Scarlet Ibis Wind Energy Facility, Nelson Mandela Bay Metropolitan, Eastern Cape Province

SCARLET IBIS WIND ENERGY FACILITY, NELSON MANDELA BAY METROPOLITAN, EASTERN CAPE PROVINCE

DEDEAT Reference Number: ECM1/C/LN1&3/M/49-2017

FINAL BASIC ASSESSMENT REPORT

PREPARED FOR:

SCARLET IBIS WIND POWER (PTY) LTD 16 Irvine Street, Port Elizabeth, 6001  041 506 4900  [email protected] www.innowind.com

PREPARED BY:

Coastal & Environmental Services

EOH Coastal & Environmental Services GRAHAMSTOWN 67 African Street, Grahamstown, 6139  046 622 2364  [email protected] EOH Coastal & Environmental Services has offices in Grahamstown, East London, Port Elizabeth, Cape Town, Johannesburg and Maputo (Mozambique) www.cesnet.co.za  www.eoh.co.za

December 2017

Report Title: Scarlet Ibis Wind Energy Facility Basic Assessment Report Report Version: Final DEDEAT Reference Number: ECM1/C/LN1&3/M/49-2017 EOH Coastal & Environmental Services Project Code: P40700012

Environmental Assessment Practitioner (EAP) Details: EAP: Alan Carter Address: 25 Tecoma Street, Berea, East London Contact Person: Caroline Evans Telephone: 046 622 2364 Email: [email protected]

EAP Declaration  I act as the independent environmental practitioner in this application;  I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;  I declare that there are no circumstances that may compromise my objectivity in performing such work;  I have expertise in conducting environmental impact assessments, including knowledge of the Act, regulations and any guidelines that have relevance to the proposed activity;  I will comply with the Act, Regulations and all other applicable legislation;  I have no, and will not engage in, conflicting interests in the undertaking of the activity;  I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;  I will provide the competent authority with access to all information at my disposal regarding the application, whether such information is favourable to the applicant or not;  All of the particulars furnished by me in this form are true and correct; and  I will perform all other obligations as expected from an environmental assessment practitioner in terms of the Regulations.

This document contains intellectual property and proprietary information that is protected by copyright in favour of EOH Coastal & Environmental Services and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of EOH Coastal & Environmental Services. This document is prepared exclusively for submission to Scarlet Ibis Wind Power (Pty) Ltd., and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.

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ENVIRONMENTAL IMPACT ASSESSMENT TEAM

Alan Carter, Project Leader Environmental EOH Coastal & Environmental Services Consultants Caroline Evans, Project Manager EOH Coastal & Environmental Services Rosalie Evans, Agriculture & Soils Specialist Agriculture & Soils EOH Coastal & Environmental Services Specialists Chantel Bezuidenhout, Agriculture & Soils Specialist (APPENDIX D1) EOH Coastal & Environmental Services Avifaunal Jon Smallie, Avifaunal Specialist Specialists WildSkies Ecological Services (APPENDIX D2) Bat Werner Marais, Bat Specialist Specialist Animalia Ecological Consultants (APPENDIX D3) Kim Brent, Ecological Specialist Ecological EOH Coastal & Environmental Services Specialists Tarryn Martin, Ecological Specialist (APPENDIX D4) EOH Coastal & Environmental Services Heritage Celeste Booth, Archaeological Specialist Specialist Booth Heritage Consulting (APPENDIX D5) Noise Morné de Jager, Acoustic Specialist Specialist Enviro Acoustic Research, MENCO (APPENDIX D6) Paleontological Rob Gess, Paleontological Specialist Specialist Rob Gess Consulting (APPENDIX D7) Thomas King, Visual Specialist Visual EOH Coastal & Environmental Services Specialists Caroline Evans, Visual Specialist (APPENDIX D8) EOH Coastal & Environmental Services

“Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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GENERAL SCARLET IBIS WEF SITE INFORMATION

Farm Name SG Digit Number Farm Number/Portion Area (ha) Welbedachtsfontein Farm 300 C07600000000030000001 Farm 300, Portion 1 271.89 ha Grassridge Farm 226 C07600000000022600003 Farm 226, Portion 3 1 352.90 ha Geluksdal Farm 590 C07600000000059000000 Farm 590 332.10 ha TOTAL 1 956.89 ha

Turbine Design Specifications Number of turbines 9 2 - 4.5MW (full breakdown of the categories of turbines available is displayed in Power output per turbine the project description) Facility output <20MW Turbine hub height Up to 100m Turbine rotor diameter Up to 90m Turbine blade length Up to 45m Turbine tip height 140m (maximum height) Turbine foundation area 400m2 Crane hardstand area 3 500m2 Turbine road width 14m to be rehabilitated to 8m

Turbine Coordinates WTG 01 33° 43' 34.93" S 25° 36' 22.28" E WTG 02 33° 43' 52.37" S 25° 36' 16.56" E WTG 03 33° 43' 55.34" S 25° 36' 54.35" E WTG 04 33° 43' 48.91" S 25° 36' 01.60" E WTG 05 33° 44' 07.30" S 25° 36' 43.19" E WTG 06 33° 44' 17.67" S 25° 36' 33.89" E WTG 07 33° 42' 17.50" S 25° 35' 12.08" E WTG 08 33° 42' 22.89" S 25° 34' 54.74" E WTG 09 33° 43' 43.73" S 25° 36' 11.44" E

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GENERAL SCARLET IBIS POWERLINE ALTERNATIVES SITE INFORMATION

Farm Number/Portion Farm Name SG Number POWERLINE ALTERNATIVE 1 (PREFERRED) 300/1 Welbedachtsfontein Farm C07600000000030000001 318/RE ERF C07600230000031800000 340 ERF C07600230000034000000 274/RE ERF C07600230000027400000 POWERLINE ALTERNATIVE 2 300/1 Welbedachtsfontein Farm C07600000000030000001 590/RE Geluksdal Farm C07600000000059000000 318/RE ERF C07600230000031800000 246/RE ERF C07600230000026800000 268 ERF C07600230000026800000 248 ERF C07600230000024800000 217 ERF C07600230000021700000 287 ERF C07600230000028700000 288 ERF C07600230000028800000 340 ERF C07600230000034000000 132 ERF C07600230000013200000 2 ERF C07600230000000200000 3 ERF C07600230000000300000 4 ERF C07600230000000400000 5 ERF C07600230000000500000 6 ERF C07600230000000600000 7 ERF C07600230000000700000 8 ERF C07600230000000800000 9 ERF C07600230000000900000 10 ERF C07600230000001000000 11 ERF C07600230000001100000 12 ERF C07600230000001200000 13 ERF C07600230000001300000 14 ERF C07600230000001400000 15 ERF C07600230000001500000 66 ERF C07600230000006600000 87 ERF C07600230000008700000 88 ERF C07600230000008800000 “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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89 ERF C07600230000008900000 109 ERF C07600230000010900000 108 ERF C07600230000010800000 107 ERF C07600230000010700000 110 ERF C07600230000011000000 111 ERF C07600230000011100000 112 ERF C07600230000011200000 113 ERF C07600230000011300000 128 ERF C07600230000012800000 129 ERF C07600230000012900000 130 ERF C07600230000013000000 131 ERF C07600230000013100000 133 ERF C07600230000013300000 134 ERF C07600230000013400000 135 ERF C07600230000013500000 136 ERF C07600230000013600000 137 ERF C07600230000013700000 138 ERF C07600230000013800000 139 ERF C07600230000013900000 140 ERF C07600230000014000000 141 ERF C07600230000014100000 142 ERF C07600230000014200000 143 ERF C07600230000014300000 144 ERF C07600230000014400000 145 ERF C07600230000014500000 146 ERF C07600230000014600000 147 ERF C07600230000014700000 148 ERF C07600230000014800000 149 ERF C07600230000014900000 150 ERF C07600230000015000000 151 ERF C07600230000015100000 152 ERF C07600230000015200000 153 ERF C07600230000015300000 154 ERF C07600230000015400000 155 ERF C07600230000015500000 156 ERF C07600230000015600000

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157 ERF C07600230000015700000 178 ERF C07600230000017800000 177 ERF C07600230000017700000 176 ERF C07600230000017600000 175 ERF C07600230000017500000 174 ERF C07600230000017400000 182 ERF C07600230000018200000 183 ERF C07600230000018300000 184 ERF C07600230000018400000 185 ERF C07600230000018500000 186 ERF C07600230000018600000 187 ERF C07600230000018700000 188 ERF C07600230000018800000 189 ERF C07600230000018900000 190 ERF C07600230000019000000 193 ERF C07600230000019300000 194 ERF C07600230000019400000 195 ERF C07600230000019500000 196 ERF C07600230000019600000 197 ERF C07600230000019700000 198 ERF C07600230000019800000 199 ERF C07600230000019900000 200 ERF C07600230000020000000 201 ERF C07600230000020100000 202 ERF C07600230000020200000 203 ERF C07600230000020300000 53 ERF C07600230000005300000 54 ERF C07600230000005400000 55 ERF C07600230000005500000 56 ERF C07600230000005600000 57 ERF C07600230000005700000 58 ERF C07600230000005800000 59 ERF C07600230000005900000 60 ERF C07600230000006000000 61 ERF C07600230000006100000 62 ERF C07600230000006200000

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63 ERF C07600230000006300000 64 ERF C07600230000006400000 65 ERF C07600230000006500000 Coega Allotment Area C0760023 POWERLINE ALTERNATIVE 3 300/1 Welbedachtsfontein Farm C07600000000030000001 300/6 Welbedachtsfontein Farm C07600000000030000006 300/4/RE Welbedachtsfontein Farm C07600000000030000004 300/19 Welbedachtsfontein Farm C07600000000030000019 300/8 Welbedachtsfontein Farm C07600000000030000008 300 Welbedachtsfontein Farm C07600000000030000000 300/2 Welbedachtsfontein Farm C07600000000030000002 316/4 Coegas Kop C07600000000031600004 316/3 Coegas Kop C07600000000031600003 316/11/RE Coegas Kop C07600000000031600011 316/2/RE Coegas Kop C07600000000031600002 434 Farm 434 C07600000000043400000 2352 ERF C07600170000235200000 16180 ERF C07600170001618000000 16179 ERF C07600170001617900000 Motherwell Allotment Area C0760017

Powerline Design Specifications 7 420m – Powerline Alternative 1 (preferred) Length of Powerline 11 000m – Powerline Alternative 2 12 200m – Powerline Alternative 3 Powerline Capacity 22kV Powerline Servitude Width 12m 89 040m2 – Powerline Alternative 1 (preferred) Total Powerline Footprint 132 000m2 – Powerline Alternative 2 146 400m2 – Powerline Alternative 3 Powerline Road Access Jeeptrack access to each powerline pylon

Powerline Coordinates Powerline Corridor START 33° 43' 47.62" S 25° 36' 23.12" E Alternative 1 CENTRE 33° 45' 22.21" S 25° 37' 31.03" E (preferred) END 33° 46' 25.19" S 25° 39' 34.40" E Powerline Corridor START 33° 43' 47.62" S 25° 36' 23.12" E CENTRE 33° 44' 05.12" S 25° 39' 24.84" E Alternative 2 END 33° 46' 28.46" S 25° 39' 33.23" E “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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Powerline Corridor START 33° 43' 47.09" S 25° 36' 20.80" E CENTRE 33° 45' 20.33" S 25° 34' 02.32" E Alternative 3 END 33° 48' 02.41" S 25° 34' 27.04" E

SUMMARY OF THE PROPOSED SCARLET IBIS WEF AND ASSOCIATE POWERLINE CORRIDOR ALTERNATIVES

WEF POWERLINE CORRIDOR 1 POWERLINE CORRIDOR 2 POWERLINE CORRIDOR 3 PREFERRED ALTERNATIVE PREFERRED ALTERNATIVE ALTERNATIVE ALTERNATIVE NO-GO IMPACT CUMULATIVE WITHOUT WITH WITHOUT WITH WITHOUT WITH WITHOUT WITH ALTERNATIVE MITIGATION MITIGATION MITIGATION MITIGATION MITIGATION MITIGATION MITIGATION MITIGATION PLANNING & DESIGN PHASE 1.1.1.1: Inadequate planning for the transportation of turbine MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A N/A and powerline parts could lead to traffic congestion 1.1.1.2: Degradation of existing road MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A N/A infrastructure due to heavy vehicle traffic 1.1.1.3: Inappropriate planning for the storage of hazardous MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A N/A substances could lead to surface and ground water pollution

GENERAL 1.1.1.4: Ground water contamination due to mixing of cement in LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A inappropriate areas on site 1.1.1.5: An increase in impermeable surfaces could lead to increased MODERATE - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A localised flooding and erosion 1.1.1.6: The loss of the Albany Adder due to disturbance of Coega N/A N/A HIGH - MODERATE - HIGH - MODERATE - N/A N/A N/A MODERATE - Bontveld bushclumps during the siting of the

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12m powerline servitude 1.1.1.7: The blocking or delaying of signal to MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A LOW - electronic devices caused by wind turbines 1.1.1.8: The movement of turbines could cause a phenomenon called shadow flicker, which could result in health impacts to individuals MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A MODERATE - exposed for extended periods of time to individuals exposed for extended periods of time 1.1.1.9: Conflict with the N/A N/A HIGH - MODERATE - HIGH - MODERATE - N/A N/A N/A MODERATE - Coega IDZ OSMP CONSTRUCTION PHASE 1.2.1.1: Dust associated with an increase in MODERATE - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A vehicles on site could result in health impacts

1.2.1.2: Noise pollution LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A 1.2.1.3: Unnecessary

GENERAL disturbance of vegetation due to LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A sprawl of campsite could cause a loss of biodiversity

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1.2.1.4: Inappropriate storage and handling of hazardous substances MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A N/A could lead to surface and ground water pollution 1.2.1.5: Littering and the use of informal ablution facilities by construction workers LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A could cause surface and ground water pollution 1.2.2.1: Loss of MODERATE - LOW - HIGH - LOW - HIGH - LOW - HIGH - LOW - LOW - MODERATE - Bontveld vegetation 1.2.2.2: Loss of Thicket LOW - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - vegetation 1.2.2.3: Removal of LOW MODERATE LOW MODERATE LOW MODERATE LOW MODERATE MODERATE MODERATE - Alien Vegetation + + + + + + + + + 1.2.2.4: Loss of Plant Species of MODERATE - LOW - HIGH - MODERATE - HIGH - MODERATE - HIGH - MODERATE - MODERATE - MODERATE - Conservation Concern 1.2.2.5: Loss of Faunal MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - SCCs

ECOLOGICAL 1.2.2.6: Poaching of HIGH - LOW - HIGH - LOW - HIGH - LOW - HIGH - LOW - N/A LOW - Wildlife 1.2.2.7: Fragmentation of vegetation and edge LOW - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - effects 1.2.2.8: Dust as a result MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - of wind erosion 1.2.2.9: Noise pollution LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A on faunal groups “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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1.2.3.1: Management of MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A N/A hazardous chemicals 1.2.3.2: Loss of Livestock and Wildlife MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A MODERATE -

Grazing 1.2.3.3: Soil MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A MODERATE - Compaction 1.2.3.4: Increase in Soil MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - Erosion AGRICULTURAL 1.2.3.5: Management of MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A N/A Topsoil 1.2.3.6: Inappropriate and Inadequate MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A LOW - Rehabilitation 1.2.4.1: Destruction or MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A LOW - alteration of bird habitat 1.2.4.2: Disturbance of

AVIFAUNA birds during LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A construction

1.2.5.1: Loss of foraging habitat LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A MODERATE -

BATS 1.2.6.1: Loss or damage of MODERATE - LOW - LOW - LOW - LOW - LOW - MODERATE - LOW - N/A MODERATE - archaeologically significant features 1.2.6.2: Loss or HERITAGE damage of Colonial LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A LOW - Period / Contemporary farming infrastructure

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1.2.7.1: Disturbance,

damage or destruction LOW of fossil heritage during MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - + PALEO the construction phase of the WEF

1.2.8.1: Visual impact of construction activity MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - N/A N/A

VISUAL

1.2.9.1: Construction Phase Noise LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A LOW -

NOISE 1.2.10.1: Influx of jobseekers and the MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A N/A impact of temporary construction workers 1.2.10.2: Skills LOW MODERATE LOW MODERATE LOW MODERATE LOW MODERATE MODERATE development and LOW - + + + + + + + + + capacity building 1.2.10.3: Skills development of LOW MODERATE LOW MODERATE LOW MODERATE LOW MODERATE MODERATE LOW - SOCIAL supporting industries / + + + + + + + + + local SMMEs 1.2.10.4: Impacts on the MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE LOW - Local Economy + + + + + + + + + 1.2.10.5: Impacts on the Nelson Mandela Bay MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - N/A MODERATE - Metropolitan Municipality OPERATIONAL PHASE

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1.3.1.1: The WEF will contribute towards a

reduction in the need for fossil fuels resulting HIGH HIGH HIGH N/A N/A N/A N/A N/A N/A LOW - in an improved air + + + GENERAL quality and contributing toward the mitigation of climate change

1.3.2.1: Invasion of alien plant species LOW LOW LOW LOW LOW HIGH - HIGH - HIGH - HIGH - MODERATE - + + + + +

ECOLOGICAL 1.3.3.1: Increase in Soil MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - MODERATE - Erosion 1.3.3.2: Loss of AGRIC Potential Agricultural LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A- LOW - Land 1.3.4.1: Displacement of birds from the site LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A- MODERATE -

and barrier effects 1.3.4.2: Bird collision with turbine blades MODERATE - LOW - N/A- N/A- N/A- N/A- N/A- N/A- N/A- MODERATE - AVIFAUNA 1.3.4.3: Collision & electrocution on N/A N/A HIGH - LOW - HIGH - LOW - HIGH - MODERATE - N/A MODERATE - overhead powerlines 1.3.5.1: Bat mortalities

due to direct blade impact or barotrauma HIGH - MODERATE - N/A N/A N/A N/A N/A N/A N/A MODERATE - BATS during foraging activities

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1.3.6.1: Impact of wind turbines on sensitive LOW - LOW - N/A N/A N/A N/A N/A N/A N/A MODERATE - visual receptors

VISUAL 1.3.6.2: Shadow Flicker LOW - LOW - N/A N/A N/A N/A N/A N/A N/A LOW -

1.3.7.1: Noise generated by wind LOW - LOW - N/A N/A N/A N/A N/A N/A LOW - LOW - NOISE turbines 1.3.8.1: Job creation MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE LOW - + + + + + + + + + 1.3.8.2: Skills MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE development and LOW - + + + + + + + + + SOCIAL capacity building 1.3.8.3: Impacts on the MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE LOW - local economy + + + + + + + + + DECOMMISSIONING PHASE 1.4.1.1: Noise and Dust MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - MODERATE - Impacts on Fauna 1.4.1.2: Poaching of HIGH - LOW - HIGH - LOW - HIGH - LOW - HIGH - LOW - HIGH - MODERATE - Wildlife 1.4.1.2: Inadequate ECOLOGICAL Rehabilitation of MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - MODERATE - Vegetation 1.4.2.1: Job creation MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE + + + + + + + + + + 1.4.2.2: Impacts on

SOCIAL living and movement MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - patterns

BASIC ASSESSMENT REPORT

(For official use only)

File Reference Number:

Application Number:

Date Received:

Basic assessment report in terms of the Environmental Impact Assessment Regulations, 2014, promulgated in terms of the National Environmental Management Act, 1998(Act No. 107 of 1998), as amended.

Kindly note that:

1. This basic assessment report is a standard report that may be required by a competent authority in terms of the EIA Regulations, 2014 and is meant to streamline applications. Please make sure that it is the report used by the particular competent authority for the activity that is being applied for. 2. The report must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The report is in the form of a table that can extend itself as each space is filled with typing. 3. Where applicable tick the boxes that are applicable or black out the boxes that are not applicable in the report. 4. An incomplete report may be returned to the applicant for revision. 5. The use of “not applicable” in the report must be done with circumspection because if it is used in respect of material information that is required by the competent authority for assessing the application, it may result in the rejection of the application as provided for in the regulations. 6. This report must be handed in at offices of the relevant competent authority as determined by each authority. 7. No faxed or e-mailed reports will be accepted. 8. The report must be compiled by an independent environmental assessment practitioner (EAP). 9. Unless protected by law, all information in the report will become public information on receipt by the competent authority. Any interested and affected party should be provided with the information contained in this report on request, during any stage of the application process. 10. A competent authority may require that for specified types of activities in defined situations only parts of this report need to be completed.

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SECTION A: ACTIVITY INFORMATION

Has a specialist been consulted to assist with the completion of this section? YES NO

If YES, please complete form XX for each specialist thus appointed:

Any specialist reports must be contained in Appendix D.

 APPENDIX D1: Agriculture & Soils Impact Assessment  APPENDIX D2: Avifaunal Impact Assessment  APPENDIX D3: Bat Impact Assessment  APPENDIX D4: Ecological Impact Assessment  APPENDIX D5: Heritage Impact Assessment  APPENDIX D6: Noise Impact Assessment  APPENDIX D7: Paleontological Impact Assessment  APPENDIX D8: Visual Impact Assessment

1. ACTIVITY DESCRIPTION

Describe the activity, which is being applied for, in detail The proposed Scarlet Ibis WEF will consist of up to nine (9) wind turbines with an output capacity of between 2MW and 4.5MW per turbine. The total output of the proposed Scarlet Ibis WEF will be less than 20MW. This will be achieved by having up to 9 turbines with an output capacity of 2MW or by reducing the number of turbines with a higher output capacity (2.5MW-4.5MW). Due to ongoing technological advancements in the turbine development industry, the range of output for the proposed WEF has been set between 2.0MW and 4.5MW. As it stands, the preferred turbine model for this development is a 2.0MW turbine. Based on the current economics of the proposed project a minimum of eight (8) 2.0MW machines would be required to make the project economically viable. However, since the wind turbine market is rapidly evolving, should 4.5MW machines become more competitive for the project, the developer would like to retain flexibility on the maximum output of each turbine authorised. The following categories of turbines are available for the proposed Scarlet Ibis WEF: Number of turbine models per output available on the Turbine output Number of market at present capacity turbines required 54 models available from various manufacturers 2.00MW 9 14 models available from various manufacturers 2.05MW 9 4 models available from various manufacturers 2.10MW 9 4 models available from various manufacturers 2.20MW 9 18 models available from various manufacturers 2.30MW 8 4 models available from various manufacturers 2.35MW 8 4 models available from various manufacturers 2.40MW 8

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49 models available from various manufacturers 2.50MW 7 1 model available from various manufacturers 2.52MW 7 2 models available from various manufacturers 2.60MW 7 2 models available from various manufacturers 2.65MW 7 2 models available from various manufacturers 2.70MW 7 5 models available from various manufacturers 2.75MW 7 1 model available from various manufacturers 2.78MW 7 3 models available from various manufacturers 2.85MW 7 58 models available from various manufacturers 3.00MW 6 1 model available from various manufacturers 3.05MW 6 1 model available from various manufacturers 3.10MW 6 3 models available from various manufacturers 3.15MW 6 16 models available from various manufacturers 3.20MW 6 1 model available from various manufacturers 3.23MW 6 11 models available from various manufacturers 3.30MW 6 9 models available from various manufacturers 3.40MW 5 2 models available from various manufacturers 3.43MW 5 11 models available from various manufacturers 3.45MW 5 5 models available from various manufacturers 3.50MW 5 12 models available from various manufacturers 3.60MW 5 1 model available from various manufacturers 3.63MW 5 1 model available from various manufacturers 3.64MW 5 1 model available from various manufacturers 3.83MW 5 2 models available from various manufacturers 3.90MW 5 1 models available from various manufacturers 3.96MW 5 5 models available from various manufacturers 4.00MW 4 7 models available from various manufacturers 4.20MW 4 4 models available from various manufacturers 4.50MW 4

The proposed 20MW Scarlet Ibis WEF will consist of the following infrastructural components:  Up to nine (9) wind turbines with a rotor diameter of up to 90m, a hub height of up to 100m and blade length of up to 45m, with a final total height of no more than 140m;  Turbine foundations of up to 400m² per turbine;  Crane hardstand areas of 3 500m2 per turbine;  A switchgear and/or transformer of 25m2 per turbine;  Internal access roads which will be 14m during the construction phase and will be rehabilitated to be 8m during the operational phase;  Medium voltage underground and/or overhead cabling between turbines and the switching station (to be laid underground where technically feasible);

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 A “Switching station and control area” of up to 7 500m2 which would consist of the electrical switching equipment, battery storage capacity, electrical compensation equipment, control room, communications, and storage;  22 kV powerline to connect the switching station to the Nelson Mandela Bay municipal grid: o Option 1: Coega Main substation, including two powerline alternatives as the potential connection point, or o Option 2: Motherwell Main substation, including one powerline alternative as the potential connection point.  Temporary infrastructure including a site camp and a laydown area of approximately 30m2 per turbine (all to be rehabilitated post construction). TABLE 1-1: LISTED ACTIVITIES TRIGGERED BY THE PROPOSED SCARLET IBIS WEF. LISTED ACTIVITIES RELEVANCE GN R. 327: Activity 1 The Scarlet Ibis WEF proposes to construct up to nine (9) wind The development of facilities or infrastructure turbines with an output capacity of between 2-4.5MW per for the generation of electricity from a turbine. The number of turbines and output will be altered renewable resource where – based on the model used and the total output capacity will be (i) The electricity output is more than 10 <20MW in total. megawatts but less than 20 megawatts. GN R. 327: Activity 12 The construction and expansion of roads will be undertaken The development of – within and within 32 metres of watercourses in places. The (ii) Infrastructure or structures with a physical roads will also guide the route of the underground cabling footprint of 100 square metres or more; connecting the turbines to the switching station. It is anticipated Where such development occurs – that this development will exceed 100 square metres in extent. (a) Within a watercourse. (c) If no development setback exists, within 32 metres of a watercourse, measured from the edge of the watercourse. GN R. 327: Activity 19 The construction of roads (specifically the roads and cabling The infilling or depositing of any material of paths linking WTG 01 to the access road; and the road linking more than 10 cubic metres into, or the WTG 07 to WTG 08) will require the infilling and depositing of dredging, excavation, removal or moving of material in excess of 10m3 during the construction period. soil, shells, shell grit, pebbles or rock of more than 10 cubic metres from a watercourse. GN R. 327: Activity 27 The construction of the Scarlet Ibis WEF and associated The clearance of an area of 1 hectares or infrastructure will require the clearing of indigenous vegetation. more, but less than 20 hectares of indigenous The total extent of the clearing will amount to approximately vegetation. 11.5ha. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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GN R. 327: Activity 28 The Scarlet Ibis WEF site (turbine sites) will be rezoned to Residential, mixed, retail, commercial, special industrial for the purposes of this development. The site industrial or institutional developments where is currently used for agriculture (grazing) and game farming in such land was used for agriculture, game places. The development is in excess of 1ha. farming, equestrian purposes or afforestation on or after 01 April 1998 and where such development: (ii) Will occur outside an urban area, where the total land to be developed is bigger than 1 hectare. GN R. 327: Activity 56 Roads will be upgraded to 14m for the purposes of the The widening of a road by more than 6 metres, construction phase (to accommodate large vehicles or the lengthening of a road by more than 1 transporting turbine parts). The total extent of the roads to be kilometre – widened/constructed to 14m is approximately 5.1km. The (ii) Where no reserve exists, where the existing roads will be rehabilitated to 8m after the completion of the road is wider than 8 metres. construction phase (for use during the operational phase). GN R. 324: Activity 4 Roads will be constructed to 14m for the purposes of the The development of a road wider than 4 metres construction phase (to accommodate large vehicles with a reserve less than 13.5 metres. transporting turbine parts). The total extent of the roads to be (a) Eastern Cape widened/constructed to 14m is approximately 5.1km. The (i) Outside urban areas: roads will be rehabilitated to 8m after the completion of the (bb) National Protected Area Expansion construction phase (for use during the operational phase). Strategy Focus areas; and (ee) Critical biodiversity areas as identified in Turbine WTG 08 is situated within a National Protected Area systematic biodiversity plans adopted by the Expansion Strategy Focus area (Baviaans-Addo NPAES, ID competent authority or in bioregional plans. 69) and the site is classified as a CBA 2. GN R. 324: Activity 10 The construction and operational phases of the proposed The development and related operation of Scarlet Ibis WEF will require the storage and handling of facilities or infrastructure for the storage, or dangerous goods on site. The volumes are expected to be: storage and handling of a dangerous good, CONSTRUCTION PHASE: 27.21m3 where such storage occurs in containers with a OPERATIONS PHASE: 42.86m3 combined capacity of 30 but not exceeding 80 cubic metres. Turbine WTG 08 is situated within a National Protected Area (a) Eastern Cape Expansion Strategy Focus area (Baviaans-Addo NPAES, ID (i) Outside urban areas: 69) and the site is classified as a CBA 2. (bb) National Protected Area Expansion Strategy Focus areas; and

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(ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans. GN R. 324: Activity 12 The proposed Scarlet Ibis WEF does not occur within a critical The clearance of an area of 300 square metres biodiversity area. or more of indigenous vegetation. (a) Eastern Cape All three powerline alternatives traverse areas classified as (ii) Within critical biodiversity areas identified in CBAs in terms of the Nelson Mandela Bay Bioregional Plan. bioregional plans. The total clearing footprint for each alternative has been calculated as follows (worst case scenario):

POWERLINE ALTERNATIVE 1 (preferred): 89 040m2 / 8.9ha POWERLINE ALTERNATIVE 2: 132 000 m2 / 13.2ha POWERLINE ALTERNATIVE 3: 146 400 m2 / 14.6ha

The vegetation disturbance for the construction and operation of the proposed 22kV powerline is as follows: a) Vegetation will need to be cleared at each pylon position; b) Vegetation will be trimmed beneath the overhead cabling; c) Vegetation will need to be cleared/trimmed to form a jeeptrack from which access must be available for each pylon for maintenance purposes. GN R. 324: Activity 14 The construction and expansion of roads will be undertaken The development of – within and within 32m of watercourses in places. The roads will (ii) Infrastructure or structures with a physical also guide the route of the underground cabling connecting the footprint of 10 square metres or more; turbines to the switching station. It is anticipated that this Where such development occurs – development will exceed 10 square metres in extent. The site (a) Within a watercourse. is situated in a CBA 2 and WTG 08 is situated within a National (a) Eastern Cape Protected Area Expansion Strategy Focus area (Baviaans- (i) Outside urban areas: Addo NPAES, ID 69). (bb) National Protected Area Expansion Strategy Focus areas; and (ff) Critical biodiversity areas or ecosystem services areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans.

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GN R. 324: Activity 15 The Scarlet Ibis WEF site (turbine sites) will be rezoned to The transformation of land bigger than 1 000 special industrial for the purposes of this development. The site square metres in size, to residential, retail, is currently zoned as an agriculture. The development is in commercial, industrial or institutional use, excess of 1 000m2. where, such land was zoned open space, conservation or had an equivalent zoning, on or after 02 August 2010. (a) Eastern Cape (i) Outside urban areas. GN R. 324: Activity 18 Roads will be upgraded to 14m for the purposes of the The widening of a road by more than 4 metres, construction phase (to accommodate large vehicles or the lengthening of a road by more than 1 transporting turbine parts). The total extent of the roads to be kilometre. widened/constructed to 14m is approximately 5.1km. The (a) Eastern Cape roads will be rehabilitated to 8m after the completion of the (i) Outside urban areas: construction phase (for use during the operational phase). The (bb) National Protected Area Expansion site is situated in a CBA 2 and WTG 08 is situated within a Strategy Focus areas; and National Protected Area Expansion Strategy Focus area (ee) Critical biodiversity areas or ecosystem (Baviaans-Addo NPAES, ID 69). services areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans.

DESCRIPTION OF THE WIND ENERGY FACILITY (WEF) (Please refer to Appendix A for illustration) The Scarlet Ibis WEF is proposed to comprise up to 9 turbines (2 and 4.5MW output each), for a total maximum output capacity of less than 20MW.

Wind energy is a form of solar energy. Winds are caused by the uneven heating of the atmosphere by the sun, the irregularities of the earth's surface, and rotation of the earth. Wind flow patterns are modified by the earth's terrain, bodies of water, and vegetation. This wind flow or motion energy (kinetic energy) can be used for generating electricity. The term “wind energy” describes the process by which wind is used to generate mechanical power or electricity. Wind turbines convert the kinetic energy in the wind into mechanical power and a generator can then be used to convert this mechanical power into electricity. The components of a typical wind turbine subsystem are shown in Figure 1-1 below:  A rotor, or blades, which are the portion of the wind turbine that collect energy from the wind and convert the wind's energy into rotational shaft energy to turn the generator. The speed of rotation of the blades is controlled by the nacelle, which can turn the blades to face into the wind (‘yaw control), and change the angle of the blades

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(‘pitch control’) to make the most use of the available wind. The maximum rotor diameter for the Scarlet Ibis WEF turbines is approximately 90m.  A nacelle (enclosure) containing a drive train, usually including a gearbox (some turbines do not require a gearbox) and a generator. The generator is what converts the turning motion of a wind turbine’s blades (mechanical energy) into electricity. Inside this component, coils of wire are rotated in a magnetic field to produce electricity. The nacelle is also fitted with brakes, so that the turbine can be switched off during very high winds, such as during storm events. This prevents the turbine from being damaged. All this information is recorded by computers and is transmitted to a control centre, which means that operators don't have to visit the turbine very often, but only occasionally for a mechanical check.  A tower, to support the rotor and drive train; The tower on which a wind turbine is mounted is not only a support structure, but it also raises the wind turbine so that its blades safely clear the ground and so can reach the stronger winds at higher elevations. The tower must also be strong enough to support the wind turbine and to sustain vibration, wind loading, and the overall weather elements for the life time of the turbine. The maximum hub height of the Scarlet Ibis WEF turbines is approximately 100m.  Electronic equipment such as controls, electrical cables, ground support equipment, and interconnection equipment.

FIGURE 1-1. ILLUSTRATION OF THE MAIN COMPONENTS OF A TYPICAL WIND TURBINE. NOTE THAT THE TRANSFORMER IN THE FIGURE ABOVE WOULD NORMALLY BE INSIDE THE TOWER (PROBABLY AT THE BASE). SOURCE: WWW.POWERNATURALLY.ORG

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Stages of Wind Farm Development

Typically, building a wind farm is divided into four phases namely:-  Preliminary civil works  Construction  Operation  Decommission

PRELIMINARY CIVIL WORKS Prior to the commencement of the main construction works, the Contractor will undertake vegetation clearance and site establishment works. The site establishment works may include the construction of one, or more, temporary construction compounds and laydown areas and the connection of services such as power and water to these compounds.

CONSTRUCTION The construction footprint will include the platforms, or “crane pads” required to construct the wind turbines, new or upgraded access roads, lay-bys, component storage areas, turning heads and a substation to evacuate the electricity generated to the municipal or national grid.

A typical platform for the assembly of the crane and construction of the turbine is shown in Figure 1-2. These platforms will be connected by access roads with the following requirements:-  Minimum of 8m width (5m running width and 1.5 m verge either side) on straight sections with widening required on corners.  Should a “crawler” type crane be used, then road widths of up to 14m on straight sections may be required, of which 8m would be retained for the life of the wind farm.  Typical 300mm deep road section  Maximum 10% vertical gradient on gravel roads  Turning heads provided within 200m of each crane pad.  Passing places of c. 50m length and 5m width located approximately every 1km

The construction footprint required will be greater than the dimensions specified above to allow for construction of the wind farm infrastructure. These areas are used temporarily over the construction period – including temporary construction compound and road verges – and will be rehabilitated at the end of construction works to reduce the footprint on the land.

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FIGURE 1-2: TYPICAL CONSTRUCTION PHASE PLATFORM

A platform of the dimensions indicated above needs to be laid down during the preliminary phase of a typical wind farm for access to the site during the construction phase by machines (bulldozers, trucks, cranes etc.).

Other works during the construction phase include: (a) Geotechnical studies and foundation works A geotechnical study of the area is undertaken for safety purposes. This comprises of drilling, penetration and pressure assessments. For the purpose of the foundations, approximately 1 500m3 of soil would need to be

www.dedea.gov.za excavated for each turbine. These excavations are then filled with steel-reinforced concrete (typically 45 tons of steel reinforcement per turbine including a “bolt ring” to connect the turbine foundation to the turbine tower). Foundation design will vary according to the type and quality of the soil.

(b) Electrical cabling Electrical and communication cables are laid approximately 1m deep in trenches which run alongside the access roads. All previous farming activities can continue unhindered on the ground above the cables during the operational phase. In some instances (for example crossing of a national road), overhead cabling will be used.

(c) Establishment of hard standing surfaces and laydown areas Laydown and storage areas will be required for the contractor’s construction equipment and turbine components on site.

(d) Site preparation If not carried out in the preliminary works phase, this will include clearance of vegetation over the access roads, platforms, lay-bys, substation and any other laydown or hard-standing areas. These activities will require the stripping of topsoil which will be stock-piled, back-filled and/or spread on site.

(e) Establishment of substation and ancillary infrastructure The establishment of these facilities/buildings will require the clearing of vegetation and levelling of the development site and the excavation of foundations prior to construction. A laydown area for building materials and equipment associated with these buildings will also be required.

(f) Turbine erection Weather permitting; the erection of the turbines can be completed swiftly and erection rates generally average 1-2 turbines per week. This phase is the most complex and costly.

(g) Undertake site remediation Once construction is completed and all construction equipment is removed, the site must be rehabilitated. On full commissioning of the facility, any access points to the site which are not required during the operational phase must be closed and rehabilitated.

Electrical Connection Each turbine is fitted with its own transformer that steps up the voltage to 22kV. The entire wind farm is then connected to the “point of interconnection” which is the electrical boundary between the wind farm and the municipal grid.

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OPERATIONAL PHASE During the period when the turbines are up and running, on-site human activity drops to a minimum, and includes routine maintenance requiring only light vehicles to access the site. Only major breakdowns would necessitate the use of cranes and trucks.

(a) Facility re-powering The Wind turbines are expected to have a lifespan of approximately 25 years (with appropriate maintenance). The infrastructure would only be decommissioned once it has reached the end of its economic or technological life. If economically feasible, the disassembly and replacement of the individual components with more appropriate technology/infrastructure available at the time will take place.

DECOMMISSIONING OF THE WIND FARM The infrastructure would only be decommissioned once it has reached the end of its economic or technological life. If economically feasible, the decommissioning activities would comprise the disassembly and replacement of the individual components with more appropriate technology/infrastructure available at the time. This operation is referred to as ‘facility re-powering’. However, if not deemed so, then the facility would be completely decommissioned which would include the following decommissioning activities.

(a) Site preparation Activities would include confirming the integrity of the access to the site to accommodate the required equipment and the mobilisation of decommissioning equipment.

(b) Disassemble all individual components The components would be disassembled and reused and recycled or disposed of in accordance with regulatory requirements.

DESCRIPTION OF THE POWERLINE OPTIONS TO CONNECT THE WEF SUBSTATION TO THE MUNICIPAL SUBSTATION (Please refer to Appendix A for illustration)

Powerline Corridor Alternative 1  Extent of powerline within corridor: 89 040m2 (12m width x 7.42km length)  Location: connecting the WEF to the Coega Substation via the Coega Industrial Development Zone (main landowner). Traverses Zone 14 and Zone 5.

Powerline Corridor Alternative 2  Extent of powerline within corridor: 132 000m2 (12m width x 11.0km length)  Location: connecting the WEF to the Coega Substation (Landowner: CDC) via rural land owned by the Nelson Mandela Bay Metropolitan (main landowner). Traverses Zone 14 and Zone 5.

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Powerline Corridor Alternative 3  Extent of powerline within corridor: 146 400m2 (12m width x 12.2km length)  Location: connecting the WEF to the Motherwell Substation via private land (with some land portions owned by the Nelson Mandela Bay Metropolitan) and adjacent to Motherwell.

PRELIMINARY CIVIL WORKS Prior to the commencement of the main construction works, the Contractor will undertake vegetation clearance and site establishment works.

CONSTRUCTION The construction footprint will include the powerline servitude (12m in width) in which the pylons, including any guy wires, will be erected.

OPERATIONAL PHASE During the period when the powerline is operating as the connection point between the WEF and the municipal grid, on-site human activity drops to a minimum, and includes routine maintenance requiring only light vehicles to access the site. Only major breakdowns would necessitate the use of cranes and trucks.

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2. FEASIBLE AND REASONABLE ALTERNATIVES

“alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to— (a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity.

Describe alternatives that are considered in this application. Alternatives should include a consideration of all possible means by which the purpose and need of the proposed activity could be accomplished in the specific instance taking account of the interest of the applicant in the activity. The no-go alternative must in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. After receipt of this report the competent authority may also request the applicant to assess additional alternatives that could possibly accomplish the purpose and need of the proposed activity if it is clear that realistic alternatives have not been considered to a reasonable extent.

Paragraphs 3 – 13 below should be completed for each alternative.

