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Title: Environmental Management Plan

No.: BRN-HSE-ZTE-PLN-004 - Rev 0

BARAN ENGINEERING (SOUTH AFRICA)

HEALTH, SAFETY, ENVIRONMENTAL MANAGEMENT MANUAL

Environmental Management Plan


Procedure Number BRN-HSE-ZTE-PLN-004 - Rev 0

ZTE PROJECT

Name Title Signature Date

Prepared By: T. Magengelele HSE Manager

Reviewed By: Rollout Manager

Approved By: Project Director

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Title: Environmental Management Plan

No.: BRN-HSE-ZTE-PLN-004 - Rev 0

1. PURPOSE

To provide and define the Environmental Management Plan for the ZTE Project.

2. SCOPE

This plan covers the Environmental requirements for the installation of optic fibre cable between
Bloemfontein and Ventersburg of the ZTE Project contract as defined in the Contract Documents and
project specifications. However no EMP has been issued by BAR for this project to date.

3. REFERENCES

Project requirements
BARAN ENGINEERING Environmental Policy
BARAN ENGINEERING Quality Manual
BARAN ENGINEERING HSE Manual
ISO 14001 -2004 requirements
EIA Report
EMPr reports
Environmental Conservation Act 73/1989
National Water Act 36/1998
Water Services Act 108/1997
Occupational Health & Safety Act 85/1993
Compensation for Occupational Injuries & Diseases Act 130/1993

4. RESPONSIBILITY

Responsible Person : The Project Director, D. Doron


Drawing up : HSE Manager, T. Magengelele
Execution : All Site Personnel
Checking : Site Safety Committee / Safety Officer

5. POLICY

The BARAN ENGINEERING Environmental Policy is available on site which reads as follows:

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Title: Environmental Management Plan

No.: BRN-HSE-ZTE-PLN-004 - Rev 0

BARAN ENGINEERING does not compromise the health and safety of its employees and respects the
environment. The companys goal is to sustain an incident-free working environment. Every direct-hire
employee and contractor to ZTE is accountable for working in a manner consistent with this goal. To this
end, BARAN will:

Foster a positive HS&E culture


Implement an effective HS&E Management System
Proactively manage HS&E performance.

BARANs Health, Safety and Environmental objectives are given equal priority with other business
objectives.

BARAN will comply with all applicable legislation and relevant industry standards. In the absence of such
regulatory controls BARAN will impose its own standards consistent with this policy.45

BARAN will strive to be a good corporate citizen. We will work with our clients, contractors and suppliers
to improve the efficiency of our operations, conserve natural resources and reduce waste and emissions.
We will seek sustainable solutions to our own and our clients business needs, bal ancing environmental,
social and economic considerations.

We will make appropriate arrangements to protect the health of our people while at work. BARAN
engages with employees, clients, partners, contractors, suppliers and communities in which we work to
achieve continual improvement in our health, safety and environmental performances.

In particular, the Company commits itself to minimize the harmful effects on the environment through
its operations and strive to develop operational procedures and methods to ensure the prevention of
pollution, the compliance with environmental regulations and the protection of its employees against
the possible harmful effects of its operations.

The following contract specific policy will also apply:

The management of BARAN ENGINEERING is committed to effecting sound environmental


management in executing its scope of work for the ZTE Project. As such the company commits
fully to support the overall Project Environmental Policy.
In pursuance of these values, Management shall:
Implement an Environmental Management Programme based on the Environmental Impact
Assessment and in compliance with the relevant environmental legislation, regulations and
standards that upholds the principles of the project Charter that was developed during EIA.
Enforce line management responsibility within the project to ensure compliance with the
Environmental Management Programme.
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Title: Environmental Management Plan

No.: BRN-HSE-ZTE-PLN-004 - Rev 0

Minimize adverse impacts on the site environment and on the surrounding communities during
all project phases.
Monitor and report fully to interested and affected parties upon the effectiveness of the project
Environmental Management Programme on an ongoing basis with a view to continuous
improvement.

Communication of the policy

Senior site management will ensure that the policy and EMP is communicated through the site
supervision to the labour force through crew and toolbox talks on an ongoing basis. The policy
and EMP will form part of ZTE specific induction for all employees arriving on site.

6. PLANNING

BARANs scope of work is to install Optic Fibre from Bloemfontein to Ventesburg as part of the ZTE
Project. The contract will take place over a period of 6 months, from March 2012 to September 2012.

The following types of Construction Plant and Equipment will be required to perform the works:

Vehicles-Trucks (semis and rigids), LDVs and Lowbeds for abnormal loads
Mobile Cranes
Auger Drills wheeled and tracked
Excavators
Trenching machines
Concrete Truck mixers and dumpers
Welding machines
Compressors
Generators.
Horizontal drilling machines

The activities their aspect/impact and mitigation will be listed on the attached Risk Assessment Study
(Attachment A)

All requirements stipulated in the EMPrs will be adhered to.

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Title: Environmental Management Plan

No.: BRN-HSE-ZTE-PLN-004 - Rev 0

If there are deviations to the route this will be communicated to the ECO and permission obtained for
route changes.
River crossings will be drilled as per the EMPrs unless otherwise agrred to with SANRAL and the ECO.

7. IMPLEMENTATION AND OPERATION

Responsibility:

The overall responsibility rests with the Project Manager as stated in section 4, Responsibility. He will
turn use subordinates to control and monitor certain activities.

Implementation of Mitigation measures:

Combinations of training, developing procedures and establishing facilities will be used to implement the
proposed mitigations in the EMP.

Awareness of EMP requirements:

All staff will be made aware of the overall requirements of the EMP during ZTEs contract specific
induction/briefing which will take place over and above the project induction. There will be topics
discussed on an ongoing basis during weekly toolbox talks in conjunction with safety issues. If an urgent
environmental issue arises a series of toolbox talks will be held to inform the entire workforce. Sub-
contractors will also receive the contract specific induction and will discuss topics as directed with their
workforce during their toolbox talks. Persons who perform tasks relating to the EMP on an ongoing basis
will receive training on managing the aspect such as refueling of plant and the collection and disposal of
solid waste. Applicable posters and signs will be displayed in visible positions relevant to the aspect
addressed.

Operations and Incidents:

If during the operations an incident happens or the mitigations in place for a particular aspect fail the
following will take place. If an incident occurs immediate action is to be taken to minimize the effects of
the incident and report it to the immediate supervisor. The supervisor will report to the Project Manager
who will institute actions to rectify the incident and inform the Project Director. Corrective action plans
will be agreed with the Project Director to minimize the risk to the environment and to rectify the effects
of the incident mitigations that are failing will be revised to reverse the failings.

8. CHECKING AND CORRECTIVE ACTION


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Title: Environmental Management Plan

No.: BRN-HSE-ZTE-PLN-004 - Rev 0

The Safety Officer will be delegated with the task of performing an ongoing surveillance on the aspects
and mitigations of the EMP and reporting the status of these to the Project Manager. This will however
not relieve all senior site management and supervisory staff from monitoring and reporting on the
effective operation of the EMP. The status of the EMP will be discussed and minuted during the weekly
ZTE Supervisors meeting incorporating its sub-contractors.

Objective and targets:

Main objective is to ensure adherence to the EMPr stipulations.


Other objectives of ZTEs EMP are listed in point 5, Policy.

9. MANAGEMENT REVIEW

ZTE will review the EMP for this project every month commencing in December 2011 after the initial
start-up of the contract and operations are all in progress. The review process will be minuted. Actual
targets achieved will be reviewed against those planned and the management will direct the operations
so as to achieve ongoing improvement of these targets.

The EMP will be reviewed by the following management team:


a) The Rollout Manager
b) The Project Director
c) The Manager of HSE
d) Client Representatives

Related Documents

Document Ref. Document Title


ZTE-HSE-ZTE-PLN- EHS Management Plan Fibreco project
001Rev 0
Forms

Form No. Form Title Rev No.


N/A
Notes and Attachments

A. Risk assessment/aspect tables


B. FIBRECO EMPrs

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Title: Environmental Management Plan

No.: BRN-HSE-ZTE-PLN-004 - Rev 0

ATTACHMENT A
Risk Assessment Study Appendix: A Rev. 0

100

10

1
Risk (MR/a)

0.1

0.01

0.001

0.0001

0.00001
56 57 59 60 61 63 66 53 64 62 65 54 55 67 50 51 52 58

Issue Num ber

Figure 1-A: Risks associated with Environment impact assessment in descending order of importance.

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ZT E Page 2 of 4 Environmental Impact Assessment
Risk Assessment Study Appendix: A Rev. 0
Organization: ZTE Leader: B. Strydom
Project Description: Environmental Impact Assessment Recorder: B. Strydom
Location: South Africa Time: NA
Date: Nov 2011
Project No.: Fibreco Project
Node Number: 002 Node Description: Environment impact assessment Team Members:

ID # Issue Consequence Frequenc y Risk Control Measures Hazard


(MR) (/a) (MR/a)
56 Smoking (Environment impact assessment; 0.1 100 10 Designated smoking areas
Safety signs posted
Inform during orientation
Review ed during toolbox talks

57 Inadequate ablution facilities (Environment impact assessment; 0.1 100 10 Provision of adequate facilities and sew er Legal
requirement
Regular inspections and hygiene

59 Inadequate provision for construction activities (Environment impact 0.1 100 10 Client carried out EIA and approved.
Assessment; Construction site is Greenfield
Construction activities managed and monitored
on a daily basis

60 Inadequate w aste storage and disposal (Environment impact assessment; 0.1 100 10 Waste bins provided for.
Waste disposed off on approved site

61 Inadequate provision for eating areas and provis ion of food stores 0.1 100 10 Site canteens and eating facilities provided for
(Environment impact assessment; as per legal requirements
Rubbish bins for spoiled food

63 Inadequate provision for noise control (Environment impact assessment; 0.1 100 10 Pre use/regular inspections on vehicles and
machinery
PPE for personnel
Slight effect on residential areas

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ZT E Page 3 of 4 Environmental Impact Assessment
Risk Assessment Study Appendix: A Rev. 0
ID # Issue Consequence Frequenc y Risk Control Measures Hazard
(MR) (/a) (MR/a)
66 Workforce impact on local community, its services and infrastructure. 10 1 10 1. All personnel to be inducted on HIV and AIDS.
(Environment impact assessment; 2. Ensure that recruitment takes place in
accordance with the IR policy.
3. Recruit local as far as possible through DOL

53 Inadequate provision for the handling and control of hazardous chemicals 0.1 12 1.2 Bunded areas for all chemicals and flammable
(Environment impact assessment; liquids.
Daily inspections and housekeeping
Over inspections by Client
Information and training
MSDS's

64 Inadequate communication re protection of environment to workforce. 0.1 12 1.2 Included in HSE plans
(Environment impact assessment; Included in HSE orientation, Toolbox talks
and inspections and audits

62 Inadequate control of dust on construction site. (Environment impact 0.01 100 1 Dust control procedure
Assessment; Water provided on construction site

65 Number off and road worthiness of vehicles not adequately managed 0.01 100 1 1. Limit no of vehicles
resulting in environmental pollution (Environment impact assessment; 2. All vehicles checked
3. Regular inspections on all vehicles.
4. Maintenance and repairs conducted
5. Drip trays for all vehicles and mobile plant

54 Fuel tanks and cars (Environment impact assessment; 0.01 12 0.12 Bunded areas
Allow ance for spillages
Spillages cleanup procedure
Provision of fire prevention/protection
Regular inspections

55 Fires on site (Environment impact assessment; 0.1 1 0.1 No fires permitted on site
No timber fires allow ed/only charcoal
Regular inspections

67 Inadequate storm w ater management resulting in pollution (Environment 0.1 1 0.1 1. Run off to be directed aw ay from offices and
Impact assessment; construction site
2. Drainage to be constructed away from
laydow n area where possible or standing w ater
w ill be pumped into storm w ater drains

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ZT E Page 4 of 4 Environmental Impact Assessment
Risk Assessment Study Appendix: A Rev. 0
ID # Issue Consequence Frequenc y Risk Control Measures Hazard
(MR) (/a) (MR/a)
50 Location of offices - positive aspect (Environment impact assessment; 0.01 0.1 0.001 Allocated by ZTE
Level and w ell drained
Monthly inspections

51 Site clearance before construction (Environment impact assessment; 0.01 0.1 0.001 Conservation of top soil necessary
No fauna or flora to be damaged
Area level and no erosion
Trees and vegetation to be protected
Streams/rivers to be protected

52 Drilling and blasting (Environment impact assessment; 0.01 0.01 0.0001 No effects on surrounding residential area
Possible blasting
Possible impact on w ildlife

58 Inadequate provision of Workshops (Environment impact assessment; 0.01 0.01 0.0001 No w orkshops on construction site
54. River Drilling and blasting (Environment impact assessment; 0.01 0.01 0.0001 No effects on surrounding residential area
Correct disposal of drilling mud
Possible impact on w ildlife
Impact on vegetation and w ater course.

55. Non adherence to EMPrs 0.01 0.01 0.0001 Training, supervision, audits, inspections

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ATTACHMENT B

Environmental Management Programme for


Route 1 Johannesburg to Bloemfontein of
the proposed FibreCo fibre optic data cable

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Table of Contents

1 Introduction and Scope of Report............................................................................... 1


1.1 Backgr o und ............................................................................................................................. ............ 1
1.2 Approach to environmental impact managem ent ............................................................................... 2
1.2.1 Overvi ew............................................................................................................................. ..... 2
1.2.2 FibreCos Social and Environmental policy ............................................................................. 2
1.2.3 Planning and design ................................................................................................................ 3
1.2.4 Pre-construction and constr uc ti on ........................................................................................... 3
1.2.5 Oper ati o n ............................................................................................................................. .... 4
1.2.6 Checking and corrective action ............................................................................................... 4
1.2.7 Management review ................................................................................................................ 5
1.2.8 Liaison ............................................................................................................................. ........ 5
1.3 Assumpti ons ............................................................................................................................. ........... 5
1.4 Uncer tai nti es .................................................................................................. ..................................... 6
2 The Proposed Project .................................................................................................. 6
2.1 Optic fibre data cable .......................................................................................................................... 6
2.1.1 Construction and installati on ................................................................................................... 7
2.1.2 Start and end points of data cable .......................................................................................... 8
2.1.3 Design and equipment standards ........................................................................................... 9
2.1.4 Monitori ng ............................................................................................................................. ... 9
2.2 Construction phas e ............................................................................................................................. 9
2.2.1 Scale and pace of constr uc ti on ............................................................................................... 9
2.2.2 Construction process ............................................................................................................... 9
2.2.3 Energy, water, sanitation and waste requir em e nts ............................................................... 10
2.2.4 Employment .......................................................................................................................... 10
2.3 Operational phas e ............................................................................................................................. 10
2.3.1 Transmission of infor mati on .................................................................................................. 10
2.3.2 Safety and security ................................................................................................................ 11
2.3.3 Energy, water, sanitation and waste requir em e nts ............................................................... 11
2.3.4 Monitori ng ............................................................................................................................. . 11
2.3.5 Employment .......................................................................................................................... 11
2.4 Decom mi ssi oni ng ............................................................................................................................. . 11

3 Impact mitigation and management ......................................................................... 11


3.1 Links with the Basic Assess m ent ...................................................................................................... 11
3.2 Mitigation and Management Measures per Phase ........................................................................... 11
3.3 Management plans............................................................................................................................ 14
3.3.1 Rationale ............................................................................................................................. .. 14
3.3.2 Construction management plan ............................................................................................ 14

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3.3.3 Labour and human resources plan ....................................................................................... 35
3.3.4 Workplace health and safety plan ......................................................................................... 36
3.3.5 Community health and safety plan ........................................................................................ 36
3.3.6 Land acquisition and compensation plan .............................................................................. 36
3.3.7 Emergency management and response plan ....................................................................... 37
3.3.8 Social responsibility plan ....................................................................................................... 37
3.3.9 Decommissioning plan .......................................................................................................... 38
3.3.10 HSE Construction Phase Roles and Responsi bili ti es ........................................................... 38
3.3.11 Contractor arrangements during the construction phas e ...................................................... 39
3.3.12 Training, awareness and capacity building ........................................................................... 39
3.3.13 Environmental procedures for the management of operational impact ................................ 40
3.4 Monitoring ............................................................................................................................. ............ 40
3.4.1 Programme monitori ng .......................................................................................................... 40
3.4.2 Plan Monitoring ..................................................................................................................... 41

List of Tables
Table 1-1: Routes under consideration and their relative distances .................................................................. 1
Table 1-2: Approaches to impact management ................................................................................................. 2
Table 2-1 End point and Repeater sites ............................................................................................................. 6
Table 3-1: Mitigation and management measures relating to impacts caused by project activities during all
project phas es ............................................................................................................................ 12
Table 3-2 Specific requirements for the siting of the cable trench and repeater sites ..................................... 20
Table 3-3 W etland/ river crossings identified by the specialist studies ............................................................ 29

List of Abbreviations
BA Basic Assessment

BBBEE Broad Based Black Economic Empowerment

dBA Noise levels for common noises measured in Decibels (dB)

DEA Department of Environmental Affairs (Competent Authority for the project)

DMR Department of Mineral Resources

DWA Department of Water Affairs (formerly Department of Water Affairs and Forestry)

DWAF Department of Water Affairs and Forestry (now Department of Water Affairs)

EAP Environmental Assessment Practitioner

ECO Environmental Control Officer

EMPr Environmental Management Programme

FibreCo FibreCo Telecommunications (Pty) Ltd

GPS Global Positioning System

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HIV Human Immunodeficiency Virus

IEC International Electrotechnical Commission

IFC International Finance Corporation

NHRA National Heritage Resources Act

SABS South African Bureau of Standards

SAHRA South African Heritage Resources Agency

SANBI South African National Biodiversity Institute

WUL Water Use Licence

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1 Introduction and Scope of Report
FibreCo Telecommunication (Proprietary) Limited (FibreCo) wishes to install a fibre optic data cable
and associated infrastructure between major centres in South Africa in order to improve
telecommunication service. This document is based on a generic environmental management
programme (EMPr) forming one component of the basic assessments (BAs) underway for the routes
anticipated to follow national and provincial highway routeing as indicated in Table 1-1:

Table 1-1: Routes under consideration and their relative distances

Route name Approximate distance (km)

Johannesburg to Bloemfontein (Route 1) 387

Bloemfontein to Graaff Reinet ((Route 2) 513

Graaff Reinet to Yzerfontein (Route 3) 940

George to Port Elizabeth (Route 4) 360

Port Elizabeth to Durban (Route 5) 968

Port Elizabeth to Colesberg (Route 6) 427

East London to Aliwal North (Route 7) 333

This EMPr is specific to Route 1 (see locality map in Appendix A).

1.1 Background
The purpose of the EMPr in its final form will be to ensure that social and environmental impacts,
risks and liabilities identified during the BA process are effectively managed during the construction,
operation and closure phases of the fibre optic data cable. It will specify the mitigation and
management measures to which FibreCo is committed, and show how the project will mobilise
organizational capacity and resources to implement these measures. The EMPr will also show how
mitigation and management measures will be scheduled. This generic EMPr has been developed at
the request of FibreCo to provide an initial indication of the measures which might be contained in
the EMPr.

The key objectives of the EMPr will be to:

Formalize and disclose the programme for environmental and social management; and
Provide a framework for the implementation of environmental and social management initiatives.
Best practice principles require that every reasonable effort be made to reduce and preferably to
prevent negative impacts, while enhancing positive benefits, especially within the communities most
directly affected by the proposed project. These principles are being used to guide the BA process.
In many cases, potential negative impacts can be avoided through careful design, routing and
location of facilities.

Work underpinning the EMPr needs to comply with the EIA Regulation requirements, and includes
the following:

A public participation process set out in Regulations 54, 55, 56, 57 and 58;
A BA report of the proposed Project, including specialist reports, that aims to:

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o List the impacts and risks associated with the proposed Project;
o Identify mitigation measures relating to the negative environmental and social
impacts identified during the BA process; and
o Formulation of the EMPr to avoid/minimize negative impacts.
The EMPr covers information on the management and/or mitigation measures that will be taken into
consideration to address impacts, where relevant, in respect of:

Planning and design;


Pre-construction and construction activities;
Operation; and
Closure.
It is necessary to highlight that the EMPr is a living document that will be periodically reviewed and
updated as necessary.

1.2 Approach to environmental impact management


Responsibility for the EMPr will reside in the HSE functional management cluster of FibreCo, but
there will be links with other functional clusters in areas such as operation and maintenance
services. The sections that follow outline the management cycle that will characterise HSE
management, and which will apply to the EMPr. Table 1-2 presents the range of approaches that will
be used to manage potential project activities.

Table 1-2: Approaches to impact management


Avoidance Avoiding activities that could result in adverse impacts and/or resources or areas considered sensitive
Prevention Preventing the occurrence of negative environmental impacts and/or preventing such an occurrence having
negative impacts
Preservation Preventing any future actions that might adversely affect an environmental resource
Minimisation Limiting or reducing the degree, extent, magnitude or duration of adverse impacts through scaling down,
relocating, redesigning and/or realigning elements of the project
Mitigation Measures taken to minimize adverse impacts on the environment
Enhancement Magnifying and/or improving the positive effects or benefits of a project
Rehabilitation Repairing affected resources, such as natural habitats or water resources
Restoration Restoring affected resources to an earlier (possibly more stable and productive) state, typically
background or pristine condition
Compensation Compensating for lost resources, and where possible, the creation, enhancement or protection of the same
type of resource at another suitable and acceptable location

1.2.1 Overview
The HSE management cycle has five broad components:

Policy
Planning and design
Project implementation (covering the construction and operation phases)
Checking and corrective action
Management review.
This addresses each of these phases of the proposed project.

1.2.2 FibreCos Social and Environmental policy


FibreCo is committed to developing and operating a terrestrial fibre optic cable system in a manner
that ensures environmental protection and minimises social impacts and is in line with industry best

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practice. This commitment is central to the companys Social and Environmental Management
system framework.

In line with this commitment FibreCo will endeavour to:

Undertake its activities in line with applicable industry standards and industry good practice;
Meet the requirements of national legislation wherever its network exists;
Manage construction activities, which FibreCo recognises as the main potential source of social
and environmental impacts, in a sustainable manner in order to minimise such impacts;
Ensure social and environmental impacts during operation of the project are avoided or reduced
as far as practicable;
Communicated and work closely with its Contractors to ensure their understanding and shared
commitment to conformance with this policy;
Provide training in social and environmental matters to key employees and Contractor
representatives where appropriate; and
Implement all reasonable precautions to protect the health and safety of its employees and
promote the health and safety of contracted workers.
These objectives shall be met via provision of adequate resources by senior management within
FibreCo to support the implementation of the social and environmental management systems. This
policy and other elements of the social and environmental management system shall be regularly
reviewed and updated in order to ensure its continued applicability to the activities of FibreCo.

1.2.3 Planning and design


Planning and design is necessary to ensure that mitigation and impact management can be
effectively implemented and minimise impacts in future stages of the project cycle. The alignment of
the fibre optic data cable and siting of repeater sites should be informed by identified environmental
sensitivities along the route, with a view to avoiding, minimising and mitigating potential negative
impacts and enhancing potential benefits.

In the case of the FibreCo Project the environmental aspects and potential impacts will mainly
emanate from the following project related activities:

1.2.4 Pre-construction and construction


The EMPr will put in place measures to avoid and mitigate impacts and optimize benefits arising
from activities during the pre-construction (e.g. establishment of access roads, campsites and
clearing of the construction right of way) and construction phase (e.g. trenching and laying of data
cable) of the Project. The construction process is detailed in Section 2 of this EMPr. The principal
role of ZTE/s during pre-construction and construction stages of the project will include: personnel
and Contractor management and training; conduct and site management; landowner relations;
maintenance of complaints register; emergency preparedness; and management and mitigation
of impacts such as noise, dust and safety).

Field investigations and surveys will be undertaken during the pre-construction and construction
stages of the project to ensure that ecological, heritage and palaeontological resources are
identified, documented and, where necessary, rescued. Permits will need to be obtained from the
relevant conservation authorities for the trimming and/or removal of indigenous trees.

Assignment of responsibility and Contractor management is especially important during the


construction phase, when Contractors are used to build the data cable. Contractors will also be used
on an ongoing basis for a range of maintenance and other functions. Contractors will be held to best
practice performance requirements.

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1.2.5 Operation
The operation of the cable will involve transmission of data along the fibre data cable along routes 1-
7, or portions thereof. The operation of the data cable is anticipated to be low-impact and is not
likely to result in significant negative effects on the environment. There will, however, be the need
for periodic maintenance and repair of the data cable and associated infrastructure. Contractors will
be held to the same HSE performance requirements that govern FibreCo.

The mechanisms for effecting the EMPr requirements are collectively called operational controls.
Such operational controls require that a responsible party, a budget and an implementation schedule
be specified and allocated, to further enable and facilitate implementation. Roles and responsibilities
need to be defined for implementation of the EMPr. To facilitate coordinated and purposeful
implementation, the EMPr management and mitigation measures are grouped in programmes and
plans.

1.2.6 Checking and corrective action


Checking and, if necessary implementing corrective action, form one of the components of the EMPr
management cycle. They ensure that the:

Required EMPr management activities are being implemented; and


Desired outcomes are being achieved.
As such this component will includes monitoring selected environmental quality variables as defined
in the objectives and targets.

Monitoring
The environmental features that are to be monitored are described in Section B of the Basic
Assessment Report. The management activities for these features are presented in Table 3-1 of the
EMPr. Monitoring results must be structured and presented for review on an ongoing basis so that if
objectives and targets are not met, corrective action can be taken.

Inspections: construction phase


Owing to the transient nature of the construction phase, the greatest source of information is that
obtained through ongoing visual inspection. At the same time some potential impacts are difficult to
monitor quantitatively, such as soil erosion and waste management. An ongoing, but pragmatic
inspection regime will be developed that allows for potential HSE transgressions to be identified
proactively so that mitigation can be quickly and effectively implemented.

Internal audits
Where the monitoring data and the inspection reports highlight problems, an internal audit can be
used to ascertain the source of the problem and to define action to prevent its recurrence. The three
key areas for audit are facilities (are they operating properly?), project procedures (are they properly
designed and implemented?) and finally, and perhaps most importantly Contractors HSE
performance.

Corrective action
There are several mechanisms for implementing corrective action, both during the construction and
operational phases. The main mechanisms to address transgressions include: verbal instruction (in
the event of minor transgressions from established procedure, usually following a site inspection);
written instruction (identifying source/s of problems, usually following an audit) and contract notice
(following possible breach of contract).

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Reporting
The findings of all of the above will be structured into instructive reporting that provides information
to all required parties on HSE performance, together with clearly defined corrective action where this
is seen to be required. Both the monitoring and inspections are reported on continuously. W ithin the
reporting structure it is necessary to create a review function that continuously assesses the
reporting and prescribes any necessary corrective action.

1.2.7 Management review


The final component of the EMPr management cycle is a formal management review that takes
place at defined intervals, both during the construction and operational phases. The purpose of the
management review is for senior project management to review the environmental management
performance during the preceding period and to propose measures for improving that performance
in the spirit of continuous improvement.

1.2.8 Liaison
Throughout the project, liaison will be maintained with relevant parties (authorities and/or
communities) to ensure the following:

Advance warning to communities and/or landowners, where a project activities is likely to


infringe on private land, or where project activities may have some adverse impact on
surrounding communities, e.g. clearing of construction of right of way and activities such as
blasting;
Feedback to the relevant authorities (e.g. water affairs, environmental affairs) on the
environmental performance during the construction phase of the project.

1.3 Assumptions
The assumptions for the project are as follows:

All the technical data and information provided by the proponent to the EAP and specialists are
accurate and up-to-date.

The public involvement process has been sufficiently effective in identifying the critical issues
that needed to be addressed through specialist investigations and/or by the EAP. Specialist input
has thus been appropriately scoped to investigate the critical issues.

The public involvement process has sought to involve key stakeholders and every effort has
been made to ensure that landowners affected by the development, in particular those whose
land is traversed by the development, have been provided opportunity to comment. It is
assumed that where participation has been sought from the organizational representative/s, that
these parties have the authority to comment on behalf of their organization.

FibreCo and its contractors will implement the measures contained in the EMPr.

A monitoring and evaluation system, including auditing, will be established to track the
implementation of the EMPr to ensure that management measures are effective to avoid,
minimize and mitigate impacts; and corrective action is undertaken to address shortcomings
and/or non-performances.

FibreCo and its consultants will adopt a process of continual improvement when managing
and/or mitigating negative environmental impacts arising from the project. The EMPr will be used
as the basis of environmental management and will be improved and refined regularly.

Assumptions specific to each specialist study are given in the specialist reports included as
Appendices D1 to D5 as applicable.

Printouts to be treated as uncontrolled.


1.4 Uncertainties
Uncertainties are as follows:

The outcome of the land acquisition/negotiation for use of servitudes has not been finalised and
falls beyond the scope of this BA and EMPr.

Although locations of repeater sites are presented in the project documentation, the exact
location of the repeater sites can only be determined once the routing is finalized following the
conclusion of the servitude negotiation process and final route determination.

2 The Proposed Project


2.1 Optic fibre data cable
Data cable design will be finalised in an iterative manner during the course of the Project planning
and design phase. The following design detail is available for the pipeline at this stage:

The project entails the establishment of a long-haul fibre optic data cable network throughout
South Africa to carry data communications over long distances and at higher bandwidths than
are currently available in the market.
Additional routes between the major centres will be required for purposes of providing resilience
to the solution. This will entail alternative routes between the centres to provide a geographically
diverse path between the end-points. Fibre optic technology allows long distances to be
spanned with few repeaters. It is envisaged that a repeater will be situated approximately every
80 to 100km along the route housed in existing base station site infrastructure owned by one of
the promoters of the project. Prefabricated Telco grade equipment shelters will be constructed at
2
repeater sites to house approximately 30m of optical amplification equipment racks (typically 8
racks) with cooling units and backup generator. The facilitys primary power source will be the
national grid using existing transmission cables.
The data cable will have end point and repeater stations located as follows:
Table 2-1 End point and Repeater sites

SiteID StartRdNm StartRoute SiteRdNm Route LatDMS LongDMS Start Mid End

IS032 N1 N1 MAIN ROAD M71 26 2' 6.333" S 28 1' 36.316" E Y

IS032 N1 N1 MAIN ROAD M71 26 2' 34.837" S 28 1' 25.969" E Y

IS032 N1 N1 MAIN ROAD M71 26 2' 7.027" S 28 1' 33.497" E Y


27 56' 37.320"
RE020 N1 N1 R554, Rural R554 26 20' 7.080" S E Y

RE020 N1 N1 - - 26 19' 58.854" S 27 56' 4.589" E Y

RE020 N1 N1 - - 26 20' 2.227" S 27 56' 2.537" E Y


27 37' 22.020"
RE021 N1 N1 - - 26 53' 19.261" S E Y
27 37' 20.750"
RE021 N1 N1 - - 26 53' 22.605" S E Y
27 36' 38.713"
RE021 N1 N1 Rural - 26 53' 22.855" S E Y
27 15' 23.732"
RE009 N1 N1 - - 27 37' 7.565" S E Y

RE009 N1 N1 - - 27 37' 40.313" S 27 15' 5.842" E Y

Printouts to be treated as uncontrolled.


SiteID StartRdNm StartRoute SiteRdNm Route LatDMS LongDMS Start Mid End
R34, 27 14' 49.788"
RE009 N1 N1 R34, R721 R721 27 35' 54.449" S E Y

RE007 N1 N1 N1 N1 28 5' 21.436" S 27 8' 26.100" E Y

RE007 N1 N1 N1 N1 28 5' 26.112" S 27 8' 21.235" E Y

ST AT IO
N
ST REET ,
BAYFOR
D
RE007 N1 N1 ST REET , - 28 5' 23.290" S 27 8' 16.920" E Y
ERASMU
S 26 42' 40.732"
RE010 N1 N1 - REET
ST - 28 46' 56.007" S E Y
26 42' 25.414"
RE010 N1 N1 - - 28 47' 9.405" S E Y
26 42' 34.200"
RE010 N1 N1 R703 R703 28 47' 21.840" S E Y
NELSON
MANDEL
IS022 A DRIVE N8 - - 29 6' 36.390" S 26 12' 8.905" E Y
NELSON
MANDEL 26 12' 55.687"
IS022 A DRIVE N8 - - 29 6' 35.883" S E Y

T HIRD
AVENUE,
KELLNER
ST REET ,
NELSON FIRST
MANDEL AVENUE, 26 12' 27.000"
A DRIVE BARNES
IS022 N8 - 29 6' 32.263" S E Y
ST REET
NELSON
MANDEL 26 12' 55.687"
IS033 A DRIVE N8 - - 29 6' 35.883" S E Y

MARKGRAA
FF ST REET ,
SAINT
GEORGE
NELSON S
MANDEL ST REET, R706, 26 12' 56.509"
IS033 A DRIVE N8 CHURC M30 29 6' 34.932" S E Y
H
ST REET

2.1.1 Construction and installation

Construction of the fibre data cable and associated infrastructure is anticipated to commence in mid
2011, following the issuing of requisite authorisations. The construction phase will take 12 months
and the cable commissioned in 2012. The expected lifespan of the cable is more than 20 years. The
process of establishing an optic fibre data cable will include the following:

Planning will be carried prior to the commencement of excavation. This phase of the project will
include surveying of the route to identify physical features that occur along the route and prepare as
constructed records (e.g. layout plans that show the length and depth of cables, indicate places
where directional drilling will occur and provide High Voltage cable points and material and
equipment schedules, amongst others.) It will also be necessary to obtain information about all
utilities that the cable will cross. All approvals and authorisations for development and crossings (e.g.

Printouts to be treated as uncontrolled.


transmission lines, railway lines, telecommunications and water pipes) will be obtained during the
planning phase of the project. A management plan will be prepared setting out the measures that
aim to avoid and/or mitigate potential risks, hazards and impacts.

Trenching and excavations will commence once the requisite approvals and authorisations have
been obtained from relevant authorities (e.g. South African National Roads Agency Limited (SANRA L)
regional managers approval of the plans, environmental authorisation and water use licences).
Trenches will be excavated to provide a minimum cover of 0.9 metre using various construction
methods (e.g. backacter to excavate soil and pecker or jackhammers to break rock before removing
with a backacter). Excavation will take place in a manner that aims to avoid damage to existing
utilities. Once the excavation has been completed, suitable bedding material (e.g. soil or sand) will be
placed in the bottom of the trench. W here the excavated material is not suitable for this purpose,
material will be obtained from existing permitted borrow pits. In urban areas, excavated material will
be handled in accordance with the requirements of the relevant local authori ty . Direction al drilling will
be undertaken in places where the cable cros ses key lines of infrastr uc tur e (rail, national roads etc.)
and will be suitably aligned and sufficiently deep so as to comply with legislation and authorities
guidelines. Buried hand holes will be established every 900m along the fibre optic data cable route. In
addition, round man holes (with visible 600 to 800mm covers) will
occur on average every 4km along the cable route or on either side of a physical feature crossing
(bridge, rivers etc.).

Duct laying will take place directly from a drum spindle mounted on an excavator moving along
the trench. To avoid slackness in the duct, cable drums will be positioned in line with the direction of
the duct pull. The cable will be kept clear of any abrasive material when being pulled into position to
prevent damage to the duct sheath. The duct will be bedded in sand/soil which shall extend 100mm
around the duct. The duct will be uniformly bedded in soil free of rocky material. The depth of cover
of cables will be approximately 950mm. Conduits will be used where appropriate, notably within a
bridge, rail, road and water course crossing. Hand holes will be located approximately every 900m
along the route.

Reinstatement will take place in accordance with authorities requirements. In urban areas,
excavated land will be returned to its original condition. Trenches will be backfilled and compacted to
original ground level. Spoil and approved backfill material will be placed in such a manner so as to
avoid future subsidence. Stones, rock and paving material will be removed from site. Trees within
the affected area will be protected as far as possible.

All activities, notably those involving the installation of the fibre optic data cable, will adhere to the
requirements of the legislation dealing with occupational health and safety and public safety. Special
attention will be given to these issues when working in close proximity to traffic as well as overhead
power transmission lines.

2.1.2 Start and end points of data cable


The data cables will start and end at a designated IS/Teraco premises. Presently the following
start/end points have been identified:

Main Road, Bryanston, Johannesburg;



Barnes Street, Bloemfontein.

Printouts to be treated as uncontrolled.


2.1.3 Design and equipment standards
The design and equipment standards for the data cable and its associated infrastructure will comply
with national and international standards and best practices. The data cable will be designed to
have a minimum lifespan of 20 years. Due to changes in technology it will be costly to upgrade the
existing cable beyond this lifespan. It is therefore likely that the fibre will be removed and the duct
abandoned.

2.1.4 Monitoring
Monitoring of the data cable, and its associated infrastructure, is essential to ensure efficient
operation. Measures will be instituted to ensure a best practice HSE system is developed and
implemented to ensure that personnel are properly trained to carry out their work.

For the first 12 months after installation of the data cable, rehabilitation measures will be monitored
to ensure problems such as erosion and alien plant infestation are rectified.

2.2 Construction phase


Pre-construction activities will include: preparation of plans; obtaining of wayleaves and permits;
servitude establishment where the route/infrastructure falls outside the national and provincial road
reserves; land surveying; establishment of construction campsite/s; building of access roads; and
clearing of vegetation and removal of obstructions in the path of the proposed data cable.

2.2.1 Scale and pace of construction


It is envisaged that construction will happen concurrently, with a suitable number of separate
construction teams working on different portions of the route corridor simultaneously. It is envisaged
that there will be between 2 and 4 construction teams operating on the development at any one time.
The final number will be determined by ZTE and will take into account a number of factors, including
time and cost.

The average rate of progress of construction will be strongly dependent on ease of excavation and
may vary from a kilometre a day to 50m per day depending on the terrain. The temporary
construction right of way required will be approximately 5-7m.

2.2.2 Construction process


The construction process is as follows:

An open ditch will be dug using excavators, backacters, specialised trenching plant and manual
labour. Topsoil will be set aside during excavation and will be replaced on the reinstated trench
prior to revegetation. This will be carried out in accordance with the SANRAL and provincial
government requirements;

The cable (ducting) will be laid on a bedding layer approximately 100mm thick and covered with
the same material to protect it from abrasion through contact with surrounding rock. Material for
the bedding will be sorted from excavated material for the trench wherever possible. W here this
is not feasible, sand will be sourced from existing mining operations, thus avoiding the need for
new borrow pits;

The trench will be backfilled with stockpiled material from the excavation of the trench. Topsoil
will be replaced on the soils surface. Erosion protection measures, where necessary, will be put
in place including packing trench walls with sand bags (Hessian bags filled with soil) to prevent

Printouts to be treated as uncontrolled.


washout of material. Alternatively, the duct will be encased where required for reasons including
constructability in rock; and

River crossings will be undertaken using the following construction methods:

o Horizontal directional drilling of a parabolic-shaped tunnel under large rivers to minimize


or avoid disturbance of the river;

o Open cuts of seasonal rivers made at right angles to reduce the length of the crossing,
and can be backfilled with concrete to reduce the risk of erosion damage; and
o Pipe jacking will be carried out as required, based on financial considerations.

When horizontal directional drilling is undertaken, it is anticipated that approximately 60 litres of


sludge will be generated per metre of drill. The sludge will be settled out in construction ponds.
Bentonite used in the drilling process will be extracted from the sludge and reused.

2.2.3 Energy, water, sanitation and waste requirements


Temporary construction camps will be established where required in remote areas. There will be
energy and water use requirements (to be determined and supplied by ZTE). W ater use will be
limited to domestic and cooling purposes, and must be arranged by ZTE from authorised supplies.
Sewage and waste generated by activities of the construction camp will need to be disposed of.
During the lifespan of the project electronic components will need to be updated and replaced from
time to time. E-waste generated will be suitably disposed of at a registered landfill site.

2.2.4 Employment
It is anticipated that the greatest number of 300 new jobs will be created during the construction
phase of the project (i.e. about 30 jobs for the Johannesburg to Bloemfontein route). These
employment opportunities will require a combination of both skilled and unskilled labour in a range of
technical fields. W herever possible, workers will be recruited from the local area.

2.3 Operational phase


2.3.1 Transmission of information
The system will comprise of a network of glass optical fibre strands (thin strands of very pure glass
each about the size of a human hair) bundled together with various layers of protection to form a
composite data cable. The cables do not contain any insulating oils or other hazardous substances.

At either end of a cable system there will be a range of electronic and optical equipments housed
within an existing building generally in metro sites. These optical devices convert electrical signals
from traditional telecommunication sources into a light signal through a laser diode and transmit a
multitude of coloured laser signals inside the glass optical fibre strands from one end of the system
to the other end. There are no electrical signals sent along the system and therefore no risk of
electromagnetic interference, induction or leaks.

Due to the properties of the glass fibres leading to attenuation and power dissipation of the laser
signal over distance, there will be signal amplification sites situated at every 80 km 100 km along a
single fibre route, and at every 200km 250km the signal will be regenerated by similar optical
transmission equipment. These sites will typically house a series of electronic equipments inside a
standard convert the laser signal into an electromagnetic signal and boost it up for re-transmission.

The laser diodes are all Class 1M products that conform to the IEC 60825-1 which states a
maximum power of 100mW and they also have built in sensors that shuts the system down when

Printouts to be treated as uncontrolled.


there is a fibre break (this works through a detection of a reflected signal when a fibre strand is cut).
This ensures that the IEC EYE SAFE standards are also met along the whole network.

2.3.2 Safety and security


The operation of the cable and its associated end points will be monitored by trained personnel.
Regular maintenance checks will also be undertaken.

