil and filters, diesel, lubricants, grease, etc.);
• Temporary general waste storage;
• Contractors’ laydown areas around the LNG/LHe Plant area; and
• Permanent offices, storage areas and workshops.
In broad summary, infrastructure required for the Cluster 2 gas field development is split between:
a) Gas Gathering Network: infrastructure required for gas extraction and transport at well sites (including
compressor stations); and
b) Gas Processing: infrastructure required for gas processing and transport of final product.
CONTRACTORS’ LAYDOWN AREAS, OFFICES AND ABLUTION FACILITY

As the gas gathering network is spread over an extensive area, it is proposed that the contractor’s laydown areas
and offices will be centrally located adjacent to the LNG/LHe Plant. During peak construction, there will be
approximately 1000 temporary workers and temporary ablution facilities will be provided. Thereafter
approximately 55 operational employees will be catered for at the LNG/LHe plant area and ablution facilities
connected to a sewage treatment works will be provided. The laydown areas, offices and ablutions facility will
be temporary whereby the offices will serve as the base of operations for coordinating the operation and the
ablution facilities will serve as a change room and ablution facility for employees while on site. Construction
materials such as aggregate and concrete will be sourced from licenced suppliers and delivered to site as and
when required.
No overnight accommodation of employees (except for security personnel) will be permitted at the Plant and
other site areas during the construction phase. Normal construction working hours will be limited between ~6
am and ~6 pm (sunrise to sunset) from Monday to Saturday while the working hours for the commissioning
phase of the LNG/LHe Plant and compressor stations may extend into the evening periods.
1473 EIA Report 50

SITE ACCESS CONTROL
Access to the individual well sites, compressor stations, and combined helium and LNG plant will be controlled
through a single entrance and exit point at each site. Well sites will be accessed via existing access roads (as far
as possible) and the plant via the existing security-controlled access road leading off the R30. All booster stations,
compressor stations, and the combined LNG/LHe plant will be fenced off with 1.8 m high razor diamond mesh
fencing or an equivalent product. All visitors to the site will be required to sign in at the security check point
located at the Plant. All employees will be required to retain proof of identification whilst on site and all vehicles
will be branded for identification purposes.
The following specific conditions have been put forward for inclusion in the decision to address access control
and safety while the EMPr contains additional conditions in this regard:
• Farm safety must be a priority and the landowners and Tetra4 must agree on security measures prior
to construction on their farms.
• Tetra4 must consult with landowners about any new work or potential changes that may take place on
their properties.
• Protocols on farm access, compensation, communication, and road maintenance must be agreed upon
and be in place before construction commences. The affected landowners must have input in the
development of these protocols.
• A grievance mechanism and claims procedure must be in place and shared with all the stakeholders
before the construction commences.
• Tetra4 must share the works schedule per property prior to commencement of any activity onsite. This
communication will include details of the respective contractors that are appointed, provide the
affected landowners with a project schedule for their respective properties and any changes to the
schedule must be formally communicated in writing to the affected landowners prior to implementing
such changes.
ROADS
Access to the LNG/LHe Plant will be via the R30, a surfaced two-lane provincial road which links to the R73 and
the town of Virginia. The access off the R30 is currently being upgraded to ensure safe entry with the installation
of slip lanes.
Exploration and production wells will be accessed via existing access roads where possible. Some existing gravel
roads may require temporary widening or reinforcement for larger construction vehicles such as drill rigs. Where
there is no existing access to exploration wells, temporary gravel access will be constructed and if required, a
suitable surface reinforcing will be temporarily installed to prevent damage to the environment (e.g. stone
compacted layer). Any temporary access roads will be rehabilitated following completion of the construction
activities requiring those temporary roads. The following serves as a guideline to how private access roads will
be documented and maintained:
• Prior to the commencement of the construction period, both the landowner and a representative of
Tetra4 will take video footage and/or photographs of the road condition of the access roads.
• After the construction period an access road inspection by both the landowner and Tetra4 will be
undertaken. Tetra4 will be obliged to rehabilitate and/or reconstruct the access roads in the same
condition as reflected in the initial photographs and/or video footage at its costs.
Production well sites will require permanent light delivery vehicle (LDV) access for security and maintenance
purposes and where no existing roads occur, permanent single lane access will be constructed. Where existing
or new access roads traverse drainage lines or streams, culverts will be installed.
1473 EIA Report 51

POWER SUPPLY
For the Cluster 2 LNG/LHe Plant, electrical power will be obtained from a new dedicated overhead powerline. A
new 132 kV dual loop-in-loop-out powerline of approximately 4 km in length to the Theseus-Oryx 132 kV Line
will be required and will likely be a 247 (double circuit) tower structure (Figure 18). The proposed powerline will
feed into a new 40 MVA substation at the LNG/LHe Plant. This proposed 132 kV power line will be constructed
in the powerline corridor shown in Figure 6.
Important Note: This powerline will be applied for separately (separate Basic Assessment application) as the
environmental authorisation will be ceded to Eskom on completion of construction. Therefore although the
power supply is described in this section, this S&EIA application does not include the relevant listed activities
relating to powerlines nor shall this be assessed in detail within this report.
Figure 18: Typical transmission tower outline drawing.
The compressor stations will require a medium voltage substation connection from existing Municipal/Eskom
lines (11 kV / 33 kV switchboard to a 400 V switchboard). The booster stations will require 220 V (low voltage)
and will be powered by either solar PV, LNG generator or municipal pole mounted transformers.
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WATER MANAGEMENT
Water management for the proposed Cluster 2 Project refers to the water requirements for exploration and
limited amounts for production activities, as well as the management of waste water such as condensate and
formation water.
WATER REQUIREMENTS
Water for construction, drilling, Plant operation, drinking and domestic purposes will be sourced from existing
municipal supply which is piped into the Cluster 1 plant service water tank.
WASTE WATER
Waste water from the Cluster 2 Project will consist of either condensate (waste water from condensation out of
the gas) or very rarely, formation water (a natural layer of water inside gas reservoirs). The amount of waste
water to be produced during the Cluster 2 gas drilling, production and processing activity is as per the schematic
diagram in Figure 21 below. The condensate and any formation water encountered will be disposed of as per
the legislative requirements which includes disposal by a licensed contractor at a suitably registered waste
disposal facility.
A Storm Water Management Plan (SWMP) for the plant area will be developed which will ensure separation of
clean and dirty water. Clean water will be diverted back into the environment in a controlled manner to prevent
scouring, sedimentation or erosion from forming, while dirty water will be collected and stored within an
evaporation pond for treatment and reuse. Waste water management within the LNG/LHe Plant will include:
• A small sewage water treatment works (SWTW) to pre-treat the site domestic wastewater before it
enters the main reverse osmosis Water Treatment Works.
• A reverse osmosis water treatment works (RO-WTW) to treat all wastewater at the LNG/Helium Plant
site with reuse of treated water (no discharge to environment).
The wastewater from the Plant (rainfall, process water, condensate, formation water, etc) will be stored in an
evaporation pond (Figure 14) before being treated. Treated water will be stored in the Service/Firewater Tank
for recirculation in the plant operations. Small volumes of brine from the 2 X WTW’s will be collected by a service
provider for offsite disposal.
The proposed SWTW can store a maximum of 45 m3 of wastewater (i.e. pre-treated) and a maximum of 36 m3
of treated water at any one time. The SWTW can treat a maximum of 30 m3 on any given day as per design flow
with normal operation only 20 m3 per day. A schematic representation of the proposed SWTW is shown in Figure
19.
The main RO-WTW will have a 5 m3 feed tank which will be supplied with effluent from an evaporation pond
(1005 m3). The brine/concentrate tank will be 100 litres while the product tank will be 5m3. Recovered
effluent/service water will be pumped from the product tank to the Service/Fire water storage tank (clean water
capacity 1407 m3). The feed tank, product tank and concentrate tank will be JoJo (Roto) tanks. The service/fire
water tank will be a steel reservoir. A schematic representation of the proposed RO-WTW is shown in Figure 20.
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Figure 19: Typical schematic of the proposed sewage water treatment works.
Figure 20: Typical schematic of the proposed reverse osmosis treatment works.
1473 EIA Report 54

Figure 21: Water balance showing the potential amount of waste water produced during gas production and processing.
1473 EIA Report 55

WASTE MANAGEMENT
The design philosophies for waste management are based on applicable legislation, in particular NEMWA, DWAF
(DWS) best practice guidelines, and currently accepted good industry practice for waste management. Principles
of waste minimisation at source, segregation for reuse, recycling and treatment or disposal will be applied to
the handling of waste, wherever possible. The waste (general and hazardous) generated during construction and
operations will be addressed as detailed below.
GENERAL WASTE
The following types of general waste (produced mainly during construction, with minimal amounts post
construction/ operation) will be generated by the proposed Cluster 2 Project:
• Domestic solid waste;
• Scrap metal; and
• Construction waste.
The Cluster 2 Project will utilise a temporary general waste storage facility and all waste will be collected by an
approved, licenced waste contractor for removal and final disposal at a registered general waste disposal facility.
No new landfills will be directly established by the project within the project boundaries.
HAZARDOUS WASTE
Hazardous waste, including but not limited to hydrocarbon containing waste (used oil and filters, diesel,
lubricants, and grease) will be stored in clearly marked skip bins (solids) and containers (liquids). These skip bins/
containers will be placed in an isolated area on a hard, impervious surface. When full, the bins/ containers will
be collected by a contractor for safe disposal or recycling companies which will be appointed to collect waste. A
waste disposal certificate will be required from the contractor to ensure safe disposal.
Drilling waste will consist of wastewater and drilling mud. This waste will be stored in lined sumps adjacent to
the drill rig and once drilling is completed, the waste will be removed from site and adequately disposed of at
an appropriately licenced waste disposal facility.
Condensate (including effluent from the filters and drop out water) removed from gas processing at the various
stations described previously will also be stored in clearly marked containers (should it not be within DWS
livestock watering and irrigation standards) for final disposal offsite at a registered hazardous waste disposal
facility by a licensed contractor.
Mercury and other trace metals are absorbed by the membranes and guard beds equipped at the plant which
are designed to last for approximately 10 years before requiring replacement. These membranes and waste
guard beds will be collected by a licenced contractor for safe disposal at a registered hazardous waste disposal
site. Records of all final waste disposal certificates will be kept.
Other liquid waste such as sewage and domestic waste water will be generated and will be treated onsite at the
plant area in the sewage treatment plant. The effluent from the sewage treatment plant will be directed to the
evaporation pond from where waste water will be treated in a reverse osmosis treatment system for reuse
within the plan operations.
PROJECT SCHEDULING
The Cluster 2 project will comprise of two components namely the gas gathering network and the LNG/LHe
Plant. The full field well development will comprise 3 phases/groups of wells during which exploration and
drilling will be undertaken. The first phase will target ~15 MMSCFD of gas followed by the second phase of ~30
MMSCFD and finally the third phase of ~45 MMSCFD. The construction of the gas gathering network (including
pipelines, booster and compressor stations, etc) will commence in ~May 2023 and be completed by ~October
2025 or as the production well development progresses. Construction of the LNG/LHe plant and associated
infrastructure will commence in ~March 2023 and be completed by ~February 2026. The operational (gas
production) timeframe for the project is approximately 20 years (~2026 to ~ 2046).
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4.2 LISTED AND SPECIFIED ACTIVITIES TRIGGERED
The NEMA, NEMWA, NWA and NEMAQA listed activities triggered by the Cluster 2 Gas Production Project are
presented in Table 7 below.
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Table 7: Applicable Listed Activities
Activity No Activity Description Applicability

NEMA LISTING NOTICE 1 ACTIVITIES
NEMA GNR 983 The development of- This project comprises linear activities such as
Activity 12 (i) dams or weirs, where the dam or weir, including infrastructure and water surface pipelines (with associated low point drains, pigging,
area, exceeds 100 square metres; or booster and compressor stations) and access roads
(ii) infrastructure or structures with a physical footprint of 100 square metres or which will impact on watercourses or within 32 m of
more; a watercourse when in proximity to these areas.
where such development occurs-
(a) within a watercourse;
(b) in front of a development setback; or
(c) if no development setback exists, within 32 metres of a watercourse,
measured from the edge of a watercourse;-
excluding-
(aa) the development of infrastructure or structures within existing ports or
harbours that will not increase the development footprint of the port or harbour;
(bb) where such development activities are related to the development of a port or
harbour, in which case activity 26 in Listing Notice 2 of 2014 applies;
(cc) activities listed in activity 14 in Listing Notice 2 of 2014 or activity 14 in Listing
Notice 3 of 2014, in which case that activity applies;
(dd) where such development occurs within an urban area;
(ee) where such development occurs within existing roads, road reserves or railway
line reserves; or
(ff) the development of temporary infrastructure or structures where such
infrastructure or structures will be removed within 6 weeks of the commencement
of development and where indigenous vegetation will not be cleared.
NEMA GNR 983 The development and related operation of facilities for the desalination of water The Reverse Osmosis Plant (RO Plant) will remove
Activity 16 with a design capacity to produce more than 100 cubic metres of treated water per salts from the wastewater in the evaporation pond
day. and therefore fulfils the function of “desalination” of
water. The RO Plant will produce ~100 m3/day of
treated water which shall be reused within the
production processes. The treated water will be
stored in the service/fire water tanks.
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NEMA GNR 983 The infilling or depositing of any material of more than 10 cubic metres into, or the This project comprises extensive linear activities
Activity 19 dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or such as pipelines (with associated low point drains,
rock of more than 10 cubic metres from a watercourse; pigging, booster and compressor stations) and
but excluding where such infilling, depositing, dredging, excavation, removal or access roads which will require infilling or depositing
moving- of more than 10 m3 of material to or from a
(a) will occur behind a development setback; watercourse when in proximity to these areas.
(b) is for maintenance purposes undertaken in accordance with a maintenance
management plan;
(c) falls within the ambit of activity 21 in this Notice, in which case that activity
applies;
(d) occurs within existing ports or harbours that will not increase the development
footprint of the port or harbour; or
(e) where such development is related to the development of a port or harbour, in
which case activity 26 in Listing Notice 2 of 2014 applies.
NEMA GNR 983 Any activity including the operation of that activity which requires an amendment In terms of the MPRDA, a Section 102 EMPr
Activity 21D or variation to a right or permit in terms of section 102 of the Mineral and amendment will be required to include the Cluster 2
Petroleum Resources Development Act, as well as any other applicable activity activities and any specific mitigation measures into
contained in this Listing Notice or in Listing Notice 3 of 2014, required for such the approved Cluster 1 EMPr.
amendment.
NEMA GNR 983 The development of a road- Approximately 480 km of access roads may be
Activity 24 (i) for which an environmental authorisation was obtained for the route required to service the various project infrastructure
determination in terms of activity 5 in Government Notice 387 of 2006 or activity 18 (~300 wells, pipelines, booster and compressor
in Government Notice 545 of 2010; or stations, etc.) although these roads will not be wider
(ii) with a reserve wider than 13,5 meters, or where no reserve exists where the than ~2 m and many will only be 2-spoor tracks.
road is wider than 8 metres; Following the EIA investigations, this listed activity
but excluding a road- has been confirmed to be not applicable to this
(a) which is identified and included in activity 27 in Listing Notice 2 of 2014; application. No roads wider than 8 m will be
(b) where the entire road falls within an urban area; or constructed and consequently this activity has been
(c) which is 1 kilometre or shorter. removed from the revised application form
(Appendix 9).
NEMA GNR 983 The clearance of an area of 1 hectare or more, but less than 20 hectares of The LNG/LHe Plant and laydown area will be ~25.4
Activity 27 indigenous vegetation, except where such clearance of indigenous vegetation is ha and the cumulative clearance for wells,
required for- compressor stations, blower stations, etc are ~100-
(i) the undertaking of a linear activity; or 150 ha.
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(ii) maintenance purposes undertaken in accordance with a maintenance Pipelines and access roads are linear activities and
management plan. therefore excluded from this listed activity and the
calculation of vegetation clearance.
NEMA GNR 983 Residential, mixed, retail, commercial, industrial or institutional developments The LNG/LHe Plant expansion is on land previously
Activity 28 where such land was used for agriculture, game farming, equestrian purposes or used for agricultural activities (grazing) and covers
afforestation on or after 01 April 1998 and where such development: an area greater than 1 hectare (outside urban area).
(i) will occur inside an urban area, where the total land to be developed is bigger
than 5 hectares; or
(ii) will occur outside an urban area, where the total land to be developed is bigger
than 1 hectare;
excluding where such land has already been developed for residential, mixed, retail,
commercial, industrial or institutional purposes.
NEMA GNR 983 The expansion of existing facilities or infrastructure for any process or activity The relevant AEL application will be submitted for
Activity 34 where such expansion will result in the need for a permit or licence or an amended the Cluster 2 specific emissions and scheduled
permit or licence in terms of national or provincial legislation governing the release processes.
of emissions, effluent or pollution, excluding-
(i) where the facility, infrastructure, process or activity is included in the list of
waste management activities published in terms of section 19 of the National
Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case
the National Environmental Management: Waste Act, 2008 applies;
(ii) the expansion of existing facilities or infrastructure for the treatment of effluent,
wastewater, polluted water or sewage where the capacity will be increased by less
than 15 000 cubic metres per day; or
(iii) the expansion is directly related to aquaculture facilities or infrastructure where
the wastewater discharge capacity will be increased by 50 cubic meters or less per
day.
NEMA GNR 983 The expansion of- The expansion to gas production activities under the
Activity 48 (i) infrastructure or structures where the physical footprint is expanded by 100 Production Right from Cluster 1 to Cluster 2 will
square metres or more; or result in infrastructure such as wells, booster
(ii) dams or weirs, where the dam or weir, including infrastructure and water stations, compressor stations, pipelines, roads etc.
surface area, is expanded by 100 square metres or more; being located within the regulated area of a
where such expansion occurs- watercourse.
(c) if no development setback exists, within 32 metres of a watercourse, measured
1473 EIA Report 60

from the edge of a watercourse;
excluding-
(aa) the expansion of infrastructure or structures within existing ports or harbours
that will not increase the development footprint of the port or harbour;
(bb) where such expansion activities are related to the development of a port or
harbour, in which case activity 26 in Listing Notice 2 of 2014 applies;
(cc) activities listed in activity 14 in Listing Notice 2 of 2014 or activity 23 in Listing
Notice 3 of 2014, in which case that activity applies;
(dd) where such expansion occurs within an urban area; or
(ee) where such expansion occurs within existing roads, road reserves or railway
line reserves.
NEMA GNR 983 The expansion and related operation of facilities for the storage, or storage and Expansion to storage of LNG at the LNG/LHe Plant
Activity 51 handling, of a dangerous good, where the capacity of such storage facility will be complex from Cluster 1 to Cluster 2 activities. The
expanded by more than 80 cubic metres. Cluster 2 plant will include 3300 m3 of storage of
LNG.
Liquid Helium is not a listed dangerous good and

therefore does not apply to this listed activity.
NEMA GNR 983 The widening of a road by more than 6 metres, or the lengthening of a road by Existing roads may require lengthening by more than
Activity 56 more than 1 kilometre- 1km however this is dependent on the location of
(i) where the existing reserve is wider than 13,5 meters; or the exploration wells which cannot be specifically
(ii) where no reserve exists, where the existing road is wider than 8 metres; located at this point.
excluding where widening or lengthening occur inside urban areas.
NEMA GNR 983 The expansion and related operation of facilities or infrastructure for the refining, The Cluster 2 Gas Production Project will add an
Activity 59 extraction or processing of gas, oil or petroleum products where the installed additional 3300 m3 of LNG and 200 m3 of Helium to
capacity of the facility will be increased by 50 cubic metres or more per day, the Cluster 1 production volumes.
excluding facilities for the refining, extraction or processing of gas from landfill sites.
NEMA GNR 983 The expansion and related operation of facilities or infrastructure for the bulk Cluster 2 will expand upon the existing approved
Activity 60 transportation of dangerous goods- Cluster 1 gas production by adding an additional 45
(i) in gas form, outside an industrial complex, by an increased throughput capacity MMSCFD to the overall gas production under the
of 700 tons or more per day; Production Right.
(ii) in liquid form, outside an industrial complex or zone, by an increased throughput
capacity of 50 cubic metres or more per day; or
(iii) in solid form, outside an industrial complex or zone, by an increased throughput
capacity of 50 tons or more per day.
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NEMA GNR 983 Phased activities for all activities- The Cluster 2 project (up to 300 production wells,
Activity 67 (i) listed in this Notice, which commenced on or after the effective date of this pipelines, compressor and booster stations) will be
Notice or similarly listed in any of the previous NEMA notices, which commenced constructed in a phased manner which may on their
on or after the effective date of such previous NEMA Notices; own not trigger a listed activity but when combined,
excluding the following activities listed in this Notice- exceed the threshold for clearance of vegetation.
17(i)(a-d);
17(ii)(a-d);
17(iii)(a-d);
17(iv)(a-d);
17(v)(a-d);
20;
21;
...;
24(i);
29;
30;
31;
32;
34;
54(i)(a-d);
54(ii)(a-d);
54(iii)(a-d);
54(iv)(a-d);
54(v)(a-d);
55;
61;
64; and
65; or
(ii) listed as activities 5, 7, 8(ii), 11, 13, 16, 27(i) or 27(ii) in Listing Notice 2 of 2014
or similarly listed in any of the previous NEMA notices, which commenced on or
after the effective date of such previous NEMA Notices;
where any phase of the activity was below a threshold but where a combination of
the phases, including expansions or extensions, will exceed a specified threshold.
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The development and related operation of facilities or infrastructure, for the The LNG/LHe Plant will store 3300 m3 of LNG which
NEMA GNR 984
storage, or storage and handling of a dangerous good, where such storage occurs in is classified as a dangerous good. Note that LHe is not
Activity 4
containers with a combined capacity of more than 500 cubic metres. classified as a dangerous good.
The development and related operation of facilities or infrastructure for the
processing of a petroleum resource, including the beneficiation or refining of gas,
The LNG/LHe Plant will be constructed for Cluster 2
oil or petroleum products with an installed capacity of 50 cubic metres or more per
NEMA GNR 984 which serves the purpose of beneficiation/refining
day, excluding activities which are included in the list of waste management
Activity 5 of gas with an installed capacity of more than 50
activities published in terms of section 19 of the National Environmental
m3/day.
Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National
Environmental Management: Waste Act, 2008 applies.
The development and related operation of facilities or infrastructure for the bulk
transportation of dangerous goods-
(i) in gas form, outside an industrial complex, using pipelines, exceeding 1 000
Cluster 2 will include the development and
metres in length, with a throughput capacity of more than 700 tons per day;
NEMA GNR 984 operation of gas pipelines exceeding 1 000 metres in
(ii) in liquid form, outside an industrial complex, using pipelines, exceeding 1 000
Activity 7 length, with a throughput capacity of more than 700
metres in length, with a throughput capacity of more than 50 cubic metres per day;
tons per day.
or
(iii) in solid form, outside an industrial complex, using funiculars or conveyors with a
throughput capacity of more than 50 tons per day.
The clearance of an area of 20 hectares or more of indigenous vegetation, excluding The LNG/LHe Plant and laydown area is ~25.4 ha and
where such clearance of indigenous vegetation is required for- the cumulative clearance for wells, compressor
NEMA GNR 984
(i) the undertaking of a linear activity; or stations, blower stations, etc are ~100-150 ha.
Activity 15
(ii) maintenance purposes undertaken in accordance with a maintenance Pipelines are linear activities and therefore excluded
management plan. from this listed activity.
GNR 985 The development of a road wider than 4 metres with a reserve less than 13,5 Approximately 480 km of access roads may be
Activity 4 metres. required to service the various project infrastructure
(~300 wells, pipelines, booster and compressor
b. Free State stations, etc.) although these roads will not be wider
i. Outside urban areas: than ~2 m and many will only be 2-spoor tracks.
(aa) A protected area identified in terms of NEMPAA, excluding disturbed areas; Following the EIA investigations, this listed activity
(bb) National Protected Area Expansion Strategy Focus areas; has been confirmed to be not applicable to this
(cc) Sensitive areas as identified in an environmental management framework as application. No roads wider than 4 m will be
contemplated in chapter 5 of the Act and as adopted by the competent authority; constructed in CBA area and consequently this
(dd) Sites or areas identified in terms of an international convention;
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(ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted activity has been removed from the revised
by the competent authority or in bioregional plans; application form (Appendix 9).
(ff) Core areas in biosphere reserves; or
(gg) Areas within 10 kilometres from national parks or world heritage sites or 5
kilometres from any other protected area identified in terms of NEMPAA or from
the core areas of a biosphere reserve, excluding disturbed areas; or
ii. Inside urban areas:
(aa) Areas zoned for use as public open space;
(bb) Areas designated for conservation use in Spatial Development Frameworks
adopted by the competent authority or zoned for a conservation purpose; or
(cc) Areas within urban protected areas.
GNR 985 The development and related operation of facilities or infrastructure for the The Cluster 2 LNG/LHe Plant will store ~3300 m3 of
Activity 10 storage, or storage and handling of a dangerous good, where such storage occurs in LNG which is defined as a dangerous good and the
containers with a combined capacity of 30 but not exceeding 80 cubic metres. facility is located in an ESA defined area.
b. Free State
i. Outside urban areas:
(aa) A protected area identified in terms of NEMPAA, excluding conservancies;
(bb) National Protected Area Expansion Strategy Focus areas;
(cc) Sensitive areas as identified in an environmental management framework as
contemplated in chapter 5 of the Act and as adopted by the competent authority;
(ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted
by the competent authority or in bioregional plans;
(ff) Core areas in biosphere reserves;
the core areas of a biosphere reserve; or
(hh) Areas within a watercourse or wetland; or within 100 metres from the edge of
a watercourse or wetland; or
(aa) Areas zoned for use as public open space; or
adopted by the competent authority or zoned for a conservation purpose.
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GNR 985 The clearance of an area of 300 square metres or more of indigenous vegetation Sections of the project footprint (pipelines, wells,
Activity 12 except where such clearance of indigenous vegetation is required for maintenance booster stations and/or compressor stations fall
purposes undertaken in accordance with a maintenance management plan. within CBA areas and watercourses where more
than 300 m2 will be cleared of vegetation.
b. Free State
i. Within any critically endangered or endangered ecosystem listed in terms of
section 52 of the NEMBA or prior to the publication of such a list, within an area
that has been identified as critically endangered in the National Spatial Biodiversity
Assessment 2004;
ii. Within critical biodiversity areas identified in bioregional plans;
iii. On land, where, at the time of the coming into effect of this Notice or thereafter
such land was zoned open space, conservation or had an equivalent zoning; or
iv. Areas within a watercourse or wetland; or within 100 metres from the edge of a
watercourse or wetland
GNR 985 The development of- Sections of the project footprint (pipelines, wells,
Activity 14 (i) dams or weirs, where the dam or weir, including infrastructure and water surface booster stations and/or compressor stations fall
area exceeds 10 square metres; or within CBA areas and watercourses and
(ii) infrastructure or structures with a physical footprint of 10 square metres or infrastructure in these areas will exceed the 10 m2
more; threshold.
where such development occurs-
(c) if no development setback has been adopted, within 32 metres of a
watercourse, measured from the edge of a watercourse;
excluding the development of infrastructure or structures within existing ports or
harbours that will not increase the development footprint of the port or harbour.
Free State
(cc) World Heritage Sites;
(dd) Sensitive areas as identified in an environmental management framework as
(ee) Sites or areas identified in terms of an international convention;
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(ff) Critical biodiversity areas or ecosystem service areas as identified in systematic
biodiversity plans adopted by the competent authority or in bioregional plans;
(gg) Core areas in biosphere reserves; or
(hh) Areas within 10 kilometres from national parks or world heritage sites or 5
the core area of a biosphere reserve; or
adopted by the competent authority, zoned for a conservation purpose.
GNR 985 The widening of a road by more than 4 metres, or the lengthening of a road by There are CBA areas overlapping with certain well
Activity 18 more than 1 kilometre. and pipeline transects, and existing roads may
require lengthening by more than 1 km however this
b. Free State is dependent on the location of the exploration wells
i. Outside urban areas: which cannot be specifically located at this point.
GNR 985 The expansion and related operation of facilities or infrastructure for the storage, or The Cluster 2 LNG/LHe Plant will store ~3300 m3 of
Activity 22 storage and handling of a dangerous good, where such storage facilities or LNG which is defined as a dangerous good and the
facility is located in an ESA defined area.
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infrastructure will be expanded by 30 cubic metres or more but no more than 80
cubic metres.
b. Free State
(aa) Areas zoned for use as public open space;
adopted by the competent authority or zoned for a conservation purpose; or
(cc) Areas on the watercourse side of the development setback line or within 100
metres from the edge of a watercourse where no such setback line has been
determined.
GNR 985 The expansion of- Expansion of the gas production pipeline network for
Activity 23 (i) dams or weirs where the dam or weir is expanded by 10 square metres or more; Cluster 2 will result in some sections of the pipeline
or being located within CBA areas and watercourses
(ii) infrastructure or structures where the physical footprint is expanded by 10 and will exceed the 10 m2 threshold.
square metres or more;
where such expansion occurs-
(b) in front of a development setback adopted in the prescribed manner; or
(c) if no development setback has been adopted, within 32 metres of a
watercourse, measured from the edge of a watercourse;
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excluding the expansion of infrastructure or structures within existing ports or
harbours that will not increase the development footprint of the port or harbour.
b. Free State
(ff) Core areas in biosphere reserves; or
NEMWA LISTED ACTIVITIES
NEMWA Category A1 The storage of general waste in lagoons. Drilling waste (drill mud) will be stored in lagoons at
each of the exploration drill sites. Although previous
samples of drill mud were classified as hazardous
waste, there remains the possibility that certain
exploration wells will be drilled through rock strata
that does not result in a hazardous classification.
Therefore this activity is applied for.
NEMWA Category A6 The treatment of general waste using any form of treatment at a facility that has Drilling waste (drill mud) will be stored in lagoons
the capacity to process in excess of 10 tons but less than 100 tons per day and the liquid fraction (water) removed from the
calculated as a monthly average, excluding the treatment of organic waste using solid fraction (drill cuttings or mud) which
composting and any other organic waste treatment. constitutes “treatment”. Although previous samples
of drill mud were classified as hazardous waste,
there remains the possibility that certain exploration
wells will be drilled through rock strata that does not
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result in a hazardous classification. Therefore this
activity is applied for.
NEMWA Category A7 The treatment of hazardous waste using any form of treatment at a facility that has Drilling waste (drill mud) will be stored in lagoons
the capacity to process in excess of 500kg but less than 1 ton per day calculated as a and the liquid fraction (water) removed from the
monthly average, excluding the treatment of effluent, wastewater, sewage or solid fraction (drill cuttings or mud) which
organic waste using composting or any other organic waste treatment. constitutes “treatment”. Previous samples of drill
cuttings (drill mud) were classified as hazardous and
therefore it can be expected that this may represent
a similar situation for the new exploration wells
(albeit this may not apply in all exploration wells).
NEMWA Category A12 The construction of a facility for a waste management activity listed in Category A The construction of lagoons for the storage of drilling
of this Schedule (not in isolation to associated waste management activity). muds.
NEMWA Category A13 The expansion of a waste management activity listed in Category A or B of this The Cluster 2 Plant and laydown areas will be located
Schedule which does not trigger an additional waste management activity in terms directly adjacent to the Cluster 1 plant and will share
of this Schedule. waste management facilities which will require
expansion to the storage areas for general and
hazardous waste.
NEMWA Category A14 The decommissioning of a facility for a waste management activity listed in On completion of exploration drilling at each drill
Category A or B of this Schedule. site, the lagoons will be decommissioned and
rehabilitated.
NEMWA Category B1 The storage of hazardous waste in lagoons excluding storage of effluent, Drilling mud will be stored in lagoons at each
wastewater or sewage. exploration well and this drill waste falls within the
hazardous class of wastes due to the chemical
properties of the underlying rock strata.
NEMWA Category B10 The construction of a facility for a waste management activity listed in Category B of The construction of lagoons for the storage of drilling
this Schedule (not in isolation to associated waste management activity). muds.
NEMWA Category B11 The establishment or reclamation of a residue stockpile or residue deposit resulting Drilling mud is classified as a residue deposit or
from activities which require a mining right, exploration right or production right in residue stockpile in terms of the NEMWA. This
terms of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 activity will therefore be triggered.
of 2002).
NEMWA Category C1 The storage of general waste at a facility that has the capacity to store in excess of During construction, general waste will be stored by
100m3 of general waste at any one time, excluding the storage of waste in lagoons various contractors in the laydown area/camp and
or temporary storage of such waste. will store more than 100 m3 when combined.
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Note: This NEMWA trigger does not require a waste
management licence but rather requires registration
and compliance with the Norms and Standards.
NEMWA Category C2 The storage of hazardous waste at a facility that has the capacity to store in excess During construction, hazardous waste will be stored
of 80m3 of hazardous waste at any one time, excluding the storage of hazardous by various contractors in the laydown area/camp
waste in lagoons or temporary storage of such waste. and will store more than 80 m3 when combined.

NEMWA Category C6 The sorting, shredding, grinding, crushing, screening or baling of general waste at a The waste storage and separation area during
waste facility that has an operational area that is 1000m 2 and more. construction will be greater than 1000 m2 (33 m X 33
m).

NWA Section 21 Activities
NWA impeding or diverting the flow of water in a watercourse and/or altering the bed, Pipelines and associated infrastructure (due to their
Section 21 (c&i) banks, course or characteristics of a watercourse. linear nature) will be constructed within the
regulated area of a watercourse. An amendment to
the existing Cluster 1 WUL will be undertaken to
include the relevant Cluster 2 water uses.
NWA Disposing of waste in a manner which may detrimentally impact on a water A general authorisation (GA) will be registered for
Section 21 (g) resource. the evaporation pond as the volumes of this pond
fall within the ambit of a GA. A similar GA
registration has already been obtained for the
Cluster 1 evaporation pond at the LNG/LHe Plant.
NEMAQA Scheduled Activities
NEMAQA Sub-category 2.4 Storage and Handling of Petroleum Products The relevant AEL application will be submitted for
the Cluster 2 scheduled processes under the
NEMAQA.
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5 POLICY AND LEGISLATIVE CONTEXT
This section provides an overview of the governing legislation identified which may relate to the proposed
project. The primary legal requirement for this project stems from the need for an EA to be granted by the
competent authority, which is the DMRE (PASA being the delegated authority), in accordance with the
requirements of both the NEMA and MPRDA. In addition, there are numerous other pieces of legislation
governed by many acts, regulations, standards, guidelines and treaties on an international, national, provincial
and local level, which should be considered in order to assess the potential applicability of these for the proposed
activity. The key legislation applicable to this project is discussed in the subsections below.
5.1 CONSTITUTION OF THE REPUBLIC OF SOUTH AFRICA

The constitution of any country is the supreme law of that country. The Bill of Rights in chapter 2 section 24 of
the Constitution of South Africa Act (Act No. 108 of 1996) makes provisions for environmental issues and
declares that: “Everyone has the right -
a) to an environment that is not harmful to their health or well-being; and
b) to have the environment protected, for the benefit of present and future generations, through
reasonable legislative and other measures that:
i. prevent pollution and ecological degradation;
ii. promote conservation; and
iii. secure ecologically sustainable development and use of natural resources while promoting
justifiable economic and social development”
The EIA and associated impact mitigation actions are conducted to fulfil the requirement of the Bill of Rights.
5.2 THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT (MPRDA)

The MPRDA aims to make provision for equitable access to and sustainable development of the nation’s mineral
and petroleum resources. The MPRDA outlines the procedural requirements that need to be met to acquire
mineral and petroleum rights in South Africa.
In terms of Section 83 of the MPRDA, a Production Right must be issued prior to the commencement of any gas
production activities. However, several amendments have been made to the MPRDA. These include, but are not
limited to, the amendment of Section 102, concerning amendment of rights, permits, programmes and plans, to
requiring the written permission of the Minister for any amendment or alteration; and the Section 5A(c)
requirement that landowners or land occupiers receive twenty-one (21) days’ written notice prior to any
activities taking place on their properties. One of the most important amendments requires all mining and
production related activities to follow the full NEMA process as per the EIA Regulations which came into effect
on 4 December 2014 for any new applications. A Production Right is subject to prescribed terms and conditions
and is valid for the period specified in the right, which periods, each of which may not exceed 30 years, and
becomes effective on the effective date.
In support of the integrated EA&WML application, the applicant is required to conduct an EIA process comprising
of the preparation of environmental Scoping and EIA Reports, an EMPr, as well as Interested and Affected Party
(I&AP) consultations, all of which must be submitted to the PASA for adjudication. This report has been compiled
in accordance with Section 23 and Appendix 3 of the EIA Regulations (2014, as amended) in order to satisfy the
criteria for an Environmental Impact Assessment (EIA) Report.
5.3 THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA)

The main aim of the National Environmental Management Act, 1998 (Act 107 of 1998 – NEMA) is to provide for
co-operative governance by establishing decision-making principles on matters affecting the environment. In
terms of the NEMA EIA Regulations, the applicant is required to appoint an EAP to undertake the EIA process,
as well as conduct the public participation process towards an application for EA. In South Africa, EIA’s became
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a legal requirement in 1997 with the promulgation of regulations under the Environment Conservation Act (ECA).
Subsequently, NEMA was passed in 1998. Section 24(2) of NEMA empowers the Minister and any MEC, with the
concurrence of the Minister, to identify activities which must be considered, investigated, assessed and reported
on to the competent authority responsible for granting the relevant EA. On 21 April 2006, the Minister of
Environmental Affairs and Tourism (now Department of Forestry, Fisheries and the Environment – DFFE)
promulgated regulations in terms of Chapter 5 of the NEMA. These regulations, in terms of the NEMA, were
amended a number of times between 2010 and 2022. The NEMA EIA Regulations, 2014, as amended, are
applicable to this project. Exploration and Production activities officially became governable under the NEMA
EIA Regulations in December 2014 with the competent authority identified as the DMRE.
The objective of the EIA Regulations is to establish the procedures that must be followed in the consideration,
investigation, assessment and reporting of the listed activities that are triggered by the proposed project. The
purpose of these procedures is to provide the competent authority with adequate information to make informed
decisions which ensure that activities which may impact negatively on the environment to an unacceptable
degree are not authorised, and that activities which are authorised are undertaken in such a manner that the
environmental impacts are managed to acceptable levels.
In accordance with the provisions of Sections 24(5) and Section 44 of the NEMA the Minister has published
Regulations (GN R. 982) pertaining to the required process for conducting EIA’s in order to apply for, and be
considered for, the issuing of an EA. These EIA Regulations provide a detailed description of the EIA process to
be followed when applying for EA for any listed activity.
An environmental Scoping and Impact Assessment process is reserved for activities which have the potential to
result in significant impacts which are complex to assess. Scoping and Impact Assessment studies accordingly
provide a mechanism for the comprehensive assessment of activities that are likely to have more significant
environmental impacts. Figure 22 below provides a graphic representation of all the components of a full EIA
process. The listed activities the proposed project triggers and consequently requires authorisation prior to
commencement are detailed in Section 0 (Table 7).
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Figure 22: EIA process diagram.
5.4 THE NATIONAL WATER ACT (NWA)

The National Water Act, 1998 (Act 36 of 1998 – NWA) makes provision for two types of applications for water
use licences, namely individual applications and compulsory applications. The NWA also provides that the
responsible authority may require an assessment by the applicant of the likely effect of the proposed licence on
the resource quality, and that such assessment be subject to the NEMA EIA Regulations. A person may use water
if the use is –
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• Permissible as a continuation of an existing lawful water use (ELWU);
• Permissible in terms of a general authorisation (GA);
• Permissible under Schedule 1; or
• Authorised by a licence.
These water use processes are described in Figure 23.
Figure 23: Authorisation processes for new water uses
The NWA defines 11 water uses in Section 21 of the Act. A water use may only be undertaken if authorised by
the Department of Human Settlements Water and Sanitation (DHSWS). The water uses for which an
authorisation or licence can be issued include:
a) Taking water from a water resource;
b) Storing water;
c) Impeding or diverting the flow of water in a watercourse;
d) Engaging in a stream flow reduction activity contemplated in section 36;
e) Engaging in a controlled activity identified as such in section 37(1) or declared under section 38(1);
f) Discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea
outfall or other conduits;
g) Disposing of waste in a manner which may detrimentally impact on a water resource;
h) Disposing in any manner of water which contains waste from, or which has been heated in, any
industrial or power generation process;
i) Altering the bed, banks, course or characteristics of a watercourse;
j) Removing, discharging or disposing of water found underground if it is necessary for the efficient
continuation of an activity or for the safety of people; and
k) Using water for recreational purposes.
The proposed Cluster 2 Gas Production Project includes extensive linear infrastructure which will impact on
water resources in certain areas. The main water use that will be applicable is the Section 21 (c&i) uses for
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activities within proximity (or within) the regulated area of a watercourse. A watercourse is defined in terms of
the Act as follows:
a) a river or spring;
b) a natural channel in which water flows regularly or intermittently;
c) a wetland, lake or dam into which, or from which, water flows; and
d) any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse,
and a reference to a watercourse includes, where relevant, its bed and banks;
The regulated area of a watercourse for section 21(c) or (i) of the Act water uses is similarly defined in terms of
the Act as follows:
a) The outer edge of the 1 in 100-year flood line and/or delineated riparian habitat, whichever is the
greatest distance, measured from the middle of the watercourse of a river, spring, natural channel, lake
or dam;
b) In the absence of a determined 1 in 100-year flood line or riparian area the area within 100m from the
edge of a watercourse where the edge of the watercourse is the first identifiable annual bank fill flood
bench (subject to compliance to section 144 of the Act); or
c) A 500 m radius from the delineated boundary (extent) of any wetland or pan.
As part of this EIA process, specialist input was obtained to delineate the watercourses as well as the 1 in 100-
year floodlines and based on this input, the relevant water uses have been identified and are currently being
applied for. The required water use licencing process is running concurrently with the EIA process.
CATCHMENT MANAGEMENT STRATEGIES

South Africa is divided into nineteen Water Management Areas (WMAs). The delegation of water resource
management from central government to catchment level is achieved by establishing Catchment Management
Agencies (CMAs) at WMA level. Each CMA progressively develops a Catchment Management Strategy (CMS) for
the protection, use, development, conservation, management and control of water resources within its WMA.
This is to ensure that on a regional scale, water is protected, used, developed, conserved, managed and
controlled in a sustainable and equitable manner for the benefit of all persons. The main instrument that guides
and governs the activities of a WMA is the Catchment Management Strategy (CMS) which, while conforming to
relevant legislation and national strategies, provides detailed arrangements for the protection, use,
development, conservation, management and control of the region's water resources. According to the DHSWS
water management areas delineations, the Cluster 2 Gas Production Project is situated in primary catchment (C)
of the Vaal River drainage system which covers a total area of approximately 246 674.5 km 2. The resource
management falls under the Vaal Water Management Area (WMA5) which spans portions of the North West
Province, northern Free State as well northern sections of the Northern Cape. The application area is situated
within quaternary catchments C42K (nett surface area of 668.0 km 2) and C42L (nett surface area of 510.8 km 2),
falls within hydrological zone E and has an estimated mean annual runoff (MAR) of between 10.0 to 13.0 mcm
(million cubic metres) (WR 2012).
5.5 THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT (NEMWA)

On 2 June 2014, the National Environmental Management: Waste Amendment Act came into force. Waste is
accordingly no longer governed by the MPRDA but is subject to all the provisions of the National Environmental
Management: Waste Act, 2008 (NEMWA).
Section 16 of the NEMWA must also be considered which states as follows:
1. A holder of waste must, within the holder’s power, take all reasonable measures to-
a) “Avoid the generation of waste and where such generation cannot be avoided, to minimise the
toxicity and amounts of waste that are generated;
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b) Reduce, re-use, recycle and recover waste;
c) Where waste must be disposed of, ensure that the waste is treated and disposed of in an
environmentally sound manner;
d) Manage the waste in such a manner that it does not endanger health or the environment or
cause a nuisance through noise, odour, or visual impacts;
e) Prevent any employee or any person under his or her supervision from contravening the Act;
and
f) Prevent the waste from being used for unauthorised purposes.”
These general principles of responsible waste management will be incorporated into the requirements in the
EMPr to be implemented for this project. Waste can be defined as either hazardous or general in accordance
with Schedule 3 of the NEMWA (2014) as amended. “Schedule 3: Defined Wastes” has been broken down into
two categories – Category A being hazardous waste; and Category B being general waste.
In order to attempt to understand the implications of these waste groups, it is important to ensure that the
definitions of all the relevant terminologies are defined:
• Hazardous waste: means “any waste that contains organic or inorganic elements or compounds that
may, owning to the inherent physical, chemical or toxicological characteristic of that waste, have a
detrimental impact on health and the environment and includes hazardous substances, materials or
objects within business waste, residue deposits and residue stockpiles.”
• Residue deposits: means “any residue stockpile remaining at the termination, cancellation or expiry of
a prospecting right, mining right, mining permit, exploration right or production right.”
• Residue stockpile: means “any debris, discard, tailings, slimes, screening, slurry, waste rock, foundry
sand, mineral processing plant waste, ash or any other product derived from or incidental to a mining
operation and which is stockpiled, stored or accumulated within the mining area for potential re-use, or
which is disposed of, by the holder of a mining right, mining permit or, production right or an old order
right, including historic mines and dumps created before the implementation of this Act.”
• General waste: means “waste that does not pose an immediate hazard or threat to health or to the
environment and includes – domestic waste; building and demolition waste; business waste; inert
waste; or any waste classified as non-hazardous waste in terms of the regulations made under Section
69.”
Furthermore, the NEMWA provides for specific waste management measures to be implemented, as well as
providing for the licensing and control of waste management activities. The Cluster 2 Gas Production Project
triggers waste management activities in terms of Category A as well as Category B of GN 921, the latter of which
states that “a person who wishes to commence, undertake or conduct an activity listed under this Category, must
conduct an environmental impact assessment process, as stipulated in the environmental impact assessment
regulations made under section 24(5) of the National Environmental Management Act, 1998 (Act No. 107 of
1998) as part of a waste management licence application.”
The listed waste activities that are triggered by the project, and which form the basis of this integrated waste
management licence application, are presented in Section 0 (Table 7).
The Waste Classification and Management Regulations (GNR 634) pertain to waste classification and
management, including the management and control of residue stockpiles and residue deposits from a
prospecting, mining, exploration or production operation which is relevant to the proposed project. The purpose
of these Regulations is to –
• Regulate the classification and management of waste in a manner which supports and implements the
provisions of the Act;
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• Establish a mechanism and procedure for the listing of waste management activities that do not require
a Waste Management Licence;
• Prescribe requirements for the disposal of waste to landfill;
• Prescribe requirements and timeframes for the management of certain wastes; and
• Prescribe general duties of waste generators, transporters and managers.
Waste classification, as presented in Chapter 4 of these regulations, entails the following:

• Wastes listed in Annexure 1 of these Regulations do not require classification in terms of SANS 10234;
• Subject to sub regulation (1), all waste generators must ensure that the waste they generate is classified
in accordance with SANS 10234 within one hundred and eighty (180) days of generation;
• Waste must be kept separate for the purposes of classification in terms of sub regulation (2), and must
not be mixed prior to classification;
• Waste-must be re-classified in terms of sub regulation (2) every five (5) years, or within 30 days of
modification to the process or activity that generated the waste, changes in raw materials or other
inputs, or any other variation of relevant factors;
• Waste that has been subjected to any form of treatment must be re-classified in terms of sub regulation
(2), including any waste from the treatment process; and
• If the Minister reasonably believes that a waste has not been classified correctly in terms of sub
regulation (2), he or she may require the waste generator to have the classification peer reviewed to
confirm the classification.
Furthermore, Chapter 8 of the Regulations stipulates that unless otherwise directed by the Minister to ensure a
better environmental outcome, or in response to an emergency so as to protect human health, property or the
environment –
• Waste generators must ensure that their waste is assessed in accordance with the Norms and Standards
for Assessment of Waste for Landfill Disposal set in terms of section 7(1) of the Act prior to the disposal
of the waste to landfill;
• Waste generators must ensure that the disposal of their waste to landfill is done in accordance with
the Norms and Standards for Disposal of Waste to Landfill set in terms of section 7(1) of the Act; and
• Waste managers disposing of waste to landfill must only do so in accordance with the Norms and
Standards for Disposal of Waste to Landfill set in terms of section 7 (1) of the Act.
Tetra4 has recently undertaken a waste classification study of the drill waste to in order to determine the waste
class (general or hazardous). The reason for this study was to confirm if the current practice for Cluster 1
exploration drilling whereby all drill waste is being disposed of as hazardous waste to Holfontein Waste Disposal
Facility is justifiable or if only a particular fraction of the waste would be hazardous. Samples were taken from
various depths during the drilling operation to determine if one of more of the lithologies (rock layers) contained
hazardous levels of relevant elements. Ironically, all lithologies being drilled through resulted in a type 3
hazardous waste rating. As such, the storage and disposal of the drill waste must be handled accordingly and
therefore the relevant waste listed activities for storage are being applied for as part of this application. As there
are no suitably licenced waste disposal facilities near to the application area, this waste will continue to be
disposed of at Holfontein Waste Disposal Facility until (and if) such time as another facility is identified.
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5.6 THE NATIONAL ENVIRONMENTAL MANAGEMENT AIR QUALITY ACT
(NEMAQA)
The National Environmental Management: Air Quality Act (Act No. 39 of 2004 as amended – NEMAQA) is the
main legislative tool for the management of air pollution and related activities. The Object of the Act is:
• To protect the environment by providing reasonable measures for –
i. the protection and enhancement of the quality of air in the republic;

ii. the prevention of air pollution and ecological degradation; and
iii. securing ecologically sustainable development while promoting justifiable economic and social
development; and
• Generally, to give effect to Section 24(b) of the constitution in order to enhance the quality of ambient
air for the sake of securing an environment that is not harmful to the health and well-being of people.
The NEMAQA mandates the Minister of Environment to publish a list of activities which result in atmospheric
emissions and consequently cause significant detrimental effects on the environment, human health and social
welfare. All scheduled processes as previously stipulated under the Air Pollution Prevention Act (APPA) are
included as listed activities with additional activities being added to the list. The updated Listed Activities and
Minimum National Emission Standards were published on the 22nd November 2013 (Government Gazette No.
37054).
According to the NEMAQA, air quality management control and enforcement is in the hands of local government
with District and Metropolitan Municipalities as the licensing authorities. Provincial government is primarily
responsible for ambient monitoring and ensuring municipalities fulfil their legal obligations, with national
government primarily as policy maker and co-ordinator. Each sphere of government must appoint an Air Quality
Officer responsible for co-ordinating matters pertaining to air quality management. Given that air quality
management under the old Act was the sole responsibility of national government, local authorities have in the
past only been responsible for smoke and vehicle tailpipe emission control.
The National Pollution Prevention Plans Regulations were published in March 2014 (Government Gazette 37421)
and tie in with the National Greenhouse Gas (GHG) Emission Reporting Regulations which took effect on 3 April
2017. In summary, the Regulations aim to prescribe the requirements that pollution prevention plans of
greenhouse gases declared as priority air pollutants, need to comply with in terms of the NEMAQA. The
Regulations specify who needs to comply, and by when, as well as prescribing the content requirements. Tetra4
has an obligation to report on the GHG emissions under these Regulations. There is also a requirement to
account for the amount of pollutants discharged into the atmosphere (total emissions for one or more specific
GHG pollutants) by 31 March each year.
As part of this EIA application, an Air Quality and GHG study has been undertaken and an amendment to the
Cluster 1 AEL will be undertaken to include the Cluster 2 relevant aspects once a decision is made on this
application.
NATIONAL DUST CONTROL REGULATIONS

Dustfall is assessed for nuisance impact and not for inhalation health impact. The National Dust Control
Regulations (Department of Environmental Affairs, 2013) prescribes measures for the control of dust in
residential and non-residential areas. Acceptable dustfall rates are measured (using American Standard Testing
Methodology (ASTM) D1739:1970 or equivalent) at and beyond the boundary of the premises where dust
originates. In addition to the dustfall limits, the National Dust Control Regulations prescribe monitoring
procedures and reporting requirements. Dust that may be created from the Cluster 2 project (including but not
limited to the construction phase) will be managed in accordance with these Regulations.
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5.7 THE NATIONAL HERITAGE RESOURCES ACT (NHRA)
The National Heritage Resources Act (Act 25 of 1999 – NHRA) stipulates that cultural heritage resources may not
be disturbed without authorisation from the relevant heritage authority. Section 34(1) of the NHRA states that,
“no person may alter or demolish any structure or part of a structure which is older than 60 years without a
permit issued by the relevant provincial heritage resources authority…” The NHRA is utilised as the basis for the
identification, evaluation and management of heritage resources and in the case of Cultural Resource
Management (CRM) those resources specifically impacted on by development as stipulated in Section 38 of
NHRA, and those developments administered through the NEMA, MPRDA and the Development Facilitation Act
(FDA) legislation. In the latter cases the feedback from the relevant heritage resources authority is required by
the State and Provincial Departments managing these Acts before any authorisations are granted for a
development. The last few years have seen a significant change towards the inclusion of heritage assessments
as a major component of Environmental Impact Processes required by the NEMA and MPRDA.
The NEMA 23(2)(b) states that an integrated environmental management plan should, “…identify, predict and
evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage”.
A study of subsections (23)(2)(d), (29)(1)(d), (32)(2)(d) and (34)(b) and their requirements reveals the
compulsory inclusion of the identification of cultural resources, the evaluation of the impacts of the proposed
activity on these resources, the identification of alternatives and the management procedures for such cultural
resources for each of the documents noted in the Environmental Regulations. A further important aspect to be
taken into account of in the EIA Regulations under the NEMA relates to the Specialist Report requirements
(Appendix 6 of EIA Regulations 2014, as amended).
The MPRDA defines ‘environment’ as it is in the NEMA and, therefore, acknowledges cultural resources as part
of the environment. Section 39(3)(b) of this Act specifically refers to the evaluation, assessment and
identification of impacts on all heritage resources as identified in Section 3(2) of the NHRA that are to be
impacted on by activities governed by the MPRDA. Section 40 of the same Act requires the consultation with
any State Department administering any law that has relevance on such an application through Section 39 of
the MPRDA. This implies the evaluation of Heritage Assessment Reports in Environmental Management Plans
or Programmes by the relevant heritage authorities.
In accordance with the legislative requirements and EIA rating criteria, the regulations of the South African
Heritage Resources Agency (SAHRA) and Association of Southern African Professional Archaeologists (ASAPA)
have also been incorporated to ensure that a comprehensive and legally compatible Heritage Report is compiled.
5.8 NATIONAL ENVIRONMENTAL MANAGEMENT BIODIVERSITY ACT (NEMBA)

The National Environmental Management Biodiversity Act (Act No. 10 of 2004 – NEMBA) provides for the
management and conservation of South Africa’s biodiversity within the framework of the NEMA as well as the
protection of species and ecosystems that warrant national protection. Within the framework of this act, various
regulations are promulgated which provide specific requirements and management measures relating to
protecting threatened ecosystems, threatened or protected species as well as the control of alien and invasive
species. A summary of these regulations is presented below.
NATIONAL LIST OF ECOSYSTEMS THAT ARE THREATENED AND NEED OF PROTECTION (GN 1002 OF
2011)
The NEMBA provides for listing of threatened or protected ecosystems in one of the following categories:
• Critically Endangered (CR) ecosystems, being ecosystems that have undergone severe degradation of
ecological structure, function or composition as a result of human intervention and are subject to an
extremely high risk of irreversible transformation;
• Endangered (EN) ecosystems, being ecosystems that have undergone degradation of ecological
structure, function or composition as a result of human intervention, although they are not critically
endangered ecosystems;
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• Vulnerable (VU) ecosystems, being ecosystems that have a high risk of undergoing significant
degradation of ecological structure, function or composition as a result of human intervention,
although they are not critically endangered ecosystems or endangered ecosystems; and
• Protected ecosystems, being ecosystems that are of high conservation value or of high national or
provincial importance, although they are not listed as critically endangered, endangered or vulnerable.
The Biodiversity Specialist has assessed whether any of these threatened or protected ecosystems occur within
the study area and provided recommendations on how the development should be reduced in certain area.
Permits for protected species under the NEMBA may also be required and this requirement for pre-construction
surveys and permit applications has been included in the EMPr.
THREATENED OR PROTECTED SPECIES REGULATIONS (GN R 152 OF 2007)
The purpose of these regulations is to -
(a) further regulate the permit system set out in Chapter 7 of the Biodiversity Act insofar as that system
applies to restricted activities involving specimens of listed threatened or protected species;
(b) provide for the registration of captive breeding operations, commercial exhibition facilities, game
farms, nurseries, scientific institutions, sanctuaries and rehabilitation facilities and wildlife traders;
(c) provide for the regulation of the carrying out of a specific restricted activity, namely hunting;
(d) provide for the prohibition of specific restricted activities involving specific listed threatened or
protected species;
(e) provide for the protection of wild populations of listed threatened species; and
(f) provide for the composition and operating procedure of the Scientific Authority.
ALIEN AND INVASIVE SPECIES LIST
This Act is applicable since it protects the quality and quantity of arable land in South Africa. Loss of arable land
should be avoided and declared Weeds and Invaders in South Africa are categorised according to one of the
following categories, and require control or removal:
• Category 1a Listed Invasive Species: Category 1a Listed Invasive Species are those species listed as such
by notice in terms of section 70(1)(a) of the Act as species which must be combated or eradicated;
• Category 1b Listed Invasive Species: Category 1b Listed Invasive Species are those species listed as such
by notice in terms of section 70(1)(a) of the Act as species which must be controlled;
• Category 2 Listed Invasive Species: Category 2 Listed Invasive Species are those species listed by notice
in terms of section 70(1)(a) of the Act as species which require a permit to carry out a restricted activity
within an area specified in the Notice or an area specified in the permit, as the case may be; and
• Category 3 Listed Invasive Species: Category 3 Listed Invasive Species are species that are listed by
notice in terms of section 70(1)(a) of the Act, as species which are subject to exemptions in terms of
section 71(3) and prohibitions in terms of section 71A of Act, as specified in the Notice.
Alien and invasive species (AIS) control has been included as a management measure in the EMPr. Tetra4 will be
required to continually monitor their development footprint areas for the presence of AIS and implement
suitable control measures to prevent further establishment or spread of these species.
5.9 THE CONSERVATION OF AGRICULTURAL RESOURCES ACT (CARA)

The Conservation of Agricultural Resources (Act 43 of 1983) aims to provide for the conservation of the natural
agricultural resources of the Republic by the maintenance of the production potential of land, by the combating
and prevention of erosion and weakening or destruction of the water sources, and by the protection of the
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vegetation and the combating of weeds and invader plants. In order to achieve the objectives of this Act, control
measures related to the following may be prescribed to land users to whom they apply:
• The cultivation of virgin soil;
• The utilisation and protection of land which is cultivated;
• The irrigation of land;
• The prevention or control of waterlogging or salination of land;
• The utilisation and protection of vleis, marshes, water sponges, water courses and water sources;
• The regulating of the flow pattern of run-off water;
• The utilisation and protection of the vegetation;
• The grazing capacity of veld, expressed as an area of veld per large stock unit;
• The maximum number and the kind of animals which may be kept on veld;
• The prevention and control of veld fires;
• The utilisation and protection of veld which has burned;
• The control of weeds and invader plants;
• The restoration or reclamation of eroded land or land which is otherwise disturbed or denuded;
• The protection of water sources against pollution on account of farming practices;
• The construction, maintenance, alteration or removal of soil conservation works or other structures on
land; and
• Any other matter which the Minister may deem necessary or expedient in order that the objects of this
Act may be achieved.
Further, different control measures may be prescribed in respect of different classes of land users or different
areas or in such other respects as the Minister may determine. Impacts on the agriculture and soil, biodiversity
and water resources have been identified with regards to this project, and mitigation and management
measures recommended.
5.10 ENVIRONMENT CONSERVATION ACT (ECA)

The Environment Conservation Act (Act 73 of 1989 – ECA) was, prior to the promulgation of the NEMA, the
backbone of environmental legislation in South Africa. To date the majority of the ECA has been repealed by
various other Acts, however Section 25 of the Act and the Noise Regulations (GN R. 154 of 1992) promulgated
under this section are still in effect. These Regulations serve to control noise and general prohibitions relating
to noise impact and nuisance.
NOISE CONTROL REGULATIONS, 1992 (GN R.154)

In terms of section 25 of the ECA, the National Noise Control Regulations (GN R. 154 – NCRs) published in
Government Gazette No. 13717 dated 10 January 1992, were promulgated. The NCRs were revised under GN R.
55 of 14 January 1994 to make it obligatory for all authorities to apply the regulations. Provincial noise control
regulations have been promulgated in Gauteng, Free State and Western Cape Provinces.
The NCRs will need to be considered in relation to the potential noise that may be generated mainly during the
construction phase of the proposed project. The two key aspects of the NCRs relate to disturbing noise and noise
nuisance.
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Section 4 of the Regulations prohibits a person from making, producing or causing a disturbing noise, or allowing
it to be made produced or caused by any person, machine, device or apparatus or any combination thereof. A
disturbing noise is defined in the Regulations as “a noise level which exceeds the zone sound level or if no zone
sound level has been designated, a noise level which exceeds the ambient sound level at the same measuring
point by 7 dBA or more.”
Section 5 of the NCRs in essence prohibits the creation of a noise nuisance. A noise nuisance is defined as “any
sound which disturbs or impairs or may disturb or impair the convenience or peace of any person”. The South
African National Standard 10103 also applies to the measurement and consideration of environmental noise and
should be considered in conjunction with these Regulations.
NOISE STANDARDS
There are a few South African scientific standards (SABS) relevant to noise from mines, industry and roads. They
are:
• South African National Standard (SANS) 10103:2008 – ‘The measurement and rating of environmental
noise with respect to annoyance and to speech communication’;
• SANS 10210:2004 – ‘Calculating and predicting road traffic noise’;
• SANS 10328:2008 – ‘Methods for environmental noise impact assessments’;
• SANS 10357:2004 – ‘The calculation of sound propagation by the Concave method’;
• SANS 10181:2003 – ‘The Measurement of Noise Emitted by Road Vehicles when Stationary’; and
• SANS 10205:2003 – ‘The Measurement of Noise Emitted by Motor Vehicles in Motion’.
The relevant standards use the equivalent continuous rating level as a basis for determining what is acceptable.
The levels may take single event noise into account, but single event noise by itself does not determine whether
noise levels are acceptable for land use purposes. With regards to SANS 10103:2008, the recommendations are
likely to inform decisions by authorities, but non-compliance with the standard will not necessarily render an
activity unlawful per se. A noise impact assessment has been undertaken for this project and the findings utilised
in the impact assessment and associated management measures in the EMPr.
5.11 THE SPATIAL PLANNING AND LAND USE MANAGEMENT ACT (SPLUMA)
The Spatial Planning and Land Use Management (Act 16 of 2013 – SPLUMA) is set to aid effective and efficient
planning and land use management, as well as to promote optimal exploitation of minerals and mineral
resources. The SPLUMA was developed to legislate for a single, integrated planning system for the entire
country. Therefore, the Act provides a framework for a planning system for the country and introduces
provisions to cater for development principles; norms and standards; inter-governmental support; Spatial
Development Frameworks (SDFs) across national, provincial, regional and municipal areas; Land Use Schemes
(LUS); and municipal planning tribunals.
Tetra4 is in the process of undertaking the relevant rezoning or land use change applications for the Plant.
5.12 OCCUPATIONAL HEALTH AND SAFETY ACT

The Occupational Health and Safety Act (Act 85 of 1993 - OHSA) provides for the health and safety of persons at
work and for the health and safety of persons in connection with the use of plant and machinery; the protection
of persons other than persons at work against hazards to health and safety arising out of or in connection with
the activities of persons at work; to establish an advisory council for occupational health and safety; and to
provide for matters connected therewith. Worker safety will form part of the contractors safety requirements
and be guided by the OHSA. This would entail a full health and safety file including but not limited to pre-
mobilization medical assessments, work environment and task specific risk assessments and method statements
etc. Once the plant is in operation worker safety will be covered by the Tetra4 safety philosophy, risk
assessments and Standard Operating Procedures which are all required to comply with the OHSA and or Mine
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Health and Safety Act (dependent on the specific aspect of the production operations). Therefore safety of all
personnel will be guided by overarching South African legislation.
The Major Hazard Installation Regulations (GNR 692 of 30 July 2001) are promulgated under the OHSA and apply
to employers, self-employed persons and users, who have on their premises, either permanently or temporarily,
a major hazard installation or a quantity of a substance which may pose a risk that could affect the health and
safety of employees and the public.
A “major hazard installation” means an installation-
a) where more than the prescribed quantity of any substance is or may be kept, whether permanently or
temporarily; or
b) where any substance is produced, processed, used, handled or stored in such a form and quantity that
it has the potential to cause a major incident;
Major Hazard Installation (MHI) risk assessments have been undertaken on both the gas transmission
infrastructure as well as the LNG Plant and the reports are included in Appendix 8. A summary of the findings
and recommendations of the MHI studies are as follows:
▪ Gas transmission infrastructure:
o The pipeline route does not pose any fatality risk to the public.
o The societal risk is zero.
o There should not be any restriction on land-use planning in the area of the pipeline route other
than to prevent possible damage to the sub-surface pipelines.
o Tetra4 Pipeline Route should NOT be classified as an MHI.
o Future development of the pipeline route does not have to be subjected to an MHI risk
assessment given that the maximum pressure in any part of the pipeline route does not exceed
30bar.
▪ LNG Plant:
o The maximum extent of the 1% consequence lethality zone is 594m, which will not impact on
any residential area or sensitive receptor.
o The risk posed to the public is lower than 1x10-7 fatality/person/year (f/p/y).
o The societal risk is well below the tolerable level in terms of SANS 1461:2018 and thus broadly
acceptable.
o The maintenance plan for the CNG and LNG facilities must be maintained.
o The site emergency plan must be reviewed in accordance with SANS 1514:2018.
o There should not be any restriction on land-use planning outside the perimeter of Tetra4
except in the case of development within the 10-7f/p/y risk zone, where such development will
involve vulnerable members of the public (children, those with mobility difficulties or those
unable to recognise physical danger), in which case advise against development should be
obtained from the local authorities.
o The Tetra4 LNG Plant should be classified as an MHI.
5.13 BASIC CONDITIONS OF EMPLOYMENT ACT

The Basic Conditions of Employment Act (Act 75 of 1997) gives effect to the right to fair labour practices referred
to in section 23(1) of the Constitution by establishing and making provision for the regulation of basic conditions
of employment; and thereby to comply with the obligations of the Republic as a member state of the
International Labour Organisation. The Basic Conditions of Employment Amendment Act, No 20 of 2013 was
published and became effective on 1 September 2014.
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5.14 LABOUR RELATIONS ACT
The Labour Relations Act (Act 66 of 1995) aims to promote economic development, social justice, labour peace
and democracy in the workplace. It sets out to achieve this by fulfilling the primary objectives of the Act, which
are to give effect to and regulate the fundamental rights conferred by section 27 of the Constitution, including
the right to fair labour practices, to form and join trade unions and employer’s organisations, to organise and
bargain collectively, and to strike and lock out; to provide a framework for regulating the relationship between
employees and their unions on the one hand, and employers and their organisations on the other hand. At the
same time it also encourages employers and employees to regulate relations between themselves; and to
promote orderly collective bargaining, collective bargaining at sectoral level, employee participation in decision-
making in the workplace and the effective resolution of labour disputes.
5.15 EMPLOYMENT EQUITY ACT

The Employment Equity Act (Act 55 of 1998) promotes equity in the workplace, ensures that all employees
receive equal opportunities and that employees are treated fairly by their employers. The law protects
employees from unfair treatment and any form of discrimination. The law states that an employer may not
discriminate against an employee directly or indirectly through employment policy or practice on the grounds
of race, gender, pregnancy, marital status, family responsibility, ethnic or social origin, colour, sexual orientation,
age, disability, religion, HIV status, conscience, belief, political opinion, culture, language, and birth.
The law aims to redress injustices of the past by implementing affirmative action measures. According to the
legislation, it isn't unfair discrimination to promote affirmative action consistent with the Act or to prefer or
exclude any person on the basis of an inherent job requirement.
5.16 PROMOTION OF EQUALITY AND PREVENTION OF UNFAIR DISCRIMINATION

The Promotion of Equality and Prevention of Unfair Discrimination Act (Act 4 of 2000) gives expression to the
right to equality. Section 8 stipulates that no person may be unfairly discriminated against on the grounds of
gender, expressly including gender-based violence. Section 8 of the Act goes onto prohibit any limitation of
women’s access to social services, such as health or education, and the denial or systemic inequality of access
to opportunities.
5.17 FIREARMS CONTROL ACT

Firearm Control Act (Act no. 60 of 2000) and associated amendments establishes the procedures under which a
firearm is permitted. It includes the provisions for permitting procedures for persons in South Africa who seek
to obtain a firearm, including procedures for ensuring competency and associated licencing and permits as well
as procedures to terminate firearm licences. Any safety and/or security personnel working on the project must
comply with the Firearms Control Act where relevant and ensure that their actions always consider the safety
of the public.
5.18 NATIONAL ENERGY ACT

