comments and responses report - gibbprojects.gibb.co.za/portals/3/projects/appendix e3... · 14 12...

COMMENTS AND RESPONSES REPORT

CLIENT : Transnet SOC Ltd PROJECT : Proposed provision of a third tippler and

infrastructure in the Port of Saldanha

INTRODUCTION This comment and response report (C&RR) holds all comments received from (PPP) for the basic assessment (BA). It holds comments received during all phases of the PPPthe basic assessment report. CONTRIBUTIONS RECEIVED The following person commented:

No Name 01 Gideon van Niekerk

02 Mr Pieter Stegmann

03 Ms Wilene Smit

04 Peter Stegmann

05 Mnr James Matthee

06 Ms Alana Duffell-Canham

07 Mr Quinton Dollman

08 Mr Pieter Fabricius

09 Ms René de Kock

10 Mr Morgan Smit and Mr Willie Goosen

11 Peter Stegmaan

12 Andrae Nieuwoudt

13 Keith Harrison

14 Pieter Jantjies

15 Pippa Haarhof

16 Troy Smuts

17 Andre Kruger

18 HSC Steenkamp

19 Anton Lubbe

20 Elmien de Bruin

21 Alan Carnegie

22 A van Zyl

23 Mr and Mrs Naude and Helmine Steyn

24 Nazeema Duarte

25 Ishaam Abader

26 Graeme Clemitson

27 Leon De Klerk

28 Christo van Wyk


DEA REF No : 14/12/16/3/3/895 roposed provision of a third tippler and associated

infrastructure in the Port of Saldanha PROJECT No : J31459

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) holds all comments received from interested and affected parties (I&APs) during the It holds comments received during all phases of the PPP, namely the I&AP registration process

Organisation Resident

Resident

Resident

Resident

Resident

Cape Nature

Afrisam

Air Quality Officer West Coast District Municipality

SANRAL

Mr Morgan Smit and Mr Willie Goosen Ratepayers Association of Vredenburg

Resident

Resident

West Coast Bird Club (WCBC)

School of Knowledge

West Coast Fossil Park

Heritage Western Cape

Saldanha Bay Municipality (Councillor Langebaan)

Nooitgedacht Boerdery

Chief Operations Officer Black Mountain Mining (Pty) Ltd

Duferco Steel Processing - Environmental co-ordinator

WESSA

Heuningklip Plaas

Mrs Naude and Helmine Steyn Residents

Saldanha Bay Municipality

Department of Environmental Affairs (DEA)

Member of Saldanha PCC

L2 Draughting Consultants

The Cove Home Owners Association

arties (I&APs) during the public participation process registration process and the public review of




No Name 29 Mike Rothenburg

30 Carolyn Ah Shene Verdoorn

31 Jacques vd Merwe

32 C. George

33 Helen Jordaan

NO DATE NAME AND

ORGANISATION ISSUES

13 12 July 2013 Keith Harrison -West Coast Bird Club (WCBC)

The WCBC supports the

1. The proposed position of the fourth tippler is shown on the

position map, so that the cumulative effect can be judged for this

and the Port Extension (4th Tippler) project.

2. The technology used for the tippler, and the conveyor belt

systems does NOT add to the current red dust problem towards

Vredenburg and Louwville.

14 12 July 2013 Pieter Jantjies We the School of Knowledge really want to thank you for keepinformed. We wish youmake us proud on you for ta

25 21 August 2013

Ishaam Abader - DEA

The above-mentioned letter dated 18 July 2013 received by the Department on 22 July 2013 has reference. The Department acknowledges receipt of the above




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Organisation Chairman BWBHOA

Policy and Advocacy Manager BirdLife South Africa

Conservation Manager: Cape West Coast Biosphere Reserve

Coastal Management Unit, Department of Environmental Affairs and Development Planning (DEA&DP)

Western Cape Directorate Land Management

ISSUES RAISED AND COMMENTS MADE

General Comments

supports the project provided:

The proposed position of the fourth tippler is shown on the

position map, so that the cumulative effect can be judged for this

and the Port Extension (4th Tippler) project.

The technology used for the tippler, and the conveyor belt

systems does NOT add to the current red dust problem towards

Vredenburg and Louwville.

1. The third tippler will serve as a backup when one of the existing tipplers is out of service for maintenance ofuture 4th tippler is being made alongside Tippler 3 (which is the subject of this Basic Assessment). If Transnet wishes to install a fourth tippler to operate dedicated environmental impacundertaken together with an amendment of the Air Emission License.

2. With the current technology, it is unavoidable that the operation of the Tippler 3 and its associated conveyor belt system will generate some fugitive dust. An engaged to assess the impact of a third tippler on dust emissionfrom the Port of Saldanha. The specialist study found that the third tippler will result in the increase of the maxima for fine and extra fine dust particles respectively. Fallout is simila(Appendix D).

We the School of Knowledge really want to thank you for keeping us . We wish you well as you take the community in consideration. It

make us proud on you for talking to our people with in a transparent way.

Noted.

mentioned letter dated 18 July 2013 [on availability of dBAR] and received by the Department on 22 July 2013 has reference. The Department acknowledges receipt of the above-mentioned notice.

The contents of your letter are noted

Development Planning (DEA&DP)

RESPONSE

The third tippler will serve as a backup when one of the existing tipplers is out of service for maintenance or repair. Provision for a

tippler is being made alongside Tippler 3 (which is the subject of this Basic Assessment). If Transnet wishes to install a fourth tippler to operate at the same time as the existing ones, a dedicated environmental impact assessment will have to be undertaken together with an amendment of the Air Emission

With the current technology, it is unavoidable that the operation of the Tippler 3 and its associated conveyor belt system will

fugitive dust. An air quality specialist has been engaged to assess the impact of a third tippler on dust emissions from the Port of Saldanha. The specialist study found that the third tippler will result in the increase of the maxima for fine and extra fine dust particles in the atmosphere by 3% and 4 %, respectively. Fallout is similarly predicted to increase by 3%

he contents of your letter are noted




NO DATE NAME AND

ORGANISATION ISSUES

26 27 August 2013

Graeme Clemitson 1. Location of Tippler 3 Why can tippler 3 not be located alongside or close to tippler 2? The BID document records ...'for all practical reasons the tippler forms part of the portside operations'...W 2. Dust mitigation measures 2.1 Will the dust extraction system & associated bag filter unit feature 'pulsing' as a means of keeping filters effective vacuum cleaner bag needs to be maintained 'clean'? 2.2 If tippler 3 located according to the BID proposal, why iincline tunnel only 310 metre long then oncan the sub-surface tunnel not be extended to the 3. Realignment of bridges/road/rail 3.1 Within my time in Saldanha Bay witnessed the building of both'Duferco' and 'Camp Road' bridges come down? Does not say much for forward planning by Transnet SOC/government authorities 3.2 Transportation of large pieces of equipment metre width does not seem wide enough, nor are bridges with height restrictions particularly friendly where they are, then adequate provision must be made for highconveyance of outpurpose terminal for the manufacturing/industrial zone. With this port becoming more than an 'irontaken into account. 4. Isolationist planning4.1 Once again we are witnessing isolatioThe National Development Commission/National Development Plan reads:'This gives the commission the license to be honest, bold, cut through the silos of government...' This raises the question of why Transnet SOC are excluding tippler 3 (and presumably tippler 4) from the iron ore expansion plan for the port as a whole. The piecemeal (silo)has been raised previously on many occasions, yet ignored. Is it a case of




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f Tippler 3 Why can tippler 3 not be located alongside or close to tippler 2? The BID document records ...'for all practical reasons the tippler forms part of the port-

Why then locate it 'outside' of the port?

ust mitigation measures l the dust extraction system & associated bag filter unit feature

'pulsing' as a means of keeping filters effective - even a normal household vacuum cleaner bag needs to be maintained 'clean'?

2.2 If tippler 3 located according to the BID proposal, why is the sub-surface incline tunnel only 310 metre long then on-surface conveyors to stockpile -

surface tunnel not be extended to the [port].

ealignment of bridges/road/rail 3.1 Within my time in Saldanha Bay witnessed the building of both the 'Duferco' and 'Camp Road' bridges - 10-12 years later and they now have to come down? Does not say much for forward planning by Transnet SOC/government authorities

3.2 Transportation of large pieces of equipment - restricting roadways to 8 th does not seem wide enough, nor are bridges with height

restrictions particularly friendly - if the port entrance access roads remain where they are, then adequate provision must be made for high-wide conveyance of out-of-size machinery being imported/exported over the multi-purpose terminal for the manufacturing/industrial zone. With this port becoming more than an 'iron-ore export' facility, other port users MUST be taken into account.

solationist planning 4.1 Once again we are witnessing isolationist planning by Transnet SOC. The National Development Commission/National Development Plan

'This gives the commission the license to be honest, bold, cut through the silos of government...' This raises the question of why Transnet SOC are

tippler 3 (and presumably tippler 4) from the iron ore expansion plan for the port as a whole. The piecemeal (silo) approach by government has been raised previously on many occasions, yet ignored. Is it a case of

1. The tippler location was determined by the rail engineers with due consideration of its space needs and in the interest of smooth rail operations. Two location alternatives, which would havthird tippler placed closer to the existing two tipplers, proved undesirable. The reasons for this are elaborated on in section D of the BAR.

2. The filters are cleaned weekly from the accumulated fine iron ore dust, which is not wasted but added tintroduction of tippler 3 will also allow for more frequent maintenance which will include the dust extraction plant system.There two main reasons: 1: cost, and 2. because an aboveconveyor can negotiate existing servicplaced underground.

3. The Camp Road bridge will only be extended, not demolished altogether. The relocation of the Duferco bridge is directly linked to the provision of a third tippler. This was not foreseen a decade ago. Transnet and provincial department of Roads are in the process of establishing a formal planning forum together with other key role players Your call for extra-wide roads and high bridges to cater for the perceived needs of other port users has been communicated Transnet who will address this as part of long term planning processes.

4. The provision of a third tippler and its associated infrastructure was motivated by Transnet as a replacement for the two existing tipplers when they have to undergo refurbishmetippler and the expansion of iron ore export business are progressing along very different time scales. This is the reason for the separation into different EIA processes.

RESPONSE

The tippler location was determined by the rail engineers with due consideration of its space needs and in the interest of smooth rail operations. Two location alternatives, which would have seen the third tippler placed closer to the existing two tipplers, proved undesirable. The reasons for this are elaborated on in section D of

The filters are cleaned weekly from the accumulated fine iron ore dust, which is not wasted but added to the product for sale. The introduction of tippler 3 will also allow for more frequent maintenance which will include the dust extraction plant system.

here two main reasons: 1: cost, and 2. because an above-ground conveyor can negotiate existing services more easily than being

The Camp Road bridge will only be extended, not demolished altogether. The relocation of the Duferco bridge is directly linked to the provision of a third tippler. This was not foreseen a decade ago.

and provincial department of Roads are in the process of establishing a formal planning forum together with other key role

wide roads and high bridges to cater for the perceived needs of other port users has been communicated to Transnet who will address this as part of long term planning

he provision of a third tippler and its associated infrastructure was motivated by Transnet as a replacement for the two existing tipplers when they have to undergo refurbishment. The provision of a third tippler and the expansion of iron ore export business are progressing along very different time scales. This is the reason for the separation into different EIA processes.




NO DATE NAME AND

ORGANISATION ISSUES

the left hand not knowing what the right other more credible reasons?

27 26 August 2013

Leon de Klerk, L2 Draughting Consultants

WATTER BELAGLIKE EN ONBENULLIGE OPTREDE OM KAMSTIG PUBLIKE DEELNAME TE VERSEKER!! VIR WIE BLUF JULLE? HOW ARE YOU BLUFFING? SOU 100% VAN DIE PUBLIEK GEKANT WEES TEEN DIE VERMEERDERING VAN UITVOERE NA 60 MILJOEN TON PER JAAR SAL DIE PROJEK STEEDS VOORTGAAN. ONS PROBEER AL VIR JARE OM TERUGVOERING VAN TRANSNET TE KRY RAKENDE DIE BESOEDELING WAT TANS DAAGSLIK PLAASVIND. ONS SIDDER OM TE SIEN WAT DIE INPAK OP DIE OMGEWING GAAN HE MET DIE BEOOGDE VERHOGING VAN UITVOERE.!! AANGEHEG N SKRYWE GEDDE GOEDE EN FOTOS VAN AARD VAN BESOEDELING. HIERDIE AANHANGSELS IS GEWYER DEUR ONTVANGER!! GEEN TERUGVOERING!!! SOOS AL DIE DAAROPVOLGENDE VERSOEKE HET DIT OP DOWE ORE GEVAL. SO ONCE AGAIN GIBB, WE ARE CONVINCED TPARTICIPATION YOU ARE ASKING FOR IS BUT ONLY A MATTER OF FORMALITY AND A WAY TO COVER THE DECISIONS ALREADY MADE. English translation:What a ridiculous and foolish behaviour to pretend that public participation is definite. Who are you trincrease of exports to 60 million ton per annum, the will still continue. We have been trying to get feedback from Transnet for years with regards to the pollution currently experienced on a daily basiproposed increase of exports will impact on the environment. Attached communication with Mr Koos De Goede dated 12 April 2010, and the photos depicting the nature of the pollution experienced was disregarded by the receiver.




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the left hand not knowing what the right hand is doing or, is there hopefully, other more credible reasons?

WATTER BELAGLIKE EN ONBENULLIGE OPTREDE OM KAMSTIG PUBLIKE DEELNAME TE VERSEKER!!

VIR WIE BLUF JULLE? HOW ARE YOU BLUFFING? SOU 100% VAN DIE PUBLIEK GEKANT WEES TEEN DIE VERMEERDERING VAN UITVOERE NA 60 MILJOEN TON PER JAAR SAL

TEEDS VOORTGAAN. ONS PROBEER AL VIR JARE OM TERUGVOERING VAN TRANSNET TE KRY RAKENDE DIE BESOEDELING WAT TANS DAAGSLIK PLAASVIND. ONS SIDDER OM TE SIEN WAT DIE INPAK OP DIE OMGEWING GAAN HE MET DIE BEOOGDE VERHOGING VAN UITVOERE.!!

AANGEHEG N SKRYWE GEDATEER 12 APRIL 2010. AAN MNR .KOOS DE GOEDE EN FOTOS VAN AARD VAN BESOEDELING. HIERDIE AANHANGSELS IS GEWYER DEUR ONTVANGER!!

GEEN TERUGVOERING!!! SOOS AL DIE DAAROPVOLGENDE VERSOEKE HET DIT OP DOWE ORE GEVAL.

SO ONCE AGAIN GIBB, WE ARE CONVINCED THAT THE PUBLIC PARTICIPATION YOU ARE ASKING FOR IS BUT ONLY A MATTER OF FORMALITY AND A WAY TO COVER THE DECISIONS ALREADY MADE.

English translation: What a ridiculous and foolish behaviour to pretend that public participation is definite. Who are you trying to fool? Should 100% of the public be against the increase of exports to 60 million ton per annum, the will still continue. We have been trying to get feedback from Transnet for years with regards to the pollution currently experienced on a daily basis. We shudder to think how the proposed increase of exports will impact on the environment. Attached communication with Mr Koos De Goede dated 12 April 2010, and the photos depicting the nature of the pollution experienced was disregarded by the

First, a correction: In terms of the Atmospheric Emissions License for the port export volumes of iron ore are already permitted up to the ceiling of 60 million tons per year. GIBB is sincere in conducting tbe Public Participation Process for the third tippler in a professional manner and according to established for environmental impact assessment. GIBB cannot comment on the historical communication track record of Transnet as this falls outside our mandate. One of the mechanisms by which you and othis through this Comments & Responses Report. I&APs can be assured that all issues raised are carefully considered by the GIBB environmental team assigned to this Basic Assessment and appropriate responses are incorporated into thand its appendices, such as the Environmental Management Programme.

RESPONSE

correction: In terms of the Atmospheric Emissions License for the port export volumes of iron ore are already permitted up to the ceiling of

GIBB is sincere in conducting tbe Public Participation Process for the third a professional manner and according to established procedures

for environmental impact assessment.

GIBB cannot comment on the historical communication track record of Transnet as this falls outside our mandate.

One of the mechanisms by which you and other I&APs receive feedback is through this Comments & Responses Report.

I&APs can be assured that all issues raised are carefully considered by the GIBB environmental team assigned to this Basic Assessment and appropriate responses are incorporated into the Basic Assessment Report and its appendices, such as the Environmental Management Programme.




NO DATE NAME AND

ORGANISATION ISSUES

No Feedback!! Just like all the other queries it landed on deaf ears. So once again GIBB, we are convinced that the public participation you are asking for is but only a matter of formality and a way to cover the decisions already made.

