2020 08 27 - Rhino 350 ER - EIAR Exec Summary

ENVIRONMENTAL IMPACT
ASSESSMENT REPORT FOR AN

APPLICATION FOR EXPLORATION
RIGHT FOR PETROLEUM (350 ER)
Various farms, Free State & KwaZulu-Natal

Prepared for: Rhino Oil and Gas Exploration South Africa
(Pty) Limited
Authority Ref: PASA: 12/3/350 ER
Date: August 2020
SLR Project No: 720.18034.00016

Report No: 2
Revision No: 0
Month/Year: March 2019
Rhino Oil and Gas Exploration South Africa (Pty) Limited
ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR AN APPLICATION FOR EXPLORATION RIGHT FOR 720.18034.00016
PETROLEUM (350 ER) August 2020
File name: 2020-08-27_Rhino 350 ER_EIAR-Exec Summary
EXECUTIVE SUMMARY
1. INTRODUCTION
This Executive Summary provides a synopsis of the Environmental Impact Report (EIR), including
Environmental Management Programme (EMPr) prepared as part of the Scoping and Environmental Impact
Assessment (hereafter collectively referred to as “S&EIA”) process that is being undertaken for the application
by Rhino Oil and Gas Exploration South Africa (Pty) Limited (Rhino Oil and Gas) for an exploration right (ER), in
terms of Section 79 of the Minerals and Petroleum Resources Development Act, 2002 (No. 28 of 2002)
(MPRDA) (Ref 12/3/350 ER), for petroleum products on various farms in the Free State and KwaZulu-Natal and
provinces.
The EIR summarises the EIA process followed to date and provides an overview of the proposed project and
the affected environment. It also provides an assessment of the impacts of the proposed project and sets out
the recommend management measures
1.1 Opportunity to Comment
This EIR has been distributed for a 30-day comment period from 28 August to 29 September 2020 in order to
provide interested and affected parties (I&APs) with an opportunity to comment on the findings of the S&EIA
process.
Copies of the full report have been made available for download from the SLR Consulting (South Africa) (Pty)
Ltd (SLR) website (at https://slrconsulting.com/public-documents) and via a zero-rated website
(https://slrpublicdocs.datafree.co/public-documents). An electronic copy of the EIR can be emailed or
provided on CD on request. The report’s Executive Summary has also been translated into Sesotho, isiZulu and
Afrikaans and is available on request.
Any comments should be forwarded to SLR at the address, telephone/fax numbers or e-mail address shown
below. For comments to be included in the Final EIA Report, they should reach SLR by no later than 29
September 2020. The document will then be updated to a final report, giving due consideration to the
comments received, and be submitted to the Petroleum Agency of South Africa (“PASA”), the designated
agency responsible for the administration of petroleum related minerals, for decision-making.
SLR Consulting (South Africa) (Pty) Ltd

Attention: Matthew Hemming
PO Box 1596, Cramerview 2060
Tel: (011) 467 0945

Fax: (011) 467 0978
Cell: 072 997 3082
E-mail: 7201803400016@slrconsulting.com
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1.2 Project Background
Rhino Oil and Gas has lodged an application for an ER with PASA.
Minerals included in the application are oil, gas, condensate, coal bed methane, helium and biogenic gas. The
ER application area is broad and encompasses parts of the Free State and Northern KwaZulu-Natal (see Figure
0). Rhino Oil and Gas previously held a Technical Co-operation Permit (TCP 165) over this area. The ER
application area excludes all properties where the granting of an ER is prohibited by Section 48 of the
MPRDA, such as protected areas, roads and residential areas.
In this ER application Rhino Oil & Gas has applied for authorisation to undertake early-phase exploration for oil
and gas which might be located within suitable geological strata. The proposed exploration work programme
is restricted to desktop data review and the undertaking of an aerial survey. The sole purpose of the
proposed work would be to indicate the presence of any possible petroleum resource which could be
investigated further. No stimulation, pressure testing, hydraulic fracturing or water abstraction is included in
the proposed exploration work to authorised by this ER.
FIGURE 0: LOCATION OF THE PROPOSED 350 ER EXPLORATION RIGHT APPLICATION AREA (ORANGE
OUTLINE)
1.3 Summary of Authorisation Requirements
An application for an ER requires statutory approval in terms of both the MPRDA and NEMA. In terms of
Section 79 of the MPRDA an ER is required from the Minister of Mineral Resources (or delegated authority)
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prior to the commencement of any exploration activities. The 350 ER application, submitted in terms of Section
79 of the MPRDA, was accepted by PASA in 23 January 2019. Acceptance of the application only permits the
applicant to continue with the regulated consultation and environmental reporting process.
Under Section 79(4) of the MPRDA a requirement for obtaining an ER is that an applicant must comply with
Chapter 5 of NEMA with regards to consultation and reporting (see below). The Minister (or delegated
authority) may only grant the ER if an Environmental Authorisation is issued. This requires that applicant obtain
an Environmental Authorisation (EA) from the competent authority, in this case being the Minister of Mineral
Resources (or delegated authority). The proposed exploration right application triggers Activity 18 of Listing
Notice 2 (GN R984) and thus a S&EIA process must be undertaken in order for PASA, as the delegated
authority, to consider an application for Environmental Authorisation and make a recommendation to the
Minister of Mineral Resources.
SLR has been appointed as the independent Environmental Assessment Practitioner (EAP) to undertake the
S&EIA process. The scope of the current EIA process is aligned specifically to the early-phase exploration work
programme (i.e. aerial full tensor gradiometry gravity survey). The environmental assessment of further
ground-based exploration including core hole drilling, seismic surveys, appraisal or well drilling activities for
exploration or future production falls outside of the scope of this EIA process.
In accordance with the EIA Regulations 2014, all other legislation and guidelines that were considered in the
preparation of the EIR are documented. The policy and legislative context within which the project is proposed
presented in Section 2 of the EIA Report.
2. EIA METHODOLOGY
2.1 Scoping Phase
The Scoping Phase complied with the requirements of NEMA and the EIA Regulations 2014, as amended. This
involved a process of notifying I&APs of the proposed project and S&EIA process in order to ensure that all
potential key environmental impacts, including those requiring further investigation, were identified.
The Scoping Report for the proposed project, which was prepared in compliance with Appendix 2 of the EIA
Regulations 2014, was accepted by PASA on 30 January 2020.
2.2 EIA Phase
In accordance with Appendix 3 of GN No. R982, the objectives of the EIA are to:
• identify the relevant policies and legislation relevant to the activity;
• present the need and desirability of the proposed activity and its preferred location;
• identify feasible alternatives related to the project proposal;
• ensure that all potential key environmental issues and impacts that would result from the proposed project
are identified;
• provide a reasonable opportunity for I&APs to be involved in the EIA process;
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• assess potential impacts of the proposed project alternatives during the different phases of project
development;
• present appropriate mitigation or optimisation measures to minimise potential impacts or enhance