ANALYSIS OF ALTERNATIVES

FUNDAMENTAL, INCREMENTAL AND NO-GO ALTERNATIVES

Fundamental alternatives

Fundamental alternatives are developments that are totally different to the proposed project and usually include the following:  Alternative property or location where it is proposed to undertake the activity (i.e. site alternatives);  Alternative type of activity to be undertaken (i.e. land-use alternatives); and  Alternative technology to be used in the activity (i.e. technical alternatives).

Incremental alternatives

Incremental alternatives relate to modifications or variations to the design of a project that provide different options to reduce or minimise environmental impacts. The incremental alternatives that can be considered with respect to the current development project include:  Alternative design; or  Alternative layout of the activity.

No-go alternative

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The “no-go” alternative assumes that the status quo (i.e. the current state of the project area) will remain unchanged. The project area is situated east and west of the R335 and is located on agricultural (stock and game farming) and mining (kaolin quarries) land. The vegetation on site is classified as Thicket and Bontveld vegetation. The current vegetation conditions at the centre of the project area are relatively intact despite infestation of alien species. Degradation within the vegetated area is evident and is likely to be a result of grazing and/or browsing, dumping of waste, footpaths and mining activities. In addition, the project site is fragmented from intact sensitive vegetation by a number of roads and a servitudes. Should the proposed development not go ahead it is likely that alien vegetation will continue to spread and displace indigenous vegetation. Figure 2-1 and Figure 2-2 illustrate the current landcover in the proposed WEF and powerline areas (please note that as per the NMBM landcover categories, “Donut” refers to undeveloped land which was not yet classified at the time of publication of the NMBM Bioregional Plan).

FIGURE 2-1: LANDUSE MAP OF THE AREA SURROUNDING THE PROPOSED SCARLET IBIS WEF

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FIGURE 2-2: LANDUSE MAP OF THE AREA SURROUNDING THE PROPOSED SCARLET IBIS WEF POWERLINE

COMPARATIVE ASSESSMENT OF ALTERNATIVES Table 2-1 and 2-2 provides a comparative assessment of identified alternatives to the proposed activity, including advantages and disadvantages. An overall assessment is made concerning whether the identified alternatives are reasonable and feasible for the further assessment of impacts.

TABLE 2-1: WIND ENERGY FACILITY REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE Property or location Alternative location 1 -  Located close to  Land previously YES The main determining factors for selecting This refers to the Current proposed site existing necessary undeveloped the proposed location were:- fundamental location (Preferred alternative). NMBM electrical  Potential visual  Proximity to a grid connection point. options, and the infrastructure. intrusion to  Available land. environmental risks and This site has been selected  Suitable wind surrounding  Available wind resource. impacts associated with based on good wind resource. communities. such options. resource potential and  Land availability  Potential impacts Preliminary investigations have identified proximity to available (Scarlet Ibis Wind on avifauna and that the proposed project site meets the electricity grid. Energy and bats. above land specifications. landowners have formally agreed to the proposed development on the site and are in full support of the use of this area). Alternative location 2 -  N/A  N/A N/A  Alternative locations for the current None identified as rights to project are limited and probably not private land must be reasonable or feasible due to lower sought from local wind resources. landowners. Location 1  The connectivity to the grid is a critical has been agreed to. factor to the overall feasibility of the Alternative sites in the area project. do not yield the same wind  The available wind resource was resource potential. considered a critical aspect.  Therefore, alternative locations were not assessed. Type of technology Alternative energy  Clean and renewable  Visually intrusive YES The activity does not exclude all current This refers to the technology 1 – Wind energy.  Avifaunal impacts land uses i.e. Wildlife and stock grazing fundamental technology turbines (Preferred  Mitigate climate  Bat impacts can still take place between turbines. options, such as energy alternative) change generation from wind vs.  Does not require large coal fired power plant, etc. areas of land.

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TABLE 2-1: WIND ENERGY FACILITY REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE and the environmental Alternative energy  Clean and renewable  Visually intrusive NO Wind and solar are not mutually exclusive, risks and impacts technology 2 – Solar PV energy.  Requires large i.e. both developments can take place in associated with such  Mitigate climate area of land. close proximity to one another. The options. change. amount of land secured is not large enough to support a solar PV development. In terms of output, wind energy has a higher potential than solar PV based on suitable land available on the site. Alternative energy  Clean and renewable  Visually intrusive. NO Not enough intense radiation in the area to technology 3 – energy  Requires large be considered viable. The solar atlas Concentrated Solar Power  Mitigate climate area of land. shows the project area to occur in an area (CSP) change.  Water a limiting that receives <6.0 kWh/m2 of solar factor. radiation per day. Although favourable for  Reflectivity of solar radiation there are areas in South mirrors potentially Africa that receive between 7 and 8 a significant issue. kWh/m2 radiation per day which is preferable when compared to areas that receive 6kWh/m2 Alternative energy  None identified  Air pollution from NO Not environmentally desirable. technology 4 – Coal fired coal dust and power plant smoke stack emissions (SO2).  Contribution to climate change.

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TABLE 2-1: WIND ENERGY FACILITY REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE  Ground contamination from coal dust. Alternative energy  Clean and renewable  Expensive source NO Sufficient suitable biomass may not be technology 5 – biomass energy. of energy available in proximity to the site. Biomass  Mitigate climate energy is not mutually exclusive. change. Alternative energy  Greater electricity  Raw material NO The significant dependence of nuclear technology 6– nuclear generation with little highly radioactive energy generation on high volumes of power raw material required  Water availability a water preclude its development on the severe limitation. proposed site. Nuclear energy is not mutually exclusive. Design or layout Alternative layout 1:  The preliminary layout  There may be YES Considering the WEF layout: A maximum This relates mostly to Preliminary WEF layout, consisted of 10 impacts associated of 9 turbine structures have been alternative ways in which access route, electrical turbines which during with upgrading and assessed. The preferred layout (which has the proposed development switching stations and underwent a desktop expanding road undergone pre-screening) has been or activity can be short connecting powerline screening phase (by reserves in informed by the EIA process and physically laid out on the the proponent) and sensitive associated specialist assessments. Thus ground to minimise or was reduced to 9 environments. the final proposed WEF layout included in reduce environmental risks turbines and refined this BAR is the optimal layout from an or impacts during for assessment environmental perspective, where all as the preferred environmentally sensitive areas have been alternative. designated as NO-GO areas. 13. Due to Alternative layout 2  The preferred YES ongoing technological advancements in the Preferred WEF layout site alternative has turbine development industry, the range of access route, electrical undergone a rigorous output for the proposed WEF has been set

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TABLE 2-1: WIND ENERGY FACILITY REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE switching stations and environmental between 2.0MW and 4.5MW. As it stands, evacuation powerline assessment to confirm the preferred turbine model for this its suitability for the development is a 2.0MW turbine. Based on area. the current economics of the proposed project a minimum of eight (8) 2.0MW machines would be required to make the project economically viable. However, since the wind turbine market is rapidly evolving, should 4.5MW machines become more competitive for the project, the developer would like to retain flexibility on the maximum output of each turbine authorised. Operational aspects Alternative operational  Operational N/A YES N/A This relates mostly to activities Management alternative ways in which alternatives will be the development or informed by specialist activity can operate in input (e.g. bird and bat order to reduce monitoring) through environmental risks or on-going operational impacts monitoring. No-go option Small stock grazing and  Will remain relatively  No contribution YES Assessed in this report. This refers to the current small scale game farming. undisturbed. towards the status quo and the risks national renewable and impacts associated to energy target. it.

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TABLE 2-2: POWERLINE ALTERNATIVES REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE Property or location Powerline Corridor  This is the most direct  Vegetation YES The main determining factors for selecting This refers to the Alternative Location 1 - route to the Coega composition is the proposed location were:- fundamental location (Preferred alternative) Substation into which relatively intact as  Proximity to a grid connection point. options, and the This site has been selected the energy generated there has been  Available land. environmental risks and based on proximity to by the WEF can feed minimal  Length of route. impacts associated with available electricity grid for distribution development. such options. (Coega Substation). purposes.  Potential impacts  The proposed on avifauna. powerline corridor is  Will traverse the the shortest powerline Coega Open route from the Space proposed WEF to the Management Plan. Coega Substation.  The proposed route is situated away from civilisation which means that it has a lower risk of theft than Alternative 3. Powerline Corridor  A feasible route to the  Land largely YES The main determining factors for selecting Alternative Location 2 - Coega Substation into previously the proposed location were:- This site has been selected which the energy undeveloped  Proximity to a grid connection point. based on proximity to generated by the WEF  Potential impacts  Available land. available electricity grid can feed for on avifauna. (Coega Substation). distribution purposes.  Will traverse the  The proposed route is Coega Open situated away from “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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TABLE 2-2: POWERLINE ALTERNATIVES REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE civilisation which Space means that it has a Management Plan lower risk of theft than Alternative 3.

Powerline Corridor  This is the most direct  Potential security YES  Alternative Location 3 - route to the impacts due to its This site has been selected Motherwell Substation proximity to the based on proximity to into which the energy Motherwell available electricity grid generated by the WEF Township. Cable (Motherwell Substation). can feed for theft is an ongoing distribution purposes. problem in the Nelson Mandela Bay Metropolitan.  Potential impacts on avifauna. Powerline Alternative 3 has been assessed as having the highest potential impact in terms of avifauna.

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TABLE 2-2: POWERLINE ALTERNATIVES REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE Powerline Alternative  Close proximity to the  A powerline NO The Grassridge substation is a high Location 4 - proposed Scarlet Ibis connecting to the voltage transmission substation, which This powerline alternative WEF. Grassridge serves as the main source of power for the was selected based on the Substation would Nelson Mandela Metropolitan. The power proximity to the Grassridge not be feasible due transmitted through Eskom’s 400kV power Substation. to technical lines is then stepped down to 132kV to constraints feed the Metro’s network at the Chatty  No available substation. It is not technically or capacity at the commercially feasible to connect a project Grassridge of this size (<20MW at 22kV) to the Substation for an Grassridge substation considering the additional voltage levels. In addition the technical connection point. constraints, the Grassridge substation is  No available space saturated which means that there is no at the Grassridge available capacity at the substation for an Substation for additional connection and there is no additional available space at the substation for infrastructure additional infrastructure components. If components. there was capacity available at the Grassridge Substation then this would have been the preferred option for the proposed Scarlet Ibis WEF

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TABLE 2-2: POWERLINE ALTERNATIVES REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE Powerline Alternative  In agreement with the  High avifaunal NO Powerline Alternative 5 (runs from the Location 5 - Coega OSMP as this sensitivity proposed WEF to the Coega Substation This site has been selected is the services corridor  High wetland located in Zone 5 of the Coega IDZ in a based on a earmarked for sensitivity northeast and then southerly direction) was recommendation by the development.  Economically assessed during the Basic Assessment CDC. unfeasible for a process and was highlighted as having a project of the size. high avifaunal sensitivity due to the presence of Martial Eagle and Secretarybird nesting sites. In addition to the avifaunal sensitivity there are also numerous wetland situated along this route and the proposed 12m servitude will not be able to circumvent the wetland buffers. Finally, this powerline is approximately double the length of the preferred powerline which makes it unfeasible from an economic development perspective. This powerline was therefore considered to be unfeasible as an alternative.

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TABLE 2-2: POWERLINE ALTERNATIVES REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE Powerline Alternative  Short distance from  Not guaranteed to NO Powerline Alternative 6 (runs from the Location 6 - the proposed Scarlet be constructed proposed WEF to a newly proposed This site has been selected Ibis WEF  Not guaranteed substation situated near Grassridge) has based on proximity to the  Outside of the Coega that there would be been ruled out because this substation is newly proposed substation IDZ boundary available capacity yet to be constructed. The construction of near Grassridge. for another this substation is proposed by another developer developer named CEA and there are no  No timelines guarantees that the projects will eventually available. materialise. Moreover even if it was to materialise this substation would be owned by CEA and there is no guarantee that CEA will accommodate the proposed Scarlet Ibis WEF on their proposed substation. Type of technology Alternative Powerline  Does not require large  Avifaunal impacts, YES The activity does not exclude all current This refers to the Technology 1 – Overhead areas of land. specifically land uses e.g. wildlife and stock grazing fundamental technology (Preferred alternative)  Less invasive and less collision risk. can still take place between powerline options, such as overhead expensive pylons. The impact for this alternative is powerlines versus maintenance during higher from an avifaunal perspective, but underground powerlines operational phase. this can be mitigated through design and the environmental alternatives. The impacts in terms of risks and impacts vegetation clearance and maintenance of associated with such the powerline route are lower for this options. alternative.

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TABLE 2-2: POWERLINE ALTERNATIVES REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE Alternative Powerline  Safer alternative for  Impacts on NO This activity is not technically feasible for Technology 2 – avifauna, specifically wetlands and other this particular development due to the Underground with regards to watercourses. length of the proposed powerlines. The collision risk.  More intensive proposed powerline alternatives must vegetation connect at suitable substations in order to clearance required. fulfil their energy transfer. This technology  High impact during alternative has therefore not been operational phase considered as a feasible alternative for the due to disturbance proposed WEF connection. of top soil for maintenance purposes. Design or layout Powerline Alternative  More reliable material  More expensive YES Steel powerline pylons are more reliable This relates mostly to Design 1: in which maintenance than wooden and suitable for the proposed 22kV alternative ways in which Steel Powerline Pylons is less likely to be pylons. powerline. The material used means a low the proposed development required, which means chance of breakages and the pylons or activity can be less disturbance to themselves will not be damaged by fire. physically laid out on the fauna and flora in the ground to minimise or area. reduce environmental risks  Low risk of damage by or impacts fires Powerline Alternative  More expensive than  Less reliable NO Design 2: steel pylons material in which Wooden Powerline Pylons maintenance is more likely to be required, which means more “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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TABLE 2-2: POWERLINE ALTERNATIVES REASONABLE ALTERNATIVE LEVEL ALTERNATIVES ADVANTAGES DISADVANTAGES COMMENT & FEASIBLE disturbance to fauna and flora in the area.  Hirer risk of damage by fires No-go option Small stock grazing and  Will remain relatively  The proposed NOT Assessed in this report. This refers to the current small scale game farming undisturbed WEF will not be APPLICABLE status quo and the risks able to connect to and impacts associated to the distribution it. substations (Coega / Motherwell Substation)

CONCLUSION

Based on the findings of the assessment outlined in Table 2-1, it has been determined that the current proposal WEF (preferred option) is the only reasonable and feasible option to have been assessed in the Basic Assessment (BA) process, together with the No-Go option. In terms of the three powerline alternatives proposed (by the developer) and the three powerline alternatives proposed (by I&APs), it has been determined that alternatives 1 (preferred) and 2 are more favourable than alternatives 3, 4, 5 and 6. This conclusions is based on the following summary of the proposed alternatives:

a) Powerline Alternative 1 (runs from the proposed WEF to the Coega Substation located in Zone 5 of the Coega IDZ in a southeastly direction) was assessed in the report due to its proximity to the Coega substation and due to low avifaunal sensitivity. It has also been stipulated in the BA and the EMPr that should this powerline alternative be selected then various condition would have to be met prior to finalising the 12m servitude within the corridor. These stipulations include, herpetology ground truthing, botanical ground truthing, avoidance of all Coega Bontveld Bushclumps and the prioritisation of previously disturbed land for the siting of the powerline pylons. This powerline corridor traverses the following in terms of the OSMP: zone 14, zone 5, intact mesic succulent thicket, 1:100 year floodline and the Coega River and its associated riparian vegetation. We believe that by ensuring strict micrositing and cooperative decision-making by including the various specialists mentioned above the 12m servitude can be placed within this corridor. In addition to the decision- making process of the actual powerline siting, the vegetation clearance required for the pylon positions will have to take place under the supervision of a suitably qualified herpetologist and botanist. b) Powerline Alternative 2 (runs from the proposed WEF to the Coega Substation located in Zone 5 of the Coega IDZ in a northeast and then southerly direction) was assessed in the report due to its proximity to the Coega substation and due to low avifaunal sensitivity. The same conditions stated above would apply to the siting of the 12m powerline servitude within powerline corridor 2. Powerline alternative 2 has sensitive heritage sites which will also require circumvention during the siting of the 22kV powerline. This powerline corridor traverses the following in terms of the OSMP: zone 14, zone 5, intact mesic succulent thicket, intact Coega Bontveld (can be circumvented), rare butterfly habitat (can be circumvented), sensitive heritage sites (can be circumvented), 1:100 year floodline and the Coega River and its associated riparian vegetation. This powerline corridor is less attractive (from an environmental perspective) than powerline corridor 1 as it is longer and will therefore require more clearing for pylons. In addition to its length this powerline also has the potential of traversing intact Coega Bontveld, sensitive butterfly habitat and sensitive heritage features. c) Powerline Alternative 3 (runs from the proposed WEF to the Motherwell Substation located in a southwestly direction) was assessed due to its proximity to the Motherwell substation. This alternative has subsequently been excluded as a feasible option due to high avifaunal sensitivity along the powerline corridor. In addition to the avifaunal impacts there are potential security issues along this route due to its proximity to the Motherwell Residential area. d) Powerline Alternative 4 (runs from the proposed WEF to the Grassridge Substation) was not assessed or considered during the Basic Assessment process due to the fact that there is no available capacity for an additional connection point and there is no available space for additional infrastructure components at the Grassridge Substation. In addition to this, a 22kV powerline would not be feasible at the Grassridge Substation due to technical constraints.

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e) Powerline Alternative 5 (runs from the proposed WEF to the Coega Substation located in Zone 5 of the Coega IDZ in a northeast and then southerly direction) was assessed during the Basic Assessment process and was highlighted as having a high avifaunal sensitivity due to the presence of Martial Eagle and Secretarybird nesting sites. In addition to the avifaunal sensitivity there are also numerous wetland situated along this route and the proposed 12m servitude will not be able to circumvent the wetland buffers. Finally, this powerline is approximately double the length of the preferred powerline which makes it unfeasible from an economic development perspective. This powerline was therefore considered to be unfeasible as an alternative. f) Powerline Alternative 6 (runs from the proposed WEF to a newly proposed substation situated near Grassridge) was not considered a feasible alternative due to the fact there is no guarantee that the CEA project will proceed and no clear timelines for this project. There is also no guarantee that CEA will accommodate the proposed Scarlet Ibis WEF on their proposed substation.

3. ACTIVITY POSITION

Indicate the position of the activity using the latitude and longitude of the centre point of the site for each alternative site. The co-ordinates should be in degrees and decimal minutes. The minutes should have at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection. List alternative sites if applicable. WEF Alternative: Latitude (S): Longitude (E): Alternative S11 (preferred or only site alternative)- Central Point 33o 43’15.18” 25o 35’59.56” Northern Point 33o 41’23.66” 25o 36’28.30” Eastern Point 33o 43’53.90” 25o 37’04.06” Southern Point 33o 44’48.73” 25o 36’13.45” Western Point 33o 42’20.56” 25o 34’32.44” Alternative S2 (if any) o ‘ o ‘ Alternative S3 (if any) o ‘ o ‘

In the case of linear activities: Alternative: Latitude (S): Longitude (E): Powerline Alternative Option S1 (preferred)  Starting point of the activity 33o 43’47.62” 25o 36’23.12”  Middle point of the activity 33o 45’22.21” 25o 37’31.03”  End point of the activity 33o 46’25.19” 25o 39’34.40”

1 “Alternative S..” refer to site alternatives. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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Powerline Alternative Option S2  Starting point of the activity 33o 43’47.62” 25o 36’23.12”  Middle point of the activity 33o 44’05.12” 25o 39’24.84”  End point of the activity 33o 46’28.46” 25o 39’33.23” Powerline Alternative Option S3  Starting point of the activity 33o 43’47.09” 25o 36’20.80”  Middle point of the activity 33o 45’20.33” 25o 34’02.32”  End point of the activity 33o 48’02.41” 25o 34’27.04”

For route alternatives that are longer than 500m, please provide an addendum with co-ordinates taken every 250 meters along the route for each alternative alignment. – Please refer to Appendix G: Other information, ADDENDUM 1: POWERLINE ALTERNATIVE COORDINATES 4. PHYSICAL SIZE OF THE ACTIVITY

Indicate the physical size of the preferred activity/technology as well as alternative activities/technologies (footprints): Alternative: Size of the activity: WEF Alternative A12 (preferred activity 115 000m2 / 11.5ha alternative) FACILITY CONSTRUCTION FINAL FOOTPRINT AFTER COMPONENT FOOTPRINT REHABILITATION Dimensions Dimensions Primary laydown area 2 2 2 2 3 500m x 9 turbines = 31 500m 3 500m x 9 turbines = 31 500m (crane and blade laydown) which equates to 3.15ha which equates to 3.15ha Dimensions To be rehabilitated 2 2 Temporary infrastructure 30m x 9 turbines = 270m which equates to 0.03ha Dimensions Dimensions Turbine foundation 400m2 x 9 turbines = 3 600m2 400m2 x 9 turbines = 3 600m2 which equates to 0.36ha which equates to 0.36ha Dimensions Dimensions Switching gear 25m2 x 9 turbines = 225m2 25m2 x 9 turbines = 225m2 which equates to 0.02ha which equates to 0.02ha Dimensions Dimensions Roads and underground cabling 14m x 5140m = 71 960 m2 8m x 5140m = 41 120m2 which equates to 7.19ha which equates to 4.11ha TOTAL TOTAL Switching Station and Control Area 7 500 m2 7 500 m2 which equates to 0.75ha which equates to 0.75ha 11.5ha = 115 000m2 8.39ha = 83 900m2 TOTAL FOOTPRINT of clearing needed for the construction of clearing remaining during the post- phase of the development of the proposed construction operational phase (after WEF rehabilitation)

2 “Alternative A..” refer to activity, process, technology or other alternatives. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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Alternative A2 (if any) m2 Alternative A3 (if any) m2 or, for linear activities: Alternative: Length of the activity: Powerline Alternative A1 (preferred activity 7 420m alternative) Powerline Alternative A2 (if any) 11 000m Powerline Alternative A3 (if any) 12 200m

Indicate the size of the alternative sites or servitudes (within which the above footprints will occur): Alternative: Size of the site/servitude: Powerline Alternative A1 (preferred powerline alternative) 89 040m2 / 8.9ha (12m width x 7 420m length) Powerline Alternative A2 (if any) 132 000m2 / 13.2ha (12m width x 11 000m length) Powerline Alternative A3 (if any) 146 400m2 / 14.6ha (12m width x 12 200m length)

5. SITE ACCESS

Does ready access to the site exist? YES NO If NO, what is the distance over which a new access road will be built m

Describe the type of access road planned:

The existing R335 route will be used as access to the site. The northern turbines (Turbine 7 and 8) will exit off the R335 to the left, and the southern turbines (Turbines 1, 2, 3, 4, 5, 6 and 9) will exit off the R335 to the right of the road. Internal access roads will be upgraded and constructed to ensure that they are 14m wide during the construction period to accommodate the turbine transportation vehicles and will be rehabilitated to 8m during the operational phase.

Include the position of the access road on the site plan and required map, as well as an indication of the road in relation to the site.

6. SITE OR ROUTE PLAN

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A detailed site or route plan(s) must be prepared for each alternative site or alternative activity. It must be attached as APPENDIX A to this document.

The site or route plans must indicate the following: 6.1 the scale of the plan which must be at least a scale of 1:500;

6.2 the property boundaries and numbers of all the properties within 50 metres of the site;

6.3 the current land use as well as the land use zoning of each of the properties adjoining the site or sites;

6.4 the exact position of each element of the application as well as any other structures on the site;

6.5 the position of services, including electricity supply cables (indicate above or underground), water supply pipelines, boreholes, street lights, sewage pipelines, storm water infrastructure and telecommunication infrastructure;

6.6 all trees and shrubs taller than 1.8 metres;

6.7 walls and fencing including details of the height and construction material;

6.8 servitudes indicating the purpose of the servitude;

6.9 sensitive environmental elements within 100 metres of the site or sites including (but not limited thereto):

. rivers; . the 1:100 year flood line (where available or where it is required by DWA); . ridges; . cultural and historical features; . areas with indigenous vegetation (even if it is degraded or invested with alien species);

6.9 for gentle slopes the 1 metre contour intervals must be indicated on the plan and whenever the slope of the site exceeds 1:10, the 500mm contours must be indicated on the plan; and

6.10 the positions from where photographs of the site were taken.

Please refer to APPENDIX A: Site Plan(s).

7. SITE PHOTOGRAPHS Colour photographs from the centre of the site must be taken in at least the eight major compass directions with a description of each photograph. Photographs must be attached under Appendix B to this form. It must be supplemented with additional photographs of relevant features on the site, if applicable.

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Please refer to APPENDIX B: Photographs.

8. FACILITY ILLUSTRATION

A detailed illustration of the activity must be provided at a scale of 1:200 as APPENDIX C for activities that include structures. The illustrations must be to scale and must represent a realistic image of the planned activity. The illustration must give a representative view of the activity.

Please refer to APPENDIX C: Facility Illustrations.

9. ACTIVITY MOTIVATION

9(a) Socio-economic value of the activity

What is the expected capital value of the activity on completion? R 250 000 000

What is the expected yearly income that will be generated by or as a result of the activity? R 35 000 000

Will the activity contribute to service infrastructure? YES NO

Is the activity a public amenity? YES NO

How many new employment opportunities will be created in the development phase of the 1 100 person activity? months

(46 – 50 individuals)

What is the expected value of the employment opportunities during the development R 15 000 000 phase?

What percentage of this will accrue to previously disadvantaged individuals? 80%

How many permanent new employment opportunities will be created during the 1 300 person operational phase of the activity? months

(1 – 5 individuals)

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What is the expected current value of the employment opportunities during the first 10 R 10 000 000 years?

What percentage of this will accrue to previously disadvantaged individuals? 80%

* NOTE: EXPLAINATION OF “PERSON MONTHS” – A “person month” is the metric for expressing the effort (amount of time) employees devote to a specific project. This is usually calculated over a calendar year.

9(b) Need and desirability of the activity

Motivate and explain the need and desirability of the activity (including demand for the activity): Increasing pressure is being placed on countries internationally to reduce their reliance on fossil fuels, such as oil and coal, which contribute towards greenhouse gases being emitted into the atmosphere and thus climate change. Renewable energy resources such as wind energy facilities and solar PV farms are being implemented as alternative sources of energy at a global scale.

Climate Change South Africa has recognised the need to expand electricity generation capacity within the country. This is based on national policy and informed by ongoing planning undertaken by the Department of Energy (DoE) and the National Energy Regulator of South Africa.

Most of South Africa’s energy comes from non-renewable sources like coal, petroleum, natural gas, propane, and uranium. It is estimated that approximately only 1% of the country’s electricity is currently generated from renewable energy sources. South Africa‘s total emissions were estimated to be 461 million tonnes CO2 equivalent in the year 2000. Approximately 83% of these emissions were associated with energy supply and consumption, 7% from industrial processes, 8% from agriculture, and 2% from waste. The South African Government recognises the need to diversify the mix of energy generation technologies within the country and to reduce the country’s reliance on fossil fuels which contribute towards climate change and are therefore not environmentally friendly. This is in accordance with the prescriptions of the United Nations Convention on Climate Change 1994 (UNFCCC) and its associated Kyoto protocol of 1997. South Africa has put in place a long term mitigation scenario (LTMS) by which the country aims to develop a plan of action which is economically viable and internationally aligned to the world effort on climate change. During this period (2003-2050) South Africa will aim to take action to mitigate greenhouse gas emissions by 30% - 40% by the year 2050. This is a reduction of between 9000 and 17 500 tons of CO2 by 2050. Consequently, the South African Government has set a target of 17 GW renewable energy contribution to new power generation capacity by 2030 (IRP, 2011). This is to be produced from wind, solar, biomass and small- scale hydro facilities. The Scarlet Ibis WEF will be the first of its kind in South Africa, contributing to the local energy supply and grid stability in the Nelson Mandela Bay Metropolitan outside of the IRP process within South Africa.

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Electricity supply in South Africa South Africa’s current electricity generation and supply system is strained with the Eastern Cape Province constrained by the availability and stability of electricity supply, reliant on the import of power from other provinces. Under the Renewable Energy Independent Power Producer Procurement Programme (REIPPPP). Currently, fossil fuels supply 90% of South Africa’s energy needs with demands on energy supply increasing by 3.5% in the next 20 years.

The Eastern Cape Sustainable Energy Strategy (The Eastern Cape Sustainable Energy Strategy, 2012) commits the Province to achieving a minimum of 2% of energy from renewable sources by 2025. The Scarlet Ibis WEF will provide additional electricity and greater grid stability within the Nelson Mandela Bay Metropolitan outside of the REIPPPP hereby directly contributing towards the Eastern Cape Sustainable Energy Strategy.

Social and Economic Development Scarlet Ibis Wind Power intends to promote local economic growth and development through direct and indirect employment, as well as the identification and implementation of social development schemes during the projects operational phase.

The above main drivers for renewable energy projects are supported by the following recent International, National and Provincial (Eastern Cape) policy documents.

International

The 1992 United Nations Framework Convention on Climate Change (UNFCCC) The UNFCCC is a framework convention which was adopted at the 1992 Rio Earth Summit. South Africa signed the UNFCCC in 1993 and ratified it in August 1997. The stated purpose of the UNFCCC is to, “achieve….stabilisation of greenhouse gas concentrations in the atmosphere at concentrations at a level that would prevent dangerous anthropogenic interference with the climate system”, and to thereby prevent human-induced climate change by reducing the production of greenhouse gases defined as, “those gaseous constituents of the atmosphere both natural and anthropogenic, that absorb and re-emit infrared radiation”.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF The UNFCCC is relevant in that the proposed Scarlet Ibis WEF project will contribute to a reduction in the production of greenhouse gases by providing an alternative to fossil fuel-derived electricity. South Africa has committed to reducing emissions to demonstrate its commitment to meeting international obligations.

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The Kyoto Protocol (2002) The Kyoto Protocol is a protocol to the UNFCCC which was initially adopted for use on 11 December 1997 in Kyoto, Japan, and which entered into force on 16 February 2005 (UNFCCC, 2009). The Kyoto Protocol is the chief instrument for tackling climate change. The major feature of the Protocol is that it sets binding targets for 37 industrialized countries and the European community for reducing greenhouse gas (GHG) emissions. This amounts to an average of 5% against 1990 levels over the five-year period 2008-2011. The major distinction between the Protocol and the Convention is that, “while the Convention encouraged industrialised countries to stabilize GHG emissions, the Protocol commits them to do so”.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF The Kyoto Protocol is relevant in that the proposed Scarlet Ibis WEF project will contribute to a reduction in the production of greenhouse gases by providing an alternative to fossil fuel-derived electricity, and will assist South Africa to begin demonstrating its commitment to meeting international obligations in terms of reducing its emissions.

National

National Development Plan (2011) The National Development Plan (NDP) (also referred to as Vision 2030) is a detailed plan produced by the National Planning Commission in 2011 that is aimed at reducing and eliminating poverty in South Africa by 2030. The NDP represents a new approach by Government to promote sustainable and inclusive development in South Africa, promoting a decent standard of living for all, and includes 12 key focus areas, those relevant to the current proposed WEF being:  An economy that will create more jobs.  Improving infrastructure.  Transition to a low carbon economy.

Sector Target • South Africa needs an additional 29,000 MW of electricity by 2030. About 10,900 MW of existing capacity will be retired, implying new build of about Electrical infrastructure 40,000 MW. • About 20,000 MW of this capacity should come from renewable sources.  Achieve the peak, plateau and decline greenhouse gas emissions trajectory by Transition to a low carbon 2025. economy  About 20,000 MW of renewable energy capacity should be constructed by

2030.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF

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The proposed Scarlet Ibis WEF will contribute towards additional energy capacity in South Africa and will contribute towards a reduction in greenhouse gas emissions.

National Climate Change Response White Paper (2012) The White Paper indicates that Government regards climate change as one of the greatest threats to sustainable development in South Africa and commits the country to making a fair contribution to the global effort to achieve the stabilisation of greenhouse gas concentrations in the atmosphere at a level that prevents dangerous anthropogenic interference with the climate system.

The White Paper also identifies various strategies in order to achieve its climate change response objectives, including:  The prioritisation of mitigation interventions that significantly contribute to an eventual decline emission trajectory from 2036 onwards, in particular, interventions within the energy, transport and industrial sectors.  The prioritisation of mitigation interventions that have potential positive job creation, poverty alleviation and/or general economic impacts. In particular, interventions that stimulate new industrial activities and those that improve the efficiency and competitive advantage of existing business and industry.

The White Paper provides numerous specific actions for various Key Mitigation Sectors including renewable energy. The following selected strategies (amongst others) must be implemented by South Africa in order to achieve its climate change response objectives:  The prioritisation of mitigation interventions that significantly contribute to a peak, plateau and decline emission trajectory where greenhouse gas emissions peak in 2020 to 2025 at 34% and 42% respectively below a business as usual baseline, plateau to 2035 and begin declining in absolute terms from 2036 onwards, in particular, interventions within the energy, transport and industrial sectors.  The prioritisation of mitigation interventions that have potential positive job creation, poverty alleviation and/or general economic impacts. In particular, interventions that stimulate new industrial activities and those that improve the efficiency and competitive advantage of existing business and industry.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF The proposed Scarlet Ibis WEF project will provide an alternative to fossil fuel-derived electricity, and will contribute to climate change mitigation.

Integrated Energy Plan for the Republic of South Africa (2003) The former Department of Minerals and Energy (DME) commissioned the Integrated Energy Plan (IEP) in response to the requirements of the National Energy Policy in order to provide a framework by which specific energy policies, development decisions and energy supply trade-offs could be made on a project-by-project basis. The framework is intended to create a balance between energy demand and resource availability so as to provide low cost electricity for social and economic development, while taking into account health, safety and environmental parameters.

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In addition to the above, the IEP recognised the following:-  South Africa is likely to be reliant on coal for at least the next 20 years as the predominant source of energy.  New electricity generation will remain predominantly coal based but with the potential for hydro, natural gas, renewables and nuclear capacity.  Need to diversify energy supply through increased use of natural gas and new and renewable energies.  The promotion of the use of energy efficiency management and technologies.  The need to ensure environmental considerations in energy supply, transformation and end use.  The promotion of universal access to clean and affordable energy, with the emphasis on household energy supply being coordinated with provincial and local integrated development programme.  The need to introduce policy, legislation and regulations for the promotion of renewable energy and energy efficiency measures and mandatory provision of energy data.  The need to undertake integrated energy planning on an on-going basis.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF The Scarlet Ibis WEF is in line with the IEP with regards to diversification of energy supply and the promotion of universal access to clean energy.

Long Term Mitigation Scenarios (2007) The aim of the Long Term Mitigation Scenarios (LTMS) was to set the pathway for South Africa’s long-term climate policy and will eventually inform a legislative, regulatory and fiscal package that will give effect to the policy package at a mandatory level. The overall goal is to “develop a plan of action which is economically risk-averse and internationally aligned to the world effort on climate change.”

The strategy assesses various response scenarios but concludes that the only sustainable option (“the preferred option”) for South Africa is the “Required by Science” scenario where the emissions reduction targets should target a band of between -30% to -40% emission reductions from 2003 levels by 2050 which includes increasing renewable energy in the energy mix by 50% by 2050.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF The proposed Scarlet Ibis WEF will contribute towards an overall reduction in emissions and aligns with the world stance on efforts towards the mitigation of climate change.

Indicate any benefits that the activity will have for society in general: The proposed Scarlet Ibis WEF will stabilise the municipal grid in the Nelson Mandela Bay Metropolitan and will contribute to South Africa and the Eastern Cape’s green energy targets.

Indicate any benefits that the activity will have for the local communities where the activity will be located:

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The Scarlet Ibis WEF will contribute new employment opportunities to the amount of 1 100 persons per month during the construction phase and 1 300 persons per month during the operational phase. 80% of the Scarlet Ibis WEF financial targets will be dedicated to previously disadvantaged individuals.

10. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES

List all legislation, policies and/or guidelines of any sphere of government that are applicable to the application as contemplated in the EIA regulations, if applicable:

TITLE OF LEGISLATION, POLICY OR GUIDELINE: ADMINISTERING AUTHORITY: DATE: Department of Environmental Affairs (DEA) or the Eastern Cape National Environmental Management Act (NEMA, Act No. 107 Department of Economic 1998 of 1998) and its subsequent amendments Development, Environmental Affairs and Tourism (DEDEAT) Department of Environmental Affairs National Environmental Management Act (NEMA, Act No. 107 (DEA) or the Eastern Cape of 1998) Environmental Impact Assessment (EIA) Regulations Department of Economic 2017 (as amended in 2017) Development, Environmental Affairs and Tourism (DEDEAT) Constitution Act (Act No. 108 of 1996) Republic of South Africa 1996 Eastern Cape Provincial Heritage National Heritage Resources Act (NHRA, Act No. 25 of 1999) 1999 Resources Authority (ECPHRA) National Water Act (NWA, Act No. 36 of 1998) and its Department of Water and Sanitation 1998 subsequent amendments (DWS) Department of Environmental Affairs (DEA) or the Eastern Cape National Environmental Management: Biodiversity Act Department of Economic 2004 (NEMBA, Act No. 10 of 2004) Development, Environmental Affairs and Tourism (DEDEAT) Department of Environmental Affairs (DEA) or the Eastern Cape National Environmental Management: Biodiversity Act, Alien Department of Economic 2014 and Invasive Species Regulations (2014) Development, Environmental Affairs and Tourism (DEDEAT) Conservation of Agricultural Resources Act (Act No. 43 Department of Agriculture, Forestry 1983 of 1983) and Fisheries (DAFF)

Nelson Mandela Bay Metropolitan Open Space System – NMB Nelson Mandela Bay Municipality 2015 MOSS as gazetted in the NMBM Bioregional Plan (2015) Occupational Health and Safety Act (OHSA, Act No. 85 of 1993) Department of Labour (DoL) 1993 Hazardous Substances Act (HS, Act No. 15 of 1973) Department of Health (DoH) 1973

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Eastern Cape Department of Eastern Cape Vision 2030 Provincial Development Plan Economic Development, 2014 (ECDP, 2014) Environmental Affairs and Tourism (DEDEAT) Local Government: Municipal Systems Act (Act No. 32 of 2000) Nelson Mandela Bay Municipality 2000 Nelson Mandela Bay Metropolitan Spatial Development Nelson Mandela Bay Municipality 2015 Framework (NMBM SDF, 2015) Nelson Mandela Bay Municipality Integrated Development Plan Nelson Mandela Bay Municipality 2016 (IDP, 2016/17 – 2020/21) South African Vegetation Map (Mucina and Rutherford, 2012) South African National Biodiversity 2006 / and Vegetation Descriptions (2006) Institute (SANBI) 2012 South African National Biodiversity Subtropical Thicket Ecosystem Programme (STEP, 2006) 2006 Institute (SANBI) Eastern Cape Department of Economic Development, Eastern Cape Biodiversity Conservation plan (ECBCP, 2007) 2007 Environmental Affairs and Tourism (DEDEAT) Department of Water and Sanitation 2011/ National Freshwater Ecosystem Priority Areas (NFEPA) (DWS) 2014

* PLEASE NOTE THAT ALL APPLICABLE LEGISLATION HAS BEEN DETAILED BELOW

The development of the proposed Scarlet Ibis WEF will be subject to the requirements of various items of South African legislation. These are described below.

The Constitution Act (No. 108 of 1996) This is the supreme law of the land. As a result, all laws, including those pertaining to the proposed development, must conform to the Constitution. The Bill of Rights - Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, everyone has the right: (a) To an environment that is not harmful to their health or well-being. (b) To have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that: (i) Prevent pollution and ecological degradation. (ii) Promote conservation. (iii) Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  The WEF developer has an obligation to ensure that the proposed activity will not result in pollution and ecological degradation.  The WEF developer has an obligation to ensure that the proposed activity is ecologically sustainable, while demonstrating economic and social development. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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National Environmental Management Act (No. 107 of 1998) The National Environmental Management Act (No. 107 of 1998) (NEMA) provides for basis for environmental governance in South Africa by establishing principles and institutions for decision-making on matters affecting the environment.

A key aspect of NEMA is that it provides a set of environmental management principles that apply throughout the Republic to the actions of all organs of state that may significantly affect the environment. Section 2 of NEMA contains principles (see Table 10-1) relevant to the proposed WEF project, and likely to be utilised in the process of decision making by DEA.

Table 10-1. NEMA Environmental Management Principles Environmental management must place people and their needs at the forefront of its concern, and serve (2) their physical, psychological, developmental, cultural and social interests equitably. (3) Development must be socially, environmentally and economically sustainable. Sustainable development requires the consideration of all relevant factors including the following: i. That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied; (4)(a) ii. That pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; iii. That waste is avoided, or where it cannot be altogether avoided, minimised and re-used or recycled where possible and otherwise disposed of in a responsible manner. Responsibility for the environmental health and safety consequences of a policy, programme, project, (4)(e) product, process, service or activity exists throughout its life cycle. The social, economic and environmental impacts of activities, including disadvantages and benefits, must (4)(i) be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment. The right of workers to refuse work that is harmful to human health or the environment and to be informed (4)(j) of dangers must be respected and protected. The costs of remedying pollution, environmental degradation and consequent adverse health effects and (4)(p) of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment. Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, (4)(r) wetlands, and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure.