28 27 August 2013

Christo van Wyk - The Cove Home Owners Association

Piece Meal Approach million ton ore export, while other tipplers are refurbished not totally correct, it must me stated that this tippler will be used for the bigger export program aiming at 80 million tons and higher, when other tipplers has been refurbished, the three tipplers together will handle the bigger export volumes in the port. Point is that this piece meal approach for the total proposed development does not take the full impact of the total project into account and EIA process“picture” of total impact through to legislators and the public. Dust – The report indication is that a 3% increase in dust impact will be experienced based on current legislation. The question should be asked: Is the current legislation limits for PM 10, etc effective and applicable in the Saldanha area, taken the Feinto account. A scientific research study should be done in the area to determine the effective dust limiresidential and other industrial communities around this ore loading facility, current civil society in Langebaan, Saldanha and Vredenburg is impacted upon negatively, with residential houses being colohave a contribution to the current existing accumulative impact on coloof residential properties in the area. Please investigate the effectiveness of current legislative dust fall out limits for the Saldanha Industrial Area currently the impactor operates within legal limits, but have a huge negative impact on residents and other industries in the area. Dust – Two LPG offloading facilities, a Cement factory and a lay down area for the oil and gas industry will be erected directly tippler site. Dust could have a negative impact on these “clean” industries. Dust – The EMF indicates that very sensitive vegetation types and rare animals species occur in the zone of impact (on Mittal’s land)




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No Feedback!! Just like all the other queries it landed on deaf ears.

So once again GIBB, we are convinced that the public participation you are asking for is but only a matter of formality and a way to cover the decisions

Piece Meal Approach - It is stated that the tippler is built to sustain the 60 million ton ore export, while other tipplers are refurbished – This statement is not totally correct, it must me stated that this tippler will be used for the bigger export program aiming at 80 million tons and higher, when other

s has been refurbished, the three tipplers together will handle the bigger export volumes in the port. Point is that this piece meal approach for the total proposed development does not take the full impact of the total project into account and EIA process is thus manipulated not to give a real “picture” of total impact through to legislators and the public.

The report indication is that a 3% increase in dust impact will be experienced based on current legislation. The question should be asked: Is he current legislation limits for PM 10, etc effective and applicable in the Saldanha area, taken the Fe2O3 dust’s pigment and discoloration qualities into account. A scientific research study should be done in the area to determine the effective dust limit that would not negatively impact on the residential and other industrial communities around this ore loading facility, current civil society in Langebaan, Saldanha and Vredenburg is impacted upon negatively, with residential houses being coloured red. This tippler will have a contribution to the current existing accumulative impact on colouring of residential properties in the area. Please investigate the effectiveness of current legislative dust fall out limits for the Saldanha Industrial Area –

tly the impactor operates within legal limits, but have a huge negative impact on residents and other industries in the area.

Two LPG offloading facilities, a Cement factory and a lay down area for the oil and gas industry will be erected directly around this proposed tippler site. Dust could have a negative impact on these “clean” industries.

The EMF indicates that very sensitive vegetation types and rare animals species occur in the zone of impact (on Mittal’s land) – this is no-go

The provision of a third tippler and motivated by Transnet as a replacement for the two existing tipplers when they have to undergo refurbishment. The provision of a third tippler and the expansion of iron ore export business are progressing along very different time scales. This is the reason for the separation into different EIA processes. WSP Environmental has undertaken an independent review and assessment of compliance of the Saldanha operations in respect of dust. Transnet has released the draft versionthis Basic Assessment. A copy of the report is provided in Appendix J of the BAR. The review analysed the historical daily, monthly and quarterly data from 2006 to 2012. Monitoring data included both PM10 as well as dust fallout, with the latter specifically being used to assess the proportion of iron oxide Fe2O3 in total dust.reported levels of PM10 are well below the present National Ambient Standard of 120 µg/m3. The dust concentmatter and as Fe2O3 flux, shows a clear trend of decreasing levels of from 2009 onwards. This decreasing trend is observed despite the increases in volumes of ore handled at the terminal. The monitoring data thus demonstrates that the dust mitigation measures implemented by Transnet have had a significant beneficial impact in reducing dust emissions from operations. The mentioned proposed industrial developments in the neighbourhood have been or are being subjected to EnviroPotential dust impacts on the proposed industrial activities are being considered in the EIAs. The EAP is aware of the conservation implications. The vegetation and other biodiversity resources on site have been assessed and mit

RESPONSE

he provision of a third tippler and its associated infrastructure was motivated by Transnet as a replacement for the two existing tipplers when they have to undergo refurbishment. The provision of a third tippler and the expansion of iron ore export business are progressing along very

ent time scales. This is the reason for the separation into different

WSP Environmental has undertaken an independent review and assessment of compliance of the Saldanha operations in respect of dust. Transnet has released the draft version of this report so that it may inform this Basic Assessment. A copy of the report is provided in Appendix J of the BAR. The review analysed the historical daily, monthly and quarterly data from 2006 to 2012. Monitoring data included both PM10 as well as

st fallout, with the latter specifically being used to assess the proportion in total dust. The compliance review found that the

reported levels of PM10 are well below the present National Ambient . The dust concentration, measured as particulate

flux, shows a clear trend of decreasing levels of from 2009 onwards. This decreasing trend is observed despite the increases in volumes of ore handled at the terminal. The monitoring data thus

s that the dust mitigation measures implemented by Transnet have had a significant beneficial impact in reducing dust emissions from

The mentioned proposed industrial developments in the neighbourhood have been or are being subjected to Environmental Impact Assessment. Potential dust impacts on the proposed industrial activities are being

The EAP is aware of the conservation implications. The vegetation and other biodiversity resources on site have been assessed and mitigation




NO DATE NAME AND

ORGANISATION ISSUES

area for any development (green belt), what will the dust effect be on the vegetation and animal life. Currently vegetation is colosheep in the area is red, with a potential negative impact on wool prices. My concern is the natural vegetatthe effect of iron ore dust on red data species in the area. Hazards – Two LPG offloading facilities, a Cement factory and a lay down area for the oil and gas industry will be erected directly around this propotippler site. LPG facilities will be Major Hazardous Installations. What will the effect of increased movement (conveyor belts, rail movement with consequential increase in spark risk, noise, dust, etc be on these installations. Quality Control –address the incoming product from the mines. Nowhere in the current study reports it is discussed or dealt with excess dust or too little moist) needs to be monitored and mawith non-conforming product needs to return to source, this quality control measures is in place in other ports (this was mentioned and is in minutes of the second 2013 Port Consultative Forum meeting). Quality control measures needs to be inproposed mitigation measures will not be effective if incoming ore is not conforming to specifications) Conveyor system addressed. Tippler 3 will increase transport. Total enclosure of conveyor systems to be investigated. Mitigation measures visit the proposed tippler during operational phase. Currently vehithe Port are discolothe Port are red!!! Washing and cleaning of vehicles leaving the tippler area needs to be included as a measure of mitigation.

33 30 August 2013

H. Jordaan, W. Cape Directorate

This Directorate has the following comments: 1. Location




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for any development (green belt), what will the dust effect be on the vegetation and animal life. Currently vegetation is coloured red and even the sheep in the area is red, with a potential negative impact on wool prices. My concern is the natural vegetation – no studies have been done to determine the effect of iron ore dust on red data species in the area.

Two LPG offloading facilities, a Cement factory and a lay down area for the oil and gas industry will be erected directly around this proposed tippler site. LPG facilities will be Major Hazardous Installations. What will the effect of increased movement (conveyor belts, rail movement with consequential increase in spark risk, noise, dust, etc be on these

– Currently the ISO 9001:2008 system of TPT does not address the incoming product from the mines. Nowhere in the current study reports it is discussed or dealt with – nonconforming raw iron ore (with excess dust or too little moist) needs to be monitored and managed (trains

conforming product needs to return to source, this quality control measures is in place in other ports (this was mentioned and is in minutes of the second 2013 Port Consultative Forum meeting). Quality control measures needs to be instituted on raw ore received at the tippler – proposed mitigation measures will not be effective if incoming ore is not conforming to specifications)

Conveyor system – Dust arising from open conveyor systems needs to be addressed. Tippler 3 will increase the length conveyor to be used for iron ore transport. Total enclosure of conveyor systems to be investigated.

Mitigation measures – The report does not address the cleaning vehicles to visit the proposed tippler during operational phase. Currently vehicles leaving

discolouring the public transport network hugely. Roads leaving red!!! Washing and cleaning of vehicles leaving the tippler area

needs to be included as a measure of mitigation.

measures have been providedconservation concern prior to construction on the site The mentioned proposed industrial developments in the neighbourhood have been or are being subjected to Environmental Potential impacts on the proposed industrial activities are being considered in the EIAs. A quality control system is the iron ore arriving at the port from the mines in the Northern CapeQuality assurance of the product is important for Transnet. Dust arising from the conveyors serving the proposed Tippler 3 is specifically addressed in the dust management plan of the port (see section 12c of the BAR and references made therein. Washing and cleaning of vehicles leaving the tippler area included in the Environmental Management Programme a measure of mitigation.

This Directorate has the following comments: Location

1. Location of tippler 3: The preferred location is well motivated for in the Basic Assessment together

RESPONSE

measures have been provided, such as the rescue of plant species of conservation concern prior to construction on the site.

The mentioned proposed industrial developments in the neighbourhood have been or are being subjected to Environmental Impact Assessment. Potential impacts on the proposed industrial activities are being

in place monitoring a variety of parameters of the iron ore arriving at the port from the mines in the Northern Cape. Quality assurance of the product is important for Transnet.

Dust arising from the conveyors serving the proposed Tippler 3 is specifically addressed in the dust management plan of the port (see section 12c of the BAR and references made therein.

Washing and cleaning of vehicles leaving the tippler area has been in the Environmental Management Programme (Appendix G) as

Location of tippler 3: The preferred location is well motivated for in the Basic Assessment together with a discussion of potential site




NO DATE NAME AND

ORGANISATION ISSUES

Land Management a. As the proposed third tippler will be located approximately

1.4 kilometres north of the two existing tipplers, the radius of the associated impacts will be significantly increased.

2. Traffic a. A traffic management plan must be compiled and

implemented for public commuting routes which will be closed for periods during the construction phase of the proposed development.

3. Dust impactsa. Although dust mitigation measures will be implemented for

the Assessment dated July 2013 included as part of the BAR highlights that the existing air quality is already compromised by the current operations.

b. It is noted that both particulate matter and total suspended partimitigation measure, as displayed in Table 4 2 of the aforementioned Basic Air Quality Assessment. However, this is not the case for the conveyor or stacker/ reclaimers where emission mitigation. Therefore, further mitigation measures need to be investigated.

c. The prevailing wind in Saldanha Bay is in a southerly direction, towards the ocean, in winter. This combined with the winter rainfall in Saldanha Bawater may have detrimental effects on the surrounding marine environments. The aforementioned Basic Air Quality Assessment must include these potential impacts for investigation.

d. Threshold levels of the acceptable average condust within residential and nonprovided in the aforementioned Basic Air Quality Assessment. Although the proposed development falls within a non




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As the proposed third tippler will be located approximately 1.4 kilometres north of the two existing tipplers, the radius of the associated impacts will be significantly increased.

A traffic management plan must be compiled and implemented for public commuting routes which will be closed for periods during the construction phase of the proposed development.

Dust impacts Although dust mitigation measures will be implemented for the proposed development, the Basic Air Quality Assessment dated July 2013 included as part of the BAR highlights that the existing air quality is already compromised by the current operations. It is noted that both particulate matter and total suspended particles at the tippler can be reduced by air filtration as a mitigation measure, as displayed in Table 4 -1 on Page 4 – 2 of the aforementioned Basic Air Quality Assessment. However, this is not the case for the conveyor or stacker/ reclaimers where emission levels remain high, even after mitigation. Therefore, further mitigation measures need to be investigated. The prevailing wind in Saldanha Bay is in a southerly direction, towards the ocean, in winter. This combined with the winter rainfall in Saldanha Bay and the affinity of dust for water may have detrimental effects on the surrounding marine environments. The aforementioned Basic Air Quality Assessment must include these potential impacts for investigation. Threshold levels of the acceptable average concentration of dust within residential and non-residential areas are not provided in the aforementioned Basic Air Quality Assessment. Although the proposed development falls within a non-residential area, it occurs within close proximity

alternatives.

2. Traffic: The need for traffic management plan is contained in the EMP, which is left for the contractor to decide where and when temporary road closure is required, if at all.

3. Dust: In 2012 Transnet (

commissioned a dust management study Saldanha from the independent consulting firm Environmental Resources Management (ERM). A copy of the study is provided in Appendix J of the BAR.dust management plan that was approved by Transnet for implementation. The plan covers the lifetime of the iron ore export facility and contains provisions how Transnet more stringent emission controls coming into effefuture. Iron dust in the sea: The independent consultant Anchor Environmental conducted a study in 2012 to assess the impact of iron oxide on the marine environment in Saldanha Bay. marine study confirmtrend in Fe loading to the sediments in the bay, this being attributed to the effectiveness of current control measures. It also noted that benthic macrofauna communities in the sediments in Saldanha Bay have been monitored along with trace metal 1999 as part of the State of the Bay monitoring programme, and that no relationship between levels of Fe and abundance and biomass of macrofauna was observed in these samples.

RESPONSE

Traffic: The need for traffic management plan is contained in the EMP, which is left for the contractor to decide where and when temporary road closure is required, if at all.

In 2012 Transnet (as Transnet Port Terminals (TPT)) commissioned a dust management study and plan for the Port of Saldanha from the independent consulting firm Environmental Resources Management (ERM). A copy of the study is provided in Appendix J of the BAR. The study presents a comprehensive dust management plan that was approved by Transnet for

he plan covers the lifetime of the iron ore export facility and contains provisions how Transnet is going to meet more stringent emission controls coming into effect in the near

Iron dust in the sea: The independent consultant Anchor Environmental conducted a study in 2012 to assess the impact of iron oxide on the marine environment in Saldanha Bay. The marine study confirmed the absence of any discernible negative trend in Fe loading to the sediments in the bay, this being attributed to the effectiveness of current control measures. It also noted that benthic macrofauna communities in the sediments in Saldanha Bay have been monitored along with trace metal since 1999 as part of the State of the Bay monitoring programme, and that no relationship between levels of Fe and abundance and biomass of macrofauna was observed in these samples.




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to a residential arthe limits for maximum acceptable average concentrations within the non

4. Potable Watera. The use of potable water for dust suspension is

unacceptable. The efficacy of alternative dust suppression methods, such as shade netting screens and/or straw stabilisation, etc. should be investigated and considered.

b. Confirmation should be obtained from Municipality with respect to the availability of sufficient, spare, unallocated water prior to an Environmental Authorisation being issued for the proposed development.

5. Ground watera. This Department notes the mention of a shallow water ta

and the lack of knowledge of the geotechnical conditions at the site proposed for development. Impacts on ground water may be experienced due to the need for excavation and blasting down to rock level for the installation of the third tippler. Ground wsurrounding the tippler as a result of the installation of impervious materials may have knockThese impacts should be investigated as part of the Basic Assessment process.

b. Although the propodrainage system which feeds a sump with permanent pumps and this groundwater is to be pumped to a lined dam close to tippler 3, the position of this dam has not been identified in the BAR.

6. Generala. The purpose of

BAR, is to alleviate one of the existing tipplers during routine maintenance, repair work or as a backup should one of the existing tipplers be out of service. The proposed third tippler is not intended to o




8


to a residential area. There is no indication in the study as to the limits for maximum acceptable average concentrations within the non-residential area abutting a residential area.

Potable Water The use of potable water for dust suspension is unacceptable. The efficacy of alternative dust suppression methods, such as shade netting screens and/or straw stabilisation, etc. should be investigated and considered. Confirmation should be obtained from the Saldanha Bay Municipality with respect to the availability of sufficient, spare, unallocated water prior to an Environmental Authorisation being issued for the proposed development.

Ground water This Department notes the mention of a shallow water table and the lack of knowledge of the geotechnical conditions at the site proposed for development. Impacts on ground water may be experienced due to the need for excavation and blasting down to rock level for the installation of the third tippler. Ground water pollution and the surfacing of water surrounding the tippler as a result of the installation of impervious materials may have knock–on effects elsewhere. These impacts should be investigated as part of the Basic Assessment process. Although the proposed tippler structure allows for a subsoil drainage system which feeds a sump with permanent pumps and this groundwater is to be pumped to a lined dam close to tippler 3, the position of this dam has not been identified in the BAR.

General The purpose of the proposed third tippler, as identified in the BAR, is to alleviate one of the existing tipplers during routine maintenance, repair work or as a backup should one of the existing tipplers be out of service. The proposed third tippler is not intended to operate simultaneously with the two

4. Water: Transnet has

piped inland to the tippler 3 site.suppression other than by the use of potable water are being considered, such as netting

5. Groundwater: geopreferred Tippler 3 location. is therefore sufficiently known. communication from the chief engineer potential impacts on groundwater and its managementexpected.

The expected volumes to be pumped from the subsoil drainage system are expected to be very small. It is no longer very likely that a dam to hold this water will be necessary.

