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Authorisation – Final Scoping Report. Prepared by P. Lee, M.C. Munnik and K. Gerstner of
Umvoto Africa (Pty) Ltd for Robertson Bakstene (Pty) Ltd. Report No. 856/25/02/2017,
March 2017, 103 pp.
Report Status
Report No. Status Reviewed by Date
856/25/02/2017 Final Report K Riemann 18-03-2017
Distribution List
Report No. Status Name Institution Date
856/25/02/2017 Final Loretta Osborne Department of
Environmental Affairs
and Development
Planning
20-03-2017
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TABLE OF CONTENTS
Chapter Description Page
1. INTRODUCTION 12
1.1 Details and Expertise of the Environmental Assessment Practitioner 12
1.2 Contact Information and Location of the Operation 12
1.3 Property Details 12
1.4 History and Background Information of the Brick Making Factory Operation 13
1.5 Purpose of Report 14
1.6 Structure of this Report 15
1.7 Content of Report 16
1.8 Assumptions and Limitations 18
2 GOVERNANCE FRAMEWORK AND ENVIRONMENTAL PROCESS 19
2.1 Legal Requirement 19 2.1.1 National Environmental Management Act 107 of 1998 (NEMA); 19 2.1.2 EIA Regulations, promulgated in terms of NEMA; 20 2.1.3 National Water Act 36 of 1998 (NWA); 22 2.1.4 National Heritage Resources Act 25 of 1999 (NHRA) 23 2.1.5 National Environmental Management: Biodiversity Act 10 of 2004
(NEMBA); 23 2.1.6 National Environmental Management: Air Quality Act 39 of 2004 24
2.2 Planning Policy Framework 25 2.2.1 Western Cape Provincial Spatial Development Framework (2014) 25 2.2.2 Cape Winelands District Municipality Integrated Development Plan (IDP) 26 2.2.3 Cape Winelands District Municipality Spatial Development Framework
(SDF) 26 2.2.4 Langeberg Local Municipality Integrated Development Plan (IDP) 27 2.2.5 Langeberg Local Municipality Spatial Development Framework (SPDF) 27
2.3 Environmental Process 28 2.3.1 Submission of Environmental Authorisation and other Relevant
Applications 29 2.3.2 S&EIR Process and Phasing 29
3 BASELINE ENVIRONMENT 31
3.1 Description Residential, Socio-Economic and Cultural Receiving Environment 32
3.1.1 Community Ownership and Traditional Authorities 32 3.1.2 Landowners and Title Deed Owners 32 3.1.3 Departure of Zoning to Land for Industrial Purpose 32 3.1.4 The Local Municipality 33 3.1.5 Existing Status of the Cultural and Heritage Environment that may be
Affected 33 3.1.6 Current on Site Land Use 33 3.1.7 Surrounding Land Use 33 3.1.8 Regional Land Conservation Units 37 3.1.9 Nearby Residences and Dwellings 37 3.1.10 Nearby businesses/ tourist places 39
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3.2 Description of the Biophysical Receiving Environment 40 3.2.1 Topography 40 3.2.2 Drainage 41 3.2.3 Noise 42 3.2.4 Air Quality: Emissions and Fugitive Dust 45 3.2.5 Soils 45 3.2.6 Geology 46 3.2.7 Climate 48 3.2.8 Biodiversity, Flora & Fauna 51 3.2.9 Surface water 52 3.2.10 Groundwater 53
4 PROJECT DESCRIPTION 54
4.1 Project Design: 54 4.1.1 Layout, road network and infrastructure 54 4.1.2 The Brick Making Process 54 4.1.3 Site & Service and Equipment Description 56 4.1.4 The conceptual brick factory layout 57 4.1.5 Stormwater Management Plan 57
5 STAKEHOLDER ENGAGEMENT 60
5.1 Objectives of the Stakeholder Engagement Process 60
5.2 Interested and Affected Parties Consultation Process 61 5.2.1 Identification of Key Stakeholders 63 5.2.2 Notification of the EIA Process 64 5.2.3 Release of Draft Scoping Report 64 5.2.4 Issues and Concerns Raised by IAP’s during Scoping 65 5.2.5 Finalising the Scoping Report 66
Figure 3-1: Neighbouring farms to Gannabosch Vlakte 51 ................................................... 36
Figure 3-2: Langeberg-West Mountain Catchment Conservation and Doringkloof Private Nature Reserve that are in close proximity to Gannabosch Vlakte 51 .................................. 37
Figure 3-3: Land units of the Rooiberg Breede Conservancy are indicated in yellow, of which Gannabosch Vlakte 51 is shown in the centre of the conservancy. ...................................... 38
Figure 3-4: Habitations in the vicinity of the proposed Robertson Brick Factory. The dots represent established homesteads. The diameter of the circle is 2 km, centred on the site of the quarry. Green star indicates Manager’s residence, blue cross indicates Cape .............. 38
Figure 3-5: Localities of residents and tourism facilities within immediate area of the proposed development. The yellow circle indicates the zone of noise extent. Dark red indicates the 1km fugitive dust fallout and light red indicates 2 km fugitive dust fallout. Both are plotted along the prevailing wind direction (bottom right corner). ..................................................................... 39
Figure 3-6: The Rooiberg Mountain Bike Trail shown to be running south of the brick factory ............................................................................................................................................ 40
Figure 3-7: Brick Factory footprint shown overlaying the mine concession and a portion to the northwest border outside of concession area. While the proposed development area impacts drainage line 2, the east and west boundary drainage lines remain intact and preserve biodiversity. .......................................................................................................................... 41
Figure 3-8: Graphical representation of predicted sound level in decibel (dB) across a specific distance in meters (m). ........................................................................................................ 43
Figure 3-9: Composite climate diagram of the Robertson region. Blue bars show the median monthly precipitation. The upper and lower red lines show the mean daily maximum and minimum temperatures respectively (After Mucina and Rutherford, 2006). .......................... 49
Figure 3-10: Average, maximum and minimum daily temperatures throughout the day, with the horizontal axis representing months of the year, starting with January (1) and ending with December (12). .................................................................................................................... 50
Figure 3-11: Wind rose of the Worcester region ................................................................... 51
Figure 4-1: Simplified flowchart of the brick making process. ............................................... 54
Figure 4-2: Conceptual storm water management plan. ....................................................... 59
Figure 5-1: Advertisements posted in local and regional newspapers and on the affected property of the EIA and PPP process. .................................................................................. 65
