Dear Sir/Madam, I would like to register as an Interested and Affected Party (IAP) with regards to the proposed mining in the following area: LOCATION: Farm 102 & 106 at Kei Mouth District of Komga, Eastern Cape PROPONENT: Lolo & Lolo Development Services cc Please confirm in writing that I have been registered as an IAP in respect of the proposed mining. Motivations for the objection to the proposed mining on farm 102 and 106 at Kei Mouth District of Komga, Eastern Cape The Scoping Report notes that the IDP of the Great Kei Municipality (GKM) has recognised the need for upgrading of the road network between Kwetyana on the N6 and the Mooiplaas Hotel, at the junction with the N2, and onwards to Kei Mouth, and that the applicant has gained information that these road projects will be underway in the near future and that it would be cheaper to haul rock from Kei Mouth than it would be from East London. It also states that there are no other proven dolerite deposit in the area and it further claims that the stone could be used for upgrades to internal roads and the construction of a new hotel. 1. Kwetyana - Mooiplaas - Kei Mouth road upgrade: The road from the N2 to Kei Mouth was upgraded a little over 10 years ago and is in very good condition, so any future road upgrade on this route would take place at a minimum distance of 42km from here (Mooiplaas), and in the case of Kwetyana that distance would climb to 98km. East London, on the other hand, is 24km by road from Kwetyana and 34km from Mooiplaas. It would therefore be much cheaper to get rock from East London than Kei Mouth for that project, so a supplier in Kei Mouth would not be able to provide stone at competitive prices. Further, if the proponent wishes to use this argument then they must produce proof that the road upgrade is to take place. 2. Alternative site: When the abovementioned tar road from Mooiplaas to Kei Mouth was built, the road builders used rock from a quarry nearby the Gugura Store, a distance of 14km from Kei Mouth (-32.647338, 28.236119), so the assertion that there is no alternative site is misleading. This site would be 14km closer to the Mooiplaas junction than the proposed site in Kei Mouth. We believe the proponent should reopen the quarry instead, as the landowner was obviously willing for it to be used when the road was built. 3. Internal road upgrades: We can find no mention in either the GKM;s 2017 2022 IDP or their 2017/2018 2019/2020 budget that any of our internal roads will be upgraded. If the proponent wishes to use this argument then they must produce proof of when these road upgrades are to take place. 4. Impact on other land users: The Scoping Report claims that the development of a quarry will only have a limited and temporary impact on grazing. The old dolerite quarry inside the proposed mine area is the only permanent water source for the livestock that use farm 102, and according to the report's own estimates, the 4.889 Ha site is capable of providing grazing for 20 units of large livestock. The loss of grazing and in particular, water, will place an enormous strain on the cattle farmer (Mr. Hibana) and Wild Coast Horse Trails, both of whom have been using this land for many years. 1
The mine will also cover the surrounding grass lands with a fine layer of dust, especially after blasting. This will cause health issues to the cattle, horses and other naturally fauna. Equine colic and digestive impaction is lethal and the loss of livestock and indigenous wildlife is not acceptable. Also, if the area is to be fenced off for two years to allow it to rehabilitate after mining ceases, then the other land users could potentially lose out on grazing for up to 7 years. This cannot be described as a temporary impact. Rehabilitation concerns The report says that if rehabilitation efforts are applied correctly then grazing would improve. This may be true in theory, but in practice the proponent has a poor track record of rehabilitating his quarries in the area. E.g. The proponent was issued a permit to mine sand on farm 106 from January 2008 to January 2010, but never rehabilitated the site on completion and it is now a site where the builders of the Cape Morgan Conference Centre have dumped large quantities of rubble and sand. The proponent has also proven not to be a diligent operator and has mined outside the demarked mining area, not followed the Mine Works Plan, nor mined with any duty of care. Not only is that site an eyesore on a hill only 800m from Morgan Bay, and on a road that experiences regular tourist traffic, but the farmers who graze cattle on that land have lost valuable grazing for nearly 10 years as a result of it being unrehabilitated. If the proponent failed to mine diligently and properly rehabilitate a mere sand quarry, then they cannot be trusted to rehabilitate or even operate a Dolerite quarry. Job creation and social impacts We believe that the proponent has already consulted with our local township communities and that