As these principles are utilised as a guideline by the competent authority in ensuring the protection of the environment, the proposed development should, where possible, be in accordance with these principles. Where this is not possible, deviation from these principles would have to be very strongly motivated.

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NEMA introduces the duty of care concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. A failure to perform this duty of care may lead to criminal prosecution, and may lead to the prosecution of managers or directors of companies for the conduct of the legal persons.

Employees who refuse to perform environmentally hazardous work, or whistle blowers, are protected in terms of NEMA.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  The WEF developer is mindful of the principles, broad liability and implications associated with NEMA and must eliminate or mitigate any potential impacts.  The WEF developer is mindful of the principles, broad liability and implications of causing damage to the environment.

National Environment Management: Biodiversity Act (No. 10 of 2004) The National Environment Management: Biodiversity Act (No. 10 of 2004) (NEMBA) provides for the management and conservation of South Africa’s biodiversity and the protection of species and ecosystems that warrant national protection.

The objectives of this Act are to:  Provide, within the framework of the National Environmental Management Act.  Manage and conserve of biological diversity within the Republic.  Promote the use of indigenous biological resources in a sustainable manner.

The Act provides for the management and conservation of South Africa’s biodiversity within the framework of the National Environmental Management Act 107 of 1998. In terms of the Biodiversity Act, the developer has a responsibility for: 1 The conservation of endangered ecosystems and restriction of activities according to the categorisation of the area (including The Endangered and Threatened Ecosystem Regulations, Government Notice R. 1002 dated 9th December 2011). 2 Application of appropriate environmental management tools in order to ensure integrated environmental management of activities thereby ensuring that all developments within the area are in line with ecological sustainable development and protection of biodiversity. 3 Limit further loss of biodiversity and conserve endangered ecosystems.

The Act’s permit system is further regulated in the Act’s Threatened or Protected Species Regulations Government Notice R. 152 of 23 February 2007.

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RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  The WEF developer must not cause a threat to any endangered ecosystems and must protect and promote biodiversity;  The WEF developer must assess the impacts of the proposed development on endangered ecosystems;  The WEF developer may not remove or damage any protected species without a permit; and  The WEF developer must ensure that the site is cleared of alien vegetation using appropriate means (AIS Regulations, Government Notice R. 598 of 1st April 2014 are applicable)

National Environmental Management: Waste Management Act (No. 59 of 2008) The National Environmental Management: Waste Management Act (No. 59 of 2008) (NEMWMA) gives legal effect to the Government’s policies and principles relating to waste management in South Africa, as reflected in the National Waste Management Strategy (NWMS).

The objects of the Act are (amongst others) to protect health, well-being and the environment by providing reasonable measures for:  minimising the consumption of natural resources;  avoiding and minimising the generation of waste;  reducing, re-using, recycling and recovering waste;  treating and safely disposing of waste as a last resort;  preventing pollution and ecological degradation; and  securing ecologically sustainable development while promoting justifiable economic and social development.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  The WEF developer must ensure that all activities associated with the project address waste related matters in compliance with the requirements of the Act.  The WEF developer must consult with the local municipalities to ensure that waste is disposed of at a registered landfill site.

National Forests Act (No. 84 of 1998) The objective of this Act is to monitor and manage the sustainable use of forests. In terms of Section 12 (1) (d) of this Act and GN No. 1012 (promulgated under the National Forests Act), no person may, except under licence:  Cut, disturb, damage or destroy a protected tree.  Possess, collect, remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose of any protected tree or any forest product derived from a protected tree.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  If any protected trees or indigenous forest in terms of this Act occur on site, the WEF developer will require a licence from the Department of Forestry (DAFF) to perform any of the above-listed activities. Identification of protected trees will take place during micro-sighting prior to construction of the proposed WEF.

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National Heritage Resources Act (No. 25 of 1999) The protection of archaeological and paleontological resources is the responsibility of a provincial heritage resources authority and all archaeological objects, paleontological material and meteorites are the property of the State. “Any person who discovers archaeological or paleontological objects or material or a meteorite in the course of development 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”.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  ECPHRA needs to be informed of the project and BA process.  A heritage impact assessment (HIA) must be undertaken.  No person may alter or demolish any structure or part of a structure, which is older than 60 years or disturb any archaeological or paleontological site or grave older than 60 years without a permit issued by the relevant provincial heritage resources authority.  No person may, without a permit issued by the responsible heritage resources authority destroy, damage, excavate, alter or deface archaeological or historically significant sites.

Electricity Regulation Act (No. 4 of 2006) The Electricity Regulation Act (Act No. 4 of 2006) came into effect on 1 August 2006 and the objectives of this Act are to:  Facilitate universal access to electricity.  Promote the use of diverse energy sources and energy efficiencies.  Promote competitiveness and customer and end user choice.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  The proposed WEF is in line with the call of the Electricity Regulation Act No. 4 of 2006 as it is has the potential to improve energy security of supply through diversification.

Occupational Health and Safety Act (No. 85 of 1993) The objective of this Act is to provide for the health and safety of persons at work. In addition, the Act requires that, “as far as reasonably practicable, employers must ensure that their activities do not expose non-employees to health hazards”. The importance of the Act lies in its numerous regulations, many of which will be relevant to the proposed Scarlet Ibis WEF. These cover, among other issues, noise and lighting.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  The WEF developer must be mindful of the principles and broad liability and implications contained in the OHSA and mitigate any potential impacts.

Aviation Act (No. 74 of 1962): 13th Amendment of the Civil Aviation Regulations 1997

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Section 14 of obstacle limitations and marking outside aerodrome or heliport (CAR Part 139.01.33) under this Act specifically deals with wind turbine generators (wind farms). According to this section, “A wind turbine generator is a special type of aviation obstruction due to the fact that at least the top third of the generator is continuously variable and offers a peculiar problem in as much marking by night is concerned. The Act emphasizes that, when wind turbine generators are grouped in numbers of three or more they will be referred to as “wind farms”.

Of particular importance to the proposed Scarlet Ibis WEF project are the following:-  Wind farm placement: Due to the potential of wind turbine generators to interfere on radio navigation equipment, no wind farm should be built closer than 35 km from an aerodrome. In addition, much care should be taken to consider visual flight rules routes, proximity of known recreational flight activity such as hang gliders, en-route navigational facilities etc.  Wind farm markings: Wind turbines shall be painted bright white to provide the maximum daytime conspicuousness. The colours grey, blue and darker shades of white should be avoided altogether. If such colours have been used, the wind turbines shall be supplemented with daytime lighting, as required.  Wind farm lighting: Wind farm (3 or more units) lighting: In determining the required lighting of a wind farm, it is important to identify the layout of the wind farm first. This will allow the proper approach to be taken when identifying which turbines need to be lit. Any special consideration to the site’s location in proximity to aerodromes or known corridors, as well as any special terrain considerations, must be identified and addressed at this time.  Turbine Lighting Assignment: The following guidelines should be followed to determine which turbines, need to be equipped with lighting fixtures. Again, the placement of the lights is contingent upon which type of configuration is being used.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  Due to requirements of the Act to ensure the safety of aircrafts, the WEF developer must engage directly with the Civil Aviation Authority regarding the structural details of the facility.

National Environmental Management: Air Quality Act (No. 39 of 2004) The National Environmental Management: Air Quality Act (No. 39 of 2004) (NEMAQA) is the principal legislation regulating air quality in South Africa. The objects of the Act are to:  Give effect to Section 24(b) of the Constitution in order to enhance the quality of ambient air for the sake of securing an environment that is not harmful to the health and well-being of people, and  Protect the environment by providing reasonable measures for:  Protection and enhancement of the quality of air in the Republic.  Prevention of air pollution and ecological degradation.  Securing ecologically sustainable development while promoting justifiable economic and social development.

The Air Quality Act empowers the Minister to establish a national framework for achieving the objects of this Act. The said national framework will bind all organs of state. The said national framework will inter alia have to establish national standards for municipalities to monitor ambient air quality and point, non-point and mobile emissions.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF

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 Although no major air quality issues are expected, the WEF developer needs to be mindful of the Act as it also relates to potential dust generation during construction, etc.

National Water Act (No. 36 of 1998) The National Water Act (No. 36 of 1998) (NWA) provides for fundamental reform of the law relating to water resources in South Africa.

The purpose of the Act amongst other things is to:  Ensure that the national water resources are protected, used, developed, conserved, managed and controlled in ways which take into account amongst other factors: o Promoting equitable access to water. o Promoting the efficient, sustainable and beneficial use of water in the public interest. o Facilitating social and economic development. o Protecting aquatic and associated ecosystems and their biological diversity. o Reducing and preventing pollution and degradation of water resources.

The NWA is concerned with the overall management, equitable allocation and conservation of water resources in South Africa. To this end, it requires registration of water users and licenses to be obtained for water use except for certain limited instances set out in the Act. These instances include domestic use, certain recreational use, where the use occurs in terms of an existing lawful use or where the Department of Water Affairs (DWA) has issued a general authorisation that obviates the need for a permit.

Water use for which a permit is required For the purposes of this Act, water uses for which a permit is required (amongst other), are defined in Section 21 as follows:  Taking water from a water resource.  Storing water.  Impeding or diverting the flow of water in a watercourse.  Discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduit.  Disposing of waste in a manner which may detrimentally impact on a water resource.  Altering the bed, banks, course or characteristics of a watercourse.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  There may be certain instances where the WEF developer may need to obtain approval in terms of the Water Act.

Conservation of Agricultural Resources Act (No. 43 of 1983) The Conservation of Agricultural Resources Act (No. 43 of 1983) (CARA) is the main statute that deals with agricultural resource conservation.

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The objects of the Act are to provide for the conservation of the natural agricultural resources of South Africa by the maintenance of the production potential of land. In order to maintain production potential of land, CARA provides for the following mechanisms; namely:  Combating and prevention of erosion and weakening and destruction of water sources.  Protection of vegetation.  Combating of weeds and invader plants.

CARA Regulations In order to give meaning to mechanisms aimed maintaining production potential of land provided for in CARA, Minister of Agriculture published regulations under CARA (CARA Regulations) which prescribes control measures which all land users have to comply, in respect of a number of matters, including the:  Cultivation of virgin soil.  Protection of cultivated land.  Utilisation and protection of the veld.  Control of weed and invader plants.  Prevention and control of veld fires and the restoration and reclamation of eroded land.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  An agricultural potential assessment must be conducted to determine how the proposed development may impact on the agricultural production potential of the WEF site.

Subdivision of Agricultural Land Act (No. 70 of 1970) The Subdivision of Agricultural Land Act (No. 70 of 1970) controls the subdivision of all agricultural land in South Africa and prohibits certain actions relating to agricultural land. In terms of the Act, the owner of agricultural land is required to obtain consent from the Minister of Agriculture in order to subdivide agricultural land.

The purpose of the Act is to prevent uneconomic farming units from being created and degradation of prime agricultural land. The Act also regulates leasing and selling of agricultural land as well as registration of servitudes.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  Approval will be required from the Department of Agriculture, Forestry and Fisheries (DAFF) for any activities on the land zoned for agriculture and any proposed rezoning or sub-divisions of agricultural land.

Mineral and Petroleum Resources Development Act (No. 28 of 2002) Mineral and Petroleum Resources Development Act (No. 28 of 2002) (MPRDA) makes provision for equitable access to and sustainable development of the South Africa’s mineral and petroleum resources and to provide for matters connected therewith.

The objects of this Act are (amongst others) to: “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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 Give effect to the principle of the State’s custodianship of the nation’s mineral and petroleum resources.  Promote equitable access to the nation’s mineral and petroleum resources to all the people of South Africa.  Give effect to section 24 of the Constitution by ensuring that the nation’s mineral and petroleum resources are developed in an orderly and ecologically sustainable manner while promoting justifiable social and economic development.

In addition, Section 53 of the Act requires that Ministerial approval is attained for “any person who intends to use the surface of any land in any way which may be contrary to any object of this Act or is likely to impede any such object”.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  The Scarlet Ibis WEF must apply to the Minister of Mineral Resources for approval to use the land for the purposes of the WEF.

National Road Traffic Act (No. 93 of 1996) The National Road Traffic Act (No. 93 of 1996) (NRTA) provides for all road traffic matters and is applied uniformly throughout South Africa. The Act enforces the necessity of registering and licensing motor vehicles. It also stipulates requirements regarding fitness of drivers and vehicles as well as making provision for the transportation of dangerous goods.

RELEVANCE TO THE PROPOSED SCARLET IBIS WEF  All the requirements stipulated in the NRTA will need to be complied with during the construction and operational phases of the proposed wind farm.

National Veld and Forest Fire Act (No. 101 of 1998) The aim of the Act is to “prevent and combat veld, forest and mountain fires” in South Africa. Of particular relevant to the proposed Scarlet Ibis WEF development the following requirements of the Act need to be considered:

Relevant Section of the Act Relevant to the proposed Scarlet Ibis WEF: The proposed Scarlet Ibis WEF must register as a member of Section 3: Fire Protection Associations. the fire protection association in the area. The proposed Scarlet Ibis WEF will be required to take all Chapter 4 Section 12-14: Veld fire practicable measures to ensure that fire breaks are prepared prevention: duty to prepare and maintain and maintained according to the specifications contained in firebreaks Section 12 - 14 The proposed Scarlet Ibis WEF must have the appropriate Section 17: Firefighting: readiness equipment, protective clothing and trained personnel for

extinguishing fires.

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Other Relevant National Legislation Other legislation that may be relevant to the proposed Scarlet Ibis WEF includes:  The Environment Conservation Act No 73 of 1989 (ECA) Noise Control Regulations, which specifically provide for regulations to be made with regard to the control of noise, vibration and shock, including prevention, acceptable levels, powers of local authorities and related matters;  The Telecommunication Act (1966) which has certain requirements with regard to potential impacts on signal reception; and  Provincial Nature and Environmental Conservation Ordinance (No. 19 of 1974), which lists species of special concern which require permits for removal. Schedules 1 to 4 list protected and endangered plant and animal species.  Spatial Planning and Land Use Management Act (SPLUMA) (Act 16 of 2013 – came into force on 1 July 2015) aims to provide inclusive, developmental, equitable and efficient spatial planning at the different spheres of the government. This act repeals national laws on the Removal of Restrictions Act, Physical Planning Act, Less Formal Township Planning Act and Development Facilitation Act.

11. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT

11(a) Solid waste management

Will the activity produce solid construction waste during the construction/initiation YES NO phase?

If yes, what estimated quantity will be produced per month? 18m3

How will the construction solid waste be disposed of (describe)?

The construction solid waste will be transported from site and disposed of at the closest registered landfill site. The solid waste will be disposed of by a subcontracted company called Skipwaste. Where will the construction solid waste be disposed of (describe)?

Registered landfill site as per municipal agreement. Will the activity produce solid waste during its operational phase? YES NO

If yes, what estimated quantity will be produced per month? m3

How will the solid waste be disposed of (describe)?

Where will the solid waste be disposed if it does not feed into a municipal waste stream (describe)?

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If the solid waste (construction or operational phases) will not be disposed of in a registered landfill site or be taken up in a municipal waste stream, then the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Can any part of the solid waste be classified as hazardous in terms of the YES NO relevant legislation? If yes, inform the competent authority and request a change to an application for scoping and EIA. Is the activity that is being applied for a solid waste handling or treatment facility? YES NO

If yes, then the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

11(b) Liquid effluent

Will the activity produce effluent, other than normal sewage, that will be disposed of in a YES NO municipal sewage system?

If yes, what estimated quantity will be produced per month? m3

Will the activity produce any effluent that will be treated and/or disposed of on site? Yes NO

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Will the activity produce effluent that will be treated and/or disposed of at another facility? YES NO

If yes, provide the particulars of the facility:

Facility name:

Contact person:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Describe the measures that will be taken to ensure the optimal reuse or recycling of waste water, if any:

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11(c) Emissions into the atmosphere

Will the activity release emissions into the atmosphere? YES NO

If yes, is it controlled by any legislation of any sphere of government? YES NO

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

If no, describe the emissions in terms of type and concentration:

11(d) Generation of noise

Will the activity generate noise? YES NO

If yes, is it controlled by any legislation of any sphere of government? YES NO

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

If no, describe the noise in terms of type and level:

The generation of noise by WEFs is governed by the Noise Control Regulations (GN R154 of 1992). In order to assess the type and level of noise generation by this facility, a Noise Impact Assessment was undertaken. Please refer to Appendix D for the full assessment.

The following is the executive summary from the noise assessment:

NOISE IMPACT FINDINGS AND MITIGATION MEASURES This study used the noise emission characteristics of the Vestas V136 3.45MW wind turbine, resulting in a worst-case scenario being evaluated.

Various construction activities would be taking place during the development of the facility and may pose a noise risk to the closest receptors. The resulting future noise projections indicated that the construction activities of the Wind Turbines, as modelled for the worst-case scenario will comply with the National “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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Noise Control Regulations for daytime activities, but may pose a noise risk of medium significance on NSD07 and NSD09 for night-time construction activities. With mitigation this potential noise impact can be reduced to a low significance (precautionary principle).

There is a very low risk of a noise impact during the construction of the access routes, underground and overhead power lines with a low risk of a noise impact during the operational phase. There is a low potential of a cumulative noise impact from other wind farms in the area.

With the input data as used, this assessment indicated that the potential noise impact would be of a low significance during the operational phase and therefore acceptable.

NOISE IMPACT RECOMMENDATIONS AND CONCLUSIONS The potential noise impact must again be evaluated should the layout be changed where any wind turbines are located closer than 1 000m from a confirmed NSD or if the developer decides to use a different wind turbine that has a sound power emission level higher than the Vestas WTG used in this report (sound power emission level exceeding 108dBA re 1pW).

Considering the modelled construction and operational noise levels, the projected noise levels will be acceptable. Considering the possible low significance of the noise impacts (with the mitigation for the construction activities as proposed), there is no reason that the development of the Scarlet Ibis WEF should not be authorised. 12. WATER USE

Please indicate the source(s) of water that will be used for the activity by ticking the appropriate box(es) municipal water board groundwater river, stream, dam other the activity will not use or lake water

If water is to be extracted from groundwater, river, stream, dam, lake or any other natural feature, please indicate the volume that will be extracted per month: litres

Does the activity require a water use permit from the Department of Water Affairs? YES NO

If yes, please submit the necessary application to the Department of Water Affairs and attach proof thereof to this application if it has been submitted.

* PLEASE NOTE THAT THE DWS WILL NOT PROCESS WATER USE LICENCE APPLICATIONS FOR WIND ENERGY FACILITIES UNTIL THE PROPOSED WEF HAS RECEIVED AUTHORISATION.

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13. ENERGY EFFICIENCY

Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient:

Construction Phase: If access to an existing power line is available, the site camp will connect to the existing power supply to provide power to the site camp. If not, diesel generators are typically used to power the site. At this stage this has not yet be decided.

Operational Phase: Not applicable as the facility will not require energy during the operational phase.

Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any:

Not applicable.

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SECTION B: SITE/AREA/PROPERTY DESCRIPTION

Important notes:

1. For linear activities (pipelines, etc.) as well as activities that cover very large sites, it may be necessary to complete this section for each part of the site that has a significantly different environment. In such cases please complete copies of Section B and indicate the area, which is covered by each copy No. on the Site Plan.

Section B Copy No. (e.g. 2 A):

2. Paragraphs 1 - 6 below must be completed for each alternative.

3. Has a specialist been consulted to assist with the completion of this YES NO section? If YES, please complete form XX for each specialist thus appointed:

All specialist reports must be contained in Appendix D.

COPY 1 - SECTION B: WIND ENERGY FACILITY

1. GRADIENT OF THE SITE

Indicate the general gradient of the site. Alternative S1: Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

Alternative S2 (if any): Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

Alternative S3 (if any): Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

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2. LOCATION IN LANDSCAPE

Indicate the landform(s) that best describes the site:

2.1 Ridgeline 2.2 Plateau 2.3 Side slope of hill/mountain 2.4 Closed valley 2.5 Open valley 2.6 Plain 2.7 Undulating plain / low hills 2.8 Dune 2.9 Seafront

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

Is the site(s) located on any of the following (tick the appropriate boxes)? Alternative S1: Alternative S2 (if Alternative S3 (if any): any):

Shallow water table (less than YES NO YES NO YES NO 1.5m deep)

Dolomite, sinkhole or doline YES NO YES NO YES NO areas

Seasonally wet soils (often close YES NO YES NO YES NO to water bodies) (Figure 3-1.1 below)

Unstable rocky slopes or steep YES NO YES NO YES NO slopes with loose soil (Figure 3- 2.1 below)

Dispersive soils (soils that YES NO YES NO YES NO dissolve in water)

Soils with high clay content (clay YES NO YES NO YES NO fraction more than 40%) (Figure 3-3.1 below)

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Any other unstable soil or YES NO YES NO YES NO geological feature (Figure 3-2.1 below)

An area sensitive to erosion YES NO YES NO YES NO (Figure 3-4.1 below)

If you are unsure about any of the above or if you are concerned that any of the above aspects may be an issue of concern in the application, an appropriate specialist should be appointed to assist in the completion of this section. (Information in respect of the above will often be available as part of the project information or at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by the Council for Geo Science may also be consulted).

FIGURE 3-1.1. HYDROLOGY MAP (WEF)

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FIGURE 3-2.1. STRUCTURALLY FAVOURABLE SOILS MAP (WEF)

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FIGURE 3-3.1. SOIL ASSOCIATION MAP (WEF)

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FIGURE 3-4.1. IDENTIFIED SOIL EROSION AREAS (WEF)

4. GROUNDCOVER

Indicate the types of groundcover present on the site:

4.1 Natural veld – good condition E 4.2 Natural veld – scattered aliens E 4.3 Natural veld with heavy alien infestation E 4.4 Veld dominated by alien species E 4.5 Gardens 4.6 Sport field 4.7 Cultivated land 4.8 Paved surface 4.9 Building or other structure 4.10 Bare soil

The location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s).

Natural veld Natural veld with Veld dominated Natural veld - good with scattered heavy alien by alien Gardens conditionE aliensE infestationE speciesE

Building or Sport field Cultivated land Paved surface Bare soil other structure

If any of the boxes marked with an “E “is ticked, please consult an appropriate specialist to assist in the completion of this section if the environmental assessment practitioner doesn’t have the necessary expertise.

A Vegetation Specialist was appointed to complete the Groundcover section of this report. Please find the full Vegetation Assessment Report attached as Appendix D: Ecological Impact Assessment Report, Specialist Reports.

The study area falls within the Thicket biome. The Thicket biome occurs within the Western and the Eastern Cape, and is one of the seven biomes found in South Africa (Knight and Cowling, 2003). Its distribution ranges down the coast, up the river valleys and into the dry mountainous areas of the South-west. Lubke (in Low and Rebelo,1998) describes the Thicket biome as a closed shrubland to low forest dominated by evergreen, sclerophyllous or succulent trees, shrubs and vines, where several of these species have stem spines. It is often dense, generally divided into strata and has little herbaceous cover. Some thicket types are referred to as “transitional thicket” due to them having similar floristic components with many other phytochoria (areas possessing a large number of endemic taxons) and occurring within almost all formal biomes (Low and Rebelo, 1998). The Thicket vegetation contains a small number of endemic species, most of which are succulents of karoo origin such as Plakkies (Crassula spp.) and Sheep Fig (Delosperma spp.) (Low and Rebelo, 1998).

SANBI VEGETATION MAP Mucina and Rutherford (2012) updated the National Vegetation map of 2006 as part of a South African National Biodiversity Institute (SANBI) funded project “…in order to provide floristically based vegetation units of South Africa,

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Lesotho and Swaziland at a greater level of detail than had been available before.” The map was developed using a wealth of data from several contributors and resulted in the best national vegetation map to date, the last being that of Acocks, developed over 50 years ago. The map and accompanying book describe each vegetation type in detail, along with the most important species, including endemic species and those that are biogeographically important. This is the most comprehensive data for vegetation types in South Africa. The accompanying shapefiles were updated in 2012.

The vegetation of the proposed study area consists of Sundays Thicket and Coega Bontveld (Figure 4-1.1).

Sundays Thicket This vegetation type occurs in the Eastern Cape Province and is characterised by undulating plains and low mountains and foothills covered with tall dense thicket. The Sundays Thicket is composed of a mosaic of predominantly spinescent species that include trees, shrubs and succulents. It is classified as ‘Least Threatened’ with a conservation target of 19%. Approximately 6% has been transformed by cultivation and urban development. Three (3) turbines are located within this vegetation type.

Coega Bontveld Coega Bontveld occurs on moderately undulating plains where a mosaic of low thicket (2-3m) built mainly of bushclumps grows. Secondary open grassland occurs over wide stretches. This unit is often restricted to ‘islands’ in a matrix of typical valley thicket. The species present are a mixture of Fynbos, Grassland and Succulent Karoo elements. The conservation status of this vegetation type is classified as ‘Least Threatened’. The conservation target (percent of area) as set by the NSBA is 19%. A total of 10% of this vegetation unit is protected in the Greater Addo Elephant National Park and almost 4% was protected in the private Grassridge Nature Reserve (which has recently been de-proclaimed). Some 4% of Coega Bontveld has been altered by cultivation and 2% by urbanisation. Six (6) turbines are located within this vegetation type.

However, it should be noted that the conservation status and significance of the Coega Bontveld has come under debate by various specialists and research scientists and is considered to be poorly protected. This is a result of its localised distribution in the Eastern Cape and due to the direct threat from mining activities in the area. Watson (2002) believes that development could push this vegetation type to near extinction unless it is properly managed.

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FIGURE 4-1.1: SANBI VEGETATION MAP OF THE PROPOSED SCARLET IBIS WEF (MUCINA & RUTHERFORD, 2012) (WEF)

SUBTROPICAL THICKET ECOSYSTEM PROGRAMME (STEP) The Subtropical Thicket Ecosystem Planning (STEP, 2006) Project aimed to identify priority areas that would ensure the long-term conservation of the subtropical thicket biome and to ensure that the conservation of this biome was considered in the policies and practices of the private and public sector that are responsible for land-use planning and the management of natural resources in the region (Pierce et al. 2005). STEP looked specifically at the thicket biome and provided a finer scale map of the study area than the Mucina and Rutherford map.

According to STEP, the study area is situated within the Grassridge Bontveld and the Sundays Valley Thicket vegetation units (Figure 4-2.1).

Grassridge Bontveld is a valley thicket mosaic type consisting of small patches of Sundays Valley Thicket in a matrix of veld that consists of a combination of species that are characteristic of fynbos (Acmadenia obtusata, Euryops ericifolius), succulent karoo (Pteronia incana) and grassland (Themeda triandra, Eustachys paspaloides). This unit “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za contains many highly localized endemics and is generally restricted to outcrops of limestone (Nanaga formation), often as ‘islands’ in a matrix of Valley Thicket. Several rare and localised endemic plant species occur here, such as Anginon rugosum, Bulbine inae, Euphorbia globosa, Lotononis micrantha and Rhombophyllum rhomboideum. This vegetation type is classified as ‘Currently Not Vulnerable’. Six (6) turbines are located within this vegetation type.

Sundays Valley Thicket is a vegetation type dominated by Schotia afra and Euclea undulata while Euphorbia ledienii and Aloe africana are reliable indicator species of this vegetation type. This vegetation type is classified as ‘Currently not vulnerable’. Three (3) turbines are located within this vegetation type.

According to STEP, Not Vulnerable ecosystems are those areas that could withstand loss of natural area through disturbance or development, however it is recommended that disturbance in these areas are kept to a minimum and that areas which have already been disturbed are utilised where feasible. It should be noted that the vegetation on site is surrounded by informal and formal developments and fragmented from other intact vegetation by the existing N2, access roads and a services servitude.

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FIGURE 4-2.1: REGIONAL VEGETATION MAP ILLUSTRATING THE VEGETATION TYPE FOUND WITHIN THE STUDY AREA AS CLASSIFIED BY STEP (2006) (WEF).

BIOREGIONAL CLASSIFICATION (EASTERN CAPE BIODIVERSITY CONSERVATION PLAN – ECBCP, 2007) The ECBCP is the first attempt of the Eastern Cape Province at detailed, low-level conservation mapping for land-use planning purposes. Specifically, the aims of the Plan were to map critical biodiversity areas through a systematic conservation planning process. The current biodiversity plan includes the mapping of priority aquatic features, land-use pressures, and critical biodiversity areas and develops guidelines for land and resource-use planning and decision- making. ECBCP, although mapped at a finer scale than the National Spatial Biodiversity Assessment (Driver et al., 2005) is still, for the large part, inaccurate and “coarse”. Therefore it is imperative that the status of the environment, for any proposed development MUST first be verified before the management recommendations associated with the ECBCP are considered (Berliner and Desmet, 2007).

The main outputs of the ECBCP are “critical biodiversity areas” or CBAs, which are allocated the following management categories: CBA 1 = Maintain in a natural state CBA 2 = Maintain in a near-natural state CBA 3 = Other natural areas: Functional landscapes

The study area is situated in an area classified as a Terrestrial CBA 2 (Figure 4-3.1) and an Aquatic CBA 2 (Figure 4- 4.1) by the ECBCP (2007).

Terrestrial CBA 2 areas are defined by the following aspects:  Endangered vegetation types identified through the ECBCP systematic conservation assessment;  Endangered vegetation types from STEP;  Endangered forest patches in terms of the National Forest Assessment;  All expert-mapped areas less than 25 000 ha in size (includes expert data from this project, STEP birds, SKEP, Wild Coast, Pondoland and marine studies);  All other forest clusters (includes 500 m buffers);  1 km coastal buffer strip;  Ecological corridors identified in other studies (e.g. from STEP, Wild Coast, Pondoland, WMA 12 SEA, etc.) and corridors mapped by experts; and  Ecological corridors identified by the ECBCP using an integrated corridor design for the whole Province;

Aquatic CBA 2 areas are defined by:  Important sub-catchments  Aquatic CBA 2 A2b Free-flowing rivers important for fish migration  Important estuaries

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The ECBCP (2007) also classifies various parcels of land into Land Management Classes broadly depending on their transformation status and ecological function. The ECBCP Land management classes’ map (Figure 4-5) for the study area shows that the study area is categorised largely as within a BLMC 2 – Near Natural Landscapes with very small portions within a BLCM 4 – Cultivated Land and other portions being classified as degraded. The recommended land use management for areas classified as such is described in Table 4-1.1 below.

The proposed Scarlet Ibis WEF is not in conflict with the ECBCP land use management recommendations as the turbines will not change the function of the landscape nor permanently transform significant portions of it. The CBA 2 area delineated by ECBCP is somewhat inconsistent with the state of the environment, as some of the areas within the study area are degraded and transformed to the point where it cannot be maintained in a near natural state.

FIGURE 4-3.1: TERRESTRIAL CRITICAL BIODIVERSITY AREAS (CBA) AS CLASSIFIED BY ECBCP (2007) (WEF)

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FIGURE 4-4.1: AQUATIC CRITICAL BIODIVERSITY AREAS (CBA) AS CLASSIFIED BY ECBCP (2007) (WEF)

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FIGURE 4-5.1: BLMC LAND MANAGEMENT CLASSES AS CLASSIFIED BY ECBCP (2007) (WEF)

TABLE 4-1.1: TERRESTRIAL CRITICAL BIODIVERSITY AREAS AND BIODIVERSITY LAND MANAGEMENT CLASSES AS DESCRIBED BY THE EASTERN CAPE BIODIVERSITY CONSERVATION PLAN (WEF) CBA Map Category Code BLMC Recommended Land Use Objective

PA1 Protected areas PA2 Natural Maintain biodiversity in as natural state as BLMC 1 landscapes possible. Manage for no biodiversity loss. Terrestrial CBA 1 (not T1 degraded)

Terrestrial CBA 1 Near-natural T1 BLMC 2 Maintain biodiversity in near natural state with (degraded) landscapes minimal loss of ecosystem integrity. No

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T2 transformation of natural habitat should be permitted. Terrestrial CBA 2 C1

ONA T3 Manage for sustainable development, keeping natural habitat intact in wetlands Functional Other natural areas BLMC 3 (including wetland buffers) and riparian landscapes ONA zones. Environmental authorisations should support ecosystem integrity.

Transformed Transformed areas TF BLMC 4 Manage for sustainable development. landscapes

LOCAL CLASSIFICATION (THE METROPOLITAN OPEN SPACE SYSTEM - MOSS, 2009) The Nelson Mandela Bay Municipality have implemented a systematic conservation assessment and plan to conserve a representative proportion of all biodiversity in the Municipality. To achieve this goal, a suite of Critical Biodiversity Areas (CBAs) and Critical Ecosystem Support Areas (CESAs) were identified. These areas, if safe guarded, will facilitate the long-term persistence of a representative portion of all biodiversity patterns, ecological processes and species of conservation concern (NMBM, 2009). This Conservation Plan was gazetted in March 2015 as part of the Metropolitan Bioregional Plan and is now widely used as the most recent and applicable fine scale conservation assessment in the NMBM.

Two (2) vegetation units are found in the study area, namely, Grassridge Bontveld and Sundays Valley Thicket and this vegetation unit is classified as “Vulnerable” (Figure 4-6.1).

Grassridge Bontveld is a subtropical Valley Thicket habitat unit consisting of small clumps of Sundays Valley Thicket in a matrix of veld that consists of a combination of species that are characteristic of fynbos (Acmadenia obtusata, Euryops ericifolius), succulent karoo (Pteronia incana) and grassland (Themeda triandra, Eustachys paspaloides). This unit contains many highly localized endemics and is found on the Alexandria Formation. Approximately 90.9% of the intact vegetation remains. This vegetation type is classified as ‘Vulnerable’. All the turbine positions (9) are located within this vegetation type.

Sundays Valley Thicket is a subtropical Valley Thicket habitat unit dominated by Boerboon (Schotia afra) and Gwarrie (Euclea undulata) trees. Suurnoors (Euphorbia ledienii) and the Uitenhage aalwyn (Aloe africana) are also reliable indicator species. This unit is generally present on red, loamy to clayey soils derived from the Sundays River and Kirkwood formations. Approximately 74.8% of the intact vegetation remains. This vegetation type is classified as ‘Vulnerable’. Portions of the linear infrastructure will affect this vegetation type.

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FIGURE 4-6.1: LOCAL VEGETATION MAP ILLUSTRATING THE VEGETATION TYPE FOUND WITHIN THE STUDY AREA AS CLASSIFIED BY NMB MOSS (2009) (WEF).

All proposed Turbines occur in this vulnerable ecosystem. The current status of where the turbines are placed is not in pristine condition due to anthropogenic impacts already present. Mitigation measures, stipulated in Chapter 8 of the Ecological Impact Assessment Report, should be implemented to prevent further loss of this ecosystem.

www.dedea.gov.za transformation threshold of the Ecosystem Status. The study area is not situated within a CBA or an Ecological Process Area, however the Coega Riverine Corridor traverse the site in various locations (Figure 4-7.1).

A river integrity assessment was conducted as part of the NMB Bioregional Plan conservation assessment, which rated the Coega River as not being intact (Stewart, 2009). Approximately 37.9 % of the river is lost due to anthropogenic activities including: drainage system alterations due to infrastructure development; bank modification, river canalisation; pollution caused by various surrounding sources such as runoff from urban areas and sediment load resulting from erosion. Despite the river being in a poor condition, further transformation and development impacts may result in the collapse of a functional state, no longer able to support biotic or abiotic process and ultimately no longer able to provide important ecological services. The river may not be able to sustain any further disturbance. The Coega River will not directly be affected by the proposed WEF.

FIGURE 4-7.1: NMB MOSS (2009) CLASSIFICATION OF CBAS, ESAS AND CORRIDORS (WEF)

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PROTECTED AREAS (NATIONAL PROTECTED AREAS EXPANSION STRATEGY, 2008) A number of formally and informally protected areas occurs in the surrounding areas of the study area. Informal Conservation Areas include the Tregathylyn Game Reserve. Formally protected areas include the Springs Local Authority Nature Reserve, Addo Elephant National Park and Swartkops Valley Authority Nature Reserve. These range from about 5 km to about 15 km from the study area. No formally and informally protected areas are found to occur within the study area.

Protected Areas Expansion strategy – Focus Areas A National Spatial Biodiversity Assessment (2004) highlighted the shortcomings in the protection of representative sample of the country‘s biodiversity and ecological process areas. The Protected Areas Expansion Strategy was developed in 2008 from this to increase conservation areas in order to meet national biodiversity targets, and outlined two strategies for expanding the current National Protected Areas: (1) For public land, the declaration of available, under- utilised and strategic parcels of public land in concordance with the relevant legal requirements for disposal of such land; and (2) For private land, contractual agreements with the affected landowners.

An area is considered important for expansion if it contributes to meeting biodiversity thresholds, maintaining ecological processes or climate change resilience. Forty-two focus areas for land-based protected area expansion have been identified and are composed of large, intact and fragmented areas suitable for the creation or expansion of large protected areas. Turbine WTG 08 is located in the Baviaans-Addo focus area (#3) in the Eastern Cape. This focus area includes vegetation types from no less than seven biomes and is an extremely important area for conserving ecological processes that support resilience to climate change. It also presents excellent opportunities for incorporating whole river reaches and irreplaceable river types in protected areas. There are opportunities for expanding the World Heritage Site- listed Baviaanskloof Megareserve, Groendal Nature Reserve and Addo Elephant National Park (NPAES, 2008).

It should however be noted that the development of the turbine footprint is small, on the outer boundary of the focus area and will not change the character of the area.

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FIGURE 4-8.1: MAP ILLUSTRATING THE PROTECTED AREAS EXPANSION FOCUS AREAS WITHIN THE STUDY AREA AND SURROUNDS (WEF).

SURFACE WATER FEATURES The NFEPA programme provides strategic spatial priorities for conserving South Africa’s freshwater ecosystems and supports sustainable use of water resources. These priority areas are called Freshwater Ecosystem Priority Areas, or FEPAs.

Wetland ecosystem types are used by NFEPA for representing natural examples of the diversity of wetland ecosystem types across South Africa. Wetlands of the same ecosystem type are expected to share similar functionality and ecological characteristics. Information used to classify wetlands as FEPAs included:  Ramsar status;  Known threatened frog and water bird occurrences; and  Expert knowledge on biodiversity importance.

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One (1) wetland (a Natural Bench Depression) has been identified approximately 540m north-west of WTG (03). None of the turbines or linear infrastructure are located within a wetland or within the 500m regulatory buffer of a wetland. The Coega River runs at its closest point approximately 780m south - west of the study area. Tributaries of the Coega River traverses the site at various locations (Figure 4-9.1) and the linear infrastructure will traverse one of the tributaries as well as a drainage line running through the property and will thus also occur within the 50m regulatory buffer of this tributary and drainage line.

A water use authorisation in terms of the National Water Act (Act 36 of 1998) sections 21 (c) and (i) will be required for all activities within 50m of a drainage line, river or tributary.

The Coega River covers a catchment area of 550km2 and a length of approximately 45km (SRK, 2007; Scherman, 2010). The Coega River is classified as an ephemeral system, and is located within the Mzimvubu to Tsitsikamma Water Management Area (WMA 7). In its lower reaches this river has been canalised mainly as a result of the establishment of an embankment composed of building rubble, and forms an estuary (Scherman Colloty and Associates, 2014). The PES of the Coega River is classified as a Category B: Largely natural with few modifications (NFEPA, 2014). The River conservation status is classified as E/F (i.e. seriously modified or critically/extremely modified). The Coega River has also been classified as a phase 2 NFEPA, identified by the NFEPA programme in moderately modified rivers. The condition of these Phase 2 FEPAs should not be degraded further, as they may in future be considered for rehabilitation once good condition FEPAs (in an A or B ecological category) are considered fully rehabilitated.

It should be noted that the main-stem Coega River will not directly be affected by the turbines or associated infrastructure.

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FIGURE 4-9.1: HYDROLOGICAL MAP ILLUSTRATING SURFACE WATER FEATURES WITHIN THE STUDY AREA (WEF).