Figure 7-1: Positions of additional potential brick clay resource sites in the region surrounding the proposed Gannabosch clay mine. Pink, (Pt-01 02 and 03) orange (Dg-01) and yellow (Dw-01) areas represent Tierberg, Gydo and Waboomberg Formation sites respective respectively, maroon polygons represent associated farms, and the red polygon represents Gannabosch Vlakte 51. ............................................................................................................................. 91
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Figure 7-2: Initial locality of the brick factory was planned to be southwest of the proposed mine footprint, between the proposed mine concession area and the Vink River on southwest corner of map. ................................................................................................................................ 92
Figure 7-3: Showing the possible alternative location for the factory at the Old Quarry Site to the northwest of the town. Also shown is the unsuitable Town Industrial Zone. ................... 93
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LIST OF TABLES
Table 1-1: EAP and Company details .................................................................................. 12
Table 3-2: Surrounding property land use ............................................................................ 35
Table 3-3: Predicted sound level per decibel (dB) across a distance in meters (m). ............. 43
Table 3-4: Listing of possible noise receptors in the surrounding area of the Brick making facility. Localities of these receptors are shown in Figure 3-5. ............................................. 44
Table 3-5: Noise limits per sector ......................................................................................... 44
Figure 3-3: Land units of the Rooiberg Breede Conservancy are indicated in yellow, of which Gannabosch Vlakte 51 is shown in the centre of the conservancy.
Figure 3-4: Habitations in the vicinity of the proposed Robertson Brick Factory. The dots
represent established homesteads. The diameter of the circle is 2 km, centred
on the site of the quarry. Green star indicates Manager’s residence, blue cross
indicates Cape
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3.1.10 Nearby businesses/ tourist places
Aside from agricultural activities, other key economic activity in the area consists of the
Cape Lime processing plant and the associated limestone quarry mine as well as several
tourist related industries. The proposed brick factory site falls within the Breede River
Valley wine route, and is a feeder road into the R66 Klein Karoo tourist route which serves
as an alternative to the highly popular N2 Garden Route. Viticulture and related tourist
interest are noted activity in the region and a number of guest houses are within the
locality. (See Figure 3-5). The Rooiberg Mountain Bike Trail is offered by the
conservancy and is part of the tourism initiatives that are currently being developed for
the area. (See Figure 3-6).
Figure 3-5: Localities of residents and tourism facilities within immediate area of the
proposed development. The yellow circle indicates the zone of noise extent.
Dark red indicates the 1km fugitive dust fallout and light red indicates 2 km
fugitive dust fallout. Both are plotted along the prevailing wind direction
(bottom right corner).
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Figure 3-6: The Rooiberg Mountain Bike Trail shown to be running south of the brick factory
3.2 DESCRIPTION OF THE BIOPHYSICAL RECEIVING ENVIRONMENT
Paragraph 2 (h) (iv) of Appendix 2, GN 982 requires a description of the biophysical
attributes associated with the development footprint Section 3.2 focuses on the
geographical, physical and biological aspects of the receiving environment.
3.2.1 Topography
The project site is situated in the low lying foothills of the Langeberg range which slope
gently toward the Vink River south of the site.
The proposed property is located within the Cape Winelands District (previously known
as the Boland region). This area is located in the middle-upper courses of the Breede
River, situated within the central Cape Fold Belt Mountains and within the Breede Valley.
It is bordered between the Langeberg ~1400 mamsl and Riviersonderend ~ 1300 mamsl
mountain ranges to the north and south respectively high. (See Figure I 1). Locally, the
property is situated on slightly southward sloping, lower lying and level shrub lands,
(indigenous Breede Alluvium Renosterveld ), within closed hills with a moderate to high
relief of ~265 to 275 mamsl (slopes with a gradient of >5% are predominant within the
region.
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3.2.2 Drainage
The property is located within the H40H quaternary catchment of the Breede-Gouritz
Catchment Management Area (BGCMA). The Breede River is the most significant
perennial river in the region. The non-perennial Vink River is located south of the property
and feeds the Breede River. Due to the low permeability of the clay soils, the property
experiences a significant amount of surface water run-off, which drains into the non-
perennial stream on the property and/or feeds into the Vink River.
Three drainage lines cross through the target area (see Figure 3-7). Drainage line 1
towards the west being of significant ecological importance has been excluded from the
amended target area and left intact as a corridor to support biodiversity and linkage within
the CBA. Drainage line 2 is of lowest significance, with no distinct channel and no noted
vegetation difference to the surrounding area. It will be compromised, via a diversion, in
the proposed development. Drainage line 3 towards the east has, like drainage line 1, is
being excluded from the target area.
These drainage lines are classified as both Ecological Support Areas and as an Aquatic
CBA. Overall, the natural habitat within the target area is in a good condition, well
connected to adjacent natural areas and is positioned within a CBA. The site accordingly
has a high ecological integrity.
Figure 3-7: Brick Factory footprint shown overlaying the mine concession and a portion to
the northwest border outside of concession area. While the proposed
development area impacts drainage line 2, the east and west boundary drainage
lines remain intact and preserve biodiversity.
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3.2.3 Noise
Noise can be defined as "unwanted sound". Response to noise is not an empirical
absolute; it is often a psychological concept and does not need to be loud to be considered
“disturbing”. Depending on their activities, people generally are tolerant to noise up to a
certain absolute level, e.g. 65 dBA. Anything above this level is considered unacceptable.