they have been promised around 60 mine worker jobs, but we have spoken with an expert in the Dolerite mining industry and he predicts that a quarry of this size will create ten jobs at most, five of which will be for outsiders with skills not found locally (heavy machinery and crushing plant operators etc.). This will have a negative effect on our communities when their expectations are not met and divisions will occur when it is realised that only a select few will benefit. The Scoping Report also says that the mine is expected to operate for between 3-8 months of the year, so any jobs created will not be full-time either. The actual number of jobs created for locals (not outsiders) must be established and reported accurately to our communities. Such misconceptions are common place between a proponent and a community. This has on many occasions, led to extremely hostile and volatile situations developing within the community and mine, often resulting in civil unrest and damage to property. Economic impacts Tourism is a huge employer in Kei Mouth and Morgan Bay. Between our two villages there are two hotels, four bed & breakfasts, four caravan parks, two backpackers and over 110 self catering establishments, and those are just the ones we know of. Together, they directly employ many hundreds of locals in an area with high unemployment. 2
Other businesses that rely on tourism are the Country Club, our two Bowls Clubs, a Horse Trails business, two Township Tours businesses, a Game Reserve just up the road, a Nature Reserve at Double Mouth, the Morganville Motorcycle Museum, the Strandloper Trail, climbing and abseiling in Morgan Bay. Restaurants and Pubs in the area also employ people and our two supermarkets (and their staff) rely on seasonal business to make it through the year. Many construction workers are employed building homes for holidaymakers from upcountry and these holidaymakers employ people to mow their lawns and guard their homes while they are away. In fact, almost every facet of our local economy relies in some way or another, on tourism. Amathole District Municipality's 2016/17 IDP: "There are several distinct tourism clusters that can be identified in the Amathole District namely: Kei Mouth, Butterworth and Hogsback and surrounds. The largest cluster, Butterworth, primarily comprises accommodation establishments and caters for the significant business tourist market that visits the area on a daily basis. The other two clusters Hogsback and surrounds; and Kei Mouth cater almost exclusively to leisure tourists." A large part of the tourism appeal of this area, is the peace and quiet, beautiful country scenery, bird life and rural charm, and we believe that that should be protected, so as to ensure the long-term growth of the tourism industry, so that everyone may reap the rewards. Due to the close proximity to both villages, its location up on a hill, on a road frequented by tourists, and the lack of natural sound or visual barriers, the mining operation will certainly be seen and heard by numerous residents and tourists in the Kei Mouth and Morgan Bay area. The dust will also be spread far and wide by the strong winds which blow through here on a regular basis. Considering all of these facts, we believe that the proposed quarry will harm the tourism potential of the area, thus creating a negative effect on households due to job losses in tourism, local business and construction sectors. We don't believe that the number of jobs the mine creates will go any way toward making up for the number of tourism related jobs which are lost. The mine will also dramatically reduce the value of property and housing in the area. We would therefore ask that the EIA conduct in-depth studies to address the potential impact of the proposed quarry on our tourism based economy. Topography The report states that Impact due to mining is irreversible. This is deplorable in an area where tourism, holiday making and eco trails earn the livelihood of the majority of inhabitants. We wholeheartedly object to a mining operation if it will cause irreversible damage. Water supply concerns It was estimated, by the Dolerite mining consultant we spoke to, that a mine of this size will consume approximately 10 000 to 20 000 litres of water per day during normal operations. This region has been an extremely water stressed area for a number of years and has frequently undergone water restrictions. If the mine is to require water in such quantities to effectively manage and control dust generation, from the crushing operation and haul roads, then it needs to be accurately determined how much water it will need and how this will effect water levels in our dams during dry periods. 3