potential benefits, respectively; and
• Through the above, to ensure informed, transparent and accountable decision-making by the relevant
authorities.
The EIA process for this application was interrupted by the COVID-19 pandemic and South Africa’s response
thereto. All timeframes relating to environmental permitting services and actions were extended by Directions
published by the Minister (refer to Section 2.3) in terms of the Disaster Management Act. EIA processes were
able to recommence from 5 June 2020, subject to provision set out in revised Directions by the Minister (refer
to Section 2.3). SLR subsequently made application to PASA for further extension of the timeframes in order for
the EIA phase of this application to be completed. PASA approved the extension and the final EIA Report is due
to PASA on or before 6 October 2020.
As per the Plan of Study for EIA presented in the Scoping Report, specialist studies were not required to inform
the impact assessment.
SLR used an assessment methodology which considered: the intensity, extent, duration of impacts, the
probability of the impact occurring, the reversibility and the degree to which the impacts can be mitigated. The
process involves consideration of, inter alia: the purpose and need for the project; views and concerns of
I&APs; social and political norms, and general public interest.
The significance of environmental impacts was rated before and after the implementation of mitigation
measures. The method applied to the assessment of environmental impacts was:
• Consequence is a function of intensity, spatial extent and duration;
• Significance is a result of the consequence and probability.
3. NEED AND DESIRABILITY
This section in the report aims to provide an overview of the need and desirability for the proposed project by
firstly, highlighting the applications for the use of natural gas (particularly with reference to the electricity
generation sector) and, secondly, indicating how these applications are aligned within the strategic context of
national policy and energy planning, broader societal needs and regional planning, as appropriate.
Use of Natural Gas
Natural gas is a fossil fuel, used globally as a source of energy for heating, cooking, and electricity generation,
amongst others. The fastest growing use of natural gas is for the generation of electric power.
Of the three fossil fuels used for electric power generation (coal, oil and natural gas), natural gas emits the
least carbon dioxide per unit of energy produced. Burning natural gas also releases lower amounts of nitrogen
oxides, sulphur dioxide, particulates and mercury when compared to coal and oil (Union of Concerned
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Scientists, n.d.). Some research shows that, over a 20-year time period, both shale gas and conventional
natural gas have a larger GHG footprint, than do coal or oil for any possible use of natural gas.
As economic growth is dependent on the availability of electricity, ensuring a sustainable and reliable supply of
electricity with sufficient capacity is a key aspect to growing the economy of South Africa. The electricity
shortages experienced in South Africa over the past decade were a contributing factor to the significant
slowdown in economic growth rate. In the context of the above, the use of natural gas for electricity
generation is considered to have substantial benefits and is identified in national policy, together with
renewable energy technologies, toward diversifying the domestic energy supply away from coal. The economic
feasibility of using natural gas for domestic power generation is dependent on the availability of domestic
reserves of natural gas, as well as the financial cost of importing natural gas.
At present, domestic resources are limited to Renergen’s Virginia Gas Project which is currently South Africa’s
only onshore production site and the offshore gas fields close to Mossel Bay (F-A field), which are understood
to be in decline. The F-O offshore field (Project Ikhwezi) is envisioned to complement this supply in the short-
to medium-term. Other proven offshore reserves include the Total’s Brulpadda discovery in Block 11B/12B and
the Ibhubesi Gas Field off the West Coast of South Africa. The development of this field to supply gas to the
existing Ankerlig Power Station is currently being considered. Neighbouring countries (Mozambique and
Namibia) and regional African nations (Angola and Tanzania) have substantial gas reserves.
Although limited, gas infrastructure and consumption do exist in South Africa. Presently, gas is imported to
South Africa through the Republic of Mozambique Pipeline Company (ROMPCO) pipeline from Mozambique.
This gas is mostly used in Sasol’s coal-to-liquid (CTL) process in Secunda (Bischof-Niemz, Carter-Brown, Wright,
& Zinaman, 2016). In Johannesburg, Egoli Gas supplies industry and households in some suburbs with
reticulated natural gas that is sourced from Sasol. In 2013, the total natural gas supply in South Africa
(domestic production and import) equated to approximately 2.5% of total primary energy supply for the
country (Bischof-Niemz, Carter-Brown, Wright, & Zinaman, 2016). Thus, an increase in domestic natural gas
reserves would enable South Africa to take steps to secure the countries’ energy supply (through
diversification), assist in reducing the emissions of greenhouse gases (by reducing the country’s reliance on coal
for electricity generation) and reduce the need for the importation of gas. As such, exploration for additional
domestic hydrocarbon reserves is considered important and supported by national policy, and any discoveries
would be well received by the local market.
National Policy and Planning Context
An overview of the national policy and planning context relating to the promotion of economic development in
general within South Africa, development of the energy sector (with specific reference to natural gas and
renewable energy) and response to climate change is provided. The following documents were considered:
• White Paper on the Energy Policy of the Republic of South Africa (1998)
• White Paper on the Renewable Energy Policy (2003)
• National Gas Infrastructure Plan (2005)
• New Growth Path (2011)
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• National Development Plan (2012)
• Draft Integrated Energy Plan (2013)
• Gas Utilisation Master Plan (GUMP)
• Paris Agreement, United Nations Framework Convention on Climate Change
• National Climate Change Response White Paper
• Integrated Resource Plan (2019)
Consideration was also given to regional policy and planning context relating to development within the Free
State and KwaZulu-Natal in general. The District Municipal planning framework was identified but has limited
relevance to the current remote sensing approach.
4. PROJECT DESCRIPTION
The EIA Report includes a general description of the proposed project and a comparative assessment of project
alternatives.
4.1 The applicant
The applicant for the Exploration Right, Rhino Oil and Gas Exploration South Africa (Pty) Ltd is a South African
registered subsidiary of Rhino Resources Ltd. Rhino Resources Ltd is a privately owned, independent,
technology driven oil and gas exploration and development company focused on Africa. More information is
available on http://www.rhinoresourcesltd.com/management.
4.2 Exploration Right application area
The exploration right application area includes approximately 4 270 properties (farms and portions) over an
area of 773 259 ha (see Figure 0). The list of the properties (farm name, number and portion), with the 21 digit
Surveyor General code, are included in the report. In broad terms the ER application area extends from the
Upper Tugela region of KwaZulu-Natal, north past Harrismith to just north of Warden in the Free State. The ER
application area extends westward, from Harrismith, past Kestell to Bethlehem. In the north the ER application
area extends from Warden past Reitz up to Lindley.
All exclusions as required by Section 48 of the MPRDA, such as protected areas and residential properties,
are excluded from this Exploration Right application area (in so far as the available information is accurate).
Access would not be required to any property as no physical, on-the-ground exploration activities are proposed
as part of the exploration work programme.
4.3 Description of the Exploration Work Programme
Rhino Oil and Gas proposes to undertake early-phase exploration for oil and gas resources which may be
located within suitable subsurface geological strata. The exploration work would target key geologies of the
Karoo Basin. The proposed exploration work programme is restricted to desktop data review and the
undertaking of an aerial survey. The initial, early-phase exploration proposed by Rhino Oil and Gas is only
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aimed at determining if there is an oil or gas resource in the area that would warrant further exploration. The
results of the proposed exploration would serve as a basis for planning possible further exploration.
The proposed 3-year exploration work programme includes:
YEAR 1:
- Data Acquisition
- Full tensor gradiometry gravity survey (OR in year 2)
YEAR 2:
- Data Processing
- Full tensor gradiometry gravity survey (if not in year 1)
YEAR 3:
- Data Migration and lead identification
A full tensor gradiometry gravity (“FTG”) survey images subsurface geology from an airborne platform. The
instrument measures gravity gradients to enable the identification of geological structures. Large areas can be
surveyed very efficiently. The survey would involve low-level grid-based flight of a light aircraft at slow speeds.
The survey plane would typically only pass over a particular area once. The flight parameters, survey grid and
timing can be adapted depending on relevant restrictions.
No further ground-based exploration, appraisal or well drilling and future production forms part of the current
ER application. Thus no extraction of hydrocarbons or water, no stimulation of wells or hydraulic fracturing
(fracking) is proposed in the initial three-year exploration work programme for which approval is sought.
4.4 Summary of project alternatives
The project scope to be considered and assessed in the EIA is the 3-year exploration work programme as
proposed by the applicant and described above. No reasonable and feasible alternatives have been proposed
and only the preferred alternative and the no-go alternative were considered during the EIA phase.
4.5 Related Applications
Rhino Oil and Gas Exploration South Africa (Pty) Limited has previously made six other applications for onshore
exploration rights in various areas of the Eastern Cape, Free State and KwaZulu-Natal Provinces. Details of
these applications and their current status are summarised in the Table below. Readers are referred to PASA’s
Hubmap for information on the location of these and other onshore oil and gas rights.
ER Ref Known as/Location Status
291 ER Rhino O&G: KwaZulu-Natal ER relinquished by holder
294 ER Rhino O&G: Free State ER granted
295 ER Rhino O&G: Eastern Cape ER granted
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ER Ref Known as/Location Status
317 ER Rhino O&G: Northern KZN EA abandoned by applicant
318 ER Rhino O&G: Northern Free State ER granted
346 ER Rhino O&G: Free State & KZN Appeal on PASA’s acceptance of ER application
350 ER Rhino O&G: Free State & KZN This application
4.6 Further exploration or future production
Further detailed exploration and future production do not form part of the current Exploration Right
application for which authorisation is sought. The regulatory framework sets out that the applicant would have
to obtain further environmental authorisation if they elected to pursue any activities beyond the scope of the
exploration work programme for which application is being made. Any further approval in terms of the MPRDA
and NEMA would be subject to an additional environmental assessment process with further public
consultation. Approvals for such additional exploration work are also likely to be required in terms of other
legislation.
If any of the future work were to pose unacceptable environmental risk, as determined by the regulated
assessment processes, then the required approvals should not be granted by the competent authorities. In
such cases the proposed work could not continue.
5. DESCRIPTION OF THE AFFECTED ENVIRONMENT

