Elliot EMP 18-04

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							                                                            BADIMO GAS (PTY) LTD

                                         EXPLORATION FOR COAL BED METHANE

                                                             ELLIOT PROJECT

                                                    EASTERN CAPE PROVINCE

                                                Reference No.: 30/5/2/3/2/65 ER



                                         ENVIRONMENTAL IMPACT ASSESSMENT &
                                      ENVIRONMENTAL MANAGEMENT PROGRAMME




                                                                    Environmental Services

                                                                                   South Africa
                                                                                  PO Box1822
Project Number:    S0191-2                                                       Rivonia, 2128
Report Number:     S0191-B/01                                          Tel: +27 (0)11 807 8225
                                                                      Fax: +27 (0)11 807 8226
Revision Number:   0                                               synergy@synergistics.co.za
Report Status:     Submission Draft
                                                                                      Namibia
Date:              2 May 2007                                                  PO Box 80966
Prepared By:       Matthew Hemming                                                  Windhoek
                                                                     Tel: +9264 (0)61 235 000
Authorised By:     Kerry Fairley                                    Fax: +9264 (0)61 235 001


Working Together
Name of Project:             Application for an Exploration Right for Coal Bed Methane –
                             Elliot Project
Reference No.:               30/5/2/3/2/65 ER
Name of Report:              Environmental        Impact       Assessment         &   Environmental
                             Management Programme.
      Date:                  2 May 2007
      Version:               Submission Draft
      Abstract:              Badimo Gas (Pty) Ltd has made an application for an
                             exploration right for coal bed methane around Elliot in the
                             Eastern Cape Province. No impacts of high significance were
                             identified during the environmental impact assessment. The
                             environmental management programme details the actions
                             required to address impacts and facilitate rehabilitation of
                             exploration sites. A site assessment and a land use
                             agreement will be critical to minimise impacts.
Name of Applicant:           Badimo Gas (Pty) Ltd
      Responsible Person:    Don Ncube
      Postal Address:        P O Box 52237 Rosebank, Johannesburg, 2146
      Telephone:             (011) 447 4827
      Facsimile:             (011) 759 7545
      E-mail:                dncube@mweb.co.za


Geological Consultant:       Banzi Geotechnics cc
      Responsible Person:    Oliver Barker (Pr.Sci.Nat.)
      Postal Address:        PO Box 322, Bruma, 2026
      Telephone:             011 648 5130
      Facsimile:             011 648 9781
      E-mail:                obb@banzi.co.za


Environmental Consultants:   Synergistics Environmental Services (Pty) Ltd
      Responsible Person:    Kerry Fairley (Pr.Sci.Nat./Registered as EAP with ICB)
      Postal Address:        PO Box 1822, Rivonia, 2128.
      Telephone:             011 807 8225
      Facsimile:             011 807 8226
      E-mail:                kerry@synergistics.co.za


Land Owners:                 Full list of title deeds included in application document.
            S0191-2                                                             2 May 2007



    EXPLORATION RIGHT APPLICATION FOR COAL BED METHANE

                                                ELLIOT

                          ENVIRONMENTAL IMPACT ASSESSMENT

                                                  AND

                     ENVIRONMENTAL MANAGEMENT PROGRAMME


                                       EXECUTIVE SUMMARY
Background Information and Project Motivation
Badimo Gas (Pty) Ltd is proposing to explore for coal bed methane in the Elliot exploration right
application area located in the Eastern Cape Province, South Africa. The exploration area is located
around and west of, Elliot Town.


Exploration for coal bed methane will be carried out as a phased, iterative process. The work will
include a desktop phase involving the evaluation of available data and the creation of geological
models, culminating in the drilling of boreholes at selected sites.


The application for an exploration right was lodged with the Petroleum Agency South Africa in terms of
the requirements of the Mineral and Petroleum Resources Development Act 28 of 2002. The
Petroleum Agency South Africa (PASA) accepted the application on 4 January 2007 and required that
public consultation be conducted and an environmental management programme be developed (Ref:
30/5/2/3/2/65 ER).


Coal bed methane or CBM, is an abundant fossil energy resource which is found in association with
nearly all coal beds where it is formed as a by-product of the coal formation process. The methane
gas is adsorbed within the structure of the coal and is kept there by overburden and hydraulic
pressure. CBM can be extracted by pumping water out of the coal bed thereby reducing the pressure
and allowing the gas to escape to the surface. The purpose of the exploration will be to explore for
CBM in the Elliot area.


CBM is a relatively clean and safe energy resource that can be used in applications such as cooking,
heating and the generation of electricity. In South Africa short term projections of the electricity supply
and demand indicate a shortfall in peak electricity generation capacity by 2006 and in the country’s
base-load capacity by 2010. CBM exploration efforts are thus strategically important in identifying and
assessing potential sources of natural gas which could provide alternative energy sources to address
South Africa’s growing demand. In addition methane gas provides a cleaner form of energy than coal
and oil as it gives off less carbon dioxide per unit of energy released while producing more heat per
gram than other complex hydrocarbons.


The Elliot exploration area is considered favourable for the occurrence of CBM due to the presence of
extensive coal deposits at depths adequate for CBM development and preservation.


Project Description
The proposed exploration programme will be carried out in two phases. The first phase involves a
desktop study in order to identify target sites for exploration drilling. This will include a review of
available information, the creation of geological and financial models and the identification of target
sites for the sampling of the coal bed methane resource.


The second phase of exploration will require the drilling of boreholes to depths of between 200 and
700 m. Boreholes will be drilled using mobile rotary diamond drilling rigs that may operate 24 hours a
day. Drilling at each site is likely to take about 3 weeks. The footprint of disturbance for an exploration
                                                   2
rig and equipment is generally less than 1 000 m and sites will be accessed using existing farm roads
where available. The budget for the initial phase of investigations allows for the drilling of
approximately 5 boreholes within the exploration area.


The rig will be managed by a site supervisor and operated by a crew of 10 persons who will be housed
at the site or nearby. Water required for the operation of the drilling rig will be obtained locally. All
waste generated at the drilling site will be collected, removed from site and disposed of at an
appropriate waste facility.


Assuming the targeted coal seams are encountered during drilling, cores will be raised to the surface
and sections inserted into sampling canisters. The samples will be taken to a laboratory for testing and
analysis.


Once the drilling and sampling of a borehole is complete the hole will be sealed using cement. If the
site is to be used in the future the hole will be capped with a borehole plinth. On completion of the
drilling and sampling, all equipment will be removed and the compacted surfaces will be scarified.
Soils that have been contaminated with oils or greases will be remediated in-situ. Natural vegetation
re-establishment will be monitored and supplemented as necessary.
Environmental Impact Assessment and Management Programme
The potential biophysical and socio-economic environmental impacts of the project, both beneficial
and adverse, were assessed during the impact assessment. Given the limited duration and extent of
the prospecting activities, the impacts on the environment are not likely to be significant. A number of
the impacts may however be residual and continue beyond the cessation of drilling activities if the
appropriate mitigation measures are not put in place. The actions required to address the impacts
identified in the environmental impact assessment are detailed in the environmental management
programme.       The environmental management programme provides an elaboration of how to
implement the mitigation measures documented in the environmental impact assessments in order to
minimise negative and enhance positive impacts that may occur during set-up, operation and
rehabilitation of drilling sites.


All relevant owners of surface rights, mineral rights and servitudes will be consulted during the
identification of target sites. It is anticipated that most exploration targets will be located on private
farming land.      It is essential that individual land owners are consulted in a timely manner regarding
site access and potential disturbance to farming activities. Issues related to trespassing, farm security
and stock theft also need to be addressed. These impacts will be mitigated through the development
of a land use agreement. Agreement must be reached between the holders of all mineral rights. A
forum through which land owners and affected parties may contact the exploration team will be
established. All complaints are to be investigated and where possible remediation measures put in
place.


Provision has been made for an environmental site assessment of each target area, which is to be
undertaken prior to site establishment. Ecological and cultural sensitivities of the site as well as
surrounding areas that could be disturbed by exploration activities will be assessed and alternative
sites with lower sensitivities selected in order to prevent impacts of significance. Where there is
concern for biodiversity conservation disturbance should be kept to a minimum as disturbances would
negatively impact conservation efforts. Areas of high biodiversity value will be avoided during the
selection of target sites. Where necessary site specific action plans are to be developed to further
protect sensitive fauna and flora.       The site assessment will also give cognisance to potential
disturbance to land use activities and sensitive receptors (such as noise or dust) in the vicinity and
efforts will be taken to keep these to a minimum.


Soils may become compacted or contaminated due to the spillage of fuels, oils, greases and other
hazardous chemicals (e.g. laboratory chemicals) that are used on site. There is also the potential for
erosion, particularly if access roads are developed on site. It is thus essential that the footprint area of
disturbance be minimised and activities contained. This will involve the clear demarcation of areas to
be used for drilling activities. Erosion control measures are to be implemented on steep slopes.
Impermeable surfaces and temporary bunds will be constructed in order to contain chemical. Given
the limited duration of drilling activities it is suggested that the clearance of vegetation be limited to
areas that require levelling for the establishment of the drilling rig. Vegetation will serve to reduce the
erosion potential of soils in disturbed areas.


Access roads should follow the natural contours as far as possible in order to further reduce the
erosion potential. On completion of the exploration activities at a particular site, the scarification of
compacted surfaces and the remediation of contaminated soils will be undertaken in order to promote
the natural re-establishment of vegetation.


Water is required for the operation of the drilling rig, which will either be sourced from nearby water
courses or existing boreholes. Access to drill water and potable water will be agreed with the land
owner prior to site establishment in the form of a land use agreement. Water use will however be
minimal and there will be no significant impact on the water resources.


Boreholes that are drilled for exploration will be sealed or capped to ensure that no gas escapes. This
is essential, as methane is a greenhouse gas that should be prevented from entering into the
atmosphere.


Conclusions
No impacts of high significance have been identified for exploration activities within the Elliot
application area. The current assessment is however limited by the fact that target drilling sites will
only be identified in Phase 2 of the exploration programme. An environmental site assessment of
each target site must be conducted to ensure that site specific impacts are kept to a minimum. There
needs to be flexibility in the relocation of the sites in order to ensure that sensitive sites are avoided as
far as possible. It is also essential that land and rights owners are informed and a land use agreement
developed in terms of site access, location of drill sites and camps, the surface area of sites, the use
of existing roads, water supply and rehabilitation. However, given the limited number of drill sites, the
potentially small area of disturbance and the short duration of activities at any particular site there is
no environmental reason why the proposed exploration activities should not continue.
                                       TABLE OF CONTENTS

1.   INTRODUCTION ......................................................................................................1

2.   TERMS OF REFERENCE ........................................................................................2

3.   METHODOLOGY .....................................................................................................4
     3.1        Collation of Baseline Data ................................................................................4
     3.2        Public Consultation ...........................................................................................4
     3.2.1      Identification of Interested and Affected Parties..................................................4
     3.2.2      Background Information Document .....................................................................5
     3.2.3      Registration of IAPs .............................................................................................5
     3.2.4      Review of Draft Report ........................................................................................6

4.   PROJECT DESCRIPTION .......................................................................................6
     4.1        Desktop Study....................................................................................................6
     4.2        Drilling Phase .....................................................................................................7
     4.2.1      Core Drilling .........................................................................................................7
     4.2.2      Sampling ..............................................................................................................7
     4.2.3      Personnel Requirements .....................................................................................8
     4.2.4      Housing and Infrastructure Requirements...........................................................8
     4.2.5      Water Use ............................................................................................................8
     4.2.6      Waste Management.............................................................................................9
     4.2.7      Rehabilitation .......................................................................................................9
     4.3        Motivation for the Project .................................................................................9
     4.4        Project Alternatives .........................................................................................12
     4.4.1      Site Location Alternatives ..................................................................................12
     4.4.2      Infrastructure Alternatives..................................................................................12
     4.4.3      No Project Alternative ........................................................................................12

5.   DESCRIPTION OF THE AFFECTED ENVIRONMENT ..........................................13
     5.1        Regional Setting...............................................................................................13
     5.2        Land Tenure .....................................................................................................13
     5.3        Geology.............................................................................................................13
     5.3.1      Geological Setting..............................................................................................13
     5.3.2      Location of Coalfield ..........................................................................................13
     5.3.3      Stratigraphy of the Coalfield ..............................................................................15
     5.3.4      Structures and Intrusions...................................................................................15
                                                          i
     5.4      Soils...................................................................................................................19
     5.5      Climate ..............................................................................................................19
     5.6      Topography ......................................................................................................19
     5.7      Land Use and Land Capability .......................................................................19
     5.8      Ecology .............................................................................................................20
     5.8.1    Vegetation ..........................................................................................................20
     5.8.2    Fauna .................................................................................................................20
     5.9      Protected Areas and Sensitive Sites .............................................................22
     5.10     Surface Water...................................................................................................22
     5.11     Ground Water ...................................................................................................22
     5.12     Air Quality .........................................................................................................23
     5.13     Noise .................................................................................................................23
     5.14     Cultural Heritage ..............................................................................................23
     5.15     Social and Economic Environment ...............................................................23

6.   RESULTS OF PUBLIC CONSULTATION..............................................................24
     6.1      Collation of Issues and Concerns..................................................................24
     6.2      Synthesis of Issues Raised` ...........................................................................24

7.   ENVIRONMENTAL AND SOCIO-ECONOMIC IMPACT ASSESSMENT ...............25
     7.1      Impact Assessment Criteria ...........................................................................25
     7.2      Assessment of Potential Impacts ..................................................................27
     7.2.1    Geology..............................................................................................................36
     7.2.2    Soils ...................................................................................................................36
     7.2.3    Topography........................................................................................................37
     7.2.4    Land Use & Land Capability ..............................................................................37
     7.2.5    Ecology ..............................................................................................................38
     7.2.6    Protected Areas and Sensitive Sites .................................................................38
     7.2.7    Surface Water ....................................................................................................38
     7.2.8    Groundwater ......................................................................................................39
     7.2.9    Air Quality...........................................................................................................39
     7.2.10   Noise ..................................................................................................................39
     7.2.11   Visual .................................................................................................................40
     7.2.12   Cultural Heritage ................................................................................................40
     7.2.13   Social and Economic Environment....................................................................40

