EAPASA Unit 19 Oxford Office Park 3 Bauhinia Street Environmental Assessment Highveld Techno Park Practitioners Association Centurion of South Africa 0157 Advancig evict semen prac n Suh Aico Email: registrar@eapasa.org / Website: www.eapasa.org EAPASA Malpractice Policy ANNEXURE A: EAPASA FORM FOR LODGING A COMPLAINT AGAINST A REGISTERED EAP ANNEXURE B: AFFIDAVIT TEMPLATE Version 7, 17 September 2020 Boerd MemberANNEXURE A: EAPASA FORM FOR LODGING A COMPLAINT AGAINST A REGISTERED EAP. NAME AND SURNAME OF COMPLAINANT fariette Liefferink on behalf of the Federation for a Sustainable Environment TELEPHONE NUMBER OF COMPLAINANT 27 11 4893 CELL NUMBER OF COMPLAINANT 27 73 231 4893, EMAIL ADDRESS OF COMPLAINANT ariette@pea.org.za NAME OF REGISTERED OR CANDIDATE EAP P ‘Nainyanni (Kennet) Singo REGISTRATION NUMBER OF EAP OR CANDIDATE EAP 021 « Ref 2019/825 APPLICABLE) DATE OF APPOINTMENT OF EAP BY COMPLAINANT (WHERE [ UR HAS A MEETING BEEN CONVENED WITH THE EAP? NATURE OF COMPLAINT Potential DATE DISPUTE AROSE por7/a018 "ARE YOU ACTIONING ON YOUR BEHALF OF OR FOR ANOTHER? in behalf of the public and the environment, and the Federation fora ble Environment EAPASA Malpractice Complaint Form, Version 7, 17 September 20200202 sequiaydas £1 “Z uoIsian “yaepyyy eondeIdIeW YSvaVa Bulg ye ssauisng ino paweo AlJeulpio OyM JeuONNDedY 1UALISSeSSYy feILELUUOWNUG pue oeUl YNpe LE OBuls Jo Burs (YsuUey) IUUEAUIPN 4010 S1 (AVS OU, SP 0} paLieyes JeYeUIELEY) pebpo} S| 1 ‘esinuatyjo peyiceds ssejun "josH00 pue en ylog ale Pue eBpe;moUry jeuOsed Au UNAM Ie} PEUIE}UCD UIBIEY SIUEIUOO SUL, 1202 ‘uoypueg skemino, ‘saisepeoig ‘a}eIsa spue|peog ‘yi 18 sseu'sng jno Aueojepise! | pue |USUIUOIAU BIAeUIeISNS & Jo} UOeJepey By} Jo OO PUE B[eWLA} YNPe UE ‘sOREU SI UI WUeUIE|AUICS Oty WE | Bumoyjo} ay} Yeo Jepun aue;ap Aqavey op (@UeU ANOA) yUVEYET] eHEUeWY ‘peub/s:opuN OY) ‘| ALV Id WAL LIAVGIS4 “ SYNXANNYDetails of other persons involved in this matter are (e.g. Developer, Project Manager, Specialist Consultants, and their level of involvement): ‘Specialist Consultants | am dissatisfied with (please outline clearly what you are dissatisfied with, provide specific information, including dates, work agreed on, the clauses of the Code of Ethical Conduct and Praciice which have been allegedly transgressed): 1. DrNdinyanni (Kenneth) Singo was an exploration geologist for Anglo American. He approached the Federation for a Sustainable Environment (FSE) in 2015 to assist him with his research for a PhD in mine closure and rehabilitation. It was confirmed by Dr Patrick Sithole, the Registrar of EAPSA on the 25% of March, 2021 that Dr Singo of Singo Consulting was registered as an EAP on EAPSA’S Register. ALKEMU PRECISION 2. In 2018 Dr Kenneth Singo of Singo Consulting was appointed the EAP for a prospecting Application by Alkemu Precision. ‘The Application was for the prospecting of gold, diamonds, iron ore and manganese. The prospecting application was within the Bovenste Oog (the Source of the Mooi River) and the Klerskraal Dam within the North West Province. The Bovenste Oog and the Klerkskraal Dam provides water to the entire Potchefstroom Area. The prospecting application furthermore falls with a freshwater ecosystem priority area and two of the farms are listed in the Protecied Areas Register. 3. The prospecting application was authorised by the DMRE. The FSE and Kiepersol Poultry Farm appealed the EA. (Please see first attached document.) 4. Kiepersol Poultry Farm appointed a registered EA, Danie Neumann of ECOTECHNIK Environmental Consultants (Pty) Ltd. ( M.Sc., B.Th. (Hons), ‘Med.Sci. (HPCSA), Pr.Sci.Nat. (SACNASP), Registered EAP (EAPASA), MIoDSA, EAPASA Board Member, IAIAsa NEC Member) to peer review the BAR/EMPR. (Please see second attached document.) Some of the findings are listed hereunder: a. A copy of the EA was provided to the Appellant 2 days before the Appeal Date b._ ‘The GPS coordinates refer to a location near Sapa in the Eastern Cape Province. ©. The Biodiversity Assessment Report stated that desktop research was conducted and used to compile a checklist for filed assessment/survey. No evidence was found that such desktop research was conducted. 