Baseline information for this EIR (See Chapter 6 of the EIR) was sourced through a desktop study and draws
extensively on information contained in studies that have been conducted by various government departments
and non-government environmental organisations responsible for the area covered by the exploration right
application. The baseline information is important to understanding of the ER application area’s overall
sensitivity, but is of limited relevance in the context of the proposed aerial surveys.
All areas with protected status under the National Environmental Management: Protected Areas Act, 2003 (No.
57 of 2003); Biodiversity Act, 2004 (No. 10 of 2004); National Forests Act, 1998 (No. 84 of 1998) and Mountain
Catchment Areas Act, 1970 (No. 63 of 1970) have been excluded from the extent of the Exploration Right
application area. The exclusions were made based on data sourced from SANBI.
All properties within the towns (i.e. erfs) located within the Exploration Right application are excluded from the
application by virtue of the fact that ‘residential areas’ are excluded from the ER application area in terms of
section 48 (2) of the MPRDA. There are several areas within the Exploration Right application area that have
significant rural communities living on property administered by the Traditional Authorities. These areas are
not formally registered as ‘residential areas’ although the density of houses may approximate that of formal
residential areas. Where feasible these have been excluded from the extent of the Exploration Right
application area.
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ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR AN APPLICATION FOR EXPLORATION RIGHT FOR PETROLEUM (350 ER)
File name: 2020-08-27_Rhino 350 ER_EIAR-Exec Summary August 2020
6. KEY PROJECT ISSUES
The following key project issues have been identified by the S&EIA project team, with input from I&APs:
SUMMARY OF THE KEY PROJECT ISSUES
Key issues identified by the project team, with I&APs input Indication of the manner in which the issues were incorporated, or the reasons for not
including them
1. Opposition to the project

