Final Basic Assessment Report

www.dedea.gov.za FINAL BASIC ASSESSMENT REPORT

KEI MOUTH ECO ESTATE, EASTERN CAPE PROVINCE OF SOUTH AFRICA DEDEAT REF: EC/12/A/LN1/LN3/M/19-35

Prepared for:

Lutuli Ranches cc c/o Mr Robin Vivian Wood Farm 3, Maiden Head Queenstown, 5320

Prepared by:

CES EAST LONDON 6 Stewart Drive, Baysville East London, 5241 Tel: 087 830 9804

Also in Grahamstown, Port Elizabeth, Cape Town, Johannesburg and Maputo (Mozambique) www.cesnet.co.za

“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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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.

www.dedea.gov.za 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 – PLEASE NOTE THE SPECIALIST DECLARATION HAS BEEN INCLUDED WITHIN THE ECOLOGICAL IMPACT ASSESSMENT REPORT

1. ACTIVITY DESCRIPTION

Describe the activity, which is being applied for, in detail

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1. PROJECT DESCRIPTION

An Environmental Authorisation (EA) was granted for the proposed Mango Grove Eco Estate located in Kei Mouth in the Eastern Cape Province in 2011 (AR/12/544,545,546/1/10). The construction of the proposed development did not commence in time and therefore the EA has since lapsed. The applicant, Mr Robin Wood of Lutuli Ranches CC, would like to re-initiate the process and has requested that CES re- apply for an EA. However, as the previous EA has since lapsed and layout of the proposed development (now named Kei Mouth Eco Estate) has changed considerably, a new EA application is required.

The proposed development, Kei Mouth Eco Estate, entails the development of 50 high income residential erven, two lodge sites each (with a capacity of 100 beds) and a recreational facility. This is considerably fewer than the 100+ units approved in the previous EA issued.

1.1 Locality

The proposed development is located 7km from the coastal village of Kei Mouth in the Eastern Cape Province. The proposed development falls under the overall jurisdiction of the Amathole District Municipality and the Great Kei Local Municipality (see Figure 1.1 below).

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Figure 1.1: Locality map of the development 1.2 Concept and vision

The current vision for the Kei Mouth Eco Estate is based on the principle that limited and environmentally appropriate development can finance the conservation of the area and promote local job creation.

The intention is to develop a conservation and eco-tourism destination with the intention of attracting people who are committed conservationists. The profile of the investors and homeowners is such that they will be willing to commit to a conservancy which will be governed by a strict code of conduct.

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The concept for the development is a low-impact eco-estate. In keeping with this, the development footprint will be restricted to a minimum, while low impact construction and technology alternatives will be selected where possible.

1.3 Layout and design

The proposed Kei Mouth Eco Estate development (which will consist of Farms 73, 76, 79 Komga of the farm Rocky Ridge) relates to the establishment of a low density 50 high-income residential erven, two lodge sites each with a capacity of 100 beds and a recreational facility. Internal strip roadways will be constructed between all residential erven, lodges and the recreational facility. Two suitable dam sites have been identified which will be developed concurrently with the installation of the bulk water infrastructure.

The proposed development will have the following activities:

• The consolidation, subdivision and rezoning of the 3 farms totalling about 599.2 Ha; • The subdivision of portions of the consolidated area into approximately 68 erven (based on 1 unit per 10 Ha as recommended by the Great Kei Spatial Development Framework) and the rezoning of the 68 erven to Resort and Special Zone: Rural Residential; • Holiday housing (development footprint of 4.6 Ha); • Lodge and chalets (development footprint of 0.52 Ha); • Services and roads (development footprint of 2 Ha); and • Remaining area (approximately 577.1 Ha) to remain as agriculture but managed as a game farm.

The associated proposed activities include:

• The construction of distributed on-site sewage treatment units (development footprint of 0.09 Ha) and underground sewage reticulation; • The construction of a network of internal roads (development footprint of 1.7 Ha); and • The installation of underground water and electricity reticulation infrastructure.

Ultimately 3.7% of the consolidated area will be occupied by residential erven, lodges and chalets, and associated infrastructure (development footprint of less than 20 Ha), while 96.3% of the area will be set aside for conservation purposes.

The proposed development will take place in a phased manner, as indicated in Figure 1.2 below. All service infrastructure will be constructed within Phase 1 of the proposed development. Please refer to Appendix C for all A3 sized facility illustrations.

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Figure 1.2: Site Development Plan.

The proposed Kei Mouth Eco Estate will be designed in such a way as to blend in with the surrounding landscape. Figure 1.3 and Figures 1.4 below provide examples of the possible architectural style for the proposed development as well as the preliminary design concept for the housing units. Preliminary Engineering Services Reports are provided in Appendix H3.

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Figure 1.3: An artist impression of a possible architectural style for the proposed development

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Figure 1.4: Preliminary plan of proposed chalets

1.4 Infrastructure

Figure 1.5 below provides an overview of the proposed service infrastructure required for the development. A3 sized facility illustrations can be found in Appendix C.

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Figure 1.5: Proposed service infrastructure

Bulk water supply

The Human Settlement Planning and Design Engineering Guideline used to calculate the required water volumes recommended an Average Annual Daily Demand (AADD) of 80 kl and an instantaneous Peak Demand of 3.2 l/s is anticipated. The Annual Water Demand will be 29 200 kl and the required Design Flow to satisfy the Annual Demand will therefore be 0.93 l/s.

There are currently no existing bulk water supply pipelines either on or in the near vicinity of the site, and therefore the following water supply methods are proposed:

• Rainwater Harvesting: The annual average rainfall is 824 mm. Taking into consideration periods of drought, the average annual rainfall will be reduced by 50% to produce a more annual average through dryer periods. Minimum storage tank/s of 40 kl per dwelling and recreational facility are proposed to be provided. Minimum storage tanks of 60 kl per lodge are to be provided.

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Table 1-1.1 below provides the desktop potential yield from rainwater harvesting.

Table 1-1.1: Potential Desktop Rainwater Harvesting Unit No Assumed Rainfall (m) Efficiency Potential Roof Area Harvest (m²) (kl/annum) Dwelling 50 15,000 0,412 95% 5870 Lodges 2 3000 0.412 95% 1175 Recreational Facility 1 1500 0.412 95% 585

• Earth Dams: Two potential dam sites have been identified. The combined potential yield of these dams will be 55 000 kl taking into account losses due to evaporation. Water from the dams will be pumped to the reservoir for treatment and storage.

As per the Preliminary Potable Water Supply Technical Report (Appendix H3): “It is proposed that the two dams be positioned and constructed as off channel dams adjacent to the natural drainage water course, with raw water transferred to the off channel dams by means of a transfer pipe. The extraction volume from the natural drainage water course shall not exceed 10% of the average annual minimum rainfall for the catchment area. A small-bore pipeline shall connect the upper level dam to the lower level dam and this upper dam shall supplement the demand from the lower dam.”

• Reservoirs: Two separate reservoirs are proposed to be used for 1) potable water abstracted from the dam supply, and for 2) firefighting and irrigation to be supplied by the dams. The potable water reservoir will have a 2-day volume of 160 kl with a design flow of 0.93 l/s based on the Guidelines for Human Settlement Planning and Design. The fire fighting and irrigation reservoir will have a 2-hour volume of 110 kl with a design flow of 15 l/s.

• Water treatment: Water abstracted from the dams will need to be treated prior to domestic use. A treatment plant comprising of chemical dosing, clarification, sand filtration and chlorination shall be constructed at the lower level dam site and the treated potable water shall be pumped to a 160 kl potable water storage reservoir positioned at an elevation which allows for a gravity feed to the development.

Based on the calculated demand from the development of 29 200 kl per annum, the combined supply from rainwater harvesting and dam storage (55000 kl) shall be adequate to meet the needs for the development.

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Should boreholes ever be required for the development in the future, the required investigations and water use licensing will be required to be submitted to the relevant authority. Refer to Figure 1.6 below and Appendix C: Facility Illustrations for the proposed water reticulation layout and potable water treatment process. In addition, please refer to the Appendix H3: Preliminary Engineering Services Reports.

Figure 1.6: Proposed underground water reticulation network (yellow lines)

Bulk sewage:

The effluent generated by the proposed site is estimated at 2.74 l/s, or 82 kl/day (30 000 kl/annum). There is currently no nearby wastewater treatment works in the area. The preferred option is to treat the effluent generated by the development via a package plant (refer to Appendix C: Facility Illustrations for the proposed design of the package plant).

