PROPOSED 132 kv TRANSMISSION LINE BETWEEN LYDENBURG & MERENSKY SUBSTATIONS, MPUMULANGA & LIMPOPO PROVINCES.

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1 1 Palaeontological heritage assessment: desktop study PROPOSED 132 kv TRANSMISSION LINE BETWEEN LYDENBURG & MERENSKY SUBSTATIONS, MPUMULANGA & LIMPOPO PROVINCES. John E. Almond PhD (Cantab.), PO Box Mill Street, Cape Town 8010, RSA September 2013 EXECUTIVE SUMMARY Eskom are proposing to construct a new 132 kv transmission line of approximately 42 to 59 km length between the existing Lydenburg Substation near Lydenburg, Mpumalanga Province, to the existing Merensky substation near Steelpoort, Limpopo Province. In addition 1X132 kv feeder bays are to be constructed at Merensky MTS and Lydenburg Substation. The proposed new Lydenburg Merensky 132 kv Sub-transmission line and associated substation developments are situated in parts of the Mpumulanga Highlands region that are underlain by (1) poorly fossiliferous sedimentary rocks of the Precambrian Pretoria Group (Silverton and Magaliesberg Formations, c. 2 billion years old), (2) unfossiliferous igneous rocks of the slightly younger Bushveld Complex, as well as by (2) superficial sediments (alluvium, scree, soils), mostly of Quaternary to Recent age. All of the bedrock and superficial sediment units within the Lydenburg Merensky Sub-transmission line study area are assessed as of negligible to low palaeontological sensitivity. Route Option 1 has the longest sector overlying the Silverton Formation outcrop area, along the western side of the Spekboomrivier Valley, where there is a (low) possibility of stromatolitic limestone horizons. There is likewise a slight possibility of Late Caenozoic mammalian remains or other fossils being encountered within superficial sediments on the northern (SE-NW) sector through to Merensky Substation. The impact significance of this route option as far as palaeontological heritage resources are concerned is rated as LOW. Route Option 2 has the longest sector overlying the Magaliesberg Formation outcrop area, on either side of the Watervalsrivier valley, where there is a possibility of microbial mat features being encountered in association with shallow water to littoral sandy sediments. There is a small possibility of stromatolitic carbonates in the southeast, near Lydenburg, and of Late Caenozoic mammalian remains or other fossils in the northernmost (SE-NW) sector

2 2 through Olifantspoortjie. The impact significance of this route option as far as palaeontological heritage resources are concerned is also rated as LOW. Route Option 3 has the longest sector overlying Late Caenozoic superficial sediments where there is a slight possibility of Late Caenozoic mammalian remains or other fossils being encountered. There is likewise a small possibility of stromatolitic carbonates in the southeast, near Lydenburg (Silverton Formation), and of microbial mat features within Magiesberg Formation quartzites on higher ground flanking the eastern side of the Watervalsrivier Valley. The impact significance of this route option as far as palaeontological heritage resources are concerned is also rated as LOW. In terms of anticipated impacts on fossil heritage resources at or beneath the ground surface there is no significant difference between sub-submissionline Route Options 1, 2 and 3. The impact significance of all three route options is rated as LOW and there is no preference on palaeontological grounds for any particular route option. The No-go option (no construction of transmission line or substation upgrade) would have a neutral impact on fossil heritage. Given the low palaeontological sensitivity of the rock units represented within the study area, and the consequent LOW impact significance of all three transmission line route options under consideration, no further specialist palaeontological heritage studies or mitigation are recommended for this project, pending the discovery of substantial new fossil material during construction. The responsible Environmental Control Officer (ECO) should monitor all substantial (> 1 m deep) excavations for fossil material. In the case of any significant fossil finds during construction (e.g. vertebrate teeth, bones, burrows, petrified wood, shells, stromatolites), these should be safeguarded - preferably in situ - and reported by the ECO as soon as possible to SAHRA (Contact details: Mrs Colette Scheermeyer, P.O. Box 4637, Cape Town Tel: cscheermeyer@sahra.org.za), so that appropriate mitigation (i.e. recording, sampling or collection) by a palaeontological specialist can be considered and implemented. These recommendations should be incorporated into the Environmental Management Plan (EMP) for this development. 1. INTRODUCTION AND BRIEF Eskom are proposing to construct a new 132 kv Sub-transmission line of approximately 42 to 59 km length between the existing Lydenburg Substation situated adjacent to the R37 on the outskirts of Lydenburg, Mpumalanga Province, to the existing Merensky substation situated adjacent to the R555 near Steelpoort, Limpopo Province (Fig. 1). In addition 1X132 kv feeder bays are to be constructed at Merensky MTS and Lydenburg Substation. A 100 m wide corridor is being assessed for the proposed Sub-transmission line project. The three alternative routes under consideration for the 132 kv Sub-transmission line (Figs. 1 & 2) are described as follows in the basic information documentation provided: Line Option 1: This is the most northerly of the line options from the Lydenburg substation and heads in a northeasterly direction and follows an existing powerline. The proposed new line bisects the Marambana River at approximately 1 km from the substation. The proposed line bisects the Jood Se Loop at 3.1 km. The proposed line bisects non-perennial drainage lines as well as running within a river valley of a tributary of the Spekboom River consisting of Lydenburg Thornveld and Ohrigstad Mountain Bushveld. No formal access roads bisect the mountainous areas as well as the river valley. Informal