The major noise generating activities will result from the operation of vehicles and tippers
associated with brick making facilities and the running of the plant, in particular the
crushers, and conveyor belts. The main noise generators in the brick factory system will
be the roller crushers (100 dBA), Cutting machines (90 dBA), and conveyors systems (100
to 120 dBA). Decibels are measured using a logarithmic scale1, meaning the cumulative
noise level expected from the factory in full production mode will approximate 103 dBA.
Noise levels at receptor location are compelled to be < 45dBA / 35dBA during the daytime
and nighttime respectively, in accordance with SANS-10103:2003 (South African National
Standards) (See Table 3-5). At this stage of the scoping process, a Noise Impact
Assessment Report is not considered necessary; however, given the proximity of the
nearby noise receptors a simplistic model was undertaken.
Assumptions:
1. The factory in full production mode is assumed to run at ~100 dBA
2. Baseline measurement is at 1 meter
3. The effect of reverberation and the topography is ignored.
2. Baseline intensity X (distance 12 / distance 22)
3. This showed a drop-off of 6.02 dB at a doubling of the distance.
Based on the accepted sound level drop of 6 dB per doubling of distance; simple modeling
predicts sound levels to approximate 45 dB at 500 m from source as shown in Table 3-3
and Figure 3-8. This is below the 65 dBA level considered to be acceptable and within
the 45 dBA requirement for rural districts according to the SANS-10103:2003 regulation
limits. (See Table 3-5).
1 The following logarithmic equation is used to calculate the sum of sound power levels: Total L = 10 x log10(Σ1n 10Ln/10), where n1 = 90, n2 = 100 , n3 = 100.
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Table 3-3: Predicted sound level per decibel (dB) across a distance in meters (m).
Figure 3-8: Graphical representation of predicted sound level in decibel (dB) across a
specific distance in meters (m).
Potentially sensitive receptors were identified using Google Earth and topographical
maps, supported by site visit information. These are listed in Table 3-4 and illustrated in
Figure 3-5. Receptors within two kilometers of the factory are listed in this table as
relevant, all others may be considered beyond the range of influence. Within the critical
500 m radius, The “Coffee and Wine Shoppe” is a likely receptor, however due to position
off the main wind axis and the intervening Cape Lime Factory, the impact of noise
disturbance is likely to be attenuated. Buitenstekloof Mountain Cottages and the Rooiberg
Cellar & Wine, Bistro, Shop are a cause for concern, again they are not directly downwind
of the factory and the distance from source is significantly beyond the 500 critical radius.
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Table 3-4: Listing of possible noise receptors in the surrounding area of the Brick making
facility. Localities of these receptors are shown in Figure 3-5.
Noise Receptor Latitude &
Longitude
Approx. distance
from operation
Saggy Stone Micro Brewery and Restaurant 33°41'37.74"S
19°43'6.11"E 7.49 Km
Tierhoek Cottages — Orange Grove Cottages 33°42'44.03"S
There is always a small chance of intersecting unmarked human remains
dating to the Later Stone Age but according the heritage specialist, the
chances are very small. Such finds can never be predicted;
As a mitigation, the education of the factory workers should be effected
to identify historical artefacts so that they may stop processes in order to
alert the factory manager;
Most artefacts will occur in upper layers in overburden and soils and will
be moved around when the topsoil is cleared and stockpiled and then
redistributed during rehabilitation. Because of their very low value, no
significant impacts are expected;
A number of isolated stone artefacts were noted scattered across the site
with the majority being in the western half. They appeared to be a mix of
Early (ESA), Middle (MSA) and Later Stone Age (LSA) artefacts. None
of these artefacts is considered of cultural significance according the
heritage consultant;
The R60 can be considered a scenic route and the visual impression of
a factory would be considered a cultural and visual impact as well as
deterrent to tourism;
To some extent the existing Cape Lime buildings and the large bluegum
trees within the Vink River riparian zone will provide visual screening and
can be used to mitigate the impact of the new brick factory buildings;
The impact of both the Cape Lime and the brick plant will add to a
cumulative visual impact and
Placement of berms using overburden and planting of windrows of rapid
developing trees (e.g. Searsia Karee, Searsia pendulia, Vachellia karoo)
can be used to screen the infrastructure; so as to retain the visual /
cultural milieu of the landscape.
Parameters Spatial Duration Severity Probability Significance
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Final Scoping Report Page 82
Pre-Mitigation 1 2 2 < 40 Very Low
Post-Mitigation 1 2 1 < 40 Insignificant
6.3.5 Socio-economic Impacts
The assessment of potential socio-economic impacts is provided below:
Table 6-9: Socio-economic impacts
Criteria Details/Discussion
Impact 1
Description of
impact
The biggest provider of jobs in the area is the agricultural sector and in
particular the viticulture industry along with associated vineyards, wine cellars
and tourism. Concern is raised that any negative environmental impact from
the development of the factory could affect far more jobs than the positive
gain achieved from the smaller workforce of the factory.
Mitigation
required
Negative environmental impacts will be mitigated as best possible by
following the guidelines that will be written in the EMPr and the MMP.
Should these practices be diligently followed, impact to the agricultural
sector can be minimised.
Parameters Spatial Duration Severity Probability Significance
Impact 2 2 3 >70 High
Post-Mitigation 2 2 2 40 to 70 Low
Impact 2
Description of
Impact
Local labour from adjacent farm communities or Robertson will be employed
by the mine. This will have a positive impact on the wellbeing of employees
with a multiplier effect on households of the employed.
Mitigation
required No mitigation required.