The National Energy Act (Act 34 of 2008) provides to ensure that diverse energy resources are available, in
sustainable quantities and at affordable prices, to the South African economy in support of economic growth
and poverty alleviation, taking into account environmental management requirements and interactions
amongst economic sectors; to provide for energy planning, increased generation and consumption of renewable
energies, contingency energy supply, holding of strategic energy feedstocks and carriers, adequate investment
in, appropriate upkeep and access to energy infrastructure; to provide measures for the furnishing of certain
data and information regarding energy demand, supply and generation; to establish an institution to be
responsible for promotion of efficient generation and consumption of energy and energy research; and to
provide for all matters connected therewith. Importantly, the Department of Energy (DoE) is mandated to
provide for energy planning and measures for the furnishing of certain data and information regarding energy
demand, supply and generation.
The objectives of this Act are to:
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a) Ensure uninterrupted supply of energy to the Republic;
b) Promote diversity of supply of energy and its sources;
c) Facilitate effective management of energy demand and its conservation;
d) Promote energy research;
e) Promote appropriate standards and specifications for the equipment, systems and processes used for
producing, supplying and consuming energy;
f) Ensure collection of data and information relating to energy supply, transportation and demand;
g) Provide for optimal supply, transformation, transportation, storage and demand of energy that are
planned, organised and implemented in accordance with a balanced consideration of security of supply,
economics, consumer protection and a sustainable development;
h) Provide for certain safety, health and environment matters that pertain to energy;
i) Facilitate energy access for improvement of the quality of life of the people of Republic;
j) Commercialise energy related technologies;
k) Ensure effective planning for energy supply, transportation and consumption; and
l) Contribute to sustainable development of South Africa s economy.
The Act provides for the establishment of the South African National Energy Development Institution (SANEDI),
whose functions include:
Energy efficiency –
i. Undertake energy efficiency measures as directed by the Minister;
ii. Increase energy efficiency throughout the economy;
iii. Increase the gross domestic product per unit of energy consumed; and
iv. Optimise the utilisation of finite energy resources;
Energy research and development -
i. Direct, monitor, conduct and implement energy research and technology development in all fields of
energy, other than nuclear energy;
ii. Promote energy research and technology innovation; and
iii. Provide for –
a. training and development in the field of energy research and technology development;
b. establishment and expansion of industries in the field of energy; and
c. commercialisation of energy technologies resulting from energy research and development
programmes;
iv. Register patents and intellectual property i n its name resulting from its activities;
v. Issue licences to other persons for the use of its patents and intellectual property;
vi. Publish information concerning its objects and functions;
vii. Establish facilities for the collection and dissemination of information in connection with research,
development and innovation;
viii. Undertake any other energy technology development related activity as directed by the Minister, with
the concurrence of the Minister of Science and Technology;
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ix. Promote relevant energy research through cooperation with any entity, institution or person equipped
with the relevant skills and expertise within and outside the Republic;
x. Make grants to educational and scientific institutions in aid of research by their staff or for the
establishment of facilities for such research;
xi. Promote the training of research workers by granting bursaries or grants in aid for research;
xii. Undertake the investigations or research that the Minister, after consultation with the Minister of
Science and Technology, may assign to it; and
xiii. Advise the Minister and the Minister of Science and Technology on research in the field of energy
technology.
In addition to the Liquid Helium (LHe) production, Liquid Natural Gas (LNG) is one of the other products the
Cluster 2 Gas Production Project will produce. LNG will be utilised mainly as an energy source supplied to end
users within South Africa and abroad. The processing and supply of this LNG will be subject to the conditions
and requirements of this Act, and the gas production on the whole will contribute to the South African economy
and promote development in technologies pertaining to helium and LNG extraction and processing.
5.19 GAS ACT

The Gas Act (Act 48 of 2001) aims to promote the orderly development of the piped gas industry; to establish a
national regulatory framework; to establish a National Gas Regulator as the custodian and enforcer of the
national regulatory framework; and to provide for matters connected therewith. The Tetra4 Production Right
(inclusive of the existing Cluster 1 and the proposed Cluster 2 gas field) will contribute towards the development
of the gas industry in South Africa.
5.20 GAS MASTER PLAN AND INTEGRATED RESOURCE PLAN

The SA Government has published a Gas Master Plan in December 2021 for comments from the public. The
background to the Master Plan is the following (quoted directly from the plan): “The National Development Plan
(NDP) envisions that by 2030 South Africa will have an energy sector that promotes economic growth and
development through adequate investment in energy infrastructure. At just 2.6% of the country’s total energy
mix, South Africa’s natural gas market is small, but with all its inherent benefits, it has the potential to completely
change the economy by stimulating economic growth and development, stability, and job creation. The
meaningful addition of natural gas to the country’s energy mix will rejuvenate an overburdened, out-dated
energy infrastructure and reduce cyclical energy shortfalls. Perhaps even more importantly, it will stimulate the
economy by allowing business and industry to lower their energy and operational spend while also creating
significant numbers of new jobs and skills development opportunities. Considering that nearly 90% of South
Africa’s existing natural gas demand is supplied by a single entity, namely Sasol Gas, the associated economic
and employment risks of limited supply options, development and sourcing of alternative natural gas resources
are high. It is imperative to ensure economic and employment stability within the natural gas sector by
introducing more suppliers. Southern Africa’s gas potential has been revealed by major discoveries that, when
developed, widen options for greater regional energy trade. South Africa’s gas resource potential remains to be
quantified but raises the prospect of possible domestic production in the longer term. Globally the natural gas
industry has moved into a supply surplus, favouring a larger role for gas as a clean fossil fuel in many countries’
energy policies. A challenge in developing the gas sector is to bring gas demand and supply on stream at the
same time and spread geographically to stimulate broader localized demand through South Africa. Without such
localized gas demand, it is difficult to develop distributed gas supply and without such distributed gas supply it is
difficult to develop localized gas demand. One way of breaking this impasse is to create significant “anchor” gas
demand through the development of a gas-to-power programme. In pursuit of adding generating capacity,
lowering carbon emissions, enhancing energy security and supporting industrial development, South Africa has
taken the first steps in a gas-to-power programme to be executed under the Integrated Resource Plan 2019,
aiming to increase the national energy mix natural gas contribution from 2.6% to 15.7% by 2030.”
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5.21 OTHER APPLICABLE ACTS AND LOCAL OR INTERNATIONAL GUIDELINES OR
STANDARDS
Other applicable acts and guidelines include: The DFFE Public Participation Guidelines; The Free State Nature
Conservation Ordinance 8 of 1969; The National Veld and Forest Fire Act 101 of 1998; and Masilonyana and
Matjhabeng Local Municipalities Integrated Development Plans. In addition, the municipal planning documents
such as the Local Municipality By-laws on Spatial Planning and Land Use Management are also applicable to the
project. These Acts, Ordinances, plans and guidelines have been considered in the preparation of this report.
In addition to the relevant provincial or local guidelines, there exists various international guidelines or standards
that have relevance to this project and application, and these are described below.
IFC PERFORMANCE STANDARDS

The International Finance Corporation (IFC) is an international financial institution that offers investment,
advisory, and asset management services to encourage private sector development in developing countries. The
IFC is a member of the World Bank Group (WBG) and is headquartered in Washington, D.C., United States. It
was established in 1956 as the private sector arm of the WBG to advance economic development by investing
in strictly for-profit and commercial projects that purport to reduce poverty and promote development.
The IFC's stated aim is to create opportunities for people to escape poverty and achieve better living standards
by mobilizing financial resources for private enterprise, promoting accessible and competitive markets,
supporting businesses and other private sector entities, and creating jobs and delivering necessary services to
those who are poverty-stricken or otherwise vulnerable. Since 2009, the IFC has focused on a set of development
goals that supported projects are expected to target. Its goals are to increase sustainable agriculture
opportunities, improve health and education, increase access to financing for microfinance and business clients,
advance infrastructure, help small businesses grow revenues, and invest in climate health.
The IFC is owned and governed by its member countries but has its own executive leadership and staff that
conduct its normal business operations. It is a corporation whose shareholders are member governments that
provide paid-in capital and which have the right to vote on its matters. Originally more financially integrated
with the WBG, the IFC was established separately and eventually became authorized to operate as a financially
autonomous entity and make independent investment decisions. It offers an array of debt and equity financing
services and helps companies face their risk exposures, while refraining from participating in a management
capacity. The corporation also offers advice to companies on making decisions, evaluating their impact on the
environment and society, and being responsible. It advises governments on building infrastructure and
partnerships to further support private sector development.
The IFC’s Sustainability Framework articulates the Corporation’s strategic commitment to sustainable
development and is an integral part of IFC’s approach to risk management. The Sustainability Framework
comprises IFC’s Policy and Performance Standards on Environmental and Social Sustainability, and IFC’s Access
to Information Policy. The Policy on Environmental and Social Sustainability describes IFC’s commitments, roles,
and responsibilities related to environmental and social sustainability. IFC’s Access to Information Policy reflects
IFC’s commitment to transparency and good governance on its operations and outlines the Corporation’s
institutional disclosure obligations regarding its investment and advisory services. The Performance Standards
(PSs) are directed towards clients, providing guidance on how to identify risks and impacts, and are designed to
help avoid, mitigate, and manage risks and impacts as a way of doing business in a sustainable way, including
stakeholder engagement and disclosure obligations of the client in relation to project-level activities. In the case
of its direct investments (including project and corporate finance provided through financial intermediaries), IFC
requires its clients to apply the PSs to manage environmental and social risks and impacts so that development
opportunities are enhanced. IFC uses the Sustainability Framework along with other strategies, policies, and
initiatives to direct the business activities of the Corporation to achieve its overall development objectives. The
PSs are often also be applied by other financial institutions and therefore these PSs are discussed in Table 8 in
terms of the applicability of the various PSs to this Tetra4 Cluster 2 development proposal.
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Table 8: IFC Performance Standards applicability to this project.
Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts
Overview Performance Standard 1 underscores the importance of managing environmental and social
performance throughout the life of a project. An effective Environmental and Social
Management System (ESMS) is a dynamic and continuous process initiated and supported by
management, and involves engagement between the client, its workers, local communities
directly affected by the project (the Affected Communities) and, where appropriate, other
stakeholders.
Objectives ➢ To identify and evaluate environmental and social risks and impacts of the project.
➢ To adopt a mitigation hierarchy to anticipate and avoid, or where avoidance is not
possible, minimize, and, where residual impacts remain, compensate/offset for risks and
impacts to workers, Affected Communities, and the environment.
➢ To promote improved environmental and social performance of clients through the
effective use of management systems.
➢ To ensure that grievances from Affected Communities and external communications from
other stakeholders are responded to and managed appropriately.
➢ To promote and provide means for adequate engagement with Affected Communities
throughout the project cycle on issues that could potentially affect them and to ensure
that relevant environmental and social information is disclosed and disseminated.
Aspects 1.1 • Policy Consideration of PS1 to this project:

The South African NEMA EIA Regulations are specifically
1.2 • Identification of Risks geared towards ensuring that a projects environmental
and Impacts and social risks and impacts are identified and assessed in
order to put forward suitable impact management actions
1.3 • Management and outcomes for final decision making by the Competent
Programmes Authority.
1.4 • Organisational Capacity This EIA Report includes a detailed assessment of this PSs
and Competency aspects relating to environmental and social risks and
impacts and the culmination of an EMPr containing the
1.5 • Emergency Preparedness relevant mitigation measures which are aimed at limiting
and Response the final significance of each identified impact.
Throughout the EIA application process, stakeholder
1.6 • Monitoring and Review engagement has been undertaken to solicit input from
I&APs and ongoing stakeholder engagement and
communication will be ongoing during the lifecycle of the
1.7 • Stakeholder Engagement
project.
1.8 • External Communication
and Grievance
Mechanism
1.9 • Ongoing Reporting to

Affected Communities
Performance Standard 2: Labour and Working Conditions;
Overview Performance Standard 2 recognises that the pursuit of economic growth through employment
creation and income generation should be accompanied by protection of the fundamental
rights of workers.
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Objectives ➢ To promote the fair treatment, non-discrimination, and equal opportunity of workers.
➢ To establish, maintain, and improve the worker-management relationship.
➢ To promote compliance with national employment and labour laws.
➢ To protect workers, including vulnerable categories of workers such as children, migrant
workers, workers engaged by third parties, and workers in the client’s supply chain.
➢ To promote safe and healthy working conditions, and the health of workers.
➢ To avoid the use of forced labour.
Aspects 2.1 • Working Conditions and Consideration of PS2 to this project:

Management of Worker
This project will require a number of temporary as well as
Relationship
permanent workers during the various project phases. In
• Human Resources Policy terms of South African labour legislation (OHSA/MHSA), it
and Management will be obligatory on Tetra4 and all sub-contractors to
ensure that workers operate in a safe working
• Working Conditions and environment and that employment contracts are fair and
terms of Engagement reasonable.
• Workers organisation
• Non- Discrimination and
Equal Opportunity
• Retrenchment
• Grievance Mechanism
2.2 • Protecting the

Workforce
• Child Labour
• Forced Labour
2.3 • Occupational health and

Safety
2.4 • Workers Engaged by

Third Parties
2.5 • Supply Chain
Performance Standard 3: Resource Efficiency and Pollution Prevention
Overview Performance Standard 3 recognises that increased economic activity and urbanisation often
generate increased levels of pollution to air, water, and land, and consume finite resources in
a manner that may threaten people and the environment at the local, regional, and global
levels. There is also a growing global consensus that the current and projected atmospheric
concentration of greenhouse gases (GHG) threatens the public health and welfare of current
and future generations. At the same time, more efficient and effective resource use and
pollution prevention and GHG emission avoidance and mitigation technologies and practices
have become more accessible and achievable in virtually all parts of the world.
Objectives ➢ To avoid or minimise adverse impacts on human health and the environment by avoiding
or minimising pollution from project activities.
➢ To promote more sustainable use of resources, including energy and water.
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➢ To reduce project related GHG emissions.
Aspects 3.1 • Policy Resource Consideration of PS3 to this project:

Efficiency
The various pollution sources and associated impacts of
• Greenhouse Gases this project have been identifieid in this EIA.
• Water Consumption A detailed Climate Change Assessment (Scope 1, 2 & 3)
has been undertaken to quantify the GHG emissions.
3.2 • Pollution Prevention Water efficiency through the recycling and reuse of water
• Air Emissions at the LNG/LHe Plant will be undertaken.
• Stormwater Surface and groundwater pollution during drilling

operations will be prevented through the casing of the
• Waste Management drillholes which prevents interplay between the gas
• Hazardous Materials resource and shallower freshwater aquifers.
Management Various procedures and plans are already in place (from
• Pesticide use and Cluster 1 development) which put forward management
Management actions for general and hazardous waste, pesticide use
and management, etc.
Performance Standard 4: Community Health, Safety, and Security
Overview Performance Standard 4 recognizes that project activities, equipment, and infrastructure can
increase community exposure to risks and impacts.
Objectives ➢ To anticipate and avoid adverse impacts on the health and safety of the Affected
Community during the project life from both routine and non-routine circumstances.
➢ To ensure that the safeguarding of personnel and property is carried out in accordance
with relevant human rights principles and in a manner that avoids or minimizes risks to
the Affected Communities.
Aspects 4.1 • Community Health and Consideration of PS4 to this project:

Safety
The aspects included in this PS are considered in this
• Infrastructure and project EIA and mitigation measures included in the EMPr.
Equipment Design and Specialist studies have identified and assessed the
Safety potential health and safety impacts on surrounding
• Hazardous Materials communities and include the Social Impact Assessment as
Management and Safety well as the Major Hazardous Installation (MHI)
assessments for the pipelines as well as the LNG/LHe
• Ecosystem Services Plant. In addition, an Emergency Preparedness and
• Community Exposure to Response Procedure (Document Ref: T4-PP-SHERQ-040)
Disease has been prepared for the gas production operations.
• Emergency Preparedness The following specific condition has been included in the
and Response recommendationed conditions of authorisation to ensure
that community health and safety is specifically
4.2 • Security Personnel considered:
• All workers must be educated on the need to ensure
safety of surrounding communities and the public in
general. Road safety legislation must be complied with
at all times with additional consideration of the World
Bank Group Environmental Health and Safety
Guidelines. A community health and safety plan
inclusive of a Traffic Management Plan will be
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developed based on risks identified in consideration of
community health and safety.
• Risks associated with the potential use of security
personnel will be assessed prior to operations and a
security management plan will be developed if
required and in accordance with IFC Performance
Standard 4.
Performance Standard 5: Land Acquisition and Involuntary Resettlement
Overview Performance Standard 5 recognises that project-related land acquisition and restrictions on
land use can have adverse impacts on communities and persons that use this land. Involuntary
resettlement refers both to physical displacement (relocation or loss of shelter) and to
economic displacement (loss of assets or access to assets that leads to loss of income sources
or other means of livelihood) as a result of project-related land acquisition and/or restrictions
on land use.
Objectives ➢ To avoid, and when avoidance is not possible, minimise displacement by exploring
alternative project designs.
➢ To avoid forced eviction.
➢ To anticipate and avoid, or where avoidance is not possible, minimise adverse social and
economic impacts from land acquisition or restrictions on land use by (i) providing
compensation for loss of assets at replacement cost and (ii) ensuring that resettlement
activities are implemented with appropriate disclosure of information, consultation, and
the informed participation of those affected.
➢ To improve, or restore, the livelihoods and standards of living of displaced persons.
➢ To improve living conditions among physically displaced persons through the provision of
adequate housing with security of tenure at resettlement sites.
Aspects 5.1 • Displacement Consideration of PS5 to this project:

• Physical Displacement Due to the nature of this gas production project, the wells,
pipelines and associated infrastructure will impact on
• Economic Displacement existing land users (mainly farm lands as well as lawful
• Private Sector occupiers of land including host communities). Socio-
Responsibilities under economic sensitivities within the proposed development
Government Managed areas have been identified (such as noise, visual, land use,
Resettlement etc.) as a primary means of avoidance however the final
placement of infrastructure will be negotiated with
affected parties to ensure minimal impact on existing land
use.
Tetra4 has compiled a Stakeholder Engagement
Procedure (Document Ref: T4-PP-SHERQ-048). The
intention of this procedure is to stipulate measures for
effective engagement and the recording of engagement
with relevant stakeholders. This document is applicable to
all parties undertaking Works as or on behalf of Tetra4
within the Virginia Production Right area. The document
highlights the requirements of all parties with regards to
stakeholder engagement, the establishment and
maintenance of good working relationships and recording
of stakeholder interactions during any Works undertaken.
In addition, a contractual document (Access Use and
Servitude Agreement) is shared with affected
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stakeholders for negotiation prior to commencement
with construction. Agreements are reached with affected
parties in terms of suitable compensation (per hectare per
year) during both the construction, operational and
decommissioning phases of the project.
Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural

Resources
Overview Performance Standard 6 recognizes that protecting and conserving biodiversity, maintaining
ecosystem services, and sustainably managing living natural resources are fundamental to
sustainable development.
Objectives ➢ To protect and conserve biodiversity.

➢ To maintain the benefits from ecosystem services.
➢ To promote the sustainable management of living natural resources through the adoption
of practices that integrate conservation needs and development priorities.
Aspects 6.1 • Protection and Consideration of PS6 to this project:

Conservation of
Due to the extensive spatial distribution of the project
Biodiversity
infrastructure, various sensitive environmental features
occur within the proposed project footprint and include
CBAs, ESAs, rivers, wetlands, pristine vegetation, etc.
Specialist assessments have been undertaken to identify
and assess the projects impact on sensitive biodiversity
areas and include a Biodiversity Impact Assessment and
Wetland and Aquatic Impact Assessment. Various levels
of mitigation are put forward by the specialist studies
based on the sensitivity of the receiving environment.
Alien and invasive species will be controlled throughout
the lifecycle of the project through the implementation of
the Declared Weeds and Invasive Alien Plant
Management Procedure (Document Ref: T4-PP-SHERQ-
038).
Performance Standard 7: Indigenous People
Overview Performance Standard 7 recognizes that Indigenous Peoples, as social groups with identities
that are distinct from mainstream groups in national societies, are often among the most
marginalized and vulnerable segments of the population. In many cases, their economic, social,
and legal status limits their capacity to defend their rights to, and interests in, lands and natural
and cultural resources, and may restrict their ability to participate in and benefit from
development. Indigenous Peoples are particularly vulnerable if their lands and resources are
transformed, encroached upon, or significantly degraded.
Objectives ➢ To ensure that the development process fosters full respect for the human rights, dignity,
aspirations, culture, and natural resource-based livelihoods of Indigenous Peoples.
➢ To anticipate and avoid adverse impacts of projects on communities of Indigenous
Peoples, or when avoidance is not possible, to minimize and/or compensate for such
impacts.
➢ To promote sustainable development benefits and opportunities for Indigenous Peoples
in a culturally appropriate manner.
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➢ To establish and maintain an ongoing relationship based on Informed Consultation and
Participation (ICP) with the Indigenous Peoples affected by a project throughout the
project’s life-cycle.
➢ To ensure the Free, Prior, and Informed Consent (FPIC) of the Affected Communities of
Indigenous Peoples when the circumstances described in this Performance Standard are
present.
➢ To respect and preserve the culture, knowledge, and practices of Indigenous Peoples.
Aspects 7.1 • General Consideration of PS7 to this project:

• Avoidance of Adverse As per IFC Guidance Note 7, in this Performance Standard,
Impacts the term “Indigenous Peoples” is used in a generic sense
to refer to a distinct social and cultural group possessing
• Participation and the following characteristics in varying degrees:
Consent
• Self-identification as members of a distinct indigenous
7.2 • Circumstances Requiring cultural group and recognition of this identity by others;
Free, Prior, and Informed • Collective attachment to geographically distinct
Consent habitats or ancestral territories in the project area and
• Impacts on Lands and to the natural resources in these habitats and territories;
Natural Resources • Customary cultural, economic, social, or political
Subject to Traditional institutions that are separate from those of the
Ownership or Under mainstream society or culture; or
Customary Use
• A distinct language or dialect, often different from the
• Critical Cultural Heritage official language or languages of the country or region
• Relocation of Indigenous in which they reside.
Peoples from Lands and With due consideration of the above accepted definition
Natural Resources in IFC Guidance Note 7 and as per the international
Subject to Traditional instruments under the United Nations (UN) Human Rights
Ownership or Under Conventions, no indigenous peoples are present within
Customary Use the study area and therefore PS7 is not triggered by this
proposed development and no further assessment in this
7.3 • Mitigation and regard is required.
Development Benefits
7.4 • Private Sector

Responsibilities Where
Government is
Responsible for
Managing Indigenous
Peoples Issues
Performance Standard 8: Cultural Heritage
Overview Performance Standard 8 recognizes the importance of cultural heritage for current and future
generations.
Objectives ➢ To protect cultural heritage from the adverse impacts of project activities and support its
preservation.
➢ To promote the equitable sharing of benefits from the use of cultural heritage.
Aspects 8.1 • Protection of Cultural Consideration of PS8 to this project:

Heritage in Project
A detailed Heritage Impact Assessment as well as a
Design and Execution
Palaeontological Impact Assessment have been
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undertaken by suitably qualified specialists. Various
cultural heritage resources have been identified within
the study area and specific mitigation measures for each
(depending on significance) put forward.
Chance Finds and Heritage Protection Procedure
(Document Ref: T4-PP-SHERQ-037) has been prepared by
Tetra4 for implementation by relevant project
roleplayers.
WORLD BANK (WB) AND INTERNATIONAL FINANCE CORPORATION (IFC) GUIDELINES

WB ENVIRONMENTAL HEALTH AND SAFETY GUIDELINE FOR LIQUEFIED NATURAL GAS FACILITIES
The EHS Guidelines for Liquefied Natural Gas (LNG) Facilities include information relevant to LNG base load
liquefaction plants, transport (by sea and land), storage, regasification (including floating storage regasification
units), peak shaving terminals, and LNG fuelling facilities. The key issues identified for LNG facilities related to
environmental issues, occupational health and safety issues, and community health and safety issues.
The following environmental issues should be considered as part of a comprehensive assessment and
management program that addresses project-specific risks and potential impacts. Potential environmental
issues associated with LNG facilities include the following:
• Hazardous material management;
• Wastewater discharges;
• Air emissions;
• Waste management;
• Noise generation;
• LNG transport related issues; and
• LNG fuelling related issues.
Occupational health and safety issues associated with LNG facilities operations include the following:
• Fires and explosions;
• Roll-over within tanks;
• Contact with cold surfaces;
• Chemical hazards; and
• Confined spaces.
Community health and safety impacts during the operation of LNG facilities or transport of LNG are related to
potential accidental natural gas leaks, in either liquid or gas form. Additionally, security of the LNG facility to
prevent unauthorised access is important.
IFC EHS GUIDELINES FOR ONSHORE OIL AND GAS DEVELOPMENT
The EHS Guidelines for Onshore Oil and Gas Development include information relevant to seismic exploration,
exploration and production drilling, development and production activities, transport activities including
flowlines and pipelines, other facilities including pump stations, metering stations, pigging stations, compressor
stations and storage facilities, ancillary and support operations, and decommissioning. Similar to the above WB
guideline for LNG facilities, the key issues identified for onshore gas developments related to environmental
issues, occupational health and safety issues, and community health and safety issues.
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Potential environmental issues associated with onshore gas development projects include the following:
• Air emissions;
• Wastewater discharges;
• Solid and liquid waste management;
• Noise generation;
• Terrestrial impacts and project footprint;
• Impacts on subsoil and aquifers;
• Spills;
• Spill Response Planning; and
• Energy efficiency and resource conservation.
In addition to the typical OHS issues of large industrial activities, the following additional issues relate to onshore
gas development projects:
• Asset Integrity Management;
• Fire and explosion;
• Air quality;
• Hazardous materials;
• Transportation;
• Well blowouts; and
• Emergency preparedness and response.
Community health and safety impacts during the construction and decommissioning of onshore gas
developments include:
• Physical hazards;
• Exposure to emissions;
• Security; and
• Impacts on land use.
IFC ENVIRONMENTAL NOISE GUIDELINE

The IFC General Environmental Health and Safety Guidelines on noise address impacts of noise beyond the
property boundary of the facility under consideration and provides noise level guidelines. The IFC states that
noise impacts should not exceed the levels presented in Table 9, or result in a maximum increase above
background levels of 3 dBA at the nearest receptor location off-site (IFC, 2007). For a person with average
hearing acuity an increase of less than 3 dBA in the general ambient noise level is not detectable.  = 3 dBA is
therefore a useful significance indicator for a noise impact.
It is further important to note that the IFC noise level guidelines for residential, institutional and educational
receptors correspond with the SANS 10103 guidelines for urban districts.
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Table 9: IFC noise level guidelines.
One Hour LAeq (dBA) One Hour LAeq (dBA)

Area
07:00 to 22:00 22:00 to 07:00
Industrial receptors 70 70
Residential, institutional and educational receptors 55 45
GHG AND CLIMATE CHANGE

Greenhouse gases (GHG) are “those gaseous constituents of the atmosphere, both natural and anthropogenic,
that absorb and emit radiation at specific wavelengths within the spectrum of thermal infrared radiation emitted
by the earth’s surface, the atmosphere itself, and by clouds. This property causes the GHG effect. Water vapour
(H2O), CO2, nitrous oxide (N2O), methane (CH4) and O3 are the primary greenhouse gases in the earth’s
atmosphere. Moreover, there are a number of entirely human-made GHG gases in the atmosphere, such as the
halocarbons and other chlorine and bromine containing substances, dealt with under the Montreal Protocol.
Beside CO2, N2O and CH4, the Kyoto Protocol deals with the greenhouse gases sulphur hexafluoride (SF6),
hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs) (IPCC, 2007). Human activities since the beginning of
the Industrial Revolution (taken as the year 1750) have produced a 40% increase in the atmospheric
concentration of carbon dioxide, from 280 ppm in 1750 to 406 ppm in early 2017 (NOAA, 2017). This increase
has occurred despite the uptake of a large portion of the emissions by various natural "sinks" involved in the
carbon cycle (NOAA, 2017). Anthropogenic CO2 emissions (i.e., emissions produced by human activities) come
from combustion of fossil fuels, principally coal, oil, and natural gas, along with deforestation, soil erosion and
animal agriculture (IPCC, 2007).
The International Finance Corporation (IFC) lists methods that countries and projects can reduce GHG impacts.
These include carbon financing; improvement of energy efficiency; GHG sinks and reservoir protection and
improvements; that environmentally friendly agriculture and forestry be encouraged; the increased use of
renewable energy methods; implementation of carbon capture and sequestration methods; and improved
waste management (recovery and use of methane emissions) as well as reducing GHG emissions from vehicle
use and industrial, construction and energy production processes (IFC, 2007). Carbon financing may have much
potential in developing countries as well as sustainable agriculture and forestry practices (IFC, 2012), and when
supported by governments may be a way of reducing the country’s GHG impacts, where projects receive carbon
credits and financing for reducing GHG emissions and installing more environmentally friendly alternatives.
Because different industries contribute various amounts of GHG emissions, the IFC performance standards
suggests that for industrial processes the CO 2-equivalent (CO2-e) emissions per year do not exceed 100 000
tonnes, this including direct (Scope 1) and indirect (Scope 2) sources (IFC, 2012).
INTERNATIONAL AGREEMENTS
In 1992, countries joined an international treaty, the United Nations Framework Convention on Climate Change
(UNFCCC) as a framework for international cooperation to combat climate change by limiting average global
temperature increases and the resulting climate change, and coping with impacts that were, by then, inevitable.
By 1995, countries launched negotiations to strengthen the global response to climate change, and, two years
later, adopted the Kyoto Protocol. The Kyoto Protocol legally binds developed country parties to emission
reduction targets. The Protocol’s first commitment period started in 2008 and ended in 2012. As agreed in Doha
in 2012, the second commitment period began on 1 January 2013 and would end in 2020 (UNFCCC, 2017) but
due to lack of ratification has not come into force.
The Paris Agreement was adopted by 196 Parties at Conference of the Parties (COP) 21 in Paris, on 12 December
2015 and commenced 4 November 2016. The Paris Agreement (2016) builds upon the Convention and – for the
first time – brings all nations into a common cause to undertake ambitious efforts to combat climate change and
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adapt to its effects, with enhanced support to assist developing countries to do so. As such, it charts a new
course in the global climate effort.
The Paris Agreement’s central aim is to strengthen the global response to the threat of climate change by
keeping a global temperature rise this century well below 2°C above pre-industrial levels and to pursue efforts
to limit the temperature increase even further to 1.5°C. Additionally, the agreement aims to strengthen the
ability of countries to deal with the impacts of climate change. To reach these ambitious goals, appropriate
financial flows, a new technology framework and an enhanced capacity building framework will be put in place,
thus supporting action by developing countries and the most vulnerable countries, in line with their own national
objectives.
The Paris Agreement is founded on the idea of countries improving on their climate change strategies in 5-year
cycles. The Paris Agreement requires all Parties to put forward their best efforts through “nationally determined
contributions” (NDCs) and to strengthen these efforts in the years ahead. This includes requirements that all
Parties report regularly on their emissions and on their implementation efforts. The Paris Agreement proposes
that Parties submit long-term low greenhouse gas emission development strategies (LT-LEDS) by 2020 but this
was not mandatory.
Parties will take stock of the collective efforts in relation to progress towards the goal set in the Paris Agreement
and to inform the preparation of NDCs. There will also be a global stocktake every 5 years to assess the collective
progress towards achieving the purpose of the Agreement and to inform further individual actions by Parties.
Ethiopia submitted their first NDC to the UNFCCC secretariat and ratified the Paris agreement on 9 March 2017.
Existing Parties were expected to submit their updated NDC in 2020; and new Parties their original NDCs. Parties
are to submit updated NDCs every 5 years. As of May 2021, there are 192 parties that have submitted their NDCs
and 8 parties that have submitted their second NDC. There are only 191 Parties to the Paris Agreement; Eritrea
has not become a Party to the Paris Agreement but has submitted its first NDC.
Countries as part of the Paris agreement established an enhanced transparency framework (ETF). ETF is to start
in 2024 and all countries will need to openly report on all activities untaken and progress in climate change
mitigation, adaptation measures as well as any support provided or received. ETF also sets out a procedure for
reviewing submitted reports. The information provided as part of the ETF will be used as an input for the global
stocktake which will assess the collective progress towards the long-term climate goals.
GLOBAL GHG EMISSION INVENTORY
The proposed Tetra4 Cluster 2 operations would most likely fall under the category of “energy” for the global
GHG inventory. According to the “mitigation of climate change” document as part of the Intergovernmental
Panel on Climate Change (IPCC) fifth Assessment Report (AR5) (IPCC, 2014) the 2010 global GHG emissions were
49 (±4.5) Gt CO2-e, of which 35% (17 Gt CO2-e) was a result of the energy sector. The World Resources Institute
Climate Watch global GHG emissions from the “industrial processes” sector were 2.7711 Gt CO 2-e in 2016 (6%
of total anthropogenic GHG emissions).
SOUTH AFRICA’S STATUS IN TERMS OF CLIMATE CHANGE AND QUANTIFICATION OF GREENHOUSE
GASES
5.21.3.3.1 PARIS AGREEMENT - NATIONALLY DETERMINED CONTRIBUTION
South Africa ratified the UNFCCC in August 1997 and acceded to the Kyoto protocol in 2002, with effect from
2005. However, since South Africa is an Annex 1 country it implies no binding commitment to cap or reduce GHG
emissions. The South African Intended Nationally Determined Contribution (INDC) was completed in 2015 and
submitted to the UNFCCC on 1 November 2016. This was undertaken to comply with decision 1/CP.19 and
1/CP.20 of the Conference of the Parties to the UNFCC. This document describes South Africa’s INDC on
adaptation, mitigation and finance and investment necessities to undertake the resolutions.
As part of the adaption portion the following goals have been assembled:
1. Goal 1: Development and implementation of a National Adaption Plan. The implementation of this will
also result in the implementation of the National Climate Change Response Plan (NCCRP) per the 2011
policy.
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2. Goal 2: In the development of national, sub-national and sector strategy framework, climate concerns
must be taken into consideration.
3. Goal 3: An official institutional function for climate change response planning and implementation
needs to be assembled.
4. Goal 4: The creation of an early warning, vulnerability, and adaptation monitoring system
5. Goal 5: Develop policy regarding vulnerability assessment and adaptation needs.
6. Goal 6: Disclosure of undertakings and costs with regards to past adaptation strategies.
As part of the mitigation portion the following have been, or can be, implemented at National level:
• The approval of 79 (5 243 MW) renewable energy Independent Power Producer (IPP) projects as part
of a Renewable Energy Independent Power Producer Procurement Programme (REI4P). An additional
6 300 MW is being deliberated.
• A “Green Climate Fund” has been created to back green economy initiatives. This fund will be increased
in the future to sustain and improve successful initiatives.
• It is intended that by 2050 electricity will be decarbonised.
• Carbon Capture and Sequestration (or Carbon Capture and Storage) (CCS).
• To support the use of electric and hybrid electric vehicles.
• Reduction of emissions can be achieved through the use of energy efficient lighting; variable speed
drives and efficient motors; energy efficient appliances; solar water heaters; electric and hybrid electric
vehicles; solar photovoltaic; wind power; CCS; and advanced bioenergy.
A draft update of the first NDC was published for public comment on the 30th of March 2021 and the final
updated of the first NDC was published and submitted to the UNFCCC on the 27th of September 2021 in
preparation for the 26th Conference of the Parties (to held in Glasgow, Scotland in November 2021). The final
update of the first NDC South Africa has not submitted its second NDC to UNFCCC. The draft document describes
South Africa’s NDC on adaptation, mitigation and finance and investment necessities to undertake the
resolutions with updated revisions to the adaptation goals and mitigation targets.
As part of the updated adaption portion the following goals have been assembled:
1. Goal 1: Enhance climate change adaptation governance and legal framework.
2. Goal 2: Develop an understanding of the impacts on South Africa of 1.5 and 2°C global warming and the
underlying global emission pathways through geo-spatial mapping of the physical climate hazards, and
adaptation needs in the context of strengthening the key sectors of the economy. This will provide the
scientific basis for strengthening the national and provincial governments’ readiness to respond to
climate risk.
3. Goal 3: Implementation of National Climate Change Adaptation Strategy (NCCAS) adaptation
interventions for the period 2021 to 2030, where priority sectors have been identified as biodiversity
and ecosystems; water; health; energy; settlements (coastal, urban, rural); disaster risk reduction,
transport infrastructure, mining, fisheries, forestry and agriculture.
4. Goal 4: Mobilise funding for adaptation implementation through multilateral funding mechanisms.
5. Goal 5: Quantification and acknowledgement of the national adaptation and resilience efforts.
As part of the mitigation portion the following have been, or can be, implemented at National level:
• The approval of 79 (5 243 MW) renewable energy Independent Power Producer projects as part of a
Renewable Energy Independent Power Producer Procurement Programme. An additional 6 300 MW is
being deliberated.
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• A “Green Climate Fund” has been created to back green economy initiatives. This fund will be increased
in the future to sustain and improve successful initiatives.
• It is intended that by 2050 electricity will be decarbonised.
• CCS.
• To support the use of electric and hybrid electric vehicles.
• Reduction of emissions can be achieved through the use of energy efficient lighting; variable speed
drives and efficient motors; energy efficient appliances; solar water heaters; electric and hybrid electric
vehicles; solar photovoltaic (PV); wind power; CCS; and advanced bioenergy.
• Updated targets based on revised 100-year global warming potential (GWP) factors (published in the
Annex to decision 18/CMA.1 of the IPCC 5th assessment report) and based on exclusion of land sector
emissions arising from natural disturbance. The updated NDC mitigation targets, consistent with South
Africa’s fair share, are presented in Table 10.
Table 10: South Africa's NCD mitigation targets.
Year Target Corresponding period
2025 South Africa’s annual GHG emissions will be in a range between 398 - 510 2021-2025
Mt CO2-e.
2030 South Africa’s annual GHG emissions will be in a range between 398 - 440 2026-2030
Mt CO2-e.
5.21.3.3.2 NATIONAL CLIMATE CHANGE RESPONSE POLICY

The National Climate Change Response White Paper stated that in responding to climate change, South Africa
has two objectives: to manage the inevitable climate change impacts and to contribute to the global effort in
stabilising GHG emissions at a level that avoids dangerous anthropogenic interference with the climate system.
The White Paper proposes mitigation actions, especially a departure from coal-intensive electricity generation,
be implemented in the short- and medium-term to match the GHG trajectory range. Peak GHG emissions are
expected between 2020 and 2025 before a decade long plateau period and subsequent reductions in GHG
emissions.
The White Paper also highlighted the co-benefit of reducing GHG emissions by improving air quality and reducing
respiratory diseases by reducing ambient particulate matter, ozone and SO 2 concentrations to levels in
compliance with NAAQS by 2020.
In order to achieve these objectives, the Department of Forestry, Fisheries and Environment (DFFE) has
appointed a service provider to establish a national GHG emissions inventory, which will report through SAAQIS.
The draft Climate Change Bill was published for comment on the 8th of June 2018 and introduced to parliament
on the 18th of February 2022 (B9-2022). The Bill is aligned with international policies guidelines and South Africa’s
Nationally Determined Contribution and aim to reduce GHG emissions as primary driver to anthropogenic
climate change. The aim of the Bill is to achieve an effective climate change response through a long-term just
transition to a low carbon economy that is climate resilient and allows for sustainable development of South
Africa. When in force, the Bill will:
• Establish provincial and municipal forums on climate change which will be responsible for coordinating
climate change response actions in each province.
• Strengthen the establishment of the Presidential Climate Change Coordinating Commission (4PC).
Although, the 4PC has already been established and has been working for the Government since
December 2020, however, its establishment only carries legal force after the Bill becomes an Act.
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• Within one year of the coming into force of the Act, establish a National Adaptation Strategy. This
strategy will guide South Africa's adaptation to the impacts of climate change and develop adaptation
scenarios which anticipate the likely impacts over the short, medium, and long term.
• Determine a national GHG emissions trajectory, which must be reviewed every five years, and which
indicates an emissions reduction objective.
• Put in place a 5-yearly sectoral emission targets for identified sectors and sub-sectors. The sectoral
targets must be aligned with the national GHG emissions trajectory and include quantitative and
qualitative GHG emission reduction goals.
• Bring into force the carbon budget allocation mechanism, which will replace the current National
Pollution Prevention Plan mechanism which is enforced under the National Environmental
Management: Air Quality Act (NEM:AQA). The carbon budget will be linked to the Carbon Tax Act, in
relation to carbon tax rates which will be charged on emissions above the carbon budget.
The Bill is nearing the end of its parliamentary process having been passed by the National Council of Provinces
and been returned to the National Assembly for concurrence. It is likely to be enacted during the operational
lifetime of the Tetra4 Cluster 2, if not before.
5.21.3.3.3 GREENHOUSE GAS EMISSIONS REPORTING
Regulations pertaining to GHG reporting using the National Atmospheric Emissions Inventory System (NAEIS)
were published in 2017 (Republic of South Africa, 2017) (as amended by GN R994, 11 September 2020). The
South African mandatory reporting guidelines focus on the reporting of Scope 1 emissions only.
The South African Greenhouse Gas Emission Reporting System (SAGERS) web-based monitoring and reporting
system will be used to collect GHG information in a standard format for comparison and analyses. The system
forms part of the national atmospheric emission inventory component of South African Atmospheric Emission
Licensing and Inventory Portal (SAAELIP). Tetra4 operations will have to report their GHG emissions to SAGERS
since there is no threshold for annual GHG emissions reporting for the Natural Gas producers as per the
amended GHG reporting guidelines (GG43712, 7 September 2020).
The DFFE is working together with local sectors to develop country specific emissions factors in certain areas;
however, in the interim the IPCC default emission figures may be used to populate the SAAQIS GHG emission
factor database. These country specific emission factors will replace some of the default IPCC emission factors.
Technical guidelines for GHG emission estimation have been issued.
Also, the Carbon Tax Act (No 15 of 2019) (Republic of South Africa, 2019) includes details on the imposition of a
tax on the CO2-e of GHG emissions. Certain production processes indicated in Annexure A of the Declaration of
Greenhouse Gases as Priority Pollutants (Republic of South Africa, 2017) with GHG more than 0.1 mega tonnes
(Mt) or million metric tonnes, measured as CO2-e, are required to submit a pollution prevention plan to the
Minister for approval.
5.21.3.3.4 NATIONAL GHG EMISSIONS INVENTORY
South Africa is perceived as a global climate change contributor and is undertaking steps to mitigate and adapt
to the changing climate. DFFE is categorised as the lead climate change institution and is required to coordinate
and manage climate related information such as development of mitigation, monitoring, adaption, and
evaluation strategies (DEA, 2019). This includes the establishment and updating of the National GHG Inventory.
The National Greenhouse Gas Improvement Programme (GHGIP) has been initiated; it includes sector specific
targets to improve methodology and emission factors used for the different sectors as well as the availability of
data.
The 2000 to 2017 National GHG Inventory was prepared using the 2006 IPCC Guidelines (IPCC, 2006) based on
updated sector information and emission estimation techniques. According to the 4th Biennial Update Report to
the UNFCCC (DFFE, 2021), the total GHG emissions in 2017 were estimated at approximately 512.14 million
metric tonnes CO2-e (excluding Forestry and Other Land Use [FOLU]). This was a 14.2% increase from the 2000
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total GHG emissions (excluding FOLU) and 2.8% decrease from the 2015 total GHG emissions (excluding FOLU).
FOLU is estimated to be a net carbon sink which reduces the 2017 GHG emissions to 482.02 million metric tonnes
CO2-e. The estimated GHG emissions (excluding FOLU) for 2017 showed the Industrial Processes and Product
Use (IPPU) sector contributed 6.3% to the total GHG emissions (excluding FOLU). The estimated CO 2-e emissions
(excluding FOLU) for 2017 for the IPPU sector is 32.08 million metric tonnes.
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6 NEED AND DESIRABILITY OF THE PROPOSED ACTIVITY
This section detailing the need and desirability of the project was obtained from Tetra4 as well as the Economic
specialist.
Tetra4 has commenced with the Cluster 1 Helium and Methane gas production operations with proven
resources of both products. Helium is one of the core products to be produced and processed by the proposed
Cluster 2 gas production development. Tetra4 plans to sell this product to an entity that will distribute the gas
nationally and internationally. Given that South Africa imports helium at present, the substitution of the
importation of this gas with a local product will be of benefit to the country s economy.
LNG is produced both worldwide and domestically at relatively low cost and is cleaner burning with lower CO2
emissions than coal, petrol, diesel or propane fuels. Natural gas vehicles show an average reduction in ozone
forming emissions of 80 percent compared to petrol vehicles. Table 11 below are some features about both
helium and LNG, potential project benefits, as well as a brief of the need and desirability of these gases.
Table 11: Helium and LNG properties and uses.
Helium Properties and Uses LNG Properties and Uses
Helium is one of the most common elements in the LNG is clear, colourless, and odourless. LNG is non-
universe. It is called a noble gas because it doesn’t corrosive and non-toxic. The potential hazards of LNG
chemically interact with other elements. Its atomic are the result of its basic properties including its
number is 2 and the weight is 4.002. In its natural cryogenic nature and dispersion and flammability
state, it doesn’t have any smell, taste or colour. characteristics.
Occurrence and Discovery Occurrence and Discovery
Helium can be found all over the universe, although Natural gas is a naturally occurring hydrocarbon gas
it isn’t widely distributed on Earth. Its most frequent mixture consisting primarily of methane, but
form is gas. It shares many characteristics with other commonly including varying amounts of other higher
noble gases. Helium doesn’t form compounds easily alkanes, and sometimes a small percentage of carbon
with other elements. It is also very stable and has dioxide, nitrogen, hydrogen sulphide, or helium. It is
many important uses. Its symbol in the periodic table formed when layers of decomposing plant and
is “He”. Its stability and non-reactive nature make it animal matter are exposed to intense heat and
the perfect tool for handling unstable materials. The pressure supplied by existing under the surface of the
element was discovered in 1868 during a solar Earth over millions of years. The energy that the
eclipse. It took scientists 30 years to extract and plants originally obtained from the sun is stored in
isolate the gas from the uranium ore clevite. the form of chemical bonds in the gas.
The gas is not prevalent on Earth. It is usually Natural gas is found in deep underground rock
extracted from natural gas and the typical amount formations or associated with other hydrocarbon
found in natural gas deposits ranges from 2 to 7%. It reservoirs in coal beds and as methane clathrates.
didn’t take long for governments to realize its Petroleum is another resource and fossil fuel found
usefulness in military operations. Access to it was in close proximity to and with natural gas. Most
restricted during the two World Wars. In its purest natural gas was created over time by two
form, the element doesn’t pose any health risks. mechanisms: biogenic and thermogenic. Biogenic gas
is created by methanogenic organisms in marshes,
bogs, landfills, and shallow sediments. Deeper in the
earth, at greater temperature and pressure,
thermogenic gas is created from buried organic
material.
Inhaling excessive amounts has its risks. The danger Most natural gas comes from three types of wells
is the gas functions as an asphyxiate. Inhaling helium namely natural gas and condensate wells, oil wells,
from pressure tanks can damage the lungs. The and coal bed methane wells.
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variants found in weather balloons may have other
elements that are unhealthy to breathe.
Helium Properties LNG Properties
Its atomic number indicates there are two electrons Quantities of natural gas are measured in normal
and two protons in a neutral helium atom. Its most cubic meters (corresponding to 0 °C at 101.325 kPa)
vital properties are density, melting and boiling or in standard cubic feet (corresponding to 16 °C and
points, state of matter and atomic mass. The density 14.73 psia). The gross heat of combustion of 1m3 of
is 101.325 kilopascals (kPa) and 0.1786 grams per commercial quality natural gas is around 39 MJ (10.8
litre at 32°F (0.0°C). Its atomic mass is 4.0026 grams kWh), but this can vary by several percent.
per mole.
Solid and liquid helium can only manifest in high and The burning of natural gas produces far lower
low temperature settings. Either condition cannot amounts of sulfur dioxide and nitrous oxides than
manifest under normal pressures. -272°C (0.95 other fossil fuels.
Kelvin) is the melting point. The boiling point is -268°C
(4.22 Kelvin).
One of the more interesting uses of helium is in Gas is an important transitionary fuel as countries
cryogenics. This field is concerned with low around the world look for reliable, affordable, safe
temperature phenomena and its production. Most of and low carbon alternatives to coal and nuclear, and
the helium produced today is used for cryogenics. ways of supporting renewable energy sources.
Common uses of Helium Common uses of LNG
Evidence shows that the human voice can be changed LNG or more specifically CNG is used as a motor fuel
with a bit of helium. The gas is also used as light instead of petroleum products, since it has a number
weight aircraft fuel. The element is usually combined of advantages, the most important being to provide
with hydrogen in air balloons. Hydrogen alone is fine, the industry with cleaner, more environmentally
but helium makes the balloon safer to use. The same friendly fuel, as well as offering business and
gas is used by caisson workers too as the divers use consumers a cost-effective alternate energy source.
oxygen and helium during their dives. The
Although vehicles can use natural gas as either a
combination provides them with the atmosphere
liquid or a gas, most vehicles use the gaseous form
necessary to survive in high pressure environments.
compressed to pressures above 200 bar. Tetra4
already has a pilot project whereby busses are
powered with gas in the region.
Helium Medical Applications LNG and Transportation
Helium can also be used for breathing observation. It LNG is liquefied natural gas. CNG is compressed
is essential in treating ailments such as asthma, natural gas. The key point – and the reason there are
emphysema and other conditions that affect two fuels, not one – is that gas has different energy
breathing. The gas is usually used to treat diseases densities in different states. One unit of liquid gas
that affect the lungs. energy takes up 3 times less volume than one unit of
compressed gas energy. More fuel can be stored
Hospital MRI scans reply on liquefied helium. When
onboard a vehicle using LNG because the fuel is
the element is set at -269°C (the low boiling point), it
stored as a liquid, making its energy density greater
becomes usable in cooling the MRI magnet.
than that of CNG. This makes LNG well suited for
Class 7 and 8 trucks requiring a greater range.
Acute and chronic forms of respiratory ailment Besides use in road vehicles, it is also used in aerial
treatments have helium components. In almost all vehicles. Compressed natural gas has been used in
cases, oxygen and helium are used together. This
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combination gets to the lungs much quicker. Helium some aircraft like the Aviat Aircraft Husky 200 CNG
in different forms and combinations are used in and the Chromarat VX 1 KittyHawk.
medical instrumentations and nuclear medicine.
Helium in Manufacturing and Cryogenics LNG in Power Generation
Of the 2014 world helium total production of about Natural gas is a major source of electricity generation
32 million kg (180 million standard cubic meters) through the use of cogeneration, gas turbines and
helium per year, the largest use (about 32% of the steam turbines. Natural gas is also well suited for a
total in 2014) was in cryogenic applications, most of combined use in association with renewable energy
which involves cooling the superconducting magnets sources such as wind or solar.
in medical MRI scanners and NMR spectrometers
Particularly high efficiencies can be achieved through
(Wikipedia).
combining gas turbines with a steam turbine in
Helium is used as a shielding gas in arc welding combined cycle mode. Natural gas burns more
processes on materials that at welding temperatures cleanly than other hydrocarbon fuels, such as oil and
are contaminated and weakened by air or nitrogen. coal, and produces less carbon dioxide per unit of
energy released. For transportation, burning natural
Helium is used as a protective gas in growing silicon
gas produces about 30 percent less carbon dioxide
and germanium crystals, in titanium and zirconium
than burning petroleum. For an equivalent amount of
production, and in gas chromatography, because it is
heat, burning natural gas produces about 45 percent
inert (Wikipedia).
less carbon dioxide than burning coal for power.
Helium in Space Technology Domestic Uses for LNG
NASA space programs use the gas to fuel their Natural gas dispensed in a residential setting can
shuttles. Liquid fuels are volatile. They are packed generate temperatures in excess of 1100 °C making it
with corrosive material that could destroy a a powerful domestic cooking and heating fuel. In
spacecrafts casing. To avoid this problem, a craft is much of the developed world it is supplied through
filled with helium gas. The same process is used in pipes to homes, where it is used for many purposes
blimps and air balloons. It is preferred to hydrogen as including ranges and ovens, gas heated clothes
it is not flammable. The element is also used to keep dryers, heating / cooling, and central heating.
nuclear reactors cool. Heaters in homes and other buildings may include
boilers, furnaces, and water heaters.
Other Helium Applications Other LNG Applications
Helium neon lasers use the element extensively. Natural gas is a major feedstock for the production of
These instruments are used for barcode reading. The ammonia, via the Haber process, for use in fertilizer
same element is needed to monitor small fractures in production.
ships and other vehicles.
Helium dating is relied on to date rocks that contain Natural gas is also used in the manufacture of fabrics,
uranium and titanium. glass, steel, plastics, paint, and other products.
The gas is used for protection during germanium
crystal and silicon production. It is valued as a
protective gas because of its inert nature.
Helium’s properties also make it ideal for observation Natural gas can be used to produce hydrogen, with
in quantum mechanics. Its structure is basic and easy one common method being the hydrogen reformer.
to study. Numerous mathematical processes are Hydrogen has many applications: it is a primary
used to assess subatomic particle behaviour. Using feedstock for the chemical industry, a hydrogenating
these techniques, neutrons, electrons and protons agent, an important commodity for oil refineries, and
can be studied. However, these tests cannot the fuel source in hydrogen vehicles.
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determine their actions 100% accurately. This is due
to the nature of quantum mechanics.
6.1 POTENTIAL PROJECT BENEFITS

The expected benefits of the proposed project to the South African economy and especially the Free State
Province will be:
• LNG is devoid of some of the criteria pollutants contained in crude oil and coal and thus produces
significantly less carbon dioxide emissions making it a cleaner fossil fuel energy source, an alternative
to renewable energy;
• Large capital investment for the gas production infrastructure with associated local and regional
benefits to the economy (drilling; setting the gas producing wells, pipeline, LNG/LHe plant; etc.);
• Local business opportunities whereby there is potential to make use of empowered local contracting
companies;
• Training and transferring experience and skills to local people employed;
• Social benefits such Tetra4 s Social and Labour Plan (SLP) interventions and other social responsibility
programmes;
• Will prompt further investigations on gas production and use in South Africa as well as other industries
that would have beneficial use of the gas (e.g.: fertilizer production, gas powered vehicles, etc);
• Promotion of gas as a bridging fuel towards South Africa achieving the renewable energy use targets as
opposed to the extensive use of fossil fuels in the short to medium term;
• Reduce the amount of Helium and LNG that South Africa needs to import; and
• Possible international investment into the country.
6.2 ECONOMIC FACTORS IN FAVOUR OF THE PROJECT

POSITIVE ECONOMIC IMPACTS
The economic impact is based on the optimum production year principle, which is one specific year. In this
regard, 6 years from today, namely 2028. The basis for selection is that in that year Tetra4 will be in full
production as is anticipated in the Cluster 2 expansion. Table 12 below provides an overview of the economic
costs as a basis of assessment and rows are numbered in the last column and the pertinent rows discussed in
more detail hereunder.
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Table 12: Potential economic benefits as calculated by the economic specialist and Tetra4.
Phase 2 Methane/LNG Helium Row #
Assume steady state date 2028 2028 Total

Daily Volume - 1000 Standard Cubic Feet 40 000 4 000 44 000 1
Yearly Volume - 1000 Standard Cubic Feet - 265 workdays 9 000 000 900 000 9 900 000 2
US Dollar Price per 1000scf 15 250 #N/A 3
Turnover in US Dollars (incl maint days) pa 135 000 000 225 000 000 360 000 000 4
Rand:USD Exchange (2028) 18.4 18.4 18.4 5
Turnover in Rand pa - Rand million 2 490 4 151 6 641 6
% GDP:Turnover - Estmated natural gas 55% 55% 55% 7
GDP (Economic Value Added by Tetra 4) pa Rand Million 1 370 2 283 3 653 8
Add GDP Multiplier 1.87 1.87 1.87 9
National GDP Addition - R Million 2 558 4 263 6 822 10
Estimated Direct Employment 457 761 1 218 11
Employment Multiplier 3.80 3.80 3.80 12
Total Employment 1 733 2 889 4 623 13
GGP Matjhabeng - 2028 Est (Rand Million) 53 221 53 221 53 221 14
% relative to GGP including mulitpliers 5% 8% 12.8% 15
Estimated Employment in Matjhabeng 80 211 80 211 80 211 16
% Additional employment relative to Matjhabeng 2.2% 3.6% 5.8% 17
New Investment over 2 years (Rounded off) - Rand Million 13 000 18
Deduct for imports (Equipment, Fabrication and Installation) 6 500 19
Annualise (Above investment over two years) 3 250 20
Estimated national investment multiplier 1.87 21
New investment after leakage and added multipliers per annum 6 078 22
Average investment in Matjabeng per annum 10 644 23
% New Investment relative to Matjabeng Economy pa 57% 24
Average Current Account last 10 years (127 176) 25
Tetra4 potential Mitigation to Current Account 6000 26
Tetra4 potential Mitigation to Current Account % 5% 27
The key findings in Table 12 above are outlined below.

• In row 8, in an optimal year for Cluster 2, Tetra4 could add an additional R3.65 billion to the local
economy. Including multipliers, this additional GDP could increase to R6.8 billion. Relative to the
Matjhabeng economy, this is a 13% addition to GDP. Subject to economic multiplier leakage, this is a
significant additional amount to the local economy.
• Row 11 shows that an additional 1 218 jobs could be created, and after multipliers this could amount
to 4 623 jobs throughout the country. Relative to the local economy, this is an addition of just over 5%
and needs to be considered as a significantly positive impact.
• The employment multiplier is higher than the GDP multiplier because the gas and helium industry is
capital intensive, meaning its cost per job created is high, and as the cost per job in downstream
industries are lower, thus the multiplier is in favour of job-creation downstream. In simple terms this
means that one job created by Tetra4 has the potential of creating almost 4x as many formal jobs.
• A further factor is that the project could save SA R6.6 billion in foreign exchange per annum – foreign
exchange earnings in a stable currency are important for a country as it is an indication of wealth – the
more stable currency a country possesses, the higher the quality of its financial standing in the world
which results in better trading relations and less expensive cost of capital.
DEMAND FOR HELIUM

The demand for a product or service is defined as a consumer's desire to purchase goods and services and
willingness to pay a price for such goods or services. The processing of helium is a high priority for Tetra4 and
the demand for this gas is important for the assessment of this expansion. A detailed discussion on what Helium
is as well as its many uses is included in Table 11. A summary of the commercial uses of Helium is shown in Figure
24.
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Figure 24: Uses of Helium.
Helium is a non-renewable natural resource that is mostly recovered from natural gas deposits. Thus, helium is
typically a by-product of natural gas fields. It is important to note that helium is found in recoverable quantities
in only a few locations around the world, many of which are being depleted.
In the gas fields of Virginia in the Free State, the source of helium for this study is indicated as being unique given
the high helium content in the gas field. This makes this development a potential “game changer” in the helium
industry in that Tetra4 could produce helium as its prime product, with methane potentially being a by-product.
This is a different strategy to how helium is currently recovered worldwide. The uniqueness of this situation is
that as pressure increases on reducing gas production worldwide, helium production will also decline. However,
in the case of Tetra4, as said, this status quo is reversed, meaning that the Virginia Gas fields may well become
a significant strategic helium resource in the world.
When looking at the future uses of helium, there is overwhelming evidence that this element with its rare
properties will continue to be in demand. Research is showing that helium is increasingly used in the health
industry, and as a coolant in the military and rocket industries. In addition, helium is targeted as a coolant in the
potential new nuclear energy generators using fusion, as opposed to fission. In addition, increasing consumption
of helium in the electronics and semiconductor industry is expected.
The importance of the demand for helium is that an economic need and desirability would be low if a sufficient
demand now, or in the future, could not be established. In this regard, all indications are that the demand for
helium is strong and sustainable, thus contributing strongly to the economic need and desirability of this
expansion.
The global supply and demand for Helium is shown in Figure 25 was sourced from the Edison Research Group as
published on Renergen’s website. It shows a possible slight oversupply of helium in next few years, but
thereafter demand is likely to outstrip supply (all things being equal).
A few independent forecasts for the global growth in demand for helium are mentioned below:
• Energy Industry Review, an energy magazine in Europe, predicts a 4 % CAGR between 2019 and 2027.
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• Mordor Intelligence, an independent research company, also predicted growth at 4 % CAGR between
2021 and 2026.
• Global Newswire, an independent market analyst reporting on listed investments, predicts the growth
to be 4.5 % to 2030.
• Various other sources put the growth rate of helium much higher than the three sources above - at
between 5-11 % CAGR based on the continued increase in scientific and technological innovation.
Figure 25: Global demand and supply of Helium in Billion Cubic Feet.
DEMAND FOR NATURAL GAS

In this and the section below, the need for natural gas is discussed. Note that natural gas is largely composed of
methane, and the gas fields under discussion yields methane as its primary gas. Thus, in discussing natural gas,
a discussion of methane is implicit.
The self-evident nature of the need for natural gas is stated in the list of items below (not an exhaustive list):
• The electric power sector uses natural gas to generate electricity. For example, natural gas accounted
for 40% of U.S. electricity generation in 2020, as opposed to 3% in SA.
• The industrial sector uses natural gas as a fuel for heating, as a feedstock to produce chemicals, fertilizer
and hydrogen, and many other applications.
• The residential sector uses natural gas for heating, cooking and other applications.
• The commercial sector needs natural gas to heat buildings and water, to operate refrigeration and
cooling equipment, to cook, to dry clothes, and to provide outdoor lighting. Some consumers in the
commercial sector also use natural gas as a fuel in combined heat and power systems.
• The transportation sector uses natural gas as a fuel to operate compressors that move natural gas
through pipelines and as a vehicle fuel in the form of compressed natural gas and liquefied natural gas.
At present gas still plays a significant role in the production of energy in the world. Gas makes up 25% of the
world’s electricity production and in addition, the growth in the demand for gas appears to be stable.
In South Africa, natural gas plays a relatively small part in contributing to electricity generation. Gas is not
regarded as a cleaner energy than “green energy” sources, for example solar, water and wind, but is undoubtedly
“cleaner” than coal. As a “bridging” source of energy, there is sufficient cause to rate gas as economically needed
and desirable. Gas processing in SA could therefore be favoured in the short and medium term, however, it is
very likely that at some future point, targets will be set to reduce gas production (although not Helium) in the
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same manner as targets are being set to reduce coal production today. Presently, the Integrated Resource Plan
2019 aims to increase the national energy mix natural gas contribution from 2.6% to 15.7% by 2030.
A SUSTAINABLE AND COMPETITIVE LOCAL GAS AND HELIUM INDUSTRY IN SOUTH

AFRICA
A further factor in favour of Tetra4’s expansion application is the potential for the development of a sustainable
and competitive gas and helium industry in South Africa. When a country has a comparative advantage
economically, such as gold for example historically in SA, that advantage creates economic wealth that then
translates into a better quality of life for that country’s citizens. Since the advent of the use of oil and gas
worldwide, SA has had a comparative disadvantage as it did not possess those natural resources. That meant SA
had to (and still does) import most of its oil and gas, which meant that foreign reserves had to be used to pay
for such imports. That in itself not only resulted in a decrease in GDP, but it also caused a reduction in the
country’s foreign reserves.
It can be argued that even though SA had been blessed with significant mineral resources, the lack of oil and gas
had been the country’s Achilles heel. The historic increase in the cost of gas and oil and weakening of the SA
Rand had brought about a persistent “imported” inflation to the SA economy for many decades, and unless SA
creates its own less expensive and clean energy, the country will remain less economically competitive than it
could be. Ironically, the commodity that SA has in abundance, coal, is today considered as an undesirable
commodity because of its effect on warming the earth. Thus, SA faces ominous comparative disadvantages in
the generation of future energy - the lack of natural gas, the small amount of energy that can be produced from
green energy in the foreseeable future, and the undesirable nature of coal as an energy source. There is thus a
strong case to be made for a much stronger natural gas industry in South Africa.
SA historically did not have a helium producer, and to that extent the advent of Tetra4’s helium production is in
fact the establishment of a helium industry in this country. Thus, starting from a zero base for helium, one could
therefore argue that the need and desirability of the advent of a helium sector in SA is beyond significantly high.
Figure 26 provides an overview/snapshot of the natural gas sector in SA where the supply chain of the piped-
gas industry is broadly categorised into three levels, namely upstream, mid-stream and downstream. The
upstream level of the piped-gas industry includes gas exploration and production activities. The midstream level
comprises transmission and distribution of gas, while the downstream level consists of gas reticulation and
trading activities. Sasol Gas is the dominant gas enterprise in South Africa, and it plays a major role in production,
transmission and distribution. There are not that many rivals in the South Africa gas sector and therefore the
sector may not be as efficient a sector as in countries with robust competition.
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Figure 26: South Africa natural gas sector overview.
Prior to Tetra4, there were only two suppliers of gas. The first is Sasol Gas that imports natural gas from the
Mozambique to Secunda via the transmission pipeline owned by the Republic of Mozambique Pipeline Investing
Company (ROMPCO). The transmission pipeline is 865 kilometres long with a 26-inch diameter, and a capacity
of 147 million Gigajoules per annum. Sasol Synfuels, which is a coal-based synthetic fuels manufacturing facility,
produces methane-rich gas in its plant in Secunda. Synthetic gas is produced through coal gasification and
natural gas reforming through the utilisation of Sasol’s proprietary technologies.
The other supplier, PetroSA, is a state-owned entity, owned by the Central Energy Fund, and was the only
producer of indigenous natural gas. Its offshore producing gas field is in the Bredasdorp basin and provides
feedstock for PetroSA’s Gas-to-Liquids (GTL) plant. It produces for its own exclusive use. However, this field is
close to being depleted, and further developments of the field have been undertaken to supply feedstock for
the GTL plant. In 2011, PetroSA was granted approval to explore additional gas reserves of the coast of Mossel
Bay, in which drilling activities have been ongoing.
From the above brief overview of the gas sector in SA, the need and desirability of a further gas supplier to
increase the competitiveness of the SA gas sector is undoubted. In this regard the economic need and desirability
of the Tetra4 expansion becomes even more evident.
6.3 ARGUMENTS NEUTRAL OR AGAINST THE PROJECT.

