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Telephone: (046) 6248483 PO Box 2407 (083) 6751520 PORT ALFRED 6170 15 August 2012

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Telephone: (046) 6248483 PO Box 2407 (083) 6751520 PORT ALFRED 6170 15 August 2012 Telephone: (046) 6248483 PO Box 2407 (083) 6751520 PORT ALFRED 6170 15 August 2012 Our Reference: NRF/NMBWSP -1 Appendix A: Letter by Mr de Wet dated 16 June 2012. B: Ndlambe Bulk Water Supply: Kleinemonde Submission dated 18 January 2012 Dr Cherrie-Lynn Mack Coastal & Environmental Services P.O. Box 8145 EAST LONDON 5210 COMMENT: PROPOSED NDLAMBE MUNICIPAL BULK WATER SCEME PROJECT INTRODUCTION 1. Notice of an Environmental Assessment dated 30 September 2011 the revised Basis Information Document, project progress report no 5 and the draft Basic Assessment Report dated June 2012 has reference. 2. Members of the project team met with committee members of Cannon Rocks and Boknesstrand Ratepayers Associations on 19 July 2012. During this meeting it was agreed that the members of the project team and the Ndlambe Ratepayers Forum (NRF) will meet on 8 August 2012. The purpose of these meetings was to clarify uncertainties and discuss concerns identified by the members of the NRF. Various questions as well as studies required, were also raised during these meetings. 3. A letter by Mr Johan de Wet, Appendix A, was also drafted to address concerns regarding the project. 4. Attached, for ease of reference, the submission from Kleinemonde Ratepayers Association, Appendix B, dated January 2012. To a large extend none of the issues raised in the submission have been addressed in progress report no5. However, some specific issues are included under Ndlambe East Project Design below. 5. Concerns and questions addressed in both appendices must also be addressed. 6. The following design standards are used in the document. 6.1. Water availability: 750L to 1000L/household/day or 130L/person/day. 6.2. Fire Fighting requirements: Delivery rate >900L/minute. In addition ± 30% of total reservoir capacity to be retained for fire fighting. REPORTS 7. Draft Basic Assessment Report. The Draft Basic Assessment Report dated June 2012 paragraph 4.2 (page 13 and 14). 2 7.1. The bulk water capacity (Ndlambe West) does not make provision for 30% of the storage capacity for emergency (fire) which is an immediate to short term concern that needs urgent attention. 7.2. Secondly, the absence of scheduled preventative maintenance on the bulk water system during the last 20 years is by far a bigger contribution towards the degeneration of the existing water infrastructure than the ageing process. 7.3. Figure A.1.6 (page 14) indicates a prediction growth of water demand of 10ML/day (4ML + 6 ML) currently to 23ML/day (9ML + 14 ML) in 2035.The same figure also indicates. Note 1: 14.5ML increased to 18ML in terms of the Revised BID 2: What is correct estimate water demand for Ndlambe West – 6 or 9 ML/day? 7.3.1. Questions. On which statistics is the predicted growth in water demand from 10ML/day (2010) to 23 ML/day (2035) based? 8. Report no 5. Ndlambe Bulk Water Supply Progress report no 5 paragraph 3.6 (page 7) indicates centralized desalination at a cost of R179m. 8.1. Question. Which desalination plant(s) is referred to in the Progress Report no5 paragraph 3.6 (page 7)? PROJECT DESIGN 9. Evaluation. The criterion that was used for the evaluation of the various project options is not visible which gives rise to the following questions. 9.1. Questions. 9.1.1. What are the factors accounting for the acceptance or the preferred alternative, is the preferred alternative based on environmental impact factors? 9.1.2. What criteria were used to decide in closing down existing water treatment works (including re-use). Also refer to Appendix A dated 16 June 2012 paragraph A.b (page 2). 9.1.3. Were the eight alternative options considered by the Department of Environmental Affairs and Tourism? 10. Water Demand. The existing water consumption indicates a usage of 10.2 ML/day (9.5ML/day plus estimated shortages of 0.7KL/day) for the Ndlambe Municipality. Whereas the project suggest a water demand of 20.8ML/day (Ndlambe east 14.5ML +Ndlambe west 6ML per day). See also Appendix A page 1, 2 and 3 under the heading “PROJECT”. 10.1. Question. With reference to the question in paragraph 7.3.1 above, what is reason for the inflated bulk water supply? 