5. LAND USE CHARACTER OF SURROUNDING AREA

Indicate land uses and/or prominent features that currently occur within a 500m radius of the site and give description of how this influences the application or may be impacted upon by the application:

5.1 Natural area 5.2 Low density residential 5.3 Medium density residential 5.4 High density residential 5.5 Informal residential 5.6 Retail commercial & warehousing 5.7 Light industrial “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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5.8 Medium industrial AN 5.9 Heavy industrial AN 5.10 Power station 5.11 Office/consulting room 5.12 Military or police base/station/compound 5.13 Spoil heap or slimes damA 5.14 Quarry, sand or borrow pit 5.15 Dam or reservoir 5.16 Hospital/medical centre 5.17 School 5.18 Tertiary education facility 5.19 Church 5.20 Old age home 5.21 Sewage treatment plantA 5.22 Train station or shunting yard N 5.23 Railway line N 5.24 Major road (4 lanes or more) N 5.25 Airport N 5.26 Harbour 5.27 Sport facilities 5.28 Golf course 5.29 Polo fields 5.30 Filling station H 5.31 Landfill or waste treatment site 5.32 Plantation 5.33 Agriculture 5.34 River, stream or wetland 5.35 Nature conservation area 5.36 Mountain, koppie or ridge 5.37 Museum 5.38 Historical building 5.39 Protected Area 5.40 Graveyard 5.41 Archaeological site 5.42 Other land uses (describe)

If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the proposed activity. N/A

If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the proposed activity. N/A “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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If YES, specify and explain:

If YES, specify:

If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the proposed activity. N/A If YES, specify and explain:

If YES, specify:

6. CULTURAL/HISTORICAL FEATURES

Are there any signs of culturally or historically significant elements, as YES NO defined in section 2 of the National Heritage Resources Act, 1999, (Act No. 25 of 1999), including Archaeological or palaeontological sites, on or close (within 20m) to the Uncertain site? If YES, Archaeological (Heritage) and Palaeontological Impact Assessment Reports have been completed for explain: this site. The next paragraph is a summary of the findings from each of the specialist assessments.

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Briefly explain ARCHAEOLOGICAL the findings of The area was surveyed by conducting spot checks along the existing internal gravel roads where the specialist: exposed surface areas allowed for investigation, these were very few over most of the area. Although the final layout of the proposed WEF was not available at the time of the survey the areas identified for the establishment of the nine turbines, new access roads and associated infrastructure were covered during the initial survey. Archaeological visibility was obscured by dense grass vegetation on the cleared hilltops and Sundays Valley Thicket that covered the rest of the properties. Photographs and the GPS co-ordinates were taken using a Garmin Oregon 650. The relevant GPS coordinates have been plotted on Google Earth generated maps. A brief overview of archaeological research within the wider region and relevant archaeological, heritage, and cultural impact assessments have been included as an overview to the possible archaeological, historical and other heritage resources that may occur within the proposed mining area.

Middle Stone Age stone artefacts occurred in most of the exposed and disturbed surface areas on the Farm Grassridge 226 (GRSA_1 – GRSA_19). This would generally be expected as the immediate and wider region is rich in the occurrence of Middle Stone Age as well as Early Stone Age archaeological material. Despite the area being covered in dense and mostly impenetrable Sundays Valley Thicket vegetation it is suffice to assume that stone artefacts will occur between the surface and 50 cm – 80 cm below the surface. Only one scatter of Middle Stone Age Stone artefacts was observed around the existing mining area on the Farm Welbedachtsfontein 300 (WELSA_1). This does not however indicate that no stone artefacts occur within the area, artefacts may not be visible at the surface owing to dense grass vegetation cover and Sundays Valley Thicket. It is therefore safe to assume that artefacts may be uncovered during the mining extension activities.

The built environment component included staff houses and the main farmhouse on the Farm Grassridge 226. These structures were built during the 1960’s (pers comm. the farm owner, Mr Snyman) and therefore are younger than 60 years and do not fall under the ambit of the NHRA 25 of 1999. The ruins of three homesteads and a brick paved gravel road were identified on the Farm Welbedachtsfontein to be older than 60 years.

The proposed development would have negative implications on the archaeological heritage remains documented within the proposed area during the construction phase of the development. The negative implications include the destruction of the surface scatters of stone artefacts and further occurrences that are not immediately visible. The recommendations must be considered as appropriate mitigation measures to protect and conserve the archaeological heritage remains observed within the proposed development area and further archaeological remains that may occur and are not immediately visible on the surface.

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PALAEONTOLOGICAL Over most of the study area the geology is masked by a thin veneers of calcrete, quaternary alluvium, soil and vegetation.

Where this is penetrated to a few metres depth by quarries and river courses it is revealed that it is underlain by palaeontologically rich and potentially important strata. These include marine Miocene to Pliocene strata of the Alexandria Formation, early Cretaceous marine strata of the Sundays River Formation and early Cretaceous fluvial deposits of the Kirkwood Formation. Considering the large size of holes excavated for the footings of wind turbines it seems likely that many, if not most of these, will penetrate deeply enough to disturb potentially fossil rich strata.

Excavation of footing holes should therefore be monitored, either by a palaeontologist or by an ECO trained by and in correspondence with a palaeontologist. This should be discussed between the palaeontologist, ECO and site engineer prior to the commencement of work.

Please find the full Archaeological and Paleontological Impact Assessment Reports attached as Appendix D: Specialist Reports. Will any building or structure older than 60 years be affected in any way? YES NO Is it necessary to apply for a permit in terms of the National Heritage YES NO Resources Act, 1999 (Act 25 of 1999)? If yes, please submit or, make sure that the applicant or a specialist submits the necessary application to SAHRA or the relevant provincial heritage agency and attach proof thereof to this application if such application has been made.

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COPY 2 - SECTION B: POWERLINE ALTERNATIVES

1. GRADIENT OF THE SITE

Indicate the general gradient of the site. Powerline Alternative 1 (Preferred): Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

Powerline Alternative 2: Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

Powerline Alternative 3: Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

2. LOCATION IN LANDSCAPE: POWERLINE ALTERNATIVE 1 (PREFERRED)

Indicate the landform(s) that best describes the site:

2.1 Ridgeline 2.2 Plateau 2.3 Side slope of hill/mountain 2.4 Closed valley 2.5 Open valley 2.6 Plain 2.7 Undulating plain / low hills 2.8 Dune 2.9 Seafront

2. LOCATION IN LANDSCAPE: POWERLINE ALTERNATIVE 2

Indicate the landform(s) that best describes the site:

2.1 Ridgeline 2.2 Plateau 2.3 Side slope of hill/mountain 2.4 Closed valley 2.5 Open valley 2.6 Plain

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2.7 Undulating plain / low hills 2.8 Dune 2.9 Seafront

2. LOCATION IN LANDSCAPE: POWERLINE ALTERNATIVE 3

Indicate the landform(s) that best describes the site:

2.1 Ridgeline 2.2 Plateau 2.3 Side slope of hill/mountain 2.4 Closed valley 2.5 Open valley 2.6 Plain 2.7 Undulating plain / low hills 2.8 Dune 2.9 Seafront

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

Is the site(s) located on any of the following (tick the appropriate boxes)? Powerline Powerline Powerline Alternative 1 Alternative 2: Alternative 3: (Preferred):

Shallow water table (less than YES NO YES NO YES NO 1.5m deep)

Dolomite, sinkhole or doline YES NO YES NO YES NO areas

Seasonally wet soils (often close YES NO YES NO YES NO to water bodies) (Figure 3-1.2 below)

Unstable rocky slopes or steep YES NO YES NO YES NO slopes with loose soil (Figure 3- 2.2 below)

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Dispersive soils (soils that YES NO YES NO YES NO dissolve in water)

Soils with high clay content (clay YES NO YES NO YES NO fraction more than 40%) (Figure 3-3.2 below)

Any other unstable soil or YES NO YES NO YES NO geological feature (Figure 3-2.2 below)

An area sensitive to erosion YES NO YES NO YES NO

FIGURE 3-1.2. HYDROLOGY MAP (POWERLINE ALTERNATIVES)

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FIGURE 3-2.2. STRUCTURALLY FAVOURABLE SOILS MAP (POWERLINE ALTERNATIVES)

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FIGURE 3-3.2. SOIL ASSOCIATION MAP (POWERLINE ALTERNATIVES)

4. GROUNDCOVER

Indicate the types of groundcover present on the site:

POWERLINE ALTERNATIVE 1 (PREFERRED)

The location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s).

Natural veld Natural veld with Veld dominated Natural veld - good with scattered heavy alien by alien Gardens conditionE aliensE infestationE speciesE

Building or Sport field Cultivated land Paved surface Bare soil other structure

POWERLINE ALTERNATIVE 2

The location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s).

Natural veld Natural veld with Veld dominated Natural veld - good with scattered heavy alien by alien Gardens conditionE aliensE infestationE speciesE

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Building or Sport field Cultivated land Paved surface Bare soil other structure

POWERLINE ALTERNATIVE 3

The location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s).

Natural veld Natural veld with Veld dominated Natural veld - good with scattered heavy alien by alien Gardens conditionE aliensE infestationE speciesE

Building or Sport field Cultivated land Paved surface Bare soil other structure

The grid connection corridors are located mainly within the Thicket biome with smaller portions within Azonal vegetation. Azonal vegetation (of the Albany Thicket biome) refer to the vegetation typical of climatic zones. The Thicket biome occurs within the Western and the Eastern Cape, and is one of the seven biomes found in South Africa (Knight and Cowling, 2003). Its distribution ranges down the coast, up the river valleys and into the dry mountainous areas of the South- west. Lubke (in Low and Rebelo,1998) describes the Thicket biome as a closed shrubland to low forest dominated by evergreen, sclerophyllous or succulent trees, shrubs and vines, where several of these species have stem spines. It is often dense, generally divided into strata and has little herbaceous cover. Some thicket types are referred to as “transitional thicket” “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za due to them having similar floristic components with many other phytochoria (areas possessing a large number of endemic taxons) and occurring within almost all formal biomes (Low and Rebelo, 1998). The Thicket vegetation contains a small number of endemic species, most of which are succulents of karoo origin such as Plakkies (Crassula spp.) and Sheep Fig (Delosperma spp.) (Low and Rebelo, 1998).

SANBI VEGETATION MAP The vegetation within the grid connection corridor alternatives consists mainly of Sundays Thicket and Coega Bontveld, with small portions occurring within Albany Alluvial vegetation (Figure 4-1.2).

Albany Alluvial Vegetation This vegetation unit typically occurs within the Eastern Cape Province between East London and Cape St Francis on wide floodplains (usually close to the coast where the topography becomes flatter) of the large rivers such as the Sundays, Zwartkops, Coega, Gamtoos, Baviaanskloof, Great Fish River etc. and is embedded within the Albany Thicket Biome. It occurs at altitudes ranging from 20–1 000m. Two major types of vegetation patterns are observed in these zones, namely riverine thicket and thornveld (Acacia natalitia). The riverine thicket tends to occur in the narrow floodplain zones in regions close to the coast or further inland, whereas the thornveld occurs on the wide floodplains further inland. The alluvial zones (recent alluvial deposits of various textures, but usually with high clay content) can become flooded following the west-east passage of frontal systems in autumn and winter or during intensive local storms in summer and has an Ia land type. Dominant species include Acacia natalitia, Cynodon dactylon, Cyperus papyrus, Pentzia incana, Phragmites australis, Salix mucronata, Schotia “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za afra and Sporobolus nitens. The conservation status of this vegetation type is classified as ‘Endangered’. The conservation target (percent of area) as set by the NSBA is 31%. Only about 6% statutorily conserved in the Greater Addo Elephant National Park, Baviaanskloof Wilderness Area, Loerie Dam, Springs, Swartkops Valley and Yellowwoods Nature Reserves and the Double Drift Reserve Complex, while about 2% has been protected in some eight private conservation areas. More than half of the area has been transformed for cultivation, urban development, road building and plantations. Alien invaders include Acacia saligna, Nerium oleander and Eucalyptus species. Very small portions of this vegetation unit crosses each of the three grid connection corridors.

FIGURE 4-1.2: SANBI VEGETATION MAP OF THE PROPOSED SCARLET IBIS WEF (MUCINA & RUTHERFORD, 2012) (POWERLINE ALTERNATIVES)

SUBTROPICAL THICKET ECOSYSTEM PROGRAMME (STEP) According to STEP, the study area is situated within the Grassridge Bontveld, Sundays Valley Thicket, Sundays Doringveld and Motherwell Karroid Thicket vegetation units (Figure 4-2.2).

Grassridge Bontveld is a valley thicket mosaic type consisting of small patches of Sundays Valley Thicket in a matrix of veld “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za that consists of a combination of species that are characteristic of fynbos (Acmadenia obtusata, Euryops ericifolius), succulent karoo (Pteronia incana) and grassland (Themeda triandra, Eustachys paspaloides). This unit contains many highly localized endemics and is generally restricted to outcrops of limestone (Nanaga formation), often as ‘islands’ in a matrix of Valley Thicket. Several rare and localised endemic plant species occur here, such as Anginon rugosum, Bulbine inae, Euphorbia globosa, Lotononis micrantha and Rhombophyllum rhomboideum. This vegetation type is classified as ‘Currently Not Vulnerable’.

Motherwell Karroid Thicket is a vegetation unit consisting mainly of thicket clumps that contain species typical of Sundays Valley Thicket and they occur in a matrix of succulent karoo, dominated by asbossie (Pteronia incana) and soon after fire, rooigras (Themeda triandra). Under these conditions this unit can be recognised from Mosaic with Grassland by the absence of Rhus pyroides. This unit is restricted to usually deep, red, loamy- to clayey soils, derived from the Alexandria and Bluewater Bay formations. It occurs mostly just above the floodplains of the local rivers and it is easily recognised by an abundance of Pteronia incana, often in combination with other karroid shrubs such as Felicia filifolia. Fynbos elements are absent. It harbours a rich component of geophytes and succulents, many of which are rare or localised endemics such as Apodolirion macowanii, Aloe bowiea and Euphorbia meloformis. It also seems to be the favoured habitat of several tortoise species, e.g. Parrot-beak Tortoise and Angulate Tortoise. This vegetation unit is classified as ‘Endangered’.

Sundays Doringveld. The thicket clumps within this vegetation unit are often species-poor but those present are typical of the Sundays Valley Thicket. Dominant in the Nama-karoo matrix are sweet thorn (Acacia karroo), wolwedoring (Lycium spp.) and quick grass (Cynodon dactylon). This unit is restricted to the often deep, red, alluvial soils in the floodplains of the Coega, Sundays and Zwartkops rivers. Acacia karoo, Aloe ferox (often also with A.ferox cross A.africana hybrids present) and Pentzia incana abundant. When pristine, the grass component (Eragrostis and Panicum species) is well developed. At present these grasses are largely absent, with only Cynodon dactylon abundant in the heavily grazed sites. Small succulents are usually abundant (e.g. Cotyledon campanulata, Glottiphyllum longum, Malephora lutea, etc.), especially amongst the woody shrubs (Cadaba aphylla, Lycium cinereum, Lycium ferocissimum, Pentzia incana, etc.). Some of these succulents are rare species (e.g. Orbea pulchella) or unique genotypes of uncommon species (e.g. Euphorbia sp.nov. Palmer 1336, Haworthia sordida var. sordida, etc.) which only occurs in this unit. A few very rare shrublets (e.g. Aphiglossa callunoides, Thesium junceum, etc.) occur in some floodplains, with at least one of the highly localised endemic species of this environment (Brachystelma tabularum) probably already extinct due to agricultural and urban development. This vegetation unit is classified as ‘Vulnerable’.

According to STEP, Vulnerable ecosystems are those areas that cover much of their original extent but where further disturbance or destruction could harm their health or functioning. These ecosystems can withstand only limited loss of natural area through disturbance or development. Endangered ecosystems are those areas whose original extent has been severely reduced through development or unsustainable land use, and whose health, functioning and existence are under serious “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za threat. These ecosystems can withstand only very minimal loss of natural area through disturbance or development. Both these vegetation units has a small distribution within the grid connection corridor options 1 and 2 and more in option 3. It should be noted that the development proposed within these vegetation units is a linear overhead powerline (and 12m servitude) and pylon disturbance can be restricted to degraded areas or areas with less SCCs to reduce vegetation loss.

FIGURE 4-2.2: REGIONAL VEGETATION MAP ILLUSTRATING THE VEGETATION TYPE FOUND WITHIN THE STUDY AREA AS CLASSIFIED BY STEP (2006) (POWERLINE ALTERNATIVES)

BIOREGIONAL CLASSIFICATION (EASTERN CAPE BIODIVERSITY CONSERVATION PLAN – ECBCP, 2007) Grid connection corridors option 1 and 2 is located within a Terrestrial CBA 1 and CBA 2 area, while corridor option 3 is only located within a CBA 2 area (Figure 4-3.2). All three corridor alternatives are located in an Aquatic CBA 2 (Figure 4-4.2) as classified by the ECBCP (2007).

Terrestrial CBA 1 areas are defined by the following aspects:  Critically endangered vegetation types (ecosystems) identified though ECBCP the systematic conservation assessment  Critically endangered vegetation types from STEP

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 Critically endangered forest patches in terms of the National Forest Assessment  Areas essential for meeting biodiversity targets for biodiversity features (SA vegetation types, expert mapped priority areas)  KZN systematic conservation planning priorities  Forest clusters identified as critical in the forestry planning process (Berliner et al 2006)

The ECBCP (2007) also classifies various parcels of land into Land Management Classes broadly depending on their transformation status and ecological function. The ECBCP Land management classes’ dataset indicates that Grid connection corridors option 1 and 2 is categorised largely as within a BLMC 1 – Natural landscape and portions within a BLMC 2 – Near Natural Landscapes. Grid connection corridor 3 is located within a BLMC 2. The recommended land use management for areas classified as such is described in Table 4-1.2 below.

The proposed Scarlet Ibis WEF and associated infrastructure is not in conflict with the ECBCP land use management recommendations as the turbines will not change the function of the landscape nor permanently transform significant portions of it. The areas cleared for the grid connection will largely be confined to pylons and servitude clearance and should as far as practically possible be confined to degraded areas or areas already disturbed. The CBA 2 area delineated by ECBCP is somewhat inconsistent with the state of the environment, as some of the areas within the study area are degraded and transformed to the point where it cannot be maintained in a near natural state.

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FIGURE 4-3.2: TERRESTRIAL CRITICAL BIODIVERSITY AREAS (CBA) AS CLASSIFIED BY ECBCP (2007) (POWERLINE ALTERNATIVES).

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FIGURE 4-4.2: AQUATIC CRITICAL BIODIVERSITY AREAS (CBA) AS CLASSIFIED BY ECBCP (2007) (POWERLINE ALTERNATIVES).

TABLE 4-1.2: TERRESTRIAL CRITICAL BIODIVERSITY AREAS AND BIODIVERSITY LAND MANAGEMENT CLASSES AS DESCRIBED BY THE EASTERN CAPE BIODIVERSITY CONSERVATION PLAN (POWERLINE ALTERNATIVES). CBA Map Category Code BLMC Recommended Land Use Objective

PA1 Protected areas PA2 Natural Maintain biodiversity in as natural state as BLMC 1 landscapes possible. Manage for no biodiversity loss. Terrestrial CBA 1 (not T1 degraded)

Terrestrial CBA 1 Near-natural T1 BLMC 2 Maintain biodiversity in near natural state with (degraded) landscapes minimal loss of ecosystem integrity. No

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T2 transformation of natural habitat should be permitted. Terrestrial CBA 2 C1

Transformed Transformed areas TF BLMC 4 Manage for sustainable development. landscapes

LOCAL CLASSIFICATION (THE METROPOLITAN OPEN SPACE SYSTEM - MOSS, 2009) Four (4) vegetation units are found within the three different grid connection corridors namely, Grassridge Bontveld, Sundays Valley Thicket, Sundays Doringveld and Motherwell Karroid Thicket (Figure 4-5.2).

Motherwell Karroid Thicket This vegetation unit consist of thicket clumps containing species typical of Sundays Valley thicket occurring in a matrix or succulent karoo dominated by Pteronia incana (asbossie). Themeda triandra is dominant son after fire. Characteristic species include local endemics such as Euphorbia meloformis. This vegetation unit is typically present on calcareous limestones of the Alexandria formation. Motherwell Karroid Thicket is classified as ‘Endangered’. Approximately 39.6% of the intact vegetation remains.

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Sundays Doringveld The thicket clumps within this vegetation unit are often species-poor but those present are typical of the Sundays Valley Thicket. Dominant in the Nama-karoo matrix are sweet thorn (Acacia karroo), wolwedoring (Lycium spp.) and quick grass (Cynodon dactylon). Characteristic features are the high cover of Panicum spp. and the presence of succulents. Some of these succulents are rare species (e.g. Harworthia sordida). This vegetation unit is restricted to deep, red, alluvial soils of the Coega, Sundays and Swartkops Rivers. Sundays Doringveld is classified as ‘Endangered’. Approximately 36.1% of the intact vegetation remains.

Table 4-2.2 below indicate the area of each vegetation unit within each corridor. This does not mean that this entire area (as calculated below) will be cleared or impacted on. It is merely an indication of the extent cover in each corridor.

Table 4-2.2: Extent of Local classified vegetation within each grid connection corridor alternative (MOSS, 2009 as gazetted as part of the NMBM Bioregional Plan, 2015). Powerline Alternative Grassridge Sundays Valley Sundays Motherwell Karroid Corridor Bontveld Thicket Doringveld Thicket

Powerline Corridor 236.5ha 113ha 23.5ha 17ha Alternative 1 (390ha)

Powerline Corridor 384.5ha 112ha 37.5ha 33ha Alternative 2 (567ha)

Powerline Corridor 428.5ha 103ha 18ha 76.5ha Alternative 3 (626ha)

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FIGURE 4-5.2: LOCAL VEGETATION MAP ILLUSTRATING THE VEGETATION TYPE FOUND WITHIN THE STUDY AREA AS CLASSIFIED BY NMB MOSS (2009) (POWERLINE ALTERNATIVES).

All three corridor alternatives are located within portions of a CBA or an Ecological Process Areas. In addition, the Coega Riverine Corridor traverse the site in various locations (Figure 4-6.2 and 4-7.2).

The NMB Bioregional Plan (2015), which is underpinned by the NMBM MOSS (2009) conservation assessment, defines a CBA area as areas which are, “Critically endangered habitats, ecological process areas, ecological corridors, habitats for species of conservation concern and some threatened ecosystems”. It is suggested that such areas should form part of the protected area system and that developments/activities that will result in further loss of these vegetation types is restricted. Even if degraded, rehabilitation or restoration should be the first option to recreate and maintain natural ecological processes in these areas. According to NMB MOSS (2009), vulnerable areas outside of CBAs must be managed for sustainable development. This means that some loss of natural habitat is allowed but this needs to be within the limits of cumulative impacts of the transformation threshold of the Ecosystem Status. Ecosystem Support Areas (ESA1) are areas of agricultural land that plays an important role in ecosystem functioning and/or provides connectivity between natural areas. Such areas must be maintained for these purposes as far as prcatically possible. According to MOSS (2009), potential may exist, within “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za these areas, depending on existing land use and potential, and current ecological state to develop Service Infrastructure such as sewer, power and telecom lines.

FIGURE 4-6.2: NMB MOSS (2009) CLASSIFICATION OF CBAS, ESAS AND CORRIDORS (POWERLINE ALTERNATIVES).

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FIGURE 4-7.2: NMB MOSS (2009) CLASSIFICATION OF ECOLOGICAL PROCESS AREAS.

COEGA OPEN SPACE MANAGEMENT PLAN (2014) AND COEGA IDZ DEVELOPMENT FRAMEWORK (2006)

The CDC compiled, with advice from Gibb Africa and Metroplan, a Development Framework Plan (DFP) for the Coega IDZ. This DFP aims to provide an overall development strategy for the Coega IDZ by identifying a series of defined objectives so that the implementation of the Coega IDZ can progress from concept to detailed planning and design. The DFP, which has been established in terms of the Land Use Planning Ordinance (Ordinance 15 of 1985, is based on a range of clusters and activity nodes. It achieves this by:

 Providing a robust but flexible land use, transportation and infrastructure strategy for the Coega site,  Ensuring that the strategy conforms with National Policy for the planning of Development Zones, Confirming that the strategy is consistent with local planning initiatives, commitments and objectives, and  Demonstrating that the strategy is based on previous feasibility studies, and current “best practice”, as demonstrated in similar projects.

The Coega OSMP (2014) sets out the uses of the open space areas within the Coega IDZ and was one of the conditions of approval as set out in the applicable ROD. “The OSMP informed the preparation of the Management Guidelines for the various “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za open space uses identified on the plan, to identify the actions required to implement the Management Guidelines” (Coega OSMP, 2014). The primary objectives of developing an OSMP for the IDZ were to:

 Promote preservation of the environment where natural systems and/or specific habitats require it.  Manage and preserve the cultural resources within the open spaces of the Coega IDZ.  Manage and preserve land for its aesthetic or passive recreational value, for active recreational use, and for its contribution to the quality of life of the concessionaires, tenants and the public.  Meet recreation space demands as well as provide natural amenities for the IDZ working population.  Ensure proper management of open space areas.  Ensure that linkages to neighbouring open space areas are maintained.  Use education to promote and accomplish the goals of the environmental vision for Coega IDZ.  Address the social and cultural needs of workers and families if and where desired.  Promote educational opportunities within the IDZ and enhance the level of environmental awareness of the workers within the IDZ.  Improve environmental quality by means of development guidelines to ensure the IDZ can compete with other alternative locations on a global scale.

Two (2) of the powerline corridor alternatives (Alternative 1 and Alternative 2) traverse the IDZ’s Zone 14 and Zone 5. The below table provides a summary of the features that may be affected.

Table 4-3.2: Affected areas within the Coega IDZ POWERLINE CORRIDOR AFFECTED AREA  Zone 14 (Advanced Manufacturing: Aeronautical And Aerospace Cluster);  Zone 5 (Metallurgical Cluster) ;  Existing infrastructure and servitudes; Powerline Alternative 1  Core Primary Network: Mesic Succulent Thicket;  1:100 floodline of the Coega River;  Riparian Zone of the Coega River;  Ecological Support Area (ESA); and  Rehabilitation Area.  Zone 14 (Advanced Manufacturing: Aeronautical And Aerospace Cluster);  Zone 5 (Metallurgical Cluster) ;  Existing infrastructure and servitudes;  Core Primary Network: Mesic Succulent Thicket;  1:100 floodline of the Coega River; Powerline Alternative 2  Riparian Zone of the Coega River;  Ecological Support Area (ESA); and  Rehabilitation Area.  An Air Quality Monitoring Station;  Core Primary Network: Bontveld; and  Species of Conservation Concern Areas (SCC).

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Permitted Landuses within these zones include:  High intensity use such an International Airport with associated infrastructure (warehousing, parking bays etc.) earmarked for Zone 14  Medium intensity use such as existing roads, servitudes and medium intensity industries.  Both these zones contain environmentally sensitive areas.

FIGURE 4-8.2: MAP ILLUSTRATING THE OPEN SPACE MANAGEMENT PLAN (OSMP) AFFECTED BY POWERLINE ALTERNATIVES 1 AND 2.

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FIGURE 4-9.2: MAP ILLUSTRATING THE COEGA IDZ ZONING.

The Open Space Management Plan was initially prepared by CES (2006) to provide ecological input into the DFP. The OSMP identified sensitive ecological areas, and areas of high biodiversity within the IDZ, to ensure that spatial planning considered the ecological setting. Ecological corridors and areas of high biodiversity or where unique fauna and flora occur were identified and where possible incorporated into the DFP. A number of ecological corridors were identified, and according to the OSMP, new powerlines associated with this WEF may traverse Ecological Process Areas, Sensitive Vegetation units, Drainage Systems and PPC pipelines. It should however be noted that limited vegetation clearing will required for the installation of a power line which will be mainly confined to pylons.

According to the OSMP, the goals of the planning and construction of linear infrastructure should be to:  Minimise the impacts on the natural environment, including sensitive vegetation types, steep slopes, wetlands and the Coega River.  Minimise potential impacts after construction by stabilising and rehabilitating disturbed areas.  Environmentally sensitive planning approach for linear infrastructure includes:

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 The construction of any infrastructure must comply with the CDC’s Environmental Specifications for Construction.  For powerlines minimise vegetation clearing during construction by ensuring that vegetation under the conductors is not cleared. Vegetation should only be cleared around towers and access roads.  It is essential to minimise vegetation clearing and ground disturbances on areas susceptible to water erosion (in and around the Coega River).  Rescue plant species protected under the Provincial Ordinance and/or translocate to areas requiring rehabilitation.  Remove and store topsoil for later use during rehabilitation. Topsoil must not be contaminated with other material or compacted by vehicular traffic.  For power lines appropriate bird flight diverters (BFD's) may need to be installed to increase the visibility of the power lines where they cross the Coega River. The requisite EIA must determine the need for BFD’s, type of BFD and spacing of the BFD’s.

In addition, the OSMP recommends the following for development within Mesic Succulent Thicket (MST):  “This habitat generally occurs on steep slopes on the banks of the Coega River, and development in the MST is to be kept to a minimum or avoided;  Fragmentation of this habitat should be avoided;  No vehicular access roads are planned across the MST habitats.  Fencing habitats if it is considered that they are under threat.  Keeping service infrastructure out of these areas.  Only passive open space pursuits (picnic sites, boardwalks, trails) to be considered.  No clearing of vegetation be allowed.  Dune vegetation, dense Mesic Succulent Thicket and Bontveld habitats should be protected from development and disturbance. Where the loss of habitat is unavoidable, linkages between habitats fragments should be maintained.”

The small egg-shaped colony of rare Gibbaria scabra plant species that has been identified in Zone 5 during the EIA that was conducted for the Alcan Aluminium smelter, will not be affected by either of the powerline corridor alternatives.

In addition to the above the OSMP recommends no development within the 1:100 year floodline of the Coega River, however it should be noted that pylons can be placed to avoid these areas. In terms of development within sensitive Bontveld areas, the OSMP recommends that Bontveld areas be managed in a manner that achieves the primary – “preserving biological diversity and improving the condition of certain areas”. These goals can be accomplished by allowing and encouraging natural processes to continue functioning, by controlling aliens and implementing restoration/rehabilitation activities as required.

The activities planned within sensitive areas will need to be subject to environmental approval to determine the areas, methodologies and technologies with the least ecological impact. As with the 1:100 year floodline, sensitive, intact areas of Bontveld can be avoided by placing the required pylons in already disturbed areas.

The OSMP (2014) sets out a number of recommended land uses for the respective zones within the IDZ. In addition to the above, these recommendations should be read in conjunction with the NMBM MOSS plan (2009), as gazetted as part of the NMB Bioregional plan (2015). Section 11.1 within the Coega OSMP can be referred to for permitted and prohibited land uses within the various sensitive environmental areas within the Coega IDZ.

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PROTECTED AREAS (NATIONAL PROTECTED AREAS EXPANSION STRATEGY, 2008) A number of formally and informally protected areas occurs in the surrounding areas of the study area. Informal Conservation Areas include the Tregathylyn Game Reserve. Formally protected areas include the Springs Local Authority Nature Reserve, Addo Elephant National Park and Swartkops Valley Authority Nature Reserve. These range from over 5 km to about 15 km from the study area. No formally and informally protected areas are found to occur within the immediate study area or within any of the corridors.

Protected Areas Expansion strategy – Focus Areas A National Spatial Biodiversity Assessment (2004) highlighted the shortcomings in the protection of representative sample of the country‘s biodiversity and ecological process areas. The Protected Areas Expansion Strategy was developed in 2008 from this to increase conservation areas in order to meet national biodiversity targets, and outlined two strategies for expanding the current National Protected Areas: (1) For public land, the declaration of available, under-utilised and strategic parcels of public land in concordance with the relevant legal requirements for disposal of such land; and (2) For private land, contractual agreements with the affected landowners.

An area is considered important for expansion if it contributes to meeting biodiversity thresholds, maintaining ecological processes or climate change resilience. Forty-two focus areas for land-based protected area expansion have been identified and are composed of large, intact and fragmented areas suitable for the creation or expansion of large protected areas. A small portion along the western boundary of grid connection corridor option 3 is located in the Baviaans-Addo focus area (#69) in the Eastern Cape. This focus area includes vegetation types from no less than seven biomes and is an extremely important area for conserving ecological processes that support resilience to climate change. It also presents excellent opportunities for incorporating whole river reaches and irreplaceable river types in protected areas. There are opportunities for expanding the World Heritage Site-listed Baviaanskloof Megareserve, Groendal Nature Reserve and Addo Elephant National Park (NPAES, 2008).

It should however be noted that the entire corridor ill not be developed and as such the powerline (should it occur within this expansion area) can be moved.

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FIGURE 4-9.2: MAP ILLUSTRATING THE PROTECTED AREAS EXPANSION FOCUS AREAS WITHIN THE STUDY AREA AND SURROUNDS (POWERLINE ALTERNATIVES).

SURFACE WATER FEATURES The Coega River and its ecological status has been described in the WEF “surface water features” in the previous section. According to NFEPA (2014), four (4) wetlands have been identified to occur within 500m of grid connection corridor options 1 and 2. No wetlands occur within these corridors, however the overhead powerline servitude and pylons may occur within the 500m regulatory boundary of these wetland or within the 50m regulatory buffer of the tributaries and drainage lines observed within the study area. Grid connection corridor option 3 occurs within 500m of at least eight (8) wetlands as identified by NFEPA (2014) and the associated powerline servitude and pylons within this corridor may occur within the 50m regulatory buffer of the various tributaries and drainage lines observed within the study area.

A water use authorisation in terms of the National Water Act (Act 36 of 1998) sections 21 (c) and (i) will be required for all activities within 50m of a drainage line, river or tributary or within 500m of the edge of a wetland.

It should be noted that the main-stem Coega River will not directly be affected by the turbines or associated infrastructure. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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FIGURE 4-10.2: HYDROLOGICAL MAP ILLUSTRATING SURFACE WATER FEATURES WITHIN THE STUDY AREA (POWERLINE ALTERNATIVES)

5. LAND USE CHARACTER OF SURROUNDING AREA: POWERLINE ALTERNATIVE 1 (PREFERRED)

5.1 Natural area 5.2 Low density residential 5.3 Medium density residential 5.4 High density residential 5.5 Informal residential 5.6 Retail commercial & warehousing 5.7 Light industrial 5.8 Medium industrial AN “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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5.9 Heavy industrial AN 5.10 Power station 5.11 Office/consulting room 5.12 Military or police base/station/compound 5.13 Spoil heap or slimes damA 5.14 Quarry, sand or borrow pit 5.15 Dam or reservoir 5.16 Hospital/medical centre 5.17 School 5.18 Tertiary education facility 5.19 Church 5.20 Old age home 5.21 Sewage treatment plantA 5.22 Train station or shunting yard N 5.23 Railway line N 5.24 Major road (4 lanes or more) N 5.25 Airport N 5.26 Harbour 5.27 Sport facilities 5.28 Golf course 5.29 Polo fields 5.30 Filling station H 5.31 Landfill or waste treatment site 5.32 Plantation 5.33 Agriculture 5.34 River, stream or wetland 5.35 Nature conservation area 5.36 Mountain, koppie or ridge 5.37 Museum 5.38 Historical building 5.39 Protected Area 5.40 Graveyard 5.41 Archaeological site 5.42 Other land uses (describe)

If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the proposed activity. N/A

If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the proposed activity. N/A

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If YES, specify and explain:

If YES, specify:

If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the proposed activity. N/A If YES, specify and explain:

If YES, specify:

5. LAND USE CHARACTER OF SURROUNDING AREA: POWERLINE 2

5.1 Natural area 5.2 Low density residential 5.3 Medium density residential 5.4 High density residential 5.5 Informal residential 5.6 Retail commercial & warehousing 5.7 Light industrial 5.8 Medium industrial AN 5.9 Heavy industrial AN 5.10 Power station 5.11 Office/consulting room 5.12 Military or police base/station/compound 5.13 Spoil heap or slimes damA 5.14 Quarry, sand or borrow pit 5.15 Dam or reservoir 5.16 Hospital/medical centre 5.17 School 5.18 Tertiary education facility 5.19 Church 5.20 Old age home 5.21 Sewage treatment plantA 5.22 Train station or shunting yard N 5.23 Railway line N 5.24 Major road (4 lanes or more) N 5.25 Airport N “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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5.26 Harbour 5.27 Sport facilities 5.28 Golf course 5.29 Polo fields 5.30 Filling station H 5.31 Landfill or waste treatment site 5.32 Plantation 5.33 Agriculture 5.34 River, stream or wetland 5.35 Nature conservation area 5.36 Mountain, koppie or ridge 5.37 Museum 5.38 Historical building 5.39 Protected Area 5.40 Graveyard 5.41 Archaeological site 5.42 Other land uses (describe)

If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the proposed activity. The proposed Powerline Alternative 2 will not impact the existing railway line.

If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the proposed activity. N/A If YES, specify and explain:

If YES, specify:

If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the proposed activity. N/A If YES, specify and explain:

If YES, specify:

5. LAND USE CHARACTER OF SURROUNDING AREA: POWERLINE 3

5.1 Natural area 5.2 Low density residential “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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5.3 Medium density residential 5.4 High density residential 5.5 Informal residential 5.6 Retail commercial & warehousing 5.7 Light industrial 5.8 Medium industrial AN 5.9 Heavy industrial AN 5.10 Power station 5.11 Office/consulting room 5.12 Military or police base/station/compound 5.13 Spoil heap or slimes damA 5.14 Quarry, sand or borrow pit 5.15 Dam or reservoir 5.16 Hospital/medical centre 5.17 School 5.18 Tertiary education facility 5.19 Church 5.20 Old age home 5.21 Sewage treatment plantA 5.22 Train station or shunting yard N 5.23 Railway line N 5.24 Major road (4 lanes or more) N 5.25 Airport N 5.26 Harbour 5.27 Sport facilities 5.28 Golf course 5.29 Polo fields 5.30 Filling station H 5.31 Landfill or waste treatment site 5.32 Plantation 5.33 Agriculture 5.34 River, stream or wetland 5.35 Nature conservation area 5.36 Mountain, koppie or ridge 5.37 Museum 5.38 Historical building 5.39 Protected Area 5.40 Graveyard 5.41 Archaeological site 5.42 Other land uses (describe)

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If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the proposed activity. N/A

If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the proposed activity. N/A If YES, specify and explain:

If YES, specify:

If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the proposed activity. N/A If YES, specify and explain:

If YES, specify:

6. CULTURAL/HISTORICAL FEATURES: POWERLINE ALTERNATIVES 1 (PREFERRED), 2 & 3

Are there any signs of culturally or historically significant elements, as YES NO defined in section 2 of the National Heritage Resources Act, 1999, (Act No. 25 of 1999), including Archaeological or palaeontological sites, on or close (within 20m) to the Uncertain site? If YES, Archaeological (Heritage) and Palaeontological Impact Assessment Reports have been explain: completed for this site. The next paragraph is a summary of the findings from each of the specialist assessments. If uncertain, conduct a specialist investigation by a recognised specialist in the field to establish whether there is such a feature(s) present on or close to the site.

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Briefly explain ARCHAEOLOGICAL the findings of Three power line alternatives have been proposed to connect the Scarlet Ibis Wind Energy the specialist: Facility to the electricity grid. Isolated scatters of Middle Stone Age stone artefacts occurred along the two routes (Option 1 and Option 2) surveyed. Only a desktop assessment for Option 3 was recommended. These artefacts were identified in exposed surface areas and most likely occur in secondary context. No other archaeological material was identified to occur in association with these artefact scatters. The ruins of three built environment structures were identified along power line route Option 2. These buildings are badly deteriorated and in some cases only the foundation is remains.

The Coega Community Cemetery occurs on the outskirts of the proposed corridor for power line route Option 2.

Recommendations The areas for the three proposed power line routes (Option 1 - Option 3) are considered as having a low archaeological heritage significance. Development may proceed as planned however the following recommendations must be considered before development continues:

The powerline route alternatives (Option 1 and Option 2) are considered as having a low archaeological sensitivity and development may proceed on either of these alternatives. However, Option 2 would be the preferred route owing to most of the area having been disturbed over time by the construction of roads as well as dumping and quarrying/mining activities. A large portion of the route proposed for Option 1 is covered in dense thicket vegetation whereby bush clearing would have to be conducted to create servitude access roads.

Powerline alternative 2 contains sensitive heritage features as per the OSMP. In line with the ROD for the Rezoning EIA and the Heritage Impact Assessment (HIA) for the Coega IDZ, specific management recommendations are made in the HIA for the Coega IDZ. No disturbance and destruction of graves is to be allowed and no physical industrial development is to take place over the graves unless they are relocated. The graves have been fenced off and adequate but controlled access into the graveyards is provided, particularly where the access may impact on protection of species in adjacent habitats. In the event of relocation being required, the legislated process, as identified within the Heritage Impact Assessment for the Coega IDZ (ECHC 2010), must be followed.

Although cultural resources are protected under the National Heritage Resources Act (No 25 of 1999), the following management actions are required to protect cultural resources: • Fence sites to prevent damage or vandalism. • Remove vegetation in and around the site to prevent damage and enhance visibility. • Repair the site when necessary to secure and prevent further deterioration. • Alien vegetation eradication within and around the cultural sites and graves.

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If the power line route alternative Option 1 is chosen as the final route, a professional archaeologist must be appointed to conduct archaeological monitoring during the bush clearing and excavation activities of the proposed development and associated infrastructure such as the servitude access roads.

If the proposed power line route alternatives, Option 1 and Option 2, are not preferred, the proposed route for Option 3 an archaeological ground truthing survey should be conducted.

Portions of the proposed area for development are covered in dense vegetation and sites/features may be covered by soil and vegetation and will only be located once this has been removed. A person must be trained as a site monitor to report any archaeological sites found during the development. Construction managers/foremen and/or the Environmental Control Officer (ECO) should be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find sites.