2.3.3 Energy, water, sanitation and waste requirements


Transmission of data will be powered by electricity drawn from the national grid with backup
generators in the case of power failures. Energy will be provided by Eskom and local authorities via
the national electricity grid. There will be the requirement for on-site ablution facilities at data end
points and repeater sites. Water use will be limited to domestic and cooling purposes, and will be
the responsibility of ZTE.

2.3.4 Monitoring
Monitoring of the data cable route and its associated infrastructure will need to be carried out for the
first 12 months after installation and rehabilitation to ensure problems such as erosion caused by
surface runoff are rectified.

2.3.5 Employment
During the operational phase, employment opportunities will be limited to technical staff responsible
for the maintenance and safety of data cable. It is anticipated that the project will create 100
permanent jobs (i.e. about 10 jobs for the Johannesburg to Bloemfontein route).

2.4 Decommissioning
It is envisaged that the data cable will be operational for 20 years. Fibre will be removed and the
ducting will be left in situ following decommissioning. Equipment at repeater sites and at data end
points will be removed and suitably disposed of and/or reused.

3 Impact mitigation and management


3.1 Links with the Basic Assessment
This chapter describes the mitigation and management measures required to respond to the
potential impacts identified. These measures are presented in Table 3-1. To facilitate cross
referencing, impact identification numbers are provided in the BA and the EMPr.

Section 3.3 of this document describes the management plans within which management and
mitigation measures will be implemented. The rationale is to cluster related measures in a cohesive
and systematic structure, ensuring clear roles and accountable management, together with
integrated and efficient implementation.

3.2 Mitigation and Management Measures per Phase


Refer to Table 3-1 below.

Printouts to be treated as uncontrolled.


Table 3-1: Mitigation and management measures relating to impacts caused by project activities during all project phases

Aspect / feature Impact Impact Management activity Schedule Management plan


reference
Prec Con Op Cl

Biophysical
Flora and fauna B1, B2, B3 Impacts on terrestrial Set up measures to ensure that during preconstruction and construction, impacts on Construction
biodiversity ecology sensitive ecological areas and individual protected biota are minimized and avoided management plan
through careful routing of the data cable and management programmes plans and Decommissioning plan
procedures during construction.
Land acquisition and
B4, B5, B6, Impacts on aquatic ecology Make certain that routing of the cable avoids and minimizes impacts on wetland and compensation plan
WW1, WW5, riverine habitat during the preconstruction and construction phase. Communication and
B7 Spread of alien invasive Apply appropriate measures during construction phase to avoid and/or minimise the information plan
species spread of alien invasive species.
Soils and land SLC1, SLC3, Impacts on soil Ensure that measures are taken to rehabilitate disturbed areas during the construction
capability SLC4 and operational phase. In instances where the route may depart from the road reserve,
it is necessary to negotiate with landowners to ensure that land is sterilised.
SLC2 Erosion potential Set up measures to ensure that soil erosion along the length of the data cable is
prevented and proactively managed.

Wetlands and WW1, WW3, Impact on flow Apply appropriate routing as well as wetland and river crossing methods to minimize
watercourses WW6, WW7, A2 disruption these systems.
WW2, WW4, Impact on water quality Implement preventative design, monitoring and management measures during the
WW8, EQ1, preconstruction and construction and operation.
EQ2
WW6, WW7 Impacts caused by flooding Ensure alignment, design and construction of the cable result in effective measures to
minimize risk from flooding for the operational cable.
Environmental EQ1, EQ2, Impacts to the quality of the Develop and implement effective measures for minimisation of littering, contamination,
quality EQ3, AQ1, environment siltation and dust during the construction phase, followed by timeous rehabilitation.
EQ4 Reduction of airspace in Measures should be taken to limit the amount of spoil soil or rock that is disposed in
landfill sites landfill sites during the construction phase.

Socioeconomic
Servitudes, services SS11, SSI2, Impacts on services and Ensure that measures are implemented to avoid and minimise disruption to existing Construction
and infrastructure SSI3 infrastructure services and infrastructure during the preconstruction and construction phase. management plan
Aspect / feature Impact Impact Management activity Schedule Management plan
reference
Prec Con Op Cl

Traffic T1, T2 Obstruction of road traffic Put measures in place to ensure that disruption of road users are avoided or minimised Construction
and risk to road users during the preconstruction and construction phase. management plan
Communication and
Agriculture A1, A2 Impacts on agricultural Implement measures to ensure that farming is not affected during the construction information plan
activities phase.
Community safety plan
Cultural resources
management plan
Labour and human
resources plan
Visual V1 Impact on landscape Make certain that visual impacts are avoided or minimised during the construction and
aesthetics operational phase. Ensure that rehabilitation is implemented promptly following laying Community safety plan
of the data cable. Soil conservation
management plan
Noise N1 Disturbance to nearby Implement measures during the preconstruction and construction phases that control
landowners and residents noise impacts. Land acquisition and
compensation plan
Health and safety HS1, HS2, HS3 Risk to safety of workers Implement measures that ensure the safety of workers and the general public during Social responsibility plan
and general public the construction. Wildfires should be avoided.
Cultural heritage CH1, CH2 Impacts on cultural heritage Develop and implement appropriate measures to avoid and minimise the damage or
resources destruction of paleaontological material as well as archaeological and historical
artefacts during preconstruction and construction. Obtain permits for cultural resource
management sites from SAHRA.
Economic E1, E2, E3 Positive impacts on job Ensure that the employment opportunities, service efficiency and communication is
creation, service costs and maximised. Coordinate an effective communication programme with local authorities,
communication SANRAL and provincial roads agencies during preconstruction, construction and
operation phases.
3.3 Management plans
3.3.1 Rationale
The majority of mitigation measures outlined in Table 3-1 cannot be implemented as discrete,
isolated actions, since there are spatial and causal interactions amongst impacts. Therefore it is
advisable to implement mitigation and management actions via integrated management plans.
These plans are outlined below. W hile generally the principles guide preconstruction and
construction, operational and decommissioning phase plans, some of them start during construction
and continue into decommissioning, such as soil conservation management, air quality and water
management. The following management plans need to be implemented during construction and
maintenance of the fibre optic data cable:

Construction management plan (Section 3.3.2);

Labour and human resources plan (Section 3.3.3);

Workplace health and safety plan (Section 3.3.4);

Community safety plan (Section 3.3.5);

Land acquisition and compensation plan (Section 3.3.6);

Emergency management and response plan (Section 3.3.7);

Social responsibility plan (Section 3.3.8); and

Decommissioning plan (Section 3.3.9).

Many of the issues to be addressed in these plans are regulated in existing laws, regulations and
guidelines. In addition, it is recognised that the content of several plans will be generic, in the sense
that existing procedures are documented in standard codes of practice, and that adaptations of such
generic plans will only be possible as a dynamic process during construction and operation. Plans
presented below, therefore, contain specific actions as well as undertakings to prepare additional
plans as required prior to the commencement of certain activities during the detailed design phase.
FibreCo recognises the need for ongoing development and revision of all plans to ensure their
continued applicability.

3.3.2 Construction management plan


The construction management plan to be implemented by ZTE shall include the following key
measures:

Management of construction campsites


1. The Contractor shall comply with all relevant laws and regulations concerning water provision,
sanitation, wastewater discharge and solid waste disposal. ZTE is referred, in particular, to the
requirements of the National W ater Act (Act 36 of 1998) and related regulations, as well as
requirements contained in the W UL.

2. ZTE shall not locate campsites in any area in which vegetation is pristine, nor within 100 m of any
watercourse, nor in any area that could cause nuisance or safety hazards to surrounding
landowners, inhabitants or the general public. The location of a construction campsite requires prior
landowner agreement.

3. Prior to the commencement of construction, ZTE shall also prepare documentation for each proposed
campsite which contains, but is not limited to, details of: (a) site layout; (b) topsoil
management; (c) sewage treatment; (d) solid waste disposal; (e) erosion control (f) fencing; (g) litter
management; (h) provision for vehicle and plant servicing; (i) management of hazardous materials, (j)
water supply, (k) management of veld fire risk (l) rehabilitation; and (m)security. The documentation
shall be submitted to FibreCo as a part of ZTEs project specific Environmental Plan prior to
establishment on site.

4. ZTE shall access construction campsites in compliance with this EMPr.

5. ZTE shall keep construction campsites clean and tidy at all times. ZTE shall not leave domestic waste
uncontained, and temporary storage shall be fenced to keep out people and animals. No permanent
domestic waste disposal shall be permitted at the campsites. All domestic refuse is to be removed
weekly to an existing licensed domestic landfill.

6. ZTE shall take specific measures to prevent the spread of veld fires, caused by activities at the
campsites. These measures may include appropriate instruction of employees about fire risks and the
construction of firebreaks around the site perimeter.

7. ZTE shall prevent accelerated erosion from construction campsites and shall not discharge polluted
runoff into drainage lines.

Management of fuels and other hazardous materials


8. ZTE shall comply with all applicable laws, regulations, permit and approval conditions and
requirements relevant to the storage, use, and proper disposal of hazardous materials.

9. ZTE shall manage all hazardous materials and wastes in a safe and responsible manner, and shall
prevent contamination of soils, pollution of water and/or harm to people or animals as a result of the
use of these materials.

10. ZTE shall prepare a hazardous materials and waste management plan for inclusion in the site
specific Environmental Plan to be submitted to FibreCo prior to establishment on site. This plan shall
include, but shall not be limited to, measures to prevent: (a) contamination of soils; (b). pollution of
water; (c) safe siting and storage; (d) containment of lubricants and waste oil during maintenance of
vehicles; and (e) tampering with tanks.

11. ZTE shall classify all hazardous materials to be used on site according to recognized Codes of
Practice such as SABS Code 0228 for the Identification and Classification of Dangerous Substances
and Goods and the DW AF Minimum Requirements for the Handling, Classification and Disposal of
Hazardous W aste, and shall ensure that the handling, storage, transport and disposal of these
materials meets the requirements of these Codes.

12. ZTE shall not locate fixed fuel storage tanks in any location other than at approved plant yards or
campsites. Any fuel storage facilities with a capacity greater than 1000 litres shall be located on flat
or gently sloping ground and shall be bermed from the surrounding area to contain at least
125% of the total capacity of the storage containers. The berms and the floor of the bermed area shall
be of impermeable material or be lined to ensure that petroleum products cannot escape.

13. ZTE shall not construct fixed fuel storage or service or refuel any vehicle or equipment within 100m of
a watercourse or wetland, within a floodplain, or where there is the potential for spilled fuel to enter a
watercourse or groundwater. Should it not be possible to establish suc h a facility outside of the
100m zone, ZTE shall ensure that the necessary precautions are taken to prevent and clean up
spillages, including spill kits on the bowsers.

14. ZTE shall enclose all fixed storage by a security fence with a lockable gate.

15. When crossing watercourses and wetlands, ZTE shall place on-site tools and equipment, such as
pumps, compressors and generators on bermed impermeable sheeting (e.g. polyethylene or
other similar material) to prevent hydraulic fluid or fuel leaks from contaminating soil or groundwater
or entering any watercourse or wetland.

16. ZTE shall take all reasonable precautions to prevent fuel and lubricant spills during the course of
construction. To this end, ZTE shall ensure that: (a) there is no overfilling of diesel bowsers and
equipment tanks; (b) regular audits are performed to verify that no leaking or defective equipment is
brought onto site; and (c) any oils or lubricants discharged during routine vehicle servicing on site are
captured using drip trays, containers or other appropriate containment measures.

17. ZTE shall ensure that all equipment which is required to work in fish-bearing waters is cleaned of oil,
grease and other contaminants damaging to aquatic life.

18. ZTE shall ensure that fuelling and repairs are carried out or supervised by personnel familiar with
spill containment and cleanup procedures.

19. ZTE shall ensure that there is sufficient absorbent material available on site to manage accidental
spills. ZTE shall immediately clean up accidental spillages of fuels and oils, or other hazardous
substances, and shall report the incident to FibreCo and the measures taken to remediate the spill
problem.

Management of the construction right-of-way


20. ZTE shall obtain access to and along the cable (a) on a public road (b) on an existing private road or
track with the consent of the relevant owner or occupier of land (c) along the cable and construction
right-of-way and (d) along a specially approved route as defined below. Access to, and along the
construction right-of-way explicitly excludes access to land other than the access routes referred to
above.

21. The category of specially approved route is for cases where there is no existing access. A specially
approved route is one for which the relevant owner or occupier of land has given consent, and for
which approval has been applied for in writing, and granted in writing by FibreCo, subject to any
conditions that the landowner or FibreCo consider to be warranted (e.g. regarding erosion control,
rehabilitation). No specially approved routes will be granted if areas of pristine habitat are to be
impacted.

22. The utility and safety of any existing access shall not be lowered by use for the construction work or
construction-related activities, nor shall spillage, littering, accelerated erosion, or other environmental
impact, occur. ZTE shall: (a) ensure compliance with these requirements; (b) exercise all relevant
health, safety and environmental controls (including dust control, nois e abatement and litter
prevention); and (c) remedy immediately any non-compliance and the effects thereof.

23. In all areas where construction requires gravelling or other methods of improving vehicle access, ZTE
shall completely remove these materials after construction and prior to rehabilitation of the area.

24. ZTE shall restrict the number of entry and exit points for security reasons. ZTE shall ensure that his
activities do not compromise the landowners or occupiers security, nor result in the loss, injury or
death of any farm animals or game.

25. The dismantling of gates and fences shall be subject to any special conditions reached in the
servitude agreements between FibreCo and landowners.

26. The Contractor shall prevent littering and the random discard of solid waste on the site. The
Contractor shall not dispose of any waste in the data cable trench.

27. ZTE shall manage hazardous waste as described in provisions 8 to 19.


28. ZTE shall minimise the risk of bush fires.

29. ZTE shall prevent trespassing on the site. Public entry to the site shall be prohibited and signs to this
effect shall be erected at points of potential public entry.

30. ZTE shall prohibit and actively monitor and prevent poaching or harassment of animals by contract
employees. Any employee found poaching shall be dismissed.

31. At the start of every working day ZTE shall patrol the open trench and rescue any animals that are
trapped in it either by catching and releasing (e.g. frogs and toads) or by driving out (e.g. dangerous
snakes).

32. ZTE shall prohibit and actively monitor and prevent the harvesting of medicinal or any other
plants by contract employees.

33. ZTE shall ensure that contract employees remain within the construction right-of-way or on approved
roads providing access to the construction right-of-way.

34. ZTE shall determine safe off-road travelling speeds for each section of the route corridor along the
right-of-way and shall ensure that these restrictions are enforced.

Emergency preparedness (see also Section 3.3.7)


35. ZTE shall develop an emergency plan that will enable rapid and effective response to all types of
environmental emergencies in accordance with recognized national and international standards.

36. The emergency plan shall include the establishment of a network of communication between ZTE
and emergency services including police, traffic police, local medical and ambulance services, fire
departments, farmers associations, cons ervancies, farmer neighbourhood watches, etc.

37. ZTE shall test emergency preparedness on a regular basis and review procedures to remedy
shortcomings to ensure a high level of emergency readiness to deal with environmental and third
party incidents.

Fire prevention and management


38. ZTE shall take all necessary precautions to prevent the ignition of veld fires caused either
deliberately or accidentally as a result of the work being performed.

39. ZTE shall prepare a fire prevention and fire emergency management plan as a part of the
Environmental Plan to be submitted to FibreCo prior to establishment on site. The plan shall include,
but not be limited to, the following: (a) sources of fire risk; (b) measures to comply with any
requirements of local authority fire departments; (c) measures to meet requirements agreed between
FibreCo and the landowner; (e) measures to minimize the risk of accidental veld fires caused by any
activity related to the work; and (f) measures to control an acc idental veld fire.

40. ZTE shall provide adequate fire fighting equipment at specified localities on the work site to meet any
emergency resulting from ignition of a veld fire. This equipment should include, but not be limited to,
(a) fire extinguishers; and (b) fire fighting flails.

41. The areas of commercial plantations through which the data cable is routed are particularly sensitive
to fire hazard (such as in commercial forests) and ZTE shall strictly comply with all fire management
requirements set by the owners of these plantations.

42. ZTE may expect that hot work will be prohibited under specified meteorological conditions and that
appropriate and adequate fire fighting equipment would be required to be on standby at all times
where hot work is being carried out.
43. Wherever practicable, bush shall not be cleared using burning. In instances where this is possible,
controlled burning can only take place upon request of and approval from the landowner, and when
there is no wind and appropriate fire fighting equipment is in attendance.

Management of dust and noise nuisance


44. The Contractor shall control dust along the construction right-of-way so as to ensure that no
detrimental effects to landowners, occupants or the general public are c aused. Control measures to
be considered include the use of water bowsers to wet down surfaces that have been denuded and
which have the potential to generate dust.

45. The Contractor shall comply with the legal requirements for the management of noise impact
specified in the Noise Regulations under the Environment Conservation Act (Act 79 of 1989). If
instructed to do so by FibreCo, ZTE shall demonstrate compliance with the noise regulations by
means of measurement of residual noise levels at receiver points specified by FibreCo. Measurement
shall be in accordance with the requirements of the noise regulations.

46. In the event that this should be required, ZTE shall notify all landowners and inhabitants within 200m
of a blast zone of the dates and times at which blasting is scheduled to occur. Blasting shall not be
undertaken between the hours of 18h00 and 07h00 without the agreement of the affected landowners
and occupiers.

47. ZTEs employees shall not make recreational use of all-terrain vehicles or motorcycles on the site.

Land owner and occupier relations


48. ZTE shall respect the property and rights of landowners and occupiers at all times and shall treat
all such persons with deliberate courtesy.

49. ZTE shall comply with all special agreements between FibreCo and affected landowners provided in
the Servitude Agreements and/or the Property Line List and/or required in terms of relevant national
legislation.

50. Access over land, the integrity of fences, the closure of gates, control of veld and forest fires, littering,
dust control, noise abatement, harassment of domestic and wild animals, sedimentation and
contamination of ground and surface waters, damage to landscape and vegetation, and all such
environmental matters, shall be controlled, as far as practicable, by the Contractor in the best
interests of the land owner or occupier.

Complaints register
51. ZTE shall establish and maintain a register for periodic review by FibreCo that logs all complaints
raised by landowners, occupiers or the general public about construction activities. The register shall
be regularly updated and maintain records, including the name of the complainant, his or her
domicile and contact details, the nature of the complaint and if any action that was taken to rectify
the problem.

Health management
52. ZTE shall comply with all relevant legislative requirements governing worker health and safety (e.g.
Occupational Health and Safety Act (Act 85 of 1993) and related amendments and regulations).

53. ZTE shall also prepare and implement a programme to minimize the spread of HIV infection
as a result of the construction contract. The programme shall be prepared with the
assistance of a medical doctor with experience of HIV prevention and treatment.
Control of construction activities in sensitive areas
54. Prior to the commencement of construction activities, ZTE shall (together with the ECO) survey the
limits of the construction right-of-way and of any additional workspace areas required for
construction and shall mark the limits using 1.5m long stakes at 200m maximum intervals. These
stakes shall be preserved throughout the work under contract. In the areas where pristine habitat is
affected, the stake interval shall be reduced to 50 m spacing and the stakes shall be painted a
conspicuous colour.

55. In these areas, the Contractor shall take the following additional precautions: (a) staff and, in
particular, machine operators shall be specifically instructed about the sensitivity of the areas; (b)
vegetation clearance shall be restricted to the absolute minimum necessary to provide access along
the construction right-of-way; and (c) site staff responsible for environmental management shall
increase the frequency of monitoring in the areas to verify continuing compliance with the
environmental standard and the restriction of vehicle traffic to within the construction right-of-way.

56. ZTE shall erect a physical barrier (e.g. a removable fence) to ensure that there is no unauthorized
access of any other areas by construction workers, or as specified in the servitude negotiations with
the affected parties.

57. In sections of the route corridor, where the data cable crosses the escarpment and where steep and
rugged terrain is experienced, ZTE shall prepare a detailed method statement for review and
approval by FibreCo prior to construction. The method statement shall include details of: (a) access
requirements and the construction of any necessary access roads; (b) any areas of cut and fill
required to complete the works; (c) an itemised list of equipment that will be used for the excavation,
laying of cable and backfilling of the trench; (d) measures to ensure the management of erosion
during the construction of the work; and (e) measures that will be used to stabilise and rehabilitate the
completed works. Such measures will need to consider special methods of retaining topsoil on the
slopes by reducing rainfall impact, re-vegetation methods that are less prone to erosion loss (veld
sod) and any other necessary measures to ensure that rehabilitation is effective.

58. Damage or harm to threatened plant species is illegal in terms of legislation. Threatened species are
defined in terms of the most recent Red Data list of Southern African Plants. While every effort has
been made to ensure that the data cable route corridor does not impact on threatened species, ZTE
shall be solely responsible for any action necessary to ensure the prevention of harm to such
species found during construction. In the event that ZTE, FibreCo or any other party in any area that
could be damaged by the works finds a threatened plant, this shall immediately be reported to
FibreCo and the relevant authority (SANBI or one of the Parks Boards as relevant). ZTE shall call
upon a suitably qualified botanical expert to oversee: (a) rescue of the plant(s) and transplantation in
a suitable local habitat in a conserved area or in a recognised botanical garden; or, where this is not
possible; and (b) the collection of seeds and cuttings for use at botanical gardens and for storage in
seed banks.

59. ZTE shall take note of the possible occurrence of threatened animals and, in particular, antelope near
the data cable route corridor. ZTE shall be particularly vigilant in these areas in order to ensure that
none of these animals are deliberately or accidentally harmed.
Table 3-2 Specific requirements for the siting of the cable trench and repeater sites

ID Latitude Longitude Province Nearest Description Specific Mitigation Measure


Town/City
ECOLOGY
1 -26.283611 27.946944 Gauteng Naturena Indigenous Avoid/minimise damage to
vegetation habitats. Control construction
activities in these areas.
Rehabilitate.
2 -26.319444 27.941389 Gauteng Nancefield Indigenous Avoid/minimise damage to
vegetation habitats. Control construction
activities in these areas.
Rehabilitate.
3 -26.326944 27.938056 Gauteng Nancefield Indigenous Avoid/minimise damage when
vegetation crossing the wetland.
Investigate fixing cable to the
bridge.
4 -26.328611 27.937222 Gauteng Nancefield Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
5 -26.330556 27.936111 Gauteng Nancefield Indigenous Avoid/minimise damage when
vegetation crossing the wetland.
Investigate fixing cable to the
bridge.
6 -26.397767 27.8934 Gauteng Ennerdale Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
7 -26.4235 27.8751 Gauteng Ennerdale Sensitive habitats Avoid/minimise damage to
South habitats. Control construction
activities in these areas.
Rehabilitate.
8 -26.562517 27.80355 Gauteng Sebokeng Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
9 -26.580533 27.796017 Gauteng Sebokeng Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
10 -26.605117 27.7841 Gauteng Sebokeng Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
11 -26.626633 27.806683 Gauteng Sebokeng Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
12 -26.647583 27.745433 Gauteng Vanderbilpark Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
13 -26.68335 27.713283 Gauteng Vanderbilpark Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
14 -26.7734 27.667017 Gauteng Sasolburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
15 -26.843617 27.640217 Gauteng Sasolburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
16 -27.025217 27.56025 Free State Parys Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
17 -27.077467 27.5423 Free State Vredefort Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
18 -27.09455 27.536417 Free State Vredefort Sensitive habitats Avoid damage to habitats when
crossing pan. Control
construction activities in these
areas. Rehabilitate.
19 -27.172867 27.509433 Free State Koppies Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
20 -27.21575 27.4982 Free State Koppies Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
21 -27.231683 27.496567 Free State Koppies Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
22 -27.293683 27.467833 Free State Koppies Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
23 -27.305083 27.459733 Free State Koppies Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
24 -27.353417 27.417555 Free State Koppies Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
25 -27.426767 27.374117 Free State Kroonstad Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
26 -27.4367 27.367183 Free State Kroonstad Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
27 -27.501033 27.323017 Free State Kroonstad Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
28 -27.5254 27.3057 Free State Kroonstad Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
29 -27.662733 27.252533 Free State Kroonstad Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
30 -27.725917 27.236267 Free State Kroonstad Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
31 -27.732933 27.233917 Free State Tierberg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
32 -27.897067 27.2064 Free State Ventersburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
33 -27.919133 27.203433 Free State Ventersburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
34 -28.03375 27.165017 Free State Ventersburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
35 -28.093533 27.13595 Free State Ventersburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
36 -28.1046 27.129017 Free State Ventersburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
37 -28.2334 27.08795 Free State Ventersburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
38 -28.370267 27.05195 Free State Winburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
39 -28.568067 26.956767 Free State Winburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
40 -28.601767 26.955533 Free State Winburg Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
41 -28.631833 26.903433 Free State Pleasant View Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
42 -28.674883 26.838783 Free State Scotland Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
43 -28.73415 26.842433 Free State Herbou Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
44 -28.817533 26.664733 Free State Geluk Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
45 -28.842917 26.5995 Free State Palmietvlei Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
46 -28.851583 26.573433 Free State Fairfield Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
47 -28.86485 26.53595 Free State Vlakfontein Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
48 -28.899767 26.471033 Free State Noord Sensitive habitats Avoid/minimise damage to
Amerika habitats. Control construction
activities in these areas.
Rehabilitate.
49 -28.91445 26.4506 Free State Amerika Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
50 -28.960267 26.36575 Free State Bloemfontein Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
51 -28.96205 26.359317 Free State Bloemfontein Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
52 -28.96795 26.335517 Free State Bloemfontein Sensitive habitats Avoid/minimise damage to
habitats. Control construction
activities in these areas.
Rehabilitate.
HERITAGE
1 -26.3353 27.9437 Gauteng Twin Oaks Historic buildings Contact archaeologist to
conduct field survey (Phase 1)
2 -26.8896 27.6108 Free State Parys Historic buildings Contact archaeologist to
conduct field survey (Phase 1)
3 -27.5984 27.2472 Free State Kroonstad Historic buildings Contact archaeologist to
conduct field survey (Phase 1)
4 -28.0898 27.1381 Free State Ventersburg Historic buildings Contact archaeologist to
conduct field survey (Phase 1)
5 -28.327295 27.065751 Free State Winburg Historic (building Do not disturb
remains)
6 -28.7894 26.7095 Free State Kleinfontein Historic buildings Contact archaeologist to
conduct field survey (Phase 1)
7 -28.793715 26.697235 Free State Verkeerdevlei Historic (building Do not disturb
remains)
8 -29.0346 26.2361 Free State Bloemfontein Anglo Boer War Contact archaeologist if artifact
sites or skeletal remains discovered
9 -29.0627 26.1977 Free State Bloemfontein Anglo Boer Contact archaeologist if
War sites artefact or skeletal remains
discovered
10 -29.0609 26.1944 Free State Bloemfontein Anglo-Boer War Contact archaeologist if
sites artefact or skeletal remains
discovered
PALAENTOLOGY
1 -27.58408 27.28467 Free State Kroonstad Palaeontological Notify a palaeontologists
material should a fossil be uncovered.
2 -28.22969 27.10016 Free State Sand River Palaeontological Notify a palaeontologists
environs. material should a fossil be uncovered.

Control of vegetation clearing


60. ZTE shall not clear any vegetation along the construction right -of-way outside of the areas defined by
the stake markers.
61. ZTE shall clear vegetation along the construction right-of-way and the access routes to the minimum
degree necessary for construction. Cleared vegetation shall be windrowed along the perimeter
of the construction right-of-way.

62. The large indigenous trees occurring in the riparian zone which have been individually categorised,
named, marked in the field shall not be damaged by ZTE unless a permit has been obtained
from the relevant conservation authority. The trees shall be plotted on the survey drawings. ZTE shall
prevent damage to these trees and/or obtain the necessary permit should it be necessary to trim or
remove these trees.

63. Where the data cable passes through an afforested (plantation) area ZTE shall comply strictly with
the conditions agreed between FibreCo and the owner.

64. Where ZTE has to dispose of vegetation cleared from the construction right -of-way, he/she may do
so with the permission of the landowner provided there is no impairment to the health and well
being of any person, to water quality, land use and capability or ecological stability of the area in
which it is disposed.

65. The burning of vegetation should be avoided as far as possible. The Contractor shall only be
permitted to undertake the controlled burning of brush and other vegetation cleared from the
construction right-of-way, upon consent from the landowner and subject to compliance with any
burning regulations of the district. A method statement shall be prepared for each controlled burn, and
submitted to the relevant fire prevention authority.

Control of topsoil and subsoil


66. ZTE shall store topsoil (defined as the soil above 150mm) excavated from the trench in a wind row
or stockpile which shall be discernibly separate from wind rows or stockpiles of any other excavated
materials.

67. ZTE shall remove topsoil from a corridor up to 0.5m wide over the line of the trench.
Topsoil shall not be disturbed, more than is absolutely necessary, on the remaining construction right -
of-way.

68. Topsoil shall not be contaminated with anything that might impair its plant-support capacity (e.g.
aggregate, cement, concrete, fuels, litter, oils, domestic and industrial waste).

69. ZTE shall temporarily stockpile topsoil in a location that will minimize any loss due to erosion or
mixing with other material.

70. ZTE shall ensure that topsoil is stockpiled in a manner and for a period of time that does not result
in deterioration in its plant support capacity.

71. After the completion of the backfilling, re-contouring and erosion control works, ZTE shall spread the
topsoil evenly at uniform depth over the areas from which it was removed.

72. The stockpiling of topsoil along the route corridor for the purposes of reinstatement is regarded as a
vital component of successful rehabilitation, and compliance with the stripping requirements specified
above will be strictly enforced. In areas where topsoil of less than 150mm is stripped, ZTE will be
required to demonstrate that substantial constraints prevailed which made this requirement
unattainable.

73. ZTE may distribute waste soil (soft material) evenly around the construction right-of-way as long as it
does not impact negatively on natural vegetation or land capability.

Control of material supply and borrow areas


74. ZTE shall, as far as possible, source all material needed to lay the data cable from existing permitted
mines and/or quarries in the area.
75. In instances where bedding material needs to be obtained from a new borrow area, ZTE shall comply
with the requirements of relevant legislation. Mining authorization from the Department of Mineral
Resources (DMR) is a legal requirement for new borrow areas, the application for which must include
an Environmental Management Programme, submitted to the Provincial Director of Mineral
Development.

76. In addition to any requirements that are specified by the DMR, ZTE shall prepare a method statement
including plans, detailing the expected quantity of excavation, temporary and permanent drainage
control, the final contouring of the borrow pit and the proposed method of rehabilitation and shall
submit this to FibreCo for approval prior to opening the borrow pit.

Control of stone and rock waste


77. ZTE may move surface stone and rock to facilitate data cable construction, but shall not stockpile or
dispose of this material off the construction right-of-way without landowner consent.

78. Where the land is naturally armoured (i.e. has significant amounts of surface rock and stone), ZTE
may return this material back over the construction right-of-way in approximately the same proportions
as occurred prior to construction.

79. ZTE shall prepare a method statement detailing the proposed location and method of disposing of
waste rock excavated from the data cable trench. As a general rule, windrowing of waste rock along
the perimeter of the trench shall be prohibited. ZTE shall identify erosion gullies or old borrow pits in
these sections of route corridor for preferential disposal of waste rock and other granular material.
The method statement shall include the measures that are proposed t o stabilise and rehabilitate
the disposal site.

Control of blasting
80. Where this occurs, blasting rock in the data cable trench, ZTE shall comply with all legal
requirements and codes of practice relating to this activity.

81. ZTE shall take all necessary precautions to ensure that blast rock is not scattered over, or outside,
the construction right- of-way, causing damage or injury to the environment, people or animals,
agriculture, buildings or other infrastructure. Where necessary, ZTE shall employ blast nets or other
safeguards in order to ensure that blast rock remains in situ after the blast, so that it may be removed
from the trench in a controlled manner.

82. ZTE shall prepare and submit to FibreCo a pre-blast photographic record of any structures or
buildings within 200m of a blast zone, including any structural defects in these structures or buildings.

83. In the event of accidental over blast, ZTE shall immediately notify FibreCo in writing, and shall
indicate what damage has occurred, how the blast rock is to be collected and disposed of and how
the damage incurred is to be rectified.

84. ZTE shall institute suitable measures to reduce blast shock, such as: (a) size of explosive charges
per delay and the number of days of explosive exposure; (b) subdividing the explosives deployment,
using electric detonating caps with delays to reduce total pressure; (c) use of decking in drill holes to
reduce total pressure; (d) use of shaped charges at surfaces to focus blast energy; (e) use of angular
stemming material in drill holes to reduce energy dispersal to the aquatic environment; (f) use of
energy absorbers upstream and downstream of the blast, such as temporary gabion structures.
Control of construction of watercourse crossings
85. ZTE is responsible for controlling riparian and stream damage to the river systems through which the
data cable is routed. The Global Positioning System (GPS) location of possible watercourse
crossings and the methods to be used to affect such crossings are outlined in the W ULA contained in
Appendix D - Surface W ater Specialist Study).

86. ZTE shall comply with any conditions of approval set by the DW A, over and above the requirements
of this EMPr.

87. ZTE shall prepare for each river crossing a detailed method statement for review by
FibreCo and for approval by the DW A. The method statement shall include but not be limited to:

a) A biophysical description of the site (profile, depth and width of channel(s), geo-technical
drawings, large trees, reed beds, etc);

b) The proposed timing and duration of watercourse crossing construction;

c) An itemised list of the equipment that will be used for the excavation, laying of data cable,
backfilling of the trench and control of water;

d) Measures that will be used to control suspended sediment and turbidity (e.g. berms, hay
bales, bidem curtains, river / stream diversions, settling ponds), damage to riparian
vegetation, spillage of fuels and oils, cement and other foreign materials and a monitoring
programme to provide rapid feedback on the effectiveness of controls.

e) Measures that will be used to ensure that identified and surveyed trees in the riparian fringe
scheduled for protection within the construction right-of-way, shall not be damaged during
construction.

f) Measures that will be used to stabilize river embankments after construction and to return
the channel to its pre-construction profile or to a more stable profile.

g) Where applicable, measures that will be used to minimize the impact of blasting on aquatic
species in the event that construction under submerged conditions are necessary.

88. During construction, ZTE shall make provision to maintain the natural flow of any drainage line
affected by construction.

89. In excavating the bed of the water body for the data cable, ZTE shall comply with the following: (a)
the excavated areas must be backfilled with material that is of the same quality, and gradation to that
which was removed except in cases where blasting and grouting of the data cable takes place; and
(b) where blasting takes place (if applicable), the rock replaced in the trench at the surface is to give
the trench as natural an appearance as possible, so that in low flow periods, a linear scar is not
obvious.

90. Where isolating the location of a works, the following measures, among others, may be considered by
ZTE in order to minimize the risk of increased suspended sediment in the water column downstream
of the works:

a) Elimination of surface flow through the construction site;

b) The use of non-erodible materials for the construction of any berms, coffer dams or other
isolation structures used in a works within a flowing watercourse. The use of non-earthen
dam structures, such as aqua dams, are possible options;

c) In cases where the entire flow of water of a water body is diverted around the water crossing
site, it must be returned to the water body immediately downstream of the crossing site;
d) The use of silt fences or hay bales to isolate the construction area from the water body in
situations where the flow velocities and volumes are low;

e) The removal and temporary storage of any material excavated from the bed or banks of the
water body to a location out of the water body until the materials are permanently removed
from the location or backfilled into the water body. W here sufficient space exists, and where
the storage will not cause any environmental damage, this may be within the macro-channel
banks of the river; and

f) The treatment of any water removed from the isolation area, prior to discharge back into the
downstream river course, to remove suspended sediment.

91. The Contractor shall monitor the effect of construction on downstream sediment loads. The
monitoring programme shall include sampling in the river upstream and downstream of the works
during the period when construction in the river is taking place especially in the wet season.

92. FibreCo shall commission periodic independent audits of sediment generation caused by the
construction works in the rivers in order to verify the results of the sediment monitoring maintained by
ZTE.

93. ZTE shall adhere to the requirements of the W UL authorisation by DWA with respect to watercourse
crossings

94. During the carrying out of the works, ZTE shall remove any fish that are found within the isolated
portion of the watercourse crossing site, without harming the fish, to an area of the water body
immediately adjacent to the watercourse crossing, outside the isolated portion of the watercourse
crossing site.

95. Where data cable construction through river channels involves excavation of submerged rock, ZTE
shall give preference to methods that do not involve underwater blasting. In the event that ZTE
adjudges underwater blasting methods to be the only practical method this shall be fully motivated
and all necessary plans shall be prepared to demonstrate that t he work can be conducted without
significant risk to aquatic organisms. Such plans shall be submitted to FibreCo and shall be approved
by the DWA as a part of the method statements for each major river crossing prior to implementation
of the works.

96. The method statements shall include all information required by the DW A.

97. ZTE shall apply measures to reduce impact on spawning fish, such as: (a) limiting the season of
explosive use from March to September (non-spawning season); and (b) use of non- explosive
scare techniques to move fish from the immediate blast zone (small repelling explosive charges are
not considered to be an effective means of driving fish from a blast area. Acoustic repellent devices
and/or bubble curtains may need to be considered).

98. ZTE shall notify DW A in advance of any underwater blasting scheduled for the major river crossings.
ZTE shall monitor the effect of underwater blasts upstream and downstream of the blast zone.

99. Where rehabilitating the river crossing works, ZTE shall comply with the following: (a) the river
channel embankments shall be returned to the pre-existing (or a more stable) profile than that which
existed prior to construction. ZTE may make use of the fixed point photography taken by FibreCo
in order to ensure compliance with this requirement; (b) river embankments shall be stabilised, using
any necessary protection measures, including re-vegetation, rip rap, reno mattresses and other
measures, to ensure that the banks are protected against erosion; (c) measures using indigenous
grasses to permanently stabilise disturbed areas shall be fully effective by the end of one
growing season; and (d) debris disposal and clean up shall be carried out to return the river co urse to
its pre-existing condition prior to the works.

100. In rehabilitating the river crossings, ZTE shall, in addition to the requirements specified in the re-
vegetation specification, include the re-planting of indigenous trees in the riparian fringe. At least
70% of the trees at each river crossing shall be alive and healthy at the end of the maintenance
period. The precise location of the trees in the riparian zone shall be provided to ZTE by FibreCo. All
trees are to be purchased from a reputable commercial supplier and are to be supplied with a phyto-
sanitary certificate which certifies that the soil in which they were propagated is weed free.

Control of wetland crossings


101. ZTE shall prevent permanent damage occurring as a result of construction of the works to all
wetlands along the construction right-of-way. The occurrence of wetlands in the construction right- of-
way is defined in the WULA. ZTE shall take note that the definition of wetlands in this EMPr is
broader than the laypersons understanding of the term wetland or marsh, and includes all areas
where hydromorphic soils occur along the route corridor.

102. As far as is reasonably practical, ZTE shall schedule construction activities to take place during
winter when surface and subsurface water flows are lowest, plants are dormant and inundation is
limited (See management measures relating to the control of topsoil and subsoil, construction in
sensitive areas and clearing of vegetation). W etland boundaries should be clearly marked in work
areas to assist the project personnel, contractors and ECO to avoid unplanned disturbances to the
wetlands.

103. The Contractor shall not remove any vegetation within the wetland, other than that which is
absolutely necessary along the data cable construction right-of-way. Remove the top 30cm as sods,
i.e. the vegetation and underlying soil must be removed as a unit and stored separately from the
underlying material. These can be stockpiled immediately next to the trench if backfilling is to occur
within 24 hours and hydrological conditions allow. Where crossing of a wetland is necessary, this
shall occur at a 90 angle to the dominant natural flow of water in the wetland. In instances where
trenching occurs in the same direction of natural flow, it is important to ensure that trenching does not
create a subsurface drain, i.e. an underground preferential flow path due to backfilling with soil of low
permeability. W here approporiate, precautions can include inserting clay plugs at approximate 1-2m
intervals.

104. As far as is possible, ZTE shall backfill the trench in the wetland with the material originally removed.
This shall be done in accordance with the natural soil profile in the wetland. The method chosen as
being most appropriate for a particular site (including the use of clay barriers at intervals along the
data cable shall not affect the natural surface or sub-surface (lateral and longitudinal groundwater
movement) flow within the wetland and shall contain/prevent channelling of water along the data
cable and/or in the backfill. Replace soil in the reverse order in which it was removed, i.e. the soil that
was removed last must be used as the first backfill. The backfill must be restored to its pre-
construction elevation upon completion of works to prevent preferential flow pathways..

105. ZTE shall test each wetland before construction and identify any clay lenses within the depth of
excavation. The Contractor shall re-seal any impermeable layer that is breached by
construction within a wetland, either by using clay removed from the trench, or alternatively with
bentonite or any other appropriate material or method approved by FibreCo.

106. ZTE shall manage all temporary construction roads in or adjacent to wetlands so as to disperse
runoff and avoid concentrating water flows. Temporary construction roads in proximity to
wetlands shall be completely removed and rehabilitated after construction, in accordance with the re-
grassing specification.

107. Limiting access and construction disturbance in wetlands is considered essential. Maintain the
minimum footprints for the work necessary to accomplish the task at hand.

108. The Contractor shall carefully monitor the use of heavy machinery within wetlands. Machine
operators shall be fully informed about the sensitivity of these areas. W here vehicles need to enter
the wetland for trenching, the impact can be mitigated by lowering tyre pressure thereby distributing
the load over a larger area.

109. ZTE shall reinstate the original wetland geometry and topography in both cross -sectional and
longitudinal profile after construction.

110. ZTE shall remove from the wetland immediately after construction is completed all coffer dams,
causeway and construction materials, discard material, berms and other foreign items used in the
construction of the data cable. Ripping and disking of the wetland surface shall be done in all
compacted areas after construction.