NATURAL GAS
There is more consensus than ever that GHG’s cause global warming. In this regard, SA at COP 26 had pledged
to reduce its GHG emissions by reducing its dependence on coal as a source of energy in favour of renewable
energy sources. In addition to this, economically, SA runs the risk of being sanctioned by the international
community should it persist with an intransigence regarding the use of coal.
Natural gas is therefore seen by many in the country as a “bridging” source of energy because it emits almost
50 % less CO2 than coal. Considering only tailpipe emissions, natural gas is 15-30 % cleaner than fuel when it is
burned. Thus, if SA converts its coal fired stations to natural gas tomorrow, it will save a considerable amount of
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GHG emissions. Thus, natural gas is certainly a cleaner energy source than coal, and therefore relative to coal,
must be considered as more desirable in this context.
However, detractors of prioritising natural gas over “green” renewable energy point out two particular
arguments against natural gas over green energy:
1. Natural gas still emits CO2, and hence the problem of mostly eradicating greenhouse gas emissions
globally remains unresolved if natural gas continues to be a source of electricity.
2. In addition to this, natural gas is composed of 70-90 % methane, a potent greenhouse gas and major
contributor to global warming. The argument is put forward that 2-3 % of methane escapes during
processing, transmission and reticulation. These fugitive emissions add to global warming.
Proponents of cleaner energy in South Africa have advocated that the country bypasses natural gas
developments in its entirety and concentrate on renewables like solar, wind and hydropower. Furthermore a
number of gas operators appear eager to enter the SA gas market, and although that could be of major benefit
in the reduction of the use of coal, at some future point the debate will intensify regarding the emissions of GHG
emissions in the gas industry vs that of other cleaner energy sources.
Economically, common sense does indicate that natural gas offers an interim solution for the climate change
target challenges in SA in the short to medium term. In the long term, it is very possible that even natural gas
usage becomes an undesirable commodity, as is the case with coal at present. That stated, an economic need
and desirability assessment must consider the current generation, and although not discounting future
generations, the economics of gas production in SA at present has a strong case.
HELIUM
Where the Tetra4 expansion is different from the typical gas producer is in the concentrations of helium in its
gas reserves. Whereas an economic cut-off as low as 0.05 % helium in natural gas has been proven to be
economically viable, Tetra4 has indicated that its helium concentrations are high – between 2-4 %. Helium
cannot be extracted without the natural gas (methane) and while natural gas may be replaced or phased out in
future, the natural gas will still be extracted to extract helium. The importance of helium both locally and globally
as well as the high concentrations of the helium in this particular gas resource provide strong motivation for the
need and desirability of this project despite the natural gas being extracted too.
6.4 NEED AND DESIRABILITY ANALYSIS

The needs and desirability analysis component of the “Guideline on need and desirability in terms of the EIA
Regulations (Notice 819 of 2014)” includes, but is not limited to, describing the linkages and dependencies
between human well-being, livelihoods and ecosystem services applicable to the area in question, and how the
proposed development’s ecological impacts will result in socio-economic impacts (e.g. on livelihoods, loss of
heritage site, opportunity costs, etc.). Table 13 present the needs and desirability analysis undertaken for the
project.
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Table 13: Needs and desirability analysis for the proposed Cluster 2 Gas Production Project.
Ref No. Question Answer

1 Securing ecological sustainable development and use of natural resources
1.1 How were the ecological integrity considerations taken into account in A number of specialist studies have informed this application and environmental
terms of: Threatened Ecosystems, Sensitive and vulnerable ecosystems, impact assessment and include:
Critical Biodiversity Areas, Ecological Support Systems, Conservation • Air Quality and GHG Study
Targets, Ecological drivers of the ecosystem, Environmental • Geohydrological Study
Management Framework, Spatial Development Framework (SDF) and • Terrestrial Biodiversity Study
global and international responsibilities. • Aquatic and Wetland Study
These studies assisted in identifying any Threatened Ecosystems, Sensitive and
vulnerable ecosystems, Critical Biodiversity Areas, Ecological Support Systems,
Conservation Targets and Ecological drivers of the ecosystem. Where sensitive
species or ecosystem drivers were identified, relevant mitigation measures were
put forward to prevent or minimise the impacts.
1.2 How will this project disturb or enhance ecosystems and / or result in the The nature of this project means that it covers an extensive area however the
loss or protection of biological diversity? What measures were explored permanent surface infrastructure is significantly reduced due to the pipelines being
to avoid these negative impacts, and where these negative impacts could underground. Where infrastructure is to be constructed or installed in natural
not be avoided altogether, what measures were explored to minimise areas, various measures are put forward to mitigate the impacts on biological
and remedy the impacts? What measures were explored to enhance diversity. The mitigation measures have been developed in consultation with the
positive impacts? relevant specialists as mentioned above. Existing and future alien and invasive
1.3 How will this development pollute and / or degrade the biophysical species will be controlled which will enhance the opportunities for indigenous and
environment? What measures were explored to either avoid these beneficial species in the environment.
impacts, and where impacts could not be avoided altogether, what
measures were explored to minimise and remedy the impacts? What
measures were explored to enhance positive impacts?
1.4 What waste will be generated by this development? What measures This development will generate various general and hazardous waste, the majority
were explored to avoid waste, and where waste could not be avoided of which will be generated during the construction phase. The general waste will
altogether, what measures were explored to minimise, reuse and / or be stored in designated areas and through the process of recovery and recycling,
recycle the waste? What measures have been explored to safely treat the volume of general waste being disposed to landfill will be minimised. The
and/or dispose of unavoidable waste? hazardous portion of the waste stream will also be adequately stored prior to
disposal at a suitably licenced hazardous waste disposal facility.
1.5 How will this project disturb or enhance landscapes and / or sites that A specialist heritage and palaeontological study has been commissioned in order
constitute the nation’s cultural heritage? What measures were explored to identify sites of cultural heritage or palaeontological significance. The identified
to firstly avoid these impacts, and where impacts could not be avoided sites including suitable buffers will be identified as highly sensitive / no-go areas to
prevent adverse impacts in these areas.
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altogether, what measures were explored to minimise and remedy the In addition to the above, a chance find procedure has been put forward by the
impacts? What measures were explored to enhance positive impacts? specialist should any unidentified sites of cultural heritage or palaeontological
significance be identified during the construction process.
1.6 How will this project use and / or impact on non-renewable natural It is acknowledged that due to the nature of gas resources, an onshore (potentially
resources? What measures were explored to ensure responsible and non-renewable) gas resource will be depleted. It has not yet been conclusively
equitable use of the resources? How have the consequences of the determined if this gas field is biogenic (renewable) or thermogenic (non-
depletion of the non-renewable natural resources been considered? renewable). Gas production will however contribute significantly to the country’s
What measures were explored to firstly avoid these impacts, and where economy as well as the transition from dirtier energy production (coal) to
impacts could not be avoided altogether, what measures were explored renewable energy production in the future. Locally produced gas will also result in
to minimise and remedy the impacts? What measures were explored to a reduced need for these resources to be imported. Therefore, at present, this gas
enhance positive impacts? resource is still needed within South Africa.
1.7 How will this project use and / or impact on renewable natural resources
and the ecosystem of which they are part? Will the use of the resources
and / or impacts on the ecosystem jeopardise the integrity of the
resource and / or system taking into account carrying capacity
restrictions, limits of acceptable change, and thresholds? What measures
were explored to firstly avoid the use of resources, or if avoidance is not
possible, to minimise the use of resources? What measures were taken
to ensure responsible and equitable use of the resources? What
measures were explored to enhance positive impacts?
1.7.1 Does the proposed project exacerbate the increased dependency on The proposed project will provide an opportunity for South Africa to move away
increased use of resources to maintain economic growth or does it from dirtier energy (coal) while transitioning to a more renewable energy source.
reduce resource dependency (i.e. de-materialised growth)? This can be translated into a “reduced dirty resource dependency”.
1.7.2 Does the proposed use of natural resources constitute the best use The harvesting of this gas resource would constitute a better use thereof as it is
thereof? Is the use justifiable when considering intra- and currently not being harvested in this area (other than by Tetra4) for any
intergenerational equity, and are there more important priorities for commercial beneficial use. In fact, several historically drilled gold prospecting
which the resources should be used? boreholes are undergoing uncontrolled release of Methane into the atmosphere
without being flared or burned (to only release CO2 which is a lower order GHG
pollutant).
Due to growing global geopolitical uncertainty and increasingly constrained transit
of international goods, South Africa would be well positioned to increase local
production of gas as opposed to relying on importation thereof.
1.7.3 Do the proposed location, type and scale of development promote a The location, type and scale of the proposed development promotes a reduced
reduced dependency on resources? dependency on the importation of gas resources from other countries. It will
further provide an opportunity to reduce dependency on more harmful resources
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such as coal for energy production. As such, this project should not be viewed in
isolation in terms of resources but in a holistic manner both nationally and globally.
1.8 How were a risk-averse and cautious approach applied in terms of ecological impacts:
1.8.1 What are the limits of current knowledge (note: the gaps, uncertainties In order to prevent repetition, the reader is directed to the assumptions and
and assumptions must be clearly stated)? limitations presented in Section 14.
1.8.2 What is the level of risk associated with the limits of current knowledge? No limits to current knowledge for any potential significant impacts have been
identified. The level of risk is therefore deemed to be low.
1.8.3 Based on the limits of knowledge and the level of risk, how and to what As preferred drilling locations and associated infrastructure such as pipelines
extent was a risk-averse and cautious approach applied to the cannot be identified at this stage due to the nature of exploration activities (i.e.
development? updated exploration model based on initial drilling to inform subsequent drilling),
a strategic assessment of transects (300m to 600m wide) has been undertaken as
part of this EIA process in order to identify areas of high sensitivity and no-go areas.
The sensitivity planning approach will guide the preferred placement of wells and
other infrastructure and will additionally be guided by specific landowner
consultations and negotiations. In this manner, a risk-averse and cautious
approach is able to be more fully realised in future project planning.
1.9 How will the ecological impacts resulting from this development impact on people’s environmental right in terms following?
1.9.1 Negative impacts: e.g. access to resources, opportunity costs, loss of The application and proposed development footprint occur predominantly on
amenity (e.g. open space), air and water quality impacts, nuisance (noise, properties that are commercial agricultural concerns. The well placing will be
odour, etc.), health impacts, visual impacts, etc. What measures were discussed and agreed with each affected landowner prior to commencement of
taken to firstly avoid negative impacts, but if avoidance is not possible, drilling and where necessary, appropriate compensation negotiated. Furthermore,
to minimise, manage and remedy negative impacts? as mentioned above, this EIA process has been undertaken at a more strategic level
1.9.2 Positive impacts: e.g. improved access to resources, improved amenity, assessment of the receiving environment within proposed development corridors
improved air or water quality, etc. What measures were taken to which allows input from numerous specialist disciplines to identify highly sensitive
enhance positive impacts? or no-go areas which can then be excluded from development where necessary.
The positive impact of job creation has been identified by the social specialist and
the requirement for local upliftment in the form of employment creation or social
programmes put forward.
1.10 Describe the linkages and dependencies between human wellbeing, The impact on third party wellbeing, livelihoods and ecosystem services is not of a
livelihoods and ecosystem services applicable to the area in question and high negative significance as the predominant land use of the affected properties
how the development’s ecological impacts will result in socio-economic is commercial agriculture as mentioned above, and the site sensitivities from a
impacts (e.g. on livelihoods, loss of heritage site, opportunity costs, etc.)? socio-economic and biophysical point of view have been identified and or
mitigation measures put forward which must be considered prior to the final
placement of infrastructure. Furthermore, landowner negotiations prior to final
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placement of infrastructure will additionally be undertaken to limit any negative
impacts on human wellbeing, livelihoods and/or ecosystems.
1.11 Based on all of the above, how will this development positively or As described above, this project is anticipated to have a low overall impact on the
negatively impact on ecological integrity objectives / targets / ecological integrity objectives or targets as consideration of these aspects will be
considerations of the area? undertaken prior to final placement of infrastructure.
1.12 Considering the need to secure ecological integrity and a healthy An area assigned a Very High terrestrial theme sensitivity has been delineated on
biophysical environment, describe how the alternatives identified (in the farm Adamsons Vley 655 (Portion 0) based on the presence of a protected
terms of all the different elements of the development and all the faunal species. Previous attempts to relocate this species have been unsuccessful
different impacts being proposed), resulted in the selection of the “best and in situ conservation remains the preferred outcome. This area should exclude
practicable environmental option” in terms of ecological considerations? any surface development infrastructure. Consultation and communication with the
lead or implementing agent for the sensitive species, Endangered Wildlife Trust
(EWT), must be implemented before any construction proximal to the specific area.
Monitoring and Management of the species will be crucial throughout the lifetime
of the project and must be discussed and implemented in conjunction with the
EWT.
1.13 Describe the positive and negative cumulative ecological / biophysical Refer to Section 10 of this report.
impacts bearing in mind the size, scale, scope and nature of the project
in relation to its location and existing and other planned developments
in the area?
2 Promoting justifiable economic and social development
2.1 What is the socio-economic context of the area, based on, amongst other considerations, the following:
2.1.1 The IDP (and its sector plans' vision, objectives, strategies, indicators and Details of the IDP’s for the Lejweleputswa District Municipality (LDM) as well as the
targets) and any other strategic plans, frameworks or policies applicable Matjhabeng and Masilonyana Local Municipalities are included in Section 9.4. The
to the area, proposed project will promote and support the sustainability of existing business
2.1.2 Spatial priorities and desired spatial patterns (e.g. need for integrated of in the local and regional economy and assist in increasing local beneficiation and
segregated communities, need to upgrade informal settlements, need shared economic growth, through extending the output production of gas.
for densification, etc.),
2.1.3 Spatial characteristics (e.g. existing land uses, planned land uses, cultural
landscapes, etc.), and
2.1.4 Municipal Economic Development Strategy ("LED Strategy").
2.2 Considering the socio-economic context, what will the socio-economic This project will result in positive socio-economic impacts in the local, regional and
impacts be of the development (and its separate elements/aspects), and national economy. Refer to the impact assessment in Section 10 in this report.
specifically also on the socio-economic objectives of the area?
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2.2.1 Will the development complement the local socio-economic initiatives The proposed Cluster 2 project will indirectly assist with increasing the gas
(such as local economic development (LED) initiatives), or skills production project which will ensure that the community projects initiated by
development programs? Tetra4 under their Social and Labour Plan will also have an increased life. This will
complement the local socio-economic initiatives identified for the area.
2.3 How will this development address the specific physical, psychological, Tetra4 is currently in the process of providing certain basic services such as water
developmental, cultural and social needs and interests of the relevant and electricity to the Adamsons Vley community as part of the Social and Labour
communities? Plan commitments for Cluster 1. This is an ongoing process throughout the project
implementation and would be extended to other communities in due course and
where possible. During the Scoping phase focus group consultation with the
Adamsons Vley community, the community members acknowledged that the
water and solar electricity project was currently underway in their community.
They have been provided with a new borehole, pump and storage tanks for water.
In addition, solar PV for lighting is being installed on the houses. Should Cluster 2
be approved and implemented, there would be further opportunities for SLP
upliftment in the long term.
2.4 Will the development result in equitable (intra- and inter-generational) None of the identified impacts are anticipated to have a high negative impact
impact distribution, in the short- and long-term? Will the impact be significance post mitigation. It is therefore not anticipated that this project will
socially and economically sustainable in the short- and long-term? result in negative equitable impact distribution in the short- and long-term.
2.5 In terms of location, describe how the placement of the proposed development will:
2.5.1 Result in the creation of residential and employment opportunities in The proposed Cluster 2 development will be an extension to the current Cluster 1
close proximity to or integrated with each other. development and will promote further employment opportunities (to a limited
2.5.2 Reduce the need for transport of people and goods. extent) both locally and regionally. This project is not anticipated to have a material
2.5.3 Result in access to public transport or enable non-motorised and impact on the need for transport of people and good or impact on access to public
pedestrian transport (e.g. will the development result in densification transport.
and the achievement of thresholds in terms of public transport),
2.5.4 Compliment other uses in the area, The Cluster 2 project will be an extension of the existing Cluster 1 project and
therefore will complement the existing activities in the area.
2.5.5 Be in line with the planning for the area. Refer to item 2.1.1 of this table (above).
2.5.6 For urban related development, make use of underutilised land available Not applicable. The proposed project is not located in an urban area.
with the urban edge.
2.5.7 Optimise the use of existing resources and infrastructure, The Cluster 2 project will be an extension of the existing Cluster 1 project and
2.5.8 Opportunity costs in terms of bulk infrastructure expansions in non- therefore will complement the existing activities and resources in the area.
priority areas (e.g. not aligned with the bulk infrastructure planning for
the settlement that reflects the spatial reconstruction priorities of the
settlement),
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2.5.9 Discourage "urban sprawl" and contribute to compaction / densification. This project is located in a rural setting and is not anticipated to have an impact on
or any control over urban sprawl in the nearby towns.
2.5.10 Contribute to the correction of the historically distorted spatial patterns Refer to items 2.5.7 – 2.5.9 of this table (above).
of settlements and to the optimum use of existing infrastructure in
excess of current needs,
2.5.11 Encourage environmentally sustainable land development practices and This project will have a minimal impact on the current land uses in the application
processes area as the pipeline network is subterranean while the production wells are
insignificantly small in area (less than 2m2 each). This will allow for existing land
uses to continue while this gas development project is ongoing.
2.5.12 Take into account special locational factors that might favour the specific The proposed Cluster 2 project is an extension of the existing Cluster 1 gas
location (e.g. the location of a strategic mineral resource, access to the production project and falls within the approved Production Right area.
port, access to rail, etc.),
2.5.13 The investment in the settlement or area in question will generate the As mentioned in 2.5.11 above, this project will not sterilise existing land uses and
highest socio-economic returns (i.e. an area with high economic therefore it will in fact result in higher economic returns per land area as both
potential). agriculture and gas production can occur simultaneously.
2.5.14 Impact on the sense of history, sense of place and heritage of the area The proposed development is an extension of the existing gas production
and the socio-cultural and cultural-historic characteristics and operations in the area and therefore will have a minimal impact on the existing
sensitivities of the area, and sense of place. Furthermore, a detailed Heritage Impact Assessment is included in
this assessment which has identified numerous existing cultural and heritage sites
which allows for their protection from negative impacts.
2.5.15 In terms of the nature, scale and location of the development promote The proposed project will indirectly contribute to continued employment in the
or act as a catalyst to create a more integrated settlement? region, as well as projects implemented from Tetra4s SLP.
2.6 How was a risk-averse and cautious approach applied in terms of socio-economic impacts:
2.6.1 What are the limits of current knowledge (note: the gaps, uncertainties Refer to Section 14 of this report.
and assumptions must be clearly stated)?
2.6.2 What is the level of risk (note: related to inequality, social fabric, The level of risk is considered low as the project is not expected to have far
livelihoods, vulnerable communities, critical resources, economic reaching negative impacts on socio-economic conditions.
vulnerability and sustainability) associated with the limits of current
knowledge?
2.6.3 Based on the limits of knowledge and the level of risk, how and to what Specific emphasis was placed on the potential socio-economic impacts.
extent was a risk-averse and cautious approach applied to the Engagements with affected communities and landowners were undertaken to
development? understand the dynamic socio-economic environment and the risks associated
with the project. Valuable feedback was received and thereafter specific conditions
of the authorisation have been put forward to ensure that pre-emptive attention
is given to these impacts at all times. In essence, no development is to take place
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on a particular property until such time as the landowner has been thoroughly
consulted, signed contracts in place and suitable compensation made for any
adverse impacts on livelihoods.
2.7 How will the socio-economic impacts resulting from this development impact on people's environmental right in terms following:
2.7.1 Negative impacts: e.g. health (e.g. HIV-Aids), safety, social ills, etc. What Refer to the impact assessment in Section 10 of this report. Both positive and
measures were taken to firstly avoid negative impacts, but if avoidance negative socio-economic impacts have been identified and relevant mitigation
is not possible, to minimise, manage and remedy negative impacts? measures put forward to reduce negative impacts and enhance positive impacts as
2.7.2 Positive impacts. What measures were taken to enhance positive far as practicable.
impacts?
2.8 Considering the linkages and dependencies between human wellbeing,
livelihoods and ecosystem services, describe the linkages and
dependencies applicable to the area in question and how the
development's socioeconomic impacts will result in ecological impacts
(e.g. over utilisation of natural resources, etc.)?
2.9 What measures were taken to pursue the selection of the "best
practicable environmental option" in terms of socio-economic
considerations?
2.10 What measures were taken to pursue environmental justice so that
adverse environmental impacts shall not be distributed in such a manner
as to unfairly discriminate against any person, particularly vulnerable and
disadvantaged persons (who are the beneficiaries and is the
development located appropriately)? Considering the need for social
equity and justice, do the alternatives identified, allow the "best
practicable environmental option" to be selected, or is there a need for
other alternatives to be considered?
2.11 What measures were taken to pursue equitable access to environmental The potential impact on existing land uses has been identified from the start of this
resources, benefits and services to meet basic human needs and ensure application process and an assessment of this impact as well as mitigation
human wellbeing, and what special measures were taken to ensure measures put forward to prevent undue negative impacts in this regard. Refer to
access thereto by categories of persons disadvantaged by unfair the impact assessment in Section 10 of this report.
discrimination?
2.12 What measures were taken to ensure that the responsibility for the Refer to the impact assessment in Section 10 of this report. The EIA and EMPr will
environmental health and safety consequences of the development has specify timeframes within which mitigation measures must be implemented.
been addressed throughout the development's life cycle?
2.13 What measures were taken to:
2.13.1 Ensure the participation of all interested and affected parties.
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2.13.2 Provide all people with an opportunity to develop the understanding, Notwithstanding the detailed description of the stakeholder consultation process
skills and capacity necessary for achieving equitable and effective included in Section 8 of this report, the consultation process has been undertaken
participation, in 3 languages (English, Afrikaans and Sesotho), published in newspaper
2.13.3 Ensure participation by vulnerable and disadvantaged persons, advertisements, erection of 78 site notices (in all three languages), direct emails,
2.13.4 Promote community wellbeing and empowerment through faxes, SMSs and registered letters where contact information was available.
environmental education, the raising of environmental awareness, the Furthermore, public and focus group meetings were undertaken during the
sharing of knowledge and experience and other appropriate means, Scoping phase with translators available for all 3 languages and another round of
2.13.5 Ensure openness and transparency, and access to information in terms meetings will be undertaken during the EIA phase during which any additional
of the process, consultation requirements of the I&APs will be identified and addressed where
2.13.6 Ensure that the interests, needs and values of all interested and affected necessary.
parties were taken into account, and that adequate recognition were
given to all forms of knowledge, including traditional and ordinary
knowledge,
2.13.7 Ensure that the vital role of women and youth in environmental
management and development were recognised and their full
participation therein will be promoted?
2.14 Considering the interests, needs and values of all the interested and
affected parties, describe how the development will allow for
opportunities for all the segments of the community (e.g. a mixture of
low-, middle-, and high-income housing opportunities) that is consistent
with the priority needs of the local area (or that is proportional to the
needs of an area)?
2.15 What measures have been taken to ensure that current and / or future Workers will be educated on a regular basis as to the environmental and safety
workers will be informed of work that potentially might be harmful to risks that may occur within their work environment. Furthermore, adequate
human health or the environment or of dangers associated with the measures will be undertaken to ensure that the appropriate personal protective
work, and what measures have been taken to ensure that the right of equipment is issued to workers based on the areas that they work and the
workers to refuse such work will be respected and protected? requirements of their job. Their right to refuse work (if considered dangerous) will
be included in the education programme.
2.16 Describe how the development will impact on job creation in terms of, amongst other aspects:
2.16.1 The number of temporary versus permanent jobs that will be created. This Cluster 2 project is an extension to the existing Cluster 1 project which is
2.16.2 Whether the labour available in the area will be able to take up the job nearing completion of construction. This would therefore provide further
opportunities (i.e. do the required skills match the skills available in the employment opportunities to those temporary employees on the Cluster 1 project
area). and who’s contracts may be nearing completion.
2.16.3 The distance from where labourers will have to travel. The specialist economic impact assessment identified that economy-wide job
2.16.4 The location of jobs opportunities versus the location of impacts. creation after multipliers may be as high as 4 600 and multiplying that by the SA
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2.16.5 The opportunity costs in terms of job creation. 6:1 dependency ratio, then the amount of people that could benefit from the
cumulative job creation could be as high as 28 000.
The current workers travel from the local area (~20-40 km) to the Cluster 1 project,
and it is therefore expected that similar travel requirements will apply to the
Cluster 2 project.
2.17 What measures were taken to ensure:
2.17.1 That there were intergovernmental coordination and harmonisation of The Scoping and EIA Process requires governmental departments to communicate
policies, legislation and actions relating to the environment. regarding any application. In addition, all relevant departments are notified at
2.17.2 That actual or potential conflicts of interest between organs of state were various phases of the project by the EAP and any feedback received from
resolved through conflict resolution procedures. government departments is considered where relevant.
2.18 What measures were taken to ensure that the environment will be held Environmental attributes that may be impact by this project have been identified
in public trust for the people, that the beneficial use of environmental and where relevant, specialist input has been solicited to ensure that a rigorous
resources will serve the public interest, and that the environment will be impact assessment process is undertaken. Where positive impacts on the interests
protected as the people's common heritage? of the public have been identified (e.g. job creation, impact on existing land use,
etc.), mitigation measures are put forward to enhance positive impacts and/or
reduce negative impacts.
2.19 Are the mitigation measures proposed realistic and what long-term The Cluster 1 EMPr construction mitigation measures have been tested in the real
environmental legacy and managed burden will be left? world as construction of Cluster 1 has recently been completed. The EIA specialist
team has assessed these Cluster 1 management measures for adequacy and where
relevant made amendments or additions. Furthermore, based on concerns raised
by the affected landowners, additional measures have been put forward to
strengthen measures and thereby reduce negative impacts.
2.20 What measures were taken to ensure that the costs of remedying Tetra4 provides annual updates of their Cluster 1 financial provisioning to the
pollution, environmental degradation and consequent adverse health Competent Authority and the provision will be adjusted to reflect the Cluster 2
effects and of preventing, controlling or minimising further pollution, costs.
environmental damage or adverse health effects will be paid for by those
responsible for harming the environment?
2.21 Considering the need to secure ecological integrity and a healthy bio- Refer to Section 7 wherein a description of the process followed to reach the
physical environment, describe how the alternatives identified (in terms proposed preferred site.
of all the different elements of the development and all the different
impacts being proposed), resulted in the selection of the best practicable
environmental option in terms of socio-economic considerations?
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2.22 Describe the positive and negative cumulative socio-economic impacts Refer to the impact assessment and mitigation measures in Section 10 of this
bearing in mind the size, scale, scope and nature of the project in relation Report.
to its location and other planned developments in the area?
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7 PROJECT ALTERNATIVES
The assessment of the identified alternatives is a key aspect of the success of the EIA process. All reasonable and
feasible alternatives must be identified and screened to determine the most suitable alternatives to prevent
unnecessary impacts on the receiving environment. There are however some constraints that must be
considered when identifying feasible alternatives for a project of this scope. Such constraints include social,
environmental, and financial related issues that will be considered in the evaluation of the alternatives.
Alternatives can typically be identified according to:
• Activity alternatives;
• Location alternatives;
• Design and layout alternatives;
• Process alternatives; and
• The No Action alternative (No-go Alternative).
For any alternative to be considered feasible such an alternative must meet the need and purpose of the
development proposal without presenting significantly high associated impacts. Essentially, alternatives
represent different means of meeting the general purpose and need of the proposed project through the
identification of the most appropriate and feasible method of development, all of which are discussed below.
Alternatives can also be distinguished into discrete or incremental alternatives. Discrete alternatives are overall
development options, which are typically identified during the pre-feasibility, feasibility and or scoping phases
of the EIA process (DEAT; 2004). Incremental alternatives typically arise during the EIA process and are usually
suggested as a means of addressing identified impacts. These alternatives are closely linked to the identification
of mitigation measures and are not specifically identified as distinct alternatives.
7.1 ACTIVITY ALTERNATIVES

The current land uses within the Cluster 2 study area and surroundings comprise of the existing Tetra4 Cluster
1 gas production project along with mining and agriculture. Gas production operations, as a land use, is often
viewed as directly competing and eventually replacing existing land uses. However, a mixed land use approach
consisting of gas production and agriculture as has been demonstrated within the Cluster 1 project is feasible
and achievable. Current agricultural activities within the Cluster 1 study area are able to continue within the
vicinity of the gas production activities, particularly because the proposed pipeline network is below ground at
a depth that allows for continued agricultural practises including ploughing. The surface infrastructure of the gas
production network is extremely small compared to the overall application area (even on an individual property)
however lessons learned from the final siting (location) of the surface infrastructure in Cluster 1 has resulted in
a more refined approach for Cluster 2.
Mixed land use consisting of conservation and gas production is unlikely to coexist due to certain land use
restrictions within national parks/ nature reserves and buffer areas as per the National Environmental
Management: Protected Areas Act (2003) (NEMPPA). However, there are currently no conservation areas (e.g.
IBAs, nature reserves, etc.) within the Cluster 2 study area, as well as no known plans for the expansion of any
IBAs or nature reserves within or adjacent to the Cluster 2 study area. The Goldfields Game Ranch as well as a
number of privately owned game farms occur within the study area however these are not designated as formal
protected areas, IBAs, nature reserves, etc. Therefore, the proposed gas production activity in conjunction with
current agricultural and mining land uses has been assessed considered in view of the above. No additional
activity alternatives are identified.
7.2 LOCATION ALTERNATIVES

Location alternatives can apply to the entire Cluster 2 project (e.g. the strategic decision to locate the proposed
development in the Free State within the Lejweleputswa District where there is an existing Production Right
held by Tetra4), as well as the specific individual components of the proposed developments (e.g. the location
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of wells, pipelines, booster and compressor stations and the LNG/LHe plant including any associated
infrastructure within the study area).
Tetra4 currently holds an approved Production Right (12/4/1/07/2/2) which spans approximately 187 000
hectares to develop gas fields around the town of Virginia in the Free State Province. Cluster 2 is the second
phase of site-specific assessments for expanded production activities planned within the Production Right area.
Cluster 1 which has just recently gone into gas production operation involved/involves exploration drilling
activities, establishment of production wells, connection of production wells with pipelines and construction and
operation of two compressor stations and the first LNG/LHe gas beneficiation plant. The Cluster 1 exploration
program has provided sufficient data to unequivocally confirm the viability of gas production in the area.
Location alternatives can be considered from a macro- or microscale. From a macro location perspective the
production is driven by the presence of the target resource and therefore this activity cannot be undertaken in
other areas due to the absence of the target resource (fractures, faults and/or fissures in the geological
structure).
The Cluster 2 project will expand upon this existing Cluster 1 operation and where possible pipelines, compressor
stations and the LNG/LHe Plant will be constructed adjacent to the Cluster 1 infrastructure to prevent
unnecessary and further disturbance of existing land uses.
In summary, the location of Cluster 2 must be within the approved Production Right area as per the proposed
study area and the Cluster 1 operation has confirmed the viability of the project in this area. Therefore an
entirely different location within South Africa is not a feasible macro-alternative that can be further interrogated.
Micro-alternatives for various infrastructure has however been considered in light of the consultation feedback
from the scoping process and is discussed in more detail in the subsections below.
During the scoping phase consultation, certain landowners voiced their concerns around the location of certain
aboveground infrastructure on their properties which has the potential to interfere with existing land use. These
concerns focussed on the following:
• Cultivated lands:
o Above ground infrastructure such as production wells, low point drains, pigging stations,
booster stations, pipe markers etc pose an obstacle to the heavy farming equipment that is
used. For example combine harvesters cannot easily navigate around these obstacles which
consequently results in reduced cultivated areas to avoid such infrastructure entirely.
o The timing of construction is important since cultivated lands require sowing and harvesting
during certain seasons.
• Game farming camps:
o Certain game farms rely on hunting as a form of income. Therefore the timing of construction
activities as well as access for maintenance during operations needs to take into consideration
the hunting season and or existing or planned hunts.
o Certain game farms have been re-established from previous cultivated lands or grasslands into
a more biodiverse ecosystem with trees, shrubs and grasses and stocked with a variety of game
animals. The effort and costs involved to achieve this land use have been considerable and any
disturbances or destruction of the current environment on these farms will result in negative
impacts on the landowners.
o Servitudes running through established forest or thicket areas result in a clearing of the trees
along the 10m wide servitude. This has a negative visual impact on the sense of place as well
as impacts on the foraging or behaviour of certain game species.
• Visual/sense of place and noise:
o Construction activities within close proximity to farmsteads etc result in a negative visual
perception as well as noise irritation.
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• Safety and security:
o Safety and security in farming areas is a well-known concern and risk and the project will
require farm access by several unknown personnel to the landowners at various stages of the
project implementation.
WELL SITES
The proposed Cluster 2 project involves 300 new production wells located within various 600 m wide transects
in the application area as shown in Figure 6. These transects have been delineated based on underlying
geological features (known fractures/fault lines) which are the most suitable location to intercept gas reserves.
Directional drilling methods are employed to intercept the fault lines which requires drilling some distance away
from the actual fault lines. As such, a 300 m buffer was applied along these known fault lines which resulted in
the 600 m wide transects within which the exploration drilling will be undertaken. As not all exploration wells
are gas bearing, the number of exploration wells will exceed the production wells by a factor of roughly 25 %
(i.e. ~400 exploration wells to result in ~300 production wells). These non-gas bearing wells will not require
pipeline connections and will be decommissioned and rehabilitated once confirmed to be non-gas bearing.
Although the final positions of the proposed exploration wells are subject to change during the exploration
campaign as new data becomes available, the final well locations will remain within the 600 m well transects
and will be guided by the sensitivities identified from the specialist assessments as well as the concerns raised
by the landowners to position the well sites in such a manner to avoid adverse impact as far as possible. The
final sensitivity mapping approach is detailed in Section 11 while the measures to address landowners’ concerns
are listed below.
1. Exploration drilling sites will be negotiated and agreed with the affected landowners prior to final siting
and appropriate compensation will additionally be agreed upon contractually and provided on an
annual basis during construction and operations.
2. If the geology allows, then the footprint of more than one drill well can be contained in the same
exploration drill site. However, should the same site be used, it cannot be done in parallel but rather in
sequence i.e. one well drilled and completed then followed by another thereby extending the time on
the property with appropriate compensation adjustments where relevant.
3. Where a production well surface infrastructure would negatively impact on existing land use (cultivated
areas, game farming, etc), the well will be connected underground (1.5m deep) to the offtake pipeline
with the surface well chamber being located some distance away from the actual well. For example the
well chamber could be located along the fence lines or similar area so as not to interfere with ongoing
land use.
4. Several specific measures to address safety and security risks have been put forward as
recommendations for inclusion in the decision and in order to prevent significant duplication in this
report, refer to Section 13.4.
PIPELINE ROUTES (SERVITUDES AND INLINE INFRASTRUCTURE)

Further to the above well site location alternative description, the pipeline routes are largely dependent on the
location of the gas-bearing wells in order to connect these wells to the main gas trunklines leading to the
compressor stations. The assessed pipeline transects are 300 m wide (Figure 6) and within these areas, the final
siting of the pipelines will be determined. The final pipeline routes will be guided by the sensitivities identified
from the specialist assessments as well as the concerns raised by the landowners to position the pipelines and
above ground inline infrastructure in such a manner to avoid adverse impact as far as possible. The final
sensitivity mapping approach is detailed in Section 11 while the measures to address landowners’ concerns are
listed below.
1. Pipelines and associated inline infrastructure will be negotiated and agreed with the affected
landowners prior to final siting and appropriate compensation will additionally be agreed upon
contractually and provided on an annual basis during construction and operations.
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2. All pipelines will be buried at least 1.5m below ground (to top of pipe).
3. Tetra4 will investigate alternatives methods for the removal of condensation water in the pipelines with
the intention to limit or reduce the number of low point drains in the system which require regular
maintenance. This may include nitrogen purging lines to flush out the system.
4. A number of specific measures to address safety and security risks have been put forward as
recommendations for inclusion in the decision and in order to prevent significant duplication in this
report, refer to Section 13.4.
COMPRESSOR STATIONS
Three compressor stations are required within the Cluster 2 gas pipeline network and must be located within
the transmission pipeline transects in order to be able to tie into the pipelines. The three compressor stations
(CS) are numbered CS1, CS2 and CS3 as shown in Figure 6. At this early stage in the project, the electricity supply
to the CS3 site on the farm Doorn River 330 (Portion 2) is uncertain and therefore an alternative site has been
considered. This alternative site is located adjacent to the existing Cluster 1 compressor station A (CSA) on the
farm Palmietkuil 328 (Portion 6) where power supply is available.
These location alternatives for CS3 are referred to as:
• CS3_L1 (Doorn River 330 (Portion 2))
• CS3_L2 (Palmietkuil 328 (Portion 6))
From an engineering cost perspective, the CS3_L2 (Palmietkuil) location would require more expensive piping in
the southern gas transmission network to strengthen the pipe network however the risk of not having sufficient
electricity for the CS3_L1 (Doorn Rivier) location would outweigh the additional costs.
During the scoping consultation process, the Doorn Rivier landowner provided a list of concerns relating to the
project and specifically the compressor stations. These concerns along with specialist input have been
considered in the preferred alternative analysis in Section 13.2.
LNG/LHE PLANT
The location of the Cluster 2 plant has been selected for two main reasons namely:
1. The approved Cluster 1 plant has been constructed in this location with access off the R30 and in
addition, certain infrastructure such as offices, ablution, waste storage and treatment can be shared by
the Cluster 2 plant. Therefore the Cluster 2 plant location has been sited directly adjacent to the existing
Cluster 1 plant which will prevent unnecessary further disturbances and impacts in other locations.
2. Tetra4 is the legal owner of the farm on which the plant complex is proposed (remaining extent of the
farm Mond van Doornrivier 38), and the sensitivities of the farm are well known with no highly sensitive
areas to be impacted on.
As the most suitable location for the Cluster 2 plant has already been identified, no location alternatives for the
Cluster 2 Plant were assessed.
7.3 DESIGN AND LAYOUT ALTERNATIVES

Design and layout alternatives ensure the consideration of different design and spatial configurations of the
proposed development within a specific location, to enhance the positive impacts and to reduce the negative
impacts. The proposed Cluster 2 gas production project is foremost guided by the location of existing gas bearing
geological fractures/faults (well transects) with the location of the LNG/LHe plant being situated adjacent to the
existing Cluster 1 plant. The pipelines and compressor stations connect the production wells and ultimately to
the plant and therefore due consideration has been given to the placement and orientation of required
infrastructure and activities. The sensitivity planning approach as described in Section 11 as well as the measures
to address impacts on landowners described in Section 7.2 above for the well and pipeline transects will guide
the final layout position of the various infrastructure. The layout of surface infrastructure, access roads, and
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associated surface structures will undergo a micro siting exercise whereby environmental features on site as
well as current land uses, and infrastructure are considered towards ensuring that the proposed Cluster 2 project
activities avoid areas of high environmental sensitivity and minimise infringement on existing infrastructure and
land use as much as possible.
The surface infrastructure to be constructed for the Cluster 2 production wells shall undergo a design change
from what was constructed in the Cluster 1 development due to security issues as well as visual impacts. There
are 19 production wells in Cluster 1 which were equipped in line with globally accepted practice designs. There
have however been various instances of theft of infrastructure due to the visibility thereof and remote locations
of some of the wells. These Cluster 1 production well designs are also more visually intrusive. As there will be
approximately 300 production wells in the Cluster 2 development, the production well chamber designs have
been altered to a concrete bunker type design which is largely underground. This will result in a far lower visual
impact as well as a smaller aboveground constructed footprint per well (1,4 m x 1,1 m concrete manhole with a
height aboveground of ~0.25m).
7.4 PROCESS ALTERNATIVES

Process alternatives imply the investigation of alternative processes or technologies that can be used to achieve
the same goal for the proposed gas production development. This includes using environmentally friendly
designs or materials and reusing scarce resources like water and non-renewable energy sources. No specific
process alternatives have been identified for the Cluster 2 project as the existing Cluster 1 development has
proven processes in place. In addition, certain preferential process alternatives have already been incorporated
into the project design such as the site water treatment facility to allow for water treatment, recovery and
conservation. Similarly any boiloff gas within the LNG tanks is captured for reprocessing as opposed to venting
to atmosphere. Therefore no additional process alternatives have been assessed.
7.5 TECHNOLOGY ALTERNATIVES

The selection of the techniques to be adopted for the construction and operation of the gas production
infrastructure has considered the requirements for gas wells (i.e. drill depths, well string casing, maximising gas
collection, etc.); pipeline function and efficiency; as well as helium and LNG processing, storage and distribution.
Based on the experience and lessons learned from the Cluster 1 development, no further technology alternatives
are proposed.
7.6 NO GO ALTERNATIVE
The “No Go” or “No Action” alternative refers to the alternative of not embarking on the proposed project at
all. This alternative would imply that the current status quo without the proposed Cluster 2 gas production
development would continue (albeit the existing Cluster 1 gas production operation would continue). It is
important to note that the No Go alternative is the baseline against which all other alternatives and the
development proposal are assessed (i.e. Cluster 1 operation is included in the baseline condition).
When considering the No Go alternative, the impacts (both positive and negative) associated with any other
specific alternative, or the current project proposal would not occur and in effect the impacts of the No Go
alternative are therefore inadvertently assessed by assessing the other alternatives. In addition to the direct
implications of retaining the status quo there are certain other indirect impacts, which may occur should the No
Go alternative be followed. The No Go alternative as a specific alternative is not considered feasible and has
been scoped out at this EIA phase assessment.
7.7 SENSITIVITY PLANNING APPROACH

As described in Section 7.2 above and detailed in Section 11, the sensitivity planning approach will guide the
final location of the proposed wells, pipelines and related infrastructure.
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8 STAKEHOLDER ENGAGEMENT
The Public Participation Process (PPP) is a requirement of several pieces of South African legislation and aims to
ensure that all relevant Interested and Affected Parties (I&APs) are consulted, involved and their comments are
considered, and a record included in the reports submitted to the Authorities. The process ensures that all
stakeholders are provided this opportunity as part of a transparent process which allows for a robust and
comprehensive environmental study. The PPP for the proposed project needs to be managed sensitively and
according to best practises to ensure and promote:
• Compliance with international best practice options;
• Compliance with national legislation;
• Establishment and management of relationships with key stakeholder groups; and
• Involvement and participation in the environmental study and authorisation/approval process.
The purpose of the PPP and stakeholder engagement process is to:
• Introduce the proposed project;
• Explain the authorisations required;
• Explain the environmental studies already completed and yet to be undertaken (where applicable);
• Solicit and record any issues, concerns, suggestions, and objections to the project;
• Provide opportunity for input and gathering of local knowledge;
• Establish and formalise lines of communication between the I&APs and the project team;
• Identify all significant issues for the project; and
• Identify possible mitigation measures or environmental management plans to minimise and/or prevent
negative environmental impacts and maximize and/or promote positive environmental impacts
associated with the project.
8.1 GENERAL APPROACH TO PUBLIC PARTICIPATION

The PPP for the proposed project has been undertaken in accordance with the requirements of the NEMA EIA
Regulations (2014), and in line with the principles of Integrated Environmental Management (IEM). IEM implies
an open and transparent participatory process, whereby stakeholders and other I&APs are afforded an
opportunity to comment on the project and have their views considered and included as part of project planning.
At the start of the application process, an initial I&AP database was compiled based on known key I&AP’s
(previous Cluster 1 application, affected landowners, Organs of State, etc.), Windeed searches and other
stakeholder databases. The I&AP database includes amongst others, landowners, communities, regulatory
authorities and other special interest groups. The database has been continually updated as and when new
I&AP’s show interest in the application.
National, Provincial and Local Government Authorities as well as State Owned Entities (SOE’s) were notified of
the proposed project and include:
• Eskom Holdings SOC Limited
• Free State Department of Agriculture& Rural Development
• Free State Department of Cooperative Governance and Traditional Affairs
• Free State Department of Economic, Small Business Development, Tourism and Environmental Affairs
• Free State Department of Mineral Resources and Energy
• Free State Department of Police, Roads and Transport
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• Free State Department of Public Works and Infrastructure
• Free State Department of Water and Sanitation
• Free State Development Corporation
• Free State Heritage Resources Authority
• Lejweleputswa Development Agency
• Lejweleputswa District Municipality
• Masilonyana Local Municipality
• Matjhabeng Local Municipality
• National Department of Agriculture, Land Reform and Rural Development
• National Department of Forestry, Fisheries and Environment
• National Department of Transport
• National Department of Water and Sanitation
• National Energy Regulator of South Africa (NERSA)
• National House of Traditional Leaders
• Petroleum Agency of South Africa (PASA)
• Sedibeng Water
• South African Heritage Resources Agency
• South African National Biodiversity Institute
• South African National Roads Agency Ltd: Eastern Region
• Transnet SOC Limited
Non-Governmental Organisations (NGOs) and Non-Profit Organisations (NPOs) including:
• African Conservation Trust
• Afriforum
• Birdlife South Africa
• Centre for Environmental Rights
• Conservation South Africa
• Earthlife Africa
• Endangered Wildlife Trust
• Federation for Sustainable Environment
• Gold and Uranium Belt Impact Sensoring Organisation
• Groundwork South Africa
• Vaal Environmental Justice Alliance
• Wildlife and Environment Society of South Africa
• World Wildlife Fund
In addition to the above, attempts to consult with directly affected landowners, adjacent landowners,
community and farming representatives, occupiers of land, etc. were made. A total of 78 site notices and a
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number of A3 posters were placed in and around the study area in conspicuous area in an attempt to solicit
input from any I&AP’s who were not pre-identified and registered on the I&AP database.
8.2 INITIAL NOTIFICATION

The PPP commenced on 20 May 2022 with an initial notification and call to register for a period of 30 days. The
initial notification was undertaken in English, Afrikaans and Sesotho and was given in the following manner:
REGISTERED LETTERS, FAXES AND EMAILS

Notification letters, faxes, and emails were distributed to all pre-identified I&APs including government
organisations, NGOs, relevant municipalities, ward councillors, landowners and other organisations that might
be interested or affected.
The notification letters included the following information to I&APs:
• The purpose of the proposed project;
• High level list of anticipated activities to be authorised;
• Scale and extent of activities to be authorised;
• Information on the intended production operation to enable I&APs to assess/surmise what impact the
activities will have on them or on the use of their land;
• Details of the affected properties (including details of where a locality map and other information could
be obtained including a Background Information Document (BID) in the 3 languages);
• Summary of the relevant legislation pertaining to the application process;
• Initial registration period timeframes;
• A request for I&APs to confirm that they wish to be registered on the database moving forward as in
terms of the POPI Act, if pre-identified I&AP’s do not confirm this, they will be removed from the
database moving forward; and
• Contact details of the EAP.
NEWSPAPER ADVERTISEMENTS / GOVERNMENT GAZETTE

Advertisements describing the proposed project and EIA process were published in the Vista Newspaper with
circulation in the vicinity of the study area. The initial advertisements were placed in the Vista newspaper in
English, Afrikaans and Sesotho on the 19 May 2022 with a government gazette published (also in 3 languages)
on 1 July 2022. The newspaper adverts included the following information:
• Project name;
• Applicant name;
• Project location description including a map;
• Nature of the activity and application;
• Where additional information could be obtained; and
• Relevant EIMS contact person and contact details for the project.
SITE NOTICE PLACEMENT

A1 Correx site notices in English, Afrikaans and Sesotho were placed at 78 locations within and around the
application area from 16 May 2022 to 19 May 2022. The on-site notices included the following information:
• Project name;
• Applicant name;
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• Project location;
• Map of proposed application area;
• Project description;
• Legislative requirements; and
• Relevant EIMS contact person and contact details for the project.
POSTER PLACEMENT
A3 posters in English, Afrikaans and Sesotho were placed at local public gathering places in Welkom, Theunissen
and Virginia (Welkom Public Library, Retail Spar, Retail Pick n Pay, Virginia Public Library, Theunissen Magistrates
Court and Masilo (Theunissen) Public Library.
The notices and posters afforded I&APs who may be interested in the project with the opportunity to register
for the project as well as to submit any issues/queries/concerns and indicate the contact details of any other
potential I&APs that should be contacted. The contact person at EIMS and contact details were stated on the
posters. Comments/concerns and queries were encouraged to be submitted in either of the following manners:
• Electronically (fax, email);
• Telephonically; and/or
• Written letters (postal).
8.3 SCOPING PHASE PUBLIC PARTICIPATION

Notification regarding the availability of the Scoping Report for public review was given in the following manner
to all registered I&APs:
• Registered letters with details on where the scoping report could be obtained and/or reviewed, public
meeting date and time, EIMS contact details as well as the public review comment period;
• Facsimile notifications with information like that in the registered letter described above;
• Email notifications with a letter attachment containing the information described above; and/or
• Summarised SMS notifications with relevant contact details and where more information could be
obtained.
Hard copies of the report were made available in the Virginia Public Library and the Welkom Public Library, and
an electronic copy was made available on the EIMS website. The scoping report was made available for public
review from 29 July 2022 to 30 August 2022 and during this period, various meetings and open days were held
as follows:
• Tuesday 23 August 2022: Community Meeting (Stilte Primary School) 12H00-14H00
• Tuesday 23 August 2022: Community Meeting (Adamsons Vley Primary School) 16H00-18H00
• Wednesday 24 August 2022: Farmers Focus Group Open Day (Goldfields Game Ranch) 10H00-16H00
• Wednesday 24 August 2022: Farmers Focus Group Public Meeting (Goldfields Game Ranch) 17H00-
19H00
• Thursday 25 August 2022: Public Open Day (NG Church Virginia) 10H00-17H00
8.4 EIA PHASE PUBLIC PARTICIPATION

Notification regarding the availability of the EIA Report and associated appendices for public review was given
in the following manner to all registered I&APs:
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• E-mail notifications containing an attached letter with details on where the EIA report could be
obtained and/or reviewed, public meeting date and time, EIMS contact details as well as the public
review comment period;
• Facsimile notifications with information like that in the letter described above; and
• Summarised SMS notifications with relevant contact details and where more information could be
obtained.
Hard copies of the report were made available in the Virginia Public Library and the Welkom Public Library, and
an electronic copy was made available on the EIMS website. The EIA report was made available for public review
from 2 December 2022 to 24 January 2023 and during this period, various meetings were held as follows:
• Tuesday 10 January 2023: Community Meeting (Stilte Primary School) 12H00-14H00
• Tuesday 10 January 2023: Community Meeting (Adamsons Vley Primary School) 16H00-18H00
• Wednesday 11 January 2023: Public Open Day (NG Church Virginia) 12H00-14H00
• Wednesday 11 January 2023: Farmers Focus Group Public Meeting (Goldfields Game Ranch) 17H00-
19H00
8.5 PUBLIC PARTICIPATION PROGRESS

Comments raised to date have been addressed in a transparent manner and included in the Public Participation
Report (Appendix 3). All comments have been considered in the drafting of this final EIA Report. Please note
that where relevant, personal information was omitted from the public domain due to the restrictions imposed
by the Protection of Personal Information Act (Act 4 of 2013 - POPIA).
A summary of the comments received to date as well as how these comments were addressed is provided below.
Table 14: Summary of comments received to date and how comments were addressed.
Concerns of water availability and quality to farmers The geohydrological specialist and air quality
and air quality impacts of the proposed project. specialist reports have assessed the impact on water
quality and availability as well as the air quality
impacts (including health risks).
I&AP deregistration requests. I&APs who formally requested to be registered were

removed from the database.
I&AP registration requests. I&APs who formally requested to be registered were

added to the database for further notifications during
upcoming application comment periods.
Eskom Holdings SOC Limited (Transmission) The requested information was shared with Eskom.
requested a Google Earth (.kmz) file.
Notification of ongoing Oryx Solar Power Plant PV Tetra4 and EIMS have taken note of this application
Authorization application from another EAP for a PV project within the Cluster 2 application area
(Environamics) within Cluster 2 project area, locality and note that there is minimal impact on the project
map sharing and BID documents, Scoping Report as a whole.
and recently EIA report for comment.
Some individuals as well as contractors have Work seekers (be it individual jobs or contractors)
expressed their interest in potential employment have been directed to the Tetra4 website which
contains a link for interested vendors etc. Community
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and business opportunities from the proposed members seeking employment (jobs) were informed
development. of the Tetra4 personnel who are responsible for
collecting CV’s, ID’s etc to ensure that their interest is
captured. All job or contract seekers were informed
that the application is still underway and that the
project commencement is dependent on the final
decision from the PASA/DMRE.
Transnet commented that the proposed No further actions required.

development does not affect their pipeline
servitudes in the region.
SAHRA provided an interim comment that a The HIA and EIA report will be uploaded to the
comment is to be provided once a HIA and draft EIA SAHRIS website once the EIA comment period
Report are made available for comment. commences.
Query regarding website document accessibility. EIMS provided the needed assistance with obtaining
the relevant documentation which was resolved
satisfactorily.
Requests by certain members of the local These comments were raised during the community
community for jobs as well as other specific services focus group meeting with the Adamsons Vley
such as electricity, skills upliftment, etc. community. The community was informed that
Tetra4 is currently in the process of providing certain
basic services such as water and electricity to the
community as part of the Social and Labour Plan
commitments. This is an ongoing process throughout
the project implementation and would be extended
to other communities in due course. The community
acknowledged that the water and solar electricity
project was currently underway in their community.
Concerns by a local NGOs - Vaal Environmental It was confirmed that Tetra4 was aware of the poor
Justice Alliance (VEJA) and Gold and Uranium Belt living standards of some communities and therefore
Impact Sensoring Organisation – GUBICO about the as part of the SLP commitments, certain upliftment
living standards of the community members. programs had been initiated and were ongoing.
NGO - Vaal Environmental Justice Alliance (VEJA) Clarification was provided that Tetra4 is a wholly
highlighted the possible confusion regarding Tetra4 owned subsidiary of Renergen and whilst the
vs Renergen and how the two companies relate to applicant in this application is Tetra4, this does not
this project as the sign outside the existing plant pose any legal constraints on the project. This report
says Renergen however the applicant in the includes a clear statement that Tetra4 is a wholly
application is Tetra4. owned subsidiary of Renergen.
Concerns that impact on landowners seem to have All specialists were provided with this comment and
been underestimated. have considered this comment in light of their
preliminary impact assessment findings. This has
been thoroughly considered and assessed by the
relevant specialists as well as the EAP in this EIA
Report with minor amendments to certain impacts.
Additional mitigation measures have been put
forward to fully address the impact findings.
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Concerns regarding the project’s impacts on the These safety, livelihoods and land value concerns
safety, livelihoods and land value for landowners. have been given specific attention in this EIA report
and detailed mitigation measures to address these
concerns have been included. In addition, specific
conditions have been put forward for inclusion in the
decision to ensure that priority is given to impacts on
safety, livelihoods and land value. Lastly, Tetra4 has
revised the landowner contract terms to provide
more specific attention to these concerns including
annual compensation for the life of the project (per
hectare rate), commitments to hold specific
negotiations with each affected landowner to ensure
infrastructure is sited in such a manner so as to
minimise impacts on existing land use and lastly to
ensure that all reasonable safety measures are
continually in place. It is understood that Tetra4 is in
the process of consulting with the landowners on the
contract terms in order to finalise the contract with
landowner input.
Access road degradation concerns from Degradation of access roads has been thoroughly
landowners. considered and mitigated in this report and
associated EMPr. This includes a pre-construction
survey by the landowner and Tetra4 of all private
access roads to be utilised by the project including
photographic and video documentation of the pre-
construction state. A similar post construction survey
will be undertaken to document any degradation of
access roads which if identified, will be to Tetra4s
account. It is acknowledged that each landowner has
a specific access road construction methodology and
this will be documented and complied with if any
repairs are required.
Request by a landowner for more detail on Where possible, infrastructure specific locations or at
infrastructure specific location and timing of the least limitations to where infrastructure will not be
project aspects. located has been provided in the Scoping Report and
this EIA Report. The project description has been
reviewed and updated where possible to include
more information on location and timing of certain
activities.
Request by a landowner for more detail on logistics Following this concern relating to the initial
regarding access and maintenance of Tetra4 landowner contract, Tetra4 have undertaken a
infrastructure on farmlands as well as contractual revision of the contract to be more specific in
concerns. addressing the various landowner concerns. Tetra4 is
currently soliciting input from landowners on the
revised contract prior to finalisation of the contract.
In terms of access for inspections and maintenance
during the operational phase, the expected
frequency is as follows:
• Production wells: Monthly (worst case)
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• Pipeline Servitude: Annually for inspections unless
landowner raises concerns or there is an
emergency (leak detected).
• Booster Station: Monthly
• Low Point Drains: Monthly
• Pigging Stations: Six monthly (bi-annually)
• Compressor Stations: Daily security inspections.
Concerns from a landowner that this project would Whilst EIMS was not able to engage this landowner
negatively impact on his farm which is his primary further during the scoping phase, attempts will be
investment for his future as well as his descendants. made to have further engagement during the EIA
This landowner did not wish to discuss anything and phase to discuss how the project would be
wished to state that he is opposed to the project. implemented in direct consultation and negotiations
with the landowner.
Concern from a landowner that the application does All comments were responded to individually and are
not contain specific location, extent and/or routing included in the PPR (Appendix 3 of this EIA report).
detail of project infrastructure on each property.
This concern is elaborated upon in a written
submission and the overall conclusion by the
landowner is that the application is premature
without including such detailed information and
should only be undertaken once this information is
available.
African Carbon Energy (Pty) Ltd submitted various All comments were responded to individually and are
comments during the public meeting, landowner included in the PPR (Appendix 3 of this EIA report).
meeting and a written submission.
A table of comments and responses is included as Appendix B7 of the attached Public Participation Report (PPR)
and Appendix B8 of the attached PPR includes the proof of correspondence. The comments and concerns
received to date have been considered in the compilation of this EIA Report.
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9 ENVIRONMENTAL ATTRIBUTES AND BASELINE ENVIRONMENT
A baseline assessment of the receiving environment upon which an activity or development is proposed is an
important aspect of the EIA process as it provides a description of the current status and trends in environmental
factors of a proposed project against which predicted changes can be compared and evaluated, as well as
baseline information against which the potential impacts can be monitored. The baseline environmental
attributes include biophysical, socio economic, and cultural aspects of a application area, which are presented
below for the Cluster 2 study area.
9.1 TOPOGRAPHY
The topography of the greater application area is generally flat and can be classified as a central interior plain or
plateau. Large dolerite intrusions are observed throughout the study area and because of its relative resistance
to erosion, the Karoo dolerite sheets generally give rise to very prominent high-standing topographic features
(DWAF, 2004). The relief of the area varies between 0 – 130 m. The landscape gradually flattens out towards the
lower laying drainage system in the north-west (approximate elevation low of 1280 mamsl), while the southern
and south-eastern perimeters are shaped by scattered outcrops with a regional topographical high point
recorded as 1540 mamsl.
The lowest topographical elevation on-site is recorded as ~1280 mamsl which is situated towards the western
and eastern borders where the Sandrivier enters and exists the gas production right boundary and form part of
the on-site drainage system. The highest topographical point recorded on site is approximately 1405 mamsl and
forms part of the quaternary catchment boundary and groundwater/ surface water divide to the southern and
south-western portion of the study area. On-site gradients are variable, but generally gentle with the average
slope calculated at ~0.8 % and an elevation loss of 130 m over a lateral distance of 16 km in a north-south
orientation whereas an average slope of ~0.4 % and elevation loss of 70 m over a lateral distance of 17.5 km is
calculated in an east- west orientation. Figure 27 depicts a topographical cross-section (south-western aspect)
of the greater study area.
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Figure 27: Topographical cross-sections of the greater application area.
9.2 DRAINAGE AND CATCHMENT

The greater study is situated in primary catchment (C) of the Vaal River drainage system which covers a total
area of approximately 246 674.5 km2. The resource management falls under the Vaal Water Management Area
(WMA5) which spans portions of the North West Province, northern Free State as well northern sections of the
Northern Cape. An overview of the study area with respect to the quaternary catchments and wetland areas is
included in Figure 28.
The application area is situated within quaternary catchments C42K (nett surface area of 668 km 2) and C42L
(nett surface area of 510.8 km2), falls within hydrological zone E and has an estimated mean annual runoff (MAR)
of between 10 to 13 mcm (million cubic metres) (WR 2012). The hydrology of the region is characterised by
predominately perennial watercourses with the regional drainage occurring in a general west to north-western
direction via the Sandrivier and Doornrivier both of which are traversing the study area from east to west
(Sandrivier) and southeast to northwest (Doornrivier). A non-perennial drainage, Bosluisspruit, also traverses
the study area and generally drains the catchment in a northern direction. The Doornrivier converges with the
Sandrivier approximately 1.3 km to the northeast of the study area from where it flows in a general westerly
direction before joining the Vetrivier roughly ~ 30 km downstream of the application area. Major surface water
features being fed by the drainage system(s) of this quaternary catchment include the Bloemhof Dam situated
<100 km to the northwest.
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Figure 28: Study area in relation to quaternary catchments and drainage areas.
9.3 CLIMATE
The study area’s rainfall is strongly seasonal, and the weather pattern reflects a typical summer rainfall region,
with > 80 % of precipitation occurring as convective thunderstorms from October to March. Patched rainfall and
evaporation data were sourced from the WR2012 database (Rainfall zone 4C4) and span a period of some 90
years (1920 – 2009). The calculated mean annual precipitation (MAP) for this rainfall zone is 521 mm/a, with the
5th percentile of the data set (roughly equivalent to a 1:20 year drought period) calculated at 343.38 mm/a
while the 95th percentile (representing a 1:20 flood period) is calculated at 752.43 mm/a. The highest MAP for
the 90 years of rainfall data was recorded as 860.3 mm (1942) while the lowest MAP of 264 mm was recorded
during 2006.
Both catchment areas are categorised under evaporation zone 19C which have a mean annual evaporation (s-
pan) ranging between 1600 mm/a to 1680 mm/a. The highest evaporation is usually experienced in December
(215 mm) while the lowest evaporation is in June (61 mm). The peak rainfall months are December and January,
and the annual evaporation volumes are more than threefold the annual precipitation.
9.4 SOCIAL
According to NEMA, environment refers to the surroundings in which humans exist. When viewing the
environment from a socio-economic perspective the question can be asked what exactly the social environment
is. Different definitions for social environment exist, but a clear and comprehensive definition that is widely
accepted remains elusive. Barnett & Casper (2001) offers the following definition of human social environment:
“Human social environments encompass the immediate physical surroundings, social relationships,
and cultural milieus within which defined groups of people function and interact. Components of
the social environment include built infrastructure; industrial and occupational structure; labour
markets; social and economic processes; wealth; social, human, and health services; power
relations; government; race relations; social inequality; cultural practices; the arts; religious
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institutions and practices; and beliefs about place and community. The social environment
subsumes many aspects of the physical environment, given that contemporary landscapes, water
resources, and other natural resources have been at least partially configured by human social
processes. Embedded within contemporary social environments are historical social and power
relations that have become institutionalized over time. Social environments can be experienced at
multiple scales, often simultaneously, including households, kin networks, neighbourhoods, towns
and cities, and regions. Social environments are dynamic and change over time as the result of both
internal and external forces. There are relationships of dependency among the social environments
of different local areas, because these areas are connected through larger regional, national, and
international social and economic processes and power relations.”
Environment-behaviour relationships are interrelationships (Bell, Fisher, Baum & Greene, 1996). The
environment influences and constrains the behaviour of people, but behaviour also leads to changes in the
environment. The impacts of a project on people can only be truly understood if their environmental context is
understood. The baseline description of the social environment includes a description of the area within a
provincial, district and local context that will focus on the identity and history of the area as well as a description
of the population of the area based on a number of demographic, social and economic variables.
DESCRIPTION OF THE AREA

The proposed site for the Cluster 2 project is located in Wards 9 and 24 of the Matjhabeng Local Municipality
and Ward 6 of the Masilonyana Local Municipality that forms part of the Lejweleputswa District Municipality in
the Free State Province. The baseline description of the environment will include these areas. Figure 29 shows
the location of the proposed Cluster 2 project as well as some social and physical infrastructure in the area and
Figure 30 shows a broad overview of the land cover in the study area.
Figure 29: Location of the proposed Cluster 2 Project in relation to Municipal Wards.
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Figure 30: Broad overview of land cover in the study area.
LEJWELEPUTSWA DISTRICT MUNICIPALITY

The Lejweleputswa District Municipality (LDM) is situated in the north western part of the Free State and borders
the North West Province to the north; the Fezile Dabi and Thabo Mofutsanyane District Municipalities to the
north-east and east respectively; the Xhariep District Municipality and Mangaung Metropolitan Municipality to
the south; and the Northern Cape Province to the west. The LDM is accessible from Johannesburg, Cape Town,
Klerksdorp and Kimberley through one of South Africa’s main national roads, the N1. The district covers an area
of 32 286 km2 and make up almost a third of the Free State province. It consists of the Masilonyana, Matjhabeng,
Nala, Tokologo and Tswelopele Local Municipalities (www.lejweleputswa.co.za).
The economy of the district relies heavily on the gold mining sector which is dominant in the Matjhabeng and
Masilonyana Local Municipalities (Lejweleputswa DM IDP 2021/22). The mining sector is on a downward trend
and many businesses that have traditionally depended on the mining sector have either closed down are in the
process of closing down. The other municipalities are dominated by agriculture.
MATJHABENG LOCAL MUNICIPALITY

The main towns in the Matjhabeng Local Municipality are Welkom, Odendaalsrus, Virginia, Hennenman,
Allanridge and Ventersburg (www.matjhabeng.fs.gov.za). The economy of the municipality is centred on mining
activities in and around Welkom, Allanridge, Odendaalsrus and Virginia. Manufacturing aimed at the mining
sector exists to a limited extent in the aforementioned towns, with other activities being limited. Other main
economic sectors include manufacturing, tourism, agriculture, gold jewellery, transportation (logistics), and
retail (Matjhabeng LM IDP 2022/2023).
MASILONYANA LOCAL MUNICIPALITY

The main towns in the Masilonyana Local Municipality are Theunissen, Brandfort, Winburg, Verkeerdevlei and
Soutpan (www.masilonyana.fs.gov.za). It is a semi-rural municipality that is dependent on agriculture and mining
1473 EIA Report 139

as the key drivers of its economy (Masilonyana LM IDP 2019/20). In 2016 the mining sector contributed about
52.4 % to the municipality’s economic output, but only about 8 % of the employment in the municipality. With
the decline in the mining sector the municipality plans to turn its focus on tourism. The municipality prides itself
on its tourism destinations.
DESCRIPTION OF THE POPULATION

The baseline description of the population will take place on three levels, namely provincial, district and local.
Impacts can only truly be comprehended by understanding the differences and similarities between the different
levels. The baseline description will focus on the Matjhabeng Local Municipality and the Masilonyana Local
Municipality in the Lejweleputswa District Municipality in the Free State Province (referred to in the text as the
study area), as these are the areas that will be most affected by the proposed project. Where possible, the data
will be reviewed on a ward level – Ward 9 and 24 of the Matjhabeng LM and Ward 6 of the Masilonyana LM.
The data used for the socio-economic description was sourced from Census 2011. Census 2011 was a de facto
census (a census in which people are enumerated according to where they stay on census night) where the
reference night was 9-10 October 2011. The results should be viewed as indicative of the population
characteristics in the area and should not be interpreted as absolute.
The following points regarding Census 2011 must be kept in mind (www.statssa.co.za):
• Comparisons of the results of labour market indicators in the post-apartheid population censuses over
time have been a cause for concern. Improvements to key questions over the years mean that the
labour market outcomes based on the post-apartheid censuses must be analysed with caution. The
differences in the results over the years may be partly attributable to improvements in the
questionnaire since 1996 rather than to actual developments in the labour market. The numbers
published for the 1996, 2001, and 2011 censuses are therefore not comparable over time and are
different from those published by Statistics South Africa in the surveys designed specifically for
capturing official labour market results.
• For purposes of comparison over the period 1996–2011, certain categories of answers to questions in
the censuses of 1996, 2001 and 2011, have either been merged or separated.
• The tenure status question for 1996 has been dropped since the question asked was totally unrelated
to that asked thereafter. Comparisons for 2001 and 2011 do however remain.
• All household variables are controlled for housing units only and hence exclude all collective living
arrangements as well as transient populations.
• When making comparisons of any indicator it must be considered that the time period between the
first two censuses is five years and that between the second and third census is ten years. Although
Census captures information at one given point in time, the period available for an indicator to change
is different.
POPULATION AND HOUSEHOLD SIZES

According to the Community Survey 2016, the population of South Africa is approximately 55,7 million and has
shown an increase of about 7.5 % since 2011. The household density for the country is estimated on
approximately 3.29 people per household, indicating an average household size of 3-4 people (leaning towards
3) for most households, which is down from the 2011 average household size of 3.58 people per household.
Smaller household sizes are in general associated with higher levels of urbanisation.
The greatest increase in population since 2011 has been on local level (Table 15), but still lower than the national
average. Population density refers to the number of people per square kilometre and the population density on
a national level has increased from 42.45 people per km2 in 2011 to 45.63 people per km 2 in 2016. In the study
area the population density has increased since 2011 with the highest density in the Matjabeng LM.
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Table 15: Population density and growth estimates (sources: Census 2011, Community Survey 2016).
Area Size in km2 Population Population Population Population Growth in

2011 2016 density 2011 density 2016 population
(%)
Free State 129,825 2,745,590 2,834,714 21.15 21.83 3.25

Province
Lejweleputswa 31,930 627,626 649,964 19.66 20.36 3.56

DM
Matjhabeng 5,155 406,461 428,843 78.85 83.19 5.51

LM
Masilonyana 6,796 63,334 66,084 9.32 9.72 4.34

LM
The number of households in the study area has increased on all levels (Table 16). The proportionate increase
in households were greater than the increase in population on all levels and exceeded the growth in households
of 12.3 % on a national level. The average household size has shown a decrease on all levels, which means there
are more households, but with less members.
Table 16: Household sizes and growth estimates (sources: Census 2011, Community Survey 2016).
Area Households Households Average Average Growth in

2011 2016 household size household size households (%)
2011 2016
Free State 823,316 946,639 3.33 2.99 14.98
Province
Lejweleputswa 183,163 219,014 3.43 2.97 19.57
DM
Matjhabeng 123,195 149,021 3.30 2.88 20.96
LM
Masilonyana 17,575 22,802 3.60 2.90 29.74
LM
The total dependency ratio is used to measure the pressure on the productive population and refer to the
proportion of dependents per 100 working-age population. As the ratio increases, there may be an increased
burden on the productive part of the population to maintain the upbringing and pensions of the economically
dependent. A high dependency ratio can cause serious problems for a country as the largest proportion of a
government’s expenditure is on health, social grants and education that are most used by the old and young
population.
The total dependency ratio in the Masilonyana LM is higher than on district or provincial level (Table 17), while
in the Matjhaneng LM the total dependency ratio is lower that on district or provincial level. The same trend
applies to the youth, aged and employment dependency ratios. Employed dependency ratio refers to the
proportion of people dependent on the people who are employed, and not only those of working age. The
employed dependency ratio for the Matjhabeng LM is lower than on district and provincial level, while for the
Masilonyana LM it is higher. This suggests high levels of poverty in the Masilonyana area.
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Table 17: Dependency ratios (source: Census 2011).
Area Total dependency Youth dependency Aged dependency Employed

dependency
Free State Province 52.88 44.48 8.39 76.34
Lejweleputswa DM 51.33 43.71 7.61 77.16
Matjhabeng LM 46.93 40.09 6.85 75.46
Ward 9 31.92 24.88 7.04 68.37
Ward 24 31.54 29.01 2.53 69.84
Masilonyana LM 54.99 45.99 9.00 82.14
Ward 6 40.36 33.35 7.01 88.18
Poverty is a complex issue that manifests itself in economic, social and political ways. To define poverty by a
unidimensional measure such as income or expenditure would be an oversimplification of the matter. Poor
people themselves describe their experience of poverty as multidimensional. The South African
Multidimensional Poverty Index (SAMPI) (Statistics South Africa, 2014) assess poverty on the dimensions of
health, education, standard of living and economic activity using the indicators child mortality, years of
schooling, school attendance, fuel for heating, lighting and cooking, water access, sanitation, dwelling type, asset
ownership and unemployment.
The poverty headcount refers to the proportion of households that can be defined as multi-dimensionally poor
by using the SAMPI’s poverty cut-offs (Statistics South Africa, 2014). The poverty headcount has increased on all
levels since 2011 (Table 18), indicating an increase in the number of multi-dimensionally poor households.
The intensity of poverty experienced refers to the average proportion of indicators in which poor households
are deprived (Statistics South Africa, 2014). The intensity of poverty has increased slightly on all levels. The
intensity of poverty and the poverty headcount is used to calculate the SAMPI score. A higher score indicates a
very poor community that is deprived on many indicators. The SAMPI score has increased in the Masilonyana
LM area, indicating that households in this area might be getting poorer. In the Matjhabeng LM area the SAMPI
score has decreased, suggesting an improvement in some respects relating to poverty in this area.
Table 18: Poverty and SAMPI scores (sources: Census 2011 and Community Survey 2016).
Area Poverty Poverty SAMPI 2011 Poverty Poverty SAMPI 2016

headcount intensity headcount intensity
2011 (%) 2011 (%) 2016 (%) 2016 (%)
Free State 5.5 42.2 0.023 5.5 41.7 0.023
Province
Lejweleputswa 5.6 42.8 0.024 4.8 42.2 0.020
DM
Matjhabeng 5.5 43.0 0.024 4.3 41.8 0.018
LM
Masilonyana 5.3 41.8 0.022 6.5 41.8 0.027
LM
POPULATION COMPOSITION, AGE, GENDER AND HOME LANGUAGE