6. The principle of integrated environmental managementthat the application fof Transnet’s future plans for the expansion of the entire iron ore export facility. However, their iron ore export operations through this Basic Assessmentthrough the amendment of the Atmospheric Emissions License to

RESPONSE

has advised that desalinated seawater can be piped inland to the tippler 3 site. Alternate means of dust suppression other than by the use of potable water are being

, such as netting.

eo-technical drilling was performed at the ippler 3 location. The groundwater situation at the site

is therefore sufficiently known. GIBB has obtained verbal communication from the chief engineer that no far reaching potential impacts on groundwater and its management are

volumes to be pumped from the subsoil drainage system are expected to be very small. It is no longer very likely that a dam to hold this water will be necessary.

ntegrated environmental management dictates he application for the Tippler 3 should be considered in light

of Transnet’s future plans for the expansion of the entire iron ore . However, Transnet is not seeking an expansion of

their iron ore export operations through this Basic Assessment or he amendment of the Atmospheric Emissions License to




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existing tipplers, therefore no net increase of the iron ore exports will result from proposed development. This being said, it must be highlighted that should this proposed development be approved and should it be the inTransnet to operate all three tipplers simultaneously, the infrastructure to do so will be already be in place and an environmental impact assessment will not be required in future. As such, the application must be considered in light of Transncomments from the Saldanha Bay Municipality with regards to the current unsatisfactory situation in the surrounding residential areas resulting from the dust nuisance and further potential cumulative impacts aexpansion of activities at the plant.

b. It is noted in the project description on page 3 of the BAR that “Transnet are not seeking an expansion of their iron ore export operations through the basic assessment’. However, a fourth tippthis potential fourth tippler is not to be built now and is not included in this application. This department is concerned as to whether this third tippler will form part of an expansion of the tippler facilityprocess may be misleading.

7. Additional comment s on this project will be provided following the submission of further information during the Basic Assessment process and upon receipt of the final BA Report.

This Directorate reserves the right to revise or withdraw any comments or request further information from you based on any information that might be received.

29 27 August 2013

Mike Rothenburg – Chairman BWBHOA

In 2006 we were promised by Mr. Louis van Niekerk the COO of Transnet at the time that no piecemeal incremental changes would be carried out without a comprehensive EIA being done. An EIA covering the additional tippler will not address the overall impact BWBHOA strongly object to the proposed new tippler until such time as all




9


existing tipplers, therefore no net increase of the iron ore exports will result from proposed development. This being said, it must be highlighted that should this proposed development be approved and should it be the intention for Transnet to operate all three tipplers simultaneously, the infrastructure to do so will be already be in place and an environmental impact assessment will not be required in future. As such, the application must be considered in light of Transnet’s future plans, particularly in view of the comments from the Saldanha Bay Municipality with regards to the current unsatisfactory situation in the surrounding residential areas resulting from the dust nuisance and further potential cumulative impacts as a result of potential expansion of activities at the plant. It is noted in the project description on page 3 of the BAR that “Transnet are not seeking an expansion of their iron ore export operations through the basic assessment’. However, a fourth tippler is mentioned throughout the BAR. Although this potential fourth tippler is not to be built now and is not included in this application. This department is concerned as to whether this third tippler will form part of an expansion of the tippler facility, and as such, the Basic Assessment process may be misleading.

Additional comment s on this project will be provided following the submission of further information during the Basic Assessment process and upon receipt of the final BA Report.

Directorate reserves the right to revise or withdraw any comments or request further information from you based on any information that might be

include the third tippler.expansion of the iron ore export business

In 2006 we were promised by Mr. Louis van Niekerk the COO of Transnet at the time that no piecemeal incremental changes would be carried out without a comprehensive EIA being done. An EIA covering the additional tippler will not address the overall impact on the area. I therefore on behalf of the BWBHOA strongly object to the proposed new tippler until such time as all

Transnet is not seeking an expansion of the irothrough this Basic Assessment. This basic assessment does not allow for any increase in export volumes of iron ore. The basic assessment only allows for the simultaneous operation of two tipplers. If Transnet wishes to operate more than two tippler simultaneously they will have to go through a

RESPONSE

include the third tippler. Presently, Transnet is no longer pursuing expansion of the iron ore export business .

Transnet is not seeking an expansion of the iron ore export operations through this Basic Assessment. This basic assessment does not allow for any increase in export volumes of iron ore. The basic assessment only allows for the simultaneous operation of two tipplers. If Transnet wishes to

than two tippler simultaneously they will have to go through a




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Transnet’s proposed plans are consolidated into one package and a comprehensive EIA is done.

01 14 June 2013 Gideon van Niekerk Comments and concerns:1. I am in favour of this port development and its associated

economic benefits to the West Coast. However, I do not want any adverse environmental impacts and residential properties.

2. In the pastwhich held frequent discussions with Saldanha Port Authorities and which eventually lead to the Port Authority paying for the repainting of residential properties dust, emanating from the port operati

3. I urge you to obtain the information list of all Saldanha residents who used this monetary payment to rewhich gave feedback of such actions in accordance with the Saldanha Port Authority procedure.

4. I then urge you to contacregarding the current state of the properties i.e. defacement of exterior wall surfaces, as well as to conduct a survey to evaluate for yourself the effect of the air borne iron ore duscouple of ye

5. The agreement with Portnet was that only those property owners who used the money to refeedback and proof of such work, will be able to claim for repainting their properties again in future, if exterior walls were again defaced by iron ore dust, due to iron ore dust pollution and/or nonenvironmental procedures.




10


Transnet’s proposed plans are consolidated into one package and a comprehensive EIA is done.

separate authorisation process

Historical Environmental and Social Issues

Comments and concerns: am in favour of this port development and its associated

economic benefits to the West Coast. However, I do not want any adverse environmental impacts affecting the surrounding area and residential properties.

In the past, a residential property owner’s forum was established which held frequent discussions with Saldanha Port Authorities and which eventually lead to the Port Authority paying for the re-painting of residential properties affected by the air borne iron ore dust, emanating from the port operations.

I urge you to obtain the information list of all Saldanha residents who used this monetary payment to re-paint their properties and which gave feedback of such actions in accordance with the Saldanha Port Authority procedure.

I then urge you to contact all those people on the list and enquire regarding the current state of the properties i.e. defacement of exterior wall surfaces, as well as to conduct a survey to evaluate for yourself the effect of the air borne iron ore dust over the past couple of years.

The agreement with Portnet was that only those property owners who used the money to re-paint their houses and gave proper feedback and proof of such work, will be able to claim for re-painting their properties again in future, if exterior walls were again defaced by iron ore dust, due to iron ore dust pollution and/or non-compliance to the relevant Saldanha Port environmental procedures.

1. By following the procedures set in the environmental impact

assessment regulations and other applicable legislation, the Environmental Assessment proposed project is socially, environmentally and economically sustainable.

With regard to points 2 – 5 made by G v Niekerk: Your commimpact of dust pollution have been noted. This Basic Assessment will be focusing on impacts stemming from the installation of a third tippler and will not be addressing historic issues.

RESPONSE

separate authorisation process.

By following the procedures set in the environmental impact assessment regulations and other applicable legislation, the

ssessment Practitioner is ensuring that the proposed project is socially, environmentally and economically

5 made by G v Niekerk: Your comments on the impact of dust pollution have been noted. This Basic Assessment will be focusing on impacts stemming from the installation of a third tippler and will not be addressing historic issues.




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I will await your feedback and actions in this regard.

03 18 June 2013 Wilene Smit Resident

I would like to register? How do I proceed?I also want to send you my complaints with photos of evidence.I also would like to know when will they come and paint my house?

05 20 June 2013 James Matthee Resident

Aangeheg ‘n opsomming van my korrespondensie met Transnet sedert 2006. Ten spryte van hulle erkennings en ondernemings, het hulle nog GEEN pogings aangewends om my te vergoed vir my skade nie.Aangeheg ook onlangse foto’s Duidelik het die besoedeling nie verbeter sedert “regstellende maatreels”gedoen is nie –ignoreer, of maak lee beloftesHierdie voorgestelde derde “ tippler”vererger en Transnet weier om verantwoordeliheid te aanvaar vir die skade – ondanks erkenning daarvan.. English translation:Attached is a summary of mspite of their acknowledgments and undertakings, they have still done NOTHING to reimburse me for my damageAttached are also recent photo’sObviously the pollution has not improved since correctional measurebeen instated - it has got worse.This proposed 3rd tippler will make the pollution even worse and Transnet refuses to take responsibility for the damage.

12 12 July 2013 Andrae Nieuwoudt

I am a PROPERTY OWNER at 19, Artemis Rd, Paradise Beach, where we suffer from red iron ore dust staining paint on the walls. About 1 year TFR investigated and offered to repaint houses or contribute towards houses because of this contamination.through put this damage as a result of red dust will increase.I strongly object to this expansion a




11


I will await your feedback and actions in this regard.

register? How do I proceed? I also want to send you my complaints with photos of evidence. I also would like to know when will they come and paint my house?

The GIBB public participation office confirmed Ms Smit’s registration via email. This Basic Assessment process will investigate the impacts resulting from the construction and operation of Tippler 3. The Basic Assessment process will not be addressing historical issues. The basic assessment aims to identify the impacts of Tippler 3 and methods to mitig

Aangeheg ‘n opsomming van my korrespondensie met Transnet sedert Ten spryte van hulle erkennings en ondernemings, het hulle nog

GEEN pogings aangewends om my te vergoed vir my skade nie. Aangeheg ook onlangse foto’s – nadat my huis reeds 2 maal oorgeverf is. Duidelik het die besoedeling nie verbeter sedert “regstellende maatreels”

– dit het vererger. Transnet verkies om my skrywes te ignoreer, of maak lee beloftes

voorgestelde derde “ tippler” sal beslis die besoedeling verder vererger en Transnet weier om verantwoordeliheid te aanvaar vir die skade

ondanks erkenning daarvan..

English translation: Attached is a summary of my correspondence with Transnet since 2006. In spite of their acknowledgments and undertakings, they have still done NOTHING to reimburse me for my damages. Attached are also recent photo’s-after my house has been painted twice. Obviously the pollution has not improved since correctional measures have

it has got worse. This proposed 3rd tippler will make the pollution even worse and Transnet refuses to take responsibility for the damage.

Your comments on the impact of dust pollution have been noted. This Basic Assessment will be focusing on impacts stemming from the installation of a third tippler and will not be addressing historic issues. An air quality specialist has been engaged to assess the impact of a third tippler on dust emission from the Port of Saldafound that the third tippler will result in the and extra fine dust particles in the atmosphere by 3% and 4 %, respectively. Fallout is similarly predicted to increase by 3%.

PROPERTY OWNER at 19, Artemis Rd, Paradise Beach, where we suffer from red iron ore dust staining paint on the walls. About 1 year TFR investigated and offered to repaint houses or contribute towards houses because of this contamination. This has never happened and with more through put this damage as a result of red dust will increase. I strongly object to this expansion as TFR are neglecting their responsibility.

Your comments on the impact of dust pollution on your house have been noted. This Basic Assessment will be focusing on impacts stemming from the installation of a third tippler and will not be addressing historic issues. However, the Basic Assessment Report states that its efforts in minimising the genera

RESPONSE

The GIBB public participation office confirmed Ms Smit’s registration via ment process will investigate the impacts resulting

from the construction and operation of Tippler 3. The Basic Assessment process will not be addressing historical issues. The basic assessment aims to identify the impacts of Tippler 3 and methods to mitigate these impacts.

Your comments on the impact of dust pollution have been noted. This Basic Assessment will be focusing on impacts stemming from the installation of a third tippler and will not be addressing historic issues.

An air quality specialist has been engaged to assess the impact of a third tippler on dust emission from the Port of Saldanha. The specialist study found that the third tippler will result in the increase of the maxima for fine and extra fine dust particles in the atmosphere by 3% and 4 %, respectively. Fallout is similarly predicted to increase by 3%.

Your comments on the impact of dust pollution on your house have been ed. This Basic Assessment will be focusing on impacts stemming from

the installation of a third tippler and will not be addressing historic issues. However, the Basic Assessment Report states that Transnet must increase its efforts in minimising the generation of red dust at all known point sources.




07 21 June 2013 Quinton Dollman Afrisam

Presentation of a dust dispersion model indicating the dust fallout on Farm 1139 downwind and to the northearmarked for our proposed cement factory currently subject of an EIA.

10 04 July 2013 Morgan Smit & Willie Goosen

We as the Ratepayers affected party to this matter. We would like to respond in saying we do not see the necessity for more tipplers in the port, because the two that are there produce dust whichagree if the present dust problem can be stopped, and no dust will leave the port in future.

11 05 July 2013 Pieter Stegmann THREE MONITOR ISSUES (Transnet application dust emission figuresunreliable) Transnet’s response in general is that they operate according to and within the environmentalthe primary source / causedust) generated by human activity effecting air, sea and land from Vredenburg to Langebaan. based on the results of their monitor Monitoring is an aifinal means to prove compliance with the Law.issues will prove the true and actual dust emission from the Oonly serve as an example to illustrate the point (three issues) that I want to make. a. VOLUME. A monitorA figure of 4.63 grams per square metre was allocated tolayer of dust in the full operational area). This is an insignificant figure but most misleading. Example. When one pourmug the sugar covermillimetre the result you have 50 squares of a millimetre each. Multiply 50 squares times 4 gram and the total volumearea is 0.69 square kilometresquares times 4.63 grams per square metre then the




12

Dust Emissions

Presentation of a dust dispersion model indicating the dust fallout on Farm 1139 downwind and to the north-west of the proposed tippler. This site is earmarked for our proposed cement factory currently subject of an EIA.

Airshed Professional Planning have compiled a draft air quality specialist report for the installation and operation of Tippler 3. Please refer to section 5 Dispersion Modelling Results of the report included under Appendix D of the Basic Assessment Report.

We as the Ratepayers Association of Vredenburg are an interested and affected party to this matter. We would like to respond in saying we do not see the necessity for more tipplers in the port, because the two that are there

which covers our whole area at the moment. We will only present dust problem can be stopped, and no dust will leave the

The two existing tipplers are experiencing major technical issues with diminishing reliability. The third tippler will serve as a backup when one of the existing tipplers is out of service for maintenance or repair. If assessed independently the tippler will only result in a 3 fine and extra fine dust particles in the atmospherepredicted to increase by 3%.

THREE MONITOR ISSUES (Transnet application dust emission figures are

response in general is that they operate according to and within environmental laws. The principle issue is: Whether the Ore Terminal is

source / cause of dust (any kind of dust including iron ore pink generated by human activity effecting air, sea and land Vredenburg to Langebaan. The Ore Terminal deny accountability

on the results of their monitoring.

is an aid to measure dust emissions but it is not the ultimate and final means to prove compliance with the Law. The following three monitor

that the monitor figures supplied by Transnet do not reflect the true and actual dust emission from the Ore Terminal. The figures I use

as an example to illustrate the point (three issues) that I want to

A monitoring measure of a square metre (for argument sake). A figure of 4.63 grams per square metre was allocated to each road (general layer of dust in the full operational area). This is an insignificant figure but most misleading. Example. When one pours a teaspoon of sugar in a coffee mug the sugar covers the bottom area of the mug. Measuring one square

the result is 4 gram. Divide the full bottom area into squares and you have 50 squares of a millimetre each. Multiply 50 squares times 4 gram

total volume is 200 grams (one tea spoon) in the mug. The Terminal square kilometre that is 6,900 square metre. Multiply 6,900

squares times 4.63 grams per square metre then the total dust volume

It would appear that the comments made by Mr Stegmann were initially made with reference to the renewal of the Atmospheric Emissions Licence (AEL) for the Port of Saldanha excluding theto GIBB. The renewal was handled by WSP Environment & Energy on behalf of Transnet and his comments were responded to by that consultant. The Environmental Assessment Practitioner from GIBB for the Tippler 3 Basic Assessment Report was not involved in the license renewal process and has had no influence on its contents and the statements made therein. A response to Mr P. Stegmann is not necessary as it has been responded to already.