There is strong opposition to the proposed exploration right application. The major themes of
Overall the public opposition makes for a very strong argument against the application and
the public opposition are the following:
the process. It is evident that the primary driver of the opposition are concerns about future
• Concern, even fear, of the future risks that might arise from production should a risks that might arise from production should a resource be found. I&APs have low levels of
resource be found. Production, and hydraulic fracturing (fracking) in particular, has
trust in the legislative provisions separating exploration and production activities, and the fact
potentially large risks to society and the environment and should not be entertained in
that the requisite approvals should not be granted if future work were to pose unacceptable
any form. There is a significant body of evidence from around the world (not least that
environmental risks. Regardless of their reasons or motivation, the fact remains that the
fracking is banned in a growing number of countries and territories) that fracking
majority of I&APs participating in the EIA process are strongly opposed to the project. It is
results in unacceptable risks to surface and groundwater resources and human
noted that a small percentage of I&APs have expressed interest in knowing the outcomes of
health. Such risks are borne by the landowners and local communities who do not
participate in the economic benefits that accrue to the right holder and government. the exploration or being able to participate in the benefits.
While there may be a consumer driven need for hydrocarbons, the risks and costs to
If the S&EIA process were simply a democratic process then the majority vote is clearly “no”.
society and the environment far outweigh the benefits. There is a lot of evidence of
It is vital that this public opinion is taken into consideration throughout the EIA process, by
the risks and costs and little evidence that gas production can consistently be
the applicant and by the decision makers.
undertaken in a safe manner. For this reason I&APs argue that the project should not
be approved.
• Concern that given the money involved, if any hydrocarbon resource is found, it will
not be possible to stop production regardless of what the future EIA processes may
indicate in terms of risk. Thus the only way to avoid such risks is to not open the door
to such projects. In addition to the argument presented above, there is an opinion that
the oil and gas industry has a reputation for massive financial contributions, bribery
and conspiracy with governments. It is considered evident that the large amounts of
money involved in the industry are such that governments have traditionally and will
continue to favour the needs of the oil and gas industry. The substantial, often short-
term, economic benefits that are likely to be derived ‘blind’ government to sound
decision making and it is the landowners and local communities who will bear the
risks. The South African government has been associated with a number of financial
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scandals, providing scant comfort for the integrity of the legislation. In order to
prevent any such risks it is best not to begin exploration as once the economic value
is known, the greed of the participating parties will make it very difficult to stop
production, despite the known risks. For this reason I&APs argue that the project
should not be approved.
• Hydrocarbon based energy is a flawed concept and countries are moving away from
new hydrocarbons in favour of a renewable energy sources. The extraction of
hydrocarbons from the earth and their subsequent processing and combustion for
human energy needs is the major driver of global warming and climate change. The
global community has acknowledged the risk that these place on the planet and
humans. Vast amounts of money and effort are being directed to avoid further climate
change. The global community has further agreed on the need to move away from
hydrocarbon based energy toward more sustainable sources such as renewable
energy. Despite gas being cleaner burning than coal and thus considered by some as
a transition fuel, the argument is that any continued development of hydrocarbons is
counter to the renewable energy path. South Africa has various policies that support
the implementation of renewables into the energy pool. For this reason I&APs argue
that the project should not be approved.
• A deep mistrust of government institutions and the people involved in such an
application and their true motives. Whilst the exploration right application and EIA
processes are set out in legislation, there is a deep mistrust of how these processes
are implemented and who the real beneficiaries are. Many people have voiced
suspicion that National government has committed to pursue gas extraction and will
do so despite public opinion or the findings of an EIA. There is also general suspicion
that high ranking political figures and connected families are involved. The South
African government and various figures have been associated with a number of
financial scandals. There is an expectation that Rhino Oil and Gas (a two person
company) is not making the application without some form of support from such
parties. Lastly there is a suspicion that Rhino Oil and Gas would ultimately sell the
right onto such parties, who would likely ignore the commitments and legislation in the
pursuit of profit. For this reason I&APs argue that the project, which has risks and
could lead to even greater risk in the future, should not be approved.
• Significant doubt over government’s ability to enforce compliance to the legislation.
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Some participants accept that the EIA process must take place in terms of legislation
and expect that the EIA and EMPr will provide for reasonable measures to manage
and mitigate risk. Thus in theory the exploration project could be undertaken without
unacceptable risk to health and the environment. The concern, however, is that there
is little to no enforcement of compliance during operations. The result is that rights
holders can and will do what they want with little regard for landowners and local
communities who will bear the brunt of negative impacts. For this reason the project,
which has risks and could lead to even greater risk in the future, should not be
approved.
Numerous objections have been made to the project and EIA process.
The EIA should assess the potential future exploration and production related impacts (including
The scope of this EIA is aligned with and limited to the activities that have been proposed by
fracking)
Rhino Oil and Gas. This is in line with the regulatory framework which sets out that the
applicant would have to obtain further environmental authorisation if they elected to pursue
any activities beyond the scope of the exploration work programme for which they have
currently made application.
A decision on the current Exploration Right application does not in any way guarantee the
holder future approvals that would be required, 1) to undertake further exploration and future
production activities, and 2) nor those required under other legislation (e.g. land owner
consent, WUL). Any further exploration work to evaluate an identified resource (i.e. beyond
the aerial survey for which authorisation is sought) or the future production of oil or gas would
require further approval in terms of the MPRDA & NEMA. Such approvals will be subject to
the relevant legal requirements which include further public consultation and environmental
impact assessment. If the future work were to pose unacceptable environmental risk, as
determined by the regulated assessment processes, then the required approvals should not
be granted by the competent authorities. In such cases the proposed work could not
continue.
In the EIA Regulations, 2014 “cumulative impact” includes the ‘reasonably foreseeable future
impact of an activity’. While it is foreseeable that further exploration and future production
activities could arise from the Exploration Right (if granted), the applicant has stated that
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there is not currently sufficient information to make reasonable assertions as to nature of any
future work. This is due to the current lack of relevant geological information, which the
proposed exploration process aims to address (refer to Section 5.2). The possible range of
the future work that could arise might vary hugely in scope, location, extent and duration
depending on whether a resource(s) is discovered, its size, properties and location. It would
not be reasonable to undertake an assessment of the environmental impacts of an undefined
project. Such impacts could not be reliably assessed and the range of outcomes is so vast
that the findings would be speculative at best and of no value in ascertaining the potential
impacts. It is also possible that future exploration determines that an economic resource
does not exist, in which case there would be no production.
Restrictions and sensitivities will prevent exploration/production