8.   ENVIRONMENTAL MANAGEMENT PROGRAMME .............................................42
     8.1      Objectives .........................................................................................................42
                                                        ii
            8.1.1       Environmental Impacts ......................................................................................42
            8.1.2       Rehabilitation .....................................................................................................42
            8.1.3       Action Plan.........................................................................................................42
            8.1.4       Time Schedule ...................................................................................................43
            8.1.5       Requirements for Implementation .....................................................................43
            8.2         Emergency Procedures...................................................................................43
            8.2.1       Fire .....................................................................................................................43
            8.2.2       Spillage of a fuel, oil, lubricant or any other chemical substance .....................44
            8.3         Monitoring and Performance Assessment ...................................................55
            8.4         Environmental Awareness Training ..............................................................55
            8.5         Financial Provision ..........................................................................................55
            8.5.1       Method of Financial Provision............................................................................55
            8.5.2       Quantum of Financial Provision.........................................................................56

9.          REFERENCES .......................................................................................................58

UNDERTAKING...................................................................................................................59




                                                                  iii
                                  LIST OF FIGURES

Figure 1:     Regional Location of the Elliot Exploration Right Application Area           3
Figure 2:     Topo-cadastral Map of the Elliot Exploration Right Application Area         14
Figure 3:     Surface Geology of the Elliot Exploration Area                              16
Figure 4:     Coalfields of the Eastern Cape Province                                     17
Figure 5:     Stratigraphy of the Molteno Coalfield                                       18
Figure 6:     Vegetation Types of the Elliot Exploration Right Application Area (source
              Mucina et al, 2004)                                                         21


                                  LIST OF TABLES

Table 1:      Impact Assessment Criteria                                                  26
Table 2:      Assessment of All Potential Environmental Impacts                           28
Table 3:      Environmental Management Programme                                          45
Table 4:      Calculation of Quantum for Financial Provision for Premature Closure        56
Table 5:      Calculation of Quantum for Financial Provision for Final Closure            57


                             LIST OF APPENDICES

Appendix 1:   Copies of Press Advertisements                                                i
Appendix 2:   Copies of Posters                                                            ii
Appendix 3:   Background Information Document                                             iii
Appendix 4:   Interested and Affected Party Database                                      iv
Appendix 5:   Responses from Interested and Affected Parties                               v
Appendix 6:   Environmental Code of Conduct                                               vi




                                         iv
                                  LIST OF ABBREVIATIONS

In text
BID             Background Information Document
CBM             Coal Bed Methane
CGS             Council for Geoscience
DME             Department of Minerals and Energy
EAP             Environmental Assessment Practitioner
EIA             Environmental Impact Assessment
EMP             Environmental Management Programme
IAP             Interested and Affected Party
MPRDA           Mineral and Petroleum Resources Development Act 28 of 2002
MSD             Material Safety Data
PASA            Petroleum Agency South Africa


                                             GLOSSARY

In text
Adsorbed                 Accumulated on the surface of a solid.
camp site                The demarcated area at which drilling employees are accommodated
                         while working at a drilling site. The area includes the cooking and ablution
                         facilities.
Diagenesis               The physical, chemical or biological alteration of sediments into
                         sedimentary rock at relatively low temperatures and pressures that can
                         result in changes to the rock's original mineralogy and texture.
drilling site            The demarcated area within which all drilling and sampling machinery,
                         vehicles and equipment operate while excavating a borehole.
exploration area         The Elliot area in which, Badimo Gas has lodged an exploration right
                         application for coal bed methane with the Petroleum Agency SA.
exploration activities   Includes all drilling, sampling and related activities that may be
                         undertaken at a drilling site.
exploration right        As defined in the Mineral and Petroleum Resources Development 28 of
                         2002.
fraccing                 Colloquial term in the petroleum industry for creating fractures in rock
                         near the bottom of a well. It usually requires pumping a fluid into the well
                         at high pressure.


                                                v
     S0191 - 2                                                                     2 May 2007



                                                METHANE:
     EXPLORATION RIGHT APPLICATION FOR COAL BED METHANE:

                                            ELLIOT
                          ENVIRONMENTAL IMPACT ASSESSMENT &

                      ENVIRONMENTAL MANAGEMENT PROGRAMME



1.         INTRODUCTION

Badimo Gas (Pty) Ltd is proposing to explore for coal bed methane in and around Elliot Town in
the Elliot District of the Eastern Cape Province, South Africa (Figure 1). The exploration project
has been termed the Elliot Project. Exploration for coal bed methane is aimed at identifying coal
bed methane gas resources located in coal seams deep underground.


Coal and coal bed methane (CBM) are abundant, complimentary, fossil energy resources found
in many areas of the world, including South Africa. CBM is a natural gas, which is found in
association with nearly all coal beds where it is formed as a by-product of the coal formation
process by both maturation and burial processes (coalification and diagenesis). The methane gas
is adsorbed within the structure of the coal and is bound to the cleats and pores within the coal by
a combination of molecular and hydraulic pressures. Groundwater within the coal bed contributes
to this pressure. CBM can be released by drilling into the coal seam, pumping out the water,
thereby releasing the pressure and encouraging the gas to flow to the surface. In some cases
various forms of stimulation such as fraccing may be required to encourage gas flow. The
escaping gas is then captured for use.


Methane is a relatively clean form of energy and can be used to generate electricity or provide
heat for domestic and industrial purposes. Once extracted methane can be easily contained and
safely used in many applications.


The exploration process is a phased, iterative process and includes the evaluation of all available
data, the creation of geological models and culminates in the drilling of boreholes at identified
target sites. Exploration for CBM requires an exploration right in terms of Section 79 of the
Mineral and Petroleum Resources Development Act 28 of 2002 (MPRDA).




Exploration for Coal Bed Methane:                1           SYNERGISTICS ENVIRONMENTAL SERVICES
Elliot Project
EIA and EMP (S0191)
An application for an exploration right in the Elliot area has been lodged by Badimo Gas with the
Petroleum Agency South Africa (PASA) in terms of the requirements of the MPRDA.                The
Petroleum Agency South Africa accepted the application on 4 January 2007 and required that
public consultation be conducted and an environmental management plan (EMP) be developed.
In accordance with the conditions defined by PASA, the results of the consultation with affected
parties and the environmental management programme must be submitted to PASA on or before
4 May 2007 (Ref: 30/5/2/3/2/65 ER).


2.         TERMS OF REFERENCE

Synergistics Environmental Services (Pty) Ltd has been appointed as independent environmental
consultants to undertake the necessary work to meet the requirements of informing an
environmental authorisation decision from PASA for exploration for coal bed methane in the Elliot
exploration area.


In accordance with Section 79, (4) of the MPRDA the applicant of an exploration right is required
to submit an environmental management programme in terms of Section 39 of the Act. The EIA
and EMP Reports are structured as a consolidated document and the results of the public
consultation are included within this document. The EMP Report has been compiled in
accordance with Section 39 of Act as well as the Draft Environmental Management Plan
Guideline      Document         for   Petroleum   Exploration   and   Production   (PASA,    2006).




Exploration for Coal Bed Methane:                   2           SYNERGISTICS ENVIRONMENTAL SERVICES
Elliot Project
EIA and EMP (S0191)
Figure 1:             Regional Location of the Elliot Exploration Right Application Area

Exploration for Coal Bed Methane:                                       3                  SYNERGISTICS ENVIRONMENTAL SERVICES
Elliot Project
EIA and EMP (S0191)
3.         METHODOLOGY


3.1        Collation of Baseline Data

Given that the actual exploration drilling sites will only be identified during Phase 2 of the
exploration programme (see Section 4.2), this assessment has aimed at identifying environmental
sensitivities within the exploration area. This has involved a desktop study and draws extensively
on information contained in studies that have been conducted by various government
departments and non-government environmental organisations responsible for the area covered
by the exploration right application.    The desktop assessment has included a review of the
following:


•    National Spatial Biodiversity Assessment;
•    Vegetation of South Africa, Lesotho and Swaziland (Low and Rebelo, 1996);
•    Vegetation of South Africa, Lesotho and Swaziland, 1: 1 000 000 scale sheet map (Mucina,
     Rutherford and Powrie, 2005);
•    Available internet information on environmental issues related to coal bed methane
     exploration and production;
•    Available internet information on the baseline environment within the exploration area; and
•    Topo-cadastal and geological maps covering the exploration area at scales ranging from 1:50
     000 to 1:250 000.


3.2        Public Consultation

3.2.1      Identification of Interested and Affected Parties

As per the requirements of the MPRDA, Synergistics has undertaken to notify and consult with
land owners and affected parties. The names and contact details of potentially interested and
affected parties (IAP) were obtained from Agri-Eastern Cape and the Local Municipality. A
background information document (BID) was distributed through the farmers unions and
municipalities and responses requested from any interested and affected party. Agricultural
Unions with members in the application area were asked to distribute the BID.


Additional measures to contact IAPs included the placement of posters, newspaper
advertisements and telephonic communications. Networking and referral by informed IAPs has
helped register additional IAPs.




Exploration for Coal Bed Methane:                4             SYNERGISTICS ENVIRONMENTAL SERVICES
Elliot Project
EIA and EMP (S0191)
3.2.1.1 Press Advertisements

An English advertisement was placed in the local newspaper the Representative of Queenstown
on Thursday 8 February 2007, informing the public of the project and inviting IAPs to contact the
public participation office and register as an interested and affected party. The Representative is
distributed in Queenstown, Elliot and surrounds. The advertisement was placed in the regionally
distributed ‘Daily Dispatch’ newspaper on Saturday 10 February (Appendix 1).


3.2.1.2 Posters

Posters introducing the project and inviting the public to register as IAPs were placed at
prominent locations within the project area on 22 February 2007 (Appendix 2).
•          An A2 size poster was placed on the notice board at the Municipal Building and
           Andrews Meat Market in Elliot.
•          A3 posters were placed at the Spar, Public Library, Post Office and First National Bank
           in Elliot.


3.2.2      Background Information Document

A background information document (BID) explaining the project and the exploration right
application process was compiled in English and Afrikaans. The BID included a response sheet,
which provided persons with the opportunity to register as IAPs and provide comment, raise
issues and concerns and ask questions. The sheet also requested that the respondent list
additional persons that might be interested in the project. The BID was circulated to the farmers
unions, municipalities and potential IAPs by registered mail, e-mail or facsimile. 30 BIDs were
posted to the Elliot Farmers Union representative for distribution to affected farmers. It was
requested that the response sheet be returned by 23 March 2007. The BID is included in
Appendix 3.


3.2.3      Registration of IAPs

Details of all persons and organisations that were contacted or sent the BID are included in the
IAP database (Appendix 4). All IAPs were asked to register by 23 March 2007. Those whom
returned the response sheet were registered as IAPs and will receive all further information
regarding the project.




Exploration for Coal Bed Methane:                5           SYNERGISTICS ENVIRONMENTAL SERVICES
Elliot Project
EIA and EMP (S0191)
3.2.4      Review of Draft Report

The draft Environmental Impact Assessment and Environmental Management Programme Report
for the Elliot Coal Bed Methane Exploration Project was made available to all interested and
affected parties for review at the Elliot Public library from 4 May until 25 May 2007 and on the
internet at www.synergistics.co.za. All registered IAPs were informed of the availability of the
documents by fax, email and telephone. All comments received from IAPs, regarding the draft
report, will be forwarded to the Petroleum Agency South Africa.


4.         PROJECT DESCRIPTION

The proposed exploration work programme will be carried out in 2 phases.


4.1        Desktop Study

The desktop study phase of the exploration will be undertaken in order to identify target
sites for exploration drilling. Phase 1 of the project will include:


•    Extensive review of available information that exists over the areas of interest will be
     undertaken. These investigations will include identifying:
            •    Sources of published and possibly unpublished data from the Council for
                 Geoscience (CGS);
            •    Private companies that may have information that could be purchased; and
            •    Resources such as information from annual reports of companies close to,
                 or adjoining the properties of interest.


•    Creation of geological models based on the database collated from these various sources;
•    Visualisation of various CBM targets (target generation);
•    Remote sensing, including the analysis of existing geophysical data available from the CGS;
•    Creation of financial models in order to decide on the potential economic viability of targets
     identified during the targeting stage and following the remote sensing stage;
•    A “pre-feasibility” analysis of the targets based on all the data gathered and analysed. This
     analysis will provide Badimo with graded targets and stop-go options based on the potential
     to find an economically viable deposit in one or more of the target areas.




Exploration for Coal Bed Methane:                    6           SYNERGISTICS ENVIRONMENTAL SERVICES
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EIA and EMP (S0191)
4.2        Drilling Phase

It is envisaged that Phase 2 will include the drilling of boreholes in order to substantiate the
models developed in the pre-feasibility work and assess the economic feasibility of targets areas.
Phase 2 may also include more detailed geophysical surveys if these are warranted.


Assuming the targeted gas concentrations are encountered during drilling, samples will be taken
for laboratory testing.        Laboratory tests will include one or more of the following: physical
desorption tests, chemical analyses, and possibly petrography and mineralogy.


4.2.1      Core Drilling

Core drilling for coal bed methane involves the use of a rotary diamond drilling rig to drill a
borehole and extract core samples. The time required on a specified drilling site is dependent on
the depth to be drilled and the tests and samples that are required. In the case of explorations
within the Elliot exploration area, it is expected that the depth of drilling will be between 200 m
and 700 m. Drilling is not likely to exceed depths of 700 m and most boreholes are expected to
take about 3 weeks per site.


In most cases the drill rig will be a self contained, truck-mounted unit that will be accompanied by
a compressor and a generator. The only additional equipment likely to be required is a water
bowser. Other vehicles required on site will include trucks for the transporting of equipment and
cars capable of reaching the site for the inspection and logging of the cores and works. The
footprint of disturbance for an exploration rig that is able to drill to a depth of 1 000 m is generally
smaller than 1 000 m2 (Plate 1).


The budget for the initial phase of investigations allows for the drilling of approximately 5
boreholes within the exploration area, although this may be adjusted as exploration proceeds. In
the case of the Elliot exploration it is expected that not more than 3 rigs will be in operation at any
one time. These may be situated many kilometres apart. Should early results of this programme
be positive, the number of boreholes may be increased over the target area.