Airshed Professional Planning have compiled a draft air quality specialist report for the installation and operation of Tippler 3. Please refer to section 5

s of the report included under Appendix D of the

The two existing tipplers are experiencing major technical issues with diminishing reliability. The third tippler will serve as a backup when one of

ut of service for maintenance or repair. If assessed independently the tippler will only result in a 3 - 4% increase in

dust particles in the atmosphere. Dust fallout is similarly

It would appear that the comments made by Mr Stegmann were initially made with reference to the renewal of the Atmospheric Emissions Licence (AEL) for the Port of Saldanha excluding the Tippler 3, and were then copied to GIBB. The renewal was handled by WSP Environment & Energy on behalf of Transnet and his comments were responded to by that consultant. The Environmental Assessment Practitioner from GIBB for the Tippler 3 Basic

t Report was not involved in the license renewal process and has had no influence on its contents and the statements made therein. A response to Mr P. Stegmann is not necessary as it has been responded to




is 31,947 grams within the areawithin the operational area exceedmonitor figure prevolume result. I suspect the operational area is most likely 5 square kilometre including the pier. This significant volumesources within the stockpiles with four stacker / extractor machines, (b) the ship loaders pouring ore from a height of four metre27 km long open sided conveyor belt system abaghouses. Open air infrastructure issues.drop more than 6 meter increasing the ore exposure to wind from the ship loaders to more than 10 metre. b. 20% / 80% AIR EMISSIONonly 20% of the averagethe benefit of doubt).occurs within the operational area. The lighter particles (80%) escape into the air crossing the monitors and boundaries of the Terminal. The lighter dust particles are carried 10/15 km far before fallout occurand Langebaan. Note. Their monitor ffigure as one cannot shift the monitors each time the wind change direction.The continuous 80%the actual volume(20%) times 4 (80%) equal 127,788 grams! Exceeding their legal limits excessively. The visual pink dust serve as proof that not even the WCDM can deny. Transnet stress compliance with the Law basedust emission recordedhave full knowledge, escaping in the airtheir response! c. PERIOD OF 24 HOURS (A DAY).period of 24 hours only. The figure of 4.63 grams per single square meter per one period of 24 hours (a day)monitoring period of a single day, supplied by Transnet in their application, ignoremonth, (iron ore) dust emanating from the Ore Terminal that




13

31,947 grams within the area of the Ore Terminal. The dust generated within the operational area exceeds the legal limit. The one square metre monitor figure presented by Transnet in their application does not reflect the

. I suspect the operational area is most likely 5 square kilometre including the pier.

volume of (iron ore) dust can come from only four "unit" within the Ore Terminal (human activity) namely (a) the open air

stockpiles with four stacker / extractor machines, (b) the ship loaders pouring height of four metres through the open air into the ships, (c) the

long open sided conveyor belt system and (d) the two tippler baghouses. Open air infrastructure issues. Note re (b): A loaded ship can drop more than 6 meter increasing the ore exposure to wind from the ship

than 10 metre.

b. 20% / 80% AIR EMISSION. Monitors within the Terminal area measure average dust released into the air. (20% - giving Transnet

the benefit of doubt). The fallout of the most heavy dust particles (20%) within the operational area. The lighter particles (80%) escape into

the air crossing the monitors and boundaries of the Terminal. The lighter dust particles are carried 10/15 km far before fallout occurs in Vredenburg and Langebaan. Note. Their monitor figures record the average / assume figure as one cannot shift the monitors each time the wind change direction.

continuous 80% dust that escapes the Terminal monitors increases volume dust emission from the Terminal from 31,947 grams

imes 4 (80%) equal 127,788 grams! Exceeding their legal limits excessively. The visual pink dust serve as proof that not even the WCDM

Transnet stress compliance with the Law based solely on the average 20% recorded by their monitors within their operational area. They,

full knowledge, deliberately ignore / deny responsibility, the 80% dust escaping in the air. They attribute this dust to other environment factors in

c. PERIOD OF 24 HOURS (A DAY). Transnet monitor figures refer to one period of 24 hours only. The figure of 4.63 grams per single square meter per one period of 24 hours (a day) is on its own most misleading. The monitoring period of a single day, supplied by Transnet in their

ignores deliberately the continuous, day after day, month after month, (iron ore) dust emanating from the Ore Terminal that accumulates




over a period of time.escaping the Ore Terminal is 3,833,640 million grams per 5. CONCLUSION. a. The total VOLUME of dust (4.68 g/c covering 9600 square meter = 31,947 g/c) is the true and actual dustOre Terminal that exceed the lawful limit of 1,200 (industrial) and 600 (residential - Blue Water Bay residential area within 2 km). b. The monitored figures generated within the Ore Terminal. c. The monitored accumulated resultinfo) dust emission from the Ore Terminal. d. The three monitor issues, volume, 20% / 80% air emission and period of 24 hours (per day) expose Transnet emission figures as unreliable (to put it mildly) and it does not reflect the true and actual dustTerminal. e. The 80% volumeon buildings in Vredenburg and Langebaan. These three monitor issues for once and all destroy the monitorresponsibility for (iron ore) dustfor a radius of 30 km. f. Add to this the fact that Transnet Terminal is the operator that handle close to 60 million tons of iron ore.g. The dust pollution did increase with the increase in the export volume since September 2010. Confirmletter and up to March / June 2013 published in the WeslanderThese reported facts contradict Transnetdust emissions in The above facts confirm the principle issueprimary source and causethe Saldanha Bay Municipal area. That they are fully accountable for the (iron ore) dust thatfrom Vredenburg to Langebaan.




14

over a period of time. Over a period of 30 days the volume of dust escaping the Ore Terminal is 3,833,640 million grams per month!

5. CONCLUSION.

a. The total VOLUME of dust (4.68 g/c covering 9600 square meter = 31,947 g/c) is the true and actual dust emission figure within the boundaries of the Ore Terminal that exceed the lawful limit of 1,200 (industrial) and 600

Blue Water Bay residential area within 2 km).

b. The monitored figures record only 20 % of the average dust emission within the Ore Terminal.

c. The monitored figure for a single 24 hours day does not reflect the result of a continuous 24 hours 7 days a week (application

info) dust emission from the Ore Terminal. d. The three monitor issues, volume, 20% / 80% air emission and period of 24 hours (per day) expose Transnet emission figures as unreliable (to put it

nd it does not reflect the true and actual dust emission from the

80% volume of (iron ore) dust released day after day accumulates in Vredenburg and Langebaan. These three monitor issues for destroy the monitor myth and legal basis of Transnet denying

responsibility for (iron ore) dust pollution within Saldanha Bay Municipal area for a radius of 30 km.

Add to this the fact that Transnet Terminal is the one and only ore that handle close to 60 million tons of iron ore.

g. The dust pollution did increase with the increase in the export volume since September 2010. Confirmed by my formal complaint per registered letter and up to March / June 2013 published in the Weslander newspaper. These reported facts contradict Transnets claim that there was a decline in

in the past three years.

confirm the principle issue that Transnet Ore Terminal is the source and cause of excessive and unlawful dust emission within

the Saldanha Bay Municipal area. That they are fully accountable for the (iron ore) dust that stains and causes damage to state and private properties

Vredenburg to Langebaan.




6. OBJECTION TO ANNEXURE C: TPT SALDANHA DUST MITACTION PLAN a. Overall objection.timeframes will have Terminal. It does not change the currair handling of ore from the three priority unit dust sources.b. The propose "conditions" mainly address maintenance procedures c. Serial ERM 009 (above) that Transnet is fully aware of the volume of dust escaping from the Terminal. No number of border monitors can monitor the dust passing the monitors in the air as explained above. 7. Kindly take note thatWSP Consultant was Transnet and acttherefore act as the neutral appeal authorityprevious consultant with the

15 14 July 2013 Pippa Haarhof – West Coast Fossil Park

Preliminary concerns would include the following:

• Dust pollution

17 10 July 2013 Andre Kruger – Saldanha Bay Municipality (Councillor Langebaan)

The present Iron Ore dust pollution is not under control. The problem must be solved before any expansion takes place. Further mitigation absolutely essential. I would hereby like to register as an interested and affected party

22 08 August 2013

A van Zyl Lugbesoedeling A.G.V die beplande projek raak landbouers direk aangesien produk wat in besoedelde lug verbou of geseel word op market afgekeur word. Huiduge besoedeling is reeds vir landbouers n problem, uitbreidings soos beoog kan landbou slegs nadelig beeinvloed. English translationAir pollution as a result of the proposed project affects agriculturalists directly because products are grown or sealed in polluted air which gets rejected at the market. The current pollution levels are already a problem for agriculturalists, and develophave a negative impact.




15

OBJECTION TO ANNEXURE C: TPT SALDANHA DUST MITIGATION

Overall objection. The proposed conditions to the renewal licence with timeframes will have no affect on the excessive dust emission from the Ore Terminal. It does not change the current infrastructure nor change the open

ing of ore from the three priority unit dust sources. b. The propose "conditions" mainly address standard operating and maintenance procedures that do not address the dust pollution at all. c. Serial ERM 009 - monitors to detect dust exceedences from site - confirm (above) that Transnet is fully aware of the volume of dust escaping from the Terminal. No number of border monitors can monitor the dust passing the

in the air as explained above.

7. Kindly take note that WSP Consultant cannot act as an "appeal" authority. WSP Consultant was appointed by Transnet and is remunerated by

act on behalf of Transnet (the "trespasser") and cannot act as the neutral appeal authority as has been done with the

previous consultant with the 2011 licence.


Dust pollution

The potential for an increase in dust pollution is specifically investigated in the Basic Assessment Report and a dedicated air quality specialist study is part of the investigations (Appendix D

The present Iron Ore dust pollution is not under control. The problem must be solved before any expansion takes place. Further mitigation steps are absolutely essential. I would hereby like to register as an interested and

This Basic Assessment will be focusing on impacts stemming from the installation of a third tippler and will not be addressing historic issues. However, the Basic Assessment Report states that Transnet must increase its efforts in minimising the generation of red dust at all known point sources.

Lugbesoedeling A.G.V die beplande projek raak landbouers direk aangesien besoedelde lug verbou of geseel word op market afgekeur

word. Huiduge besoedeling is reeds vir landbouers n problem, uitbreidings soos beoog kan landbou slegs nadelig beeinvloed.

English translation Air pollution as a result of the proposed project affects agriculturalists directly

ause products are grown or sealed in polluted air which gets rejected at the market. The current pollution levels are already a problem for agriculturalists, and developments such as the proposed project can only have a negative impact.

Evidence from the scientific literature shows that human health risks are associated with certain levels of exposure to particulate matter in the air. Evidence from the scientific literatassociated with certain levels of exposure to particulate matter. Once the particles have settled onto the leaves, smothering with dust can block the stomata through which plants exchange gas with the surrounding airSmothering can also directly affect photosynthesis. Indirect effects may involve chemical and physical modification of the soil properties. In response to these perceived issues, standards and guidelines have been set for annual and daily exposure limit

The potential for an increase in dust pollution is specifically investigated in the Basic Assessment Report and a dedicated air quality specialist study is

Appendix D).

This Basic Assessment will be focusing on impacts stemming from the installation of a third tippler and will not be addressing historic issues.

Basic Assessment Report states that Transnet must increase its efforts in minimising the generation of red dust at all known point sources.

Evidence from the scientific literature shows that human health risks are associated with certain levels of exposure to particulate matter in the air. Evidence from the scientific literature also shows that plant health can be associated with certain levels of exposure to particulate matter. Once the particles have settled onto the leaves, smothering with dust can block the stomata through which plants exchange gas with the surrounding air. Smothering can also directly affect photosynthesis. Indirect effects may involve chemical and physical modification of the soil properties.

In response to these perceived issues, standards and guidelines have been set for annual and daily exposure limits to protect the health of the general




23 17 August 2013

Mr & Mrs Naude and Helmine Steyn

There has been no mitigation of iron ore dust pollution. The environment is the big loser, as well as the public in the Saldanha Bay and Langebaan Lagoon areas. Our comments, which are in your possession, have not changed and the situation is worsening, whthe proposed increase in the iron ore tonnage including the dredging. The air pollution license should stipulate that the amount of the iron ore Transnet is allowed to export will be progressively reduced for as long asTransnet fails to control iron ore dust emissions. Mounting public anger and mistrust in soenvironmental impact studies by others have not resulted in the necessary improvement in the quality of life or maintaining a hefor both nature and lagoon, clean and sensitive ecosystems as well as to us, the people of the West Coast. Everyone in business (wealth creation), retirement (better and more convenient facilities, has benefitted in the past 20 years but the environment has suffered a heavy blow, due to the lack of the environmental control. The proposed iron ore expansion wito both the people living here, the natural resources, the Langebaan Lagoon




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public. As new evidence becomes available the standards are being revised. To this end, new reduced maximum exposure levels to airborne dust are scheduled to come into effect over the next number of years in South Afr The air quality specialist study conducted as part of the Basic Assessment for the introduction of a third tippler at Saldanha has considered both present and future emission standards, especially for industrial and for residential areas. The air quality specialist study found that tdirectly north of the facility owing to the predominant strong southerly winds occurring in the area. The current monthly average fallout rate of 600 mg/m²/day is within the non-residenrespect to the residential area classification.fallout rates have been set by government for agricultural land. The EAP is aware of the conservation implications of this developmeassessment of the vegetation on site has been made. This has informed the impact assessment and the mitigation measures that must be implemented.

There has been no mitigation of iron ore dust pollution. The environment is the big loser, as well as the public in the Saldanha Bay and Langebaan Lagoon areas. Our comments, which are in your possession, have not changed and the situation is worsening, which will be further exacerbated by the proposed increase in the iron ore tonnage including the dredging.

The air pollution license should stipulate that the amount of the iron ore Transnet is allowed to export will be progressively reduced for as long as Transnet fails to control iron ore dust emissions. Mounting public anger and mistrust in so-called anxious public comment and environmental impact studies by others have not resulted in the necessary improvement in the quality of life or maintaining a healthy clean environment for both nature and lagoon, clean and sensitive ecosystems as well as to us, the people of the West Coast.

Everyone in business (wealth creation), retirement (better and more convenient facilities, has benefitted in the past 20 years but the environment has suffered a heavy blow, due to the lack of the environmental control.

The proposed iron ore expansion will leave unthinkable permanent damage to both the people living here, the natural resources, the Langebaan Lagoon

The Environmental Management Programme which forms part of this Basic Assessment Report stipulates mitigation metipplers are well maintained the dust impact from the addition of the third tippler will be minimal. The Basic Assessment only allows for the simultaneous operation of two tipplers. If Transnet wishes to operate more they will have to go through a separate authorisation process

public. As new evidence becomes available the standards are being revised. To this end, new reduced maximum exposure levels to airborne dust are scheduled to come into effect over the next number of years in South Africa.

The air quality specialist study conducted as part of the Basic Assessment for the introduction of a third tippler at Saldanha has considered both present and future emission standards, especially for industrial and for residential

ality specialist study found that the major dust-fall impact area lies directly north of the facility owing to the predominant strong southerly winds occurring in the area. The current monthly average fallout rate of 600

residential area classification, but marginal with respect to the residential area classification. No specific standards for dust fallout rates have been set by government for agricultural land.

The EAP is aware of the conservation implications of this development. An assessment of the vegetation on site has been made. This has informed the impact assessment and the mitigation measures that must be implemented.

The Environmental Management Programme which forms part of this Basic Assessment Report stipulates mitigation measures for dust pollution. If the tipplers are well maintained the dust impact from the addition of the third

ssessment only allows for the simultaneous operation of two tipplers. If Transnet wishes to operate more than two tipplers simultaneously they will have to go through a separate authorisation process.




and the pristine way of life.

24 19 August 2013

Nazeema Duarte The Draft Basic Assessment Report DBAR for the Provision of a Third (3Tippler and Associated Infrastructure at the Port of Saldanha dated 18 July 2013 refers.

1. The DBAR for the 3GIBB has been appointed to Draft a Scoping report for the expansion of the iron ore terminal withthird tippler is not just for maintenance or emergencies; it is envisioned for the expansion of the iron ore terminal.

2. For an alternative to be considered, it has to be reasonable and feasible. The second alternative (technoneither reasonable nor feasible, therefore it should not be considered as an alternative.

3. The air quality assessment is based on no nett expansion as the third tippler is meant for maintenance and as a standoperation simthat the third tippler, may not be used operationally until all the relevant authorisations for the expansion of the iron ore terminal have been issued.

4. The air quality assessment also indicates that theemissions with regards to the third tippler, in isolation has a small impact however continued mitigation efforts must be instituted to improve the existing air quality which is already compromised by the current operations. This statemeof dust fallout control measures and monitoring.

5. The recommendation by the specialist; to implement the fallout monitoring network should be implemented.

6. It is of concern that the basic assessment indicates that althoughthe third tippler contributes a small amount of the total particulate emissions compared to other sources, the operation of a third tippler; let alone a fourth tippler which is earmarked for the expansion of the iron ore terminal could potentially lead tosituation where the combined emissions will exceed legislative prescripts.

7. Whilst the Strategic integrated Project 5 (“SIP5) and the National Spatial Development Perspective (”NSDP’) has to be taken into consideration, the affected communities in Saldasatisfied with the measures put in place thus far to protect their property from the iron ore dust nuisance to date as is evident from Appendix E3 (Comment and Response Report). Even though the




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and the pristine way of life.