Impact on roads The access road from the R349 to the proposed site is a 1.5km gravel road. It is in very poor condition and regular use by heavy trucks will only cause it to deteriorate further, especially after rain. It is also very narrow in the middle section, which would make it impossible for a truck and an oncoming vehicle to pass. This road is frequently used by holidaymakers for running, walking, mountain biking, horse riding and dog walking, as it forms a scenic, safe and accessible loop from both Morgan Bay and Kei Mouth. Ecological impacts The proposed site is only 560m away from a Nature Reserve. NEMA sets a buffer zone around protected areas, so it must be established whether the proposed mine is within the buffer zone of the Cape Morgan Nature Reserve. The SANBI Land Use Decision Support (LUDS) map clearly indicates that the farms are in Highest Biodiversity Importance areas and the farms are also situated within an area that has been identified as a Terrestrial Critical Biodiversity Area Level 1 (CBA1) according to the Eastern Cape Biodiversity Conservation Plan - an area required to meet biodiversity targets for ecosystems, species and ecological processes. The scoping report attempts to gloss over the CBA1 rating (page 61), but in light of these facts we request that you undertake specialist studies to ensure that all potential impacts on the ecology of the area be understood and addressed thoroughly, so that the biodiversity of the area is not damaged any further. Future of the site If part of the reasoning for choosing this site, was that previous mining had taken place there, then there is an even greater likelihood that this site will be reopened and expanded in the future, if the proponent is allowed to expand the workings now. Alternative land uses The Scoping Report completely ignores, or is oblivious to the studies that were previously conducted in conjunction with the DEAET to establish a nature reserve on the land where the proposed dolerite mine would be located. The report also states that Conservation will not provide any feasible job opportunities for community members. At this point we want to demonstrate how far from the truth this is. The area between Kei Mouth and Morgan Bay could justifiably be transformed into a nature reserve that would provide more long-term jobs than a mining project which will only offer a maximum of 5 years of employment, for between 3-8 months of each year, and will irrevocably damage the landscape for other land users and residents for generations to come. As evidence of this, an application to create a nature reserve on that land was completed by the Friends of Morgan Bay to the point where only a few minor details were required. The reason it did not proceed was the lack of the appropriate person in the municipality to take authority over the project. 4
From the IDP of the Great Kei Municipality of a few years ago, section 2.3.12 ENVIRONMENT: Associated with this is the proposal by the Friends of Morgan Bay for an extension of the Cape Morgan Reserve by rezoning adjacent commonage in a north westerly direction. This proposal would enable the establishment of a Biosphere Reserve linked to the streams feeding into the Incarha Estuary. A number of benefits would accrue to the community in the form of resource utilisation (grass for building and craft manufacturing) traditional ceremonies, tourism activities, research project, eco-tourism job opportunities, protection of flora and fauna and re-introduction of locally extinct species. To set aside more land for conservation is also in line with national strategy and municipal objectives. The Great Kei Municipal area of 1,421 square kilometres hosts less than half a percent (0.5%) of proclaimed nature reserves. The national target is to have ten percent (10%). Natural beauty is an asset that is the easiest to utilise for fulfilling so many of the Municipality's stated objectives, the highest priority being Poverty Relief through job creation and stimulation of tourism. The Eastern Cape Parks & Tourism Agency stewardship programme, which looks at municipal areas of land that can be conserved to increase biodiversity (an international directive), are presently re-evaluating this proposal. Here follows a summary of the proposal: A Bush Camp Lodge and Resort is one of the proposals in the nature reserve. This could be sustainably utilised to accommodate holidaymakers where locals could be employed for general housekeeping and security as well as cooking and nature walks. It could also be utilised as a tourist accommodation and corporate venue, which could make use of the nearby conference facilities in the Cape Morgan Nature Reserve. The kind of development envisaged is much on the same lines as the Mpekweni Resort near the Fish River. A very quick conservative estimate of the potential job creation that can be expected, initially amounts to 50 permanent appointments for the Bush Camp Resort only. There can also be 17 temporary positions during the Nature Reserve establishment phase, of two years or more. Environmental Education. Taking a holistic view, the establishment of a Nature Reserve could be joined with Cape Morgan Nature Reserve in Eco Education. There are 4 to 6 habitat types and present facilities at Cape Morgan Nature Reserve to support Environmental Education. There is a wealth of local expertise that can provide input to this activity in terms of: Education Management Business Fencing and building The existing traditional family on the property. It would be preferable to develop the potential of the local families who live on the property, rather than stocking stalls or huts with people, as in a zoo. The local families can apply their knowledge in storytelling, sangomas, abakhwetha ceremonies and traditional medicines. A community area can be created for traditional activities and culture providing income to the community. 5