4.2.2      Sampling

Sampling will include the recovery of core from the rotary diamond drill. The cores will be raised
to the surface and sample sections will be immediately inserted into specially designed steel,
aluminium (Plate 2) or PVC sampling canisters. The sampling canisters have pressure valves and
connector nipples to allow for attachment to laboratory equipment.



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The canisters containing the core samples will be removed to a laboratory facility for degassing,
testing and analysis. The facility may be an on-site caravan or a laboratory in a nearby town. If
the drilling site is located sufficiently close to the laboratory of the testing company, the samples
will be taken directly to the laboratory. A cement plug and borehole identification plinth will be
established if the site is likely to be reused. Once the drilling and sampling of a borehole is
complete the hole will be sealed with cement. If a borehole releases gases spontaneously the
hole will be fitted with certain gas monitoring equipment which will be housed in a temporary
structure and the site will be cordoned off with secure fencing to prevent entry by people and
animals.


4.2.3      Personnel Requirements

Drilling rigs will be managed by a site supervisor who would be simultaneously responsible for all
drilling operations. The number of employees required to operate a drill rig is variable but is
normally not more than 10 persons for a deep hole. The rig will be run on a double shift basis and
will operate 24 hours a day.


4.2.4      Housing and Infrastructure Requirements

Driller’s accommodation is normally at a camp site adjacent to the drilling site and will be
arranged on an ad hoc basis with the land owner. All access and accommodation on farms will be
conducted in terms of a written agreement with the land owner. Tented or caravan
accommodation is normal in South Africa for drillers. A local site office may be established in one
of the centres convenient to the exploration sites.        However, most of the test work will be
conducted from an on-site caravan or the samples will be transported to a laboratory.


Drilling sites will, be accessed using existing farm tracks and roads where available. It may
however, be necessary to create additional access routes to specific sites and this will be done in
terms of a written agreement with the land owner.


4.2.5      Water Use

Water required for the operation of the drilling rig as well as potable water will be obtained locally,
by agreement with land owners. The water may be pumped from a river or stream or sourced
from a borehole. Approximately 5 000 litres of water per day is envisaged to be the average
water requirement per drilling site, if drilling conditions are reasonably good and the formation is
solid. The water requirements are however dependent on the site specific conditions. If faults or
cracks are encountered during drilling, significant increases in water losses could be expected for
short periods of time. The water used in drilling forms a sludge which will be collected in a sludge
pond for later disposal at an appropriately licensed facility.
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The daily water requirements for the operation of the drilling rig will fall within the water volumes
permitted by the General Authorisations (No. 1191 in the Government Gazette No. 26187
published on 26 March 2004) issued by the Department of Water Affairs and Forestry for the
taking of water from a resource. No water use license will thus be required for the exploration
project.


4.2.6      Waste Management

All waste generated at the drilling site will be collected in plastic or steel drums and removed from
site and disposed at an appropriate waste facility. Hazardous waste will be collected and stored
separately, and disposed of at an appropriate facility. Chemical toilets will be provided for the
crew and the sewage disposed of at the nearest waste tip or sewage farm, or as required by the
local authority.


4.2.7      Rehabilitation

On completion of the drilling, boreholes that have production potential will be capped, while those
with no potential will be sealed and closed. The site will be cleared of all incidental oils and
chemicals. All imported materials incompatible with the top soils will be removed and disposed of
at the nearest appropriate waste facility. The sludge pond created by the drilling operations will be
pumped out and the mud disposed of at the nearest appropriate waste facility. The running
surface of the drilling site will be scarified and the top soils returned as and where these were
removed. Vegetation re-establishment will be monitored and supplemented as necessary. All
works and procedures will be conducted in terms of a written agreement with the land owner.


4.3                   for
           Motivation for the Project

The exploration phase for CBM is a fairly limited, standard process and is likely to have few
impacts on the economy and environment of the region. However, should exploration result in the
discovery of a viable deposit of CBM, the production and processing of this resource will have
significant positive economic impacts as it will provide an energy source for both local and
regional use.


CBM is a relatively clean and safe energy resource that has never been commercially developed
or utilised in South Africa. Once above ground CBM is safe to use in both low-tech as well as
high-tech applications and is easy to distribute.     In South Africa this translates into readily
available energy for domestic heating and cooking as well as a variety of energy uses in industrial
applications. The end-use application of methane gas obtained from these coal beds has not

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been defined as this is dependant on the quantity and quality of the resource. CBM gas can be
used in many commercial and industrial applications, including but not limited to:


•   Power generation (ESKOM or independent power producers);
•   Town gas;
•   Manufacture of fertiliser;
•   Glass and metal manufacture;
•   Sasol Synfuels;
•   Steel Reduction; and
•   Compressed natural gas.


Short term projections of the electricity supply and demand in South Africa indicate a shortfall in
peak electricity generation capacity from 2006 and in the country’s base-load capacity by 2010.
Electricity demand is currently growing in excess of 4.0% per annum which implies that a new
~4800 MW power station will be required every four years from 2010. Current plans to meet
these power generation demands include the de-mothballing of the Simunye Power Stations and
the development of additional coal-fired power stations such as Matimba B (Bohlweki, 2006).
This means that by 2030 South Africa will need more than 200 Mtpa of coal for electricity
generation. It should be noted that the coal supply to the current base-load power stations will
gradually decline to less than 70 Mtpa as the coal reserves at the mines from which they are
currently being supplied are depleted. Generation capacity will also decline as some of the base-
load stations reach the end of their economic life.


CBM exploration efforts are thus strategically important in identifying and assessing potential
sources of natural gas which could provide alternative energy sources to address South Africa’s
growing demand. In addition methane gas provides a cleaner form of energy than coal and oil.
Methane has a very low heat of combustion and produces more heat per gram than other
complex hydrocarbons while giving off less carbon dioxide per unit of energy released.


Mining activities in South Africa have already resulted in and are still resulting in the release of
large amounts of methane gas into the atmosphere. This is resulting in significant loses of an
energy resource and the uncontrolled release of a greenhouse gas. Extraction of CBM prior to
mining will enable this energy resource to be utilised and consequently reduce the emissions of
greenhouse gases.




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Plate 1:              View of a drilling rig that is capable of drilling to        Plate 2:   An aluminium canister used to
                      1000m operating between agricultural lands                              store core samples




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The Elliot exploration area is considered favourable for the occurrence of coal bed methane due
to the known existence of extensive coal reserves at adequate depths for CBM development and
preservation. It is anticipated that there could be a significant methane gas resource which still
remains trapped within the coal beds or in secondary concentrations.


In addition the proximity of the Elliot exploration area to new power station developments in the
Eastern Cape region mean that gas could also be supplied to these power stations. Such a
situation may provide for the development of a gas based economy and could provide gas to the
industrial centres in the region.


4.4        Project Alternatives

4.4.1      Site Location Alternatives

Target sites for the drilling of boreholes will be identified based on the work conducted in Phase 1
of the exploration process. The location of these sites will initially be based solely on the
geological and modelling data. Only once the potential target sites have been geo-referenced
and ground-truthed can the suitability of each site be assessed. Should the identified drilling site
location be incompatible with the existing land use or be in an environmentally sensitive area the
site can be moved to an adjacent area that is less sensitive.


4.4.2      Infrastructure Alternatives

Different drill/production rigs that could be used to reduce disturbance may be considered if highly
sensitive sites require drilling. These will be selected on merit and in terms of what is available
and of adequate capacity for the work and depth to be drilled.


4.4.3      No Project Alternative

Without exploration projects in the Elliot area potential CBM resources, which are a relatively
clean and efficient energy source, will not be realised. In addition the non-discovery of a CBM
resource in the Elliot area may have a negative impact on the prospectivity for the development of
a gas industry in the region.




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5.                            AFFECTED
           DESCRIPTION OF THE AFFECTED ENVIRONMENT


5.1        Regional Setting

The proposed Elliot exploration right application area (exploration area) is located in north eastern
areas of the Eastern Cape Province, South Africa. This is a rugged area in the foothills of the
southern Drakensberg Mountains. The exploration area includes 34 farms and covers an area of
approximately 24 000 ha that extends from immediately east of Elliot Town, west towards
Dordrecht. The Tsomo River forms the northern boundary of the exploration area, whilst the R 56
road to Indwe runs largely along the southern boundary of the exploration area (Figure 2).


5.2        Land Tenure

The majority of the land within the exploration area is privately owned farm land (Figure 2). The
title deed information obtained from the office of the Surveyor General was included with the
exploration right application, submitted to PASA. Please consult this documentation for detailed
information pertaining to land tenure. There may also registered servitudes within the area, these
will be identified and the holders consulted once the location of the drilling sites has been
determined.


5.3        Geology

5.3.1      Geological Setting

Rocks of the application area consist of Molteno and Elliot Formation sediments of the Karoo
Supergroup. Outcrops consist predominantly of gritty, coarse-grained sandstones, and grey or
reddish mudstones. The characteristic red sandstones of the Elliot Formation are also called the
“Red Beds”(Figure 3). Outcrops of dolerite sills occupy about 30% of the surface area in the
Molteno-Dordrecht-Indwe region and often cap hills in the area. They are usually associated with
argillaceous sediments which present less resistance to intrusion than sandstone beds. There are
areas of dolerite as well as alluvial sands in the Elliot area.


5.3.2      Location of Coalfield

The Molteno Coalfield extends in an arc from Aliwal North and Jamestown in the west, through
Molteno, Dordrecht, Indwe, Elliot, to north of Mount Fletcher in the east, in the Eastern Cape
(Figure 4). The coalfield was a major coal-producing region between 1900 and 1904. Elliot is
situated toward the east of the coalfield.




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Figure 2:             Topo-cadastral Map of the Elliot Exploration Right Application Area
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5.3.3      Stratigraphy of the Coalfield

Six coal seams are sporadically developed in the Molteno Formation over a vertical interval of
some 400 m (Figure 5). However, only the three lower seams are reasonably persistent. These
seams are mainly developed at the base of the Molteno Formation, in the Bamboesberg Member.
The Indwe and overlying Guba coal seams are developed at the top of the Bamboesberg
Sandstone Member.


The Indwe seam varies in lithology and thickness over short distances, it is a composite seam
consisting of alternating coal and shale, of which the percentage coal varies between 30 and 65
%. It attains a maximum thickness of about 6 m in the Aliwal North area.


The Guba Seam is less developed over the coalfield and contains fewer shale partings than the
Indwe Seam. The upper portion of the seam has frequently been eroded by the overlying Indwe
Sandstone. The thickness of the seam varies considerably across the coalfield, attaining a
maximum thickness of about 3 m.


The Cala Pass or Molteno Seam occurs at the top of the Mayaputi Member and is overlain by the
Qiba Member. This seam is discontinuous and contains more shale than the seams lower in the
Molteno Formation. It comprises mostly carbonaceous shale with laminae of bright coal, reaching
a maximum thickness of 2 m, but is usually less than 1 m thick.


Coal seams above these levels comprise dominantly carbonaceous shale with thin bands of
bright coal and are of limited lateral extent.


5.3.4      Structures and Intrusions

Major structural events have not significantly affected the strata of the Molteno Coalfield. Folds
are generally of a simple nature comprising a series of gentle anticlines and synclines, and were
probably formed by differential compaction of the sediments and dolerite intrusions. Strata in the
                                                         o
area have a regional dip ranging from horizontal to 5 towards the southeast. Faults generally
have a small displacement and are normal and vertical with a north-south or east-west strike.


The Molteno Coalfield is widely invaded by vertical to sub vertical dolerite dykes, up to 20 m thick.
Outcrops of dolerite sills occupy about 30% of the surface area in the Molteno-Dordrecht-Indwe
region and often cap hills in the area. They are usually associated with argillaceous sediments
which present less resistance to intrusion than sandstone beds. Coal in proximity to the intrusions
is devolatilized due to the effects of thermal metamorphism.



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Figure 3:             Surface Geology of the Elliot Exploration Area



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                                                                      This application




Figure 4:              Coalfields of the Eastern Cape Province




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Figure 5:             Stratigraphy of the Molteno Coalfield




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5.4        Soils

Soils in the Elliot area are generally shallow and often rocky. They have minimal development
and are largely found on hard or weathering rock. Intermittent, diverse soils derived from
sandstone, mudstone, the volcanic rocks of the Stormberg plateau and dolerites are found. Soils
on the slopes are often less then 450 mm deep and are generally only suitable for natural
vegetation. On the valley bottoms, deeper soils with marked clay accumulation are encountered.
These are strongly structured, non-reddish soils and are frequently cultivated. Areas of alluvial
sands are also present.


5.5        Climate

The region receives an average rainfall of around 795 mm per annum but the higher altitude
areas can receive as much as 1600 mm per annum. Most of the rain falls in the summer months.
Temperatures vary from -13 C to 40 C with an annual average of 15 C. During severe winters
frost does occur but snowfalls are not common.


5.6        Topography

The Elliot exploration area is rugged and is surrounded by mountainous features with scenic,
wooded gorges, ravines, and numerous streams. The general area is comprised of undulating
grasslands, rolling koppies, non-perennial rivers and perennial water bodies. The altitude of the
area is generally between 1300 and 1400 metres above sea level, although there are koppies
and rocky ridges in north east that are above 2000 metres above sea level.


5.7        Land Use and Land Capability

Agriculture is the pre-dominant land use on the farms in the exploration area with stock grazing of
cattle or sheep on the natural grasslands being the largest land user. The lower slopes and
valleys are often under pasture. Mushroom and trout farming are two significant land uses in the
region. There are currently no major industrial developments or coal mines within the proposed
exploration area although mining has taken place in the past. The mountainous areas host an
abundance of caves which frequently contain rock art and engravings in the sandstone. The Elliot
area offers white water rafting, hiking, scenic routes and is a popular tourist spot.




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5.8        Ecology

5.8.1      Vegetation

The vegetation of the region falls within the southern and western extent of the southern
Drakensberg grasslands. Within the exploration area 5 vegetation types have been identified
(Mucina et al, 2004). These include Lesotho Basaltic Highland Grassland, Southern Drakensberg
Highland Grassland, Tsomo Grassland, Drakensberg Foothill Moist Grassland and Eastern
Temperate Freshwater Wetlands (Figure 5).