The Draft Basic Assessment Report DBAR for the Provision of a Third (3rd) Tippler and Associated Infrastructure at the Port of Saldanha dated 18 July

The DBAR for the 3rd tippler “back-up” (sic) is misleading because GIBB has been appointed to Draft a Scoping report for the expansion of the iron ore terminal with the vision of 4 tipplers. The third tippler is not just for maintenance or emergencies; it is envisioned for the expansion of the iron ore terminal. For an alternative to be considered, it has to be reasonable and feasible. The second alternative (technology alternatives), is neither reasonable nor feasible, therefore it should not be considered as an alternative. The air quality assessment is based on no nett expansion as the third tippler is meant for maintenance and as a stand-by; not for operation simultaneously with the other two tipplers. This means that the third tippler, may not be used operationally until all the relevant authorisations for the expansion of the iron ore terminal have been issued. The air quality assessment also indicates that the effect of the air emissions with regards to the third tippler, in isolation has a small impact however continued mitigation efforts must be instituted to improve the existing air quality which is already compromised by the current operations. This statement is indicative of the shortfall of dust fallout control measures and monitoring. The recommendation by the specialist; to implement the fallout monitoring network should be implemented. It is of concern that the basic assessment indicates that although the third tippler contributes a small amount of the total particulate emissions compared to other sources, the operation of a third tippler; let alone a fourth tippler which is earmarked for the expansion of the iron ore terminal could potentially lead to a situation where the combined emissions will exceed legislative prescripts. Whilst the Strategic integrated Project 5 (“SIP5) and the National Spatial Development Perspective (”NSDP’) has to be taken into consideration, the affected communities in Saldanha Bay are not satisfied with the measures put in place thus far to protect their property from the iron ore dust nuisance to date as is evident from Appendix E3 (Comment and Response Report). Even though the

1. Transnet is not seeking an expansion of the iron ore export operations through this Basic Assessment.assessment does not allow for any increase in export volumes of iron ore. The basic assessment only allows for the simultaneous operation of two tipplers. If Ttwo tippler simultaneously they will have to go through a separate authorisation process

2. Noted. The proposed tippler is the best technology alternative, the open air tippler was included to demonstrate the efficiency in the tippler building in reducing dust emissions. The Basic Assessment Report states that this alternative was dismissed at the design phase.

3. See point 1, the increase in export tonnages of iron ore. The third tippler may be operated, but only when one of the existing tipplers are out of operation for maintenance or repair and the export oPort of Saldanha is still capped at 60

4. Over the past number of years Transnet has steadily increasethe dust control measures. This the air quality compliance review by WSP Environmentato in section 12c of the Basic Assessment Report.

5. The specialist recommendations have Environmental Management Programme.

6. The prescribed mitigation measures in the EMPr must be implemented and dust monitoring conducted to assess the effectiveness of these measures

7. In 2012 Transnet (as Transnet Port Terminals (TPT)) commissioned a dust management study Saldanha from the independent consulting firm Environmental Resources Management (ERM). A copy of the study is provided in Appendix J of the BAR.dust management plan that was approved by Transnet for

seeking an expansion of the iron ore export operations through this Basic Assessment. This basic assessment does not allow for any increase in export volumes of iron ore. The basic assessment only allows for the simultaneous operation of two tipplers. If Transnet wishes to operate more than two tippler simultaneously they will have to go through a separate authorisation process Noted. The proposed tippler is the best technology alternative, the open air tippler was included to demonstrate the efficiency in the tippler building in reducing dust emissions. The Basic Assessment Report states that this alternative was dismissed at

See point 1, the Basic Assessment does not allow for any increase in export tonnages of iron ore. The third tippler may be

but only when one of the existing tipplers are out of operation for maintenance or repair and the export of iron ore the Port of Saldanha is still capped at 60 million tonnes per annum. Over the past number of years Transnet has steadily increased the dust control measures. This improvement is documented in the air quality compliance review by WSP Environmental referred to in section 12c of the Basic Assessment Report.

The specialist recommendations have been incorporated into the Environmental Management Programme.

he prescribed mitigation measures in the EMPr must be and dust monitoring conducted to assess the

effectiveness of these measures.

In 2012 Transnet (as Transnet Port Terminals (TPT)) commissioned a dust management study and plan for the Port of Saldanha from the independent consulting firm Environmental Resources Management (ERM). A copy of the study is provided in Appendix J of the BAR. The study presents a comprehensive dust management plan that was approved by Transnet for




Environmental Assessment Practitioner clearly Basic Assessment will not deal with historical issues, the historical issues indicate that there is a problem which is not being addressed.

8. In light of the above mentioned and due to numerous complaints having been received by this authooperation of the plant (of which the proposed tippler will form part) it is satisfactorily before future expansion be considered i.e. reducing the nuisance factor and any associate

9. The semi enclosed conveyor belt carrying iron ore from the third tippler will be contributing to the red dust problem in the Saldanha Bay municipal area.

10. Provision should be made for a long term process for the removal/control of alien vegetation there will be seed banks which will not be collected during site clearance.

11. Please also take into consideration the setback/hazard line studies being conducted by Royal Haskoning DHV for the west coast.

11 18 June 2013 Pieter Stegmann Resident

1. The approval of the 1 July 2011 Atmospheric Emission Licence (AEL), to increase the export volume from 47 to 60 million tons, WITHOUT ANY CHANGE TO THE CURRENT INFRASTRUCTURE have increased the dust emission drastically. The d10/15 km

2. The licensing authority, West Coast District Municipality, have failed to execute their duty according to the Air Quality Act and is now under investigation by the Public ProtectorTerminal have now again applthat expired 31 March 2013.

3. The epresent AEL application situationpossible strict infrastructure c




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Environmental Assessment Practitioner clearly states that this Basic Assessment will not deal with historical issues, the historical issues indicate that there is a problem which is not being addressed. In light of the above mentioned and due to numerous complaints having been received by this authority over the period of operation of the plant (of which the proposed tippler will form part) it is imperative that the existing situation be addressed satisfactorily before future expansion be considered i.e. reducing the nuisance factor and any associated risks. The semi enclosed conveyor belt carrying iron ore from the third tippler will be contributing to the red dust problem in the Saldanha Bay municipal area. Provision should be made for a long term process for the removal/control of alien vegetation in the disturbed areas because there will be seed banks which will not be collected during site clearance. Please also take into consideration the setback/hazard line studies being conducted by Royal Haskoning DHV for the west

implementation. The plan makes a firm commitment towards improved cooperation wi

8. Noted. At this stage no expansion of the operations is taking place.

9. Dust suppression at the conveyor belt transfer points is one of the focus areas of intervention by Transnet.

10. The EMPr requires all invasive alien vegetatarea to be removed and destroyed.

11. The proposed tippler is located 1.4 km inland from the coast, it is not expected that the setback/ hazardous line will apply to this proposed development.

Atmospheric Emission Licence

The approval of the 1 July 2011 Atmospheric Emission Licence (AEL), to increase the export volume from 47 to 60 million tons, WITHOUT ANY CHANGE TO THE CURRENT INFRASTRUCTURE have increased the dust emission drastically. The dust pollution extent now 10/15 km north and 10/15 km south of the Terminal. The licensing authority, West Coast District Municipality, have

to execute their duty according to the Air Quality Act and is now under investigation by the Public Protector. Transnet Terminal have now again applied for the renewal of their licence that expired 31 March 2013. The e-mail below and the next e-mail tomorrow explain the present AEL application situation with legal consequences and possible strict infrastructure changes at the Terminal.

1. The impact of dust emissions from Tippler 3 have been assessed by an air quality specialist. Dust emissions from the conveyors can be reduced through wetting of iron ore, use of chemical suppressants and enclosing the conveyors where practical. According to the results of the modelling conducted by the air quality specialist, the proposed third tippler may increase the maxima for fine and extra fine dust particles in the atmosphere by 3% and 4%, respectively. Fallout is similarly predicted to increase by 3%. The specialist report contains charts showing modelled fallout across the region. Pieter Stegmann can check his claimed dust pollution extents with the use of said charts.

2. The application for an Air Emissions License is running in parallel with this Basic Assessment, but with Transnet handling the Air Emission Licence (AEL)

3. The EAP has no knowledge of the e

The plan makes a firm commitment towards mproved cooperation with authorities and civil society. Noted. At this stage no expansion of the operations is taking

Dust suppression at the conveyor belt transfer points is one of the focus areas of intervention by Transnet.

he EMPr requires all invasive alien vegetation within the works area to be removed and destroyed. The proposed tippler is located 1.4 km inland from the coast, it is not expected that the setback/ hazardous line will apply to this proposed development.

The impact of dust emissions from Tippler 3 have been assessed by an air quality specialist. Dust emissions from the conveyors can be reduced through wetting of iron ore, use of chemical suppressants and enclosing the conveyors where practical.

o the results of the modelling conducted by the air quality specialist, the proposed third tippler may increase the maxima for fine and extra fine dust particles in the atmosphere by 3% and 4%, respectively. Fallout is similarly predicted to increase

. The specialist report contains charts showing modelled fallout across the region. Pieter Stegmann can check his claimed dust pollution extents with the use of said charts. The application for an Air Emissions License is running in parallel

c Assessment, but with Transnet handling the Air Emission Licence (AEL) application The EAP has no knowledge of the e-mails referred to.




11 19 June 2013 Peter Stegmann The renewal licence cannot be issued on the basis of theprovided by the Transnet Port Terminal, Saldanha application. The first paragraph ofQuote: "the AEL has been issued on the company's application dated 25that becomes available during processing of the application." THE 2013 AEL APPLICATION FORM: COMMENTS 1. SCHEDULE 3.2. Description of surrounding land use (within 5 km radius) a. You and your officials should takeapplication to their figures do not includelimit is five kilometrelaw, Act and Licence, when dust emissionNEMA Acts. The visual iron oreevidence. b. The visual currTransnet Terminal c. The Blue Water Bay residential area,area. South of the Terminal, just outside the 5 km limit,Curo School and Laguna Mall, Club Mykonos Resort and many new housing developments. The closeness ofresidential areas cannot be ignored by Transnet and you / WCDM, as you did with the first application. d. This surroundilegal and licence actionemission from Transnet ore Terminal to contain ore dust within their operational area alone. e. The actual "Description of surrVredenburg and LangebaanMalls and housing developmentsMunicipal area! Three towns! 2. ACTUAL CONSUMPTION / PRODUCTION. 42 MILLION TO




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icence cannot be issued on the basis of the information Transnet Port Terminal, Saldanha - Company, in their 2013

The first paragraph of the issued Licence, 1 July 2011, read: Quote: "the AEL has been issued on the basis of information provided in the

s application dated 25 November (Sept.?) 2010 and information available during processing of the application."

THE 2013 AEL APPLICATION FORM: COMMENTS

3.2. Description of surrounding land use (within 5 km

You and your officials should take note that Transnet restrict their application to their operational area. All their facts and emission

do not include the surrounding area. Their NEMA pollution "legal" five kilometre of surrounding area that the law allows! They break the

law, Act and Licence, when dust emissions exceeds 5 km as per the relevant NEMA Acts. The visual iron ore dust (stains) in three towns serve as proof /

current pollution extends 10/15 km to the North and South of Transnet Terminal, a radius of 30 km!

c. The Blue Water Bay residential area, 2 km away, is within this 5 km South of the Terminal, just outside the 5 km limit, as is a newly built School and Laguna Mall, Club Mykonos Resort and many new housing

developments. The closeness of Blue Water Bay, a school and many new residential areas cannot be ignored by Transnet and you / WCDM, as you did with the first application.

d. This surrounding area situation demands a drastic and immediate and licence actions to change Transnet infrastructure to eliminate dust

Transnet ore Terminal to contain ore dust within their operational area alone.

"Description of surrounding land use should include Vredenburg and Langebaan that includes 90% of all schools, hospitals,

and housing developments / residential areas within the Saldanha Bay Municipal area! Three towns!

ACTUAL CONSUMPTION / PRODUCTION. 42 MILLION TONS.

It would appear that the comments made by Mr Stegmann were initially made with reference to the renewal of the Atmospheric Emissions Li(AEL) for the Port of Saldanha excluding the Tippler 3, and were then copied to GIBB. The renewal was handled by WSP Environment & Energy on behalf of Transnet and his comments were responded to by that consultant. The Environmental Assessment PractiAssessment Report was not involved in the license renewal process and has had no influence on its contents and the statements made therein. A response to Mr P. Stegmann is not necessary as it has been responded to already elsewhere.

appear that the comments made by Mr Stegmann were initially made with reference to the renewal of the Atmospheric Emissions Licence (AEL) for the Port of Saldanha excluding the Tippler 3, and were then copied to GIBB. The renewal was handled by WSP Environment & Energy on behalf of Transnet and his comments were responded to by that consultant. The Environmental Assessment Practitioner from GIBB for the Tippler 3 Basic Assessment Report was not involved in the license renewal process and has had no influence on its contents and the statements made therein. A response to Mr P. Stegmann is not necessary as it has been responded to




Schedule 5.1 and 2 of the application indicateand actual production capacity of 42 million tons. I have now receiveevidence, see annexure 3, page 1, from Transnet themselves that the actual tonnage is close to 60 millionthis tonnage figure. made a false declaration in his application. I have doubts aboutreason why I have askreports. I suspect that they are exceeding 60 million tons! that YOU supply me with the 3. FACTS (dust source points) AND FIGURES (dust emission) INFORMATION SUPPLIED IN APPLICATION The facts and figures are operational situation at the Ore Terminal for the following reasons: a. FACTS - SOURCE POINTS30 source points (schedule 5.4.5). i. Two tippler baghouses (brick buildings for unloading of ore train trucks).ii. Seven stockpiles only (WCDM TO VERIFY). Priority 1 source point. Including 4 stacker/reclaimer machines.iii. Two ship loading machines. iv. Twelve transfer points. (WCDM to explain)v. Five roads! The layer of dust on the roads is not the source but the of dust coming from the conveyors alongside the roads and stockpiles. Identifying roads as source point isvi. Excluding the conveyor belt systemidentified as a dust emission source point! b. FIGURES - DUST EMISSIONand other legal / monitoring / formula info me NOTE: Monitors. It is scientifically (wetenskaplik) IMPOSSIBLE to measure / determine the dust emission from given in the application. Due to (a) the operations creating and working awaypoints), (c) the 18 meter ground), (d) the air




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Schedule 5.1 and 2 of the application indicates the actual consumption rate and actual production capacity of 42 million tons. I have now received evidence, see annexure 3, page 1, from Transnet themselves that the actual tonnage is close to 60 million tons. The drastic increase in pollution confirms this tonnage figure. This new information confirms that Transnet Manager made a false declaration in his application.

s about the 42 million tons figure in the application. This was the why I have asked you for copies if the Company's latest two annual

reports. I suspect that they are exceeding 60 million tons! I now demand that YOU supply me with the audit annual reports.

3. FACTS (dust source points) AND FIGURES (dust emission) TION SUPPLIED IN APPLICATION

The facts and figures are unreliable and do not reflect the true and actual operational situation at the Ore Terminal for the following reasons:

SOURCE POINTS. Two tippler baghouses (schedule 5.4.1) plus source points (schedule 5.4.5).

i. Two tippler baghouses (brick buildings for unloading of ore train trucks). ii. Seven stockpiles only (WCDM TO VERIFY). Priority 1 source point. Including 4 stacker/reclaimer machines.

Two ship loading machines. Priority 2 source point. iv. Twelve transfer points. (WCDM to explain) v. Five roads! The layer of dust on the roads is not the source but the result of dust coming from the conveyors alongside the roads and stockpiles. Identifying roads as source point is most misleading.

Excluding the conveyor belt system. This Priority 3 source point is NOT dust emission source point!

DUST EMISSION (schedule 5.4.4 and 5.4.6 read with 5.4.8 - and other legal / monitoring / formula info mentioned).

. It is scientifically (wetenskaplik) IMPOSSIBLE to measure / determine the dust emission from each stockpile or each source points as given in the application. Due to (a) the closeness of the stockpiles, (b) 24/7

ng and working away of stockpiles (affecting all the source points), (c) the 18 meter height of stockpiles - six stories (monitors on the ground), (d) the air flow in waves crossing monitors and hills, (e) fluctuation




in wind directions distance and areawithin the operational area or immediate surrounding area. The 24 hour ore handling operationopen air stockpiles iron ore dust from the Ore Terminal.(schedule 4.3 actually read 4.4). i. Transnet allocateimpossible. They "legally" manipulate the figures, own admission, by "assuming" and "estimate" the "average" emission figures. I suspect they use the figures from xfigure. Divide this figure by the number of stockpiemission figure for each stockpile! They may also, to improve their figures, divide the average monitored figure by the specified 30 ii. Transnet allocate the dust emission figure of ship loaders. The lowest figures of small stockpile). This is absurd! loading source pointhandle 21 million tonsthe four stacker / reclaimer machinesmillion tons. Excluding ± 25%ship loaders! Transnet ownin the application is figures manipulatedpoint! b. Dust emanating from each road is 4.83 g/s. Nearly 20 times higher than the emission from each 0dust on the road/pier under the ship loaders, that I have seen,more than the average on the roads. However, the road emission figures confirm the visual pollution situation emission of dust from the open air stockpiles, ship loaders and conveyors (running alongside the roads) pollute (a) the whole operational area and (b) the surrounding veld/bridge/road next to thethe 5 km surrounding area. c. That, with the proportionally also a drastic increaseexperienced in three towns




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directions and wind strengths that spread of dust over a vast distance and area that cannot be measured by any number of monitors. Not

the operational area or immediate surrounding area or the 30 km surrounding area. The 24 hour ore handling operations with wind exposed open air stockpiles cannot be "intermittent" but is a "continuous" emission of iron ore dust from the Ore Terminal.(schedule 4.3 actually read 4.4).

i. Transnet allocates dust emission figures to each source point which is hey "legally" manipulate the figures, own admission, by

"assuming" and "estimate" the "average" emission figures. I suspect they use the figures from x-number of monitors to arrive at an average pollution figure. Divide this figure by the number of stockpiles to determine the emission figure for each stockpile! They may also, to improve their figures, divide the average monitored figure by the specified 30 source points!

ii. Transnet allocate the dust emission figure of 0.223 g/s to each of the two The lowest figures of all the 30 source points (excluding one

small stockpile). This is absurd! All export ore concentrate at this ship loading source point through which 42 million tons pass - each ship loader handle 21 million tons (for argument sake). The emission figure for each of the four stacker / reclaimer machines is 0.786 g/s who each handle only 10.5

Excluding ± 25% ore going directly from the train trucks to the Transnet own figures illustrate that the emission figures quoted

in the application is unreliable and the ship loader emission manipulated not to expose this as a Priority 2 pollution source

b. Dust emanating from each road is 4.83 g/s. Nearly 20 times higher than the emission from each 0.223 g/s ship loader! These figures is absurd! The dust on the road/pier under the ship loaders, that I have seen, is ten times more than the average on the roads. However, the road emission figures confirm the visual pollution situation within the whole Terminal area. That the emission of dust from the open air stockpiles, ship loaders and conveyors (running alongside the roads) pollute (a) the whole operational area and (b) the surrounding veld/bridge/road next to the Terminal and (c) extend beyond

km surrounding area.