3 3 (4x4) tracks occur within the hillslopes and summit of the mountains. The alignment follows the single alternative towards the Merensky substation to the west. Line Option 2 From the Lydenburg substation this alternative is proposed for the alternatives 2 and 3 and runs to the north of the substation for 300 m and then deviates towards the north-west for 3.99 km. It bisects the Manamfana River and tributary as well as Jood se Loop.The alignment then runs in a north-westerly direction for approximately 3.35 km. Several existing informal tracks occur within the slopes and summits of the mountains. The alignment only bisects small non-perennial drainage lines. The alternative alignment 1 heads towards the west of alignment 3. Line Option 3: This option follows alternative 2 from the Lydenburg substation for approximately 18 km and then heads in a northerly direction along the Waterval River. Large areas adjacent to the proposed alignment have been historically transformed into centre-pivot irrigated lands and citrus orchards. The alignment bisects several seasonal tributaries of the Waterval River. The remnant riparian zones are however extremely narrow (<150 m) and can easily be spanned by towers. Large areas of the riparian zones have already been cleared or are heavily invaded with alien invasive vegetation. This is the preferred option from an ecological perspective although the alignment towards the Merensky substation should be re-aligned approximately 300 m to the west of the Sterkfontein River towards the Lydenburg-Steelpoort road and follow existing tracks, agricultural and old mining areas. This will limit the vegetation clearance within the heavily wooded mid slopes on the Farm Olifantspoortjie where the existing and proposed alignments bisect. The present desktop palaeontological heritage assessment was commissioned as part of the Basic Assessment for the transmission line development by Royal HaskoningDHV (Contact details: 1 st Floor Canon Building, Quenera Office Park, Beacon Bay, 5241, South Africa. Tel: Melissa.Naidoo@rhdhv.com). This desktop palaeontological heritage specialist report provides a brief comparative assessment of the observed or inferred palaeontological heritage along the various transmission line routes under consideration for the Lydenburg Merensky transmission line project with recommendations for further specialist palaeontological studies where these are considered necessary. This desktop study forms part of a broad-based heritage assessment for the project which falls under Sections 35 and 38 (Heritage Resources Management) of the South African Heritage Resources Act (Act No. 25 of 1999). The approach to this palaeontological heritage study is briefly as follows. Fossil bearing rock units occurring beneath the various Sub-transmission line route options are determined from geological maps and satellite images (Section 2, Figs. 2 & 4). Known fossil heritage from each rock unit is inventoried from scientific literature, previous assessments of the broader study region, and the author s field experience and palaeontological database (Section 3 and Table 1). Based on this data the palaeontological heritage sensitivity of the route options are assessed and compared, with recommendations for any further specialist studies (Sections 4 and 5).

4 4 Fig. 1. Outline map showing the various route options (Alternatives 1 to 3) under consideration for the proposed new 132 kv Sub-transmission line between Lydenburg Substation, Mpumalanga Province, and Merensky Substation, Limpopo Province (Image kindly provided by Royal HaskoningDHV).

5 5 Fig. 2. Google earth satellite image of the Lydenburg Merensky Sub-transmission line study area showing the three route options under consideration. These routes are: Route Option 1 (red), Route 2 (green) Route 3 (pink). N.B. North is towards the left.

6 Legislative context of this palaeontological study The proposed Lydenburg Merensky Sub-transmission line development traverses areas of Mpulanaga and Limpopo Provinces that are underlain by potentially fossil-rich sedimentary rocks of Precambrian, and younger, Tertiary or Quaternary age (Sections 2 and 3). The construction phase of the development may entail substantial surface clearance and excavations into the superficial sediment cover as well as locally into the underlying bedrock, notably for Sub-transmission line tower installations. In addition, substantial areas of bedrock may be sealed-in or sterilized by infrastructure such as lay-down areas, construction camps as well as new gravel roads. All these developments may adversely affect fossil heritage preserved at or beneath the surface of the ground within the study area by destroying, disturbing or permanently sealing-in fossils that are then no longer available for scientific research or other public good. Once constructed, the operational and decommissioning phases of the Sub-transmission line developments are unlikely to involve further adverse impacts on palaeontological heritage, however. The various categories of heritage resources recognised as part of the National Estate in Section 3 of the National Heritage Resources Act (1999) include, among others: geological sites of scientific or cultural importance; palaeontological sites; palaeontological objects and material, meteorites and rare geological specimens. According to Section 35 of the National Heritage Resources Act, dealing with archaeology, palaeontology and meteorites: (1) The protection of archaeological and palaeontological sites and material and meteorites is the responsibility of a provincial heritage resources authority. (2) All archaeological objects, palaeontological material and meteorites are the property of the State. (3) Any person who discovers archaeological or palaeontological objects or material or a meteorite in the course of development or agricultural activity must immediately report the find to the responsible heritage resources authority, or to the nearest local authority offices or museum, which must immediately notify such heritage resources authority. (4) No person may, without a permit issued by the responsible heritage resources authority (a) destroy, damage, excavate, alter, deface or otherwise disturb any archaeological or palaeontological site or any meteorite; (b) destroy, damage, excavate, remove from its original position, collect or own any archaeological or palaeontological material or object or any meteorite; (c) trade in, sell for private gain, export or attempt to export from the Republic any category of archaeological or palaeontological material or object, or any meteorite; or (d) bring onto or use at an archaeological or palaeontological site any excavation equipment or any equipment which assist in the detection or recovery of metals or archaeological and palaeontological material or objects, or use such equipment for the recovery of meteorites. (5) When the responsible heritage resources authority has reasonable cause to believe that any activity or development which will destroy, damage or alter any archaeological or palaeontological site is under way, and where no application for a permit has been submitted and no heritage resources management procedure in terms of section 38 has been followed, it may

7 7 (a) serve on the owner or occupier of the site or on the person undertaking such development an order for the development to cease immediately for such period as is specified in the order; (b) carry out an investigation for the purpose of obtaining information on whether or not an archaeological or palaeontological site exists and whether mitigation is necessary; (c) if mitigation is deemed by the heritage resources authority to be necessary, assist the person on whom the order has been served under paragraph (a) to apply for a permit as required in subsection (4); and (d) recover the costs of such investigation from the owner or occupier of the land on which it is believed an archaeological or palaeontological site is located or from the person proposing to undertake the development if no application for a permit is received within two weeks of the order being served. Minimum standards for the palaeontological component of heritage impact assessment reports have been developed by SAHRA (2013) Approach to the palaeontological heritage assessment In preparing a palaeontological desktop study the potentially fossiliferous rock units (groups, formations etc) represented within the study area are determined from geological maps (See Appendices 1-4). The known fossil heritage within each rock unit is inventoried from the published scientific literature, previous palaeontological impact studies in the same region, and the author s field experience (Consultation with professional colleagues as well as examination of institutional fossil collections may play a role here, or later following field assessment during the compilation of the final report). This data is then used to assess the palaeontological sensitivity of each rock unit to development (Table 1. Provisional tabulations of palaeontological sensitivity of all formations in Limpopo Province have already been compiled by J. Almond (unpublished data). The potential impact of the proposed development on local fossil heritage is then determined on the basis of (1) the palaeontological sensitivity of the rock units concerned and (2) the nature and scale of the development itself, most significantly the extent of fresh bedrock excavation envisaged. When rock units of moderate to high palaeontological sensitivity are present within the development footprint, a Phase 1 field assessment study by a professional palaeontologist is usually warranted to identify any palaeontological hotspots and make specific recommendations for any mitigation required before or during the construction phase of the development. On the basis of the desktop and Phase 1 field assessment studies, the likely impact of the proposed development on local fossil heritage and any need for specialist mitigation are then determined. Adverse palaeontological impacts normally occur during the construction rather than the operational or decommissioning phase. Phase 2 mitigation by a professional palaeontologist normally involving the recording and sampling of fossil material and associated geological information (e.g. sedimentological data) may be required (a) in the pre-construction phase where important fossils are already exposed at or near the land surface and / or (b) during the construction phase when fresh fossiliferous bedrock has been exposed by excavations. To carry out mitigation, the palaeontologist involved will need to apply for a palaeontological collection permit from the relevant heritage management authority, i.e. SAHRA for the Northern Cape and Free State Contact details: Mrs Colette Scheermeyer, P.O. Box 4637, Cape Town Tel: cscheermeyer@sahra.org.za). It should be emphasized that, providing appropriate mitigation is carried out, the majority of developments involving bedrock excavation can make a positive contribution to our understanding of local palaeontological heritage.