Lesotho Basaltic Grasslands and Southern Drakensberg Highland Grassland occur on the higher
ground to the north and east of the exploration area. These short, dense grass velds are
dominated by Themeda triandra and an admixture of other common grassveld species such as
Heteropogon, Eragrostis and Diheteropogon sp. Within the exploration area the grasslands are of
the Tsomo and Drakensberg Foothills Moist types. These taller, sweeter grasslands are
dominated by species such as Themeda triandra, Pennisetum sphacelatum and Tetrachne
dregei. Karroid species invade when the vegetation is trampled. The Eastern Freshwater
Temperate Wetland is located immediately to the north of Elliot and consists of various sedge and
reed species.


5.8.2      Fauna

As natural vegetation remains over much of the area, particularly the hillier areas, there is habitat
available for indigenous fauna. Species such as Springbok, Blesbok, Grey Rhebok, Steenbok,
Mountain Reedbuck, Common Duiker, Eland, Rock Hyrax, Cape Clawless Otter, Water
Mongoose, Black-backed Jackal, Caracal, Yellow Mongoose, White-tailed Mongoose, Black
Footed Cat, African Wild Cat, Small Grey Mongoose, Striped Polecat, Bat-eared Fox, Cape Fox,
Leopard, African Weasel, Aardwolf, Aardvark, Suricate, Baboon and Scrub Hare could be found
in the region. Many smaller mammal species can be expected to occur. These species are rated
as least concern or lower in the Red Data Book (Friedmann and Daly, 2004).


5.8.2.1 Mammals of Conservation Importance

Species such as South African Hedgehog, Spotted-necked Otter, Honey Badger, Serval and
Brown Hyaena could potentially occur in the area. These species are listed as near threatened in
the Red Data Book and require consideration when planning exploration in natural habitat. In
addition smaller mammal species such as Golden Moles, bats and rodents which are listed or
data deficient in the Red Data Book and should be considered prior to exploration.




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Figure 6:             Vegetation Types of the Elliot Exploration Right Application Area (source Mucina et al, 2004)
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5.8.2.2 Birds of Conservation Importance

There are no Important Bird Areas recognised in the Elliot region, the nearest being in KwaZulu-
Natal at Matatiele and in the Drakensberg proper (Barnes 1998). However grassland vulnerable
species such as African Marsh Harrier, Lesser Kestrel, Blue Crane, Grey Crowned Crane,
Stanley’s Bustard, Grass Owl, Southern Ground Hornbill and Yellow-breasted Pipit are known to
occur in the region. Consideration should be given to the occurrence of these species, particularly
when exploration occurs within an area of natural grassland or near a wetland.


5.9        Protected Areas and Sensitive Sites

There are no formally protected areas located within or near to the Elliot project area (Figure 6).
The exploration area falls outside of the Albany Centre of plant endemism (Van Wyk and Smith,
2001) Limited information exists on environmentally sensitive sites within the region and thus far
no sensitive sites have been identified within the exploration area. The exploration area lies at the
western edge of the Southern Drakensberg priority area identified by the National Grasslands
Biodiversity Programme as important for terrestrial biodiversity (NGBP, 2005).


5.10       Surface Water

The Elliot area has numerous small streams and dams. The major rivers in the area are the Slang
and Tsomo Rivers (Figure 6) which drain to the south. Mean annual runoff in the exploration area
is approximately 104 mm/a.


5.11       Ground Water

The exploration area falls in quaternary catchment T11A. The characteristics and depositional
history of the Molteno Formation indicate that the area should form an “ideal” aquifer. This applies
not only to the pebble conglomerates and coarse-grained sandstones at the base of the
Formation, but also to the other sedimentary bodies. The average depth to groundwater is
approximately 12 – 13 m across the exploration area. Groundwater use in the quaternary
catchments within the exploration area are low, around 0.015 to 0.2 Mm3/a, while recharge is
approximately 58 mm/a. Ground water quality in the area is generally good with the natural total
dissolved solid values in the vicinity of 257 mg/l. Exploitation potential of the ground water is
approximately 1.7 to 3 Mm3/a.




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5.12       Air Quality

Air quality in the immediate area is generally good as there is little industrial development in the
vicinity. The widespread use of coal, as opposed to paraffin, gas or electricity creates smog over
the town in the winter months that becomes a health hazard (IDP, 2006/07). Regional air quality
is also generally good.


Particulate matter from veld fires, ploughing activities and exposed agricultural lands could
potentially contribute to increased dust levels in the area. Dust fallout from vehicles travelling on
gravel farm roads and uncultivated lands will also contribute to air quality impacts in the area.
Such fallout is expected to be local and is not expected to impact air quality on a regional scale.


5.13       Noise

Farms within the exploration area are rural in nature and generally quiet. Noise that is generated
here is typical of agricultural areas and comes from agricultural vehicles, machinery and road
traffic. The train line from Indwe to Ugie passes through the exploration area and may result in
occasional higher noise levels in those areas adjacent to the line.


5.14                Heritage
           Cultural Heritage

The district is comprised largely of farming communities and it is possible that there are grave
sites located on many of the farms. There are numerous caves in the region with preserved rock
art from the Khoi people. It is known that there are examples of rock art on the farms
Crossmaloof, Rob Don and Strathgowan (National Cultural History Museum) and it is likely that
there are others.


5.15       Social and Economic Environment

The exploration area lies within the Sakhisizwe Local Municipality. The municipal area has a
population of a little over 60 000 people (Census, 2001) of which the vast majority are under the
age of 34. Annual income per household is less than R20 000 pa for a large percentage of the
residents and unemployment is very high within Sakhisiwe. Agriculture provides the greatest
employment with manufacturing contributing to a lesser degree.        Tourism is developing in the
region with both outdoor and cultural tourism contributing.




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The municipality has a housing backlog that must be addressed. Service levels for water and
sanitation in particular are poor with more than 50% of households not having access to RDP
standard services. The high unemployment rate means that many residents do not pay for
services, placing a heavy burden on the municipality.


6.                           CONSULTATION
           RESULTS OF PUBLIC CONSULTATION


6.1        Collation of Issues and Concerns

Issues and concerns relating to the application for an exploration right for coal bed methane in the
Elliot area have been captured by means of:


•          Response sheets, circulated with the BID;
•          Telephonic conversations; and
•          Email correspondence.


All responses and communications received from interested and affected parties have been
compiled and included with this document (Appendix 5). A formal response sheet, as well as a
number of emails, letters and telephonic correspondence have been received by Synergistics to
date.


6.2        Synthesis of Issues Raised`


IAP Question or Comment                                             Project Response
A number of requests from business and individuals to be            Badimo has and will consider joint ventures with local
involved with Badimo Gas as a service provider or as                business people. Wherever possible services and
employees.                                                          employees will be sourced from the local community.
Does Badimo aim to purchase properties if the                       Badimo does not intend to purchase any of the properties
exploration deems the project productive? Can the owner             on which they have made an application for exploration
sell just the mineral rights?                                       rights. In terms of the MPRDA the mineral rights are not
                                                                    owned by the land owner, but by the state.
A meeting must be held with all affected parties prior to           A land access agreement will be developed between
any work beginning. Many boreholes were drilled on the              Badimo Gas and the owner of any rights or servitude at
farm many years ago as part of oil exploration. I have this         identified target sites. Consultation will be conducted well
information.                                                        before any exploration begins. Any information from past
                                                                    drilling operations would be greatly appreciated.
The Department of Minerals and Energy (DME), Eastern                See letter from DME (Appendix 5)
Cape confirmed that, according to their records, the land
of the Badimo exploration right applications is not
affected by any old order right or any right in terms of the
MPRDA.




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7.                           SOCIO-                ASSESSMENT
           ENVIRONMENTAL AND SOCIO-ECONOMIC IMPACT ASSESSMENT


7.1        Impact Assessment Criteria

An environmental assessment of the potential impacts resulting from the drilling of exploratory
CBM boreholes within the exploration area was conducted.           The assessment involved the
application of scientific measurements and professional judgement to identify and determine the
significance of environmental impacts associated with the proposed project.          The process
involved consideration of the purpose and need for the project; views and concerns of IAPs and
the sensitivity of the receiving environment.


The significance of an impact is defined as a combination of the consequence of the impact
occurring and the probability that the impact will occur. The consequence of the impact is a
result of the extent of the impact, the duration over which the impact occurs and its intensity.


An explanation of the criteria that were systematically applied throughout the assessment
process, and terms used in the rating process are provided in Table 1 below.




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Table 1:              Impact Assessment Criteria

   Extent- the area of impact
   Site:                  impact limited to the drilling area.
   Local:                 impact limited to the drilling area and immediate neighbours. < 500 m
   Regional:              impact extending beyond the immediate neighbours.
   Don’t know:            a reasonable assessment is not possible due to the lack of current information.
                          Further work is required.
   Can’t know:            a reasonable assessment is not possible even with further work.

   Duration – the length of the period over which the impact occurs
   Short-term:            the impact will occur over a small portion of the drilling period at a site (< 1 week).
   Medium-term:           the impact will occur throughout the drilling activities (~ 3 weeks).
   Long-term:             the impact continues for a limited period after drilling activities cease (< 3
                          months).
   Residual:              the impact will continue after drilling activities cease.
   Don’t know:            a reasonable assessment is not possible due to the lack of current information.
                          Further work is required.
   Can’t know:            a reasonable assessment is not possible even with further work.

   Intensity – the magnitude of the impact
   Low:                   the impact is of a small magnitude.
   Medium:                the impact is of a medium magnitude.
   High:                  the impact is of a high magnitude.
   Don’t know:            a reasonable assessment is not possible due to the lack of current information.
                          Further work is required.
   Can’t know:            a reasonable assessment is not possible even with further work.

   Probability – the chance that the impact will occur
   Definite:              impact will occur.
   Probable:              impact will most likely occur.
   Possible:              impact could occur.
   Unlikely:              impact is unlikely to occur.
   Don’t know:            a reasonable assessment is not possible due to the lack of current information.
                          Further work is required.
   Can’t know:            a reasonable assessment is not possible even with further work.

   Significance – a summary of the impact importance taking into account the above
   considerations.
   Positive:              discernable benefits
   Very High:             impact is of the highest order possible.
   High:                  impact is substantial.
   Moderate:              impact is real but not substantial in relation to other impacts.
   Low:                   impact is of a low order.
   Very low:              impact is negligible.

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   Don’t know:            a reasonable assessment is not possible due to the lack of current information.
                          Further work is required.
   Can’t know             a reasonable assessment is not possible event with further work.


   Mitigation measures –
   These are measures that can be implemented at the operation in order to reduce the significance of
   the impact. The detailed actions, which are required to ensure that mitigation is successful, are
   given in the environmental management programme.

   Mitigation Confidence
   High:                   mitigation measures are both easy and inexpensive to implement.
   Medium:                 mitigation measures are easy to implement but are expensive/mitigation
                           measures are inexpensive but difficult to implement/mitigation measures may be
                           affected by technical requirements of drilling programme.
   Low:                    mitigation measures are both difficult and expensive to implement.


7.2        Assessment of Potential Impacts

The impacts associated with the proposed exploration activities are summarised in Table 2. The
key findings are discussed below.          The impacts have been assessed based on the project
description as outlined in Section 4. It is assumed that all mitigation measures described in this
section will be implemented as part of the environmental management programme.




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Table 2:                 Assessment of All Potential Environmental Impacts

                                                                                                                 Significance
                                                                                                                                                                        Mitigation
     Nature of Impact                Impact Source         Extent   Duration   Intensity     Probability    Without        With                 Mitigation
                                                                                                                                                                        Confidence
                                                                                                           Mitigation    Mitigation

Geology
                                                                                                                                      • Target selection to avoid
                                                                                                                                        areas with active
Creation of conduits
                                    Drilling of borehole    site    residual     high         unlikely        low         unlikely      underground mining.              medium
between geological strata
                                                                                                                                      • Boreholes to be sealed with
                                                                                                                                        cement.
                                  Removal of core                                                                                     • None necessary.
Damage to coal reserves        material during drilling.    site    residual     low          unlikely      unlikely      unlikely    • Not related to exploration as       -
                               Extraction of CBM gas.                                                                                   described in this project.
Soils
                                                                                                                                      • Minimise area of
                                                                                                                                        disturbance.
                                                                                                                                      • Vegetation to be left in
                                                                                                                                        place to protect soils.
                                  Erosion from soil
Loss of soil resource           disturbance at drilling     site    residual     low          possible        low         very low    • Where vegetation clearance         high
                                                                                                                                        cannot be avoided
                                         site
                                                                                                                                        stormwater management
                                                                                                                                        measures to be put in place.
                                                                                                                                      • Rehabilitation of disturbed
                                                                                                                                        areas.
                                                                                                                                      • Minimise footprint area of
                                                                                                                                        disturbance.
                                                                                                                                      • Access roads to follow
                                  Erosion from soil                                                                                     slope contours where
                               disturbance on access       local    residual   medium         possible     moderate         low         possible.                        medium
                                       roads                                                                                          • Vegetation to be left in
                                                                                                                                        place to protect soils.
                                                                                                                                      • Rehabilitation of disturbed
                                                                                                                                        areas.
Contamination of soils          Spillage of fuels, oils,    site    residual   medium         probable     moderate         low       • Impermeable surfaces to be       medium
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                                                                                                                    Significance
                                                                                                                                                                             Mitigation
     Nature of Impact               Impact Source            Extent   Duration    Intensity     Probability    Without        With                  Mitigation
                                                                                                                                                                             Confidence
                                                                                                              Mitigation    Mitigation
                                lubricants and drilling                                                                                      provided in areas where
                                        sludge                                                                                               hydrocarbons are managed.
                                                                                                                                         •   Emergency spill procedure
                                                                                                                                             to be put in place.
                               Uncontrolled disposal of                                                                                  •   Chemical toilets to be put in
                                                             local    residual    medium         possible     moderate       very low                                         medium
                                      sewage.                                                                                                place on site.
                                                                                                                                         •   Minimise area of
                                                                                                                                             compaction.
                                 Placement of drilling
Compaction of soils                                           site    residual    medium         probable     moderate         low       •   Scarify compacted surfaces       medium
                                     rigs on site.
                                                                                                                                             where necessary as part of
                                                                                                                                             rehabilitation.
                                                                                                                                         •   Use existing access roads
                                                                                                                                             as far as practicable.
                               Vehicles accessing site       local    residual      low          probable     moderate         low       •   Scarify compacted surfaces       medium
                                                                                                                                             where necessary as part of
                                                                                                                                             rehabilitation.
Topography
                                                                                                                                         • Stockpile soils for
Changes to the shape or
                                                                                                                                           rehabilitation.
form of the land               Levelling of drilling sites    site    residual      low          possible        low         very low                                           high
                                                                                                                                         • Rehabilitate to original
                                                                                                                                           landform.
Land Use & Land
Capability
                                                                                                                                         • Site selected to minimise
                                                                                                                                           disturbance of current land
                                                                                                                                           use.
                               Establishment of drilling                                                                                 • Land use agreement with
Change of current land use                                   local    long-term     high          definite    moderate         low                                            medium
                               site and access road.                                                                                       relevant surface and
                                                                                                                                           mineral right owner to
                                                                                                                                           define location and extent of
                                                                                                                                           drilling site
Reduction in land capability        Undertaking of           local    residual      low          possible        low         very low    • Site selected to minimise          medium