111. ZTE shall re-vegetate the area encompassing the data cable construction right-of-way based on
measures devised by ecological specialist. Appropriate plant species, seeding methods and
replanting, as indicated in the specification and approved by FibreCo, shall be used to achieve this.
Measures are as follows:

112. The wetland crossings identified by the W ULA (See Appendix D), and where the above measures
(101-111) apply, are as follows:

Table 3-3 Wetland/ river crossings identified by the specialist studies


ID Latitude Longitude Province Nearest Description Mitigation Measure
Town/City
WETLAND
1 -26.320111 27.940472 Gauteng Nancefield Palustrine. Stay within road reserve.
valley bottom.
emergent
2 -26.327556 27.937167 Gauteng Nancefield Riverine. Upper Stay within road reserve.
perennial. Utilise bridge. Do not disturb
Water the wetland area.
surfacEand
Aquatic bed
3 -26.39625 27.893472 Gauteng Ennerdale Palustrine. Stay within road reserve.
Valley Bottom.
aquatic bed
4 -26.519611 27.810194 Gauteng Evaton Palustrine. Stay within road reserve.
Valley Bottom.
aquatic bed
5 -26.543833 27.806222 Gauteng Bloemfontein Palustrine. Stay within road reserve.
Valley Bottom.
aquatic bed
6 -26.580333 27.795667 Gauteng Sebokeng Riverine. Upper Utilise bridge pillars. Stay out
perennial. of the riparian zone.
SurfacEwater
and aquatic bed
7 -26.646889 27.745639 Gauteng Sebokeng Riverine. Upper Utilise bridge pillars.
perennial.
SurfacEwater
and aquatic bed
8 -26.682583 27.713028 Gauteng Vanderbijlpark Palustrine. Stay in road reserve out of
Valley bottom. riparian zone.
Emergent.
ID Latitude Longitude Province Nearest Description Mitigation Measure
Town/City
9 -26.773944 27.66625 Free State Sasolburg Riverine. Upper Utilise bridge pillars.
perennial.
surfacEwater
and aquatic bed
10 -26.843667 27.63975 Free State Sasolburg Riverine. Upper Utilise bridge pillars. Stay out of
perennial. riparian area. Alien vegetation
surfacEwater control.
and aquatic bed
11 -26.871111 27.629306 Free State Sasolburg Palustrine. Stay in road reserve and out of
Valley bottom. the wetland area.
Emergent.
12 -26.953111 27.592222 Free State Parys Palustrine. Stay in road reserve
Valley bottom.
Emergent.
13 -27.077361 27.542139 Free State Vredefort Palustrine. Stay in road reserve. Stay away
Valley bottom. from wetland area.
Emergent.
14 -27.231833 27.496417 Free State Koppies Riverine. Upper Utilise bridge structure.
perennial.
Aquatic bed and
water surface
15 -27.304806 27.459778 Free State Koppies Lacustrine. Stay in road reserve.
Littoral. Water
surfacEand
aquatic bed
16 -27.353333 27.425444 Free State Koppies Palustrine. Stay in road reserve and out of
Valley bottom. the wetland area.
Emergent
17 -27.524028 27.306472 Free State Kroonstad Palustrine. Stay in road reserve.
Valley bottom.
Emergent
18 -27.662889 27.252306 Free State Kroonstad Riverine. Upper Utilise bridge pillars. Alien
perennial. vegetation control. Institute
Aquatic bed and erosion control measures.
water surface
19 -27.732917 27.233833 Free State Tierberg Riverine. Upper Utilise bridge pillars. Alien
perennial. vegetation control.
Aquatic bed
20 -28.000778 27.17975 Free State Ventersburg Palustrine. Utilise bridge pillars.
Valley bottom. Alien vegetation control.
Emergent
21 -28.184361 27.103694 Free State Ventersburg Riverine. upper Utilise bridge pillars.
perennial.
Aquatic bed and
water surface
22 -28.233667 27.087833 Free State Ventersburg Riverine. upper Utilise bridge pillars.
perennial.
Aquatic bed and
water surface
23 -28.441833 27.033 Free State Winburg Palustrine. Stay within road reserve. Avoid
Valley bottom. wetland area. Do not impede
Emergent flow.
24 -28.568444 26.956528 Free State Winburg Riverine. Upper Stay out of riverine area.
perennial. Utilise bridge pillars. Institute
water erosion control measures.
surfacEand
aquatic bed
25 -28.631611 26.903611 Free State Pleasant View Riverine. Upper Stay out of riverine area.
perennial. Utilise bridge pillars. Institute
water erosion control measures.
surfacEand
ID Latitude Longitude Province Nearest Description Mitigation Measure
Town/City
aquatic bed

26 -28.686389 26.820972 Free State Scotland Palustrine. Stay within road reserve.
Valley bottom. Institute erosion control
Emergent measures.
27 -28.756972 26.737389 Free State Verkeerdevlei Palustrine. Stay within road reserve. Alien
Valley bottom. vegetation control.
Emergent
28 -28.790333 26.701389 Free State Verkeerdevlei Palustrine. Stay within road reserve.
Valley bottom.
Emergent
29 -28.792389 26.698806 Free State Verkeerdevlei Palustrine. Stay within road reserve.
Valley bottom.
Emergent
30 -28.85125 26.5735 Free State Fairfield Palustrine. Utilise bridge pillars. Avoid
Upper riparian zone. Control alien
Perennial. vegetation. Institute erosion
Water control measures.
surfacEand
Aquatic bed
31 -28.851833 26.571528 Free State Fairfield Palustrine. Stay within road reserve. Alien
Valley bottom. vegetation control.
Emergent.
32 -28.864556 26.536056 Free State Vlakfontein Palustrine. Stay within road reserve. Avoid
Valley bottom. wetland areas.
Emergent.
33 -28.914389 26.45025 Free State Amerika Palustrine. Stay within road reserve. Do
Valley bottom. not impede flow of wetland.
Aquatic bed.
34 -28.930639 26.425583 Free State Kleinosspruit Palustrine. Stay within road reserve. Alien
Valley bottom. vegetation control.
Emergent.
35 -28.959972 26.365972 Free State Bloemfontein Palustrine. Stay within road reserve. Alien
Valley bottom. vegetation control. Erosion
Emergent. control.
36 -28.962 26.358611 Free State Bloemfontein Riverine. Upper Stay out of riparian zone. Alien
Perennial. control. Utilise pillars of
Aquatic bed. bridge
structure or middleman.
Institute erosion control
37 -28.967833 26.335 Free State Bloemfontein Riverine. Upper measures.
Stay out of riparian zone.
Perennial. Utilise pillars of bridge
Aquatic bed. structure.
38 -28.975333 26.300194 Free State Bloemfontein Palustrine. Stay in road reserve. Alien
Slope. Emergent vegetation control.
39 -28.977889 26.287833 Free State Bloemfontein Palustrine. Stay within road reserve.
Valley bottom.
Emergent
SURFACE WATER
1 -26.328266 27.936820 Gauteng Nancefiled Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
2 -26.396371 27.893478 Gauteng Ennerdale Watercourse. requirements.
Stay within road reserve.
Culvert Control riparian and stream
crossing. damage. Adhere to
DWA/DEA authorisation
3 -26.543761 27.806610 Gauteng Evaton Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
ID Latitude Longitude Province Nearest Description Mitigation Measure
Town/City
4 -26.580350 27.796119 Gauteng Sebokeng Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
5 -26.647756 27.745227 Gauteng Vanderbijlpark Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
6 -26.683094 27.713198 Gauteng Vanderbijlpark Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
7 -26.773544 27.666880 North West/Free Sasolburg Watercourse. Stay within road reserve.
state Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
8 -26.844010 27.640104 North West/Free Sasolburg Watercourse. requirements.
Stay within road reserve.
state Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
9 -26.958314 27.589711 North West/Free Parys Watercourse. Stay within road reserve.
state Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
10 -27.076950 27.542408 Free State Vredefort Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
requirements.
11 -27.172843 27.509404 Free State Koppies Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
12 -27.231235 27.496541 Free State Koppies Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
requirements.
13 -27.294602 27.467022 Free State Koppies Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
14 -27.352513 27.426073 Free State Koppies Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
requirements.
15 -27.436133 27.367524 Free State Kroonstad Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
16 -27.662520 27.252439 Free State Kroonstad Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
17 -27.732577 27.234063 Free State Kroonstad Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
18 -27.919280 27.203378 Free State Ventersburg Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
19 -28.001165 27.179716 Free State Ventersburg Watercourse. requirements.
Stay within road reserve.
ID Latitude Longitude Province Nearest Description Mitigation Measure
Town/City
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
20 -28.104916 27.128883 Free State Ventersburg Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
21 -28.184302 27.103816 Free State Ventersburg Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
22 -28.233346 27.087990 Free State Ventersburg Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
23 -28.400224 27.036899 Free State Winburg Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
24 -28.568206 26.956689 Free State Winburg Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
requirements.
25 -28.631796 26.903399 Free State Winburg Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
26 -28.674885 26.838831 Free State Winburg Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
27 -28.757852 26.736734 Free State Brandfort Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
28 -28.791951 26.699434 Free State Brandfort Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
requirements.
29 -28.817433 26.664889 Free State Brandfort Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
30 -28.851625 26.573320 Free State Brandfort Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
31 -28.962133 26.359185 Free State Bloemfontein Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
32 -28.968078 26.335124 Free State Bloemfontein Watercourse. Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to
DWA/DEA authorisation
33 -29.046115 26.210199 Free State Bloemfontein Watercourse. requirements.
Stay within road reserve.
Bridge crossing. Control riparian and stream
damage. Adhere to DWA/DEA
authorisation requirements.
113. Control of impact of construction activities on groundwater

114. ZTE shall where possible avoid activities within 100m of a borehole.

115. Where possible, the pipeline route corridor will be realigned to avoid damage to a borehole.

Control of the impact of construction activities on archaeological sites and


graves and palaeontological remains

116. In terms of the Natural Heritage Resources Act (Act 25 of 1999), no graves or archaeological sites,
including man-made structures more than 60 years old, may be disturbed, damaged or destroyed by
any person without requisite arrangements or permits from SAHRA.

117. The ECO shall check that measures required by heritage professionals and SAHRA to ensure that
these are complied with for all routes.

118. The cable shall be aligned to avoid known grave sites and sites of archaeological and
palaeontological significance as far as possible.

119. When planning to align the data cable to bypass the above sites, ZTE shall make sure that this work
is done under the supervision of an ECO.

120. ZTE shall be responsible for commissioning a Phase 1 archaeological survey of repeater sites
identified Table 3-2 to verify if there are any heritages resources that will be impacted by construction
activities. If any of the sites earmarked as warranting protection by the heritage specialist cannot be
adequately protected during construction, then ZTE shall immediately draw this to FibreCos
attention, and shall prepare a proposal to reconfigure the layout of the repeater to avoid impacting on
identified heritage features.

121. The ECO must be trained in basic archaeological site identification in order to immediately inform the
archaeologist/palaeontologist of any chance discovery of archaeological sites or burials. The
archaeologist will then implement the required legal steps in terms of the applicable section of the
National Heritage Resources Act (NHRA) (Act 25 of 1999).

122. ZTE shall make provision for accidental discovery of archaeological sites and graves along the
construction right-of-way. Once the route corridor is surveyed and staked, and prior to construction,
ZTE shall, with the assistance of the ECO, verify that no further sites exist along the construction
right-of-way over and above those described in this EMPr. In the event that any sites found are
significant enough to warrant conservation, the Contractor shall determine whether this is
feasible and, if not, immediately notify FibreCo of the route alignment adjustment necessary to avoid
the site.

123. In fulfilment of the requirements of the South African Heritage Resources Agency (SAHRA), ZTE
shall prepare the necessary documentation and obtain the permits/authorisations from the relevant
SAHRA office to construct through and/or on those heritage sites which are directly affected by
construction activities but are considered to be of low significance. It should be noted that buildings
60 years and older must be assessed and a permit obtained from SAHRA before demolition is
considered.

Rehabilitation
124. ZTE shall restore the trench and construction right-of-way to the natural contours of the ground
and shall allow normal surface drainage.

125. ZTE shall remove all temporary works along the construction right -of-way and fences and private
roads disturbed by construction shall be restored to their original condition.
126. ZTE shall loosen compacted soils along the construction right-of-way by means of a plough or
scarifier. Scarifying areas where topsoil has been removed shall be carried out prior t o the
replacement of topsoil. Care shall be taken to avoid topsoil inversion if scarifying is carried out in
areas where topsoil has not been removed. Any ripping or scarifying operation shall not exceed a
depth of 100 mm.

127. ZTE shall prevent concentrated run-off along, or next to, the construction right-of-way, and shall
do so by shaping the land, establishing vegetation, and taking other appropriate measures to absorb
and disperse runoff.

128. In places where erosion control is required, including the top of bank of all gullies, watercourses,
large depressions and steep slopes, the Contractor shall construct diversion banks across the
construction right-of-way to divert the flow of water away from the backfilled trench and into the
natural drainage courses.

129. In all cases, ZTE shall cover the backfilled data cable trench evenly with topsoil to a minimum
depth of 150mm.

130. On any deviations from the road reserve which cross arable land, ZTE shall ensure that stone and
rock within the soil profile are stockpiled so as to minimize constraints on adjacent land.

131. Where the land is naturally armoured with surface rock or stone, the Contractor shall, after
construction, replace the armouring over the construction right-of-way to protect against erosion.

132. On slopes steeper than 5%, ZTE shall use special protection methods to arrest soil erosion
during the vulnerable period before vegetation re-establishment occurs.

133. Where brush and tree limbs cannot be chipped or used by local communities, this vegetation shall
be spread evenly over the construction right-of-way to preserve and assist the regeneration of natural
vegetation, erosion control and providing animal habitation. Tree trunks and large limbs are to be laid
in a random fashion across the natural slope of the ground, and should not obstructing access by
construction vehicles. No tree trunks and large limbs shall be placed in gullies or erosion ditches.

134. ZTE shall establish vegetation cover (using species appropriate to the local area) in all areas
disturbed by the works in the first growing season after construction, and shall maintain this cover for
the duration of the maintenance period. ZTE shall notify FibreCo in writing, prior to re-vegetation, of
the method of preparation (scarifying / ripping / discing), soil amelioration (addition of lime or gypsum),
fertilizing, and seeding (source, mixture and quantity) to be used in rehabilitating each area of the
works and the post-establishment maintenance regime to be implemented.

135. ZTE shall maintain and submit to FibreCo records of the method used to re-establish grass in
each area of the contract.

136. Revegetation shall be done on the construction right-of-way including, but not limited to, all borrow
areas, temporary access roads, spoil sites, camp sites and the like.

137. Once the grass has been established, the maintenance period shall commence. This period shall
extend for a minimum period of one calendar year.

3.3.3 Labour and human resources plan


The labour and human resources plan to be implemented by ZTE and FibreCo shall include the
following key measures:

1. ZTE shall establish a labour and human resources plan which shall be submitted to
FibreCo.

2. The plan shall be based on the following principles:


a. Compliance with national policy and legislation (e.g. Employment Equity Act) and
international labour conventions and norms.
b. Clear and transparent conditions of service, as appropriate.
c. Open and fair recruitment procedures.
d. Well-structured, transparent and locally-appropriate remuneration and compensation
procedures.
e. Accessible and appropriate training and development.
f. Clearly defined and open dispute resolution procedures.

3. Wherever possible, first priority should be given to hiring qualified local people.

4. The labour and human resources plan shall, as appropriate, be adapted by FibreCo and applied
during the operational phase of the project to cover maintenance of the infrastructure.

3.3.4 Workplace health and safety plan


The workplace health and safety plan to be implemented by ZTE and FibreCo shall include the
following key measures:

1. All relevant national legislation, including the OHS Act and related regulations, shall be adhered
to in order to provide a safe and healthy environment for all employees, Contractors, suppliers
and the community during construction and operational phases of the Project.

2. ZTE shall develop a health and safety plan in fulfilment of legal requirements for submission to
and approval by FibreCo prior to the start of construction activities.

3. FibreCo shall ensure workplace health and safety during the construction and operational
(maintenance) phases of the data cable. Management should lead by example to ensure that
legislative and contractual requirements are met.

4. Health and safety performance will be continuously monitored and procedures reviewed with the
aim of eliminating risk as far as reasonably practicable.

3.3.5 Community health and safety plan


The community health and safety plan to be implemented by ZTE and FibreCo shall include the
following key measures:

1. All relevant national legislation, including the OHS Act and related regulations, shall be adhered
to ensure that the health and safety of proximate communities and the public at large are not
threatened during construction and operational phases of the Project.

2. During the construction phase, ZTE shall manage and control construction activities in order to
minimise the risks to community health and safety. Special attention shall be paid to threats
posed by the movement of construction vehicles, violation of cultural sensitivities through
damage to graves and historic buildings and sites, contravention of community norms relating to
sexual practice and use of alcohol, security and access control to the construction right -of-way,
transport safety management and control of dust, noise and water pollution.

3. ZTE and FibreCo and its Contractors shall ensure that proximate communities are aware of the
procedures for ensuring community safety should potentially hazardous activities such as
blasting be required (See communication and information principles).

3.3.6 Land acquisition and compensation plan


Should there be diversions off the SANRAL and provincial road servitudes, the land acquisition and
compensation plan to be implemented by FibreCo shall include the following key measures:
1. FibreCo shall carry out negotiations with landowners in order acquire the land needed for the
data cable servitude. Compensation will be based on current land and land use valuations in
accordance with legislation, as appropriate.

2. The data cable route corridor shall be aligned to avoid resettlement of households and economic
displacement.

3. In order to comply with lender requirements (e.g. Equator Principles and IFC Performance
Standards), FibreCo shall prepare a land acquisition and compensation plan that describes how
project affected persons will be compensated, and how it will seek to improve conditions for
those affected by project activities. This plan should be based on the following principles:

a. Avoidance of resettlement and economic displacement wherever possible.


b. Fair compensation, at full replacement cost, prior to displacement.
c. The pursuit of amicable and negotiated settlement in the context of compensation
and assistance.
d. Structured and responsive monitoring and evaluation.

4. Land expropriation will only be considered where necessary.

3.3.7 Emergency management and response plan


The emergency management and response plan to be implemented by FibreCo shall include the
following:

Emergency management planning


1. FibreCo shall develop an emergency management plan to guide the coordination and
operational handling of an emergency situation to include:

a. Structure and operation of the emergency management team.


b. Establishment of an emergency management centre.
c. Information retained by the emergency management team.
d. Incidents requiring activation of the plan.
e. Incident severity classification.
f. Process to be followed in the event of an emergency.

2. Information pertaining to emergency management shall be reported through the HSE reporting
process.

Emergency response plan

The community health and safety plan to be implemented by ZTE and FibreCo shall include
the following key measures:

3. FibreCo should compile a comprehensive safety emergency management plan for the data
cable, and liaise with emergency services of local municipalities where relevant.

4. Emergency preparedness will include: staff emergency training; equipment maintenance and
inspection.

3.3.8 Social responsibility plan

The social responsibility plan to be implemented by FibreCo and its Contractors shall include the
following:
1. Compliance with the principles of Broad Based Black Economic Empowerment (BBBEE) as
enshrined in the BBBEE Act (Act 53 of 2003) and its associated codes of good practice by
FibreCo and its Contractors.

2. As necessary, compliance with the requirements of the Preferential Procurement Policy


Framework Act (Act 5 of 2000).

3. In fulfilment of the above, maximize local employment and local subcontracting.

4. Where practicable, provide support to community initiatives aimed at the promotion of


sustainable development. This support could take many forms, including the provision of
technical information and advice and facilitating development in the areas affected by the data
cable.

3.3.9 Decommissioning plan

The decommissioning plan directs pre- and post-closure activities. The provisions relating to this
plan area as follows:

Planning for decommissioning


1. FibreCo shall develop a final decommissioning plan in conjunction with local authorities and
communities at least one year before the end of data cable operation, and update the plan
annually thereafter to ensure that the provisions and costing reflects current realities.

2. Prior to closure, FibreCo will hold negotiations with the relevant authorities and the local
population to identify the best possible use for infrastructure. W here appropriate, negotiations
will be held to make necessary arrangements to transfer useful infrastructure to new owners.

Decommissioning
3. During the decommissioning of the cable, FibreCo shall ensure appropriate disposal of E-waste
and other waste in accordance with waste management legislation dealing with the disposal of
hazardous and general waste.

4. FibreCo shall institute data cable abandonment measures as agreed to with relevant authorities.

5. The cleared sites and associated infrastructure such as access roads will be rehabilitated by
FibreCo and its environmental consultant/s using industry best practice methods.

Post closure
6. Once the data cable has been abandoned, FibreCo will retain a number of responsibilities.
These may include responsibility for ensuring that the right-of-way and any facilities left in place
remain free of problems associated with abandonment.

3.3.10 HSE Construction Phase Roles and Responsibilities


FibreCo plans to put in place a specific team (Owner's Team) to manage the construction phase of
the proposed Project. This team will be separate from the operations team, but will coordinate as
required to ensure that there are no conflicts between operational and construction requirements.
The physical construction will be managed by a Managing Contractor, who in turn will sub-contract
specific components to various construction sub-Contractors.

The Managing Contractors environmental and social staff will be supervised by the Owners Team
HSE organization. The Owners Teams HSE staff will include the following:

HSE Manager to oversee the implementation of all HSE requirements as defined by FibreCo
(essentially the requirements stipulated in this EMPr, but others may also become apparent and
be included during project implementation). He/she should possess the requisite qualification
pertaining to HSE.

Environment Manager will also oversee environmental matters with his HSE staff (HSE officers).
The staff should possess a suitable qualification in a natural science and/or environmental
science / management discipline and should have appropriate experience.

The HSE Officer (HSEO) - will assume the ECO function and be responsible for the
implementation of the various environmental management requirements that need to be met by
the Managing Contractor as well as the various other Contractors that will be operating on the
site. This function will include regular inspections, coordination of reporting, and site wide
environmental monitoring. The HSEO should have a tertiary qualification in a natural science
and/or environmental science/management discipline with 3-5 years relevant work experience.

Independent environmental consultant/s will be commissioned from time-to-time to assist with


specific tasks (e.g. review information and provide advice on specialist issues, assist in the
preparation of an annual monitoring report and conduct environmental auditing). An independent
environmental expert(s), in any field (e.g. wetlands, terrestrial ecology, water management,
archaeology etc.), may be appointed on request of the Environmental Manager or Owners
Representative to provide specialist advice.

Contractors will be expected to have their own Environment Managers and their activities will be
overseen by the Owners Team HSE staff. In addition, key line functions will have specific
environmental and social management responsibilities included in their job descriptions and
performance criteria. Critical among these is the Construction Manager. The Construction Manager
will be accountable for environmental and social management during the construction phase.
Specific responsibilities will include:

The effective implementation of the EMPr;

Regular performance reviews; and

Corrective and/or remedial action where this may be required.

3.3.11 Contractor arrangements during the construction phase


The following construction phase Contractor arrangements will be made to support HSE and EMPr
implementation:

A detailed code of practice for construction teams will be prepared and implemented. This code
will guide the management and behaviour of construction teams. The code will include items
relating to health, safety and community relations. The code of practice for construction workers
will include HIV/Aids counselling.

Information on the implications of construction will be disseminated before construction starts.

Information on the construction phase will be disseminated to affected landowners prior to


construction.

Contracts will be key tools in managing many potential negative impacts, such as transport
related incidents. In this context both construction and operational contracts will specify required
environmental and social practices.

3.3.12 Training, awareness and capacity building


The presence on site of one experienced HSE Manager, with previous exposure to similar projects,
will allow on-the-job training.
3.3.13 Environmental procedures for the management of operational impact
Prior to the commissioning of the cable, FibreCo will establish operational procedures to give effect
to the measures contained in the management plans presented in Section 3.3 of the EMPr. These
procedures will form part of the FibreCos HSE system and include: the routine maintenance of the
cable right-of-way; environmental management of the data cable right-of-way during repairs;
management of major erosion incidents; traffic safety; management of solid waste and health and
safety.

Each procedure should include the following information:

Procedure name and reference

Purpose of the procedure

Responsibilities for identifying operational impacts

Liaison with authorities and communities, where appropriate

Training of maintenance teams, where appropriate

Record keeping and reporting

Scheduling, where appropriate.

3.4 Monitoring
All management plans will be subject to monitoring. In general, monitoring will have two key
elements: routine monitoring against set standards or performance criteria; and periodic review or
evaluation. This will often focus on the effectiveness and impact of the programme or plan as a
whole. In some cases, independent parties will undertake review and evaluation. The diverse
monitoring requirements and responsibilities will be consolidated within the HSE function, and will
share human resources, databases and management reporting procedures.

During the construction phase, FibreCo shall be fully entitled to monitor and inspect Contractors
written records to demonstrate compliance with the EMPr. This compliance monitoring is intended to
verify that the responsible parties are implementing the management measures / procedures /
specifications contained in the EMPr. Compliance will mean that ZTE is fulfilling his/her contractual
obligations.

W here necessary, baseline monitoring will be used as a means of longer term (post construction)
verification of biophysical conditions along the data cable route corridor, to critically evaluate issues
of habitat recovery, alien plant infestation and erosion along the data cable right-of-way.

3.4.1 Programme monitoring


FibreCo shall regularly monitor EMPr implementation. This process will include (as appropriate) the
regular monitoring of:

Erosion of soil along the construction right-of-way (12 months).

Air quality and ambient emissions, including dust generated by construction activities (3 months).

Rehabilitation of the construction right-of-way (0-2 years).

Noise (measured in dBA) generated by construction activities, including blasting, using specific
measurement parameters, reference times and measurement locations.

3.4.2 Plan Monitoring


All of the management plans make provision for monitoring and evaluation. Special attention should
be given to the monitoring arrangements relating to biophysical, heritage and palaeontological
impacts.

During the construction phase of the Project, ZTEs HSE manager must report all environmental
impacts (e.g. large scale sedimentation and erosion, damage to and/or destruction of, natural
vegetation and damage to heritage resource) as well as accidents and incidents to the Owners
Representative. These reported impacts and incidents will be captured on a database to ascertain
trends and track progress in the implementation of preventative and corrective actions, and
benchmarking against other, similar operations.

Depending on the level of severity, accidents and incidents during construction or maintenance will
be investigated by ZTEs HSE division, with key input from the line management to ensure
accountability. Rewards and recognition will be given to the best performing work teams on a
periodic basis on a periodic basis. The primary objective of these interventions is to recognise the
positive behaviours and outcomes of workers with regards to safety.
Environmental Management Programme for
Route 2 Bloemfontein to Graaff-Reinet of the
proposed FibreCo optic fibre data cable
Table of Contents
1 Introduction and Scope of Report............................................................................... 1
1.1 Background ......................................................................................................................................... 1
1.2 Approach to environmental impact management ............................................................................... 3
1.2.1 Overview ................................................................................................................................. 3
1.2.2 FibreCos Social and Environmental policy ............................................................................. 4
1.2.3 Planning and design................................................................................................................ 4
1.2.4 Pre-construction and construction........................................................................................... 5
1.2.5 Operation................................................................................................................................. 6
1.2.6 Checking and corrective action ............................................................................................... 6
1.2.7 Management review ................................................................................................................ 7
1.2.8 Liaison ..................................................................................................................................... 7
1.3 Assumptions........................................................................................................................................ 7
1.4 Uncertainties ....................................................................................................................................... 8
2 The Proposed Project .................................................................................................. 8
2.1 Optic fibre data cable .......................................................................................................................... 8
2.1.1 Construction and installation ...................................................................................................9
2.1.2 Start and end points of data cable ........................................................................................ 10
2.1.3 Design and equipment standards ......................................................................................... 11
2.1.4 Monitoring.............................................................................................................................. 11
2.2 Construction phase ........................................................................................................................... 11
2.2.1 Scale and pace of construction ............................................................................................. 11
2.2.2 Construction process............................................................................................................. 11
2.2.3 Energy, water, sanitation and waste requirements ............................................................... 12
2.2.4 Employment .......................................................................................................................... 12
2.3 Operational phase............................................................................................................................. 12
2.3.1 Transmission of information .................................................................................................. 12
2.3.2 Safety and security ................................................................................................................ 12
2.3.3 Energy, water, sanitation and waste requirements ............................................................... 13
2.3.4 Monitoring.............................................................................................................................. 13
2.3.5 Employment .......................................................................................................................... 13
2.4 Decommissioning.............................................................................................................................. 13
3 Impact mitigation and management ......................................................................... 13
3.1 Links with the Basic Assessment ...................................................................................................... 13
3.2 Mitigation and Management Measures per Phase ........................................................................... 14
3.3 Management plans.............................................................................................................. .............. 27
3.3.1 Rationale ............................................................................................................................... 27
3.3.2 Construction management plan ............................................................................................ 27
3.3.3 Labour and human resources plan ....................................................................................... 52
3.3.4 Workplace health and safety plan ......................................................................................... 53
3.3.5 Community health and safety plan ........................................................................................ 53
3.3.6 Land acquisition and compensation plan .............................................................................. 53
3.3.7 Emergency management and response plan ....................................................................... 54
3.3.8 Social responsibility plan ....................................................................................................... 54
3.3.9 Decommissioning plan .......................................................................................................... 55
3.3.10 HSE Construction Phase Roles and Responsibilities ........................................................... 55
3.3.11 Contractor arrangements during the construction phase...................................................... 56
3.3.12 Training, awareness and capacity building ........................................................................... 57
3.3.13 Environmental procedures for the management of operational impact ................................ 57
3.4 Monitoring ......................................................................................................................................... 57
3.4.1 Programme monitoring.......................................................................................................... 57
3.4.2 Plan Monitoring ..................................................................................................................... 58

List of Tables
Table 1-1: Routes under consideration and their relative distances .................................................................. 1
Table 1-2: Approaches to impact management ................................................................................................. 3
Table 2-1 Repeater sites .................................................................................................................................... 8
Table 3-1: Mitigation and management measures relating to impacts caused by project activities during all
project phases ............................................................................................................................ 14
Table 3-2 Specific requirements for the siting of the cable trench and repeater sites ..................................... 33
Table 3-3 Wetland/ river crossings identified by the specialist studies ............................................................ 43

List of Figures
Figure 1: Proposed optic fibre data cable Route 2 along the N6, R398 and N9 between Bloemfontein and
Graaff-Reinet................................................................................................................................ 2
List of Abbreviations
BA Basic Assessment

ECO Environmental Control Officer

EMPr Environmental Management Programme

DEA Department of Environmental Affairs (Competent Authority for the project)

PM Project Manager

SANRAL South African National Roads Agency Limited

Glossary of Terms
Construction Right of Way The area within which ZTE will be required to work along the fibre data cable route corridor. FibreCos
standard agreement with the South African National Roads Agency Limited (SANRAL) limits this to 2
metres from the road reserve boundary.

Contractor The company commissioned to construct the fibre data cable and its associated infrastructure

Environmental Consultant An independent environmental consultant with experience in the environmental? management of
construction contracts

Environmental Control Officer The Environmental Control Officer (ECO) is the person responsible for ensuring that the registration
and updating of all relevant EMPr documentation is carried out. The ECO is informed of revisions and
updates to the EMPr by the Project Manager. A controlled document is official only if the issue/revision
has been approved.

FibreCo Refers to FibreCo Telecommunication (Proprietary) Limited

HSE management Approach that addresses health, safety and environmental considerations in the management cycle of
the Project, i.e. policy, planning and design, implementation (preconstruction, construction and
operation), monitoring and corrective action and review.

Operational controls Mechanisms used to effect the EMPr requirements

Permanent right-of-way The area that constitutes the permanent servitude registered against the property owners title deed.
The servitude width varies

Plan Sets out the intended method and/or specific measures required to mitigate and/or enhance the
negative and positive impacts of the Project. A plan usually focuses on one project phase, i.e. pre-
construction and construction, operation or closure.

Programme Identifies a series of interrelated measures (often contained in detailed plans) for managing the
environmental effects of the Project. A programme provides broad direction and covers more than one
project phase.

Servitude A right, established by mutual agreement or in terms of legislation, to use a landowners property for
construction and operation of the fibre data cable.

The works All areas within which ZTEs activities will take place, including the construction right-of-way, access
roads, campsites, borrow pits and the like.

Wetlands Include all areas where the soils were formed under seasonal or permanent saturation.
1 Introduction and Scope of Report
FibreCo Telecommunication (Proprietary) Limited (FibreCo) wishes to install a fibre optic data cable
and associated infrastructure between major centres in South Africa in order to improve
telecommunication service. This document is based on a generic environmental management
programme (EMPr) forming one component of the basic assessments (BAs) underway for the routes
anticipated to follow national and provincial highway routeing as indicated in Table 1-1:

Table 1-1: Routes under consideration and their relative distances

Route name Approximate distance (km)

Johannesburg to Bloemfontein (Route 1) 387

Bloemfontein to Graaff Reinet ((Route 2) 513

Graaff Reinet to Yzerfontein (Route 3) 940

George to Port Elizabeth (Route 4) 360

Port Elizabeth to Durban (Route 5) 968

Port Elizabeth to Colesberg (Route 6) 427

East London to Aliwal North (Route 7) 333

This EMPr is specific to Route 2 (see Figure 1)

1.1 Background
The purpose of the EMPr in its final form will be to ensure that social and environmental impacts,
risks and liabilities identified during the BA process are effectively managed during the construction,
operation and closure phases of the fibre optic data cable. It will specify the mitigation and
management measures to which FibreCo is committed, and show how the project will mobilise
organizational capacity and resources to implement these measures. The EMPr will also show how
mitigation and management measures will be scheduled. This generic EMPr has been developed at
the request of FibreCo to provide an initial indication of the measures which might be contained in
the EMPr.

The key objectives of the EMPr will be to:

Formalize and disclose the programme for environmental and social management; and
Provide a framework for the implementation of environmental and social management initiatives.
Best practice principles require that every reasonable effort be made to reduce and preferably to
prevent negative impacts, while enhancing positive benefits, especially within the communities most
directly affected by the proposed project. These principles are being used to guide the BA process.
In many cases, potential negative impacts can be avoided through careful design, routing and
location of facilities.
Figure 1: Proposed optic fibre data cable Route 2 along the N6, R398 and N9 between
Bloemfontein and Graaff-Reinet
Work underpinning the EMPr needs to comply with the EIA Regulation requirements, and includes
the following:

A public participation process set out in Regulations 54, 55, 56, 57 and 58;
A BA report of the proposed Project, including specialist reports, that aims to:
o List the impacts and risks associated with the proposed Project;
o Identify mitigation measures relating to the negative environmental and social
impacts identified during the BA process; and
o Formulation of the EMPr to avoid/minimize negative impacts.
The EMPr covers information on the management and/or mitigation measures that will be taken into
consideration to address impacts, where relevant, in respect of:

Planning and design;


Pre-construction and construction activities;
Operation; and
Closure.
It is necessary to highlight that the EMPr is a living document that will be periodically reviewed and
updated as necessary.

1.2 Approach to environmental impact management


Responsibility for the EMPr will reside in the HSE functional management cluster of FibreCo, but
there will be links with other functional clusters in areas such as operation and maintenance
services. The sections that follow outline the management cycle that will characterise HSE
management, and which will apply to the EMPr. Table 1-2 presents the range of approaches that will
be used to manage potential project activities.

Table 1-2: Approaches to impact management


Avoidance Avoiding activities that could result in adverse impacts and/or resources or areas considered sensitive
Prevention Preventing the occurrence of negative environmental impacts and/or preventing such an occurrence
having negative impacts
Preservation Preventing any future actions that might adversely affect an environmental resource
Minimisation Limiting or reducing the degree, extent, magnitude or duration of adverse impacts through scaling down,
relocating, redesigning and/or realigning elements of the project
Mitigation Measures taken to minimize adverse impacts on the environment
Enhancement Magnifying and/or improving the positive effects or benefits of a project
Rehabilitation Repairing affected resources, such as natural habitats or water resources
Restoration Restoring affected resources to an earlier (possibly more stable and productive) state, typically
background or pristine condition
Compensation Compensating for lost resources, and where possible, the creation, enhancement or protection of the same
type of resource at another suitable and acceptable location

1.2.1 Overview
The HSE management cycle has five broad components:

Policy
Planning and design
Project implementation (covering the construction and operation phases)
Checking and corrective action
Management review.
This addresses each of these phases of the proposed project.
1.2.2 FibreCos Social and Environmental policy
FibreCo Telecommunications is committed to developing and operating a terrestrial fibre optic cable
system in a manner that ensures environmental protection and minimises social impacts and is in
line with industry best practice. This commitment is central to the companys Social and
Environmental Management system framework.

In line with this commitment FibreCo will endeavour to:

Undertake its activities in line with applicable industry standards and industry good practice;
Meet the requirements of national legislation wherever its network exists;
Manage construction activities, which FibreCo recognises as the main potential source of social
and environmental impacts, in a sustainable manner in order to minimise such impacts;
Ensure social and environmental impacts during operation of the project are avoided or reduced
as far as practicable;
Communicated and work closely with it contractors to ensure their understanding and shared
commitment to conformance with this policy;
Provide training in social and environmental matters to key employees and contractor
representatives where appropriate; and
Implement all reasonable precautions to protect the health and safety of its employees and
promote the health and safety of contracted workers.
These objectives shall be met via provision of adequate resources by senior management within
FibreCo to support the implementation of the social and environmental management systems. This
policy and other elements of the social and environmental management system shall be regularly
reviewed and updated in order to ensure its continued applicability to the activities of FibreCo.

1.2.3 Planning and design


Planning and design is necessary to ensure that mitigation and impact management can be
effectively implemented in the context of the relevant HSE policies. Planning involves the following
activities:

Identifying and defining the various environmental aspects and related potential positive and
negative impacts that can result from the companys activities.
Establishing a procedure to identify legal and other requirements to which the organisation is
subject.
Identifying and defining appropriate mitigation and management measures, including those
reinforcing positive impacts.
Establishing and maintaining documented, scheduled environmental objectives and targets at
each relevant function and level within the organisation.
In the case of the FibreCo Project the environmental aspects and potential impacts will mainly
emanate from the following project related activities:

Construction and installation of the optic fibre data cable project for Routes 1 to 7 with routing
and distances as indicated in Table 1-1.
o Trenching and excavations which will commence once the requisite approvals and
authorisations have been obtained from relevant authorities (e.g. South African
National Roads Agency Limited (SANRAL) regional managers approval of the
plans, provincial road authorities, local authorities, environmental authorisation and
water use licences). Trenches will be excavated to provide a minimum cover of
900mm using various construction methods (e.g. hand excavation, backacter to
excavate soil and pecker or jackhammers to break rock before removing with a
backacter, specialised trenching machines, etc.). Excavation will take place in a
manner that aims to avoid damage to existing utilities. Once the excavation has
been completed, suitable bedding material (e.g. soil or sand) will be placed in the
bottom of the trench. Where the excavated material is not suitable for this purpose,
material will be obtained from existing permitted borrow pits. In urban areas,
excavated material will be handled in accordance with the requirements of the
relevant local authority. Directional drilling will be undertaken in places where the
cable crosses key lines of infrastructure (rail, national roads etc.) and will be suitably
aligned and sufficiently deep so as to comply with legislation and authorities
guidelines. Buried hand holes will be established approximately every 900m along
the fibre optic data cable route. In addition, round manholes (with visible 600 to
800mm covers) will occur on average every 4km along the cable route or on either
side of a physical feature crossing (bridge, rivers etc.), with large man holes (with
visible double covers of 1,8mx2m) being installed as required at major junction
points and at repeater sites.
o Duct laying will take place directly from a drum spindle mounted on an excavator
moving along the trench. To avoid slackness in the duct, duct drums will be
positioned in line with the direction of the duct pull. The duct will be kept clear of any
abrasive material when being pulled into position to prevent damage to the duct
sheath. The duct will be bedded in sand/soil which shall extend 100mm around the
duct. The duct will be uniformly bedded in soil free of rocky material. The depth of
cover of duct will be approximately 950mm. Conduits will be used where
appropriate, notably within a bridge, rail, road and water course crossing. Hand
holes will be located approximately every 900m along the route.

Construction of associated repeater stations


Although it is the intention to remain within the SANRAL road reserve for the majority of the route,
are likely to be sections of the route where there are diversions from the road reserve.

Impacts will be described and rated in terms of their potential significance in the environmental
assessment. The management measures presented in this EMPr will be developed in response to
these impacts. Performance standards providing a robust measure of the effectiveness of the
defined mitigation are defined as part of the project monitoring (See Section 2.3).

Caution will be implemented in order to prevent or minimize the risk of disturbance to and damage
and/or destruction of:

Archaeological and cultural sites along all routes.


Rare and endangered flora and fauna
Wetlands found at points along the entire length of the fibre data cable route corridor.
Rivers 28 watercourse crossings have been identified by specialists (Table 3-3).
Human settlements and economic activity, especially around urban centres, including Human
settlements and economic activity, especially around urban centres, including Bloemfontein;
Graaff Reinet and Aliwal North.

1.2.4 Pre-construction and construction


The EMPr will put in place measures to avoid and mitigate impacts and optimize benefits arising
from activities during the pre-construction (e.g. establishment of access roads, campsites and
clearing of the construction right of way) and construction phase (e.g. trenching and laying of data
cable) of the Project. The construction process is detailed in Section 2.1 and again in Section 3.3.2
of this EMPr. The principal focus of management for pre-construction and construction will include:
personnel and contractor management and training; conduct and site management; landowner
relations; maintenance of complaints register; emergency preparedness; and management and
mitigation of impacts such as noise, dust and safety). The plan relating to these management
measures are presented in Section 2.1.
Assignment of responsibility and contractor management is especially important during the
construction phase, when contractors are used to build the data cable. Contractors will also be used
on an ongoing basis for a range of maintenance and other functions. Contractors will be held to best
practice performance requirements.