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The location of the package plant is above the 1:100-year floodline (as shown in Figure 1.9 below). The treated effluent will be stored in a conservancy tank and used for irrigational purposes (gardens). The option of using the treated effluent to supplement grey water can be investigated further in the future, if needed. No treated effluent will be discharged directly into any tributary of the Great Kei River.

The package plant will include a lined conservancy tank to act as an emergency storage in the case of a temporary shutdown and/or overflow, with a 48 hour of average dry weather daily inflow capacity. Emergency power (stand by diesel generator) shall be provided to prevent overflows from occurring during any power outage.

Soil percolation tests were undertaken by means of digging three one metre deep test pits at locations where housing clusters were envisioned. Based on the guidelines offered by the Department of Water Affairs, acceptable percolation rates for the implementation a septic tank system are between 100 and 300mm/hr. The percolation test results indicated rates of between 50 and 60mm/hr which would indicate the avoidance of a septic tank system.

Refer to Figure 1.9 below and Appendix C: Facility Illustrations for the proposed sewer reticulation layout and package plant design.

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Package plant

Figure 1.9: Proposed underground sewage reticulation network (purple lines)

Solid Waste

The total waste to be generated by the proposed Kei Mouth Eco Estate is estimated at 78.4m3 per month.

The waste for the proposed development will be transported by individual households to a proposed refuse area (local transfer station) located near the access control (gatehouse) to the development as illustrated on the Site Development Plan. The service provider, being either the municipality or private contractor, will be responsible for transporting waste from the development to the Kei Mouth transfer station or to the nearest licensed landfill disposal site.

www.dedea.gov.za to temporarily store waste for a maximum period of 14 days (2 weeks) to allow for possible disruptions in the regular service. The development will be expected to comply with the requirements of the ADM and the GKLM, as well as the NEMWA norms and standards for storage of waste.

Road access

Access to the development is via the surfaced MR00697 roadway to Kei Mouth, and a suitable intersection to the development has already been constructed and provided with appropriate de-acceleration and acceleration lanes. It is not envisioned that this intersection will need any further upgrading as the traffic volume due to the development will not be dramatically altered.

The access road from the R349 to the boundary of the development will need upgrading (refer to Figure 1.10 below and Appendix C). Application to the Provincial Road authority will need to be made and the roadway will be designed and constructed to the applicable road standard for the class of access road required.

Internal roadways within the development will be reinforced concrete strip roads (Figure 1.11). The roads will generally follow the existing ground contours and will therefore offer a minimal footprint as no major road earthwork operations are envisaged.

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Figure 1.10: Proposed access road from the R349 (yellow line).

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Figure 1.11: Proposed internal road structure

Electrical

The village of Kei Mouth is supplied by an existing 22kVa Eskom power line. The route of this power line follows the MR00697 access road to Kei Mouth. Eskom have provided a connection together with a transformer from this power line to farm 77 of the Farm Rocky Ridge. All internal reticulation will be via underground cabling. Refer to Figures 1.12 and 1.13 for the proposed layout of the internal electrical reticulation (white lines).

Extensive use will also be made of various renewable energy resources such as photovoltaics (PV) and solar water heating systems.

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Figure 1.12: Proposed internal electrical reticulation (underground cabling)

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Figure 1.13: Proposed internal electrical reticulation

Telecommunication

An application for Telkom supply will be lodged with Telkom by the developer. The Telkom supply route will be along the existing access roadway to the development and thereafter reticulated to the dwellings, lodges and recreational facility.

Stormwater

A Stormwater Management Plan will be required to be developed by a qualified engineer for the development prior to construction.

Where roadways intersect water courses, suitable stormwater culverts will be laid to allow for the flow of stormwater beneath the roadways. Suitable cross berms will be constructed at intervals along steep roadways to channel stormwater away and onto the natural terrain thus preventing any erosion from occurring. If needs be, suitable energy dissipaters will be installed to both spread and minimise flow velocities.

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Any streams that need to be crossed will be done using precast concrete culverts designed to accommodate the 1 in 50-year flood event. All applicable water use licensing applications (currently in progress) must be submitted to the Department of Water and Sanitation (DWS).

Land-use zoning

The study area is currently managed as a private game and nature reserve (Great Kei Private Nature Reserve – not formally protected) and is undeveloped. It is currently zoned as Agriculture. Appendix C: Facility Illustration provides a detailed description of the site development plan, detailing the rezoning requirements and restrictions of the proposed development. The zoning of the study area will largely remain as Agriculture (managed as a game farm), with the addition of Resort Zone 2 (Holiday housing and Resort Hotel/Lodge) and Special Zone (roadways and service infrastructure).

The site development plan was submitted to the GKLM for rezoning approval. Please refer to Appendix H4 for the rezoning approval received.

2. BIOPHYSICAL ENVIRONMENT

2.1 Climate

The proposed Kei Mouth Eco Estate is located 7km by road from Kei Mouth within the Eastern Cape Province.

Kei Mouth normally receives about 699 mm of rain per year, with most rainfall occurring during summer. The chart in Figure 2.1 shows the average rainfall values for Kei Mouth per month. It receives the lowest rainfall (13 mm) in June and the highest (92 mm) in November. The average midday temperatures for Butterworth range from 20.4°C in July to 25.4°C in February. The region is the coldest during July when the temperature drops to 9.5°C on average during the night.

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Average rainfall (mm) Average midday temperature (°C) Average night-time temperature (°C)

092 026 018

13 20 10

J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D

Figure 2.1. Average rainfall and temperatures for the study area over a 12-month period.

2.2 Topography, Geology and Soils

The topography of the area is characterised by an undulating relief with a number of steeply incised valleys, generally running in a south-easterly direction cutting the area at regular intervals. There are, therefore, limited tracts of flat land for settlement or agriculture which makes the costs of service provision high.

The elevation of the study area ranges from 6 to about 237 metres above sea level (Figure 2.2a north- south and Figure 2.2b east-west). The topography of the proposed development area is varied with large flat plateaus that slope gently to the south east. These flatter slopes give way to gently undulating ones around the drainage lines, and steep to very steep slopes in the iCwili River gorge and the Great Kei River gorge.

Figure 2.2a: Elevation of the study area shown in a north to south direction

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Figure 2.2b: Elevation of the study area shown in an east to west direction

The geology of the area is made up of mudstones and sandstones of the Karoo sequence (Figure 2.3). In many cases, these have been intruded by dolerite dykes and sheets. One such dyke runs across the property in a south-east to north east direction and is perpendicular to the iCwili River. Dolerite dykes are well known borehole sites (for underground water). With the dyke cutting off the stream it should have excellent recharge potential. The soils are generally moderate to deep clay loams along the coast with undulating relief and moderate to deep sandy loams of undulating relief further inland with steep relief in the vicinity of the Great Kei River. The erodibility index of the soils in the region is recorded as being medium to high.

The Beaufort Group is the geologically dominant group in the district and forms part of the Karoo Supergroup (Figure 2.3). The Beaufort Group is divided into two subgroups, namely the Tarkastad and the Adelaide, which, in turn, can be themselves divided into formations. The Katberg and Balfour formation, make up the geology of this development. The Katberg formation is sandstone rich and is 500 to 1000 mm thick. The sandstone is well lithified and varies in composition from a fine grained, argillaceous variety to a medium coarse grained, arenaceous type. The sandstone is horizontally laminated, cross bedded or massive, and, on average, comprises 90% of the total thickness. The geology is responsible for the soil types and together they influence the runoff coefficient for the dams.

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Figure 2.3: Geology of the study area

2.3 Vegetation and floristics

According to the South Africa Vegetation Map (SA VEGMAP) (SANBI, 2018), the study area falls within Bhisho Thornveld, Transkei Coastal Belt and Hamburg Dune Thicket (Figure 2.4).

Bhisho Thornveld: The vegetation of the Bhisho Thornveld is distributed from Mthatha in a band parallel to, but inland of the coast, to the north of East London. Bhisho Thornveld also occurs on dissected hills and low mountains around Grahamstown and in a few fragments in valleys northeast of the Amathole Mountains. This vegetation consists of open savanna characterised by small trees of Acacia natalitia with a short to medium, dense, sour grassy understorey, usually dominated by Themeda triandra when in good condition.

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In terms of its ecosystem threat status, the National Biodiversity Assessment (NBA, 2018) classifies the Transkei Coastal Belt vegetation as Least Concern. The conservation target for this vegetation type is 25%.