That, with the increase in export volume at Transnet there was proportionally also a drastic increase in iron ore dust pollution experienced in three towns covering a radius of 30 kilometre.




d. There was no change in operations athave cause also an increase in iron ore dust pollution, other than at Transnet Port Terminal (increase from 47 to 60 million tons). e. There is no red ground / soil in Langebaan or Saldanha Bay, only white sand near the lagoon, f. The undisputable fact remains that (a)North to Vredenburg and 10 km South to Langebaan and (b) the visual presence of iron ore dust pollution in the towns serve as prothere is only one source from where this iron ore dust can come from and that is from the Ore Terminal which alone (b) handleore versus one stockpile at g. Transnet emission figures doexplain the severe and and Langebaan (winter winds).photo's published March 2013 and those published by AgriForum June 2013 serve as evidencemission figures. As well as my complaint sinceTransnet, my house inspected January 2011 (three times over 5 months) / as seen by Transnet Environment Manager and confirmation by WCDM environment official and official from the Western Cape Provincial Government. Together with my three reports and numerous eserve as documentary evidence with regard to the previous application and it also apply to this application. h. Comment. An environment auditor's audit reportthe limited information available to himsituation mentioned above make it impossible for the auditor to report the true and actual situation at the Terof iron ore dust in Langebaan and Vredenburg. 4. REPORTS by Transnet submitted to WCDM Authority Addendum A and B. The above doubtful "facts and figures" will also be reflected in the reports submitted to WCDM. Transnet according to Addendum B, schedule 11.13.7,8 and 9care" to contain the atmospheric dust emissions,the Weslander and my complaint since September 2010 serve as proof and evidence.




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d. There was no change in operations at Saldanha Steel Factory that may have cause also an increase in iron ore dust pollution, other than at Transnet Port Terminal (increase from 47 to 60 million tons).

e. There is no red ground / soil in Langebaan or Saldanha Bay, only white goon, that may be a source of red iron ore stains.

undisputable fact remains that (a) iron ore pollution extends 10 km North to Vredenburg and 10 km South to Langebaan and (b) the visual presence of iron ore dust pollution in the towns serve as proof THAT (a) there is only one source from where this iron ore dust can come from and that is from the Ore Terminal which alone (b) handle "42 million tons" of iron ore versus one stockpile at Saldanha Steel Factory.

Transnet emission figures do not (cannot admit guilt exceeding 5 km) explain the severe and visual dust pollution in Vredenburg (summer winds) and Langebaan (winter winds). Attached Weslander letters and

published March 2013 and those published by AgriForum June 2013 serve as evidence / proof that contradict Transnet dust pollution /

figures. As well as my complaint since September 2010 to my house inspected January 2011 (three times over 5 months)

Transnet Environment Manager and confirmation by WCDM nvironment official and official from the Western Cape Provincial

Government. Together with my three reports and numerous e-mails that serve as documentary evidence with regard to the previous application and it also apply to this application.

environment auditor's audit report would be based solely on information available to him. The restrictive scientifically

mentioned above make it impossible for the auditor to report the true and actual situation at the Terminal. Neither can he deny the presence of iron ore dust in Langebaan and Vredenburg.

by Transnet submitted to WCDM Authority - mentioned in Addendum A and B. The above doubtful "facts and figures" will also be reflected in the reports submitted to WCDM. Transnet according to Addendum B, schedule 11.13.7,8 and 9 have fail to execute its "duty of

to contain the atmospheric dust emissions, The letters and photos in the Weslander and my complaint since September 2010 serve as proof and




5. Transnet abuseestimate, average) 6. RECOMMENDATION.Transnet Port Terminal, Saldanha the NEMA DUE TO (a) late submission of application (knowing the tineeded to process the application) and thatlicence, (b) the unreliable informationto execute their "duty of care"a drastic increase in iand damages to state and private properties within a radius of 30 kilometre! Three towns! In view of the "information that become available during processing of the application," mentioned above andlegal action against Transnet Port Terminal, Saldanha, the Company.advise.

08 27 June 2013 Pieter Fabricius With regards to your advertisement in the “Weslander” of 13 June 2013 it was noted that you have made no mention of the need to obtain authorization in terms of the National Environmental Management :AirQuality Act,2004 (Act 39 of 2004).This proposal will require an amendment to the Provincial Atmospheric Emission License of Transnet Port Terminals and should have been mentioned in your advertisement. It is recommended that you conduct your public participation process required for both authorizations simultaneously.In order for you to obtain a reference number from the licensing authority, in this instance the West Coast District Municipality; you will have to submit an application on the prescribed fowww.westcoastdm.co.za

11 18 June 2013 Pieter Stegmann Resident

1. No addition or expansion to Transnet Saldanha Terminal can be done before major changes to the infrastructure




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Transnet abuse the prescribed application form to manipulate (assume, estimate, average) their "facts and figures" in their application..

6. RECOMMENDATION. That the WCDM apply severe "sanctions" against Transnet Port Terminal, Saldanha - the company, in terms of section 28 of the NEMA DUE TO (a) late submission of application (knowing the time needed to process the application) and that they now operate without a

unreliable information in their application and (c) their failure "duty of care" in terms of the 1 July 2011 licence causing

a drastic increase in iron ore dust pollution effecting the health of residence and damages to state and private properties within a radius of 30 kilometre!

In view of the "information that become available during processing of the application," mentioned above and my previous e-mail, you need to take legal action against Transnet Port Terminal, Saldanha, the Company. Kindly

With regards to your advertisement in the “Weslander” of 13 June 2013 it was noted that you have made no mention of the need to obtain authorization in terms of the National Environmental Management :Air Quality Act,2004 (Act 39 of 2004). This proposal will require an amendment to the Provincial Atmospheric Emission License of Transnet Port Terminals and should have been mentioned in your advertisement. It is recommended that you conduct your

cipation process required for both authorizations simultaneously. In order for you to obtain a reference number from the licensing authority, in this instance the West Coast District Municipality; you will have to submit an application on the prescribed form that is available on council’s website. www.westcoastdm.co.za

Unfortunately there was an initial delay in commencing with the Atmospheric Emissions License amendment to include the third tippler that was outside GIBB's control. Since then the amendment application process has commenced and is following the procedure Newspaper advertisements will shortly be published informing the public of the AEL process and announcing a 21 day registration period for Stakeholders will then be able to view and comment on both processes together, namely the final Basic Assessment Report and the AEL application.

Changes to Port Infrastructure

No addition or expansion to Transnet Saldanha Terminal can be done before major changes to the infrastructure are made.

1. Your submission is interpreted such that you cannot agree to additions or expansions of the Saldanha Terminal until Transnet has addressed existing environmental impacts. More specifically the nuisance of redthe Terminal. You wish for Transnet to increase its efforts in minimising the generation of red dust. This general principle of responsible environmental management is also supported in the text of the Basic Assessment Report.

Unfortunately there was an initial delay in commencing with the Atmospheric Emissions License amendment to include the third tippler that was outside GIBB's control. Since then the amendment application process has commenced and is following the procedure outlined by Mr Fabricius.

Newspaper advertisements will shortly be published informing the public of the AEL process and announcing a 21 day registration period for I&APs. Stakeholders will then be able to view and comment on both processes

ely the final Basic Assessment Report and the AEL

Your submission is interpreted such that you cannot agree to additions or expansions of the Saldanha Terminal until Transnet has addressed existing environmental impacts. More specifically

red-coloured iron dust fallout some distance from he Terminal. You wish for Transnet to increase its efforts in minimising the generation of red dust. This general principle of responsible environmental management is also supported in the text of the Basic Assessment Report.




2. Tippler 3 will require an extension to the open sided conveyor belt

system and an increase in the number of open air stockpiles. This will result in an increase in iron ore dust emission.

07 21 June 2013 Quinton Dollman Afrisam

The implications of the new Duferco bridge over rail on the infrastructure to the west of the rail line and how this new bridge will link with the existing Duferco private road.

09 04 July 2013 René de Kock The South African National Roads Agency SOC Limited (SANRAL) has no comment with regard to the above application, as no national road will be affected.

11 05 July 2013 Pieter Stegmann I stand by my formal objections addressed in my three e a. E-mail dated 18 June 2013 (Infrastructure Facts and Questions: Legal Implications). Awaiting verification by WCDM.themselves to answer my question of how many stockpiles was there at the time they submitted their application. They know exactly how many stockpiles are there at any given date. That is their core business. They refuse to identify and explain the "Transfer Point" sconveyor belt doesnumber of 12 "Transfer Points" as source points is suspicious. b. E-mail dated 19 June 2013. (Infrastructure Emission Figures Unreliable) read with three mo c. E-mail dated 24 June 2013 (DA Policy and recommenthe licence).

19 16 July 2013 Anton Lubbe Chief Operations Officer

Black Mountain Mining (Pty) Ltd hereby wishes to register as a I&AP and raise the following issues:

1. What infrastructure is to be added to the Port of Saldanha to accommodate the increased export volumes such as zinc concentrate, lead concentrate, copper concentrate and magnetite ore? Export requirements are to include infrastructure for the following: a) Access to port for train and truck delivery of concentrate materialb) Offloadingc) Ship access to port for cape size vesselsd) Ship loading facilities for bulk concentrate




24

Tippler 3 will require an extension to the open sided conveyor belt system and an increase in the number of open air stockpiles. This will result in an increase in iron ore dust emission.

2. In addition to the third tipp

other infrastructure will be required. Please refer to Section 1 Project Description of the conveyor belt will link Tippler 3 to the stockpiles in the port. At this stage, no new stockpiles are proposed.

The implications of the new Duferco bridge over rail on the infrastructure to the west of the rail line and how this new bridge will link with the existing Duferco private road.

To accommodate the new Duferco Bridge a section of the haul road linking Namakwa Sands to the port will be relocated onto property owned by Arcelor Mittal.

The South African National Roads Agency SOC Limited (SANRAL) has no comment with regard to the above application, as no national road will be

Noted

I stand by my formal objections addressed in my three e-mails:

mail dated 18 June 2013 (Infrastructure Facts and Questions: Legal Awaiting verification by WCDM. Transnet cannot implicate

to answer my question of how many stockpiles was there at the time they submitted their application. They know exactly how many stockpiles are there at any given date. That is their core business. They refuse to identify and explain the "Transfer Point" sources. The 27 km long

es not consist of one or two km long sections therefore the "Transfer Points" as source points is suspicious.

mail dated 19 June 2013. (Infrastructure Emission Figures Unreliable) three monitor issues below (addendum to this e-mail).

mail dated 24 June 2013 (DA Policy and recommended conditions to

The contents of the emails welsewhere in this document (three comments above)

Black Mountain Mining (Pty) Ltd hereby wishes to register as a I&AP and raise the following issues:

What infrastructure is to be added to the Port of Saldanha to accommodate the increased export volumes of other bulk commodities such as zinc concentrate, lead concentrate, copper concentrate and magnetite ore? Export requirements are to include infrastructure for the

Access to port for train and truck delivery of concentrate material Offloading and undercover storage facilities for bulk concentrate Ship access to port for cape size vessels Ship loading facilities for bulk concentrate

1. The proposed third tippler will be used by Transnet as a backup when one of the existing two tipplers is out of operatin export of iron ore or export of additional bulk materials will result from the installation of the third tippler. 2, 3 and 4. It recommended that direct interaction between Black Mountain

In addition to the third tippler new sections of railway line and other infrastructure will be required. Please refer to Section 1 Project Description of the Basic Assessment report. A new conveyor belt will link Tippler 3 to the stockpiles in the port. At this

stockpiles are proposed.

To accommodate the new Duferco Bridge a section of the haul road linking Namakwa Sands to the port will be relocated onto property owned by Arcelor

contents of the emails were duly noted. They were responded to (three comments above).

The proposed third tippler will be used by Transnet as a backup when one of the existing two tipplers is out of operation for maintenance. No expansion in export of iron ore or export of additional bulk materials will result from the

2, 3 and 4. It recommended that direct interaction between Black Mountain




2. What is being done to improve the current system of export of bulk

commodities other than iron ore in order to ieffectiveness and costing structures? The use of 100T wagons and effective port offof other products.

3. What facilities are available to import 310 000T of coal per annum into

Saldanha and transport via rail line to the Loop 10 siding owned by Black Mountain Mining?

4. Can a rail link between Aggeneys and Loop 10/ Halfweg be constructed to facilitate effective transport of material to stimulate economic investment and job creation in

5. What impact will this development have on the current port operations

as regards to export of other bulk cargo?

20 30 July 2013 Elmien de Bruyn Replacement of Duferco bridge must avoid public roads because the high loads are not allowed on public roads. Road turns must allow for gecurves for the large truck

20 29 August 2013

Elmien de Bruyn – Duferco Steel Processing

According to the drawings reflected in the DBAR the proposed new Duferco Bridge joins up with the public road transport cost to Duferco due to the maximum load per vehicle allowed on a public road. Duferco strongly objects to any linkage with public roads and are hereby requesting that alternative locations for the new bridge be investigated to ensure that the new bridge link up wand not the public road. If the haul road is to be reproperties, the necessary negotiations to obtain permission for the construction and use of the new haul road must form part of the project and be for the responsibility and cost of the project and not of Duferco; The new bridge must be designed taking into account the heavier loads transported to and from Duferco; Duferco will not be responsible for any cost implications relating to the new bridge and/or infrastructure to link up with the existing haul road; The existing bridge must only be demolished after the new bridge is operational.




25

What is being done to improve the current system of export of bulk commodities other than iron ore in order to improve shipping effectiveness and costing structures? The use of 100T wagons and effective port off-loading tipplers as per iron ore, will reduce freight costs of other products.

What facilities are available to import 310 000T of coal per annum into danha and transport via rail line to the Loop 10 siding owned by

Black Mountain Mining? Can a rail link between Aggeneys and Loop 10/ Halfweg be constructed to facilitate effective transport of material to stimulate economic investment and job creation in the Northern Cape?

What impact will this development have on the current port operations as regards to export of other bulk cargo?

Mining and Transnet is sought as regards the questions posed in points 2 to 4. The EAP is not mandated to advise on these mattersGIBB's mandate. 5. The construction of a third tippler is not anticipated to impact on current port operations as it will be located 1.

Duferco bridge must avoid public roads because the high loads are not allowed on public roads. Road turns must allow for gentle

large trucks used by Duferco.

The requirements by Duferco for a private haul road and bridge were noted. The upcoming detail design by the appointed consulting engineers will respond to the extra heavy loads carried by the trucks and their turning circle space requirements

According to the drawings reflected in the DBAR the proposed new Duferco Bridge joins up with the public road - this would result in a huge increase in

Duferco due to the maximum load per vehicle allowed on a public road. Duferco strongly objects to any linkage with public roads and are hereby requesting that alternative locations for the new bridge be investigated to ensure that the new bridge link up with the existing haul road and not the public road. If the haul road is to be re-routed across other properties, the necessary negotiations to obtain permission for the construction and use of the new haul road must form part of the project and

responsibility and cost of the project and not of Duferco;

The new bridge must be designed taking into account the heavier loads transported to and from Duferco;

will not be responsible for any cost implications relating to the new bridge and/or infrastructure to link up with the existing haul road;

The existing bridge must only be demolished after the new bridge is

The concerns of Duferco Steel Procbetween ArcelorMittal and their plant. The final transport road design has not been complete and Duferco's needs will be accommodated by Transnet. There is no intention to join the new bridge with a public road.

Mining and Transnet is sought as regards the questions posed in points 2 to 4. The EAP is not mandated to advise on these matters; they are outside

5. The construction of a third tippler is not anticipated to impact on current t operations as it will be located 1.5 km north of the port.