1.2.5 Operation
The operation of the cable will involve transmission of data along the fibre data cable along routes 1-
7, or portions thereof. The operation of the data cable is anticipated to be low-impact and is not
likely to result in significant negative effects on the environment. There will, however, be the need
for periodic maintenance and repair of the data cable and associated infrastructure. Contractors will
be held to the same HSE performance requirements that govern FibreCo.

The mechanisms for effecting the EMPr requirements are collectively called operational controls.
Such operational controls require that a responsible party, a budget and an implementation schedule
be specified and allocated, to further enable and facilitate implementation. Roles and responsibilities
need to be defined for implementation of the EMPr. To facilitate coordinated and purposeful
implementation, the EMPr management and mitigation measures are grouped in programmes and
plans.

1.2.6 Checking and corrective action


Checking and, if necessary implementing corrective action, form one of the components of the EMPr
management cycle. They ensure that the:

Required EMPr management activities are being implemented; and


Desired outcomes are being achieved.
As such this component will includes monitoring selected environmental quality variables as defined
in the objectives and targets.

Monitoring
The environmental variables that are to be monitored are described in the description of the baseline
environment in Section 3.1. Monitoring results must be structured and presented for review on an
ongoing basis so that if objectives and targets are not met, corrective action can be taken.

Inspections: construction phase


Owing to the transient nature of the construction phase, the greatest source of information is that
obtained through ongoing visual inspection. At the same time some potential impacts are difficult to
monitor quantitatively, such as soil erosion and waste management. An ongoing, but pragmatic
inspection regime will be developed that allows for potential HSE transgressions to be identified
proactively so that mitigation can be quickly and effectively implemented.

Internal audits
Where the monitoring data and the inspection reports highlight problems, an internal audit can be
used to ascertain the source of the problem and to define action to prevent its recurrence. The three
key areas for audit are facilities (are they operating properly?), project procedures (are they properly
designed and implemented?) and finally, and perhaps most importantly Contractors HSE
performance.

Corrective action
There are several mechanisms for implementing corrective action, both during the construction and
operational phases. The main mechanisms to address transgressions include: verbal instruction (in
the event of minor transgressions from established procedure, usually following a site inspection);
written instruction (identifying source/s of problems, usually following an audit) and contract notice
(following possible breach of contract).

Reporting
The findings of all of the above will be structured into instructive reporting that provides information
to all required parties on HSE performance, together with clearly defined corrective action where this
is seen to be required. Both the monitoring and inspections are reported on continuously. Within the
reporting structure it is necessary to create a review function that continuously assesses the
reporting and prescribes any necessary corrective action.

1.2.7 Management review


The final component of the EMPr management cycle is a formal management review that takes
place at defined intervals, both during the construction and operational phases. The purpose of the
management review is for senior project management to review the environmental management
performance during the preceding period and to propose measures for improving that performance
in the spirit of continuous improvement.

1.2.8 Liaison
Throughout the project, liaison will be maintained with relevant parties (authorities and/or
communities) to ensure the following:

Advance warning to communities and/or landowners, where a project activities is likely to


infringe on private land, or where project activities may have some adverse impact on
surrounding communities, e.g. clearing of construction of right of way and activities such as
blasting;
Feedback to the relevant authorities (e.g. water affairs, environmental affairs) on the
environmental performance during the construction phase of the project.

1.3 Assumptions
All the technical data and information provided by the proponent to the EAP and specialists are
accurate and up-to-date.

The public involvement process has been sufficiently effective in identifying the critical issues
that needed to be addressed through specialist investigations and/or by the EAP. Specialist
input has thus been appropriately scoped to investigate the critical issues.

The public involvement process has sought to involve key stakeholders and every effort has
been made to ensure that landowners affected by the development, in particular those whose
land is traversed by the development, have been provided opportunity to comment. It is
assumed that where participation has been sought from the organizational representative/s, that
these parties have the authority to comment on behalf of their organization.

FibreCo and its contractors will implement the measures contained in the EMPr.

A monitoring and evaluation system, including auditing, will be established to track the
implementation of the EMPr to ensure that management measures are effective to avoid,
minimize and mitigate impacts; and corrective action is undertaken to address shortcomings
and/or non-performances.

FibreCo and its consultants will adopt a process of continual improvement when managing
and/or mitigating negative environmental impacts arising from the project. The EMPr will be used
as the basis of environmental management and will be improved and refined regularly.
Assumptions specific to each specialist study are given in the specialist reports included as
Appendices D1 to D5 of the Basic Assessment Report as applicable.

1.4 Uncertainties
The outcome of the land acquisition/negotiation for use of servitudes has not been finalised and
falls beyond the scope of this BA and EMPr.

Although locations of repeater sites are presented in the project documentation, the exact
location of the repeater sites can only be determined once the routing is finalized following the
conclusion of the servitude negotiation process and final route determination.

2 The Proposed Project


2.1 Optic fibre data cable
Data cable design will be finalised in an iterative manner during the course of the Project planning
and design phase. The following design detail is available for the pipeline at this stage:

The project entails the establishment of a long-haul fibre optic data cable network throughout
South Africa to carry data communications over long distances and at higher bandwidths than
are currently available in the market.
Additional routes between the major centres will be required for purposes of providing resilience
to the solution. This will entail alternative routes between the centres to provide a geographically
diverse path between the end-points. Fibre optic technology allows long distances to be
spanned with few repeaters. It is envisaged that a repeater will be situated approximately every
80 to 100km along the route housed in existing base station site infrastructure owned by one of
the promoters of the project. Prefabricated Telco grade equipment shelters will be constructed at
2
repeater sites to house approximately 30m of optical amplification equipment racks (typically 8
racks) with cooling units and backup generator. The facilitys primary power source will be the
national grid using existing transmission cables.
The data cable will have repeater stations located as follows:

Table 2-1 Repeater sites


SiteID Start Rd Nm Start Site Rd Nm S Min E Min Start Mid End
Route Deg Deg

IS022 NELSON N8 29 6.606" 26 12.148" Y


MANDELA
DRIVE
IS022 NELSON N8 29 6.598" 26 12.928" Y
MANDELA
DRIVE
IS022 NELSON N8 THIRD AVENUE, KELLNER 29 6.538" 26 12.450" Y
MANDELA STREET, FIRST AVENUE,
DRIVE BARNES STREET

IS033 NELSON N8 29 6.598" 26 12.928" Y


MANDELA
DRIVE
IS033 NELSON N8 MARKGRAAFF STREET, 29 6.582" 26 12.942" Y
MANDELA SAINT GEORGES STREET,
DRIVE CHURCH STREET

RE004 N9 N9 Rural 31 45.772" 24 55.195" Y


RE004 N9 N9 Rural 31 45.680" 24 54.907" Y
SiteID Start Rd Nm Start Site Rd Nm S Min E Min Start Mid End
Route Deg Deg

RE004 N9 N9 Rural 31 45.784" 24 55.190" Y


RE005 R56 R56 Rural 31 23.638" 25 36.791" Y
RE005 R56 R56 Rural 31 23.648" 25 36.779" Y
RE005 R56 R56 Rural 31 23.640" 25 36.766" Y
RE011 N6 N6 311m north of GROENEWOUS 29 38.720" 26 10.722" Y
STREET

RE011 N6 N6 Rural 29 38.724" 26 10.691" Y


RE011 N6 N6 274m north of GROENEWOUS 29 38.738" 26 10.719" Y
STREET

RE012 N6 N6 30 12.820" 26 31.995"


RE013 N9 N9 32 16.259" 24 32.717" Y
RE013 N9 N9 32 16.302" 24 32.722" Y
RE013 N9 N9 R63, BREE STREET, 32 16.620" 24 33.810" Y
KAPPERTJIE STREET,
SUNFLOWER STREET, VINK
STREET, NARSING STREET,
ASHER STREET, R63

RE023 N6 N6 30 40.436" 26 42.244" Y


RE023 N6 N6 30 40.447" 26 42.242" Y
RE023 N6 N6 Rural 30 40.440" 26 42.199" Y
RE024 R391 R391 31 7.521" 26 11.706" Y
RE024 R391 R391 31 7.551" 26 11.689" Y
RE024 R391 R391 Rural 31 7.534" 26 11.649" Y
RE028 M30 M30 CHURCH STREET 29 12.649" 26 12.837" Y
RE028 N6 N6 29 12.674" 26 12.840" Y
RE028 M30 M30 29 12.618" 26 12.839" Y

2.1.1 Construction and installation

Construction of the fibre data cable and associated infrastructure is anticipated to commence in mid
2011, following the issuing of requisite authorisations. The construction phase will take 12 months
and the cable commissioned in 2012. The expected lifespan of the cable is more than 20 years. The
process of establishing an optic fibre data cable will include the following:

Planning will be carried prior to the commencement of excavation. This phase of the project will
include surveying of the route to identify physical features that occur along the route and prepare as
constructed records (e.g. layout plans that show the length and depth of cables, indicate places
where directional drilling will occur and provide High Voltage cable points and material and
equipment schedules, amongst others.) It will also be necessary to obtain information about all
utilities that the cable will cross. All approvals and authorisations for development and crossings (e.g.
transmission lines, railway lines, telecommunications and water pipes) will be obtained during the
planning phase of the project. A management plan will be prepared setting out the measures that
aim to avoid and/or mitigate potential risks, hazards and impacts.

Trenching and excavations will commence once the requisite approvals and authorisations have
been obtained from relevant authorities (e.g. South African National Roads Agency Limited
(SANRAL) regional managers approval of the plans, environmental authorisation and water use
licences). Trenches will be excavated to provide a minimum cover of 0.9 metre using various
construction methods (e.g. backacter to excavate soil and pecker or jackhammers to break rock
before removing with a backacter). Excavation will take place in a manner that aims to avoid damage
to existing utilities. Once the excavation has been completed, suitable bedding material (e.g. soil or
sand) will be placed in the bottom of the trench. Where the excavated material is not suitable for this
purpose, material will be obtained from existing permitted borrow pits. In urban areas, excavated
material will be handled in accordance with the requirements of the relevant local authority.
Directional drilling will be undertaken in places where the cable crosses key lines of infrastructure
(rail, national roads etc.) and will be suitably aligned and sufficiently deep so as to comply with
legislation and authorities guidelines. Buried hand holes will be established every 900m along the
fibre optic data cable route. In addition, round man holes (with visible 600 to 800mm covers) will
occur on average every 4km along the cable route or on either side of a physical feature crossing
(bridge, rivers etc.).

Duct laying will take place directly from a drum spindle mounted on an excavator moving along
the trench. To avoid slackness in the duct, cable drums will be positioned in line with the direction of
the duct pull. The cable will be kept clear of any abrasive material when being pulled into position to
prevent damage to the duct sheath. The duct will be bedded in sand/soil which shall extend 100mm
around the duct. The duct will be uniformly bedded in soil free of rocky material. The depth of cover
of cables will be approximately 950mm. Conduits will be used where appropriate, notably within a
bridge, rail, road and water course crossing. Hand holes will be located approximately every 900m
along the route.

Reinstatement will take place in accordance with authorities requirements. In urban areas,
excavated land will be returned to its original condition. Trenches will be backfilled and compacted to
original ground level. Spoil and approved backfill material will be placed in such a manner so as to
avoid future subsidence. Stones, rock and paving material will be removed from site. Trees within
the affected area will be protected as far as possible.

All activities, notably those involving the installation of the fibre optic data cable, will adhere to the
requirements of the legislation dealing with occupational health and safety and public safety. Special
attention will be given to these issues when working in close proximity to traffic as well as overhead
power transmission lines.

2.1.2 Start and end points of data cable


The data cables will start and end at a designated IS/Teraco premises. Presently the following
start/end points have been identified:

Bryanston, Johannesburg;
Bloemfontein;
Bree Street, Cape Town;
Durban; and
George.

Locations of these and other sites will be determined as the project progresses.
2.1.3 Design and equipment standards
The design and equipment standards for the data cable and its associated infrastructure will comply
with national and international standards and best practices. The data cable will be designed to
have a minimum lifespan of 20 years.

2.1.4 Monitoring
Monitoring of the data cable, and its associated infrastructure, is essential to ensure efficient
operation. Measures will be instituted to ensure a best practice HSE system is developed and
implemented to ensure that personnel are properly trained to carry out their work.

2.2 Construction phase


Pre-construction activities will include: preparation of plans; servitude establishment where the
route/infrastructure falls outside the national and provincial road reserves; land surveying;
establishment of construction campsite/s; building of access roads; and clearing of vegetation and
removal of obstructions in the path of the proposed data cable.

2.2.1 Scale and pace of construction


It is envisaged that construction will happen concurrently, with a suitable number of separate
construction teams working on different portions of the route corridor simultaneously. It is envisaged
that there will be between 2 and 4 construction teams operating on the development at any one time.
The final number will be determined by ZTE and will take into account a number of factors, including
time and cost.

The average rate of progress of construction will be strongly dependent on ease of excavation and
may vary from a kilometre a day to 50 m per day depending on the terrain. The temporary
construction right of way required will be approximately 5-7 m.

2.2.2 Construction process


The construction process is as follows:

An open ditch will be dug using excavators, backacters, specialised trenching plant and manual
labour. Topsoil will be set aside during excavation and will be replaced on the reinstated trench
prior to revegetation. This will be carried out in accordance with the SANRAL and provincial
government requirements;

The cable (ducting) will be laid on a bedding layer approximately 100 mm thick and covered with
the same material to protect it from abrasion through contact with surrounding rock. Material for
the bedding will be sorted from excavated material for the trench wherever possible. Where this
is not feasible, sand will be sourced from existing mining operations, thus avoiding the need for
new borrow pits;

The trench will be backfilled with stockpiled material from the excavation of the trench. Topsoil
will be replaced on the soils surface. Erosion protection measures, where necessary, will be put
in place including packing trench walls with sand bags (Hessian bags filled with soil) to prevent
washout of material. Alternatively, the duct will be encased where required for reasons including
constructability in rock; and

River crossings will be undertaken using the following construction methods:

o Directional drilling of a parabolic-shaped tunnel under large rivers to minimize or avoid


disturbance of the river;
o Open cuts of rivers made at right angles to reduce the length of the crossing, and can be
backfilled with concrete to reduce the risk of erosion damage; and
o Pipe jacking will be carried out as required, based on financial considerations.

2.2.3 Energy, water, sanitation and waste requirements


Temporary construction camps will be established where required in remote areas. There will be
energy and water use requirements (to be determined and supplied by ZTE). Water use will be
limited to domestic and cooling purposes, and must be arranged by ZTE from authorised supplies.
Sewage and waste generated by activities of the construction camp will need to be disposed of.
During the lifespan of the project electronic components will need to be updated and replaced from
time to time. E-waste generated will be suitably disposed of at a registered landfill site.

2.2.4 Employment
It is anticipated that the greatest number of new jobs will be created during the construction phase of
the project. These employment opportunities will require a combination of both skilled and unskilled
labour in a range of technical fields. Wherever possible, workers will be recruited from the local area.
At the time of writing this generic EMPr no figures were available.

2.3 Operational phase


2.3.1 Transmission of information
The system will comprise of a network of glass optical fibre strands (thin strands of very pure glass
each about the size of a human hair) bundled together with various layers of protection to form a
composite data cable. The cables do not contain any insulating oils or other hazardous substances.

At either end of a cable system there will be a range of electronic and optical equipments housed
within an existing building generally in metro sites. These optical devices convert electrical signals
from traditional telecommunication sources into a light signal through a laser diode and transmit a
multitude of coloured laser signals inside the glass optical fibre strands from one end of the system
to the other end. There are no electrical signals sent along the system and therefore no risk of
electromagnetic interference, induction or leaks.

Due to the properties of the glass fibres leading to attenuation and power dissipation of the laser
signal over distance, there will be signal amplification sites situated at every 80 km 100 km along a
single fibre route, and at every 200km 250km the signal will be regenerated by similar optical
transmission equipment. These sites will typically house a series of electronic equipments inside a
standard convert the laser signal into an electromagnetic signal and boost it up for re-transmission.

The laser diodes are all Class 1M products that conform to the IEC 60825-1 which states a
maximum power of 100mW and they also have built in sensors that shuts the system down when
there is a fibre break (this works through a detection of a reflected signal when a fibre strand is cut).
This ensures that the IEC EYE SAFE standards are also met along the whole network.

2.3.2 Safety and security


The operation of the cable and its associated end points will be monitored by trained personnel.
Regular maintenance checks will be also be undertaken.
2.3.3 Energy, water, sanitation and waste requirements
Transmission of data will be powered by electricity drawn from the national grid with backup
generators in the case of power failures. Energy will be provided by Eskom and local authorities via
the national electricity grid. There will be the requirement for on-site ablution facilities at data end
points and repeater sites. Water use will be limited to domestic and cooling purposes, and will be
the responsibility of ZTE.

2.3.4 Monitoring
Monitoring of the data cable route and its associated infrastructure will need to be carried out for the
first 12 months after installation and rehabilitation to ensure problems such as erosion caused by
surface runoff are rectified.

2.3.5 Employment
During the operational phase, employment opportunities will be limited to technical staff responsible
for the maintenance and safety of data cable. No figures were available at the time of writing this
report.

2.4 Decommissioning
It is envisaged that the data cable will be operational for 20 years. The facility will be left in situ
following decommissioning. Equipment at repeater sites and at data end points will be removed and
suitably disposed of/ reused.

3 Impact mitigation and management


3.1 Links with the Basic Assessment
This chapter describes the mitigation and management measures required to respond to the
potential impacts identified. These measures are presented in Table 3-1. To facilitate cross
referencing, impact identification numbers are provided in the BA and the EMPr.

Section 3.3 of this document describes the management plans within which management and
mitigation measures will be implemented. The rationale is to cluster related measures in a cohesive
and systematic structure, ensuring clear roles and accountable management, together with
integrated and efficient implementation.
3.2 Mitigation and Management Measures per Phase
Table 3-1: Mitigation and management measures relating to impacts caused by project activities during all project phases
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
Soils and land 5 Unstable geology / soils Make sure that careful routing of the data cable is implemented to Soil conservation
capability avoid areas where the geology and/or landform is unstable and management
could be susceptible to events including landslides or Decommissioning plan
subsidence. Ensure that data cable design and construction take
Land acquisition and
account of potential risks the data cable, in particular for the
compensation plan
operational phase.
5 Sterilization of soils Ensure that negotiations are carried out with landowners to
compensate them for temporary losses caused by sterilisation of
soil in the construction-right-of way during preconstruction and
construction. This will apply in instances where the development
departs from the road servitude. In these instances provision
should be made through servitude negotiations for those farmers
suffering permanent loss of the servitude for cultivation of deep-
rooting crops. Servitude negotiations will be held with SANRAL
and relevant provincial road agencies.
5 Loss of land capability and potential Where applicable, establish measures for the effective
rehabilitation to ensure that appropriate/compatible farming
activities can resume in the construction-right-of-way and
servitude during the operational phase of the project. Where
appropriate, ensure that negotiations with landowners take
account of loss of production of crops such as forestry and fruit
orchards.
4 Increased erosion potential and Set up measures to ensure that for all project phases that soil
sedimentation erosion along the length of the data cable is prevented and
proactively managed.
5 Contamination of soils Measures need to be put in place to prevent soil contamination
for the preconstruction and construction phase (from vehicles and
machinery).
Ground-water Impact on flow Apply appropriate routing to avoid springs, boreholes and Water quality management
strategic groundwater resources to minimize structural damage programme
from construction activities including any potential blasting. Construction management
plan
Decommissioning
management plan
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
Air quality 45 Decreased air quality due to dust Develop and implement effective measures for minimisation of Air quality management
dust during the preconstruction and construction phase, followed programme
by timeous rehabilitation.
Waste 44 Pollution from waste generation Make certain that procedures for safe and appropriate disposal of Waste management plan
waste are developed and implemented for all project phases.
Hazardous waste generated during construction and E-waste
generated during operation will need to be disposed at a
hazardous waste site.

Noise and 50 Noise during construction Implement measures to ensure that ambient noise levels are Noise management plan
vibration minimised during the preconstruction and construction phase. Communication and
Maintenance during operation Implement measures to ensure that ambient noise levels are information plan
minimised during maintenance. Community safety plan

Blasting Ensure that procedures are put in place to minimise impacts and
provide advance warning of the blasting timetable to
communities.
Offence to cultural practices of local Implement measures to ensure that behaviour and practices of
communities staff and contractors do not cause offence to local communities
and landowners during preconstruction and construction, as well
as the operational phase.
Visual impacts 51 Impacts on the visual landscape Make certain that visual impacts during the preconstruction and Construction management
construction phase are minimised. Ensure that rehabilitation is plan
implemented promptly following laying of the data cable. Construction control plan
Socio- 51 Compatibility with existing and Ensure that routing of the data cable avoids dense settlements, Construction management
economic proposed land uses as well as where possible plantations and orchards where plan
possible. Coordinate an effective communication programme with Labour and human resources
local authorities, SANRAL and provincial roads agencies during plan
preconstruction, construction and maintenance activities.
Community safety plan
Soil conservation
management plan
Land acquisition and
compensation plan
Cultural resources
management programme
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
49 Increased crime and in-migration Implement measures to manage expectations about job creation
during the preconstruction, construction phase as well as the
operational phase. Develop and put into practice strategies to
minimize crime, to include effective communication with
landowners to inform them about the movement of work teams,
and codes of conduct for contractors and employees.
53 Creation of employment Implement where feasible measures to employ local community
opportunities members during both the preconstruction and construction
phase.
49 Disruption of social / economic Where possible plan routing to minimise disruption of sensitive
activities social receptors and that measures are put in place for the
preconstruction and construction phase to minimize disruption of
communities and economic activities.
48 Disruption of utilities and Ensure that routing prevents disruption of infrastructure as far as
transport possible and that effective communication is maintained with
utilities to avoid and minimize interruption of services during
preconstruction and construction.
Increased risk of disease Ensure effective communication with communities to limit
expectations of employment creation. Develop and implement a
health, safety and environment programme for employees.
49 Social divisions over limited jobs and Develop and implement transparent employment and
perceived preferential access procurement measures which comply with the regulatory
framework and maximise local benefits.
Traffic 46 & 48 Damage to roads and other transport Ensure that routing minimises disruption of major road and
infrastructure railway networks. Put measures in place to ensure that disruption
of road and rail is minimised for the preconstruction and
construction phase.
48 Increased traffic and road safety Implement measures to ensure that traffic and road safety
hazard hazards are minimised during the preconstruction, construction
and maintenance.
Health and 47 Occupational health and safety Develop and implement measures to promote the health and Workplace health and safety
safety safety of contractors and employees during the preconstruction plan
and construction phase. Community safety plan
Public safety Develop and implement measures to minimize the risk of injury of Emergency response plan
the public during preconstruction and construction. Social responsibility plan
Damage to the data cable by third Implement effective communication and knowledge of
party interference requirements with landowners and utilities to minimize risk of
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
accidental damage to the data cable.
Surface Water 42 Impact on flow Apply appropriate routing as well as river crossing methods to Water quality management
Impacts minimize disruption of wetlands and rivers during preconstruction Construction management
and construction. plan
41 Impact on water quality Implement preventative design, monitoring and management Construction control plan
measures during the preconstruction and construction and Communication and
operation. information plan
Damage to the data cable and Ensure alignment, design and construction of the cable result in
associated infrastructure by flooding effective measures to minimize risk from flooding for the
operational cable.
41 General wetland impacts 1. Wetland boundaries should be clearly marked in work areas Method statements for each
to assist the project personnel, contractors and river crossing
environmental officer to avoid unplanned disturbances to
the wetlands as well as to demarcate the area to which
these guidelines apply.
2. Preferably trenching should be done in the dry season to
minimize the risk of compaction and disturbance to the
wetland.
3. Where machinery is to be used, the necessary
precautionary measures need to be put in place to minimize
their impact, especially when this involves driving through
eh wetland. Where vehicles need to enter the wetland for
trenching, the impact can be mitigated by lowering the tyre
pressure, thereby distributing the load over a larger area.
This more so for wetter wetlands.
4. Maintain only the minimal footprints for the wrok necessary
to accomplish the task at hand.
5. Remove the top 30 cm as sods, i.e. the vegetation and
underlying soil must be removed as a unit and stored
separately from the underlying material. These can be
stockpiled immediately next to the trench if backfilling is to
occur within 24 hours and if the local hydrological conditions
allow, i.e. there is no surface water on site.
6. Replace the oil in the reverse order in which it was
removed, i.e. the soil that was removed last must be used
as the first backfill.
7. Ensure that the top 30 cm of backfill is the topsoil (sod)
layer of the material that was excavated from the wetland;
8. The backfill must be restored to it pre-construction elevation
upon completion of the work. This is to prevent the
establishment of preferential flow pathways.
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
9. Ensure that trenching does not create a subsurface drain,
i.e. and underground preferential flow path due to i.e.
backfilling with soil of lower permeability. This in particular
where trenching is to occur in the same direction of the
natural flow. Precautions can include inserting clay plugs at
approximate 1m 2m intervals.
10. The use of concrete within wetlands is not considered to
pose any specific environmental risk, other than potentially
influencing subsurface drainage patters through its physical
presence. This will, however, depend on the extent.
41 Reduction in water quality ZTE shall prepare for each river crossing a detailed method Method statements for each
downstream statement for review by FibreCo and for approval by the DWA. river crossing
1. Construction will take place during the dry season.
2. Large rivers with constant, high volume flows and which
possess other characteristics that make trenching
impractical will be crossed via directional drilling.
3. River diversions will be properly constructed to ensure that
no river water flows through the construction area.
4. All diversions and coffer dams will be constructed of non-
erodible material during construction, for example, sand
bags or clean gravel with plastic liners.
5. Any water released from coffer dams to the natural water
body will be treated suitably prior to discharge, for example,
water may be filtered through hay bales to remove sediment
where appropriate
6. Stormwater from upstream will be diverted around the
construction sites and stormwater in the construction area
will be contained for settling of any eroded solids prior to
release. to limit the volumes of water flowing through the
site, becoming contaminated and adding to erosion.
7. Berms will be constructed along the entire right of way and
along the edge of watercourses where necessary to
minimise sediment flow into the watercourse.
8. All berms will be constructed of non-erodible material, for
example, sand bags or clean gravel with plastic liners.
9. Berms will be constructed downstream of all construction
areas in rivers to ensure that sediments do not travel
downstream during storm events.
10. Any water released from the construction area to the natural
water body will be treated suitably prior to discharge, for
example, water ponded at berms may be filtered through
hay bales to remove sediment where appropriate.
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
11. Any material excavated from the bed or banks of the
watercourse will be removed and temporarily stored at a
location out of the water body until the materials are
permanently removed from the location or backfilled into the
water body. Where sufficient space exists, and where the
storage will not cause any environmental damage, this may
be within the macro-channel banks of the river.
12. All machinery and substances used on the site will be
checked for leaks and otherwise properly maintained.
Where leaks are found immediate action must be taken to
stop the leaks. All contamination from leaks will be
immediately removed and remediated.
13. Provision shall be made to suitably manage sewage and
liquid waste generated during construction
14. Water used for drilling will be treated to a standard
acceptable to DWA before release to a water course; this
will largely entail settling and release of settled water with
settled solids used for backfill.
15. Water downstream of river crossing sites will be monitored
before and during construction to ensure no degradation of
water quality.
16. All contractors will be in possession of an up-to-date
Emergency Preparedness Plan, which will include
telephone numbers of relevant emergency authorities.
17. FibreCo shall commission periodic independent audits of
sediment generation caused by the construction works in
the rivers in order to verify the results of the sediment
monitoring maintained by ZTE
18. All construction areas will be rehabilitated so that erosion
does not occur after construction is complete;
19. Rehabilitation will include:
All construction materials and debris will be removed and
river banks and channels will be returned to pre-existing
profile (or a more stable profile than that which existed prior
to construction). ZTE may make use of the fixed point
photography taken by FibreCo in order to ensure
compliance with this requirement;
River embankments shall be stabilised, using any necessary
protection measures, including re-vegetation, rip rap, reno
mattresses and other measures, to ensure that the banks
are protected against erosion;
Indigenous species will be used for rehabilitation and where
soils have been compacted, these will be loosened to 30 cm
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
prior to revegetation;
Where appropriate, silt fences placed at 90 degrees to the
stormwater approach could be used to stabilise disturbed
banks and reduce the erosive potential of stormwater during
vegetation establishment these fences will be removed
once vegetation is established;
Livestock will be removed or at a minimum controlled in key
areas for a period of one year to facilitate vegetation
regrowth;
The use of riprap will be restricted to areas where flow
conditions preclude effective vegetation stabilisation;
20. Permanent slope breakers will be installed along the data
cable route
21. In excavating the bed of the water body for the data cable,
ZTE shall comply with the following:
the excavated areas must be backfilled with material that is
of the same quality, and gradation to that which was
removed except in cases where blasting and grouting of the
data cable takes place;
where blasting takes place (if applicable), the rock replaced
in the trench at the surface is to give the trench as natural
an appearance as possible, so that in low flow periods, a
linear scar is not obvious.
22. ZTE will ensure that the data cable is buried an
adequate depth below all rivers and wet areas to ensure that
subsurface flow does not expose the data cable.
23. Conduct annual monitoring of rehabilitated sites for at least
three years post construction and implementation of
corrective action where required, for example, removal of
alien invasive vegetation (revegetation is considered
successful if the cover of grass, herbaceous and/or woody
species is at least 80 percent of the type, density, and
distribution of the vegetation compared to baseline
conditions, or in adjacent areas that were not disturbed by
construction).
24. Avoid removal of the data cable.
25. If the data cable is removed the mitigation measures as for
the construction phase must be followed.
13 Alteration of watercourse flow 1. River diversions will be properly constructed and water will
be returned to the natural course of the river immediately
downstream of the construction site
2. Large rivers with constant, high volume flows and which
possess other characteristics that make trenching
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
impractical will be crossed via directional drilling so that the
flow is not altered.
3. The volume of water used for drilling will be kept to a
minimum so as to minimise the change in flow in the river.
Alternatively drilling water could be directed to a sewage
works if the sewage works will agree to take that water.
4. After construction is complete the natural course (bed and
banks) of the river will be restored.
5. Avoid removal of the data cable.
6. If the data cable is removed the mitigation measures as for
the construction phase must be followed.
Wetland 13 Impacts on instream flow and Stay in road reserve wherever possible
wetland recharge All excavated trenches are to be backfilled and lightly
compacted and reseeded with indigenous vegetations
species that provide cover and bind soil
Reprofile area to ensure that no changes to runoff patterns
occurs
Ensure that alien vegetation is controlled in disturbed areas
after construction I completed
The duration of impacts on the system should be minimised
as far as possible by ensuring that the duration of time in
which flow alteration and sedimentation will take place is
minimised.
During the construction phase, no vehicles should be
allowed to indiscriminately drive through the wetland areas.
All areas affected by construction should be rehabilitated
upon completion of the construction phase of the
development. Areas should be reseeded with indigenous
grasses as required.
Fires within the wetland areas must be prevented at all
times.
14 impacts due to sedimentation, Stay in road reserve wherever possible
erosion and canalisation All excavated trenches are to be backfilled and lightly
compacted and reseeded with indigenous vegetations
species that provide cover and bind soil
Adequate stormwater management must be incorporated
into the design of the proposed development order to
prevent erosion. In this regard special mention is made of
the installation of drift fences to capture silt. This measure is
particularly important in catchments of increased ecological
importance and sensitivity and in systems where the bed
substrate consists of cobbles
Reprofile area to ensure that no changes to runoff patterns
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
occurs
The duration of impacts on the system should be minimised
as far as possible by ensuring that the duration of time in
which flow alteration and sedimentation will take place is
minimised.
During the construction phase, no vehicles should be
allowed to indiscriminately drive through the wetland areas.
All areas affected by construction should be rehabilitated
upon completion of the construction phase of the
development. Areas should be reseeded with indigenous
grasses as required.
Fires within the wetland areas must be prevented at all
times.
16 Impacts on riverine systems of Refer to all site specific impacts for riverine and tidal
conservation importance systems

17 Impacts on instream and wetland Stay in road reserve wherever possible


migratory corridors Reprofile area to ensure that no changes to runoff patterns
occurs
The duration of impacts on the system should be minimised
as far as possible by ensuring that the duration of time in
which flow alteration and sedimentation will take place is
minimised.
During the construction phase, no vehicles should be
allowed to indiscriminately drive through the wetland areas.
All areas affected by construction should be rehabilitated
upon completion of the construction phase of the
development. Areas should be reseeded with indigenous
grasses as required.
Fires within the wetland areas must be prevented at all
times.
22 Impacts due to inundation Stay in road reserve wherever possible
Ensure that no alteration of the river bed material or river
bed profile occurs or that the longitudinal and cross
sectional profile of the wetland occurs
Adequate stormwater management must be incorporated
into the design of the proposed development order to
prevent erosion. In this regard special mention is made of
the installation of drift fences to capture silt. This measure is
particularly important in catchments of increased ecological
importance and sensitivity and in systems where the bed
substrate consists of cobbles
Reprofile area to ensure that no changes to runoff patterns
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
occurs
The duration of impacts on the system should be minimised
as far as possible by ensuring that the duration of time in
which flow alteration and sedimentation will take place is
minimised.
During the construction phase, no vehicles should be
allowed to indiscriminately drive through the wetland areas.

All areas affected by construction should be rehabilitated
upon completion of the construction phase of the
development. Areas should be reseeded with indigenous
grasses as required. Fires within the wetland areas must be
prevented at all times.
24 Alien invasive vegetation All excavated trenches are to be backfilled and lightly
encroachment compacted and reseeded with indigenous vegetations
species that provide cover and bind soil
Fires within the wetland areas must be prevented at all
times to prevent certain alien species such as Acacia
mearnsii from germinating.
In terms of the amendments to the regulations under the
Conservation of Agricultural Resources Act, 1983 and
Section 28 of the National Environmental Management Act,
1998 landowners are legally responsible for the control of
invasive alien plants on their properties and it is therefore
recommended that the declared weed and invader species
be removed.
For a minimum period of two years after construction, active
management of the rehabilitated areas should take place to
remove any recruited alien vegetation.
Vegetation 7 - 12 Impacts on terrestrial ecology Set up measures to ensure that during preconstruction and Conservation of natural
Ecology construction, impacts on sensitive ecological areas and individual habitats programme
protected biota are minimized and avoided through careful Construction management
routing of the data cable and management programmes plans plan
and procedures during construction.
Construction control plan
7 - 42 Impacts on aquatic ecology Make certain that routing of the cable avoids and minimizes Decommissioning
impacts on wetland and riverine habitat during the management plan
preconstruction and construction phase
11 Spread of alien invasive species Apply appropriate measures during construction phase to avoid
and/or minimise the spread of alien invasive species.
7 Clearing of vegetation and Although no particular side of the servitude is favoured with
regard minimising the impact on the vegetation along this route,
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
consequent loss of plant cover and however areas through major passes and large cuttings are
available habitat considered to be extremely sensitive. This is firstly due to the
lack of space, and secondly due to the unstable nature of the
rock and soil formations found in the region. A number of the
passes already have erosion / rock fall protection measures in
place, further reducing the available space for trenches.
Clearing of vegetation should be kept to a minimum, with
earthworks being kept to a minimum. Exposed areas should be
closed and compacted immediately after the construction.
Re-vegetation, where needed, as part of a rehabilitation plan is
always advocated, however to the low annual rainfall (normal
conditions), this may not be practical. It is suggested that the
shallow topsoil layer be stockpiled separately from the subsoil
layers, should the excavation exceed 0.5 m. Topsoil layers,
which contain seed and vegetative material, should be
reinstated last thus allowing plants to rapidly re-colonise the
closed trench.
8 Loss of biodiversity and change in It should also be noted that the passes and cutting also have the
plant community structure highest number of protected plants and these will require
permits from the local authorities with regard their removal (e.g.
Aloes). It is therefore suggested that prior to any construction
occurring, that a plant search and rescue operation is initiated
as part of the pre-construction Environmental Management
Plan. Some of these plants could then be retained for the re-
vegetation purposes, while excess plants could be distributed
amongst the following conservation, resource use and scientific
study groups for example:
Eastern Cape Parks Board this provincial authority uses
plants in the re-vegetation / rehabilitation of several nature
reserves within the province
Umtathi Training Project Africulture Programme. This
group collects and grows plants sourced from wild
populations that would be found acceptable for use in
traditional medicines, thus reducing the pressure on the
natural resources.
Depart of Botany, Rhodes University, Great Escarpment
Project. Taxonomists from this group are actively source
plants for genetic studies from the mountainous regions of
the study area, as preliminary results indicate that the
Sneeuberg (Graaff Reinet, Middleburg, Burgersdorp and
Queenstown) area should be classified as a Botanical Hot-
spot for biodiversity due to the high number of plant
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
endemics.
9 Loss of species or ecosystems of See above
special concern
10 Increase in the potential for soil The Construction Environmental Management Plan must
erosion include a monitoring step that evaluates the re-vegetation
process, the rate of plant colonisation and areas that are
showing erosion on a monthly basis.
11 Increase in invasive and alien Alien / invasive plants species will be monitored and cleared on
species cover an annual basis, using the most appropriate measures as
suggested by the Department of Agriculture, Fisheries and
Forests, see Henderson (2001).
12 Impact of repeater stations Prior to any construction occurring, the suggested plant search
and rescue operation must be initiated as part of the pre-
construction Environmental Management Plan, with particular
reference to RE012 and RE004, as these rocky areas contain
conservation needy species. (Note that proposed RE012 site
has been relocated to Smithfield where the impacts are
significantly reduced.)
Run-off from the hard surface areas should be managed using
suitable stormwater infrastructure in order to prevent any
erosion from occurring around the site
Fuel storage should be kept to a practical minimum, e.g. enough
fuel to supply the generator for no more than 12 hours, in order
to minimise the risk. Adequate security should also be installed
as a number of the areas are remote increasing the risk of
potential theft, which increases the risk of potential spills.
Bunds around any fuel stores should be adequately sized in
order to retain any accidental spills.
Archaeological 57 Concentrations of archaeological All work in that area should stop and it should be reported
material and human remains are immediately to the nearest museum/archaeologist or to the
exposed during construction South African Heritage Resources Agency so that a systematic
and professional investigation can be undertaken. Sufficient
time should be allowed to remove/collect such material (See
appendix 1 for a list of possible archaeological sites that may be
found in the area)
58 The memorial accident crosses The memorial accident crosses should not be removed or
that occur along the route within the disturbed, however, if this is not possible then the crosses
proposed area, area considered as should be removed and relocated nearby or returned apriori the
heritage objects and are a part of installation of the fibre optic data cable
the modern cultural landscape
Impact Schedule
Aspect Impact Management activity Management plan
reference Prec Con Op Cl
58 Historical buildings, national The monuments that occur within the proposed route are clearly
monuments, statues, memorials. marked and most of them are protected by fences and should
be avoided during construction.
Palaeontologic 59 1. Excavations into roadcuttings identified during the survey in
al sensitive Karoo Supergroup sedimentary strata (see map)
between Graaf Reinet and Aliwal North are monitored on
site by a qualified palaeontologist, who should collect and
log important palaeontological material identifiable prior to
cutting, aswell as material freshly disturbed during cutting.
2. Disturbance of Palaeontological material in Karoo
Supergroup road cuttings between Aliwal North and
Bloemfontein, or in more recent alluvial deposits between
roadcuttings along the entire route, should be immediately
reported to a palaeontologist.
3.3 Management plans
3.3.1 Rationale
The majority of mitigation measures outlined in Table 3-1 cannot be implemented as discrete,
isolated actions, since there are spatial and causal interactions amongst impacts. Therefore it is
advisable to implement mitigation and management actions via integrated management plans.
These plans are outlined below. While generally the principles guide preconstruction and
construction, operational and decommissioning phase plans, some of them start during construction
and continue into decommissioning, such as soil conservation management, air quality and water
management. The following management plans need to be implemented during construction and
maintenance of the data cable:

Construction management plan (Section 3.3.2);

Labour and human resources plan (Section 3.3.3);

Workplace health and safety plan (Section 3.3.4);

Community safety plan (Section 3.3.5);

Land acquisition and compensation plan (Section 3.3.6);

Emergency management and response plan (Section 3.3.7);

Social responsibility plan (Section 3.3.8); and

Decommissioning management plan. (Section 3.3.9).

Many of the issues to be addressed in these plans are regulated in existing laws, regulations and
guidelines. In addition, it is recognised that the content of several plans will be generic, in the sense
that existing procedures are documented in standard codes of practice, and that adaptations of such
generic plans will only be possible as a dynamic process during construction and operation. Plans
presented below, therefore, contain specific actions as well as undertakings to prepare additional
plans as required prior to the commencement of certain activities during the detailed design phase.
FibreCo recognises the need for ongoing development and revision of all plans to ensure their
continued applicability.

3.3.2 Construction management plan


The construction management plan to be implemented by ZTE shall include the following key
measures:

Management of construction campsites


1. ZTE shall comply with all relevant laws and regulations concerning water provision, sanitation,
wastewater discharge and solid waste disposal. ZTE is referred, in particular, to the
requirements of the National Water Act (Act 36 of 1998) and related regulations, as well
as requirements contained in the WUL.

2. ZTE shall not locate campsites in any area in which vegetation is pristine, nor within
100 m of any watercourse, nor in any area that could cause nuisance or safety hazards to
surrounding landowners, inhabitants or the general public. The location of a construction
campsite requires prior landowner agreement.