Transkei Coastal Belt: The vegetation of the Transkei Coastal Belt can be found within the Eastern Cape Province as a narrow strip along the Wild Coast of Transkei and the Indian Ocean seaboards between Port St Johns and the Great Kei River. Altitude ranges from 20 - 450 m. It is highly dissected, hilly coastal country with alternating steep slopes of low-reach river valleys and coastal ridges. A mosaic of grassland vegetation on the higher lying areas and characteristically on hill tops and upper hill slopes, with alternating bush clumps and small forests. It is characterised by small trees of Acacia natalitia, Cestrum laevigatum, and Aloe Ferox.

In terms of its ecosystem threat status, the NBA (2018) classifies the Transkei Coastal Belt vegetation as Least Concern. According to the SA VEGMAP (2018), only 1 % of this vegetation type is protected with about 20 % having been already transformed mainly by cultivation.

Hamburg Dune Thicket This vegetation type occurs in the Eastern Cape Province along coastal stretches from the Fish River Mouth to just east of Kei Mouth. It occurs on flat to moderately undulating coastal dunes.

The vegetation is made up of low to medium-sized (1 - 4 m), dense thicket dominated by woody shrubs and stunted trees, with lianas and vines abundant, and the understorey poorly developed. These thickets are best developed in dune slacks, whereas on more open inland slopes they occur as small bush clumps in a matrix of low coastal grassland (Panicum deustum, Stenotaphrum secundatum). Where these grasslands occur on deep sandy soils (around Kiwane), several fynbos elements (Agathosma, Aspalathus, Metalasia, Struthiola) are present in the matrix, while savanna elements (Phoenix reclinata) are more common where the grasslands occur on richer soils (around Hamburg).

In terms of its ecosystem threat status, the NBA (2018) classifies the Hamburg Dune Thicket as Least Concern. This vegetation is poorly protected with 31.44 % currently transformed mainly due to alien invasion by Psidium guava and some degree of erosion.

Site visit findings: The site visit confirmed that the eastern portion of the study area is notably impacted by alien invasive vegetation, largely comprising of Acacia sp. such as Acacia mernsii (Black wattle), and Lantana camara and Melia azedarach (Syringa sp.).

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The steeper slopes alongside the Great Kei River and inland tributaries are characterised by intact thicket more typical of the Transkei Coastal Belt. Open areas situated on the hilltops and flatter areas are characterised by bush clumps interspersed by grasslands, which is typical of the Bisho Thornveld (eastern portion of the study area) and Transkei Coastal Belt (western portion of the study area).

Protected tree species, Sideroxylon inerme (milkwood), were noted with various bush clumps on site. There will be no development in the dense thicket dominated valleys or close to water courses, except for the installation of underground pipelines. Majority of the development footprint (roughly 80 %) will be located within open grassland areas on the tops of ridges, with minimal clearing of thicket vegetation required. Should any protected tree or plant species be required to be removed, the relevant permits will need to be obtained prior to clearance.

Refer to Appendix D: Ecological Impact Assessment Report for the specialist findings.

Figure 2.4. Vegetation of the study area.

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2.4 Rivers and wetlands

The area is incised by various water courses draining northwards into the Great Kei River and southwards towards the coast. Apart from the Great Kei River, the dominant water course is the iCwili River which originates within the area of the proposed development and drains towards Kei Mouth.

Several NFEPA wetlands (both natural and artificial) are located within the surrounding areas, however, none are located within the proposed development area (refer to Figure 2.5 below). The following NFEPA Rivers are found within the proposed development footprint: • iCwili River – Class D: Largely Modified (PES, 1999); and • Great Kei River – Class C: Moderately Modified (PES, 1999).

According to the National Biodiversity Assessment (2018), the iCwili River is listed as having a LEAST THREATENED Ecosystem Threat Level. The Great Kei River is listed as having an ENDANGERED Ecosystem Threat Level.

The proposed upgrade of the MN10129 access road to the proposed development will cross the iCwili river, and the proposed water and sewage reticulation will cross several tributaries of the Great Kei River, and will therefore require a water use license application to be submitted to DWS (see Figure 2.5 below). The proposed location of the sewage package plant will be located outside of the 1:100-year floodline, as shown in Figure 1.9 above, and will also be subject to a water use license application.

The proposed dam sites will be positioned and constructed as off channel dams adjacent to the natural drainage water course. The extraction volume from the natural drainage water course shall not exceed 10% of the average annual minimum rainfall for the catchment area.

As recommended by the Ecological Specialist (refer to Appendix D), 100m from the 1:100-year floodline of the Great Kei River must be considered a no-go area, and 50 m buffers must be applied to the iCwili River and smaller tributaries within the study area. The buffer areas are considered sensitive areas as they are important drainage areas, comprise of steep slopes susceptible to erosion and are likely to contain vegetation Species of Conservation Concern (SCC). No development (other than authorised service infrastructure and the proposed dams) should occur within these buffer areas.

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Figure 2.5. Rivers and wetlands associated within the study area.

2.5 Land Use

The study area was zoned as Agriculture, and recently rezoned to Agriculture, Resort and Special Zone: Rural Residential. The study site is currently undeveloped. The study area is comprised of the following:

• Previously cultivated/grazing land; • Degraded thicket and bushland; and • Intact thicket and bushland.

No state forests or forest plantations are located within the study area.

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Figure 2.6: Land use map of the study area

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2.6 Spatial Planning and Conservation

NEMBA Threatened Ecosystems

A national list of threatened ecosystems in need of protection was published through the National Environmental Management: Biodiversity Act (No. 10 of 2004) (NEMBA) (GN. 1002 of 2011). The proposed development does not fall within a NEMBA threatened ecosystem.

Eastern Cape Biodiversity Conservation Plan (ECBCP)

The Eastern Cape Biodiversity Conservation Plan (ECBCP, 2007, and currently under revision) attempts to map priority areas for conservation in the province, as well as assign land use categories depending on current conditions of unit areas and conservation targets that need to be achieved. The main outputs of the ECBCP are “critical biodiversity areas” or CBAs, which are allocated the following management categories:

• CBA 1 = Biodiversity Land Management Class (BLMC1) requires the area to be maintained in a natural state; and • CBA 2 = BLMC2 requires the area to be maintained in a near-natural state

These management categories are further sub-categorised as follows:

• CBA R1 =Statutory protected conservation areas such as South African National Parks and Eastern Cape Provincial Nature Reserves; • CBA R2 = Non-statutory protected areas such as municipal, private or voluntary conservation areas; • CBA T1 = Critically endangered ecosystems and irreplaceable sites; • CBA T2 = Near irreplaceable sites and endangered ecosystems; • CBA A1 = Irreplaceable river sub-catchments and critical wetlands; and • CBA A2 = Supporting river sub-catchments (A2a) and migratory river catchments (A2b).

The proposed development falls within a CBA 1 Aquatic area (A1 and A2b categories), and a CBA 1 Terrestrial area (T1 and Reserve 2 categories) with the majority of the proposed development being located within a CBA Reserve 2, namely the Great Kei Private Nature and Game Reserve, which is classified as non-statutory protected areas (see Figure 2.9 below).

According to the BLMCs, majority of the study area should be maintained in a natural state. Of the 599.2 Ha of proposed application area, 577.1 Ha will remain as agricultural land and managed as a game farm,

www.dedea.gov.za leaving 22.1 Ha remaining for the proposed development. The actual development footprint will, however, be less than 20 Ha as shown in Figures 1.1 and 1.2 above.

As concluded in the Ecological Impact Assessment Report (Appendix D), “majority of the development footprint, except for authorised routes of the internal roads and service pipelines, will target open grassland areas on the tops of ridges, with minimal clearing of intact thicket vegetation required. It was recommended that the proposed development be located at least 100 m from the 1:100-year floodline of the Great Kei River, to maintain important ecological corridors and network areas, as identified by STEP.

Although the applicable land-use management objective of the area requires that the land be maintained in a natural state, within minimal loss to biodiversity, the proposed development is in line with the STEP and GKLM SDF ‘Limited Development Areas’ land-use guidelines. The site visit confirmed the study area was previously used for cultivation and livestock grazing, with evidence of disturbance and alien invasive vegetation infestation (decreasing in severity from east to west towards the Great Kei River).

Provided that the proposed development avoids ‘no-go’ areas, such as riverine thicket within the 1:100- year floodline of the Great Kei River and smaller tributaries, and implements strict management plans (incorporated into the home owners agreements) in accordance with the biodiversity management guidelines, the proposed development has the potential to conserve a large portion of land (577 Ha of the 599.2 Ha application area to remain undeveloped and natural), which may face the risk of future degradation due to ongoing farming and poor land-use management practices.”