Rhino Oil and Gas has indicated that the broad view necessary for early-phase exploration,
particularly in regions with limited geological information, requires a regional approach.
Hence the need to apply for a right over a wide area, so that aerial exploration surveys have
the best chance of identifying the boundaries of relevant geological structures. Such
information is important to petroleum exploration. This is not to say that exploration would be
undertaken in all areas over which the right is held.
Rhino Oil and Gas has made this application over properties where it is lawful to hold an
Exploration Right. In their view the application area complies with Section 48 of the MPRDA
(see Section 5.2.2.1). If however there are properties where Section 48 of the MPRDA has
not been applied properly or for which the parameters have changed in the interim, then the
application area would need to be adjusted.
Rhino Oil and Gas is also aware that restrictions/exclusions may be applicable to further
exploration and future production activities. Such restrictions/exclusions might prevent the
production of oil and gas from target areas. However, the nature of such
restrictions/exclusions could vary depending on the activities proposed and regulatory
requirements. Thus the Restrictions/exclusions relating to further exploration and future
production activities are not applicable to this EIA. Restrictions/exclusions relating to the
proposed exploration work programme will be identified and applied through the course of
this EIA. The land use, water resources and biodiversity features that underlie the sensitivity
of sites within the Exploration Right application area will be documented in the EIA Report.
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Such information could result in the extent of the Exploration Right application area being
adjusted.
Rhino Oil and Gas continually monitors the regulatory regime and environmental sensitivities
of target areas and will consider this information in making decisions on whether to proceed
with future exploration activities. Rhino Oil and Gas would apply the restrictions/exclusions
relevant to future exploration activities at the appropriate time to ensure a lawful and
environmentally responsible approach.
The adequacy of the public participation process / methodology was challenged, particularly
The requirements for public participation and the timeframes for a scoping and EIA process
with regards informing rural communities.
are set out in the EIA Regulations 2014. The timeframes provided in the EIA Regulations
require that an applicant must within 106 days of acceptance of the Scoping Report by the
competent authority submit an EIA report, which has been subject to a public participation
process of at least 30 days. To date this has included:
• Land owner identification and notification (by email, post, fax and SMS).
• I&AP identification and notification (by email, post, fax and SMS).
• Distribution of a Background Information Document (BID) in English, Afrikaans,
isiZulu and Sotho) to the above parties.
• Advertisements in 11 newspapers in the week of 12 November (in English,
Afrikaans and isiZulu).
• Site notices placed at multiple locations within towns in the application area.
• Six public information meetings held in the week of 3 to 7 December 2018.
• The project has also been reported on in several regional and local newspapers
and social media campaigns.
• Notification to I&APs of the acceptance of the Scoping Report.
Further details of the outlining the public participation process are provided in the EIA report
(Section Error! Reference source not found.)
Objections to the application
SLR has, and will continue to, receive and document all opposition to and objections against
the application. Throughout the course of the current S&EIA process SLR will respond to all
submissions which are reasonable and relevant to the exploration work programme
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proposed for this Exploration Right application.
I&APs are advised that where objections are based on concerns relating to further
exploration or future production activities these will be documented but not responded to in
this EIA process. The reason for this is that legislation provides that Rhino Oil and Gas would
have to make further application for approval/authorisation for any activities beyond the
proposed exploration work programme. The responsibility for assessing impacts and
considering objections to future work rests with those future application and decision-making
processes.
Objections that cannot be resolved through the EIA process would have to be handled in
terms of the mechanisms provided for in the legislation.
2. Impacts on Physical Aspects

Effect on Soils and Land Cover
No physical, on the ground activities are included in the proposed exploration work
programme. Thus there would be no impacts to soils or land cover.
These issues will not be investigated further in the EIR.
Effect on Surface Water

programme. The proposed aerial survey would not cause impacts to groundwater quality.
The use of water will be limited to that that required to operate and maintain an aeroplane for
the duration of the survey period. The water would be sourced from existing suppliers and its
consumption is unlikely to meaningfully influence groundwater supply.
These issues do not require to be investigated further in the EIR. However, the importance
and sensitivity of the various water resources will be documented in Section Error!
Reference source not found..
Effect on Groundwater
programme. The proposed aerial survey would not cause impacts to groundwater quality.
The use of water will be limited to that that required to operate and maintain an aeroplane for
xv
720.18034.00016
including them
the duration of the survey period. The water would be sourced from existing suppliers and its
consumption is unlikely to meaningfully influence groundwater supply.
These issues do not require to be investigated further in the EIR. However, the importance
and sensitivity of the various water resources will be documented in Section Error!
Reference source not found..
Effect on air quality

programme. The proposed aerial survey would not generally cause impacts to air quality.
The FTG survey aeroplane will consume fuel and release emissions during operations as will
the vehicles of support services. Given the relatively short duration, small source and wide
extent of the survey neither the regional nor localised impact of the emissions is likely to be
detectable.
This issue of the effect on localised air quality will thus not be investigated further in the EIR.
However, the potential greenhouse gas emissions of the aerial survey will be estimated.
Effect on geology and seismicity

programme. The proposed aerial survey would not cause vibrations that could result in
seismic events. This issue does not require to be investigated further in the EIR.
3. Impacts on Biological Aspects

Effect on flora
programme. The proposed aerial survey would not cause impacts to floral habitats or plants.
These issues do not require to be investigated further in the EIR.
Effect on wetland habitats

programme. The proposed aerial survey would not cause direct impacts to wetland habitats.
Additionally the project would not cause impacts to surface water quality and therefore would
not affect water entering wetlands. These issues do not require to be investigated further in
the EIR.
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720.18034.00016
including them
Effect on faunal habitats

programme. The proposed aerial survey would not cause impacts to faunal habitats. These
issues do not require to be investigated further in the EIR.
Disturbance of fauna
programme. Thus the project would not generally cause impacts to fauna. However, the
flying of aerial surveys may cause disturbances to the fauna through increased activities in a
particular area, noise and direct mortality. The potential impact on fauna will be assessed in
the EIA phase. The aim of this assessment will be to determine which species, particularly
those of conservation concern, would be sensitive to the impacts of the aerial surveys. The
known distribution and key habitats/sites for such species within the application area will be
mapped at a broad scale. Additionally the relevant legal restrictions on flight location and
parameters will be identified and documented in an EMPr.
4. Impacts on Socio-Economic Aspects