Parameters Spatial Duration Severity Probability Significance
Impact 2 3 1 >90 Medium
(Positive)
Impact 3
Description of
impact
Tourism, may be negatively impacted;’ this includes visits to wine farms,
mountain bike trail and passing road traffic using R60/62 scenic tourism route
Mitigation
required
Visual screening of the infrastructure must be undertaken to ameliorate
the impact to tourists. This must be undertaken by the placement of
berms using overburden and planting of windrows of rapid developing
trees (e.g. Searsia Karee, Searsia pendulia, Vachellia karoo) to screen
the infrastructure; so as to retain the visual and cultural milieu of the
landscape.
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Parameters Spatial Duration Severity Probability Significance
Impact 2 3 1 > 90 Medium
Post-Mitigation 2 2 1 > 70 Low
Impact 4
Description of
impact
Agricultural activities, may be negatively impacted; due to possible fugitive
dust loading from the plant. Dust prevents crop growth and will also have
health impacts on the labourers and residents, potentially impacting
agricultural production. Dust in the size range 20 to 100 µm diameter,
originating from unenclosed material handling and processing, and from wind
erosion of unconsolidated stockpiles, will result in fallout dust (vertical
deposition onto horizontal surfaces) and impaction dust (horizontal deposition
onto vertical surfaces) during wind conditions of greater than 15 km/h. Below
this wind speed of 15 km/h, particles in this size range generated by
mechanical handling will deposit within the site boundaries, and the wind has
insufficient energy to generate dust from unconsolidated surfaces
Mitigation
required
Recommended mitigation measures proposed by the air emission specialist
include:
Confine vehicle movements on unpaved roads to demarcated areas only
Hard pave all turning circles and material discharge and stock pile reclaim
areas
Enclose coal and clay stockpiles with three sided concrete bins, with
opening facing SW or NE (at right angles to prevailing winds).
Erect wind fences or plant indigenous trees as wind breaks at strategic
locations (e.g. upwind of stock piles and turning circles).
Ensure that site drainage carries spillage of clay or coal fines away from
traffic movement zones (and directed to lined sumps or at a minimum into
settling ponds to prevent loss beyond the boundary);
Spraying of clay or coal stockpiles if wind erosion is observed;
Hard paving of turn-off point from tarred road onto site access road for 10
to 15 meters to reduce spillage and carry-over of material from unpaved
to paved road.
Parameters Spatial Duration Severity Probability Significance
Impact 2 3 2 > 90 High
Post-Mitigation 2 2 1 > 70 Low
Impact 5
Description of
impact
Loss of value of neighbouring properties resultant from change of land from
Agriculture to Temporary Industry
Mitigation
required A specialist report by a Professional Appraiser needs to be undertaken.
Parameters Spatial Duration Severity Probability Significance
Impact 2 3 2 > 90 High
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Post-Mitigation 2 2 1 > 70 Low
6.3.6 Air Quality
The assessment of potential impacts on air quality is provided below:
Table 6-10: Air Quality
Criteria Details/Discussion
Impact 1
Description of impact
Dust generated from site clearing, soil transportation, stockpiling, construction may be windblown as fugitive dust and settle on surrounding, residential, agricultural and environmental receptors. Unsightly brick dust and coal dust staining may occur on nearby infrastructure.
Mitigation required
Recommended mitigation measures proposed by the air emission specialist include:
Confine vehicle movements on unpaved roads to demarcated areas only;
Hard pave all turning circles and material discharge and stock pile reclaim areas;
Enclose coal and clay stockpiles with three sided concrete bins, with opening facing SW or NE (at right angles to prevailing winds);
Erect wind fences or plant indigenous trees as wind breaks at strategic locations (e.g. upwind of stock piles and turning circles);
Ensure that site drainage carries spillage of clay or coal fines away from traffic movement zones (and directed to lined sumps or at a minimum into settling ponds to prevent loss beyond the boundary);
Spraying of clay or coal stockpiles if wind erosion is observed;
Hard pave and reinforce first 15 m leading off the Langvlei Quarry public road so that heavy trucks do not damage tarred road edges and create pot holes due to the turning motion of the truck, and possible spillage from the load bed of coal delivery trucks;
Demarcate turning circles, haul road and parking areas with fencing to limit overspill of vehicles into no-go zones;
Set up water sprayers along haul roads to dampen dust and minimise dust loading to surrounding vegetation;
Limit width of haul roads and access tracks to maximum 4 meters to allow sprayers to reach full width of road;
Ensure that all stockpiles, i.e. topsoil, overburden, clay ore, coal storage are enclosed within three sided protection walls and a low bund wall on fourth side to limit spillage onto loading apron;
Limit maximum height of stockpiles to 2 m and orientate long axis along SE-NW prevailing wind direction;
Design bund walls to prevent wind erosion with orientation such that open end is at right angles to prevailing NW-SE winds;
Sweeping of all aprons surrounding tip points and stockpiles;
Speed control for all roads to limit dust generation;
Scarify compacted areas after construction or mining to allow for natural vegetation regrowth and
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Regular twice weekly visual checking and recording of visible dust emissions from all identified dust sources and emission points. These check lists to be signed off and permanently retained for analysis of dust emission points and opportunities for continuous improvement and
In order to establish a baseline dust fall; site-representative dust fall monitoring, in terms of the National Dust Control; Regulations, will be undertaken prior to the commencement of activities.
Parameters Spatial Duration Severity Probability Significance
Pre-Mitigation 2 3 2 > 90 High
Post-Mitigation 1 2 1 > 70 Very Low
Impact 2
Description of impact
Sulphur dioxide (SO2 emission). Sulphur dioxide is emitted due to combustion of sulphur contained in the coal fuel used to energise the clamp kilns.
Mitigation required
There are no mitigation measures that can be applied to the clamp kiln brick making technology;
Passive monitoring of SO2 along the boundary lines of brick works in South Africa have not yielded any instances in which the concentrations approached the national DEA limit values.