If concentrations pre-colonial archaeological heritage material and/or human remains (including graves and burials) are uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/or the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) (043 745 0888) so that systematic and professional investigation/excavation can be undertaken. Phase 2 mitigation in the form of test-pitting/sampling or systematic excavations and collections of the pre-colonial shell middens and associated artefacts will then be conducted to establish the contextual status of the sites and possibly remove the archaeological deposit before development activities continue.

The developer / ECO / or construction manager must apply to the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) for a destruction permit for the stone artefacts prior to the commencement of the development activities.

It is unlikely that the built environment structure will be negatively impacted during the development, these structures should be noted and avoided for pylon positions.

PALAEONTOLOGICAL Over most of the study area the geology is masked by a thin veneers of calcrete, quaternary alluvium, soil and vegetation.

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Considering the size of the holes excavated for the footings of powerline pylons it seems likely that many of these will penetrate deeply enough to disturb potentially fossil rich strata.

Please find the full Archaeological and Paleontological Impact Assessment Reports attached as APPENDIX D: Specialist Reports. Will any building or structure older than 60 years be affected in any way? YES NO Is it necessary to apply for a permit in terms of the National Heritage YES NO Resources Act, 1999 (Act 25 of 1999)? If yes, please submit or, make sure that the applicant or a specialist submits the necessary application to SAHRA or the relevant provincial heritage agency and attach proof thereof to this application if such application has been made. SECTION C: PUBLIC PARTICIPATION

1. ADVERTISEMENT

The person conducting a public participation process must take into account any guidelines applicable to public participation as contemplated in section 24J of the Act and must give notice to all potential interested and affected parties of the application which is subjected to public participation by—

(a) fixing a notice board (of a size at least 60cm by 42cm; and must display the required information in lettering and in a format as may be determined by the competent authority) at a place conspicuous to the public at the boundary or on the fence of— (i) the site where the activity to which the application relates is or is to be undertaken; and (ii) any alternative site mentioned in the application;

Please refer to Appendix E1: Notice Board

(b) giving written notice to— (i) the owner or person in control of that land if the applicant is not the owner or person in control of the land; (ii) the occupiers of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken; (iii) owners and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken;

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(iv) the municipal councillor of the ward in which the site or alternative site is situated and any organisation of ratepayers that represent the community in the area; (v) the municipality which has jurisdiction in the area; (vi) any organ of state having jurisdiction in respect of any aspect of the activity; and (vii) any other party as required by the competent authority;

Please refer to Appendix E2: Notification Documents

In addition to the initial email/postal notifications, all registered I&APs were notified of the release of the Draft Basic Assessment Report for a thirty (30) day review period.

(c) placing an advertisement in— (i) one local newspaper (The PE Herald); or (ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations; (d) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in subregulation 54(c)(ii); and (e) using reasonable alternative methods, as agreed to by the competent authority, in those instances where a person is desiring of but unable to participate in the process due to— (i) illiteracy; (ii) disability; or (iii) any other disadvantage.

Please refer to Appendix E3: Advertisements

2. CONTENT OF ADVERTISEMENTS AND NOTICES

A notice board, advertisement or notices must: (a) indicate the details of the application which is subjected to public participation; and (b) state— (i) that the application has been submitted to the competent authority in terms of these Regulations, as the case may be; (ii) whether basic assessment or scoping procedures are being applied to the application, in the case of an application for environmental authorisation; (iii) the nature and location of the activity to which the application relates; “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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(iv) where further information on the application or activity can be obtained; and (iv) the manner in which and the person to whom representations in respect of the application may be made.

3. PLACEMENT OF ADVERTISEMENTS AND NOTICES

Where the proposed activity may have impacts that extend beyond the municipal area where it is located, a notice must be placed in at least one provincial newspaper or national newspaper, indicating that an application will be submitted to the competent authority in terms of these regulations, the nature and location of the activity, where further information on the proposed activity can be obtained and the manner in which representations in respect of the application can be made, unless a notice has been placed in any Gazette that is published specifically for the purpose of providing notice to the public of applications made in terms of the EIA regulations.

Advertisements and notices must make provision for all alternatives.

4. DETERMINATION OF APPROPRIATE MEASURES

The practitioner must ensure that the public participation is adequate and must determine whether a public meeting or any other additional measure is appropriate or not based on the particular nature of each case. Special attention should be given to the involvement of local community structures such as Ward Committees, ratepayers associations and traditional authorities where appropriate. Please note that public concerns that emerge at a later stage that should have been addressed may cause the competent authority to withdraw any authorisation it may have issued if it becomes apparent that the public participation process was inadequate.

5. COMMENTS AND RESPONSE REPORT

The practitioner must record all comments and respond to each comment of the public before the application is submitted. The comments and responses must be captured in a comments and response report as prescribed in the EIA regulations and be attached to this application. The comments and response report must be attached under Appendix E.

Please refer to Appendix E4: Issues & Response Trail

6. AUTHORITY PARTICIPATION

Authorities are key interested and affected parties in each application and no decision on any application will be made before the relevant local authority is provided with the opportunity to give input. The planning and

www.dedea.gov.za the environmental sections of the local authority must be informed of the application at least 30 (thirty) calendar days before the submission of the application.

List of authorities informed: Stakeholder Contact Person Mr Dayalan Govender Department of Economic Development, Mr Andries Struwig Environmental Affairs and Tourism (Eastern Cape) Mr Gerry Pienaar Mr Alan Southwood Department of Water Affairs (DWA) (Eastern Cape) Ms Marisa Bloem Ms Brenda Ngebulana Department of Mineral Resources (DMR) (Eastern Cape) Deidre Watkins Ms Zimkita Tyala Ms Thoko Buthelezi Department of Agriculture Forestry & Fisheries (DAFF) Mr Thabo Nokoyo Ms Mashudu Marubini Department of Energy Ms Mokgadi Mathekgana Eskom Mr Eddie Leach Eskom: Renewable Energy Mr John Geeringh Cllr Athol Trollip

Cllr Andrew Whitfield Nelson Mandela Bay Metropolitan (Eastern Cape)

Cllr Annette Lovemore

Nelson Mandela Bay Metropolitan Ward 53 Councillor Cllr Nomazulu Mthi

Nelson Mandela Bay Metropolitan Ward 56 Councillor Cllr Mgcokoca Ms Aseza Dlanjwa SALGA Eastern Cape Mr Zamikhaya Mpulampula Ms Zona Cokie Eastern Cape Provincial Heritage Resources Authority Mr Lennox Zote (ECPHRA) Mr Sello Mokhanya Telkom Mr Raymond Couch

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Sentech Ms Alishea Viljoen Vodacom Mr Andre Barnard MTN Mr Krishna Chetty Mr Hugo Dippenaar Mr Rudi Liebenberg Cell C Mr Wiaan Vermaak Mr Dirk Van Der Walt Mr Joshua Engelbrecht Civil Aviation Authority (CAA) Ms Lizelle Stroh Air Traffic and Navigation Services (ATNS) Mr Dylan Fryer Roads (SANRAL/Public Works) Ms Nanna Gouws BirdLife South Africa Dr Hanneline Smit-Robinson BirdLife South Africa: Birds and Renewable Energy Manager Ms Samantha Ralson BirdLife South Africa: Policy & Advocacy Manager Mr Simon Gear Endangered Wildlife Trust: CEO Ms Yolan Friedman Endangered Wildlife Trust: Head of Conservation Science Dr Harriet Davies-Mostert Endangered Wildlife Trust: African Crane Conservation Programme Manager Ms Kerryn Morrison Endangered Wildlife Trust: African Crane Conservation Programme Field Officer Ms Glenn Ramke Mr Lourens Leeuwner Endangered Wildlife Trust: Wildlife & Energy Programme Ms Megan Murison Mr Wayne Erlank Ms Leandri Gerber ECPTA Mr Brian Reeves Mr Patrick Zake Ms Asanda Sontsele Luvuyo Mkontwana Sandisiwe Ncemane Coega Development Corporation Ms Andrea Shirley Ms Viwe Biyana

List of authorities from whom comments have been received:  Department of Economic Development, Environmental Affairs and Tourism (Eastern Cape)  Coega Development Corporation

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Please refer to Appendix E5: Stakeholder/Landowner/Surrounding Landowner/I&AP Database

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7. CONSULTATION WITH OTHER STAKEHOLDERS

Note that, for linear activities, or where deviation from the public participation requirements may be appropriate, the person conducting the public participation process may deviate from the requirements of that subregulation to the extent and in the manner as may be agreed to by the competent authority.

Any stakeholder that has a direct interest in the site or property, such as servitude holders and service providers, should be informed of the application at least 30 (thirty) calendar days before the submission of the application and be provided with the opportunity to comment.

Has any comment been received from stakeholders? YES NO If “YES”, briefly describe the feedback below (also attach copies of any correspondence to and from the stakeholders to this application): Communication with DEDEAT has involved confirmation that DEDEAT (Sarah Baartman District) is the Competent Authority for the proposed development. A pre-application meeting was also held with DEDEAT in Port Elizabeth.

Please refer to Appendix E.2 for the Notification Correspondence and Appendix E.4 for the full Issues and Response Trail. Please also refer to Appendix E.5 for the full stakeholder/landowner/surrounding landowner/I&AP database.

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SECTION D: IMPACT ASSESSMENT

The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2014, and should take applicable official guidelines into account. The issues raised by interested and affected parties should also be addressed in the assessment of impacts.

1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES

List the main issues raised by interested and affected parties.

 The cumulative effects of all the wind farms in the Grassridge area  The contribution of operational WEF data into the bird and bat impact assessment reports.  Who the energy will be sold to seeing that Eskom is not keen to buy renewable energy at present  Explanation of how this project differs from all the other wind energy EIAs done by Innowind in and around the Coega IDZ.

Response from the practitioner to the issues raised by the interested and affected parties (A full response must be given in the Comments and Response Report that must be attached to this report):  The BAR does include a cumulative impacts section which takes into account existing and proposed wind farms within a 30km radius of the proposed Scarlet Ibis WEF. Maps indicating the location of the adjacent WEFs will be available in the documentation.  Please note that the avifaunal and bat specialists who undertook the monitoring for the Scarlet Ibis WEF are the same specialists who were/are involved in the pre-construction and operational monitoring for the adjacent WEFs. Both specialists have used site specific information combined with their local knowledge based on the outcome of the adjacent projects.  The energy will be sold to a private off-taker within the NMBM, however due to ongoing negotiations with the off-taker this information is currently confidential and as such cannot be disclosed by the developer at this stage in the process.  In August 2011, InnoWind secured an Environmental Authorisation (EA) to build 75 wind turbines in NMBM across various properties, including but not limited to Zone 14 of the Coega IDZ and the property upon which the Scarlet Ibis WEF has been proposed. After submitting a first phase of the project in the Department of Energy’s Renewable Energy Independent Power Producer Procurement Program (REIPPPP), the Environmental Authorisation was split, with phase 1 comprising of the 20 wind turbines that were built by InnoWind on the RE of Farm Grassridge 227 and Farm Grassridge 228 (i.e. the operational Grassridge WEF). The remainder of the Environmental Authorisation was then amended to only focus on the construction of infrastructures on the properties owned by PPC (i.e. RE of Farm Grassridge 227, Farm Grassridge 228, RE of Farm Grassridge 190 and portion 1 of farm Grassridge 190) with the total number of authorized wind turbines being 30 in this amended EA. As such the initial number of wind turbines authorized by DEA was eventually “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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downscaled from 75 to 50. There is currently no Environmental Authorisation to build wind turbines in zone 14 of the IDZ or on the Scarlet Ibis properties.

PLEASE NOTE THAT IN ADDITION TO THE ABOVE MENTIONED COMMENTS AND RESPONSES THERE ARE 51 COMMENTS/QUESTIONS AND RESPONSES CONTAINED IN THE ISSUES AND RESPONSE TRAIL (PLEASE REFER TO APPENDIX E.4)

Please refer to Appendix E.2 for the Notification Correspondence and Appendix E.4 for the full Issues and Response Trail

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2. IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION, OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES

List the potential direct, indirect and cumulative property/activity/design/technology/operational alternative related impacts (as appropriate) that are likely to occur as a result of the planning and design phase, construction phase, operational phase, decommissioning and closure phase, including impacts relating to the choice of site/activity/technology alternatives as well as the mitigation measures that may eliminate or reduce the potential impacts listed.

The impact assessment for the proposed Scarlet Ibis WEF was conducted in two parts; a general impact assessment, and various specialist impact assessments. The general impact assessment identified and assessed impacts across four phases of development:  Planning & Design Phase  Construction Phase  Operational Phase  Decommissioning Phase

The general impact assessment covered issues such as:  Drainage line impacts  General construction impacts  Access roads  Underground electrical connections  Stormwater  Electromagnetic Interference

1.1 Planning and Design Phase Impacts

1.1.1 General

Impact 1.1.1.1: Inadequate planning for the transportation of turbine and powerline parts could lead to traffic congestion

Cause and Comment Inadequate planning for the transportation of turbine and powerline parts and specialists construction equipment to the site by long and/or slow moving vehicles could cause traffic congestion, especially if temporary road closures are required.

Mitigation Measures

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• Project planning must include a plan for transport management plan that will be implemented especially during the construction phase of the development. • The necessary road traffic permits must be obtained for transporting parts, containers, materials and construction equipment to the site.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase Without mitigation Short Term Regional Severe May Occur MODERATE - With mitigation Short Term Regional Moderate Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

Impact 1.1.1.2: Degradation of existing road infrastructure due to heavy vehicle traffic

Cause and Comment The integrity of existing highway infrastructure such as bridges and barriers may be compromised by the burden of heavy vehicle traffic delivering components to site.

Mitigation Measures • Careful planning of the routes taken by heavy vehicles must highlight areas of road that may need to be upgraded in order to accommodate these vehicles. Once identified these areas must be upgraded if necessary.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase Without mitigation Short Term Regional Moderate Probable MODERATE - With mitigation Short Term Regional Moderate Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

Impact 1.1.1.3: Inappropriate planning for the storage of hazardous substances could lead to surface and ground water pollution

Cause and Comment Inappropriate planning for the storage of hazardous substances such as diesel, paint, pesticides, etc. could lead to surface and ground water pollution due to, for example, oil leaks, spillage of diesel, etc. The total anticipated amount of hazardous substances to be used and stored on site are: “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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CONSTRUCTION PHASE: 27.21m3 OPERATIONS PHASE: 42.86m3

Mitigation Measures • All hazardous substances must be stored in a bunded area with an impermeable surface beneath them. Ensure that such areas are designed into the layout plan for the site camp. • A Spill Response Contingency Plan must be drafted and implemented.

Significance Statement: WEF Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase Without mitigation Long Term Localised Severe May Occur MODERATE - With mitigation Long Term Localised Moderate Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

Impact 1.1.1.4: Ground water contamination due to mixing of cement in inappropriate areas on site

Cause and Comment The mixing of cement on site could result in ground water and surface water contamination from compounds in the cement. In addition, a large number of cement mixing stations on site could increase the presence of impermeable areas of hard standing which could in turn increase rates of runoff thereby increasing the risk of localised flooding, soil erosion, siltation, sedimentation and the formation of gullies.

Mitigation Measures • Cement mixing must be conducted at a single location which should be centrally located, where practical. Ensure that this site is chosen and agreed to by the ECO prior to construction. • Wash water from cleaning vehicles and implements must be managed: stored on site and disposed off-site at a licenced WWTW; waste manifests to prove legal disposal.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase Without mitigation Short Term Localised Moderate May Occur LOW - With mitigation Short Term Localised Moderate Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

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Impact 1.1.1.5: An increase in impermeable surfaces could lead to increased localised flooding and erosion

Cause and Comment The construction of roads and impermeable areas of hard standing (both turbines and powerline pylons) could increase rates of run-off and lead to an increase in localised flooding and erosion. An inappropriate stormwater management plan could result in a higher severity of flooding and erosion.

Mitigation Measures • All structures must be located at least 32m away from identified drainage lines unless authorised by the Department of Water and Sanitation. • All structures must be located at least 500m from the delineated edge of wetlands unless authorised by the Department of Water and Sanitation. No non-linear structures will be allowed within 50m of the delineated edge unless authorised by the DWS. A Stormwater Management Plan must be designed and implemented to ensure maximum water seepage at the source of the water flow • The Stormwater Management Plan must also include management mitigation measures for water pollution, waste water management and the management of surface erosion.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase WEF Long Term Localised Moderate Probable MODERATE - Without mitigation WEF Long Term Localised Moderate May Occur LOW - With mitigation Powerline 1 Long Term Localised Moderate May Occur LOW - Without mitigation Powerline 1 Long Term Localised Moderate May Occur LOW - With mitigation Powerline 2 Long Term Localised Moderate May Occur LOW - Without mitigation Powerline 2 Long Term Localised Moderate May Occur LOW - With mitigation Powerline 3 Long Term Localised Moderate May Occur LOW - Without mitigation Powerline 3 Long Term Localised Moderate May Occur LOW - With mitigation No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Regional Moderate May Occur LOW -

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Impact 1.1.1.6: The loss of the Albany Adder due to disturbance of Coega Bontveld bushclumps during the siting of the 12m powerline servitude

Cause and Comment Poor planning of the siting of the 12m powerline servitude could lead to the loss of habitat of the Albany Adder. Due to the scarcity of this species it is paramount that all potential habitable areas are avoided during the placement of the powerline pylons.

Mitigation Measures • All structures (powerline pylons) must be located outside of any Coega Bontveld bushclumps. • The Endangered Wildlife Trust herpetology unit must undertake a search and rescue of the powerline corridor prior to the siting of the servitude within the corridor. • All additional mitigation measures recommended by the Endangered Wildlife Trust, based on their study, must be included in the EMPr. • Monitoring by a suitably qualified herpetologist must take place during the construction period to ensure that any Albany Adder’s found during the period are relocated to a suitable habitat.

Significance Statement: Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase Powerline 1 Permanent Localised Moderate May Occur HIGH - Without mitigation Powerline 1 Short Term Localised Moderate May Occur MODERATE - With mitigation Powerline 2 Permanent Localised Moderate May Occur HIGH - Without mitigation Powerline 2 Short Term Localised Moderate May Occur MODERATE - With mitigation Powerline 3 N/A N/A N/A N/A N/A Without mitigation Powerline 3 N/A N/A N/A N/A N/A With mitigation No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Regional Moderate May Occur MODERATE -

Impact 1.1.1.7: The blocking or delaying of signal to electronic devices caused by wind turbines

Cause and Comment

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WEFs can cause television, radio and microwave interference by blocking and/or causing part of the signal to be delayed.

Mitigation Measures • Accurate siting of wind turbines in the planning and design phase will reduce the possibility of these impacts • If complaints are received by neighbouring landowners regarding the issue, then the developer must investigate and mitigate these issues to the best of their abilities.

Significance Statement: WEF Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase Without mitigation Long Term Study Area Moderate May Occur MODERATE - With mitigation Long Term Study Area Moderate Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

Impact 1.1.1.8: The movement of turbines could cause a phenomenon called shadow flicker, which could result in health impacts to individuals exposed for extended periods of time

Cause and Comment Rotating wind turbine blades interrupt the sunlight producing unavoidable flicker bright enough to pass through closed eyelids, and moving shadows cast by the blades on windows can affect illumination inside buildings. This effect is commonly known as shadow flicker. Wind turbine shadow flicker has the potential to induce photosensitive epilepsy seizures however the risk is low with large modern models and if proper planning is adhered to. It is possible to model the potential shadow flicker and determine potential negative impacts.

Mitigation Measures • Planning should ensure the flash frequency does not exceed three per second, and the shadows cast by one turbine on another should not have a cumulative flash rate exceeding three per second.

Significance Statement: WEF Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Planning and Design phase Without mitigation Long Term Study Area Moderate May Occur MODERATE - With mitigation Long Term Study Area Moderate Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Regional Moderate Likely MODERATE -

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Impact 1.1.1.9: Conflict with the Coega IDZ OSMP

Cause and Comment Powerline Alternative 1 and Powerline Alternative 2 traverse the Coega IDZ (zones 14 and 5). The Coega OSMP sets out the uses of the open space areas within the Coega IDZ and was one of the conditions of approval as set out in the applicable ROD (related to the RODs obtained by Coega in the IDZ). The OSMP informed the preparation of the Management Guidelines for the various open space uses identified on the plan, to identify the actions required to implement the Management Guidelines. Powerline Alternatives 1 and 2 may be in conflict with the spatial planning of the Coega OSMP.

Mitigation Measures • The powerline servitude siting of powerline pylons must avoid intact Coega Bontveld bushclumps; • The powerline servitude siting of powerline pylons must utilise previous disturbed areas where feasible; • The siting of the powerline must take into account existing roads to ensure that the jeeptrack required for maintenance purposes has a reduced impact; • Any additional mitigation measures required by the CDC must be taken into account in the EMPr (dependant on the authorisation of the specific powerline alternative); • Minimise the siting of powerline pylons on steep slopes, wetlands and the Coega River; • Minimise potential impacts after construction by stabilising and rehabilitating disturbed areas; • The construction of any the powerline must comply with the CDC’s Environmental Specifications for Construction; • Minimise vegetation clearing during construction by ensuring that vegetation under the conductors is not cleared. Vegetation should only be cleared around the powerline pylons and the jeeptrack; • Rescue plant species protected under the Provincial Ordinance and/or translocate to areas requiring rehabilitation; • Remove and store topsoil for later use during rehabilitation. Topsoil must not be contaminated with other material or compacted by vehicular traffic; and • Bird flight diverters (BFD's) may need to be installed to increase the visibility of the powerlines where they cross the Coega River.

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With mitigation Powerline 3 N/A N/A N/A N/A N/A Without mitigation Powerline 3 N/A N/A N/A N/A N/A With mitigation No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Regional Moderate Likely MODERATE -

1.2 Construction Phase Impacts

1.2.1 General

Impact 1.2.1.1: Dust associated with an increase in vehicles on site could result in health impacts

Cause and Comment Dust is likely to be a potential nuisance during the construction due to an increase in vehicles transporting supplies during this period. Also as a result of vegetation clearing. This is the main cause. Dust can have detrimental effects on human health for individuals within a close proximity to the site.

Mitigation Measures • Nuisance dust can be reduced by implementing the following: o Damping down of un-surfaced and un-vegetated areas using water from a licensed source; o Retention of vegetation where possible; o Only clear what is strictly necessary at any one time, i.e. do not clear the entire site at the beginning of construction; o Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of dust to surrounding areas o Surface all access roads with a gravel layer before commencing any construction activities; and o A speed limit of 40km/h must not be exceeded on dirt roads. • Any complaints or claims emanating from the lack of dust control should be attended to immediately by the Contractor.

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Cumulative N/A N/A N/A N/A N/A

Impact 1.2.1.2: Noise pollution

Cause and Comment Adverse noise effects will occur during the construction period due to movement and use of heavy machinery. Activities such as excavation of foundations, road construction and vegetation stripping could lead to adverse noise for individuals located within close proximity of the construction site.

Mitigation Measures • Ensure that all equipment is properly maintained and faulty silencers are replaced immediately. • Follow the recommendations provided in the Environmental Management Programme (EMPr) to limit disturbance created by noise and vibration. These include: o Concentrate all construction activities during the daytime hours (between sunrise and sunset), where feasible. o Provide ear protection equipment to staff working directly with noise generating machinery, also during short stays in areas with excessive noise. o Install silencers and noise control mechanisms (insulates) in equipment and machines that generate high levels of noise. • Avoid unnecessary idling times. • Minimizing the need for trucks/equipment to reverse. This will reduce the frequency at which disturbing but necessary reverse warnings will occur. Alternatives to the traditional reverse ‘beeper’ alarm such as a ‘self- adjusting’ or ‘smart’ alarm could be considered. These alarms include a mechanism to detect the local noise level and automatically adjust the output of the alarm is so that it is 5 to 10 dB above the noise level in the vicinity of the moving equipment. The promotional material for some smart alarms does state that the ability to adjust the level of the alarm is of advantage to those sites ‘with low ambient noise level’ (Burgess & McCarty, 2009).

Impact 1.2.1.3: Unnecessary disturbance of vegetation due to sprawl of campsite could cause a loss of biodiversity.

Cause and Comment An unnecessary sprawl of the construction camp site beyond the demarcated area could result in an increase in the loss of vegetation and biodiversity surrounding the campsite.

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Mitigation Measures • The ECO must assist in the siting of all construction camp related structures (including any concrete batching plants or centralised concrete mixing areas) and supervise any bush clearing for the construction camp. • The construction camp should be clearly demarcated and fenced to avoid sprawl. • The construction area must be located in a degraded area where very little to no bush clearing is required to the extent possible. Where permits are required to remove plants, these will be applied for by the developer prior to the start of construction; • The camp site may not be located in the Coega IDZ; and • If there is a concrete batching site, it should be fenced. Shade cloth should be attached to the fence to stop sand blowing around.

Impact 1.2.1.4: Inappropriate storage and handling of hazardous substances could lead to surface and ground water pollution

Cause and Comment Inappropriate storage and handling of hazardous substances such as diesel, paint, pesticides, etc. could lead to surface and ground water pollution due to, for example, oil leaks, spillage of diesel, etc. The total amount of hazardous goods required for the construction phase is 27.21m3.

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With mitigation Long Term Localised Moderate Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

Impact 1.2.1.5: Littering and the use of informal ablution facilities by construction workers could cause surface and ground water pollution

Cause and Comment The littering of general waste and the use of the surrounding environmental as informal ablutions by construction workers could lead to pollution in the surrounding water sources and the general vegetation which could have a detrimental impact on plant and animal species in the surrounding areas.

Mitigation Measures • Littering must be avoided and litter bins must be made available at various strategic points onsite. • Refuse from the construction site must be collected on a regular basis and deposited at an appropriate landfill site. • The bins should be animal proof i.e. the lids must not allow animals to get in and scavenge. • There must be sufficient litter bins on site and they should be emptied regularly and as necessary. Waste manifests to be provided by the municipality to prove legal disposal. • Portable ablution facilities must be located on site and must be situated away from (>50m) from any watercourses.

1.2.2 Ecological (as per Ecological Impact Assessment, Appendix D)

Impact 1.2.2.1: Loss of Bontveld vegetation

Cause and Comment Vegetation clearance for the proposed development and associated infrastructure such as linear infrastructure will result in a direct loss of Bontveld vegetation. All nine (9) of the turbines are located within Bontveld vegetation and all three grid connection corridors have areas larger than 200ha of this vegetation unit. It should however be noted that the powerline will have a 12 m wide servitude and only small amounts of vegetation clearing will be required. Impacts in Coega Bontveld can be reduced by strategically placing infrastructure to avoid bushclumps (which has been done

www.dedea.gov.za for the main Wind Farm components) and succulent patches which are the sensitive components of this vegetation type. For the grid connection powerline and servitude, effective measures must be taken to ensure that the impacts in these areas are reduced where feasible and that project infrastructure such as pylons are realigned to avoid large bushclumps and succulent patches.

Under the no-go option the overall impact would be minimal to moderate as there is already loss of indigenous vegetation in the area due to the presence of mining activities and an existing operation WEF and other infrastructure such as substations. Poor land management is also evident. Further loss and degradation of the vegetation is likely to occur as a result of the above.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance WEF Without Permanent Study Area Moderate Definite MODERATE - Mitigation WEF With Permanent Localised Slight Probable LOW - Mitigation Powerline 1 Permanent Study Area Moderate Definite HIGH - Without Mitigation Powerline 1 Permanent Localised Slight Probable LOW - With Mitigation Powerline 2 Permanent Study Area Moderate Definite HIGH - Without Mitigation Powerline 2 Permanent Localised Slight Probable LOW - With Mitigation Powerline 3 Permanent Study Area Moderate Definite HIGH - Without Mitigation Powerline 3 Permanent Localised Slight Probable LOW - With Mitigation No-Go Option Long term Study Area Slight Probable LOW - Cumulative Permanent Regional Moderate Probable MODERATE -

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• A 10 m safe buffer should be placed around all bushclumps which should be deemed no-go areas. • The clearance of vegetation at any given time should be kept to a minimum in order to reduce the possibility of soil erosion. • Vegetation clearing and trampling should be avoided in areas demarcated as no-go areas. • Temporary infrastructure such as the site camp, laydown areas and storage areas must be placed in areas already transformed. • Employees must be prohibited from making fires and harvesting plants. • All alien vegetation within the development footprint should be removed from site and disposed of at a registered waste disposal site for the duration of construction and continuous monitoring of seedlings need to occur. • Only indigenous species should be used for Rehabilitation purposes. • As far as practically be possible, existing roads needs to be utilised. • All species protected in terms of the PNCO and ToPS regulations will require permits from DEDEAT prior to their removal. • Any protected trees outside of the IDZ that need to be removed will require a permit from DAFF. Approval within the IDZ must be sought through the CDC.

Impact 1.2.2.2: Loss of Thicket vegetation

Cause and Comment Vegetation clearance for the proposed development will result in a direct loss of Thicket vegetation. This area, although intact in some parts has been impacted by the invasion of alien species as well as by the disturbance of the current land use in the area where some of the vegetation has been removed as a result of other developments (mining etc.). None of the turbines occur within the Thicket vegetation. Only linear infrastructure will result in the direct loss of this vegetation type. Where possibly linear infrastructure has been placed in along existing roads/disturbed areas to keep vegetation clearance to a minimum. Large areas within the grid connection corridors are within this vegetation unit and some loss of Thicket is expected, however this will be confined to the location of the powerline servitude and pylons and will not be the full extent of these corridors and with affective management and placement of these within less intact portions, the impact can effectively be managed. It should also be noted that only one corridor will be chosen and one grid connection powerline will be developed.

Under the no-go option the overall impact would be minimal as there is already loss of indigenous vegetation in the area due to the presence of mining activities and an existing operation WEF. Further loss and degradation of the vegetation is likely to occur as a result of the above.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance WEF Permanent Study Area Slight Definite LOW - Without Mitigation “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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WEF Permanent Localised Slight Definite LOW - With Mitigation Powerline 1 Permanent Study Area Slight Definite MODERATE - Without Mitigation Powerline 1 Permanent Localised Slight Definite LOW - With Mitigation Powerline 2 Permanent Study Area Slight Definite MODERATE - Without Mitigation Powerline 2 Permanent Localised Slight Definite LOW - With Mitigation Powerline 3 Permanent Study Area Slight Definite MODERATE - Without Mitigation Powerline 3 Permanent Localised Slight Definite LOW - With Mitigation No-Go Option Long term Study Area Slight Probable LOW - Cumulative Permanent Regional Moderate Probable MODERATE -

Mitigation Measures • A comprehensive Search and Rescue prior to vegetation clearance must be undertaken. • SCCs should either be housed in an onsite nursery for use during rehabilitation or be relocated to suitable areas where vegetation clearance will not occur. • If possible, the removal of Milkwood trees should be avoided, however where not possible applicable permits have to be obtained prior to vegetation clearance. • Large populations of Aloes should be avoided. • A 10 m safe buffer should be placed around all bushclumps which should be deemed no-go areas. • The clearance of vegetation at any given time should be kept to a minimum in order to reduce the possibility of soil erosion. • Vegetation clearing and trampling should be avoided in areas demarcated as no-go areas. • Temporary infrastructure such as the site camp, laydown areas and storage areas must be placed in areas already transformed. • Employees must be prohibited from making fires and harvesting plants. • All alien vegetation within the development footprint should be removed from site and disposed of at a registered waste disposal site for the duration of construction and continuous monitoring of seedlings need to occur. • Only indigenous species should be used for Rehabilitation purposes. • As far as practically be possible, existing roads needs to be utilised.

Impact 1.2.2.3: Removal of Alien Vegetation

Cause and Comment

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The construction of the development will result in the clearance of alien vegetation already present on portions of the study area. This will be a positive impact as alien invasive species will be removed and consequently this will also improve the condition of the existing indigenous vegetation as there will be less competition from alien invasives.

Under the no-go option the existing alien vegetation will continue to encroach the study area until it eventually replaces the indigenous vegetation and it is very likely that these will spread to the surrounding environment.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Without Mitigation Long term Study Area Slight beneficial Definite LOW + With Mitigation Long term Study area Moderate beneficial Definite MODERATE + No-Go Option Long term Study Area Moderate Definite MODERATE - Cumulative Long term Regional Moderate beneficial Definite MODERATE +

Mitigation Measures • All alien vegetation within the development footprint should be removed from site and disposed of at a registered waste disposal site for the duration of construction and continuous monitoring of seedlings need to occur until construction is complete.

Impact 1.2.2.4: Loss of Plant Species of Conservation Concern

Cause and Comment Approximately seventeen (17) species are listed as protected on the Eastern Cape PNCO list, and one (1) on the NEM:BA list. One (1) protected tree species (Sideroxylon inerme) was recorded to occur as scattered individuals within the study area. Appendix 2 of the Ecological Impact Assessment Report provides a comprehensive list of species found and expected to be found within the study area. There may be a number of additional species of conservation concern that could be found on site during construction that were not observed during this study.

The impacts at a larger spatial scale will only be important in the case of species that have a globally restricted range, or are otherwise in need of protection. In these cases development of any sort may significantly reduce the area of occupancy of the species. A reduction of the area of occupancy in turn may threaten the chances of survival for these plant species of concern. Given the location of this site and the relatively small to medium footprint (large areas are linear infrastructure) of the development it is unlikely that this development will result in the severe loss of habitat availability and SCC as these can possibly be avoided. However, due to the species richness and abundance of SCC within the grid connection corridors, it is anticipated that not all SCC can be avoided.

Under the no-go option the area may lose some indigenous species as alien invasive species compete with the indigenous plant species and continuous disturbance can also negatively affect the species present in the area. In “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

www.dedea.gov.za addition, there is already disturbance in the form of clearing in and around the study area for mining etc. and the further loss of SCC is probable.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance WEF Permanent Study Area Severe Definite MODERATE - Without Mitigation WEF Permanent Localised Slight Unlikely LOW - With Mitigation Powerline 1 Permanent Study Area Severe Definite HIGH - Without Mitigation Powerline 1 Permanent Localised Slight Unlikely MODERATE - With Mitigation Powerline 2 Permanent Study Area Severe Definite HIGH - Without Mitigation Powerline 2 Permanent Localised Slight Unlikely MODERATE - With Mitigation Powerline 3 Permanent Study Area Severe Definite HIGH - Without Mitigation Powerline 3 Permanent Localised Slight Unlikely MODERATE - With Mitigation No-Go Option N/A N/A N/A N/A N/A Cumulative Permanent Regional Moderate Probable MODERATE -

Mitigation Measures • No development should occur in the bushclumps and succulent patches associated with the Bontveld as it is has been identified as an area of high sensitivity. • Prior to the construction of the proposed WEF: o Each turbine site and the final location of the grid connection powerline must be groundtruthed and SCC identified and the correct permits acquired for their removal, should any be removed. o A search and rescue plan must be developed in order to identify and transplant SCC, some of these species will not transplant thus areas with these species should be avoided as far as possible and be left undisturbed. o Species of special concern must be marked/tagged prior to construction. • During Construction of the proposed WEF: o Employees must be prohibited from harvesting wild plants. o Fires must be prohibited, except in areas which are clearly demarcated and contain safety equipment. o Laydown areas must be rehabilitated once they are no longer required and an alien invasive management program implemented to ensure alien species do not invade these areas. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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o Construction activities must remain within the demarcated area. • An ECO must be employed to ensure that the construction activities remain within the designated area and that no unauthorised activities occur. • A search and rescue plan is recommended for species that are likely to have a high survival rate such as Aloe and Euphorbia species. • The disturbed area must be rehabilitated with indigenous plant species and seedlings of alien vegetation must be removed on a continuous basis during the construction phase.

Impact 1.2.2.5: Loss of Faunal SCCs

Cause and Comment A few faunal species of conservation concern (SCC) occur within the study area. Disturbance during the construction phase may result in the displacement of various animal species due to loss of habitat, and an increase in traffic in the area could result in road fatalities for slow moving animals and affect SCC. An increase in noise could impact the breeding behaviour of some species. However, the construction period will be of short duration.

Under the no-go option the overall impact would be low negative, as the area would continue in its current state where disturbance by mining and other activities is already evident.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Without Mitigation Permanent Study Area Severe Definite MODERATE - With Mitigation Permanent Localised Slight Unlikely LOW - No-Go Option Long term Study Area Slight Probable LOW - Cumulative Permanent Regional Moderate Probable MODERATE -

Mitigation and management • Clearing or damaging of intact areas should be avoided; • Workers must also be educated on wildlife conservation and must not be allowed to trap or poach animals on site. • The construction site must be monitored for animal traps and evidence of poaching • Curtail unnecessary night driving on roads and implement a speed limit (40km/h is recommended) so that accidents are prevented • Protect abiotic habitats, such as termite mounds which play an important ecological role such as providing shelter for reptiles.

Impact 1.2.2.6: Poaching of Wildlife

Cause and Comment “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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During the construction phase, disturbance by labourers will increase and this may lead to poaching of wild animals within the study area.

Under the no-go option the overall impact would be low negative, as the area would continue in its current state where disturbance by mining and other activities is already evident.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Without Mitigation Permanent Study Area Severe Definite HIGH - With Mitigation Permanent Localised Slight Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Permanent Regional Moderate Probable LOW -

Mitigation and management • Construction employees must be transported to and from the site daily. • No residence may be set up on site. • An inspection of the immediate vegetation surrounding the turbine sites and powerline routes for evidence of snares must be undertaken. These checks must be undertaken twice weekly.

Impact 1.2.2.7: Fragmentation of vegetation and edge effects

Cause and Comment Fragmentation is one of the most important impacts on vegetation, especially when this creates breaks in previously continuous vegetation, causing a reduction in the gene pool and a decrease in species richness and diversity. This impact occurs when areas are cleared to build large developments or an area is invaded by alien invasive plant species. Fragmentation results in the isolation of functional ecosystems, and results in reduced biodiversity and reduced movement due to the absence of ecological corridors. Although the surrounding area already has large areas cleared for various developments this particular development may increase fragmentation within the immediate study area. Having said that, the vegetation on site is partially fragmented from various vegetation corridors by the existing access roads, service corridors, mining etc. In areas where there is already evidence of fragmentation, the construction of the WEF and linear infrastructure could result in the conditions becoming exacerbated.

As mentioned previously, the broader area in which the project is located is currently showing signs of disturbance and is already fragmented, and this is likely to continue even without the proposed project going ahead.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance

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WEF Permanent Study Area Slight Definite LOW - Without Mitigation WEF Long term Localised Slight Definite LOW - With Mitigation Powerline 1 Permanent Study Area Moderate Definite MODERATE - Without Mitigation Powerline 1 Long term Localised Slight Definite LOW - With Mitigation Powerline 2 Permanent Study Area Moderate Definite MODERATE - Without Mitigation Powerline 2 Long term Localised Slight Definite LOW - With Mitigation Powerline 3 Permanent Study Area Moderate Definite MODERATE - Without Mitigation Powerline 3 Long term Localised Slight Definite LOW - With Mitigation No-Go Option Long term Localised Slight Probable LOW - Cumulative Permanent Regional Moderate Definite MODERATE -

Mitigation Measures • No development should occur in the bushclumps and succulent patches associated with the Bontveld as it is has been identified as an area of high sensitivity. • Prior to the construction of the proposed WEF: o Each turbine site and the final location of the grid connection powerline must be groundtruthed and SCC identified and the correct permits acquired for their removal, should any be removed. o A search and rescue plan must be developed in order to identify and transplant SCC, some of these species will not transplant thus areas with these species should be avoided as far as possible and be left undisturbed. o Species of special concern must be marked/tagged prior to construction. • During Construction of the proposed WEF: o Employees must be prohibited from harvesting wild plants. o Fires must be prohibited, except in areas which are clearly demarcated and contain safety equipment. o Laydown areas must be rehabilitated once they are no longer required and an alien invasive management program implemented to ensure alien species do not invade these areas. o Construction activities must remain within the demarcated area. • An ECO must be employed to ensure that the construction activities remain within the designated area and that no unauthorised activities occur. • A search and rescue plan is recommended for species that are likely to have a high survival rate such as Aloe and Euphorbia species.

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• The disturbed area must be rehabilitated with indigenous plant species and seedlings of alien vegetation must be removed on a continuous basis during the construction phase.

Impact 1.2.2.8: Dust as a result of wind erosion

Cause and Comment The removal of vegetation during the construction phase may result in wind erosion of the exposed areas. This will result in the loss of important topsoil and may cause irreversible damage to the landscape if left unmitigated.