In all the areas under investigation, the majority of the population belongs to the Black population group (Figure
31), but the proportions differ. Ward 24 has the highest proportion of people belonging to the Black population
group, while Ward 9 has the highest proportion of people belonging to the White population group.
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Figure 31: Population distribution (shown in percentage, source: Census 2011).
The average age on local level is higher than on district and provincial level (Table 19). The highest average age
is in Ward 9 of the Matjhabeng LM.
Table 19: Average age (source: Census 2011).
Area Average Age (in years)
Free State Province 28.38
Lejweleputswa DM 28.52
Matjhabeng LM 28.89
Ward 9 32.84
Ward 24 30.46
Masilonyana LM 28.73
Ward 6 31.21
The age distribution of the areas under investigation shows that the population in on a ward level tend to be
older than on district or provincial level, with a greater proportion of people aged between 35 years to 64 years
(Figure 32).
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Figure 32: Age distribution (shown in percentage, source: Census 2011).
GENDER
The gender distribution on provincial, district and local level is balanced (Figure 33), but on a ward level there is
a bias towards males. A higher incidence of males is usually found in mining areas and all three the wards have
mining areas that appear to have residences for mine workers.
Figure 33: Gender distribution (shown in percentage, source: Census 2011).
LANGUAGE
Almost two thirds of people in the region have Sesotho as home language (Figure 34), except in Ward 9 where
it is only about a third of people. In Ward 9 more than 40% of people have Afrikaans as home language. Almost
a fifth of people in Ward 24 has IsiXhosa as home language, suggesting a high incidence of migrant mine workers
residing in this ward. Based on the predominant languages in the area, the notifications for this application have
been distributed in English, Afrikaans and Sesotho.
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Figure 34: Language distribution (shown in percentage, source: Census 2011).
EDUCATION
Figure 35 shows the education profiles for the areas under investigation for those aged 20 years or older. Ward
9 has the highest proportion of people who have completed Grade 12 or higher, while more than 70 % of people
in Wards 6 and 24 have not completed secondary school.
Figure 35: Education profiles (those aged 20 years or older, shown in percentage, source: Census 2011).
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EMPLOYMENT
Ward 6 has the lowest proportion of people of economically active age (aged between 15 years and 65 years)
that are employed (Figure 36), while Wards 9 and 24 have the highest proportions. Since 2010 employment in
the gold mining industry showed a steady decline from 157 019 in 2010 to 94 399 in 2020
(www.mineralscouncil.org.za). As such the proportion unemployed people in the area are likely to have
increased since 2011.
Figure 36: Labour status (those aged between 15 - 65 years, shown in percentage, source: Census 2011).
Most of the employed people in the areas under investigation work in the formal sector (Figure 37). Ward 9 has
the highest proportion of people working in the formal sector while Ward 6 has the highest proportion of people
working for private households.
Figure 37: Employment sector (those aged between 15 - 65 years, shown in percentage, source: Census 2011).
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HOUSEHOLD INCOME
Ward 24 has the highest proportion of households that have no annual household income (Figure 38), while
Ward 9 has the highest average household income.
Figure 38: Annual household income (shown in percentage, source: Census 2011).
HOUSING
On a ward level most households live in areas classified as urban. Wards 24 and 6 have the highest incidence of
households living on farms. In Ward 24 almost a quarter of households live on farms. Ward 9 includes a large
portion of the town of Virginia.
Table 20: Geotypes (source: Census 2011, households).
Area Urban Tribal/Traditional Farm
Free State Province 84.5 8.8 6.7
Lejweleputswa DM 93.9 0.0 6.1
Matjhabeng LM 97.7 0.0 2.3
Ward 9 94.2 0.0 5.8
Ward 24 75.2 0.0 24.8
Masilonyana LM 91.4 0.0 8.6
Ward 6 87.4 0.0 12.6
Most households live in formal residential areas (Figure 39), with about a quarter of households in Ward 6 and
a third of households in Ward 24 residing in collective living quarters. Just over a quarter of households in Ward
24 live in informal residential areas.
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Figure 39: Enumeration area types (persons, shown in percentage, source: Census 2011).
Most of the dwellings in the area are houses or brick/concrete block structures that are on a separate yard,
stand or farm (Figure 40), except in Ward 24 where about a third of the dwellings are informal and a fifth live in
a flat or an apartment in a block of flats.
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Figure 40: Dwelling types (shown in percentage, source: Census 2011).
Ward 24 has the largest proportion of households that are renting their dwellings (Figure 41), with more than
half of the households renting, while Ward 6 has the largest proportion of households that own their dwellings
and have paid them off in full.
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Figure 41: Tenure status (shown in percentage, source: Census 2011).
HOUSEHOLD SIZE
Household sizes on a ward level in the Matjhabeng LM tend to be smaller than on local, district or provincial
level (Figure 42), with approximately 50 % or more of households on ward level consisting of one or two people,
compared to just over 40 % on local, district and provincial level. In Ward 6 of the Masilonyana LM households’
sizes tend to be larger than on local, district or provincial level.
Figure 42: Household size (shown in percentage, source: Census 2011).
ACCESS TO WATER AND SANITATION

Ward 24 has the lowest incidence of households that access to water from a local or a regional water scheme,
but the highest incidence of households that get their water from a borehole or another source (Figure 43).
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Figure 43: Water source (shown in percentage, source: Census 2011).
Access to piped water, electricity and sanitation relate to the domain of Living Environment Deprivation as
identified by Noble et al (2006). Almost 90 % of households in Ward 9 has access to piped water inside the
dwelling (Figure 44). In Ward 6 more than 90 % of households have access to water insider their dwelling or
stand, compared to almost 80 % in Ward 24.
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Figure 44: Piped water (shown in percentage, source: Census 2011).
The highest incidence of households that do not have access to any sanitation services is in Ward 24 (Figure 45),
with approximately a third of the households in the ward having access to pit toilets without ventilation.
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Figure 45: Sanitation (shown in percentage, source: Census 2011).
ENERGY
Electricity is seen as the preferred lighting source (Noble et al, 2006) and the lack thereof should thus be
considered a deprivation. Even though electricity as an energy source may be available, the choice of energy for
cooking may be dependent on other factors such as cost. More than 80 % of households have access to electricity
as energy source for lighting (Figure 46), with candles the second most used source.
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Figure 46: Energy source for lighting (shown in percentage, source: Census 2011).
REFUSE REMOVAL
Wards 6 and 24 have the lowest incidence of households that have their refuse removed at least once a week
by a local authority or private company (Figure 47), with almost a third of households in Ward 24 having no
rubbish disposal.
Figure 47: Refuse removal (shown in percentage, source: Census 2011).
9.5 ECONOMIC ENVIRONMENT

An economic impact assessment has been conducted by Strategy4Good and the final report included in
Appendix 4. The sub-sections below provide an overview of the economic baseline applicable to this project. As
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the majority of the study area falls within the Matjhabeng Local Municipality which is also a significantly larger
municipality than the Masilonyana Local Municipality, the economic impacts of the project have been compared
to the Matjhabeng Local Municipality.
NATIONAL ECONOMY
In the broader receiving environment, the national economy is under much stress and in a receiving environment
of this nature it would be commonplace to observe that all desirable economic development would be urgent
for SA. In this regard, the Cluster 2 development should be viewed as a significant benefit to the SA economy.
An estimated 2.6 million people lost their jobs due to the pandemic and the current unemployment rate is ~34%.
Socio-economic indicators are likely to continue to decline and therefore Tetra4 and its suppliers could expect a
disproportionate amount of job applications.
LOCAL ECONOMY
The total GGP of the Matjhabeng municipality is estimated at R45 billion at present and this can be considered
as a large economy by size in South Africa. SA’s GDP is just under R5 000 billion rand and although Matjhabeng’s
economy is only ~1 % of that amount, it needs to be compared to the 0,2 % of the average municipality in SA.
Thus, Matjhabeng’s economy is 5 times larger than the average municipality in SA and hence could be considered
as a relatively big economy in the country. The significance of this is that the local area has a reasonable
economic base that could sustain itself and as a rule ought to provide in some of Tetra4’s supplier and
procurement needs.
As shown in Figure 48 to Figure 51 below, the local economy’s GDP growth rates had been mostly negative
between 2005-2014. As the data for the local economy’s performance was not available after 2014, a look at
the SA GDP growth rate shows that nationally there were no signs to indicate that the economy was improving.
One could therefore assume that the local economy may also not have experienced strong growth, albeit that
higher commodity prices may have had a positive impact locally in 2021 (that year’s statistic not in the graph.)
From the figures below it can also be seen that the mining industry made up 56 % of the local economy in 2014.
Compare this to national mining contribution to GDP of less than 10 %. The Government sector, which is not a
propulsive industry, is the next biggest economic sector in Matjhabeng. The critical sector for economic success
namely the manufacturing sector is very small in that economy.
Mining output in the local economy is showing a downward trend at a rate of 1.5 % per year. Figure 51 shows
that Matjhabeng had been hit hard by declining gold production. Its workforce had been halved since the golden
years of the 1990’s and this had led to high unemployment rates.
The area’s population is large with well over 400 000 inhabitants. The population growth rate in Matjhabeng
was estimated at 0,5 % in the last decade, compared to 1,5 % in SA, which indicates that the Gold Fields is not a
major in-migration area at present. This can only be ascribed to the area’s inability to absorb jobseekers in the
economy prompting less people to in-migrate. As is the case in the rest of South Africa, the Matjhabeng
unemployment rate is high, bordering on 40 %.
Due to the urbanised nature of Matjhabeng, it’s Agricultural Sector is small contributing less than 2 % to its
economy. The agricultural sector in the region is much larger as is expected in the Free State, averaging 5 % of
GDP.
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Figure 48: Key economic graphs.
Figure 49: Structure of Matjhabeng economy by economic output 2014 – sector specific.
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Figure 50: Structure of Matjhabeng economy by economic output 2014 – overall output.
Figure 51: South African gold production.
STRENGTHS OF THE LOCAL ECONOMY

The local economy is considered to have the following strong points:
• Matjhabeng has a relatively large GGP compared to other municipalities, which ought to leverage
possibilities for further development in the area.
• The road infrastructure from Matjhabeng that connects it to both the Johannesburg markets and
Durban ports is of a very high quality, which makes import and export linkages more efficient than for
many other municipalities in the country.
• Barring further mine closures, Matjhabeng may be finding a new economic equilibrium which ought to
increase business confidence and investment in the area.
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• The 2014/15 IDP indicates that the average household income has increased, which ought to contribute
to social stability.
• The IDP also states that educational levels in the area have improved substantially, and a better-
educated population is crucial for economic development.
• The IDP furthermore states that Matjhabeng has a Human Development Index (HDI) of 0.66, which is
one of the highest in the Free State and just above the average SA HDI. However, the country’s HDI is
still low compared to that of developed countries, and it requires much improvement before
Matjhabeng could be a significantly competitive economy.
WEAKNESSES OF THE LOCAL ECONOMY
• Matjhabeng is dependent on one propulsive industry, namely mining. With an undiversified economy
it is thus vulnerable to the prospects of mining.
• The Matjhabeng municipality itself does not seem to have a strong set of financial statements. Its
current liabilities exceed its current assets by a large margin, and it has been recording deficits (losses)
for the last few years. In addition to this, it also had qualified audits which does not bode well for the
financial management of the municipality.
• Other weaknesses are in alignment with what most of SA is experiencing at present:
o Long term decline in business confidence;
o Unreliable electricity supply;
o Low growth economic environment;
o Generally low investment environment;
o High unemployment;
o Unplanned urbanisation;
o Crime;
o Apparent government inefficiencies.
In summary, Matjhabeng has a relatively large economy compared to that of other SA municipalities, but its GGP
has been declining for years. Although the local economy still has a measure of critical mass that could provide
continued private consumption expenditure which could sustain it for quite some time, it requires new
investments to sustain itself. The Matjhabeng economy is by all accounts finding a new equilibrium – an
economy that is adjusting to declines in mining employment and a stagnating population. The increase in
government expenditure and perennial agricultural activities are keeping the municipality’s decline in check, but
if more mines close down its GGP and formal employment is set to decline more. At present it is not sure what
the impact of higher commodity prices are on the local economy. An investment such as that of Tetra4 will
undoubtedly improve the economic prospects for the local economy.
9.6 CULTURAL AND HERITAGE RESOURCES

A Specialist Heritage and Palaeontology Impact Assessment study has been undertaken to inform this
application and the final report included in Appendix 4. Based on the historical and archaeological overview, the
previous assessments undertaken in the area as well as the fieldwork undertaken as part of this application, the
heritage assessment findings are summarised below:
• Thirty-five (35) heritage sites which were previously identified for a 2016/2017 assessment, fall within
the footprint areas of the current proposed Tetra4 Cluster 2 Gas Production Project. These comprised:
o 10 graves and burial grounds (TET 1, TET 7-8, TET 11, TET 15, TET 19, TET 22, SSL/BET/72, SITE
2, SITE 19);
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o 11 structures (TET 2-3, TET 9, TET 27, SSL/BET/25-26, SSL/BET/36, SITE 1A, SITE 1B, SITE 20-
21); and
o 14 historic to recent sites with possible graves (TET 4-6, TET 13-14, TET 25a, TET 25b, TET 26,
SSL/BET/37-39, SSL/BET/53, SSL/BET/60, SSL/BET/66).
• During the current field assessment, a further thirty-seven (37) heritage sites were recorded as detailed
below:
o 6 sites containing burial grounds and graves (T0003, T0009, T0010, T0013, T0024, T0029);
o 8 sites historic to recent sites with possible graves (T0007, T0008, T0011, T0015, T0023, T0026,
T0027, T0028); and
o 23 structures (T0001, T0002, T0004, T0005, T0014, T0016, T0017, T0018, T0019, T0020, T0021,
T0022, T0025, T0030, T0031, T0033, T0034, T0036, T0037, T0038, T0039, T0040, T0041).
The combined seventy-two (72) identified heritage sites (as described above) were then assigned a sensitivity
rating as either high, medium, low or none as follows:
• 37 sites were rated as having high heritage significance (IIIA): TET 1, TET 7-8, TET 11, TET 15, TET 19,
TET 22, SSL/BET/72, SITE 2, SITE 19, TET 4-6, TET 13-14, TET 25a, TET 25b, TET 26, SSL/BET/37-39,
SSL/BET/53, SSL/BET/60, SSL/BET/66, T0003, T0009, T0010, T0013, T0024, T0029, T0007, T0008, T0011,
T0015, T0023, T0026, T0027, T0028;
• 12 sites were rated as having medium heritage significance (IIIB): TET 2, TET 3, TET 9, SITE 1A, SITE 1B,
SITE 20, SITE 21, T0014, T0015, T0021, T0040, T0041;
• 13 sites were rated as having low heritage significance (IIIC): TET 27, SSL/BET/25, SSL/BET/26,
SSL/BET/36, T0016, T0017, T0018, T0019, T0020, T0022, T0025, T0037, T0038; and
• 10 sites were rated as having no research potential or other cultural significance (NCW): T0001, T0002,
T0004, T0005, T0030, T0031, T0033, T0034, T0036, T0039.
A set of photographs of each of the heritage sites can be viewed in the heritage specialist report. The location
of the identified heritage sites are superimposed on the project infrastructure areas in Figure 52 with the
relevant insets included in Figure 53 to Figure 62.
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Figure 52: Map showing heritage sensitivity rating of identified heritage resources.
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Figure 53: Heritage sensitivity rating of identified heritage resources - Inset A.
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Figure 54: Heritage sensitivity rating of identified heritage resources - Inset B.
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Figure 55: Heritage sensitivity rating of identified heritage resources - Inset C.
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Figure 56: Heritage sensitivity rating of identified heritage resources - Inset D.
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Figure 57: Heritage sensitivity rating of identified heritage resources - Inset E.
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Figure 58: Heritage sensitivity rating of identified heritage resources - Inset F.
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Figure 59: Heritage sensitivity rating of identified heritage resources - Inset G.
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Figure 60: Heritage sensitivity rating of identified heritage resources - Inset H.
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Figure 61: Heritage sensitivity rating of identified heritage resources - Inset I.
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Figure 62: Heritage sensitivity rating of identified heritage resources - Inset J.
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A Palaeontological study was undertaken by Elize Butler (February 2022) and the study indicates the proposed
Cluster 2 development is underlain by Quaternary sediments as well as Permian aged sandstone and shale of
the Adelaide Subgroup (Beaufort Group, Karoo Supergroup). According to the PalaeoMap of the South African
Heritage Resources Information System (SAHRIS) the Palaeontological Sensitivity of Quaternary sediments in
this area is Moderate, while that of the Adelaide Subgroup (Beaufort Group, Karoo Supergroup) is Very High.
A 2-day site-specific field survey of the development footprint was conducted on foot and by a motor vehicle on
26 to 27 February 2021. No visible evidence of fossiliferous outcrops was found in the development footprint
and thus an overall medium palaeontological significance is allocated to the development footprint. It is
therefore considered by the specialist that the proposed development will not lead to detrimental impacts on
the palaeontological reserves of the area and construction of the development may be authorised in its whole
extent.
9.7 SOILS AND LAND CAPABILITY

According to the land type database (Land Type Survey Staff, 1972 - 2006) the assessment corridor to be focused
on falls within the Ae40, Bd20, Dc8, Dc9 and Dc12 land types. The Ae land type mostly consist of apedal
(yellow/red), duplex soils characterised with high clay contents and shallow profiles associated with partially
weathered/ un-weathered material with the possibility of other soils occurring throughout. Lime is generally
present in low-lying areas. The Bd land type consists of mostly apedal and duplex soils with miscellaneous land
classes including rocky areas with Mispah and Oakleaf soils forms according to the SA soil classification working
group (1990). The Dc land types is characterised with duplex, transitional young alluvial soil deposits with
occasional red soils, some saturated profiles, shallow soils, and intrusive hard rocks. The terrain units and
expected soils for the Ae40 land type is illustrated in Figure 63 and Table 21 respectively. Similarly, those for the
Bd20 land type is depicted in Figure 64 and Table 22; Dc8 land type in Figure 65 and Table 23; Dc9 land type in
Figure 66 and Table 24 and Dc12 in Figure 67 and Table 25 respectively.
Figure 63: Illustration of land type Ae40 terrain unit (Land Type Survey Staff, 1972 - 2006).
Table 21: Soils expected at the respective terrain units within the Ae 40 land type (Land Type Survey Staff, 1972
- 2006).
Terrain Units
4 (92%) 4 (1) (4%) 5 (4%)
Hutton 89 % Swartland 25 % Katspruit, Rensburg 75 %
Clovelly 7% Mispah 50 % Swartland 25 %
Bainsvlei 2% Oakleaf 25 %
Avalon 2%
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Figure 64: Illustration of land type Bd 20 terrain unit (Land Type Survey Staff, 1972 - 2006).
Table 22: Soils expected at the respective terrain units within the Bd 20 land type (Land Type Survey Staff, 1972
- 2006).
Terrain Units
1 (55%) 3 (40%) 4 (3%) 5 (2%)
Clovelly 65 % Clovelly 45 % Hutton 50 % Valsrivier 55 %
Avalon 30 % Avalon 20 % Valsrivier 18 % Arcadia, 30 %
Rensburg
Arcadia, 1% Hutton 25 % Avalon 10 % Oakleaf 10 %
Rensburg
Katspruit 1% Valsrivier 8% Clovelly 5% Katspruit 10 %
Valsrivier 3% Arcadia, 1% Oakleaf 5%
Rensburg
Katspruit 1% Arcadia, 1%
Rensburg
Figure 65: Illustration of land type Dc 8 terrain unit (Land Type Survey Staff, 1972 - 2006).
2006).
Terrain Units
5 (44%) 5(1) (40%) 5 (2) 27%) 5 (3) (16%)
Arcadia 42 % Arcadia 41 % Oakleaf 66 % Dundee 7%
Valsrivier 48 % Rensburg 59 % Valsrivier 32 % Stream 28 %
beds
Sterkspruit 6% Stream 2% Fernwood 22 %
beds
Katspruit 1% Oakleaf 13 %
Bonheim 4%
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2006).
Terrain Units
1 (10%) 3 (27%) 4 (41%) 5 (22%)
Hutton 100 % Hutton 88 % Swartland 28 % Willowbrook 91 %
Clovelly 11 % Valsrivier 24 % Valsrivier 5%
Oakleaf 1% Oakleaf 23 % Arcadia 2%
Sterkspruit 17 % Sterkspruit 1%
Arcadia 4% Mispah 1%
Estcourt 3%
Mispah 1%
Table 25: Soils expected at the respective terrain units within the Dc 12 land type (Land Type Survey Staff, 1972
- 2006).
Terrain Units
1 (3%) 1 (1) (20%) 2 (1%) 3 (6%) 3 (1) (38) 4 (24) 5 (8)
Rocks 33% Mispah 37% Rocks 60% Rocks 33% Swartland 34% Bonheim 29% Oakleaf 41%
Mayo 23% Swartland 19% Mispah 30% Mayo 25% Mispah 18% Swartland 27% Katspruit 27%
Mispah 21% Glenrosa 13% Glenrosa 10% Swartland 17% Bonheim 14% Valsrivier 15% Stream 13%
beds
Glenrosa 13% Westleigh 12% Mispah 17% Valsrivier 9% Arcadia 15% Valsrivier 6%
Swartland 10% Mayo 6% Glenrosa 8% Glenrosa 7% Sterkspruit 4% Bonheim 5%
Bonheim 5% Arcadia 7% Mispah 4% Glenrosa 4%
Valsrivier 3% Westleigh 5% Mayo 3% Mayo 4%
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Terrain Units
1 (3%) 1 (1) (20%) 2 (1%) 3 (6%) 3 (1) (38) 4 (24) 5 (8)
Rocks 3% Mayo 3% Glenrosa 2%
Hutton 2% Hutton 2% Rocks 1%
The slope percentage of the application area has been calculated and is illustrated in Figure 68. The majority of
the assessment area is characterised by a slope percentage between 0 and 20%, with some smaller patches
within the application area characterised by a slope percentage above 40. This illustration indicates mostly a
uniform area with few undulating slopes, mountainous areas and ridges. The Digital Elevation Model (DEM) of
the application area is included in Figure 69.
The land potential level for the application areas is level 6 (these land potential levels are defined as having
restricted to very restricted potentials, regular, moderate and/or severe limitations due to soil, slope,
temperatures or rainfall.
Fifteen land capabilities have been digitised by (DAFF, 2017) across South Africa, of which ten land capability
classes are located within the proposed infrastructure transects/ corridors, including;
• Land Capability 1 to 5 (very low to low);
• Land Capability 6 to 8 (moderately low to moderate); and
• Land Capability 8 to 10 (moderate to moderate high).
The baseline findings and the sensitivities as per the Department of Agriculture, Forestry and Fisheries (DAFF,
2017) national raster file concur with one another. According to the DEA Screening Tool (2022) land capability
was identified as very low to moderate high and the farming field crop sensitivity as high to very high in some
areas (Figure 71).
Where proposed infrastructure is located within high and very high sensitivity agricultural land uses, stakeholder
engagement with the landowners can be undertaken to compensate for the loss of any high-productivity crop
fields. Furthermore, it is advisable to rearrange proposed components around high/very high sensitivity crop
fields to ensure the conservation thereof where possible.
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Figure 68: Slope percentage map for the assessment area.
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Figure 69: Elevation map for the assessment area.
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Figure 70: Land Capability Sensitivity (DAFF, 2017).
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Figure 71: Farming Field crop Sensitivity (DEA, 2022).
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9.8 HYDROLOGY AND FLOODLINES
The application area is located within the 42K, 42L and 43K quaternary catchment areas as defined by Water
Resources of South Africa, 2005 study (WR 2005). The main drainage features traversing the application area
include the Bosluisspruit River, Doring River and the Sand River, of which the Sand River is the major system
originating in the east and draining south-west past Welkom and the Project site.
Based on the observations made from Google Earth Pro satellite imagery (Google Earth, 2022) and the site visit
that was conducted on the 13th of April 2022 by the Hydrological specialist (SMEC South Africa), the application
area comprises mostly of farmlands with some bush areas in-between. In general, based on the available
topographic survey data, the application area is generally flat (<10% slope). According to the “SANRAL Drainage
Manual, 6th Edition”, the soils in the application area have a moderately low to moderately high internal
drainage capacity and generalised SCS soil grouping classification for South Africa. Soils that are well drained
produce a lower stormflow response than poorly drained soils.
The delineation of catchment areas draining to the above-mentioned rivers was undertaken using the
topography of the area defined by SRTM DEM data. A catchment area is generally defined as that area from
which all rainfall will drain into a drainage system through surface flow, to a common point.
The focus of the reporting on this section is on the major points of the major rivers, however, the application
area has multiple small tributaries that drain into the major rivers at multiple points along the major rivers; these
were individually considered as flow change locations in the river modelling so that the peak flow at the
downstream end of a river doesn’t represent the entire river. The catchment areas are shown in Figure 72.
Figure 72: Catchment areas.
The physical properties of the various catchment areas shown in Figure 72 are summarized in Table 26.
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Table 26: Catchment Area Physical Properties.
Description Unit 1 2 3 4 5
Size of Catchment Area km² 7118 7054 442 155 68
Hydraulic length of Catchment km 251 239 58 29 20
Average Stream Slope m/m 0.0013 0.0013 0.0032 0.0055 0.0079
Floodline modelling was undertaken to determine the 1:100-year floodlines for the major rivers within the
application area. The 1:100-year floodlines are indicated in Figure 73 and the floodlines are considered the
regulated area of a watercourse in which any activities will require the requisite water use authorisations.
Figure 73: 1:100-year floodlines.
9.9 GEOLOGY
The below sections present the geological setting of the study area.
REGIONAL GEOLOGY
Although the application area’s surficial geology comprises mostly aeolian sands, quaternary deposits and
isolated outcrops of the Karoo Supergroup i.e., dolerite and sandstone/ shales, the greater study area is
generally also underlain by rocks of the Witwatersrand Supergroup as well as the Ventersdorp Supergroup. The
primary source of gas originates from the Witwatersrand Supergroup as well as the shallower Karoo sediments.
It can be inferred from exploration borehole geological logs that the estimated depth of the unconsolidated
material within the application area is approximately 11 m.
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The Witwatersrand Supergroup is a sedimentary deposition across the stable granite-gniess basement which
commenced around 3 billion years ago. In stratigraphic terms the Witwatersrand sequence is divided into two
divisions, the lower dominantly marine, slate rich West Rand Group and the upper dominantly alluvial sandstone
rich Central Rand Group (Johnson, 2006). The Witwatersrand Supergroup depth within the study area was
inferred from exploration borehole geological logs and is estimated at an average depth of >1600 mbgl.
The Ventersdorp Supergroup uncomfortably overlies the Witwatersrand Supergroup. This Group is very thick,
more than 4500 m. The lower Kliprivierberg Group is mafic lava and tuff while the upper Platberg Group is
conglomerates and breccia on top of Kliprivierberg, with intermediate and felsic lava higher, with quartzite, shale
and siltstone layers in between. The Ventersdorp Supergroup depth within the study area was inferred from
exploration borehole geological logs and is estimated at an average depth of >1120 mbgl.
The Karoo Super Group is the largest stratigraphic unit in Southern Africa covering almost two thirds of the land
surface. The supergroup consists of a sequence of units, mostly of nonmarine origin, deposited between the
Late Carboniferous and Early Jurassic, a period of about 120 million years. The Karoo Supergroup consist of
argillaceous rocks of the Beaufort Group i.e. lower Adelaide Subgroup (Late Permian) and an upper Tarkastad
Subgroup, the Permian Ecca Group which consist largely of shales and sandstones as well as the Dwyka Group
(Late Carboniferous to Early Permian) which consists mainly of diamictite (tillite). The Ecca Group underlies the
Beaufort Group in all known outcrops and exposures and follows conformably after the Dwyka Group in certain
sections, however in some localities overlies unconformably over older basement rocks. The Karoo Supergroup
(which include the Beaufort as well as Ecca Groups) depth within the study area was inferred from exploration
borehole geological logs and is estimated at an average depth of 300 mbgl. Gas will be extracted from deep-
seated fracture zones associated with the Ventersdorp lavas and Witwatersrand quartzites.
LOCAL GEOLOGY
According to the 1:250 000 geological maps (2826: Winburg), a large portion of the study area’s surficial geology
comprises aeolian sands and quaternary deposits. Isolated patches within the study area are also covered by
alluvial sand deposits which is mainly associated with the Sand and Doringriver floodplains and constrained by
drainage patterns and riparian zones. The site is underlain by the Adelaide Subgroup (Vpa) consisting of
alternating layers of bluish-grey, greenish-grey or greyish-red mudrock and grey, very fine to medium-grained,
lithofeldspathic sandstone, the Vryheid Formation (Pv) which consists mainly of fine grained mudstone,
carbonaceous shale with alternating and coarse grained, bioturbated immature sandstones respectively as well
as the Volksrust Formation (PVo) which consists of grey to black, silty shale with thin, usually bioturbated,
siltstone or sandstone lenses and beds, particularly towards its upper and lower boundaries. The Dwyka Group
consists mainly of diamictite (tillite) which is generally massive with little jointing, but it may be stratified in
places.
STRUCTURAL GEOLOGY
Large dolerite intrusions in the form of dykes and sills are observed throughout the study area. The Karoo
sediments in this portion of the water management area (WMA) are much intruded by sub accordant sheets,
and to a lesser extent by near-vertical dykes of Karoo dolerite (DWAF, 2004). The Karoo Basin is characterised
by a vast network of post-Karoo intrusive dolerite (Jd) sills and dykes that rapidly intruded at 183 to 182 Ma. The
intrusive Karoo dolerite suite represents a shallow feeder system which occurs as an interconnected network of
dykes, sills as well as sheets which typically form resistant caps of hills compromising softer sedimentary strata.
Exploration data evaluated suggest dykes are relatively thin, usually not wider than 5 m while sills may be as
thick as 100 m. On a regional scale various dykes can be observed which may have an impact on the local
hydrogeological regime as it can serve as potential preferred pathways for groundwater flow and contaminant
transport.
9.10 GROUNDWATER (GEOHYDROLOGY)

The groundwater (geohydrology) study was undertaken by Gradient Groundwater Consulting and the final
report is included in Appendix 4. The baseline geohydrological features are presented in the subsections below.
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HYDROCENSUS
A hydrocensus user survey within the greater study area was conducted during February and March 2022 where
relevant hydrogeological baseline information was gathered. The aim of the hydrocensus survey is to determine
the ambient and background groundwater conditions and applications and to identify potential sensitive
environmental receptors i.e., groundwater users in the direct vicinity of the gas production operations. A total
of 78 groundwater receptors i.e., boreholes, artesian wells, wind pumps as well as surface water features were
visited as part of the hydrocensus user survey which are largely applied for livestock watering and domestic
water supply purposes. Relevant hydrocensus information is summarised in Table 27 while a spatial distribution
map is shown in Figure 76.
Of the boreholes recorded, the majority are in use (>78 %) while ~17 % are not currently being utilized.
Approximately 4 % of boreholes allocated could not be visited due to access challenges.
Most boreholes recorded are being applied for livestock watering and domestic water supply purposes (~45 %)
while domestic and household purposes which is combined with either irrigation or livestock purposes account
for >18 %. A small number of boreholes are also being applied for either monitoring or industrial purposes (~5
%) while ~17 % of boreholes do not have an application and are not currently being utilized. Refer to Figure 74
for a summary of groundwater applications. According to the Middle Vaal ISP (DWAF, 2004), most boreholes are
being applied for irrigation and small-town water supply.
The majority of boreholes visited are equipped with submersible pumps and accounts to 57 %, while 15 % of
boreholes were fitted either with a wind pump, mono pump (4 %), handpump (1 %) or solar pump (1 %). An
average of 18 % of boreholes are not equipped as indicated in Figure 75.
Figure 74: Hydrocensus user survey: Groundwater application.
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Figure 75: Hydrocensus user survey: Equipment type.
GROUNDWATER FLOW
The following sub-sections outline the groundwater flow dynamics of the study area.
UNSATURATED ZONE
The thickness of the unsaturated or vadose zone was determined by subtracting the undisturbed static water
level elevation from corresponding surface topography. The latter will govern the infiltration rate, as well as
effective recharge of rainfall to the aquifer. Furthermore, the nature of the formation(s) forming the unsaturated
zone will significantly influence the mass transport of any potential surface contamination to the underlying
aquifer(s). The unsaturated zone within the study area is in the order of 0m (fully saturated to surface) to >26 m
with a mean thickness of approximately ~9 m. It should be noted that due to the argillaceous nature of the host
aquifer(s) the shallow water levels observed at some of the borehole localities can be attributed to clay/silt
lenses and be indicative of perched aquifer conditions and not necessarily represent the vadose zone.
DEPTH TO GROUNDWATER
A distribution of borehole water levels recorded as part of the hydrocensus user survey conducted as well as
monitoring borehole water levels measured were considered and used to interpolate local groundwater
elevation and hydraulic head contours as summarised in in the specialist report. Artesian conditions were
observed at three of the boreholes visited namely HBH31, 21B as well as 8B which can be indicative of semi-
confined to confined aquifer conditions present or perched aquifer conditions. The minimum water level was
recorded at 0 mbgl, while the deepest water level was measured at borehole locality Mon-HDR1 (26.71 mbgl).
The average water level is calculated at 8.91 mbgl which is much shallower than the regional average water level
of ~23 mbgl (Aquiworx, 2014).
Time-series water levels within the existing Tetra 4 monitoring boreholes was assessed by comparing water
levels representative of the dry-cycle contribution vs water levels representative of the wet cycle contribution.
It is noted that most water levels suggest a decrease in water levels and recovering trend. The latter can be
attributed the onset of the wet cycle and above average rainfall events experienced with rainfall recharge
replenishing aquifer storage. It can be observed that there is a definite and relatively quick response to rainfall,
1473 EIA Report 183

suggesting that recharge of the shallow, intergranular aquifer takes place without a prolonged lag effect. The
average change in most water levels is <5 %, which accounts to less than 0.5 m, while the relatively low
Coefficient of Variation (CV) values derived from statistical analyses suggest that the local groundwater system
is in quasi-steady state conditions.
GROUNDWATER FLOW DIRECTION AND HYDRAULIC GRADIENTS
Analysed data indicate that the surveyed water levels correlate very well to the topographical elevation.
Accordingly, it can be assumed that the regional groundwater flow direction is dictated by topography. Bayesian
interpolation was used to interpolate the groundwater levels throughout the study area. The inferred
groundwater flow direction will be towards the lower laying drainage system(s) traversing the application area
from where groundwater will discharge as baseflow. The groundwater flow direction within the southern
catchment of the Sandrivier and Doornrivier, also in the vicinity of the proposed plant expansion footprint, will
be in a general northern direction, whereas the groundwater flow direction within the northern catchment of
the study area will be mostly in a south to southwestern direction as depicted in Figure 77.
1473 EIA Report 184

Table 27: Hydrocensus user survey: relevant geosite information.
Water Borehole
Site ID Latitude Longitude level depth Field notes
(mbgl) (mbgl) Site type Site status Equipment Water application
HBH1 -28.14362 26.80863 NAWL Borehole In use Submersible pump Livestock Flooded Area
HBH2 -28.12872 26.80516 NAWL Borehole In use Windpump Domestic & livestock
HBH3 -28.12768 26.80522 NAWL Borehole In use Submersible pump Domestic & livestock ROCLA
HBH6 -28.12005 26.79521 1.52 30 Borehole In use Submersible pump Domestic & garden
HBH7 -28.12940 26.77388 NAWL Borehole Not in use No access None Blocked
HBH8 -28.15651 26.79403 NAWL Borehole In use Submersible pump Livestock
HBH9 -28.15477 26.78428 10.87 30 Borehole In use Submersible pump Livestock
HBH10 -28.11906 26.81375 NAWL Borehole In use Submersible pump Industrial ROCLA
HBH11 -28.11540 26.81199 NAWL Borehole In use Submersible pump Domestic
HBH12 -28.13337 26.76153 13.65 30 Borehole In use Submersible pump Domestic & livestock
HBH14 -28.12823 26.75381 16.65 Borehole In use Submersible pump Domestic & livestock
HBH18 -28.13405 26.75741 16.47 40 Borehole Not in use Not equipped None Open
HBH19 -28.13356 26.75760 NAWL Borehole In use Submersible pump Domestic & livestock
HBH21 -28.09424 26.73133 2.67 Borehole Not in use Not equipped None Open
HBH22 -28.11837 26.71244 NAWL Borehole Not in use Not equipped None Closed
HBH26 -28.12714 26.65699 NAWL Borehole Not in use Not equipped None Closed
HBH28 -28.06977 26.66653 5.02 40 Borehole In use Submersible pump Domestic
HBH29 -28.07050 26.66551 NAWL Borehole In use Mono pump Livestock
HBH30 -28.07475 26.67059 NAWL Borehole In use Submersible pump Livestock
HBH31 -28.10189 26.64343 0.00 Borehole In use Not equipped Domestic & garden Artesian
HBH32 -28.09055 26.65710 NAWL Borehole In use Mono pump Domestic & garden
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Water Borehole
HBH33 -28.11279 26.63522 15.70 Borehole In use Submersible pump Domestic & garden
HBH38 -28.18060 26.64045 2.94 50 Borehole In use Submersible pump Livestock
HBH41 -28.14747 26.72413 NAWL 80 Borehole In use Submersible pump Domestic & irrigation
HBH42 -28.14750 26.72416 NAWL 80 Borehole In use Submersible pump Domestic & irrigation
HBH43 -28.15102 26.72540 NAWL Borehole Not in use Not equipped None No access
HBH47 -28.14472 26.73037 NAWL Borehole In use Solar pump Domestic & livestock
HBH50 -28.18372 26.74679 NAWL Borehole In use No access Domestic & livestock No access
HBH51 -28.19216 26.72884 NAWL Borehole In use No access Monitoring No access
HBH52 -28.18767 26.73012 1.08 10 Borehole In use Not equipped Monitoring Open
HBH53 -28.18655 26.73110 2.80 5 Borehole In use Not equipped Monitoring Open
HBH55 -28.24598 26.71291 NAWL Borehole In use Submersible pump Domestic & livestock
HBH57 -28.25142 26.74366 NAWL Borehole Not in use Not equipped None Blocked
HBH59 -28.25111 26.74382 8.35 Borehole In use Submersible pump Domestic & irrigation
HBH62 -28.22459 26.80767 12.70 30 Borehole In use Windpump Livestock
HBH63 -28.20166 26.78398 NAWL Borehole In use Windpump Livestock
HBH64 -28.21076 26.78479 NAWL Borehole No access Windpump No access
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Water Borehole
HBH67 -28.21859 26.75478 NAWL Borehole Not in use Not equipped None Open. Bees.
HBH70 -28.22878 26.74097 3.10 Borehole In use Windpump Domestic & livestock
HBH72 -28.19312 26.73970 1.75 Borehole Not in use Not equipped None Open
HBH73 -28.19301 26.73964 1.63 Borehole In use Mono pump Domestic & livestock
HBH76 -28.09771 26.73687 NAWL Borehole Not in use Handpump None
SRD -28.12263 26.70925 N/A Surface water N/A N/A N/A Sand River downstream point
SRU -28.10651 26.73623 N/A Surface water N/A N/A N/A Sand River upstream point
N/A: Not applicable
NAWL: No access to water level
1473 EIA Report 187

Figure 76: Spatial distribution of hydrocensus user survey geosites.
1473 EIA Report 188

Figure 77: Regional groundwater flow direction and depth to groundwater.
1473 EIA Report 189

GROUNDWATER QUALITY
The hydrochemical results of the hydrocensus boreholes water samples analysed suggest the overall ambient
groundwater quality is good with the majority of macro and micro determinants falling within or below the SANS
241:2015 limits. Groundwater can be described as neutral, saline to very saline and hard to very hard. The
groundwater quality is impacted by the geological formations, which were deposited in shallow marine
environments and are therefore naturally saline (Lea, 2017).
It is observed that most of the boreholes indicate elevated Nitrate (NO 3) concentrations. The latter may be
attributed to the agricultural land-use activities dominating the greater study area with elevated NO 3
concentrations potentially derived from leachate of fertilizer to the local aquifer. It should be noted that
elevated nitrate concentrations were also recorded in most of the hydrocensus boreholes identified during the
initial groundwater study of 2017 (Lea, 2017). It is noted that the TDS concentration increase towards the
northern section of the study area as well as near the drainages present. This can most likely be attributed to
the geology within these sections. It is noted that borehole localities with elevated NO 3 concentrations are
generally situated within or directly down-gradient of planted crop areas as well as near surface water features.
Isolated sampling localities also suggest elevated Calcium (Ca), Magnesium (Mg), Sodium (Na) and Chloride (Cl)
concentrations which may be indicative of the intermediate, fractured aquifer unit being targeted by the
respective borehole(s), sourcing more stagnant groundwater. The latter may also be indicative of over-
abstraction of the respective boreholes which result in more saline matrix water being sourced due to turbulent
flow conditions instead of water being sourced from fractures via laminar flow conditions.
Surface water samples included an upstream (SRU) and down-stream (SRD) water sample which were collected
from the Sandrivier passing down-gradient of the existing and proposed plant expansion footprint area. The
surface water quality can be classified as moderate to good with Aluminium (Al) and Iron (Fe) being slightly
elevated. It should be noted that there is not a significant change in the downstream water quality compared to
the upstream quality with an increase in Aluminium (Al), however all surface water samples analysed suggest
elevated heavy metal concentrations i.e., Al and Fe.
The hydrochemical results of the monitoring boreholes water samples analysed suggest the overall ambient
groundwater quality to be moderate with a higher salt load being observed. Groundwater can be described as
neutral, saline to very saline and hard to very hard. The majority of samples analysed suggest elevated
Calcium/Magnesium-Chloride concentrations with isolated boreholes (BH04 and BH05) indicating elevated
concentrations of Manganese (Mn).
GROUNDWATER CONTAMINATION RISK ASSESSMENT

The most widely accepted definition of groundwater contamination is defined as the introduction into water of
any substance in undesirable concentration not normally present in water e.g., microorganisms, chemicals,
waste or sewerage, which renders the water unfit for its intended use (UNESCO, 1992). The objective of this
study is to formulate a risk-based framework from geological and hydrogeological information obtained as part
of this investigation. As part of the aquifer classification, a Groundwater Quality Management (GQM) Index is
used to define the level of groundwater protection required. The GQM Index is obtained by multiplying the
rating of the aquifer system management and the aquifer vulnerability. A GQM Index = 4 was calculated for the
local aquifer system and according to this estimate, a “Medium” level groundwater protection is required for
this aquifer system.
The concept of groundwater vulnerability to contamination by applying the DRASTIC methodology was
introduced by Aller et al. (1987) and refined by the US EPA (United States Environmental Protection Agency).
DRASTIC is an acronym for a set of parameters that characterise the hydrogeological setting and combined
evaluated vulnerability: Depth to water level, Nett Recharge, Aquifer media, Soil media, Topography, Impact of
the vadose zone and Hydraulic Conductivity. This method provides a basis for evaluating the vulnerability to
pollution of groundwater resources based on hydrogeological parameters. Lynch et al (1994) suggests a
considerable variation in terms of hydraulic conductivity in hard rock aquifers and revised this methodology to
accommodate local aquifer conditions accordingly. According to the DRASTIC index methodology applied, the
1473 EIA Report 190

proposed activities and associated infrastructure’s risk to groundwater pollution of the aquifer system(s), is
rated as “Moderate”.
To evaluate the risk of groundwater contamination of shallow freshwater aquifers which are exploited by
farmers etc., potential sources of contamination should be identified, as well as potential pathways and
receptors. The pollution linkage concept relies on the identification of a potential pollutant (i.e. source) on-site
which is likely to have the potential to cause harm on a receptor by means of a pathway by which the receptor
may be exposed to the contaminant.
The following potential sources have been identified:
i. Migration of saline groundwater from the deep, fractured aquifer to the overlying, shallow freshwater
aquifer(s) during the gas exploration and production phase.
ii. Migration of stray gas from the deep, fractured aquifer to the overlying, shallow freshwater aquifer(s)
during the gas exploration and production phase.
iii. Migration of contaminants from the plant expansion waste storage facilities and evaporation pond into
local water resources and host aquifers.
The following aquifer pathways have been identified:
i. Vertical flow through the unsaturated/vadose zone as well as saturated zone to the underlying
intergranular and fractured rock aquifers. The rate at which seepage will take place is governed by the
permeability of sub-surface soil layers and host-rock formations.
ii. Preferential flow-paths include the contact between the depth of weathering and fresh un-weathered
rock, fractures, faults, joints and bedding planes. Secondary fractures may also potentially act as
transport mechanisms.
iii. If not adequately sealed and suitably mitigated, gas exploration and production wells will form
preferential flow paths and serve as a direct connection between the deeper, fractured aquifer and
shallow, potable aquifer unit(s).
The following receptors were identified:
i. Shallow, inter-granular as well as the intermediate, fractured aquifer units situated within the plume
migration footprint(s).
ii. Down-gradient drainages and streams including associated riparian zone aquifer system(s) and
baseflow contribution.
iii. Private or neighbouring boreholes associated with relevant fracture zones and/or structures(s) if
intercepted by the pollution plume migration footprint.
NUMERICAL GROUNDWATER FLOW AND CONTAMINANT TRANSPORT MODEL

The purpose of a groundwater model is to serve as a tool to evaluate various water management options and
scenarios. The detail on how the model is constructed is included in the groundwater specialist report. The
model shows the direction of natural groundwater movement which will result in the downstream
transportation of any artificially introduced contaminants from a particular source or location. This would result
in downstream receptors (e.g. abstraction boreholes, etc) becoming contaminated) if the contaminant source is
not suitably mitigated in the first place The steady state hydraulic heads and groundwater flow direction is
presented in Figure 78.
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Figure 78: Steady state hydraulic heads and groundwater flow direction.
1473 EIA Report 192

A contaminant transport scenario was conducted simulating stray methane gas (CH 4) from leaking gas
production boreholes. The drilling and operation of gas production wells could result in the migration of stray
gas from the deep-seated fracture zones to formations higher up in the geological sequence. This impact has
been recorded in the US where hydraulic fracturing, dewatering or a combination of these has occurred (Jackson
et al, 2013). It should be stated that Tetra4 does not intend to undertake hydraulic fracturing, or any well
stimulation and the existing dataset suggests that no dewatering of produced water will be required.
Accordingly, the risk of stray gas migration is therefore expected to be low. It should be noted that this scenario
is highly unlikely under natural conditions as the production zone(s) is separated from the shallow and potable
Karoo aquifer by very low permeability shale formations which will act as an aquitard towards any groundwater
and stray gas migration. This is however provided that well construction, including cementation and the
installation of steel casing, is sound. As such, the impact assessment evaluated represents a worst-case scenario
and simulates the eventual occurrence once stray gas does reach the shallow aquifer. The mechanisms by which
stray gas can migrate into the shallower potable Karoo aquifer include (iLEH, 2017):
• Leakage of stray gas along poorly sealed gas production wells;
• Gas leakage because of an overpressure event and barrier (casing and cementation) failure; and
• Migration of gas from deep-seated fracture zones along fractures and faults.
As methane gas reaches saturation in water at 28 milligrams per litre (mg/L) at atmospheric pressure (Eltschlager
and others, 2001), this concentration was applied as source term for this scenario. According to the U.S.
Environmental Protection Agency (EPA, 2011) as well as U.S. Department of the Interior, Office of Surface Mining
(2011), methane concentrations below 10 mg/L are generally considered safe.
Various management scenarios were modelled for the purposes of planning and decision making with stress
periods listed in Table 28:
i. Scenario 01: Steady state water balance (∞).
ii. Scenario 02a: Migration of saline groundwater from the deep, fractured aquifer to the overlying,
potable aquifer(s) during the operational gas production phase.
iii. Scenario 02b: Migration of stray methane (CH4) gas emanating from the deep, fractured aquifer to the
overlying, potable aquifer(s) during the operations gas production phase.
iv. Scenario 03: Migration of the TDS pollution plume emanating from the plant footprint area during the
operational gas production phase.
v. Scenario 04a: Migration of saline groundwater from the deep, fractured aquifer to the overlying,
potable aquifer(s) during the post-closure and decommissioning phase (50-year and 100-year
scenarios).
vi. Scenario 04b: Migration of stray methane (CH4) gas emanating from the deep, fractured aquifer to the
overlying, potable aquifer(s) during the post-closure and decommissioning phase (50-year and 100-year
scenarios).
vii. Scenario 05: Migration of the TDS pollution plume emanating from the plant footprint area during the
post-closure and decommissioning phase (50-year and 100-year scenarios).
Table 28: Summary of model stress-periods.
Stress period Description
Year01 – Year20 Gas production operational phase
Year 21 – Year 71 50-years post closure
Year 72 – Year 121 100-years post closure
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SCENARIO 01: STEADY STATE BASELINE WATER BALANCE (∞)
Recharge is assumed the only source of inflow to the system and has been simulated at 1.03E +05 m3/d, while the
largest loss to the groundwater system is via baseflow, 1.02E +04 m3/d. The imbalance of the delineated aquifer
unit, ignoring internal transfer, is calculated at 1.90E+3 m3/d.
SCENARIO 02A: MIGRATION OF SALINE GROUNDWATER FROM THE DEEP, FRACTURED AQUIFER TO
THE OVERLYING, POTABLE AQUIFER(S) DURING THE OPERATIONAL GAS PRODUCTION PHASE.
This scenario summarises the simulated point source pollution plume migration of saline groundwater
emanating from the deep, fractured aquifer should the integrity of the gas production boreholes be jeopardised
i.e., leaking boreholes for the operational phase (20-year period). The TDS pollution plume extend covers a total
area of approximately 414.06ha in the Karoo formations, reaching a maximum distance of ~80.0m in a radial
pattern from the gas production borehole(s), and approximately 251.60ha in the alluvial deposits, reaching a
maximum distance of ~200.0m in a radial pattern from the gas production borehole after a simulation period of
20-years (refer to Figure 81). The simulation indicates that the following neighbouring boreholes will potentially
be intercepted by the simulated pollution plume HBH08, HBH41, HBH42, HBH43, HBH63, HBH72, HBH73 and
HBH74. It is noted that the pollution plume does extend beyond the project boundary. Figure 80 indicates the
expected flow pathways of particles derived from the source points and it is evident that the pollution plume
migration in the denser Karoo formations is sluggish while movement in the unconsolidated alluvial deposits of
the riparian zone suggest a larger flux.
Figure 79 summarises a time-series graph of the TDS mass load contribution to down-gradient receptors. It is
evident that source term mass load contribution to existing neighbouring borehole situated near the gas
production boreholes does not exceed ~800.0mg/l and ranges between 600mg/l to 700.0mg/l.
saline aquifer on observation boreholes targetting the potable shallow, intergranular aquifer (Operational
phase).
1473 EIA Report 194

Figure 80: Scenario 02: Simulated particle tracking of contaminants originating from the deeper, fractured aquifer migrating from leaking boreholes within the intergranular
aquifer (Operational phase).
1473 EIA Report 195

Figure 81: Scenario 02a: TDS pollution plume migration of contaminants originating from the deeper, fractured aquifer migrating through the intergranular aquifer
(Operational phase).
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SCENARIO 02B: MIGRATION OF STRAY METHANE (CH4) GAS EMANATING FROM THE DEEP,
FRACTURED AQUIFER TO THE OVERLYING, POTABLE AQUIFER(S) DURING THE OPERATIONS GAS
PRODUCTION PHASE.
This scenario summarises the simulated point source pollution plume migration of stray methane (CH4) gas
i.e., leaking boreholes. The CH4 pollution plume extend covers a total area of approximately 162.74ha in the
Karoo formations, reaching a maximum distance of ~50.0m in a radial pattern from the gas production
borehole(s), and approximately 62.83ha in the alluvial deposits, reaching a maximum distance of ~100.0m in a
radial pattern from the gas production borehole after a simulation period of 20-years (refer to Figure 83). The
simulation indicates that the following neighbouring boreholes will potentially be intercepted by the simulated
pollution plume HBH08, HBH41, HBH42, HBH43, HBH63, HBH72, HBH73 and Tetra4 monitoring borehole 11A. It
is noted that the pollution plume does not extend beyond the project boundary.
Figure 82 summarises a time-series graph of the CH4 mass load contribution to down-gradient receptors. It is
evident that source term mass load contribution to existing neighbouring borehole situated near the gas
production boreholes remains below the EPA safety threshold (2011) of 10.0mg/l and ranges between 0.01mg/l
to 1.50mg/l.
Figure 82: Scenario 02b: Time-series graph indicating the CH4 mass load contribution of deeper, fractured
aquifer on observation boreholes targetting the potable shallow, intergranular aquifer (Operational phase).
1473 EIA Report 197

Figure 83: Scenario 02b: CH4 pollution plume migration of contaminants originating from the deeper, fractured aquifer migrating through the intergranular aquifer
(Operational phase).
1473 EIA Report 198

SCENARIO 03: MIGRATION OF THE TDS POLLUTION PLUME EMANATING FROM THE PLANT
FOOTPRINT AREA DURING THE OPERATIONAL GAS PRODUCTION PHASE.
This scenario summarises the simulated pollution plume migration from the plant footprint areas for the
operational phase. The TDS pollution plume extent covers a total area of approximately 48.80ha reaching a
maximum distance of ~110.0m in a general north-northwest direction towards the lower laying drainage
system(s) after a simulation period of 20-years as depicted in Figure 86. The simulation indicates that no
neighbouring boreholes or local drainages are expected to be impacted on during the operational phase.
evident that the TDS mass load contribution to down-gradient receptors increase to a concentration of between
200.0 – 800.0 mg/l, however, remains below the SANS 241:2015 limit of 1200.0mg/l for the duration of the
simulation period.
Figure 85 depicts a model cross section of the pollution plume migration within the simulated aquifer. It is
evident that the mass transport of the pollution plume is mostly limited to the shallow, intergranular aquifer.
down-gradient observation boreholes targeting the potable shallow, intergranular aquifer (Operational phase).
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Figure 85: Scenario 03: Model domain 3-D FEM mesh view (cross sectional view southwest-northeast orientation
A-A’) of the TDS pollution plume originating at the plant footprint (Operational phase).
1473 EIA Report 200

Figure 86: Scenario 03: TDS pollution plume migration of contaminants originating from the plant footprint within the intergranular aquifer (Operational phase).
1473 EIA Report 201

SCENARIO 04A: MIGRATION OF SALINE GROUNDWATER FROM THE DEEP, FRACTURED AQUIFER TO
THE OVERLYING, POTABLE AQUIFER(S) DURING THE POST-CLOSURE AND DECOMMISSIONING
PHASE (50-YEAR AND 100-YEAR SCENARIOS).
This scenario summarises the simulated point source pollution plume migration of saline groundwater
i.e., leaking boreholes for the post-closure phase. The TDS pollution plume extend covers a total area of
approximately 643.70ha in the Karoo formations, reaching a maximum distance of ~100.0m in a radial pattern
from the gas production borehole(s), and approximately 392.70ha in the alluvial deposits, reaching a maximum
distance of ~250.0m in a radial pattern from the gas production borehole(s) after a simulation period of 50-
years.
The TDS pollution plume extend covers a total area of approximately 1 456.42ha in the Karoo formations,
reaching a maximum distance of ~150.0m in a radial pattern from the gas production borehole(s), and
approximately 769.70ha in the alluvial deposits, reaching a maximum distance of ~350.0m in a radial pattern
from the gas production borehole(s) after a simulation period of 100-years (refer to Figure 89). The simulation
indicates that the following neighbouring boreholes will potentially be intercepted by the simulated pollution
plume HBH08, HBH41, HBH42, HBH43, HBH48, HBH50, HBH63, HBH72, HBH73, HBH74 as well as Tetra4
monitoring boreholes Mon 2057 and 11A. It is noted that the pollution plume does not extend beyond the
project boundary.
Figure 88 indicates the expected flow pathways of particles derived from the source points and as noted earlier,
it is evident that the pollution plume migration in the denser Karoo formations is sluggish while movement in
the unconsolidated alluvial deposits of the riparian zone suggest a larger flux. Figure 87 summarises a time-series
graph of the TDS mass load contribution to down-gradient receptors. It is evident that source term mass load
contribution to existing neighbouring and monitoring boreholes situated near the gas production boreholes
ranges between 650.0mg/l to >1200.0mg/l. It is noted that the SANS241:2015 limit is exceeded at borehole
localities HBH63 and Mon 2057.
saline aquifer on observation boreholes targeting the potable shallow, intergranular aquifer (post-closure
phase).
1473 EIA Report 202

Figure 88: Scenario 04: Simulated particle tracking of contaminants originating from the deeper, fractured aquifer migrating from leaking boreholes within the intergranular
aquifer (post-closure phase).
1473 EIA Report 203

Figure 89: Scenario 04a: TDS pollution plume migration of contaminants originating from the deeper, fractured aquifer migrating through the intergranular aquifer (post-
closure phase).
1473 EIA Report 204

SCENARIO 04B: MIGRATION OF STRAY METHANE (CH4) GAS EMANATING FROM THE DEEP,
FRACTURED AQUIFER TO THE OVERLYING, POTABLE AQUIFER(S) DURING THE POST-CLOSURE AND
DECOMMISSIONING PHASE (50-YEAR AND 100-YEAR SCENARIOS).
This scenario summarises the simulated point source pollution plume migration from of stray methane (CH 4) gas
i.e., leaking boreholes for the post-closure phase. The CH4 pollution plume extend covers a total area of
approximately 414.06ha in the Karoo formations, reaching a maximum distance of ~80.0m in a radial pattern
from the gas production borehole(s), and approximately 141.37ha in the alluvial deposits, reaching a maximum
distance of ~150.0m in a radial pattern from the gas production borehole(s) after a simulation period of 50-
years.
The CH4 pollution plume extend covers a total area of approximately 643.70ha in the Karoo formations, reaching
a maximum distance of ~100.0m in a radial pattern from the gas production borehole(s), and approximately
392.70ha in the alluvial deposits, reaching a maximum distance of ~250.0m in a radial pattern from the gas
production borehole(s) after a simulation period of 100-years (refer to Figure 91). The simulation indicates that
the following neighbouring boreholes will potentially be intercepted by the simulated pollution plume HBH08,
HBH41, HBH42, HBH43, HBH48, HBH49, HBH63, HBH72, HBH73 as well as Tetra4 monitoring boreholes Mon
2057 and 11A. It is noted that the pollution plume does not extend beyond the project boundary.
Figure 90 summarises a time-series graph of the CH4 mass load contribution to down-gradient receptors. It is
evident that source term mass load contribution to existing neighbouring and monitoring boreholes situated
near the gas production boreholes ranges between 0.50mg/l to ~2.0mg/l, however, remains below the EPA
safety threshold (2011) of 10.0mg/l.
Figure 90: Scenario 04b: Time-series graph indicating the CH4 mass load contribution of waste facilities on down-
gradient receptors.
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Figure 91: Scenario 04b: CH4 pollution plume migration of contaminants originating from the deeper, fractured aquifer migrating through the intergranular aquifer (post-
closure phase).
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SCENARIO 05: MIGRATION OF THE TDS POLLUTION PLUME EMANATING FROM THE PLANT
FOOTPRINT AREA DURING THE POST-CLOSURE AND DECOMMISSIONING PHASE (50-YEAR AND 100-
YEAR SCENARIOS).
This scenario summarises the simulated pollution plume migration from the plant footprint areas for the post-
closure phase. The TDS pollution plume extend covers a total area of approximately 54.8ha reaching a maximum
distance of ~170.0m in a general north-northwest direction towards the lower laying drainage system(s) after a
simulation period of 50-years and covers a total area of approximately 71.20ha reaching a maximum distance of
~300.0m in a general north-northwest direction towards the lower laying drainage system(s) after a simulation
period of 100-years as depicted in Figure 96.
Figure 94 and Figure 95 indicates the expected flow pathways of particles for the 50- and 100-years simulation
periods respectively, and it is evident that the pollution plume potentially reaches the local drainages system
down-gradient of the plant footprint during the post-closure phase.
evident that the TDS mass load contribution to down-gradient receptors increase to a concentration above the
SANS 241:2015 limit of 1200.0mg/l for the post-closure simulation period.
Figure 93 summarises a time-series graph of the TDS mass load percentage contribution to down-gradient river
receptors of the Sandrivier and Doringrivier. It is evident that the TDS mass load contribution increases to a
percentage of ~10.0% to the Sandrivier where the mass load contribution to the Doringrivier increase to a
percentage of ~2.0% for the duration of the post-closure simulation period.
down-gradient observation boreholes targeting the potable shallow, intergranular aquifer (post-closure phase).
1473 EIA Report 207

down-gradient river receptors expressed as the percentage change in salt load (post-closure phase).
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Figure 94: Scenario 05: Simulated particle tracking of contaminants originating from the plant footprint within the intergranular aquifer (50-years post-closure).
1473 EIA Report 209

Figure 95: Scenario 05: Simulated particle tracking of contaminants originating from the plant footprint within the intergranular aquifer (100-years post-closure).
1473 EIA Report 210

Figure 96: Scenario 05: TDS pollution plume migration of contaminants originating from the plant footprint within the intergranular aquifer (post-closure phase).
1473 EIA Report 211

HYDROGEOLOGICAL SENSITIVITY
Based on the findings of the geohydrological specialist study and outcomes of the impact assessment a
hydrogeological sensitivity map was generated, highlighting groundwater zones which will be sensitive to
contamination and should form part of the monitoring protocol. Refer to Table 29 for a summary of identified
hydrogeological sensitive areas with a spatial representation depicted in Figure 97.
Table 29: Hydrogeological sensitivity rating.
Hydrogeological
Sensitivity
Description component Motivation Weighting
rating
identified
The inherent feature status and All areas not This area excludes groundwater
sensitivity is already degraded. included in either receptors or sensitive areas
The proposed development will the moderately of identified as part of the
not affect the current status highly sensitive assessment.
Low and/or may result in a positive zones as -1
impact. These features would be identified.
the preferred alternative for
mining or infrastructure
placement.
The proposed development will A zone of 450m These aquifers cover a
negatively influence the current around the substantial portion of the study
status of the feature to a proposed gas area and are limited to a zone of
moderate degree of modification. production wells variable width and depth. The
situated within alluvial aquifer is specifically
the primary vulnerable to contamination as it
porosity aquifer there is a direct connectivity with
associated with rivers and streams and associated
alluvium material high permeability. This aquifer is
deposited in flood moderately susceptible to
plains. impacts from contaminant
sources originating within this
A zone of 250m buffer zone as point source
around the pollution.
proposed gas
production wells The intergranular Karoo aquifer
situated within can be classified as a secondary
Moderate +1
the Karoo porosity aquifer and is generally
formations. unconfined with phreatic water
levels. Due to higher effective
A buffer zone of porosity (n) this aquifer is most
50m along susceptible to impacts from
identified fault contaminant sources. This
zones traverse aquifer is moderately susceptible
the project area. to impacts from contaminant
sources originating within this
buffer zone as point source
pollution.
Fault zones targeted as part of

the gas production operation can
serve as potential preferred
pathways for groundwater flow
and contaminant transport.
1473 EIA Report 212

Hydrogeological
Sensitivity
Description component Motivation Weighting
rating
identified
The proposed development will A zone of 350m These aquifers cover a
negatively influence the current around the substantial portion of the study
status of the feature to a high proposed gas area and are limited to a zone of
degree of modification. production wells variable width and depth. The
situated within alluvial aquifer is specifically
the riparian zone vulnerable to contamination as it
primary porosity there is a direct connectivity with
aquifer associated rivers and streams and associated
with alluvium high permeability. This aquifer is
material highly susceptible to impacts
deposited in flood from contaminant sources
plains. originating within this buffer
High +1
zone as point source pollution.
A zone of 150m
around the The intergranular Karoo aquifer
proposed gas can be classified as a secondary
production wells porosity aquifer and is generally
situated within unconfined with phreatic water
the Karoo levels. Due to higher effective
formations. porosity (n) this aquifer is highly
susceptible to impacts from
contaminant sources originating
within this buffer zone as point
source pollution.
1473 EIA Report 213

Figure 97: Hydrogeological sensitivity map.
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9.11 TERRESTRIAL BIODIVERSITY
Terrestrial Biodiversity has been assessed by The Biodiversity Company (TBC) and the specialist report is included
in Appendix 4. The baseline terrestrial biodiversity (flora and fauna) findings are presented in the subsections
below.
ECOLOGICALLY IMPORTANT LANDSCAPE FEATURES

The following features describe the general area and habitat, this assessment is based on spatial data that was
available from various sources such as the provincial environmental authority and SANBI. The findings of the
desktop analysis into sensitive areas and the relevance to this project are listed in Table 30.
Table 30: Desktop spatial features examined.
Desktop Information Considered Relevant/Irrelevant

Critical Biodiversity Area Relevant – Intersects CB1, CBA2, ESA1 and ESA2
Ecosystem Threat Status Relevant – Located within an Endangered and Least
Concerned ecosystem
Ecosystem Protection Level Relevant – Located within a Not Protected and a
Poorly Protected ecosystem
Protected Areas Relevant – Within 5km of a protected area
National Protected Area Expansion Strategy Relevant –Overlap any NPAES areas
Important Bird and Biodiversity Areas Irrelevant – Does not overlap IBA, is 29,5 km from
the Willem Pretorius Nature Reserve IBA
South African Inventory of Inland Aquatic Relevant – overlaps with three CR rivers and
Ecosystems numerous unclassified wetlands.
National Freshwater Ecosystem Priority Areas Relevant – overlaps with a true FEPA wetland and an
unclassified river.
Strategic Water Source Areas Irrelevant – Not located within a SWSA, closest
SWSA is 122 km away
BIODIVERSITY SPATIAL PLAN (BSP)

Conservation of CBAs is crucial, in that if these areas are not maintained in a natural or near-natural state,
biodiversity conservation targets cannot be met. Maintaining an area in a natural state can include a variety of
biodiversity compatible land uses and resource uses (SANBI-BGIS, 2017). The proposed development overlaps
with an area regarded as CBA1, CBA2, ESA1, ESA2, Other, and Degraded. The application area falls across both
a CBA2 and an ESA1 classified area (Figure 98).
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Figure 98: Application area superimposed on the Free State BSP.
THE NATIONAL BIODIVERSITY ASSESSMENT

The National Biodiversity Assessment (NBA) was completed as a collaboration between the SANBI, the DEA (now
the DFFE) and other stakeholders, including scientists and biodiversity management experts throughout the
country over a three-year period. The purpose of the NBA is to assess the state of South Africa’s biodiversity
with a view to understanding trends over time and informing policy and decision-making across a range of
sectors. The two headline indicators assessed in the NBA are ecosystem threat status and ecosystem protection
level which are discussed in more detail in the sub-sections below.
ECOSYSTEM THREAT STATUS
Ecosystem threat status outlines the degree to which ecosystems are still intact or alternatively losing vital
aspects of their structure, function and composition, on which their ability to provide ecosystem services
ultimately depends. Ecosystem types are categorised as Critically Endangered (CR), Endangered (EN), Vulnerable
(VU) or Least Threatened (LT), based on the proportion of each ecosystem type that remains in good ecological
condition. The application area was superimposed on the terrestrial ecosystem threat status (Figure 99).
According to the spatial dataset the proposed development overlaps with LC and EN ecosystems.
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Figure 99: The application area showing the regional ecosystem threat status of the associated terrestrial
ecosystems (NBA, 2018).
ECOSYSTEM PROTECTION LEVEL

Ecosystem protection level tells us whether ecosystems are adequately protected or under-protected.
Ecosystem types are categorised as not protected, poorly protected, moderately protected or well protected,
based on the proportion of each ecosystem type that occurs within a protected area recognised in the Protected
Areas Act. The application area was superimposed on the ecosystem protection level map to assess the
protection status of terrestrial ecosystems associated with the development (Figure 100). The application area
overlaps with Not Protected (NP) and Poorly Protected (PP) ecosystems.
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Figure 100: The application area showing the regional level of protection of terrestrial ecosystems (NBA, 2018).
PROTECTED AREAS
According to the protected area spatial datasets, the application area does not occur within any protected area
but does overlap with a National Protected Area Expansion Strategy (NPAES) area and is within the 5 km buffer
of protected areas. The H.J Joel Private Nature Reserve is found 876 m from the application area (Figure 101).
The south-eastern corner of the application area overlaps with a NPAES priority focus area (Figure 102).
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Figure 101: Map illustrating the location of protected areas proximal to the assessment area.
Figure 102: Map illustrating the location of NPAES proximal to the assessment area.
1473 EIA Report 219

IMPORTANT BIRD AND BIODIVERSITY AREAS (IBAS)
The proposed development does not overlap any IBA (Figure 103). The closest IBA, the Willem Pretorius Nature
Reserve, is located approximately 29.5 km to the east.
Figure 103: Location of Important Bird and Biodiversity Areas (IBAs) in relation to the assessment area.
HYDROLOGICAL SETTING
Three major river systems assessed as part of the South African Inventory of Inland Aquatic Ecosystems (SAIIAE)
overlap with the proposed development area (Sand River, Doring River and Bosluisspruit) (Figure 104). The
threat status, protection level and condition of South African rivers and wetlands were released with the
National Biodiversity Assessment (NBA) 2018. Ecosystem Threat Status (ETS) are based on the extent to which
each type had been altered from its natural condition. Ecosystem types are categorised as CR, EN, VU or LC.
Critically Endangered, EN and VU ecosystem types are collectively referred to as ‘threatened’. The rivers were
all classed as CR, while the wetlands were not evaluated as part of NBA 2018.
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Figure 104: Hydrological context of the assessment area based on the NBA spatial dataset (2018).
Freshwater Ecosystem Priority Areas (FEPAs) (Driver et al., 2011) are intended to be conservation support tools
and are envisioned to guide the effective implementation of measures to achieve the National Environment
Management Biodiversity Act (NEM:BA) biodiversity goals. Figure 105 shows the assessment area overlaps with
a true FEPA wetland and an unclassified river.
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Figure 105: Hydrological context of the assessment area based on the NFEPA spatial dataset (2011).
VEGETATION TYPES
The application area is situated within the Grassland biome. This biome is centrally located in southern Africa,
and adjoins all except the desert, fynbos and succulent Karoo biomes (Mucina & Rutherford, 2006). Major
macroclimatic traits that characterise the grassland biome include:
• Seasonal precipitation; and
• The minimum temperatures in winter (Mucina & Rutherford, 2006).
The grassland biome is found chiefly on the high central plateau of South Africa, and the inland areas of KwaZulu-
Natal and the Eastern Cape. The topography is mainly flat and rolling but includes the escarpment itself. Altitude
varies from near sea level to 2850 m above sea level.
Grasslands are dominated by a single layer of grasses. The amount of cover depends on rainfall and the degree
of grazing. The grassland biome experiences summer rainfall and dry winters with frost (and fire), which are
unfavourable for tree growth. Thus, trees are typically absent, except in a few localized habitats. Geophytes
(bulbs) are often abundant. Frosts, fire and grazing maintain the grass dominance and prevent the establishment
of trees.
On a fine-scale vegetation type, the application area overlaps predominantly with the Highveld Alluvial
Vegetation (Least Threatened) and Vaal Vet Sandy Grassland (Endangered) as shown in Figure 106.
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Figure 106: The application area showing the vegetation type based on the Vegetation Map of South Africa,
Lesotho & Swaziland (BGIS, 2018).
FLORA ASSESSMENT
This section is divided into three sections:
3. Indigenous Flora;
4. Invasive Alien Plants (IAPs); and
5. Protected Plant Species.
INDIGENOUS FLORA
The vegetation assessment was conducted throughout the extent of the application area. A total of 122 tree,
shrub, herbaceous and graminoid plant species were recorded in the application area during the field
assessment (Table 31). Plants listed as Category 1 alien or invasive species under the NEMBA appear in green
text. Plants listed in Category 2 or as ‘not indigenous’ or ‘naturalised’ according to NEMBA, appear in blue text.
The list of plant species recorded is by no means comprehensive, and repeated surveys during different
phenological periods not covered may likely yield up to 20 % additional flora species for the application area.
However, floristic analysis conducted to date is regarded as a sound representation of the local flora for the
application area.
Table 31: Trees, shrub and herbaceous plant species recorded in the application area.
Family Scientific Name Threat Status (SANBI, 2017) SA Alien Category