Continuous monitoring of SO2 emission must be carried out at four points along the main wind axis (NW-SE);
Recommended that these monitoring sites be located on the NE, SE, SW and NW boundaries, to take into account the higher frequency of wind along the SE-NW and NW to SE axis;
Special attention to be given under meteorological conditions leading to an inversion whereby temperatures increase with height above ground. A cooler trapped layer at surface is prevented from rising above the warmed capping inversion, thus trapping any pollutants that are present. This is usually prevalent during windless cold early morning and late evening times. During such meteorological conditions, Sulphur levels may rise above acceptable levels and may drift off the main wind axis (NW-SE) and
Cumulative impacts: There are no other activities emitting SO2 within a 5 km radius, so there are no cumulative concentrations that could raise the ambient SO2 levels towards the limit.
Parameters Spatial Duration Severity Probability Significance
Pre-Mitigation 2 3 1 > 90 Low
Post-Mitigation 2 3 1 > 70 Low
6.3.7 Noise Impact
The assessment of potential impacts on noise levels is provided below:
Table 6-11: Noise
Criteria Details/Discussion
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Impact 1
Description of
impact
The major noise generating activities will result from the operation of vehicles
and tippers associated with brick making facilities and the running of the plant,
the crushers, and conveyor belts.
Mitigation
required
Operating hours kept to during 08h00 to 17h00 during week days, and
08h00 to 14h00 on Saturdays;
Berms and windrows will be constructed around the brick facility area
which will aid block sound emission and
Factory vehicles will be regularly services and exhaust systems will be
maintained in good order in compliance with limiting noise emissions.
Parameters Spatial Duration Severity Probability Significance
Pre-Mitigation 1 3 2 > 90 Medium
Post-Mitigation 1 3 1 > 90 Low
6.3.8 Visual Impacts
The assessment of potential visual impacts is provided below:
Table 6-12: Visual Impact
Criteria Details/Discussion
Impact 1
Description of
impact
The geographical area from which the project will theoretically be visible,
known as the View Catchment Area (VCA), is dictated primarily by
topography. The extent is approximately 10km to the north west bounded by
the Langeberg, 5km south to Aasvoelberg and 8km to the east and south east
bounded by the higher ridgeline of Rooiberg. Of more significance is the Zone
of Visual Influence (ZVI) of the proposed project, i.e. the actual area from
where the project will be seen. Topography (minor ridges), vegetation (trees
and hedges), buildings and distance will reduce the area from which the site
and proposed project will be seen, particularly due to the relatively low
elevation of the site and its flatness. Hence the ZVI will be less than the VCA.
Mitigation
required
During the operation of the brick factory, the development will be visible.
On completion of mining, and with the removal of the factory infrastructure
and re-vegetation, the remnant impact will not be acutely visible and
Plant windrows of quick growing, preferably indigenous, trees, around the
brick factory site to screen the operation.
Parameters Spatial Duration Severity Probability Significance
Pre-Mitigation 2 3 2 > 90 High
Post-Mitigation 2 2 1 > 90 Low
Impact 2
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Description of
impact Change from naturally vegetated site to a brick factory
Mitigation
required
Plant windrows of quick growing, preferably indigenous, trees, around the
site to screen the brick factory and
The over burden from the first phase could be used as a berm on which
these trees can be planted, increase the screening effect from early days
Parameters Spatial Duration Severity Probability Significance
Pre-Mitigation 1 3 3 > 90 High
Post-Mitigation 1 3 1 > 70 Low
Impact 3
Description of
impact
The proposed development will be visible from receptors within the ZVI.
These include: The R60 scenic tourist route and some dwellings
Mitigation
required
Plant windrows of quick growing, preferably indigenous, trees, around the
site to screen the brick factory and
The over burden from the first phase could be used as a berm on which
these trees can be planted, increase the screening effect from early days
Pre-Mitigation 1 3 3 > 90 High
Post-Mitigation 1 3 1 > 70 Low
6.3.9 Traffic Impacts
The assessment of potential traffic impacts is provided below:
Table 6-13: Traffic impact
Criteria Details/Discussion
Impact 1
Description of
impact Impact on traffic on Worcester – Robertson Trunk Road TR 31/1
Mitigation
required
The Shoulder Sight Distance to the left along TR 31/1 from DR 1384 is
limited by vegetation that is obscuring the sight line at an eye height of
1.05 m for passenger cars. However, at an eye height of 1.80 m (for all
design vehicles other than passenger cars, the shoulder sight distance is
sufficient. The Shoulder Sight Distance should be improved for
passenger cars by trimming the vegetation along TR 31/1 to the left of
DR 1384.
The Shoulder Sight Distance to the right of DR 1384 along TR 31/1 is
sufficient for passenger cars and other design vehicles. And
There are existing passing lanes in both directions along TR 31/1 on both
approaches to DR 1384 that separate decelerating turning from the
faster, straight through traffic along TR 31/1. This contributes to safety at
the intersection.
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Parameters Spatial Duration Severity Probability Significance
Pre-Mitigation 1 2 2 > 90 Low
Post-Mitigation 1 2 1 > 90 Very Low
Impact 2
Description of
impact Impact on traffic on the Langvlei Quarry Divisional Road DR 1384
Mitigation
required
Access to / from the development site will be off the Langvlei Quarry
Divisional Road, DR 1384 that intersects TR 31/1 to the south. DR 1384
also provides access to Langvlei train station and Cape Lime. The traffic
impact specialist comments that there is sufficient Shoulder Sight
Distance both to the left and right along DR 1384 at the position of the
proposed access to the development. The proposed access point along
DR 1384 is therefore deemed safe.
Road Network Management have nonetheless issued precise
instructions on the position and construction of the access point. This will
mitigate any possible impact to road safety. The exiting access at ~ 0.92
km off DR 1384 must be permanently closed. The Road Network
Management have approved a new access at ~ 1.21 km off the DR 1384.
Access must be built according to Main Farm Access regulations and be
hard surfaced.