8 Assumptions & limitations The accuracy and reliability of palaeontological specialist studies as components of heritage impact assessments are generally limited by the following constraints: 1. Inadequate database for fossil heritage for much of the RSA, given the large size of the country and the small number of professional palaeontologists carrying out fieldwork here. Most development study areas have never been surveyed by a palaeontologist. 2. Variable accuracy of geological maps which underpin these desktop studies. For large areas of terrain these maps are largely based on aerial photographs alone, without ground-truthing. The maps generally depict only significant ( mappable ) bedrock units as well as major areas of superficial drift deposits (alluvium, colluvium) but for most regions give little or no idea of the level of bedrock outcrop, depth of superficial cover (soil etc), degree of bedrock weathering or levels of small-scale tectonic deformation, such as cleavage. All of these factors may have a major influence on the impact significance of a given development on fossil heritage and can only be reliably assessed in the field. 3. Inadequate sheet explanations for geological maps, with little or no attention paid to palaeontological issues in many cases, including poor locality information; 4. The extensive relevant palaeontological grey literature - in the form of unpublished university theses, impact studies and other reports (e.g. of commercial mining companies) - that is not readily available for desktop studies; 5. Absence of a comprehensive computerized database of fossil collections in major RSA institutions which can be consulted for impact studies. A Karoo fossil vertebrate database is now accessible for impact study work. In the case of palaeontological desktop studies without supporting Phase 1 field assessments these limitations may variously lead to either: (a) underestimation of the palaeontological significance of a given study area due to ignorance of significant recorded or unrecorded fossils preserved there, or (b) overestimation of the palaeontological sensitivity of a study area, for example when originally rich fossil assemblages inferred from geological maps have in fact been destroyed by tectonism or weathering, or are buried beneath a thick mantle of unfossiliferous drift (soil, alluvium etc). Since most areas of the RSA have not been studied palaeontologically, a palaeontological desktop study usually entails inferring the presence of buried fossil heritage within the study area from relevant fossil data collected from similar or the same rock units elsewhere, sometimes at localities far away. Where substantial exposures of bedrocks or potentially fossiliferous superficial sediments are present in the study area, the reliability of a palaeontological impact assessment may be significantly enhanced through field assessment by a professional palaeontologist. In the case of the Lydenburg Merensky Sub-transmission line study area a major limitation for fossil heritage studies is the paucity of previous specialist palaeontological studies in the region as a whole. Little palaeontological data is available in the relevant geological sheet map explanations.

9 Information sources The information used in this desktop study was based on the following: 1. A short project outline and maps provided by Royal HaskoningDHV; 2. A review of the relevant scientific literature, including published geological maps and accompanying sheet explanations. 3. The author s database on the formations concerned and their palaeontological heritage. 2. GEOLOGICAL OUTLINE OF THE STUDY AREA The Lydenburg Merensky 132 kv Sub-transmission line study area comprises mountainous, highly dissected terrain along the Mpumulanga Limpopo provincial border to the southwest of the Transvaal Drakensberg escarpment (Fig. 2). The mountain ranges and intervening valleys (e.g. Spekboomrivier, Watervalsrivier) run approximately north-south, conformable with the underlying bedrock geology. This region belongs to the Mpumalanga Highlands geomorphic province of Partridge et al. (2010), essentially a part of the Eastern Transvaal Basin featuring especially high elevation and relief. As described by these authors: The ridge-and-valley topography is imparted by lithological contrasts in the westward-dipping rocks of the Pretoria Group and Malmani dolomites, so that open strike valleys alternate with narrow gorges through quartzite ridges (ibid., p. 23). The geology of the Lydenburg Merensky study region is outlined on the northern edge of 1: sheet map 2530 Barberton / Nelspruit and the southern portion of sheet map 2430 Pilgrim s Rest (Fig. 4). Short explanations to these sheets have been published by Walraven (1989a, 1989b respectively). The region is underlain by (1) sedimentary bedrocks of the Transvaal Supergroup, and in particular the upper part of the Pretoria Group towards the eastern edge of the Transvaal Basin (Eriksson et al. 2006), as well as by (2) basic igneous intrusions of the Bushveld Complex (Cawthorne et al. 2006). These Precambrian bedrocks are dated at between 2 and 2.2 Ga (billion years old), well before the evolution of macroscopic multicellular organisms (cf McCarthy & Rubidge 2005). The ancient bedrocks are mantled with a range of much younger superficial deposits, notably various alluvial sediments in the river valleys as well as scree and residual soils on the valley slopes and mountainous areas. Most of these younger deposits are probably Quaternary to Recent in age. In the following section of the report the various rock units encountered along each of the transmission line route options are briefly reviewed. All major rock units mapped along the transmission line corridors between Lydenburg and Merensky Substations are listed in Table 1, together with a brief summary of their geology, age, known fossil heritage and inferred palaeontological sensitivity (data largely based on Almond, unpublished database). The location of these rock units within the stratigraphic column for South Africa is shown in Fig. 3. They include a wide range of sedimentary and igneous rocks ranging in age from Early Proterozoic (c. 2.2 Ga = billion years old) to Recent. The igneous rocks (e.g. lavas, dolerite and norite intrusions) are entirely unfossiliferous while a high proportion of the sedimentary rocks are of low palaeontological sensitivity (Section 3).