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Figure 2.8. Critical Biodiversity Area assessment of the study area, as per the ECBCP.

Protected Areas and National Protected Areas Expansion Strategy

As discussed above, the proposed Kei Mouth Eco Estate is located within a non-statutory protected area (Great Kei River Private Nature Reserve – owned by the applicant) (see Figure 2.9 below). In addition, the proposed project area is located within 5 km of the East London Coast Nature Reserve, Kei Mouth State Reserve, and the Nyara River Mouth to Great Kei River Mouth Marine Protected Area (MPA).

Target areas (focus areas) for expansion of the Protected Area network in South Africa were identified through a systematic biodiversity planning process undertaken as part of the development of the National Protected Areas Expansion Strategy (NPAES), as well as the Provincial Protected Area Expansion Strategy (2012). The proposed development falls within the Bisho Kei Focus Area.

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Figure 2.9. Protected Areas within the study area

Great Kei Local Municipality Spatial Development Framework (SDF)

The Great Kei Local Municipality (GKLM) SDF, which incorporates environmental guidelines from the GKLM Strategic Environment Framework (SEA), provides guidelines for spatial planning within the GKLM. Refer to Appendix H1 for additional information regarding applicable spatial planning guidelines within the GKLM. Table 2.1 below summarises these environmental guidelines.

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Table 2.1 Summary of GKLM Environmental Guidelines for spatial planning NO-GO Areas GO-BUT Areas Inside Urban Edges Limited Development Areas No Development Areas Away from Urban Edge Adjacent to Urban Edge or within Transitional Area Areas of high Urban Settlement: Limited by: Limited by: environmental sensitivity • Residential • EIA process; • EIA process; and conservation value: • Public-Funded Housing • Low density; • Low density; • Primary dune systems • Resort Development • Density/footprint/impact • Density/footprint/impact • Indigenous forests • Business and Trade restrictions; restrictions; • Proclaimed nature • Other • Not in areas of environmental • Not in areas of reserves; sensitivity; environmental sensitivity; • STEP Protected, Develop from Inside- • Unique & Sustainable • Unique & Sustainable Process and Outward (Phasing) Developments; Developments; Critically Endangered • Must show tangible economic • Must show tangible areas; BUT, no for: benefits to broader economic benefits to • Rivers, estuaries and • Environmentally community; broader community; undisturbed riparian sensitive areas within • Clustering of built form; • Clustering of built form; zones of rivers; the urban edge Limited • Aesthetic controls; • Aesthetic controls; • Diverse coastal development in Coastal • Mitigate impacts; • Mitigate impacts; grasslands and coastal Buffer Zone • Show net gains for the • Show net gains for the thicket vegetation • Lack of services environment; environment; types; and • Appropriateness of • Appropriateness of • Dynamic coastal areas development in Coastal development in Coastal including primary and Buffer Zone; and Buffer Zone; and mobile dunes and • Provision of services • Provision of services areas within 50m of the high water mark, including coastal cliffs. Zoning: Open Space Zoning: Various Zoning: Mixed – Agriculture Zoning: Mixed – Agriculture Zone III (nature reserve) Zone I/Resort Zone I or Zone I/Resort Zone I or or Special Zone: II/Residential/Open II/Residential/Open Conservation Space/Special Zone Space/Special Zone

Based on the environmental guidelines above, the following NO-GO areas will apply to the proposed Kei Mouth Eco Estate:

• STEP Critically Endangered areas (refer to Figure 2.5a); and • Rivers, estuaries and undisturbed riparian zones of rivers.

As illustrated in Figure 1.2 above, the current and planned zoning of the proposed development will largely remain as Agriculture (managed as a game farm), with the addition of Resort Zone 2 (Holiday housing and

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Resort Hotel/Lodge) and Special Zone (roadways and service infrastructure). This zoning within Limited Development Areas will have specific environmental guidelines that will need to be considered, as detailed in Table 2.1 above.

3. Socio-economic profile

The proposed development is located 7km from Kei Mouth within Ward 6 of the Great Kei Local Municipality (GKLM), in ADM, Eastern Cape Province of South Africa.

3.1 Population and Education

The GKLM has a total population of 31 692 people, of which 66.4% of the population are between the age of 15 and 64. The population is dominated by females of approximately 53%, while males compose only about 47 % of the population. About 62.0% of the populations fall between 15-64 years, whilst 9.3 % are in the pension group (over 65 years) and only 28.7 % is less than 15 years. This indicates that there is a high dependency ratio of about 61.3 %.

Of those aged 20 years and older, 19.2% have no schooling, 93.7% have completed primary schooling, 15.0% have completed matric and 2.5% have some form of higher education (GKLM IDP, 2016/2017).

3.2 Income, Poverty Levels and Employment

The GKLM is characterised by a small population, low population density, concentration of employment in agriculture, disinvestment in rural areas, the dominance of one urban centre in the region and the resultant disparity between rural and urban areas (GKLM IDP, 2016/2017). In 2007, the GKLM had a high prevalence of poverty with 54% of households living below the poverty line.

Over 39% of the population are formally employed. The unemployment rate of 17% is similar to that of the ADM. Total employment within the GKLM is dominated by the agricultural sector (35.6%). The percentage of the population not economically active is 53%, which is lower than the provincial average.

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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.

ANALYSIS OF ALTERNATIVES: FUNDAMENTAL, INCREMENTAL AND NO-GO ALTERNATIVES

Fundamental alternatives

Fundamental alternatives are developments that are totally different to the project that is currently proposed and usually includes the following:

• Alternative property or location where the activity is to be undertaken (i.e. site alternatives); • Alternative type of activity to be undertaken (i.e. land-use alternatives);

Incremental alternatives

Incremental alternatives relate to modifications or variations to the design or technology of a project that provide different options to reduce or minimize environmental impacts. There are several incremental alternatives that can be considered, including: • The design or layout of the activity;

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• The technology to be used in the activity, and; • The operational aspects of the activity.

No-go alternative

It is mandatory to consider the “no-go” option in the EIA process. The “no-go” alternative refers to the current status quo and the risks and impacts associated with it. Some existing activities may carry risks and may be undesirable.

COMPARATIVE ASSESSMENT OF ALTERNATIVES

Table 2.1 below provides a comparative assessment of identified alternatives for the proposed Kei Mouth Eco Estate including advantages and disadvantages. An overall assessment is made concerning whether the identified alternatives are reasonable and feasible for further impact assessment.

CONCLUSION

Activity alternatives – the current preferred activity is deemed to be the only feasible activity alternative as this activity has the potential to increase tourism and job opportunities in the area. In addition, the proposed Kei Mouth Eco Estate (previously named Mango Grove Eco Estate and Conservancy) received an environmental authorization in 2011 (AR/12/544,545,546/1/10), which suggests that the proposed activity is likely to be suitable for area in question.

Location alternatives – the current preferred location is ideal for the type of development and is the only location available to the applicant. This is the only location alternative that will be assessed in the EIA.

Incremental alternatives – the following design/technological design alternative will be assessed during the EIA process:

• Sewage technology alternative – As there is no waste water treatment works in the vicinity of the proposed development, a commercially supplied packaged plant system, is the preferred sewage treatment alternative for the proposed development. Due to poor percolation results in the area, the installation of a septic tank system is not recommended.

It was determined that the current preferred alternatives together with the No-Go option are the only reasonable and feasible options for further assessment in the EIA, based on the assessment in Table 2.1 below.

Table 2.1: Assessment of alternatives

Alternative level Alternatives Advantages Disadvantages Reasonable Further Comment and feasible assessment www.dedea.gov.za Fundamental Alternative 1- • Potential increase in • Potential YES YES The proposed alternative– Type of Proposed Kei Mouth tourism, job creation and environmental development has the Activity Eco Estate (preferred socio – economic impacts potential to increase tourism, job opportunities alternative) development in the area. associated with • Majority of the property construction and general socio- will remain in a natural activities. economic development in state and managed as a • Of the 599.2 Ha the area. This is the only game farm which is in property, less than alternative that will be line with the ECBCP 20 Ha of natural assessed in the impact guidelines. habitat will be assessment. transformed. Alternative 2 – none N/A N/A N/A N/A identified. Refer to no- go.