Endemic
Acanthaceae Blepharis squarrosa LC Endemic
Acanthaceae Crabbea angustifolia LC Endemic
Agavaceae Chlorophytum cooperi LC Not
Endemic
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Endemic
Aizoaceae Delosperma herbeum LC Not
Endemic
Amaranthaceae Achyranthes aspera Naturalized
exotic
Amaranthaceae Gomphrena celosioides Naturalized
exotic
Amaryllidaceae Ammocharis coranica LC-Schedule 6 Protected Not
Endemic
Amaryllidaceae Boophone disticha LC Schedule -6 Protected Not
Endemic
Anacardiaceae Schinus terebinthifolius Naturalized
exotic
Anacardiaceae Searsia lancea LC Not
Endemic
Anacardiaceae Searsia pyroides var. pyroides LC Not
Endemic
Apocynaceae Nerium oleander NEMBA Category
1b.
Asclepiadaceae Gomphocarpus fruticosus LC Indigeno
subsp. fruticosus us
Asparagaceae Asparagus cooperi LC Not
Endemic
Asparagaceae Asparagus laricinus LC Not
Endemic
Asparagaceae Eucomis autumnalis LC -Schedule 6 Protected Not
Endemic
Asphodelaceae Aloe dominella Near Threatened B1ab(ii,iii,v) (- Endemic
Schedule 6 Protected)
Asteraceae Artemisia afra LC Not
Endemic
Asteraceae Berkheya onopordifolia var. LC Not
onopordifolia Endemic
Asteraceae Berkheya pinnatifida LC Not
Endemic
Asteraceae Bidens pilosa Naturalized
exotic weed
Asteraceae Cirsium vulgare NEMBA Category
1b.
Asteraceae Conyza bonariensis Naturalized
exotic
Asteraceae Cotula anthemoides LC Not
Endemic
Asteraceae Felicia muricata subsp. LC Not
muricata Endemic
Asteraceae Geigeria burkei LC Not
Endemic
Asteraceae Hilliardiella elaeagnoides LC Not
Endemic
Asteraceae Macledium zeyheri LC Not
Endemic
Asteraceae Nidorella anomala LC Not
Endemic
Asteraceae Schkuhria pinnata Naturalized
exotic
Asteraceae Senecio inornatus LC Not
Endemic
Asteraceae Stoebe plumosa LC Not
Endemic
Asteraceae Tagetes minuta Naturalized
exotic
1473 EIA Report 224

Endemic
Asteraceae Xanthium stramonium NEMBA Category
1b.
Asteraceae Zinnia peruviana Naturalized
exotic
Cactaceae Opuntia ficus-indica NEMBA Category
1b.
Cactaceae Opuntia stricta NEMBA Category
1b.
Campanulaceae Wahlenbergia undulata LC Not
Endemic
Cannabaceae Celtis africana LC Not
Endemic
Caryophyllacea Pollichia campestris LC Not
e Endemic
Commelinaceae Commelina africana LC Not
Endemic
Commelinaceae Commelina erecta LC Not
Endemic
Commelinaceae Cyanotis speciosa LC Not
Endemic
Convolvulaceae Cuscuta campestris Naturalized
exotic
Cucurbitaceae Cucumis zeyheri LC Not
Endemic
Ebenaceae Diospyros austro-africana LC Not
Endemic
Fabaceae Chamaecrista mimosoides LC Not
Endemic
Fabaceae Robinia pseudoacacia NEMBA Category
1b.
Fabaceae Vachellia karroo LC Not
Endemic
Geraniaceae Monsonia angustifolia LC Not
Endemic
Hyacinthaceae Dipcadi longifolium LC Not
Endemic
Hyacinthaceae Ledebouria marginata LC Not
Endemic
Hyacinthaceae Schizocarphus nervosus LC-Schedule 6 Protected
Hypoxidaceae Hypoxis hemerocallidea LC Not
Endemic
Hypoxidaceae Hypoxis iridifolia LC Not
Endemic
Iridaceae Gladiolus crassifolius LC-Schedule 6 Protected Not
Endemic
Iridaceae Gladiolus permeabilis LC-Sched 6 Protected Endemic
Malvaceae Hermannia depressa LC Not
Endemic
Malvaceae Hibiscus trionum LC Not
Endemic
Malvaceae Hibiscus trionum Naturalized
exotic
Malvaceae Malva neglecta Naturalized
exotic
Meliaceae Melia azedarach NEMBA Category
1b.
Moraceae Morus alba NEMBA Category
3
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Endemic
Myrtaceae Eucalyptus camaldulensis NEMBA Category
1b
Oxalidaceae Oxalis depressa LC Not
Endemic
Pentzia Pentzia globosa LC Not
Globosa Endemic
Pinaceae Pinus pinaster NEMBA Category
2
Poaceae Aristida adscensionis LC Not
Endemic
Poaceae Aristida canescens subsp. LC Not
canescens Endemic
Poaceae Aristida congesta subsp. LC Not
barbicollis Endemic
Poaceae Aristida congesta subsp. LC Not
congesta Endemic
Poaceae Arundo donax NEMBA Category
1b.
Poaceae Bambusa sp Naturalized
exotic
Poaceae Bewsia biflora LC Not
Endemic
Poaceae Cenchrus ciliaris LC Not
Endemic
Poaceae Chloris gayana LC Not
Endemic
Poaceae Cortaderia selloana NEMBA Category
1b.
Poaceae Cymbopogon caesius LC Not
Endemic
Poaceae Cynodon dactylon LC Not
Endemic
Poaceae Digitaria eriantha LC Not
Endemic
Poaceae Eleusine coracana Naturalized
exotic
Poaceae Eragrostis chloromelas LC Not
Endemic
Poaceae Eragrostis curvula LC Not
Endemic
Poaceae Eragrostis gummiflua LC Not
Endemic
Poaceae Eragrostis obtusa LC Not
Endemic
Poaceae Eragrostis superba LC Not
Endemic
Poaceae Fingerhuthia africana LC Not
Endemic
Poaceae Heteropogon contortus LC Not
Endemic
Poaceae Hyparrhenia hirta LC Not
Endemic
Poaceae Hyperthelia dissoluta LC Not
Endemic
Poaceae Melinis repens LC Not
Endemic
Poaceae Microchloa caffra LC Not
Endemic
Poaceae Panicum maximum LC Not
Endemic
1473 EIA Report 226

Endemic
Poaceae Paspalum dilatatum LC Indigeno
us
Poaceae Pennisetum clandestinum NEMBA Category
1b.
Poaceae Phragmites australis LC Not
Endemic
Poaceae Pogonarthria squarrosa LC Not
Endemic
Poaceae Setaria pumila LC Not
Endemic
Poaceae Setaria sphacelata var. Sericea LC Not
Endemic
Poaceae Setaria sphacelata var. LC Not
sphacelata Endemic
Poaceae Setaria sphacelata var. torta LC Not
Endemic
Poaceae Setaria verticillata LC Not
Endemic
Poaceae Sporobolus africanus LC Not
Endemic
Poaceae Themeda triandra LC Not
Endemic
Poaceae Trachypogon spicatus LC Not
Endemic
Poaceae Trichoneura grandiglumis LC Not
Endemic
Poaceae Urochloa mosambicensis LC Not
Endemic
Polygonaceae Persicaria lapathifolia Naturalized
exotic
Rhamnaceae Ziziphus mucronata subsp. LC Not
mucronata Endemic
Rosaceae Prunus persica Naturalized
exotic
Salicaceae Populus alba NEMBA Category
2
Salicaceae Populus deltoides Naturalized
exotic
Salicaceae Salix babylonica Naturalized
exotic
Scrophulariacea Jamesbrittenia aurantiaca LC Not
e Endemic
Scrophulariacea Selago densiflora LC Not
e Endemic
Solanaceae Datura ferox NEMBA Category
1b.
Solanaceae Solanum lichtensteinii LC Not
Endemic
Tamaricaceae Tamarix chinensis NEMBA Category
1b.
Typhaceae Typha capensis LC Not
Endemic
Verbenaceae Verbena astrigera Naturalized
exotic
Verbenaceae Verbena bonariensis NEMBA Category
1b.
Zygophyllaceae Tribulus terrestris LC Not
Endemic
1473 EIA Report 227

INVASIVE ALIEN PLANTS
Invasive Alien Plants (IAPs) tend to dominate or replace indigenous flora, thereby transforming the structure,
composition and functioning of ecosystems. Therefore, it is important that these plants are controlled by means
of an eradication and monitoring programme. Some invader plants may also degrade ecosystems through
superior competitive capabilities to exclude native plant species.
Fourteen (14) IAP species were recorded within the application area. These species are listed under the Alien
and Invasive Species List 2020, Government Gazette No. GN1003 as Category 1b. Category 1b species must be
controlled by implementing an IAP Management Programme, in compliance of section 75 of the NEMBA.
PROTECTED PLANT SPECIES
Several individuals of protected plant species that are protected by the Free State Nature Conservation
Ordinance 8 of 1969 were observed in various parts of the application area. According to the list of protected
species under Schedule, if any individuals of these plant species are to be disturbed, permits must be obtained
from the Free State Department of Economic, Small Business Development, Tourism and Environmental Affairs
(FSDESTEA).
FAUNA ASSESSMENT
Avifauna, Mammal and Herpetofauna observations and recordings fall under this section.
AVIFAUNA
Eighty-nine (89) (37.7 % of expected) species were recorded in the application area during the survey based on
either direct observation, vocalisations, or the presence of visual tracks & signs, (Table 32). Four (4) (red text)
species are rated as Species of Conservation Concern (SCC), whereas 75 were listed as protected provincially.
Table 32: A list of avifaunal species recorded for the application area.
Species Common Name Regional (SANBI, IUCN (2021) Free State Nature
2016) Conservation Ordinance
8 of 1969
Acridotheres tristis Myna, Common Unlisted LC -
Afrotis afraoides Korhaan, Northern Unlisted LC Schedule 1 Protected
Black
Alopochen aegyptiaca Goose, Egyptian Unlisted LC Schedule 1/2 Protected
Amadina erythrocephala Finch, Red-headed Unlisted LC Schedule 1 Protected
Anas erythrorhyncha Teal, Red-billed Unlisted LC Schedule 1 Protected
Anas sparsa Duck, African Black Unlisted LC Schedule 1 Protected
Anas undulata Duck, Yellow-billed Unlisted LC Schedule 1/2 Protected
Anhinga rufa Darter, African Unlisted LC Schedule 1 Protected
Apus apus Swift, Common Unlisted LC Schedule 1 Protected
Ardea cinerea Heron, Grey Unlisted LC Schedule 1 Protected
Ardea intermedia Egret, Yellow-billed Unlisted LC Schedule 1 Protected
(Intermediate)
Ardea melanocephala Heron, Black-headed Unlisted LC Schedule 1 Protected
Ardea purpurea Heron, Purple Unlisted LC Schedule 1 Protected
Ardeola ralloides Heron, Squacco Unlisted LC Schedule 1 Protected
Asio capensis Owl, Marsh Unlisted LC Schedule 1 Protected
Bostrychia hagedash Ibis, Hadeda Unlisted LC Schedule 1 Protected
Bubulcus ibis Egret, Cattle Unlisted LC Schedule 1 Protected
1473 EIA Report 228

8 of 1969
Burhinus capensis Thick-knee, Spotted Unlisted LC Schedule 1 Protected
Buteo buteo Buzzard, Common Unlisted LC Schedule 1 Protected
(Steppe)
Buteo rufofuscus Buzzard, Jackal Unlisted LC Schedule 1 Protected
Charadrius tricollaris Plover, Three-banded Unlisted LC Schedule 1 Protected
Chlidonias hybrida Tern, Whiskered Unlisted LC Schedule 1 Protected
Chlidonias leucopterus Tern, White-winged Unlisted LC Schedule 1 Protected
Chrysococcyx caprius Cuckoo, Diderick Unlisted LC Schedule 1 Protected
Circus macrourus Harrier, Pallid NT NT Schedule 1 Protected
Columba livia Dove, Rock Unlisted LC -
Coracias caudatus Roller, Lilac-breasted Unlisted LC Schedule 1 Protected
Corvus albus Crow, Pied Unlisted LC -
Corythornis cristatus Kingfisher, Malachite Unlisted Unlisted Schedule 1 Protected
Cursorius temminckii Courser, Temminck's Unlisted LC Schedule 1 Protected
Dendrocygna viduata Duck, White-faced Unlisted LC Schedule 1 Protected
Whistling
Egretta ardesiaca Heron, Black Unlisted LC Schedule 1 Protected
Egretta garzetta Egret, Little Unlisted LC Schedule 1 Protected
Elanus caeruleus Kite, Black-shouldered Unlisted LC Schedule 1 Protected
Estrilda astrild Waxbill, Common Unlisted LC Schedule 1 Protected
Euplectes afer Bishop, Yellow- Unlisted LC -
crowned
Euplectes ardens Widowbird, Red- Unlisted LC -
collared
Euplectes orix Bishop, Southern Red Unlisted LC -
Euplectes progne Widowbird, Long- Unlisted LC -
tailed
Falco amurensis Falcon, Amur Unlisted LC Schedule 1 Protected
Falco rupicolus Kestrel, Rock Unlisted LC Schedule 1 Protected
Fulica cristata Coot, Red-knobbed Unlisted LC Schedule 1 Protected
Himantopus himantopus Stilt, Black-winged Unlisted LC Schedule 1 Protected
Hirundo dimidiata Swallow, Pearl- Unlisted LC Schedule 1 Protected
breasted
Lamprotornis bicolor Starling, Pied Unlisted LC -
Lanius collaris Fiscal, Common Unlisted LC Schedule 1 Protected
(Southern)
Lanius minor Shrike, Lesser Grey Unlisted LC Schedule 1 Protected
Lybius torquatus Barbet, Black-collared Unlisted LC Schedule 1 Protected
Melierax canorus Goshawk, Southern Unlisted LC Schedule 1 Protected
Pale Chanting
Merops apiaster Bee-eater, European Unlisted LC Schedule 1 Protected
Microcarbo africanus Cormorant, Reed Unlisted LC Schedule 1 Protected
Mirafra africana Lark, Rufous-naped Unlisted LC Schedule 1 Protected
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8 of 1969
Myrmecocichla Chat, Anteating Unlisted LC Schedule 1 Protected
formicivora
Netta erythrophthalma Pochard, Southern Unlisted LC Schedule 1 Protected
Numida meleagris Guineafowl, Helmeted Unlisted LC Schedule 1/2 Protected
Nycticorax nycticorax Night-Heron, Black- Unlisted LC Schedule 1 Protected
crowned
Oena capensis Dove, Namaqua Unlisted LC Schedule 1 Protected
Oxyura maccoa Duck, Maccoa NT VU Schedule 1 Protected
Passer domesticus Sparrow, House Unlisted LC -
Phoenicopterus roseus Flamingo, Greater NT LC Schedule 1 Protected
Phoeniculus purpureus Wood-hoopoe, Green Unlisted LC Schedule 1 Protected
Platalea alba Spoonbill, African Unlisted LC Schedule 1 Protected
Plectropterus gambensis Goose, Spur-winged Unlisted LC Schedule 1/2 Protected
Plegadis falcinellus Ibis, Glossy Unlisted LC Schedule 1 Protected
Plocepasser mahali Sparrow-weaver, Unlisted LC -
White-browed
Ploceus velatus Masked-weaver, Unlisted LC -
Southern
Podiceps nigricollis Grebe, Black-necked Unlisted LC Schedule 1 Protected
Prinia flavicans Prinia, Black-chested Unlisted LC Schedule 1 Protected
Pternistis swainsonii Spurfowl, Swainson's Unlisted LC Schedule 1/2 Protected
Rhinoptilus africanus Courser, Double- Unlisted LC Schedule 1 Protected
banded
Sagittarius serpentarius Secretarybird VU EN Schedule 1 Protected
Saxicola torquatus Stonechat, African Unlisted LC Schedule 1 Protected
Spatula hottentota Teal, Hottentot Unlisted LC Schedule 1 Protected
Spatula smithii Shoveler, Cape Unlisted LC Schedule 1 Protected
Spilopelia senegalensis Dove, Laughing Unlisted LC -
Sporopipes squamifrons Finch, Scaly-feathered Unlisted LC -
Streptopelia capicola Turtle-dove, Cape Unlisted LC -
Sturnus vulgaris Starling, Common Unlisted LC Schedule 1 Protected
Tachybaptus ruficollis Grebe, Little Unlisted LC Schedule 1 Protected
Telophorus zeylonus Bokmakierie, Unlisted LC Schedule 1 Protected
Bokmakierie
Trachyphonus vaillantii Barbet, Crested Unlisted LC Schedule 1 Protected
Tringa stagnatilis Sandpiper, Marsh Unlisted LC Schedule 1 Protected
Tyto alba Owl, Barn Unlisted LC Schedule 1 Protected
Upupa africana Hoopoe, African Unlisted LC Schedule 1 Protected
Uraeginthus angolensis Waxbill, Blue Unlisted LC Schedule 1 Protected
Urocolius indicus Mousebird, Red-faced Unlisted LC Schedule 1 Protected
Vanellus armatus Lapwing, Blacksmith Unlisted LC Schedule 1 Protected
Vanellus coronatus Lapwing, Crowned Unlisted LC Schedule 1 Protected
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8 of 1969
Vidua macroura Whydah, Pin-tailed Unlisted LC Schedule 1 Protected
MAMMALS
Twenty-two (22) mammal species were observed during the survey of the application area (Table 33) based on
either direct observation or the presence of visual tracks and signs. Three (3) (in red text) of the species recorded
are regarded as SCC. Four (4) mammal species are considered ‘captive’ species as these were only present within
the game farm areas, marked in blue text.
Table 33: Summary of mammal species recorded within the application area.
Species Common Name Regional (SANBI, 2016) IUCN (2021) Free State
Nature
Conservation
Ordinance 8 of
1969
Antidorcas marsupialis Springbok LC LC Schedule 2-
Protected
Aonyx capensis Cape Clawless Otter NT NT -
Atilax paludinosus Water Mongoose LC LC -
Canis mesomelas Black-backed Jackal LC LC -
Chlorocebus pygerythrus Vervet Monkey LC LC -
Connochaetes taurinus Blue Wildebeest LC LC Schedule 2-
Protected
Cryptomys hottentotus Southern African Mole-rat LC LC -
Cynictis penicillata Yellow Mongoose LC LC -
Damaliscus pygargus Blesbok LC LC Schedule 2-
Protected
Genetta genetta Small-spotted Genet LC LC -
Giraffa camelopardalis Giraffe LC VU Schedule 2-
Protected
Herpestes sanguineus Slender Mongoose LC LC -
Hystrix africaeaustralis Cape Porcupine LC LC -
Kobus leche Lechwe Unlisted NT -
Leptailurus serval Serval NT LC -
Lepus saxatilis Scrub Hare LC LC Schedule 2-
Protected
Micaelamys namaquensis Namaqua Rock Mouse LC LC -
Parahyaena brunnea Brown Hyaena NT NT -
Raphicerus campestris Steenbok LC LC Schedule 2-
Protected
Sylvicapra grimmia Common Duiker LC LC Schedule 2-
Protected
Tragelaphus strepsiceros Greater Kudu LC LC Schedule 2-
Protected
Xerus inauris South African Ground Squirrel LC LC -
HERPETOFAUNA
1473 EIA Report 231

9.11.9.3.1 REPTILES
Eleven (11) species of reptiles were recorded in the application area during survey period (Table 34). One SCC,
namely Smaug giganteus (Sungazer/Giant Dragon Lizard) was recorded during the field assessment. However,
there is the possibility of more species being present, as certain reptile species are secretive and require long-
term surveys to ensure capture.
Smaug giganteus (Sungazer/Giant Dragon Lizard) is categorised as VU on both a regional and an international
scale. Additionally, the species is listed on the Convention on International Trade in Endangered Species (CITES)
Appendix II, as well as a Threatened or Protected Species (TOPS). It is endemic to South Africa, where it is found
only in the grasslands of the northern Free State and the southwestern parts of Mpumalanga with an estimated
EOO (km²) of 37 617 (Alexander et al., 2018). The species is considered to be a habitat specialist, that is highly
philopatric (tending to return to or remain near a particular site or area) for burrowing sites. Sungazers/Giant
Dragon Lizards also won’t easily disperse across the landscape to make new burrows should its habitat be
destroyed (Alexander et al., 2018)
Habitat loss due to agriculture is a continuing threat. Large portions of the grassland habitat are underlain by
coal beds of varying quality and extent, and exploitation of coal for fuel has and will result in further habitat loss.
Another substantial threat to the species is illegal collection for the pet trade to an extent that it is one of the
most exported species from South Africa with 1 194 individuals exported between 1985 and 2014 for pet trade
(Parusnath et al, 2017; UNEP-WCMC, 2017).
A collection of burrows was observed during the field survey however it is presumed that there are several
additional burrows. Due to the sensitivity of this species, especially in regard to its illegal collection, no waypoints
will be displayed or provided in this report or the specialist report.
Table 34: Summary of reptile species recorded within the application area.
Species Common Name Regional IUCN Free State Nature

(SANBI, (2021) Conservation Ordinance 8 of
2016) 1969
Crotaphopeltis Red-lipped Snake LC LC -
hotamboeia
Dasypeltis scabra Rhombic Egg-eater LC LC -
Smaug giganteus Sungazer VU VU Schedule 1 Protected
Boaedon capensis Brown House Snake LC LC -
Pseudaspis cana Mole Snake LC LC -
Leptotyphlops scutifrons Peters' Thread Snake LC LC -
Lygodactylus capensis Common Dwarf Gecko LC LC -
Panaspis wahlbergii Wahlberg's Snake- LC LC -
eyed Skink
Trachylepis punctatissima Speckled Rock Skink LC LC -
Rhinotyphlops lalandei Delalande's Beaked LC LC -
Blind Snake
Varanus niloticus Nile Monitor LC LC -
9.11.9.3.2 AMPHIBIANS
Four (4) amphibian species were recorded in the application area (Table 35). One species recorded is a SCCs
(shown in red text).
1473 EIA Report 232

Table 35: Summary of amphibian species recorded within the application area.
Species Common Name Regional IUCN Free State Nature

(SANBI, 2016) (2021) Conservation Ordinance 8 of
1969
Amietia quecketti Common River Frog LC LC -
Cacosternum boettgeri Common Caco LC LC -
Pyxicephalus adspersus Giant Bullfrog NT LC -
Sclerophrys gutturalis Guttural Toad LC LC -
HABITAT ASSESSMENT AND SITE ECOLOGICAL IMPORTANCE

HABITAT ASSESSMENT
The main habitat types identified across the application area were initially identified largely based on aerial
imagery. These main habitat types were refined based on the field coverage and data collected during the survey
and the delineated habitats can be seen in Figure 107 and Figure 108. Emphasis was placed on limiting timed
meander searches along the proposed area within the natural habitats and therefore habitats with a higher
potential of hosting SCC.
Figure 107: Habitats identified within the application area (northern section).
1473 EIA Report 233

Figure 108: Habitats identified within the application area (southern section).
Degraded Habitat
The degraded habitat includes areas that are connected to and play a crucial role regarding the water resource
habitats present. This habitat type is regarded as semi-natural, but disturbed due to fragmentation, grazing by
livestock and also human infringement in areas close to roads.
Generally, this habitat unit has intact ecological functioning attributed to faunal communities found in this
habitat. The current ecological condition of this habitat, regarding the driving forces, are inconsistent due to the
different land uses. Portions of these areas have been disturbed by the historic and current grazing pressure.
Additionally, the presence of some disturbances such as AIP presence or edge effect impacts on floral
communities have resulted in decreased habitat integrity. The condition difference within this habitat depends
on the extent of the disturbance in some areas being more severe, usually related to one being more overgrazed
than the other.
Although the habitat unit is not entirely disturbed, ongoing and historic disturbances have resulted in the plant
community no longer being fully representative of the reference vegetation. However, the habitat indicators
that are known to show ‘unhealthy’ Dry Highveld Grassland such as grassland dominated by karroid shrubs, or
the absence of endangered animal species.
The main ecological characteristics of dry highveld grasslands, which the Vaal Vet Sandy Grassland, is classified
as, (SANBI, 2013):
• Climate; fundamentally different from any other grassland systems due to the significant difference in
climate. This grassland experiences cold (frost) winters, but a defining difference is the low and highly
variable summer rainfall that affects the grassland productivity, due to water being the main factor
affecting growth, and not the duration or temperature of the season;
• Fire; plays a role in maintaining these grasslands, however not as important as grazing. Due to its slow
growing nature, the grassland recovers slowly from fire events;
1473 EIA Report 234

• Grazing, a slow growing sweetveld grassland being able to support animal production for most of the
year, grazing is an important driver in these systems. and this is the most important ecosystem process
that can be managed to maintain biodiversity and productivity in these ecosystems;
• Life-history strategies; due to the environmental conditions, driven primarily by adaptation to drought,
the plants persist mainly through being long-lived, perennial plants replacing themselves through seeds
or vegetative reproduction;
• Encroachment by invasive woody species; due to the factors limiting encroachment (fire, rainfall and
frost) being variable in this grassland, if the biomass is reduced by grazing or decreased fire intensity,
bush encroachment by trees such as Vachellia karoo, or woody karroid shrubs (such as Pentzia and
Felicia species) can occur.
• Geology; The underlying geology is an important determinant of the biodiversity patterners and
processes. Especially dolerite sheets that correlates to high levels of plant species richness and
endemism.
The portions of this remaining habitat unit can thus be regarded as incredibly important, not only within the
local landscape, but also regionally; it acts as a greenland, used for habitat, foraging area and movement
corridors for fauna (including the SCC recorded). The habitat sensitivity of the degraded habitat is regarded as
high/very high, mainly due to the role of this habitat to biodiversity within a very fragmented local landscape,
not to mention the various ecological datasets.
The management and spatial guidelines for the land use of these grasslands that are relevant to this application
area include (SANBI,2013) namely to avoid habitat loss in threatened grassland vegetation types: Threatened
vegetation types such as Vaal-Vet Sandy Grassland are highly fragmented and there should be no further habitat
loss, or ploughing, in these vegetation types without proper impact assessments.
Water resources (Wetlands, rivers and riparian zones)
This habitat unit represents the water resource habitats with the adjacent vegetation that it is connected to. The
riparian habitat unit or riparian zone represents areas associated with the Sand River as well as a small tributary
to the river. Although the stream and associated dams are in a relatively modified poor condition with the
presence of invasive species, bank erosion and overgrazing/trampling adjacent to the stream, the riparian
vegetation serves an important ecological function with high conservation value. Riparian areas have high
conservation value and can be considered the most important part of a watershed for a wide range of values
and resources. They provide important habitat for a large volume of wildlife and often forage for domestic
animals. The vegetation they contain are an important part of the water balance for the hydrological cycle
through evapotranspiration. The wetlands (and riparian zones) habitat unit is considered to be of very high
ecological sensitivity due to the contribution of the various wetland (and riparian) features to faunal migratory
connectivity, ecoservices provision and the unique habitat provided for faunal and floral species. The wetland
habitats have been provided by the wetland specialist, and the accompanying wetland report must be consulted
for the relevance and sensitivity of these systems which have been included within this report.
Even though somewhat disturbed, the ecological integrity, importance, and functioning of these areas play a
crucial role as a water resource system and an important habitat for various fauna and flora, including the SCC
recorded. The preservation of this system is an important aspect to consider for the proposed development,
even more so due to the high sensitivity of the area according to the various ecological datasets. This habitat
needs to be protected and improved due to the role of this habitat as a water resource.
Disturbed Habitat
The disturbed habitat is regarded as areas that has been impacted by edge effects of transformed areas as well
as direct impacts from historic and ongoing overgrazing, dumping and infringement. This area has been
disturbed and modified from its natural state, it represents habitat that is more disturbed than the ‘degraded
habitat’ area, but not as disturbed as the ‘transformed’ area. This habitat is regarded as areas that have been
impacted more by historic overgrazing, mismanagement, and harmful land use (historic agriculture). These
habitats aren’t entirely transformed but in a constant disturbed state as they can’t recover to a more natural
1473 EIA Report 235

state due to ongoing disturbances and impacts it receives from grazing and mismanagement. These areas are
considered to have a medium sensitivity due to the fact that the areas may be used as a movement corridor and
in many cases form a barrier between the more degraded bushveld and the transformed areas.
Transformed Habitat
The transformed habitat unit, which is the largest of the habitat units, represents areas where vegetation cover
has been significantly impacted by current and historical mining and agricultural activities as well as through
infrastructure associated with the mining/agricultural activities. This habitat unit has no conservation value from
an ecological perspective.
SITE ECOLOGICAL IMPORTANCE
The biodiversity theme sensitivity as indicated in the DFFE screening report was derived to be Very High. This
was based on the CBA 1, ESA 1 & 2 areas as well as the NPAES area. The animal sensitivity was rated as Medium,
while the plant sensitivity was rated as Low.
The sensitivity scores identified during the field survey for each terrestrial habitat are mapped. The location and
extent of these habitats are illustrated in Figure 109 and Figure 110. All habitats within the assessment area of
the proposed project were allocated a sensitivity category (Table 36). The sensitivities of the habitat types
delineated are illustrated in ‘Very High/High Sensitivity’ areas are due to the following, and the guidelines can
be seen in Table 37:
• All habitats within the assessment area were observed to be utilised by threatened (local classification)
species during the field survey, these species comprised of:
o One (1) flora species;
o Four (4) avifaunal species;
o Three (3) mammal species;
o One (1) reptile species; and
o One (1) amphibian species.
• Unique, important (EN Ecosystem CBA1/ESA 1& 2) and very low resilience habitats (water resource);
and
• Habitat that is regarded as crucial to the survival of a threatened species.
Table 36: Summary of habitat types delineated within the field assessment area of the application area.
Conservation Functional Biodiversity Receptor Site Ecological

Habitat
Importance Integrity Importance Resilience Importance
Degraded
(Sensitive High High Medium Low Very High
Species)
Degraded High Medium Medium Low High
Water
High Medium Medium Very Low High
Resource
Disturbed Medium Medium Medium Medium Medium
Transformed Very Low Very Low Very Low Medium Very Low
Table 37: Guidelines for interpreting Site Ecological Importance in the context of the proposed development
activities.
Site Ecological
Interpretation in relation to development activities
Importance
Avoidance mitigation – no destructive development activities should be considered. Offset
Very High
mitigation not acceptable/not possible (i.e., last remaining populations of species, last
1473 EIA Report 236

Site Ecological
Interpretation in relation to development activities
Importance
remaining good condition patches of ecosystems/unique species assemblages). Destructive
impacts for species/ecosystems where persistence target remains.
Avoidance mitigation wherever possible. Minimisation mitigation – changes to project
infrastructure design to limit the amount of habitat impacted, limited development
High
activities of low impact acceptable. Offset mitigation may be required for high impact
activities.
Minimisation and restoration mitigation – development activities of medium impact
Medium
acceptable followed by appropriate restoration activities.
Minimisation mitigation – development activities of medium to high impact acceptable and
Very Low
restoration activities may not be required.
Figure 109: The study area superimposed over the sensitivities in the northern section of the study area.
1473 EIA Report 237

Figure 110: The study area superimposed over the sensitivities in the southern section of the study area.
9.12 AQUATIC AND WETLANDS

The aquatic and wetland environment has been assessed by The Biodiversity Company (TBC) and the specialist
report is included in Appendix 4. The baseline aquatic and wetland findings are presented in the subsections
below.
WETLAND DELINEATION AND DESCRIPTION

During the site visit four different wetland types were delineated in accordance with the DWAF (2005) guidelines
(Figure 111). The four different types were classified as being:
1. Channelled valley bottoms;
2. Unchannelled valley bottoms;
3. Hillslope seeps; and
4. Depression wetlands.
A description of these wetland types is included in the specialist report.
1473 EIA Report 238

Figure 111: Delineation of wetlands within the study area.
ECOLOGICAL FUNCTIONAL ASSESSMENT

The average ecosystem services scores for the assessed wetlands are presented in Figure 112. The ecosystem
services provided by the wetland units identified on site were assessed and rated using the WET-EcoServices
method (Kotze et al., 2008). Due to the high number of wetlands identified within the study area the wetlands
have not been classified into HGM units. The wetland ecosystem services scores range from “Moderately High”
to “Moderately Low”. Ecosystem services contributing to these scores include flood attenuation, streamflow
regulation, sediment trapping, phosphate assimilation, nitrate assimilation, toxicant assimilation, erosion
control, biodiversity maintenance and tourism and recreation.
The wetlands that scored “Moderately High” ecosystem services were mostly the channelled valley bottoms
where water drains into from the catchment areas. The catchments of these systems are predominantly used
for agricultural fields were pesticides and herbicides are used to help maintain crop yields These pesticides and
herbicides are taken out of the watercourses through the wetlands to help provide cleaner drinking water for
the people downstream. The channels also help with streamflow regulation to prevent erosion within the
wetlands as well as to regulate flood attenuation. The channelled valley bottoms also have water throughout
the year providing important habitat and resources all year round.
Most wetlands scored “Intermediate” ecosystem services scores within the application area. The reason for this
score is since the areas around the wetlands are predominately used for agriculture which will release pesticide
and herbicides into the wetlands but toxicants from anthropogenic activities are minimal. The wetlands scored
“Intermediate” instead of “Moderately High” since the wetland have less vegetation cover and is also more
temporarily wet. The lack of water during the dry season as well as the lack of vegetation cover take away habitat
for species as well as resources for humans. The wetlands do however play a vital role in sediment trapping,
streamflow regulation as well as flood attenuation and was thus score higher than some of the wetlands.
1473 EIA Report 239

The wetlands that scored the lowest ecosystem services score in this application area of “Moderately Low” were
predominantly depression and seep wetlands. Seeps and Depression wetlands do not play a major role in
streamflow regulation, flood attenuation and sediment trapping and thus scores lower ecosystem services in
general. During the site visit this was evident as well. The depression wetland situated inside the crop fields have
little to no hydrophyte vegetation which limits their ability to accumulate toxicants out the water. The lack of
vegetation also hinders the wetlands’ ability to provide habitat for charismatic species and limits the available
resources for human use.
Figure 112: Average ecosystem service scores for the delineated wetland systems.
THE ECOLOGICAL HEALTH ASSESSMENT

The Present Ecological State (PES) for the assessed wetlands is presented in Figure 113. The delineated wetland
systems have been scored overall PES ratings ranging of “Moderately Modified” (class C) to “Seriously Modified”
(Class E). The wetlands were scored “Seriously Modified” due to multiple agricultural activities inside the
wetlands. Many of the wetlands have been stripped of all vegetation and planting have taken place inside the
wetland. The agricultural activities in the catchment areas of the wetlands which increased the overland flow of
water and increase the possibility of flooding and erosion taking place. Multiple gravel roads, pipes and fences
transverse through some of the wetlands modifying the water movement inside the wetlands.
The wetlands that scored “Moderately Modified” PES scores were located within the more natural areas of the
study area. The wetlands are not subjected to agricultural activities and is thus in better ecological state.
Although no agricultural activities take place inside the wetlands catchment the wetlands are still modified by
human impacts. The largest modification will be through overgrazing by wildlife on the game farms. There are
also roads and fences crossing through the wetlands and some anthropogenic activities taking place inside the
wetlands.
1473 EIA Report 240

Figure 113: Overall present ecological state of delineated wetlands.
BUFFER REQUIREMENTS
The “Preliminary Guideline for the Determination of Buffer Zones for Rivers, Wetlands and Estuaries”
(Macfarlane et al. 2014) was used to determine the appropriate buffer zone for the proposed activities. After
taking into consideration the different activities the buffer size for the delineated wetlands were calculated as
35 m (Figure 114).
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Figure 114: Extent of recommended buffer zones.
9.13 AIR QUALITY AND HEALTH

An air quality study has been undertaken by Airshed Planning Professionals and the specialist report is included
in Appendix 4. The air quality findings are presented in the subsections below.
SURFACE WIND FIELD

The wind roses comprise 16 spokes, which represent the directions from which winds blew during a specific
period. The colours used in the wind roses below, reflect the different categories of wind speeds; the yellow
area, for example, representing winds in between 4 and 5 m/s. The dotted circles provide information regarding
the frequency of occurrence of wind speed and direction categories. The frequency with which calms occurred,
i.e. periods during which the wind speed was below 1 m/s are also indicated. The period wind field and diurnal
variability in the wind field are shown in Figure 115, while the seasonal variations are shown in Figure 116.
During the 2019 to 2021 period, the wind field was dominated by winds from the north-northeast and northeast,
followed by northerly and easterly winds. During the day (6AM – 6PM), the prevailing wind field is from the
north to northeast and the west, with less frequent winds from the north-westerly sector, the easterly sector
and the south-west. During the night, the wind field shifts to the easterly sector (north-northeast to east-
southeast), with very little flow from the westerly sector. Long-term air quality impacts are therefore expected
to be the most significant to the south and southwest of the application area. The strongest winds (more than 6
m/s) were also from the north and northeast and occurred mostly during the day, with 15 m/s the highest wind
speed recorded. The average wind speed over the three years is 3.7 m/s, with calm conditions occurring for 3.5%
of the time (Figure 115).
Seasonally, the wind flow pattern conforms to the period average wind flow pattern. The seasonal wind field
shows little seasonal differences in the wind fields. During summer and spring, the dominant winds are from the
north-northeast to east, with more frequent westerly winds during spring. Autumn reflects dominant north-
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easterly and easterly winds, with a similar wind field during winter, but with more frequent north-north-easterly
and east-south-easterly winds (Figure 116).
Period
Calms: 3.50%
Daytime Night-time
Calms: 2.54% Calms: 4.65%
Figure 115: Period, day- and night-time wind roses (SAWS Welkom Data, 2019 to 2021).

Summer Autumn
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Winter Spring
Figure 116: Seasonal wind roses (SAWS Welkom Data, 2019 to 2021).
AMBIENT AIR QUALITY WITHIN THE REGION

SOURCES OF POLLUTION IN THE REGION
Neighbouring land-use in the surrounding of the proposed project comprises predominantly of agriculture
activities. These land-uses contribute to baseline pollutant concentrations via fugitive and process emissions,
vehicle tailpipe emissions, household fuel combustion, biomass burning and windblown dust from exposed
areas.
9.13.2.1.1 AGRICULTURE
Agriculture is a major land-use activity within and beyond the Project boundary. These activities include crop
farming such as maize, and livestock farming. Particulate matter is the main pollutant of concern from
agricultural activities as particulate emissions are derived from windblown dust, burning crop residue, and dust
entrainment because of vehicles travelling along dirt roads. In addition, pollen grains, mould spores and plant
and insect parts from agricultural activities all contribute to the particulate load. Should chemicals be used for
crop spraying, they would typically result in odiferous emissions. Crop residue burning is also an additional
source of particulate emissions and other toxins. Due to the small scale of farming activities these are regarded
to have an insignificant cumulative impact.
Livestock farms, especially cattle, are also significant sources of fugitive dust especially when feedlots are used
and the cattle trample in confined areas. Pollutants associated with dairy production for instance include
ammonia (NH3), hydrogen sulphides (H2S), methane (CH4), carbon dioxide (CO2), oxides of nitrogen (NOx) and
odour related trace gasses. According to the US-EPA, cattle emit methane through a digestive process that is
unique to ruminant animals called enteric fermentation. The calf-cow sector of the beef industry was found to
be the largest emitter of methane emissions. Where animals are densely confined the main pollutants of concern
include dust from the animal movements, their feed and their manure, ammonia (NH 3) from the animal urine
and manure, and hydrogen sulphides (H2S) from manure pits.
Organic dust includes dandruff, dried manure, urine, feed, mould, fungi, bacteria and endotoxins (produced by
bacteria, and viruses). Inorganic dust is composed of numerous aerosols from building, materials and the
environment. Since the dust is biological it may react with the defence system of the respiratory tract. Odours
and VOCs associated with animal manure is also a concern when cattle are kept in feedlots. The main impact
from methane is on the dietary energy due to the reduction of carbon from the rumen. Dust and gasses levels
are higher in winter or whenever animals are fed, handled or moved.
9.13.2.1.2 MINING SOURCES
Particulates represent the main pollutant of concern at mining operations. The amount of dust emitted by these
activities depends on the physical characteristics of the material, the way in which the material is handled and
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the weather conditions (e.g. high wind speeds, rainfall, etc.). Mining of gold, as well as ore extraction and
processing plants are all commercial activities situated in the region of the Project.
9.13.2.1.3 DOMESTIC FUEL COMBUSTION
Domestic households are known to have the potential to be one the most significant sources that contribute to
poor air quality within residential areas. Individual households are low volume emitters, but their cumulative
impact is significant. It is likely that households within the local communities or settlements utilize coal, paraffin
and/or wood for cooking and/or space heating (mainly during winter) purposes. Pollutants arising from the
combustion of wood include respirable particulates, CO and SO2 with trace amounts of polycyclic aromatic
hydrocarbons (PAHs), in particular benzo(a)pyrene and formaldehyde. Particulate emissions from wood burning
have been found to contain about 50 % elemental carbon and about 50 % condensed hydrocarbons.
Coal is relatively inexpensive in the region and is easily accessible due to the proximity of the region to coal
mines and the well-developed coal merchant industry. Coal burning emits a large amount of gaseous and
particulate pollutants including SO2, heavy metals, PM including heavy metals and inorganic ash, CO, PAHs
(recognized carcinogens), NO2 and various toxins. The main pollutants emitted from the combustion of paraffin
are NO2, particulates, CO and PAHs.
9.13.2.1.4 BIOMASS BURNING
Biomass burning includes the burning of evergreen and deciduous forests, woodlands, grasslands, and
agricultural lands. Within the project vicinity, crop-residue burning and wildfires (locally known as veld fires)
may represent significant sources of combustion-related emissions. The frequency of wildfires in the grasslands
varies between annual and triennial.
Biomass burning is an incomplete combustion process (Cachier, 1992), with carbon monoxide, methane and
nitrogen dioxide gases being emitted. Approximately 40 % of the nitrogen in biomass is emitted as nitrogen, 10%
is left in the ashes, and it may be assumed that 20 % of the nitrogen is emitted as higher molecular weight
nitrogen compounds (Held, et al., 1996). The visibility of the smoke plumes is attributed to the aerosol
(particulate matter) content. In addition to the impact of biomass burning within the vicinity of the Project
activity, long-range transported emissions from this source can be expected to impact on the air quality between
the months of August to October. It is impossible to control this source of atmospheric pollution loading;
however, it should be noted as part of the background or baseline condition before considering the impacts of
other local sources.
9.13.2.1.5 FUGITIVE DUST SOURCES
These sources are termed fugitive because they are not discharged to the atmosphere in a confined flow stream.
Sources of fugitive dust identified in the study area include paved and unpaved roads and wind erosion of
sparsely vegetated surfaces.
9.13.2.1.6 UNPAVED AND PAVED ROADS
Emissions from unpaved roads constitute a major source of emissions to the atmosphere in the South African
context. When a vehicle travels on an unpaved road the force of the wheels on the road surface causes
pulverization of surface material. Particles are lifted and dropped from the rolling wheels, and the road surface
is exposed to strong turbulent air shear with the surface. The turbulent wake behind the vehicle continues to
act on the road surface after the vehicle has passed. Dust emissions from unpaved roads vary in relation to the
vehicle traffic and the silt loading on the roads. Unpaved roads in the region are mainly haul and access roads.
Emissions from paved roads are significantly less than those originating from unpaved roads, however they do
contribute to the particulate load of the atmosphere. Particulate emissions occur whenever vehicles travel over
a paved surface. The fugitive dust emissions are due to the re-suspension of loose material on the road surface.
Paved roads in the region include the R710, M4, R708 and R30.
9.13.2.1.7 WIND EROSION OF OPEN AREAS
Windblown dust generates from natural and anthropogenic sources. For wind erosion to occur, the wind speed
needs to exceed a certain threshold, called the threshold velocity. This relates to gravity and the inter-particle
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cohesion that resists removal. Surface properties such as soil texture, soil moisture and vegetation cover
influence the removal potential. Conversely, the friction velocity or wind shear at the surface is related to
atmospheric flow conditions and surface aerodynamic properties. Thus, for particles to become airborne, its
erosion potential has to be restored; that is, the wind shear at the surface must exceed the gravitational and
cohesive forces acting upon them, called the threshold friction velocity. Every time a surface is disturbed, its
erosion potential is restored (US EPA, 2004). Erodible surfaces may occur as a result of agriculture and/or grazing
activities.
9.13.2.1.8 VEHICLE TAILPIPE EMISSIONS
Emissions resulting from motor vehicles can be grouped into primary and secondary pollutants. While primary
pollutants are emitted directly into the atmosphere, secondary pollutants form in the atmosphere as a result of
chemical reactions. Significant primary pollutants emitted combustion engines include carbon dioxide (CO 2),
carbon (C), sulfur dioxide (SO2), oxides of nitrogen (mainly NO), particulates and lead. Secondary pollutants
include NO2, photochemical oxidants such as ozone, sulfur acid, sulphates, nitric acid, and nitrate aerosols
(particulate matter). Vehicle type (i.e. model-year, fuel delivery system), fuel (i.e. oxygen content), operating
(i.e. vehicle speed, load) and environmental parameters (i.e. altitude, humidity) influence vehicle emission rates.
Transport in the vicinity of the Project is via trucks and private vehicles along the R710, M4, R708 and R30 roads
(which are the main sources of vehicle tailpipe emissions), as well as vehicles and machinery travelling on
unpaved and private roads.
AIR QUALITY SAMPLING RESULTS
Airshed was appointed to sample identified potential pollutants of concern, as stipulated in the Cluster 1
Environmental Management Programme (EMPr), around the Tetra4 Virginia Compression Plant. The passive
sampling campaign used Radiello® passive diffusive samplers at three (3) sites around the property and at an
upwind background site located near a residential receptor. Sampling and assessment of ambient
concentrations include sulfur dioxide (SO2); nitrogen dioxide (NO2); hydrogen fluoride (HF) and, total volatile
organic compounds (TVOCs).
Passive sampling was conducted at two (2) locations near the boundary of the facility and at a background
location close to a nearby residential receptor. Sampling site locations are shown in Figure 117, with the
coordinates, elevation and site classification detailed in Table 38.
The aim of the passive sampling campaign was to quantify ambient air pollutant concentrations which could
present odour and health issues for Tetra4 personnel and the neighbouring communities. Two 14-day campaigns
were conducted at the Tetra4 Virginia Compression Plant, one in summer and one in winter since 2019.
Pollutants assessed included SO2, NO2, and VOCs.
Table 38: Sampling site coordinates, elevation, and classification.
Site ID Site location Latitude Longitude Elevation (m) Classification
TET1 HDR1 Wellhead -28.12576 26.718934 1 299 Boundary
TET2 HDR1 Compressor -28.12701 26.719149 1 299 Boundary
TET3 Background site -28.12011 26.720198 1 296 Residential
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Figure 117: Tetra4 passive sampling locations.
All pollutant concentrations, including the suite of VOC compounds detected, were screened against NAAQS,
chronic inhalation reference concentrations, and inhalation unit risk factors (for increased life-time cancer risk)
published by international agencies. Extrapolated results from the seven (7) sampling campaigns indicate:
• Low background SO2 concentrations, falling well within the NAAQSs.
• Background NO2 concentrations indicate fairly high short-term (hourly) levels but still below the NAAQ
limit and well below the annual limit.
• Sampled concentrations of HF are very low.
• Chronic exposure to total VOCs (TVOCs) concentration was less than 6 μg/m3 at all sites, and therefore
lower than the 100 μg/m3 health-effect screening level.
9.14 CLIMATE CHANGE

PHYSICAL RISKS OF CLIMATE CHANGE ON THE REGION
In 2017 the South African Weather Service (SAWS) published an updated Climate Change Reference Atlas (CCRA)
based on Global Climate Change Models (GCMs) projections (SAWS, 2017). It must be noted that as with all
atmospheric models there is the possibility of inaccuracies in the results as a result of the model’s physics and
accuracy of input data; for this reason, an ensemble of models’ projections is used to determine the potential
change in near-surface temperatures and rainfall depicted in the CCRA. The projections are for 30-year periods
described as the near future (2036 to 2065) and the far future (2066 to 2095). Projected changes are defined
relative to a historical 30-year period (1976 to 2005). The Rossby Centre regional model (RCA4) was used in the
predictions for the CCRA which included the input of nine GCMs results. The RCA4 model was used to improve
the spatial resolution to 0.44° x 0.44°- the finest resolution GCMs in the ensemble were run at resolutions of
1.4° x 1.4° and 1.8° x 1.2°.
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Two trajectories are included based on the four Representative Concentration Pathways (RCPs) discussed in the
IPCC’s fifth assessment report (AR5) (IPCC, 2013). RCPs are defined by their influence on atmospheric radiative
forcing in the year 2100. RCP4.5 represents an addition to the radiation budget of 4.5 W/m 2 as a result of an
increase in GHGs. The two RCPs selected were RCP4.5 representing the medium-to-low pathway and RCP8.5
representing the high pathway. RCP4.5 is based on a CO2 concentration of 560 ppm and RCP8.5 on 950 ppm by
2100. RCP4.5 is based on the expectation that current interventions will reduce GHG emissions and that it will
be sustained (after 2100 the concentration is expected to stabilise or even decrease). RCP8.5 is based on no
interventions implemented to reduce GHG emissions (then after 2100 the concentration is expected to continue
to increase).
RCP4.5 TRAJECTORY
Based on the median, for the region in which the proposed facility and communities are situated, the annual
average near surface temperatures (2 m above ground) are expected to increase by between 1.5°C and 2.0°C
for the near future and between 2.0°C and 2.5°C for the far future. The seasonal average temperatures are
expected to increase for all seasons, in the same order as the annual average increases, with slightly larger
temperature increases in autumn (March to May) and larger increases in spring (September to November). The
total annual rainfall is expected to increase by between 5 mm and 10 mm for the near future and decrease by
up to 20 mm in the far future. Seasonal rainfall is expected to increase in summer (December to February) up to
30mm in the near- and far future, while other seasons are likely to show decreases between 5 and 10 mm.
RCP8.5 TRAJECTORY
Based on the median, the region in which the proposed facility and communities are situated, the annual average
near surface temperatures (2 m above ground) are expected to increase by between 2.0°C and 2.5°C for the
near future and between 5.0°C and 5.5°C for the far future. The seasonal average temperatures are expected to
increase for all seasons in similar ranges to the annual average temperature, with higher increases in spring,
summer, and autumn. The total annual rainfall change is likely to increase by between 20 and 30 mm, while it is
more uncertain for the far future with potential decrease up to 5 mm. Seasonal rainfall changes could see an
increase of 5 mm in spring and summer in the near future with decreased up to 10 mm in autumn and winter.
In the far future, the seasonal the rainfall changes are similar to the near future, except in summer where
increased rainfall could be up to 50 mm.
WATER STRESS AND EXTREME EVENTS

South Africa is known to be a water stressed country (Kusangaya, Shekede, & Mbengo, 2017), but
Welkom/Virginia falls within a low water- stress and depletion zone. It falls in a Low-Medium interannual
variability but with a Medium-High seasonal variability, leading to a Medium-High drought risk. Climate change,
through elevated temperatures, is likely to increase evaporation rates and decrease water volumes available for
dryland and irrigated agriculture (Davis-Reddy & Vincent, 2017). Commercial agriculture (crop and livestock
farming) is the predominant agricultural land-use in the vicinity of Welkom and Virginia.
Extreme weather events affecting southern Africa, including heat waves, flooding due to intensified rainfall due
to large storms and drought, have been shown to increase in number since 1980 (Davis-Reddy & Vincent, 2017).
Projections indicate (Davis-Reddy & Vincent, 2017):
• With high confidence, that heat wave and warm spell duration are likely to increase while cold extremes
are likely to decrease, where up to 80 days above 35°C are projected by the end of the century under
the RCP4.5 scenario;
• With medium confidence, that droughts are likely to intensify due to reduced rainfall and/or an increase
in evapotranspiration; and
• With low confidence, that heavy rainfall events (more than 20 mm per 24 hours) will increase.
1473 EIA Report 248

SCOPE 1 GHG EMISSION SOURCES
CLEARING AND REHABILITATION – CARBON SEQUESTRATION AND CARBON SINK
Accounting for the uptake of carbon by plants, soils and water is referred to as carbon sequestration and these
sources are commonly referred to as carbon sinks. Quantifying the rate of carbon sequestration is however not
a trivial task requiring detailed information on the geographical location, climate (specifically temperature and
humidity) and species dominance (Ravin & Raine, 2007).
Photosynthesis is the main sequestration process in forests and in soils. Carbon is absorbed as fixed carbon into
the roots, trunk, branches, and leaves and during the shedding of leaves, but is emitted – although at a reduced
percentage – from foliage and when biomass decays. Several factors also determine the amount of carbon
absorbed by trees such as species, size, and age. Mature trees, for example, will absorb more carbon than
saplings (Ravin & Raine, 2007).
Aspects required to calculate the carbon stack change in the pool (in tons of carbon per year) include the climate,
the type of forest or vegetation removed and the type to be re-introduced, and management measures. Soil
type also has different absorption and release ratios that need to be included. “Decomposition of soil organic
matter in drained inland grassland” was used to the carbon losses from the cleared areas. It should be noted
that carbon losses apply to the replacement of vegetation with built infrastructure, except where temporary
clearing activities could have long-term impacts on water resources, including rivers, aquifers, streams, and
wetlands, or water infrastructure (for example dams and storm water systems) (Government Gazette No. 44761,
Notice 559, 25 June 2021), where in this case, vegetation is likely to recover over the pipeline areas.
The areas to be cleared were accounted for as indicated in Table 39.
Table 39: Tetra4 Cluster 2 land clearance during construction.
Construction Description of Area Area (m2) (unit No of units Total area (m2)
Activity area)
Land Clearance Road construction 5 000 1 5 000
Pipeline 2 500 139 346 530

construction (a)
Well construction 900 300 270 000
Booster station 3 600 30 108 000

construction
Compressor station 3 600 3 10 800

construction
Plant construction 93 979 1 93 979
Area (m2) 834 309
Area (ha) 83.43
CONSTRUCTION FUEL COMBUSTION

There will be an initial carbon sink loss due to the vegetation removal for the new and expansion Cluster 2 areas.
GHG will also be emitted through operating diesel-powered mobile and stationary equipment, as listed in Table
40.
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Table 40: Tetra4 Cluster 2 construction fuel combustion.
Mobile Diesel Total kWh Stationary Equipment Total kWh

Equipment
Plant 11 799 841 Natural gas generator 210 287
Pipeline 854 684
Wells 1 275 986
Booster Stations 1 275 986
Compressor Stations 1 275 986
Drilling 862 682
OPERATIONS
The main sources of GHG due to the proposed operations are the mobile (trucking) and stationary equipment
(generators) (Table 41), and emissions from the gas processing (fugitives, flaring and raw CO2 venting) calculated
in Gg per 106m3 raw gas feed (Table 42) and emissions from transmission and storage (calculated in Gg/year/km
and Gg/year/m³ respectively (Table 43).
Table 41: Tetra4 Cluster 2 operational phase fuel combustion per year.
Road transportation Total GJ Stationary Equipment Total kWh

(diesel)
Trucking 7 350 Natural gas generator 36 842 352
Table 42: Tetra4 Cluster 2 gas processing during an operational year.
Gas processed Volume (103 m3)

Raw gas processed 203 786.67
Table 43: Tetra4 Cluster 2 transmission (pipeline fugitives and venting) and storage during an operational year.
Gas Length (km) Storage per Volume Product (tpa) Density

transmission year (m3/year) (kg/m3)
Pipeline length 120 Product 232 558.14 100 000 430

The South African CO2eq emission factors (kg/tonne of fuel consumed) were used (DEA, 2017), with different
emission factors for the fuel, and mobile and stationary sources.
DECOMMISSIONING
As operations progress, the previously cleared areas that form part of the project will be rehabilitated resulting
in a carbon sink gain. Even assuming rehabilitation uses the same indigenous vegetation, the carbon balance will
not be completely restored. There may also be potential soil degradation due to stockpiling. However, there is
insufficient data at this point to determine the decommissioning GHG emissions. This is likely to be equivalent
or less than the construction phase, with the reestablishment of a carbon sink in the revegetation of the site.
SCOPE 2 GHG EMISSION SOURCES

Scope 2 GHG emissions apply to consumption of purchased electricity, heat, or steam. Tetra 4 Cluster 2 will make
use of Eskom electricity supply for some operations as listed in Table 44.
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Table 44: Tetra4 Cluster 2 ESKOM electricity supply during construction and operations.
Project phase Activity MW No of hours/ year Total MWh
Construction Gas gathering - - -
Plant 0.16 5 278 844
Operations Gas gathering 9.72 8 322 80 890
Plant 23.06 8 322 191 905
SUMMARY OF SCOPE 1 AND SCOPE 2 GHG EMISSIONS

A summary of the calculated GHG emissions for the construction and operational phases is provided in Table 45.
Table 45: Tetra4 Cluster 2 Scope 1 and 2 GHG emission summary.
Emission summary
CO2 (as CH4 (as N2O (as Total CO2-e

Construction Activities
tCO2-e) tCO2-e) tCO2-e) (tonnes/year)
Land clearance 509 509
Off-road mobile equipment 4 627 6 529 5 162
Generators 42 0.09 0.02 43

Total Scope 1
Emission
Well drilling 10 716 10 716
Well testing 14 517 14 517
Well servicing 1 534 1 534
Land clearance, heavy construction,

Total Scope 1
generators, well drilling, well testing 32 479 32 479
Emissions
and well servicing
Total Scope 2
Electricity bought from Eskom 861 861
Emissions
Total emissions (Construction) 33 341
CO2 (as CH4 (as N2O (as Total CO2-e

Operations Activities
tCO2-e) tCO2-e) tCO2-e) (tonnes/year)
Scope 1
Road transportation 19 858 19 858
Emissions
Generators 7 441 15 4 7 460
Gas processing (fugitives) 65 4 828 4 893
Gas processing (flaring) 367 6 2 374
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Gas processing (CO2 venting) 8 151 8 151
Gas storage 12 12
Gas transmission (pipeline fugitives) 2 6 900 6 902
Gas transmission (pipeline venting) 1 2 760 2 761
Road transportation, gas processing,

Total Scope 1
transmission and storage, 50 411 50 411
Emission
generators
Total Scope 2
Electricity bought from ESKOM 278 251 278 251
Emission
Total emissions (Operations) 328 662
SCOPE 3 GHG EMISSIONS

Scope 3 GHG emissions are listed in Table 46.
Table 46: Tetra4 Cluster 2 GHG Scope 3 emission summary.
Total CO2-e
Scope 3 Sector Activities
(tonnes/year)
Category 4 – Upstream transportation

6 498
and distribution
Category 6 – Business travel 26

Total Scope 3 emissions –
Transportation
Category 7 – Employee commuting 2 297
Category 9 – Downstream transportation

17 962
and distribution
Total Scope 3 emissions – Products Category 1 – Purchased goods and

147 442
used services
Total Scope 3 emissions – Use of

Category 11 – Use of sold products 398 391
products
Total Scope 3 emissions – Other

Category 5 – Generated in operations 14 677
sources
Total emissions 587 293
The main source of scope 3 emissions would be the end use of the LNG. As LNG will be replacing other fuels
already in use, there will be a reduction in indirect GHG emissions as shown in Table 47. By using LNG, indirect
GHG emissions would be reduced by 85 960 tons per annum (tpa)
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Table 47: Tetra4 Cluster 2 GHG scope 3 use of sold products to replace other fuels currently in use.
Scope 3 sector Activities Total CO2-e (tonnes/year)

products currently (diesel)

products currently (LPG)

products currently (HFO)

products currently (Total)

products in future
Total emissions reduction 85 960
THE PROJECT’S GHG EMISSIONS IMPACT

IMPACT ON THE NATIONAL INVENTORY
The operational phase of Tetra4 Cluster 2 will likely result in an increase in Scope 1 & 2 emissions. The annual
operational CO2-e emissions from the Tetra4 Cluster 2 operations would contribute approximately 0.08% to the
South African “energy” sector total (410.64 million metric tonnes CO2-e, excluding FOLU) and represent a
contribution of 0.064% to the National GHG inventory total (512.66 million metric tonnes CO 2-e, excluding
FOLU), based on the published 2017 National GHG Inventory (DFFE, 2021). The annual CO 2-e emissions from the
construction phase would contribute approximately 0.008% to the South African “energy” sector total and
represents a contribution of 0.007% to the National GHG inventory total (DFFE, 2021).
ALIGNMENT WITH NATIONAL POLICY
Regulations pertaining to GHG reporting using the NAEIS were published in 2017 (Republic of South Africa, 2017)
(as amended by GN R994, 11 September 2020) where mandatory reporting guidelines focus on reporting of
Scope 1 emissions only. The DFFE is working together with local sectors to develop country specific emissions
factors in certain areas; however, in the interim the IPCC default emission figures may be used to populate the
SAAQIS GHG emission factor database. With the operational Scope 1 CO2-e emissions below 100 000 t/a, Tetra4
does not have to report on SAGERS, calculate its Carbon Tax nor compile a pollution prevention plan (PPP).
PHYSICAL RISKS OF CLIMATE CHANGE ON THE PROJECT’S CONSTRUCTION AND OPERATIONS
9.14.7.3.1 TEMPERATURE
With the increase in temperature, including heat waves, there is the likelihood of an increase in discomfort,
possibility of heat related illness (such as heat exhaustion, heat cramps, and heat stroke). Both these have the
potential to negatively affect staff process performance and productivity.
From a process point of view, elevated ambient temperatures (up to 45°C) may slightly reduce the fuel
requirements needed to meet the generating capacity required. However, water use as a dust control measure
during construction, may increase.
9.14.7.3.2 RAINFALL, WATER STRESS, AND EXTREME EVENTS
Rainfall decreases in autumn, winter and spring could result in constrained water supply outside of summer
months. During drought conditions water supply could decline and intended use of reclaimed water and
boreholes/wellpoints should be investigated to secure long-term supplies.
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The impact of intense rainfall events on the LNG/LHe Plant cannot be ruled out, where the frequency of intense
rainfall events could increase from the long-term baseline. These events could affect production capacity during
intense rainfall (unless fully protected from rain and wind), flooding affecting site access, safe operation of
equipment, delivery of fuel; collection of compressed gas product, as well as physical damage to infrastructure
during high wind speed events associated with intense storms.
POTENTIAL EFFECT OF CLIMATE CHANGE ON THE COMMUNITY
9.14.7.4.1 TEMPERATURE
With the increase in temperature, including heat waves, there is the likelihood of an increase in discomfort and
possibility of heat related illness (such as heat exhaustion, heat cramps, and heat stroke). There is also the
possibility of increased evaporation which in conjunction with the decrease in rainfall can result in water
shortage. This does not only negatively affect the community’s water supply but can reduce the crop yields and
affect livestock resulting in compromised food security.
9.14.7.4.2 RAINFALL, WATER STRESS, AND EXTREME EVENTS
As discussed above the decrease in rainfall can result in the following effects:
• Reduced water supply of reduced water quality; and,
• A negative impact on food security.
The impact of intense rainfall events on the local communities cannot be ruled out, where the frequency of
these event could increase from the long-term baseline. These events could affect road access within the area
due to flooding, and physical damage to public and private infrastructure through flooding and high wind speeds.
PROJECT ADAPTATION AND MITIGATION MEASURES

Climate change management includes both mitigation and adaptation. The main aim of mitigation is to stabilise
or reduce GHG concentrations as a result of anthropogenic activities. This is achievable by lessening sources
(emissions) and/or enhancing sinks through human intervention. Mitigation measures are typically the focus of
the energy, transport, and industry sectors (Thambiran & Naidoo, 2017). Adaptation measures focus on
minimising the impact of climate change, especially on vulnerable communities and sectors. Inclusion of the
climate change adaptation in business strategic implementation plans is one of the outcomes defined in the
Draft National Climate Change Adaptation Strategy (Government Gazette No.42466:644, May 2019).
Additional support infrastructure can reduce the climate change impact on the staff and project, for example
improving thermal and electrical efficiency of buildings to reduce electricity consumption, ensuring adequate
water supply for staff and reducing on-site water usage as much as possible. A community development program
could be initiated to assist communities near the Tetra4 project site that are vulnerable to climate change
impacts, such as thermal and electrically efficient buildings (to minimise electricity needs for heating and
cooling), energy efficient stoves (to minimise the use of coal and woody biomass), or small-scale renewable
energy innovations suitable for use in homes.
Project specific mitigation measures, may include:
• GHG emissions from vehicles and equipment:
o Maintain vehicles and machinery in accordance with manufacturers standard specifications;

and
o A leak-detection program to be implemented to reduce product loss.
• GHG emissions from flaring, venting and fugitives:
o Emissions of GHG should be limited as much as possible to reduce the global impact;
o Flaring and venting of GHG should be minimised; and
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o Prudent operations and reductions in plant upsets would lead to fewer maintenance, start-up,
and shutdown events that cause flare and blowdown emissions, with the added benefit of
retaining more product.
• GHG from National Grid:
o The implementation and use of renewable energy such as solar photovoltaic (PV) units to
replace/ reduce the reliance on ESKOM electricity would reduce the Tetra4 Cluster 2 GHG
emissions significantly since ESKOM’s contribution to the operational phase is the main source
of GHG emissions; and
o The use of LNG instead of diesel for generators and other stationary equipment would reduce
the Project’s GHG footprint further.
9.15 NOISE RECEPTORS

A specialist assessment of the noise environment within the study area has been undertaken by Airshed Planning
Professionals and the specialist report is included in Appendix 4. The findings are presented in the subsections
below.
NOISE SENSITIVE RECEPTORS

NSRs generally include places of residence and areas where members of the public may be affected by noise
generated by proposed activities. Potential noise sensitive receptors within the study area are shown in Figure
118 include individual homesteads and industrial and residential areas (i.e., Virginia).
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Figure 118: Sensitive noise receptors within the study area.
Sampling points for the noise survey conducted by Airshed in 2022 were selected based on proposed project
activities, position of identified sensitive receptors and noise survey locations selected for the baseline campaign
conducted in 2016. The baseline 2016 and 2022 noise survey results are included in the specialist report. All the
measurements indicated a site with a very complex sound character. Areas away from busy roads and mining
activities are very quiet, with measurement locations closer to houses, busy roads and mining activities
indicating higher sound levels. Vegetation growth closer to dwellings creates habitat, attracting birds and
insects, which in turn make sounds that increases the ambient sound levels. The vegetation also increased wind-
induced noises. The larger study area, away from roads, dwellings and mining activities can be rated as Rural as
per the SANS 10103:2008 criteria.
NOISE PROPAGATION AND SIMULATION

The noise source inventory, noise propagation modelling and results for the construction and operational phase
of the project are discussed in detail in the specialist report while a summary of the findings are presented below
for ease of reference.
The simulated noise levels for the construction and operational phase took into consideration the working hours
as follows:
• Construction activities will take place during day-time hours with a one-hour lunch break.
• Operational activities were assumed to take place 24 hour per day, 7 days per week.
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The exact location of the wells and pipelines will only be determined during the exploration phase as more data
becomes available to guide the positioning of further wells and associated pipelines. As such, the simulated noise
levels will be used to determine suitable mitigation measures associated with each aspect of the project. A
summary of the noise simulations against the IFC day- and night-time guidelines (55dBA and 45dBA respectively)
is provided in Table 48. Numerous Isopleths (noise simulation maps) are presented in the noise specialist study
for each of the project aspects should the reader require a visual representation of the simulation.
Table 48: Noise simulation (IFC day- and night-time) against construction and operational aspects.
Construction noise exceedance Operational noise exceedance distance to

Aspect distance to receptors for IFC receptors for IFC daytime and night-time
daytime guideline (55dBA) guidelines (55dBA & 45dBA)
Well drilling 400m from Noise Sensitive N/A

(construction) Receptors.
Pipeline 90m from Noise Sensitive N/A

construction Receptors.
Blower Stations 600m from Noise Sensitive IFC day- (55 dBA) and night-time (45 dBA) noise
Receptors. guidelines for residential areas are exceeded up
to 50 m and 150 m from the Blower Station
sites respectively.
LNG/LHe Plant and The IFC day-time noise guidelines The IFC day- (55 dBA) and night-time (45 dBA)
Compressor for residential areas (55 dBA) are noise guidelines for residential areas are not
Stations not exceeded at any of the exceeded at any of the identified NSRs.
identified NSRs.
9.16 VISUAL RECEPTORS

Landscape and visual impacts are being assessed by Environmental Planning and Design and the specialist report
is included in Appendix 4. The baseline receiving environment findings are presented in the subsections below.
LANDSCAPE CHARACTER AREAS AND VISUAL ABSORPTION CAPACITY (VAC)

Landscape Character Areas (LCAs) are defined as “single unique areas which are the discrete geographical areas
of a particular landscape type”. The overriding character differentiating factors within the subject landscape
appear to be landform /drainage and vegetation cover. The landform appears to divide the landscape into Four
discrete areas including;
1. Cultivated Rural Landscape Character Area. This area has gently undulating topography and a
predominance of cultivated fields that are generally separated by areas of natural grassland. This is a
relatively open landscape with little VAC which is only provided by minor ridgelines and alien
vegetation;
2. Natural Landscape Character Area. This area is comprised of the shallow valleys surrounding
watercourses and is generally covered in Natural Vegetation including grassland and woody alien
species that occur in alluvial areas. VAC within these areas is generally moderate due to the fact that
much of the woody vegetation extends above eye level;
3. Mining Landscape Character Area. This area includes all mining operations and the extensive stockpiles
and infrastructure that associated with them; and
4. The Urban / Residential LCA. This area is comprised entirely of the urban areas of Virginia and Welkom.
VAC is generally high within these areas due to the extent of structures and urban vegetation. Also due
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to distance (minimum 2.7km) surrounding rural vegetation and mining activities are likely to provide
an effective screen.
Visual Receptors are defined as “individuals and / or defined groups of people who have the potential to be
affected by the proposal”. The significance of a change in a view for a visual receptor is likely to relate to use.
Uses such as guest houses, recreation and tourism related areas are likely to rely on the maintenance of an
outlook for successfully attracting guests and users. Residential areas could depend on outlook for the
enjoyment of the area by residents and for maintaining property values. A route that is particularly important
for tourism may also be dependent on outlook for the maintenance of a suitable experience for users.
Visual receptors within the affected landscape that due to use could be sensitive to landscape change are
indicated below.
• Area Receptors may include;
o Urban areas within the towns of Virginia and Welkom which are located approximately 2.7km
to the east and 7.3km north of the proposed Cluster 2 Boundary Extension respectively; and
o The H Joel Private Nature Reserve which, at its closest, is located approximately 1.0km to the
south of the proposed Cluster 2 Extension area.
• Point Receptors that include;
o There are a number of Local Farmsteads and Homesteads located both within the surrounding
landscape. From the site visit it appears that the farmsteads within the proposed site have a
primarily agricultural use.
• Linear Receptors or routes through the area that include;
o The R30, the R730 and the unsurfaced local roads that that run through the proposed Cluster
2 Extension area. All of these are used mainly by local people with little or no tourism /
recreational importance.
The landscape character areas and visual receptors within the study area are presented in Figure 119 and Figure
120.
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Figure 119: Landscape character areas and visual receptors.
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Figure 120: Visual receptors within and near the study area.
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VISUAL SENSITIVITY
Site (Landscape) sensitivity (Figure 121) is largely related to the way that the site fits into the surrounding
landscape i.e. is it an important component. The sensitivity of potential receptors generally relates to whether
views are important to support current or potential usage. However, they also relate to nuisance and whether
for instance a proposed use could impose on and make an existing use uncomfortable or even untenable.
The landscape within which the proposed projects is located is not highly sensitive. It has largely been
transformed by large scale mining operations and commercial agriculture. The topography and vegetation
patterns are also such that there is little VAC, receptors are therefore to a large degree affected by views of
mining operations. However, the development proposal is likely to result in a finer grain industrial character
which could mean that even though most individual elements are relatively small they will be considerably closer
to most potential receptors. The visual sensitivity of the landscape has been categorised into no-go, high,
medium and low (non-sensitive) areas as described below.
• No-Go Areas:
o Since the affected landscape is highly transformed by both agriculture and mining and because
protected areas are highly unlikely to be affected, there are no potentially affected areas
where development should not happen due to potential landscape or visual impacts.
• Areas with High Sensitivity:
o There are potentially affected areas that could be sensitive to potential development, these
include:
▪ All Natural areas that are largely located within the shallow river valleys. These areas
have largely survived in a natural state due to their unsuitability for large scale mining
and agriculture, they are therefore relatively intact. In addition to the provision of key
environmental services such as attenuation of storm run-off, they provide visual
buffers between intensive agriculture and mining operations. There are therefore
sound reasons to maintain the integrity of these areas. From a landscape and visual
perspective however, it is likely that the location of wells, compressor stations and
pipelines might occur within these areas with minimal impact. However, this is
subject to minimal disturbance and appropriate mitigation to ensure that the natural
landscape character remains intact;
▪ All areas within close proximity to homesteads. Currently there are views from many
homesteads of large-scale mining operations. However, there are very few
homesteads that have close range views over industrial operations. It is possible that
the development of the various elements associated with the proposed project could
be located in close proximity to homesteads and, subject to distance, these could
dominate views of residents. Due to the small scale of the majority of proposed
elements, the screening ability of natural areas in which many of the proposed
elements are located, a 250 m buffer has been indicated around homesteads. It is not
proposed that development in these areas is prevented, however, development must
be undertaken in a way that views from affected homesteads are not dominated by
views of the elements, appropriate mitigation is undertaken, and appropriate
consultation is undertaken with residents.
▪ All areas within close proximity to roads. Views from the main “R” roads that pass
through the affected area are currently largely comprised of large-scale arable
agriculture in the foreground and middle distance backed by large scale mining
operations. These views are punctuated by natural landscape areas as the motorist
crosses the shallow river valleys. Subject to distance, the majority of proposed
elements are such that their location within the current large scale open agricultural
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landscape is unlikely to be highly obvious. Due to their scale, a well, compressor
station or LV overhead power line located 250 m away from a road is unlikely to the
highly visible from the road. A pipeline at any distance from the road, as long as
appropriate rehabilitation is undertaken, is unlikely to be highly visible.
• Areas with Medium Sensitivity
o Areas with medium sensitivity to development include all arable agricultural areas outside 250
m from homesteads and roads.
• Non-Sensitive Areas
o All non-sensitive areas including mining areas outside 250m from homesteads and roads.
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Figure 121: Landscape visual sensitivity rating for the study area.
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10 ENVIRONMENTAL IMPACT ASSESSMENT
This section describes the impact assessment methodology, the identified impacts and an assessment of each.
10.1 IMPACT ASSESSMENT METHODOLOGY

The impact significance rating methodology, as provided by EIMS, is guided by the requirements of the NEMA
EIA Regulations 2014 (as amended). The broad approach to the significance rating methodology is to determine
the environmental risk (ER) by considering the consequence (C) of each impact (comprising Nature, Extent,
Duration, Magnitude, and Reversibility) and relate this to the probability/ likelihood (P) of the impact occurring.
This determines the environmental risk. In addition, other factors, including cumulative impacts and potential
for irreplaceable loss of resources, are used to determine a prioritisation factor (PF) which is applied to the ER
to determine the overall significance (S). The impact assessment methodology has been applied to all identified
alternatives. Where possible, mitigation measures have been recommended for impacts identified.
DETERMINATION OF ENVIRONMENTAL RISK

The significance (S) of an impact is determined by applying a prioritisation factor (PF) to the environmental risk
(ER). The environmental risk is dependent on the consequence (C) of the particular impact and the probability
(P) of the impact occurring. Consequence is determined through the consideration of the Nature (N), Extent (E),
Duration (D), Magnitude (M), and Reversibility (R) applicable to the specific impact.
For the purpose of this methodology the consequence of the impact is represented by:
(𝑬 + 𝑫 + 𝑴 + 𝑹) ∗ 𝑵
𝑪=
𝟒
Each individual aspect in the determination of the consequence is represented by a rating scale as defined in
Table 49 below.
Table 49: Criteria for Determining Impact Consequence.
Aspect Score Definition
-1 Likely to result in a negative/ detrimental impact
Nature
+1 Likely to result in a positive/ beneficial impact
1 Activity (i.e. limited to the area applicable to the specific activity)
2 Site (i.e. within the development property boundary),
Extent 3 Local (i.e. the area within 5 km of the site),
4 Regional (i.e. extends between 5 and 50 km from the site
5 Provincial / National (i.e. extends beyond 50 km from the site)
1 Immediate (<1 year)
2 Short term (1-5 years)
3 Medium term (6-15 years)

Duration
Long term (15-65 years, the impact will cease after the operational life span of
4
the project)
Permanent (>65 years, no mitigation measure of natural process will reduce the
5
impact after construction)
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Aspect Score Definition
Minor (where the impact affects the environment in such a way that natural,
1
cultural and social functions and processes are not affected)
Low (where the impact affects the environment in such a way that natural,
2
cultural and social functions and processes are slightly affected)
Moderate (where the affected environment is altered but natural, cultural and
Magnitude/ 3 social functions and processes continue albeit in a modified way, moderate
Intensity improvement for +ve impacts)
High (where natural, cultural or social functions or processes are altered to the
4
extent that it will temporarily cease, high improvement for +ve impacts)
Very high / don’t know (where natural, cultural or social functions or processes
5 are altered to the extent that it will permanently cease, substantial improvement
for +ve impacts)
1 Impact is reversible without any time and cost.
2 Impact is reversible without incurring significant time and cost.
Reversibility 3 Impact is reversible only by incurring significant time and cost
4 Impact is reversible only by incurring prohibitively high time and cost
5 Irreversible Impact
Once the C has been determined the ER is determined in accordance with the standard risk assessment
relationship by multiplying the C and the P. Probability is rated/ scored as per Table 50.
Table 50: Probability Scoring.
Improbable (the possibility of the impact materialising is very low as a result of design, historic
1
experience, or implementation of adequate corrective actions; <25 %),
Probability
2 Low probability (there is a possibility that the impact will occur; >25 % and <50 %),
3 Medium probability (the impact may occur; >50 % and <75 %),
4 High probability (it is most likely that the impact will occur- > 75 % probability), or
5 Definite (the impact will occur),
The result is a qualitative representation of relative ER associated with the impact. ER is therefore calculated as
follows:
ER= C x P
Table 51: Determination of Environmental Risk.
5 5 10 15 20 25
Consequence
4 4 8 12 16 20
3 3 6 9 12 15
2 2 4 6 8 10
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1 1 2 3 4 5
1 2 3 4 5
Probability
The outcome of the environmental risk assessment will result in a range of scores, ranging from 1 through to 25.
These ER scores are then grouped into respective classes as described in Table 52.
Table 52: Significance Classes.
Environmental Risk Score
Value Description
<9 Low (i.e. where this impact is unlikely to be a significant environmental risk/ reward).
≥9 - <17 Medium (i.e. where the impact could have a significant environmental risk/ reward),
≥17 High (i.e. where the impact will have a significant environmental risk/ reward).
The impact ER has been determined for each impact without relevant management and mitigation measures
(pre-mitigation), as well as post implementation of relevant management and mitigation measures (post-
mitigation). This allows for a prediction in the degree to which the impact can be managed/mitigated.
IMPACT PRIORITISATION
Further to the assessment criteria presented in the section above, it is necessary to assess each potentially
significant impact in terms of:
1. Cumulative impacts; and
2. The degree to which the impact may cause irreplaceable loss of resources.
To ensure that these factors are considered, an impact prioritisation factor (PF) has been applied to each impact
ER (post-mitigation). This prioritisation factor does not aim to detract from the risk ratings but rather to focus
the attention of the decision-making authority on the higher priority/significance issues and impacts. The PF has
been applied to the ER score based on the assumption that relevant suggested management/mitigation impacts
are implemented.
Table 53: Criteria for Determining Prioritisation.
Considering the potential incremental, interactive, sequential, and

Low (1) synergistic cumulative impacts, it is unlikely that the impact will result
in spatial and temporal cumulative change.