10 Transvaal Supergroup The 15 km-thick Transvaal Supergroup succession spans the time period 2.7 to 2.1 billion years ago (Late Archaean to Early Proterozoic) and comprises a wide range of relatively unmetamorphosed clastic and sedimentary as well as volcanic rocks overlying the Kaapvaal Craton. Important reviews of this key Precambrian rock succession of South Africa have been given by Tankard et al. (1982), Catuneanu and Eriksson (1999), Moore et al. (2001), and Eriksson et al. (1991, 1993, 2006). A key earlier work is the PhD thesis by Button (1973; see also Button 1986). The upper Transvaal Supergoup rocks in the study area to the northwest of Lydenburg belong to the Early Proterozoic Pretoria Group and lie towards the eastern edge of the Transvaal Basin where the Pretoria Group succession reaches its maximum thickness of c. 8 km (Eriksson 1999). This succession consists of a wide range of rock types, including mudrocks, quarztites and andesites with subordinate diamictites, conglomerates, carbonates and iron formation. In contrast to the underlying Chuniespoort Group, the sediments are predominantly clastic rather than chemical in nature. Depositional settings include alluvial fans and floodplains, delta complexes, coastal settings as well as deep basinal environments (Eriksson et al. 1991, 1993, 1995, 1999, 2006). The degree to which the depository was a closed, lacustrine system versus an epicontinental sea, or a combination of both, remains unresolved Silverton Formation In stratigraphic terms the Silverton Formation mudrocks are sandwiched between the sandstonedominated Daspoort (Vmd) and Magaliesberg (Vmg) Formations within the upper part of the Pretoria Group succession. The Silverton Formation of the Transvaal Basin is a heterolithic (i.e. lithologically varied), mudrock-dominated succession of moderate to deep basinal mudrocks that were deposited on an offshore shelf along the margins of the Kaapvaal Craton, mainly by suspension settling but with subordinate influence by gravity flow and storm processes (Eriksson et al. 2002, 2009). The mudrocks mainly comprise greenish laminated shale, but massive claystones also occur. Volcanic ash-rich intervals (tuffs, tuffaceous shales) are common, and there are minor beds of chert and carbonate, while sandstones become commoner in the upper part of the succession that was deposited under shallower, shoaling conditions. In the eastern portion of the Pretoria Group depositional basin the Silverton Formation reaches thicknesses of 1000 to 2230 m (Eriksson 1999). In the eastern part of the Transvaal Basin, including the study region, there is a prominent interval of volcanic rocks (pyroclastics including tuffs and agglomerates, as well as basaltic lavas) in the middle of the Silverton Formation succession that is known as the Machadodorp Member (Vsm). Various features of these volcanics (e.g. pillow lavas, water-lain tuffs) show that they were erupted beneath the sea. The volcanics are associated with minor carbonate rocks and vary from 50 to 500 m in thickness in the eastern outcrop area of the Pretoria Group (Button 1973, 1974, Eriksson 1999, Eriksson et al. 2006). As seen on the geological maps (Fig. 4), the Pretoria Group succession youngs broadly from the east to west in the study region. The proposed transmission line development transects the outcrop areas of the Machadodorp Member volcanics as well as the upper, mudrock-dominated part of the Silverton Formation known as the Lydenburg Shale Member (Vsl) (Visser 1989, Eriksson 1999). This shaly unit contains tuff units while carbonate sediments occur towards the top of the succession in the north-western part of the Pretoria Basin (along the RSA / Botswana border) but not in the deeperwater settings represented in the study area in the far east. The carbon isotope record of the Silverton Formation mudrocks and carbonates has been analysed by Bekker et al. (2008) who infer an age of between 2.22 and 2.06 Ga (billion years) and most probably around 2.15 Ga - for these rocks, a period notable for a major positive carbon isotope excursion that can be correlated globally

11 11 (Bekker et al. 2008). Organic carbon within the shales is attributed to microbial activity under euxinic (low oxygen) conditions (cf also Eriksson et al. 1989). Igneous intrusions (e.g. dolerites related to the Bushveld Complex) have thermally metamorphosed the Silverton rocks in some areas to form hornfels, calcsilicates and quarzites (locally mapped as a separate zone). The Silverton Formation reaches a thickness of 1-3 km in the eastern part of the Transvaal Basin and is recessive weathering, generating rolling hills and valley topography (Visser 1989). Levels of outcrop exposure are generally very low, but good exposures of green, finely laminated shales of the Lydenburg Member are reported in the Baberton / Nelspruit sheet area (Walraven 1989a). They contain occasional thin carbonate horizons that might be of stromatolitic origin according to this last author. The transgressive (high sea level) event that led to the deposition of the deep water Silverton mudrocks was followed by shallowing that culminated in the regressive (low sea level) fluvial and deltaic sandstones of the overlying Magaliesberg Formation (Vmg in Fig. **). The uppermost portion of the Lydenburg succession shows ripple cross-lamination, quartzitic interbeds and other sedimentary features indicating gradual shallowing of the depository Magaliesberg Formation The Magaliesburg Formation is a prominent-weathering, quartzite- dominated succession of up to 550 m thickness within the upper part of the Pretoria Group. The quartzites are pure white, coarse-graiend and contain laterally impersistent shaley horizons. The formation shows a gradational lower contact with the underlying Silverton Formation mudrocks via a heterolithic transition zone of interbedded shale and quartzites (locally mapped as a separate unit). The uppermost c. 50 m. consists of interbedded multi-hued shales, siltstones and quartzites (Walraven 1989a). A shallow marine setting for the Magaliesberg arenites was favoured by early workers, but more recent studies infer a regressive shoreline with deposition on braid-deltas and within high-energy tidal channels and flats (Eriksson 1999, Eriksson et al. 2006). This is supported by abundant evidence for sediment binding by microbial mats, as reflected in the distinctive preservation of ripples, wrinkle structures and distinctive trace-fossil like cracking patterns ( Manchuriophycus ) (Bosch & Eriksson 2008, Parizot et al. 2005) Bushveld Complex The Pretoria Group sediments in the northernmost portion of the study area, east of Merensky Substation, are intruded by basic intrusive igneous rocks of the Rustenberg Layered Suite, dated to 2.06 Ga (billion years), i.e. Late Vaalian / Early Proterozoic age (Walraven 1981, Ehlers & Du Toit 2002, Cawthorn et al. 2006, Baglow & Brandl 2009). This forms part of the Bushveld Complex which is the largest layered igneous complex in the world with the richest reserves of platinum group metals known (Eales 2001). The Bushveld rock units represented in the study area, viz. the Shelter Norite (Vsn) and overlying Croydon Subsuite (Vcr) consist entirely of basic to ultrabasic igneous rocks intruded at depth within the Earth s crust and are consequently entirely unfossiliferous (See Walraven 1989a, 1989b for details). They will therefore not be treated further here. Baking of the adjacent Pretoria Group sediments is expected to have destroyed all or most of their original fossil content.