Fundamental Alternative Location • The applicant is the land • Close proximity to YES YES The proposed property is alternative - Property 1 - Current proposed owner, and therefore the the Great Kei river, ideal for the type of or location site (preferred proposed site is the only with potential development envisaged due to its scenic location alternative) land available to the construction applicant. related impacts. and proximity to the Great • Ideal scenic location for Kei river and the coast. tourism opportunities. The property previously received an

www.dedea.gov.za environmental authorisation for the proposed development, which has since lapsed.

Alternative Location N/A N/A N/A N/A Alternative locations for 2 - None identified the project will not be assessed as the applicant is the land owner, and therefore the proposed site is the only land available to the applicant for the proposed development.

Incremental alternative Alternative • Low maintenance costs. • Risk of bad odour NO NO Poor percolation rates in - Technology Sewerage • Simple and easy to on site. the development area do alternative Technology 1 – operate • Possibility of soil not recommend for septic septic tank system contamination and tanks systems to be used. overflowing is not maintained well. • Susceptible to clogging by fats/oils, etc. thrown down drains. • Poor percolation rates in the area would result in the

www.dedea.gov.za inadequate sewage treatment. Alternative • Lower odour risk • More complex and YES YES A package plant system is Sewerage • Lower risk of pollution. higher the preferred sewage Technology 2 – • Produces purified re- maintenance treatment alternative for commercially usable water which costs. the proposed • Risk of pollution to supplied packaged complies with development. responsible disposal surrounding plant system. requirements and environment if not satisfies limits for maintained. discharge to the environment.

No-go option Existing activities on • No construction related • No stimulation to YES YES Assessed in the impact site include: risks to the surrounding the tourism and job assessment process. This refers to the environment market in the area. current status quo and Land will remain as a the risks and impacts private game /nature associated with it. reserve. Some existing activities may carry risks.

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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.

Latitude (S): Longitude (E): Alternative: Alternative S11 (preferred or only site 32° 39.251’S 28° 20.413’ E alternative) Alternative S2 (if any) o ‘ o ‘ Alternative S3 (if any) o ‘ o ‘ In the case of linear activities: Alternative: Latitude (S): Longitude (E): Alternative S1 (preferred or only route alternative) • Starting point of the activity • Middle point of the activity • End point of the activity Alternative S2 (if any) • Starting point of the activity o ‘ o ‘ • Middle point of the activity o ‘ o ‘ • End point of the activity o ‘ o ‘ Alternative S3 (if any) • Starting point of the activity o ‘ o ‘ • Middle point of the activity o ‘ o ‘ • End point of the activity o ‘ o ‘

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.

1 “Alternative S..” refer to site alternatives.

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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: Alternative A12 (preferred activity alternative) 198 000 m2 Alternative A2 (if any) m2 Alternative A3 (if any) m2 or, for linear activities: Alternative: Length of the activity: Alternative A1 (preferred activity alternative) m Alternative A2 (if any) m Alternative A3 (if any) m

Indicate the size of the alternative sites or servitudes (within which the above footprints will occur): Alternative: Size of the site/servitude: Alternative A1 (preferred activity alternative) m2 Alternative A2 (if any) m2 Alternative A3 (if any) m2

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 2 km of new road to be constructed

2 “Alternative A..” refer to activity, process, technology or other alternatives.

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Describe the type of access road planned:

Access to the development is via the surfaced MR00697 roadway to Kei Mouth, and a suitable intersection to the development has already been constructed and provided with appropriate de- acceleration and acceleration lanes. It is not envisioned that this intersection will need any further upgrading as the traffic volume due to the development will not be dramatically altered.

A new access road from the R349 to the boundary of the development (2 km of new road) will need to be constructed (refer to Figure 1.10 above and Appendix C). Application to the Provincial Road authority will need to be made and the roadway will be designed and constructed to the applicable road standard for the class of access road required.

The existing internal roadways within the development will be upgraded and reinforced as concrete strip roads (Figure 1.11). The roads will generally follow the existing ground contours and will therefore offer a minimal footprint as no major road earthwork operations are envisaged.

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

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;

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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 DWS); ▪ 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.

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.

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.

9. ACTIVITY MOTIVATION

9(a) Socio-economic value of the activity

What is the expected capital value of the activity on completion? Not determined yet

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What is the expected yearly income that will be generated by or as a result of the Not determined yet activity?

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 50 phase of the activity?

What is the expected value of the employment opportunities during the Not determined yet development phase?

What percentage of this will accrue to previously disadvantaged individuals? Not determined yet

How many permanent new employment opportunities will be created during the Not determined yet operational phase of the activity?

What is the expected current value of the employment opportunities during the first Not determined yet 10 years?

What percentage of this will accrue to previously disadvantaged individuals? Not determined yet

9(b) Need and desirability of the activity

Motivate and explain the need and desirability of the activity (including demand for the activity):

It is proposed that there is a need and desirability for the proposed activity in that:

• The development represents a market mechanism for allocating private land to uses supporting environmentally responsible stewardship and conservation; • Is a sustainable form of land development; • Sets in place development patterns that entrenches a low density form of land development while maximising the area of land set aside for conservation; • Meets a tangible need in the market place for such a development; and

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• Will provide employment opportunities for local residents during the construction and operational phase of the activity.

Environmental Gains

In the context of the above the SEA associated with the GKLM SDF notes the following in terms of environmental offsets:

• All developments in Limited Development Areas (LDAs) located outside the Urban Edge should be assessed in terms of the net environmental gains that the development can potentially contribute, including where developments can contribute to the management of conservation-worthy and coastal areas. The principle that appropriate environmentally sensitive development can finance conservation in certain instances should be considered when assessing development proposals. Low density and aesthetically appropriate residential development that primarily promotes conservation and also eco-tourism and community projects should be encouraged.

Economic Growth and Job Creation:

• The GKLM IDP recognises that economic growth is a prerequisite to development. • Tourism and Infrastructure developments are identified as important elements of Local Economic Development.

Offsetting Coastal Sprawl:

• The Eastern Cape coastal zone has recently experienced unprecedented development, which contributes towards coastal sprawl. The 2003 ADM LED report indicates that the demand for coastal housing developments continues to exert significant pressure on coastal areas for land and development. Coastal residential “resorts” range from caravan and cottage type clusters to high income residential units. • The development of residential, resort and tourism facilities on the proposed Kei Mouth Eco Estate represents an important movement of development inland from the coast as opposed to development along the coast. • The viability of the development is contingent on the financial attractiveness to potential investors. • A balance therefore needs to be established between the financial aspects of the initiative (investor expectations, extent of development, conservancy costs, etc.) and meeting the core environmental and conservation objectives of the initiative.

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Indicate any benefits that the activity will have for society in general: The proposed development will create employment opportunities (over 50 permanent skilled and semi-skilled jobs), increase tourism in the area and provide lodging facilities for the public.

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

The proposed development will create employment opportunities for the local community and boost tourism in the area.

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: Constitution Act (No. 108 of 1996) Constitution Assembly 1996 Department of National Environmental Management Act (No. 107 of 1998 Environmental Affairs (DEA) 1998) and DEDEAT National Environmental Management: Protected Areas Department of Act (No. 57 of 2003) Environmental Affairs (DEA) 2003 and DEDEAT National Environmental Management: Waste Act (No. 59 Department of of 2008) Environmental Affairs (DEA) 2008 and DEDEAT Department of Water and National Water Act (No. 36 of 1998) 1998 Sanitation (DWS) National Environmental Management: Biodiversity Act DEA & DEDEAT 2004 (No. 10 of 2004) National Heritage Resource Act (No. 25 of 1999) SAHRA 1999 Department of Agriculture National Forests Act (No. 84 of 1998) 1998 Forestry and Fisheries Occupational Health and Safety Act (No. 85 of 1993) Department of Labour 1993 Great Kei Local Municipality: SEA and SDF Great Kei Local Municipality 2004 Amathole District Amathole District Municipality IDP 2018 Municipality

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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? 100m3

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

Solid waste will be removed and disposed of at a licensed landfill site.

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

The construction solid waste will be disposed of at a registered landfill site within the GKLM.

Will the activity produce solid waste during its operational phase? YES NO

If yes, what estimated quantity will be produced per month? 100m3

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

The waste for the proposed development will be transported by individual households to a proposed refuse area (local transfer station) located near the access control (gatehouse) to the development as illustrated on the Site Development Plan (Figure 1.2 above). The service provider, being either the municipality or private contractor, will be responsible for transporting waste from the development transfer stations to the nearest landfill disposal site.