Cumulative Impact
Medium (2) synergistic cumulative impacts, it is probable that the impact will result
(CI)
in spatial and temporal cumulative change.

High (3) synergistic cumulative impacts, it is highly probable/ definite that the
impact will result in spatial and temporal cumulative change.
Low (1) Where the impact is unlikely to result in irreplaceable loss of resources.
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Where the impact may result in the irreplaceable loss (cannot be
Medium (2) replaced or substituted) of resources but the value (services and/or
Irreplaceable Loss functions) of these resources is limited.
of Resources (LR)
Where the impact may result in the irreplaceable loss of resources of
High (3)
high value (services and/or functions).
The value for the final impact priority is represented as a single consolidated priority, determined as the sum of
each individual criteria represented in Table 53. The impact priority is therefore determined as follows:
Priority = CI + LR
The result is a priority score which ranges from 2 to 6 and a consequent PF ranging from 1 to 1.5 (refer to Table
54).
Table 54: Determination of Prioritisation Factor.
Priority Prioritisation Factor
2 1
3 1.125
4 1.25
5 1.375
6 1.5
In order to determine the final impact significance, the PF is multiplied by the ER of the post mitigation scoring.
The ultimate aim of the PF is an attempt to increase the post mitigation environmental risk rating by a factor of
0.5, if all the priority attributes are high (i.e. if an impact comes out with a high medium environmental risk after
the conventional impact rating, but there is significant cumulative impact potential and significant potential for
irreplaceable loss of resources, then the net result would be to upscale the impact to a high significance).
Table 55: Final Environmental Significance Rating.
Environmental Significance Rating
Value Description
High negative (i.e. where the impact must have an influence on the decision process to
≤ -17
develop in the area).
Medium negative (i.e. where the impact could influence the decision to develop in the
> -17 ≤ -9
area).
Low negative (i.e. where this impact would not have a direct influence on the decision to
> -9 < 0
0 No impact
Low positive (i.e. where this impact would not have a direct influence on the decision to
>0 < 9
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Environmental Significance Rating
Medium positive (i.e. where the impact could influence the decision to develop in the
≥ 9 < 17
area).
High positive (i.e. where the impact must have an influence on the decision process to
≥ 17
The significance ratings and additional considerations applied to each impact has been used to provide a
qualitative comparative assessment of the alternatives being considered. In addition, professional expertise and
opinion of the specialists and the environmental consultants has been applied to provide a qualitative
comparison of the alternatives under consideration. This process will identify the best alternative for the
proposed project.
10.2 IDENTIFICATION AND ASSESSMENT OF IMPACTS

This Section presents the potential impacts that have been identified during the scoping phase assessment. It
should be noted that this report has been made available to I&AP’s for review and comment with all comments
and responses included in the final Scoping report submitted to the PASA for adjudication. Potential
environmental impacts were identified during the scoping process. These impacts were identified by the EAP,
the appointed specialists, and updated where relevant based on public input.
Without proper mitigation measures and continual environmental management, most of the identified impacts
may potentially become cumulative, affecting areas outside of their originally identified zone of impact. As this
Cluster 2 development is an extension to the existing Cluster 1 development within the Production Right and
both share the same infrastructure (wells, pipelines, stations, plant, etc), the current approved EMPr mitigation
measures have been assessed for their adequacy in mitigating the Cluster 2 development and specifically
assessed in terms of the Generic EMPr for Gas Infrastructure as published by the DFFE.
Relevant cumulative impacts have been identified. When considering cumulative impacts, it is important to bear
in mind the scale at which different impacts occur. There is potential for a cumulative effect at a broad scale,
such as regional deterioration of air quality, as well as finer scale effects occurring in the area surrounding the
activity. The main impacts which have a cumulative effect on a regional scale are related to the transportation
vectors that they act upon. For example, air movement patterns result in localised air quality impacts having a
cumulative effect on air quality in the region. Similarly, water acts as a vector for distribution of impacts such as
contamination across a much wider area than the localised extent of the impacts source. At a finer scale, there
are also impacts that have the potential to result in a cumulative effect, although due to the smaller scale at
which these operate, the significance of the cumulative impact is lower in the broader context.
CONSTRUCTION PHASE IMPACTS

AIR QUALITY IMPACTS
For air quality impacts during the construction phase, the assumption is that construction activities would be
during day-time hours only. Given the nature of construction activities for the roads/pipeline, wells and booster
stations (where the location may vary depending on the gas reserves in the area) the air quality impacts (due to
dust and vehicle exhaust gas) at the nearest residential receptors to the construction areas may exceed the
respective short-term NAAQS’s for residential areas. If there are exceedances of the standards, however, it
would be of short duration. The negative air quality impacts are therefore considered to be of medium
significance without mitigation and low significance with mitigation at the nearest receptors due to construction
activities for roads/pipeline sections and construction of wells/booster stations.
Unlike the roads/pipeline, wells or booster stations (where the location may vary depending on the gas reserves
in the area) the locations of the three compressor stations and plant have been fixed. The construction period
for the plant is also longer (i.e. more than 1 year). The air quality impacts (due to dust and vehicle tailpipe
emissions) at the nearest residential receptors to the construction areas may exceed the respective short-term
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NAAQS’s for residential areas. These exceedances, should they occur, would be of short duration as the
construction activities will be intermittent in nature and not part of routine operations. The negative air quality
impacts are therefore considered to be of medium significance without mitigation and low significance with
mitigation at the nearest receptors.
The following air quality impacts have been identified and assessed by the air quality specialist:
• Increase in air quality impacts due to construction of the road/pipeline
• Increase in air quality impacts due to construction of the wells and booster stations
• Increase in air quality impacts due to construction of the plant and compressor stations
In order to mitigate the above impacts, the following mitigation measures are put forward:
(i) Mitigation measures
• As construction will only take place during day-time hours and will be of limited duration, AQSRs within
150 m of the road/pipeline construction site should be notified of the activities and potential
disturbance durations prior to construction taking place.
• As construction will only take place during day-time hours and will be of limited duration, AQSRs within
300 m radius of all well construction sites and 200 m from booster station construction sites should be
notified of the activities and potential disturbance durations prior to construction taking place.
• For construction/operation, it is recommended to pave the access road between the plant and the R30
provincial road. This would result in a control efficiency of between 87% and 92% (US EPA, 2006).
• For topsoil management during construction and rehabilitation, the existing EMPr (nr 35) should be
amended to include the recommendation that exposed areas must be ensured to remain moist through
water spraying during dry, windy periods (CE 50%).
• During all phases, material transfers are to be controlled using water sprays resulting in 50% control
efficiency.
• The following good practice should be followed during all phases of the project: To ensure lower
exhaust emissions from vehicles and machinery, equipment suppliers or contractors should be required
to ensure compliance with appropriate emission standards for production fleets. Also, maintenance
and repair of diesel engines should be carried out as prescribed by manufacturer to maximize
combustion and reduce gaseous emissions.
• Fuel efficient driving practices on site, during all phases of the Project, may also help lower exhaust
emissions from vehicles and machinery, such as stipulating a maximum speed on all unpaved roads. In
addition, other fuel-efficient practices that may lower exhaust emissions include limiting idling of
machinery, driving in an upper gear rather than a lower gear as much as possible, ensuring tire pressure
are always adequate etc.
• Products, liquid fuels, and chemicals should be stored in areas where there are provisions for
containment of spills.
• The project proponent has indicated that all infrastructure and facilities will be designed, installed and
maintained according to best industry practices to control fugitive and unintended methane emissions
as prescribed in (US EPA, 2015). In addition, the following actions are recommended:
o If applicable, the implementation of a leak detection and repair (LDAR) program, which include
identifying equipment, leak definition, monitoring equipment, repairing equipment, and
recordkeeping; and
o Regular check (monthly or quarterly) and reporting of exploration well, booster and
compressor facility installations, as well as pipelines portions close to ground surface or those
that have potential to be vandalized.
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(ii) Cumulative Impacts
• Considering the potential incremental, interactive, sequential, and synergistic cumulative impacts, it is
unlikely that the impact will result in spatial and temporal cumulative change.
(iii) Irreplaceable loss of Resources
• The impact is unlikely to result in irreplaceable loss of resources.
CLIMATE CHANGE IMPACTS
The significance of climate change impacts was based on Scope 1, 2 and 3 GHG emissions and assessed according
to the NEMA impact assessment methodology. Since climate change is a global phenomenon, the criterion is
not fully applicable to an assessment of the impacts of GHG emissions on climate change. Furthermore, the
extent of climate change impact is always national or wider and therefore can result in an overly conservative
significance, and since the overall consequence and significance are not influenced by the extent, but rather by
the intensity of emissions, “extent” was not included in the significance rating.
Given the nature of construction activities for the roads/pipeline, wells and booster stations (where the location
may vary depending on the gas reserves in the area) the negative climate change impacts are considered to be
of low significance without mitigation and low significance with mitigation.
• As construction will be of limited duration develop and implement management programs and
procedures to limit GHG emissions as far as possible.
NOISE IMPACTS
For noise impacts during the construction phase, the assumption is that construction activities would be during
day-time hours only. Given the nature of construction activities for the pipeline, wells and Blower Stations
(where the location may vary depending on the gas reserves in the area) the noise levels at the nearest
residential receptors to the construction areas may exceed IFC guidelines for residential areas (55 dBA). If there
are exceedances of this guideline, it would be of short duration. The negative noise impacts are therefore
considered to be of medium significance without mitigation and low significance with mitigation at the nearest
receptors due to these activities.
The noise levels at the nearest residential receptors due to the construction activities of the Plant and
Compressor Stations are not likely to exceed daytime IFC guidelines for residential areas (55 dBA). The negative
noise impacts are therefore considered to be of low significance without and with mitigation at the nearest
receptors due to these activities.
• As construction will only take place during day-time hours and will be of limited duration, NSRs within
90 m of the pipeline construction site should be notified of the activities and potential disturbance
durations prior to construction taking place.
• As construction will only take place during day-time hours and will be of limited duration, NSRs within
400 m radius of all well construction sites and 600 m from Blower Station construction sites should be
notified of the activities and potential disturbance durations prior to construction taking place.
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• The noise levels due to Blower Station operations is likely to exceed the IFC night-time noise guideline
for residential areas up to 150 m from the operations. Care should be taken to site the Blower Stations
at least 150 m from all NSRs.
• Although the current EMPr (number 50) specifies complaints need to be registered it is recommended
that the complaints register description be expanded (for number 50 and number 78) as follows:
o A complaints register, including the procedure which governs how complaints are received,
managed and responses given, must be implemented, and maintained.
• The existing EMPr specifies that construction activities should where possible be during day-time
(number 50). It is recommended that this be expanded as follows (applying to all phases of the project):
o Unless it is an emergency situation, non-routine noisy activities such as construction,
decommissioning, start-up and maintenance, should be limited to day-time hours.
• It is recommended that the current EMPr include the following specifications for equipment (number
50 and number 78) be amended as follows:
o Equipment to be employed should be reviewed to ensure the quietest available technology is
used. Equipment with lower sound power levels must be selected in such instances and
vendors/contractors should be required to guarantee optimised equipment design noise
levels.
• The existing EMPr specifies enclosures (number 50). The following additional information could be
included:
o It should be noted that the effectiveness of partial enclosures and screens can be reduced if
used incorrectly, e.g., noise should be directed into a partial enclosure and not out of it, there
should not be any reflecting surfaces such as parked vehicles opposite the open end of a noise
enclosure.
• The following good practice should be implemented (additional measures to be included in the EMPr
(number 50 and number 78)):
o Machines and mobile equipment used intermittently should be shut down between work
periods or throttled down to a minimum and not left running unnecessarily. This will reduce
noise and conserve energy.
o Acoustic covers of engines should be kept closed when in use or idling.
• Construction activities that are to take place within the below specified distances from noise sensitive
receptors must first be discussed and agreed with the affected party:
o Wells: 400 m
o Pipeline: 90 m
o Blower station: 600 m
o Plant: 430 m
o Compressors: 420 m
• In the event that noise related complaints are received, the existing EMPr makes provision for short
term ambient noise measurements. The EMPr specifies that the noise levels should be co-ordinated
with the 10-m wind speed. It should be noted that it is good practice to undertake noise measurements
when wind speeds are less than 5 m/s and it is recommended that this description be amended.
• It is also recommended that the following procedure be adopted and included in the EMPr for all noise
surveys (for complaints):
o Any surveys should be designed and conducted by a trained specialist.
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o Sampling should be carried out using a Type 1 SLM that meets all appropriate IEC standards
and is subject to annual calibration by an accredited laboratory.
o The acoustic sensitivity of the SLM should be tested with a portable acoustic calibrator before
and after each sampling session.
o Samples sufficient for statistical analysis should be taken with the use of portable SLM’s
capable of logging data continuously over the time period. Samples, representative of the day-
and night-time acoustic environment should be taken.
o The SLM should be located approximately 1.5 m above the ground and no closer than 3 m to
any reflecting surface.
o Efforts should be made to ensure that measurements are not affected by the residual noise
and extraneous influences, e.g. wind, electrical interference and any other non-acoustic
interference, and that the instrument is operated under the conditions specified by the
manufacturer. It is good practice to avoid conducting measurements when the wind speed is
more than 5 m/s, while it is raining or when the ground is wet.
o A detailed log and record should be kept. Records should include site details, weather
conditions during sampling and observations made regarding the acoustic environment of
each site.
SOCIAL IMPACTS
The proposed Cluster 2 project will impact on high quality agricultural soil which is used to grow crops that
contribute to food security in South Africa. One of the most significant potential social impacts associated with
the proposed project is the potential impacts on livelihoods of the farming community. Farmers may fear that
their land rights and property values will be affected. The project will require access to farms, and because of
the current socio-political issues in South Africa, this is a sensitive matter. Farmers may also be concerned about
the impact of the Cluster 2 project on their existing way of life, and on the infrastructure on their farms. An
impact assessment of each of the below impacts has been undertaken and a more detailed description of each
impact is provided in the social specialist report in Appendix 4. Furthermore, each of the below impacts is
relevant to the construction and operational phases.
• Impact on livelihoods
• Uncertainty in landowners maintaining full control over their properties
• Nuisance factor due to increase in ambient dust and noise levels
• Changes in travel patterns
• Damage to farm roads, existing services, and infrastructure
• Impacts on livelihoods due to behaviour of contractors
• Impacts on safety and security of local residents
• impacts on sense and spirit of place
• Impacts on the social licence to operate
• Increase in social pathologies
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• Secondary economic opportunities.
• The Tetra4 community liaison officer (CLO) must continue to deal with the affected landowners
throughout the life of the project
• In cases where there the farmer does not agree with the compensation offered by Tetra4 related to
loss of potential income due to exploration, construction or operational activities, Tetra 4 must appoint
an agricultural economist at their cost to determine what the actual losses will be to the farmers due
to the drilling and trenching activities on their properties. Farmers must be compensated for the actual
losses for the entire period that they cannot use the land due to Tetra’s activities. This may be one or
two years, depending on when in the season the drilling and trenching take place, and how long the
property is affected. The principles explained in the IFC Handbook for Preparing a Resettlement Action
Plan must be followed. This includes a land use/land capability inventory; an asset register and physical
asset survey; an income stream analysis and entitlement matrix. Compensation must be determined
with input from the landowners.
• If any existing livelihood activities will be affected negatively Tetra4 must enter into negotiations with
the affected parties as soon as reasonably achievable to ensure the affected parties are compensated
fairly or can make additional arrangements. Interference with existing livelihoods should be avoided if
possible. If any new activities are planned for a property, Tetra4 must consult with the landowner and
obtain his consent to execute the activity on his/her land.
• If any interference takes place and there are actual losses, the landowner should be compensated for
their losses. Tetra4 must have a claims procedure that is communicated to all affected landowners.
There must be specific timeframes dealing with response times and time it takes to close out
complaints. In order to receive compensation, the claim forms must be submitted to the Tetra4 CLO
Compensation should follow the IFC principles, which states that market related prices should be paid,
and if anything is restored, it must be to the same or better standards than before.
• If areas are fenced, the fences must be checked for snares on a daily basis for the duration of the
construction period. All incidences must be reported to the closest police station. Anti-poaching toolbox
talks should form part of the induction process of all the fencing teams. Any contractor or employee
caught poaching should be removed from site.
• Tetra4 must provide detailed written information to the landowners to assist them with making
informed decisions. The information must include:
o Depth and route of the pipeline
o Timeframe associated with the drilling and installation process - when will Cluster 2 start and
end.
o A3 or A2 maps of the entire project area for each affected landowner
o Information about well heads and boreholes:
▪ How long does it take to drill a borehole?
▪ Can more than one borehole be drilled with the same drill point?
▪ What infrastructure are needed around the well heads and sketches of this
infrastructure
▪ Are all the drill points necessary?
▪ What will happen if there is a change in the infrastructure presented to the
landowners?
▪ Can more than one wellhead be operated from one underground manhole?
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▪ Will the boreholes be left open for a period of time after the holes were drilled?
▪ How are the wellheads connected to each other?
▪ What happens if no gas is found at a borehole?
▪ Will unproductive boreholes be investigated again later?
o Positions of blowers, booster stations and compressors, if any. Sketches of all associated
infrastructure.
o Will there be overhead power lines or electric cables? Will cables be buried?
o What maintenance will be required, and how often will teams need access for maintenance?
o Where will the condensation wells be?
o How will condensation water be removed? The contract states it will be no more than once a
week, but is it once a week per well, or once a week that the vehicle gets access?
o Who will be responsible for damage to Tetra4 property?
• Any future expansion plans must be communicated to any landowner that will be influenced by the
expansion.
• The relevant specialists will provide scientific mitigation measures for this aspect. Practical, visible
solutions such as putting shade nets against fences close to dwellings during the construction phase
should be investigated. No drilling or construction must take place on weekends or between sunset and
sunrise.
• It may be unavoidable to change travel patterns. It is important to inform the affected stakeholders
about the possibility of this impact as soon as possible. It will allow them time to get used to the idea
and plan their activities accordingly. It is also important that locally affected parties give input in
potential mitigation measures. Before construction and drilling commences Tetra4 must meet
individually with each landowner to discuss their movement patterns and needs. Tetra4 must provide
all the affected landowners with a construction and drilling schedule to ensure that they know when
construction will take place on their properties. It is recommended that construction and drilling be
done outside the peak planting and harvesting seasons. Any changes to the construction and drilling
schedule must be communicated to the farmers at least a week in advance. As far as possible
obstruction of access routes and sensitive areas must be avoided. If it cannot be avoided both parties
must agree on alternative routes, and Tetra4 should carry the cost of implementing the alternatives.
Industrial vehicles should not travel during peak traffic times. If practical and required by the
landowner, access routes to land/infrastructure should be reinstated in the decommissioning phase.
This must be done in conjunction with the landowners.
• If private roads are affected by project activities, it is the responsibility of Tetra4 to maintain these
roads as long as they use it. Tetra4 should engage with the relevant farmers about road maintenance,
as some of them have preferential ways in which the roads must be maintained, for example if roads
are only graded and not built up it turns into rivers when there is heavy rain. The road maintenance
agreements must be formalised before construction and drilling commences to ensure all parties
involved are protected and know their rights and responsibilities. Tetra4 must make sure that all
compacting and rehabilitating of trenches are done to the specifications in the Environmental
Management Plan. It is recommended that construction and drilling be planned for the dry season.
Tetra4 must provide all the affected landowners with a construction and drilling schedule to ensure
that they know when construction will take place on their properties. Any changes to the construction
and drilling schedule must be communicated to the farmers at least a week in advance.
• Before the project commences Tetra4 should compile an asset and infrastructure baseline of any
landowner infrastructure such as fences, pipes, electricity lines, roads and troughs that may be affected
by the project. Photographs and GPS co-ordinates of the infrastructure must be included in the
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baseline. A copy of the baseline affecting their property should be given to each landowner, who should
sign off the document to ensure that it is accurate. Tetra4 should keep the master document. If any
damage occurs it should be reinstated to its pre-project status. If the infrastructure must move, it must
be done at Tetra4’s cost. Tetra4 must ensure that the construction team has a copy of the asset and
infrastructure baseline to guarantee that no infrastructure will be damaged due to ignorance during
the construction phase of the project.
• All contractors should sign a code of conduct as part of their induction process. Induction must explicitly
include aspects such as closing gates and littering. Toolbox talks must be designed to include social and
environmental aspects. A fining system must be put in place for any transgressions affecting the
landowners. It is important to instil respect for the landowners and their livelihoods from the beginning
of the project.
• Tetra4 should work with the preferred farmers’ security group (Erfenis Veiligheid) and implement the
AgriSA farm access protocol for everybody that need to access the properties. Pictures, make and
registration numbers of all vehicles used by Tetra4 on site should be provided to the farmer’s security
group and distributed to all affected landowners to ensure that they will be able to identify these
vehicles if they access their properties. For scheduled and maintenance work Tetra4 should give a roster
to the farmers stating dates and approximate times that contractors will be on the farms. Farmers
emphasised that they need to know of people accessing the farm ahead of time. It is too late to inform
them when entering the property. All access arrangements should be made at least 24 hours before
access is required. Tetra4 must meet with the landowners before the construction and drilling phase
commence and formalise security arrangements. This should be done in writing and include the existing
forums that the landowners know and trust.
• All contractors and employees need to wear photo identification cards. Vehicles should be marked as
construction vehicles and should have Tetra4’s logo clearly exhibited. Entry and exit points of the site
should be controlled during the construction and drilling phase. Areas where materials are stockpiled
must be fenced. The schedules of the security company should be communicated to the farmers,
especially to those farmers that have Tetra4 infrastructure that need to be guarded. It must be
considered that guards changing shifts contribute to the impact of strangers accessing properties, and
therefore a system that consider the safety of both the Tetra4 infrastructure and the safety of the
landowners must be implemented. The necessary sanitation facilities must be made available, and
some form of shelter from the elements. The security guards must not be allowed to make fires for
cooking or heating purposes.
• A system to arrange access to properties must be devised and formalised. The landowners must agree
to the system. Access must be arranged at least 24 hours prior, except in emergencies, when the
landowners should also be informed immediately. Landowners have the right to refuse people access
to their properties if it was not arranged in advance. If routine access is required, the landowners must
be provided with a roster indicating dates and approximate times that access will be required. Tetra4
must compensate the landowners for any damage to property or goods if it was due to behaviour of
their contractors. Sub-contractors must be made aware of this and a clause spelling out their liability
should be included in their contracts
• It is difficult to mitigate the impact on sense of place as it is experienced on a personal level. In general,
the mitigation measures suggested in the visual, noise, ecological impact assessments and other
relevant specialist studies should be adhered to. The relevant specialists will provide scientific
mitigation measures for the aspects relevant to their studies. The direction and brightness of lights
close to residences must be considered. Pipeline markers on game farms must be camouflaged by
either painting it in a colour that blend in with the surrounding areas, or putting natural materials such
as branches or wooden poles around it. This must be done in consultation with the affected
landowners. Sense of place is a personal experience, but successful rehabilitation will go a long way in
recreating a rural sense of place. The public perception would be negative or positive depending on the
successful implementation of the rehabilitation.
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• Tetra4 has a dedicated person that communicate with the landowners with whom they have a positive
relationship. It is important that this relationship is extended to the Cluster 2 landowners. Information
sharing, frequent communication and quick responses to issues/complaints/enquiries will assist Tetra4
with maintaining their SLO
• Toolbox talks should include talks about the impact of promiscuous behaviour. Tetra4 should develop
an in-house infectious diseases strategy to address health issues within the workforce. A workforce
code of conduct should be developed to maximise positive employee behaviour in the local community,
and optimise integration.
• Tetra4 should ensure that a good proportion of secondary economic opportunities are given to local
contractors. Services and goods must be procured locally as far as reasonably possible. Aspects of this
positive impact will occur by default when the construction force lives locally and they utilise local
services and support local shops.
probable that the impact may result in spatial and temporal cumulative change.
• The impact is unlikely to result in irreplaceable loss of resources but where this may occur, mitigation
measures shall be put forward to reduce this potential as far as possible.
ECONOMIC IMPACTS
The majority of the economic impacts of this project have been rated as positive with the impacts extending
from a local level, through to the region and also to a national level. In addition, the Gas Act makes provision for
black economic transformation and the provisions thereof is described in the BBBEE Act. This project will need
to comply with these provisions which compliance will have an obvious positive impact on economic
transformation. During the construction phase, the positive impacts on the local economy will be the greatest
(through employment opportunities as well as material and contractor requirement) while during the
operational phase the economic impacts move towards a more regional and national level when gas production
and distribution is in full swing. From an economic perspective, the decommissioning phase would represent a
negative impact due to the local, regional and national financial and general economic benefits from the project
effectively ceasing.
The following economic impacts relating to all phases of the project have been identified:
• Gross Geographical Product (GGP)/ Gross Domestic Product (GDP) Impact
• Employment Impacts
• Forex savings
• Fiscal Income
• Economic development per capita
• Country and Industry Competitiveness
• Black Economic Transformation
• Alternative Land-use
• Need and Desirability
• Impact on individual farmland values
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• Ensure that as much of the infrastructure as possible is sited away from agricultural lands. Utilize
servitudes, farm roads and any other routes to avoid sensitive areas. Ensure that pipelines are buried
at sufficient depth (>1 m minimum) to avoid interference with arable agriculture activities.
• Communication to stakeholders about the nature and extent of economic opportunities should be
undertaken. No unrealistic expectations should be created and the recruitment policy giving preference
to local labour should be communicated from the beginning of the project. The local area of influence
should be agreed with stakeholders early on in the process.
• Landowners must be consulted, and all reasonable requests complied with. A written landowner
agreement should be negotiated and concluded prior to commencement. Should this not be possible,
a record should be kept of reasonable negotiations with the land owners.
• The pipelines will be buried in accordance with the schedule as agreed upon with landowners to
minimise disturbance to farming operations.
• If any farm labourers apply for positions at Tetra4 or one of its contractors, Tetra4 or the contractor
must ensure that the labourer is aware that the position may only be temporary and what the long-
term consequences of taking the position are.
• Preference for employment should be given to the local community. The recruitment policy must be
communicated openly and made available to the public if requested.
• Tetra4 should liaise with local training institutions or service providers to determine whether there are
any opportunities to offer internships and practical experience for their students. Tetra4 must ensure
that skills development requirements form part of their contracts with sub-consultants as prescribed in
the SLP. The skills development requirements and bursaries for local learners as discussed in their Social
and Labour Plan (SLP) must be implemented.
• Tetra4 must appoint a CLO that deals with the affected landowners throughout the life of the project.
If existing activities will be affected negatively Tetra4 must enter into negotiations with the affected
parties as soon as reasonably achievable to ensure the affected parties are compensated fairly or can
make additional arrangements. Interference with existing livelihoods should be avoided if possible. If
any new activities are planned for a property, Tetra4 must consult with the landowner and take
reasonable steps to obtain his consent to execute the activity on his/her land. A system to arrange
access to properties must be devised and formalised. All reasonable efforts must be taken to obtain
agreement on the system with the landowners and it must be formalised. Access must be arranged at
least 24 hours prior, except in emergencies, when the landowners should also be informed
immediately. If routine access is required, the landowners must be provided with a roster indicating
dates and approximate times that access will be required. Tetra4 must compensate the landowners for
any damage to property or goods if it was due to behaviour of their contractors. Sub-contractors must
be made aware of this and a clause spelling out their liability should be included in their contracts. All
contractors should sign a code of conduct as part of their induction process. Induction must explicitly
landowners.
• Contractors should be required to make use of a certain proportion of local labour - it is acknowledged
that not all skills will be available locally. Jobs should be advertised in a way that is accessible to all
members of society and labour desks (labour registration stations) should be in accessible areas. No
unrealistic expectations should be created and the recruitment policy giving preference to local labour
should be communicated from the beginning of the project. The local area of influence should be
agreed with the stakeholders early on in the process.
• Procurement targets to be in line with the existing Social Labour Plan (SLP).
• Comply with downscaling regulations of the DMRE.
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• The impact may result in the irreplaceable loss of resources however the value of these resources would
be limited.
GROUNDWATER IMPACTS
It should be noted that vast areas within the study area have been subjected to historical mining activities and,
as such, reflect modified to highly modified present ecological status. A total number of >15 000 historical
exploration wells have been drilled throughout the study area, some of which remain uncased and unsealed.
The latter may act as preferential pathways and conduits for groundwater flow and contaminant transport
mechanisms. As mentioned earlier an impact can be defined as any change in the physical-chemical, biological,
cultural and/or socio-economic environmental system that can be attributed to human and/or other related
activities. Accordingly, this already highly modified zones should form part of the impact significance rating and
risk approach.
The environmental significance rating of the following potential impact is rated as medium negative without the
implementation of mitigation measures and low negative with the implementation of mitigation measures.
• Mobilisation and maintenance of heavy vehicle and machinery on-site may cause hydrocarbon
contamination of groundwater resources.
During the construction phase minimal impacts on the groundwater system are expected. The environmental
significance rating of the following potential impacts is rated as low negative with and without the
implementation of mitigation measures.
• Groundwater deterioration and siltation due to contaminated stormwater run-off from the
construction area.
• Poor quality leachate may emanate from the construction camp which may have a negative impact on
• Poor storage and management of hazardous chemical substances on-site may cause groundwater
pollution.
The following mitigation measures should be considered to minimise the potential groundwater impacts during
the construction phase.
• Develop a stormwater management plan in accordance with GN704 in order to separate dirty/contact
water from clean water circuits. All water retention structures, process water dams; storm water dams,
retention ponds etc. should be constructed to have adequate freeboard to be able to contain water
from 1:50 year rain events.
• All construction should take place during the dry season, as far as possible.
• Location of construction camps must be carefully considered and within the approved area to ensure
that the site does not impact on sensitive areas identified during the Environmental Assessment phase
or field work.
• Sites must be located, where possible, on previously disturbed areas.
• Every effort must be made to keep the footprint as small as possible.
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• Any excess sand, stone and cement must be removed or reused from site on completion of the
construction period and disposed at a registered disposal facility. Certificates of safe disposal for
general and recycled waste must be maintained and retained on file.
• Construction vehicles and machinery must be serviced and maintained regularly in order to ensure that
oil spillages are limited. Spill trays must be provided if refuelling of operational vehicles is done on site.
Further to this spill kits must be readily available in case of accidental spillages with regular spot checks
to be conducted.
• During servicing of vehicles or equipment, especially where emergency repairs are effected outside the
workshop area, a suitable drip tray must be used to prevent spills onto the soil.
• Leaking equipment must be repaired immediately or be removed from site to facilitate repair.
• Workshop areas must be monitored for oil and fuel spills.
• An appropriate number of spill kits must be available and must be located in all areas where activities
are being undertaken.
• All hazardous substances used on-site should have an applicable Material Safety Data Sheet (MSDS) to
provide information regarding the hazards, emergency response, protective measures and correct
storage methodology.
• Hazardous substance containment facilities to be used during operational phase should comply with
the relevant hazardous substance storage legislation in order to ensure spillages are contained.
• All hazardous substances and material used on-site should be stored in a dedicated, closed-off facility
with an impervious floor and bunded area to prevent seepage and/or run-off in case of accidental spills.
• The impact may result in irreplaceable loss of resources if not adequately mitigated but the value of the
resources will be limited.
HYDROLOGICAL IMPACTS
During the construction phase, pipes connecting the new wells to the compressor stations and helium plant will
be laid down. Construction work for laying of pipes across rivers or parallel to them may involve the excavation
of riverbed material and restoring the river to a near-natural state thereafter. Horizontal Directional Drilling
(HDD) will be the method generally used on site to lay pipes so that the impact is minimal/negligible.
The potential hydrological impacts that have been identified during the construction phase include the
following:
• Exposure of soil, leading to increased runoff, and erosion, and thus increased sedimentation of the
watercourses.
• Soil and stormwater contamination by oils and hydrocarbons spills, originating from construction
vehicles
• Increase in the number of alien and/or invasive vegetation as a result of disturbances.
• Alterations of the river banks and river bed due to movement near the drainage lines.
Although the above hydrological impacts are predicted to have a minimal/negligible impact significance, the
following mitigation measures should be considered:
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• Ensure total footprint area is kept to a minimum.
• Traffic and movement of machinery should be minimised and restricted to certain paths.
• Progressive rehabilitation of disturbed land should be carried out.
• Construction waste must be collected and stored safely for disposal in accordance with the relevant
waste regulations, protocols, and product specifications. Care must be taken not to leave any waste on
project area that can lead to future contamination of the project area or the downstream area.
• Monitoring for the project area for alien and invasive vegetation species must be undertaken,
specifically for access roads through or along the watercourses. Should alien and invasive plan species
be identified, they must be removed and disposed of as per an alien and invasive species control plan
and the area must be revegetated with suitable indigenous vegetation.
• The reaches of all watercourses where no construction activities are planned to occur must be
considered no-go areas.
IMPACTS ON HERITAGE OR PALAEONTOLOGICAL FEATURES
A total of fourteen (14) burial grounds and graves (TET 1, TET 7-8, TET 11, TET 15, TET 19, TET 22, SSL/BET/72,
SITE 2, SITE 19 and T0003, T0009, T0024, T0029) were identified within the proposed development areas. Burial
grounds and graves have high heritage significance and are given a IIIA significance rating in accordance with the
system described in Section 4 of this document.
Burial grounds and graves are protected under Section 36 of the NHRA 25 of 1999. Thus, the sites are
provisionally rated as having a high heritage significance with a heritage rating of IIIA. All graves have high levels
of emotional, religious and in some cases historical significance. It is also important to understand that the
identified graves could have significant heritage value to the relevant families.
A total of fourteen (14) possible grave sites (TET 4-6, TET 13, TET 14, TET 25a, TET 25b, TET 26, SSL/BET/37-39,
SSL/BET/53, SSL/BET/60, SSL/BET/66) were identified within the proposed development area. Burial grounds
and graves have high heritage significance and are given a IIIA significance rating.
A total of thirty-one (31) structures (TET 2, TET3, TET 9, TET 27, SSL/BET/25-26, SSL/BET/36, SITE 1A, SITE 1B,
SITE 20-21and T0001, T0002, T0004, T0005, T0017, T0018, T0019, T0020, T0021, T0025, T0030, T0031, T0033,
T0034, T0036, T0037, T0038, T0039, T0040, T0041) were identified within the proposed development area.
Twenty-one (21) of the heritage sites (TET27, SSL/BET/25, SSL/BET/26, SSL/BET/36, T0001, T0002, T0004, T0005,
T0017, T0018, T0019, T0020, T0025, T0030, T0031, T0033, T0034, T0036, T0037, T0038, T0039) are assessed to
have a low heritage significance are not included in the impact assessment. The reason for this is that sites of
low significance will not require mitigation.
Structures older than 60 years fall under the protection of Section 34(1) of the National Heritage Resources Act
25 of 1999. Additionally, in terms of Section 35(4) of the National Heritage Resources Act (25 of 1999), man-
made features and artefacts older than 100 years are defined as being archaeological. In the same section, the
Act also states that such archaeological sites and objects may not be disturbed, altered, modified or destroyed
without a suitable permit from the South African Heritage Resources Agency (SAHRA).
The pre-mitigation impact significance for burial grounds, graves, heritage sites/structures is rated as MEDIUM,
but with the implementation of the required mitigation measures the post-mitigation impact will be LOW. The
overall Environmental significance will be Low negative.
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No visible evidence of fossiliferous outcrops was found in the development footprint and thus an overall medium
palaeontological significance is allocated to the development footprint. It is therefore considered that the
proposed development will not lead to detrimental impacts on the palaeontological reserves of the area.
(iv) Mitigation measures
• Implement a chance find procedures in case where possible heritage finds are uncovered.
• Burial Grounds and Graves (TET 1, TET 7-8, TET 11, TET 151, TET 19, TET 22, SSL/BET/72, SITE 2, SITE 19
and T0003, T0009, T0024, T0029):
o The graves should be demarcated with a 50-meterbuffer and should be avoided and left in
situ.
o A Grave Management Plan should be developed for the graves which also need to be approved
by SAHRA BGG.
o If the site is going to be impacted and the graves need to be removed a grave relocation
process as per the Heritage Management Plan for the site is recommended as a mitigation and
management measure. This will involve the necessary social consultation and public
participation process before grave relocation permits can be applied for with the SAHRA BGG
under the NHRA and National Health Act regulations.
• Historic to recent sites with possible grave sites (TET 4-6, TET 13, TET 14, TET 25a, TET 25b, TET 26,
SSL/BET/37-39, SSL/BET/53, SSL/BET/60, SSL/BET/66):
o Apply for the test excavation and/or GPR permit to determine if the site contains graves.
o If human remains are discovered a grave relocation process is recommended as a mitigation
and management measure. This will involve the necessary social consultation and public
participation process before grave relocation permits can be applied for with the SAHRA BGG
under the NHRA and National Health Act regulations.
o When graves are discovered/uncovered the site should be demarcated with a 50-meter no-
go-buffer-zone and the grave should be avoided.
o If, during test excavations, it is determined that the site does not contain graves, no further
mitigation will be required.
• Structures (TET2, TET3, TET9, SITE 1A, SITE 1B, SITE 20, SITE 21, T0021, T0040, T0041):
o It is recommended that a no-go-buffer-zone of at least 30m is kept to the closest
infrastructure.
o If development occurs within 30m of the site, the structure will need to be satisfactorily
studied and recorded before impact occurs.
o Recording of the site i.e. (a) map indicating the position and footprint of the structure (b)
photographic recording of the structure (c) measured drawings of the floor plans of the
structure.
o Submission of permit application to SAHRA to allow for the disturbance to the site. A Cluster
2 Heritage Report must accompany the permit.
• Structures (TET27, SSL/BET/25, SSL/BET/26, SSL/BET/36, T0017, T0018, T0019, T0020, T0025, T0037,
T0038):
o No mitigation is required. The documentation of the site in the HIA report is sufficient and the
site can be destroyed without a permit but with the approval of the HIA report.
• Palaeontology:
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o The ECO for the project must be informed that the Adelaide Subgroup (Beaufort Group, Karoo
Supergroup) has a Very High Palaeontological Sensitivity.
o If Palaeontological Heritage is uncovered during surface clearing and excavations the Chance
find Protocol attached should be implemented immediately. Fossil discoveries ought to be
protected and the ECO/site manager must report to South African Heritage Resources Agency
(SAHRA) (Contact details: SAHRA, 111 Harrington Street, Cape Town. PO Box 4637, Cape Town
8000, South Africa. Tel: 021 462 4502. Fax: +27 (0)21 462 4509. Web: www.sahra.org.za) so
that mitigation (recording and collection) can be carried out.
o Before any fossil material can be collected from the development site the specialist involved
would need to apply for a collection permit from SAHRA. Fossil material must be housed in an
official collection (museum or university), while all reports and fieldwork should meet the
minimum standards for palaeontological impact studies proposed by SAHRA (2012).
(v) Cumulative Impacts
(vi) Irreplaceable loss of Resources
TERRESTRIAL BIODIVERSITY IMPACTS
The majority of the biodiversity within the study area has been fragmented and impacted on by existing land
uses including agriculture, farmsteads, roads powerlines and other infrastructure as well as mining. Due to the
spatial extent of the proposed Cluster 2 infrastructure, a variety of terrestrial biodiversity areas exist. These
range from low sensitive (e.g. agricultural areas etc) to highly sensitive areas (e.g. pristine areas, wetlands and
watercourses as well as areas where red data species occur). Furthermore the study area contains CBA1 and ESA
1&2 areas. The ecological integrity, importance, and functioning of these terrestrial biodiversity areas provide a
variety of ecological services that are considered beneficial, with one key service being the maintenance of
biodiversity. The preservation of these systems is the most important aspect to consider for the proposed
project. Thus, if these areas are not maintained in a natural or near natural state, destroyed or fragmented
further, then meeting targets for biodiversity features will not be achieved.
The following construction phase impacts have been identified and assessed in this report:
• Destruction, further loss and fragmentation of the vegetation community.
• Introduction of alien species, especially plants.
• Erosion due to storm water runoff and wind.
• Displacement of faunal community due to habitat loss, direct mortalities and disturbance (road
collisions, noise, light, dust, vibration and poaching).
• Any drill sites or infrastructure routes located inside medium, high or very high sensitive sites on the
sensitivity /constraint map require a site-specific pre-commencement assessment. The pre-
commencement assessment must address the sensitive aspects on site, as identified in the overall
sensitivity / constraint map. The pre-commencement assessment must be compiled by the site
Environmental Officer (EO) with a suitable environmental qualification and experience. All
recommendations of the pre-commencement assessment must be implemented on site. The
completeness and adequacy of the pre-commencement assessment in respect of identifying and
managing on site sensitivities must be included in the monthly ECO reports and annual independent
audit.
• The area delineated as no-go must be avoided. No development may take place within this area.
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• Once prospective drilling sites are identified, a suitably trained EO must undertake a site-specific pre-
commencement assessment to assess the site for any potential environmental sensitivities prior to
commencement. Should environmental sensitivities be identified, the relevant Tetra4 Response or
Action Plan Procedures must be adhered to.
• If sensitive species occur within the preferred footprint, the first option should be to relocate the
proposed footprint followed by the alternative of preparing a relocation plan (prepared by a suitably
qualified specialist).
• Search and rescue of species of concern. Obtain permits for disturbance/destruction of any
listed/protected species found on site. Where possible, undertake activities in previously disturbed
areas and/or habitats with lower sensitivity. Where possible, locate activities on the boundaries of
existing disturbance. Use existing access roads as much as possible.
• Construction activities must take place systemically, especially in relation to the game farm areas. These
particularly pertains for Game Farm Areas.
• Where possible, locate infrastructure in previously disturbed places and/or habitats with a lower
sensitivity score. Rehabilitate disturbed areas as soon as possible. Control alien plants.
• Where possible, undertake activities in previously disturbed areas and/or habitats with lower
sensitivity. Where possible, locate activities on the boundaries of existing disturbance. Use existing
access roads as much as possible. Rehabilitate disturbed areas as soon as possible.
• If areas are fenced, the fences must be checked for snares. All incidences must be reported to the
closest police station. Anti-poaching toolbox talks should form part of the induction process of all the
fencing teams. Any contractor or employee caught poaching should be removed from site.
• The areas to be developed must be specifically demarcated to prevent movement into surrounding
environments, especially wetlands and watercourses. Areas of indigenous vegetation, even secondary
communities outside of the direct project footprint, should under no circumstances be fragmented or
disturbed further. Clearing of vegetation should be minimized and avoided where possible.
• Restrict the clearing of watercourse vegetation as far as possible. Areas that have been cleared should
be re-vegetated with indigenous species or other suitable plant species, such as Eragrostis tef, after
construction and initial rehabilitation work (reinstatement of the geomorphological template) is
completed. Compile and implement an alien plant control program with a particular focus on alien
control in watercourses (including wetlands) during the rehabilitation phase of the project. Rehabilitate
disturbed areas as soon as possible. Restrict new footprints to disturbed areas as far as possible. Regular
monitoring should be undertaken in the watercourses to check any possible invasion by alien
vegetation so that they can be weeded out before they grow and spread out.
probable that the impact will result in spatial and temporal cumulative change.
• The impact is unlikely to result in irreplaceable loss of resources over the majority of the application
area.
AQUATIC AND WETLAND IMPACTS
The impacts that have been identified on aquatic and wetland systems during the construction phase include
altered surface flow dynamics; erosion; alteration of sub-surface flow dynamics; sedimentation of the water
resource; direct and indirect loss of wetland areas; water quality impairment; compaction; decrease in
vegetation; change of drainage patterns; altering hydromorphic properties; altered surface flow dynamics;
erosion; alteration of sub-surface flow dynamics; indirect loss of wetland areas; water quality impairment;
compaction; decrease in vegetation; change of drainage patterns; and altering hydromorphic properties.
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Three levels of risk have been identified and determined for the impact assessment and these include low,
medium and high risks. High risks are applicable despite the potential direct risks posed, this is motivated by the
direct impacts posed by the project and the nature of the proposed project. Medium risk refers to wetland areas
that are either directly affected or on the periphery of the infrastructure and at an indirect risk. Low risks are
wetland systems beyond the application area that would be avoided, or wetland areas that could be avoided if
feasible. The significance of all post-mitigation risks was determined to be low.
• The construction vehicles and machinery must make use of existing access routes as much as possible,
before adjacent areas are considered for access.
• The contractors used for the project should have spill kits available to ensure that any fuel or oil spills
are clean-up and discarded correctly.
• It is preferable that construction takes place during the dry season to reduce the erosion potential of
the exposed surfaces.
• All chemicals and toxicants to be used for the construction must be stored within the drilling site and
in a bunded area.
• All machinery and equipment should be inspected regularly for faults and possible leaks, these should
be serviced off-site.
• All contractors and employees should undergo induction which is to include a component of
environmental awareness. The induction is to include aspects such as the need to avoid littering, the
reporting and cleaning of spills and leaks and general good “housekeeping”.
• Adequate sanitary facilities and ablutions on the servitude must be provided for all personnel
throughout the application area. Use of these facilities must be enforced (these facilities must be kept
clean so that they are a desired alternative to the surrounding vegetation).
• Have action plans on site, and training for contactors and employees in the event of spills, leaks and
other impacts to the aquatic systems.
• Any exposed earth should be rehabilitated promptly by planting suitable vegetation (vigorous
indigenous grasses) to protect the exposed soil.
• All waste generated on-site during construction must be adequately managed. Separation and recycling
of different waste materials should be supported.
IMPACTS ON SOIL (PEDOLOGY)
During the construction phase, foundations will be cleared with topsoil often being stripped and stockpiled.
Access roads will be created with trenches being dug for the installation of relevant pipelines. Construction of
compressor sites will take place together with the erection of transmission lines where relevant. Contractor and
laydown yards will also be cleared with construction material being transported to laydown yards. The
construction phase of the compressors will include a short powerline and water connection to the compressors
as well as ablution facilities etc. For the wells the construction phase will consist of the clearance of drilling sites.
Based on the impact assessment, the results indicate “Insignificant” to “Very Low” post-mitigation significance
ratings for the proposed components. It is therefore clear that the proposed activities are expected to have a
minimal impact on land potential resources.
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• Only predefined access roads are to be used to reduce any unnecessary compaction.
• Prevent any spills from occurring. Machines must be parked within hard park areas and must be
checked daily for fluid leaks.
• Invasive plant control must be undertaken quarterly.
• All excess soil (soil that are stripped and stockpiled to make way for foundations) must be stored,
continuously rehabilitated to be used for rehabilitation of eroded areas.
• If a spill occurs, it is to be cleaned up immediately and reported to the appropriate authorities.
• The cumulative impacts have been scored “Medium”, indicating that the potential incremental,
interactive, sequential, and synergistic cumulative impacts. It is probable that the impact will result in
spatial and temporal cumulative change.
• The irreplaceable loss of resources has been scored “Low”, where the impacts are unlikely to result in
an irreplaceable loss of resources.
VISUAL IMPACTS
In general terms the proposed project could industrialise this Landscape Character Area. Large scale mining
operations are currently visible from within this landscape. The proposed project will see drilling operations
occurring throughout the area during exploration and construction. However when this is complete, there will
be up to 300 production wells, booster and compressor stations, LNG/LHe plant and a 4km long 132kV overhead
power line within the landscape. These are relatively small infrastructure elements. The large-scale agricultural
nature of the landscape will remain very evident. A degree of industrialisation will therefore occur however, the
existing landscape character will still dominate.
In terms of cumulative effects, the proposed project will not significantly change the character of views. It will
however combine with large scale mining operations including stockpiles and plant during the construction and
operational phases to intensify current impacts on landscape character.
After decommissioning, visual impacts will reduce due to the removal of operational plant etc. Due to the fact
that the affected landscape is relatively flat and open, no mitigation is feasible.
• Rehabilitate disturbed area and reinstate agricultural usage.
• Minimise disturbance of the natural landscape.
• Return disturbed agricultural land to agricultural use.
• Undertake rehabilitation and screen planting where possible.
• Locate wells and compressor stations a minimum 250m from the edge of local roads.
• Ensure that temporary lighting is of sufficient power to ensure safety but not so powerful that it creates
glare that could cause danger for drivers or nuisance for neighbours.
• Ensure that temporary lighting minimises light spill outside the area that it is intended to light.
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OPERATIONAL PHASE IMPACTS

AIR QUALITY IMPACTS
For air quality impacts during the operational phase, the assumption is that the operational activities would take
place during day- and night-time conditions. Given the location of the plant and the compressor stations and
their potential air quality impacts, it is unlikely that the respective NAAQS’s and NDCR limits for residential areas
will be exceeded at AQSRs due to plant or compressor operations.
The operation of vehicles on unpaved roads, and specifically the plant access road, even under mitigated
conditions, could result in single exceedances of the respective NAAQS’s and NDCR limits for residential areas at
AQSRs. The negative air quality impacts are therefore considered to be of medium significance at the nearest
receptors but will reduce to low significance should the roads be paved.
The air quality impacts due to booster station (generator) operations are likely to exceed the long-term NAAQS’s
for residential areas up to 90 m from the operations. Care should be taken to site the booster stations at least
100 m from all AQSRs. With careful siting, NAAQSs for residential areas should not be exceeded at AQSRs. The
negative air quality impacts are therefore considered to be of medium significance (given the possible impact
zone of 90 m) but will reduce to low significance at the nearest receptors with mitigation measures in place.
The air quality impacts due to plant (flaring) operations are not likely to exceed the long-term NAAQS’s. The
negative air quality impacts are therefore considered to be of low significance at the nearest receptors.
• Ground level concentrations and dust fallout due to vehicle operations on unpaved roads are likely to
exceed the PM10 NAAQS limit and NDCR limit for residential areas up to 80 m from the operations. Care
should be taken to apply mitigation measures to unpaved roads located near AQSRs.
• Air quality impacts due to booster station operations are likely to exceed the PM 2.5 and NO2 NAAQS for
residential areas up to 100 m from the operations. Care should be taken to site the booster stations at
least 100 m from all AQSRs.
• The existing EMPr (nr 39) states that in controlling vehicle entrained PM during construction, it is
recommended that water (at an application rate of 2 litre/m 2-hour), be applied on all unpaved road
sections to ensure a minimum of 50% control efficiency (CE), and that binding agents or chemical
suppressants (such as “Dust-A-Side” or “Dustex”) should be considered for application on all unpaved
road sections (emissions reduction efficiency of more than 80%). This should be amended to also be
applicable during the operational phase.
• For construction/operation, it is recommended to pave the access road between the plant and the R30
provincial road. This would result in a control efficiency of between 87% and 92% (US EPA, 2006).
• During all phases, material transfers are to be controlled through the use of water sprays resulting in
50% control efficiency.
• The following good practice should be followed during all phases of the project: In order to ensure
lower exhaust emissions from vehicles and machinery, equipment suppliers or contractors should be
required to ensure compliance with appropriate emission standards for production fleets. Also,
maintenance and repair of diesel engines should be carried out as prescribed by manufacturer in order
to maximize combustion and reduce gaseous emissions.
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• The project proponent has indicated that all infrastructure and facilities will be designed, installed and
maintained according to best industry practices to control fugitive and unintended methane emissions
as prescribed in (US EPA, 2015). In addition, the following actions are recommended:
o If applicable, the implementation of a leak detection and repair (LDAR) program, which include
identifying equipment, leak definition, monitoring equipment, repairing equipment, and
recordkeeping; and
o Regular check (monthly or quarterly) and reporting of exploration well, booster and
compressor facility installations, as well as pipelines portions close to ground surface or those
that have potential to be vandalized.
The significance of climate change impacts was based on Scope 1, 2 and 3 GHG emissions and assessed according
to the NEMA impact assessment methodology. Since climate change is a global phenomenon, the criterion is
not fully applicable to an assessment of the impacts of GHG emissions on climate change. Furthermore, the
extent of climate change impact is always national or wider and therefore can result in an overly conservative
significance, and since the overall consequence and significance are not influenced by the extent, but rather by
the intensity of emissions, “extent” was not included in the significance rating.
Vehicle and trucks, natural gas generators, and the processing and flaring of gas, could result in medium
significance on climate change and could reduce, although still medium significance with mitigation and
adaptation measures in place.
Gas, however, is considered a 'transition' fuel on the decarbonising roadmap and GHG emissions per unit of gas
combusted is less than per unit coal. Also, the 'extractive' GHG cost (Scope 1 & 2 for Construction and
Operations) is offset by the benefit of helium (a rare resource) and LNG co-extraction. Vehicle and trucks, natural
gas generators, the processing and flaring of gas, fugitive releases, and indirect upstream and downstream
emissions could result in Medium significance on climate change and could reduce, although still Medium
significance with mitigation and adaptation measures in place.
• Emissions of GHG should be limited as much as possible to reduce the global impact.
• Flaring and venting of GHG should be minimised.
• A leak-detection program to be implemented to reduce product loss.
• Replacing Eskom electricity supply with renewable energy.
• Using LNG instead of diesel in equipment and machinery.
likely that the impact will result in spatial and temporal cumulative change.
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10.2.2.2.1 CLIMATE CHANGE ALTERNATIVE SIGNIFICANCE RATING
Other literature (Murphy & Gillam, 2013) suggests use of thresholds (Table 56) presented as tonnes of CO2e per
year, as basis for specific consideration of the specific elements to be assessed in the EIA, as guidance states that
the contribution of an individual project to climate change cannot be measured.
Table 56: GHG and Climate in EIAs - Elements to consider.
GHG emissions (tonnes Qualitative rating Elements of assessment to consider