4. The Biodiversity Assessment Report stated that vegetation, faunal or animal assessment were done visually. ‘There was no evidence that the assessment was conducted and there was no list of species found on site during the ostensible surveys. ©. The Biodiversity Assessment Report stated that the study site falls within “other natural Areas” and "no natural remaining” categories. ECOTECHNIK found that this statement is totally wrong. Most of the site is categorised as critical biodiversity areas or ecological sensitive areas. f. ECOTECHNIK found that the biodiversity assessment report is fatally flawed and should be distegarded as a specialist study. g. ECOTECHNIK found that the geological section of the EIA/EMPR provides an in depth discussion on the geology of the Bushveld Complex but the Bushveld Complex has no relevance to the Application since the area falls within a dolomitic area. EAPASA Malpractice Affidavit, Version 7, 17 September 2020h, ECOTECHNIK concluded that there are “blatant omissions and i activity. This is not what is expected from a professional EAP.” i. The public comment period was advertised from 21 November to 24 December 2018. In terms of Government Gazette 40772 15 December — 5 January must be excluded. 5. Notwithstanding the abovementioned information, the Minister of Environment, Forestry and Fisheries di Poultry Farm’s appeals on all grounds except one, namely the financial provisioning. 6. Kiepersol Poultry Farm has taken the Minister’s decision on review. The outcome is awaited, accuracies” and that “the geological section is simply a copy and paste sed the grounds of the F sand Kiepersol MANZOWANDLE INVESTMENTS 7. Dr Kenneth Singo of Singo Consulting was appointed as the EAP for a mining right application by Manzowandle Investments in Barberton in 2019. (Please see fourth attached document.) 8, It was found that Singo Consulting used identical wording in the Agricultural Assessment Report for the proposed Coal Mine on the border of the Kruger Park as was done by the Biodiversity Company in 2017 for the Viakvarkfontein Coal Mine expansion near Delmas. The Viekvarkfontein Mine near Delmas/Oogies is over 230 km away from Barberton and in an entirely different geographical and climatic zone. This raised the issue of potential plagiarism. 9. It was furthermore found that Singo Consulting copied and pasted the EIA and EMPR for the Lefa Colliery in Sasolburg, dated I August 2017 even though the EIAs are of completely different areas, geography, biodiversity, population profiles, etc. The conclusions and remedial actions are also identicial. The EIA/EMPR was conducted by Amo van der Berg of REC Services (Pty) Ltd. 10. It was found that at least 160 out of 237 pages of text (67.5%) are direct copies from other EAPs’ work. (Please see third attached document.) LEGARE MINING 11. Dr Kenneth Singo of Singo Consulting was appointed as the EAP for a prospecting right application at Rondavelskraal in the North West Province, (Please see fifth attached document.) 12, According to the BID the Draft BAR/EMPR will be available from 23 March 2021. At the time of writing registered IAPs have not received the documents. 13. The BID states that Rondavelskraal 290P falls within two different magisterial districts namely Madikwe and Mankwe. Neither of which is correct. 14, Reference is made in the BID to the MPRDA, 38 of 1998. It is incorrect and should read MPRDA, 28 of 2002. 15. The BID refers toa “mining application process being a success or declined” under the heading “Basic and Environmental Impact Assessment Process”. This has clearly been taken from a mining right application document and copied and pasted in this application, which is for prospecting and not mining. 16. The BID refers to a scoping phase under the heading “Public Participation Process”. This has clearly been taken from a mining right application document and copied and paste in this application for a prospecting right. EAPASA Malpractice Affidavit, Version 7, 17 September 2020have attached the following documents: 6.1 A copy of the form (appointment of EAP, if applicable to complaint) YES ("| 6.2 Any documents and or records (including electronic data relating to the work such as reports, environmental standards and specifications, calculations, contractual documents, photographs or the like) which will serve to ilustrate or substantiate any of the complaint, as listed below: vy &) @ a a Appeal Form-OMR NW30-5-1-1-3.2-14 SummarySINGO ID MINING Landowner EAPSADRRICHARD _FSE EAPSADR Ref NW 3051121246 12466)EM -KIEPERSC Plagiarismadf RIGHT pdf MANDZO —Notifiction.pd# HILL RESPONSE.doo RICHARD HILL CORR | know and understand the contents of this declaration | have no objection to taking the prescribed oath, | consider the prescribed oath as binding on my conscience. DEPONENT It is hereby certified that the aforesaid declaration was signed and swom in my presence on this the 12" day of April2021_at Douglasdale, the deponent having confirmed and acknowledged: a) That the deponent knows and understands the contents ofthis dectaration; b) That the deponent has no objection to taking the prescribed oath; and ©) That the deponent considers the prescribed oath as binding on the deponent'’s conscience. 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