The internal collection service, including the nature of the service and its frequency, could be customised in accordance with the home owner’s association requirements. The frequency of the service should be at least once a week. However, the local transfer station must have sufficient capacity to temporarily store waste for a maximum period of 14 days (2 weeks) to allow for possible disruptions in the regular service. The development will be expected to comply with the requirement of the ADM and the GKLM, and the NEMWA norms and standards for storage of waste. Residents of the proposed development will be expected to comply with local authority requirements. Disposal onsite will not be permitted.

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

N/A

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? N/A

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

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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.

The effluent generated by the proposed site is estimated at 2.74 l/s, or 82kl/day (82 m3 per day or 2500m3 per month) which is less than the GNR. 325 Listing Notice 2 threshold of 15 000m3 or more per day, and less than the GNR. 327 Listing Notice 1 threshold of 2000m3 to 15 000m3 per day. In addition, the proposed package plant and treatment of sewage effluent will not trigger the thresholds contained in Government Notice (GN) 921 of NEMWA: “List of Waste Management Activities that have, or are likely to have, a detrimental effect on the environment”, therefore, not requiring a Waste License.

For this development, a sewage package plant will be constructed on site. The treated effluent will be stored in a conservancy tank and used for irrigational purposes (gardens) (effluent quality standards to meet those of Department of Water and Sanitation (DWS) and subject to a water use license application process). No treated effluent will be discharged directly into any tributary of the Great Kei River. Refer to Appendix C: Facility Illustrations for the proposed design of the package plant, and Appendix H3: Preliminary Engineering Services Reports.

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

If yes, provide the particulars of the facility:

Facility name: n/a

Contact person:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

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

The effluent generated by the proposed site is estimated at 2.74 l/s, or 82 kl/day. There is currently no nearby wastewater treatment works in the area, therefore, the sewage will be treated via a package plant on site.

The treated effluent will be stored in a conservancy tank and used for irrigational purposes (gardens). The option of using the treated effluent to supplement grey water can be investigated further in the future, if needed.

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:

N/A

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.

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

General construction noise during the construction phase.

During operational, noise levels will be in line with a low-density development. Other than increased traffic flow to the property, noise levels will be minimal and should not have a large impact on the surrounding environment.

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: 2500 m3

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. REFER TO APPENDIX E1 FOR PROOF OF WULA APPLICATION PROCESS INITIATED.

13. ENERGY EFFICIENCY

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

The proposed development plans to make use of various renewable energy resources such as photovoltaics (PV) and solar water heating systems, where possible.

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

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Use of alternative renewable energy sources such as solar power and heating systems may be considered in the design and layout. If renewable energy technology is not considered in this design, provision will be made for future installation.

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 C and indicate the area, which is covered by each copy No. on the Site Plan.

Section C Copy No. (e.g. n/a 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.

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

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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

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)

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Unstable rocky slopes or steep YES NO YES NO YES NO slopes with loose soil

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%)

Any other unstable soil or YES NO YES NO YES NO geological feature

An area sensitive to erosion YES NO YES NO YES NO

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).

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

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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 other Sport field Cultivated land Paved surface Bare soil 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. REFER TO APPENDIX D: ECOLOGICAL IMPACT ASSESSMENT REPORT

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 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

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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): Benmore Lodge located 500m to the south of the southern property boundary line, and umThombe Kei River Lodge (closed) to the north of the proposed Kei Mouth Eco Estate development area.

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

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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 No site? If YES, N/A – none identified within the development footprint during the site visit explain:

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.

Briefly explain n/a the findings of the specialist: YES NO Will any building or structure older than 60 years be affected in any way? 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.

www.dedea.gov.za 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; (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; (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; (c) placing an advertisement in— (i) one local newspaper; 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;

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(ii) disability; or (iii) any other disadvantage.

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; (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,

www.dedea.gov.za 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.

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 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.

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List of authorities informed: The following authorities have been informed:

• Department of Water and Sanitation (DWS), • Department of Agriculture, Forestry and Fisheries (DAFF) • Department of Economic Development Environmental Affairs and Tourism (DEDEAT), • South African Heritage Resources Agency (SAHRA) • Eastern Cape Provincial Heritage Resources Agency (ECPHRA), • Department of Rural Development and Land Reform (DRDLR), • Eastern Cape Department of Roads and Transport (ECDRT) • Great Kei Local Municipality, • Amathole District Municipality, and • Eastern Cape Parks and Tourism Agency (ECPTA).

Other key stakeholders include:

• Eskom; • Surrounding Landowners; • Kei Mouth Home Owners Association, and • Great Kei Local Municipality Ward 6 Councillor.

List of authorities from whom comments have been received:

DEDEAT: • Refer to Appendix E3 for comments received on the Draft BAR and CES’s response. DWS: • Refer to pre-consultation meeting minutes attached in Appendix E1. • Refer to Appendix E3 for comments received on the Draft BAR and CES’s response.

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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):

Refer to comments and response report in Appendix E. Only comments made by DWS during the WULA pre-application meeting have been received to date. Any comments received during the 30-day public review period will be incorporated into the Final Basic Assessment Report.

www.dedea.gov.za SECTION D: IMPACT ASSESSMENT

The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2010, 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.

Refer to comments and response report in Appendix E.

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):

Please refer to comments and response report in Appendix E.

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 Kei Mouth Eco Estate development was conducted in two parts; a general impact assessment (including sanitation), and a more detailed Ecological Impact Assessment (see Appendix D). Overall, the impact assessment identified and assessed impacts across the following phases of development:

• Planning & Design Phase • Construction Phase • Operational Phase

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Table 3.1 below provides a breakdown of the impact identification process into overall themes, potential issues, and the source of the issue across all project phases of the proposed development. It also identifies the potential receptors of each issue identified and the action taken to further assess each issue during the Basic Assessment process. Table 3.2 to 3.6 provides the detailed impact assessment for all phases of the proposed development, including the assessment for the No-Go Alternative and cumulative impacts.

Refer to Appendix G for the impact assessment methodology used.

www.dedea.gov.za Table 3.1: Potential issues and impacts identified throughout all project phases of the proposed development. PHASE POTENTIAL ASSESSMENT THEME POTENTIAL ISSUES SOURCE OF ISSUE PLANNING & RECEPTORS CONSTRUCTION OPERATIONAL ACTIONS DESIGN Non-compliance Applicant Obtaining Environmental Legal and Policy Authorisation from X X Policy Compliance relevant Competent Authorities Scheduling of Inappropriate scheduling Aquatic environments X X Construction Material Stockpiling Earthworks; pollution Aquatic environment X Changes to fluvial Earthworks, service infrastructure Assessed in the geomorphology and placement and installation X X General Impact hydrology Assessment Stormwater and erosion Inappropriate planning/ Aquatic environment X X X management management Inappropriate planning/ Study area and Bio-physical Waste Management management, construction rubble surrounds X X X and litter Sewage waste, Inappropriate Study area and Assessed in the planning/maintenance. surrounds, aquatic General Impact Sewage Package Plant environments X X Assessment and Design & Operation Ecological Impact Assessment Inappropriate planning/ Erosion prone areas in Assessed in the Rehabilitation & management study area X X General Impact Maintenance Assessment

www.dedea.gov.za PHASE POTENTIAL ASSESSMENT THEME POTENTIAL ISSUES SOURCE OF ISSUE PLANNING & RECEPTORS CONSTRUCTION OPERATIONAL ACTIONS DESIGN Clearance of Natural and Vegetation clearance Aquatic environment X X Riparian Vegetation Loss of Species of Vegetation clearance Local biodiversity Conservation Concern X X Assessed in the Biological (SCC) Ecological Impact Inadequate protection of Land use, development footprint Local biodiversity Assessment X X X high conservation areas Control of alien invasive Inappropriate alien vegetation Flora & Fauna in study X X X plant species management plan area Job creation Construction activities Individuals X X Assessed in the General Impact Air pollution Earthworks and Road traffic Neighbouring community X Assessment Noise pollution Earthworks and Road traffic Neighbouring community X Visual Presence of site Neighbouring community X X Construction activities and Labourers Health and Safety X Socio-economic equipment Sanitation and Water Inadequate facilities on site Labourers, Watercourses X Management of Cement, tar, fuel, bitumen, oil Project site and X X hazardous substances waterbodies Traffic Construction activities Traffic flow X X X Tourism Eco Estate Tourism industry X

