SLR Consulting (South Africa) Proprietary Limited

Registered Address: Suite 1 - Building D, Monte Circle, 178 Montecasino Boulevard, Fourways, Johannesburg, Gauteng, 2191

Johannesburg Office: Physical Address: Suite 1 - Building D, Monte Circle, 178 Montecasino Boulevard, Fourways, Johannesburg, Gauteng, 2191

Postal Address: PO Box 1596, Cramerview, 2060, South Africa Postal Address: PO Box 1596, Cramerview, 2060 Tel: +27 11 467 0945

Reg. No: 2007/005517/07 Cape Town Office: Physical Address: 5th Floor, Letterstedt House, Newlands on Main, Cnr Main and Campground Roads, Newlands, Cape Town, Western Cape, 7700

Vat No: 4630242198 Postal Address: PO Box 10145, Caledon Square, 7905 Tel: +27 21 461 1118

Directors: R Hounsome, F Fredericks, D Junak www.slrconsulting.com

Project Reference: 720.18034.00016 File Ref. 2020-07-31_Rhino 350ER_EIA Phase Public Participation Plan

31 July 2020

PETROLEUM AGENCY OF SOUTH AFRICA Typerpoort Building 7 Mispel Street Bellville, 7530

ATTENTION: ACTING CHIEF EXECUTIVE OFFICER

CC: Stet Mushwana/ Sinazo Mnyaka Dear Sir / Madam

ENVIRONMENTAL AUTHORISATION APPLICATION FOR PROPOSED EXPLORATION RIGHT ON VARIOUS FARMS IN THE FREE STATE AND KWAZULU-NATAL PROVINCES (12/3/350 ER): PUBLIC PARTICIPATION PLAN FOR ENVIRONMENTAL IMPACT ASSESSMENT PHASE

The Petroleum Agency of South Africa’s (PASA) letter of 23 July 2020, granting an extension to Environmental Impact Assessment (EIA) Report submission deadline, refers. We thank you for the granting the extension and note the requirement to submit a Public Participation Plan to be considered by the PASA prior to commencing with the Interested and Affected Party (I&AP) consultation during the EIA phase. The Public Participation Plan, attached as Annexure A, outlines the tasks to be implemented by SLR Consulting (South Africa) (Pty) Ltd and is based on:

• The consultation detailed in the approved Plan of Study for EIA (approval dated 30 January 2020); and

• The Directions Regarding Measures to Address, Prevent and Combat the Spread of COVID-19 Relating to National Environmental Management Permits and Licences” published in Government Notice (GN R 650 of 5 June 2020).

We trust that you find this in order and would appreciate a written response. Should you have any queries above, or require any further information, please do not hesitate to contact the undersigned. Kind regards

Matthew Hemming Environmental Assessment Practitioner

ANNEXURE A – PUBLIC PARTICIPATION PLAN

ENVIRONMENTAL AUTHORISATION APPLICATION FOR PROPOSED EXPLORATION RIGHT ON VARIOUS FARMS IN THE FREE STATE AND KWAZULU-NATAL PROVINCES (12/3/350 ER)

PUBLIC PARTICIPATION PLAN FOR ENVIRONMENTAL IMPACT ASSESSMENT PHASE

Task No.

Task Details

1. Continued development of the database and notice to Registered I&AP

1.1

• Ongoing queries with Deeds Office

• Ongoing queries with Master of relevant high

courts (applicable for properties held in a trust)

• The Registered I&AP database will continue being developed

through researching landowner details held in the regional Deeds

Office and the provincial Master of the High Courts.

At the time of compiling this Plan, the regional deeds office and Master

of the High Courts remained closed because of COVID-19 restrictions.

1.2

• Notification to landowners • Where additional land owner details are acquired, notifications will

be sent and the EIA report will document the percentage land

owner notified.

1.3 • Publish notices in the official gazettes • Notices will be placed in the Free State and KwaZulu-Natal

Provincial Gazettes.

1.4

• Radio notices • Radio notices were broadcast on two local stations at the time

lockdown commenced.

• Further radio notices will be broadcast on two stations local to

rural KZN and south-eastern Free State.

2. Distribution of information to Registered I&APs

2.1

• Notification of the availability of the EIA Report • Written notice to all Registered I&APs informing them of the

availability of the EIA Report for review and comment will be

distributed via email, mobile text message and post.

• More than 90% of Registered I&APs have email addresses.

2.2

• Distribution of the EIA Report’s Executive

Summary

• A copy of the Executive Summary of the EIA Report will be

appended to the email notice (See Task 2.1). More than 90% of

Registered I&APs have email addresses.

• The Executive Summary will provide an overview of the EIA

Report and enable I&APs to review and comment.

2.3

• Distribution of the EIA Report • Copies of the EIA Report will be made available to Registered

I&APs via:

o On SLR’s web page at www.slrconsulting.co.za.

o On a project specific data-free website (accessible from mobile

devices without data costs to the user); and

o Compact disks to be sent to commenting authorities and any

Registered I&AP should they request a copy

Distribution via a data-free website replaces the planned publication of

the EIA Report in in local public libraries. Public libraries remain closed

and prohibited as a means of distributing the EIA Report as per the

Directions issued by the DEFF (June, 2020). Given the current rate of

COVID infections, SLR remains of the view that placement of physical

report copies would not be practical or responsible.

Should local public libraries become accessible to the public prior to the

EIA Report being published, SLR will make hard copies of the report

ENVIRONMENTAL AUTHORISATION APPLICATION FOR PROPOSED EXPLORATION RIGHT ON VARIOUS FARMS IN THE FREE STATE AND KWAZULU-NATAL PROVINCES (12/3/350 ER)

PUBLIC PARTICIPATION PLAN FOR ENVIRONMENTAL IMPACT ASSESSMENT PHASE

Task No.