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                                                                                                                     Significance
                                                                                                                                                                             Mitigation
     Nature of Impact                Impact Source           Extent     Duration   Intensity     Probability    Without        With                 Mitigation
                                                                                                                                                                             Confidence
                                                                                                               Mitigation    Mitigation
                                  exploration activities.                                                                                   disturbance of land
                                                                                                                                            capability.
                                                                                                                                          • Implement rehabilitation
                                                                                                                                            measures to minimise
                                                                                                                                            impact on land capability.
                                                                                                                                          • Target selection to avoid
                                                                                                                                            areas with active
                                    Drilling and drilling               medium-
Sterilisation of coal reserves                                local                  low          unlikely      unlikely      unlikely      underground mining.                 high
                                          activities                     term
                                                                                                                                          • Not related to exploration as
                                                                                                                                            described in this project.
Ecology
                                                                                                                                          • Site selection, based on
                                                                                                                                            environmental site
                                                                                                                                            assessment, aimed at
                                                                                                                                            minimising disturbance to
Removal/ damage of               Establishment of drilling                                                                                  natural vegetation.
                                                              local     residual     high         probable     moderate         low                                           medium
natural vegetation               sites and access routes.                                                                                 • Minimise the area of
                                                                                                                                            disturbance.
                                                                                                                                          • Vegetation is to be left in
                                                                                                                                            place unless site levelling is
                                                                                                                                            required.
                                                                                                                                          • No smoking at the drilling
                                                                                                                                            site.
                                                                                                                                          • Fires only allowed at the
                                                                                                                                            cooking area in the camp
                                                                                                                                            site.
                                     Accidental fires        regional   residual     high         possible       high         medium      • Code of conduct to include        medium
                                                                                                                                            measures for the prevention
                                                                                                                                            of fires.
                                                                                                                                          • Emergency equipment and
                                                                                                                                            procedure for fire fighting to
                                                                                                                                            be in place.
Damage to habitats or             Vegetation clearance        local     residual     high         possible     moderate       very low    • Site selection, based on          medium

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                                                                                                                 Significance
                                                                                                                                                                          Mitigation
     Nature of Impact                Impact Source          Extent   Duration   Intensity    Probability    Without        With                  Mitigation
                                                                                                                                                                          Confidence
                                                                                                           Mitigation    Mitigation
species of conservation             for drilling sites or                                                                                 environmental site
importance                            access roads.                                                                                       assessment to minimise
                                                                                                                                          impacts on habitats of
                                                                                                                                          conservation importance.
                                                                                                                                      •   Minimise area of
                                                                                                                                          disturbance.
                                                                                                                                      •   Site assessment to identify
                                                                                                                                          habitats of conservation
                                                                                                                                          importance and site specific
                                                                                                                                          actions to be developed
                                                                                                                                          where required.
                                                                                                                                      •   Poaching is illegal and is to
                                                                                                                                          be prohibited.
                                                                                                                                      •   Environmental awareness
                                        Poaching            local    residual     low         possible        low         very low                                           high
                                                                                                                                          training.
                                                                                                                                      •   Code of conduct to cover
                                                                                                                                          aspects on poaching.
                                                                                                                                      •   Environmental site
                                                                                                                                          assessment including
Disturbance of sensitive                                             medium-                                                              consideration of impacts on
                                    Drilling activities     local               medium        possible     moderate         low                                            medium
species in the locality.                                              term                                                                the local environment.
                                                                                                                                      •   Site selection to avoid local
                                                                                                                                          impacts.
                                                                                                                                      •   Removal of alien vegetation
                                                                                                                                          which may establish in
                                                                                                                                          disturbed areas.
                               Disturbance of existing
Proliferation of invasive                                                                                                             •   Rehabilitation; monitoring
                               vegetation and soils by
                                                            local    residual   medium        probable     moderate         low           including alien plant              low
plant species                   drilling activities and
                                                                                                                                          establishment and
                                        vehicles
                                                                                                                                          implementation of a control
                                                                                                                                          programme where
                                                                                                                                          necessary.


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                                                                                                                    Significance
                                                                                                                                                                             Mitigation
     Nature of Impact               Impact Source          Extent     Duration    Intensity     Probability    Without        With                  Mitigation
                                                                                                                                                                             Confidence
                                                                                                              Mitigation    Mitigation

Protected Areas and
Sensitive Sites
                                                                                                                                         • No drilling sites to be
Damage of sensitive areas
                              Establishment of drilling                                                                                    established on sites formally
identified in conservation                                   site     residual      high         possible     moderate       very low                                           high
                              sites or access routes.                                                                                      identified as being of
plans
                                                                                                                                           conservation importance.
                                                                                                                                         • No exploration allowed
                                                                                                                                           within the 1 in 50 year flood
                                                                                                                                           line or within 100m from a
                                                                                                                                           drainage line or wetland.
Disturbance of riparian       Establishment of drilling
                                                                                                                                         • River and wetland crossings
habitats, river banks or      sites or access routes,        site     residual    medium         possible     moderate         low                                            medium
                                                                                                                                           to be avoided.
wetland                           drilling activities.
                                                                                                                                         • Stream banks are not be
                                                                                                                                           damaged in order to access
                                                                                                                                           water for exploration
                                                                                                                                           activities.
Surface Water
                                                                                                                                         • Implement measures to
Contamination of surface        Spillage of fuels, oils               medium-                                                              protect soils from pollution.
                                                           regional                 low          possible        low         very low                                         medium
water                             and lubricants                       term                                                              • Sites beyond the 1:50 year
                                                                                                                                           flood line.
                                                                                                                                         • Implement measures for soil
                                Increase in sediment
                                                                                                                                           erosion control.
                                 loads as a result of      regional   long-term     low          unlikely        low         very low                                         medium
                                       erosion                                                                                           • Sites beyond the 1:50 year
                                                                                                                                           flood line.
                                                                                                                                         • Provide toilet and waste
                                General and human                     medium-
                                                           regional                 low          possible        low         very low      disposal facilities at drilling    medium
                                      waste                            term
                                                                                                                                           site and camp
                                                                                                                                         • Use water efficiently.
                               Taking water for drilling              medium-
Reduction of stream flow                                   regional                 low          possible        low           low       • Do not use more water than           high
                                     activities.                       term
                                                                                                                                           legally authorised.


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                                                                                                                   Significance
                                                                                                                                                                            Mitigation
     Nature of Impact               Impact Source          Extent     Duration   Intensity     Probability    Without        With                  Mitigation
                                                                                                                                                                            Confidence
                                                                                                             Mitigation    Mitigation
Groundwater
Contamination of ground         Seepage of fuels, oils                                                                                  • Implement measures to
                                                           regional   residual     low          possible        low         very low                                         medium
water                              and lubricants                                                                                         protect soils from pollution
                                                                                                                                        • Holes that will not be used
                              Cross-contamination of
                                                                                                                                          further in the exploration will
                              aquifers due to borehole     regional   residual     low          unlikely      very low      very low                                         medium
                                                                                                                                          be backfilled with cement
                                    construction.
                                                                                                                                          and sealed.
                                                                                                                                        • Use water efficiently.
Reduction in groundwater       Taking water for drilling              medium-
                                                            local                  low          possible        low           low       • Do not use more water than           high
levels                                activities                       term
                                                                                                                                          legally authorised.
Air Quality
                                                                                                                                        • There is to be no
                                 Exhaust fumes from
Release of gaseous                                                    medium-                                                             unnecessary revving of
                               vehicles and machinery       local                  low          possible        low         very low                                           high
emissions                                                              term                                                               engines or operation of
                                related to exploration.
                                                                                                                                          motors.
                                                                                                                                        • Cap boreholes when no
                                Release of methane                                                                                        drilling taking place and seal
                                                            don’t     medium-
                                gas from exploration                               High         probable       high         very low      boreholes to prevent                 high
                                                            know       term
                                     boreholes.                                                                                           emissions immediately after
                                                                                                                                          completion of drilling.
                                Exploration vehicles                                                                                    • Restrict travelling speed of
                                                                      medium-
Dust Fallout                    travelling on gravel        local                  low           definite       low           low         vehicles sufficiently to             high
                                                                       term
                                        roads                                                                                             reduce dust.
Noise
                                                                                                                                        • Ensure all mufflers on
                                                                                                                                          vehicles are in full
                                                                                                                                          operational order.
Increase in ambient noise        Operation of heavy                   medium-                                                           • Site selection to give
                                                            local                  low           definite       low         very low                                         medium
levels                          machinery and traffic                  term                                                               cognisance to the location
                                                                                                                                          of noise receptors and
                                                                                                                                          efforts to be taken to
                                                                                                                                          minimise such disturbance.

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                                                                                                                    Significance
                                                                                                                                                                              Mitigation
     Nature of Impact               Impact Source          Extent     Duration    Intensity     Probability    Without            With                 Mitigation
                                                                                                                                                                              Confidence
                                                                                                              Mitigation       Mitigation
Visual
                                                                                                                                            • Drilling sites to be
                                  Drilling rigs and
                                                                                                                                              established out of view of
                               associated equipment                   medium-
Disruption of views                                        regional                 low          Unlikely        low            very low      major tourist routes.            medium
                                   located within                      term
                                                                                                                                            • Rehabilitate site to original
                                    landscapes.
                                                                                                                                              condition.
Cultural Heritage
                                                                                                                                            • Establishment of drilling
                                                                                                                                              sites within any battle site,
                                                                                                                                              heritage area, cemetery or
                                                                                                                                              grave to be prohibited.
Destruction of cultural        Establishment of drilling                                                                                    • Area of disturbance to be
                                                             site     residual      high         unlikely        low            very low                                       medium
heritage sites and artefacts   sites or access routes.                                                                                        within that prohibited to
                                                                                                                                              occur without a heritage
                                                                                                                                              impact survey.
                                                                                                                                            • Report all discoveries to
                                                                                                                                              local museum.
Social and Economic
Environment
                                                                                                                                            • Preference to be given to
                                                                      medium-
Contribution to the economy          Employment            regional                 low          probable              low positive           the employment of local            low
                                                                       term
                                                                                                                                              persons.
                                                                                                                                            • Preference to given to use
                               Use of contractors and                 medium-
                                                           regional                 low          probable              low positive           of local contractors and         medium
                                purchasing of goods                    term
                                                                                                                                              local suppliers.
                                                                                                                                            • Implement measures to
                                Dust and noise from                                                                                           minimise air quality and
                                                                      medium-
Creation of nuisance            drilling activities and     local                   low          possible        low            very low      noise impacts.                   medium
                                                                       term
                                        vehicles                                                                                            • Establish a forum for
                                                                                                                                              persons to raise complaints.
Disturbance of farming or      Loss of crop or grazing                                                                                      • Site assessment to mitigate
                                                             site     long-term   medium         probable        low            very low                                       medium
other land use activities.          land due to                                                                                               impacts on land use.

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                                                                                                                      Significance
                                                                                                                                                                             Mitigation
     Nature of Impact               Impact Source           Extent     Duration     Intensity     Probability    Without        With                 Mitigation
                                                                                                                                                                             Confidence
                                                                                                                Mitigation    Mitigation
                                establishment of drilling                                                                                  • Land Use Agreement with
                                sites and access routes.                                                                                     individual farmers as to the
                                                                                                                                             use of land.
                                                                                                                                           • Site assessment to identify
                                                                                                                                             impacts on infrastructure.
                                Disturbance of service
                                                              site     short-term   medium         probable      medium          low       • Land Use Agreement with
                                     infrastructure
                                                                                                                                             holders of registered
                                                                                                                                             servitudes.
                                                                                                                                           • Implement accidental fire
                                    Accidental fires        regional    residual      high         possible       high        moderate       mitigation measures as for       medium
                                                                                                                                             protection of vegetation.
                                                                                                                                           • Trespassing to be
                                                                                                                                             prohibited. Personnel to be
                                                                                                                                             allowed within restricted
                                                                                                                                             areas.
                                                                       medium-
                                 Trespassing and theft       local                    low          possible     moderate       very low    • Code of Conduct to include       medium
                                                                        term
                                                                                                                                             the prohibition of
                                                                                                                                             trespassing.
                                                                                                                                           • Drilling personnel to carry
                                                                                                                                             identification.
                                                                                                                                           • Liaison between holders of
                                                                                                                                             different rights over same
                                                                                                                                             location.
                                  Granting of rights by
Conflict with holders of                                                                                                                   • Agreement between rights
                                   DME and PASA for
rights for different minerals                                local     long term      high         possible       high           low         holders over exploration         medium
                                different minerals in the
in the same location                                                                                                                         and prospecting methods,
                                      same location
                                                                                                                                             impacts, mitigation and
                                                                                                                                             liabilities.
                                                                                                                                           • DME and PASA to liaise
                                                                                                                                           • Implement measures to
Loss of sense of place and        Visual intrusion of                  medium-                                                               reduce the visual impacts of
                                                            regional                  low          unlikely        low         very low                                       Medium
eco-tourism potential           exploration equipment.                  term                                                                 exploration. Rehabilitate sit
                                                                                                                                           • Rehabilitate site.