Effects on heritage
programme. Thus the project would not cause impacts to heritage resources.
This issue does not require to be investigated further in the EIR.
Effects on roads and other infrastructure

programme. The proposed aerial survey would not cause impacts to existing infrastructure
such as roads and water supply. The FTG survey contractors will operate from an existing
airport/airfield in terms of a commercial agreement with the owner/operator of the facility. The
short-term use of such a facility for the survey (with a small staff compliment) is not
considered likely to place the infrastructure or other users thereof at any significant risk.
This issue does not require to be investigated further in the EIR.
Effect on existing land uses

programme. The proposed aerial survey would not cause impacts to existing land uses
xvii
720.18034.00016
including them
through either direct transformation or disturbances. The sensitivity of the various land uses
to such surveys will be documented in the EIA Report. This issue does not require to be
investigated further in the EIR.
Effect on ambient noise levels

programme. Thus the project would not generally result in disturbing noise levels. However,
the aerial FTG surveys (at low altitude) will generate noise that can be considered a
nuisance or cause a disturbance to a receptor. The survey aeroplane is modified to generate
low noise and vibration levels as these would otherwise interfere with the FTG
instrumentation. No health impacts (such as loss of hearing or increased blood pressure)
are anticipated based on the proposed FTG survey.
The potential noise impact of the FTG survey are assessed in Section Error! Reference
source not found.. Additionally the relevant legal restrictions on flight location and
parameters are identified and documented in an EMPr.
Effect on safety and security

programme. The proposed aerial survey would not result in in an influx of workers to an area
nor would any exploration worker require access to property. The public would have almost
no interaction with the aerial survey and would not be placed in danger. This issue does not
require to be investigated further in the EIR.
Risk of fires
programme. The proposed aerial survey would not result in any change to the fire risk. Rhino
Oil and Gas would have risk insurance for the activities being undertaken. This issue does
not require to be investigated further in the EIR.
Effect on land tenure

programme. Thus Rhino Oil and Gas has no intent of accessing any property to conduct
exploration, nor will have permission in terms of its exploration right to undertake any on the
ground exploration.
xviii
720.18034.00016
including them
Despite the issuance of an exploration right, the owner remains in control of the surface
rights. A land owner has specific rights over land for which they hold title and is entitled to
deny access to their land as this is private property. There would not be any change in land
tenure.
Should Rhino Oil and Gas wish to access any property for the undertaking of future
exploration (subject to obtaining the required approvals), they could not do so without
engaging with the land owner to agree on the terms of access. Rhino Oil and Gas’s stated
approach is to negotiate with willing participants (Section Error! Reference source not
found.).
Effect on local economy

programme. Thus the project would not generally result in actions which disturb or disrupt the
local environment (other than perhaps noise, see above) or the activities which drive the
local economies. It also is not anticipated that the proposed exploration work programme
would have any positive impact on the regional economy. The majority of the services
required are specialised and would likely be undertaken by foreign contractors. There would
be a limited opportunity for local business to supply goods and services to the survey
contractors. Overall the project would not result in significant changes to the economy.
This issue does not require to be investigated further in the EIR. The importance and
sensitivity of the various agricultural and tourism economies are documented in Section
Error! Reference source not found..
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720.18034.00016
including them
Contribution to socio-economic development

Exploration is recognised as an economically high-risk activity that would not result in the
generation of income for the holder of such a right as no resources are extracted or
beneficiated. Thus in the exploration phase of such a project there is limited opportunity for
contributions to be made to economic and social development. The requirement for BBBEE
participation during exploration is specified in the Petroleum and Liquid Fuels Charter (not
the Mining Charter) and specifies that licences for exploration must make a 9% stake
available for buy-in by Historically Disadvantaged South Africans and contribute to the
"Upstream Training Trust" to fund skills development at various levels in the industry. Rhino
Oil and Gas would comply with all such requirements. This issue does not require to be
investigated further in the EIR.
Rehabilitation and liability for damages