12 Late Caenozoic superficial sediments A wide spectrum of superficial sediments of probable Quaternary to Recent age are grouped together as Q (pale yellow) on the geological maps of the study area (Fig. 4). These mainly comprise various sandy to gravelly alluvial sediments within the river valleys, scree deposits (colluvium) on mountain slopes as well as residual (downwasted) soils. Very little information about them is given in the relevant geological sheet explanations (Walraven 1989a, 1989b).

13 13 Fig. 3. Stratigraphic column for southern Africa showing the main rock units represented within the Lydenburg Merensky Sub-transmission line study area, Mpumulanga and Limpopo Provinces (thick vertical red lines) (Modified from Johnson et al. 2006). These include the Early Proterozoic Pretoria Group (sedimentary) and Bushveld Complex (igneous) as well as a range of Late Caenozoic superficial sediments (scree, alluvium etc).

14 14 Merensky Substation N 5 km Lydenburg Substation Fig. 4. Extracts from 1: geology sheets 2430 Pilgrim s Rest (above) and 2530 Barberton / Nelspruit (below) (Council for Geoscience, Pretoria) showing the three 132 kv Subtransmission line route options between Lydenburg and Merenksy Substations (Option 1 red; Option 2 green; Option 3 pink). The main rock units mapped along the various corridors are listed below.

15 15 1. Pretoria Group (TRANSVAAL SUPERGROUP) Silverton Formation: Machadodorp Member (Vsm, grey), Lydenburg Member (Vsl, reddishbrown) Magaliesberg Formation (Vm, lilac) 2. Rustenburg Layered Suite (BUSHVELD COMPLEX) Shelter Norite (Vsn, v. pale green) Croydon Subsuite (Vcr, blue-green) Dolerite intrusions (Vdi, green) 3. SUPERFICIAL SEDIMENTS alluvium, scree etc (Q, pale yellow) Route Option 1 The Lydenburg Substation as well as the southernmost sector of the Route Option 1 Subtransmission line corridor (red line on geological map, Fig. 4) are underlain by basinal mudrocks of the Silverton Formation that in this area are extensively intruded by dolerite dykes. Narrow outcrop areas of Machadodorp Member volcanics also crop out in the area north of Lydenburg. The long SSE-NNW trending eastern sector of Route 1 traverses the outcrop area of the Silverton Formation (Lydenburg Member) along the western side of the Spekboomrivier Valley. The northern, SE-NW sector through to Merensky Substation runs at low elevations and is almost entirely underlain by Late Caenozoic superficial sediments, with possible small stretches of Shelter Norite (Bushveld Complex basic igneous rocks) in Olifantspoortjie. The Merensky Substation is also underlain by superficial sediments. Route Option 2 The southern (SW-NE) and central (N-S) sectors of Route Option 2 (green line in Fig. 4) traverse rocky mountain terrain built by quartzitic rocks of the Magaliesberg Formation, with the exception of a short stretch on superficial sediment towards the south. The SE-NW northern sector through Olifantspoortjie likewise overlies superficial sediments, with possible short stretches of Bushveld complex igneous rocks, as described earlier for Option 1. Route Option 3 The south-eastern sector of Route Option 3 (pink line on Fig. 4) crosses Silverton Formation mudrocks and several NNE-SSW dolerite intrusions in the lower-lying ground. The higher ground flanking the eastern side of the Watervalsrivier Valley is capped by resistant-weathering quartzites and related heterolithic rocks of the Magaliesberg Formation. Silverton mudrocks reappear on the lowermost western slopes of the ridge. The N-S sector of Route Option 2 is underlain by Late Caenozoic sediments (alluvium, soils etc) of the Watervalsrivier.

16 16 3. OVERVIEW OF PALAEONTOLOGICAL HERITAGE WITHIN THE STUDY AREA Fossil biotas recorded from each of the main rock units mapped along the Lydenburg Merensky transmission line route options are briefly reviewed below and summarized in Table 1, where an indication of the palaeontological sensitivity of each rock unit is also given (Based on Almond, unpublished database). The quality of fossil preservation may be compromised in some areas due to near-surface weathering as well as baking by igneous intrusions. Note that the intrusive igneous rocks of the Rustenberg Layered Suite (Bushveld Complex) are completely unfossiliferous and therefore will not be considered further here Fossils in the Silverton Formation The carbon-rich mudrocks of the Silverton Formation are very likely to contain assemblages of organic-walled microfossils, while other microbial assemblages may be preserved within the chert horizons. However, the author is unaware of any formal studies on these microfossils. Domal stromatolites (microbial mounds) are recorded from shallow-water carbonates in the north-western sector of the Transvaal Basin (e.g. Bekker et al. 2008, p. 281) but not from the present study area in the eastern part of the basin. Walraven (1989a) does suggest, however, that thinly laminated carbonate facies within the Silverton Formation in the Barberton / Nelspruit sheet area may be or stromatolitic origin Fossils in the Magaliesberg Formation Abundant evidence for Early Proterozoic microbial mat structures, presumably generated in the photoc zone, has recently been reported within the shallow water arenites of the Magaliesberg Formation that crops out to the west of the study area (Parizot et al. 2005, Bosch & Eriksson 2008). Some of the sedimentary structures generated by the microbial mats have a complex structure that is very reminiscent of invertebrate burrows, and indeed they have occasionally been given fossil names elsewhere (e.g. Manchuriophycus / Rhysonetron) (See Eriksson et al. 2007, Seilacher 2007) Fossils within the Late Caenozoic superficial sediments The diverse superficial deposits within the South African interior have been comparatively neglected in palaeontological terms. However, sediments associated with ancient drainage systems, springs and pans in particular may occasionally contain important fossil biotas, notably the bones, teeth and horn cores of mammals as well as remains of reptiles like tortoises (e.g. Skead 1980, Klein 1984, Brink, J.S. 1987, Bousman et al. 1988, Bender & Brink 1992, Brink et al. 1995, MacRae 1999, Meadows & Watkeys 1999, Churchill et al. 2000, Partridge & Scott 2000, Brink & Rossouw 2000, Rossouw 2006). Other late Caenozoic fossil biotas that may occur within these superficial deposits include non-marine molluscs (bivalves, gastropods), ostrich egg shells, trace fossils (e.g. calcretised termitaria, coprolites, invertebrate burrows, rhizocretions), and plant material such as peats or palynomorphs (pollens) in organic-rich alluvial horizons (Scott 2000) and diatoms in pan sediments. In Quaternary deposits, fossil remains may be associated with human artefacts such as stone tools and are also of archaeological interest (e.g. Smith 1999 and refs. therein). Ancient solution hollows within extensive calcrete hardpans may have acted as animal traps in the past. As with coastal and interior limestones, they might occasionally contain mammalian bones and teeth (perhaps associated with hyaena dens) or invertebrate remains such as snail shells.