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7.2.1      Geology

It is highly unlikely that drilling into, and extracting a small core from, the coal seams will impact
on the geological strata in any significant manner. The boreholes will be sealed with cement
following completion of drilling.


7.2.2      Soils

Given the limited duration and extent of the prospecting activities the impacts on soils are likely to
be moderate to low. However, if the appropriate mitigation measures are not put in place such
impacts could be residual, lasting long after exploration activities have ceased. Drilling vehicles
should not access vleis or wetlands and areas with wet soils should be avoided. The footprint of
drill sites and access roads is to be clearly demarcated and no disturbance is to take place
outside of this area. The footprint area should include the turning circle required for the all
vehicles and the working space of the drill site and must be limited to an area as small as is
reasonably possible.


Soils can be eroded from areas exposed by the establishment of drilling infrastructure and access
roads. Given that drilling activities will be carried out on site for a very small period of time, it is
recommended that vegetation should not be stripped to allow for the establishment of
infrastructure. The maintenance of vegetation on site will ensure that soils are not lost due to
water or wind erosion. Rehabilitation should encourage the regrowth of vegetation to minimise
soil losses.


The construction of new access roads should be limited through careful site layout planning and
should it be necessary to access a slope, the road should follow the natural contours of the land.
Drainage and erosion controls are to be instituted where required on slopes and will include the
construction of erosion control berms.


Contamination of soils by hydrocarbon products is possible but impacts are considered to be of
moderate significance given the relatively small volumes of fuels, oils and lubricants that will be
stored and used on site. The potential impact can be reduced by ensuring that storage and use
of hydrocarbons will take place on impermeable surfaces. Storage areas are also to include
temporary bunds to contain any accidental spills. Spill kits must be available on site.


Soils will be compacted due to the presence of heavy machinery and the movement of vehicles to
and from the site.         Compacted soils will need to be scarified as part of the rehabilitation
programme.



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7.2.3      Topography

The development of drilling sites and access roads will only impact on the local topography in
areas where steep slopes are encountered and levelling of the ground is required. Areas that are
levelled for drilling sites and access roads will be restored to the original landform upon
completion of the exploration. This would mean that the final impact on topography as a result of
exploration activities will be of very low significance.


7.2.4      Land Use & Land Capability

Farmers concerns over the impact of exploration activities on farming activities are valid as each
exploration drilling site will occupy an area of up to 1 000 m2 and will preclude other land uses for
the duration of the drilling period. Such impacts would be of moderate significance. Assessment
of drilling sites prior to site establishment in consultation with the land and rights owners will
ensure that conflicting land uses are avoided where possible and disturbance to farming activities
are kept to a minimum. Permanent impacts on the land capability are unlikely and rehabilitation of
the disturbed areas will enable existing or suitable land use to be implemented shortly after
drilling has commenced. Boreholes not to be used in the future are to be sealed with cement
below a depth sufficient to allow for normal farming operations to continue without the risk of the
borehole being accidentally opened by daily activities e.g. ploughing of fields.


The sterilisation or damage of coal reserves during this early phase of exploration activities is
highly unlikely. Consultation with mining houses that hold relevant prospecting and mining rights
prior to site establishment will ensure that exploration drilling will not take place in areas where
active underground coal mining is taking place. The drill rig will only be in place for a short period
of time and there will not be permanent impacts preventing future mining of these coal reserves.


Damage to service infrastructure such as pipelines, electricity transmission and distribution lines
could occur if drilling sites are located on servitudes. Consultation with the relevant holders of
servitudes for such services prior to the establishment of a drilling site will ensure drilling does not
damage infrastructure or disrupt services.




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7.2.5      Ecology

Impacts of moderate significance on the ecology are likely if drilling activities occur in areas
where plant and faunal species of conservation importance occur. Damage or destruction of the
vegetation, habitat and the loss of plant and faunal species of conservation concern could result
from exploration activities.        Assessment of proposed sites by an environmental assessment
practitioner (EAP) or ecologist will be required to assess ecological sensitivities of the site as well
as surrounding areas that could be disturbed by exploration activities. Alternative sites are to be
selected where sensitivities are identified in order to prevent impacts of significance. Where
necessary site specific action plans are to be developed to further protect sensitive fauna and
flora.


7.2.6      Protected Areas and Sensitive Sites

Disturbance to protected areas and sensitive sites is to be avoided as impacts would negatively
impact conservation of these areas and species occurring there. It should however be noted that
no protected areas or sensitive sites have been identified within the exploration area.
Assessment of each proposed drilling site by an EAP or ecologist prior to site establishment in
consultation with the relevant conservation plans will prevent damage or disturbance to sensitive
sites, effectively mitigating the impacts.


7.2.7      Surface Water

Potential impacts of exploration activities on surface water include the contamination of the
resource as a secondary impact resulting from soil contamination or erosion. Since the primary
impact is considered to be moderate to low and easily mitigated, there is no major concern that
the exploration activities will result in any significant risk to water resources.


Water will be required for the operation of the drilling rig and this may be abstracted from a
surface water resource such as a river or dam. This abstraction must be done without impacting
on the water use of the land owner or contravention of the conditions defined in the General
Authorisation issued by the Department of Water Affairs and Forestry (No 1191 published in the
Government Gazette no. 26187 dated 26 March 2004). No impoundments or alterations will be
made to the bank or flow path of the water resource.




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7.2.8      Groundwater

Exploration activities are not expected to have a significant impact on groundwater resources.
This is motivated by the fact that there will be no significant extraction of groundwater from any
borehole during the exploration phase of the project. Groundwater use will be limited to the
possible extraction of water from existing boreholes for the operation of the drilling rig. The
amount of water extracted will be limited and not in contravention of the conditions defined in the
General Authorisation issued by the Department of Water Affairs and Forestry (No 1191
published in the Government Gazette no. 26187 dated 26 March 2004).


Since the potential for soil contamination is limited it is not expected that such contamination will
impact on groundwater quality.      Pollution control measures for the protection of soils must
however be put in place.


Drilling will create a small connection between geological strata that may be a conduit for water
movement. This is unlikely to have a residual impact as unsuccessful boreholes will be sealed
with cement. Successful exploration boreholes that are to be revisited will be lined, and any water
carrying zones sealed off, thereby preventing the transmission of ground water from upper
aquifers to those lower in the sequence and especially from those in the coal seams.


7.2.9      Air Quality

The release of gas from exploration boreholes is of concern if the boreholes are not sealed
sufficiently on completion of drilling. Boreholes that are to be used for further investigation are to
be capped when there are no drilling activities taking place. Boreholes not to be used in the
future are to be sealed, with a significant impermeable cement seal which ensures that no gas will
escape.


Dust fallout resulting from the movement of vehicles to and from the exploration sites on gravel
roads may contribute to elevated particulate matter levels in the air on a local scale. Limiting
vehicle speeds will ensure that dust entrainment is limited and impacts are of low significance.


7.2.10     Noise

The operation of the drill rig and the movement of vehicles to and from the prospecting site are
likely to contribute to noise levels in the local extent. This is aggravated by the possible operation
of the drill rig over a 24-hour period. The site assessment undertaken prior to site establishment
is to focus on a site selection that will minimise impacts on noise receptors.




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7.2.11      Visual

Drilling rigs will be limited in number and thus are not expected to have a major impact on natural
views on a regional context. However, since the area has significant eco- and cultural- tourism
appeal the disruptions of views from any tourist route should be avoided or limited to a short
duration.


7.2.12      Cultural Heritage

The cultural heritage of the area is reasonably well researched and known and it is thus unlikely
that a drilling site could be located on a heritage site. Site assessment by an EAP is to ensure
that establishment of a drilling site and the development of access routes does not take place
within any cemetery, graveyard or cultural site.     Any discovery of a cultural artefact will be
reported to the local museum.


7.2.13      Social and Economic Environment

Positive impacts of the exploration project will include the creation of employment and the
stimulation of the local economy through the purchase of supplies. These impacts will be of low
significance as employment opportunities are limited and temporary. Supplies needed to operate
the drilling equipment and sustain the personnel will be acquired locally thus providing limited
input into the local economy.


Exploration activities will result in some noise, and dust pollution which could be a nuisance to
local residents and thus have an impact on their lives.        The implementation of mitigation
measures to reduce noise and dust impacts will reduce nuisance impacts. Early and ongoing
communications with affected parties and land owners are also necessary to manage such
impacts as well as ensure that disruptions to the daily activities of local persons are kept to a
minimum.


Concerns regarding site access, fence cutting, trespassing and farm security as a result of the
drilling teams being on private land will be alleviated by developing relationships with individual
farm owners and accessing private land as per a land use agreement approved by the land
owners and Agri-SA. Poaching, theft and accidental fire are all issues associated with access
granted during exploration activities. It is also recommended that all exploration personnel carry
identification cards which can be produced on request. No fires are to be allowed on site and an
emergency procedure for the control of accidental fire is to be put in place. A land use agreement
must also be developed with the holders of registered servitudes.




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The unconditional granting of rights for different minerals in the same location by the DME and
PASA could result in significant problems when both holders of rights wish to exploit their
respective resource. Where applications for competing rights have been granted to both parties
agreement will need to be reached between the parties as to how the resource is exploited to the
mutual benefit of both parties. The agreement should consider the methods and timing of
exploration and prospecting, the location of activities, identification of impacts and mitigation and
the determination of liabilities. The DME and PASA must liaise more closely to ensure that
applications in the same location, albeit for different minerals are not granted or are not granted
unconditionally.




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8.            ENVIRONMENTAL MANAGEMENT PROGRAMME


8.1           Objectives

The objective of the EMP is to detail actions required to address the impacts identified in the EIA
(Section 7) during the establishment, operation and rehabilitation of drilling sites. The EMP
provides an elaboration of how to implement the mitigation measures documented in the EIA.


8.1.1         Environmental Impacts

The aim of the EMP is to reduce the significance of negative impacts and enhance positive
impacts as far as practicably possible. The overall objectives are thus to:


•    minimise disturbance on the physical environment including the protection of soils, surface
     water and groundwater during drilling operations;
•    minimise disturbance to the ecological environment and prevent disturbance to sensitive
     sites;
•    prevent disturbance of sites of cultural and historical importance;
•    minimise disturbance to current land uses and neighbouring activities;
•    provide for a forum for consultation with land owners and affected parties; and
•    facilitate socio-economic development where practicable.


8.1.2         Rehabilitation

Exploration activities are to be undertaken in a manner which facilitates site rehabilitation and the
restoration of existing land capabilities. The primary objectives for rehabilitation include the:


•    removal of all infrastructure and material introduced to site;
•    removal of all wastes and their appropriate disposal;
•    promotion of the rapid re- establishment of natural vegetation and the restoration of site
     ecology; and
•    facilitation of the re-establishment of the land use and land capability to as close as
     reasonably possible to the original conditions.


8.1.3         Action Plan

The various actions that need to be implemented, to ensure that the environmental objectives are
met, are detailed in the EMP. The actions are aimed at mitigating environmental impacts and
implementing the rehabilitation plan.


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The management actions are stated in a manner that ensures that they can be audited during the
performance assessment programme.


8.1.4      Time Schedule

Time-frames detail the implementation schedule of management actions.                   The successful
implementation and commencement within the timeframes is to be monitored as part of the
performance assessment programme.


8.1.5      Requirements for Implementation

Additional measures that will need to be put in place to allow for the successful implementation of
the action plan are listed where relevant.


8.2        Emergency Procedures

Emergency procedures indicate the actions to be taken in the case of an environmental
emergency. An environmental emergency refers to an event that could result in a pollution
incident or damage to the biophysical or social environment including surrounding habitats or land
use. The environmental emergency procedures required as a result of the proposed exploration
activities have been identified in the EMP (Table 3).


8.2.1      Fire

The following are to be included as key criteria of the emergency procedure:
•   Fire fighting equipment, including fire-extinguishers and fire beaters, are to be kept on site.
              o    At least one fire extinguisher at both the drilling and the camp sites.
              o    Three fire beaters at both the drilling and the camp sites.
•   Contact details of the land owner, neighbouring land owners as well as the local fire
    department are to be kept on hand at the drilling and camp sites.
•   The making of fires for cooking, warmth or any other purposes, except in the demarcated
    cooking area, is to be prohibited.


In the event of a fire starting on site, the following steps are to be implemented:
    - Attempt to extinguish or contain the fire, using the beaters or extinguishers. Elicit help of
        staff in the area.
    - If the fire cannot be extinguished or contained using these measures, the Site Manager is
        to be contacted and notified of the location and extent of fire.
    - In the case of a fire occurring in close proximity to a methane-rich borehole site, stop the
        drilling and cap the borehole to prevent gaseous emissions come into contact with the fire.
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    - All flammable substances in the path of the fire are to be removed.
    - Notify the land owner of the fire and elicit assistance in fighting the fire.
    - Mobilise staff to utilise the plant equipment and the water cart, plus any other fire
        extinguishing media to extinguish or contain the fire.
    - Contact the local fire fighting emergency service to assist in fighting the fire.
    - Contact neighbouring land owners who have property in the path of the fire.
    - The incident is to be reported as part of the incident reporting procedure. The cause is to
        be investigated and measures put in place to prevent such an incident from re-occurring.


8.2.2      Spillage of a fuel, oil, lubricant or any other chemical substance

The following are to be included as key criteria of the emergency procedure:
•   Material safety data (MSD) sheets are to be obtained for all hazardous chemicals stored on
    site. These should be kept in close proximity to where the chemicals are stored on site.
    Ensure that the MSD sheets contain sufficient information on environmental risks and clean-up
    measures.
•   Spill kits are to be purchased and kept on site in close proximity to fuel/oil/lubricant storage
    areas. These should include a bucket, absorbent material (sand or commercial product such
    as Peatsorb) and a spade.
•   A commercially available product for the treatment of soils contaminated with hydrocarbons is
    to be purchased and kept on site.