As no physical, on the ground activities are included in the proposed exploration work
programme the project would not cause disturbances on the ground that would require
rehabilitation.
However, as required by Section 24P of NEMA, Rhino Oil and Gas would have to provide a
quantum for financial provision for rehabilitation, closure and on-going post decommissioning
management of negative environmental impacts (Regulations Pertaining to the Financial
Provision for Prospecting, Exploration, Mining or Production Operations, GN 1147). This
quantum must be made available by Rhino Oil and Gas to PASA as security for the
completion of rehabilitation should Rhino Oil and Gas fail to do so (Section Error! Reference
source not found.).
xx
7. IMPACT ASSESSMENT CONCLUSIONS
Only those potential impacts associated with remote exploration techniques have been assessed. The potential
impacts of core hole drilling and seismic surveys have not been assessed in this EIA as they do not form part of
the proposed ‘early-phase exploration’ work for which Rhino Oil and Gas are seeking environmental
authorisation.
7.1 Aerial FTG Surveys
Biophysical Impacts
The flying of a light aircraft to undertake an FTG survey is not anticipated to have any impact of significance on
the biophysical environment. Overpass flights of light aircraft are not uncommon over the region, even
protected areas. Other than a momentary flight response, it is estimated that the impact of noise on wildlife
would be insignificant.
Cultural/ Heritage Impacts
The flying of a light aircraft to undertake an FTG survey is not anticipated to have any impact of significance on
the cultural or heritage environment. Any noise impact would be as described below.
Socio-economic impacts: Noise Impacts
The noise generated by a light aircraft flying at a low altitude (approximately 100 m) could be a nuisance to or
result in the localised disturbance of a receptor. No health impacts (such as loss of hearing or increased blood
pressure) are anticipated based on the proposed FTG survey.
Based on a light aircraft (e.g. Cessna) flying at a low altitude of + 80 m, it is estimated that the maximum noise
level would not exceed 70 dBA outdoors and 60 dBA indoors. The latter is similar to conversational speech
measured at 1 m. At any one location the duration of the overflight would be tens of seconds. Indoors the
noise generated would probably not be noticed. Although the survey would cover wide areas, the extent of the
impact is localised for each receptor. Where there are no receptors there would be no impact. Thus,
depending on the selected flight path, an impact is possible.
Although aircraft noise would increase noise levels in what are largely quiet rural and agricultural areas, only a
slight disturbance or nuisance is anticipated (i.e. low intensity). Based on these considerations and the fact
that disturbances from light aircraft are not uncommon with a multitude of light aircraft working in and
traversing the region, the significance of this impact is considered to be very low before and after mitigation.
All planned survey flights should comply with local civil aviation rules. Flight paths must be pre-planned to
avoid special nature reserves, national parks and world heritage sites. Where this is not possible, an altitude of
2 500 feet (762 m) should be maintained (as per Section 47(1) of NEMPAA), unless permission is obtained from
the management authority or in an emergency. Where flights are planned to occur over game farms,
landowners should be notified of the survey programme prior to survey commencement.
xxi
7.2 Local limitations
The flying of a light aircraft to undertake an FTG survey would be unlikely to pose significant risk to the
environment. As a result there are relatively few constraints arising from legislation, regulation, guidelines and
best practice that would apply. The FTG survey would have no effect on water use or availability and could
therefore be undertaken without regard for water related constraints and restrictions.
At the time of completion of the EIR there was no indication of any change to the public or landowner position
with regards the application. The majority opinion is opposed to exploration for unconventional gas or
petroleum resources in the ER application area.
7.3 Granting of a Right
There is strong public opinion and I&APs refer to a significant body of evidence from around the world (not
least that fracking is banned in a growing number of countries and territories), that late phase exploration and
production of unconventional gas has huge risks to society and the environment. Such risks are borne by the
landowners and local communities who do not participate in the economic benefits that accrue to the right
holder and government. While there may be a consumer driven need for hydrocarbon extraction, the risks and
costs to society and the environment far outweigh the benefits. The extraction of unconventional
hydrocarbons is therefore not wanted in the ER application area.
Even though early-phase exploration may have impacts of low significance, the public have raised concern that
the granting of an exploration right would set in motion the development of a petroleum extraction project
that would be extremely difficult to stop. Because the future process has unknown outcome and risk, this
exploration right should not be approved.
The MPRDA provides that the State, as custodian of mineral and petroleum resources in South Africa, may
issue mineral and petroleum rights to applicants. Such rights must enable the sustainable development of
South Africa’s mineral and petroleum resources within a framework of national environmental policy, while
promoting economic and social development.
The granting of a right has no effect on the presence or absence of a resource; merely on who has the
entitlement to that mineral (i.e. minerals and petroleum exist regardless of the holder). A mineral and/or
petroleum right is only part of the regulatory approval required by a holder and in isolation does not enable the
holder to access the subject mineral. A holder must also have obtained environmental authorisation in terms of
Chapter 5 of the NEMA. Furthermore, a mineral and/or petroleum right and environmental authorisation do
not provide blanket approval for any conceived operation, but are both particular to the specific activities that
the holder has detailed in an application. The holder is also required to negotiate access with the land owner
and determine payment of compensation for loss or damages due to the specific activities. It is therefore
presented that the grant of a right over a parcel of land does not provide the holder carte blanche with respect
to the mineral and land in question. There is thus not necessarily a direct conflict with the land owners’ right to
use the surface. It would in fact be the undertaking of specified activities that could result in an impact on or
conflict between the land owner and the mineral and/or petroleum rights holder (if any). Such specified
activities would have been subject to approval through an environmental authorisation process. In the case of
xxii
this application by Rhino Oil and Gas, only remote sensing activities are included which have been shown not to
have any impact on the environment.
Any further exploration activity (beyond what may be approved in an environmental authorisation) would have
to be subject to the requisite environmental assessment and authorisation process under the NEMA and an
amendment to the ER in terms of the MPRDA. Such processes assess the merits of an application in light of the
principles of sustainable development as set out in Section 2 of NEMA. An environmental authorisation process
would not grant approval for the undertaking of activities resulting in impacts of unacceptable significance.
Each of the petroleum right approval sections in the MPRDA (80 and 84) set out that such rights may only be
granted if the activity will not result in unacceptable pollution, ecological degradation or damage to the
environment. Thus a decision to grant the current ER application by Rhino Oil and Gas (for remote sensing
activities only) does not presuppose that future applications for further exploration or production would be
approved.
It is also noted that the specified activities associated with a mineral and/or petroleum right may also be
subject to approval requirements under other legislation. The need for such authorisations (e.g. water use
licence, land use planning permission etc.) provides further permitting frameworks for impact assessment and
management.
7.4 No-go Alternative
The potential positive implications of not going ahead with the proposed exploration are:
• no impacts resulting from the FTG survey within the exploration right area;
• no (reduced) chance of any risks arising from further exploration or future production; and
• allayment of the current majority opposition from the public.
The potential negative implications of not going ahead with the proposed exploration are as follows:
• South Africa would lose the opportunity to further understand and potentially establish the extent of
indigenous oil or gas reserves in the Free State and KwaZulu-Natal;
• Lost economic opportunities related to sunken costs (i.e. costs already incurred) of initial desktop
investigations in the proposed exploration licence area;
• If economic oil and gas reserves do exist and are not developed, South Africa / Rhino Oil and Gas would
lose the opportunity to maximise the use of its own indigenous oil and gas reserves; and
• Other sources of energy would need to be identified and developed in order to meet the growing demand
in South Africa.
The great majority of I&APs that have participated in the EIA process have expressed their opposition to all
forms of oil and gas exploration in the Free State and KwaZulu-Natal and to this application in particular. Thus
xxiii
the “no-go” alternative would alleviate much of the anxiety and concerns related to potential future shale gas
development should reserves be identified for further exploration and/or future production.
Given the wide array of unknown facts regarding the potential for economic growth and the potential for
environmental impacts arising from unconventional gas production, as well as the unknown facts of the future
energy mix in the absence of gas, the overall impact associated with the “no-go” alternative is considered to be
of unknown significance.
7.5 Cumulative Impact
Given that the assessed impacts of the aerial FTG surveys and other remote sensing methods are considered be
of very low significance, there is no chance of cumulative impacts of any significance. Given that there are
many separate applications for exploration rights in the eastern regions of South Africa, cognisance will need to
be given to potential cumulative impacts if these applications proceed past early-phase exploration.
I&APs continue to request that the impacts of potential further exploration and future production be assessed
in this EIA order for them to have a complete understanding of the risk of the eventual oil or gas production
project (given that the purpose of exploration is to get to extraction). Rhino Oil and Gas maintains that it
cannot yet, without conducting the early-phase exploration work, know what the future options entail.
Without information on the scope, extent, duration and location of future activities proposed by an applicant it
is not possible for an EAP to undertake a reliable assessment of future impacts.
8. CONCLUSIONS AND RECOMMENDATIONS