3. Prior to the commencement of construction, ZTE shall also prepare documentation for each
proposed campsite which contains, but is not limited to, details of: (a) site layout; (b) topsoil
management; (c) sewage treatment; (d) solid waste disposal; (e) erosion control (f) fencing; (g)
litter management; (h) provision for vehicle and plant servicing; (i) management of hazardous
materials, (j) water supply, (k) management of veld fire risk (l) rehabilitation; and (m)security. The
documentation shall be submitted to FibreCo as a part of ZTEs project specific Environmental
Plan prior to establishment on site.

4. ZTE shall access construction campsites in compliance with this EMPr.

5. ZTE shall keep construction campsites clean and tidy at all times. ZTE shall not leave
domestic waste uncontained, and temporary storage shall be fenced to keep out people and
animals. No permanent domestic waste disposal shall be permitted at the campsites. All
domestic refuse is to be removed weekly to an existing licensed domestic landfill.

6. ZTE shall take specific measures to prevent the spread of veld fires, caused by activities at the
campsites. These measures may include appropriate instruction of employees about fire risks
and the construction of firebreaks around the site perimeter.

7. ZTE shall prevent accelerated erosion from construction campsites and shall not discharge
polluted runoff into drainage lines.

Management of fuels and other hazardous materials


8. ZTE shall comply with all applicable laws, regulations, permit and approval conditions and
requirements relevant to the storage, use, and proper disposal of hazardous materials.

9. ZTE shall manage all hazardous materials and wastes in a safe and responsible manner, and
shall prevent contamination of soils, pollution of water and/or harm to people or animals as a
result of the use of these materials.

10. ZTE shall prepare a hazardous materials and waste management plan for inclusion in the site
specific Environmental Plan to be submitted to FibreCo prior to establishment on site. This plan
shall include, but shall not be limited to, measures to prevent: (a) contamination of soils; (b).
pollution of water; (c) safe siting and storage; (d) containment of lubricants and waste oil during
maintenance of vehicles; and (e) tampering with tanks.

11. ZTE shall classify all hazardous materials to be used on site according to recognized Codes of
Practice such as SABS Code 0228 for the Identification and Classification of Dangerous
Substances and Goods and the DWAF Minimum Requirements for the Handling, Classification
and Disposal of Hazardous Waste, and shall ensure that the handling, storage, transport and
disposal of these materials meets the requirements of these Codes.

12. ZTE shall not locate fixed fuel storage tanks in any location other than at approved plant yards or
campsites. Any fuel storage facilities with a capacity greater than 1000 litres shall be located on
flat or gently sloping ground and shall be bermed from the surrounding area to contain at least
125% of the total capacity of the storage containers. The berms and the floor of the bermed area
shall be of impermeable material or be lined to ensure that petroleum products cannot escape.

13. The Contractor shall not construct fixed fuel storage or service or refuel any vehicle or
equipment within 100 m of a watercourse or wetland, within a floodplain, or where there is the
potential for spilled fuel to enter a watercourse or groundwater. Should it not be possible to
establish such a facility outside of the 100 m zone, the Contractor shall ensure that the
necessary precautions are taken to prevent and clean up spillages, including spill kits on the
bowsers. o

14. ZTE shall enclose all fixed storage by a security fence with a lockable gate.
15. When crossing watercourses and wetlands, the Contractor shall place on-site tools and
equipment, such as pumps, compressors and generators on bermed impermeable sheeting (e.g.
polyethylene or other similar material) to prevent hydraulic fluid or fuel leaks from contaminating
soil or groundwater or entering any watercourse or wetland.

16. ZTE shall take all reasonable precautions to prevent fuel and lubricant spills during the course
of construction. To this end, ZTE shall ensure that: (a) there is no overfilling of diesel bowsers
and equipment tanks; (b) regular audits are performed to verify that no leaking or defective
equipment is brought onto site; and (c) any oils or lubricants discharged during routine vehicle
servicing on site are captured using drip trays, containers or other appropriate containment
measures.

17. ZTE shall ensure that all equipment which is required to work in fish-bearing waters is cleaned of
oil, grease and other contaminants damaging to aquatic life.

18. ZTE shall ensure that fuelling and repairs are carried out or supervised by personnel familiar with
spill containment and cleanup procedures.

19. ZTE shall ensure that there is sufficient absorbent material available on site to manage
accidental spills. ZTE shall immediately clean up accidental spillages of fuels and oils, or other
hazardous substances, and shall report the incident to FibreCo and the measures taken to
remediate the spill problem.

Management of the construction right-of-way


20. ZTE shall obtain access to and along the cable (a) on a public road (b) on an existing private
road or track with the consent of the relevant owner or occupier of land (c) along the cable
and construction right-of-way and (d) along a specially approved route as defined below. Access
to, and along the construction right-of-way explicitly excludes access to land other than the
access routes referred to above.

21. The category of specially approved route is for cases where there is no existing access. A
specially approved route is one for which the relevant owner or occupier of land has given
consent, and for which approval has been applied for in writing, and granted in writing by
FibreCo, subject to any conditions that the landowner or FibreCo consider to be warranted (e.g.
regarding erosion control, rehabilitation). No specially approved routes will be granted if areas of
pristine habitat are to be impacted.

22. The utility and safety of any existing access shall not be lowered by use for the construction
work or construction-related activities, nor shall spillage, littering, accelerated erosion, or other
environmental impact, occur. ZTE shall: (a) ensure compliance with these requirements; (b)
exercise all relevant health, safety and environmental controls (including dust control, noise
abatement and litter prevention); and (c) remedy immediately any non-compliance and the
effects thereof.

23. In all areas where construction requires gravelling or other methods of improving vehicle access,
ZTE shall completely remove these materials after construction and prior to rehabilitation of the
area.

24. ZTE shall restrict the number of entry and exit points for security reasons. ZTE shall ensure
that his activities do not compromise the landowners or occupiers security, nor result in the
loss, injury or death of any farm animals or game.

25. The dismantling of gates and fences shall be subject to any special conditions reached in the
servitude agreements between FibreCo and landowners.
26. ZTE shall prevent littering and the random discard of solid waste on the site. The
Contractor shall not dispose of any waste in the data cable trench

27. ZTE shall manage hazardous waste as described in provisions 8 to 19.

28. ZTE shall minimise the risk of bush fires (refer to provision 6 and 38-43).

29. ZTE shall prevent trespassing on the site. Public entry to the site shall be prohibited and signs to
this effect shall be erected at points of potential public entry.

30. The Contractor shall prohibit and actively monitor and prevent poaching or harassment of
livestock, wild and domestic animals by contract employees. Any employee found poaching shall
be dismissed.

31. At the start of every working day ZTE shall patrol the open trench and rescue any animals that
are trapped in it either by catching and releasing (e.g. frogs and toads) or by driving out (e.g.
dangerous snakes).

32. ZTE shall prohibit and actively monitor and prevent the harvesting of medicinal or any other
plants by contract employees.

33. ZTE shall ensure that contract employees remain within the construction right-of-way or on
approved roads providing access to the construction right-of-way.

34. ZTE shall determine safe travelling speeds for each section of the route corridor along the right-
of-way and shall ensure that these restrictions are enforced. This may include, but not be
limited to, the monitoring of vehicle speeds and the erection of speed limit signs.

Emergency preparedness (see also Section 3.3.7)


35. ZTE shall develop an emergency plan that will enable rapid and effective response to all types of
environmental emergencies in accordance with recognized national and international standards.

36. The emergency plan shall include the establishment of a network of communication between ZTE
and emergency services including police, traffic police, local medical and ambulance services,
fire departments, farmers associations, conservancies, farmer neighbourhood watches, etc.

37. ZTE shall test emergency preparedness on a regular basis and review procedures to remedy
shortcomings to ensure a high level of emergency readiness to deal with environmental and third
party incidents.

Fire prevention and management


38. ZTE shall take all necessary precautions to prevent the ignition of veld fires caused either
deliberately or accidentally as a result of the work being performed.

39. ZTE shall prepare a fire prevention and fire emergency management plan as a part of the
Environmental Plan to be submitted to FibreCo prior to establishment on site. The plan shall
include, but not be limited to, the following: (a) sources of fire risk; (b) measures to comply with
any requirements of local authority fire departments; (c) measures to meet requirements agreed
between FibreCo and the landowner; (e) measures to minimize the risk of accidental veld fires
caused by any activity related to the work; and (f) measures to control an accidental veld fire.

40. ZTE shall provide adequate fire fighting equipment at specified localities on the work site to meet
any emergency resulting from ignition of a veld fire. This equipment should include, but not be
limited to, (a) fire extinguishers; and (b) fire fighting flails.
41. The areas of commercial plantations through which the data cable is routed are particularly
sensitive to fire hazard (such as in commercial forests) and ZTE shall strictly comply with all fire
management requirements set by the owners of these plantations.

42. ZTE may expect that hot work will be prohibited under specified meteorological conditions and
that appropriate and adequate fire fighting equipment would be required to be on standby at all
times where hot work is being carried out.

43. Wherever practicable, bush shall not be cleared using burning. In instances where this is
possible, controlled burning can only take place upon request of and approval from the
landowner, and when there is no wind and appropriate fire fighting equipment is in attendance.

Management of dust and noise nuisance


44. ZTE shall control dust along the construction right-of-way so as to ensure that no detrimental
effects to landowners, occupants or the general public are caused. Control measures to be
considered include the use of water bowsers to wet down surfaces that have been denuded and
which have the potential to generate dust.

45. ZTE shall comply with the legal requirements for the management of noise impact specified in the
Noise Regulations under the Environment Conservation Act (Act 79 of 1989). If instructed to do
so by FibreCo, ZTE shall demonstrate compliance with the noise regulations by means of
measurement of residual noise levels at receiver points specified by FibreCo. Measurement shall
be in accordance with the requirements of the noise regulations.

46. In the event that this should be required, the Contractor shall notify all landowners and
inhabitants within 200m of a blast zone of the dates and times at which blasting is scheduled to
occur. Blasting shall not be undertaken between the hours of 18h00 and 07h00 without the
agreement of the affected landowners and occupiers (See construction control plan, provisions
80-84).

47. The Contractors employees shall not make recreational use of all-terrain vehicles or
motorcycles on the site.

Land owner and occupier relations


48. ZTE shall respect the property and rights of landowners and occupiers at all times and shall
treat all such persons with deliberate courtesy.

49. The Contractor shall comply with all special agreements between FibreCo and affected
landowners provided in the Servitude Agreements and/or the Property Line List and/or required
in terms of relevant national legislation.

50. Access over land, the integrity of fences, the closure of gates, control of veld and forest fires,
littering, dust control, noise abatement, harassment of domestic and wild animals, sedimentation
and contamination of ground and surface waters, damage to landscape and vegetation, and all
such environmental matters, shall be controlled, as far as practicable, by ZTE in the best
interests of the land owner or occupier.

Complaints register
51. ZTE shall establish and maintain a register for periodic review by FibreCo that logs all complaints
raised by landowners, occupiers or the general public about construction activities. The register
shall be regularly updated and maintain records, including the name of the complainant, his or
her domicile and contact details, the nature of the complaint and if any action that was taken to
rectify the problem.
Health management
52. ZTE shall comply with all relevant legislative requirements governing worker health and safety
(e.g. OHS Act (Act 85 of 1993) and related amendments and regulations).

53. ZTE shall also prepare and implement a programme to minimize the spread of HIV infection as a
result of the construction contract. The programme shall be prepared with the assistance of a
medical doctor with experience of HIV prevention and treatment.

Control of construction activities in sensitive areas


54. Prior to the commencement of construction activities, ZTE shall (together with the ECO)
survey the limits of the construction right-of-way and of any additional workspace areas required
for construction and shall mark the limits using 1.5 m long stakes at 200 m maximum intervals.
These stakes shall be preserved throughout the work under contract. In the areas where
pristine habitat is affected, the stake interval shall be reduced to 50 m spacing and the stakes
shall be painted a conspicuous colour.

55. In these areas, ZTE shall take the following additional precautions: (a) staff and, in particular,
machine operators shall be specifically instructed about the sensitivity of the areas; (b)
vegetation clearance shall be restricted to the absolute minimum necessary to provide
access along the construction right-of-way; and (c) site staff responsible for environmental
management shall increase the frequency of monitoring in the areas to verify continuing
compliance with the environmental standard and the restriction of vehicle traffic to within the
construction right-of-way.

56. ZTE shall erect a physical barrier (e.g. a removable fence) to ensure that there is no
unauthorized access of any other areas by construction workers, or as specified in the servitude
negotiations with the affected parties.

57. In sections of the route corridor, where the data cable crosses the escarpment and where steep
and rugged terrain is experienced, ZTE shall prepare a detailed method statement for review and
approval by FibreCo prior to construction. The method statement shall include details of: (a)
access requirements and the construction of any necessary access roads; (b) any areas of cut
and fill required to complete the works; (c) an itemised list of equipment that will be used for the
excavation, laying of cable and backfilling of the trench; (d) measures to ensure the management
of erosion during the construction of the work; and (e) measures that will be used to stabilise
and rehabilitate the completed works. Such measures will need to consider special methods of
retaining topsoil on the slopes by reducing rainfall impact, re-vegetation methods that are less
prone to erosion loss (veld sod) and any other necessary measures to ensure that rehabilitation
is effective.

58. Damage or harm to threatened plant species is illegal in terms of legislation. Threatened species
are defined in terms of the most recent Red Data list of Southern African Plants. While every
effort has been made to ensure that the data cable route corridor does not impact on threatened
species, ZTE shall be solely responsible for any action necessary to ensure the prevention of
harm to such species found during construction. In the event that ZTE, FibreCo or any other
party in any area that could be damaged by the works finds a threatened plant, this shall
immediately be reported to FibreCo and the relevant authority (SANBI or one of the Parks
Boards as relevant). ZTE shall call upon a suitably qualified botanical expert to oversee: (a)
rescue of the plant(s) and transplantation in a suitable local habitat in a conserved area or in a
recognised botanical garden; or, where this is not possible; and (b) the collection of seeds and
cuttings for use at botanical gardens and for storage in seed banks.
Table 3-2 Specific requirements for the siting of the cable trench and repeater sites
ID Feature No Distance Length or Nearest Description Sensitivity Significant Mitigation Measure Specific
from Area of Town/City Action
road feature (where
reserve applicable)
(if
outside)
ECOLOGY
1 RE012 1.5km 100m2 Smithfield Indigenous 1 Yes Repeater located in vegetation type (Besemkaree Koppies Search and
vegetation Shrubland) that has been highlighted as having a medium rescue
sensitivity to development, thus due care should be used when
selecting the final locality of this site. There are two reservoirs (-
30.198081 26.525786) in close proximity to the proposed site,
with tracks leading to them. It is proposed that an adjacent
locality to these is selected. (Note that proposed RE012 site
has been relocated to Smithfield where the impacts are
significantly reduced.)
2 3.7km Smithfield Indigenous 1 Yes Minimise the potential loss in plant species and prevent a change Search and
vegetation in future vegetation composition and structure. Removal of rescue
3 513m Smithfield Indigenous 1 Yes protected plants will require permits from the local authorities Search and
vegetation (e.g. Aloes). prior to any construction occurring, that a plant rescue
4 10.6km Rouxville Indigenous 1 Yes search and rescue operation. Contact bontanist. Whereas some Search and
vegetation plants will be retained for revegetation purposes, excess plants rescue
5 1km Rouxville Indigenous 1 Yes will be used for conservation or research purposes, The following Search and
vegetation groups can be consulted in this regard: Eastern Cape Parks rescue
6 1.5km Aliwal North Indigenous 1 Yes Board this provincial authority uses plants in the re-vegetation / Search and
vegetation rehabilitation of several nature reserves within the province; rescue
7 1.5km Aliwal North Indigenous 1 Yes Umtathi Training Project Africulture Programme. This group Search and
vegetation collects and grows plants sourced from wild populations that rescue
8 26.5km Aliwal North Indigenous 1 Yes would be found acceptable for use in traditional medicines, thus Search and
vegetation reducing the pressure on the natural resources; and Depart of rescue
9 RE045 26.5km Aliwal North Indigenous 1 Yes Botany, Rhodes University, Great Escarpment Project. Search and
to vegetation Taxonomists from this group are actively source plants for rescue
Middelburg genetic studies from the mountainous regions of the study area,
as preliminary results indicate that the Sneeuberg (Graaff Reinet,
Middleburg, Burgersdorp and Queenstown) area should be
classified as a Botanical Hot-spot for biodiversity due to the high
number of plant endemics.
HERITAGE
1 2H1 Reddersburg Collection of 2 Yes Construction managers/foreman should be informed before
Afrikaans construction starts on the possible types of heritage and the
Monuments procedures to follow in the event of a discovery. Care must be
2 2H2 Smithfield Great Trek 2 Yes taken not to damage historic buildings and monuments.
stone
ID Feature No Distance Length or Nearest Description Sensitivity Significant Mitigation Measure Specific
from Area of Town/City Action
road feature (where
reserve applicable)
(if
outside)
monument
3 2H3 Later Stone 2 Yes
Age stone
artefacts
4 2H4 Later Stone 2 Yes
Age stone
artefacts
5 2H5 Aliwal North Historical 2 Yes
graveyard
6 2H6 Burgersdorp Hagenhuis 2 Yes
Restaurant/Cof
fee Shop
(National
Monument)
7 2H7 Burgersdorp Information 2 Yes
Centre
(National
Monument)
8 2H8 Burgersdorp Taal Monument 2 Yes
PALAENTOLOGY
1 1.5km Aliwal North palaeontolgical 1 Possible Excavations into roadcuttings identified during the survey in Investigation
material sensitive Karoo Supergroup sedimentary strata between Graaff
2 1.2km Aliwal North palaeontolgical 1 Possible Reinet and Aliwal North must be monitored on site by a qualified Investigation
material palaeontologist, who should collect and log important
3 900m Burgersdorp palaeontolgical 1 Possible palaeontological material identifiable prior to cutting, as well as Investigation
material material freshly disturbed during the cutting.
4 700m Burgersdorp palaeontolgical 1 Possible Investigation
material
5 1500m Burgersdorp palaeontolgical 1 Possible Investigation
material
6 800m Burgersdorp palaeontolgical 1 Possible Investigation
material
7 700m Burgersdorp palaeontolgical 1 Possible Investigation
material
8 1500m Burgersdorp palaeontolgical 1 Possible Investigation
material
9 1500m Burgersdorp palaeontolgical 1 Possible Investigation
material
ID Feature No Distance Length or Nearest Description Sensitivity Significant Mitigation Measure Specific
from Area of Town/City Action
road feature (where
reserve applicable)
(if
outside)
10 700m Steynsburg palaeontolgical 1 Possible Investigation
material
11 1500m Steynsburg palaeontolgical 1 Possible Investigation
material
12 1200m Steynsburg palaeontolgical 1 Possible Investigation
material
13 700m Steynsburg palaeontolgical 1 Possible Investigation
material
14 800m Steynsburg palaeontolgical 1 Possible Investigation
material
15 1000m Steynsburg palaeontolgical 1 Possible Investigation
material
16 1000m Steynsburg palaeontolgical 1 Possible Investigation
material
17 2000m Steynsburg palaeontolgical 1 Possible Investigation
material
WETLAND
1 BLMGR SOI11 C9 Bloemfontein Palustrine, 1 Yes Stay out of wetland zone. Stay within road reserve. Refer to
Valley bottom, method
Emergent statement
2 BLMGR SOI11 C8 Reddersburg Riverine, Upper 1 Yes Stay out of riverine area. Utilise bridge pillars. Refer to
Perennial, method
Aquatic bed statement
3 BLMGR SOI11 C7 Middelfontein Palustrine, 1 Yes Stay in road reserve. Refer to
Valley bottom, method
Emergent statement
4 BLMGR SOI11 C6 Middelfontein Palustrine, 1 Yes Stay in road reserve. Refer to
Valley bottom, method
Emergent statement
5 BLMGR SOI11 C5 Smithfield Palustrine, 1 Yes Stay in road reserve. Refer to
Valley bottom, method
Emergent statement
6 BLMGR SOI11 C4 Smithfield Lacustrine, 1 Yes Stay in road reserve. Refer to
Limnetic, method
Aquatic bed statement
7 BLMGR SOI11 C3 Smithfield Palustrine, 1 Yes Stay in road reserve. Avoid disturbance of seasonal zone. Refer to
Valley bottom, method
Emergent statement
ID Feature No Distance Length or Nearest Description Sensitivity Significant Mitigation Measure Specific
from Area of Town/City Action
road feature (where
reserve applicable)
(if
outside)
8 BLMGR SOI11 C2 Smithfield Palustrine, 1 Yes Stay in road reserve. Avoid riparian zone. Refer to
Valley bottom, method
Emergent statement
9 BLMGR SOI11 C1 Smithfield Palustrine, 1 Yes Stay in road reserve. Avoid riparian zone. Refer to
Valley bottom, method
Emergent statement
10 BLMGR C3 Smithfield Riverine, Upper 1 Yes Utilize bridge. Erosion control and alien vegetation control. Refer to
Perennial, method
Aquatic bed statement
11 BLMGR C2 Rouxville Riverine, Upper 1 Yes Stay in road reserve. Stay out of riparian zone. Refer to
Intermittent, method
Non vegetated statement
12 BLMGR C1 Rouxville Palustrine, Flat, 1 Yes Stay in road reserve. Refer to
Emergent method
statement
13 BLMGR SOI10 C3 Aliwal North Palustrine, 1 Yes Utilise bridge structure. Stay out of riperian zone. Refer to
Valley bottom, method
Emergent statement
14 BLMGR SOI10 C2 Aliwal North Riverine, Upper 1 Yes Utilise bridge structure. Stay out of river zone. Refer to
Intermittent, method
Non vegetated statement
15 BLMGR SOI10 C1 Aliwal North Palustrine, 1 Yes Stay within road reserve due to culvert structure. Flow control. Refer to
Valley bottom, method
Emergent statement
SURFACE WATER
1 92 25m Bloemfontein Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
2 93 25m Bloemfontein Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
3 125 60m Bloemfontein Bridge HIGH Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
4 114 50m Reddersburg Bridge HIGH Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
5 11 45m Reddersburg Bridge HIGH Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
6 145 25m Smithfield Bridge HIGH Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
7 133 10m Smithfield Bridge HIGH Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
ID Feature No Distance Length or Nearest Description Sensitivity Significant Mitigation Measure Specific
from Area of Town/City Action
road feature (where
reserve applicable)
(if
outside)
8 153 10m Smithfield Bridge HIGH Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
9 15 65m Smithfield Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
10 150 25m Rouxville Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
11 17 140m Aliwal North Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
12 142 100m Aliwal North Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
13 137 50m Burgersdorp Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
14 18 135m Burgersdorp Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
15 144 45m Burgersdorp Bridge LOW/MARGINAL Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
16 162 30m Burgersdorp Bridge LOW/MARGINAL Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
17 158 25m Burgersdorp Bridge LOW/MARGINAL Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
18 157 50m(1),60 Steynsburg Bridge LOW/MARGINAL Yes Stay within road reserve. Control riparian and stream damage. Trenching
m(2) Adhere to DWA/DEA authorisation requirements.
19 0 Steynsburg Yes Stay within road reserve. Control riparian and stream damage.
Adhere to DWA/DEA authorisation requirements.
20 304 60m Teebus Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
21 306 50m Middelburg Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Directional
Adhere to DWA/DEA authorisation requirements.
22 305 55m Middelburg Bridge MODERATE Yes Stay within road reserve. Control riparian and stream damage. Trenching
Adhere to DWA/DEA authorisation requirements.
59. The Contractor shall take note of the possible occurrence of threatened animals and, in
particular, antelope near the data cable route corridor. In addition to the general prohibitions
specified in provision 5, ZTE shall be particularly vigilant in these areas in order to ensure that
none of these animals are deliberately or accidentally harmed.

Control of vegetation clearing


60. ZTE shall not clear any vegetation along the construction right-of-way outside of the areas
defined by the stake markers referred to in provision 7 above.

61. ZTE shall clear vegetation along the construction right-of-way, and the access routes defined in
provisions 1 and 2, to the minimum degree necessary for construction. Cleared vegetation shall
be windrowed along the perimeter of the construction right-of-way.

62. The large indigenous trees occurring in the riparian, which have been individually categorised,
named, marked in the field shall not be damaged by ZTE. The trees shall be plotted on the
survey drawings. ZTE shall prevent damage to these trees in all cases where the trunk of the tree
is situated outside of the permanent right-of-way (6 m wide).

63. Where the data cable passes through an afforested (plantation) area ZTE shall comply strictly
with the conditions agreed between FibreCo and the owner.

64. Where ZTE has to dispose of vegetation cleared from the construction right-of-way, he/she may
do so with the permission of the landowner provided there is no impairment to the health and
well being of any person, to water quality, land use and capability or ecological stability of
the area in which it is disposed.

65. The burning of vegetation should be avoided as far as possible. ZTE shall only be permitted to
undertake the controlled burning of brush and other vegetation cleared from the construction
right-of-way, upon consent from the landowner and subject to compliance with any burning
regulations of the district. A method statement shall be prepared for each controlled burn,
and submitted to the relevant fire prevention authority.

Control of topsoil and subsoil


66. ZTE shall store topsoil (defined as the soil above 150 mm) excavated from the trench in a wind
row or stockpile which shall be discernibly separate from wind rows or stockpiles of any other
excavated materials.

67. ZTE shall remove topsoil from a corridor up to 0.5 m wide over the line of the trench.
Topsoil shall not be disturbed, more than is absolutely necessary, on the remaining construction
right-of-way.

68. Topsoil shall not be contaminated with anything that might impair its plant-support capacity (e.g.
aggregate, cement, concrete, fuels, litter, oils, domestic and industrial waste).

69. ZTE shall temporarily stockpile topsoil in a location that will minimize any loss due to erosion or
mixing with other material.

70. ZTE shall ensure that topsoil is stockpiled in a manner and for a period of time that does not
result in deterioration in its plant support capacity.

71. After the completion of the backfilling, re-contouring and erosion control works, ZTE shall spread
the topsoil evenly at uniform depth over the areas from which it was removed.

72. The stockpiling of topsoil along the route corridor for the purposes of reinstatement is regarded
as a vital component of successful rehabilitation, and compliance with the stripping requirements
specified in measures 7 and 8 will be strictly enforced. In areas where topsoil of less than 150
mm is stripped, ZTE will be required to demonstrate that substantial constraints prevailed
which made this requirement unattainable.

73. ZTE may distribute waste soil (soft material) evenly around the construction right-of- way as long
as it does not impact negatively on natural vegetation or land capability.

Control of material supply and borrow areas


74. ZTE shall, as far as possible, source all material needed to lay the data cable from existing
permitted mines and/or quarries in the area.

75. In instances where bedding material needs to be obtained from a new borrow area, ZTE
shall comply with the requirements of relevant legislation. Mining authorization from the
Department of Mineral Resources (DMR) is a legal requirement for new borrow areas, the
application for which must include an Environmental Management Programme, submitted to the
Provincial Director of Mineral Development.

76. In addition to any requirements that are specified by the DMR, ZTE shall prepare a method
statement including plans, detailing the expected quantity of excavation, temporary and
permanent drainage control, the final contouring of the borrow pit and the proposed method of
rehabilitation and shall submit this to FibreCo for approval prior to opening the borrow pit.

Control of stone and rock waste


77. ZTE may move surface stone and rock to facilitate data cable construction, but shall not stockpile
or dispose of this material off the construction right-of-way without landowner consent.

78. Where the land is naturally armoured (i.e. has significant amounts of surface rock and stone),
ZTE may return this material back over the construction right-of-way in approximately the same
proportions as occurred prior to construction.

79. ZTE shall prepare a method statement detailing the proposed location and method of disposing
of waste rock excavated from the data cable trench. As a general rule, windrowing of waste rock
along the perimeter of the trench shall be prohibited. ZTE shall identify erosion gullies or old
borrow pits in these sections of route corridor for preferential disposal of waste rock and other
granular material. The method statement shall include the measures that are proposed to
stabilise and rehabilitate the disposal site.

Control of blasting
80. Where this occurs, blasting rock in the data cable trench, ZTE shall comply with all legal
requirements and codes of practice relating to this activity.

81. ZTE shall take all necessary precautions to ensure that blast rock is not scattered over, or
outside, the construction right- of-way, causing damage or injury to the environment, people or
animals, agriculture, buildings or other infrastructure. Where necessary, ZTE shall employ blast
nets or other safeguards in order to ensure that blast rock remains in situ after the blast, so that it
may be removed from the trench in a controlled manner.

82. ZTE shall prepare and submit to FibreCo a pre-blast photographic record of any structures or
buildings within 200 m of a blast zone, including any structural defects in these structures or
buildings.

83. In the event of accidental over blast, ZTE shall immediately notify FibreCo in writing, and shall
indicate what damage has occurred, how the blast rock is to be collected and disposed of and
how the damage incurred is to be rectified.
84. ZTE shall institute suitable measures to reduce blast shock, such as: (a) minimizing the size of
explosive charges per delay and the number of days of explosive exposure; (b) subdividing the
explosives deployment, using electric detonating caps with delays to reduce total pressure; (c)
use of decking in drill holes to reduce total pressure; (d) use of shaped charges at surfaces to
focus blast energy; (e) use of angular stemming material in drill holes to reduce energy dispersal
to the aquatic environment; (f) use of energy absorbers upstream and downstream of the blast,
such as temporary gabion structures.

Control of construction of watercourse crossings


85. ZTE is responsible for controlling riparian and stream damage to the river systems through which
the data cable is routed. The Global Positioning System (GPS) location of possible
watercourse crossings and the methods to be used to affect such crossings are outlined
in the WULA contained in Appendix D - Surface Water Specialist Study).

86. ZTE shall comply with any conditions of approval set by the DWA, over and above the
requirements of this EMPr.

87. ZTE shall prepare for each river crossing a detailed method statement for review by
FibreCo and for approval by the DWA. The method statement shall include but not be limited to:

a) A biophysical description of the site (profile, depth and width of channel(s), geo-technical
drawings, large trees, reed beds, etc);

b) The proposed timing and duration of watercourse crossing construction;

c) An itemised list of the equipment that will be used for the excavation, laying of data cable,
backfilling of the trench and control of water;

d) Measures that will be used to control suspended sediment and turbidity (e.g. berms, hay
bales, bidem curtains, river / stream diversions, settling ponds), damage to riparian
vegetation, spillage of fuels and oils, cement and other foreign materials and a monitoring
programme to provide rapid feedback on the effectiveness of controls.

e) Measures that will be used to ensure that identified and surveyed trees in the riparian fringe
scheduled for protection within the construction right-of-way, shall not be damaged during
construction.

f) Measures that will be used to stabilize river embankments after construction and to return
the channel to its pre-construction profile or to a more stable profile.

g) Where applicable, measures that will be used to minimize the impact of blasting on aquatic
species in the event that construction under submerged conditions is necessary.

88. During construction, ZTE shall make provision to maintain the natural flow of any drainage line
affected by construction.

89. In excavating the bed of the water body for the data cable, ZTE shall comply with the following:
(a) the excavated areas must be backfilled with material that is of the same quality, and
gradation to that which was removed except in cases where blasting and grouting of the data
cable takes place; and (b) where blasting takes place (if applicable), the rock replaced in the
trench at the surface is to give the trench as natural an appearance as possible, so that in low
flow periods, a linear scar is not obvious.

90. Where isolating the location of a works, the following measures, among others, may be
considered by ZTE in order to minimize the risk of increased suspended sediment in the water
column downstream of the works:
a) Elimination of surface flow through the construction site;

b) The use of non-erodible materials for the construction of any berms, coffer dams or other
isolation structures used in a works within a flowing watercourse. The use of non-earthen
dam structures, such as aquadams, are possible options;

c) In cases where the entire flow of water of a water body is diverted around the water crossing
site, it must be returned to the water body immediately downstream of the crossing site;

d) The use of silt fences or hay bales to isolate the construction area from the water body in
situations where the flow velocities and volumes are low;

e) The removal and temporary storage of any material excavated from the bed or banks of the
water body to a location out of the water body until the materials are permanently removed
from the location or backfilled into the water body. Where sufficient space exists, and where
the storage will not cause any environmental damage, this may be within the macro-channel
banks of the river; and

f) The treatment of any water removed from the isolation area, prior to discharge back into the
downstream river course, to remove suspended sediment.

91. ZTE shall monitor the effect of construction on downstream sediment loads. The monitoring
programme shall include sampling in the river upstream and downstream of the works
during the period when construction in the river is taking place especially in the wet
season.

92. FibreCo shall commission periodic independent audits of sediment generation caused by the
construction works in the rivers in order to verify the results of the sediment monitoring
maintained by ZTE.

93. ZTE shall adhere to the requirements of the WUL authorisation by DWA with respect to
watercourse crossings

94. During the carrying out of the works, ZTE shall remove any fish that are found within the
isolated portion of the watercourse crossing site, without harming the fish, to an area of the water
body immediately adjacent to the watercourse crossing, outside the isolated portion of the
watercourse crossing site.

95. Where data cable construction through river channels involves excavation of submerged rock,
ZTE shall give preference to methods that do not involve underwater blasting. In the event that
ZTE adjudges underwater blasting methods to be the only practical method this shall be fully
motivated and all necessary plans shall be prepared to demonstrate that the work can be
conducted without significant risk to aquatic organisms. Such plans shall be submitted to FibreCo
and shall be approved by the DWA as a part of the method statements for each major river
crossing prior to implementation of the works.

96. The method statements shall include all information required by the DWA.

97. ZTE shall apply measures to reduce impact on spawning fish, such as: (a) limiting the season of
explosive use from March to September (non-spawning season); and (b) use of non- explosive
scare techniques to move fish from the immediate blast zone (small repelling explosive
charges are not considered to be an effective means of driving fish from a blast area. Acoustic
repellent devices and/or bubble curtains may need to be considered).

98. ZTE shall notify DWA in advance of any underwater blasting scheduled for the major river
crossings. ZTE shall monitor the effect of underwater blasts upstream and downstream of the
blast zone.
99. Where rehabilitating the river crossing works, ZTE shall comply with the following: (a) the river
channel embankments shall be returned to the pre-existing (or a more stable) profile than that
which existed prior to construction. ZTE may make use of the fixed point photography taken by
FibreCo in order to ensure compliance with this requirement; (b) river embankments shall be
stabilised, using any necessary protection measures, including re- vegetation, rip rap, reno
mattresses and other measures, to ensure that the banks are protected against erosion; (c)
measures using indigenous grasses to permanently stabilise disturbed areas shall be fully
effective by the end of one growing season; and (d) debris disposal and clean up shall be carried
out to return the river course to its pre-existing condition prior to the works.

100. In rehabilitating the river crossings, ZTE shall, in addition to the requirements specified
in the re-vegetation specification, include the re-planting of indigenous trees in the riparian fringe.
At least 70% of the trees at each river crossing shall be alive and healthy at the end of the
maintenance period. The precise location of the trees in the riparian zone shall be provided to
the Contractor by FibreCo. All trees are to be purchased from a reputable commercial
supplier and are to be supplied with a phyto-sanitary certificate which certifies that the soil in
which they were propagated is weed free.

Control of wetland crossings


101. ZTE shall prevent permanent damage occurring as a result of construction of the works to
all wetlands along the construction right-of-way. The occurrence of wetlands in the construction
right-of-way is defined in the WULA. The Contractor shall take note that the definition of
wetlands in this EMPr is broader than the laypersons understanding of the term
wetland or marsh, and includes all areas where hydromorphic soils occur along the route
corridor.

102. As far as is reasonably practical, ZTE shall schedule construction activities to take place
during winter when surface and subsurface water flows are lowest, plants are dormant and
inundation is limited (See management measures relating to the control of topsoil and subsoil,
construction in sensitive areas and clearing of vegetation).

103. ZTE shall not remove any vegetation within the wetland, other than that which is absolutely
necessary along the data cable construction right-of-way. Where crossing of a wetland is
necessary, this shall occur at a 90 angle to the dominant natural flow of water in the wetland.

104. As far as is possible, ZTE shall backfill the trench in the wetland with the material originally
removed. This shall be done in accordance with the natural soil profile in the wetland. The
method chosen as being most appropriate for a particular site (including the use of clay barriers
at intervals along the data cable shall not affect the natural surface or sub-surface (lateral
and longitudinal groundwater movement) flow within the wetland and shall
contain/prevent channelling of water along the data cable and/or in the backfill.

105. ZTE shall test each wetland before construction and identify any clay lenses within the
depth of excavation. ZTE shall re-seal any impermeable layer that is breached by construction
within a wetland, either by using clay removed from the trench, or alternatively with bentonite or
any other appropriate material or method approved by FibreCo.

106. ZTE shall manage all temporary construction roads in or adjacent to wetlands so as to
disperse runoff and avoid concentrating water flows. Temporary construction roads in proximity
to wetlands shall be completely removed and rehabilitated after construction, in accordance with
the re-grassing specification.
107. Limiting access and construction disturbance in wetlands is considered essential. The
Contractor shall take particular note of provisions in this regard.

108. ZTE shall carefully monitor the use of heavy machinery within wetlands. Machine operators
shall be fully informed about the sensitivity of these areas.

109. ZTE shall reinstate the original wetland geometry and topography in both cross- sectional
and longitudinal profile after construction.

110. ZTE shall remove from the wetland immediately after construction is completed all coffer
dams, causeway and construction materials, discard material, berms and other foreign items
used in the construction of the data cable. Ripping and disking of the wetland surface shall be
done in all compacted areas after construction.