Parameters Spatial Duration Severity Probability Significance
Pre-Mitigation 1 2 2 > 90 Low
Post-Mitigation 1 2 1 > 90 Very Low
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6.4 CUMULATIVE IMPACTS
Cumulative impacts are the direct and indirect impacts that act together with existing and
future potential impacts of other activities, or proposed activities in the region that affect
the same resources and receptors. With respect to this project, potential cumulative
impacts are:
Industrial processing activities of the Cape Lime factory within the floodplain of the
Vink River are leading towards degradation of the drainage lines, ESA and
impinging on the integrity of the CBA. Any development within a CBA is
undesirable as it will result in the cumulative impact of a reduction of a network of
natural sites identified to meet biodiversity pattern and process thresholds. The
development of the Robertson Brick Factory will imply additional pressure to the
environment. The geographical orientation of the associated mine development
and the position of the factory to least impact on major drainage lines, has gone
someway ensure that sufficient ecological corridors are left intact for biodiversity
needs.
The visual impact of the Cape Lime factory is a noted deterrent to tourism activities
that are on the Breede River Wine Route on the R60. Additional developments of
the Gannabosch Mine and Robertson Brick Factory add some “moderate”
(Anderson, M. 2016) level of cumulative impact which can be mitigated if
recommendations of the specialist are followed.
The cumulative effect from mining, current activities at the Cape Lime plant and
future brick manufacturing could increase the levels of fugitive dust. This may
negatively affect agriculture, viticulture, scenic milieu and the health of residents
in the fallout zone. Control and management measures will be described in the
EIA/EMP.
Noise is not evaluated to be a cumulative impact if activities are confined to
standard daytime operational practice.
Cumulative impact must also consider the positive impact of the presence of business
activity in the Langeberg region and the input of social upliftment programs that form an
essential aspect of the factory development program. The supply of essential services
and meeting the demand for bricks of the construction industry are also considered a
positive cumulative impact.
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7 ALTERNATIVE LAND USE AND DEVELOPMENTS
CONSIDERED
Appendix 2 of the GN 982 Paragraph 2 (h) (ix) to (xi) of the NEMA EIA Regulations, 2014,
concerns the site choice and alternatives to the preferred option. The EIA Regulations
require that all S&EIR processes must identify and describe ‘alternatives to the proposed
activity that are feasible and reasonable’. The different types or categories of alternatives
for this project include: location alternatives, type of activity, design or layout alternatives,
and operational alternatives. The ‘No Go’ or ’No Project’ alternative must also be
considered.
7.1 ALTERNATIVE CLAY RESOURCE THAT COULD PROVIDE OTHER LOCALITIES FOR THE
FACTORY
Ideally the brick making factory should be linked to the Gannabosch Clay Mine.
Processing and manufacture of the finished product needs to take place as close to, or
preferably at the mine location. This therefore eliminates the possibility or rationale of
establishing the brick factory at an alternative site to the clay mine. Transport of raw clay
to an offsite process plant may not be economically viable nor logistically efficient.
A desktop study to seek viable alternative sites for the mine was undertaken by UA, which
was followed up by site specific visits by the proponent. This was specifically in response
to a need to establish the mine outside of the CBA. While clay deposits were found to be
in existence in the area, (see Figure 7-1), the following limiting factors had to be
considered.
• Ground truthing by the proponent indicated that none of these alternative sites had
a similar reserve potential who claim that the thickness and depth of the clay
deposits is not comparable to that found on Gannabosch Vlakte 51;
• None of the sites provided similar ease of access to adequate site and service
infrastructure required to support a brick factory: Proximity to water (4000 liters
per hour) and electricity (Three Phase 440 V) and access to road infrastructure
are minimum requirements and a failure to provide for this will mean the need to
construct roads, and apply for servitude rights;
• The proponent has established co-operation with the surface owner which lacking
at alternative localities and
• The alternative sites would need to produce clay with the qualities to provide bricks
of comparable qualities to the Gannabosch proposed site as specified in the 2015,
CSIR/Cermalab Report.
Further detail of the alternative resource study is available to read in Annexure I:
Alternative Resource Survey Report (Umvoto Africa, 2017).
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Figure 7-1: Positions of additional potential brick clay resource sites in the region surrounding the proposed Gannabosch clay mine. Pink, (Pt-01 02 and 03)
orange (Dg-01) and yellow (Dw-01) areas represent Tierberg, Gydo and Waboomberg Formation sites respective respectively, maroon polygons represent associated farms, and the red polygon represents Gannabosch
Vlakte 51.
7.2 SOUTHWESTERN ALTERNATIVE FOR LOCALITY OF THE FACTORY
The position of the brick factory was initially proposed to be on the southwestern extent of
the mine concession area. At this stage in the scoping process the proposed Gannabosch
mine was ~ 14 ha and placed on the western side of the Langvlei Quarry road (see Figure
7-2). Following recommendations of both the fresh water ecologists and the botanical
specialist, it was decided to reposition the factory to the northern extent of the mine area.
This had important repercussions; in so far as leaving the Vink River Aquatic Buffer zone
intact and avoiding the ecologically sensitive drainage line 1B. It also suited the proponent
because exploration drilling had shown the clay is thinner to non-existent towards the
north, therefore less resource is lost to the factory footprint.
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Figure 7-2: Initial locality of the brick factory was planned to be southwest of the proposed mine footprint, between the proposed mine concession area and the Vink
River on southwest corner of map.
7.3 THE CAPE LIME PROPERTY ALTERNATIVE
The Cape Lime factory is located just south of the proposed clay mine and could possibly
host the brick making facility. The onsite provision of site and service (electricity, water,
waste management) make this a practicable alternative. Utilising existing disturbed land
is a key advantage according to the policies of the Town Planning Department of the
Langeberg Local Municipality. This will be evaluated in discussions between Afrimet as
operator of the Cape Lime and the brick factory proponent.