SLR, as the environmental assessment practitioner appointed by Rhino Oil and Gas, has undertaken a Scoping
and EIA process in terms of the EIA Regulations, 2014 to inform an authority decision on the application made
for environmental authorisation under the NEMA. The current ER application only includes remote exploration
techniques, restricted to analysis of existing data and an aerial full tensor gradiometry gravity survey. If the
application is approved Rhino Oil and Gas would be in a position to conduct the remote exploration techniques.
Thereafter, should Rhino Oil and Gas propose to conduct ground-based exploration activities (core boreholes
and seismic surveys) this would necessitate a further application to PASA and a separate environmental
assessment and authorisation process in terms of NEMA.
The key finding of the EIA is of a contrast between very low significance impacts resulting from an exploration
work programme which is limited to desktop and remote sensing methods and extremely strong public
opposition to all forms of exploration for onshore unconventional gas.
The assessment concluded that the impacts of proposed exploration activities would be extremely limited in
extent, widely dispersed, of very short duration and very low intensity and would there have very low
significance. On the simple merits of the application there is therefore no environmental reason why the
exploration activities should not be approved. All of the ER application area would be suitable for the
undertaking of the remote sensing exploration methods as proposed. It is noted however that the proposed
activities are likely to be the first in a series of exploration stages comprising activities that would likely
increase in impact significance (if exploration was successful and the project proceeded to the following
xxiv
stages). The intensity and duration of such impacts would likely increase with each subsequent phase, but
would likely become confined to increasingly limited target areas.
The public opposition to the exploration right application has been strongly voiced and have been received
almost unanimously from all the sectors of society that have participated in the EIA. It is evident however that
the majority of the opposition is not directly against the merits of exploration activities as proposed, but rather
against the anticipated outcome and risks that, if exploration is successful, could result from production. The
public perception is interpreted to be that issuing of an exploration right could lead to successful exploration;
that would ultimately result in an application for production with the potential use of hydraulic fracturing. It is
further perceived that this could lead to widespread impacts on water and land causing devastation to local
livelihoods. The perception is informed by the widely publicised, purported negative effects of hydraulic
fracturing and the decisions taken by many governing bodies from around the world to suspend such activities.
The related concern is that once an exploration right is granted, it will be nearly impossible to stop the process
later, even if the environmental risks to local receptors outweigh the benefits. This is seen to arise from a
mistrust and or misunderstanding of the governance framework that is in place to regulate petroleum
exploration and production; concern as to whether government can balance the needs and interests of local
people against such development, and an expectation that enforcement of compliance with environmental
management obligations would be poor. For these reasons the public approach is to ‘close the door on
exploration before it opens’, thereby preventing any future risk, or potential benefit, from resulting.
It is the opinion of SLR in terms of the sustainability criteria described above and the nature and extent of the
proposed early-phase exploration programme (remote sensing only), that the generally very low significance of
the impacts, with the implementation of the proposed mitigation measures, should support a positive decision
being made by the Minister of Mineral Resources (or delegated authority) in this regard. Since the proposed
exploration activities are associated with Rhino Oil and Gas’s initial three-year exploration work programme,
the applicant requests that that Environmental Authorisation (should it be granted) be issued and remain valid
for a period of three years or more.
The estimated cost for management and / or rehabilitation of potential negative environmental impacts that
might be incurred during the proposed remote sensing exploration activities is nil.
In spite of the recommendation for a positive environmental authorisation of the current exploration work
programme, the following key points with likely applicability to potential future applications and activities are
noted by the EAP:
• parts of the exploration right application area have environmental attributes that may not be compatible
with development (including ground-based exploration or production activities);
• restrictions imposed by current regulations would render parts of the exploration right application area
unavailable to certain ground-based exploration and production activities; and
• I&APs in general are strongly opposed to all forms of onshore exploration and extraction of unconventional
oil and gas and this is unlikely to change for future applications or operations.
The applicant and authority have been informed this and advised that current planning and decision-making
should as much as possible take cognizance of the above.
xxv
9. ENVIRONMENTAL MANAGEMENT PROGROGRAMME
The EMPR, once approved by the competent authority, is a legal document and Rhino Oil and Gas is overall
accountable and responsible for the implementation thereof. The EMPR is set out to provide environmental
management i) objectives, ii) outcomes and iii) actions for the planning and design, undertaking of exploration;
and rehabilitation and post closure phases.
xxvi

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ENVIRONMENTAL IMPACT

ASSESSMENT REPORT FOR AN

Various farms, Free State & KwaZulu-Natal

Date: August 2020

SLR Project No: 720.18034.00016

1.1 Opportunity to Comment

SLR Consulting (South Africa) (Pty) Ltd

PO Box 1596, Cramerview 2060

Tel: (011) 467 0945

1.2 Project Background

1.3 Summary of Authorisation Requirements

2.2 EIA Phase

• identify the relevant policies and legislation relevant to the activity;

• identify feasible alternatives related to the project proposal;

• provide a reasonable opportunity for I&APs to be involved in the EIA process;

• present appropriate mitigation or optimisation measures to minimise potential impacts or enhance

• Consequence is a function of intensity, spatial extent and duration;

• Significance is a result of the consequence and probability.

3. NEED AND DESIRABILITY

Use of Natural Gas

National Policy and Planning Context

• White Paper on the Renewable Energy Policy (2003)

• National Gas Infrastructure Plan (2005)

• New Growth Path (2011)

• National Development Plan (2012)

• Draft Integrated Energy Plan (2013)

• Gas Utilisation Master Plan (GUMP)

• Paris Agreement, United Nations Framework Convention on Climate Change

• National Climate Change Response White Paper

• Integrated Resource Plan (2019)

4.1 The applicant

4.2 Exploration Right application area

4.3 Description of the Exploration Work Programme

- Data Migration and lead identification

4.4 Summary of project alternatives

4.5 Related Applications

ER Ref Known as/Location Status

291 ER Rhino O&G: KwaZulu-Natal ER relinquished by holder

294 ER Rhino O&G: Free State ER granted

295 ER Rhino O&G: Eastern Cape ER granted

ER Ref Known as/Location Status

317 ER Rhino O&G: Northern KZN EA abandoned by applicant

318 ER Rhino O&G: Northern Free State ER granted

350 ER Rhino O&G: Free State & KZN This application

4.6 Further exploration or future production

5. DESCRIPTION OF THE AFFECTED ENVIRONMENT

6. KEY PROJECT ISSUES

1. Opposition to the project

Restrictions and sensitivities will prevent exploration/production

proposed for this Exploration Right application.

2. Impacts on Physical Aspects

These issues will not be investigated further in the EIR.

Effect on Surface Water

Effect on air quality

Effect on geology and seismicity

3. Impacts on Biological Aspects

Effect on wetland habitats

Effect on faunal habitats

4. Impacts on Socio-Economic Aspects

This issue does not require to be investigated further in the EIR.

Effects on roads and other infrastructure

This issue does not require to be investigated further in the EIR.

Effect on existing land uses