In the event of a chemical spill taking place on site, the following actions should take place:
    -   Close, seal or otherwise prevent further spillage from the source.
    -   Take reasonable steps to contain the spilled product. This may include the construction of
        earth berms. Attention should be given to the protection of watercourses and drainage
        lines.
    -   Notify the Site Manager of the spill.
    -   Lift as much of the spilled material as practical.
    -   In the case of a hydrocarbon spill, add an absorbent material to remove the remaining
        material.
    -   In the case of any other chemical spill, handle and remove the material in accordance with
        the MSD requirements.
    -   Place all spilled material and absorbent material used in clean-up in a container for
        disposal as hazardous waste.
    -   In the case of a hydrocarbon spill, treat any contaminated soil in the footprint area with a
        suitable, commercially available product for the in situ remediation of such spills.
    -   The incident is to be reported as part of the incident reporting procedure. The cause is to
        be investigated and measures put in place to prevent such an incident from re-occurring.
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Table 3:                Environmental Management Programme


                Objectives                                                  Action Plan                                                 Schedule                Requirements for Implementation
1.   Roles and Responsibilities

To assign roles and responsibilities for the   • Badimo Gas is ultimately responsible for implementation of and           Immediate, upon approval of the   -
implementation of the EMP requirements.            compliance with the EMP by the entire workforce.                       EMP by PASA.

                                               • Badimo Gas is to assign responsibility for the implementation of         Immediate, upon appointment of    Contract to include assignment of
                                                   the EMP to the site manager of the contracted drilling company.        contractor.                       responsibility and liability for
                                                                                                                                                            compliance with EMP.

                                               •    Badimo Gas is to appoint an EAP responsible for                       Immediate, upon approval of the   -
                                                    Environmental Induction Programme, Environmental Site                 EMP by PASA.
                                                    Assessment and Performance Monitoring.
2.   Environmental Awareness

To ensure that all members of the              •     All personnel involved in the exploration project are to undergo     Prior to commencement of work     Environmental Induction Programme
exploration workforce are aware of their             environmental induction and awareness training.                      at a site.                        including:
responsibilities towards environmental         •     All personnel are to sign a register acknowledging that have                                           - Environmental Awareness;
protection and the EMP requirements.                 understood and will adhere to the Code of Conduct.
                                                                                                                                                            - Job Specific Training;
To ensure that all members of the              •     Identification of environmental risks of jobs is to be included in   Prior to commencement of work
                                                                                                                                                            - Emergency Procedures (Section 8.2);
workforce are aware of the environmental             the Job Specific Training.                                           at a site.
risks and consequences of their actions.                                                                                                                    - Code of Conduct (Appendix 6).



To ensure on-going environmental               •     Code of Conduct is to be displayed prominently on site.              Ongoing during operations.        Code of Conduct and Emergency
awareness by all members of the                                                                                                                             Procedure Posters displayed on site.

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                Objectives                                                    Action Plan                                       Schedule                 Requirements for Implementation
workforce.
                                               •   Emergency Procedures are to be displayed prominently on site.
3.   Public Relations

To keep affected parties informed of           •   Feedback is to be given to registered IAPs of Phase 1 findings.    On completion of Phase 1.         Feedback notices to all IAPS, possible
developments.                                                                                                                                           public meeting.
                                               •   All personnel are to be provided with an identifiable uniform or
To alleviate concerns of safety and security                                                                          On appointment of personnel.      Branded uniform or ID card.
                                                   access card which should be carried on the person at all times.

To minimise disturbance to neighbouring        •   Driving on private roads not designated as site access roads is    Ongoing during operations.        Code of Conduct (Appendix 6)
activities.                                        to be prohibited, unless prior permission has been obtained
                                                                                                                                                        Land Use Agreement
                                                   from the land owner.
                                               •   All gates on private roads are to be closed if found closed and
                                                   left open if found open.
                                               •   Access only permitted to areas agreed upon
                                               •   Provide land owners and potentially affected parties with
To minimise the nuisance to affected                                                                                  Site establishment.               Complaints Forum.
                                                   contact information of drilling site supervisor to allow for
parties.
                                                   reporting of complaints.
                                               •   Reported complaints are to be recorded in the incident
                                                   reporting procedure.
                                               •   The holders of prospecting and mining rights and registered
To avoid conflicts with rights holders                                                                                One month before site             Signing of Land Use Agreement
                                                   servitudes are to be consulted and agreement reached on the
                                                                                                                      establishment.
                                                   establishment of drilling and associated infrastructure on site.
4.   Site Access
                                               •   The owners of surface rights at exploration target areas are to
To avoid conflicts with land and rights                                                                               One month before site             Follow Farm Access Protocol
                                                   be consulted and permission obtained to access and establish
owners                                                                                                                establishment.                    developed by Agri-SA.

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                Objectives                                             Action Plan                                            Schedule                  Requirements for Implementation
                                              drilling and associated infrastructure on site.
                                                                                                                                                       Signing of Land Use Agreement by the
                                          •   Agreement is to be sought from owners of surface and mineral
                                                                                                                                                       relevant owners.
                                              rights and registered servitudes on the location and extent of
                                              drilling site, the use of roads & water and the establishment of
                                              camps.
                                          •   Follow Farm Access Protocol developed by Agri-SA.
To not compromise security on farms                                                                               Ongoing during operations.           Code of Conduct
                                          •   Access into areas other than those agreed for use by the
                                                                                                                                                       Signing of Land Use Agreement by the
                                              exploration team is to be prohibited without the permission of
                                                                                                                                                       land owner.
                                              the land owner.
                                          •   All gates on the land owners’ property are to be closed if found
                                              closed and left open if found open.

5.   Environmental Site Assessment

To identify environmental sensitivities   •   EAP or ecologist to conduct an Environmental Site Assessment        After target sites are identified.   Environmental Site Assessment.
within the target area.                       of proposed drilling and camp sites within target areas.

                                          •   Environmental Site Assessment is to identify environmental
                                              sensitivities including species or habitats of conservation
                                              importance, graves/cemeteries or cultural sites, steep slopes,
                                              receptors to dust and noise.

                                          •   Environmental Site Assessment is to identify drainage lines and
                                              watercourses and make recommendations to ensure the drilling
                                              site is beyond the 1:50 year flood line.

                                          •   The      Environmental    Site    Assessment       is   to   make
                                              recommendations on alternative sites/ access routes and/or

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                Objectives                                                  Action Plan                                            Schedule                   Requirements for Implementation
                                                 site specific actions required to ensure the protection of the
                                                 environment.

6.   Erosion Control
                                             •   Avoid, as far as possible, areas with soils that have high
To prevent soil erosion as a result of the                                                                              Site establishment.
                                                 erosion potential.
development of access roads and drilling
sites.                                       •   Access routes on slopes are to follow natural contours of the
                                                 land as far as possible.
                                             •   Should it be necessary to access slopes where there is a risk of
                                                 erosion, appropriate erosion controls (such as cross berms) are
                                                 to be put in place.
                                             •   Earthworks are to be limited to areas where site levelling is
                                                 required for the placement of infrastructure.
                                             •   Soil stripping is to be limited to areas where levelling is required
                                                 for the development of site infrastructure.
                                             •   Vegetation is not to be removed except in areas where site
                                                 levelling is required.
                                             •   Where vegetation is required to be cut in order to improve the
                                                 access to an area, this is to be undertaken in accordance with
                                                 the recommendations of the Environmental Site Assessment.
                                             •   Soil that is removed during site levelling is to be placed
                                                 upstream of the site in order to divert stormwater run-off around
                                                 exposed soils surfaces.
7.   Protection of Sensitive Sites
                                             •   Access routes, drilling and camp sites are to be selected in
To protect sensitive sites.                                                                                             Prior to site establishment.         Environmental Site Assessment

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                 Objectives                                              Action Plan                                            Schedule                      Requirements for Implementation
                                                 consultation with the EAP, based on the outcomes of the
                                                 Environmental Site Assessment.
                                             •   Access routes, drilling and camp site areas are to disturb the
To minimise the area of disturbance.                                                                                 Site establishment.                  -
                                                 minimum area possible. Provision is to be made for the turning
                                                 of vehicles within the demarcated area.
                                             •   Access routes, drilling and camp site areas are to be
                                                 demarcated using beacons/flags and demarcation tape.

                                             •   Sensitive sites are to be demarcated using beacons/flags and        Site establishment.                  -
                                                 demarcation tape.
                                             •   Entry into areas (either on foot or by vehicle) outside of that
                                                                                                                     Ongoing during operations.           -
                                                 which has been demarcated for use in exploration is prohibited
                                                 without the permission of the land owner.
8.   Water Use
                                             •   Obtain permission from the land owner for access to the water
To ensure legality of water use.                                                                                     Prior to site establishment.         Signing of Land Use Agreement by the
                                                 resource and the placement of infrastructure.
                                                                                                                                                          land owner
                                             •   Water consumption is to remain within the limits of the General
                                                                                                                     Ongoing during operations.           -
                                                 Authorisation for that water use.
                                             •   The alteration of river banks to allow access to watercourses is
To protect watercourses and drainage lines                                                                           Prior to site establishment and      Environmental Site Assessment
                                                 to be prohibited.
from damage due to water use.                                                                                        ongoing during operations.
                                             •   Ensure drilling and camp site are not within 1:100 year floodline
                                                 or 100m of a watercourse.
                                             •   Potable water source is to be identified prior to site
To ensure access to potable water use.                                                                               Prior to site establishment.         Signing of Land Use Agreement by the
                                                 establishment.
                                                                                                                                                          land owner.


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                Objectives                                             Action Plan                                             Schedule                      Requirements for Implementation
                                            •   Permission is to be obtained for the sourcing of water from
                                                this source.
9.   Spill Prevention and Clean Up
                                            •   Bunded areas are to be created for the storage of all hazardous
To contain spillage of hazardous chemical                                                                           Site establishment.                  -
                                                chemical substances (fuel, oil, lubricants and laboratory
substances and prevent the contamination
                                                chemicals).
of soils or water resources
                                            •   Temporary bunds are to include an impervious floor (plastic
                                                sheeting) and earth/sandbag walls.
                                            •   Bund should have capacity to contain 110% of the contents
                                                contained within the bund.
                                            •   Sludge ponds are to be lined with impervious plastic sheeting.
                                            •   Major repair work to vehicles and machinery is to take place off-
                                                                                                                    Ongoing during operations.           -
                                                site.
                                            •   Emergency repair /maintenance/ refuelling / oil changes to be
                                                done over an impervious surface (plastic lining).
                                            •   Drip trays to be placed below all vehicles, or containers
                                                which leak oil.
                                            •   Emergency procedure to be put in place for the containment
To clean up and remediate spillages of                                                                              Prior to site establishment.         Emergency Spill Procedure (Section
                                                and clean-up of spillages of hazardous chemical substances.
hazardous chemical substances.                                                                                                                           8.2.2)
                                            •   Necessary measures for the implementation of the Emergency
                                                                                                                    Site establishment.                  Purchase Spill Kit and Treatment
                                                Spill Procedure are to be in place from site establishment.
                                                                                                                                                         Products
                                                Including a Spill Kit and Treatment Products
                                            •   Personnel responsible for the handling of hazardous chemical
                                                                                                                    Prior to the commencement of         Environmental Induction Programme
                                                substances are to be trained on the implementation of the

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                   Objectives                                            Action Plan                                            Schedule                Requirements for Implementation
                                                  Emergency Spill Procedure as part of the Job Specific Training.    work on site.                  (EMP section 2)
10. Air Quality Protection
                                              •   Exploration vehicles are to travel on gravel at speeds that
To reduce the magnitude and extent of                                                                                Ongoing during operations.     Part of training and awareness during
                                                  reduce the potential for entrained dust production (less than 60
dust dispersion.                                                                                                                                    environmental induction programme
                                                  km/hr on private gravel roads).
                                              •   Exploration boreholes are to be capped when no drilling work is
To minimise the release of greenhouse                                                                                Ongoing during operations.     -
                                                  being undertaken.
gases.
                                              •   Exploration boreholes which will not be used during production
                                                                                                                     Rehabilitation.                -
                                                  to be sealed with cement once exploration work has been
                                                  completed.
                                              •   Exploration boreholes that have production potential are to be
                                                                                                                     On going during operations
                                                  capped with a plinth and gas monitoring equipment.
                                              •   Prospecting boreholes from previous exploration work may be
                                                                                                                     Rehabilitation.                -
                                                  sealed with cement.
                                              •   On abandonment of a site or exploration area for any reason,
                                                                                                                     Rehabilitation.                -
                                                  all boreholes will be sealed with cement.
11. Solid Waste Management
                                              •   Separate receptacles are to be provided for the disposal of
To ensure the appropriate disposal of solid                                                                          Site establishment.            -
                                                  hazardous and general wastes at the waste generation points.
waste to prevent the contamination of soils
and water resources.
                                              •   All items that have come into contact with any hazardous
                                                                                                                     Ongoing during operations.     -
                                                  chemical substance (including fuels/oils/greases/laboratory
                                                  chemicals, sludge) are to be disposed as hazardous waste.


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                  Objectives                                              Action Plan                                              Schedule                    Requirements for Implementation
                                            •    All other substances are to be disposed of as general waste.
                                            •    Waste is to be taken to a recognised landfill site willing to
                                                                                                                      Ongoing during operations, and       -
                                                dispose of the waste.
                                                                                                                      at rehabilitation.

12. Fire Prevention
                                            •    Disposal facilities for cigarettes are to be provided at the camp
To reduce the potential for fire on site.                                                                             Prior to the commencement of         Environmental Induction Programme
                                                site.
                                                                                                                      work on site and ongoing during
                                            •    No smoking at the drilling site.                                     operations
                                            •    Fires at the drilling site are to be prohibited.
                                            •    Fires at the camp site, except within the cooking fire place, are
                                                to be prohibited.
                                            •    Firewood must be purchased and may not be collected locally.
                                            •    An Emergency Fire Procedure is to be put in place for the
To minimise the damage caused by an                                                                                   Prior to site establishment.         Emergency Fire Procedure (Section
                                                 containment and extinguishing of accidental fires.
accidental fire                                                                                                                                            8.2.1).
                                            •    Necessary measures for the implementation of the Emergency
                                                                                                                      Site establishment.                  -
                                                 Fire Procedure are to be in place from site establishment.
                                                 Including fire-extinguishers and fire beaters.
                                            •    Personnel are to be trained on the implementation of the
                                                                                                                      Prior to the commencement of         Environmental Induction Programme
                                                 Emergency Fire Procedure as part of the Job Specific Training.
                                                                                                                      work on site.