Task Details

available at these facilities.

2.4

• 30-day period for Review of EIA Report • Point 4.4 of the Directions provides that timeframes for actions

within the EIA process are deemed extended by 30-days, on

condition that where such actions can be concluded in a shorter

timeframe they should be.

• Given that the great majority of Registered I&APs have access to

email and thus the internet, they would all be able to access the

EIR report for review and return comments to SLR electronically.

It is thus motivated that a 30-day period, as prescribed in the EIA

Regulations is adequate for the Registered I&APs to submit

comment.

• PASA has approved that the EIA Report, reflecting the inclusion of

comments, is to be submitted no later than 6 October 2020.

3. Decision on the application

3.1

• Notice of the decision • Registered I&APs will be informed of the decision, the reasons

therefore and the fact that an appeal may be lodged in terms of

the National Appeals Regulations, 2014 via email, mobile text

message and post.

SLR Consulting (South Africa) Proprietary Limited

Registered Address: Suite 1 - Building D, Monte Circle, 178 Montecasino Boulevard, Fourways, Johannesburg, Gauteng, 2191

Johannesburg Office: Physical Address: Suite 1 - Building D, Monte Circle, 178 Montecasino Boulevard, Fourways, Johannesburg, Gauteng, 2191

Postal Address: PO Box 1596, Cramerview, 2060, South Africa Postal Address: PO Box 1596, Cramerview, 2060 Tel: +27 11 467 0945

Reg. No: 2007/005517/07 Cape Town Office: Physical Address: 5th Floor, Letterstedt House, Newlands on Main, Cnr Main and Campground Roads, Newlands, Cape Town, Western Cape, 7700

Vat No: 4630242198 Postal Address: PO Box 10145, Caledon Square, 7905 Tel: +27 21 461 1118

Directors: R Hounsome, F Fredericks, D Junak www.slrconsulting.com

Project Reference: 720.18034.00016 File Ref. 2020-07-23_Rhino 350ER_Application for extension of EIA timeframe

23 July 2020

PETROLEUM AGENCY OF SOUTH AFRICA Typerpoort Building 7 Mispel Street Bellville, 7530

ATTENTION: ACTING CHIEF EXECUTIVE OFFICER

CC: Stet Mushwana/ Sinazo Mnyaka Dear Sir / Madam

ENVIRONMENTAL AUTHORISATION APPLICATION FOR PROPOSED EXPLORATION RIGHT ON VARIOUS FARMS IN THE FREE STATE AND KWAZULU-NATAL PROVINCES (12/3/350 ER): MOTIVATION TO EXTEND THE SUBMISSION DATE FOR THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT

Your letter of 30 January 2020, accepting the Final Scoping Report and Plan of Study for Environmental Impact Assessment (EIA) on this application, refers. We thank you for the acceptance of the Final Scoping Report and note the requirement to implement the Plan of Study for EIA and submit an Environmental Impact Assessment Report on or before 25 May 2020. SLR Consulting (South Africa) (Pty) Ltd, as the Environmental Assessment Practitioner appointed by Rhino Oil and Gas Exploration South Africa (Pty) Ltd, had commenced with implementation of the Plan of Study for EIA and the points noted in your letter when the COVID-19 pandemic struck South Africa. On March 31 the Minister of Forestry, Fisheries and the Environment issued Directions in terms of Regulation 10 (8) of the Regulations issued in terms of section 27 (2) of the Disaster Management Act, 2002: Measures to address, prevent and Combat the Spread of COVID-19. These Directions suspended all environmental permitting processes and related timeframes at the commencement of lock down (i.e. 27 March 2020). On 5 June 2020 the Minister published “Directions Regarding Measures to Address, Prevent and Combat the Spread of COVID-19 Relating to National Environmental Management Permits and Licences”. These revised Directions enabled environmental management permit and licensing processes to recommence, subject to the Regulations issued in terms of Section 27 of the Disaster Management Act, 2002. The revised Directions set out that the timeframes suspended under the repealed Directions are resumed as of 5 June 2020 and deemed to be extended by 21 days (Direction 4.3). The EIA Report for 350 ER was due to PASA on or before 25 May 2020. This timeframe was interrupted by the COVID-19 lock down from 27 March 2020 and 70 days were lost up to 5 June 2020. The revised deadline for

submission of the EIA Report in terms of the Directions would therefore be 4 September 2020 (i.e. 5 June + 70 days + 21 days). As at 23 July there are 44 days remaining in this period. SLR has advised Rhino Oil and Gas Exploration South Africa (Pty) Ltd that a minimum of 70 days are required in order to:

• implement the Plan of Study for EIA,

• draft the EIA Report,

• provide the EIA Report to I&APs for 30-day public review;

• finalise the EIA Report reflecting the incorporation of I&AP comments; and

• submit the EIA Report to PASA. Additionally, the legal team appointed by Rhino Oil and Gas Exploration South Africa (Pty) Ltd continues with their attempt to gather the contact details of Trust land owners from the Master of the court. This exercise has been further complicated by the COVID-19 response. It is an important activity in order to improve the percentage of land owners that are notified of the application and as much time as possible is required to achieve a meaningful outcome. SLR is awaiting feedback from the legal team on the Trust contact information. As a result, we hereby request for an extension of time in terms of Regulation 3(7) of the Environmental Impact Assessment Regulations, 2014 such that the Environmental Impact Assessment Report for the 12/3/350 ER application will be submitted to PASA on or before 5 October 2020. We trust that you find this in order and would appreciate a written response. Should you have any queries on the above, or require any further information, please do not hesitate to contact the undersigned. Kind regards

Matthew Hemming Environmental Assessment Practitioner