17 17 Table 1. Fossil heritage previously recorded within the main rock units cropping out along the various Lydenburg Merensky transmission line corridor options MAJOR GEOLOGICAL UNIT FORMATION, ROCK TYPES & AGE FOSSIL HERITAGE PALAEONT- OLOGICAL SENSITIVITY RECOMMENDED MITIGATION LATE CAENOZOIC TERRESTRIAL DEPOSITS OF THE INTERIOR (Qs, T-Qc) (Most too small to be indicated on 1: geological maps) Fluvial, pan, lake and terrestrial sediments, including diatomite (diatom deposits), pedocretes (e.g. calcrete), spring tufa / travertine, cave deposits, peats, colluvium, soils, surface gravels including downwasted rubble MOSTLY QUATERNARY TO HOLOCENE Bones and teeth of wide range of mammals (e.g. mastodont proboscideans, rhinos, bovids, horses, micromammals), reptiles (crocodiles, tortoises), ostrich egg shells, fish, freshwater and terrestrial molluscs (unionid bivalves, gastropods), crabs, trace fossils (e.g. termitaria, horizontal invertebrate burrows, stone artefacts), petrified wood, leaves, rhizoliths, diatom floras, peats and palynomorphs. GENERALLY LOW (BUT LOCALLY HIGH) Scattered records, many poorly studied and of uncertain age Monotoring of deeper excavations (> 1m) for fossils (e.g. mammalian bones, teeth) by ECO. Any substantial fossil finds to be reported by ECO to SAHRA. (Possible peak formation Ma) BUSHVELD MAGMATIC PROVINCE /BUSHVELD COMPLEX Mafic intrusives of Rustenberg Layered Suite. NO FOSSILS ZERO NONE Vdi diabase Vsn Shelter Norite Late Vaalian / Early Proterozoic 2.06 Ga Baking by hot igneous intrusions may also destroy fossil heritage in neighbouring country rocks

18 TRANSVAAL SUPERGROUP Late Archaean Early Proterozoic (= Vaalian) <2.7 to 2.1 Ga PRETORIA GROUP 18 Magaliesberg Fm (Vmg, Vlm) Coastal sandstones with mudrocks Microbial mat structures (Desiccated mats sometimes resemble trace fossils) LOW Monotoring of deeper excavations (> 1m) for fossils (e.g. stromatolites) by ECO. Silverton Fm (Vsi) Marine mudrocks with minor carbonates, volcanic rocks (= Machadodorp Member) [Green areas are younger basic igneous intrusions (Vdi)] Stromatolites Pretoria Group subunits with stromatolites probably also contain microfossils. This may well also apply to carbonaceous mudrocks. LOW / MEDIUM Any substantial fossil finds to be reported by ECO to SAHRA.

19 19 4. BRIEF COMPARISON OF TRANSMISSION LINE ROUTE OPTIONS IN TERMS OF PALAEONTOLOGICAL SENSITIVITY Route Option 1 has the longest sector overlying the Silverton Formation outcrop area, along the western side of the Spekboomrivier Valley, where there is a (low) possibility of stromatolitic limestone horizons. There is likewise a slight possibility of Late Caenozoic mammalian remains or other fossils being encountered withn superficial sediments on the northern (SE-NW) sector through to Merensky Substation. The impact significance of this route option as far as palaeontological heritage resources are concerned is rated as LOW. Route Option 2 has the longest sector overlying the Magaliesberg Formation outcrop area, on either side of the Watervalsrivier valley, where there is a possibility of microbial mat features being encountered in association with shallow water to littoral sandy sediments. There is a small possibility of stromatolitic carbonates in the southeast, near Lydenburg, and of Late Caenozoic mammalian remains or other fossils in the northernmost (SE-NW) sector through Olifantspoortjie. The impact significance of this route option as far as palaeontological heritage resources are concerned is also rated as LOW. Route Option 3 has the longest sector overlying Late Caenozoic superficial sediments where there is a slight possibility of Late Caenozoic mammalian remains or other fossils being encountered. There is likewise a small possibility of stromatolitic carbonates in the southeast, near Lydenburg (Silverton Formation), and of microbial mat features within Magiesberg Formation quartzites on higher ground flanking the eastern side of the Watervalsrivier Valley. The impact significance of this route option as far as palaeontological heritage resources are concerned is also rated as LOW. 5. CONCLUSIONS & RECOMMENDATIONS The proposed new Lydenburg Merensky 132 kv Sub-transmission line and associated substation developments are situated in parts of the Mpumulanga Highlands that are underlain by (1) poorly fossiliferous sedimentary rocks of the Precambrian Pretoria Group (c. 2 billion years old), (1) unfossiliferous igneous rocks of the slightly younger Bushveld Complex, as well as by (2) superficial sediments (alluvium, scree, soils), mainly of Quaternary to Recent age. The construction phase of the Sub-transmission line and associated infrastructure (e.g. tower footings, service roads, working and laydown areas, substations, construction camps, any borrow pits) may entail substantial excavations into or disturbance of the superficial sediment cover as well as the underlying bedrocks. In addition, considerable areas of bedrock may be sealed-in or sterilized by lay-down areas as well as new gravel roads. All these developments may adversely affect fossil heritage resources preserved at or beneath the surface of the ground within the development footprint by destroying, disturbing or permanently sealing-in fossils that are then no longer available for scientific research or other public good. Negative impacts on local fossil heritage are mainly anticipated during the construction phase of the transmission line development in connection with excavations for Sub-transmission tower footings and stays as well as surface clearance and new cuttings made for service roads and laydown areas. The magnitude of these impacts is largely determined by the Sub-transmission line corridor that is chosen. Upgrading of existing substations and construction camps are unlikely to generate significant additional palaeontological impacts. Once constructed, the operational and decommissioning phases of the Sub-transmission line are unlikely to involve further adverse impacts on palaeontological heritage.