The requirements by Duferco for a private haul road and bridge were noted. The upcoming detail design by the appointed consulting engineers will respond to the extra heavy loads carried by the trucks and their turning circle

The concerns of Duferco Steel Processing regarding the transport of steel between ArcelorMittal and their plant. The final transport road design has not been complete and Duferco's needs will be accommodated by Transnet. There is no intention to join the new bridge with a public road.




06 21 June 2013 Alana Duffell-Canham Cape Nature

The site for the proposed tippler was historically covered by Saldanha Flats Strandveld. Although the tippler site has been largely transformed, natural vegetation could still be impacted on by the associated infrastructure and services that will be required and thistypes such as Saldanha



• Potential negative impact on living biota in the affected area

06 26 July 2013 Alana Duffell-Canham

Cape Nature would like to thank you for the opportunity to comment on this proposed activity and wish to make the following comments:

1. The site for the proposed tippler and associated infrastructure appears to be covered by Saldanha Flats Strandveld. Although the List of Threatened Ecosystems published at the end of 2011 under the National Environmental Management: Biodiversity Act (NEMBactually lists Saldanha Flats Strandveld as Vulnerable (and no longer Endangered as listed by the South African vegetation map) CapeNature has recently undertaken to reinvestigate the remaining extent of these vegetation types. It was found that Saldanh36% of its original extent remaining as Endangered in terms of Section 52 of the Biodiversity Act.

2. Although the tippler site has been largely degraded and lies between a road and railwawhat other areas (location and size) will be affected by activities such as the relocation of the bridge as well as the condition of the vegetation on these sites. Site offices, laydown areas, storage demolition etc. all need to be identified and indicated as part of the EIA process along with photographs and a detailed description of all sites (not just the tippler alternatives) to be affected by this proposed development.

CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received.




26

Ecological Considerations

The site for the proposed tippler was historically covered by Saldanha Flats

Although the tippler site has been largely transformed, natural vegetation impacted on by the associated infrastructure and services that

will be required and this should be taken into consideration. Other vegetation types such as Saldanha Limestone Strandveld may also be impacted.

The EAP is aware of the conservation implicationvegetation on site has been assessed and mitigation measures have been provided, such as the rescue of plants of conservation concern prior to construction.


Potential negative impact on living biota in the affected area

The EAP is aware of the conservation implications of this development. The vegetation on site has been assessed and mitigation measures have provided.

Nature would like to thank you for the opportunity to comment on this proposed activity and wish to make the following comments:

The site for the proposed tippler and associated infrastructure appears to be covered by Saldanha Flats Strandveld. Although the List of Threatened Ecosystems published at the end of 2011 under the National Environmental Management: Biodiversity Act (NEMBA) actually lists Saldanha Flats Strandveld as Vulnerable (and no longer Endangered as listed by the South African vegetation map) CapeNature has recently undertaken to reinvestigate the remaining extent of these vegetation types. It was found that Saldanha Flats Strandveld only has 36% of its original extent remaining – it thus meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act.

Although the tippler site has been largely degraded and lies between a road and railway, it is unclear from the information provided exactly what other areas (location and size) will be affected by activities such as the relocation of the bridge as well as the condition of the vegetation on these sites. Site offices, laydown areas, storage areas for rubble after demolition etc. all need to be identified and indicated as part of the EIA process along with photographs and a detailed description of all sites (not just the tippler alternatives) to be affected by this proposed development.

Nature reserves the right to revise initial comments and request further information based on any additional information that may be received.

1. The Basic Assessment Report has been updated with the findings of

CapeNature’s assessment of Saldanha Flats Stran

the conservation status and updating the percentage of the remaining

extent (Section 9D).

2. Areas of intact vegetation on site and within the surrounding areas

have been designated as no

map showing designated no

The EAP is aware of the conservation implications of this development. The vegetation on site has been assessed and mitigation measures have been

, such as the rescue of plants of conservation concern prior to


The Basic Assessment Report has been updated with the findings of

CapeNature’s assessment of Saldanha Flats Strandveld by amending

the conservation status and updating the percentage of the remaining

Areas of intact vegetation on site and within the surrounding areas

have been designated as no-go areas. Refer to Appendix A4 for a

g designated no-go areas.




30 29 August 2013

Carolyn Ah Shene-Verdoorn Policy & Advocacy Manager BirdLife South Africa

BirdLife South Africa would like to provide comments on the abovementioned development application and specifically the Draft Basic Assessment Report.development in this municipal region, and in particular the need focreation within the region. However BirdLife South Africa supports sustainable development which will not jeopardise the longenvironment and socio BirdLife South Africa also recognises that this region has been identified as part of the Saldanha Industrial Development Zone and the export of Iron Ore is a vital income earning activity for the country. However there are concerns regarding this development whicEnvironmental Impact Assessment and the associated Environmental Management Plan. The reasons for BirdLife South Africa’s concern regarding this application include: • The presence of threatened vegetation types and a CritiBiodiversity Area as outlined in the Draft Basic Assessment Report. The presence of the endangered Saldanha Flats Strandveld is cause for concern since this vegetation type is not well protected, and construction activities would no doubt impact negatiare located within this vegetation type (Page 5 Impact Assessment Report). • In addition the 11Saldanha Limestone Strandveld is further cause for concern andfurther loss to biodiversity. • Due to the fact that “construction activities may result in damage to or the destruction of endangered vegetation types” (Page 5 Impact Assessment Report Appendix F) BirdLife South Africa would support the preferred alternative (Alternative 1), as this has the lowest impact on the vegetation. The site is located to the north of the global Important Bird and Biodiversity Area SA 105; West Coast National Park and Saldanha Bay Islands. The Langebaan Lagoon andfor a number of different bird species including threatened, endemic and significant congregatory populations. The threatened species include Greater and Lesser Flamingo, Africanand Black Harrier




27

South Africa would like to provide comments on the abovementioned development application and specifically the Draft Basic Assessment Report. BirdLife South Africa recognises the need for development in this municipal region, and in particular the need for job creation within the region. However BirdLife South Africa supports sustainable development which will not jeopardise the long-term future of the environment and socio-economic conditions of this area.

South Africa also recognises that this region has been identified as part of the Saldanha Industrial Development Zone and the export of Iron Ore is a vital income earning activity for the country. However there are concerns regarding this development which should be addressed in a full Environmental Impact Assessment and the associated Environmental Management Plan. The reasons for BirdLife South Africa’s concern regarding this application include:

The presence of threatened vegetation types and a Critical Biodiversity Area as outlined in the Draft Basic Assessment Report. The presence of the endangered Saldanha Flats Strandveld is cause for concern since this vegetation type is not well protected, and construction activities would no doubt impact negatively on the vegetation, as all tippler alternatives are located within this vegetation type (Page 5 Impact Assessment Report).

In addition the 11 kV powerline location within the endangered Saldanha Limestone Strandveld is further cause for concern and results in a further loss to biodiversity.

Due to the fact that “construction activities may result in damage to or the destruction of endangered vegetation types” (Page 5 Impact Assessment Report Appendix F) BirdLife South Africa would support the

eferred alternative (Alternative 1), as this has the lowest impact on the

The site is located to the north of the global Important Bird and Biodiversity Area SA 105; West Coast National Park and Saldanha Bay Islands. The Langebaan Lagoon and the Saldanha Bay Islands provide important habitat for a number of different bird species including threatened, endemic and significant congregatory populations.

The threatened species include Greater and Lesser Flamingo, African-Marsh and Black Harrier and Caspian Tern, among others. The Important Bird and

BirdLife's stance on the socioacknowledged, as is their support fprinciples are entrenched in the National Environmental Management Act (NEMA), and through it to the Environmental Impact Regulations by which this Basic Assessment is covered. The EAP is aware of the conservation implvegetation on site has been assessed and mitigation measures have been provided. It is noted that BirdLife South Africa would support the preferred alternative (Alternative 1), as this has the lowest impact on the vegetat The regional conservation context, including Langebaan Lagoon, is acknowledged. It must be stressed that the preferred position of the third tippler is approximately 1.4 km inland from the base of the finger jettyfrom the edge of the Langebaan Lagoonthe port, this one is probably the farthest removed from the edge of the water. The rejected location alternatives 2 and 3 as described in the BAssessment Report (BAR), would have been positioned muwater.

BirdLife's stance on the socio-economic aspects of the proposed project is acknowledged, as is their support for sustainable development. The same principles are entrenched in the National Environmental Management Act (NEMA), and through it to the Environmental Impact Regulations by which this Basic Assessment is covered.


BirdLife South Africa would support the preferred alternative (Alternative 1), as this has the lowest impact on the vegetation.

regional conservation context, including Langebaan Lagoon, is

that the preferred position of the third tippler is km inland from the base of the finger jetty, and hence

Langebaan Lagoon. Of the various functional units of the port, this one is probably the farthest removed from the edge of the

The rejected location alternatives 2 and 3 as described in the Basic , would have been positioned much closer to the




Biodiversity Area hosts up to 15 different species in significant numbers (greater than 0.5% of the total biogeographic population of that species). A full list of these species can be made availablmigratory birds who travel from Europe to overprotection and conservation of these species is therefore not only a national issue, but of global importance and reon various multiMigratoryWaterbird Agreement. In addition this site is a designated Ramsar site, and thus is considered to be a wetland of international significance. South Africa as a signatory to Ramsar convention has a responsibility to provide for the conservation and wise-use of such wetlands. The proximity of the development to the Important Bird and Biodiversity Area and Ramsar site is not recognised in the Draft Basic Assessment Report BirdLife South Africa would therefore request that full consideration of the impact on these be given in the Environmental Impact Assessment.

31 29 August 2013

Jacques vd Merwe - Conservation Manager: Cape West Coast Biosphere reserve WCBR

The Cape West Coast Biosphere Reserve (CWCBR), of the UNESCO: Man and Biosphere Programme, aims to implementing sustainable principles along the West Coast, in addition to integrating rapidbiodiversity and heritage conservation. The CWCBR extends from the Diep River in the south to the Berg River in the north and inland to Malmesbury and therefore the pthis regard, the CWCBR would like to comment as follows: Biodiversity and Ecology- The development layout must be determined by the environmental sensitivity of the site. Buffer zones must be provided around areas identified as high conservation value to buffer against edge effects. The delineation of the areas of high conservation value must be undertaken by the botanical specialist.- All listed alien plants must be removed from the property in accordance with the Conservation of Agricultural Resources Act (CARA) (Act 43 of 1983). - Roads going through natural vegetation cannot be used and no construction of new roads is allowed passing through the natural vegetation Planning




28

Biodiversity Area hosts up to 15 different species in significant numbers (greater than 0.5% of the total biogeographic population of that species).

A full list of these species can be made available. Many of these species are migratory birds who travel from Europe to over-winter in South Africa. The protection and conservation of these species is therefore not only a national issue, but of global importance and re-iterated by South Africa’s involvement on various multi-lateral treaties specifically the African-Eurasian MigratoryWaterbird Agreement.

In addition this site is a designated Ramsar site, and thus is considered to be a wetland of international significance. South Africa as a signatory to the Ramsar convention has a responsibility to provide for the conservation and

use of such wetlands.

The proximity of the development to the Important Bird and Biodiversity Area and Ramsar site is not recognised in the Draft Basic Assessment Report and BirdLife South Africa would therefore request that full consideration of the impact on these be given in the Environmental Impact Assessment.

The Cape West Coast Biosphere Reserve (CWCBR), of the UNESCO: Man and Biosphere Programme, aims to implementing sustainable development principles along the West Coast, in addition to integrating rapid growth with biodiversity and heritage conservation. The CWCBR extends from the Diep River in the south to the Berg River in the north and inland to Malmesbury and therefore the proposed development is located within the CWCBR. In this regard, the CWCBR would like to comment as follows:

Biodiversity and Ecology The development layout must be determined by the

environmental sensitivity of the site. Buffer zones must be provided for around areas identified as high conservation value to buffer against edge effects. The delineation of the areas of high conservation value must be undertaken by the botanical specialist.

All listed alien plants must be removed from the property in cordance with the Conservation of Agricultural Resources Act (CARA) (Act

Roads going through natural vegetation cannot be used and no construction of new roads is allowed passing through the natural vegetation

As is described in the relevant sections of the B(BAR) (Sections 2A), location alternatives for the third tippler were evaluated against environmental sensitivity constraints. alternative is positioned such that it has section of vegetation to be cleared is not part of a continuous patch of vegetation, but isolated by linear features, namely the rail lines and conveyor belts. The EAP has a BSc (Hons) in botany titles. The need for alien eradication is specifically referred to in the accompanying Environmental Management Programme (EMPr).

As is described in the relevant sections of the Basic Assessment Report , location alternatives for the third tippler were evaluated

against environmental sensitivity constraints. In this respect, the preferred such that it has a low impact on the vegetation. The

section of vegetation to be cleared is not part of a continuous patch of vegetation, but isolated by linear features, namely the rail lines and

in botany qualification amongst other academic

The need for alien eradication is specifically referred to in the accompanying Environmental Management Programme (EMPr).




- The proposed development frameworks and other municipal and provincial spatial planning and zoning schemes. Motivation must be provided for any deviation from these planning frameworks. Industrial developments must be located in areas zoned for industry.- Green Technology- The Basic Assessment report must detail a cradle to grave approach with regard to making use of green technology and greening principles. This entails employing the aboveaspects and all phases of the development, starting from the sourcing of the products until the exit of the manufactured product. Therefore in the Final Basic Assessment report it must be detailed how environmentally friendly principles have been applied to the follow• The raw materials sourced that are used at any stage of the process (including credentials of suppliers)• Transportation (including vehicle emissions and damage to roads from heavy-duty trucks)• Construction of any buildings or st• All processes required for the manufacture of products• Use of alternative technologies as opposed to placing further burden on the provision of bulk services• Waste production and removal (including the endmaterials) • Contribnational bulk infrastructure where alternative technologies are not possible.• Specialist studies must be undertaken and included in the Final Basic Assessment Report on the impact of air, noise, surfgroundwater, smell and visual pollution.• Contributions by the company to environmental and social programmes. Socio-Economic Development- The project must make use of local labour. Statistics of the origin of labour used in both constructionmonthly basis at the Environmental Monitoring Committee (EMC) meetings and/or to the Environmental Control Officer (ECO).- Potential contributions by the company to social and economic upliftment should be detailed in - Potential contributions to local gross domestic product (GDP) and




29

The proposed development must comply with spatial development frameworks and other municipal and provincial spatial planning and zoning schemes. Motivation must be provided for any deviation from these planning frameworks. Industrial developments must be located in

as zoned for industry.

Green Technology The Basic Assessment report must detail a cradle to grave

approach with regard to making use of green technology and greening principles. This entails employing the above-mentioned principles in all

all phases of the development, starting from the sourcing of the products until the exit of the manufactured product. Therefore in the Final Basic Assessment report it must be detailed how environmentally friendly principles have been applied to the following (amongst others):

The raw materials sourced that are used at any stage of the process (including credentials of suppliers)

Transportation (including vehicle emissions and damage to roads duty trucks)

Construction of any buildings or structures All processes required for the manufacture of products Use of alternative technologies as opposed to placing further

burden on the provision of bulk services Waste production and removal (including the end-point of waste

Contributions by the company to upgrading of municipal and/or national bulk infrastructure where alternative technologies are not possible.

Specialist studies must be undertaken and included in the Final Basic Assessment Report on the impact of air, noise, surface water, groundwater, smell and visual pollution.

Contributions by the company to environmental and social

Economic Development The project must make use of local labour. Statistics of the origin

of labour used in both construction and operation must be reported on a monthly basis at the Environmental Monitoring Committee (EMC) meetings and/or to the Environmental Control Officer (ECO).

Potential contributions by the company to social and economic upliftment should be detailed in the Final Basic Assessment Report

Potential contributions to local gross domestic product (GDP) and

The actual construction footprint of Tippler 3 and its associated infrastructure is largely governed by engineering constraints. Rail tracks can only have gentle curves, so motor vehicle roads have limited options for routing. The EMPr contains the provisiendemic or endangered species prior to site clearance must be carried out. The proposed development will take place on land zoned for the use. Transnet is a state-owned company and as such follows the procuremepolicies prescribed by the stateTransnet participates in government's Competitive Supplier Development Programme which involves procuring in such a way as to increase the competitiveness and capacity of the lore facility at the Port of Saldanha is contributing substantially to the development of the local economy in the area by providing jobs, the training of technical qualified people and direct investment into service As a state owned company Transnet is also bound by the environmental policy of the South African government, which is expressed in the National Environmental Management Act and associated regulations. the procedures set in the Environmentand other applicable legislation, the EAP is ensuring that the proposed project is socially, environmentally and economically sustainable. By following the set procedures,placed at the forefront of concern, and their physical, psychological, developmental, cultural and social interests are equitably served. This Basic Assessment has drawn on the results from several specialist studies, including those mentioned by Mr v Temporary jobs may be created during the construction phase. These jobs will be a combination of skilled, semilabour for the Tippler 3 construction will follow Transnet's labour policy, which is set by standards applicable nation

The actual construction footprint of Tippler 3 and its associated infrastructure is largely governed by engineering constraints. Rail tracks can only have gentle curves, so motor vehicle roads have limited options for routing. The EMPr contains the provision that search and rescue of rare, endemic or endangered species prior to site clearance must be carried out.