7.4 ROBERTSON TOWN ALTERNATIVE SITES
In seeking alternative sites for the factory it is relevant to attempt to find alternative
locations that are outside of the CBA. Industrial and previously disturbed sites within
Robertson could be a viable target area with the understanding that the main
disadvantages will be in the transport of raw material from the mine to factory. The
industrial zone of Robertson (See Figure 7-3) is not a good alternative due to its proximity
to town and already limited capacity with no possibility to expand. The old quarry site to
the northwest of the Robertson (northwest of the Droeheuvel area) (See Figure 7-3), was
considered as an alternative location. The land was previously disturbed and in need of
rehabilitation. It is positioned off the main wind axis, thereby unlikely to impact directly on
the air quality of the town. However the land is not available and is currently in use by
Afrimet. Both alternatives for Robertson were therefore rejected.
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Figure 7-3: Showing the possible alternative location for the factory at the Old Quarry Site to the northwest of the town. Also shown is the unsuitable Town Industrial
Zone.
7.5 MONTAGU AND ASHTON TOWN ALTERNATIVE SITES
The town of Ashton has an industrial zone that is less constricted than Robertson and
could be considered as a receptor of a brick factory plant. This option was not considered
as viable given the transport distance from mine to factory. The Klein Karoo Brick factory
site in Montagu also has the constraints of transport distance and further investigation
would also be required to assess why the old plant was closed. Opinions of stakeholders
in the Montagu area would need to be evaluated.
7.6 REDUCED SIZE OF BRICK MAKING FACTORY
The Klein Karoo Bricks factory that was based in Montagu closed in June of 2016. The
closure of this production facility has no doubt left a need for bricks in the region. In
discussions with the Langeberg LM it was established that Klein Karoo Bricks produced
between 500 000 to 600 000 brick per month. The Bauhaus Economic Impact Study has
suggested that “The Current estimated shortfall of Bricks in this Region is 1 000 000 bricks
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per month (Steenkamp, 2016). Consideration therefore needs to be given that the scale
of the proposed Robertson Bakstene operation allows for more than the current local
market. The Bauhaus economic study should ideally provide reasons for the closure of
the Montagu based operation and also consider suitable technology options, alternative
to bricks, as a construction material to meet the needs and desirability of the local market
shortfall.
The current design of the plant is scaled to operating at a production rate of ~ 2 million
units per month. This will require a plant footprint size of ~ 5 ha which will accommodate
the extrusion plant, the proposed four clamp kilns and miscellaneous storage and
despatch areas. A reduced size of operation at ~ 1 million units per month will be
evaluated as part of the Draft Environmental Impact Assessment Report that will undergo
a PPP. Reducing the production capacity of the factory could enable a reduced footprint.
This approach may present an acceptable mitigation to comments from IAP’s and
stakeholders in terms of cumulative socio-economic impacts and the biodiversity impact
on the CBA.
7.7 ALTERNATIVE BRICK FIRING TECHNOLOGIES
The current approach put forward in this Scoping Report is toward firing of the bricks using
clamp kilns. In the view of some IAP’s, this can be considered outdated with high
emissions and could have implications on the wellbeing of neighbouring inhabitants and
ecological health of the environment. Alternative technologies exist that provide more
acceptable environmental solutions. Tunnel kilns, and the Habla oven were considered
initially by the proponent and disregarded due to the fact that night time noise levels from
fans and heaters would be a disturbance given the 24 hour cycle of the firing process.
Nonetheless it is conceded that further investigation need to be explored and evaluated
as part of the Draft Environmental Impact Assessment Report that will undergo a PPP.
7.8 THE NO GO ALTERNATIVE
The No Go alternative for manufacturing bricks is considered in accordance with the
requirements of the EIA Regulations, 2014 (as per Appendix 2. Section 2 (i) (i) of Notice
R.982, 2014). The No-Go alternative entails no change in existing status quo, of the land
use on Gannabosch Vlakte 51. If this carries a knock-on effect implicating the mine also
as a No Go, it further suggests the land use will remain, as zoned, for use as agricultural
land.
Protection and environmental custody of the CBA: It can be argued that the No Go
Alternative will benefit the region through the provision of a landscape corridor required
for habitat connectivity and an upland-lowland corridor between the Langeberg Mountains
and the Breede River. An alternate, suggested by Cape Nature Conservation, is
additional mitigation in the form of a biodiversity offset. Such an offset should be obtained
according to the Western Cape’s Draft Provincial Guidelines on Biodiversity Offsets and
a suitably selected botanical specialist will need to be appointed to conduct the study. The
offset will need to identify a suitable area with a comparative “like for like” vegetative value
and the determination of a multiplication factor for land size. It would further need to set
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out the most appropriate regulatory mechanism for securing stewardship of the area for
conservation in the long term.
Comparatives between agricultural and industrial sector socio-economic influence:
The No Go option ensures that the status quo of agricultural employment remains
unaffected. IAP’s have strongly argued that should the mine and factory have an
environmental impact leading to a decline in agricultural productivity of the area; the
impact of both the mine and the factory will be disadvantageous to employment
statistics. Given that the agricultural sector currently employs large numbers of people
and this will clearly exceed any proposed benefit to be achieved by the mine/factory where
the volume of labour will be significantly lower, it can be argued that the No Go option has
a positive socio-economic benefit.
If the proposed operation were not to proceed, the land may or may not be utilised for
grazing of livestock in the future. As much as the no go option may result in the protection
of the environment in situ; however, the consequences of not proceeding with the
proposed operation will include the forfeiture of a mining and factory development
opportunity and therefore the loss of support towards the Langeberg Municipality for
attaining some of the objectives as per their SDF goals. It is expected that an alternate
party is likely to apply for the mining right with the DMR. It would further suggest that no
new employment opportunities would be created nor would the Social and Labour Plan
upliftment and development programs take place.