111. ZTE shall re-vegetate the area encompassing the data cable construction right-of- way based
on measures devised by ecological specialist. Appropriate plant species, seeding methods and
replanting, as indicated in the specification and approved by FibreCo, shall be used to
achieve this. Measures are as follows:

112. The wetland crossings identified by the WULA (See Appendix D), and where the above
measures (104-115) apply, are as follows:

Table 3-3 Wetland/ river crossings identified by the specialist studies

Major Crossings
Crossing River/Dam Name/
Longitude Latitude Crossing type Drilling Type
Name Tributary
11 26.2457874 -29.8072746 Riet Bridge Directional
17 26.7053634 -30.6857394 Orange Bridge Directional
15 26.6543099 -30.2797604 Caledon Bridge Directional
133 26.4444405 -30.0625802 Unknown Bridge Directional
114 26.1806422 -29.6352216 Fouriespruit Bridge Directional
145 26.4017579 -30.0027296 Skulpspruit Bridge Directional
125 26.2017547 -29.4145322 X Bridge Directional
40 24.5606441 -32.1846512 Sondags Bridge Directional
306 25.4716872 -31.4552855 Groot-Brak Bridge Directional
288 24.7808285 -31.8997813 Sondags Bridge Directional
92 26.2115807 -29.2788268 Kaalspruit Bridge Trenching
93 26.2055709 -29.3550918 Klein-Kaalspruit Bridge Trenching
150 26.713536 -30.316368 Eldoradospruit Bridge Trenching
283 24.6043701 -32.0727347 Paardekloofstroom Bridge Trenching
284 24.6595472 -32.0056474 Rubidge Sloot Bridge Trenching
292 24.5465876 -32.2118907 Broederstroom Bridge Trenching
301 24.9669352 -31.681211 Oompies-Noord Bridge Trenching
307 24.9051945 -31.7777847 Willem Burgers Bridge Trenching
142 26.6456836 -30.7114357 Melkspruit Bridge Trenching
18 26.420234 -30.8591263 Stormbergspruit Bridge Trenching
137 26.4633626 -30.7833599 Brandkopspruit Bridge Trenching
Major Crossings
Crossing River/Dam Name/
Longitude Latitude Crossing type Drilling Type
Name Tributary
305 25.3484831 -31.4553616 Rooispruit Bridge Trenching
304 25.685922 -31.3695828 Teebus Bridge Trenching
302 25.0200413 -31.5046454 Droe Bridge Trenching
303 25.0195533 -31.5127949 Klein-Brak Bridge Trenching
144 26.3307165 -30.9978311 Buitendagspruit Bridge Trenching
158 26.1777296 -31.1670445 Unknown Bridge Trenching
162 26.1887711 -31.1407102 Unknown Bridge Trenching
157 26.1248083 -31.263454 Unknown Bridge Trenching
155 26.8053189 -30.4921131 Beeskraalspruit Culvert Trenching
153 26.5439266 -30.2142908 Groenspruit Bridge Trenching

Minor Crossings
Crossing Longitude Latitude River/Dam Name Tributary DrillingType
Name
2_1 26.2122254 -29.266798 Unknown Kaal Spruit Trenching
2_2 26.19501 -29.512007 Unknown Kaffer Spruit Trenching
2_3 26.1876158 -29.595294 Unknown Fourie Spruit Trenching
2_4 26.1847843 -29.703203 Unknown Riet River Trenching
2_5 26.1952825 -29.734507 Unknown Riet River Trenching
2_6 26.2041341 -29.748384 Unknown Riet River Trenching
2_7 26.2177826 -29.767914 Unknown Riet River Trenching
2_8 26.2218944 -29.773968 Unknown Riet River Trenching
2_9 26.2281761 -29.782648 Unknown Riet River Trenching
2_10 26.2575863 -29.822966 Unknown Riet River Trenching
2_11 26.2655813 -29.833188 Unknown Riet River Trenching
2_12 26.2778593 -29.848721 Unknown Riet River Trenching
2_13 26.29956 -29.875733 Unknown Riet River Trenching
2_14 26.3024153 -29.879259 Unknown Riet River Trenching
2_15 26.3365725 -29.921411 Unknown Cut-off Trenching
2_16 26.3802792 -29.962171 Unknown Smith Field Dam Trenching
2_17 26.4301051 -30.044025 Unknown Smith Field Dam Trenching
2_18 26.5058957 -30.170146 Unknown Smith Field Dam Trenching
2_19 26.513491 -30.185964 Unknown Groenspruit Trenching
2_20 26.5407596 -30.223077 Unknown Groenspruit Trenching
2_21 26.5787001 -30.2542 Unknown Caledon River Trenching
2_22 26.6262774 -30.27438 Unknown Caledon River Trenching
2_23 26.6970902 -30.302306 Unknown Leeuspruit Trenching
2_24 26.7447888 -30.344046 Kleinspruit Leeuspruit Trenching
Minor Crossings
Crossing Longitude Latitude River/Dam Name Tributary DrillingType
Name
2_25 26.7732282 -30.36963 Unknown Leeuspruit Trenching
2_26 26.8327623 -30.415259 Unknown Leeuspruit Trenching
2_27 26.8285982 -30.427213 Unknown Beeskraalspruit Trenching
2_28 26.7981292 -30.513718 Unknown Beeskraalspruit Trenching
2_29 26.7890099 -30.555746 Unknown Beeskraalspruit Trenching
2_30 26.7870766 -30.561903 Unknown Beeskraalspruit Trenching
2_31 26.7786295 -30.586679 Unknown Beeskraalspruit Trenching
2_32 26.7750699 -30.594431 Unknown Nuwejaarspruit Trenching
2_33 26.7654092 -30.604996 Unknown Nuwejaarspruit Trenching
2_34 26.7534763 -30.619225 Unknown Nuwejaarspruit Trenching
2_35 26.7511563 -30.623092 Unknown Nuwejaarspruit Trenching
2_36 26.7484199 -30.62785 Unknown Nuwejaarspruit Trenching
2_37 26.7406866 -30.640878 Unknown Orange River Trenching
2_38 26.7255473 -30.654352 Unknown Orange River Trenching
2_39 26.7186766 -30.655958 Unknown Orange River Trenching
2_40 26.7158213 -30.657267 Unknown Orange River Trenching
2_41 26.7036563 -30.675588 Unknown Orange River Trenching
2_42 26.7029127 -30.680377 Unknown Orange River Trenching
2_43 26.6979531 -30.692767 Unknown Orange River Trenching
2_44 26.6915285 -30.696723 Unknown Orange River Trenching
2_45 26.6908444 -30.697021 Unknown Orange River Trenching
2_46 26.6899521 -30.697675 Unknown Orange River Trenching
2_47 26.6862045 -30.699906 Unknown Orange River Trenching
2_48 26.6749615 -30.708293 Unknown Melkspruit Trenching
2_49 26.6641647 -30.709989 Unknown Melkspruit Trenching
2_50 26.655093 -30.710851 Unknown Melkspruit Trenching
2_51 26.6378122 -30.712487 Unknown Melkspruit Trenching
2_52 26.6230595 -30.71561 Unknown Melkspruit Trenching
2_53 26.6178069 -30.716723 Unknown Orange River Trenching
2_54 26.6134763 -30.717817 Unknown Orange River Trenching
2_55 26.5949165 -30.713715 Unknown Orange River Trenching
2_56 26.5869691 -30.711906 Unknown Orange River Trenching
2_57 26.5675527 -30.712716 Unknown Orange River Trenching
2_58 26.5527524 -30.718093 Unknown Orange River Trenching
2_59 26.5375239 -30.724232 Unknown Orange River Trenching
2_60 26.5175364 -30.731085 Unknown Isolated Small Dam Trenching
2_61 26.5151569 -30.731846 Unknown Isolated Small Dam Trenching
Minor Crossings
Crossing Longitude Latitude River/Dam Name Tributary DrillingType
Name
2_62 26.5096842 -30.733655 Unknown Isolated Small Dam Trenching
2_63 26.5012609 -30.736558 Unknown Isolated Small Dam Trenching
2_64 26.4835101 -30.754356 Klipplaatspruit Sonskynspruit Trenching
2_65 26.4658545 -30.780245 Unknown Braamspruit Trenching
2_66 26.4349215 -30.825454 Unknown Stormbergspruit Trenching
2_67 26.421311 -30.847679 Unknown Stormbergspruit Trenching
2_68 26.4116028 -30.874804 Unknown Stormbergspruit Trenching
2_69 26.4086523 -30.879183 Unknown Stormbergspruit Trenching
2_70 26.4012759 -30.889747 Unknown Stormbergspruit Trenching
2_71 26.3853811 -30.900931 Unknown Wilgerspruit Trenching
2_72 26.3557568 -30.927295 Unknown Stormbergspruit Trenching
2_73 26.3518069 -30.932625 Unknown Stormbergspruit Trenching
2_74 26.3385295 -30.9499 Unknown Cut-off Trenching
2_75 26.3332471 -30.962178 Unknown Wonderboomspruit Trenching
2_76 26.3328188 -30.976027 Unknown Wonderboomspruit Trenching
2_77 26.3196366 -31.010862 Unknown Wonderboomspruit Trenching
2_78 26.3189704 -31.011719 Unknown Wonderboomspruit Trenching
2_79 26.3154012 -31.016953 Unknown Wonderboomspruit Trenching
2_80 26.2999347 -31.02828 Unknown Wonderboomspruit Trenching
2_81 26.2847061 -31.038321 Unknown Wonderboomspruit Trenching
2_82 26.2801852 -31.042509 Unknown Wonderboomspruit Trenching
2_83 26.2786623 -31.043794 Unknown Wonderboomspruit Trenching
2_84 26.2763304 -31.045935 Unknown Wonderboomspruit Trenching
2_85 26.2722378 -31.0496 Unknown Wonderboomspruit Trenching
2_86 26.2670505 -31.053835 Unknown Wonderboomspruit Trenching
2_87 26.2585321 -31.061544 Unknown Wonderboomspruit Trenching
2_88 26.2571044 -31.062877 Unknown Wonderboomspruit Trenching
2_89 26.2400199 -31.06992 Unknown Wonderboomspruit Trenching
2_90 26.2254576 -31.073823 Unknown Wonderboomspruit Trenching
2_91 26.2240299 -31.075155 Unknown Wonderboomspruit Trenching
2_92 26.2218408 -31.076963 Unknown Wonderboomspruit Trenching
2_93 26.2176529 -31.080675 Unknown Wonderboomspruit Trenching
2_94 26.2131795 -31.086767 Unknown Wonderboomspruit Trenching
2_95 26.2093248 -31.095476 Unknown Isolated Small Dam Trenching
2_96 26.1969992 -31.121459 Unknown Unknown Trenching
2_97 26.1931445 -31.129978 Unknown Unknown Trenching
2_98 26.1831983 -31.153106 Unknown Cut-off Trenching
Minor Crossings
Crossing Longitude Latitude River/Dam Name Tributary DrillingType
Name
2_99 26.1713962 -31.181327 Unknown Wonderboomspruit Trenching
2_100 26.1649717 -31.196603 Unknown Wonderboomspruit Trenching
2_101 26.1595465 -31.209499 Unknown Wonderboomspruit Trenching
2_102 26.1446511 -31.247333 Unknown Wonderboomspruit Trenching
2_103 26.1345621 -31.26694 Unknown Wonderboomspruit Trenching
2_104 26.1297211 -31.267575 Unknown Wonderboomspruit Trenching
2_105 26.1162896 -31.265875 Unknown Wonderboomspruit Trenching
2_106 26.0978168 -31.262528 Unknown Wonderboomspruit Trenching
2_107 26.0949043 -31.261842 Unknown Wonderboomspruit Trenching
2_108 26.0892507 -31.260586 Unknown Wonderboomspruit Trenching
2_109 26.0720044 -31.25596 Unknown Wonderboomspruit Trenching
2_110 26.0702911 -31.25556 Unknown Wonderboomspruit Trenching
2_111 26.0671503 -31.254647 Unknown Wonderboomspruit Trenching
2_112 26.0626788 -31.253219 Unknown Wonderboomspruit Trenching
2_113 26.0380656 -31.252248 Unknown Wonderboomspruit Trenching
2_114 26.034011 -31.252477 Unknown Wonderboomspruit Trenching
2_115 26.0258447 -31.252705 Unknown Broekspruit Trenching
2_116 26.0006034 -31.254019 Unknown Broekspruit Trenching
2_117 25.9952924 -31.253733 Unknown Broekspruit Trenching
2_118 25.979588 -31.25339 Unknown Broekspruit Trenching
2_119 25.9711933 -31.252191 Unknown Strydpoort River Trenching
2_120 25.9664534 -31.255789 Unknown Strydpoort River Trenching
2_121 25.9605713 -31.257559 Unknown Isolated Small Dam Trenching
2_122 25.9582871 -31.257045 Unknown Isolated Small Dam Trenching
2_123 25.9476651 -31.255161 Unknown Isolated Small Dam Trenching
2_124 25.8991812 -31.265097 Unknown Strydpoort River Trenching
2_125 25.8781658 -31.268809 Unknown Isolated Dam Trenching
2_126 25.8728549 -31.269266 Unknown Isolated Dam Trenching
2_127 25.8636035 -31.274177 Unknown Isolated Dam Trenching
2_128 25.837991 -31.289414 Unknown Steynsburgspruit Trenching
2_129 25.8207104 -31.294199 Steynsburgspruit Teebus River Trenching
2_130 25.7874092 -31.297936 Unknown Teebus River Trenching
2_131 25.785934 -31.300078 Unknown Teebus River Trenching
2_132 25.7825551 -31.313365 Unknown Teebus River Trenching
2_133 25.7825551 -31.314221 Unknown Teebus River Trenching
2_134 25.7822696 -31.315459 Unknown Teebus River Trenching
2_135 25.7803184 -31.317933 Unknown Teebus River Trenching
Minor Crossings
Crossing Longitude Latitude River/Dam Name Tributary DrillingType
Name
2_136 25.7739891 -31.32964 Unknown Teebus River Trenching
2_137 25.7727042 -31.33359 Unknown Teebus River Trenching
2_138 25.7714193 -31.336112 Unknown Teebus River Trenching
2_139 25.7681832 -31.343308 Unknown Teebus River Trenching
2_140 25.7672314 -31.345259 Unknown Teebus River Trenching
2_141 25.7663748 -31.34721 Unknown Teebus River Trenching
2_142 25.7429419 -31.35373 Kromkloofsloot Teebus River Trenching
2_143 25.7372788 -31.354634 Unknown Teebus River Trenching
2_144 25.71929 -31.357442 Unknown Teebus River Trenching
2_145 25.7141504 -31.358822 Unknown Teebus River Trenching
2_146 25.6640259 -31.37652 Unknown Teebus River Trenching
2_147 25.6585436 -31.37909 Unknown Teebus River Trenching
2_148 25.6400409 -31.39114 Unknown Teebus River Trenching
2_149 25.6359292 -31.393424 Unknown Teebus River Trenching
2_150 25.6350155 -31.393767 Unknown Teebus River Trenching
2_151 25.6260725 -31.395537 Unknown Teebus River Trenching
2_152 25.6205331 -31.394738 Unknown Teebus River Trenching
2_153 25.6183631 -31.394566 Unknown Teebus River Trenching
2_154 25.6076269 -31.394281 Unknown Teebus River Trenching
2_155 25.4797366 -31.452934 Unknown Cut-off Trenching
2_156 25.415988 -31.463157 Unknown Cut-off Trenching
2_157 25.3934878 -31.461272 Unknown Cut-off Trenching
2_158 25.3612223 -31.458474 Unknown Rooispruit Trenching
2_159 25.3552261 -31.458188 Unknown Rooispruit Trenching
2_160 25.2974337 -31.455105 Unknown Cut-off Trenching
2_161 25.2857839 -31.454419 Unknown Cut-off Trenching
2_162 25.2842991 -31.454191 Unknown Cut-off Trenching
2_163 25.161536 -31.472728 Unknown Cut-off Trenching
2_164 25.0950006 -31.48761 Unknown Cut-off Trenching
2_165 25.0838647 -31.489723 Unknown Cut-off Trenching
2_166 25.0774116 -31.490865 Unknown Cut-off Trenching
2_167 25.0673608 -31.492578 Unknown Cut-off Trenching
2_168 25.0118908 -31.543958 Unknown Cut-off Trenching
2_169 24.9882485 -31.617969 Unknown Cut-off Trenching
2_170 24.9880771 -31.619796 Unknown Cut-off Trenching
2_171 24.9873348 -31.622594 Unknown Cut-off Trenching
2_172 24.9868208 -31.625164 Unknown Cut-off Trenching
Minor Crossings
Crossing Longitude Latitude River/Dam Name Tributary DrillingType
Name
2_173 24.9823093 -31.642582 Unknown Cut-off Trenching
2_174 24.9821951 -31.643438 Unknown Cut-off Trenching
2_175 24.9779121 -31.656459 Unknown Cut-off Trenching
2_176 24.970374 -31.670222 Unknown Cut-off Trenching
2_177 24.9654627 -31.686406 Unknown Oompies River Trenching
2_178 24.9639209 -31.692459 Unknown Oompies River Trenching
2_179 24.9604373 -31.707478 Unknown Cut-off Trenching
2_180 24.9498797 -31.726145 Unknown Oompies River Trenching
2_181 24.9454539 -31.731999 Unknown Oompies River Trenching
2_182 24.9435622 -31.735639 Unknown Oompies River Trenching
2_183 24.9424914 -31.737602 Unknown Oompies River Trenching
2_184 24.9397432 -31.742242 Unknown Oompies River Trenching
2_185 24.9337469 -31.749502 Unknown Cut-off Trenching
2_186 24.9317482 -31.751929 Unknown Cut-off Trenching
2_187 24.9298565 -31.753571 Unknown Cut-off Trenching
2_188 24.9078584 -31.775735 Unknown Willem Burgers River Trenching
2_189 24.9063831 -31.776878 Unknown Willem Burgers River Trenching
2_190 24.8800187 -31.808762 Unknown Ventershoekspruit Trenching
2_191 24.8598409 -31.818052 Unknown Ventershoekspruit Trenching
2_192 24.858318 -31.819575 Unknown Ventershoekspruit Trenching
2_193 24.8561289 -31.822858 Unknown Ventershoekspruit Trenching
2_194 24.8554151 -31.826903 Unknown Ventershoekspruit Trenching
2_195 24.8567951 -31.831995 Unknown Ventershoekspruit Trenching
2_196 24.8766065 -31.844321 Unknown Sondags River Trenching
2_197 24.8797474 -31.845463 Unknown Sondags River Trenching
2_198 24.8807468 -31.847129 Unknown Sondags River Trenching
2_199 24.8750361 -31.852316 Unknown Sondags River Trenching
2_200 24.8730849 -31.853839 Unknown Sondags River Trenching
2_201 24.8319678 -31.8704 Unknown Sondags River Trenching
2_202 24.8276372 -31.872732 Unknown Sondags River Trenching
2_203 24.8224976 -31.879965 Unknown Sondags River Trenching
2_204 24.7952766 -31.890959 Unknown Sondags River Trenching
2_205 24.7513993 -31.924033 Unknown Sondags River Trenching
2_206 24.7453079 -31.929268 Unknown Cut-off Trenching
2_207 24.7425477 -31.931505 Unknown Cut-off Trenching
2_208 24.7377888 -31.935835 Unknown Cut-off Trenching
2_209 24.7314118 -31.941498 Unknown Cut-off Trenching
Minor Crossings
Crossing Longitude Latitude River/Dam Name Tributary DrillingType
Name
2_210 24.728033 -31.944449 Unknown Cut-off Trenching
2_211 24.7268908 -31.945781 Unknown Cut-off Trenching
2_212 24.725368 -31.948304 Unknown Cut-off Trenching
2_213 24.7253204 -31.949255 Unknown Cut-off Trenching
2_214 24.7265101 -31.959811 Unknown Cut-off Trenching
2_215 24.724559 -31.961714 Unknown Cut-off Trenching
2_216 24.7208946 -31.967235 Unknown Cut-off Trenching
2_217 24.7002409 -31.980369 Unknown Cut-off Trenching
2_218 24.622718 -32.033812 Unknown Cut-off Trenching
2_219 24.6191013 -32.040427 Unknown Cut-off Trenching
2_220 24.6186254 -32.041759 Unknown Cut-off Trenching
2_221 24.6023974 -32.086503 Unknown Paardekloofstroom Trenching
2_222 24.604301 -32.095307 Unknown Paardekloofstroom Trenching
2_223 24.6047769 -32.097258 Unknown Paardekloofstroom Trenching
2_224 24.6051576 -32.099019 Unknown Paardekloofstroom Trenching
2_225 24.6054432 -32.101113 Unknown Paardekloofstroom Trenching
2_226 24.6083937 -32.116008 Unknown Paardekloofstroom Trenching
2_227 24.5993041 -32.123337 Unknown Paardekloofstroom Trenching
2_228 24.5694181 -32.164501 Unknown Sondags River Trenching
2_229 24.5403768 -32.222513 Unknown Vanryneveldspasdam Trenching
2_230 24.5397224 -32.224 Unknown Vanryneveldspasdam Trenching
2_231 24.5376404 -32.22971 Unknown Vanryneveldspasdam Trenching
2_232 24.5376859 -32.243705 Unknown Vanryneveldspasdam Trenching
2_233 26.494778 -30.148639 Unknown Smith Field Dam Trenching
2_234 26.759417 -30.609917 Unknown Nuwejaarspruit Trenching

113. Control of impact of construction activities on groundwater

114. ZTE shall where possible avoid activities within 100m of a borehole.

115. Where possible, the pipeline route corridor will be realigned to avoid damage to a borehole.

Control of the impact of construction activities on archaeological sites and


graves and palaeontological remains
116. In terms of the Natural Heritage Resources Act (Act 25 of 1999), no graves or archaeological
sites, including man-made structures more than 60 years old, may be disturbed, damaged or
destroyed by any person without requisite arrangements or permits from SAHRA.

117. The ECO shall check that measures required by heritage professionals and SAHRA to
ensure that these are complied with for all routes.

118. The cable shall be aligned to avoid known grave sites and sites of archaeological and
palaeontological significance as far as possible.
119. When planning to align the data cable to bypass the above sites, ZTE shall make sure that
this work is done under the supervision of an ECO.

120. ZTE shall be responsible for the following: (a) land survey of the position of all known
archaeological sites and graves identified and verify of which of these is affected by the
construction right-of-way. If any of the sites earmarked as warranting protection (See provisions
70 a-g above) cannot be adequately protected during construction, then ZTE shall immediately
draw this to FibreCos attention, and shall prepare a proposal for slight modification of the route
alignment to avoid the site.

121. The ECO must be trained in basic archaeological site identification in order to immediately
inform the archaeologist/palaeontologist of any chance discovery of archaeological sites or
burials. The archaeologist will then implement the required legal steps in terms of the applicable
section of the NHRA.

122. ZTE shall make provision for accidental discovery of archaeological sites and graves
along the construction right-of-way. Once the route corridor is surveyed and staked, and prior to
construction, ZTE shall, with the assistance of the ECO, verify that no further sites exist along
the construction right-of-way over and above those described in this EMPr. In the event that
any sites found are significant enough to warrant conservation, ZTE shall determine whether
this is feasible and, if not, immediately notify FibreCo of the route alignment adjustment
necessary to avoid the site.

123. In fulfilment of SAHRA requirements, the Contractor shall prepare the necessary
documentation and obtain the permits from the SAHRA to construct through those sites which
are directly affected by the construction works but are considered to be of low significance. It
should be noted that buildings 60 years and older must be assessed and a permit obtained from
SAHRA before demolition is considered.

Rehabilitation
124. ZTE shall restore the trench and construction right-of-way to the natural contours of the
ground and shall allow normal surface drainage.

125. ZTE shall remove all temporary works along the construction right-of-way and fences and
private roads disturbed by construction shall be restored to their original condition.

126. ZTE shall loosen compacted soils along the construction right-of-way by means of a plough
or scarifier. Scarifying areas where topsoil has been removed shall be carried out prior to the
replacement of topsoil. Care shall be taken to avoid topsoil inversion if scarifying is carried out in
areas where topsoil has not been removed. Any ripping or scarifying operation shall not exceed a
depth of 100 mm.

127. ZTE shall prevent concentrated run-off along, or next to, the construction right-of- way, and
shall do so by shaping the land, establishing vegetation, and taking other appropriate measures
to absorb and disperse runoff.

128. In places where erosion control is required, including the top of bank of all gullies,
watercourses, large depressions and steep slopes, ZTE shall construct diversion banks
across the construction right-of-way to divert the flow of water away from the backfilled trench
and into the natural drainage courses.

129. In all cases, ZTE shall cover the backfilled data cable trench evenly with topsoil to a
minimum depth of 150mm.
130. On any deviations from the road reserve which cross arable land, ZTE shall ensure
that stone and rock within the soil profile are stockpiled so as to minimize constraints on adjacent
land.

131. Where the land is naturally armoured with surface rock or stone, ZTE shall, after
construction, replace the armouring over the construction right-of-way to protect against erosion.

132. On slopes steeper than 5%, ZTE shall use special protection methods to arrest soil
erosion during the vulnerable period before vegetation re-establishment occurs.

133. Where brush and tree limbs cannot be chipped or used by local communities, this vegetation
shall be spread evenly over the construction right-of-way to preserve and assist the regeneration
of natural vegetation, erosion control and providing animal habitation. Tree trunks and large
limbs are to be laid in a random fashion across the natural slope of the ground, and should not
obstructing access by construction vehicles. No tree trunks and large limbs shall be placed in
gullies or erosion ditches.

134. ZTE shall establish vegetation cover (using species appropriate to the local area) in all areas
disturbed by the works in the first growing season after construction, and shall maintain this
cover for the duration of the maintenance period. ZTE shall notify FibreCo in writing, prior to
re-vegetation, of the method of preparation (scarifying / ripping / discing), soil amelioration
(addition of lime or gypsum), fertilizing, and seeding (source, mixture and quantity) to be used in
rehabilitating each area of the works and the post-establishment maintenance regime to be
implemented.

135. ZTE shall maintain and submit to FibreCo records of the method used to re- establish
grass in each area of the contract.

136. Revegetation shall be done on the routine right-of-way including, but not limited to, all
borrow areas, temporary access roads, spoil sites, camp sites and the like.

137. Once the grass has been established, the maintenance period shall commence. This period
shall extend for a minimum period of one calendar year.

3.3.3 Labour and human resources plan


The labour and human resources plan to be implemented by ZTE and FibreCo shall include
the following key measures:

1. ZTE shall establish a labour and human resources plan which shall be submitted to
FibreCo.

2. The plan shall be based on the following principles:

a. Compliance with national policy and legislation (e.g. Employment Equity Act) and
international labour conventions and norms.
b. Clear and transparent conditions of service, as appropriate.
c. Open and fair recruitment procedures.
d. Well-structured, transparent and locally-appropriate remuneration and compensation
procedures.
e. Accessible and appropriate training and development.
f. Clearly defined and open dispute resolution procedures.

3. Wherever possible, first priority should be given to hiring qualified local people.

4. The labour and human resources plan shall, as appropriate, be adapted by FibreCo and applied
during the operational phase of the project to cover maintenance of the infrastructure.
3.3.4 Workplace health and safety plan
The workplace health and safety plan to be implemented by ZTE and FibreCo shall include the
following key measures:

1. All relevant national legislation, including the OHS Act and related regulations, shall be adhered
to in order to provide a safe and healthy environment for all employees, contractors, suppliers
and the community during construction and operational phases of the Project.

2. ZTE shall develop a health and safety plan in fulfilment of legal requirements for submission to
and approval by FibreCo prior to the start of construction activities.

3. FibreCo shall ensure workplace health and safety during the construction and operational
(maintenance) phases of the data cable. Management should lead by example to ensure that
legislative and contractual requirements are met.

4. Health and safety performance will be continuously monitored and procedures reviewed with the
aim of eliminating risk as far as reasonably practicable.

3.3.5 Community health and safety plan


The community health and safety plan to be implemented by ZTE and FibreCo shall include
the following key measures:

1. All relevant national legislation, including the OHS Act and related regulations, shall be adhered
to ensure that the health and safety of proximate communities and the public at large are not
threatened during construction and operational phases of the Project.

2. During the construction phase, ZTE shall manage and control construction activities in order to
minimise the risks to community health and safety. Special attention shall be paid to threats
posed by the movement of construction vehicles, violation of cultural sensitivities through
damage to graves and historic buildings and sites, contravention of community norms relating to
sexual practice and use of alcohol, security and access control to the construction right-of-way,
transport safety management and control of dust, noise and water pollution. Refer to the
construction management plan in Section 3.3.2.

3. ZTE and FibreCo and its contractors shall ensure that proximate communities are aware of the
procedures for ensuring community safety should potentially hazardous activities such as
blasting be required (See communication and information principles).

3.3.6 Land acquisition and compensation plan


Should there be diversions off the SANRAL and provincial road servitudes, the land acquisition and
compensation plan to be implemented by FibreCo shall include the following key measures:

1. FibreCo shall carry out negotiations with landowners in order acquire the land needed for the
data cable servitude. Compensation will be based on current land and land use valuations in
accordance with legislation, as appropriate.

2. The data cable route corridor shall be aligned to avoid resettlement of households and economic
displacement.

3. In order to comply with lender requirements (e.g. Equator Principles and IFC Performance
Standards), FibreCo shall prepare a land acquisition and compensation plan that describes how
project affected persons will be compensated, and how it will seek to improve conditions for
those affected by project activities. This plan should be based on the following principles:

a. Avoidance of resettlement and economic displacement wherever possible.


b. Fair compensation, at full replacement cost, prior to displacement.
c. The pursuit of amicable and negotiated settlement in the context of compensation
and assistance.
d. Structured and responsive monitoring and evaluation.

4. Land expropriation will only be considered where necessary.

3.3.7 Emergency management and response plan


The emergency management and response plan to be implemented by FibreCo shall include the
following:

Emergency management planning


1. FibreCo shall develop an emergency management plan to guide the coordination and
operational handling of an emergency situation to include:

a. Structure and operation of the emergency management team.


b. Establishment of an emergency management centre.
c. Information retained by the emergency management team.
d. Incidents requiring activation of the plan.
e. Incident severity classification.
f. Process to be followed in the event of an emergency.

2. Information pertaining to emergency management shall be reported through the HSE reporting
process.

The value of the guarantee will be reviewed annually to ensure that the value of the fund reflects the
inflationary environment of the time and thus will remain constantly sufficient to cover the cost in the
event of the above occurrences at any stage during the life of the project.

Emergency response plan

The community health and safety plan to be implemented by ZTE and FibreCo shall include
the following key measures:

3. FibreCo should compile a comprehensive safety emergency management plan for the data
cable, and liaise with emergency services of local municipalities where relevant.

4. Emergency preparedness will include: staff emergency training; equipment maintenance and
inspection.

3.3.8 Social responsibility plan

The social responsibility plan to be implemented by FibreCo and its contractors shall include the
following:

1. Compliance with the principles of Broad Based Black Economic Empowerment (BBBEE) as
enshrined in the BBBEE Act (Act 53 of 2003) and its associated codes of good practice by
FibreCo and its contractors.

2. As necessary, compliance with the requirements of the Preferential Procurement Policy


Framework Act (Act 5 of 2000).

3. In fulfilment of the above, maximize local employment and local subcontracting.

4. Where practicable, provide support to community initiatives aimed at the promotion of


sustainable development. This support could take many forms, including the provision of
technical information and advice and facilitating development in the areas affected by the data
cable.

3.3.9 Decommissioning plan

The decommissioning plan directs pre- and post-closure activities. The provisions relating to this
plan area as follows:

Planning for decommissioning


1. FibreCo shall develop a final decommissioning plan in conjunction with local authorities and
communities at least one year before the end of data cable operation, and update the plan
annually thereafter to ensure that the provisions and costing reflects current realities.

2. Prior to closure, FibreCo will hold negotiations with the relevant authorities and the local
population to identify the best possible use for infrastructure. Where appropriate, negotiations
will be held to make necessary arrangements to transfer useful infrastructure to new owners.

Decommissioning
3. During the decommissioning of the cable, FibreCo shall ensure appropriate disposal of E-waste
and other waste in accordance with waste management legislation dealing with the disposal of
hazardous and general waste.

4. FibreCo shall institute data cable abandonment measures as agreed to with relevant authorities.

5. The cleared sites and associated infrastructure such as access roads will be rehabilitated by
FibreCo and its environmental consultant/s using industry best practice methods.

Post closure
6. Once the data cable has been abandoned, FibreCo will retain a number of responsibilities.
These may include responsibility for ensuring that the right-of-way and any facilities left in place
remain free of problems associated with abandonment.

7. A monitoring plan, with adequate resources, shall be developed and implemented by FibreCo
that includes the following:

a. Monitoring of rehabilitated sites to confirm whether progress is satisfactory. Should


any areas be identified where additional rehabilitation is required appropriate
remedial actions will be taken. It is anticipated that within 3 to 5 years a sustainable
vegetation cover will have been established, where this is appropriate.
b. Land use management in those sections of the data cable that fall within areas that
are sensitive to land disturbance. Land management characteristics that may be
better suited to abandonment-in-place are: natural areas; unstable or highly erodible
surfaces; river crossings; flood irrigated fields; road and railway crossings; areas of
pristine habitat; wetlands; and areas exhibiting poor and/or limited access.
c. Ground subsidence must be given special attention as erosion may cause direct
siltation to a watercourse, or cause a slope to fail with subsequent siltation.
Measures should be put in place in areas where there is a high risk of subsidence
such as on steep slopes.

3.3.10 HSE Construction Phase Roles and Responsibilities


FibreCo plans to put in place a specific team (Owner's Team) to manage the construction phase of
the proposed Project. This team will be separate from the operations team, but will coordinate as
required to ensure that there are no conflicts between operational and construction requirements.
The physical construction will be managed by a Managing Contractor, who in turn will sub-contract
specific components to various construction sub-contractors.

The Managing Contractors environmental and social staff will be supervised by the Owners Team
HSE organization. The Owners Teams HSE staff will include the following:

HSE Manager to oversee the implementation of all HSE requirements as defined by FibreCo
(essentially the requirements stipulated in this EMPr, but others may also become apparent and
be included during project implementation). He/she should possess the requisite qualification
pertaining to HSE.

Environment Manager will also oversee environmental matters with his HSE staff (HSE officers).
The staff should possess a suitable qualification in a natural science and/or environmental
science / management discipline and should have appropriate experience.

The HSE Officer (HSEO)- will be responsible for the implementation of the various
environmental management requirements that need to be met by the Managing Contractor as
well as the various other contractors that will be operating on the site. This function will include
regular inspections, coordination of reporting, and site wide environmental monitoring. The ECO
should have a tertiary qualification in a natural science and/or environmental
science/management discipline with 3-5 years relevant work experience.

Independent environmental consultant/s will be commissioned from time-to-time to assist with


specific tasks (e.g. review information and provide advice on specialist issues, assist in the
preparation of an annual monitoring report and conduct environmental auditing). An independent
environmental expert(s), in any field (e.g. wetlands, terrestrial ecology, water management,
archaeology etc.), may be appointed on request of the Environmental Manager or Owners
Representative to provide specialist advice.

Contractors will be expected to have their own Environment Managers and their activities will be
overseen by the Owners Team HSE staff. In addition, key line functions will have specific
environmental and social management responsibilities included in their job descriptions and
performance criteria. Critical among these is the Construction Manager. The Construction Manager
will be accountable for environmental and social management during the construction phase.
Specific responsibilities will include:

The effective implementation of the EMPr;

Regular performance reviews; and

Corrective and/or remedial action where this may be required.

3.3.11 Contractor arrangements during the construction phase


The following construction phase contractor arrangements will be made to support HSE and EMPr
implementation:

A detailed code of practice for construction teams will be prepared and implemented. This code
will guide the management and behaviour of construction teams. The code will include items
relating to health, safety and community relations. The code of practice for construction workers
will include HIV/Aids counselling.

Information on the implications of construction will be disseminated before construction starts.

Information on the construction phase will be disseminated to IAPs prior to construction.


Contracts will be key tools in managing many potential negative impacts, such as transport
related incidents. In this context both construction and operational contracts will specify required
environmental and social practices.

3.3.12 Training, awareness and capacity building


The presence on site of one experienced HSE Manager, with previous exposure to similar projects,
will allow on-the-job training.

3.3.13 Environmental procedures for the management of operational impact


Prior to the commissioning of the cable, FibreCo will establish operational procedures to give effect
to the measures contained in the management programmes and plans presented in Section 3.3.
These procedures will form part of the FibreCos HSE system and include: the routine maintenance
of the cable right-of-way; environmental management of the data cable right-of-way during repairs;
management of major erosion incidents; traffic safety; management of solid waste and health and
safety.

Each procedure should include the following information:

Procedure name and reference

Purpose of the procedure

Responsibilities for identifying operational impacts

Liaison with authorities and communities, where appropriate

Training of maintenance teams, where appropriate

Record keeping and reporting

Scheduling, where appropriate.

3.4 Monitoring
All programmes and plans will be subject to monitoring. In general, monitoring will have two key
elements: routine monitoring against set standards or performance criteria; and periodic review or
evaluation. This will often focus on the effectiveness and impact of the programme or plan as a
whole. In some cases, independent parties will undertake review and evaluation. The diverse
monitoring requirements and responsibilities will be consolidated within the HSE function, and will
share human resources, databases and management reporting procedures.

During the construction phase, FibreCo shall be fully entitled to monitor and inspect Contractors
written records to demonstrate compliance with the EMPr. This compliance monitoring is intended to
verify that the responsible parties are implementing the management measures / procedures /
specifications contained in the EMPr. Compliance will mean that ZTE is fulfilling his/her contractual
obligations.

Where necessary, baseline monitoring will be used as a means of longer term (post construction)
verification of biophysical conditions along the data cable route corridor, to critically evaluate issues
of habitat recovery, alien plant infestation and erosion along the data cable right-of-way.

3.4.1 Programme monitoring


FibreCo shall regularly monitor programme implementation. This process will include (as
appropriate) the regular monitoring of:

Erosion of soil along the construction right-of-way (12 months).


Air quality and ambient emissions, including dust generated by construction activities (3 months).

Rehabilitation of the construction right-of-way (0-2 years).

Where relevant, noise (measured in dBA) generated by construction activities (including blasting;
12 months) using specific measurement parameters, reference times and measurement
locations.

3.4.2 Plan Monitoring


All of the management plans make provision for monitoring and evaluation. Special attention should
be given to the monitoring arrangements relating to biophysical impacts.

During the construction phase of the Project, ZTEs HSE manager must report all environmental
impacts (e.g. large scale sedimentation and erosion, damage to and/or destruction of, natural
vegetation and damage to heritage resource) as well as accidents and incidents to the Owners
Representative. These reported impacts and incidents will be captured on a database to ascertain
trends and track progress in the implementation of preventative and corrective actions, and
benchmarking against other, similar operations.

Depending on the level of severity, accidents and incidents during construction or maintenance will
be investigated by ZTEs HSE division, with key input from the line management to ensure
accountability. Rewards and recognition will be given to the best performing work teams on a
periodic basis on a periodic basis. The primary objective of these interventions is to recognise the
positive behaviours and outcomes of workers with regards to safety.
Environmental Management Programme for
Route 7 Aliwal North to East London of the
proposed FibreCo fibre optic data cable (Ref.
No. 12/12/20/2192)
Table of Contents

1 Introduction and Scope of Report............................................................................... 1


1.1 Backgr o und ............................................................................................................................. ............ 1
1.2 Approach to environmental impact managem ent ............................................................................... 2
1.2.1 Overvi ew............................................................................................................................. ..... 2
1.2.2 FibreCos Social and Environmental policy ............................................................................. 2
1.2.3 Planning and design ................................................................................................................ 3
1.2.4 Pre-construction and constr uc ti on ........................................................................................... 3
1.2.5 Oper ati o n ............................................................................................................................. .... 4
1.2.6 Checking and corrective action ............................................................................................... 4
1.2.7 Management review ................................................................................................................ 5
1.2.8 Liaison ............................................................................................................................. ........ 5
1.3 Assumpti ons ............................................................................................................................. ........... 5
1.4 Uncer tai nti es ............................................................................................................................. .......... 6

2 The Proposed Project .................................................................................................. 6


2.1 Optic fibre data cable .......................................................................................................................... 6
2.1.1 Construction and installati on ................................................................................................... 7
2.1.2 Start and end points of data cable .......................................................................................... 8
2.1.3 Design and equipment standards ........................................................................................... 8
2.1.4 Monitori ng ............................................................................................................................. ... 8
2.2 Construction phas e ............................................................................................................................. 8
2.2.1 Scale and pace of constr uc ti on ............................................................................................... 8
2.2.2 Construction process ............................................................................................................... 8
2.2.3 Energy, water, sanitation and waste requir em e nts ................................................................. 9
2.2.4 Employment ............................................................................................................................ 9
2.3 Operational phas e ............................................................................................................................. .. 9
2.3.1 Transmission of infor mati on .................................................................................................... 9
2.3.2 Safety and security ................................................................................................................ 10
2.3.3 Energy, water, sanitation and waste requir em e nts ............................................................... 10
2.3.4 Monitori ng ............................................................................................................................. . 10
2.3.5 Employment .......................................................................................................................... 10
2.4 Decom mi ssi oni ng ............................................................................................................................. . 10
3 Impact mitigation and management ......................................................................... 10
3.1 Links with the Basic Assess m ent ...................................................................................................... 10
3.2 Mitigation and Management Measures per Phase ........................................................................... 11
3.3 Management plans............................................................................................................................ 15
3.3.1 Rationale ............................................................................................................................. .. 15
3.3.2 Construction management plan ............................................................................................ 15
3.3.3 Labour and human resources plan ....................................................................................... 32
3.3.4 Workplace health and safety plan ......................................................................................... 32
3.3.5 Community health and safety plan ........................................................................................ 33
3.3.6 Land acquisition and compensation plan .............................................................................. 33
3.3.7 Emergency management and response plan ....................................................................... 33
3.3.8 Social responsibility plan ....................................................................................................... 34
3.3.9 Decommissioning plan .......................................................................................................... 34
3.3.10 HSE Construction Phase Roles and Responsi bili ti es ........................................................... 35
3.3.11 Contractor arrangements during the construction phas e ...................................................... 36
3.3.12 Training, awareness and capacity building ........................................................................... 36
3.3.13 Environmental procedures for the management of operational impact ................................ 36
3.4 Monitoring ............................................................................................................................. ............ 36
3.4.1 Programme monitori ng .......................................................................................................... 37
3.4.2 Plan Monitoring ..................................................................................................................... 37

List of Tables
Table 1-1: Routes under consideration and their relative distances .................................................................. 1
Table 1-2: Approaches to impact management ................................................................................................. 2
Table 2-1 End point and Repeater sites ............................................................................................................. 6
Table 3-1: Mitigation and management measures relating to impacts caused by project activities during all
project phas es ............................................................................................................................ 12
Table 3-2 Specific requirements for the siting of the cable trench and repeater sites ..................................... 21
Table 3-3 Wetland/ river crossings identified by the specialist studies ................................................... 28

List of Abbreviations
BA Basic Assessment

BBBEE Broad Based Black Economic Empowerment

dBA Noise levels for common noises measured in Decibels (dB)

DEA Department of Environmental Affairs (Competent Authority for the project)

DMR Department of Mineral Resources

DWA Department of Water Affairs (formerly Department of Water Affairs and Forestry)

DWAF Department of Water Affairs and Forestry (now Department of Water Affairs)

EAP Environmental Assessment Practitioner

ECO Environmental Control Officer

EMPr Environmental Management Programme

FibreCo FibreCo Telecommunications (Pty) Ltd

GPS Global Positioning System


HIV Human Immunodeficiency Virus

IEC International Electrotechnical Commission

IFC International Finance Corporation

NHRA National Heritage Resources Act

SABS South African Bureau of Standards

SAHRA South African Heritage Resources Agency

SANBI South African National Biodiversity Institute

WUL Water Use Licence


1 Introduction and Scope of Report
FibreCo Telecommunication (Proprietary) Limited (FibreCo) wishes to install a fibre optic data cable
and associated infrastructure between major centres in South Africa in order to improve
telecommunication service. This document is based on a generic environmental management
programme (EMPr) forming one component of the basic assessments (BAs) underway for the routes
anticipated to follow national and provincial highway routeing as indicated in Table 1-1:

Table 1-1: Routes under consideration and their relative distances

Route name Approximate distance (km)

Johannesburg to Bloemfontein (Route 1) 387

Bloemfontein to Graaff Reinet ((Route 2) 513

Graaff Reinet to Yzerfontein (Route 3) 940

George to Port Elizabeth (Route 4) 360

Port Elizabeth to Durban (Route 5) 968

Port Elizabeth to Colesberg (Route 6) 427

East London to Aliwal North (Route 7) 333

This EMPr is specific to Route 7 (see locality map in Appendix A).

1.1 Background
The purpose of the EMPr in its final form will be to ensure that social and environmental impacts,
risks and liabilities identified during the BA process are effectively managed during the construction,
operation and closure phases of the fibre optic data cable. It will specify the mitigation and
management measures to which FibreCo is committed, and show how the project will mobilise
organizational capacity and resources to implement these measures. The EMPr will also show how
mitigation and management measures will be scheduled. This generic EMPr has been developed at
the request of FibreCo to provide an initial indication of the measures which might be contained in
the EMPr.

The key objectives of the EMPr will be to:

Formalize and disclose the programme for environmental and social management; and
Provide a framework for the implementation of environmental and social management initiatives.
Best practice principles require that every reasonable effort be made to reduce and preferably to
prevent negative impacts, while enhancing positive benefits, especially within the communities most
directly affected by the proposed project. These principles are being used to guide the BA process.
In many cases, potential negative impacts can be avoided through careful design, routing and
location of facilities.