11. Project Time Frame. The total time frame of the project is not clear. If the demand of water is projected for 2035 what are the requirements for the short term 2012 to 2015 or medium term to 2025? In the event of a phased implementation approach, the time frame is essential to allow for milestones and the allocation of capital funds to each milestone as well as the visibility regarding funds required for operation. Funds required for operation will include normal corrective and preventative maintenance that will include amongst other the replacement of components such as filters etc. It is believed that the lifespan of a desalination plant varies between 13 to 15 years. At the end of its lifespan, the plant needs to be replaced/refurbished with the possible exception of minor components such as 3 electric motors. Considering the expected life of a desalination plant of 13 to 15 years and the projection of the project until 2035, all desalination plants will have to replaced almost twice during the above mentioned period. 12. Storage Capacity. It is uncertain if the existing bulk water storage capacity of the Ndlambe Municipality conforms to outlet control requirements at its reservoirs to accommodate water reserves for fire fighting in accordance with design guidelines/legislation (see paragraph 6 above). 13. Question. Do any of the bulk water reservoirs in the Ndlambe Municipal area make provision for a 30% storage capacity for firefighting? 14. Studies. 14.1. A study to be conducted to determine whether the existing water reservoirs in the Ndlambe Municipal Area conform to storage reserves to satisfy legislation requirements or not. If not, the study must provide design guidelines of future reservoirs. 15. Project Costs. 15.1. Cost Escalation. In terms of the progress report no 5 (page 6) the cost of the project escalated from R484m to R780m, which is an increase of 87% in comparison to the increase of 38% as indicated in the report. 15.2. Question. What is the real project escalation? 15.3. Cost Distribution. Uncertainty exists regarding the distribution of project cost in terms of the various sources and their percentage liability, including the Nngqushwa Local Municipality. The progress report no 5 (executive summary page ii) indicates the co- funding of approximately 40% (± R348m) of the project cost, by Amatola Water and Ndlambe Municipality and do not refer to any cost sharing by the Nngqushwa Local Municipality. 15.4. The running costs of desalination plants are expensive. It is of concern to what extend the project cost has escalated from the original to the present. If this cost escalation is to continue it will eventually become too expensive to end-users to foot the bill - as was the case with the Bigon Africa proposal. What will the envisaged future water cost per liter be? Will consumers be billed for water usage only or will there be a water availability fee irrespective if water was consumed or not? If so, what will the estimated water availability fee be? Refer to question 15.5 below. 15.5. Question. What percentage of the project cost will the Ndlambe Municipality be liable for? 15.6. Electricity. Uncertainty exists regarding the availability of electricity to satisfy the demand i.e Cannon Rocks ± 24Mw, plus Port Alfred/ Nngqushwa Local Municipality ± 58Mw per day. 15.7. Question. Will there be any cost sharing between ESKOM and the municipality regarding additional electricity supply? NLAMBE EAST PROJECT DESIGN 16. Desalination Plant. The option to install a desalination plant at the Dabi Dam which will supply water to Ndlambe, is not only more expensive but also contrary to a basic principle namely the source or supply should be as close as possible to the user. If the Dabi Dam RO plant is built so far from Port Alfred, who will maintain and run it? To operate and control it from Port Alfred will be difficult and costs will be high. If the desalination plant is constructed at or near Port Alfred would it not be more cost effective to control and 4 operate? Why pump water away from Port Alfred to be treated and then back to the point of consumption? Also refer to Appendix A paragraph B.a and b (page 3). 17. Water Losses. The loss of water experienced in the Port Alfred and Bathurst water infrastructure is of great concern. Should this problem not be addressed first, it would result in an increased loss of potable water. 18. Water reticulation/storage: Kleinemonde. The following issues have not been addressed in the report. 18.1 Water reticulation - Appendix B paragraph 2.1, 4.3 and 4.4. 18.2 Water storage - Appendix B paragraph 2.2 and 4.6. 19. Sources. 19.1. It is uncertain if water from the Sarel Hayward dam will also be subjected to a desalination process. Also refer to Appendix A paragraph B.c.d (page 4 and 5). 19.2. Appendix B paragraph 3 (3.1 and 3.2) addresses augmentation options to the existing water supply to Kleinemonde. 19.2 Apart from the above sources it has been brought to our attention that in the Fish River Light house area, a high yielding borehole was drilled for the proposed Carpe Diem development. This development was not approved but the possible use of this borehole should be investigated.
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