Under the no-go option pollution such as litter and other anthropogenic disturbances that has led to degraded land and bare soils is already evident and will continue. In addition, existing mining areas are already emitting dust due to the large open quarries being created.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Without Mitigation Short term Study Area Moderate Definite MODERATE - With Mitigation Short term Localised Slight May occur LOW - No-Go Option Long term Study area Slight Definite LOW - Cumulative Long term Regional Moderate Definite MODERATE -

Mitigation Measures • Construction activities such as digging of trench that can result in excessive dust pollution should preferably cease during period of high winds. • Exposed soil surfaces should be wet down where required to avoid dust emissions. • Vehicles transporting construction material such as building sands should remain at a speed limit of 40km/h and if required cover their loads with a tarpaulin to avoid dust emissions. • Limit the height of stockpiles to 1.5m. • Newly cleared and exposed areas must be managed for dust and landscaped with indigenous vegetation to avoid soil erosion. Where necessary, temporary stabilization measures must be used until vegetation establishes. • Plan for the worst case, that is, for heavy rainfall and runoff events, or high winds. • Appropriate erosion control measures must be implemented and a monitoring programme established to ensure that no erosion is taking place. At the first sign of erosion the necessary remedial action must be taken. • Reasonable measures to limit erosion and sedimentation due to construction activities must be implemented and must comply with the measures outlined in the EMPr as and when required.

Impact 1.2.2.9: Noise pollution on faunal groups

Cause and Comment

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Noise pollution can depress local populations of sensitive faunal groups. Animals differ in the degree to which they tolerate such disturbance, and can be expected to have potentially negative and positive impacts on various faunal groups. For example, large breeding birds are sensitive to noise and increased noise and motor vibrations in the nearby streams may impact amphibian breeding choruses, but these impacts will be localised and many amphibian species are surprisingly tolerant of noise (Branch, pers. comm.). Noise pollution will occur during construction and mitigation measures outlined below will need to be applied.

Under the No-go option, there is currently noise in the form of the mining operations and an operating WEF.

Significance statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Without Mitigation Short term Study Area Moderate Probable LOW - With Mitigation Short term Localised Slight May occur LOW - No-Go Option Long term Study area Slight Definite LOW - Cumulative N/A N/A N/A N/A N/A

Mitigation and management • Noise mitigation is difficult, but reduction measures should be implemented in all sensitive areas (e.g. adjacent to wetlands and rivers) at sensitive times (e.g. at night), except under exceptional circumstances such as completing work that already commenced or when day time working hours were too windy to do turbine erections . • Machinery that generates noise must be regularly maintained in order to ensure that no unnecessary additional noise is produced. • Equipment with lower sound levels should be selected where feasible. • Vehicles associated with the construction of the development, should only be allowed to drive on roads at night if there is an emergency.

1.2.3 Agriculture and Soils (as per Agriculture & Soil Impact Assessment, Appendix D)

Impact 1.2.3.1: Management of hazardous chemicals

Cause and Comment The inadequate management of hazardous substances during the Construction Phase of the proposed Scarlet Ibis WEF could result in soil contamination and a loss of fertile soils due to hazardous substance spills.

Mitigation Measures • Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 must be adhered to. This applies to solvents and other chemicals possibly used during the construction process;

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• Cement must not be mixed directly on the ground, or mixed during rainfall events when the potential for transportation into the stormwater system is the greatest; • Cement must only be mixed in the area demarcated for this purpose and on impermeable surfaces; • Drip trays must be placed under construction machinery to avoid soil contamination; • The appointed ECO must determine the precise method of treatment of polluted soil. This could involve the application of soil absorbent materials, oil-digestive powders to the contaminated soil or the excavation of the contaminated soil depending on the nature of the spill; • If refuelling occurs on site, a dedicated area should be established and refuelling should only take place on impermeable surfaces; • All fuel should be stored in a bunded area; • Ensure all construction machinery is in sound working order to prevent oil leaks; and • Any hazardous materials that need to be stored on site must be done under lock and key.

Significance Statement: WEF Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Construction phase Without Mitigation Medium Term Study Area Severe May Occur MODERATE - With Mitigation Short Term Study Area Moderate May Occur LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

Impact 1.2.3.2: Loss of Livestock and Wildlife Grazing

Cause and Comment The clearance of grasses and shrubs during the Construction Phase for the placement of the wind turbine foundations, associated infrastructure and powerline pylons will result in the loss of land used for livestock and wildlife grazing which could impact on the wildlife and agriculture on the proposed properties.

Mitigation Measures • The clearance of vegetation should be limited to the demarcated construction footprint.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Construction phase Without Mitigation Medium Term Study Area Moderate Definite MODERATE - With Mitigation Medium Term Study Area Slight Definite LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Long term Regional Moderate Definite MODERATE - “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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Impact 1.2.3.3: Soil Compaction

Cause and Comment Soil will be compacted by construction vehicles and construction activities during the Construction Phase. Compacted soil results in the reduced ability for plant growth and water absorption as well as the increase in runoff.

Mitigation Measures • Heavy construction activities should be scheduled to avoid excessively wet periods, where possible; and • Topsoil stockpiles must not be compacted.

Impact 1.2.3.4: Increase in Soil Erosion

Cause and Comment The clearing of vegetation during the Construction Phase will result in the exposure of soils. Exposed soils are susceptible to erosion by wind and water (i.e. run-off) during wind and/or rainfall events. Sections of the proposed Scarlet Ibis WEF site are currently eroded. It is envisioned that sections of the proposed site will continue to erode in the absence of the proposed Scarlet Ibis WEF development.

Mitigation Measures • Disturbance and clearing of vegetation should be kept to the minimum required for the construction of the Scarlet Ibis WEF and associated structures; • All reasonable measures to limit erosion caused by construction activities must be taken; and • The appointed ECO must monitor the soil erosion and remedial action must be taken at the first signs of erosion.

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With Mitigation Short Term Study Area Moderate Probable LOW - No-Go Long Term Study Area Moderate Definite MODERATE - Cumulative Long term Regional Moderate Possible LOW -

Impact 1.2.3.5: Management of Topsoil

Cause and Comment The inadequate management of topsoil during the Construction Phase of the proposed Scarlet Ibis WEF, associated infrastructure and the powerline pylons could result in the loss of important topsoil and may cause irreversible damage to the landscape if left unmitigated. In addition, the loss or damage to topsoil will have a significant impact on the rehabilitation of the site.

Mitigation Measures • Stripping of topsoil should be undertaken in such a manner as to minimise erosion by wind or runoff; • Areas from which the topsoil is to be removed must be cleared of any foreign material which could form part of the topsoil during removal including rubble, any waste material, litter, excess vegetation and any other material which could reduce the quality of the topsoil; • Ensure that subsoil and topsoil are not mixed during stripping, excavation, reinstatement and rehabilitation. If topsoil is mixed with clay subsoil the usefulness of the topsoil for rehabilitation of the site will be lost; • Once cleared, soils should be exposed for the minimum time possible; • Topsoil should be temporarily stockpiled, separate from subsoil and rocky materials; • Topsoil should only be stockpiled in areas designated by the appointed ECO; • Stockpiled topsoil must not be compacted; and • Any excess topsoil that is not used for rehabilitation must be removed from the site.

Impact 1.2.3.6: Inappropriate and Inadequate Rehabilitation

Cause and Comment Inadequate rehabilitation during the Construction Phase of the proposed Scarlet Ibis WEF and powerline could result in the loss of valuable topsoil, irreversible damage to the landscape and the invasion of alien vegetation.

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Mitigation Measures • If the topsoil is sterile or the seedbank is affected then topsoil should be supplemented with an indigenous seed mix; • Soils outside of the development footprint that are exposed during the construction of the WEF and the powerline must only be bare for the minimum time possible; • Stockpiled topsoil must not be compacted; and • The site must be rehabilitated to the satisfaction of the appointed ECO.

1.2.4 Avifauna (as per Avifaunal Impact Assessment, Appendix D)

Impact 1.2.4.1: Destruction or alteration of bird habitat

Cause and Comment Construction of the facility will result in a certain amount of destruction and removal of natural vegetation which was previously available to avifauna for use. This impact is anticipated to be of MODERATE NEGATIVE significance pre mitigation. The area is also significantly disturbed by various human activities including: brickworks (and associated dust blown onto vegetation); pipelines; roads; power lines; and general farming practices. This impact is anticipated to be of MODERATE significance pre-mitigation. A certain amount of habitat destruction is inevitable for the construction of roads and turbines. However by adhering to the sensitivity map developed in the Avifaunal Impact Report, it is possible to reduce the significance of this impact to LOW.

Mitigation Measures • Siting of turbines and the powerline must adhere to the sensitivity map in Section 6 of the Avifaunal Impact Assessment Report (Appendix D)

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Spatial Scale Severity of Impact Likelihood Significance Scale

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Construction phase Without Mitigation Long Term Study Area Moderately severe Definite MODERATE - With Mitigation Long Term Study Area Slight - Definite LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Long term Regional Moderate Possible LOW -

Impact 1.2.4.2: Disturbance of birds during construction

Cause and comment This is rated as LOW significance on account of there being no known sensitive or Red Listed bird species breeding on or near the site. No specific mitigation is required for this impact, unless breeding sites are found prior to construction. If such sites are found, case specific mitigation measures will need to be designed by the specialist as part of the EMPr.

Mitigation measures • Nothing specific required. Adhere to sensitivity map.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Severity of Temporal Scale Spatial Scale Likelihood Significance Impact Construction phase Without Mitigation Short Term Study Area Moderately severe Probable LOW - With Mitigation Short Term Study Area Slight - Probable LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

1.2.5 Bats (as per Bat Impact Assessment, Appendix D)

Impact 1.2.5.1: Loss of foraging habitat

Cause and Comment Loss of foraging habitat. Some minimal foraging habitat will be permanently lost by construction of turbines and access roads. Temporary foraging habitat loss will occur during construction due to storage areas and movement of heavy vehicles.

Mitigation Measures Keep to designated areas when storing building materials, turbine components and/or construction vehicles and keep to designated roads with all construction vehicles. Damaged areas after construction should be rehabilitated by a vegetation succession specialist. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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1.2.6 Heritage (as per Heritage Impact Assessment, Appendix D)

Impact 1.2.6.1: Loss or damage of archaeologically significant features

Cause and Comment The primarily Middle (MSA), but including Later Stone Age (LSA) cultural landscape of the Scarlet Ibis WEF can be described as an organically evolved fossil landscape least evidently shaped by humans, with little to no visual or physical impact altering the landscape itself. Extremely low recorded surface artefact ratios, vast undefined occurrence size and uncertainty thereof as a result of vegetation cover all prohibit further interpretation, but most probably pointing towards a variety of landscape use: Quarrying, or raw material sourcing, and preliminary knapping – more directly associated with surface raw material outcrops across hilly terrain, to process knapping and general landscape use across flats and in proximity to drainage lines and other paleo-water sources.

Mitigation Measures: WEF • If the current layout of the wind energy facility is changed, altered, or additions of infrastructure in area that were covered during this study an archaeological walk-through survey of the changes must be conducted and further mitigatory recommendations made if necessary. • Portions of the proposed area for development are covered in dense vegetation and sites/features may be covered by soil and vegetation and will only be located once this has been removed. A person must be trained as a site monitor to report any archaeological sites found during the development. Construction managers/foremen and/or the Environmental Control Officer (ECO) should be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find sites. • If concentrations pre-colonial archaeological heritage material and/or human remains (including graves and burials) are uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/or the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) (043 745 0888) so that systematic and professional investigation/excavation can be undertaken. Phase 2 mitigation in the form of test-pitting/sampling or systematic excavations and collections of the pre-colonial shell middens and associated artefacts will then be conducted to establish the contextual status of the sites and possibly remove the archaeological deposit before development activities continue.

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Mitigation Measures: Powerline Alternatives • The power line route alternatives (Option 1 and Option 2) are considered as having a low archaeological sensitivity and development may proceed on either of these alternatives. However, Option 2 would be the preferred route owing to most of the area having been disturbed over time by the construction of roads as well as dumping and quarrying/mining activities. A large portion of the route proposed for Option 1 is covered in dense thicket vegetation whereby bush clearing would have to be conducted to create servitude access roads. • If the power line route alternative Option 1 is chosen as the final route, a professional archaeologist must be appointed to conduct archaeological monitoring during the bush clearing and excavation activities of the proposed development and associated infrastructure such as the servitude access roads. • If the proposed power line route alternatives, Option 1 and Option 2, are not preferred, the proposed route for Option 3 an archaeological ground truthing survey should be conducted. • Portions of the proposed area for development are covered in dense vegetation and sites/features may be covered by soil and vegetation and will only be located once this has been removed. A person must be trained as a site monitor to report any archaeological sites found during the development. Construction managers/foremen and/or the Environmental Control Officer (ECO) should be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find sites. • If concentrations pre-colonial archaeological heritage material and/or human remains (including graves and burials) are uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/or the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) (043 745 0888) so that systematic and professional investigation/excavation can be undertaken. Phase 2 mitigation in the form of test-pitting/sampling or systematic excavations and collections of the pre-colonial shell middens and associated artefacts will then be conducted to establish the contextual status of the sites and possibly remove the archaeological deposit before development activities continue. • The developer / ECO / or construction manager must apply to the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) for a destruction permit for the stone artefacts prior to the commencement of the development activities. • It is unlikely that the built environment structure will be negatively impacted during the development, these structures should be noted and avoided for pylon positions.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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Construction phase WEF Permanent Localised Moderate Definite MODERATE - Without Mitigation WEF Permanent Localised Low Probable LOW - With Mitigation Powerline 1 Permanent Localised Low Possible LOW - Without Mitigation Powerline 1 Possible Permanent Localised Low LOW - With Mitigation Powerline 2 Possible Permanent Localised Low LOW - Without Mitigation Powerline 2 Possible Permanent Localised Low LOW - With Mitigation Powerline 3 Permanent Localised Moderate Probable MODERATE - Without Mitigation Powerline 3 Permanent Localised Low Probable LOW - With Mitigation No-Go Option N/A N/A N/A N/A N/A Cumulative Permanent Regional Moderate Probable MODERATE -

Impact 1.2.6.2: Loss or damage of Colonial Period / Contemporary farming infrastructure

Cause and Comment Currently no colonial period/contemporary farming infrastructure is likely to be impacted, but if this changes, an architect historian must be appointed to do an impact assessment and apply for relevant destruction permits if required.

Mitigation Measures No further mitigation is required as this site should not be impacted by the development. In the event of a possible future impact, a list must be kept by the developer for inclusion in the ECO / heritage monitoring report.

1.2.7 Paleontological (as per Paleontological Impact Assessment, Appendix D)

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Impact 1.2.7.1: Disturbance, damage or destruction of fossil heritage during the construction phase of the WEF

Cause and Comment Over most of the study area the geology is masked by a thin veneers of calcrete, quaternary alluvium, soil and vegetation. Where this is penetrated to a few metres depth by quarries and river courses it is revealed that it is underlain by paleontologically rich and potentially important strata. These include marine Miocene to Pliocene strata of the Alexandria Formation, early Cretaceous marine strata of the Sundays River Formation and early Cretaceous fluvial deposits of the Kirkwood Formation. Considering the large size of holes excavated for the footings of wind turbines it seems likely that many, if not most of these, will penetrate deeply enough to disturb potentially fossil rich strata. Impacts associated with the disturbance, damage or destruction of fossil heritage during the construction phase of the WEF are probable and permanent in effect but significant impacts are likely to be limited to small portions of the development footprint. The overall significance of the impact without mitigation would be MODERATE NEGATIVE. Impact significance can be meaningfully reduced through mitigation but will still remain moderate negative. Improved understanding of local fossil heritage through professional paleontological mitigation can be viewed as a positive impact, however.

Mitigation Measures Excavation of footing holes should therefore be monitored, either by a palaeontologist or by an ECO trained by and in correspondence with a palaeontologist. This should be discussed between the palaeontologist, ECO and site engineer prior to the commencement of work.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Construction phase Without Mitigation Permanent Localised Slight Probable MODERATE - With Mitigation Permanent Localised Slight Probable MODERATE - No-Go Permanent Localised Slight Probable LOW + Cumulative Permanent Localised Moderate Probable MODERATE -

1.2.8 Visual (as per Visual Impact Assessment, Appendix D)

Impact 1.2.8.1: Visual impact of construction activity

Cause and comment There are various activities which will take place during the construction phase which will have impacts on sensitive visual receptors: • Large areas of vegetation will need to be cleared to make way for digging of the turbine foundations, hardstand areas, substation footprints, access roads, laydown areas, workshops and storage yards.

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• Construction of wind turbines will potentially draw attention if they are exposed above the skyline. • There will be a large increase in the movement of vehicles in the area: large trucks delivering supplies and construction material; graders, excavators and bulldozers; light vehicle movement around site; large trucks hauling rubble and construction waste, etc. • Soil stockpiles and heaps of vegetation debris. • Dust emissions from construction activity.

The duration of the construction phase impacts will be “Short Term”. The extent is “Regional” as construction activity will be visible beyond the immediate environs of the site. The severity of the impact is expected to be “Moderate” should mitigation measures not be employed. If they are, the impact is expected to be “Slight”. The likelihood of surrounding farmers having their views impacted by construction activity is “Definite”.

Mitigation measures • The construction contractor should clearly demarcate construction areas so as to minimise site disturbance. • Treat roads to reduce dust emissions. • The site should be kept neat and tidy. Littering should be fined and the ECO should organise rubbish clean-ups on a regular basis.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Severity of Temporal Scale Spatial Scale Likelihood Significance Impact Construction phase Without Mitigation Short term Regional Moderate Definite MODERATE - With Mitigation Short term Regional Slight Definite MODERATE - No-Go Option N/A N/A N/A N/A N/A Cumulative N/A N/A N/A N/A N/A

1.2.9 Noise (as per Noise Impact Assessment, Appendix D)

Impact 1.2.9.1: Construction Phase Noise

Cause and comment The impact assessment for the various construction activities are described in section 4.1 of the Noise Impact Report, defined and assessed in section 8.1 of the Noise Impact Report. Considering the projected noise levels as well as the expected daytime ambient sound level (higher than 45 dBA), there is a very low risk for a noise impact during the construction phase for daytime construction activities (see impact table below). Similarly, considering potential night- time equivalent rating levels for a rural noise district (35 – 42 dBA) the significance of a construction noise impact would be low.

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Significance Statement (assessed and represented per NSD): WEF

Significance

Probability

Magnitude

Duration Projected Average Extent NSD noise level daytime ambient

(dBA) sound levels

1 28.6 Low Short Localised Improbable Low 2 30.1 Low Short Localised Improbable Low

(low wind (low 3 32.1 Low Short Localised Improbable Low

45 4 38.8 Low Short Localised Improbable Low

–

52 dBA52 5 36.5 conditions Low Short Localised Improbable Low 6 41.0 Low Short Localised Improbable Low 7 45.6 Low Short Localised Improbable Low

)

8 33.5 Low Short Localised Improbable Low 9 39.2 Low Short Localised Improbable Low Comments: Assuming an ambient sound level of 45 dBA to estimate the magnitude rating in line with the precautionary principle. Probability is estimated considering the likely range of ambient sound levels as well as total projected noise levels. Confidence in High finding Mitigation Mitigation is not required measures Cumulative impacts Construction noises will cumulatively add to any other noises in the area, but it will be insignificant. This impact will only disappear after the operational phase finished and rehabilitation of the area is Residual Impacts: completed.

1.2.10 Social

Impact 1.2.10.1: Influx of jobseekers and the impact of temporary construction workers

Cause and Comment A 8-month construction period is foreseen and approximately 100 to 300 workers would intermittently be on site per month. An estimated 80 - 90% of these jobs would be allocated to unskilled and semi-skilled positions.

Negative impacts resulting from an inflow of temporary workers and jobseekers could include: • Conflict between locals and ‘outsiders’ if an outside labour force receives preference; • Provision of accommodation for temporary workers could become an economic and social burden for the developer and the Municipality; • Workers that remain in the area after the construction period ends could place additional pressure on local government for housing and associated infrastructure and services. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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• An increase of single-headed households without a main income provider and pressure on health care, social grants and infrastructure; • Poor control and management of the area where jobseekers gather could result in environmental issues and pollution (littering, inadequate sanitation facilities, etc.); and • Safety and security issues for the surrounding communities due to an influx of ‘jobless’ people.

Mitigation Measures • Co-operate with the NMBM and CDC and their relevant structures to compile / update a database of an available labour force, skills requirements, etc. This process should start well in advance of the construction period commencing. • Liaise with NMBM regarding their methods used to advertise for employment. Take care not to create unrealistic expectations and communicate the time frames, skills requirements and commencement of the activities clearly to the communities. • Set up a central labour desk where workers register. Only workers registered on this database should be considered for employment. • Recruitment of temporary workers at the access to the construction site should not be allowed. The Community Liaison Officer (CLO) should work in consultation with the Ward Councillors and community representatives to establish labour desks at the most suitable localities within the communities where workers are sourced. • The area where workers are recruited should not be near schools or other sensitive receptors where a large influx of people could cause safety and security impacts for the residents and other parties. Provide sufficient sanitation and refuse facilities to curb littering and pollution. • Identify a CLO for the various areas/regions well in advance of the construction period commencing. Set up criteria for the CLO’s to ensure that the correct people are appointed. The CLO should have knowledge of the local community members and area, be educated, committed to the cause, accessible for community members as well as for the developer, etc. • Give preference to workers from the local and metropolitan municipal area. • Contractually oblige Sub-contractors to only employ workers through the labour desk and make this fact known to the communities. This would address and limit the uncoordinated influx of people to the site and to the surrounding towns, as they would be unable to secure work if not through the labour desk. • Issues such as accommodation for workers, transport, catering and any other needs for employees, whether locals or outsiders, must be discussed with the Metropolitan Municipality in good time. Once construction starts structures must already be in place to address SMME needs and requirements and implement management measures.

No-go option: • The influx of jobseekers would not be affected. However, seasonal workers would still move into the area seeking employment at packing sheds and farms.

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• Impacts on health services due to HIV and the spreading of other STD’s, conflict between locals and outsiders, impacts on infrastructure and housing would not be affected and pressure on the Municipality for service delivery would not be impacted.

Impact 1.2.10.2: Skills development and capacity building

Cause and Comment Skills development and capacity building for workers, whether through training or hands-on experience would be a positive outcome of the construction phase. However, due to the relative short length of the construction phase it is doubtful that comprehensive skills training programmes could be undertaken.

The majority of the workforce would be unskilled labour that does manual labour and activities which requires minimal previous work experience or training (digging of trenches, site clearing, etc.). However, experience gained at the construction site could, to a certain extent, be advantages for these workers once they seek employment at other construction sites.

Semi-skilled labour would require previous work experience and/or a certain level of training as pre-requisite of employment. Skills development and capacity building for the anticipated 10-15% of the workforce would thus be valuable and significant and in addition to technical training, could include Fire Marshall training, First Aid Training, etc.

Skilled workers would fill specialist positions and a higher / tertiary education would be essential. Even as such, renewable energy technology is new technology in South Africa and on-site training and skills transfer, especially for South Africans, is likely.

Mitigation Measures • Suitable semi and skilled employees have to be identified. Tap into existing skills databases of the affected Municipality and Coega IDZ and do a skills audit of the available workforce. • Compile a training programme and train workers where possible in advance to maximize skills development and minimize the number of people that are brought in from other areas.

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No-go option • Should the project not be implemented no skills development would manifest.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Construction phase Without Mitigation Short Term Regional Slight May occur LOW + With Mitigation Short Term Regional Moderate Probable MODERATE + No-Go Short Term Regional Slight Unlikely LOW - Cumulative Short Term Regional Moderate Probable MODERATE +

Impact 1.2.10.3: Skills development of supporting industries / local SMMEs

Cause and Comment Supporting industries refer to small business enterprises and services that would be required to fulfil needs or requirements that develop as a result of the construction activities and would thus fall under the ‘Enterprise Development’ (ED) and ‘Socio-economic Development’ (SED) component of the project. This could include catering, laundry services, suppliers of protective clothing, transport, etc.

It would be the responsibility of the Municipality to ensure that SMME’s are prepared and registered in order to tender and emphasis is placed on their role in this regard in the mitigation measures proposed below.

Mitigation Measures • Involve the NMBM in the ED’s and SED’s from the onset of the project through open engagement. The Developer should identify the needs and service requirements and convey this to the local Municipal structures and appoint service providers well in advance to ensure that they are prepared and trained once construction starts. • The Municipal structures, Ward Councillors and Ward Committees are responsible to transfer information to their constituencies, create task teams and/or PSC’s that would ensure compliance with tender procedures. • Municipal structures could train SMMEs and PDIs and assist them in registering and preparing for tender. • Appoint a Compliance Officer (CO) that monitors the processes and ensures compliance with the recruitment policies.

No-go option • Less economic development and SMME opportunities for locals.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance

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Construction phase Without Mitigation Short term Regional Slight May occur LOW + With Mitigation Short term Regional Moderate Probable MODERATE + No-Go Short term Regional Slight Unlikely LOW - Cumulative Short Term Regional Moderate Probable MODERATE +

Impact 1.2.10.4: Impacts on the Local Economy

Cause and Comment Positive impacts for the local economy associated with the construction phase would include: • Employment of locals and an increase in salary earners; • Contracts with SMME’s and local service providers (catering, transport, etc.) where possible; • Local procurement of material and goods, if possible; • Increase in spending power and expenditure on groceries, goods and services, which would be advantages for local merchants, food suppliers and informal traders; and • Accommodation of foreigners in local establishments and other spin-offs.

Local procurement would be more focused on the procurement of general construction materials and goods as the majority of technology requirements would be imported. The site is located in relative close proximity to a number of industrial zones in the NMBM where manufacturing of components, material and goods could be produced to the benefit of the local economy.

No-go option • No positive impacts on the local economy would be experienced as a result of the WEF development (employment and SMME development, etc. would not be influenced).

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Construction phase Without Mitigation Short Term Regional Slight Definite MODERATE + With Mitigation Short Term Regional Moderate Definite MODERATE + No-Go Short Term Regional Slight Unlikely LOW - Cumulative Short Term Regional Moderate Probable MODERATE +

Impact 1.2.10.5: Impacts on the Nelson Mandela Bay Metropolitan Municipality

Cause and Comment The proposed construction project would hold economic advantages for the affected Municipality in terms of employment, skills development, small business development and other possible spinoffs. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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However, a project of this nature also poses various challenges for Municipalities. These include possible shortfalls in capacity and management experience, bureaucratic procedures that hamper progress, financial constraints, possible exploitation and even corruption opportunities.

Specific impacts on the NMBM as a result of the construction phase of the Scarlet Ibis WEF would include: • An increase in responsibility to do a skills analysis, compile a database of an available local workforce, identify local service providers and provide relevant training; • Issuing of zoning permits timeously; • Representation on the Environmental Monitoring Committee (EMC) to do environmental monitoring of the construction site, representation on a Project Steering Committee (PSC) and any other structures, which requires extra time and capacity; and • Legal responsibilities in terms of actions against land owners, the developer or any other parties that contravene Municipal bylaws.

Mitigation Measures • Set up a Steering Committee for the duration of the construction period to serve as a platform where progress can be monitored and conduct quarterly Steering committee meetings where any complaints and grievances can be addressed. DEDEAT should be represented on the EMC and PSC. • Apply timeously for the relevant zonings and permits.

No-go option • No impacts on job descriptions and/or responsibilities of Government Officials.

1.3 Operational Phase Impacts

1.3.1 General

Impact 1.3.1.1: The WEF will contribute towards a reduction in the need for fossil fuels resulting in an improved air quality and contributing toward the mitigation of climate change

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Cause and comment The electricity generated by the development will displace some of that produced by fossil fuel based forms of electricity generation. The scheme, over its lifetime, will therefore avoid the production of a significant amount of CO2, SO2 and

NO2 that would otherwise be emitted to the atmosphere.

Mitigation measures • Enhance this impact by promoting the use of renewable energy locally.

Significance Statement: WEF Effect Risk or Impact Overall Significance Temporal Scale Spatial Scale Severity of Impact Likelihood Operational Phase Without mitigation Long Term International Mod. Beneficial Probable BENEFICIAL + With mitigation Long Term International Beneficial Probable VERY BENEFICIAL + No-Go Long Term International Slight Possible LOW - Cumulative Long Term International Beneficial Probable VERY BENEFICIAL +

1.3.2 Ecological (as per the Ecological Impact Assessment, Appendix D)

Impact 1.3.2.1: Invasion of alien plant species

Cause and Comment The removal of existing vegetation creates ‘open’ habitats that will inevitably be colonised by pioneer plant species. While this is part of a natural process of regeneration, which would ultimately lead to the re-establishment of a secondary vegetation cover, it also favours the establishment of undesirable species in the area, such as Acacias, Opuntia sp and weeds. These species colonise areas of disturbance and once established, they are typically very difficult to eradicate and can pose a threat to the ecosystem. The study area has a number of alien species present and the seedbank is therefore likely to contain seeds primarily from these undesirable species.

Under the no-go option the existing alien vegetation will continue to encroach and it is very likely that these will spread to the surrounding environment.

Mitigation Measures • Implement an Alien Management Plan during the operational phase for the first year after construction has been completed. • Eradicate alien plants from the impacted area as they appear; and • Monitor the study area for any new growth of invasive plants (every 3 months for a period of 12 months after the completion of construction).

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• A rehabilitation plan must be designed and implemented; • During the rehabilitation of the area, measures should be put in place to prevent accidental or unintended introduction of alien species from occurring; and • An Alien Invasive Control Programme must be implemented.

No-Go Option: If no development was to occur on the site the overall impact would be MODERATE NEGATIVE since the existing alien invasive species will continue to increase in numbers in the project area due to the current land-use.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Impact Total Score Temporal Scale Spatial Scale Severity of Impact Likelihood Operational phase Without Mitigation Permanent Study Area Severe Probable HIGH - With Mitigation Long Term Localised Mod. Beneficial Probable LOW + No-Go Permanent Study Area Moderate Definite MODERATE -

1.3.3 Agriculture and Soils (as per the Agriculture & Soils Impact Assessment, Appendix D)

Impact 1.3.3.1: Increase in Soil Erosion

Cause and Comment The increase in hard surfaces during the Operational Phase, including turbine foundations, will increase runoff and could result in an increase in soil erosion.

Sections of the proposed Scarlet Ibis WEF site and the powerline corridors are currently eroded. It is envisioned that sections of the proposed site will continue to erode in the absence of the proposed Scarlet Ibis WEF and powerline development.

Mitigation Measures • All reasonable measures to limit erosion during the Operational Phase must be taken; and • Remedial action must be taken at the first signs of erosion.

Significance Statement: WEF and Powerline Alternative Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Long Term Study Area Moderate Definite MODERATE - With Mitigation Short Term Study Area Slight Probable LOW - “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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No-Go Long Term Study Area Moderate Definite MODERATE - Cumalative Long Term Study Area Moderate Definite MODERATE -

Impact 1.3.3.2: Loss of Potential Agricultural Land

Cause and Comment The construction of the Scarlet Ibis WEF will contribute to the overall reduction of available land for potential agricultural development in the Eastern Cape Province. Loss of land currently utilised as agricultural land is definite. The extent of the impact is likely to occur over a long period (20 years) but will be localised to the immediate study area. Mitigation will not change the overall significance of the impact but will reduce the cumulative impact.

Mitigation Measures No mitigation has been provided because the proposed site consists of scarce or absent soils that favour arable land use and the agricultural land identified on the proposed Scarlet Ibis WEF site consists of areas cleared for grazing and only the footprint of the proposed WEF will impact on the available grazing as livestock and wildlife will be able to graze around and underneath the turbine structures.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Long Term Regional Slight Definite LOW - With Mitigation Long Term Regional Slight Definite LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Regional Slight Definite LOW -

1.3.4 Avifauna (as per Avifaunal Impact Assessment, Appendix D)

Impact 1.3.4.1: Displacement of birds from the site and barrier effects

Cause and comment Once operational the facility could displace certain birds from the area, or cause them to fly further to get around the facility. Displacement of birds is judged to be of LOW NEGATIVE significance pre mitigation.

Mitigation measures • Nothing specific required. Adhere to sensitivity map.

Significance Statement: WEF and Powerline Alternatives Impact Effect

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Risk or Overall Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Long Term Study Area Slight - Probable LOW - With Mitigation Long Term Study Area Slight - Probable LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Study Area Moderately severe Probable MODERATE -

Impact 1.3.4.2: Bird collision with turbine blades

Cause and comment Birds in flight on the site could collide with operational turbine blades, thereby being killed or seriously injured. Collision of birds with turbines is judged to be of MODERATE NEGATIVE significance pre mitigation.

Mitigation measures The significance of this impact can be reduced to LOW NEGATIVE significance by adhering to the sensitivity map in Section 6 of the Avifaunal Impact Assessment Report, and by providing a contingency mitigation budget in the operational phase to allow adaptive management of impacts that arise. The most likely of these is that of Black Harrier, which could possibly be at risk of collision in certain years when conditions are right for them on site. If such a situation arises possible necessary mitigation measures could include: further research into the problem; human based turbine shutdown on demand; habitat alteration; bird deterrence from site; and any others identified as feasible.

Significance Statement: WEF Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Long Term Study Area Moderately severe - Possible MODERATE - With Mitigation Long Term Study Area Slight - Possible LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Study Area Moderately severe Possible MODERATE -

Impact 1.3.4.3: Collision & electrocution on overhead powerlines

Cause and comment Birds could perch on the pylons/towers of the overhead powerline and be at risk of electrocution if the design is not bird friendly. Birds in flight could collide with the overhead cables, particularly the earth wire. Collision and electrocution of birds on overhead powerlines on site is anticipated to be of HIGH NEGATIVE significance.

Mitigation measures

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Both of these impacts can be mitigated successfully in our opinion to reduce the significance to LOW NEGATIVE. In both cases the first and foremost approach to mitigation should be the selection of the shortest and most sensible possible length of new overhead power line to be constructed and the optimal route for this line, i.e. Powerline Alternative 1 (see Section 6.2 of the Avifaunal Impact Assessment). To mitigate for collision of the relevant species, it is recommended that the conductors on the high bird collision risk sections of the line be fitted with the best available (at the time of construction) Eskom approved anti bird collision line marking device. This should preferably be a dynamic device, i.e. one that moves as it is believed that these are more effective in reducing collisions, especially for bustards (see Shaw 2013), which are one of the key species (Denham’s Bustard) in this area. It is recommended that a durable device be used as this area is clearly prone to a lot of strong wind and dynamic devices may be susceptible to mechanical failure. It will be either InnoWind or NMBM’s responsibility to ensure that these line marking devices remain in working order for the full lifespan of the powerline, as we cannot afford to have significant numbers of bird collisions on this new line. It is important that these devices are installed as soon as the conductors are strung, not only once the line is commissioned, as the conductors pose a collision risk as soon as they are strung. The devices should be installed alternating a light and a dark colour to provide contrast against dark and light backgrounds respectively. This will make the overhead cables more visible to birds flying in the area. Note that 100% of the length of each span needs to be marked (i.e. right up to each tower/pylon) and not the middle 60% as some guidelines recommend. This is based on a finding by Shaw (2013) that collisions still occur close to the towers or pylons. It is also recommended that the stay wires on the met masts on site be installed with these devices as soon as possible.

In the case of bird electrocution, the power line must be built on an Eskom approved bird-friendly pole structure which provides ample clearance between phases and phase-earth to allow large birds to perch on them in safety.

Significance Statement: POWERLINE ALTERNATIVES Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Powerline 1 Long Term Study Area Severe - Probable HIGH - Without Mitigation Powerline 1 Long Term Study Area Slight - Possible LOW - With Mitigation Powerline 2 Long Term Study Area Severe - Probable HIGH - Without Mitigation Powerline 2 Long Term Study Area Slight - Possible LOW - With Mitigation Powerline 3 Long Term Study Area Severe - Probable HIGH - Without Mitigation Powerline 3 Long Term Study Area Moderate - Possible MODERATE - With Mitigation No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Study Area Severe - Probable MODERATE - “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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1.3.5 Bats (as per the Bat Impact Assessment, Appendix D)

Impact 1.3.5.1: Bat mortalities due to direct blade impact or barotrauma during foraging activities

Cause and Comment Bats are thought to perceive turbines as possible roosting spaces or foraging areas due to the presence of concentrated pockets of insects within the wing path (Horn et al. 2008). The presence of lights on wind turbines have also been identified as possible causes for increased bat fatalities as a result of higher insect densities attracted to the flashing lights (Johnson et al. 2003). Clearings around wind turbines may also improve conditions for insects, thereby attracting bats to the area and the “swishing sound” of the turbine blades could confuse bats (Kunz et al. 2007). Whatever the reason for bat mortalities around wind turbines, the facts indicate that this is a very serious and concerning problem.

Mitigation Measures • It is essential that an effective mitigation measure, such as curtailment, be implemented to lessen bat mortalities. In the process of curtailment, the turbine is kept stationary at a lower wind speeds and is allowed to rotate in response to a specific wind velocity. • In theory, there is a negative correlation between bat activity and wind speed, thus, by increasing the turning speed of the blades, the movement of air around the blades will increase, resulting in decreased bat activity. • Adhere to the sensitivity maps as per the Bat Impact Assessment Report, avoid areas of high bat sensitivity and their buffers as well as preferably avoid areas of Moderate bat sensitivity and their buffers (this has already been achieved by the proposed development).

Significance Statement: WEF Effect Risk or Overall Impact Severity of Temporal Scale Spatial Scale Likelihood Significance Impact Operational phase Without Mitigation Long Term Study Area Severe Definite HIGH - With Mitigation Long Term Study Area Moderately severe Possible MODERATE - No-Go Option N/A N/A N/A N/A N/A Cumulative Long Term Study Area Severe Probable MODERATE -

1.3.6 Visual (as per the Visual Impact Assessment, Appendix D)

Impact 1.3.6.1: Impact of wind turbines on sensitive visual receptors

Cause and comment

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The hub of the turbines proposed will be 100m above the ground. The three blades will each be 45m long. Therefore the viewshed calculation has calculated the 9 turbines’ viewshed using a maximum blade tip height of 145m. The turbines will be visible primarily from the area to the south-east of the WEF. Notable features in this area include: Motherwell, the Coega Industrial Development Zone, the N2 national highway, and the Port of Ngqura. None of these areas is considered to be sensitive to the presence of the wind farm.

Mitigation measures Other than avoiding the site completely there are no mitigation measures that will reduce the visual intrusion of the wind turbines due to their size, height and visibility, and the lack of screening opportunities in the landscape.

Significance Statement: WEF Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Permanent Study area Slight Definite LOW - With Mitigation Permanent Study area Slight Definite LOW - No-Go Option N/A N/A N/A N/A N/A Without Mitigation Permanent Regional Moderate Definite MODERATE -

Impact 1.3.6.2: Shadow Flicker

Cause and comment Shadow flicker results from the shade cast by a wind turbine and its rotating blades. The shade cast by the blades “flicker” from the point of view of a stationary observer as the blades rotate. This is most pronounced when the shadow is cast through a building’s opening, such as a window, especially when the window is one of the main sources of light in a room.

The most research on shadow flicker has been conducted in Europe, and Europe has the most thorough set of regulations and best-practise guidelines relating to shadow flicker. England’s Companion Guide to PPS22 (2004) and BERR (2007), and Northern Ireland’s Best Practice Guidance to PPS18 (2009) state that only properties within 130 degrees either side of north of a particular turbine can be affected by shadows (Parsons Brinckerhoff, 2011). We assume therefore that the situation in South Africa is opposite i.e. only properties within 130 degrees either side of south of a particular turbine can be affected by shadows. These guidelines also state that shadow flicker only occurs within ‟10 x rotor diameters” of a turbine. There is general consensus amongst the European nations that this is the potentially affected shadow flicker zone. The rotor diameter for the proposed Scarlett Ibis WEF turbines is 90m. This means that the area within 900m of the turbines, in the appropriate direction range, is potentially affected by shadow flicker.

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Mitigation measures The following mitigation measures are possible: • Careful site design; • Temporary turbine shut-down. This can be done when a particular turbine is causing shadow flicker at a particular time of the day; • Installation of blinds; and • Landscaping and vegetation screening.

We recommend that the potential for shadow flicker on the two potentially-affected buildings be assessed. A building should not be affected for more than 30 hours per year, or for longer than 30 minutes in a day (Parsons Brinckerhoff, 2011).

Trees can be planted, but will take a few years before they grow tall enough to provide a screen. In the meantime, blinds may be installed on the affected windows.

Significance Statement: WEF Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Permanent Local Slight May occur LOW - With Mitigation Permanent Local Slight Unlikely LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Permanent Local Slight May occur LOW -

1.3.7 Noise (as per the Noise Impact Assessment, Appendix D)

Impact 1.3.7.1: Noise generated by wind turbines

Cause and comment Only the night-time scenario was assessed, as this is the most critical time period when a quiet environment is desired. The noise rating levels are calculated in section 8.2 of the Noise Impact Assessment Report for the various operational activities defined in section 4.2 of the report.

As can be seen from the table below, the projected noise rating levels will be approximately 43 dBA at NSD09.

Based on the projected noise rating levels: • The change in ambient sound levels could be between 0 and 1 dB when assuming ambient sound levels ranging between 45 and 50 dBA at NSD07. At a wind speed of 10 m/s or higher it is highly unlikely that the wind turbines will be audible. It should be noted that ambient sound levels will be higher at NSD07 due to the proximity of the R335 road; • The duration will be the full project life - Long term (4); “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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• The wind turbines may be audible up to 1,500 m during special conditions – Regional (3).