Work underpinning the EMPr needs to comply with the EIA Regulation requirements, and includes
the following:

A public participation process set out in Regulations 54, 55, 56, 57 and 58;
A BA report of the proposed Project, including specialist reports, that aims to:
o List the impacts and risks associated with the proposed Project;
o Identify mitigation measures relating to the negative environmental and social
impacts identified during the BA process; and
o Formulation of the EMPr to avoid/minimize negative impacts.
The EMPr covers information on the management and/or mitigation measures that will be taken into
consideration to address impacts, where relevant, in respect of:

Planning and design;


Pre-construction and construction activities;
Operation; and
Closure.
It is necessary to highlight that the EMPr is a living document that will be periodically reviewed and
updated as necessary.

1.2 Approach to environmental impact management


Responsibility for the EMPr will reside in the HSE functional management cluster of FibreCo, but
there will be links with other functional clusters in areas such as operation and maintenance
services. The sections that follow outline the management cycle that will characterise HSE
management, and which will apply to the EMPr. Table 1-2 presents the range of approaches that will
be used to manage potential project activities.

Table 1-2: Approaches to impact management


Avoidance Avoiding activities that could result in adverse impacts and/or resources or areas considered sensitive
Prevention Preventing the occurrence of negative environmental impacts and/or preventing such an occurrence having
negative impacts
Preservation Preventing any future actions that might adversely affect an environmental resource
Minimisation Limiting or reducing the degree, extent, magnitude or duration of adverse impacts through scaling down,
relocating, redesigning and/or realigning elements of the project
Mitigation Measures taken to minimize adverse impacts on the environment
Enhancement Magnifying and/or improving the positive effects or benefits of a project
Rehabilitation Repairing affected resources, such as natural habitats or water resources
Restoration Restoring affected resources to an earlier (possibly more stable and productive) state, typically
background or pristine condition
Compensation Compensating for lost resources, and where possible, the creation, enhancement or protection of the same
type of resource at another suitable and acceptable location

1.2.1 Overview
The HSE management cycle has five broad components:

Policy
Planning and design
Project implementation (covering the construction and operation phases)
Checking and corrective action
Management review.
This addresses each of these phases of the proposed project.

1.2.2 FibreCos Social and Environmental policy


FibreCo is committed to developing and operating a terrestrial fibre optic cable system in a manner
that ensures environmental protection and minimises social impacts and is in line with industry best
practice. This commitment is central to the companys Social and Environmental Management
system framework.

In line with this commitment FibreCo will endeavour to:

Undertake its activities in line with applicable industry standards and industry good practice;
Meet the requirements of national legislation wherever its network exists;
Manage construction activities, which FibreCo recognises as the main potential source of social
and environmental impacts, in a sustainable manner in order to minimise such impacts;
Ensure social and environmental impacts during operation of the project are avoided or reduced
as far as practicable;
Communicated and work closely with its Contractors to ensure their understanding and shared
commitment to conformance with this policy;
Provide training in social and environmental matters to key employees and Contractor
representatives where appropriate; and
Implement all reasonable precautions to protect the health and safety of its employees and
promote the health and safety of contracted workers.
These objectives shall be met via provision of adequate resources by senior management within
FibreCo to support the implementation of the social and environmental management systems. This
policy and other elements of the social and environmental management system shall be regularly
reviewed and updated in order to ensure its continued applicability to the activities of FibreCo.

1.2.3 Planning and design


Planning and design is necessary to ensure that mitigation and impact management can be
effectively implemented and minimise impacts in future stages of the project cycle. The alignment of
the fibre optic data cable and siting of repeater sites should be informed by identified environmental
sensitivities along the route, with a view to avoiding, minimising and mitigating potential negative
impacts and enhancing potential benefits.

In the case of the FibreCo Project the environmental aspects and potential impacts will mainly
emanate from the following project related activities:

1.2.4 Pre-construction and construction


The EMPr will put in place measures to avoid and mitigate impacts and optimize benefits arising
from activities during the pre-construction (e.g. establishment of access roads, campsites and
clearing of the construction right of way) and construction phase (e.g. trenching and laying of data
cable) of the Project. The construction process is detailed in Section 2 of this EMPr. The principal
role of ZTE/s during pre-construction and construction stages of the project will include: personnel
and Contractor management and training; conduct and site management; landowner relations;
maintenance of complaints register; emergency preparedness; and management and mitigation
of impacts such as noise, dust and safety).

Field investigations and surveys will be undertaken during the pre-construction and construction
stages of the project to ensure that ecological, heritage and palaeontological resources are
identified, documented and, where necessary, rescued. Permits will need to be obtained from the
relevant conservation authorities for the trimming and/or removal of indigenous trees.

Assignment of responsibility and Contractor management is especially important during the


construction phase, when Contractors are used to build the data cable. Contractors will also be used
on an ongoing basis for a range of maintenance and other functions. Contractors will be held to best
practice performance requirements.
1.2.5 Operation
The operation of the cable will involve transmission of data along the fibre data cable along routes 1-
7, or portions thereof. The operation of the data cable is anticipated to be low-impact and is not
likely to result in significant negative effects on the environment. There will, however, be the need
for periodic maintenance and repair of the data cable and associated infrastructure. Contractors will
be held to the same HSE performance requirements that govern FibreCo.

The mechanisms for effecting the EMPr requirements are collectively called operational controls.
Such operational controls require that a responsible party, a budget and an im plementation schedule
be specified and allocated, to further enable and facilitate implementation. Roles and responsibilities
need to be defined for implementation of the EMPr. To facilitate coordinated and purposeful
implementation, the EMPr management and mitigation measures are grouped in programmes and
plans.

1.2.6 Checking and corrective action


Checking and, if necessary implementing corrective action, form one of the components of the EMPr
management cycle. They ensure that the:

Required EMPr management activities are being implemented; and


Desired outcomes are being achieved.
As such this component will includes monitoring selected environmental quality variables as defined
in the objectives and targets.

Monitoring
The environmental features that are to be monitored are described in Section B of the Basic
Assessment Report. The management activities for these features are presented in Table 3-1 of the
EMPr. Monitoring results must be structured and presented for review on an ongoing basis so that if
objectives and targets are not met, corrective action can be taken.

Inspections: construction phase


Owing to the transient nature of the construction phase, the greatest source of information is that
obtained through ongoing visual inspection. At the same time s ome potential impacts are difficult to
monitor quantitatively, such as soil erosion and waste management. An ongoing, but pragmatic
inspection regime will be developed that allows for potential HSE transgressions to be identified
proactively so that mitigation can be quickly and effectively implemented.

Internal audits
Where the monitoring data and the inspection reports highlight problems, an internal audit can be
used to ascertain the source of the problem and to define action to prevent its recurrence. The three
key areas for audit are facilities (are they operating properly?), project procedures (are they properly
designed and implemented?) and finally, and perhaps most importantly Contractors HSE
performance.

Corrective action
There are several mechanisms for implementing corrective action, both during the construction and
operational phases. The main mechanisms to address transgressions include: verbal instruction (in
the event of minor transgressions from established procedure, usually following a site inspection);
written instruction (identifying source/s of problems, usually following an audit) and contract notice
(following possible breach of contract).
Reporting
The findings of all of the above will be structured into instructive reporting that provides information
to all required parties on HSE performance, together with clearly defined corrective action where this
is seen to be required. Both the monitoring and inspections are reported on continuously. W ithin the
reporting structure it is necessary to create a review function that continuously assesses the
reporting and prescribes any necessary corrective action.

1.2.7 Management review


The final component of the EMPr management cycle is a formal management review that takes
place at defined intervals, both during the construction and operational phases. The purpose of the
management review is for senior project management to review the environmental management
performance during the preceding period and to propose measures for improving that performance
in the spirit of continuous improvement.

1.2.8 Liaison
Throughout the project, liaison will be maintained with relevant parties (authorities and/or
communities) to ensure the following:

Advance warning to communities and/or landowners, where a project activities is likely to


infringe on private land, or where project activities may have some adverse impact on
surrounding communities, e.g. clearing of construction of right of way and activities such as
blasting;
Feedback to the relevant authorities (e.g. water affairs, environmental affairs) on the
environmental performance during the construction phase of the project.

1.3 Assumptions
The assumptions for the project are as follows:

All the technical data and information provided by the proponent to the EAP and specialists are
accurate and up-to-date.

The public involvement process has been sufficiently effective in identifying the critical issues
that needed to be addressed through specialist investigations and/or by the EAP. Specialist input
has thus been appropriately scoped to investigate the critical issues.

The public involvement process has sought to involve key stakeholders and every effort has
been made to ensure that landowners affected by the development, in particular those whose
land is traversed by the development, have been provided opportunity to comment. It is
assumed that where participation has been sought from the organizational representative/s, that
these parties have the authority to comment on behalf of their organization.

FibreCo and its contractors will implement the measures contained in the EMPr.

A monitoring and evaluation system, including auditing, will be established to track the
implementation of the EMPr to ensure that management measures are effective to avoid,
minimize and mitigate impacts; and corrective action is undertaken to address shortcomings
and/or non-performances.

FibreCo and its consultants will adopt a process of continual improvement when managing
and/or mitigating negative environmental impacts arising from the project. The EMPr will be used
as the basis of environmental management and will be improved and refined regularly.

Assumptions specific to each specialist study are given in the specialist reports included as
Appendices D1 to D5 as applicable.
1.4 Uncertainties
Uncertainties are as follows:

The outcome of the land acquisition/negotiation for use of servitudes has not been finalised and
falls beyond the scope of this BA and EMPr.

Although locations of repeater sites are presented in the project documentation, the exact
location of the repeater sites can only be determined once the routing is finalized following the
conclusion of the servitude negotiation process and final route determination.

2 The Proposed Project


2.1 Optic fibre data cable
Data cable design will be finalised in an iterative manner during the course of the Project planning
and design phase. The following design detail is available for the pipeline at this stage:

The project entails the establishment of a long-haul fibre optic data cable network throughout
South Africa to carry data communications over long distances and at higher bandwidths than
are currently available in the market.

Additional routes between the major centres will be required for purposes of providing resilience
to the solution. This will entail alternative routes between the centres to provide a geographically
diverse path between the end-points. Fibre optic technology allows long distances to be
spanned with few repeaters. It is envisaged that a repeater will be situated approximately every
80 to 100km along the route housed in existing base station site infrastructure owned by one of
the promoters of the project. Prefabricated Telco grade equipment shelters will be constructed at
2
repeater sites to house approximately 30m of optical amplification equipment racks (typically 8
racks) with cooling units and backup generator. The facilitys primary power source will be the
national grid using existing transmission cables.

The data cable will have end point and repeater stations located as follows:

Table 2-1 End point and Repeater sites

SiteID StartRdNm StartRoute SiteRdNm Route LatDMS LongDMS Start Mid End
RE023 N6 N6 N6 7 3040'26.791"S 2642'14.503" E Y
RE023 N6 N6 N6 7 3040'26.868"S 2642'12.037" E Y
RE023 N6 N6 N6 7 3040'26.401"S 2642'11.931" E Y
RE043 N6 N6 N6 7 3041'20.138"S 2642'32.045" E Y
RE043 N6 N6 N6 7 3041'19.218"S 2642'26.852" E Y
RE043 N6 N6 N6 7 3041'19.68"S 2642'27"E Y
RE042 N6 N6 N6 7 316'20.977"S 2649'1.512"E Y
RE043 N6 N6 N6 7 316'20.841"S 2649'2.285"E Y
RE044 N6 N6 N6 7 316'43.558"S 2649'6.25"E Y
RE049 N6 N6 N6 7 3134'2.615"S 2639'14.953" E Y
RE049 N6 N6 N6 7 3133'58.794"S 3133'58.794"S Y
RE049 N6 N6 N6 7 3133'54.717"S 2639'2.879"E Y
RE035 N6 N6 N6 7 323'27.302"S 276'5.606"E Y
RE035 N6 N6 N6 7 323'30.641"S 276'16.718"E Y
RE035 N6 N6 N6 7 323'37.8"S 276'25.2" E Y
RE036 N6 N6 N6 7 3234'33.509"S 2725'33.444" E Y
RE036 N6 N6 N6 7 3234'32.238"S 2725'24.549" E Y
RE036 N6 N6 N6 7 3234'23.881"S 2725'18.12"E Y

2.1.1 Construction and installation

Construction of the fibre data cable and associated infrastructure is anticipated to commence in mid
2011, following the issuing of requisite authorisations. The construction phase will take 12 months
and the cable commissioned in 2012. The expected lifespan of the cable is more than 20 years. The
process of establishing an optic fibre data cable will include the following:

Planning will be carried prior to the commencement of excavation. This phase of the project will
include surveying of the route to identify physical features that occur along the route and prepare as
constructed records (e.g. layout plans that show the length and depth of cables, indicate places
where directional drilling will occur and provide High Voltage cable points and material and
equipment schedules, amongst others.) It will also be necessary to obtain information about all
utilities that the cable will cross. All approvals and authorisations for development and crossings (e.g.
transmission lines, railway lines, telecommunications and water pipes) will be obtained during the
planning phase of the project. A management plan will be prepared setting out the measures that
aim to avoid and/or mitigate potential risks, hazards and impacts.

Trenching and excavations will commence once the requisite approvals and authorisations have
been obtained from relevant authorities (e.g. South African National Roads Agency Limited (SANRA L)
regional managers approval of the plans, environmental authorisation and water use licences).
Trenches will be excavated to provide a minimum cover of 0.9 metre using various construction
methods (e.g. backacter to excavate soil and pecker or jackhammers to break rock before removing
with a backacter). Excavation will take place in a manner t hat aims to avoid damage to existing
utilities. Once the excavation has been completed, suitable bedding material (e.g. soil or sand) will be
placed in the bottom of the trench. W here the excavated material is not suitable for this purpose,
material will be obtained from existing permitted borrow pits. In urban areas, excavated material will
be handled in accordance with the requirements of the relevant local authori ty . Direction al drilling will
be undertaken in places where the cable crosses key lines of infrastr uc tur e (rail, national roads etc.)
and will be suitably aligned and sufficiently deep so as to comply with legislation and authorities
guidelines. Buried hand holes will be established every 900m along the fibre optic data cable route. In
addition, round man holes (with visible 600 to 800mm covers) will
occur on average every 4km along the cable route or on either side of a physical feature crossing
(bridge, rivers etc.).

Duct laying will take place directly from a drum spindle mounted on an excavator moving along
the trench. To avoid slackness in the duct, cable drums will be positioned in line with the direction of
the duct pull. The cable will be kept clear of any abrasive material when being pulled into position to
prevent damage to the duct sheath. The duct will be bedded in sand/soil which shall extend 100mm
around the duct. The duct will be uniformly bedded in soil free of rocky material. The depth of cover
of cables will be approximately 950mm. Conduits will be used where appropriate, notably within a
bridge, rail, road and water course crossing. Hand holes will be located approximately every 900m
along the route.

Reinstatement will take place in accordance with authorities requirements. In urban areas,
excavated land will be returned to its original condition. Trenches will be backfilled and compacted to
original ground level. Spoil and approved backfill material will be placed in such a manner so as to
avoid future subsidence. Stones, rock and paving material will be removed from site. Trees within
the affected area will be protected as far as possible.

All activities, notably those involving the installation of the fibre optic data cable, will adhere to the
requirements of the legislation dealing with occupational health and safet y and public safety. Special
attention will be given to these issues when working in close proximity to traffic as well as overhead
power transmission lines.

2.1.2 Start and end points of data cable


The data cables will start and end at designated points; RE043 in Aliwal North and the intersection of
the N6 and N2 (refer to route maps contained in Appendices A1 and A2).

2.1.3 Design and equipment standards


The design and equipment standards for the data cable and its associated infrastructure will comply
with national and international standards and best practices. The data cable will be designed to
have a minimum lifespan of 20 years. Due to changes in technology it will be costly to upgrade the
existing cable beyond this lifespan. It is therefore likely that the fibre will be removed and the duct
abandoned.

2.1.4 Monitoring
Monitoring of the data cable, and its associated infrastructure, is essential to ensure efficient
operation. Measures will be instituted to ensure a best practice HSE system is developed and
implemented to ensure that personnel are properly trained to carry out their work.

For the first 12 months after installation of the data cable, rehabilitation measures will be monitored
to ensure problems such as erosion and alien plant infestation are rectified.

2.2 Construction phase


Pre-construction activities will include: preparation of plans; obtaining of wayleaves and permits;
servitude establishment where the route/infrastructure falls outside the national and provincial road
reserves; land surveying; establishment of construction campsite/s; building of access roads; and
clearing of vegetation and removal of obstructions in the path of the proposed data cable.

2.2.1 Scale and pace of construction


It is envisaged that construction will happen concurrently, with a suitable number of separate
construction teams working on different portions of the route corridor simultaneously. It is envisaged
that there will be between 2 and 4 construction teams operating on the development at any one time.
The final number will be determined by ZTE and will take into account a number of factors, including
time and cost.

The average rate of progress of construction will be strongly dependent on ease of excavation and
may vary from a kilometre a day to 50m per day depending on the terrain. The temporary
construction right of way required will be approximately 5-7m.

2.2.2 Construction process


The construction process is as follows:

An open ditch will be dug using excavators, backacters, specialised trenching plant and manual
labour. Topsoil will be set aside during excavation and will be replaced on the reinstated trench
prior to revegetation. This will be carried out in accordance with the SANRAL and provincial
government requirements;

The cable (ducting) will be laid on a bedding layer approximately 100mm thick and covered with
the same material to protect it from abrasion through contact with surrounding rock. Material for
the bedding will be sorted from excavated material for the trench wherever possible. W here this
is not feasible, sand will be sourced from existing mining operations, thus avoiding the need for
new borrow pits;

The trench will be backfilled with stockpiled material from the excavation of the trench. Topsoil
will be replaced on the soils surface. Erosion protection measures, where necessary, will be put
in place including packing trench walls with sand bags (Hessian bags filled with soil) to prevent
washout of material. Alternatively, the duct will be encased where required for reasons including
constructability in rock; and

River crossings will be undertaken using the following construction methods:

o Horizontal directional drilling of a parabolic-shaped tunnel under large rivers to minimize


or avoid disturbance of the river;
o Open cuts of seasonal rivers made at right angles to reduce the length of the crossing,
and can be backfilled with concrete to reduce the risk of erosion damage; and

o Pipe jacking will be carried out as required, based on financial considerations.

When horizontal directional drilling is undertaken, it is anticipated that approximately 60 litres of


sludge will be generated per metre of drill. The sludge will be settled out in construction ponds.
Bentonite used in the drilling process will be extracted from the sludge and reused.

2.2.3 Energy, water, sanitation and waste requirements


Temporary construction camps will be established where required in remote areas. There will be
energy and water use requirements (to be determined and supplied by ZTE). W ater use will be
limited to domestic and cooling purposes, and must be arranged by ZTE from authorised supplies.
Sewage and waste generated by activities of the construction camp will need to be disposed of.
During the lifespan of the project electronic components will need to be updated and replaced from
time to time. E-waste generated will be suitably disposed of at a registered landfill site.

2.2.4 Employment
It is anticipated that the greatest number of 300 new jobs will be created during the construction
phase of the project (i.e. about 30 jobs for the Johannesburg to Bloemfontein route). These
employment opportunities will require a combination of both skilled and unskilled labour in a range of
technical fields. W herever possible, workers will be recruited from the local area.

2.3 Operational phase


2.3.1 Transmission of information
The system will comprise of a network of glass optical fibre strands (thin strands of very pure glass
each about the size of a human hair) bundled together with various layers of protection to form a
composite data cable. The cables do not contain any insulating oils or other hazardous substances.

At either end of a cable system there will be a range of electronic and optic al equipments housed
within an existing building generally in metro sites. These optical devices convert electrical signals
from traditional telecommunication sources into a light signal through a laser diode and transmit a
multitude of coloured laser signals inside the glass optical fibre strands from one end of the system
to the other end. There are no electrical signals sent along the system and therefore no risk of
electromagnetic interference, induction or leaks.

Due to the properties of the glass fibres leading to attenuation and power dissipation of the laser
signal over distance, there will be signal amplification sites situated at every 80 km 100 km along a
single fibre route, and at every 200km 250km the signal will be regenerated by similar optical
transmission equipment. These sites will typically house a series of electronic equipments inside a
standard convert the laser signal into an electromagnetic signal and boost it up for re-transmission.

The laser diodes are all Class 1M products that conform to the IEC 60825-1 which states a
maximum power of 100mW and they also have built in sensors that shuts the system down when
there is a fibre break (this works through a detection of a reflected signal when a fibre strand is cut).
This ensures that the IEC EYE SAFE standards are also met along the whole network.

2.3.2 Safety and security


The operation of the cable and its associated end points will be monitored by trained personnel.
Regular maintenance checks will also be undertaken.

2.3.3 Energy, water, sanitation and waste requirements


Transmission of data will be powered by electricity drawn from the national grid with backup
generators in the case of power failures. Energy will be provided by Eskom and local authorities via
the national electricity grid. There will be the requirement for on-site ablution facilities at data end
points and repeater sites. Water use will be limited to domestic and cooling purposes, and will be
the responsibility of ZTE.

2.3.4 Monitoring
Monitoring of the data cable route and its associated infrastructure will need to be carried out for the
first 12 months after installation and rehabilitation to ensure problems such as erosion caused by
surface runoff are rectified.

2.3.5 Employment
During the operational phase, employment opportunities will be limited to technical staff responsible
for the maintenance and safety of data cable. It is anticipated that the project will create 100
permanent jobs (i.e. about 10 jobs for the Johannesburg to Bloemfontein route).

2.4 Decommissioning
It is envisaged that the data cable will be operational for 20 years. Fibre will be removed and the
ducting will be left in situ following decommissioning. Equipment at repeater sites and at data end
points will be removed and suitably disposed of and/or reused.

3 Impact mitigation and management


3.1 Links with the Basic Assessment
This chapter describes the mitigation and management measures required to respond to the
potential impacts identified. These measures are presented in Table 3-1. To facilitate cross
referencing, impact identification numbers are provided in the BA and the EMPr.

Section 3.3 of this document describes the management plans within which management and
mitigation measures will be implemented. The rationale is to cluster related measures in a cohesive
and systematic structure, ensuring clear roles and accountable management, together with
integrated and efficient implementation.

3.2 Mitigation and Management Measures per Phase


Refer to Table 3-1 below.
Table 3-1: Mitigation and management measures relating to impacts caused by project activities during all project phases

Aspect / Impact Impact Management activity Schedule Management plan


feature reference
Prec Con Op Cl

Biophysical
Flora and fauna B1, B2, B3 Impacts on terrestrial Set up measures to ensure that during preconstruction and construction, impacts on sensitive Construction
biodiversity ecology ecological areas and individual protected biota are minimized and avoided through careful management plan
routing of the data cable and management programmes plans and procedures during Decommissioning plan
construction.
Land acquisition and
compensation plan
The patch of forest near the R63/N6 Kei Road interchange (S32.690559 E 27.557804)
requires botanical specialist input during route finalization in the preconstruction phase

Clearing of vegetation should be kept to a minimum, with earthworks being kept to a minimum.
Exposed areas should be closed and compacted immediately after the construction
Re-vegetation, where needed, as part of a rehabilitation plan is advocated where practical. The
shallow topsoil layer should be stockpiled separately from the subsoil layers, should the
excavation exceed 0.5 m. Topsoil layers, which contain seed and vegetative material, should
be reinstated last thus allowing plants to rapidly re-colonise the closed trench
The passes and cutting also have the highest number of protected plants and these will require
permits from the local authorities with regard their removal (e.g. Aloes). During preconstruction,
a plant search and rescue operation should be undertaken. Some of these plants could be
retained for re-vegetation purposes, and excess plants distributed conservation, resource use
and scientific study groups such as:
Eastern Cape Parks Board
Umtathi Training Project Africulture Programme
B4, B5, B6, Impacts on aquatic Make certain that routing of the cable avoids and minimizes impacts on wetland and riverine
WW1, WW5, ecology habitat during the preconstruction and construction phase.
B7 Spread of alien invasive Apply appropriate measures during construction phase to avoid and/or minimise the spread of
species alien invasive species.

Alien / invasive plants species will be monitored and cleared on an annual basis, using the most
appropriate measures as suggested by the Department of Agriculture, Fisheries and Forests,
see Henderson (2001) (see Appendix D1)
Soils and land SLC1, SLC3, Impacts on soil Ensure that measures are taken to rehabilitate disturbed areas during the construction and
capability SLC4 operational phase. In instances where the route may depart from the road reserve, it is
necessary to negotiate with landowners to ensure that land is sterilised.
Aspect / Impact Impact Management activity Schedule Management plan
feature reference
Prec Con Op Cl

SLC2 Erosion potential Set up measures to ensure that soil erosion along the length of the data cable is prevented and
proactively managed.

The Construction Environmental Management Plan must include a monitoring step that
evaluates the re-vegetation process, the rate of plant colonisation and areas that are showing
erosion on a monthly basis.
Wetlands and WW1, WW3, Impact on flow Apply appropriate routing as well as wetland and river crossing methods to minimize disruption
watercourses WW6, WW7, these systems.
A2
WW2, WW4, Impact on water quality Implement preventative design, monitoring and management measures during the
WW8, EQ1, preconstruction and construction and operation.
EQ2
WW6, WW7 Impacts caused by Ensure alignment, design and construction of the cable result in effective measures to minimize
flooding risk from flooding for the operational cable.
Environmental EQ1, EQ2, Impacts to the quality of Develop and implement effective measures for minimisation of littering, contamination, siltation
quality EQ3, AQ1, the environment and dust during the construction phase, followed by timeous rehabilitation.
EQ4 Reduction of airspace Measures should be taken to limit the amount of spoil soil or rock that is disposed in landfill sites
in landfill sites during the construction phase.

Socioeconomic
Servitudes, SS11, SSI2, Impacts on services Ensure that measures are implemented to avoid and minimise disruption to existing services Construction
services and SSI3 and infrastructure and infrastructure during the preconstruction and construction phase. management plan
infrastructure Community safety plan
Traffic T1, T2 Obstruction of road Put measures in place to ensure that disruption of road users are avoided or minimised during Labour and human
traffic and risk to road the preconstruction and construction phase. resources plan
users Land acquisition and
compensation plan
Agriculture A1, A2 Impacts on agricultural Implement measures to ensure that farming is not affected during the construction phase.
activities Social responsibility plan
Emergency
management response
plan

Visual V1 Impact on landscape Make certain that visual impacts are avoided or minimised during the construction and
aesthetics operational phase. Ensure that rehabilitation is implemented promptly following laying of the
Aspect / Impact Impact Management activity Schedule Management plan
feature reference
Prec Con Op Cl
data cable.
Noise N1 Disturbance to nearby Implement measures during the preconstruction and construction phases that control noise
landowners and impacts.
residents
Health and safety HS1, HS2 Risk to safety of Implement measures that ensure the safety of workers and the general public during the
workers and general construction. Wildfires should be avoided.
public
Cultural heritage CH1, CH2 Impacts on cultural Develop and implement appropriate measures to avoid and minimise the damage or destruction
heritage resources of paleaontological material as well as archaeological and historical artefacts during
preconstruction and construction. Obtain permits for cultural resource management sites from
SAHRA.
There are a large number of places along this route where the cable route will have to be cut
through palaeontologically sensitive strata, particularly where these are exposed in road cuttings
and river beds (see maps in specialist report in Appendix D5). In these cases there is a high
likelihood that palaeontological material will be exposed and potentially lost. It is recommended
that:
Excavations into roadcuttings identified as sensitive during the survey (see maps in
Appendix D5) are monitored on site by a qualified palaeontologist, who should collect
and log important palaeontological material identifiable prior to cutting, as well as
material freshly disturbed during cutting.
Excavation crews should be warned to be on the lookout for palaeontological
material when working in areas between those identified to be of likely
palaeontological sensitivity. Any suspected palaeontological material should
immediately be reported to the palaeontologist for assessment.
Dinosaur skeletal remains discovered in the Allemanspoort cuttings should be
excavated and removed (by a qualified palaeontologist) to an official repository prior
to commencement of this project.
Economic E1, E2, E3 Positive impacts on job Ensure that the employment opportunities, service efficiency and communication is maximised.
creation, service costs Coordinate an effective communication programme with local authorities, SANRAL and
and communication provincial roads agencies during preconstruction, construction and operation phases.
3.3 Management plans
3.3.1 Rationale
The majority of mitigation measures outlined in Table 3-1 cannot be implemented as discrete,
isolated actions, since there are spatial and causal interactions amongst impacts. Therefore it is
advisable to implement mitigation and management actions via integrated management plans.
These plans are outlined below. W hile generally the principles guide preconstruction and
construction, operational and decommissioning phase plans, some of them start during construction
and continue into decommissioning, such as soil conservation management, air quality and water
management. The following management plans need to be implemented during construction and
maintenance of the fibre optic data cable:

Construction management plan (Section 3.3.2);

Labour and human resources plan (Section 3.3.3);

Workplace health and safety plan (Section 3.3.4);

Community safety plan (Section 3.3.5);

Land acquisition and compensation plan (Section 3.3.6);

Emergency management and response plan (Section 3.3.7);

Social responsibility plan (Section 3.3.8); and

Decommissioning plan (Section 3.3.9).

Many of the issues to be addressed in these plans are regulated in existing laws, regulations and
guidelines. In addition, it is recognised that the content of several plans will be generic, in the sense
that existing procedures are documented in standard codes of practice, and that adaptations of such
generic plans will only be possible as a dynamic process during construc tion and operation. Plans
presented below, therefore, contain specific actions as well as undertakings to prepare additional
plans as required prior to the commencement of certain activities during the detailed design phase.
FibreCo recognises the need for ongoing development and revision of all plans to ensure their
continued applicability.

3.3.2 Construction management plan


The construction management plan to be implemented by ZTE shall include the following key
measures:

Management of construction campsites


1. The Contractor shall comply with all relevant laws and regulations concerning water provision,
sanitation, wastewater discharge and solid waste disposal. ZTE is referred, in particular, to the
requirements of the National W ater Act (Act 36 of 1998) and related regulations, as well as
requirements contained in the W UL.

2. ZTE shall not locate campsites in any area in which vegetation is pristine, nor within 100 m of any
watercourse, nor in any area that could cause nuisance or safety hazards to surrounding
landowners, inhabitants or the general public. The location of a construction campsite requires prior
landowner agreement.

3. Prior to the commencement of construction, ZTE shall also prepare documentation for each proposed
campsite which contains, but is not limited to, details of: (a) site layout; (b) topsoil
management; (c) sewage treatment; (d) solid waste disposal; (e) erosion control (f) fencing; (g) litter
management; (h) provision for vehicle and plant servicing; (i) management of hazardous materials, (j)
water supply, (k) management of veld fire risk (l) rehabilitation; and (m)security. The documentation
shall be submitted to FibreCo as a part of ZTEs project specific Environmental Plan prior to
establishment on site.

4. ZTE shall access construction campsites in compliance with this EMPr.

5. ZTE shall keep construction campsites clean and tidy at all times. ZTE shall not leave domestic waste
uncontained, and temporary storage shall be fenced to keep out people and animals. No permanent
domestic waste disposal shall be permitted at the campsites. All domestic refuse is to be removed
weekly to an existing licensed domestic landfill.

6. ZTE shall take specific measures to prevent the spread of veld fires, caused by activities at the
campsites. These measures may include appropriate instruction of employees about fire risks and the
construction of firebreaks around the site perimeter.

7. ZTE shall prevent accelerated erosion from construction campsites and shall not discharge polluted
runoff into drainage lines.

Management of fuels and other hazardous materials


8. ZTE shall comply with all applicable laws, regulations, permit and approval conditions and
requirements relevant to the storage, use, and proper disposal of hazardous materials.

9. ZTE shall manage all hazardous materials and wastes in a safe and responsible manner, and shall
prevent contamination of soils, pollution of water and/or harm to people or animals as a result of the
use of these materials.

10. ZTE shall prepare a hazardous materials and waste management plan for inclusion in the site
specific Environmental Plan to be submitted to FibreCo prior to establishment on site. This plan shall
include, but shall not be limited to, measures to prevent: (a) contamination of soils; (b). pollution of
water; (c) safe siting and storage; (d) containment of lubricants and waste oil during maintenance of
vehicles; and (e) tampering with tanks.

11. ZTE shall classify all hazardous materials to be used on site according to recognized Codes of
Practice such as SABS Code 0228 for the Identification and Classification of Dangerous Substances
and Goods and the DW AF Minimum Requirements for the Handling, Classification and Disposal of
Hazardous W aste, and shall ensure that the handling, storage, transport and disposal of these
materials meets the requirements of these Codes.

12. ZTE shall not locate fixed fuel storage tanks in any location other than at approved plant yards or
campsites. Any fuel storage facilities with a capacity greater than 1000 litres shall be located on flat
or gently sloping ground and shall be bermed from the surrounding area to contain at least
125% of the total capacity of the storage containers. The berms and the floor of the bermed area shall
be of impermeable material or be lined to ensure that petroleum products cannot escape.

13. ZTE shall not construct fixed fuel storage or service or refuel any vehicle or equipment within 100m of
a watercourse or wetland, within a floodplain, or where there is the potential for spilled fuel to enter a
watercourse or groundwater. Should it not be possible to establish such a facility outside of the
100m zone, ZTE shall ensure that the necessary precautions are taken to prevent and clean up
spillages, including spill kits on the bowsers.

14. ZTE shall enclose all fixed storage by a security fence with a lockable gate.

15. When crossing watercourses and wetlands, ZTE shall place on-site tools and equipment, such as
pumps, compressors and generators on bermed impermeable sheeting (e.g. polyethylene or
other similar material) to prevent hydraulic fluid or fuel leaks from contaminating soil or groundwater
or entering any watercourse or wetland.

16. ZTE shall take all reasonable precautions to prevent fuel and lubricant spills during the course of
construction. To this end, ZTE shall ensure that: (a) there is no overfilling of diesel bowsers and
equipment tanks; (b) regular audits are performed to verify that no leaking or defective equipment is
brought onto site; and (c) any oils or lubricants discharged during routine vehicle servicing on site are
captured using drip trays, containers or other appropriate containment measures.

17. ZTE shall ensure that all equipment which is required to work in fish-bearing waters is cleaned of oil,
grease and other contaminants damaging to aquatic life.

18. ZTE shall ensure that fuelling and repairs are carried out or supervised by personnel familiar with
spill containment and cleanup procedures.

19. ZTE shall ensure that there is sufficient absorbent material available on site to manage accidental
spills. ZTE shall immediately clean up accidental spillages of fuels and oils, or other hazardous
substances, and shall report the incident to FibreCo and the measures taken to remediate the spill
problem.

Management of the construction right-of-way


20. ZTE shall obtain access to and along the cable (a) on a public road (b) on an existing private road or
track with the consent of the relevant owner or occupier of land (c) along the cable and construction
right-of-way and (d) along a specially approved route as defined below. Access to, and along the
construction right-of-way explicitly excludes access to land other than the access routes referred to
above.

21. The category of specially approved route is for cases where there is no existing access. A specially
approved route is one for which the relevant owner or occupier of land has given consent, and for
which approval has been applied for in writing, and granted in writing by FibreCo, subject to any
conditions that the landowner or FibreCo consider to be warranted (e.g. regarding erosion control,
rehabilitation). No specially approved routes will be granted if areas of pristine habitat are to be
impacted.

22. The utility and safety of any existing access shall not be lowered by use for the construction work or
construction-related activities, nor shall spillage, littering, accelerated erosion, or other environmental
impact, occur. ZTE shall: (a) ensure compliance with these requirements; (b) exercise all relevant
health, safety and environmental controls (including dust control, noise abatement and litter
prevention); and (c) remedy immediately any non-compliance and the effects thereof.

23. In all areas where construction requires gravelling or other methods of improving vehicle access,
ZTE shall completely remove these materials after construction and prior to rehabilitation of the area.

24. ZTE shall restrict the number of entry and exit points for security reasons. ZTE shall ensure that his
activities do not compromise the landowners or occupiers security, nor result in the loss, injury or
death of any farm animals or game.

25. The dismantling of gates and fences shall be subject to any special conditions reached in the
servitude agreements between FibreCo and landowners.

26. The Contractor shall prevent littering and the random discard of solid waste on the site. The
Contractor shall not dispose of any waste in the data cable trench.

27. ZTE shall manage hazardous waste as described in provisions 8 to 19.


28. ZTE shall minimise the risk of bush fires.

29. ZTE shall prevent trespassing on the site. Public entry to the site shall be prohibited and signs to this
effect shall be erected at points of potential public entry.

30. ZTE shall prohibit and actively monitor and prevent poaching or harassment of animals by contract
employees. Any employee found poaching shall be dismissed.

31. At the start of every working day ZTE shall patrol the open trench and rescue any animals that are
trapped in it either by catching and releasing (e.g. frogs and toads) or by driving out (e.g. dangerous
snakes).

32. ZTE shall prohibit and actively monitor and prevent the harvesting of medicinal or any other
plants by contract employees.

33. ZTE shall ensure that contract employees remain within the construction right -of-way or on approved
roads providing access to the construction right-of-way.

34. ZTE shall determine safe off-road travelling speeds for each section of the route corridor along the
right-of-way and shall ensure that these restrictions are enforced.

Emergency preparedness (see also Section 3.3.7)


35. ZTE shall develop an emergency plan that will enable rapid and effective response to all types of
environmental emergencies in accordance with recognized national and international standards.

36. The emergency plan shall include the establishment of a network of communication between ZTE
and emergency services including police, traffic police, local medical and ambulance services, fire
departments, farmers associations, conservancies, farmer neighbourhood watches, etc.

37. ZTE shall test emergency preparedness on a regular basis and review procedures to remedy
shortcomings to ensure a high level of emergency readiness to deal with environmental and third
party incidents.

Fire prevention and management


38. ZTE shall take all necessary precautions to prevent the ignition of veld fires caused either
deliberately or accidentally as a result of the work being performed.

39. ZTE shall prepare a fire prevention and fire emergency management plan as a part of the
Environmental Plan to be submitted to FibreCo prior to establishment on site. The plan shall include,
but not be limited to, the following: (a) sources of fire risk; (b) measures to comply with any
requirements of local authority fire departments; (c) measures to meet requirements agreed between
FibreCo and the landowner; (e) measures to minimize the risk of accidental veld fires caused by any
activity related to the work; and (f) measures to control an accidental veld fire.

40. ZTE shall provide adequate fire fighting equipment at specified localities on the work site to meet any
emergency resulting from ignition of a veld fire. This equipment should include, but not be limited to,
(a) fire extinguishers; and (b) fire fighting flails.

41. The areas of commercial plantations through which the data cable is routed are particularly sensitive
to fire hazard (such as in commercial forests) and ZTE shall strictly comply with all fire management
requirements set by the owners of these plantations.

42. ZTE may expect that hot work will be prohibited under specified meteorological conditions and that
appropriate and adequate fire fighting equipment would be required to be on standby at all times
where hot work is being carried out.
43. Wherever practicable, bush shall not be cleared using burning. In instances where this is possible,
controlled burning can only take place upon request of and approval from the landowner, and when
there is no wind and appropriate fire fighting equipment is in attendance.

Management of dust and noise nuisance


44. The Contractor shall control dust along the construction right-of-way so as to ensure that no
detrimental effects to landowners, occupants or the general public are caused. Control measures to
be considered include the use of water bowsers to wet down surfaces that have been denuded and
which have the potential to generate dust.

45. The Contractor shall comply with the legal requirements for the management of noise impact
specified in the Noise Regulations under the Environment Conservation Act (Act 79 of 1989). If
instructed to do so by FibreCo, ZTE shall demonstrate compliance with the noise regulations by
means of measurement of residual noise levels at receiver points specified by FibreCo. Measurement
shall be in accordance with the requirements of the noise regulations.

46. In the event that this should be required, ZTE shall notify all landowners and inhabitants within 200m
of a blast zone of the dates and times at which blasting is scheduled to occur. Blasting shall not be
undertaken between the hours of 18h00 and 07h00 without the agreement of the affected landowners
and occupiers.

47. ZTEs employees shall not make recreational use of all-terrain vehicles or motorcycles on the site.

Land owner and occupier relations


48. ZTE shall respect the property and rights of landowners and occupiers at all times and shall treat
all such persons with deliberate courtesy.

49. ZTE shall comply with all special agreements between FibreCo and affected landowners provided in
the Servitude Agreements and/or the Property Line List and/or required in terms of relevant national
legislation.

50. Access over land, the integrity of fences, the closure of gates, control of veld and forest fires, littering,
dust control, noise abatement, harassment of domestic and wild animals, sedimentation and
contamination of ground and surface waters, damage to landscape and vegetation, and all such
environmental matters, shall be controlled, as far as practicable, by the Contractor in the best
interests of the land owner or occupier.

Complaints register
51. ZTE shall establish and maintain a register for periodic review by FibreCo that logs all complaints
raised by landowners, occupiers or the general public about construction activities. The register shall
be regularly updated and maintain records, including the name of the complainant, his or her
domicile and contact details, the nature of the complaint and if any action that was taken to rectify
the problem.

Health management
52. ZTE shall comply with all relevant legislative requirements governing worker health and safety (e.g.
Occupational Health and Safety Act (Act 85 of 1993) and related amendments and regulations).

53. ZTE shall also prepare and implement a programme to minimize the spread of HIV infection
as a result of the construction contract. The programme shall be prepared with the
assistance of a medical doctor with experience of HIV prevention and treatment.
Control of construction activities in sensitive areas
54. Prior to the commencement of construction activities, ZTE shall (together with the ECO) survey the
limits of the construction right-of-way and of any additional workspace areas required for
construction and shall mark the limits using 1.5m long stakes at 200m maximum intervals. These
stakes shall be preserved throughout the work under contract. In the areas where pristine habitat is
affected, the stake interval shall be reduced to 50 m spacing and the stakes shall be painted a
conspicuous colour.