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8 CONCLUSIONS
This Final Scoping Report concludes the Public Participation Process and provides an initial
environmental impact assessment for the proposed Robertson Brick Factory. The intent of
the scoping process was to encourage participative dialogue between the proponent and
interested and affected persons and to ensure that the application process is transparent,
serves the region socio-economically and safeguards the biodiversity of the environment. The
process has endeavoured to involve the public as IAP’s and institutional organisations as
commenting authorities and elicit from all stakeholders the concerns and comments with
regard to the proposed development. Some of these concerns have been discussed in this
Scoping Report, while others remain to be examined more thoroughly in the Draft EIA
Report. The Scoping Report has also endeavoured to draw out all impacts and to suggest
mitigating and optimisation interventions. A decision making matrix has been used to evaluate
the significance of the impact in both the pre and post mitigation scenarios. Due to the fact
that not all concerns are thoroughly discussed, the significance ratings may be amended as
the process proceeds into the draft EIA phase. Finally the Scoping Report provides an
assessment of alternatives in locality, size, technology, and business approach and to align
these alternatives to critical environmental and socio-economic objectives. It is common
practice in an S&EIA study to provide a number of alternatives to the proposed development
that will allow the decision-making authority to make preferred choices. The assessment of
the alternatives is not completed for the scoping phase and further studies and considerations
will need to be included in the Draft EIA Report.
We trust that adequate scoping and public participation has followed correct protocol and will
allow the DEA&DP to make an informed decision and promote the process forward towards
the preparation of the Draft EIA Report.
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9 UNDERTAKING AND AFFIRMATION BY THE EAP
Paragraph 2 (j) requires an undertaking by the Environmental Assessment Practitioner to state
his/her independence from the proponent, the correctness of information contained in the
report and the completeness and thoroughness to include all comments from stakeholders
and IAPs.
9.1 DECLARATION BY ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)
I Paul Lee, as the appointed environmental assessment practitioner (“EAP”) hereby
declare/affirm the correctness of the information provided or to be provided as part of the
application, and that I:
in terms of the general requirement to be independent:
o other than fair remuneration for work performed/to be performed in terms of this
application, have no business, financial, personal or other interest in the activity or
application and that there are no circumstances that may compromise my objectivity;
in terms of the remainder of the general requirements for an EAP, am fully aware of and
meet all of the requirements and that failure to comply with any the requirements may
result in disqualification;
have disclosed/will disclose, to the applicant, the specialist (if any), the Department and
registered interested and affected parties, all material information that have or may have
the potential to influence the decision of the Department or the objectivity of any report,
plan or document prepared or to be prepared as part of the application;
have ensured/will ensure that information containing all relevant facts in respect of the
application was/will be distributed or was/will be made available to registered interested
and affected parties and that participation will be facilitated in such a manner that all
interested and affected parties were/will be provided with a reasonable opportunity to
participate and to provide comments;
have ensured/will ensure that the comments of all interested and affected parties were/will
be considered, recorded and submitted to the Department in respect of the application;
have ensured/will ensure the inclusion of inputs and recommendations from the specialist
reports in respect of the application, where relevant;
have kept/will keep a register of all interested and affected parties that participate/d in the
public participation process; and
am aware that a false declaration is an offence in terms of regulation 48 of the NEMA EIA
Regulations, 2014.
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2017-03-17
Signature of the environmental assessment practitioner: Date:
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REFERENCES Cole, D.I., Ngcofe, L., Halenyane, K. (2014) Mineral Commodities in the Western Cape
Province, South Africa, Council of Geoscience: Report Number:2014-0012,
Western Cape Regional Office. February 2014
CFM, (2017), Elsenberg GIS: ArcGIS Services Directory, Western Cape Government:
Agriculture [accessed 2017 March 10]. http://gis.elsenburg.com/app/cfm.
CNdV, (2014): Langeberg Municipality: Spatial Development Framework (Draft): prepared for
DEA&DP and Langeberg Municipality. , November 2014
Western Cape Department of Agriculture, WCDA & Western cape Department of
Environmental Affairs & Development planning, WCDEA&DP (2015) Status Quo
Review of Climate Change and Agriculture in the Western Cape, Prepared by
SMART Agri & African Climate & Development Initiative, ACDI
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APPENDIX A – CURRICULUM VITAE OF EAP
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APPENDIX B – COMPANY REGISTRATION CERTIFICATE
(ROBERTSON BAKSTENE (PTY) LTD.)
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APPENDIX C – HERITAGE WESTERN CAPE
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APPENDIX D – LUPA TEMPORARY ZONE DEPARTURE
APPLICATION
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APPENDIX E – INTERESTED AND AFFECTED PARTIES REGISTER
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APPENDIX F – IAP & STAKEHOLDER CONCERNS RAISED
F-1: COLLATED COMMENTS AND CONCERNS
F-2: ALL IAP RESPONSES
F-3: IAP SIGNED PETITIONS
F-4: DOCUMENTED LAWYER LETTERS
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APPENDIX G – LAND AFFAIRS RESPONSE
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APPENDIX H – TITLE DEED (GANNABOSCH VLAKTE 51)
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APPENDIX I – MAPS
Figure I 1 Regional Topographic Map
Figure I 2 Locality Map
Figure I 3 Site & Services Infrastructure
Figure I 4 Layout Plan
Figure I 5 Factory Infrastructure Plan
Figure I 6 Local Geology Map
Figure I 7 Local Vegetation Map
Figure I 8 Biodiversity Map
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Figure I 1: Regional Topographic Map
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Figure I 2: Locality Map including the coordinates of the target property, Gannabosch Vlakte 51 (black boundary line) are shown
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Figure I 3: Layout Plan of proposed brick factory (Black area marked BF1 to BF4) on the mine concession (red polygon), showing slight overrun on the northwest border. Also shown are service and infrastructure that is external to the boundary of both the mine and Gannabosch Vlakte 51, this incudes water and electricity supply.
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Figure I 4: : Zoomed in layout plan showing position of the brick making factory in relation to the mine concession area as per points BF1 to BF4.
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Figure I 5: Conceptual layout plan showing brick processing infrastructure with estimated sizes of individual areas.