The significance of the noise impact is considered to be low as assessed and summarized in the table below for all NSD.

Significance Statement (assessed and represented per NSD): WEF

Average Significance

Probability

Magnitude

Duration

night- Extent Projected time NSD noise level ambient

(dBA)

sound

levels 1 31.0 Low Long Regional Improbable Low 2 32.1 Low Long Regional Improbable Low

(low wind (low 3 29.2 Low Long Regional Improbable Low

4 38.5 – Low-medium Long Regional Improbable Low

52 dBA52 5 38.1 conditions Low-medium Long Regional Improbable Low 6 38.8 Low-medium Long Regional Improbable Low

7 42.4 ) Medium-high Long Regional Possible Low

8 34.2 Low Long Regional Improbable Low 9 37.2 Low Long Regional Improbable Low Comments: Assuming an ambient sound level of 35 dBA to estimate the magnitude rating in line with the precautionary principle. Probability is estimated considering the likely range of ambient sound levels as well as total projected noise levels. Confidence in High finding Mitigation Significance of noise impact is low and the impact is acceptable. Mitigation is not required. measures Cumulative impacts Operational noises will cumulatively add to any other noises in the area, but it will be insignificant. This impact will only disappear after the operational phase is finished and rehabilitation of the area is Residual Impacts: completed.

1.3.8 Social

Impact 1.3.8.1: Job creation

Cause and Comment Few permanent employment positions (unskilled, semi- and highly skilled) would emerge during the 25 year operational period of the Scarlet Ibis WEF. Employment positions could include: • Technicians, electricians, IT specialists, engineers, administrators (highly skilled); • Security (semi-skilled); and

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• Site maintenance (lower skilled).

Periodically temporary employment may become available for civil works maintenance (roads, crane pads, etc.) and site clearance to minimize potential veld fires, etc. The opportunity for local service providers exists to conclude contracts with the developer to perform duties at the plant.

Mitigation Measures • Maximize the number of local permanent and temporary employees (from the NMBM) where possible. • Through ED contributions do training and capacity building where necessary.

No-go option • No employment creation and opportunities for skills development would occur.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Long term Regional Slight Definite MODERATE + With Mitigation Long term Regional Moderate Definite MODERATE + No-Go Long term Regional Slight Unlikely LOW - Cumulative Long term Regional Moderate Definite MODERATE +

Impact 1.3.8.2: Skills development and capacity building

Cause and Comment Although limited, skills development and capacity building would result as on-site training is likely. An important outcome of skills development and training is that employees would be in a position to source work on similar plants once their contracts expire. A skilled labour force is more likely to find employment, resulting in economic advantages for the local economy over the long-term.

Mitigation Measures • Implement measures (bonuses or other financial benefits) for highly skilled staff to minimize the negative impacts associated with a high staff turnover. • Do training and capacity building wherever necessary.

No-go option: • No contribution to local employment and skills development. • No contribution to the local economy.

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Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Long Term Regional Slight May Occur MODERATE + With Mitigation Long Term Regional Slight Probable MODERATE + No-Go Long Term Regional Slight Unlikely LOW - Cumulative Long term Regional Moderate Definite MODERATE +

Impact 1.3.8.3: Impacts on the local economy

Cause and Comment During the operational phase it is expected that the local economy would benefit in the following ways: • The families of employees would benefit economically with an increase in incomes and spending power; • A possible increase in municipal rates and taxes, as the land would be rezoned from “Agriculture” to “Special Use for Agriculture and Renewable Energy Infrastructure”, resulting in higher levels of rateable income; • Local communities would benefit economically through shareholding and community upliftment and Social Development projects; and • The establishment of local downstream industries and services that would support the WEF’s operations (to a lesser extent).

The local economy would experience definite positive impacts over the long term. However, the Rand-value for rates and taxes, net incomes and shareholding dividends is not known at this stage. Without mitigation an overall moderate significance rating is applied. A slight severity has been assigned as standard environmental principle. Confidence in the overall significance is low.

Mitigation Measures • Maximize the number of local permanent and temporary employees (from the NMBM) where possible. • Do training and capacity building wherever necessary. • Assist and guide the local community with regards to the needs of the WEF plant and the types of supporting industries and services required for its successful operation. Enterprise Development funding is available to assist the local SMME’s with skills training and capacity building, etc.

No-go option • No economic benefits in terms of salaries, ED and SED contributions and community projects would accrue to the local communities. • No skills development and capacity building opportunities for local SMME and other supporting industries. • No economic benefits for the local Municipalities.

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Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Long Term Regional Slight Definite MODERATE + With Mitigation Long Term Regional Moderate Definite MODERATE + No-Go Long Term Regional Slight Unlikely LOW - Cumulative Long Term Regional Moderate Definite MODERATE +

1.4 Decommissioning Phase Impacts

1.4.1 Ecological (as per the Ecological Impact Assessment. Appendix D)

Impact 1.4.1.1: Noise and Dust Impacts on Fauna

Cause and Comment During decommissioning structures may need to be removed. Vehicular movement, noise and habitat destruction will disturb animals in the study area.

Mitigation Measures • Restrict decommissioning activities to post-dawn and pre-dusk. • Decommissioning of the turbines must be undertaken in the shortest time practical. • Speed limits must be implemented and enforced - 40km/h is recommended.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Short Term Localised Moderate Possible HIGH - With Mitigation Short Term Study Area Slight Possible LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Short Term Regional Moderate Possible MODERATE -

Impact 1.4.1.2: Poaching of Wildlife

Cause and Comment During decommissioning phase, disturbance by labourers will increase and this may lead to poaching of wild animals within the study area.

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Mitigation Measures • Decommission employees must be transported to and from the site daily. • No residence may be set up on site. • An inspection of the immediate vegetation surrounding the turbine sites for evidence of snares must be undertaken. These checks must be undertaken twice weekly.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Short Term Localised Moderate Possible HIGH - With Mitigation Short Term Study Area Slight Possible LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Short Term Regional Moderate Possible MODERATE -

Impact 1.4.1.2: Inadequate Rehabilitation of Vegetation

Cause and Comment Poor rehabilitation may result in limited re-vegetation and long-term ecological damage.

Mitigation Measures • A percentage of operational earnings should be set aside for the decommissioning phase, which must include costs for landscaping and re-vegetation of the whole development footprint. • A Decommissioning Rehabilitation Plan must be developed and include primary objectives of rehabilitation and the latest acceptable methods for implementation.

Significance Statement: WEF and Powerline Alternatives Effect Risk or Overall Impact Temporal Scale Spatial Scale Severity of Impact Likelihood Significance Operational phase Without Mitigation Short Term Localised Moderate Possible MODERATE - With Mitigation Short Term Study Area Slight Possible LOW - No-Go Option N/A N/A N/A N/A N/A Cumulative Short Term Regional Moderate Possible MODERATE -

1.4.2 Social

Impact 1.4.2.1: Job creation

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Temporary workers would be required to do the dissembling and/or replacement of components and skilled employees (project managers, technicians, etc.) would also be required. The number of employment positions is unknown as this is new technology and none of the existing plants have as yet been decommissioned. However, it could be expected that suitable workers will be available as a large number of people would have gained relevant skills over the 25 year operational period of the Scarlet Ibis WEF and similar plants in the region.

Significance Statement: WEF and Powerline Alternatives Effect Overall Impact Risk or Likelihood Temporal Scale Spatial Scale Severity of Impact Significance Decommissioning phase Without Mitigation Short Term Regional Moderate Definite MODERATE + No-Go Option N/A N/A N/A N/A N/A Cumulative Short Term Regional Moderate Definite MODERATE +

Impact 1.4.2.2: Impacts on living and movement patterns

Cause and Comment Negative impacts on traffic movement patterns would be inevitable as large construction vehicles would be required to move new and old components to and from the site.

Although traffic volumes on the R335 and road conditions at the time of decommissioning are unknown at this stage, the impact could be regarded as severe due to the high number of trucks and abnormal loads that would be transported. An impact with an overall negative moderate significance is likely.

Significance Statement: WEF and Powerline Alternatives Effect Overall Impact Risk or Likelihood Temporal Scale Spatial Scale Severity of Impact Significance Decommissioning phase Without Mitigation Short Term Regional Severe Definite MODERATE - No-Go Option N/A N/A N/A N/A N/A Cumulative Short Term Regional Moderate Definite MODERATE -

THE FOLLOWING PAGES CONTAIN A SUMMARY OF IMPACTS RELATED TO THE PROPOSED WEF AND ASSOCIATE POWERLINE ALTERNATIVES

contamination due to mixing of cement in LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A

GENERAL inappropriate areas on site 1.1.1.5: An increase in impermeable surfaces could lead to increased MODERATE - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A localised flooding and erosion 1.1.1.6: The loss of the Albany Adder due to disturbance of Coega Bontveld bushclumps N/A N/A HIGH - MODERATE - HIGH - MODERATE - N/A N/A N/A MODERATE - during the siting of the 12m powerline servitude 1.1.1.7: The blocking or delaying of signal to MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A LOW - electronic devices caused by wind turbines

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1.1.1.8: The movement of turbines could cause a phenomenon called shadow flicker, which could result in health impacts to individuals MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A MODERATE - exposed for extended periods of time to individuals exposed for extended periods of time 1.1.1.9: Conflict with the N/A N/A HIGH - MODERATE - HIGH - MODERATE - N/A N/A N/A MODERATE - Coega IDZ OSMP CONSTRUCTION PHASE 1.2.1.1: Dust associated with an increase in MODERATE - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A vehicles on site could result in health impacts 1.2.1.2: Noise pollution LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A 1.2.1.3: Unnecessary disturbance of

vegetation due to LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A sprawl of campsite

GENERAL could cause a loss of biodiversity 1.2.1.4: Inappropriate storage and handling of hazardous substances MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A N/A could lead to surface and ground water pollution

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1.2.1.5: Littering and the use of informal ablution facilities by construction workers LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A could cause surface and ground water pollution 1.2.2.1: Loss of MODERATE - LOW - HIGH - LOW - HIGH - LOW - HIGH - LOW - LOW - MODERATE - Bontveld vegetation 1.2.2.2: Loss of Thicket LOW - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - vegetation 1.2.2.3: Removal of LOW MODERATE LOW MODERATE LOW MODERATE LOW MODERATE MODERATE MODERATE - Alien Vegetation + + + + + + + + + 1.2.2.4: Loss of Plant Species of MODERATE - LOW - HIGH - MODERATE - HIGH - MODERATE - HIGH - MODERATE - MODERATE - MODERATE - Conservation Concern 1.2.2.5: Loss of Faunal MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - SCCs

ECOLOGICAL 1.2.2.6: Poaching of HIGH - LOW - HIGH - LOW - HIGH - LOW - HIGH - LOW - N/A LOW - Wildlife 1.2.2.7: Fragmentation of vegetation and edge LOW - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - effects 1.2.2.8: Dust as a result MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - LOW - MODERATE - of wind erosion 1.2.2.9: Noise pollution LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A on faunal groups 1.2.3.1: Management of MODERATE - LOW - N/A N/A N/A N/A N/A N/A N/A N/A hazardous chemicals

1.2.3.2:AL Loss of Livestock and Wildlife MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A MODERATE - AGRICULTUR Grazing

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1.2.3.3: Soil MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A MODERATE - Compaction 1.2.3.4: Increase in Soil MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - Erosion 1.2.3.5: Management of MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A N/A Topsoil 1.2.3.6: Inappropriate and Inadequate MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A LOW - Rehabilitation 1.2.4.1: Destruction or MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - N/A LOW - alteration of bird habitat 1.2.4.2: Disturbance of

AVIFAUNA birds during LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A N/A construction

1.2.5.1: Loss of foraging habitat LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A MODERATE -

damage or destruction LOW of fossil heritage during MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - + PALEO the construction phase of the WEF

1.2.8.1: Visual impact of construction activity MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - N/A N/A

VISUAL

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1.2.9.1: Construction Phase Noise LOW - LOW - LOW - LOW - LOW - LOW - LOW - LOW - N/A LOW -

reduction in the need for fossil fuels resulting HIGH HIGH HIGH N/A N/A N/A N/A N/A N/A LOW - in an improved air + + + GENERAL quality and contributing toward the mitigation of climate change

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1.3.2.1: Invasion of alien plant species LOW LOW LOW LOW LOW HIGH - HIGH - HIGH - HIGH - MODERATE - + + + + +

due to direct blade impact or barotrauma HIGH - MODERATE - N/A N/A N/A N/A N/A N/A N/A MODERATE - BATS during foraging activities 1.3.6.1: Impact of wind turbines on sensitive LOW - LOW - N/A N/A N/A N/A N/A N/A N/A MODERATE - visual receptors

VISUAL 1.3.6.2: Shadow Flicker LOW - LOW - N/A N/A N/A N/A N/A N/A N/A LOW -

1.3.7.1: Noise generated by wind LOW - LOW - N/A N/A N/A N/A N/A N/A LOW - LOW - NOISE turbines

1.3.8.1: Job creation MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE

SO LOW - CIA + + + + + + + + + “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

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1.3.8.2: Skills MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE development and LOW - + + + + + + + + + capacity building 1.3.8.3: Impacts on the MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE LOW - local economy + + + + + + + + + DECOMMISSIONING PHASE 1.4.1.1: Noise and Dust MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - MODERATE - Impacts on Fauna 1.4.1.2: Poaching of HIGH - LOW - HIGH - LOW - HIGH - LOW - HIGH - LOW - HIGH - MODERATE - Wildlife 1.4.1.2: Inadequate ECOLOGICAL Rehabilitation of MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - LOW - MODERATE - MODERATE - Vegetation 1.4.2.1: Job creation MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE + + + + + + + + + + 1.4.2.2: Impacts on

SOCIAL living and movement MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - MODERATE - patterns

CUMULATIVE IMPACT STATEMENT (COMPULSORY FOR WEF DEVELOPMENTS IN SOUTH AFRICA) The cumulative impacts of the proposed Scarlet Ibis WEF have been based on an assessment of existing and potential wind energy facilities within 30km of the site. The map below illustrates the WEFs which have been taken into consideration, namely: • Grassridge WEF – authorised and constructed • Dassiesridge WEF – authorised but not yet constructed • Grassridge II WEF – authorised but not yet constructed (made up of Ukomeleza WEF and Motherwell WEF)

The key cumulative fields of impact relate to avifaunal, bat and ecological impacts. Due to the rural nature of the site the visual impact, from a cumulative perspective is considered to be of moderate significance. The experience of the Avifaunal and Bat specialists on the surrounding WEFs combined with the proposed Scarlet Ibis WEF monitoring meant that they were able to factor in existing mitigation measures which have already been implemented/suggested for the Grassridge I, Dassiesridge and Grassridge II projects. The significance of the cumulative impacts for the Scarlet Ibis WEF is considered to be of MODERATE SIGNIFICANCE.

AVIFAUNAL CUMULATIVE SUMMARY (as per Avifaunal Impact Assessment, Appendix D) The proposed Scarlet Ibis Wind Energy Facility is situated in an area of the country where several such projects are either under assessment or already authorised, and one site is operational. These sites are as follows:  Dassiesridge Wind Energy Facility. Authorised – approximately 67 turbines  Grassridge Wind Energy Facility. Operational – 20 turbines. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

 Ukomeleza Wind Energy Facility. Approximately 28 turbines. (Part of Grassridge II)  Motherwell Wind Energy Facility. Approximately 22 turbines. (Part of Grassridge II)

In such areas, where multiple facilities may be built, it is important to consider the overall or cumulative impact of these facilities on birds. Consideration of each project in isolation may not adequately judge the effect that projects will have on avifauna when combined.

The International Finance Corporation (IFC) recognises Cumulative Impact Assessment (CIA) and management as essential in risk management. However CIA is also “One of the biggest risk management challenges currently facing project developers in emerging markets…”. Challenges include: a lack of basic baseline data, uncertainty associated with anticipated developments, limited government capacity, and absence of strategic regional, sectoral, or integrated resource planning schemes. Considerable debate exists as to whether CIA should be incorporated into good practice of Environmental and Social Impact Assessment, or whether it requires a separate stand-alone process. As a minimum, according to the IFC, developers should assess whether their projects could contribute to cumulative impacts or be impacted upon by other projects. The IFC recommend that developers conduct a Rapid Cumulative Impact Assessment (RCIA) either as part of the EIA or separately. This RCIA should follow 6 steps: 1 & 2 – scoping; 3 - baseline determination; 4 - assessment of the contribution of the development under evaluation to the predicted cumulative impacts; 5 - evaluation off the significance of predicted cumulative impacts to the viability or sustainability of the affected environmental components; 6 - design and implementation of mitigation measures to manage the development’s contribution to the cumulative impacts and risks (see the “Good Practice Handbook - Cumulative Impact Assessment and Management: Guidance for the Private Sector in Emerging Markets”. International Finance Corporation).

Additional challenges specific to the Scarlet Ibis area and avifauna include:  The difficulty in defining which projects to include in a CIA. Not all the projects in the area have obtained environmental authorisation, or authorisation from the Department of Energy, so may never materialise. The question is which projects should be considered then, only those authorised, or those successful bidders, or those that have reached financial close.  The difficulty in defining the spatial extent of a CIA, bearing in mind that some of the relevant bird species move hundreds of kilometres across the landscape and could theoretically be affected by developments within this entire range.

The IFC step wise approach is useful to follow for this study, and has been elaborated on below:

Steps 1 & 2: The Scarlet Ibis study has achieved these through the scoping of issues and identification of aspects worthy of attention. It is assumed that these aspects will be similar on the other project sites in similar topography and vegetation.

Step 3: This has been conducted on a ‘per species’ basis in Section 4 of the Avifaunal Impact Assessment report, based on 12-month monitoring results and other studies in the area.

Step 4: requires a judgment of the contribution that the Scarlet Ibis site makes to the predicted cumulative impacts. In our opinion, with respect to the key species listed as most important for this area, the Scarlet Ibis site makes a small contribution to impacts in the area, on account of its small size (area and number of turbines). “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

Step 5: The overall cumulative effect of wind energy facilities on birds in this area, is likely to be of MODERATE NEGATIVE significance prior to mitigation in our opinion.

Step 6: It is recommended that each project within this broader area ensures that no effort is spared in mitigating impacts on avifauna. It is hoped that if each project provides sufficient mitigation, the overall cumulative impact can be reduced. There are strong grounds for a strategic cumulative avifaunal impact assessment to be conducted for the greater Coega area as soon as possible. It is recommended that the Department of Environmental Affairs implement such a study.

BAT CUMULATIVE SUMMARY (as per Bat Impact Assessment, Appendix D) The main impact on bats that raises concern from a cumulative impact assessment point of view is the bat mortalities due to direct turbine blade collision or barotrauma during operation. Mortalities of bats due to wind turbines during foraging and migration can have significant ecological consequences as the bat species at risk are insectivorous and thereby contribute significantly to the control of nocturnal flying insects. If such an impact is present on multiple wind farms in close vicinity of each other, insect numbers can increase regionally and possibly cause outbreaks of colonies of certain insect species.

Figure 36 of the Bat Impact Assessment Report displays bat sensitivity maps of the Dassiesridge WEF, Grassridge WEF, Ukomeleza WEF and Motherwell WEF near the proposed Scarlet Ibis WEF. The bat sensitivity maps were inspected for congruency of sensitive areas and similarities in their buffer distances. The sensitivity map of the Scarlet Ibis WEF is sufficient and consistent when assessed with nearby site sensitivity maps, and the nearby sites turbine layout adhered to their respective sensitivity maps.

The sensitivity maps were also used to assess whether the Scarlet Ibis WEF turbine layout intersects interlinking bat sensitivity habitats between the different sites i.e. valley areas, rivers and streams, mountain ridges. The Scarlet Ibis WEF turbine layout does not traverse large scale ecological corridors or ecological areas of connectivity. Thus, the existing bat sensitivity map is sufficient in this regard.

The final pre-construction bat monitoring reports of the Dassiesridge WEF, Grassridge WEF, Ukomeleza WEF and Motherwell WEF each identify peak bat activity periods with some similarities to that of the proposed Scarlet Ibis WEF peak bat activity periods. Such similarities point to a large-scale trend in bat activity across the greater area.

The most effective mitigation measures from a cumulative point of view can be achieved when all WEF’s in the area adhere to their respective recommended mitigation measures and sensitivity maps. That will subsequently create safe zones and corridors for bats on a spatial and temporal scale. Mitigation curtailment is already currently being applied at the operational Grassridge WEF.

ECOLOGICAL CUMULATIVE SUMMARY (as per Ecological Impact Assessment, Appendix D)

Sadler (1996) defines cumulative impacts as the “the net result of environmental impact from a number of projects and activities”. The impact of the proposed WEF may not be significant or be a serious threat to the environment, but a large number of projects in one area, or occurring in the same vegetation type may have significant impacts (DEAT, “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

2004). This section attempts to identify the cumulative impacts associated with Wind farm projects taking place in similar vegetation types in this area. Even though the possible extent of the cumulative impacts cannot be determined due to uncertainty around the number of projects that will be successful, it is still important to try and identify the negative and positive impacts which may arise in the long term and this includes assessing this project in conjunction with other WEF projects.

Currently one WEF is operational within the immediate area (approximately 5-8 km north of the Proposed Scarlet Ibis WEF) and portions of the site. In addition, 3 other WEF projects has been approved by DEA, also within the immediate area, and at least two (2) other WEF application processes are underway in the proximity of Coega. The vegetation on all these sites is likely to be similar to that found within the study area. Based on this the following impacts have been identified:

Loss of vegetation communities and Biodiversity

1. Loss of Thicket and fragmentation

Cause and Comment Only small amounts of this vegetation type (listed as Vulnerable and Endangered in some parts of the site) will be impacted by the proposed Scarlet Ibis WEF, as seen above, this loss will not result in significant losses of the vegetation type but the cumulative impacts associated with this project and other WEFs (e.g. Grassridge WEF and proposed Ukomeleza and Dassiesridge WEF) in the area must be assessed. However, in addition to the clearance required for the WEF, it should be noted that areas of this vegetation type will need to be cleared for the grid connection powerline. The Sundays River Valley Biodiversity Sector Plan states that the removal of large area of this vegetation has been identified as one of the factors which may encourage global climate change due to the increase in CO2 input into the atmosphere. The Thicket vegetation acts as a carbon sink by fixing carbon in plants and storing it in the soil through the process of decomposition. Portulacaria afra (Spekboom) is a common species in the Thicket vegetation, and studies have shown it is able to store large quantities of carbon. This vegetation type has a wider distribution than the Bontveld vegetation and the cumulative impacts on this vegetation type are likely to be moderate.

Mitigation Measures All mitigation measures described in the Ecological Impact Assessment must be implemented to ensure that the impacts associated with this project are kept to a minimum to minimise the cumulative impacts.

2. Overall loss of Bontveld and fragmentation

Cause and Comment The proposed WEF will impact largely on this vegetation type (listed as Vulnerable), however Bontveld is already threatened by activities such as mining and other WEFs in the area. In conjunction with the surrounding developments in the wider area such as the Coega IDZ, it will cause the additional loss of vegetation communities through direct (clearing) impacts, and the loss of Species of Conservation Concern (Fauna and Flora) to the point where local extinctions in the area may be expected. There will also be a significant increased risk of invasion by alien species to the point where alien vegetation displaces entire sections of indigenous vegetation. Given the limited distribution of this vegetation type, the unmitigated cumulative impacts associated with the neighbouring existing Grassridge WEF, PPC “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

mine, mining for brick making and the proposed Ukomeleza and Dassiesridge WEF and other developments within Bontveld, will likely be high. However, since Bontveld is comprised of a mosaic of vegetation (Bushclumps, succulent patches and grassland) mitigation measures that avoid areas of high sensitivity such as Bushclumps and succulent patches, will reduce the impacts the WEF and associated grid connection is likely to have.

3. Loss of SCCs

Cause and Comment The proposed project will have an impact on SCC found to occur within both vegetation types. SCC are species which need to be conserved as they are threatened by the loss of habitat, habitat fragmentation, harvesting or poaching etc. Anthropogenic activities are some of the causes which result in the above threats. The extent of the loss of SCC cannot be predicted and therefore a precautionary approach has been adopted. The cumulative impact associated with the loss of SSC associated with the proposed WEF and the surrounding WEFs nearby is likely to be moderate as layout changes can be made to avoid highly sensitive areas where SCCs are abundant.

ENVIRONMENTAL SENSITIVITY: WIND ENERGY FACILITY A site development sensitivity map (Figure 3-1.1) was developed based on specialist and general site information gathered, and the site was classified into areas of LOW, MODERATE (conditional development) and HIGH sensitivity.

• HIGH sensitivity areas included areas of high sensitivity indicated by the bird and bat specialists and buffers around existing infrastructure (including a 500m buffer around all noise sensitive areas). • MODERATE sensitivity areas are areas where construction is conditional on the fulfilment of one or other aspect- specific requirement. For example, all construction on the Ecological MODERATE sensitivity area will require micrositing to ensure that the correct plant/tree removal permits area obtained prior to construction. • LOW sensitivity areas are areas where construction may take place without significant impact.

Turbine WTG 01: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits). WTG 01 ancillary infrastructure (road and cable route) will be below at ground level due to Avifaunal HIGH sensitivity and will require micrositing (plant and tree removal permits). WTG 01 ancillary infrastructure will also require a General Authorisation (DWS).

Turbine WTG 02: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits pending). WTG 02 ancillary infrastructure (road and cable route) requires micrositing (plant and tree removal permits).

Turbine WTG 03: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits). WTG 03 ancillary infrastructure (road and cable route) requires micrositing (plant and tree removal permits).

Turbine WTG 04: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits). WTG 04 ancillary infrastructure (road and cable route) will require micrositing (plant and tree removal permits).

Turbine WTG 05: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits). WTG 05 ancillary infrastructure (road and cable route) will be below at ground level due to Avifaunal HIGH sensitivity and will require micrositing (plant and tree removal permits)

Turbine WTG 06: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits pending). WTG 06 ancillary infrastructure (road and cable route) requires micrositing (plant and tree removal permits).

Turbine WTG 07: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits). WTG 07 ancillary infrastructure (road and cable route) will be below at ground level due to Avifaunal HIGH sensitivity and will require micrositing (plant and tree removal permits).

Turbine WTG 08: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits). WTG 08 ancillary infrastructure (road and cable route) will be below at ground level due to Avifaunal HIGH sensitivity and will require micrositing (plant and tree removal permits). WTG 08 ancillary infrastructure will also require a General Authorisation (DWS).

Turbine WTG 09: Situated in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits). WTG 09 ancillary infrastructure (road and cable route) will be below at ground level due to Avifaunal HIGH sensitivity and will require micrositing (plant and tree removal permits).

FIGURE 3-1.1: SITE SENSITIVITY OF THE SCARLET IBIS WEF

The three key sensitivity layers which were used in this analysis include the Ecological, Avifaunal and Bat Sensitivities. These layers have been combined to illustrate an overall sensitivity map. Please refer to the specialist reports which form part of the Basic Assessment report for individual sensitivity maps from each specialist. The MODERATE sensitivity areas in which turbines are situated have been labelled as such to ensure that the correct plant removal permits are obtained prior to the commencement of construction.

All turbines have been moved out of the HIGH sensitivity areas during the pre-screening process through the input of the various specialist consultants. The Final Layout is considered a low impact layout should all mitigation measures be adhered to and all permits (DEDEAT, DWS and DAFF) be obtained.

ENVIRONMENTAL SENSITIVITY: POWERLINE ALTERNATIVES Site development sensitivity maps were developed based on specialist and general site information gathered, and the site was classified into areas of LOW, MODERATE (conditional development) and HIGH sensitivity.

• HIGH sensitivity areas included areas of high sensitivity indicated by the ecological and avifaunal specialists. The high sensitivity areas also include potential conflicting landuses as identified by the Coega OSMP.

• MODERATE sensitivity areas are areas where construction is conditional on the fulfilment of one or other aspect- specific requirement. For example, all construction on the Ecological MODERATE sensitivity area will require micrositing to ensure that the correct plant/tree removal permits area obtained prior to construction. • LOW sensitivity areas are areas where construction may take place without significant impact.

POWERLINE ALTERNATIVE 1 (PREFERRED): Powerline Corridor 1 is situated mainly in HIGH sensitivity, based on the fact that it traverses sensitive areas within Zones 14 and 5 of the Coega IDZ. However, there will be a need for micrositing prior to siting of the powerline within the corridor to ensure that sensitive intact vegetation is avoided. Based on the ecological assessment of the powerline corridor it is the opinion of the Ecological specialist that the intact bushclumps can be avoided, thus reducing the sensitivity of this corridor to MODERATE sensitivity. From an avifaunal perspective this corridor was found to be acceptable. The siting of the route within this corridor must involve:  The Endagered Wildlife Trust herpetology unit to ensure that the Albany Adder’s primary critical habitat (Coega Bontveld) is avoided. Search and rescue to try and locate this species must also be undertaken. The results of this study must inform the final routing of the powerline and the mitigation measures must be contained within the EMPr.  The use of previous disturbed land, where feasible, and the avoidance of intact bushclumps. Vegetation clearance is only allowed for the powerline pylons, the area beneath the powerline should be trimmed but may not be removed. Existing jeeptrack style roads should be used as pylon service roads as far as possible.  Micrositing by an archaeologist to ensure that all sensitive archeological features are buffered and avoided.  The final powerline must be fitted with bird diverters, as per the recommendations in the OSMP. Powerline Corridor 1 is the shortest connection route and the siting of the powerline must involve strict management. Once these mitigation measures have been adhered to we believe that this corridor will be able to house the powerline servitude with a less of an impact than Powerline Corridor 2 and 3. Powerline Corridor 1 is the preferred corridor in which to house the powerline servitude from an Ecological and Avifaunal perspective. This route is the preferred corridor in which to place the powerline servitude.

POWERLINE ALTERNATIVE 2: Powerline Corridor 2 is situated mainly in HIGH sensitivity, based on the fact that it traverses sensitive areas within Zones 14 and 5 of the Coega IDZ. However, there will be a need for micrositing prior to siting of the powerline within the corridor to ensure that sensitive intact vegetation is avoided. Based on the ecological assessment of the powerline corridor it is the opinion of the Ecological specialist that the intact bushclumps can be avoided, thus reducing the sensitivity of this corridor to MODERATE sensitivity. From an avifaunal perspective this corridor was found to be acceptable. From a heritage perspective this corridor contains sensitive heritage features which will have to be avoided. The Coega OSMP identifies intact Coega Bontveld, sensitive heritage features and sensitive butterfly habitat along this route. This route is therefore less preferred than powerline alternative 1. The siting of the route within this corridor must involve:  The Endagered Wildlife Trust herpetology unit to ensure that the Albany Adder’s primary critical habitat (Coega Bontveld) is avoided. Search and rescue to try and locate this species must also be undertaken. The results of this study must inform the final routing of the powerline and the mitigation measures must be contained within the EMPr. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

 The use of previous disturbed land, where feasible, and the avoidance of intact bushclumps. Vegetation clearance is only allowed for the powerline pylons, the area beneath the powerline should be trimmed but may not be removed. Existing jeeptrack style roads should be used as pylon service roads as far as possible.  Micrositing by an archaeologist to ensure that all sensitive archeological features are buffered and avoided.  Avoidance of areas identified as sensitive butterfly habitat, as per the OSMP.  The final powerline must be fitted with bird diverters, as per the recommendations in the OSMP. This route, while less favourable than powerline corridor 1, is suitable to house the powerline servitude, on condition that all mitigation measures are adhered to in the final powerline route sighting.

POWERLINE ALTERNATIVE 3: Powerline Corridor 3 is situated mainly in MODERATE sensitivity, based on the need for micrositing prior to construction (plant and tree removal permits) and the presence of bushclumps. Powerline Corridor 3 is the least favourable corridor in which to house the powerline servitude due to its length and due to HIGH sensitivity from an Avifaunal perspective. As per the avifaunal impact assessment report, this route is not recommended and should not be considered as a connection option.

FIGURE 3-1.2: SITE SENSITIVITY OF THE SCARLET IBIS WEF ALTERNATIVE POWERLINE CORRIDORS (WITH THE OSMP INCLUDED)

FIGURE 3-1.2(B): COEGA OSMP

FIGURE 3-2.2: SITE SENSITIVITY OF THE SCARLET IBIS WEF ALTERNATIVE POWERLINE CORRIDORS (WITH THE OSMP EXCLUDED)

The two figures indicated above illustrate the site sensitivities based on: Figure 3-1.2: Ecological and Avifaunal surveys and impact assessment with the addition of the Coega OSMP as the primary layer for sensitivities in the Coega IDZ. Figure 3-2.2: Ecological and Avifaunal surveys and impact assessment

The first figure for the two remaining powerline corridors, namely Powerline Corridor 1 and 2, indicates a blanket sensitivity for the Coega OSMP, whereas the second figure indicates the sensitivity of these corridors based on a site visit by the Ecological and Avifaunal specialists. The Ecological specialist identified sensitive areas of intact vegetation which will need to microsited (both by a botanist and a herpetologist) prior to the siting of the powerline within these corridors. Geotechnical surveys will need to be included in the decision making process of the siting of the pylons to ensure that the line is both technically feasible and environmentally sustainable.

3. ENVIRONMENTAL IMPACT STATEMENT SECTION

Taking the assessment of potential impacts into account, please provide an environmental impact statement that summarises the impact that the proposed activity and its alternatives may have on the environment after “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

the management and mitigation of impacts have been taken into account, with specific reference to types of impact, duration of impacts, likelihood of potential impacts actually occurring and the significance of impacts.

ENVIRONMENTAL IMPACT STATEMENT The preferred (only) alternative for the proposed Scarlet Ibis WEF has numerous negative impacts associated with it. The majority of these impacts are of moderate negative significance, as indicated in the summary table above, and these can be reduced to low negative significance with the implementation of mitigation measures.

The powerline corridors all have numerous negative impacts associated with them. The majority of the impacts for Alternative 1 and 2 can be mitigated to low negative significance. Alternative 3 is not favourable as it is considered to have a higher negative significance in terms of avifauna. Alternative 3 is also the longest route which is not favourable from an Ecological and Heritage sensitivity perspective.

The no-go alternative (current status quo) will result in a number of negative impacts and will also result in the loss of the potential positive impacts associated with the proposed development.

SIGNIFICANCE OF MITIGATION The implementation of the mitigation measures will reduce the overall significance of the negative impacts as well as enhance the overall significance of the positive impacts. The location and the scale of the activity will not pose environmental impacts of any significance provided that the mitigation measures listed below, as well as those listed in the Environmental Management Programme (EMPr), are adequately adhered to.

CONCLUSION Based on the findings stipulated in this report, it is the opinion of the EAP that the proposed Scarlet Ibis WEF near Port Elizabeth in the Eastern Cape Province should receive a positive authorisation provided that the applicant (and those employed by the applicant) complies with the mitigation measures listed above as well as those listed in the EMPr. In addition, the EAP recommends that Powerline Corridor 1 be selected as it is the most suitable location in which to place the 22kV connection powerline based on the outcomes of this report and its associated specialist assessments.

SECTION E. RECOMMENDATIONS OF PRACTITIONER

Is the information contained in this report and the documentation attached hereto YES NO sufficient to make a decision in respect of the activity applied for (in the view of the environmental assessment practitioner)?

Is an EMPr attached? YES NO

The EMPr must be attached as Appendix F.

If “NO”, indicate the aspects that should be assessed further as part of a Scoping and EIA process before a decision can be made (list the aspects that require further assessment):

N/A

If “YES”, please list any recommended conditions, including mitigation measures that should be considered for inclusion in any authorisation that may be granted by the competent authority in respect of the application:

PLANNING & DESIGN PHASE GENERAL MITIGATION MEASURES Activity/Issue Specification Traffic & Transport • Project planning must include a plan for transport management plan that will be implemented especially during the construction phase of the development. • The necessary road traffic permits must be obtained for transporting parts, containers, materials and construction equipment to the site. • Careful planning of the routes taken by heavy vehicles must highlight areas of road that may need to be upgraded in order to accommodate these vehicles. Once identified these areas must be upgraded if necessary. Storage of Hazardous • All hazardous substances such as paints, diesel and cement must be stored in substances a bunded area with an impermeable surface beneath them. • Cement mixing must be done at a single location which should be suitably located. Environmental • Ensure that all relevant legislation and policy is consulted and further ensure that Legislation and Policy the project is compliant with such legislation and policy. In addition, planning for the construction and operation of the proposed energy facility should consider available best practice guidelines. These should include (but are not restricted to): 1. Local and District Spatial Development Frameworks 2. Local Municipal bylaws Stormwater Management • Structures must be located at least 32m away from identified drainage lines. Plan and Erosion • Water Use Licences will be required, where relevant, prior to construction • A Storm Water Management Plan must be designed and implemented to ensure maximum water seepage at the source of water flow. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

• The plan must include management mitigation measures for water pollution, waste water management and the management of surface erosion e.g. by considering the applicability of contouring, etc. Waste Management Plan • Must develop and implement a waste management plan for handling on site waste. • Designate an appropriate area where waste can be stored before disposal. Electromagnetic • Accurate siting of wind turbines must take place in the planning and design Interference phase to reduce these effects. • If complaints are received from surrounding landowners regarding this issue, the developer must investigate and mitigate these issues to the best of their abilities. Shadow Flicker • The layout of wind turbines must be designed in order to minimize the effects of shadow flicker on surrounding landowners. • Recommendations made by the visual impact assessor with regard to the identification of landowners who may be within range of the shadow flicker caused by the turbines, must be implemented. • If surrounding landowners complain of shadow flicker-related issues, these must be investigated and mitigated to the best of the developers’ ability. Positioning of the • The Endangered Wildlife Trust herpetology unit must conduct a search and Powerline servitude and rescue of the powerline corridor to locate any Albany Adder’s. The pylons recommendations from the EWT study must inform the siting of the powerline within the selected corridor. • A suitably qualified botanist must clearly demarcate all intact bushclumps as part of the EWT study to assist in the decision making process of the siting of the powerline servitude. • All sensitive heritage features must be avoided during the siting of the powerline servitude. • Existing roads must be used where feasible. • Vegetation clearing may only occur for the placement of powerline pylons, the siting of the powerline pylons must be based on three factors: avoidance of intact bushclumps, avoidance of potential Albany Adder habitat and a geotechnical study.

CONSTRUCTION PHASE GENERAL MITIGATION MEASURES Activity/Issue Specification Site Establishment • The contractor shall establish construction camps, offices, workshops and any other infrastructure as per the agreed site layout plan in a manner that does not adversely affect the environment. • The contractor shall submit a method statement for site clearance for approval by the Proponent in consultation with the ECO. Site establishment shall take place in an orderly manner and all required amenities shall be installed at camp sites before the main workforce move onto site. • The Construction camp shall have the necessary ablution facilities with chemical toilets at commencement of construction activities to the satisfaction of the Project Coordinator. The Contractor shall inform all site staff to make use of supplied ablution facilities and under no circumstances shall indiscriminate sanitary activities be allowed other than in supplied facilities.

• Safe drinking water for human consumption shall be available at the site offices and at other convenient locations on site. All water used on site must be taken from a legal source and comply with the recognised standards for potable and other uses. • The contractor shall provide adequate facilities for his staff so that they are not encouraged to supplement their comforts on site by accessing what can be taken from the natural surroundings. • The contractor shall ensure that energy sources are available at all times for construction and supervision personnel for heating and cooking purposes. • The Contractor shall supply waste collection bins where such is not available and all solid waste collected shall be disposed of at a municipal registered landfill. These bins must be equipped with animal proof lids to ensure the contents are not accessible to wild or domestic animals. A certificate of disposal shall be obtained by the Contractor and kept on file. Where a registered waste site is not available close to the construction site, the Contractor shall provide a method statement (i.e. how and where he intends to dispose of the waste) with regard to waste management. The disposal of waste shall be in accordance with all relevant legislation. Under no circumstances may solid waste be burnt on site. • ECO to assist in siting of structures and supervise any bush clearing for the construction camp. Construction camp should be fenced to avoid sprawl. Site Clearing • Site clearing must take place in phased manner, as and when required. Areas which are not to be affected by construction within two months must not be cleared, in order to reduce erosion risks. The area to be cleared must be clearly demarcated and this footprint strictly maintained. • Vegetation clearing must be restricted to the identified sites for the construction camp, cement mixing areas, ancillary infrastructure lay down areas, underground power cable route, control cabin and other activities on site that have been identified as necessary for development of the project. • Where feasible, spoil must be used for rehabilitation on-site. Where this is not possible spoil that is removed from the site must be removed to an approved spoil site or municipal licensed landfill site. • Silt fences and erosion control measures must be implemented in areas where these risks are more prevalent. These include steep areas. • Topsoil must be neatly stockpiled adjacent to the excavations ready for backfill when required. • The Contractor shall ensure that all work is undertaken in a manner which minimises the impact on vegetation outside the immediate area of the Works. No tree or shrub outside the area of the Works shall be felled, topped, cut or pruned until it has been clearly marked for this purpose by the Project Coordinator. The method of marking will be specified by the Project Coordinator, and the Contractor will be informed in writing; and no tree outside the area of the works shall be burned for any purpose. Soil Impacts Topsoil • The full depth of topsoil should be stripped from areas affected by construction and related activities prior to the commencement of major earthworks. This should include the building footprints, working areas and storage areas. Topsoil must be reused where possible to rehabilitate disturbed areas. • Care must be taken not to mix topsoil and subsoil during stripping.