20 20 All of the bedrock and superficial sediment units within the Lydenburg Merensky Sub-transmission line study area are assessed as of negligible to LOW palaeontological sensitivity (Table 1). In terms of anticipated impacts on fossil heritage resources at or beneath the ground surface there is no significant difference between Sub-transmission line Route Options 1, 2 and 3. The impact significance of all three route options is rated as LOW and there is no preference on palaeontological grounds for any particular route option. The No-go option (no construction of transmission line or substation upgrade) would have a neutral impact on fossil heritage Recommendations Given the low palaeontological sensitivity of the rock units represented within the study area, and the consequent LOW impact significance of all three Sub-transmission line route options under consideration, no further specialist palaeontological heritage studies or mitigation are recommended for this project, pending the discovery of substantial new fossil material during construction. The responsible Environmental Control Officer (ECO) should monitor all substantial (> 1 m deep) excavations for fossil material. In the case of any significant fossil finds during construction (e.g. vertebrate teeth, bones, burrows, petrified wood, shells, stromatolites), these should be safeguarded - preferably in situ - and reported by the ECO as soon as possible to SAHRA (Contact details: Mrs Colette Scheermeyer, P.O. Box 4637, Cape Town Tel: cscheermeyer@sahra.org.za), so that appropriate mitigation (i.e. recording, sampling or collection) by a palaeontological specialist can be considered and implemented. These recommendations should be incorporated into the Environmental Management Plan (EMP) for this development. 6. ACKNOWLEDGEMENTS Ms Melissa Naidoo of Royal HaskoningDHV, Beacon Bay, is thanked for commissioning this study and for kindly providing the necessary background information. 7. REFERENCES BEKKER, A. et al Fractionation between inorganic and organic carbon during the Lomagundi ( Ga) carbon isotope excursion. Earth and Planetary Science Letters 271, BOSCH, P. & ERIKSSON, P A note on two occurrences of inferred microbial mat features preserved in the c. 2.1 Ga Magaliesberg Formation (Pretoria Group, Transvaal Supergroup) sandstones, near Pretoria, South Africa. South African Journal of Geology 111, BOUSMAN, C.B. et al Palaeoenvironmental implications of Late Pleistocene and Holocene valley fills in Blydefontein Basin, Noupoort, C.P., South Africa. Palaeoecology of Africa 19: BRINK, J.S The archaeozoology of Florisbad, Orange Free State. Memoirs van die Nasionale Museum 24, 151 pp. BRINK, J.S. et al A new find of Megalotragus priscus (Alcephalini, Bovidae) from the Central Karoo, South Africa. Palaeontologia africana 32:

21 21 BRINK, J.S. & ROSSOUW, L New trial excavations at the Cornelia-Uitzoek type locality. Navorsinge van die Nasionale Museum Bloemfontein 16, BUTTON, A A regional study of the stratigraphy and development of the Transvaal Basin in the eastern and northeastern Transvaal. Unpublished PhD thesis, University of the Witwatersrand, Johannesburg, 352 pp. BUTTON. A Low-potash pillow basalts in the Pretoria group, Transvaal Supergroup. Transactions of the Geological Society of South Africa 77, BUTTON, A The Transvaal Sub-basin of the Transvaal Sequence. Mineral deposits of Southern Africa (Anhaeusser, C.R. & Maske, S. Eds.), CATUNEANU, O. & ERIKSSON, P.G The sequence stratigraphic concept and the Precambrian rock record: an example from the Ga Transvaal Supergroup, Kaapvaal craton. Precambrian Research 97, CAWTHORN, R.G., EALES, H.V., WALRAVEN, F., UKEN, R. & WATKEYS, M.K The Bushveld Complex. In: Johnson. M.R., Anhaeusser, C.R. & Thomas, R.J. (eds.) The geology of South Africa, pp Geological Society of South Africa, Johannesburg & the Council for Geoscience, Pretoria. CHURCHILL, S.E. et al Erfkroon: a new Florisian fossil locality from fluvial contexts in the western Free State, South Africa. South African Journal of Science 96: EALES, H.V A first introduction to the geology of the Bushveld Complex and those aspects of South African geology that relate to it, 84 pp. Council for Geoscience, Pretoria. ERIKSSON, P.G Pretoria Group. SA Committee for Stratigraphy. Catalogue of South African lithostratigraphic units 6, Council for Geoscience, Pretoria. ERIKSSON, P.G., TWIST, D., SNYMAN, C.P. & BURGER, L The geochemistry of the Silverton Formation, Transvaal Sequence. University of Pretoria, Institute for Geological Research on the Bushveld Complex 79, iii + 24 pp. ERIKSSON, P.G., SCHRIEBER, U.M. & VAN DER NEUT, M A review of the sedimentology of the Early Proterozoic Pretoria Group, Transvaal Sequence, South Africa: implications for tectonic setting. Journal of African Earth Sciences (and the Middle East) 13, ERIKSSON, P.G., SCHWEITZER, J.K., BOSCH, P.J.A., SCHREIBER, U.M., VAN DEVENTER, J.L. & HATTON, C.J The Transvaal Sequence: an overview. Journal of African Earth Sciences (and the Middle East) 16, ERIKSSON, P.G., HATTINGH, P.J. & ALTERMANN, W An overview of the geology of the Transvaal Sequence and Bushveld Complex, South Africa. Mineralium Deposita 30, ERIKSSON, P.G., ALTERMANN, W., EBERHARDT, L., AREND-HEIDBRINCK, S. & BUMBY, A.J Palaeoproterozoic epeiric sea palaeoenvironments: the Silverton Formation (Pretoria Group, Transvaal Supergroup), South Africa. In: Altermann, W. & Corcoran, P.L. (Eds.) Precambrian sedimentary environments: a modern approach to ancient depositional systems. International Association of Sedimentologists Special Publication 33, Blackwell Publishing Ltd, Oxford. ERIKSSON, P.G., ALTERMANN, W. & HARTZER, F.J The Transvaal Supergroup and its precursors. In: Johnson, M.R., Anhaeusser, C.R. & Thomas, R.J. (Eds.) The geology of South Africa, pp Geological Society of South Africa, Marshalltown. ERIKSSON, P.G., PORADA, H., BANERJEE, S., BOUOUGRI, E., SARKAR, S. & BUMBY, A.J Mat-destruction features. In: Schieber, J., Bose, P.K., Eriksson, P.G., Banerjee, S., Sarkar, S., Altermann, W. and Catuneanu, O. (Eds.) Atlas of microbial mat features preserved within the clastic rock record, p Elsevier.