13. Sewage and Effluent Management
                                            •    Chemical toilets, or an equivalent alternative, are to be provided
To manage sewage in a manner that                                                                                     Site Establishment.                  Contractor to provide chemical toilets.
                                                 at the drilling and camp site area.
ensures the protection of soils and water
resources.                                  •    Sewage from the toilets is to be disposed of at a recognised
                                                 facility.

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                 Objectives                                                Action Plan                                              Schedule                  Requirements for Implementation
                                               •   Use is to be made of existing facilities where available.
To manage grey water in a manner that                                                                                   Prior to Site Establishment.      Signing of land use agreement by land
                                                   Permission needs to be obtained from the land owner for use of
ensures the protection of soils and water                                                                                                                 owner.
                                                   such facilities.
resources.
                                               •   In the absence of existing facilities. A French Drain is to be
                                                                                                                        Site Establishment.               -
                                                   constructed for the management of effluent from the camp
                                                   washing facility, situated as far as possible, but not less than
                                                   200 metres, from any stream, river, pan, dam or borehole.
                                               •   Only domestic type wash water shall be allowed to enter this
                                                   drain and any effluents containing oil, grease or other industrial
                                                   substances must be collected in a suitable receptacle and
                                                   removed from the site, either for resale or for appropriate
                                                   disposal at a recognised facility.

14. Rehabilitation
                                               •   Remove all waste, temporary structures, equipment and
To return land to a condition as close as is                                                                            Within 2 weeks of completion of   Financial provision for rehabilitation
                                                   surplus materials upon completion of exploration activities.
reasonably possible to pre-exploration land                                                                             exploration activities at any     available as a bank guarantee within
use potential.                                 •   Requests from land owners to retain infrastructure created           particular site.                  14 days of receipt of exploration right.
                                                   during exploration activities may be considered.
                                               •   Cap boreholes that will be used in future with a cement plinth
                                                   immediately on completion of drilling activities.
                                               •   Seal boreholes that will not to be used in future with cement
                                                   immediately on completion of exploration activities.
                                               •   Compacted surfaces on access roads, camp and drilling site
                                                   are to be scarified to a depth of 300 mm.
                                               •   Areas contaminated with hydrocarbons are to be treated in situ

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                Objectives                                                Action Plan                                             Schedule          Requirements for Implementation
                                                  using a commercially available bioremediation product.
                                              •   Soil is to be returned to levelled areas and the land shaped to
                                                  its original form.
                                              •   Areas with French drains should be loosely compacted, levelled
                                                  and covered with topsoil 100 mm above ground level.
                                              •   Waste is to be removed from site and disposed of at a
                                                  recognised facility.

15. Rehabilitation Monitoring          and
       Maintenance
                                              •   The establishment of vegetation in denuded areas, including
To monitor and maintain rehabilitated sites                                                                             Every 6 months.            Site Visit by EAP.
                                                  invasion by alien vegetation, is to be monitored.
                                              •   Alien vegetation is to be physically/chemically removed
                                                                                                                        Every 6 months.            Site Visit by EAP.
                                                  (depending on the species) from rehabilitated areas.
                                              •   Where vegetation has not established within 6 months of
                                                                                                                        Every 6 months.            Site Visit by EAP.
                                                  rehabilitation, a locally occurring seed mix/plants and fertilizers
                                                  are to be used to augment vegetation recovery as required.




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8.3        Monitoring and Performance Assessment

The following monitoring and performance assessment programme will be put in place for the
Elliot Exploration Project.
Frequency of             Performance           Responsibility    Reporting Requirements         Report Submission
 Monitoring              Assessment
    Daily         Visual    inspection    of   Site Manager     Reporting of environmental   Environmental incidents to
                  compliance with conditions                    incidents through incident   be reported to Badimo Gas
                  of EMP.                                       reporting structure.         representative.
    Weekly        Internal audit using EMP     Site Manager     Non-compliance reporting     EMP checklist to be
                  compliance checklist                                                       submitted to EAP.
  Every Six       External EMP compliance          EAP          Performance Assessment       Report submitted to PASA
   Months         audit                                         Report    in    terms   of
                                                                Regulation 55 of the MPRD
                                                                Regulations.


8.4        Environmental Awareness Training

The successful implementation of the EMP is dependent on training and awareness of all
personnel working on the drilling site. The environmental awareness plan aims at:


    •    promoting general environmental awareness amongst all employees;
    •    informing all personnel of environmental policies, procedures and programmes applicable
         to the exploration activities;
    •    providing general training on the implementation of environmental management actions;
         and
    •    providing job specific environmental training to ensure the protection of the environment.


The environmental awareness training programme will include:


    •    environmental induction of new employees;
    •    code of conduct signed by all inducted employees;
    •    identification of environmental risks associated with each job and job specific training on
         addressing these risks; and
    •    training on the implementation of emergency procedures where necessary.


8.5        Financial Provision

8.5.1      Method of Financial Provision

The financial provision for premature and final closure of the exploration activities will be by
means of a financial guarantee from an approved financial institution. The financial guarantee will
be made available within 14 days upon approval of the exploration right.
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8.5.2      Quantum of Financial Provision

The amount that is necessary for the rehabilitation of damage caused by the operation, both
sudden closure (termed premature closure) during the normal operation of the project and at final,
planned closure has been estimated below.


8.5.2.1 Premature Closure

The cost calculation is based on the following assumptions that a maximum of three drilling sites
will be active at any one particular time. Rehabilitation of drilling sites will be ongoing as part of
operations and only 3 sites will be active at a time. Thus the cost of rehabilitation, as a result of
premature cessation of operations, will be limited to the rehabilitation of three sites.           The
calculation of the quantum of financial provision is given in Table 4.


Table 4:              Calculation of Quantum for Financial Provision for Premature Closure
 Premature Closure                             Unit       Quantity        Rate          Cost
 Drill Sites
 Sealing of boreholes with concrete         boreholes             3      R 500.00     R 1,500.00
                                                 2
 Contouring of levelled areas                  m                750        R 2.00     R 1,500.00
                                                 2
 Ripping of compacted surfaces                 m               3000        R 1.50     R 4,500.00
                                                 2
 In situ remediation of contaminated soil      m                  9      R 500.00     R 4,500.00
                                                 2
 Seeding                                       m               3000        R 1.00     R 3,000.00
 Disposal of wastes                                                                   R 1,500.00

 Access Roads
                                                    2
 Ripping of compacted surfaces                  m              4500        R 1.50     R 6,750.00
                                                  2
 Seeding                                        m              4500        R 1.00     R 4,500.00

 Camp Sites
                                                    2
 Ripping of compacted surfaces                  m                75        R 1.50       R 112.50
                                                  2
 Contouring/ Replacement of soils               m                75        R 1.50       R 112.50
                                                  2
 Seeding                                        m                75        R 1.00        R 75.00

 Management Costs
 Rehabilitation management                     hrs                 8     R 350.00     R 2,800.00

 Monitoring and Maintenance
 Follow-up monitoring                          hrs                 8     R 350.00     R 2,800.00
 Physical weed removal                         hrs                 8     R 100.00      R 800.00
 Planting/seeding and fertiliser
 application (to promote vegetation
                                                    2
 establishment)                                 m              2500        R 0.50     R 1,250.00
 Total (excl. VAT)                                                                   R 35,700.00
 VAT                                                                                  R 4,998.00
 Total (Incl. VAT)                                                                   R 40,698.00


Exploration for Coal Bed Methane:                   56        SYNERGISTICS ENVIRONMENTAL SERVICES
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8.5.2.2 Final Closure

The cost calculation is based on the assumption that a maximum of three drilling sites will be
active at any one particular time. Since the rehabilitation of sites will be ongoing as part of
operations, the cost of final rehabilitation will be limited to three active sites. The calculation of
the quantum of financial provision is given in Table 5 and equates to the same cost required for
premature closure.


Table 5:              Calculation of Quantum for Financial Provision for Final Closure

 Final Closure                                 Unit       Quantity       Rate           Cost
 Drill Sites
 Sealing of boreholes with concrete         boreholes             3     R 500.00      R 1,500.00
                                                 2
 Contouring of levelled areas                  m                750       R 2.00      R 1,500.00
                                                 2
 Ripping of compacted surfaces                 m               3000       R 1.50      R 4,500.00
                                                 2
 In situ remediation of contaminated soil      m                  9     R 500.00      R 4,500.00
                                                 2
 Seeding                                       m               3000       R 1.00      R 3,000.00
 Disposal of wastes                                                                   R 1,500.00

 Access Roads
                                                    2
 Ripping of compacted surfaces                  m              4500       R 1.50      R 6,750.00
                                                  2
 Seeding                                        m              4500       R 1.00      R 4,500.00

 Camp Sites
                                                    2
 Ripping of compacted surfaces                  m                75       R 1.50        R 112.50
                                                  2
 Contouring/ Replacement of soils               m                75       R 1.50        R 112.50
                                                  2
 Seeding                                        m                75       R 1.00         R 75.00

 Management Costs
 Rehabilitation management                     hrs                 8    R 350.00      R 2,800.00

 Monitoring and Maintenance
 Follow-up monitoring                          hrs                 8    R 350.00      R 2,800.00
 Physical weed removal                         hrs                 8    R 100.00       R 800.00
 Planting/seeding and fertiliser
 application (to promote vegetation
                                                    2
 establishment)                                 m              2500       R 0.50      R 1,250.00
 Total (excl. VAT)                                                                   R 35,700.00
 VAT                                                                                  R 4,998.00
 Total (Incl. VAT)                                                                   R 40,698.00




Exploration for Coal Bed Methane:                   57        SYNERGISTICS ENVIRONMENTAL SERVICES
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EIA and EMP (S0191)
9.         REFERENCES

                                                                              (in text)
Barnes (ed.) The Eskom Red Data Book of Birds of South Africa, Lesotho        (Barnes, 2000)
and Swaziland, BirdLife South Africa. 2000.
Barnes (ed.) The Important Bird Areas of southern Africa. Birdlife South      (Barnes, 1998)
Africa, Johannesburg. 1998.
Bohlweki Environmental, Environmental Impact Report for the proposed          (Bohlweki, 2006)
establishment of a New Coal-Fired Power Station in the Lephalale Area,
Limpopo Province. 2006.
Friedmann and Daly (eds), Red Data Book of the Mammals of South               (Friedmann & Daly,
Africa: A Conservation Assessment, CBSG Southern Africa, Conservation         2004)
Breeding Specialist Group, Endangered Wildlife Trust. South Africa. 2004.
International Panel on Climate Change, 3rd Assessment Report, United          (IPCC, 2006)
Nations Framework Convention on Climate Change, 2006.
International Union for the Conservation of Nature and Natural Resources.     (IUCN, 2006)
2006 IUCN Red List of Threatened Species, 2006.
Inkwanca Municipality. Integrated Development Plan, 2006/07                   (IDP, 2006/07)
Mucina, L., Rutherford, M.C. & Powrie, L.W. Vegetation Map of South           (Mucina et al, 2005)
Africa, Lesotho and Swaziland. South African National Biodiversity
Institute. 2005.
National Cultural History Museum. Heritage Sites Database. 2006.              (NCHM, 2006)
National Grasslands Biodiversity Programme. Background Information            (NGBP, 2005)
Report No.1: Biodiversity profile      and    spatial biodiversity priority
assessment. October 2005
Petroleum Agency SA. Draft Environmental Management Plan Guideline.           (PASA, 2006)
For Petroleum Exploration and Production. March 2006.
U.S. Department of Energy, Energy Information Administration, U.S.            (USDE, 2002)
Crude Oil, Natural Gas, and Natural Gas Liquids Reserves: 2002 Annual
Report DOE/EIA-0216. 2002.
Van Wyk, A.E. and Smith, G.F. Regions of Floristic Endemism in                (Van        Wyk    and
Southern Africa. Umdaus Press, 2001.                                          Smith, 2001)




Exploration for Coal Bed Methane:               58           SYNERGISTICS ENVIRONMENTAL SERVICES
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UNDERTAKING

         I,            O. B. Barker                             the undersigned and duly authorised
         thereto by                 Badimo Gas (Pty) Ltd                         ,have studied and
         understand the contents of the environmental management programme and hereby duly
         undertake to adhere to the conditions as set out therein including any amendments
         approved by the Regional Director, as well as the requirements of the Minerals and
         Petroleum Resources Development Act (No. 28 of 2002) and the regulations thereto.


         Signed at       Johannesburg        this   2nd      day of      May, 2007



         Signature of applicant:                            Designation: Manager, Exploration




         Agency declaration:          This document was completed by Matthew Hemming and
         authorized by Kerry Colleen Fairley on behalf of Synergistics Environmental Services
         (Pty) Ltd.




         Signature of consultant                           Designation




Exploration for Coal Bed Methane:                   59         SYNERGISTICS ENVIRONMENTAL SERVICES
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Appendix 1:           Copies of Press Advertisements




Exploration for Coal Bed Methane:               i      SYNERGISTICS ENVIRONMENTAL SERVICES
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EIA and EMP (S0191)
Appendix 2:           Copies of Posters




Exploration for Coal Bed Methane:         ii   SYNERGISTICS ENVIRONMENTAL SERVICES
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EIA and EMP (S0191)
Appendix 3:           Background Information Document




Exploration for Coal Bed Methane:             iii       SYNERGISTICS ENVIRONMENTAL SERVICES
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Appendix 4:           Interested and Affected Party Database




Exploration for Coal Bed Methane:               iv         SYNERGISTICS ENVIRONMENTAL SERVICES
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EIA and EMP (S0191)
Appendix 5:           Responses from Interested and Affected Parties




Exploration for Coal Bed Methane:               v          SYNERGISTICS ENVIRONMENTAL SERVICES
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EIA and EMP (S0191)
Appendix 6:           Environmental Code of Conduct




Exploration for Coal Bed Methane:             vi      SYNERGISTICS ENVIRONMENTAL SERVICES
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