Environmental Education is already taking place and the resident Xhosa family is being visited by Morgan Bay Eco-Trails. A Craft Centre in the nature reserve could be developed in traditional Xhosa style where activities could be practised such as song, dance, poetry and local cooking offered. The huts can be built with local materials such as wattle, daub and grass thatch. This would attract oversees tourists if they could actually stay in the huts and enjoy indigenous traditional meals. The introduction of various types of game would be another tourist attraction. A suggestion is to spread the income generated by annual culling events by offering meat to the community at very reduced prices and plough this back into the reserve for its running costs. Introduction of Endangered/Extinct Animals such as Oribi in the nature reserve would need to be integrated with the total management plan. For greater authenticity, locals would be encouraged to stock with Nguni cattle, these are indigenous and part of the area s history. The well-known Mrs. Ann van Dyk of the dewild cheetah farm north of Tswane has shown a keen interest in establishing some kind of animal rehabilitation centre on the reserve. She however wants to see the reserve established and running effectively before any commitment is undertaken. Guides for walking trails will be trained by Nature Conservation, or by local initiative, that take holidaymakers, visitors and hotel groups on guided tours. A circular route was suggested that could incorporate sections for the spotting of birds, trees, plants, butterflies, forest vegetation, insects and so forth. There could also be a Boma type facility with a fireplace. This activity would be supported by Strandloper Trails and would be used by them. It is suggested that certain access points be provided with boardwalks that are wheelchair and even blind friendly. Paths would be cut in the forest and will be marked. The area lends itself ideally for the establishment of a nursery for indigenous plants (some already in existence) that traditional medicines are made from. A nursery on the reserve could serve to provide the raw ingredients to manufacturers of the medicine and it could be further developed to process the raw ingredients into saleable products for selling at the reserve or to export. Stromatolites. The proposed area for the Nature Reserve has access to a very rare and unique asset that would be of great interest to tourists and the media. This will result in excellent and positive publicity something that will put the Municipality (so to say) on the map with tremendous financial spin-offs. This asset has the potential to take the area to the status of a World Heritage Site. The asset referred to here is Stromatolites. Stromatolites are layered limestone rocks (CaCO 3) formed through the activities of bacteria. They are known from rocks that are 3.5 billion years old. These life forms predate virtually everything else on Earth and are still forming today. Stromatolites are living fossils in the classical sense. The process of stromatolite formation is not simple and not completely understood. They don t look like much but are geologically and biologically very significant and are being studied by Professors Ron Uken and Alan Smith of Natal University. Other examples are found at Shark Bay Western Australia and Chetumal Bay Belize. 6
Conclusion The proponent has a poor track-record with regards to quarry rehabilitation in this area and we don't believe they have given valid or sufficient motivations for opening this quarry, especially when there is another proven deposit with direct tar road access, 14km closer to the N2. This quarry will remove the only permanent water source for the cattle and horses on that property and keep the grazing area fenced off for years to come. A quarry at this location will create noise, dust and an unpleasant environment for locals and tourists, which will have a negative impact on tourism jobs and our local economy. Mine activities will consume large amounts of water in an area with limited supply and mining vehicles will damage the roads. We would much rather see the area conserved so that we can protect the tourism industry, property values and the health and wellbeing of all residents and visitors. A better site must be found for the mine. 7