CO2e/year)
GHGs < 25 000 Very Low Quantify GHG
25 000 < GHGs < 100 000 Low Look at possible mitigation, quantify GHG, place
in context
100 000 < GHGs < 1 000 000 Medium As above and prepare management plan,
describe existing climate conditions, consider
how changes in climate may affect project and
surroundings
GHGs > 1 000 000 High As above and consider adaptation analyses
Based on the suggested thresholds from Table 56, the construction phase Scope1 and Scope 2 GHG emissions
would result in Very Low significance, separately and combined. The operational phase would result in Low
significance for Scope 1 emissions, and Medium for Scope 2 emissions, where the combined (Scope 1 and Scope
2) significance would be Medium. The contribution of Scope 3 to GHG emissions would still result in a Medium
significance.
NOISE IMPACTS
For noise impacts during the operational phase, the assumption is that the operational activities would take
place during day- and night-time conditions. The noise levels due to Blower Station operations is likely to exceed
the IFC night-time noise guideline for residential areas up to 150 m from the operations. Care should be taken
to site the Blower Stations at least 150 m from all NSRs. With careful siting, IFC noise guidelines for residential
areas should not be exceeded at NSRs. The negative noise impacts are therefore considered to be of low
significance at the nearest receptors.
Given the location of the Plant and the Compressor Stations and the potential noise levels due to operations, it
is unlikely that IFC noise guidelines for residential areas will be exceeded at NSRs. The negative noise impacts
are therefore considered to be of low significance at the nearest receptors.
• The noise levels due to Blower Station operations is likely to exceed the IFC night-time noise guideline
for residential areas up to 150 m from the operations. Care should be taken to site the Blower Stations
at least 150 m from all NSRs.
• Although the current EMPr (number 50) specifies complaints need to be registered it is recommended
that the complaints register description be expanded (for number 50 and number 78) as follows:
o A complaints register, including the procedure which governs how complaints are received,
managed and responses given, must be implemented, and maintained.
• The existing EMPr specifies that construction activities should where possible be during day-time
(number 50). It is recommended that this be expanded as follows (applying to all phases of the project):
o Unless it is an emergency situation, non-routine noisy activities such as construction,
decommissioning, start-up and maintenance, should be limited to day-time hours.
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• It is recommended that the current EMPr include the following specifications for equipment (number
50 and number 78) be amended as follows:
o Equipment to be employed should be reviewed to ensure the quietest available technology is
used. Equipment with lower sound power levels must be selected in such instances and
vendors/contractors should be required to guarantee optimised equipment design noise
levels.
• The existing EMPr specifies enclosures (number 50). The following additional information could be
included:
o It should be noted that the effectiveness of partial enclosures and screens can be reduced if
used incorrectly, e.g., noise should be directed into a partial enclosure and not out of it, there
should not be any reflecting surfaces such as parked vehicles opposite the open end of a noise
enclosure.
• The following good practice should be implemented (additional measures to be included in the EMPr
(number 50 and number 78)):
o Machines and mobile equipment used intermittently should be shut down between work
periods or throttled down to a minimum and not left running unnecessarily. This will reduce
noise and conserve energy.
o Acoustic covers of engines should be kept closed when in use or idling.
• Operational activities that take place within the below specified distances from noise sensitive
receptors must first be discussed and agreed with the affected party (prior to construction):
o Operation (daytime):
▪ Blower station: 50 m
▪ Plant: 170 m
▪ Compressors: 80 m
o Operation (night-time):
▪ Blower station: 150 m
▪ Plant: 580 m
▪ Compressors: 150 m
• Regular and effective maintenance of equipment are included in the current EMPr (number 50). This
should also be included for the operational phase (number 78).
• In the event that noise related complaints are received, the existing EMPr makes provision for short
term ambient noise measurements. The EMPr specifies that the noise levels should be co-ordinated
with the 10-m wind speed. It should be noted that it is good practice to undertake noise measurements
when wind speeds are less than 5 m/s and it is recommended that this description be amended.
• It is also recommended that the following procedure be adopted and included in the EMPr for all noise
surveys (for complaints):
o Any surveys should be designed and conducted by a trained specialist.
o Sampling should be carried out using a Type 1 SLM that meets all appropriate IEC standards
and is subject to annual calibration by an accredited laboratory.
o The acoustic sensitivity of the SLM should be tested with a portable acoustic calibrator before
and after each sampling session.
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o Samples sufficient for statistical analysis should be taken with the use of portable SLM’s
capable of logging data continuously over the time period. Samples, representative of the day-
and night-time acoustic environment should be taken.
o The SLM should be located approximately 1.5 m above the ground and no closer than 3 m to
any reflecting surface.
o Efforts should be made to ensure that measurements are not affected by the residual noise
and extraneous influences, e.g. wind, electrical interference and any other non-acoustic
interference, and that the instrument is operated under the conditions specified by the
manufacturer. It is good practice to avoid conducting measurements when the wind speed is
more than 5 m/s, while it is raining or when the ground is wet.
o A detailed log and record should be kept. Records should include site details, weather
conditions during sampling and observations made regarding the acoustic environment of
each site.
• The impact is unlikely to result in irreplaceable loss of resources
SOCIAL IMPACTS
The proposed Cluster 2 project will impact on high quality agricultural soil which is used to grow crops that
contribute to food security in South Africa. One of the most significant potential social impacts associated with
the proposed project is the potential impacts on livelihoods of the farming community. Farmers may fear that
their land rights and property values will be affected. The project will require access to farms, and because of
the current socio-political issues in South Africa, this is a sensitive matter. Farmers may also be concerned about
the impact of the Cluster 2 project on their existing way of life, and on the infrastructure on their farms. An
impact assessment of each of the below impacts has been undertaken and a more detailed description of each
impact is provided in the social specialist report in Appendix 4. Furthermore, each of the below impacts is
relevant to the construction and operational phases.
• Impact on livelihoods
• Impact of servitudes on land values
• Damage to farm roads, existing services, and infrastructure
• Impacts on safety and security of local residents
• impacts on sense and spirit of place
• Impacts on the social licence to operate
• Public perceptions about safety associated with gas production
• Contribution to economy of South Africa
• Secondary economic opportunities
• Potential opportunity for education, skills development, and training.
• The Tetra4 community liaison officer (CLO) must continue to deal with the affected landowners
throughout the life of the project.
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• In cases where there the farmer does not agree with the compensation offered by Tetra4 related to
loss of potential income due to exploration, construction or operational activities, Tetra 4 must appoint
an agricultural economist at their cost to determine what the actual losses will be to the farmers due
to the drilling and trenching activities on their properties. Farmers must be compensated for the actual
losses for the entire period that they cannot use the land due to Tetra’s activities. This may be one or
two years, depending on when in the season the drilling and trenching take place, and how long the
property is affected. The principles explained in the IFC Handbook for Preparing a Resettlement Action
Plan must be followed. This includes a land use/land capability inventory; an asset register and physical
asset survey; an income stream analysis and entitlement matrix. Compensation must be determined
with input from the landowners.
• If any existing livelihood activities will be affected negatively Tetra4 must enter into negotiations with
the affected parties as soon as reasonably achievable to ensure the affected parties are compensated
fairly or can make additional arrangements. Interference with existing livelihoods should be avoided if
possible. If any new activities are planned for a property, Tetra4 must consult with the landowner and
obtain his consent to execute the activity on his/her land.
• If any interference takes place and there are actual losses, the landowner should be compensated for
their losses. Tetra4 must have a claims procedure that is communicated to all affected landowners.
There must be specific timeframes dealing with response times and time it takes to close out
complaints. In order to receive compensation, the claim forms must be submitted to the Tetra4 CLO
Compensation should follow the IFC principles, which states that market related prices should be paid,
and if anything is restored, it must be to the same or better standards than before.
• If areas are fenced, the fences must be checked for snares on a daily basis for the duration of the
construction period. All incidences must be reported to the closest police station. Anti-poaching toolbox
talks should form part of the induction process of all the fencing teams. Any contractor or employee
caught poaching should be removed from site.
• Servitudes should only be registered for the life of the operations or as long as the well and pipeline in
use are productive. At the end of the life of operations, or when a well or pipeline is no longer
productive od used, servitudes must be de-registered at the cost of Tetra4. Servitudes cannot be seen
as access routes unless it has been specified as such and agreed on by both parties.
• Temporary access and land arrangements must be made until there are more certainty on exactly
where the wells will be. Servitudes should only be registered for productive wells.
• If private roads are affected by project activities, it is the responsibility of Tetra4 to maintain these
roads as long as they use it. Tetra4 should engage with the relevant farmers about road maintenance,
as some of them have preferential ways in which the roads must be maintained, for example if roads
are only graded and not built up it turns into rivers when there is heavy rain. The road maintenance
agreements must be formalised before construction and drilling commences to ensure all parties
involved are protected and know their rights and responsibilities. Tetra4 must make sure that all
compacting and rehabilitating of trenches are done to the specifications in the Environmental
Management Plan. It is recommended that construction and drilling be planned for the dry season.
Tetra4 must provide all the affected landowners with a construction and drilling schedule to ensure
that they know when construction will take place on their properties. Any changes to the construction
and drilling schedule must be communicated to the farmers at least a week in advance.
• Before the project commences Tetra4 should compile an asset and infrastructure baseline of any
landowner infrastructure such as fences, pipes, electricity lines, roads and troughs that may be affected
by the project. Photographs and GPS co-ordinates of the infrastructure must be included in the
baseline. A copy of the baseline affecting their property should be given to each landowner, who should
sign off the document to ensure that it is accurate. Tetra4 should keep the master document. If any
damage occurs it should be reinstated to its pre-project status. If the infrastructure must move, it must
be done at Tetra4’s cost. Tetra4 must ensure that the construction team has a copy of the asset and
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infrastructure baseline to guarantee that no infrastructure will be damaged due to ignorance during
the construction phase of the project.
• Tetra4 should work with the preferred farmers’ security group (Erfenis Veiligheid) and implement the
AgriSA farm access protocol for everybody that need to access the properties. Pictures, make and
registration numbers of all vehicles used by Tetra4 on site should be provided to the farmer’s security
group and distributed to all affected landowners to ensure that they will be able to identify these
vehicles if they access their properties. For scheduled and maintenance work Tetra4 should give a roster
to the farmers stating dates and approximate times that contractors will be on the farms. Farmers
emphasised that they need to know of people accessing the farm ahead of time. It is too late to inform
them when entering the property. All access arrangements should be made at least 24 hours before
access is required. Tetra4 must meet with the landowners before the construction and drilling phase
commence and formalise security arrangements. This should be done in writing and include the existing
forums that the landowners know and trust.
• All contractors and employees need to wear photo identification cards. Vehicles should be marked as
construction vehicles and should have Tetra4’s logo clearly exhibited. Entry and exit points of the site
should be controlled during the construction and drilling phase. Areas where materials are stockpiled
must be fenced. The schedules of the security company should be communicated to the farmers,
especially to those farmers that have Tetra4 infrastructure that need to be guarded. It must be
considered that guards changing shifts contribute to the impact of strangers accessing properties, and
therefore a system that consider the safety of both the Tetra4 infrastructure and the safety of the
landowners must be implemented. The necessary sanitation facilities must be made available, and
some form of shelter from the elements. The security guards must not be allowed to make fires for
cooking or heating purposes.
• A system to arrange access to properties must be devised and formalised. The landowners must agree
to the system. Access must be arranged at least 24 hours prior, except in emergencies, when the
landowners should also be informed immediately. Landowners have the right to refuse people access
to their properties if it was not arranged in advance. If routine access is required, the landowners must
be provided with a roster indicating dates and approximate times that access will be required. Tetra4
must compensate the landowners for any damage to property or goods if it was due to behaviour of
their contractors. Sub-contractors must be made aware of this and a clause spelling out their liability
should be included in their contracts
• It is difficult to mitigate the impact on sense of place as it is experienced on a personal level. In general,
the mitigation measures suggested in the visual, noise, ecological impact assessments and other
relevant specialist studies should be adhered to. The relevant specialists will provide scientific
mitigation measures for the aspects relevant to their studies. The direction and brightness of lights
close to residences must be considered. Pipeline markers on game farms must be camouflaged by
either painting it in a colour that blend in with the surrounding areas, or putting natural materials such
as branches or wooden poles around it. This must be done in consultation with the affected
landowners. Sense of place is a personal experience, but successful rehabilitation will go a long way in
recreating a rural sense of place. The public perception would be negative or positive depending on the
successful implementation of the rehabilitation.
• Tetra4 has a dedicated person that communicate with the landowners with whom they have a positive
relationship. It is important that this relationship is extended to the Cluster 2 landowners. Information
sharing, frequent communication and quick responses to issues/complaints/enquiries will assist Tetra4
with maintaining their SLO
• Tetra4 should compile a background information document (BID) explaining the process and potential
risks in laymen terms. This should be distributed to local stakeholders. Special sessions to inform the
farm workers in their native languages must be conducted. They can also consider a media awareness
campaign on local radio stations and press statements to local papers.
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• Tetra4 must become a member of the local firefighting association. Access routes and procedures in
case of any veld fire must be determined and shared with the firefighting association, farm owners and
Tetra4 staff.
• Wells and pipelines must be kept away from residences as far as possible
• Tetra4 should ensure that a good proportion of secondary economic opportunities are given to local
contractors. Services and goods must be procured locally as far as reasonably possible. Aspects of this
positive impact will occur by default when the construction force lives locally and they utilise local
services and support local shops.
• Tetra4 should liaise with local training institutions to determine whether there are any opportunities
to offer internships and practical experience for their students. Tetra4 must ensure that skills
development requirements form part of their contracts with sub-consultants. The skills development
requirements in their Social and Labour Plan (SLP) must be implemented. Tetra4 can liaise with local
schools to participate in science classes or bring science pupils to visit the facility once it is operational.
• The impact is unlikely to result in irreplaceable loss of resources but where this may occur, mitigation
measures shall be put forward to reduce this potential as far as possible.
ECONOMIC IMPACTS
The majority of the economic impacts of this project have been rated as positive with the impacts extending
from a local level, through to the region and also to a national level. In addition, the Gas Act makes provision for
black economic transformation and the provisions thereof is described in the BBBEE Act. This project will need
to comply with these provisions which compliance will have an obvious positive impact on economic
transformation. During the construction phase, the positive impacts on the local economy will be the greatest
(through employment opportunities as well as material and contractor requirement) while during the
operational phase the economic impacts move towards a more regional and national level when gas production
and distribution is in full swing. From an economic perspective, the decommissioning phase would represent a
negative impact due to the local, regional and national financial and general economic benefits from the project
effectively ceasing.
The following economic impacts relating to all phases of the project have been identified:
• GGP/GDP Impact
• Forex savings
• Fiscal Income
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landowners.
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probable that the impact will result in spatial and temporal cumulative positive economic change.
• The impact may result in the irreplaceable loss of resources however the value of these resources would
be limited.
GROUNDWATER IMPACTS
The potential impacts on groundwater resources associated with the operational phase activities include the
following:
• Migration of saline groundwater from the deep, fractured aquifer to the overlying, shallow freshwater
aquifer(s) during the gas production phase.
• Migration of stray methane (CH4) gas from the deep, fractured aquifer to the overlying, shallow
freshwater aquifer(s) during the gas production phase.
• Groundwater pollution as a result of wastewater spills and seepage from the evaporation dams.
• Poor quality leachate may emanate from the plant footprint area which may have a negative impact on
pollution.
• Leakage of harmful substances from tanks, pipelines or other equipment may cause groundwater
pollution.
• Leachate of contaminants used in the drilling mud sump(s) to the intergranular, potable aquifer(s)
during the operational phase.
The environmental significance rating of the following potential impacts is rated as high negative without the
implementation of mitigation measures and medium negative with the implementation of mitigation measures.
• Migration of saline groundwater from the deep, fractured aquifer to the overlying, shallow freshwater
• Migration of stray methane (CH4) gas from the deep, fractured aquifer to the overlying, shallow
freshwater aquifer(s) during the gas production phase.
The environmental significance rating of the following potential impacts is rated as medium negative without
the implementation of mitigation measures and low negative with the implementation of mitigation measures.
pollution.
• Leakage of harmful substances from tanks, pipelines or other equipment may cause groundwater
pollution.
• Leachate of contaminants used in the drilling mud sump(s) to the intergranular, potable aquifer(s)
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The environmental significance rating of the following potential impact is rated as low negative without the
the operational phase.
• All exploration wells should be sealed-off with a combination of casing and grouting to ensure isolation
of the saline water from the host-aquifer(s).
• Development and implementation of an integrated groundwater monitoring program evaluating
hydrochemistry will serve as early warning and detection mechanism to implement mitigation
measures.
• Monitoring results should be evaluated and reviewed on a biannual basis by a registered hydrogeologist
for interpretation and trend analysis for submission to the Regional Head of Department. Based on the
water quality results, the monitoring network should be refined and updated every three to five years
based on hydrochemical results obtained to ensure optimisation and adequacy of the proposed
localities.
• The calibrated groundwater flow model should be updated on a bi-annual basis as newly gathered
monitoring results become available in order to be applied as groundwater management tool for future
scenario predictions.
• All exploration wells should be sealed-off with a combination of casing and grouting to ensure isolation
of the gas from the host-aquifer(s).
• An appropriately sized spill kit must kept onsite and available at all times. The spill kit size must be
relevant to the scale of the activities involving the use of hazardous substances.
• The responsible operator must have the required training to make use of the spill kit in emergency
situations.
• Plant areas must be fitted with a containment facility for the collection of dirty water. This facility must
be impervious to prevent soil and groundwater contamination. Ii.
• The plant area must have a concrete slab that is sloped to facilitate runoff into a collection sump.
• Operational vehicles and machinery must be serviced and maintained regularly in order to ensure that
to be conducted.
• Workshop areas must be monitored for oil and fuel spills, and a suitable oil/water separator should be
in place where maintenance work on vehicles and equipment can be performed. .
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• All hazardous substances used on-site should have an applicable Material Safety Data Sheet (MSDS) to
provide information regarding the hazards, emergency response, protective measures and correct
storage methodology.
• Hazardous substance containment facilities to be used during operational phase should comply with
the relevant hazardous substance storage legislation in order to ensure spillages are contained.
• All hazardous substances and material used on-site should be stored in a dedicated, closed-off facility
with an impervious floor and bunded area to prevent seepage and/or run-off in case of accidental spills.
• Annual external audits should be conducted to ensure that pipelines and waste facilities are maintained
and functioning effective and according to licence conditions.
• The Licensee shall appoint a suitably qualified and responsible person to give effect to all
recommendations as stipulated in specialist reports to ensure compliance to licence conditions
pertaining to activities in order to ensure that potential impact(s) are minimised, and mitigation
measures proposed are functioning effectively.
• A stormwater management plan in accordance with GN704, separating dirty/contact water from clean
water circuits, should be in place until all decommissioning and rehabilitation activities have been
concluded.
• A rehabilitation plan must be developed based on site-specific issues and requirements including soft
and hard engineering interventions and revegetation.
• An ECO must be appointed to oversee the rehabilitation phase and ensure least possible harm to
biodiversity and ensure compliance to the rehabilitation plan.
The activities expected during the operational phase involve the operation of the well pad, pipelines,
compression station and LNG/LHe beneficiation plant, movement of trucks and other vehicles, general and
hazardous waste management, gas processing as well as operation of road tankers for gas distribution. The
potential environmental impacts and mitigation measures during the operational phase are listed below.
• Disturbance to soil and ongoing erosion as a result of periodic maintenance activities.
• Altered water quality as a result of increased availability of pollutants.
• Potential increase in the number of alien and/or invasive vegetation as a result of floods or people who
visit the site.
(vii) Mitigation measures
• No movement of construction equipment through the watercourses may be permitted during standard
operational activities or maintenance activities. Use must be made of the existing and/or approved
watercourse crossings only.
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• Regular conditional inspections of all stormwater infrastructure are required. Inspection data must be
recorded and accumulated for tracking purposes. Regular reporting should be scheduled management
task.
• Specific attention must be given to inspection during and after any rain and/or flood event to kerb any
damage that may have occurred.
• Oil recovered from construction vehicles and machinery should be collected, stored and disposed of by
accredited vendors for recycling.
(viii) Cumulative Impacts
(ix) Irreplaceable loss of Resources
Most of the biodiversity within the study area has been fragmented and impacted on by existing land uses
including agriculture, farmsteads, roads powerlines and other infrastructure as well as mining. Due to the spatial
extent of the proposed Cluster 2 infrastructure, a variety of terrestrial biodiversity areas exist. These range from
low sensitive (e.g. agricultural areas etc) to highly sensitive areas (e.g. pristine areas, wetlands and watercourses
as well as areas where red data species occur). Furthermore the study area contains CBA1 and ESA 1&2 areas.
The ecological integrity, importance, and functioning of these terrestrial biodiversity areas provide a variety of
ecological services that are considered beneficial, with one key service being the maintenance of biodiversity.
The preservation of these systems is the most important aspect to consider for the proposed project. Thus, if
these areas are not maintained in a natural or near natural state, destroyed or fragmented further, then meeting
targets for biodiversity features will not be achieved.
The following operational phase impacts have been identified and assessed in this report:
• Tetra4 must timeously control alien and invasive species in all areas disturbed by project specific
construction.
• Use existing access roads as much as possible. Rehabilitate disturbed areas as soon as possible.
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The impacts that have been identified on aquatic and wetland systems during the operational phase include
altered surface flow dynamics; erosion; alteration of sub-surface flow dynamics; sedimentation of the water
resource; direct and indirect loss of wetland areas; water quality impairment; compaction; decrease in
vegetation; change of drainage patterns; altering hydromorphic properties; altered surface flow dynamics;
erosion; alteration of sub-surface flow dynamics; indirect loss of wetland areas; water quality impairment;
compaction; decrease in vegetation; change of drainage patterns; and altering hydromorphic properties.
• Maintenance and inspection vehicles and machinery must make use of existing and pre-defined access
routes.
• All waste generated on-site must be adequately managed. Separation and recycling of different waste
materials should be supported.
The operational phase will include an increase in traffic, ongoing maintenance and anthropogenic activities
associated with the extraction of gas. It is worth noting that the bulk of the impacts would have already been
associated with the construction phase, with the remainder of the operational activities only being associated
with the already developed areas. The operational phase of the compressors and wells includes anthropogenic
movement, together with the physical extraction of gas. Besides compaction and erosion caused by increased
traffic, few aspects are expected to be associated with this phase. The operational phase of the pipelines will
include infrastructure being maintained and monitored regularly, with no other expected impacts potentially
threatening the land capability.
• If a spill occurs, it is to be cleaned up immediately and reported to the appropriate authorities.
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VISUAL IMPACTS
be up to 300 production wells, booster and compressor stations, LNG/LHe plant and a 4km long 132kV overhead
After decommissioning, visual impacts will reduce due to the removal of operational plant etc. Since the affected
landscape is relatively flat and open, no mitigation is feasible.
• Locate wells and compressor stations a minimum 250m from homesteads.
• Undertake rehabilitation.
• Re-establish agricultural uses.
• Undertake screen planting between the R30 and the proposed production plant if possible.
DECOMMISSIONING REHABILITATION AND CLOSURE PHASE IMPACTS

AIR QUALITY IMPACTS
The assumption is that decommissioning would be during day-time hours only. Given the nature of
decommissioning activities, and the extent of the process, NAAQS limits for residential areas may be exceeded
sporadically at AQSRs. Mitigation measures, however, can be implemented to reduce emissions due to fugitive
dust. The negative air quality impacts are therefore considered to be of medium significance without mitigation
and low significance with mitigation at the nearest receptors.
• In controlling vehicle entrained PM, it is recommended that water be applied on all unpaved road
sections to ensure a minimum of 50% control efficiency (CE). In addition, binding agents or chemical
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suppressants (such as “Dust-A-Side” or “Dustex”) should be considered for application on all unpaved
road sections.
• For topsoil management during construction and rehabilitation, the existing EMPr (nr 35) should be
amended to include the recommendation that exposed areas must be ensured to remain moist through
water spraying during dry, windy periods (CE 50%).
• During all phases, material transfers are to be controlled through the use of water sprays resulting in
50% control efficiency.
• The following good practice should be followed during all phases of the project: In order to ensure
lower exhaust emissions from vehicles and machinery, equipment suppliers or contractors should be
required to ensure compliance with appropriate emission standards for production fleets. Also,
maintenance and repair of diesel engines should be carried out as prescribed by manufacturer in order
to maximize combustion and reduce gaseous emissions.
As operations progress, the previously cleared areas that form part of the project will be rehabilitated resulting
in a carbon sink gain. Even assuming rehabilitation uses the same indigenous vegetation, the carbon balance will
not be completely restored. There may also be potential soil degradation due to stockpiling. However, there is
insufficient data at this point to determine the decommissioning GHG emissions and significance thereof during
the decommissioning phase. This is likely to be equivalent or less than the construction phase, with the
reestablishment of a carbon sink in the revegetation of the site.
NOISE IMPACTS
The assumption is that decommissioning would be during day-time hours only. Given the nature of
decommissioning activities, and the extent of the process, IFC noise guidelines for residential areas may be
exceeded sporadically at NSRs. Attenuation measures, however, can be implemented to reduce noise levels. The
negative noise impacts are therefore considered to be of medium significance without mitigation and low
significance with mitigation at the nearest receptors.
• Regular and effective maintenance of equipment are essential to noise control. Increases in equipment
noise are often indicative of eminent mechanical failure. Also, sound reducing equipment/materials
can lose effectiveness before failure and can be identified by visual inspection.
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ECONOMIC IMPACTS
Whilst the construction phase and operational phase economic impacts were largely rated as highly positive,
the decommissioning phase would represent a negative impact due to the local, regional and national financial
and general economic benefits from the project effectively ceasing.
The following economic impacts relating to the decommissioning phase of the project have been identified:
• GGP/GDP Impact
• Forex savings
• Fiscal Income
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landowners.
unlikely that the impact will result in spatial and temporal cumulative positive economic change.
• The impact is unlikely to result in irreplaceable loss of recourses.
GROUNDWATER IMPACTS
The potential impacts on groundwater resources associated with the decommissioning phase activities include
the following:
• Migration of saline groundwater from the deep, fractured aquifer to the overlying, potable aquifer(s)
during the borehole closure and decommissioning phase.
• Migration of stray methane (CH4) gas from the deep, fractured aquifer to the overlying, potable
aquifer(s) borehole closure and decommissioning phase.
• De-mobilisation of heavy vehicle and machinery as part of the decommissioning phase on-site may
cause hydrocarbon contamination of groundwater resources.
The environmental significance rating of the following potential impacts is rated as medium negative without
the implementation of mitigation measures and medium negative with the implementation of mitigation
measures.
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• Migration of saline groundwater from the deep, fractured aquifer to the overlying, potable aquifer(s)
• Migration of stray methane (CH4) gas from the deep, fractured aquifer to the overlying, potable
The environmental significance rating of the following potential impacts is rated as low negative without the
• De-mobilisation of heavy vehicle and machinery as part of the decommissioning phase on-site may
the construction phase.
• "Contractor to prepare a consolidated site-specific closure/sealing plan to be submitted for approval.
The plan should include a detailed description of the following aspects:
o Calliper Logging should be conducted to identify and investigate potential blockages/cavities
within well.
o Cement Bond Logging should be performed to investigate the current integrity of the casing
and cementation.
o Contractor to determine the most suitable and appropriate closure, sealing and rehabilitation
strategy with specific focus on the plugging method to ensure no vertical gas and/or fluid
movements within the well.
o Develop cement formulation for cementing the entire well annulus.
o Develop cement formulation to top-up “no bond” or “poor bond” cemented sections between
casing and formation walls – ensure cement seals and does not disperse into porous
formations.
o Cement formulations and volumetric calculations to be approved by well engineer/cement
specialist.
o Contractor must ensure cement mixture seals the entire well length along the well annulus.
o Cement plugs must be stacked along the full length and diameter of the well to surface (open
hole section above the packer as well as the upper casing) to ensure efficient redundancy.
o All plugs must be tagged to ensure successful placement.
o Cementation extent: Should be from end of hole (bottom of well) to surface.
o Cementation technique: Squeeze technique - this displacement method minimizes the
contamination of the cement by being able to displace fluid within the well, thus allowing for
a more stable well plug. Contractor must also make use of wiper plugs for cement
displacement.
o Contractor to conduct cement top-ups along the annulus and existing cemented sections
showing “no bond” or “poor bond” from logging results.
o A surface / shallow cement plug (+/ 50m below ground Level) must be set, and the well casing
must be cut and capped 1 m below ground level to remove the wellhead and all casing above
this point.
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o Integrity of the plugs must be confirmed by setting weight down on the upper most plug (using
the drill string) as well as a differential pressure test for 4 hours at determined pressure with
less than 10% bleed over the period. Pressure test data to be captured in 15-minute intervals
for the entire 4-hour testing period. "
• Development and implementation of a post-closure groundwater monitoring program evaluating
hydrochemistry will serve as early warning and detection mechanism to implement mitigation
measures.
• A rehabilitation plan must be developed based on site-specific issues and performed in accordance to
best practise guidelines and guided by the closure and rehabilitation plans.
• An ECO must be appointed to oversee the rehabilitation phase and ensure least possible harm to
biodiversity and ensure compliance to the rehabilitation plan.
• Operational vehicles and machinery must be serviced and maintained regularly in order to ensure that
to be conducted.
• Workshop areas must be monitored for oil and fuel spills, and a suitable oil/water separator should be
in place where maintenance work on vehicles and equipment can be performed. .
The decommissioning phase involves the removal of all berms, trenches and other storm water infrastructure,
stationary infrastructure, certain pipeline surface infrastructure and wastes. As the pipelines that cross the
watercourse will not be removed during decommissioning (i.e. no further surface or subsurface disturbance),
the hydrological impact on is minimal/negligible.
The potential hydrological impacts that have been identified during the decommissioning phase include the
following:
• Increased erosion due to construction vehicles movement.
• Stormwater Contamination resulting from spillages of polluted groundwater from wells
• Potential increase in the number of alien and/or invasive vegetation as a result of floods or people who
visit the site.
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(x) Mitigation measures
• Topsoil removed during construction must be stored on site for rehabilitation and re-vegetation. The
soil must be stabilised using materials such as netting or geotextiles where necessary.
• The site shall be re-instated to its original condition as far as possible. No foreign material generated /
deposited during decommissioning shall remain on site.
• Rehabilitate disturbance areas as soon as decommissioning in an area is completed.
• All wells should be capped to prevent the spilling of contaminated groundwater.
(xi) Cumulative Impacts
(xii) Irreplaceable loss of Resources
The majority of the biodiversity within the study area has been fragmented and impacted on by existing land
uses including agriculture, farmsteads, roads powerlines and other infrastructure as well as mining. Due to the
spatial extent of the proposed Cluster 2 infrastructure, a variety of terrestrial biodiversity areas exist. These
range from low sensitive (e.g. agricultural areas etc) to highly sensitive areas (e.g. pristine areas, wetlands and
watercourses as well as areas where red data species occur). Furthermore the study area contains CBA1 and ESA
1&2 areas. The ecological integrity, importance, and functioning of these terrestrial biodiversity areas provide a
variety of ecological services that are considered beneficial, with one key service being the maintenance of
biodiversity. The preservation of these systems is the most important aspect to consider for the proposed
project. Thus, if these areas are not maintained in a natural or near natural state, destroyed or fragmented
further, then meeting targets for biodiversity features will not be achieved.
The following decommissioning and rehabilitation phase impacts have been identified and assessed in this
report:
• Use existing access roads as much as possible. Rehabilitate disturbed areas as soon as possible.
• Compile and implement an alien plant control program with a particular focus on alien control in
watercourses (including wetlands) during the rehabilitation phase of the project. Rehabilitate disturbed
areas as soon as possible. Restrict new footprints to disturbed areas as far as possible. Regular
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monitoring should be undertaken in the watercourses to check any possible invasion by alien
vegetation so that they can be weeded out before they grow and spread out.
The impacts that have been identified on aquatic and wetland systems during the decommissioning and
rehabilitation phase include altered surface flow dynamics; erosion; alteration of sub-surface flow dynamics;
sedimentation of the water resource; direct and indirect loss of wetland areas; water quality impairment;
compaction; decrease in vegetation; change of drainage patterns; altering hydromorphic properties; altered
surface flow dynamics; erosion; alteration of sub-surface flow dynamics; indirect loss of wetland areas; water
quality impairment; compaction; decrease in vegetation; change of drainage patterns; and altering
hydromorphic properties.
• All vehicles and machinery must make use of existing access routes as much as possible.
• Spill kits must be available to ensure that any fuel or oil spills are clean-up and discarded correctly.
• All machinery and equipment should be inspected regularly for faults and possible leaks, these should
be serviced off-site.
• All contractors and employees should undergo induction which is to include a component of
environmental awareness. The induction is to include aspects such as the need to avoid littering, the
reporting and cleaning of spills and leaks and general good “housekeeping”.
• Adequate sanitary facilities and ablutions on the servitude must be provided for all personnel
throughout the application area. Use of these facilities must be enforced (these facilities must be kept
clean so that they are a desired alternative to the surrounding vegetation).
• All waste generated on-site during decommissioning must be adequately managed. Separation and
recycling of different waste materials should be supported as a first priority and only thereafter
disposed of at a suitably waste disposal facility.
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The decommissioning/closure phase for the proposed activities will result in similar impacts to the construction
phase, in that infrastructure will be removed and the application area disturbed once again. The rehabilitation
phase is expected to reduce the overall negative impact significance for selected aspects such as the removal
and rehabilitation of roads.
• Prevent any spills from occurring. Machines must be parked within hard park areas and must be
checked daily for fluid leaks.
• Invasive plant control must be undertaken quarterly.
• Rip compacted soil and return topsoil to ensure that good vegetation cover is achieved.
• Only indigenous species are to be used in rehabilitation and revegetation.
VISUAL IMPACTS
be up to 300 production wells, booster and compressor stations, LNG/LHe plant and a 4 km long 132 kV overhead
After decommissioning, visual impacts will reduce due to the removal of operational plant etc. Since the affected
landscape is relatively flat and open, no mitigation is feasible.
• Rehabilitate disturbed area and reinstate agricultural usage.
• Remove all above ground infrastructure.
• Return land to pre-construction use.
• Minimise disturbance of the natural landscape.
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• Ensure that temporary lighting minimises light spill outside the area that it is intended to light.
NO-GO ALTERNATIVE
The no-go alternative option means ‘do nothing’ or the option of not undertaking the proposed Cluster 2 project
or any of its activities, consequently leading to the continuation of the current land-use. As such, the ‘do nothing’
alternative or keeping the current status quo of the various current land uses also provides the baseline against
which the impacts of all other alternatives were compared.
Should the Cluster 2 project not go ahead, there would be certain impacts identified above which would change
from negative to positive (mostly biophysical and cultural impacts) and conversely certain impacts would change
from positive to negative (mostly social and economic impacts).
10.3 SUMMARY OF IMPACT ASSESSMENT

A summary of all the identified impacts, their associated phases, as well as their impact calculations and
significance are presented in Table 57 below. This impact assessment has been informed by the final specialist
studies following due consideration of comments received during the scoping review process.
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Table 57: EIA Phase Impact Assessment.
IMPACT DESCRIPTION Pre-Mitigation Post Mitigation Priority Factor Criteria
Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Nature
Nature
Impact
Extent
Extent
Phase
Air Quality - Increase
in air quality impacts
1 Air Quality Alternative 1 Construction -1 3 1 3 2 4 -9 -1 3 1 3 2 3 -6.8 Medium 2 1 -8
due to construction of
the road/pipeline
2 Air Quality due to construction of Alternative 1 Construction -1 3 1 4 2 4 -10 -1 3 1 3 2 3 -6.8 Medium 2 1 -8
the wells and booster
stations
3 Air Quality due to construction of Alternative 1 Construction -1 3 2 4 2 4 -11 -1 3 2 3 2 3 -7.5 Medium 2 1 -8
the plant and
compressor stations
4 Air Quality due to the operation Alternative 1 Operation -1 3 4 3 2 4 -12 -1 2 4 2 2 3 -7.5 Medium 2 1 -8
of vehicles on
unpaved roads
5 Air Quality Alternative 1 Operation -1 3 4 3 2 4 -12 -1 3 4 2 2 3 -8.3 Medium 1 1 -8
due to operation of
the booster stations
6 Air Quality Alternative 1 Operation -1 2 4 2 2 3 -7.5 -1 2 4 2 2 3 -7.5 Medium 1 1 -8
due to operation of
the plant
7 Air Quality due to Alternative 1 Decommissioning -1 3 2 4 2 4 -11 -1 3 2 3 2 3 -7.5 Medium 1 1 -8
decommissioning and
closure
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Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Climate Change risk
8 Climate Change due to Scope 1 & 2 Alternative 1 Construction -1 1 2 5 3 -8 -1 1 1 5 3 -7 Low 2 2 -9
construction
Climate Change risk
9 Climate Change due to Scope 1 & 2 Alternative 1 Operation -1 4 3 5 3 -12 -1 4 2 5 3 -11 Medium 3 2 -15
construction
Noise - Increase in
noise levels due to
10 Noise Alternative 1 Construction -1 3 2 4 2 4 -11 -1 3 2 3 2 3 -7.5 Medium 1 1 -8
construction of the
pipeline
Noise - Increase in
noise levels due to
11 Noise construction of the Alternative 1 Construction -1 3 3 4 2 4 -12 -1 3 3 3 2 3 -8.3 Medium 1 1 -8
wells and Blower
Stations
Noise - Increase in
noise levels due to
12 Noise construction of the Alternative 1 Construction -1 3 3 3 2 3 -8.3 -1 3 3 2 2 3 -7.5 Medium 1 1 -8
Plant and Compressor
Stations
Noise - Increase in
noise levels due to
13 Noise Alternative 1 Operation -1 3 4 2 3 3 -9 -1 3 4 2 3 2 -6 Medium 1 1 -6
Blower Station
operation
Noise - Increase in
noise levels due to
14 Noise Alternative 1 Operation -1 3 4 2 3 3 -9 -1 3 4 2 3 2 -6 Medium 1 1 -6
Plant and Compressor
Station operation
Noise - Increase in
15 Noise Alternative 1 Decommissioning -1 3 2 4 2 4 -11 -1 3 2 3 2 3 -7.5 Medium 1 1 -8
noise levels
Groundwater
deterioration and
16 Geohydrology siltation due to Alternative 1 Construction -1 2 2 2 2 2 -4 -1 2 2 1 2 1 -1.8 Medium 1 1 -2
contaminated
stormwater run-off
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Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
from the construction
area.
Poor quality leachate
may emanate from
the construction camp
17 Geohydrology Alternative 1 Construction -1 3 2 3 3 3 -8.3 -1 2 2 2 3 2 -4.5 Medium 2 2 -6
which may have a
negative impact on
Mobilisation and
maintenance of heavy
vehicle and machinery
on-site may cause
18 Geohydrology Alternative 1 Construction -1 3 5 4 4 3 -12 -1 2 5 4 4 2 -7.5 Medium 2 2 -9
hydrocarbon
contamination of
groundwater
resources.
Poor storage and
management of
hazardous chemical
19 Geohydrology substances on-site Alternative 1 Construction -1 3 2 3 3 3 -8.3 -1 2 2 2 3 2 -4.5 Medium 2 2 -6
may cause
groundwater
pollution.
Migration of saline
groundwater from the
deep, fractured
20 Geohydrology aquifer to the Alternative 1 Operation -1 3 5 5 5 4 -18 -1 3 5 4 4 3 -12 Medium 2 2 -15
overlying, potable
aquifer(s) during the
gas production phase.
Migration of stray gas
from the deep,
fractured aquifer to
21 Geohydrology Alternative 1 Operation -1 3 5 5 5 4 -18 -1 3 5 4 4 3 -12 Medium 2 2 -15
the overlying, potable
gas production phase.
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Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Groundwater
pollution as a result of
22 Geohydrology wastewater spills and Alternative 1 Operation -1 3 5 4 4 3 -12 -1 2 5 4 4 2 -7.5 Medium 2 2 -9
seepage from the
evaporation dams.
may emanate from
the plant footprint
23 Geohydrology Alternative 1 Operation -1 3 5 4 4 3 -12 -1 2 5 4 4 2 -7.5 Medium 2 2 -9
area which may have
a negative impact on
Mobilisation and
maintenance of heavy
vehicle and machinery
on-site may cause
24 Geohydrology Alternative 1 Operation -1 3 2 3 3 3 -8.3 -1 2 2 2 3 2 -4.5 Medium 2 2 -6
hydrocarbon
contamination of
groundwater
resources.
Poor storage and
management of
hazardous chemical
25 Geohydrology substances on-site Alternative 1 Operation -1 3 5 4 4 3 -12 -1 2 5 4 4 2 -7.5 Medium 2 2 -9
may cause
groundwater
pollution.
Leakage of harmful
substances from
tanks, pipelines or
26 Geohydrology Alternative 1 Operation -1 3 5 4 4 3 -12 -1 2 5 4 4 2 -7.5 Medium 2 2 -9
other equipment may
cause groundwater
pollution.
Migration of saline
groundwater from the
27 Geohydrology deep, fractured Alternative 1 Decommissioning -1 3 3 5 5 4 -16 -1 2 2 4 4 3 -9 Medium 2 2 -11
aquifer to the
overlying, potable
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Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
borehole closure and
decommissioning
phase.
Migration of stray gas
from the deep,
fractured aquifer to
the overlying, potable
28 Geohydrology Alternative 1 Decommissioning -1 3 3 5 5 4 -16 -1 2 2 4 4 3 -9 Medium 2 2 -11
aquifer(s) borehole
closure and
decommissioning
phase.
Groundwater
pollution as a result of
29 Geohydrology wastewater spills and Alternative 1 Decommissioning -1 3 3 3 4 2 -6.5 -1 2 2 2 3 1 -2.3 Medium 1 2 -3
seepage from the
evaporation dams.
may emanate from
the plant footprint
30 Geohydrology Alternative 1 Decommissioning -1 3 3 3 4 2 -6.5 -1 2 2 2 3 1 -2.3 Medium 1 2 -3
area which may have
a negative impact on
De-mobilisation of
heavy vehicle and
machinery as part of
the decommissioning
31 Geohydrology phase on-site may Alternative 1 Decommissioning -1 3 3 3 4 2 -6.5 -1 2 2 2 3 1 -2.3 Medium 1 2 -3
cause hydrocarbon
contamination of
groundwater
resources.
Hydrology - Loss of
32 Hydrology watercourse Alternative 1 Construction -1 2 1 1 2 2 -3 -1 2 1 1 2 1 -1.5 Low 2 1 -2
vegetation
33 Hydrology Erosion Alternative 1 Construction -1 1 2 1 2 4 -6 -1 1 1 2 2 2 -3 Low 2 1 -3
1473 EIA Report 314

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Stormwater
34 Hydrology Alternative 1 Construction -1 1 2 2 2 4 -7 -1 1 1 2 2 2 -3 Medium 2 1 -3
contamination
35 Hydrology Alternative 1 Construction -1 3 4 3 3 2 -6.5 -1 2 2 1 2 1 -1.8 Low 2 1 -2
Vegetation
Alterations of the
36 Hydrology river banks and river Alternative 1 Construction -1 2 2 2 3 3 -6.8 -1 2 2 1 2 2 -3.5 Medium 2 2 -4
bed
37 Hydrology Erosion Alternative 1 Operation -1 2 4 3 2 2 -5.5 -1 2 4 3 2 1 -2.8 Low 2 2 -3
Stormwater
38 Hydrology Alternative 1 Operation -1 3 3 3 3 3 -9 -1 2 2 1 2 2 -3.5 Medium 2 2 -4
contamination
39 Hydrology Alternative 1 Operation -1 3 4 3 3 3 -9.8 -1 2 2 1 3 2 -4 Medium 2 2 -5
Vegetation
40 Hydrology Erosion Alternative 1 Decommissioning -1 2 3 3 2 2 -5 -1 2 3 3 2 1 -2.5 Low 2 2 -3
Stromwater
41 Hydrology Alternative 1 Decommissioning -1 3 3 3 3 3 -9 -1 2 2 1 2 2 -3.5 Medium 2 2 -4
contamination
42 Hydrology Alternative 1 Decommissioning -1 3 4 3 3 2 -6.5 -1 2 2 1 2 1 -1.8 Low 2 1 -2
Vegetation
Impact on
Heritage &
43 unidentified heritage Alternative 1 Construction -1 1 5 1 5 1 -3 -1 1 4 2 4 2 -5.5 Medium 2 3 -8
Palaeontology
resources
Heritage & Impact on burial
44 Alternative 1 Construction -1 2 4 5 5 4 -16 -1 1 4 2 5 2 -6 Medium 2 3 -8
Palaeontology grounds and graves
Heritage & Impact on historic to
45 Palaeontology recent sites with Alternative 1 Construction -1 2 4 4 5 3 -11 -1 1 4 2 5 2 -6 Medium 1 3 -8
possible graves
Heritage & Impact on structures
46 Palaeontology of medium heritage Alternative 1 Construction 1 1 5 3 5 3 10.5 -1 1 3 3 3 2 -5 Medium 2 2 -6
significance
Heritage & Impact on
47 Alternative 1 Construction -1 4 5 4 5 4 -18 -1 4 5 2 5 2 -8 Medium 2 3 -11
Palaeontology palaeontology
48 Social Impact on livelihoods Alternative 1 Construction -1 2 2 4 4 5 -15 -1 2 2 2 3 5 -11 High 2 2 -14
49 Social Impact on livelihoods Alternative 1 Operation -1 3 4 5 4 5 -20 -1 3 4 4 4 4 -15 High 2 3 -21
Impact of servitudes
50 Social Alternative 1 Operation -1 3 5 5 4 5 -21 -1 3 4 4 4 4 -15 High 3 2 -21
on land values
1473 EIA Report 315

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
51 Social Uncertainty Alternative 1 Planning -1 3 3 4 3 5 -16 -1 3 2 3 3 3 -8.3 High 2 2 -10
Nuisance factor due
52 Social to increase in ambient Alternative 1 Construction -1 2 2 3 3 5 -13 -1 2 2 3 3 4 -10 High 2 1 -11
dust and noise levels
Changes in travel
53 Social Alternative 1 Construction -1 2 2 4 2 5 -13 -1 2 2 3 2 4 -9 High 2 1 -10
patterns
Damage to farm
roads, existing
services, and
infrastructure
Damage to farm
roads, existing
services, and
infrastructure
Impacts on livelihoods
56 Social due to behaviour of Alternative 1 Construction -1 3 2 4 2 4 -11 -1 2 2 3 2 3 -6.8 High 2 1 -8
contractors
Impacts on safety and
57 Social security of local Alternative 1 Construction -1 3 2 5 3 4 -13 -1 3 2 3 3 4 -11 High 3 3 -17
residents
Impacts on safety and
58 Social security of local Alternative 1 Operation -1 3 4 5 3 5 -19 -1 3 4 4 3 4 -14 High 2 2 -18
residents
impacts on sense and
spirit of place
impacts on sense and
spirit of place
Impacts on the social
61 Social Alternative 1 Construction -1 3 2 4 3 4 -12 1 2 2 4 3 4 11 Medium 2 2 14
licence to operate
Impacts on the social
62 Social Alternative 1 Operation -1 3 4 5 3 4 -15 1 3 4 4 2 4 13 Medium 2 2 16
licence to operate
Increase in social
63 Social Alternative 1 Construction -1 3 2 3 3 4 -11 -1 3 2 3 2 4 -10 Medium 2 1 -11
pathologies
Public perceptions
64 Social Alternative 1 Operation -1 3 3 4 2 4 -12 -1 3 2 2 2 3 -6.8 Medium 1 1 -7
about safety
1473 EIA Report 316

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
associated with gas
production
Contribution to
65 Social economy of South Alternative 1 Operation 1 5 4 4 5 5 22.5 1 5 4 5 5 5 23.8 High 2 1 27
Africa
Secondary economic
66 Social Alternative 1 Construction 1 3 2 4 2 4 11 1 4 4 4 2 5 17.5 Medium 2 1 20
opportunities
Secondary economic
67 Social Alternative 1 Operation 1 3 4 4 2 4 13 1 4 4 4 3 5 18.8 Medium 2 1 21
opportunities
Potential opportunity
for education, skills
68 Social Alternative 1 Operation 1 3 4 4 2 4 13 1 4 4 4 3 5 18.8 Medium 2 1 21
development, and
training
Impact on Existing
69 Visual Agricultural Alternative 1 Construction -1 2 1 3 2 4 -8 -1 2 1 3 2 4 -8 Medium 2 1 -9
Landscape Character
Impact on Existing
70 Visual Agricultural Alternative 1 Operation -1 1 4 1 2 2 -4 -1 1 4 1 2 2 -4 Medium 2 1 -5
Landscape Character
Impact on Existing
71 Visual Agricultural Alternative 1 Decommissioning -1 2 4 2 2 4 -10 -1 1 1 1 1 1 -1 Medium 2 1 -1
Landscape Character
Impact on Existing
72 Visual Natural Landscape Alternative 1 Construction -1 2 1 3 2 4 -8 -1 1 1 2 2 2 -3 Medium 2 1 -3
Character
Impact on Existing
73 Visual Natural Landscape Alternative 1 Operation -1 2 4 2 2 3 -7.5 -1 1 4 1 1 2 -3.5 Medium 2 1 -4
Character
Impact on Existing
74 Visual Natural Landscape Alternative 1 Decommissioning -1 2 1 2 2 3 -5.3 -1 1 1 1 1 2 -2 Medium 1 1 -2
Character
The visual impact on
75 Visual Alternative 1 Construction -1 2 1 3 2 4 -8 -1 2 1 2 2 3 -5.3 Medium 2 1 -6
views from local roads
76 Visual Alternative 1 Operation -1 2 4 3 2 4 -11 -1 2 4 2 2 3 -7.5 Medium 2 1 -8
1473 EIA Report 317

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
77 Visual Alternative 1 Decommissioning -1 2 3 3 2 4 -10 -1 1 1 1 1 1 -1 Medium 1 1 -1
Change of Natural of
78 Visual Views from Alternative 1 Construction -1 2 4 4 2 4 -12 -1 2 1 1 2 3 -4.5 Medium 2 1 -5
Homesteads
79 Visual Views from Alternative 1 Operation -1 1 4 2 2 3 -6.75 -1 1 4 1 2 2 -4 Medium 2 1 -5
Homesteads
80 Visual Views from Alternative 1 Decommissioning -1 2 3 3 2 4 -10 -1 1 1 1 1 1 -1 Medium 1 1 -1
Homesteads
views from local
81 Visual Alternative 1 Construction -1 2 1 4 1 4 -8 -1 1 1 1 1 1 -1 Medium 1 1 -1
homesteads due to
Lighting
views from local
82 Visual Alternative 1 Operation -1 2 4 4 1 4 -11 -1 1 4 1 1 1 -1.8 Medium 1 1 -2
homesteads due to
Lighting
views from local
83 Visual Alternative 1 Decommissioning -1 2 1 4 1 4 -8 -1 1 1 1 1 1 -1 Medium 1 1 -1
homesteads due to
Lighting
Temporary
disturbance of wildlife
due to increased
84 Terrestrial human presence and Alternative 1 Planning -1 2 2 2 1 2 -3.5 -1 1 1 1 1 2 -2 High 1 1 -2
possible use of
machinery and/or
vehicles.
Destruction, further
loss and
85 Terrestrial fragmentation of the Alternative 1 Construction -1 2 2 4 3 4 -11 -1 2 2 3 2 4 -9 High 2 2 -11
vegetation
community
1473 EIA Report 318

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Introduction of alien
86 Terrestrial species, especially Alternative 1 Construction -1 2 3 3 2 3 -7.5 -1 1 2 2 3 3 -6 High 2 1 -7
plants
Erosion due to storm
87 Terrestrial Alternative 1 Construction -1 2 3 3 2 3 -7.5 -1 2 2 2 3 3 -6.8 Medium 2 1 -8
water runoff and wind
Displacement of
faunal community
due to habitat loss,
direct mortalities and
88 Terrestrial Alternative 1 Construction -1 2 3 4 3 3 -9 -1 1 3 3 3 3 -7.5 High 2 1 -8
disturbance (road
collisions, noise, light,
dust, vibration and
poaching).
Environmental
pollution due to
potential leaks,
89 Terrestrial discharges, pollutant Alternative 1 Operation -1 3 3 3 3 3 -9 -1 2 3 3 3 2 -5.5 High 1 1 -6
leaching into the
surrounding
environment
Continued
fragmentation,
further loss and
90 Terrestrial Alternative 1 Operation -1 2 4 3 2 4 -11 -1 2 3 3 3 3 -8.3 High 2 2 -10
vegetation
community
Vegetation loss due to
erosion and
91 Terrestrial encroachment by Alternative 1 Operation -1 2 4 3 2 3 -8.3 -1 2 3 2 2 2 -4.5 Medium 2 1 -5
alien invasive plant
species
Potential leaks,
discharges, pollutant
from activities
92 Terrestrial Alternative 1 Operation -1 3 3 3 3 3 -9 -1 2 3 2 3 3 -7.5 High 1 1 -8
leaching into the
surrounding
environment
1473 EIA Report 319

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Continued
displacement and
faunal community
(including threatened
or protected species)
due to ongoing
93 Terrestrial anthropogenic Alternative 1 Operation -1 2 4 3 3 4 -12 -1 2 3 3 3 2 -5.5 High 2 1 -6
disturbances (noise,
dust and vibrations)
and habitat
degradation/loss
(litter, road
mortalities and/or
poaching).
Continued
encroachment of
vegetation
94 Terrestrial community by alien Alternative 1 Decommissioning -1 2 2 3 3 3 -7.5 -1 2 3 2 2 2 -4.5 High 1 1 -5
invasive plant species
as well as erosion due
to disturbed soils
Continued
displacement and
faunal community
(including potential
threatened or
95 Terrestrial protected species) Alternative 1 Decommissioning -1 2 2 3 3 3 -7.5 -1 2 3 2 2 2 -4.5 High 1 1 -5
due to ongoing
habitat
degradation/loss
(infringement, litter,
road mortalities
and/or poaching).
1473 EIA Report 320

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Construction of
96 Pedology compressors and Construction -1 2 2 3 3 3 -7.5 -1 2 2 3 3 3 -7.5 Medium 2 1 -8
wells
Construction of
97 Pedology pipelines and Construction -1 2 2 2 2 3 -6 -1 2 2 2 2 3 -6 Medium 2 1 -7
transmission loop
Operation of
98 Pedology Operation -1 2 4 3 2 3 -8.3 -1 2 4 3 2 2 -5.5 Medium 2 1 -6
Compressor and Wells
Operation of pipelines
99 Pedology Operation -1 2 4 2 2 3 -7.5 -1 2 4 2 2 2 -5 Medium 2 1 -6
and transmission loop
Decommissioning of
100 Pedology Compressors and Decommissioning -1 2 2 2 2 3 -6 -1 2 2 2 2 3 -6 Medium 2 1 -7
Wells
Decommissioning of
101 Pedology pipelines and Decommissioning -1 2 2 2 2 2 -4 -1 2 2 2 2 2 -4 Medium 2 1 -5
transmission loop
Exploration Wells -
102 Wetlands Alternative 1 Planning -1 2 2 2 2 2 -4 -1 2 2 3 2 1 -2.3 Medium 2 1 -3
Habitat
Exploration Wells -
Water Quality
Exploration Wells -
Flow
Pipelines and
105 Wetlands Transmission loop - Alternative 1 Construction -1 3 2 3 2 3 -7.5 -1 2 2 2 2 2 -4 Medium 2 1 -5
Habitat
Pipelines and
106 Wetlands Transmission loop - Alternative 1 Construction -1 2 2 2 1 2 -3.5 -1 2 2 2 1 2 -3.5 Medium 1 1 -4
Water Quality
Pipelines and
107 Wetlands Transmission loop - Alternative 1 Construction -1 1 1 2 2 2 -3 -1 1 1 2 2 2 -3 Medium 1 1 -3
Flow
Compressors Station
108 Wetlands Alternative 1 Construction -1 2 3 3 3 3 -8.3 -1 2 3 2 3 2 -5 Medium 2 1 -6
CS1 - Habitat
Compressors Station
109 Wetlands Alternative 1 Construction -1 2 2 2 1 2 -3.5 -1 2 2 2 1 2 -3.5 Medium 1 1 -4
CS1 - Water Quality
1473 EIA Report 321

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Compressors Station
110 Wetlands Alternative 1 Construction -1 1 1 2 2 2 -3 -1 1 1 2 2 2 -3 Medium 1 1 -3
CS1 - Flow
Compressors Station
CS1 - Habitat
Compressors Station
CS1 - Water Quality
Compressors Station
113 Wetlands Alternative 2 Construction -1 1 1 2 2 2 -3 -1 1 1 1 2 2 -2.5 Medium 1 1 -3
CS1 - Flow
Compressors CS2 -
Habitat
Compressors CS2 -
Water Quality
Compressors CS2 -
Flow
Compressors CS3 -
Habitat
Compressors CS3 -
Water Quality
Compressors CS3 -
Flow
Compressors CS3 -
Habitat
Compressors CS3 -
Water Quality
Compressors CS3 -
Flow
123 Wetlands Powerlines - Habitat Alternative 1 Construction -1 3 3 3 2 2 -5.5 -1 1 1 2 2 2 -3 Medium 1 1 -3
Powerlines - Water
124 Wetlands Alternative 1 Construction -1 1 1 1 1 2 -2 -1 1 1 2 1 1 -1.3 Medium 1 1 -1
Quality
125 Wetlands Powerlines - Flow Alternative 1 Construction -1 1 1 1 2 2 -2.5 -1 1 1 2 1 1 -1.3 Medium 1 1 -1
Access Roads -
Habitat
Access Roads - Water
Quality
128 Wetlands Access Roads - Flow Alternative 1 Construction -1 2 1 2 2 2 -3.5 -1 1 1 1 1 2 -2 Medium 1 1 -2
1473 EIA Report 322

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
LNG/LHe Plant -
Habitat
LNG/LHe Plant -
Water Quality
131 Wetlands LNG/LHe Plant - Flow Alternative 1 Construction -1 1 1 2 2 2 -3 -1 1 1 1 2 2 -2.5 Medium 1 1 -3
Pipelines and
132 Wetlands Transmission loop - Alternative 1 Operation -1 2 2 2 2 2 -4 -1 2 1 1 1 2 -2.5 Medium 2 1 -3
Habitat
Pipelines and
133 Wetlands Transmission loop - Alternative 1 Operation -1 2 2 2 1 2 -3.5 -1 1 1 1 1 2 -2 Medium 1 1 -2
Water Quality
Pipelines and
134 Wetlands Transmission loop - Alternative 1 Operation -1 1 1 2 2 2 -3 -1 1 1 1 1 1 -1 Medium 1 1 -1
Flow
Compressors Station
135 Wetlands Alternative 1 Operation -1 3 4 3 3 3 -9.8 -1 3 4 3 2 2 -6 Medium 2 1 -7
CS1 - Habitat
Compressors Station
136 Wetlands Alternative 1 Operation -1 2 2 2 1 2 -3.5 -1 2 2 2 1 2 -3.5 Medium 1 1 -4
CS1 - Water Quality
Compressors Station
137 Wetlands Alternative 1 Operation -1 2 2 2 2 2 -4 -1 2 2 2 2 2 -4 Medium 1 1 -4
CS1 - Flow
Compressors Station
CS1 - Habitat
Compressors Station
CS1 - Water Quality
Compressors Station
CS1 - Flow
Compressors CS2 -
Habitat
Compressors CS2 -
Water Quality
Compressors CS2 -
Flow
Compressors CS3 -
Habitat
Compressors CS3 -
Water Quality
1473 EIA Report 323

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Compressors CS3 -
Flow
Compressors CS3 -
Habitat
Compressors CS3 -
Water Quality
Compressors CS3 -
Flow
150 Wetlands Powerlines - Habitat Alternative 1 Operation -1 2 4 2 2 2 -5 -1 1 4 1 1 2 -3.5 Medium 1 1 -4
Powerlines - Water
Quality
152 Wetlands Powerlines - Flow Alternative 1 Operation -1 1 1 1 1 1 -1 -1 1 1 2 1 1 -1.3 Medium 1 1 -1
Access Roads -
153 Wetlands Alternative 1 Operation -1 3 4 3 2 3 -9 -1 1 4 2 2 2 -4.5 Medium 1 1 -5
Habitat
Quality
155 Wetlands Access Roads - Flow Alternative 1 Operation -1 2 4 2 2 2 -5 -1 1 4 1 1 2 -3.5 Medium 1 1 -4
LNG/LHe Plant -
Habitat
LNG/LHe Plant -
Water Quality
158 Wetlands LNG/LHe Plant - Flow Alternative 1 Operation -1 1 1 2 2 2 -3 -1 1 4 1 1 2 -3.5 Medium 1 1 -4
Pipelines and
159 Wetlands Transmission loop - Alternative 1 Decommissioning -1 3 2 3 2 3 -7.5 -1 2 2 2 2 2 -4 Medium 2 1 -5
Habitat
Pipelines and
160 Wetlands Transmission loop - Alternative 1 Decommissioning -1 2 2 2 1 2 -3.5 -1 2 2 2 1 2 -3.5 Medium 1 1 -4
Water Quality
Pipelines and
161 Wetlands Transmission loop - Alternative 1 Decommissioning -1 1 1 2 2 2 -3 -1 1 1 2 2 2 -3 Medium 1 1 -3
Flow
Compressors Station
162 Wetlands Alternative 1 Decommissioning -1 3 2 3 3 3 -8.3 -1 2 3 2 3 2 -5 Medium 2 1 -6
CS1 - Habitat
1473 EIA Report 324

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Compressors Station
163 Wetlands Alternative 1 Decommissioning -1 2 2 2 1 2 -3.5 -1 2 2 2 1 2 -3.5 Medium 1 1 -4
CS1 - Water Quality
Compressors Station
164 Wetlands Alternative 1 Decommissioning -1 1 1 2 2 2 -3 -1 1 1 2 2 2 -3 Medium 1 1 -3
CS1 - Flow
Compressors Station
CS1 - Habitat
Compressors Station
CS1 - Water Quality
Compressors Station
167 Wetlands Alternative 2 Decommissioning -1 1 1 2 2 2 -3 -1 1 1 1 2 2 -2.5 Medium 1 1 -3
CS1 - Flow
Compressors CS2 -
Habitat
Compressors CS2 -
Water Quality
Compressors CS2 -
Flow
Compressors CS3 -
Habitat
Compressors CS3 -
Water Quality
Compressors CS3 -
Flow
Compressors CS3 -
Habitat
Compressors CS3 -
Water Quality
Compressors CS3 -
Flow
177 Wetlands Powerlines - Habitat Alternative 1 Decommissioning -1 3 2 3 2 2 -5 -1 1 1 2 2 2 -3 Medium 1 1 -3
Powerlines - Water
178 Wetlands Alternative 1 Decommissioning -1 1 1 1 1 2 -2 -1 1 1 2 1 1 -1.3 Medium 1 1 -1
Quality
179 Wetlands Powerlines - Flow Alternative 1 Decommissioning -1 1 1 1 2 2 -2.5 -1 1 1 2 1 1 -1.3 Medium 1 1 -1
Access Roads -
Habitat
1473 EIA Report 325

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
Quality
182 Wetlands Access Roads - Flow Alternative 1 Decommissioning -1 2 1 2 2 2 -3.5 -1 1 1 1 1 2 -2 Medium 1 1 -2
LNG/LHe Plant -
Habitat
LNG/LHe Plant -
Water Quality
185 Wetlands LNG/LHe Plant - Flow Alternative 1 Decommissioning -1 1 1 2 2 2 -3 -1 1 1 1 2 2 -2.5 Medium 1 1 -3
186 Economic GGP Impact Alternative 1 Construction 1 4 2 5 5 4 16 1 4 2 5 5 4 16 High 1 2 18
187 Economic Employment Impacts Alternative 1 Construction 1 3 2 3 5 4 13 1 3 2 3 5 4 13 High 1 2 15
188 Economic Forex savings Alternative 1 Construction -1 5 2 1 5 3 -9.8 -1 5 2 1 5 3 -9.8 High 1 2 -11
189 Economic Fiscal Income Alternative 1 Construction 1 5 1 1 5 4 12 1 5 1 1 5 4 12 High 1 2 14
Economic
190 Economic development per Alternative 1 Construction 1 4 2 4 5 4 15 1 4 2 4 5 4 15 High 1 2 17
capita
191 Economic Alternative 1 Construction 1 5 2 4 5 4 16 1 5 2 4 5 4 16 Medium 1 2 18
Competitiveness
Black Economic
192 Economic Alternative 1 Construction 1 5 2 4 3 4 14 1 5 2 4 3 4 14 Medium 1 2 16
Transformation
193 Economic Alternative Land-use Alternative 1 Construction 1 2 2 1 2 5 8.75 1 2 2 1 2 5 8.75 High 1 2 10
194 Economic Need and Desirability Alternative 1 Construction 1 4 2 5 4 4 15 1 4 2 5 4 4 15 High 1 2 17
Impact on individual
195 Economic Alternative 1 Construction -1 3 2 3 2 3 -7.5 -1 3 2 3 2 3 -7.5 Low 1 2 -8
farmland values
196 Economic GGP Impact Alternative 1 Operation 1 5 4 5 5 5 23.8 1 5 4 5 5 5 23.8 High 3 2 33
197 Economic Employment Impacts Alternative 1 Operation 1 4 4 4 5 4 17 1 4 4 4 5 4 17 High 3 2 23
198 Economic Forex savings Alternative 1 Operation 1 5 4 4 5 4 18 1 5 4 4 5 4 18 High 3 2 25
199 Economic Fiscal Income Alternative 1 Operation 1 5 4 3 5 4 17 1 5 4 3 5 4 17 High 3 2 23
Economic
200 Economic development per Alternative 1 Operation 1 4 4 4 5 4 17 1 4 4 4 5 4 17 High 3 2 23
capita
1473 EIA Report 326

Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
201 Economic Alternative 1 Operation 1 5 5 5 5 4 20 1 5 5 5 5 4 20 Medium 3 2 28
Competitiveness
Black Economic
202 Economic Alternative 1 Operation 1 5 4 4 3 4 16 1 5 4 4 3 4 16 Medium 3 2 22
Transformation
203 Economic Alternative Land-use Alternative 1 Operation 1 2 4 1 2 5 11.3 1 2 4 1 2 5 11.3 High 3 2 15
204 Economic Need and Desirability Alternative 1 Operation 1 5 5 5 5 4 20 1 5 5 5 5 4 20 High 3 2 28
205 Economic Alternative 1 Operation -1 3 4 3 2 3 -9 -1 3 4 3 2 3 -9 Medium 3 2 -12
farmland values
206 Economic GGP Impact Alternative 1 Decommissioning -1 4 2 4 3 4 -13 -1 4 2 4 3 4 -13 High 1 1 -13
207 Economic Employment Impacts Alternative 1 Decommissioning -1 4 2 4 3 4 -13 -1 4 2 4 3 4 -13 High 1 1 -13
208 Economic Forex savings Alternative 1 Decommissioning -1 4 5 4 5 5 -23 -1 4 5 4 5 5 -23 High 1 1 -23
209 Economic Fiscal Income Alternative 1 Decommissioning -1 4 5 4 5 5 -23 -1 4 5 4 5 5 -23 High 1 1 -23
Economic
210 Economic development per Alternative 1 Decommissioning -1 4 2 4 3 4 -13 -1 4 2 4 3 4 -13 High 1 1 -13
capita
211 Economic Alternative 1 Decommissioning -1 5 5 3 5 4 -18 -1 5 5 3 5 4 -18 Medium 1 1 -18
Competitiveness
Black Economic
212 Economic Alternative 1 Decommissioning -1 3 5 3 5 4 -16 -1 3 5 3 5 4 -16 Medium 1 1 -16
Transformation
213 Economic Alternative Land-use Alternative 1 Decommissioning -1 2 2 4 4 5 -15 -1 2 2 4 4 5 -15 High 1 1 -15
214 Economic Need and Desirability Alternative 1 Decommissioning -1 4 2 5 4 4 -15 -1 4 2 5 4 4 -15 High 1 1 -15
215 Economic Alternative 1 Decommissioning 1 3 2 3 3 3 8.25 1 3 2 3 3 3 8.25 Medium 1 1 8
farmland values
216 Economic GGP Impact Alternative 1 Rehab and closure -1 4 5 4 5 5 -23 -1 4 5 4 5 5 -23 High 1 1 -23
217 Economic Employment Impacts Alternative 1 Rehab and closure -1 4 5 4 5 5 -23 -1 4 5 4 5 5 -23 High 1 1 -23
218 Economic Forex savings Alternative 1 Rehab and closure -1 4 5 4 5 5 -23 -1 4 5 4 5 5 -23 High 1 1 -23
219 Economic Fiscal Income Alternative 1 Rehab and closure -1 4 5 4 5 5 -23 -1 4 5 4 5 5 -23 High 1 1 -23
Economic
220 Economic development per Alternative 1 Rehab and closure -1 4 5 4 5 5 -23 -1 4 5 4 5 5 -23 High 1 1 -23
capita
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Cumulative Impact
Post-mitigation ER
Irreplaceable loss
Pre-mitigation ER
Reversibility
Reversibility
Alternative
Confidence
Magnitude
Magnitude
Probability
Probability
Final score
Discipline
Identifier
Duration
Duration
Impact
Nature
Nature
Extent
Extent
Phase
221 Economic Alternative 1 Rehab and closure -1 5 5 3 2 4 -15 -1 5 5 3 2 4 -15 Medium 1 1 -15
Competitiveness
Black Economic
222 Economic Alternative 1 Rehab and closure -1 3 5 3 5 4 -16 -1 3 5 3 5 4 -16 Medium 1 1 -16
Transformation
223 Economic Alternative Land-use Alternative 1 Rehab and closure -1 2 5 4 4 5 -19 -1 2 5 4 4 5 -19 High 1 1 -19
224 Economic Need and Desirability Alternative 1 Rehab and closure -1 4 5 5 4 4 -18 -1 4 5 5 4 4 -18 High 1 1 -18
225 Economic Alternative 1 Rehab and closure 1 3 2 3 3 3 8.25 1 3 2 3 3 3 8.25 Medium 1 1 8
farmland values
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11 FINAL SENSITIVITY ANALYSIS
Environmental sensitivity mapping provides a strategic overview of the environmental, cultural and social assets
in a region. The sensitivity mapping technique integrates numerous datasets (base maps and shapefiles) into a
single consolidated layer making use of Geographic Information System (GIS) software and analysis tools.
Environmental sensitivity mapping is a rapid and objective method applied to identify areas which may be
particularly sensitive to development based on environmental, cultural and social sensitivity weightings – which
is refined by specialists’ input within each respective specialist field based on aerial or ground-surveys.
Therefore, the sensitivity mapping exercise assists in the identification of sensitive areas within and surrounding
the proposed application area. Table 58 provides an overview of the sensitivity ranking system and Figure 122
provides a visual representation of the combined sensitivity mapping approach.
This sensitivity mapping approach allows for the identification of lower risk areas for positioning the project
infrastructure whilst protecting identified sensitive environmental areas/ features though more rigorous
mitigation (where possible). Areas identified as no-go would be fully excluded from any project related
development regardless of the level of mitigation put forward. Furthermore, environmental sensitivity is used
to aid in decision-making during consultation processes, forming a strategic part of environmental assessment
processes.
The compilation of this map has taken into consideration the individual raking of sensitivity by the following
respective specialist disciplines:
• Air quality & Health Risk;
• Geohydrology;
• Heritage (Note: Heritage sites are not visible on the combined sensitivity map due to the small scale of
these sites. Please refer to individual heritage sensitivity maps);
• Hydrology (1:100-year floodlines);
• Noise;
• Social;
• Soils and Agriculture;
• Terrestrial Biodiversity (including Aquatic and Wetlands); and
• Visual.
The individual sensitivity maps for the above mentioned studies are presented in Figure 123 to Figure 141 and
Figure 142 presents the risk based consolidated sensitivity/ composite map which provides an overlay of all
sensitivity areas however each specialist discipline sensitivities have various management and mitigation
measures. Work within the various sensitivity rankings must be managed according to the EMPr (Appendix 5) as
well as the recommendations in the individual specialist reports (Appendix 4).
The application area contains a range of low, medium and high sensitive areas as well as two no-go areas which
are as follows:
1. The Beatrix tailings storage facility has been designated as a no-go area due to the limitations of any
development on the facility (damage to this facility would be unacceptable).
2. An area assigned a Very High terrestrial theme sensitivity has been delineated on the farm Adamsons
Vley 655 (Portion 0) based on the presence of a protected faunal species. Previous attempts to relocate
this species have been unsuccessful and in situ conservation remains the preferred outcome. This area
should exclude any surface development infrastructure. Consultation and communication with the lead
or implementing agent for the sensitive species, Endangered Wildlife Trust (EWT), must be
implemented before any construction proximal to the specific area. Monitoring and Management of
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the species will be crucial throughout the lifetime of the project and must be discussed and
implemented in conjunction with the EWT.
The detailed specialist assessments of the receiving environment within the well and pipeline transects have
allowed specific mitigation measures to be put forward for these areas including the high, medium, low and
least concern areas and development within the transects must comply with the EMPr. The areas outside of the
well and pipeline transects have been assessed and ranked based on previous studies as well as desktop analysis
(including lidar imagery where possible) and therefore any activities outside of the ground-truthed transects
must follow a risk-based approach to determine what additional measures, if any, must be implemented. For
any minor4 infrastructure required outside of the well and pipeline transects, a risk-based approach will be
undertaken based on the following methodology:
• Infrastructure required within low sensitive areas can be undertaken and managed in line with
identified mitigation measures in the EMPr.
• Infrastructure located inside medium or highly sensitive sites on the sensitivity maps require a site-
specific pre-commencement assessment. The pre-commencement assessment must address the
sensitive aspects on site, as identified in the relevant specialist reports. The pre-commencement
assessment must be compiled by the site Environmental Officer (EO) with a suitable environmental
qualification and experience. All recommendations of the pre-commencement assessment must be
clearly recorded and thereafter implemented on site. The completeness and adequacy of the pre-
commencement assessment in respect of identifying and managing on site sensitivities must be
included in the monthly ECO reports and annual independent audit reports.
Table 58: Sensitivity rating system.
Sensitivity Rating Description Management Method

The inherent feature status and sensitivity is
already degraded. The proposed development
will not affect the current status and/or may
Least Concern Comply with EMPr
result in a positive impact. These features would
be the preferred alternative for infrastructure
placement.
The proposed development will not have a
Low significant effect on the inherent features status Comply with EMPr
and sensitivity.
Undertake risk-based assessment
The proposed development will negatively prior to final infrastructure
Medium
influence the current status of the feature. placement and then comply with
EMPr.
Undertake risk-based assessment
The proposed development will negatively
prior to final infrastructure
High significantly influence the current status of the
placement and then comply with
feature.
EMPr.
No development permitted under any No development permitted under
No-Go
circumstances. any circumstances.
4
By “minor” it is important to note that the intention is not to provide for carte-blanch development of areas
outside of the transects.
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Figure 122: Example of combined sensitivity mapping approach.
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Figure 123: Soils and Agricultural Sensitivity Map.
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Figure 124: Social Sensitivity Map.
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Figure 125: Hydrology sensitivity map (1:100-year floodlines).
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Figure 126: Geohydrology sensitivity map.
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Important
No-Go Area
Figure 127: Biodiversity (ecology, aquatic and wetlands) sensitivity map.
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Figure 128: Air quality sensitivity map.
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Figure 129: Noise sensitivity map.
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Figure 130: Visual sensitivity map.
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Figure 131: Map showing heritage sensitivity rating of identified heritage resources. See insets below.
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Figure 132: Heritage sensitivity rating of identified heritage resources. Inset A.
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Figure 133: Heritage sensitivity rating of identified heritage resources. Inset B.
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Figure 134: Heritage sensitivity rating of identified heritage resources. Inset C.
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Figure 135: Heritage sensitivity rating of identified heritage resources. Inset D.
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Figure 136: Heritage sensitivity rating of identified heritage resources. Inset E.
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Figure 137: Heritage sensitivity rating of identified heritage resources. Inset F.
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Figure 138: Heritage sensitivity rating of identified heritage resources. Inset G.
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Figure 139: Heritage sensitivity rating of identified heritage resources. Inset H.
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Figure 140: Heritage sensitivity rating of identified heritage resources. Inset I.
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Figure 141: Heritage sensitivity rating of identified heritage resources. Inset J.
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Figure 142: Combined sensitivity map.
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12 DECOMMISSIONING REHABILITATION AND CLOSURE
For a detailed description of the financial provision and costing for the proposed Cluster 2 gas production project,
please refer to Appendix 6 for a standalone Rehabilitation and Closure Report.
13 CONCLUSION AND RECOMMENDATIONS