The proposed development will take place on land zoned for the intended

owned company and as such follows the procurement policies prescribed by the state, here the Department of Public Enterprises. Transnet participates in government's Competitive Supplier Development Programme which involves procuring in such a way as to increase the competitiveness and capacity of the local supply base. As it stands, the iron ore facility at the Port of Saldanha is contributing substantially to the development of the local economy in the area by providing jobs, the training of technical qualified people and direct investment into services.

As a state owned company Transnet is also bound by the environmental policy of the South African government, which is expressed in the National Environmental Management Act and associated regulations. By following

Environmental Impact Assessment Regulations and other applicable legislation, the EAP is ensuring that the proposed project is socially, environmentally and economically sustainable. By

, the interest of people and their needs are t the forefront of concern, and their physical, psychological,

developmental, cultural and social interests are equitably served.

This Basic Assessment has drawn on the results from several specialist studies, including those mentioned by Mr van der Merwe.

Temporary jobs may be created during the construction phase. These jobs will be a combination of skilled, semi-skilled and unskilled. The sourcing of labour for the Tippler 3 construction will follow Transnet's labour policy, which is set by standards applicable nation-wide.




total jobs created should be detailed in the report. Tourism - The West Coast has been identified as an area that has high potential for economic growthThese sectors are however not always compatible. A specialist impact assessment must be undertaken on the impact of the development on tourism. Monitoring - An independent Environmental Control Officer (ECOappointed to oversee the construction phase and operational phase of the development. Monitoring must be according to the approved Environmental Management Plan (EMP) and monthly reports must be submitted by the ECO indicating compliance or non- An Environmental Monitoring Committee (EMC) must be established that includes representatives of the developers, DEA&DP, the ECO and civil society. The EMC should meet on a monthly basis and the ECO must present the monthly report. The EMC shothe operational phase of the development.- A monitoring programme must be established to determine the potential increase of pollutants emitted by the proposed development. This must include baseline data from prior to the initiati- A search and rescue programme for fauna and flora must be undertaken prior to any clearing of vegetation. The specimens must be relocated to the natural area within or adjacent to the development. Search and rescue specimens must be trasurvival. Membership of the Cape West Coast Biosphere Reserve- GIBB Pty Ltd is hereby encouraged to become members of the CWCBR whereby a mutually beneficial relationship can be formed. The Cape West Coast Biosphercomment as additional information regarding the development in question becomes available. The Cape West Coast Biosphere Reserve withholds the right to submit further comment as additional information regardidevelopment in question becomes available.

32 29 August 2013

Ms. C. George 1. The Cohas the following comment.




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total jobs created should be detailed in the report.

The West Coast has been identified as an area that has high potential for economic growth in both the industrial and the tourism sectors. These sectors are however not always compatible. A specialist impact assessment must be undertaken on the impact of the development on

An independent Environmental Control Officer (ECO) must be appointed to oversee the construction phase and operational phase of the development. Monitoring must be according to the approved Environmental Management Plan (EMP) and monthly reports must be submitted by the ECO indicating compliance or non-compliance.

An Environmental Monitoring Committee (EMC) must be established that includes representatives of the developers, DEA&DP, the ECO and civil society. The EMC should meet on a monthly basis and the ECO must present the monthly report. The EMC should continue through to the operational phase of the development.

A monitoring programme must be established to determine the potential increase of pollutants emitted by the proposed development. This must include baseline data from prior to the initiation of operations.

A search and rescue programme for fauna and flora must be undertaken prior to any clearing of vegetation. The specimens must be relocated to the natural area within or adjacent to the development. Search and rescue specimens must be transplanted as soon as possible to ensure

Membership of the Cape West Coast Biosphere Reserve GIBB Pty Ltd is hereby encouraged to become members of the

CWCBR whereby a mutually beneficial relationship can be formed. The Cape West Coast Biosphere Reserve withholds the right to submit further comment as additional information regarding the development in question becomes available. The Cape West Coast Biosphere Reserve withholds the right to submit further comment as additional information regarding the development in question becomes available.

Tippler 3 needs to be built because the two existing tipplers will have to undergo refurbishment in a phased manner. There will be no increase in the export of iron ore. Overall, there will be no change to the present situation, and hence there is no need to investigate tourism impacts through dedicated specialist studies. The BAR and EMPr makes provisioEnvironmental Control Officersearch and rescue of species of conservation concern is stipulated. GIBB (Pty) Ltd is an independent engineering and science company that does not engage in environmental advocacy.

oastal Management Unit (CMU) has reviewed the BAR and has the following comment.

Tippler 3 needs to be built because the two existing tipplers will have to phased manner. There will be no increase in the

export of iron ore. Overall, there will be no change to the present situation, and hence there is no need to investigate tourism impacts through

The BAR and EMPr makes provision for the appointment of an Environmental Control Officer. Likewise, a monitoring programme and the search and rescue of species of conservation concern is stipulated.

GIBB (Pty) Ltd is an independent engineering and science company that does not engage in environmental advocacy.




1.1 The CMU does not support Site Alternative 3,alternative involves excavating into the edge of a 20vegetated dune. This excavation will destroy part of the sensitive dune ecosystem and can cause further destabilisation of the dine belt which forms an integral part in the protection of cinundation and storm surge.

1.2 It is imperative that the dust impact be strictly managed by the adhering to the mitigation measures outlined in the EMP and the standards set in the Air Emissions License.

1.3 Furthermore, the pnoise on or emanating from the site “should be increased. A suggestion would be to increase the penalty to the same value as that of “

2. The CMU takes cognisance that further authorismay be required. Please note that due to the nature of the proposed development, the CMU may provide further information in respect of those applications.

The CMU reserves the right to revise or withdraw comments or request further information based on any information received.



• Modifications to geological features

• Disturbance of potential palaeontological deposits

16 15 July 2013 Troy Smuts, Heritage Officer, Heritage Western Cape

Heritage Western Cape requires a Notification of Intent to Develop (NID) to be submitted regarding the proposed Transnet SOC Ltd expantion of the iron ore tippler facility in the Port of Saldanha, as required by Section 38 of the National Heritage Resource




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The CMU does not support Site Alternative 3, this alternative involves excavating into the edge of a 20 m high, vegetated dune. This excavation will destroy part of the sensitive dune ecosystem and can cause further destabilisation of the dine belt which forms an integral part in the protection of coastal properties/development from inundation and storm surge. It is imperative that the dust impact be strictly managed by the adhering to the mitigation measures outlined in the EMP and the standards set in the Air Emissions License. Furthermore, the penalties relating to the Dust “or excess noise on or emanating from the site “should be increased. A suggestion would be to increase the penalty to the same value as that of “polluting natural water bodies”.

The CMU takes cognisance that further authorisations/permits may be required. Please note that due to the nature of the proposed development, the CMU may provide further information in respect of those applications.

The CMU reserves the right to revise or withdraw comments or request ion based on any information received.

The rejection of Alternative 3 is noted. Adherence to air quality standards through the application of effective mitigation measures is supported by the EAP. The suggested draft penalty amounts will be authority for decision-making and adjustment if needed.

Heritage Issues


Modifications to geological features

Disturbance of potential palaeontological deposits

Construction work for the Tippler 3 is not expected to modify geological features of note if the preferred alternative (alternative 1) as described in the Basic Assessment Report is selected. The footprint of Tippler 3 has been cleared previously for construction purposes when the port was builtresources remain to present on the surface. Allowance is made in the EMPr for the correct handling of paconstruction activities.

Heritage Western Cape requires a Notification of Intent to Develop (NID) to be submitted regarding the proposed Transnet SOC Ltd expantion of the iron ore tippler facility in the Port of Saldanha, as required by Section 38 of the National Heritage Resource Act (Act 25 of 1999). If this form has not already

A Notification of Intent to Develop has been submitted to Heritage Western Cape, who have responded and acknowledged receipt

ction of Alternative 3 is noted.

Adherence to air quality standards through the application of effective mitigation measures is supported by the EAP.

The suggested draft penalty amounts will be submitted to the competent making and adjustment if needed.

Construction work for the Tippler 3 is not expected to modify geological features of note if the preferred alternative (alternative 1) as described in the Basic Assessment Report is selected.

The footprint of Tippler 3 has been cleared previously for construction ort was built in the 1970s. It is unlikely that any heritage

resources remain to present on the surface. Allowance is made in the EMPr for the correct handling of paleontological resources if uncovered during

otification of Intent to Develop has been submitted to Heritage Western , who have responded and acknowledged receipt.




been submitted, please complete and submit the attached NID form and checklist, and send through one hardcopy and one digital copy (on a CD) along with any associated documentation to the HWC offices.

16 21 August 2013

Troy Smuts, Heritage Western Cape

Your NID dated 8 August 2013 was Tabled and the following was discussed:

1. The proposal is to construct an additional tippler2. The new tippler building will be a steel superstructure with

galvanized and painted steel sheet covers/cladding, windows and doors including the brick and concrete control room.

3. It will house two cranes of 20rails. The proposed new conveyor tunnel is expected to be approximately 160 m long.

4. Palaeontological and archaeological resources of the Langebaan area is well known for its rich heritage resources.

5. The footprint of construction purposes when the Port was built.

Decision:

1. Heritage Western Cape has no objection to the development proceedings.

2. Palaeontological monitoring of all bulk earth works is required and a report submittethe structure is required.

11 05 July 2013 Pieter Stegmann The RO Desalination plant is not operational since 1 May 2011 due to "technical problems" a senior Transnet official told the Weslander. Transnet cannot take the risk to pour 43 tons of waste the end of the pier) in response t

18 16 July 2013 H.S.C Steenkamp Pyplyne kruis my plaas + Eskom lyne + paaie + paaie.

- Die Sishen spoorlyne Kruis my grond- Bly tans op Saldanha sit en kyk hoe julle ert laai- Is 54 jaar in die boerdery




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been submitted, please complete and submit the attached NID form and checklist, and send through one hardcopy and one digital copy (on a CD) along with any associated documentation to the HWC offices.

Your NID dated 8 August 2013 was Tabled and the following was discussed:

proposal is to construct an additional tippler The new tippler building will be a steel superstructure with galvanized and painted steel sheet covers/cladding, windows and doors including the brick and concrete control room. It will house two cranes of 20 ton lifting capacity, including their rails. The proposed new conveyor tunnel is expected to be approximately 160 m long. Palaeontological and archaeological resources of the Langebaan area is well known for its rich heritage resources. The footprint of tippler 3 has been cleared previously for construction purposes when the Port was built.

Heritage Western Cape has no objection to the development proceedings. Palaeontological monitoring of all bulk earth works is required and a report submitted to HWC for comment prior to construction of the structure is required.

The contents of your letter have been noted. The EMPhas been updated to reflect the need to conduct palaeontologicalof bulk earthworks during construction, as well as preparation of a report to HWC of any palaeontological fossils that may have been unearthed.

Desalination Plant

The RO Desalination plant is not operational since 1 May 2011 due to "technical problems" a senior Transnet official told the Weslander. Transnet cannot take the risk to pour 43 tons of waste per month into the lagoon (at the end of the pier) in response to my Report 2 dated 11 April 2011.

The EAP for the Tippler 3 Basic Assessment Report desalination plant is inoperative.

Impact on Surrounding Land Uses

Pyplyne kruis my plaas + Eskom lyne + paaie + Provinsiale + Streeksdiens

Die Sishen spoorlyne Kruis my grond Bly tans op Saldanha sit en kyk hoe julle ert laai Is 54 jaar in die boerdery

The contents of your letter have been noted. The EMPr for the Tippler BAR has been updated to reflect the need to conduct palaeontological monitoring of bulk earthworks during construction, as well as preparation of a report to HWC of any palaeontological fossils that may have been unearthed.

The EAP for the Tippler 3 Basic Assessment Report cannot confirm that the desalination plant is inoperative.




- Betrokke in granite klip - Is ook betrokke by hernubare energie- Het my eerste gronde in 1959 gekoop- Boer me

English TranslationPipelines, Eskom lines, and provincial and secondary roads cross my land.

- The Sishen Railway intersects my land- I currently live in Saldanha and observe how you load iron ore- I’ve been involved with farming for 54 years- Involved in granite mining- Involved in renewable energy- I purchase my first piece of land in 1959- I farm sheep, dairy cattle and ostriches,

21 30 July 2013 Alan Carnegie I am a retired civil engineer and have had my home base in Saldanhathe 1960s. Initially the dust from the Iron ore terminal was not a problem because there was very little industrial or residential growth. These days the iron ore dust has become a serious problem affecting both industrial and residential growth. I Saldanha. I urgently appeal to you to consider building this tippler at Bruinpunt . This is where the SaldanhaModern design techniques have demonstrated that it is pviable ore terminals in open seas conditions. Sheltered water space is created by means of an offshore detached breakwater. Assuming it is still the intention to significantly increase the export tonnage, and then it would make sense to exterminal at Bruinpunt. Some of the advantages of such a terminal are as follows:

1. The turnaround time back to Sishen would reduce dramatically because the whole train could be fed by the tippler vIn Saldanha the thalves which is most time consuming.

2. There is a saving of 16% on rail haulage. 3. The above efficiencies should postpone the day when it becomes

necessary to double up on the Sis4. I have sounded out the residents in Strandfontein and Doringbaai.

The reaction in such an ore terminal on their doorstep was mostly




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Betrokke in granite klip Is ook betrokke by hernubare energie Het my eerste gronde in 1959 gekoop Boer met skape + beeste melk en vleis bees + Koring + volstryse

English Translation: Pipelines, Eskom lines, and provincial and secondary roads cross my land.

The Sishen Railway intersects my land I currently live in Saldanha and observe how you load iron ore I’ve been involved with farming for 54 years Involved in granite mining Involved in renewable energy I purchase my first piece of land in 1959 I farm sheep, dairy cattle and ostriches,

The proposed tippler 3 will be located in an industrial areafarming activities. This Basic Assessment does not address the capacity upgrade of the Sishen – Saldanha railway. If and when this is considered by Transnet you will automatically be added to the interested and affected party databasereceive notification for the proposed

Project Alternatives

m a retired civil engineer and have had my home base in Saldanha since the 1960s. Initially the dust from the Iron ore terminal was not a problem because there was very little industrial or residential growth. These days the iron ore dust has become a serious problem affecting both industrial and residential growth. I see that it is your intention to build a third tippler in Saldanha. I urgently appeal to you to consider building this tippler at

ruinpunt . This is where the Saldanha - Sishen track joins the coast. echniques have demonstrated that it is possible to build

viable ore terminals in open seas conditions. Sheltered water space is created by means of an offshore detached breakwater. Assuming it is still the intention to significantly increase the export tonnage, and then it would make sense to export the additional tonnage through a new state-of-the-art terminal at Bruinpunt. Some of the advantages of such a terminal are as

The turnaround time back to Sishen would reduce dramatically because the whole train could be fed by the tippler via a "balloon". In Saldanha the train has to be fed through the tippler in two halves which is most time consuming.

here is a saving of 16% on rail haulage. The above efficiencies should postpone the day when it becomes necessary to double up on the Sishen track. I have sounded out the residents in Strandfontein and Doringbaai. The reaction in such an ore terminal on their doorstep was mostly

The suggestion made by Mr Carnegie goes far bealternative for the proposed third tippler as it involves the construction of a second iron ore export terminal further north and approximately 120 km distant from Saldanha. The detailed evaluation of such a proposal is not within the brief given to GIBB by Transnet for the Basic Assessment for the installation of a third tippler.

The proposed tippler 3 will be located in an industrial area so will not impact

This Basic Assessment does not address the capacity upgrade of the Sishen Saldanha railway. If and when this is considered by Transnet you will

automatically be added to the interested and affected party database and proposed project.

The suggestion made by Mr Carnegie goes far beyond a simple locality alternative for the proposed third tippler as it involves the construction of a second iron ore export terminal further north and approximately 120 km distant from Saldanha. The detailed evaluation of such a proposal is not

e brief given to GIBB by Transnet for the Basic Assessment for the




positive. The iron ore stockpiles could be located in the cleft left behind after the breakwater rock has been rshould not be an insurmountable problem like it is in Saldanha.

5. No dredging will be required for Bruinpunt. Additional Saldanha will require dredging. History has shown that Mari culture takes a knock when dredging is required. pleasure to accompany you on a first hand site visit to the site. I could set up a meeting with the locals and also invite some of our leading coastal engineers to provide the technical details




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positive. The iron ore stockpiles could be located in the cleft left behind after the breakwater rock has been removed. Ore dust should not be an insurmountable problem like it is in Saldanha. No dredging will be required for Bruinpunt. Additional berths in Saldanha will require dredging. History has shown that Mari culture takes a knock when dredging is required. It would be my pleasure to accompany you on a first hand site visit to the site. I could set up a meeting with the locals and also invite some of our leading coastal engineers to provide the technical details.

comments and responses report - gibbprojects.gibb.co.za/portals/3/projects/appendix e3... · 14 12...

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