• Polluted topsoil must be disposed of at a licensed landfill site. Waste manifests must be kept to prove that this has been disposed of legally.

Soil Stripping • No soil stripping must take place on areas within the site that the contractor does not require for construction works, or on areas of retained vegetation. • Subsoil and topsoil should, in all construction and lay down areas, be stockpiled separately to be returned for backfilling in the correct soil horizon order. • Construction vehicles must only be allowed to utilise existing tracks or pre- planned access routes.

Stockpiles • Stockpiles should not be situated such that they obstruct natural water pathways and drainage channels. • Stockpiles should not exceed 1.5m in height. • If stockpiles are exposed to windy conditions or heavy rain, they should be covered either by vegetation or cloth. • Stockpiles may further be protected by the construction of berms or low brick walls around their bases. • Stockpiles should be kept clear of weeds and alien vegetation growth by regular weeding.

Fuel storage • Topsoil and subsoil to be protected from contamination. • Fuel and material storage must be away from stockpiles. • Cement, concrete and chemicals must be mixed on an impermeable surface and provisions should be made to contain spillages or overflows into the soil. • Any storage tanks containing hazardous materials must be placed in bunded containment areas with sealed surfaces. The bund walls must be high enough to contain 110% of the total volume of the stored hazardous material. • Contaminated soil must be contained and disposed of off-site at an approved landfill site. Waste manifests must be kept to prove that this has been disposed of legally.

Concrete mixing • No vehicles transporting concrete to the site may be washed on site. • If a batching plant is necessary, run-off should be managed effectively to avoid contamination of other areas of the site. Untreated run-off from the batch plant must not be allowed to get into the storm water system or any rivers, streams, wetlands or existing erosion channels / dongas. • If it is impractical to dispose of water at a WWTW then a Method Statement should be compiled to make provision for a system that will not allow waste water to contaminate the surrounding area. • Drip trays should be used when off-loading concrete trucks to collect any concrete that spills.

Earthworks • To take into consideration: “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

• Soils compacted during construction should be deeply ripped to loosen compacted layers and re-graded to even running levels. Topsoil should be spread over landscaped areas. Erosion • Wind screening and stormwater control should be undertaken to prevent soil loss from the site. • All erosion control mechanisms need to be regularly maintained. • Retention of vegetation where possible to avoid soil erosion • Vegetation clearance should be phased to ensure that the minimum area of soil is exposed to potential erosion at any one time. • Re-vegetation of disturbed surfaces should occur immediately after the construction activities are completed. • No impediment to the natural water flow other than approved erosion control works is permitted. Air Quality Dust control • Damping down of un-surfaced and un-vegetated areas during dusty periods is required. Potable water must not be used for this and only water abstracted from sources approved by DWS in agreement with the landowners is permitted. • Retention of vegetation where possible will reduce dust travel. • Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas. • The Contractor shall be responsible for dust control on site to ensure no nuisance is caused to the Landowner or neighbouring Communities. • A notice at the junction of the R335 and the access road must be installed with a phone number that public can use to lodge complaints about dust. • A speed limit of 40km/h must not be exceeded on dirt roads (if any). • Any complaints or claims emanating from the lack of dust control shall be attended to immediately by the Contractor.

Emissions control • Regular servicing of vehicles in order to limit gaseous emissions (to be done off- site). • Regular servicing of on-site toilets to avoid potential odours. • Allocated cooking areas must be provided.

Fire prevention • All cooking shall be done in demarcated areas that are safe in terms of runaway or uncontrolled fires. It is recommended that a formal “braai area” is demarcated at the site office for cooking. • The Contractor shall have operational firefighting equipment available on site at all times. The level of firefighting equipment must be assessed and evaluated thorough a typical risk assessment process. It may be required to increase the level of protection, especially during the winter months. Water Quality Sanitation • Adequate sanitary and ablutions facilities must be provided for construction workers • The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.

Hazardous materials • Use and /or storage of materials, fuels and chemicals which could potentially leak into the ground must be controlled in a manner that prevents such occurrences. • All storage tanks containing hazardous materials must be placed in bunded containment areas with sealed surfaces. • The bund wall must be high enough to contain 110% of the total volume of the stored hazardous material with an additional allocation for potential high runoff stormwater events. • Any hazardous substances must be stored at least 100m from any of the water bodies on site. • Contaminated wastewater (such as concrete wastewater) must be managed by the Contractor to ensure existing water resources on the site are not contaminated. All wastewater from general activities in the camp shall be collected and removed from the site for appropriate disposal at a licensed commercial facility. • Waste manifests must be kept to prove legal disposal at a hazardous landfill site

Water resources • Site staff shall not be permitted to use any other open water body or natural water source adjacent to or within the designated site for the purposes of bathing, washing of clothing or for any construction related activities. • Municipal water (or another source approved by the ECO) should be used for all activities such as washing of equipment or disposal of any type of waste, dust suppression, concrete mixing, compacting, etc. • Compaction of backfilled material must attain low soil permeability. • Site design and operation must that surface/storm water is diverted away from excavation trenches. • Backfilling of trenches must be done in such a way that water ponding and erosion of the backfilled trench are avoided.

Stormwater • The site must be managed in a manner that prevents pollution of drains, downstream watercourses or groundwater, due to suspended solids, silt or chemical pollutants. • Temporary cut-off drains and berms may be required to capture stormwater and promote infiltration. • Hazardous substances must be stored at least 100m away from any water bodies on site to avoid pollution. Noise • Construction site yards, workshops, and other noisy fixed facilities should be located well away from noise sensitive areas. Once the proposed final layouts are made available by the contractor(s), the sites must be evaluated in detail and specific mitigation measures designed into the system. • Noise levels must be kept within acceptable limits. All noise and sounds generated must adhere to SABS 0103 specifications for maximum allowable noise levels for residential areas. No pure tone sirens or hooters may be utilised except where required in terms of SABS standards or in emergencies.

Biodiversity • The EWT herpetology unit must survey the site prior to construction to ensure that search and rescue of the Albany Adder is undertaken prior to the presence of construction vehicles. • Any animals rescued or recovered will be relocated in suitable habitat away from the substation and line infrastructure. An expert who holds a Competency Certificate to handle Dangerous and Venomous Reptiles should be contracted to remove any animals. • Cleared vegetation can be used to form wood piles and logs and stumps. Dead or decaying wood piles should be created as these will provide valuable refuge areas especially due to the clearance of vegetation cover. • Logs and stumps also provide important habitats for several reptile species as well as smaller mammals, amphibians, arachnids and scorpions. With time they will eventually be reduced to valuable compost by several animal species. Dead trees and stumps will also be used for nesting purposes by barbets, hoopoes, owls, hornbills as well as perching or hunting platforms for birds like the kingfisher. • Any lizards, gecko’s, monitors or snakes encountered should be allowed to escape to suitable habitat away from the disturbance. No reptile should be intentionally killed, caught or collected during any phase of the project. • General avoidance of snakes is the best policy if encountered. Snakes should not be intentionally harmed or killed and allowed free movement away from the area. • Appropriate footwear should be worn in the field. • During construction activities wherever possible work should be restricted to one area at a time. This will give smaller birds, mammals, reptiles and amphibians an opportunity to move into undisturbed areas close to their natural habitat. The contractor must ensure that no faunal species are disturbed, trapped, hunted or killed during the construction phase. • No further vegetation clearance except for the removal of alien invasive species. All remaining indigenous vegetation must be conserved wherever possible. • No roads shall be cut through river- and stream banks (riparian vegetation) as this may lead to erosion. • There must be no unnecessary disturbance of natural vegetation. Where unavoidable, such disturbed areas must be rehabilitated. • Implement a worker environmental education program and implement best management practices. Waste Management Construction rubble • Construction rubble shall be disposed of in pre-agreed, demarcated spoil dumps that have been approved by Nelson Mandela Bay Metropolitan. Waste manifests must be kept to prove that this has been disposed of legally.

Litter management • Sufficient waste bins (with animal proof lids) must be provided at the construction site for different types of waste disposal and for recycling purposes. • Refuse bins must be placed at strategic positions to ensure that litter does not accumulate within the construction site. • A housekeeping team should be appointed to regularly maintain the litter and rubble situation on the construction site. • Littering by the employees of the Contractor shall not be allowed under any circumstances. The ECO shall monitor the neatness of the work sites as well as the Contractor campsite. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

• Sanitary bins must be provided for women. • All waste must be removed from the site and transported to a landfill site as approved by the relevant Municipality.

Hazardous waste • All waste hazardous materials must be carefully stored as advised by the ECO, and then disposed of off-site at a licensed landfill site. • Contaminants to be stored safely to avoid spillage • Machinery must be properly maintained to keep oil leaks in check.

Sanitation • The Contractor shall install mobile chemical toilets on the site. • Staff shall be sensitised to the fact that they should use these facilities at all times. • No indiscriminate sanitary activities on site shall be allowed. • Ablution facilities shall be within 100m from workplaces but not closer than 100m from any natural water bodies or boreholes. There should be enough toilets available to accommodate the workforce. Male and females must be accommodated separately where possible. Alternatively ablution facilities may be located in a place approved by the ECO. • Toilets shall be serviced regularly and the ECO shall inspect toilets regularly. • Potable water must be provided for all construction staff.

Remedial actions • Depending on the nature and extent of the spill, contaminated soil must be either excavated or treated on-site. • The ECO must determine the precise method of treatment of polluted soil. • This could involve the application of soil absorbent materials or oil-digestive powders to the contaminated soil. • If a spill occurs on an impermeable surface such as cement or concrete, the surface spill must be contained using oil absorbent materials. • Contaminated remediation materials must be carefully removed from the area of the spill so as to prevent further release of petrochemicals to the environment, and stored in adequate containers until appropriate disposal. • Spill kits must be provided at strategic points within the construction site. Health and Safety Worker safety • Implementation of safety measures, work procedures and first aid must be implemented on site. • A health and safety plan in terms of the Occupational Health and Safety Act (Act No. 85 of 1993) must be drawn up to ensure worker safety. • Contractors must ensure that all equipment is maintained in a safe operating condition. • A record of health and safety incidents must be kept on site. • Any health and safety incidents must be reported to the Project Coordinator immediately. • First aid facilities must be available on site at all times. • Workers have the right to refuse work in unsafe conditions. • Material stockpiles or stacks must be stable and well secured to avoid collapse and possible injury to site workers.

Worker facilities • Eating areas should be regularly serviced and cleaned to ensure the highest possible standards of hygiene and cleanliness

Protective gear • Personal Protective Equipment (PPE) must be made available to all construction staff and the wearing and use of PPE must be compulsory. Hard hats and safety shoes must be worn at all times and other PPE worn where necessary i.e. dust masks, ear plugs, hard hat, safety boots and overalls etc. • No person is to enter the site without the necessary PPE. • The construction camp must remain fenced for the entire construction period. • Potentially hazardous areas such as trenches are to be demarcated and clearly marked with orange snow netting. The ESO must check the trenches before work commences to ensure that no animal species have fallen in. • Adequate warning signs of hazardous working areas must be erected in suitable locations. • Uncovered manholes and excavations must be clearly demarcated • Emergency numbers for local police, fire department, Eskom and the Municipality must be placed in a prominent area. • Firefighting equipment must be placed in prominent positions across the site where it is easily accessible. This includes fire extinguishers, a fire blanket as well as a water tank. • A speed limit of 40km/h must be adhered to by all vehicles and machinery.

Hazardous Material Storage • Staff that will be handling hazardous materials must be trained to do so. • Any hazardous materials (apart from fuel) must be stored within a lockable store with a sealed floor. • All storage tanks containing hazardous materials must be placed in bunded containment areas with sealed surfaces. The bund walls must be high enough to contain 110% of the total volume of the stored hazardous material. • The provisions of the Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practise must be adhered to. This applies to solvents and other chemicals possibly used in the construction time.

Procedure in the event of a petrochemical spill • The individual responsible for or who discovers the petrochemical spill must report the incident to the Project Coordinator, ECO and or Contractor as soon as reasonably possible. • The problem must be assessed and the necessary actions required will be undertaken. • The immediate response must be to contain the spill.

Fire management • Firefighting equipment should be present on site at all times as per Occupational Health and Safety Act. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

• All construction staff must be trained in fire hazard control and firefighting techniques. • All flammable substances must be stored in dry areas which do not pose an ignition risk to the said substances. • No open fires will be allowed on site unless in a demarcated area identified by the ECO. This area must be equipped with fire extinguishers. • Smoking may only be conducted in demarcated areas as agreed upon by the ECO and contractor. This area must be equipped with fire extinguishers. Security • Unsocial activities such as consumption or illegal selling of alcohol, drug utilisation or selling on site are prohibited. • Any persons found to be engaged in such activities shall have disciplinary and / or criminal action taken against them. • No person shall enter the site unless authorised to do so by the contractor, Project Coordinator and ECO. All visitors must report to the site office on arrival, undergo induction training, sign an indemnity form and be in possession of the correct PPE clothing to wear while on site. • If any fencing interferes with the construction process, such fencing shall be deviated until construction is completed. The deviation of fences shall be negotiated and agreed with the landowner in writing by the ECO. • Trespassing on private / commercial properties adjoining the site is forbidden. • The site must be secured in order to reduce the opportunity for criminal activity in the locality of the construction site Social Environment • All contact with affected parties shall be courteous at all times. The rights of the affected parties shall be respected at all times. • A complaints register should be kept on site. Details of complaints should be incorporated into the audits as part of the monitoring process. This register is to be tabled during monthly site meetings. • No interruptions other than those negotiated shall be allowed to any essential services. • Damage to infrastructure shall not be tolerated and any damage shall be rectified immediately by the Contractor. A record of all damage and remedial actions shall be kept on site. • Road rehabilitation should take place during and once construction is completed. • Construction traffic should only make use of approved routes. • Where possible unskilled job opportunities should be afforded to local community members. • Equal opportunities for employment should be created to ensure that the local female population also have access to these opportunities. Females should be encouraged to apply for positions. • Payment should comply with applicable Labour Law legislation in terms of minimum wages. • Local companies should be given the opportunity to tender for the provision of locally-sourced materials, labour, plant, transport, etc. Cultural and Heritage • Local museums as well as the South African Heritage Resource Agency (SAHRA) Artefacts and the Eastern Cape Heritage Resource Agency (ECHRA) should be informed if any artefacts are uncovered in the affected area and mitigation measures recommended by SAHRA should be followed.

• The contractor must ensure that his workforce is aware of the necessity of reporting any possible historical or archaeological finds to the ECO so that appropriate action can be taken. • Any discovered artefacts shall not be removed under any circumstances. Any destruction of a site can only be allowed once a permit is obtained and the site has been mapped and noted. • Permits shall be obtained from the Eastern Cape Heritage Resource Agency (whichever is relevant) Construction site Removal of equipment decommissioning • All structures comprising the construction camp are to be removed from site. • The area that previously housed the construction camp is to be checked for spills of substances such as oil, paint, etc., and these shall be cleaned up and contaminants disposed of appropriately. • All hardened surfaces within the construction camp area should be ripped, all imported materials removed, and the area shall be top soiled and rehabilitated using the guidelines as set out in the section on Flora and Fauna that forms part of this document.

Temporary services • The Contractor must arrange the cancellation of all temporary services. • Temporary roads must be closed and access across these blocked. • All areas where temporary services were installed are to be rehabilitated to the satisfaction of the ECO.

Associated infrastructure • Surfaces are to be checked for waste products from activities such as concrete batching and cleared in a manner approved by the ECO. • All surfaces hardened due to construction activities are to be ripped and imported material thereon removed. • All rubble is to be removed from the site to an approved disposal site as approved by the ECO. Burying of rubble on site is prohibited. Waste manifests must be kept to prove that this has been disposed of legally. • The site is to be cleared of all litter. Waste manifests must be kept to prove that this has been disposed of legally. • The Contractor is to check that all watercourses are free from building rubble, spoil materials and waste materials. • Fences, barriers and demarcations associated with the construction phase are to be removed from the site. • All residual stockpiles must be removed or spread on site as directed by the ECO. • All unused building materials must be removed from the site. • The Contractor must repair any damage that the construction works has caused to neighbouring properties, specifically, but not limited to, damage caused by poor storm water management.

Rehabilitation • Disturbed areas of natural vegetation as well as cut and fills must be rehabilitated immediately after the installation of the new towers to prevent further soil erosion.

• Re-seeding shall be done on disturbed areas as directed by the ECO. Only seeds of indigenous plants must be used. • Recommended rehabilitation is in the form of active re-vegetation of affected areas, including areas where surface disturbances resulted from construction, as well as areas that were used for alternative or other functions, such as storage areas, parking bays, etc.; • Existing access roads should be left ‘as is’ for future use during maintenance operations; • In accordance with the Conservation of Agricultural Resources Act, No 43 of 1983, slopes in excess of 2% must be contoured and slopes in excess of 12% must be terraced. Other methods of rehabilitation may also be used at the discretion of the ECO, e.g. stone pitching, logging, etc. Contour banks shall be spaced according to the slope on tower sites. The type of soil shall also be taken into consideration. • Final inspection in order to ensure adherence to EMPr guidelines, completion of localised/ remaining areas of impact, monitoring of rehabilitation success, etc. SPECIALIST MITIGATION MEASURES Activity/Issue Specification Ecological • A comprehensive Search and Rescue prior to vegetation clearance must be undertaken. • A search and rescue plan is recommended for species that are likely to have a high survival rate such as Aloe and Euphorbia species. • SCCs should either be housed in an onsite nursery for use during rehabilitation or be relocated to suitable areas where vegetation clearance will not occur. • If possible, the removal of Milkwood trees should be avoided, however where not possible applicable permits have to be obtained prior to vegetation clearance. • Large populations of Aloes should be avoided. • A 10m safe buffer should be placed around all bushclumps which should be deemed no-go areas. • The clearance of vegetation at any given time should be kept to a minimum in order to reduce the possibility of soil erosion. • Vegetation clearing and trampling should be avoided in areas demarcated as no-go areas. • Temporary infrastructure such as the site camp, laydown areas and storage areas must be placed in areas already transformed. • Employees must be prohibited from making fires and harvesting plants. • All alien vegetation within the development footprint should be removed from site and disposed of at a registered waste disposal site for the duration of construction and continuous monitoring of seedlings need to occur. • Only indigenous species should be used for rehabilitation purposes. • As far as practically be possible, existing roads needs to be utilised. • Construction activities such as digging of trench that can result in excessive dust pollution should preferably cease during period of high winds. • Exposed soil surfaces should be wet down where required to avoid dust emissions. • Vehicles transporting construction material such as building sands should remain at a speed limit of 40km/h and if required cover their loads with a tarpaulin to avoid dust emissions. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

• Limit the height of stockpiles to 1.5m. • Newly cleared and exposed areas must be managed for dust and landscaped with indigenous vegetation to avoid soil erosion. Where necessary, temporary stabilization measures must be used until vegetation establishes. • Plan for the worst case, that is, for heavy rainfall and runoff events, or high winds. • Appropriate erosion control measures must be implemented and a monitoring programme established to ensure that no erosion is taking place. At the first sign of erosion the necessary remedial action must be taken. • Reasonable measures to limit erosion and sedimentation due to construction activities must be implemented and must comply with the measures outlined in the EMPr as and when required. • Machinery that generates noise must be regularly maintained in order to ensure that no unnecessary additional noise is produced. • Equipment with lower sound levels should be selected where feasible. • Vehicles associated with the construction of the development, should only be allowed to drive on roads at night if there is an emergency. Agriculture & Soils • Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 must be adhered to. This applies to solvents and other chemicals possibly used during the construction process; • Cement must not be mixed directly on the ground, or mixed during rainfall events when the potential for transportation into the stormwater system is the greatest; • Cement must only be mixed in the area demarcated for this purpose and on impermeable surfaces; • Drip trays must be placed under construction machinery to avoid soil contamination; • The appointed ECO must determine the precise method of treatment of polluted soil. This could involve the application of soil absorbent materials, oil-digestive powders to the contaminated soil or the excavation of the contaminated soil depending on the nature of the spill; • If refuelling occurs on site, a dedicated area should be established and refuelling should only take place on impermeable surfaces; • All fuel should be stored in a bunded area; • Ensure all construction machinery is in sound working order to prevent oil leaks; • Any hazardous materials that need to be stored on site must be done under lock and key. • The clearance of vegetation should be limited to the demarcated construction footprint. • Heavy construction activities should be scheduled to avoid excessively wet periods, where possible; and • Topsoil stockpiles must not be compacted. • The appointed ECO must monitor the soil erosion and remedial action must be taken at the first signs of erosion. • Stripping of topsoil should be undertaken in such a manner as to minimise erosion by wind or runoff; • Areas from which the topsoil is to be removed must be cleared of any foreign material which could form part of the topsoil during removal including rubble, any waste material, litter, excess vegetation and any other material which could reduce the quality of the topsoil;

• Ensure that subsoil and topsoil are not mixed during stripping, excavation, reinstatement and rehabilitation. If topsoil is mixed with clay subsoil the usefulness of the topsoil for rehabilitation of the site will be lost; • Once cleared, soils should be exposed for the minimum time possible; • Topsoil should be temporarily stockpiled, separate from subsoil and rocky materials; • Topsoil should only be stockpiled in areas designated by the appointed ECO; • Stockpiled topsoil must not be compacted; • Any excess topsoil that is not used for rehabilitation must be removed from the site. • If the topsoil is sterile or the seedbank is affected then topsoil should be supplemented with an indigenous seed mix; • Soils outside of the development footprint that are exposed during the construction of the WEF must only be bare for the minimum time possible; • Stockpiled topsoil must not be compacted; • The site must be rehabilitated to the satisfaction of the appointed ECO. Avifauna • The sensitivity map produced as an outcome of the 12-month avifaunal pre- construction monitoring must be adhered to. • Conductors on the high bird collision risk sections of the line must be fitted with the best available (at the time of construction) Eskom approved anti bird collision line marking device. This should preferably be a dynamic device, i.e. one that moves as it is believed that these are more effective in reducing collisions. Paleontological • Excavation of footing holes should be monitored, either by a palaeontologist or by an ECO trained by and in correspondence with a palaeontologist. This should be discussed between the palaeontologist, ECO and site engineer prior to the commencement of work. Heritage • If the current layout of the wind energy facility is changed, altered, or additions of infrastructure in area that were covered during this study an archaeological walk-through survey of the changes must be conducted and further mitigatory recommendations made if necessary. • Portions of the proposed area for development are covered in dense vegetation and sites/features may be covered by soil and vegetation and will only be located once this has been removed. A person must be trained as a site monitor to report any archaeological sites found during the development. Construction managers/foremen and/or the Environmental Control Officer (ECO) should be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find sites. • If concentrations pre-colonial archaeological heritage material and/or human remains (including graves and burials) are uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/or the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) (043 745 0888) so that systematic and professional investigation/excavation can be undertaken. Phase 2 mitigation in the form of test-pitting/sampling or systematic excavations and collections of the pre- colonial shell middens and associated artefacts will then be conducted to establish the contextual status of the sites and possibly remove the archaeological deposit before development activities continue. “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

• The developer / ECO / or construction manager must apply to the Eastern Cape Provincial Heritage Resources Agency (ECPHRA) for a destruction permit for the stone artefacts prior to the commencement of the development activities. • The built environment structure situated on the Farm Welbedachtsfontein 300 (WELBE_1 – WELBE_3) and the brick paved road are older than 60 years and therefore protected under Section 34 of the NHRA. These structures should not be negatively impacted during the development and operations activities related to the WEF. Noise • The results of the Noise Impact Assessment undertaken by a Noise Specialist does not recommend any noise mitigation. This is due to the fact that the site is a mining area and because the NSD’s identified have not been identified as sensitive. Social • Cooperate with the NMBM and their relevant structures to compile / update a database of an available labour force, skills requirements, etc. This process should start well in advance of the construction period commencing. • Liaise with NMBM regarding their methods used to advertise for employment. Take care not to create unrealistic expectations and communicate the time frames, skills requirements and commencement of the activities clearly to the communities. • Set up a central labour desk where workers register. Only workers registered on this database should be considered for employment. • Recruitment of temporary workers at the access to the construction site should not be allowed. The Community Liaison Officer (CLO) should work in consultation with the Ward Councillors and community representatives to establish labour desks at the most suitable localities within the communities where workers are sourced. • Identify a CLO for the areas well in advance of the construction period commencing. Set up criteria for the CLO’s to ensure that the correct people are appointed. The CLO should have knowledge of the local community members and area, be educated, committed to the cause, accessible for community members as well as for the developer, etc. • Give preference to workers from the local metropolitan municipal area, followed by people from the district municipality. • Contractually oblige Sub-contractors to only employ workers through the labour desk and make this fact known to the communities. This would address and limit the uncoordinated influx of people to the site and to the surrounding towns, as they would be unable to secure work if not through the labour desk. • Issues such as accommodation for workers, transport, catering and any other needs for employees, whether locals or outsiders, must be discussed with Metropolitan Municipality in good time. Once construction starts structures must already be in place to address SMME needs and requirements and implement management measures. • A skills audit of the available workforce must be conducted in order to minimise the numbers of workers (skilled, semi- and unskilled) to be brought in from other areas. • Enhance on a capacity building and skills development strategy to lessen any possible skills disparities between the local skills available and the requirements of the project.

• A policy regarding employment equity of minority groups (women, youth and the disabled) should be formulated and implemented wherever possible. • Announce disruptions, road closures, etc. by using the local media, road sign boards and other Municipal structures. • Erect signboards along surrounding routes indicating accesses to the construction site. • Set up the labour desk in a secure and suitable area, preferably in the communities where workers are being sourced, to discourage the gathering of temporary workers at the entrance and access roads to the construction site where it could affect road users and surrounding land owners. Visual • Dust suppression is important as dust will raise the visibility of the development. • New road construction should be minimised and existing roads should be used where possible. • The contractor should maintain good housekeeping on site to avoid litter and minimise waste. • Night lighting of the construction sites should be minimised within requirements of safety and efficiency.

OPERATIONAL PHASE GENERAL MITIGATION MEASURES Activity/Issue Specification Ecology • Ensure that maintenance staff and vehicles remain on designated roads and paths within the site. • Avoid unnecessary disturbance of existing bush/thicket patches. Lighting • Reduce night lighting impacts by using shaded lighting and using lights at low levels. Architecture of ancillary • Ensure that the surfaces of all project structures and buildings visible to the infrastructure public are maintained such that: 1. their colours minimize visual intrusion and contrast by blending with the existing colours of the surrounding landscape, 2. their colours and finishes do not create excessive glare, and 3. their colours and finishes are consistent with local policies and ordinances. Storage of hazardous • Ensure that all hazardous substances are stored in appropriately bunded substances locations. Operating equipment • Lower noise emission levels from inverters and transformers can be achieved by housing them in enclosed structures. Stormwater management • Maintain recommendations of the Storm Water Management Plan. Waste management • Develop and implement a waste management plan incorporating recycling and waste minimization and legal aspects into the plan. • Develop and implement a worker education plan for waste management in the work environment. SPECIALIST MITIGATION MEASURES Activity/Issue Specification

Ecological • Implement an Alien Management Plan during the operational phase for the first year after construction has been completed. • Eradicate alien plants from the impacted area as they appear; and • Monitor the study area for any new growth of invasive plants (every 3 months for a period of 12 months after the completion of construction). • A rehabilitation plan must be designed and implemented; • During the rehabilitation of the area, measures should be put in place to prevent accidental or unintended introduction of alien species from occurring; and • An Alien Invasive Control Programme must be implemented. Agriculture & Soils • All reasonable measures to limit erosion during the Operational Phase must be taken; and • Remedial action must be taken at the first signs of erosion. Avifauna • Bird friendly pole/pylon designs (for example monopoles) should be used to prevent electrocutions. Visual • Turbine maintenance should be conducted regularly. • Wind turbines shall be painted bright white to provide maximum daytime conspicuousness. Lighting should be designed to minimise light pollution without compromising safety. • Wind farms are required by law to be lit at night as they represent hazards to aircraft due to the height of the turbines. Marking of turbines depends on wind farm layout and not all turbines need to be lit. Social • Maximize the number of local permanent and temporary employees (from the NMBM) where possible. • Do training and capacity building wherever necessary. • Assist and guide the local community with regards to the needs of the WEF plant and the types of supporting industries and services required for its successful operation. Enterprise Development funding is available to assist the local SMME’s with skills training and capacity building, etc. • Establish a PSC or similar structure consist of representatives of DEDEAT and the NMBM and their relevant Directorates for Economic Development;

DECOMMISSIONING PHASE GENERAL MITIGATION MEASURES Activity/Issue Specification Ecology • Construction vehicles and machinery should make use of existing infrastructure such as roads as far as possible to minimise disturbance on the receiving environment. • Ensure that all bare land is rehabilitated after decommissioning. Noise sensitive receptors • Machinery that causes noise must only be operated at appropriate times (during the day and at normal working hours). Pollution • Littering must be avoided and litter bins should be made available at various strategic points on site. Refuse from the construction site should be collected on a regular basis and deposited at an appropriate landfill. • No storage of fuels and hazardous materials should be permitted near sensitive water resources. All hazardous substances (e.g. diesel, oil drums, etc.) to be stored in a bunded area.

• Ensure adequate storm water management by implementing recommendations of the Storm Water Management Plan during construction. Dust • Reduce fugitive/nuisance dust by implementing the following: · o Damping down of un-surfaced and un-vegetated areas; o Retention of vegetation where possible; · o Demolitions and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas; o A speed limit of 40km/h must not be exceeded on dirt roads. • Any complaints or claims emanating from the lack of dust control should be attended to immediately by the Contractor. Traffic & Transport • Deconstruction vehicles and machinery should make use of existing infrastructure such as roads as far as possible to minimise disturbance on the receiving environment. • There must be no unnecessary disturbance of existing vegetation. Soil Erosion • After the removal of all wind turbine-related structures, the disturbed soils should be re-vegetated to avoid unnecessary soil erosion. Land use • Ensure that an appropriate land use is adopted.

SECTION F: APPENDICES

The following appendixes must be attached as appropriate:

APPENDIX A: SITE PLAN(S) - Wind Energy Facility - Powerline Corridor Alternatives

APPENDIX B: PHOTOGRAPHS - Wind Energy Facility - Powerline Corridor Alternatives

APPENDIX C: FACILITY ILLUSTRATION(S) - Wind Energy Facility - Powerline Corridor Alternatives

APPENDIX D: SPECIALIST REPORTS - Appendix D1: Agriculture & Soils Impact Assessment - Appendix D2: Avifaunal Impact Assessment - Appendix D3: Bat Impact Assessment - Appendix D4: Ecological Impact Assessment - Appendix D5: Heritage Impact Assessment - Appendix D6: Noise Impact Assessment - Appendix D7: Paleontological Impact Assessment - Appendix D8: Visual Impact Assessment

APPENDIX E: PUBLIC PARTICIPATION - Appendix E1: Notice Board - Appendix E2: Correspondence - Appendix E3: Advertisements - Appendix E4: Issues & Response Trail - Appendix E5: Stakeholder/Landowner/Surrounding Landowner/I&AP Database

APPENDIX F: ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) - Environmental Management Programme (EMPr)

APPENDIX G: OTHER INFORMATION - Addendum 1: Sensitivity Maps (WEF and Powerline Alternatives) - Addendum 2: Powerline Alternative Coordinates

ADDENDUM 1: POWERLINE ALTERNATIVE COORDINATES (250m intervals)

POWERLINE ALTERNATIVE 1 (PREFERRED) START 33° 43' 47.620" S 25° 36' 23.120" E 250m 33° 43' 55.364" S 25° 36' 28.284" E 500m 33° 44' 02.384" S 25° 36' 33.050" E 750m 33° 44' 09.404" S 25° 36' 37.816" E 1 000m 33° 44' 16.424" S 25° 36' 42.582" E 1 250m 33° 44' 23.444" S 25° 36' 47.348" E 1 500m 33° 44' 30.464" S 25° 36' 52.114" E 1 750m 33° 44' 37.484" S 25° 36' 56.880" E 2 000m 33° 44' 44.504" S 25° 37' 01.647" E 2 250m 33° 44' 52.524" S 25° 37' 01.469" E 2 500m 33° 45' 00.588" S 25° 37' 01.074" E 2 750m 33° 45' 06.024" S 25° 37' 07.273" E 3 000m 33° 45' 10.842" S 25° 37' 15.024" E 3 250m 33° 45' 15.661" S 25° 37' 22.775" E 3 500m 33° 45' 21.394" S 25° 37' 29.510" E 3 750m 33° 45' 27.491" S 25° 37' 35.841" E 4 000m 33° 45' 33.589" S 25° 37' 42.171" E 4 250m 33° 45' 39.686" S 25° 37' 48.502" E 4 500m 33° 45' 45.784" S 25° 37' 54.833" E 4 750m 33° 45' 51.881" S 25° 38' 01.164" E 5 000m 33° 45' 57.979" S 25° 38' 07.495" E 5 250m 33° 46' 04.077" S 25° 38' 13.826" E 5 500m 33° 46' 07.584" S 25° 38' 22.156" E 5 750m 33° 46' 09.881" S 25° 38' 31.420" E 6 000m 33° 46' 12.178" S 25° 38' 40.685" E 6 250m 33° 46' 14.475" S 25° 38' 49.949" E 6 500m 33° 46' 16.772" S 25° 38' 59.214" E 6 750m 33° 46' 19.069" S 25° 39' 08.479" E 7 000m 33° 46' 21.366" S 25° 39' 17.744" E 7 250m 33° 46' 23.663" S 25° 39' 27.009" E END 33° 46' 25.191" S 25° 39' 34.408" E

POWERLINE ALTERNATIVE 2 START 33° 43' 47.625" S 25° 36' 23.127" E 250m 33° 43' 56.299" S 25° 36' 25.650" E 500m 33° 43' 59.575" S 25° 36' 32.673" E 750m 33° 44' 00.241" S 25° 36' 42.300" E 1 000m 33° 43' 54.297" S 25° 36' 48.318" E 1 250m 33° 43' 47.787" S 25° 36' 54.027" E 1 500m 33° 43' 43.050" S 25° 37' 01.827" E 1 750m 33° 43' 38.373" S 25° 37' 09.699" E 2 000m 33° 43' 32.858" S 25° 37' 16.599" E “Innovation for Sustainable Development” t Floor Room 274 • Beacon Hill • Hockley Close • Kind William’s Town • 5600 | Private Bag X0054 • 5605 • Republic of South Africa TeL; 043 605 7099• Fax: 043 605 7300 | Email: • Web: www.dedeat.gov.za VERSION 1 dated 8 December 2014

2 250m 33° 43' 26.433" S 25° 37' 22.445" E 2 500m 33° 43' 26.185" S 25° 37' 31.638" E 2 750m 33° 43' 26.750" S 25° 37' 41.273" E 3 000m 33° 43' 27.316" S 25° 37' 50.908" E 3 250m 33° 43' 27.881" S 25° 38' 00.543" E 3 500m 33° 43' 30.500" S 25° 38' 09.434" E 3 750m 33° 43' 34.495" S 25° 38' 17.827" E 4 000m 33° 43' 38.490" S 25° 38' 26.220" E 4 250m 33° 43' 42.485" S 25° 38' 34.613" E 4 500m 33° 43' 46.480" S 25° 38' 43.007" E 4 750m 33° 43' 50.474" S 25° 38' 51.400" E 5 000m 33° 43' 54.468" S 25° 38' 59.794" E 5 250m 33° 43' 58.463" S 25° 39' 08.188" E 5 500m 33° 44' 02.457" S 25° 39' 16.583" E 5 750m 33° 44' 06.451" S 25° 39' 24.977" E 6 000m 33° 44' 13.673" S 25° 39' 27.645" E 6 250m 33° 44' 21.672" S 25° 39' 28.933" E 6 500m 33° 44' 29.671" S 25° 39' 30.222" E 6 750m 33° 44' 36.811" S 25° 39' 27.709" E 7 000m 33° 44' 43.178" S 25° 39' 21.771" E 7 250m 33° 44' 49.545" S 25° 39' 15.832" E 7 500m 33° 44' 55.911" S 25° 39' 09.893" E 7 750m 33° 45' 03.799" S 25° 39' 09.754" E 8 000m 33° 45' 11.056" S 25° 39' 06.671" E 8 250m 33° 45' 17.829" S 25° 39' 01.415" E 8 500m 33° 45' 24.601" S 25° 38' 56.159" E 8 750m 33° 45' 31.374" S 25° 38' 50.903" E 9 000m 33° 45' 39.376" S 25° 38' 50.923" E 9 250m 33° 45' 47.443" S 25° 38' 51.225" E 9 500m 33° 45' 55.510" S 25° 38' 51.526" E 9 750m 33° 46' 02.762" S 25° 38' 53.752" E 10 000m 33° 46' 07.729" S 25° 39' 01.369" E 10 250m 33° 46' 12.696" S 25° 39' 08.986" E 10 500m 33° 46' 17.663" S 25° 39' 16.603" E 10 750m 33° 46' 22.631" S 25° 39' 24.221" E END 33° 46' 27.598" S 25° 39' 31.839" E

POWERLINE ALTERNATIVE 3 START 33° 43' 47.091" S 25° 36' 20.802" E 250m 33° 43' 43.089" S 25° 36' 12.223" E 500m 33° 43' 41.666" S 25° 36' 03.748" E 750m 33° 43' 45.593" S 25° 35' 55.309" E 1 000m 33° 43' 49.519" S 25° 35' 46.871" E 1 250m 33° 43' 53.446" S 25° 35' 38.432" E 1 500m 33° 43' 57.372" S 25° 35' 29.993" E 1 750m 33° 44' 02.673" S 25° 35' 23.708" E 2 000m 33° 44' 10.508" S 25° 35' 21.391" E

2 250m 33° 44' 18.440" S 25° 35' 20.820" E 2 500m 33° 44' 26.462" S 25° 35' 21.874" E 2 750m 33° 44' 34.484" S 25° 35' 22.929" E 3 000m 33° 44' 42.506" S 25° 35' 23.983" E 3 250m 33° 44' 50.528" S 25° 35' 25.038" E 3 500m 33° 44' 58.550" S 25° 35' 26.092" E 3 750m 33° 45' 01.622" S 25° 35' 18.137" E 4 000m 33° 45' 03.989" S 25° 35' 08.901" E 4 250m 33° 45' 06.356" S 25° 34' 59.665" E 4 500m 33° 45' 08.723" S 25° 34' 50.428" E 4 750m 33° 45' 11.090" S 25° 34' 41.192" E 5 000m 33° 45' 13.456" S 25° 34' 31.955" E 5 250m 33° 45' 15.822" S 25° 34' 22.719" E 5 500m 33° 45' 18.188" S 25° 34' 13.482" E 5 750m 33° 45' 20.554" S 25° 34' 04.245" E 6 000m 33° 45' 24.792" S 25° 33' 56.244" E 6 250m 33° 45' 30.055" S 25° 33' 48.920" E 6 500m 33° 45' 35.319" S 25° 33' 41.596" E 6 750m 33° 45' 40.582" S 25° 33' 34.272" E 7 000m 33° 45' 45.844" S 25° 33' 26.947" E 7 250m 33° 45' 52.617" S 25° 33' 22.409" E 7 500m 33° 46' 00.349" S 25° 33' 19.642" E 7 750m 33° 46' 08.081" S 25° 33' 16.875" E 8 000m 33° 46' 15.812" S 25° 33' 14.107" E 8 250m 33° 46' 23.797" S 25° 33' 13.198" E 8 500m 33° 46' 31.862" S 25° 33' 12.888" E 8 750m 33° 46' 39.928" S 25° 33' 12.578" E 9 000m 33° 46' 47.994" S 25° 33' 12.268" E 9 250m 33° 46' 56.060" S 25° 33' 11.958" E 9 500m 33° 47' 04.125" S 25° 33' 11.648" E 9 750m 33° 47' 11.066" S 25° 33' 14.343" E 10 000m 33° 47' 16.237" S 25° 33' 21.762" E 10 250m 33° 47' 21.408" S 25° 33' 29.182" E 10 500m 33° 47' 26.579" S 25° 33' 36.603" E 10 750m 33° 47' 31.750" S 25° 33' 44.023" E 11 000m 33° 47' 36.921" S 25° 33' 51.444" E 11 250m 33° 47' 42.092" S 25° 33' 58.865" E 11 500m 33° 47' 47.262" S 25° 34' 06.286" E 11 750m 33° 47' 52.433" S 25° 34' 13.708" E 12 000m 33° 47' 57.603" S 25° 34' 21.129" E END 33° 48' 02.417" S 25° 34' 27.044" E