22 22 ERIKSSON, P.G., RAUTENBACH, C.J. de W., WRIGHT, D.T., BUMBY, A.J., CATUNEANU, O., MOSTERT, P. & VAN DER NEUT, M Possible evidence for episodic epeiric marine and fluvial sedimentation (and implications for palaeoclimatic conditions), c Ga, Kaapvaal craton, South Africa. Palaeogeography, Palaeoclimatology, Palaeoecology 273, KLEIN, R.G The large mammals of southern Africa: Late Pliocene to Recent. In: Klein, R.G. (Ed.) Southern African prehistory and paleoenvironments, pp Balkema, Rotterdam. MACRAE, C Life etched in stone. Fossils of South Africa, 305 pp. The Geological Society of South Africa, Johannesburg. MCCARTHY, T. & RUBIDGE, B The story of Earth and life: a southern African perspective on a 4.6-billion-year journey. 334pp. Struik, Cape Town. MEADOWS, M.E. & WATKEYS, M.K Palaeoenvironments. In: Dean, W.R.J. & Milton, S.J. (Eds.) The karoo. Ecological patterns and processes, pp Cambridge University Press, Cambridge. MOORE, J.M., TSIKOS, H. & POLTEAU, S Deconstructing the Transvaal Supergroup, South Africa: implications for Palaeoproterozoic palaeoclimate models. African Earth Sciences 33, PARIZOT, M., ERIKSSON, P.G., AIFA, T., SARKAR, S., BANERJEE, S., CATUNEANU, O., ALTERMANN, W., BUMBY, A.J., BORDY, E.M., VAN ROOY, J.L. & BOSHOFF, A.J Suspected microbial mat-related crack-like sedimentary structures in the Palaeoproterozoic Magaliesberg Formation sandstones, South Africa. Precambrian Research 138, PARTRIDGE, T.C. & SCOTT, L Lakes and pans. In: Partridge, T.C. & Maud, R.R. (Eds.) The Cenozoic of southern Africa, pp Oxford University Press, Oxford. PARTRIDGE, T.C., BOTHA, G.A. & HADDON, I.G Cenozoic deposits of the interior. In: Johnson, M.R., Anhaeusser, C.R. & Thomas, R.J. (Eds.) The geology of South Africa, pp Geological Society of South Africa, Marshalltown. PARTRIDGE, T.C., DOLLAR, E.S.J., MOOLMAN, J. & DOLLAR, L.H The geomorphic provinces of South Africa, Lesotho and Swaziland: a physiographic subdivision for earth and environmental scientists. Transactions of the Royal Society of South Africa 65, ROSSOUW, L Florisian mammal fossils from erosional gullies along the Modder River at Mitasrust Farm, Central Free State, South Africa. Navorsinge van die Nasionale Museum Bloemfontein 22, SEILACHER, A Trace fossil analysis, xiii + 226pp. Springer Verlag, Berlin. SKEAD, C.J Historical mammal incidence in the Cape Province. Volume 1: The Western and Northern Cape. 903pp. Department of Nature and Environmental Conservation, Cape Town. TANKARD, A.J., JACKSON, M.P.A., ERICKSSON, K.A., HOBDAY, D.K., HUNTER, D.R. & MINTER, W.E.L Crustal evolution of Southern Africa 3.8 billion years of earth history. xv pp. Springer Verlag, New York. VISSER, D.J.L The geology of the Republics of South Africa, Transkei, Bophuthatswana, Venda and Ciskei and the Kingdoms of Lesotho and Swaziland. Explanation: geological map 1: , 491 pp. Council for Geoscience, Pretoria. WALRAVEN, F The geology of the Rustenburg area. Explanation to 1: geology sheet 2526 Rustenburg, 37 pp. Council for Geoscience, Pretoria. WALRAVEN, F. 1989a. Die geologie van die gebied Barberton. Explanation to 1: geology sheet 2530 Baberton / Nelspruit, 35 pp. Council for Geoscience, Pretoria.

23 23 WALRAVEN, F. 1989b. The geology of the Pilgrim s Rest area. Explanation to 1: geology sheet 2430 Pilgrim s Rest, 24 pp. Council for Geoscience, Pretoria. 8. QUALIFICATIONS & EXPERIENCE OF THE AUTHOR Dr John Almond has an Honours Degree in Natural Sciences (Zoology) as well as a PhD in Palaeontology from the University of Cambridge, UK. He has been awarded post-doctoral research fellowships at Cambridge University and in Germany, and has carried out palaeontological research in Europe, North America, the Middle East as well as North and South Africa. For eight years he was a scientific officer (palaeontologist) for the Geological Survey / Council for Geoscience in the RSA. His current palaeontological research focuses on fossil record of the Precambrian - Cambrian boundary and the Cape Supergroup of South Africa. He has recently written palaeontological reviews for several 1: geological maps published by the Council for Geoscience and has contributed educational material on fossils and evolution for new school textbooks in the RSA. Since 2002 Dr Almond has also carried out palaeontological impact assessments for developments and conservation areas in the Western, Eastern and Northern Cape under the aegis of his Cape Town-based company. He is a long-standing member of the Archaeology, Palaeontology and Meteorites Committee for Heritage Western Cape (HWC) and an advisor on palaeontological conservation and management issues for the Palaeontological Society of South Africa (PSSA), HWC and SAHRA. He is currently compiling technical reports on the provincial palaeontological heritage of Western, Northern and Eastern Cape for SAHRA and HWC. Dr Almond is an accredited member of PSSA and APHP (Association of Professional Heritage Practitioners Western Cape). Declaration of Independence I, John E. Almond, declare that I am an independent consultant and have no business, financial, personal or other interest in the proposed railway project, application or appeal in respect of which I was appointed other than fair remuneration for work performed in connection with the activity, application or appeal. There are no circumstances that compromise the objectivity of my performing such work. Dr John E. Almond Palaeontologist,