The Scoping Phase of the EIA process pre-identified potential issues and impacts associated with the proposed
project and following the scoping consultation process, valuable comments were received from various I&APs
which the EAP and specialist team considered carefully in the drafting of this EIA phase reports. The EIA Phase
addressed those identified potential environmental impacts and benefits (direct, indirect and cumulative
impacts) associated with applicable phases of the project and recommendations made of appropriate mitigation
measures for potentially significant environmental impacts. The release of a draft EIA Report provides
stakeholders with an opportunity to verify that the issues they have raised through the EIA process had been
captured and adequately considered.
The EIA Phase aimed to achieve the following:
• Provide an overall assessment of the social, economic and biophysical environments affected by the
proposed project.
• Assess potentially significant impacts (direct, indirect and cumulative, where required) associated with
the proposed project.
• Identify and recommend appropriate mitigation measures for potentially significant environmental
impacts; and
• Undertake a fully inclusive public involvement process to ensure that I&APs are afforded the
opportunity to participate, and that their issues and concerns are recorded.
13.1 CONCLUSIONS FROM SPECIALIST STUDIES

The conclusions and recommendations of this EIA are the result of the assessment of identified impacts by
specialists, and the parallel process of public participation. The public consultation process has been extensive,
and every effort has been made to include representatives of all stakeholders in the study area. The main
conclusions from each of the specialist studies are presented below.
AIR QUALITY STUDY CONCLUSIONS

A quantitative air quality impact assessment was conducted for the planning and design, construction,
operation, decommissioning, rehabilitation and closure phase activities of the Tetra4 Cluster 2 Project. The
assessment included an estimation of atmospheric emissions, the simulation of pollutant levels and
determination of the significance of impacts. This section summarises the main findings of the impact
assessment.
The conclusions and recommendations of the assessment are summarised below:
• The receiving environment:
o The area is dominated by winds from the north-northeast and northeast, followed by northerly
and easterly winds with an average wind speed of 3.7 m/s.
o Ambient air pollutant levels in the project area are currently affected by the following sources
of emission: agricultural activities, gold mining and ore processing, fugitive and process
emissions, vehicle tailpipe emissions, household fuel combustion, biomass burning and
windblown dust from exposed areas.
o AQSRs such as residences and farm holdings are located within and beyond the project
boundary. Nearby towns include Welkom, Virginia, Bronville, Harmony and Theunissen.
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• Impact of the Project:
o Planning, design and construction phase impacts:
▪ Construction activities for the roads/pipeline, wells and booster stations (where the
location may vary depending on the gas reserves in the area) vehicle and equipment
(vehicle entrainment and vehicle exhaust gas), three compressor stations and the
plant might include land clearing, topsoil removal, material loading, bulk services
construction, hauling, excavation, back-filling, road construction (where necessary)
and traffic, rig-move/drilling, pipeline installation, and wind erosion of exposed areas.
▪ Resulting potential air quality health and nuisance impacts at the nearest residential
receptors resulted in a medium significance without mitigation and low significance
with mitigation. Worst-case simulated construction impacts are not anticipated to
occur over long intervals since construction activities will only last a few weeks and
peak activities will not be consistent over the specified period.
o Operational phase impacts:
▪ Potential air quality impacts, including health and nuisance impacts, as a result of
operational phase activities such as operation of the well pad, roads, pipelines,
compression station, booster station and combined LNG/LHe plant, as well as
associated emissions from movement of trucks and other vehicles, flaring (if
applicable), and gas processing as well as operation of heavy machinery.
▪ Vehicles on unpaved roads, and specifically the plant access road, even under
mitigated conditions are likely to result in medium significance at the nearest
receptors but will reduce to low significance should the road be paved.
▪ Air quality impacts due to booster station (generator) operations of medium
significance but low significance at the nearest receptors with mitigation measures in
place.
▪ Plant (flaring) operations are unlikely to result in exceedances of the respective
NAAQS’s and are therefore considered to be of low significance at the nearest
receptors.
o Decommissioning, rehabilitation and closure phase impacts:
▪ Potential air quality impacts, including health impacts as a result of decommissioning,
rehabilitation and closure phase activities such as decommissioning/ removal of all
berms, trenches and other storm water infrastructure, stationary infrastructure,
pipeline infrastructure, and wastes.
▪ The environmental risk was assigned a score of low significance due to localised
impacts of the various emissions, their temporary nature, and the likelihood that
these activities will not occur concurrently at all portions of the site.
In conclusion, it is the specialist opinion that the project may be authorised provided that the recommended air
quality management measures are implemented.
CLIMATE CHANGE STUDY CONCLUSIONS

A Climate Change Assessment (CCA) was conducted to determine the potential long term climate change
impacts as a result of the Tetra4 Cluster 2 operations. Greenhouse gas (GHG) emissions for the project were
calculated based on the Department of Forestry, Fisheries and Environment (DFFE) 2022 Methodological
guidelines for quantification of GHG emissions which are based on the Intergovernmental Panel on Climate
Change (IPCC) emission factors. This study considered Scope1, Scope 2 and Scope 3 emissions, where Scope 1
are the emissions directly attributable to the project and Scope 2 emissions are the emissions associated with
bought-in electricity. Scope 3 emissions consider the “embedded” carbon in bought-in materials and transport
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as well as the use of exported materials. Only Scope 1 emissions need to be quantified to be in line with the
DFFE guidelines; the addition of Scope 2 would place the assessment in line with the guidelines provided by the
International Finance Corporation (IFC).
The conclusions and recommendations of the assessment are summarised below:
• The region around Welkom and Virginia where Tetra4 Cluster 2 project is proposed to be developed is
likely to experience increased temperatures and extreme weather-related events in the future. Climate
change impacts will disproportionately affect under-developed communities that lack the physical and
financial resources to cope with the physical effects of climate change, such as droughts, floods and
increases in diseases.
• Scope- 1, 2 and 3 emissions were estimated based on emission factors and expected production rates
or raw material use. The main construction activities attributing to GHG emissions are well drilling, well
testing and well servicing followed by off-road mobile equipment. During operations, the electricity
bought from ESKOM (Scope 2) is the main source, followed by road transportation and gas process
venting (Scope 1). The main source of Scope 3 GHG emissions would be the end use of the LNG, but as
LNG will be replacing other fuels already in use, there will result in a reduction in indirect GHG
emissions.
• Construction- and operational-related GHG emissions from the proposed Tetra4 Cluster 2 project
cannot be attributed directly to any particular climate change effects, and, when considered in
isolation, will have a Low to Medium impact on the National GHG inventory total. The main GHG impact
is associated with downstream use of the LNG, i.e. Scope 3. GHG emissions per unit of gas combusted,
however, is less than per unit coal.
• Since climate change is a global challenge, there is a collective responsibility to address climate change
and Tetra4 has an individual responsibility to minimise its own negative contribution to the issue. It is
recommended that renewable energy (such as photovoltaic solar panels) be considered to replace/
reduce the reliance on ESKOM electricity which is likely to reduce the significance from the Tetra4
Cluster 2 project from Medium to Low, since ESKOM’s contribution to the operational phase is the main
source of GHG emissions. Also, the use of LNG instead of diesel will reduce the GHG footprint further.
Maintenance of vehicles and machinery, the implementation of a leak-detection program, and the
minimisation of flaring and venting would reduce the potential for GHG emissions.
• Once operational, it is recommended records be kept of actual fuel usage for transport of materials and
products, energy requirements, production rates, flare and venting rates and raw material consumption
for GHG reporting purposes and refinement of the emissions inventory.
Based on Tetra4 Cluster 2 Scope 1, 2 and 3 GHG emissions, it is the specialist opinion that the project may be
authorised due to its low to medium impact significance.
NOISE STUDY CONCLUSIONS

A summary of simulated noise levels due to project construction and operational activities area as follows:
• Construction activities:
o Activities were specified to take place during day-time hours only
o Exceedances of the day-time IFC noise guidelines for residential, educational, and institutional
areas (55 dBA) were as follows:
▪ Wells: Up to 400 m from activities.
▪ Pipeline: Up to 90 m from activities.
▪ Blower Stations: Up to 600 m from activities (this is a conservative estimate as

topography was not taken into account for these predictions).
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▪ Plant: Up to 420 m from Plant area.
▪ Compressor Stations: Up to 380 m from Compressor Station areas.
• Operational activities:
o Activities were assumed to take place continuously (24 hours per day)
o Exceedances of the night-time IFC noise guidelines for residential, educational, and
institutional areas (45 dBA) were as follows:
▪ Blower Stations: Up to 150 m from activities (this is a conservative estimate as

topography was not taken into account for these predictions).
▪ Plant: Up to 600 m from Plant area.
▪ Compressor Stations: Up to 120 m from Compressor Station areas.
It is recommended that general good practice measures for managing noise as set out in this report, be adopted
as part of the facility’s Environmental Management Plan. In the event that noise related complaints are received
short term (30-min to 24-hours in duration) ambient noise measurements should be conducted as part of
investigating the complaints. The results of the measurements should be used to inform any follow up
interventions.
The significance of project activities was found to be as follows:
• Construction activities:
o Wells, Blower Stations and pipeline: Significance rating was medium without mitigation and
low with mitigation.
o Compressor Stations and plant: Significance rating was low without and with mitigation.
• Operational activities:
o Blower Stations, Compressor Stations and plant: Significance was low without and with
mitigation
• Decommissioning activities: Significance rating was medium without mitigation and low with
mitigation.
Based on the findings of the assessment and provided the recommended general “good practice” management
and mitigation measures are in place, it is the specialist opinion that the project may be authorised.
ECONOMIC STUDY CONCLUSIONS

Matjhabeng has a relatively large economy compared to that of other SA municipalities, but its GGP has been
declining for years. Although the local economy still has a measure of critical mass that could provide continued
private consumption expenditure which could sustain it for quite some time, it requires new investments to
sustain itself.
The Matjhabeng economy is by all accounts finding a new equilibrium – an economy that is adjusting to declines
in mining employment and a stagnating population. The increase in government expenditure and perennial
agricultural activities are keeping the municipality’s decline in check, but if more mines close down its GGP and
formal employment is set to decline more. At present it is not sure what the impact of higher commodity prices
are on the local economy.
An investment such as that of Renergen will undoubtedly improve the economic prospects for the local
economy. Furthermore, both the economic quantitative and qualitative factors ought to be considered as
positive for the SA economy in general and therefore the project is supported from an economic perspective.
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GEOHYDROLOGY STUDY CONCLUSIONS
The project area’s surficial geology comprises mostly aeolian sands, quaternary deposits and isolated outcrops
of the Karoo Supergroup i.e., dolerite and sandstone/ shales, while the greater study area is generally also
underlain by rocks of the Witwatersrand Supergroup as well as the Ventersdorp Supergroup. Isolated patches
within the study area are also covered by alluvial sand deposits which is mainly associated with the Sand and
Doringriver floodplains and constrained by drainage patterns and riparian zones. The primary source of gas
originates from the Witwatersrand Supergroup as well as the shallower Karoo sediments.
The site is predominantly underlain by an intergranular and fractured aquifer system (d2) with the aquifer media
consisting mainly of fractured and weathered compact argillaceous strata. According to Vegter’s groundwater
regions delineated (2000) the study area can be classified as falling under the North-eastern Pan Belt region.
For the purposes of this investigation, four main hydrostratigraphic units/aquifer systems can be inferred in the
saturated zone:
i. A shallow quaternary and recent types of sediments (unconfined) are characteristically a primary
porosity aquifer associated with alluvium material deposited in flood plains of the main rivers traversing
the study area. These aquifers cover a large portion of the study area and are limited to a zone of
variable width and depth. The alluvial aquifer is specifically vulnerable to contamination as it there is a
direct connectivity with rivers and streams and associated high permeability.
ii. A shallow, intergranular aquifer (unconfined to semi-confined) occurring in the transitional soil and
weathered bedrock formations of the Karoo Supergroup rocks underlain by more consolidated bedrock.
Groundwater flow patterns usually follow the topography, discharging as natural springs at topographic
low-lying areas. Usually, this aquifer can be classified as a secondary porosity aquifer and is generally
unconfined with phreatic water levels. Due to higher effective porosity (n) this aquifer is most
susceptible to impacts from contaminant sources.
iii. An intermediate, fractured aquifer (semi-confined to confined) where pores are well-cemented and
do not allow any significant flow of water. Groundwater flow is dictated by transmissive secondary
porosity structures such as bedding plane fractures, faults, contact zones as well as fracture zones that
occur in the relatively competent Karoo Supergroup host rock. Fractured sandstones, mudstones and
shales sequences are considered as fractured rock aquifers holding water in storage in both pore spaces
and fractures. This aquifer system usually displays semi-confined or confined characteristics with
piezometric heads often significantly higher than the water-bearing fracture position. Although
generally low yielding, this aquifer is important to local groundwater users as it forms the sole source
of water supply in the region (Lea, 2017).
iv. A deeper, fractured aquifer (semi-confined to confined) where pores are well-cemented and do not
allow any significant flow of water. Groundwater flow is dictated by transmissive secondary porosity
structures such as bedding plane fractures, faults and contact zones fracture zones that occur in the
relatively competent Ventersdorp and Witwatersrand Supergroups host rock. Volcanic formations of
the Ventersdorp lavas can also act as aquicludes, restricting the vertical movement of groundwater.
Fractured quartzites of the Witwatersrand Supergroup are considered as fractured rock aquifers
holding water in storage in both pore spaces and fractures. Groundwater yields, although more
heterogeneous, can be expected to be higher than the weathered zone aquifer. This aquifer system
usually displays semi-confined or confined characteristics with piezometric heads often significantly
higher than the water-bearing fracture position.
The water in the deep aquifers is naturally saline due to their marine depositional history. It should be noted
that the shallow potable Karoo aquifers are separated from deep aquifer systems associated with the
Ventersdorp and Witwatersrand Supergroup formations by the 30.0 m thick dolerite sill (which may act as an
aquitard) that extends across the study area and by the 65.0 m thick Dwyka Tillite sedimentary deposit acting as
an aquiclude. It should furthermore be noted that, under natural conditions, there is very limited hydraulic
connectivity between the deep, fractured and shallow, intergranular aquifers.
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The hydraulic conductivity of sedimentary formations such as evident on site can range from 10E -6 – 10E-2 m/d.
Historical aquifer tests results confirm that the permeability of the shales is very low
(9E-4m/d). The hydraulic conductivity of fractured igneous rocks (i.e., dolerite) varies between 10E -6 – 10E-1 m/d,
while conductivity values for un-fractured igneous rocks (i.e., fresh dolerite sill) ranges between 10E -9 – 10E-6
m/d. The hydraulic conductivity of quaternary deposits and alluvial pockets associated with the drainage system
i.e., riverbed aquifers can be orders higher and can vary between 10E -2 – 10E1 m/d.
An approximation of recharge for the study area is estimated at ~4.0 % of MAP i.e., ~21.69 mm/a.
A total of 78 groundwater receptors i.e., boreholes, artesian wells, wind pumps as well as surface water features
were visited as part of the hydrocensus user survey which are largely applied for livestock watering and domestic
water supply purposes. Of the boreholes recorded, the majority are in use (>78.0 %) while ~17.0 % are not
currently being utilized.
The unsaturated zone within the study area is in the order of 0 (fully saturated to surface) to >26.0 m with a
mean thickness of approximately ~9.0 m. It should be noted that due to the argillaceous nature of the host
aquifer(s) the shallow water levels observed at some of the borehole localities can be attributed to clay/silt
lenses and be indicative of perched aquifer conditions and not necessarily represent the vadose zone.
Artesian conditions were observed at three of the boreholes visited namely HBH31, 21B as well as 8B which can
be indicative of semi-confined to confined aquifer conditions present or perched aquifer conditions. The
minimum water level was recorded at 0.0mbgl, while the deepest water level was measured at borehole locality
Mon-HDR1 (26.71 mbgl).
It is noted that most water levels suggest a decrease in water levels and recovering trend. The latter can be
attributed the onset of the wet cycle and above average rainfall events experienced with rainfall recharge
replenishing aquifer storage. It can be observed that there is a definite a relatively quick response to rainfall,
suggesting that recharge of the shallow, intergranular aquifer takes place without a prolonged lag effect.
Statistical analyses of the water level trends furthermore suggest that the local groundwater system is in quasi-
steady state conditions.
Analysed data indicate that the surveyed water levels correlate very well to the topographical elevation (R 2
<0.98). Accordingly, it can be assumed that the regional groundwater flow direction is dictated by topography.
Bayesian interpolation was used to interpolate the groundwater levels throughout the study area. The inferred
groundwater flow direction will be towards the lower laying drainage system(s) traversing the project area from
where groundwater will discharge as baseflow. The groundwater flow direction within the southern catchment
of the Sandrivier and Doringrivier, also in the vicinity of the proposed plant expansion footprint, will be in a
general northern direction, whereas the groundwater flow direction within the northern catchment of the study
area will be mostly in a south to southwestern direction.
The average groundwater gradient (i) of the shallow, weathered aquifer in the vicinity of the proposed plant
expansion footprint is relatively flat and calculated at a mean of 0.002, with a maximum of 0.003 in a south to
north orientation and a minimum of 0.001 in a general southeast to northwest orientation.
The expected seepage rate from contamination originating at the proposed plant expansion footprint as well as
associated infrastructure is estimated at an average of approximately 1.26 m/a, with a maximum distance of
~2.20 m/a in a southern to northern direction.
Under natural conditions this area exhibits certain regions where there is pronounced interaction between
surface and groundwater and regional drainages can be generally classified as influent or gaining stream
systems. The alluvial associated with the floodplains of the Sand - and Doringrivier forms a primary aquifer and
is directly connected with surface water resources, especially during high flow conditions.
The hydrochemical results of the hydrocensus boreholes water samples analysed suggest the overall ambient
groundwater quality is good with most macro and micro determinants falling within or below the SANS 241:2015
limits. Groundwater can be described as neutral, saline to very saline and hard to very hard. The groundwater
quality is impacted by the geological formations, which were deposited in shallow marine environments and are
therefore naturally saline.
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It is observed that most of the boreholes indicate elevated Nitrate (NO 3) concentrations. The latter may be
attributed to the agricultural land-use activities dominating the greater study area with elevated NO3
concentrations potentially derived from leachate of fertilizer to the local aquifer. It is noted that borehole
localities with elevated NO3 concentrations are generally situated within or directly down-gradient of planted
crop areas as well as near surface water features.
Surface water quality can be classified as moderate to good with Aluminium (Al) and Iron (Fe) being slightly
elevated. It should be noted that there is not a significant change in the downstream water quality compared to
the upstream quality with an increase in Aluminium (Al), however all surface water samples analysed suggest
elevated heavy metal concentrations i.e., Al and Fe.
Three distinct categories can be observed, Category A: Calcium-Bi-carbonate dominance which suggest a
recently recharged and unimpacted groundwater environment (majority of samples), Category B: Calcium-
Magnesium-Chloride dominance which indicate a static and disordinate environment as well as Category C:
Sodium-Potassium-Bi-carbonate dominance which indicate an area of dynamic groundwater environments.
The surface water samples analysed can be categorized as having Calcium-Magnesium-Chloride dominance
which indicate a static and disordinate environment, one would except a more Calcium-Bi-carbonate signature
from an unpolluted surface water source, however baseflow discharge present from the saline groundwater
resource will have an impact on the salinity of the surface water resources as is evident.
Comparison of different hydrochemical signatures observed suggest on-site boreholes to target a shallow, inter-
granular aquifer unit as well as a deeper (possibly intermediate, fractured aquifer unit) being more saline.
The Sodium-Potassium-Chloride dominance of the deep, fractured aquifer groundwater suggest extremely
saline conditions as expected.
According to the aquifer classification map of South Africa the project area is underlain by a “Minor aquifer”. It
should however be noted that the shallow, intergranular aquifer is important to local groundwater users as it
form the sole source of water supply in the region. Furthermore, the primary riparian zone aquifer is classified
as a major aquifer system due to its highly permeable nature as well as good water quality.
A GQM Index = 4 was calculated for the local aquifer system and according to this estimate, a “Medium” level
groundwater protection is required for this aquifer system. According to the DRASTIC index methodology
applied, the existing/proposed activities and associated infrastructure’s risk to groundwater pollution of the
shallow, intergranular aquifer is rated as “Moderate”, Di = 109.
A numerical groundwater flow and mass transport migration model was developed and calibrated in steady
state based on gathered site characterisation information which was applied as initial hydrogeological conditions
for transient simulations.
A scenario was simulated representing point source pollution plume migration of saline groundwater emanating
from leaking boreholes targeting the deep, fractured aquifer for the operational phase (20-year period). The TDS
pollution plume extend covers a total area of approximately 414.06 ha in the Karoo formations, reaching a
maximum distance of ~80.0 m in a radial pattern from the gas production borehole(s), and approximately 251.60
ha in the alluvial deposits, reaching a maximum distance of ~200.0 m in a radial pattern from the gas production
borehole(s) after a simulation period of 20-years. The simulation indicates that the following neighbouring
boreholes will potentially be intercepted by the simulated pollution plume HBH08, HBH41, HBH42, HBH43,
HBH63, HBH72, HBH73 and HBH74.
It can be noted that the pollution plume migration in the denser Karoo formations is sluggish while movement
in the unconsolidated alluvial deposits of the riparian zone suggest a larger flux.
It is evident that source term mass load contribution to existing neighbouring borehole situated near the gas
production borehole(s) does not exceed ~800.0 mg/l and ranges between 600 mg/l to 700.0 mg/l
A scenario was simulated representing point source pollution plume migration of stray methane (CH 4) gas
emanating from leaking boreholes targeting the deep, fractured aquifer for the operational phase (20-year
period). The CH4 pollution plume extend covers a total area of approximately 162.74 ha in the Karoo formations,
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reaching a maximum distance of ~50.0 m in a radial pattern from the gas production borehole(s), and
approximately 62.83 ha in the alluvial deposits, reaching a maximum distance of ~100.0 m in a radial pattern
from the gas production borehole(s) after a simulation period of 20-years. The simulation indicates that the
following neighbouring boreholes will potentially be intercepted by the simulated pollution plume HBH08,
HBH41, HBH42, HBH43, HBH63, HBH72, HBH73 and Tetra4 monitoring borehole 11A.
It is noted that the source term mass load contribution to existing neighbouring borehole situated near the gas
production borehole(s) remains below the EPA safety threshold (2011) of 10.0 mg/l and ranges between 0.01
mg/l to 1.50 mg/l.
A scenario was simulated with a pollution plume migration from the plant footprint areas for the operational
phase. The TDS pollution plume extend covers a total area of approximately 48.80 ha reaching a maximum
distance of ~110.0 m in a general north-northwest direction towards the lower laying drainage system(s) after a
simulation period of 20-years. The simulation indicates that no neighbouring boreholes or local drainages are
expected to be impacted on during the operational phase.
It is evident that the TDS mass load contribution to down-gradient receptors increase to a concentration of
between 200.0 – 800.0 mg/l, however, remains below the SANS 241:2015 limit of 1200.0 mg/l for the duration
of the simulation period.
It can be noted that the mass transport of the pollution plume is mostly limited to the shallow, intergranular
aquifer.
A scenario was simulated representing point source pollution plume migration of saline groundwater emanating
from leaking boreholes targeting the deep, fractured aquifer for the post-closure phase. The TDS pollution plume
extend covers a total area of approximately 643.70 ha in the Karoo formations, reaching a maximum distance of
~100.0 m in a radial pattern from the gas production borehole(s), and approximately 392.70 ha in the alluvial
deposits, reaching a maximum distance of ~250.0 m in a radial pattern from the gas production borehole(s) after
a simulation period of 50-years. The TDS pollution plume extend covers a total area of approximately 1 456.42
ha in the Karoo formations, reaching a maximum distance of ~150.0m in a radial pattern from the gas production
borehole(s), and approximately 769.70 ha in the alluvial deposits, reaching a maximum distance of ~350.0 m in
a radial pattern from the gas production borehole(s) after a simulation period of 100-years. The simulation
indicates that the following neighbouring boreholes will potentially be intercepted by the simulated pollution
plume HBH08, HBH41, HBH42, HBH43, HBH48, HBH50, HBH63, HBH72, HBH73, HBH74 as well as Tetra4
monitoring boreholes Mon 2057 and 11A.
It is noted that source term mass load contribution to existing neighbouring and monitoring boreholes situated
near the gas production boreholes ranges between 650.0 mg/l to >1200.0 mg/l. Furthermore, it is observed that
the SANS241:2015 limit is exceeded at borehole localities HBH63 and Mon 2057.
A scenario was simulated representing point source pollution plume migration of stray methane (CH4) gas
emanating from leaking boreholes targeting the deep, fractured aquifer for the post-closure phase. The CH 4
pollution plume extend covers a total area of approximately 414.06 ha in the Karoo formations, reaching a
maximum distance of ~80.0 m in a radial pattern from the gas production borehole(s), and approximately 141.37
ha in the alluvial deposits, reaching a maximum distance of ~150.0 m in a radial pattern from the gas production
borehole(s) after a simulation period of 50-years. The CH4 pollution plume extend covers a total area of
approximately 643.70ha in the Karoo formations, reaching a maximum distance of ~100.0 m in a radial pattern
from the gas production borehole(s,) and approximately 392.70 ha in the alluvial deposits, reaching a maximum
distance of ~250.0 m in a radial pattern from the gas production borehole(s) after a simulation period of 100-
years. The simulation indicates that the following neighbouring boreholes will potentially be intercepted by the
simulated pollution plume HBH08, HBH41, HBH42, HBH43, HBH48, HBH49, HBH63, HBH72, HBH73 as well as
Tetra4 monitoring boreholes Mon 2057 and 11A.
It is evident that source term mass load contribution to existing neighbouring and monitoring boreholes situated
near the gas production boreholes ranges between 0.50 mg/l to ~2.0 mg/l, however, remains below the EPA
safety threshold (2011) of 10.0 mg/l.
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A scenario was simulated with a pollution plume migration from the plant footprint areas for the post-closure
phase. The TDS pollution plume extend covers a total area of approximately 54.8 ha reaching a maximum
distance of ~170.0 m in a general north-northwest direction towards the lower laying drainage system(s) after a
simulation period of 50-years and covers a total area of approximately 71.20 ha reaching a maximum distance
of ~300.0 m in a general north-northwest direction towards the lower laying drainage system(s) after a
simulation period of 100-years. It is evident that the pollution plume potentially reaches the local drainages
system down-gradient of the plant footprint during the post-closure phase.
It is observed that the TDS mass load contribution to down-gradient receptors increase to a concentration above
the SANS 241:2015 limit of 1200.0 mg/l for the post-closure simulation period. It is noted that the TDS mass load
contribution increases to a percentage of ~10.0 % to the Sandrivier where the mass load contribution to the
Doringrivier increase to a percentage of ~2.0 % for the duration of the post-closure simulation period.
It should be noted that vast areas within the study area have been subjected to historical mining activities and,
as such, reflect modified to highly modified present ecological status. A total number of >15 000 historical
exploration wells have been drilled throughout the study area, some of which remain uncased and unsealed.
The latter may act as preferential pathways and conduits for groundwater flow and contaminant transport
mechanisms. As mentioned earlier an impact can be defined as any change in the physical-chemical, biological,
cultural and/or socio-economic environmental system that can be attributed to human and/or other related
activities. Accordingly, this already highly modified zones should form part of the impact significance rating and
risk approach.
During the construction phase the environmental significance rating of groundwater quality impacts on down-
gradient receptors are rated as medium negative without implementation of remedial measures and low
negative with implementation of proposed mitigation measures. The main impacts associated with the
construction phase activities include the following:
i. Groundwater deterioration and siltation due to contaminated stormwater run-off from the
construction area.
ii. Poor quality leachate may emanate from the construction camp which may have a negative impact on
iii. Mobilisation and maintenance of heavy vehicles and machinery on-site may cause hydrocarbon
iv. Poor storage and management of hazardous chemical substances on-site may cause groundwater
pollution.
During the operational phase the environmental significance rating of groundwater quality impacts on down-
gradient receptors are rated as medium to high negative without implementation of remedial measures and low
to medium negative with implementation of proposed mitigation measures. The main impacts associated with
the operational phase activities include the following:
i. Migration of saline groundwater from the deep, fractured aquifer to the overlying, potable aquifer(s)
during the gas production phase.
ii. Migration of stray methane (CH4) gas from the deep, fractured aquifer to the overlying, potable
iii. Groundwater pollution because of wastewater spills and seepage from the evaporation dams.
iv. Poor quality leachate may emanate from the plant footprint area which may have a negative impact on
v. Mobilisation and maintenance of heavy vehicle and machinery on-site may cause hydrocarbon
vi. Poor storage and management of hazardous chemical substances on-site may cause groundwater
pollution.
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vii. Leakage of harmful substances from tanks, pipelines or other equipment may cause groundwater
pollution.
viii. Leachate of contaminants used in the drilling mud sump(s) to the intergranular, potable aquifer(s)
During the decommissioning and post-closure phase the environmental significance rating of groundwater
quality impacts on down-gradient receptors are rated as medium negative without implementation of remedial
measures and low to medium negative with implementation of proposed mitigation measures. The main
impacts associated with the post-closure and decommissioning phase activities include the following:
i. Migration of saline groundwater from the deep, fractured aquifer to the overlying, potable aquifer(s)
ii. Migration of stray methane (CH4) gas from the deep, fractured aquifer to the overlying, potable
iii. Groundwater pollution because of wastewater spills and seepage from the evaporation dams.
iv. Poor quality leachate may emanate from the plant footprint area which may have a negative impact on
v. De-mobilisation of heavy vehicle and machinery as part of the decommissioning phase on-site may
The most significant impact of the project on the regional groundwater regime is deterioration of the potable
Karoo aquifer water quality as well as modification of the riparian zone primary porosity aquifer associated with
alluvium material deposited in flood plains. Groundwater is the sole water resource to the landowners and rural
communities within the study area and can thus be classified as a sole source aquifer. It can be concluded that,
should the prescribed mitigation and management measures, as stipulated in the groundwater management
plan, be implemented and honoured, the impacts associated with the project phases can be minimised. It is
important that an integrated groundwater monitoring program be developed and applied serving as an early
warning and detection mechanism to implement mitigation measures. The calibrated groundwater flow model
should be applied as groundwater management tool for future scenario predictions.
The following recommendations are proposed following this investigation:
i. Mitigation and management measures as set out in the groundwater management plan should be
implemented as far as practically possible. It should be noted that the mitigation and management
measures recommended in this report should be incorporated into the existing EMPr groundwater
management plan and do not substitute the existing mitigation measures, but rather supplement them.
ii. Any development and/or drilling which takes place within the primary porosity aquifer associated with
alluvium material deposited in flood plains must be avoided where possible and restricted if it cannot
be avoided.
iii. The identified hydrogeological sensitive areas and buffer zones delineated as part of this assessment
must be adhered to during the construction and operational phase activities. It is recommended that a
localised hydrocensus user survey be performed within a 500.0m radius of each proposed gas
production borehole situated within the riparian zone(s) and 350.0m radius of each proposed gas
production borehole situated within the Karoo formations in order to identify the presence of other
sensitive groundwater receptors and/or private boreholes. Accordingly, the gas production well design
must take the results of the hydrocensus into consideration, specifically with regard to the planning
and placement of boreholes as part of future drilling programmes.
iv. Additional monitoring boreholes should be established down-gradient of the existing and proposed
plant expansion footprints to evaluate the mass load contribution to sensitive environmental and
groundwater receptors. Drilling localities should be determined by means of a geophysical survey to
target lineaments and weathered zones acting as preferred groundwater flow pathways and
contaminant transport mechanisms.
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v. It is recommended that the revised monitoring program as set out in this report should be implemented
and adhered to. It is imperative that monitoring be conducted to serve as an early warning and
detection system. Monitoring results should be evaluated on a bi-annual basis by a suitably qualified
person for interpretation and trend analysis and submitted to the Regional Head: Department of Water
and Sanitation.
vi. The numerical groundwater flow modelling assumptions should be verified and confirmed. The
calibrated groundwater flow model should be updated on a biennial basis as newly gathered
monitoring results become available to be applied as groundwater management tool for future
scenario predictions.
vii. All preferred groundwater flow pathways which are in direct connection with surface topography such
as decommissioned gas production boreholes as well as historical mining exploration boreholes should
be sealed off and rehabilitated according to best practise guidelines.
HYDROLOGY STUDY CONCLUSIONS

Most impacts are considered to be easily detectable and the considered mitigation measures are easily
practicable therefore the risks associated with the development are considered to be low.
TERRESTRIAL BIODIVERSITY STUDY CONCLUSIONS

Based on the latest available ecologically relevant spatial datasets, the following information is pertinent to the
degraded and water resource habitats in the project area:
• It is recognised as a CBA 1 and ESA 1& 2 as per the Free State Conservation Plan; and
• Categorised as intact constituents of an EN ecosystem or CR river as identified by the National
Biodiversity Assessment.
The ecological integrity, importance, and functioning of these terrestrial biodiversity areas provide a variety of
ecological services that are considered beneficial, with one key service being the maintenance of biodiversity.
The preservation of these systems is the most important aspect to consider for the proposed project. Thus, if
these areas are not maintained in a natural or near natural state, destroyed or fragmented, then meeting targets
for biodiversity features will not be achieved.
Observation and species records during the field survey denote that certain habitats within the assessment area
were utilised by threatened flora and fauna species, comprising of:
• One flora species;
• Four (4) avifaunal species;
• Three (3) mammal species;
• One (1) reptile species; and
• One (1) amphibian species.
The completion of a comprehensive desktop study, in conjunction with the results from the field survey, suggest
there is a high confidence in the information provided. The survey ensured that there was a suitable groundtruth
coverage of the assessment area and major habitats and ecosystems were assessed to obtain a general species
(fauna and flora) overview and the major current impacts were observed.
The developer is urged to provide a layout or design which represents a compromise between the needs of the
development and the environmental concerns at the site, especially in regard to the very high/high sensitivity
areas. A potential suggested alternative could be to make use of the existing agricultural areas within the
surrounds.
The existence and importance of these habitats is regarded as crucial, due to the fauna species recorded as well
as the role of this intact unique habitat to biodiversity within a very fragmented and disturbed local landscape,
not to mention the sensitivity according to various ecological datasets.
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In order to ensure that the ecosystem and biodiversity is adequately protected it is strongly recommended that
a follow up survey to more accurately determine the population size and extent of Smaug giganteus
(Sungazer/Giant Dragon Lizard).
AQUATIC STUDY CONCLUSIONS

The baseline assessment established three main watercourses within the project area, namely the Sand River,
Doring River, and Boschluispruit, and a single system outside the project boundary, the Palmietkuilspruit.
Additionally, numerous ephemeral systems and wetlands occur throughout the project area. The ecological
assessment of the watercourses indicated moderate to large modifications attributed to varying land use,
namely agriculture, mining, and urban activities upstream of the project area on the Sand River (Virginia). The
land use activities have cumulatively resulted in a moderate deterioration in water quality, flow, and instream
habitat, and subsequently to the biotic communities within the systems. Despite modifications, the Sand River
met the Resource Quality Objectives for the reach, and all the water resources associated with the project area
are considered sensitive. Given the findings of this assessment, no pristine or natural waterbodies were
observed or expected in any of the project right areas, with the Doring River being classed as largely modified
(class D), the Boschluispruit as largely modified (class D), and the Sand River as moderately modified (class C).
The upper reaches of the Boschluispruit and several tributaries within the project area are characteristic of
wetland systems, and riparian zones and buffers were applied according to the wetland report (TBC, 2022). The
Sand, Doring and lower reaches of the Boschluispruit presented well defined riparian zones consisting of woody
vegetation. The soils along the watercourses are highly susceptible to erosion and considered sensitive to any
potential anthropogenic activities along these systems which could potentially compromise the ecological
integrity of the watercourses.
The water resources are poorly protected, and the ecosystems are critically endangered. Additionally, no
Freshwater Priority Areas are assigned to them. Labeobarbus kimberleyensis (Largemouth Yellowfish) is
expected within the Sand River and is the only species of conservational concern within the catchment and red
listed as Near Threatened due to habitat fragmentation and water quality deterioration. The species was not
collected during the survey, however, despite the absence of the species during the survey, the precautionary
approach would assume the species to be within the project area and would likely be collected with increased
sampling effort. The poorly protected nature of the systems indicates that strict mitigation measures should be
adhered to ensure no further deterioration of the watercourses should the project proceed.
The buffers determined for the lower foothill systems was calculated at 50 m, and for the ephemeral systems,
drainage lines and wetlands a buffer of 35 m.
The impact assessment considered both direct and indirect impacts, to the water resources. According to the
layout provided and the delineated riparian zones and applicable buffers, the compression station, and pipeline
crossings intersect with the water resources. Considering the pipelines are linear infrastructure, avoidance of
the watercourses is not possible, strict mitigation implementation is required to ensure the minimisation of
erosion and additional deterioration of the water resources are negated. The locality of compressor station CS1
falls within the riparian zone and buffer of the Sand River. This poses a moderate risk to the watercourse and
alternative sites should be selected as erosion of the banks is likely. The position of compressor stations CS2 and
CS3 are located within delineated wetlands and are addressed in the wetland specialist assessment.
Risks associated with the proposed infrastructure range from low to moderate, with the majority of moderate
risks being reduced to low with the implementation of adequate mitigation measures, however, activities within
the buffers and water resources remain moderate.
It is the specialist’s opinion that no fatal flaws have been identified for the proposed activities. The alternative
positioning of the compressor stations is preferred due to the avoidance of water resource sensitive areas. The
soils within the catchment are prone to erosion and care is required to ensure proposed activities do not
exacerbate erosion within the catchment. Monitoring of the aquatic resources is required during construction
and operational activities.
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A competent Environmental Control Officer (ECO) must oversee the construction activities and associated
concurrent rehabilitation measures undertaken, with watercourse areas as a priority. Two follow up ECO
assessments/audits must be carried out in the first and sixth months of operation. The ECO must be supplied
with a copy of this and the other specialists reports and must be familiar with the mitigation and
recommendations prior to construction.
WETLAND STUDY CONCLUSIONS

Natural wetlands classified as being channelled valley bottoms, depressions, hillslope seeps and unchanneled
valley bottom as well as artificial systems were identified within the study area. The Present Ecological State
(PES) of the wetlands ranges from “Seriously Modified” to ‘Moderately Modified”. Most modifications to
wetlands in the study area is from agricultural activities taking place in the wetland and their respective
catchments.
The Ecosystem Services of the wetlands range from “Moderately High” to “Moderately Low” for the study area.
The valley bottom scored overall higher ecosystem services scores due to their ability to regulate streamflow,
prevent flooding and helps with erosion control. The vegetation cover within the wetlands plays a major role in
the ecosystem services scores. All the wetlands delineated within the study area were rate to be “Moderately”
sensitive due to the relatively high protection status of the wet veg type and the low protection status of the
wetland itself.
The buffer zone calculated for the delineated wetlands is 35 m. This buffer zone will ensure the conservation of
the delineated wetlands from the proposed activities.
The impact assessment considered both direct and indirect impacts, to the water resources. It is evident that
the pipeline and the transmission loop will encroach into the delineated wetland areas. The buffers around the
wells and compressors also encroach into the wetland buffers but impacts can be avoided with the mitigation
provided.
All the risks were considered low (post-mitigation). No moderate post-mitigation risks are anticipated to occur
for the proposed project. Overall, the impacts associated with this service development are unlikely to negatively
impact water resources to any appreciable level provided that the suggested mitigations measures are
effectively implemented. Additionally, the project focusses on conveying gas, thus risks associated with leaks
are considered low.
It is the specialist’s opinion that no fatal flaws have been identified, and that the proposed activities may proceed
as have been planned. Given the fact that “Low” post-mitigation significance ratings were determined for various
aspects of the proposed project, it’s the specialist’s opinion that a General Authorisation could be applied for.
SOIL AND AGRICULTURE STUDY CONCLUSIONS

Three main sensitive soil forms were identified within the assessment area, namely the Avalon, Ermelo and
Griffin soil forms. The land capability sensitivities (DAFF, 2017) indicate land capabilities with “Low” and
“Moderate high” sensitivities, which correlates with the findings from the baseline assessment.
The assessment area is associated with arable soils, due to the type of soils which the DEA Screening Tool (2022)
also identified as high to very high sensitivity for field crops farming. However, the available climatic conditions
of low annual rainfall and high evapotranspiration potential severely limits crop production significantly resulting
in land capabilities with “Low” and “Moderate high” sensitivities. The land capabilities associated with the
regulated area are suitable for cropping and grazing, which corresponds with the current land use.
The final results indicate “Insignificant” to “Very Low” post-mitigation significance ratings for the proposed
components. It is therefore clear that the proposed activities are expected to have a minimal impact on land
potential resources. It is worth noting that some “High” sensitivity crop field areas were identified by means of
the DEA Screening tool (2022) which is not expected to be avoided throughout the life of the operation.
Therefore, stakeholder engagement must be undertaken to compensate land owners for high crop field land
use areas where necessary.
With this being considered, it is recommended that the proposed activities may proceed as have been planned.
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VISUAL STUDY CONCLUSIONS
Because the affected landscape areas are neither unique or protected and due to the fact that mitigation
measures should generally be effective in minimising landscape impacts and visual impact experienced by
potential receptors, there is no reason from a landscape and visual impact perspective that the project should
not proceed as long as listed mitigation measures are implemented.
13.2 PREFERRED ALTERNATIVES

The preferred alternatives are discussed in the sections below.
LOCATION ALTERNATIVES
Two location alternatives were assessed for Compressor Station 3 as listed below:
• CS3_L1 (Doorn River 330 (Portion 2))
• CS3_L2 (Palmietkuil 328 (Portion 6))
From an air quality and noise perspective, both alternatives are considered equally weighted with low negative
final impact significance and therefore either alternative is acceptable. The visual specialist assessment
identified the preferred compressor station 3 alternative as being CS3_L2 which is close to Compressor Station
2 and also within 1km of a local road whereas the alternative location is within 400m of a group of eight
homesteads and 1.3km of the R30.
From a social perspective, the landowner who owns Portion 2 of the farm Doorn Rivier 330 has specifically raised
his concern that the project infrastructure would significantly alter his visual sense of place.
As neither of the two location alternatives were highlighted as no-go or significantly flawed by any of the
specialist assessments, the CS3_L2 (Preferred Alternative) on the farm Palmietkuil 328 Portion 6 is considered
the preferred alternative.
LAYOUT ALTERNATIVES
Based on the sensitivity planning approach, two areas have been delineated as no-go areas. The first is the
Sibanye Beatrix tailings facility however there is no planned project infrastructure in this location and therefore
this no-go area is for information purposes. The second location identified as no-go is located in the north of the
application area on the farm Adamsons Vley 655 (Portion 0) as this area contains a very highly sensitive area due
to the presence of a protected species which cannot be relocated. This area includes proposed project
infrastructure (wells and pipelines) however based on this EIA assessment and as per the recommendation of
the Terrestrial Ecologist, the surface area within this buffered area must remain undisturbed and must be
treated as a no-go area. Consultation and communication with the lead or implementing agent for the sensitive
species, Endangered Wildlife Trust (EWT), must be implemented before any construction proximal to the specific
area. Monitoring and Management of the species will be crucial throughout the lifetime of the project and must
be discussed and implemented in conjunction with the EWT
NO-GO ALTERNATIVE
The no-go alternative has been considered as a baseline against all project impacts. This alternative is not
considered reasonable as no fatal flaws in the overall project plan have been identified. Where necessary, certain
restrictions on sensitive areas have been put forward as well as identification of no-go areas however the overall
project plan remains feasible.
13.3 ENVIRONMENTAL IMPACT STATEMENT

The findings of the specialist studies conclude that there are no environmental fatal flaws that should prevent
the proposed project from proceeding, provided that the recommended mitigation and management measures
are implemented. Based on the nature and extent of the proposed project, the limited level of disturbance
predicted as a result of the production activities, the findings of the specialist studies, and the understanding of
the significance level of potential environmental impacts, it is the opinion of the EIA project team and the EAP
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that the significance levels of the majority of identified negative impacts can generally be reduced to an
acceptable level by implementing the recommended mitigation measures and the project should be authorized
on condition that the below recommended conditions are included in the decision and that compliance with the
EMPr must be strictly adhered to.
13.4 RECOMMENDATIONS FOR INCLUSION IN INTEGRATED DECISION

In addition to the standard conditions of an integrated Environmental Authorisation, the following specific
conditions must be included in the EA to specifically add focus on the pertinent issues raised during this EIA
application process. This section was expanded upon to include additional specialist conditions as requested by
a landowner during the EIA comment period.
• If any deviations are to be undertaken from the designs and/or footprints of infrastructure or activities
to take place outside of the assessed well or pipeline transects (as indicated in the EIA/EMPr), Tetra4
must follow due process in terms of applications for Amendments where such applications are
determined to be required. The Competent Authority must be notified of any deviations and the
required amendment process confirmed with the Competent Authority prior to implementing any
deviations.
• Ensure that as much of the infrastructure as possible is sited away from agricultural lands.
• The identified drill site should, where possible, not infringe on the landowners’ surface activities.
• The location of the drilling site should be done so as to impact minimally on the daily activities of the
landowner. The location of the site should be consulted with the landowner.
• As far as possible, exploration wells should be constructed (drilled) outside of existing cultivated lands.
Where this is not possible, the final production well concrete bunkers must be located outside of
cultivated lands and the borehole and connecting pipeline must be at least 1.5 m below surface to
prevent interference with crop production activities.
• Tetra4’s activities will cause a certain level of economic displacement for some of the affected farmers.
In the event that the farmer disagrees with the compensation offered, the actual impact on their
livelihoods must be assessed by an agricultural economist or suitably experienced third party.
Compensation must be done according to international best practice.
• The impacts of servitudes on the land value of the affected properties must be considered and
mitigated by means of negotiation. If the negotiation process is unsuccessful, it must be arbitrated by
a suitably qualified third party. Once the preferred routing has been identified, Tetra4 must engage
with the affected landowners for consensus of the preferred final pipeline routing. The preferred or
final routing will be developed through reasonable negotiations with landowners for their respective
property. The agreed upon routing must be attached to Landowner agreements as a sketch plan and
indicate the provisional servitude area.
• Temporary access and land arrangements must be made until there are more certainty on exactly
where the wells will be. Servitudes should only be registered for productive wells.
• Tetra4 must take reasonable measures to prevent any disruption to the landowners’ use of the
properties (e.g. farming, crops, pivots, crop-dusting safety limitations, etc.). Landowners/tenants
should be compensated for loss of arable land in accordance with the landowner access agreements
(contracts).
• Adverse impacts on farming activities during the planting or harvesting season must be minimised as
far as possible however should tangible impacts occur during these times, adequate compensation
must be provided to the affected party.
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• If any damage is done to the property or harvest of the landowner, they must be compensated for their
losses.
• If any damage to landowners’ property occurs as a result of project activities, Tetra4 must carry the
cost of rehabilitation /repair /replacement and compensate the farmer for his losses. If needed an
external mediation process should be followed.
• There must be a formal procedure in place on how to report incidents and/or damage to landowner
property and a claims procedure to ensure records of all grievances are kept. To receive compensation,
the claim forms must be submitted to the Tetra4 CLO or suitable representative. Compensation should
follow the IFC principles, which states that market related prices should be paid, and if anything is
restored, it must be to the same or better standards than before.
• Tetra4 should engage with the relevant farmers about road maintenance, as some of landowners have
preferential ways in which the roads must be maintained. The road maintenance agreements must be
formalised before construction commences.
• Weed species should be eradicated at all disturbed areas. This must be monitored for a period following
rehabilitation to ensure that alien invasive plants do not establish themselves.
• Rehabilitate area to its original landform or as agreed to by the landowner, tenants and/or authorities.
• Landowners should be notified prior to accessing their land. The number and identity of workers, the
purpose of the visit and specific areas to be visited, should be provided in the notification.
• A procedure to arrange access to properties must be devised and formalised. All reasonable efforts
must be taken to obtain agreement on the procedure with the landowners and it must be formalised.
Access must be arranged at least 24 hours prior, except in emergencies, when the landowners should
also be informed immediately. If routine access is required, the landowners must be provided with a
roster indicating dates and approximate times that access will be required.
• Tetra4 must meet with the landowners before the construction phase commences and formalise
security arrangements in writing and where appropriate include the existing forums.
• If any new activities are planned for a property, Tetra4 must consult with the landowner and take
reasonable steps to obtain his consent to execute the activity on his/her land.
• Light (visual) impact should be kept to a minimum (e.g. use of full cut-off lighting fixtures if necessary).
• Affected landowners must be provided with the construction schedule and when revisions to the
schedule are made, these must be communicated to the affected landowners. Furthermore,
construction timeframes must be made clear to individual affected landowners prior to construction.
• The impacts of servitudes on the land value of the affected properties must be considered and
mitigated by means of negotiation. If the negotiation process is unsuccessful, it must be arbitrated by
a suitably qualified third party.
• Farm safety must be a priority and the landowners and Tetra4 must agree on security measures prior
to construction on their farms.
• Tetra4 must consult with landowners about any new work or potential changes that may take place on
their properties.
• Protocols on farm access, compensation, communication, and road maintenance must be agreed upon
and be in place before construction commences. The affected landowners must have input in the
development of these protocols.
• A grievance mechanism and claims procedure must be in place and shared with all the stakeholders
before the construction commences.
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• A special meeting must be conducted with farm workers and other vulnerable parties, in their mother
languages, to ensure that they understand the technical and safety aspects of the project.
• Construction activities may only take place during the daytime (sunrise to sunset) and no construction
personnel may remain on private land at night (sunset to sunrise).
• The separation distances as indicated in the air quality specialist study must be complied with for the
respective project phases and project components.
• Tetra4 must develop the following procedures and strict adherence with these procedures must be
undertaken at all times by all relevant project personnel:
o Pipeline Monitoring Maintenance Procedure
o Access Procedure
o Access Road Inspection and Maintenance Procedure
• The no-go area identified by the Terrestrial Ecologist on the farm Adamsons Vley 655 (Portion 0) must
be excluded from any surface development infrastructure. Consultation and communication with the
lead or implementing agent for the sensitive species, Endangered Wildlife Trust (EWT), must be
implemented before any construction proximal to the specific area. Monitoring and Management of
the species will be crucial throughout the lifetime of the project and must be discussed and
implemented in conjunction with the EWT.
• Tetra4 must implement a reasonable fine and/or disciplinary action where landowner access
agreements are not followed. Such fine or disciplinary action must be of a suitable value to deter
nonadherence with landowner access agreements.
• A revised landowner contract must be finalized prior to commencement of construction and Tetra4 will
engage with each individual affected landowner regarding the detailed planned works on their
properties.
• Tetra4 must share the works schedule per property prior to commencement of any activity onsite. This
communication will include details of the respective contractors that are appointed, provide the
affected landowners with a project schedule for their respective properties and any changes to the
schedule must be formally communicated in writing to the affected landowners prior to implementing
such changes.
• Once the preferred routing has been identified, Tetra4 must engage with the affected landowners for
consensus of the preferred final pipeline routing. The preferred or final routing will be developed
through reasonable negotiations with landowners for their respective property. The agreed upon
routing must be attached to Landowner agreements as a sketch plan and indicate the provisional
servitude area.
• Tetra4 must investigate alternative methods to remove condensation water within the pipe network
with the intention to limit or reduce the number of low points drains in the system. This may include
nitrogen purging lines to flush out the system.
• The annual NEMA audits undertaken by an independent auditor must specifically record any concerns
raised during the audit period in relation to safety and security and negative impacts on livelihoods of
affected landowners within the application area. Furthermore, the audit report must include detail on
how any such concerns have been dealt with.
• All workers must be educated on the need to ensure safety of surrounding communities and the public
in general. Road safety legislation must be complied with at all times with additional consideration of
the World Bank Group Environmental Health and Safety Guidelines. A community health and safety
plan inclusive of a Traffic Management Plan will be developed based on risks identified in consideration
of community health and safety.
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• Risks associated with the potential use of security personnel will be assessed prior to operations and a
security management plan will be developed if required and in accordance with IFC Performance
Standard 4.
• Renewable energy (such as PV Solar) should be considered to replace/ reduce the reliance on Eskom
electricity which, if implemented, would likely to reduce the operational phase climate change
significance from the project from Medium to Low, since Eskom’s contribution to the operational phase
is the main source of GHG emissions. Also, the use of LNG instead of diesel for power generation will
reduce the GHG footprint further.
• All references to “construction” in the EIA Report and EMPr shall be deemed to include commencement
of a listed activity and all exploration related activities. The terms “construction” and “exploration”
should be deemed to be synonymous in so far as they relate to disturbance of the receiving
environment.
1473 EIA Report 369

14 ASSUMPTIONS AND LIMITATIONS
The following assumptions and limitations relating to this EIA phase assessment should be noted:
14.1 GENERAL
• This study is based on the engineering designs and Reports provided by the applicant, and it is assumed
that no significant changes or deviations to the final designs will occur.
• In determining the significance of impacts, with mitigation, it is assumed that mitigation measures
proposed in the report are correctly and effectively implemented and managed throughout the life of
the project.
14.2 SOILS AND LAND CAPABILITY (AGRICULTURE)

• The assessment is based on auger points taken and observations on site. There may be variations in
terms of the delineation of the soil forms across the area;
• Due to the size of the proposed area only the key areas where infrastructure is located were focused
on, the remaining areas were predominantly delineated through means of desktop; and
• The GPS used for delineations is accurate to within five meters. Therefore, the delineation plotted
digitally may be offset by at least five meters to either side.
14.3 AIR QUALITY AND HEALTH RISK

• Project information required to calculate emissions for proposed operations was provided by Tetra4
and EIMS. Where necessary, assumptions were made based on common industry practice and
experience.
• Only routine emissions for the operational phase were estimated and simulated. Atmospheric releases
occurring as a result of non-routine conditions were not accounted for limited to emergency flaring at
the plant, with other non-routine releases expected to be minimal.
• Emission factors were used to estimate all fugitive and processing emissions resulting from plant,
construction activities and transport. These emission factors generally assume average operating
conditions.
• The access road from the R30 road to the plant was assumed to be unpaved for the purposes of the
assessment. As such, a worst-case scenario was modelled as the access road will be paved in future.
• The compressor stations were assumed to be electrically powered, whereas the booster stations were
assumed to use diesel generators.
• Flaring was simulated at the plant only (no flaring of wells was included). Throughput data were
provided for two designs (continuous and emergency design) and modelled accordingly.
• Assumptions on flare stack metrics were made based on similar operation elsewhere (Burger and
Akinshipe, 2014).
• It was assumed that no smoke/soot will be emitted by the flare.
• The impact assessment was limited to airborne particulates (including TSP, PM10 and PM2.5) and
gaseous pollutants from combustion and non-combustion machinery, including CO, NOx, VOCs and SO2.
• Nitrogen monoxide (NO) emissions are rapidly converted in the atmosphere into nitrogen dioxide
(NO2). NO2 impacts where calculated by using a NO2/NOx emission ratio of 0.2 (Howard, 1988).
• Planning and design, decommissioning, closure and rehabilitation phase impacts were not quantified.
Impacts associated with these phases are highly variable and generally less significant than construction
and operational phase impacts. Mitigation and management measures recommended for the
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construction and operational phases are however also applicable to the planning and design,
decommissioning, closure and rehabilitation phases.
14.4 CLIMATE CHANGE

• Project information required to calculate GHG emissions for proposed operations were provided by
Tetra4 via EIMS. Where necessary, assumptions were made based on common industry practice and
experience.
• The compressor stations were assumed to be electrically powered, whereas the booster stations were
assumed to use natural gas generators.
• The methodological guidelines for quantification of GHG emissions (DFFE, 2022), published in October
2022, have been used to estimate the Scope 1 GHG emissions. The 100-year GWPs were used.
• GHG emissions from the well drilling5, well testing6, and well servicing7 were based on measurements
provided by Tetra4, and not calculated using emission factors. These activities were included under
construction operations.
• Scope 3 emissions were estimated using the UK DEFRA (2022) emission factors
(https://www.gov.uk/government/publications/greenhouse-gas-reporting-conversion-factors-2022).
• The following Scope 3 categories are excluded since these are not regarded applicable to the project:
o Category 2: Capital Goods.
o Category 8: Upstream Leased Assets.
o Category 10: Processing of Sold Products.
o Category 12: End-of-Life Treatment of Sold Products.
o Category 13: Downstream Leased Assets.
o Category 14: Franchises.
o Category 15: Investments.
• The following assumptions apply to the Scope 3 assessment:
o Raw materials needed for the wells and plant was assumed to be 100 980 tonne concrete, 26
060 tonne metal and 9 000 tonne HDPE.
o It was assumed that the raw materials would be transported by truck to site (450 km).
o Industrial waste to be sent to a landfill was assumed to be 31 428 tpa.
o Business travel was assumed to be 6 people travelling to USA and Europe per year.
o It was assumed that contractors and permanent staff (total 1 254 people) would have the
following split for employee commuting to work (2.8% diesel car, 4.6% petrol car, 19.6% taxi
and 73% bus). It was assumed that the return trip per day was 60 km.
o It was assumed that 60% of the LNG (~ 90 000 tpa) would be shipped by sea tanker to China
as a worst case scenario.
5 Data obtained from kestrel flow meter while drilling and extrapolated for duration of exploration drilling in gas bearing
units.
6 Data obtained from flow testing and flaring of existing exploration wells.
7 Data obtained from fugitive monitoring of both existing production and exploration wells.
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o It was assumed that the Helium (1 825 tpa) would be transported by truck to Durban (600 km),
and then by ship (cargo ship average bulk carrier) to either Europe, Asia or North America
(average 14 461 km).
o It was assumed that the LNG (~ 160 000 tpa) would be combusted (end use of product).
14.5 ECONOMIC
• Although Tetra4’s Cluster 1 production project is in progress (thus there is direct evidence that the
enterprise is operational), the Cluster 2 economic impact is based on an intent, namely Tetra4’s intent
to generate the output and employment as is discussed in the economic specialist report. The
eventuation of these benefits is reliant on an economically viable Tetra4, an assumption that is made
in the compilation of the economic specialist report.
• As a sub-section of the economic viability, it is assumed that Tetra4 will be fully funded for its Cluster 2
project.
• Accepting of the above assumption, the next limitation is the ratios and multipliers used in the
economic valuation. Although care was taken to use acceptable economic science, there is always a risk
that some of the estimates may not eventuate in practice, and hence that the actualised economic and
employment benefits may be much less. This is a limitation over which no assessment has control but
needs to be mentioned.
• A further important limitation is that multipliers on a national level are different compared to a
municipal level. This is due to the “leakages” from a local economy, for example income earned by a
mine is often distributed to a region outside the enterprise’s’ municipality, or procurement if from
outside the region, or salaries and wages are not always spent in a local economy. For this reason the
direct impact is used as a barometer of impacts on the local economy and when multipliers were
included those ratios were stated as relative to the local economy. However, despite this limitation the
economy-wide benefits compared to the local base is instructive as it allows a competent authority a
better perspective of the total local and national benefits relative to the local base.
• The gas multipliers for a well-established gas driven economy will be different to that of SA and for this
reason, where possible, multipliers were adjusted to assume a more mature gas industry in SA.
• The economic impacts are calculated on the supply side of the economy in an optimal year. Thus, GDP
is calculated as the sum of salaries and wages, depreciation and gross operating profit for the optimal
year.
• For a long-term project such as Tetra4 the net present value of economic benefits could also have been
used, but it has been shown that using the optimal year methodology, is equally correct, and easier to
understand for the lay reader.
• The investment of the project is used separately as year 1 and 2 increases in GDP.
• As the world had experienced, outlier events such as the impact of Covid-19 are not included in this
assessment.
14.6 GEOHYDROLOGY
Data limitations were addressed by following a conservative approach and assumptions include the following:
• The scale of the investigation was set at 1:50 000 resolutions in terms of topographic and spatial data,
a lower resolution of 1:250 000 scale for geological data and a 1: 500 000 scale resolution for
hydrogeological information.
• The Digital Elevation Model (DEM) data was interpolated with a USGS grid spacing of 25 m intervals.
• Rainfall data and other climatic data was sourced from the WR2012 database.
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• Water management and catchment-based information was sourced from the GRDM and Aquiworx
databases.
• The concept of representative elementary volumes (REV) has been applied i.e., a scale has been
assumed so that heterogeneity within a system becomes negligible and thus can then be treated as a
homogeneous system. The accuracy and scale of the assessment will result in deviations at point e.g.
individual boreholes.
• The investigation relied on data collected as a snapshot of field surveys and existing monitoring data.
Further trends should be verified by continued monitoring as set out in the monitoring program.
• Stratigraphical units, as delineated from surface geology within the model domain, are assumed to
occur throughout the entire thickness of the model and were incorporated as such.
• The geological structures (fault zones and dyke contact zones) were modelled as permeable linear
zones.
• The model basement i.e., competent Karoo basement or Dwyka tillite/diamictite is assumed to
generally be impermeable and serves to isolate the fractured Karoo aquifer from the fractured pre-
Karoo aquifer units.
• Model calibration was achieved by assigning a ratio of 1:1 for Hydraulic Conductivity (K) in x and y
directions, with a ratio of 1:10 in the z direction i.e., anisotropic aquifer (except for alluvial deposits
which were assigned at a 1:1 ratio).
• Perennial rivers within the model domain have been treated as gaining type streams. As such
groundwater is lost from the system via baseflow to local drainages.
• Groundwater divides have been assumed to align with surface water divides and it is assumed that
groundwater cannot flow across this type of boundaries.
• The numerical groundwater flow model was developed considering site specific information. It should
be stated that influences from neighbouring mining developments were not taken into consideration
as part of this investigation.
• Prior to development, the system is in equilibrium and therefore in steady state.
• Where data was absent or insufficient, values were assumed based on literature studies and referenced
accordingly.
14.7 HERITAGE AND PALAEONTOLOGY

• Not detracting in any way from the comprehensiveness of the fieldwork undertaken, it is important to
realise that the heritage resources located during the fieldwork do not necessarily represent all the
possible heritage resources present within the area. Various factors account for this, including the
subterranean nature of some archaeological sites, as well as the dense vegetation cover and
disturbance found in some areas (crops: maize, sunflowers, soya bean; ploughed land).
• There was also restricted access to certain farm properties (BLAAUWDRIFT No.188 (Portion 3),
BRUINTJE HOOGTE No.367 (Portion 2, 3), BRYAN No.561 (Portion 10, 21, 28, 29, 30, 31, 38), GLEN ROSS
No.734 (Portion 4, 5, 6, 7, 18, 20), JONKERS RUST No.72, KALKOENKRANS No.225 (Portion 3), MOND
VAN DOORNRIVIER No.38 (Portion 2), MOOIFONTEIN No.639, PALMIETJUIL No.548 (Portion 1), STILLE
WONING no.703, VLAKPAN No.358) due to farm owners not giving permission to access their
properties, flooded roads and dangerous game life on the properties.
• As such, should any heritage features and/or objects not included in the present inventory be located
or observed, a heritage specialist must immediately be contacted. Such observed or located heritage
features and/or objects may not be disturbed or removed in any way until such time that the heritage
specialist has been able to make an assessment as to the significance of the site (or material) in
question. This applies to graves and cemeteries as well. In the event that any graves or burial places are
1473 EIA Report 373

located during the development, the procedures and requirements pertaining to graves and burials will
apply as set out below.
• The study area boundaries and development footprints depicted in this report were provided by the
client. As a result, these were the areas assessed during the fieldwork. Should any additional
development footprints located outside of these study area boundaries be required, such additional
areas will have to be assessed in the field by an experienced archaeologist/heritage specialist long
before construction starts.
• When conducting a PIA several factors can affect the accuracy of the assessment. The focal point of
geological maps is the geology of the area, and the sheet explanations were not meant to focus on
palaeontological heritage. Many inaccessible regions of South Africa have not been reviewed by
palaeontologists and data is generally based on aerial photographs. Locality and geological information
of museums and universities databases have not been kept up to date or data collected in the past have
not always been accurately documented.
• Comparable Assemblage Zones in other areas is used to provide information on the existence of fossils
in an area which was not yet been documented. When similar Assemblage Zones and geological
formations for Desktop studies is used it is generally assumed that exposed fossil heritage is present
within the footprint.
14.8 NOISE
• The quantification of sources of noise was limited to the construction and operational phase of the
project. Impacts due to closure phase activities are expected to be similar to construction activities and
its impacts only assessed qualitatively. Noise impacts will cease post-closure.
• The source power levels were calculated based on information provided by EIMS. The assumption is
that this information is correct and reflects the routine construction and operational phase of the
project.
• Structural obstacles were not included in the propagation modelling of the project noise sources. This
is a conservative approach as the simulated noise impacts would not be attenuated by structural
obstacles.
• Process activities were assumed to be 24 hours per day, 7 days per week.
• Although other existing sources of noise within the area were identified during the survey, such sources
were not quantified but were taken into account during the baseline sampling.
• The environmental noise assessment focuses on the evaluation of impacts for humans.
• The scope of work did not include a vibration assessment.
14.9 SOCIAL
• Not every individual in the community could be interviewed therefore only key people in the
community were approached for discussion. These key people include all the directly affected
landowners. Additional information was obtained using existing data.
• The social environment constantly changes and adapts to change, and external factors outside the
scope of the project can offset social changes, for example changes in local political leadership,
droughts or economic conditions. It is therefore difficult to predict all impacts to a high level of
accuracy, although care has been taken to identify and address the most likely impacts in the most
appropriate way for the current local context within the limitations. In addition, it is also important to
manage social impacts for the life of the project, especially in the light of the changing social
environment.
1473 EIA Report 374

• Social impacts can be felt on an actual or perceptual level, and therefore it is not always straightforward
to measure the impacts in a quantitative manner.
• Social impacts commence when the project enters the public domain. Some of these impacts will occur
irrespective of whether the project continues or not, and other impacts have already started. These
impacts are difficult to mitigate, and some would require immediate action to minimise the risk.
• There are different groups with different interests in the community, and what one group may
experience as a positive social impact, another group may experience as a negative impact. This duality
will be pointed out in the impact assessment phase of the report.
• Social impacts are not site-specific but take place in the communities surrounding the proposed
development.
14.10 TERRESTRIAL BIODIVERSITY

• The assessment area was based on the area provided by the client and any alterations to the area
and/or missing GIS information pertaining to the assessment area would have affected the area
surveyed;
• Only a single season survey will be conducted for the respective studies, this would constitute a wet
season survey with its limitations;
• Access to certain portions within the study area was not possible due to the fact that the land owner
did not give the go-ahead;
• Whilst every effort is made to cover as much of the site as possible, representative sampling is
completed and by its nature it is possible that some plant and animal species that are present on site
were not recorded during the field investigations; and
• The GPS used in the assessment has an accuracy of 5 m and consequently any spatial features may be
offset by 5 m.
14.11 AQUATIC AND WETLANDS

• Areas characterised by external wetland indicators have been focussed on for this study. Areas lacking
these characteristics, i.e. disturbed areas, developed areas etc. have not been focussed on;
• Due to the size of the proposed area only the key areas where infrastructure is located were focused
on, the remaining areas were predominantly delineated through means of desktop; and
• The GPS used for water resource delineations is accurate to within five meters. Therefore, the wetland
delineation plotted digitally may be offset by at least five meters to either side.
14.12 VISUAL
• A site visit was undertaken over a two-day period (21st and 22nd February 2022).
• The timing of photography was planned to ensure that the sun was as far as possible behind the
photographer to ensure that as much detail as possible was recorded in the photographs.
• GIS data sets used in the assessment are either available on line to the public or have been sourced
from relevant government departments.
• Photographs were taken with a Canon EOS M50 camera fitted with a 22mm lens.
• Visibility of the proposed facilities has been assessed using the Global Mapper Viewshed tool.
• Most data sets have been used for assessment context. These have largely been sourced from
government departments. Whilst these have been mainly mapped at national scale, they were found
to be largely sufficient to provide context for the assessment. Where additional detail was required,
1473 EIA Report 375

such as the location of local roads and homesteads, this was mapped on site and / or captured from
online mapping.
• The visibility assessments were based on terrain data that has been derived from satellite imagery
(STRM Worldwide Elevation Data). This data was originally prepared by NASA and is freely available on
the CIAT-CCAFS website (http://www.cgiar-csi.org). This data has been ground truthed using a GPS as
well as online mapping. This is the key data on which the definition of possible affected landscapes and
receptors was based and is considered sufficient for this purpose.
• Calculation of visibility is based purely on the Digital Elevation Model and does not take into account
the screening potential of vegetation or other development.
• A stack height of 16 m for the plant flare has been assumed for in this assessment.
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15 UNDERTAKING REGARDING CORRECTNESS OF INFORMATION
I Brian Whitfield herewith undertake that the information provided in the foregoing report is correct, and that
the comments and inputs from stakeholders and Interested and Affected Parties has been correctly recorded in
the report.
Signature of the EAP
________________
Date: 2023-02-01
16 UNDERTAKING REGARDING LEVEL OF AGREEMENT

I Brian Whitfield herewith undertake that the information provided in the foregoing report is correct, and that
the level of agreement with Interested and Affected Parties and stakeholders has been correctly recorded and
reported herein.
Signature of the EAP
________________
Date: 2023-02-01
1473 EIA Report 377

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ENVIRONMENTAL IMPACT ASSESSMENT

PASA Ref: 12/4/007

EIMS REFERENCE: 1473

NAME SIGNATURE DATE

COMPILED: Brian Whitfield 2022/11/29

CHECKED: Liam Whitlow 2022/11/29

AUTHORIZED: Liam Whitlow 2022/11/29

REVISION AND AMENDMENTS

REVISION DATE: REV # DESCRIPTION

2022/11/29 ORIGINAL DOCUMENT Report for Public Review

2023/02/01 FINAL DOCUMENT Final Report for Competent Authority Decision

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Appendix 3: Public Participation Report

Appendix 4: Specialist Reports

Appendix 5: Environmental Management Programme

Appendix 6: Financial Provision Report

Appendix 7: Tetra4 Well Closure and Rehabilitation Guideline

Appendix 8: Major Hazardous Installation Reports

Appendix 9: Application Form Revision and PASA correspondence

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1.1 PROJECT OVERVIEW

1.2 NEED FOR THE PROJECT

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GAS INLINE STATIONS

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LNG AND HELIUM PLANT

• Helium Separation Unit;

• Gas Liquefaction System;

• LHe Storage (~2x100 m3);

• LNG Storage (~11x300 m3); and

• LHe and LNG road tanker loading bays.

1.4 SPECIALIST STUDIES

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1.6 PUBLIC PARTICIPATION

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Comment Summary How comment was addressed

I&AP deregistration requests. I&APs who formally requested to be registered were

I&AP registration requests. I&APs who formally requested to be registered were

Transnet commented that the proposed No further actions required.

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1.7 IMPACT STATEMENT