55. In these areas, the Contractor shall take the following additional precautions: (a) staff and, in
particular, machine operators shall be specifically instructed about the sensitivity of the areas; (b)
vegetation clearance shall be restricted to the absolute minimum necessary to provide access along
the construction right-of-way; and (c) site staff responsible for environmental management shall
increase the frequency of monitoring in the areas to verify continuing compliance with the
environmental standard and the restriction of vehicle traffic to within the construction right-of-way.

56. ZTE shall erect a physical barrier (e.g. a removable fence) to ensure that there is no unauthorized
access of any other areas by construction workers, or as specified in the servitude negotiations with
the affected parties.

57. In sections of the route corridor, where the data cable crosses the escarpment and where steep and
rugged terrain is experienced, ZTE shall prepare a detailed method statement for review and
approval by FibreCo prior to construction. The method statement shall include details of: (a) access
requirements and the construction of any necessary access roads; (b) any areas of cut and fill
required to complete the works; (c) an itemised list of equipment that will be used for the excavation,
laying of cable and backfilling of the trench; (d) measures to ensure the management of erosion
during the construction of the work; and (e) measures that will be used to stabilise and rehabilitate the
completed works. Such measures will need to consider special methods of retaining topsoil on the
slopes by reducing rainfall impact, re-vegetation methods that are less prone to erosion loss (veld
sod) and any other necessary measures to ensure that rehabilitation is effective.

58. Damage or harm to threatened plant species is illegal in terms of legislation. Threatened species are
defined in terms of the most recent Red Data list of Southern African Plants. While every effort has
been made to ensure that the data cable route corridor does not impact on threatened species, ZTE
shall be solely responsible for any action necessary to ensure the prevention of harm to such
species found during construction. In the event that ZTE, FibreCo or any other party in any area that
could be damaged by the works finds a threatened plant, this shall immediately be reported to
FibreCo and the relevant authority (SANBI or one of the Parks Boards as relevant). ZTE shall call
upon a suitably qualified botanical expert to oversee: (a) rescue of the plant(s) and transplantation in
a suitable local habitat in a conserved area or in a recognised botanical garden; or, where this is not
possible; and (b) the collection of seeds and cuttings for use at botanical gardens and for storage in
seed banks.

59. ZTE shall take note of the possible occurrence of threatened animals and, in particular, antelope near
the data cable route corridor. ZTE shall be particularly vigilant in these areas in order to ensure that
none of these animals are deliberately or accidentally harmed.
Table 3-2 Specific requirements for the siting of the cable trench and repeater sites

Location Feature to protect Recommendations:

Paleontological features
Road cuttings including in Road crossings in the identified Excavations into roadcuttings identified as sensitive
the following areas: areas have a high likelihood of (see maps in Appendix D5) must be monitored on
containing fossil deposits site by a qualified palaeontologist, who should
Penhoek Pass collect and log important palaeontological material
identifiable prior to cutting, as well as material
Allemans Poort freshly disturbed during cutting.

Excavation crews should be warned to be on the


Xolora Mountains
lookout for palaeontological material when working
in areas between those identified to be of likely
Katberg Formation palaeontological sensitivity. Any suspected
palaeontological material should immediately be
Exposed road reported to the palaeontologist for assessment.
cuttings northand
south of Dinosaur skeletal remains discovered in the
Cathcart Allemanspoort cuttings should be excavated and
removed (by a qualified palaeontologist) to an
WaQu River crossing official repository prior to commencement of this
project.
Black Kei River Crossing

Burgersdorp Formation
(Queesntown district )

Lessayton River
Wetland and river areas

Klipspruit River The flow depths for these small Construction should occur during dry season to avoid
sensitive rivers vary from about 2m flooding effects.
305220,6S 264809,7E deep upstream of the culverts to
Eland River about 3m deep (flood depths).
At the peak flow of
304613,5S 26457,0E about
1100m3/s, both rivers might be
flooded during the wet season.

Orange River system The presence of endemic species Stay in road reserve wherever possible
contained by the river system. The
304109,23S riverine systems in this area are of
high importance in supporting The duration of impacts on the system should be
instream taxa.
264221,06 E minimised as far as possible by ensuring that the
duration of time in which flow alteration and
sedimentation will take place is minimised.

During the construction phase, no vehicles should be


allowed to indiscriminately drive through the
wetland areas.

All areas affected by construction should be


rehabilitated upon completion of the construction
phase of the development. Areas should be
reseeded with indigenous grasses as required.

Ecological features
R63/N6 interchange Forest patch in close proximity to Appropriate selection of final alignment in
N6 consultation with suitably qualified ecologist during
32.690559S 27.557804E preconstruction
Location Feature to protect Recommendations:
Cuttings and passes Passes and cuttings have the Prior to any construction occurring, a plant search
highest number of protected plants and rescue operation is initiated as part of the pre-
Along entire route and these will require permits from construction Environmental M anagement Plan for
the local authorities with regard these areas only. Some of these plants could then
their removal (e.g. Aloes). be retained for the re-vegetation purposes, while
excess plants could be distributed amongst the
following conservation, resource use and scientific
study groups for example:
Eastern Cape Parks Board this
provincial authority uses plants in the re-
vegetation /
rehabilitation of several nature reserves within
the province
Umtathi Training Project Africulture
Programme. This group collects and
grows plants sourced from wild populations
that would be found acceptable for use in
traditional medicines, thus reducing the pressure
on the natural resources
Heritage features
Queenstown Town Hall (Declared National Appropriate selection of final alignment in
M onument) consultation with suitably qualified heritage
31.53.820S; 26.52.429E specialist during preconstruction

Queenstown Boer War (1988-1902) statue of Appropriate selection of final alignment in


soldier consultation with suitably qualified heritage
31.53.769S; 26.52.255E specialist during preconstruction

Queenstown Church (historical) Appropriate selection of final alignment in


consultation with suitably qualified heritage
31.53.820S; 26.52.429E specialist during preconstruction

Control of vegetation clearing


60. ZTE shall not clear any vegetation along the construction right -of-way outside of the areas defined by
the stake markers.

61. ZTE shall clear vegetation along the construction right-of-way and the access routes to the minimum
degree necessary for construction. Cleared vegetation shall be windrowed along the perimeter
of the construction right-of-way.

62. The large indigenous trees occurring in the riparian zone which have been individually categorised,
named, marked in the field shall not be damaged by ZTE unless a permit has been obtained
from the relevant conservation authority. The trees shall be plotted on the survey drawings. ZTE shall
prevent damage to these trees and/or obtain the necessary permit should it be necessary to trim or
remove these trees.

63. Where the data cable passes through an afforested (plantation) area ZTE shall comply strictly with
the conditions agreed between FibreCo and the owner.

64. Where ZTE has to dispose of vegetation cleared from the construction right-of-way, he/she may do
so with the permission of the landowner provided there is no impairment to the health and well
being of any person, to water quality, land use and capability or ecological stability of the area in
which it is disposed.

65. The burning of vegetation should be avoided as far as possible. The Contractor shall only be
permitted to undertake the controlled burning of brush and other vegetation cleared from the
construction right-of-way, upon consent from the landowner and subject to compliance with any
burning regulations of the district. A method statement shall be prepared for each controlled burn, and
submitted to the relevant fire prevention authority.

Control of topsoil and subsoil


66. ZTE shall store topsoil (defined as the soil above 150mm) excavated from the trench in a wind row
or stockpile which shall be discernibly separate from wind rows or stockpiles of any other excavated
materials.

67. ZTE shall remove topsoil from a corridor up to 0.5m wide over the line of the trench.
Topsoil shall not be disturbed, more than is absolutely necessary, on the remaining construction right -
of-way.

68. Topsoil shall not be contaminated with anything that might impair its plant-support capacity (e.g.
aggregate, cement, concrete, fuels, litter, oils, domestic and industrial waste).

69. ZTE shall temporarily stockpile topsoil in a location that will minimize any loss due to erosion or
mixing with other material.

70. ZTE shall ensure that topsoil is stockpiled in a manner and for a period of time that does not result
in deterioration in its plant support capacity.

71. After the completion of the backfilling, re-contouring and erosion control works, ZTE shall spread the
topsoil evenly at uniform depth over the areas from which it was removed.

72. The stockpiling of topsoil along the route corridor for the purposes of reinstatement is regarded as a
vital component of successful rehabilitation, and compliance with the stripping requirements specified
above will be strictly enforced. In areas where topsoil of less than 150mm is stripped, ZTE will be
required to demonstrate that substantial constraints prevailed which made this requirement
unattainable.

73. ZTE may distribute waste soil (soft material) evenly around the construction right -of-way as long as it
does not impact negatively on natural vegetation or land capability.

Control of material supply and borrow areas


74. ZTE shall, as far as possible, source all material needed to lay the data cable from existing permitted
mines and/or quarries in the area.

75. In instances where bedding material needs to be obtained from a new borrow area, ZTE shall comply
with the requirements of relevant legislation. Mining authorization from the Department of Mineral
Resources (DMR) is a legal requirement for new borrow areas, the application for which must include
an Environmental Management Programme, submitted to the Provinc ial Director of Mineral
Development.

76. In addition to any requirements that are specified by the DMR, ZTE shall prepare a method statement
including plans, detailing the expected quantity of excavation, temporary and permanent drainage
control, the final contouring of the borrow pit and the proposed method of rehabilitation and shall
submit this to FibreCo for approval prior to opening the borrow pit.

Control of stone and rock waste


77. ZTE may move surface stone and rock to facilitate data cable construction, but shall not stockpile or
dispose of this material off the construction right-of-way without landowner consent.

78. Where the land is naturally armoured (i.e. has significant amounts of surface rock and stone), ZTE
may return this material back over the construction right-of-way in approximately the same proportions
as occurred prior to construction.
79. ZTE shall prepare a method statement detailing the proposed location and method of disposing of
waste rock excavated from the data cable trench. As a general rule, windrowing of waste rock along
the perimeter of the trench shall be prohibited. ZTE shall identify erosion gullies or old borrow pits in
these sections of route corridor for preferential disposal of waste rock and other granular material.
The method statement shall include the measures that are proposed to stabilise and rehabilitate
the disposal site.

Control of blasting
80. Where this occurs, blasting rock in the data cable trench, ZTE shall comply with all legal
requirements and codes of practice relating to this activity.

81. ZTE shall take all necessary precautions to ensure that blast rock is not scattered over, or outside,
the construction right- of-way, causing damage or injury to the environment, people or animals,
agriculture, buildings or other infrastructure. Where necessary, ZTE shall employ blast nets or other
safeguards in order to ensure that blast rock remains in situ after the blast, so that it may be removed
from the trench in a controlled manner.

82. ZTE shall prepare and submit to FibreCo a pre-blast photographic record of any structures or
buildings within 200m of a blast zone, including any structural defects in these structures or buildings.

83. In the event of accidental over blast, ZTE shall immediately notify FibreCo in writing, and shall
indicate what damage has occurred, how the blast rock is to be collected and disposed of and how
the damage incurred is to be rectified.

84. ZTE shall institute suitable measures to reduce blast shock, such as: (a) size of explosive charges
per delay and the number of days of explosive exposure; (b) subdividing the explosives deployment,
using electric detonating caps with delays to reduce total pressure; (c) use of decking in drill holes to
reduce total pressure; (d) use of shaped charges at surfaces to focus blast energy; (e) use of angular
stemming material in drill holes to reduce energy dispersal to the aquatic environment; (f) use of
energy absorbers upstream and downstream of the blast, such as temporary gabion structures.

Control of construction of watercourse crossings


85. ZTE is responsible for controlling riparian and stream damage to the river systems through which the
data cable is routed. The Global Positioning System (GPS) location of possible watercourse
crossings and the methods to be used to affect such crossings are outlined in the W ULA contained in
Appendix D - Surface W ater Specialist Study).

86. ZTE shall comply with any conditions of approval set by the DW A, over and above the requirements
of this EMPr.

87. ZTE shall prepare for each river crossing a detailed method statement for review by
FibreCo and for approval by the DW A. The method statement shall include but not be limited to:

a) A biophysical description of the site (profile, depth and width of channel(s), geo-technical
drawings, large trees, reed beds, etc);

b) The proposed timing and duration of watercourse crossing construction;

c) An itemised list of the equipment that will be used for the excavation, laying of data cable,
backfilling of the trench and control of water;

d) Measures that will be used to control suspended sediment and turbidity (e.g. berms, hay
bales, bidem curtains, river / stream diversions, settling ponds), damage to riparian
vegetation, spillage of fuels and oils, cement and other foreign materials and a monitoring
programme to provide rapid feedback on the effectiveness of controls.

e) Measures that will be used to ensure that identified and surveyed trees in the riparian fringe
scheduled for protection within the construction right-of-way, shall not be damaged during
construction.

f) Measures that will be used to stabilize river embankments after construction and to return
the channel to its pre-construction profile or to a more stable profile.

g) Where applicable, measures that will be used to minimize the impact of blasting on aquatic
species in the event that construction under submerged conditions are necessary.

88. During construction, ZTE shall make provision to maintain the natural flow of any drainage line
affected by construction.

89. In excavating the bed of the water body for the data cable, ZTE shall comply with the following: (a)
the excavated areas must be backfilled with material that is of the same quality, and gradation to that
which was removed except in cases where blasting and grouting of the data cable takes place; and
(b) where blasting takes place (if applicable), the rock replaced in the trench at the surface is to give
the trench as natural an appearance as possible, so that in low flow periods, a linear scar is not
obvious.

90. Where isolating the location of a works, the following measures, among others, may be considered by
ZTE in order to minimize the risk of increased suspended sediment in the water column downstream
of the works:

a) Elimination of surface flow through the construction site;

b) The use of non-erodible materials for the construction of any berms, coffer dams or other
isolation structures used in a works within a flowing watercourse. The use of non-earthen
dam structures, such as aqua dams, are possible options;

c) In cases where the entire flow of water of a water body is diverted around the water crossing
site, it must be returned to the water body immediately downstream of the crossing site;

d) The use of silt fences or hay bales to isolate the construction area from the water body in
situations where the flow velocities and volumes are low;

e) The removal and temporary storage of any material excavated from the bed or banks of the
water body to a location out of the water body until the materials are permanently removed
from the location or backfilled into the water body. W here sufficient space exists, and where
the storage will not cause any environment al damage, this may be within the macro-channel
banks of the river; and

f) The treatment of any water removed from the isolation area, prior to discharge back into the
downstream river course, to remove suspended sediment.

91. The Contractor shall monitor the effect of construction on downstream sediment loads. The
monitoring programme shall include sampling in the river upstream and downstream of the works
during the period when construction in the river is taking place especially in the wet season.

92. FibreCo shall commission periodic independent audits of sediment generation caused by the
construction works in the rivers in order to verify the results of the sediment monitoring maintained by
ZTE.

93. ZTE shall adhere to the requirements of the W UL authorisation by DWA with respect to watercourse
crossings
94. During the carrying out of the works, ZTE shall remove any fish that are found within the isolated
portion of the watercourse crossing site, without harming the fish, to an area of the water body
immediately adjacent to the watercourse crossing, outside the isolated portion of the watercourse
crossing site.

95. Where data cable construction through river channels involves excavation of submerged rock, ZTE
shall give preference to methods that do not involve underwater blasting. In the event that ZTE
adjudges underwater blasting methods to be the only practical method this shall be fully motivated
and all necessary plans shall be prepared to demonstrate that the work can be conducted without
significant risk to aquatic organisms. Such plans shall be submitted to FibreCo and shall be approved
by the DWA as a part of the method statements for each major river crossing prior to implementation
of the works.

96. The method statements shall include all information required by the DW A.

97. ZTE shall apply measures to reduce impact on spawning fish, such as: (a) limiting the season of
explosive use from March to September (non-spawning season); and (b) use of non- explosive scare
techniques to move fish from the immediate blast zone (small repelling explosive charges are not
considered to be an effective means of driving fish from a blast area. Acoustic repellent devices
and/or bubble curtains may need to be considered).

98. ZTE shall notify DW A in advance of any underwater blasting scheduled for the major river crossings.
ZTE shall monitor the effect of underwater blasts upstream and downstream of the blast zone.

99. Where rehabilitating the river crossing works, ZTE shall comply with the following: (a) the river
channel embankments shall be returned to the pre-existing (or a more stable) profile than that which
existed prior to construction. ZTE may make use of the fixed point photography taken by FibreCo
in order to ensure compliance with this requirement; (b) river embankments shall be stabilised, using
any necessary protection measures, including re-vegetation, rip rap, reno mattresses and other
measures, to ensure that the banks are protected against erosion; (c) measures using indigenous
grasses to permanently stabilise disturbed areas shall be fully effective by the end of one growing
season; and (d) debris disposal and clean up shall be carried out to return the river course to its pre-
existing condition prior to the works.

100. In rehabilitating the river crossings, ZTE shall, in addition to the requirements specified in the re-
vegetation specification, include the re-planting of indigenous trees in the riparian fringe. At least
70% of the trees at each river crossing shall be alive and healthy at the end of the maintenance
period. The precise location of the trees in the riparian zone shall be provided to ZTE by FibreCo. All
trees are to be purchased from a reputable commercial supplier and are to be supplied with a phyto-
sanitary certificate which certifies that the soil in which they were propagated is weed free.

Control of wetland crossings


101. ZTE shall prevent permanent damage occurring as a result of construction of the works to all
wetlands along the construction right-of-way. The occurrence of wetlands in the construction right- of-
way is defined in the WULA. ZTE shall take note that the definition of wetlands in this EMPr is
broader than the laypersons understanding of the term wetland or marsh, and includes all areas
where hydromorphic soils occur along the route corridor.

102. As far as is reasonably practical, ZTE shall schedule construction activities to take place during
winter when surface and subsurface water flows are lowest, plants are dormant and inundation is
limited (See management measures relating to the control of topsoil and subsoil, construction in
sensitive areas and clearing of vegetation). W etland boundaries should be clearly marked in work
areas to assist the project personnel, contractors and ECO to avoid unplanned disturbances to the
wetlands.

103. The Contractor shall not remove any vegetation within the wetland, other t han that which is
absolutely necessary along the data cable construction right-of-way. Remove the top 30cm as sods,
i.e. the vegetation and underlying soil must be removed as a unit and stored separately from the
underlying material. These can be stockpiled immediately next to the trench if backfilling is to occur
within 24 hours and hydrological conditions allow. Where crossing of a wetland is necessary, this
shall occur at a 90 angle to the dominant natural flow of water in the wetland. In instances where
trenching occurs in the same direction of natural flow, it is important to ensure that trenching does not
create a subsurface drain, i.e. an underground preferential flow path due to backfilling with soil of low
permeability. W here approporiate, precautions can include inserting clay plugs at approximate 1-2m
intervals.

104. As far as is possible, ZTE shall backfill the trench in the wetland with the material originally removed.
This shall be done in accordance with the natural soil profile in the wetland. The method chosen as
being most appropriate for a particular site (including the use of clay barriers at intervals along the
data cable shall not affect the natural surface or sub-surface (lateral and longitudinal groundwater
movement) flow within the wetland and shall contain/prevent channelling of water along the data
cable and/or in the backfill. Replace soil in the reverse order in which it was removed, i.e. the soil that
was removed last must be used as the first backfill. The backfill must be restored to its pre-
construction elevation upon completion of works to prevent preferential flow pathways..

105. ZTE shall test each wetland before construction and identify any clay lenses within the depth of
excavation. The Contractor shall re-seal any impermeable layer that is breached by
construction within a wetland, either by using clay removed from the trench, or alternatively with
bentonite or any other appropriate material or method approved by FibreCo.

106. ZTE shall manage all temporary construction roads in or adjacent to wetlands so as to disperse
runoff and avoid concentrating water flows. Temporary construction roads in proximity to wetlands
shall be completely removed and rehabilitated after construction, in accordance with the re- grassing
specification.

107. Limiting access and construction disturbance in wetlands is considered essential. Maintain the
minimum footprints for the work necessary to accomplish the task at hand.

108. The Contractor shall carefully monitor the use of heavy machinery within wetlands. Machine
operators shall be fully informed about the sensitivity of these areas. W here vehicles need to enter
the wetland for trenching, the impact can be mitigated by lowering tyre pressure thereby distributing
the load over a larger area.

109. ZTE shall reinstate the original wetland geometry and topography in both cross -sectional and
longitudinal profile after construction.

110. ZTE shall remove from the wetland immediately after construction is completed all coffer dams,
causeway and construction materials, discard material, berms and other foreign items used in the
construction of the data cable. Ripping and disking of the wetland surface shall be done in all
compacted areas after construction.

111. ZTE shall re-vegetate the area encompassing the data cable construction right-of-way based on
measures devised by ecological specialist. Appropriate plant species, seeding methods and
replanting, as indicated in the specification and approved by FibreCo, shall be used to achieve this.
Measures are as follows:

112. The wetland crossings identified by the W ULA (See Appendix D), and where the above measures
(101-111) apply, are as follows:
Table 3-3 Wetland/ river crossings identified by the specialist studies

Crossing Watercourse Impact Minimisation


Longitude Latitude Province Farm
Name type
Trench through
watercourse using
Eastern
148 26.701887 -31.3286157 Frere Dell 108 NonPerennial measures contained
Cape in method
statement guideline.
Trench through
watercourse using
Eastern Allemanspoort measures contained
159 26.7566252 -31.2475804 NonPerennial in method
Cape 103
statement
guideline.
Trench through
watercourse using
Eastern Allemanspoort measures contained
160 26.7452202 -31.2659881 NonPerennial
Cape 103 in method
statement
guideline.
S tay within road
reserve. Trench
through watercourse
Eastern Plessies Kraal
154 26.8087218 -31.1183769 Perennial using measures
Cape 189 contained in method
statement
guideline.
Trench through
watercourse using
Modderpoort
Eastern measures contained
156 26.8659828 -31.0618722 186, Diepkloof Perennial
Cape in method
181, Nek 180 statement
guideline.
Horizontal
directional drilling
required. Apply
Eastern measures contained
138 26.7490186 -30.7702188 Vaal Kop 74 NonPerennial
Cape in method
statement
guideline.
S tay within road
reserve. Alien
control. Horizontal
directional drilling
Eastern required. Apply
161 26.802694 -30.872141 Kalkoenkraal 95 NonPerennial
Cape measures contained
in method
statement
guideline.

S tay within road


reserve. Erosion
control. Horizontal
directional drilling
Eastern
316 27.6428675 -32.738679 Farm 1830 Perennial required. Apply
Cape measures contained
in method
statement
guideline.
Trench through
Eastern
317 27.558266 -32.6908272 Farm 26 Perennial watercourse using
Cape
measures contained
in method
statement
guideline.
Trench through
watercourse using
Near S tudam
Eastern measures contained
324 26.7746319 -31.8562592 and Lesseyton NonPerennial
Cape in method
81 statement
guideline.
Trench through
watercourse using
Eastern Near Lesseyton measures contained
325 26.7800246 -31.8629366 NonPerennial
Cape 81 in method
statement
guideline.
Trench through
watercourse using
Near The
Eastern measures contained
326 26.881272 -31.9001368 Hexagon and NonPerennial
Cape in method
S outh
statement
Bourne
guideline.
Trench through
watercourse using
Eastern measures contained
327 27.0697304 -32.0344593 Lausanne 296 NonPerennial in method
Cape
statement
guideline.
S tay within road
reserve. Alien
control. Trench
Eastern through watercourse
44 27.1110168 -32.1082843 Bloemhof 13 Perennial using measures
Cape
contained in method
statement
guideline.
S tay within road
reserve. Trench
through watercourse
Eastern
320 27.1205864 -32.1579385 Hopewell 15 Perennial using measures
Cape contained in method
statement
guideline.
S tay within road
reserve. Use old
bridge. Trench
Eastern through watercourse
323 27.1585084 -32.3207616 Ellington 65 Perennial using measures
Cape
contained in method
statement
guideline.
S tay within road
reserve. Alien
control. S ediment
control. Trench
Eastern through watercourse
333 27.2842716 -32.42213 Old Drift 315 Perennial
Cape using measures
contained in method
statement
guideline.
Trench through
Between
watercourse using
Eastern Fourie's Rust
321 27.4500855 -32.6018276 Perennial measures contained
Cape and
in method
Riverside
statement
Lodge
guideline.

Trench through
watercourse using
Eastern measures contained
330 27.5054074 -32.6434832 Farm 571 Perennial
Cape in method
statement
guideline.
S tay within road
reserve. Alien
control. Trench
Eastern through watercourse
328 27.3746891 -32.464077 Hove 125 Perennial using measures
Cape
contained in method
statement
guideline.
S tay within road
reserve or use old
Near bridge. Trench
Eastern Greytown and through watercourse
329 27.4350569 -32.4930586 Perennial using measures
Cape Fort
Cunynghame contained in method
S tate Forest statement
guideline.

113. Control of impact of construction activities on groundwater

114. ZTE shall where possible avoid activities within 100m of a borehole.

115. Where possible, the pipeline route corridor will be realigned to avoid damage to a borehole.

Control of the impact of construction activities on archaeological sites and


graves and palaeontological remains
116. In terms of the Natural Heritage Resources Act (Act 25 of 1999), no graves or archaeological sites,
including man-made structures more than 60 years old, may be disturbed, damaged or destroyed by
any person without requisite arrangements or permits from SAHRA.

117. The ECO shall check that measures required by heritage professionals and SAHRA to ensure that
these are complied with for all routes.

118. The cable shall be aligned to avoid known grave sites and sites of archaeological and
palaeontological significance as far as possible.

119. When planning to align the data cable to bypass the above sites, ZTE shall make sure that this work
is done under the supervision of an ECO.

120. ZTE shall be responsible for commissioning a Phase 1 archaeological survey of repeater sites
identified Table 3-2 to verify if there are any heritages resources that will be impacted by construction
activities. If any of the sites earmarked as warranting protection by the heritage specialist cannot be
adequately protected during construction, then ZTE shall immediately draw this to FibreCos
attention, and shall prepare a proposal to reconfigure the layout of the repeater to avoid impacting on
identified heritage features.

121. The ECO must be trained in basic archaeological site identification in order to immediately inform the
archaeologist/palaeontologist of any chance discovery of archaeological sites or burials. The
archaeologist will then implement the required legal steps in terms of the applicable section of the
National Heritage Resources Act (NHRA) (Act 25 of 1999).
122. ZTE shall make provision for accidental discovery of archaeological sites and graves along the
construction right-of-way. Once the route corridor is surveyed and staked, and prior to construction,
ZTE shall, with the assistance of the ECO, verify that no further sites exist along the construction
right-of-way over and above those described in this EMPr. In the event that any sites found are
significant enough to warrant conservation, the Contractor shall determine whether this is
feasible and, if not, immediately notify FibreCo of the route alignment adjustment necessary to avoid
the site.

123. In fulfilment of the requirements of the South African Heritage Resources Agency (SAHRA), ZTE
shall prepare the necessary documentation and obtain the permits /authorisations from the relevant
SAHRA office to construct through and/or on those heritage sites which are directly affected by
construction activities but are considered to be of low significance. It should be noted that buildings
60 years and older must be assessed and a permit obtained from SAHRA before demolition is
considered.

Rehabilitation
124. ZTE shall restore the trench and construction right-of-way to the natural contours of the ground
and shall allow normal surface drainage.

125. ZTE shall remove all temporary works along the construction right-of-way and fences and private
roads disturbed by construction shall be restored to their original condition.

126. ZTE shall loosen compacted soils along the construction right-of-way by means of a plough or
scarifier. Scarifying areas where topsoil has been removed shall be carried out prior to the
replacement of topsoil. Care shall be taken to avoid topsoil inversion if scarifying is carried out in
areas where topsoil has not been removed. Any ripping or scarifying operation shall not exceed a
depth of 100 mm.

127. ZTE shall prevent concentrated run-off along, or next to, the construction right-of-way, and shall
do so by shaping the land, establishing vegetation, and taking other appropriate measures to absorb
and disperse runoff.

128. In places where erosion control is required, including the top of bank of all gullies, watercourses,
large depressions and steep slopes, the Contractor shall construct diversion banks across the
construction right-of-way to divert the flow of water away from the backfilled trench and into the
natural drainage courses.

129. In all cases, ZTE shall cover the backfilled data cable trench evenly with topsoil to a minimum
depth of 150mm.

130. On any deviations from the road reserve which cross arable land, ZTE shall ensure that stone and
rock within the soil profile are stockpiled so as to minimize constraints on adjacent land.

131. Where the land is naturally armoured with surface rock or stone, the Contractor shall, after
construction, replace the armouring over the construction right-of-way to protect against erosion.

132. On slopes steeper than 5%, ZTE shall use special protection methods to arrest soil erosion
during the vulnerable period before vegetation re-establishment occurs.

133. Where brush and tree limbs cannot be chipped or used by local communities, this vegetation shall
be spread evenly over the construction right-of-way to preserve and assist the regeneration of natural
vegetation, erosion control and providing animal habitation. Tree trunks and large limbs are to be laid
in a random fashion across the natural slope of the ground, and should not obstructing access by
construction vehicles. No tree trunks and large limbs shall be placed in gullies or erosion ditches.
134. ZTE shall establish vegetation cover (using species appropriate to the local area) in all areas
disturbed by the works in the first growing season after construction, and shall maintain this cover for
the duration of the maintenance period. ZTE shall notify FibreCo in writing, prior to re-vegetation, of
the method of preparation (scarifying / ripping / discing), soil amelioration (addition of lime or gypsum),
fertilizing, and seeding (source, mixture and quantity) to be used in rehabilitating each area of the
works and the post-establishment maintenance regime to be implemented.

135. ZTE shall maintain and submit to FibreCo records of the method used to re-establish grass in
each area of the contract.

136. Revegetation shall be done on the construction right-of-way including, but not limited to, all borrow
areas, temporary access roads, spoil sites, camp sites and the like.

137. Once the grass has been established, the maintenance period shall commence. This period s hall
extend for a minimum period of one calendar year.

3.3.3 Labour and human resources plan


The labour and human resources plan to be implemented by ZTE and FibreCo shall include the
following key measures:

1. ZTE shall establish a labour and human resources plan which shall be submitted to
FibreCo.

2. The plan shall be based on the following principles:

a. Compliance with national policy and legislation (e.g. Employment Equity Act) and
international labour conventions and norms.
b. Clear and transparent conditions of service, as appropriate.
c. Open and fair recruitment procedures.
d. Well-structured, transparent and locally-appropriate remuneration and compensation
procedures.
e. Accessible and appropriate training and development.
f. Clearly defined and open dispute resolution procedures.

3. Wherever possible, first priority should be given to hiring qualified local people.

4. The labour and human resources plan shall, as appropriate, be adapted by FibreCo and applied
during the operational phase of the project to cover maintenance of the infrastructure.

3.3.4 Workplace health and safety plan


The workplace health and safety plan to be implemented by ZTE and FibreCo shall include the
following key measures:

1. All relevant national legislation, including the OHS Act and related regulations, shall be adhered
to in order to provide a safe and healthy environment for all employees, Contractors, suppliers
and the community during construction and operational phases of the Project.

2. ZTE shall develop a health and safety plan in fulfilment of legal requirements for submission to
and approval by FibreCo prior to the start of construction activities.

3. FibreCo shall ensure workplace health and safety during the construction and operational
(maintenance) phases of the data cable. Management should lead by example to ensure that
legislative and contractual requirements are met.

4. Health and safety performance will be continuously monitored and procedures reviewed with the
aim of eliminating risk as far as reasonably practicable.
3.3.5 Community health and safety plan
The community health and safety plan to be implemented by ZTE and FibreCo shall include the
following key measures:

1. All relevant national legislation, including the OHS Act and related regulations, shall be adhered
to ensure that the health and safety of proximate communities and the public at large are not
threatened during construction and operational phases of the Project.

2. During the construction phase, ZTE shall manage and control construction activities in order to
minimise the risks to community health and safety. Special attention shall be paid to threats
posed by the movement of construction vehicles, violation of cultural sensitivities through
damage to graves and historic buildings and sites, contravention of community norms relating to
sexual practice and use of alcohol, security and access control to the construction right -of-way,
transport safety management and control of dust, noise and water pollution.

3. ZTE and FibreCo and its Contractors shall ensure that proximate communities are aware of the
procedures for ensuring community safety should potentially hazardous activities such as
blasting be required (See communication and information principles).

3.3.6 Land acquisition and compensation plan


Should there be diversions off the SANRAL and provincial road servitudes, the land acquisition and
compensation plan to be implemented by FibreCo shall include the following key measures:

1. FibreCo shall carry out negotiations with landowners in order acquire the land needed for the
data cable servitude. Compensation will be based on current land and land use valuations in
accordance with legislation, as appropriate.

2. The data cable route corridor shall be aligned to avoid resettlement of households and economic
displacement.

3. In order to comply with lender requirements (e.g. Equator Principles and IFC Performance
Standards), FibreCo shall prepare a land acquisition and compensation plan that describes how
project affected persons will be compensated, and how it will seek to improve conditions for
those affected by project activities. This plan should be based on the following principles:

a. Avoidance of resettlement and economic displacement wherever possible.


b. Fair compensation, at full replacement cost, prior to displacement.
c. The pursuit of amicable and negotiated settlement in the context of compensation
and assistance.
d. Structured and responsive monitoring and evaluation.

4. Land expropriation will only be considered where necessary.

3.3.7 Emergency management and response plan


The emergency management and response plan to be implemented by FibreCo shall include the
following:

Emergency management planning


1. FibreCo shall develop an emergency management plan to guide the coordination and
operational handling of an emergency situation to include:

a. Structure and operation of the emergency management team.


b. Establishment of an emergency management centre.
c. Information retained by the emergency management team.
d. Incidents requiring activation of the plan.
e. Incident severity classification.
f. Process to be followed in the event of an emergency.

2. Information pertaining to emergency management shall be reported through the HSE reporting
process.

Emergency response plan

The community health and safety plan to be implemented by ZTE and FibreCo shall include
the following key measures:

3. FibreCo should compile a comprehensive safety emergency management plan for the data
cable, and liaise with emergency services of local municipalities where relevant.

4. Emergency preparedness will include: staff emergency training; equipment maintenance and
inspection.

3.3.8 Social responsibility plan

The social responsibility plan to be implemented by FibreCo and its Contractors shall include the
following:

1. Compliance with the principles of Broad Based Black Economic Empowerment (BBBEE) as
enshrined in the BBBEE Act (Act 53 of 2003) and its associated codes of good practice by
FibreCo and its Contractors.

2. As necessary, compliance with the requirements of the Preferential Procurement Policy


Framework Act (Act 5 of 2000) .

3. In fulfilment of the above, maximize local employment and local subcontracting.

4. Where practicable, provide support to community initiatives aimed at the promotion of


sustainable development. This support could take many forms, including the provision of
technical information and advice and facilitating development in the areas affected by the data
cable.

3.3.9 Decommissioning plan

The decommissioning plan directs pre- and post-closure activities. The provisions relating to this
plan area as follows:

Planning for decommissioning


1. FibreCo shall develop a final decommissioning plan in conjunction with local authorities and
communities at least one year before the end of data cable operation, and update the plan
annually thereafter to ensure that the provisions and costing reflects current realities.

2. Prior to closure, FibreCo will hold negotiations with the relevant authorities and the local
population to identify the best possible use for infrastructure. W here appropriate, negotiations
will be held to make necessary arrangements to transfer useful infrastructure to new owners.

Decommissioning
3. During the decommissioning of the cable, FibreCo shall ensure appropriate disposal of E-waste
and other waste in accordance with waste management legislation dealing with the disposal of
hazardous and general waste.

4. FibreCo shall institute data cable abandonment measures as agreed to with relevant authorities.
5. The cleared sites and associated infrastructure such as access roads will be rehabilitated by
FibreCo and its environmental consultant/s using industry best practice methods.

Post closure
6. Once the data cable has been abandoned, FibreCo will retain a number of responsibilities.
These may include responsibility for ensuring that the right-of-way and any facilities left in place
remain free of problems associated with abandonment.

3.3.10 HSE Construction Phase Roles and Responsibilities


FibreCo plans to put in place a specific team (Owner's Team) to manage the construction phase of
the proposed Project. This team will be separate from the operations team, but will coordinate as
required to ensure that there are no conflicts between operational and construction requirements.
The physical construction will be managed by a Managing Contractor, who in turn will sub-contract
specific components to various construction sub-Contractors.

The Managing Contractors environmental and social staff will be supervised by the Owners Team
HSE organization. The Owners Teams HSE staff will include the following:

HSE Manager to oversee the implementation of all HSE requirements as defined by FibreCo
(essentially the requirements stipulated in this EMPr, but others may also become apparent and
be included during project implementation). He/she should possess the requisite qualification
pertaining to HSE.

Environment Manager will also oversee environmental matters with his HSE staff (HSE officers).
The staff should possess a suitable qualification in a natural science and/or environmental
science / management discipline and should have appropriate experience.

The HSE Officer (HSEO) - will assume the ECO function and be responsible for the
implementation of the various environmental management requirements that need to be met by
the Managing Contractor as well as the various other Contractors that will be operating on the
site. This function will include regular inspections, coordination of reporting, and site wide
environmental monitoring. The HSEO should have a tertiary qualification in a natural science
and/or environmental science/management discipline with 3-5 years relevant work experience.

Independent environmental consultant/s will be commissioned from time-to-time to assist with


specific tasks (e.g. review information and provide advice on specialist issues, assist in the
preparation of an annual monitoring report and conduct environmental auditing). An independent
environmental expert(s), in any field (e.g. wetlands, terrestrial ecology, water management,
archaeology etc.), may be appointed on request of the Environmental Manager or Owners
Representative to provide specialist advice.

Contractors will be expected to have their own Environment Managers and their activities will be
overseen by the Owners Team HSE staff. In addition, key line functions will have specific
environmental and social management responsibilities included in their job descriptions and
performance criteria. Critical among these is the Construction Manager. The Construction Manager
will be accountable for environmental and social management during the construction phase.
Specific responsibilities will include:

The effective implementation of the EMPr;

Regular performance reviews; and

Corrective and/or remedial action where this may be required.


3.3.11 Contractor arrangements during the construction phase
The following construction phase Contractor arrangements will be made to support HSE and EMPr
implementation:

A detailed code of practice for construction teams will be prepared and implemented. This code
will guide the management and behaviour of construction teams. The code will include items
relating to health, safety and community relations. The code of practice for construction workers
will include HIV/Aids counselling.

Information on the implications of construction will be disseminated before construction starts.

Information on the construction phase will be disseminated to affected landowners prior to


construction.

Contracts will be key tools in managing many potential negative impacts, such as transport
related incidents. In this context both construction and operational contracts will specify required
environmental and social practices.

3.3.12 Training, awareness and capacity building


The presence on site of one experienced HSE Manager, with previous exposure to similar projects,
will allow on-the-job training.

3.3.13 Environmental procedures for the management of operational impact


Prior to the commissioning of the cable, FibreCo will establish operational procedures to give effect
to the measures contained in the management plans presented in Section 3.3 of the EMPr. These
procedures will form part of the FibreCos HSE system and include: the routine maintenance of the
cable right-of-way; environmental management of the data cable right-of-way during repairs;
management of major erosion incidents; traffic safety; management of solid waste and health and
safety.

Each procedure should include the following information:

Procedure name and reference

Purpose of the procedure

Responsibilities for identifying operational impacts

Liaison with authorities and communities, where appropriate

Training of maintenance teams, where appropriate

Record keeping and reporting

Scheduling, where appropriate.

3.4 Monitoring
All management plans will be subject to monitoring. In general, monitoring will have two key
elements: routine monitoring against set standards or performance criteria; and periodic review or
evaluation. This will often focus on the effectiveness and impact of the programme or plan as a
whole. In some cases, independent parties will undertake review and evaluation. The diverse
monitoring requirements and responsibilities will be consolidated within the HSE function, and will
share human resources, databases and management reporting procedures.

During the construction phase, FibreCo shall be fully entitled to monitor and inspect Contractors
written records to demonstrate compliance with the EMPr. This compliance monitoring is intended to
verify that the responsible parties are implementing the management measures / procedures / specifications
contained in the EMPr. Compliance will mean that ZTE is fulfilling his/her contractual obligations.

W here necessary, baseline monitoring will be used as a means of longer term (post construction) verification of
biophysical conditions along the data cable route corridor, to critically evaluate issues of habitat recovery, alien
plant infestation and erosion along the data cable right-of-way.

3.4.1 Programme monitoring


FibreCo shall regularly monitor EMPr implementation. This process will include (as appropriate) the regular
monitoring of:

Erosion of soil along the construction right-of-way (12 months).

Air quality and ambient emissions, including dust generated by construction activities (3 months).

Rehabilitation of the construction right-of-way (0-2 years).

Noise (measured in dBA) generated by construction activities, including blasting, using specific
measurement parameters, reference times and measurement locations.

3.4.2 Plan Monitoring


All of the management plans make provision for monitoring and evaluation. Special attention should be given to
the monitoring arrangements relating to biophysical, heritage and palaeontological impacts.

During the construction phase of the Project, ZTEs HSE manager must report all environmental impacts (e.g.
large scale sedimentation and erosion, damage to and/or destruction of, natural vegetation and damage to
heritage resource) as well as accidents and incidents to the Owners Representative. These reported impacts
and incidents will be captured on a database to ascertain trends and track progress in the implementation of
preventative and corrective actions, and benchmarking against other, similar operations.

Depending on the level of severity, accidents and incidents during construction or maintenance will be
investigated by ZTEs HSE division, with key input from the line management to ensure accountability. Rewards
and recognition will be given to the best performing work team s on a periodic basis on a periodic basis.
The primary objective of these interventions is to recognise the positive behaviours and outcomes of workers
with regards to safety.

Appendix F-4 - Environmental Method Statements.pdf

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