www.dedea.gov.za PHASE POTENTIAL ASSESSMENT THEME POTENTIAL ISSUES SOURCE OF ISSUE PLANNING & RECEPTORS CONSTRUCTION OPERATIONAL ACTIONS DESIGN Heritage and Earthworks, construction activities Heritage sites and Assessed in the Paleontological Paleontological findings X X Impact Assessment Environment

www.dedea.gov.za Table 3.2: Planning and Design Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANC NATURE OF ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES E POST- IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION PLANNING & DESIGN PHASE ENVIRONMENTAL POLICY Relevant National During the planning and design phase, failure to comply with existing Direct Localised Long-term Possible Severe HIGH • The development must adhere to the relevant legislation and/or LOW Legislation and Policy policies and legal obligations can lead to the project conflicting with local, Cumulative NEGATIVE policy, e.g. ECBCP, Municipal By-laws, GKLM SEA & SDFs, etc. NEGATIVE provincial and national policies, legislation, etc. This can result in legal • All legal matters pertaining to permitting must be completed prior to non-compliances, fines, delays in construction activity, overall project any construction activity. failure and undue disturbance to the natural environment. • All necessary Water Use Licenses must be in order for any construction activities within close proximity to a watercourse, as well as any additional water uses as per Section 21 of the National Water Act. • All relevant permits must be obtained from the competent authority in order to remove/relocate any protected plant species. • All necessary permits must be in place prior to the removal/destruction of any potential heritage or paleontological resources found on site, should it be required. BIO-PHYSICAL During the planning and design phase, inappropriate construction Indirect Localised Medium Possible Moderately MODERATE • Sensitive riparian areas must to be designated as No-Go areas. LOW scheduling that does not take into account the seasonal requirements of Cumulative Term Severe NEGATIVE • Wherever possible, construction activities must be undertaken during NEGATIVE Scheduling of the aquatic environment, e.g. allowing for unimpeded flood events, could the driest part of the year to minimize downstream sedimentation due construction lead to short-term (and potentially long-term) impacts on the aquatic to excavation, etc. environment such as excessive sediment mobilization, etc. During the planning and design phase, the inappropriate design of storm Direct Localised Long Term Possible Moderately HIGH • A Stormwater Management Plan must be developed by a qualified MODERATE water infrastructure will lead to stream sedimentation and erosion of the Cumulative severe NEGATIVE engineer and implemented during the construction and operation NEGATIVE surrounding area. phase of the estate. • Al necessary Water Use Licenses must be obtained prior to Stormwater and construction. The conditions contained within the Water Use license/s Erosion Management must be adhered to. • An Erosion Management Plan must be compiled during the planning and design phase, to be implemented during construction and operation of the proposed development Waste Management During the planning and design phase, inadequate planning for the Indirect Localised Short Term Possible Moderate MODERATE • A Waste Management Plan must be compiled during the planning and LOW management of construction rubble and litter, and identification of NEGATIVE design phase, to be implemented during construction and operation NEGATIVE licensed waste facilities, could lead to pollution in the study area and of the proposed development. surrounding areas. Sewage Package During the planning and design phase, poor package plant system design Direct Localised Long Term Possible Severe HIGH • The sewage package system must be designed and implemented by a MODERATE Plant Design & can result in ineffective sewage treatment thus contaminating ground, Cumulative NEGATIVE qualified engineer with input from geo-hydrologist, where required. NEGATIVE Operation groundwater and surface water (rivers and streams). • Sanitation systems must be located above 1:100-year flood line. • A water quality monitoring programme must be established to be implemented during the operation phase of the estate to ensure that the discharge treated effluent meets the required standards. During the planning and design phase, inadequate planning for Indirect Localised Long Term Possible Moderately MODERATE • A Rehabilitation & Maintenance Plan must be compiled during the LOW rehabilitation during construction and operation could lead to Severe NEGATIVE planning and design phase, to be implemented during the NEGATIVE degradation of the study area and surrounding areas. construction and operational phase of the development. Rehabilitation & • The plan must detail measures that ensure the day-to-day operations Maintenance of the development do not cause unnecessary degradation to the surrounding environment and to ensure on-going maintenance of all service infrastructure is undertaken at regular intervals to minimize risks to the surrounding environment. BIOLOGICAL Loss of natural and During the planning and design phase, the inappropriate design of the Direct, Project Long Term Definite Moderately HIGH • The development footprint must be surveyed and demarcated prior MODERATE riparian vegetation development and associated infrastructure will lead to the unnecessary Indirect, Level severe NEGATIVE to construction commencing to ensure that there is no unnecessary NEGATIVE loss of natural and riparian vegetation. Cumulative loss of natural vegetation outside the approved footprint.

www.dedea.gov.za Table 3.2: Planning and Design Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANC NATURE OF ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES E POST- IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION PLANNING & DESIGN PHASE • The design and layout of the development and associated infrastructure must have as minimal impact on the natural vegetation as possible. • The placement of the estate buildings must be planned in such a way as to avoid intact thicket/bushland, as much as possible. • Service infrastructure must follow the road reserve, as much as practically possible. • A Rehabilitation Plan must be developed during the pre-construction to include details on rehabilitating disturbed natural areas once construction has been completed. • An ECO must be appointed pre-construction to ensure that the pre- construction requirements area adhered to, i.e. walkthroughs conducted, and management plans are developed. Loss of Species of During the planning and design phase, the inappropriate design of the Direct Project Permanent Possible Moderately MODERATE • A search and rescue walkthrough must be undertaken by a suitably LOW Conservation proposed development will lead to the loss of identified and unidentified Level severe NEGATIVE qualified individual, pre-construction, to identify any potential plant NEGATIVE Concern (SCC) plant and animal SCC. SCC’s located within the surveyed construction footprint. This must ideally be undertaken with the ECO and Contractor/Developer present. • All relevant permits must be obtained from the competent authority prior to construction in order to remove/relocate any plant SCC’s. During the planning and design phase, the planning and of the Kei Mouth Direct Localised Long-Term Probable Moderately LOW • A Conservation Management Plan must be developed for the Eco MODERATE Eco Estate in a manner which promotes conservation and adheres to the Indirect Beneficial POSITIVE Estate by a suitably qualified individual, which must include POSITIVE land-use guidelines of the ECBCP and local SDF, will positively contribute Cumulative addressing issues such as: to biodiversity conservation goals within the local area. • Identification of No-Go and sensitive areas, including the regulation of specific activities within such areas • Hunting • Inappropriate use of vehicles • Inappropriate stocking of game (e.g. overstocking and inappropriate species) Inadequate • Introduction of dangerous animals protection of high • Types of vehicles that will be permitted in the conservation areas conservation areas (i.e. of access roads) • Domestic pets • Vegetation and Alien species control and management • Fire control and veld burning • Fencing • Access control • Having the remaining application area (particularly the portions towards the Great Kei River) proclaimed as a private nature reserve should be considered. Control of alien During the planning and design phase, inadequate planning for the Direct Localised Long Term Probable Severe HIGH • During the planning and design phase, an Alien Vegetation MODERATE invasive plant species removal and management of alien vegetation could result in the invasion NEGATIVE Management Plan must be complied to be implemented during NEGATIVE of alien vegetation in both terrestrial and riparian areas during the construction and operation of the estate to reduce the establishment construction and operation phase. and spread of undesirable alien plant species. SOCIO-ECONOMIC Visual During the planning and design phase, inadequate consideration giving Direct Localised Permanent Definite Moderately MODERATE • The development will largely be visible to rural developments on the LOW towards potential neighbouring visual receptors will lead to visual severe NEGATIVE former Transkei side of the Great Kei River and hidden from NEGATIVE impacts as a result of poor building placement on the property. neighbouring farms. The design and construction of the development must therefore take into account the following: • Sighting and scale of structures:

www.dedea.gov.za Table 3.2: Planning and Design Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANC NATURE OF ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES E POST- IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION PLANNING & DESIGN PHASE • Lighting: All exterior lighting must be shaded and directed downwards. • Street lighting should be avoided to retain the natural / rural character of the area. Low-level bollard lights could be used close to buildings, in parking areas and along paths. All lighting should be fitted with reflectors to avoid light spillage and minimise visual impact of lights at night. • Signage should generally be avoided on access routes and on buildings, to minimise visual clutter. No commercial signage should be permitted. Information signs should have a distinctive colour and standard symbols, similar to those used by SANParks. Signs should be located against a backdrop to avoid silhouette effects on the skyline. Low signs tend to be less obtrusive in the landscape. • Utility lines should be located underground to minimise visual intrusion in the exposed landscape. Utility structures, including power lines, pylons and masts should be carefully sited to avoid intrusion on the skyline. • Satellite dishes and aerials must not protrude above the ridgeline of building roofs to minimise visual clutter in the landscape. • Informal landscape design should be used in preference to formal or geometric layouts. • Formal gardens or lawns should be avoided, and only locally occurring species should be used, given the context of the site adjacent to a national park. • Landscaping guidelines should be included in the Development Plan and Architectural Design Manual. A list of approved species should be included. Landscape plans are to be submitted with all building plans. • Homeowners Association (HOA) Agreement: The above mitigation measures must be included in the Homeowners Agreement and the controls provided must be complied with. Traffic During the planning and design phase, inadequate planning for the Direct Localised Short term Definite Moderately MODERATE • A Traffic Management Plan must be compiled during the planning and LOW management of traffic through the project area may result in a severe NEGATIVE design phase detailing appropriate mitigation measures for NEGATIVE magnitude of impacts, such as increased dust generation, noise pollution, construction related traffic impacts. and increased public safety risks. • Appropriate signage and traffic calming measures must be implemented, to ensure road users are aware of the possibility of construction vehicles turning off/onto the Kei Mouth road. Heritage & During the planning and design phase, inadequate planning and Direct Project Permanent Possible Severe HIGH • Any comments and/or instructions received from the Eastern Cape LOW Palaeontological consideration of cultural, heritage and paleontological artefacts of level NEGATIVE Provincial Heritage Resources Authority (ECPHRA) and the South NEGATIVE Environment significance may lead to their damage/destruction African Heritage Resource Agency (SAHRA) must be taken into consideration prior and during construction. • All necessary permits must be in place prior to the removal/destruction of any potential heritage or paleontological resources, if found on site during the site walkthrough by the ECO. • Prior to construction, the ECO and contractor must be made aware of potential new fossil findings. They must familiarise themselves with the sort of fossils they may be found in this area. • Should any graves be located prior to construction, the area must be demarcated and considered a No-Go area. The local heritage authority must be notified. • A full grave relocation process must be followed in accordance with the applicable regulations, should this be required.

During the construction phase, stockpiling of construction Direct Project Short Term Probable Moderately MODERATE • Topsoil which is excavated/removed during earthwork activities must be LOW NEGATIVE materials close to watercourses could result in erosion and Indirect Area severe NEGATIVE stockpiled on site for use during rehabilitation. mobilisation of the materials into the nearby Cumulative • No construction material is to be stored within 50 m of a watercourse or watercourses/wetlands, resulting in sedimentation and a wetland system. Material Stockpiling decrease in water quality and aquatic habitat. • Stockpiles must be monitored for erosion and mobilisation of materials towards watercourses. • If this is noted by an ECO, suitable cut-off drains/berms/sediment traps must be placed between the stockpile area and the nearest watercourse. During the construction phase, the inappropriate routing of Direct Localised Short term Probable Moderately MODERATE • The conditions set out in the Storm Water Management Plan and Erosion LOW NEGATIVE Stormwater and stormwater will lead to stream sedimentation, adversely Indirect severe NEGATIVE Management Plan must be implemented and adhered to. Erosion affecting the aquatic environment. Cumulative • The ECO must monitor for erosion and mobilization of sediment and Management recommend appropriate remedial action if required. Waste Management During the construction phase, litter on site may attract vermin, Direct Localised Short Term Probable Moderately MODERATE • The conditions set out in the Waste Management Plan must be implemented LOW NEGATIVE detract from the visual appeal of the area, and pollute the Severe NEGATIVE and adhered to. surrounding areas. Construction rubble left onsite could pollute • Construction rubble must be disposed of in predetermined, demarcated spoil the area and encourage the growth of opportunistic alien dumps. vegetation. • The ECO must monitor the Contractor campsite for litter and waste. • All waste must be stored on site in closed bins and removed from the site and transported to the closest licensed landfill site. BIOLOGICAL Loss of Natural and During the construction phase, indiscriminate removal of Direct Project Medium Probable Severe HIGH • All No-Go areas, such as riparian areas, 100m inland from the 1:100-year LOW NEGATIVE Riparian Vegetation natural and riparian vegetation at rivers and water crossing Cumulative Level term NEGATIVE floodline of the Great Kei River and 50 m buffers applied to the iCwili River sites, or encroachment into surrounding areas could lead to and smaller tributaries within the study area, must be avoided during construction.

SOCIO-ECONOMIC During the construction phase, the proposed development will Direct Localised Short Term Probable Moderately LOW POSITIVE • Where possible, individuals from the nearest local communities must be MODERATE Job creation create temporary employment opportunities which will benefit Beneficial contracted for unskilled and semi-skilled employment. POSITIVE the local community. During the construction phase, dust (air) pollution caused by Direct Project Short Term Probable Moderate MODERATE • Cleared surfaces must be dampened whenever possible, especially during LOW NEGATIVE grading and levelling exposed land can cause a nuisance to Level NEGATIVE dry and windy conditions, to avoid excessive dust generation. Air pollution nearby traffic and neighbouring residential areas. • Any complaints or claims emanating from dust issues must be attended to immediately and noted in the complaints register. During the construction phase, noise pollution caused by Direct Localised Short Term Probable Moderate MODERATE • Construction activity close to residential settlements/BnBs, which includes LOW NEGATIVE construction activities could potentially be a nuisance to NEGATIVE the movement of construction vehicles, must be restricted to normal Noise pollution neighbouring residential areas and local BnBs. working hours (7:00am – 17:00pm). • There must be a complaints register on site for nearby residents to make complaints, if required. These must be addressed and recorded. During the construction phase, the construction of the proposed Direct Localised Short Term Probable Moderate MODERATE • Construction of the development must be done in accordance with the LOW NEGATIVE Kei Mouth Eco Estate, as well as temporary construction related NEGATIVE approved architectural design and aesthetics code. structures and activities may impact on the aesthetic • The site camp must be placed in an area that is not visually obtrusive to the Visual appearance of the project area. neighbouring properties or local communities. • The site camp and temporary structures must be decommissioned, and the area rehabilitated once construction has been completed. • All waste, materials and equipment must be removed from site.

www.dedea.gov.za Table 3.3 Construction Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE SIGNIFICANCE NATURE OF ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES POST- IMPACT (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION MITIGATION CONSTRUCTION PHASE: • The project area is to be kept tidy and free of litter, where possible. During the construction phase, inadequate attention to fire Direct Localised Short Term Possible Severe HIGH • The contractor must ensure that operational firefighting equipment is LOW NEGATIVE safety awareness and fire safety equipment could result in NEGATIVE present on site at all times as per Occupational Health and Safety Act. runaway fires, an unsafe working environment and the loss of • All construction foremen must be trained in fire hazard control and property. 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. • No smoking near flammable substances. • All cooking must be done in demarcated areas considered safe in terms of Health and Safety runaway or uncontrolled fires. During the construction phase, the inappropriate use of Direct Project Short Term Possible Severe HIGH • The contractor must ensure that workers adhere to all safety regulations as LOW NEGATIVE equipment and machinery on site may result in worker injuries level NEGATIVE per Occupational Health and Safety Act. or loss of life. • Appropriate PPE must be worn by workers at all time. • Regular training/talks must be given to all workers on site regarding safe working procedures. During the construction phase, the construction site and Direct Project Short Term Possible Moderately MODERATE • Appropriate warning signs must be in place to notify the public regarding LOW NEGATIVE associated activities may present safety risks to the local level Severe NEGATIVE construction activities and any areas of high risk, i.e. open excavations. community should access control and appropriate • The construction site and camp must have access control and be signage/demarcation not be in place. demarcated, where possible. • Open excavations must be appropriately demarcated, where possible. During the construction phase, improper management (usage Direct Localised Short Term Possible Severe HIGH • Hazardous Chemical Substances Regulations promulgated in terms of the MODERATE and storage) of hazardous substances such as cement, tar Cumulative NEGATIVE Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice NEGATIVE bitumen, fuel and oil may result in spillages occurring leading to must be adhered to. This applies to solvents and other chemicals possibly site contamination. used during the construction process. • The individual(s) that will be handling hazardous materials must be trained to do so. • All hazardous chemicals must be stored properly in a secure, bunded and contained area. • Concrete must not be mixed directly on the ground, or during rainfall events when the potential for transport to the stormwater system is the greatest. Management of • Concrete must only be mixed in the area demarcated for this purpose and on hazardous an impermeable surface, and not within 50m of any river/watercourse. substances • Oil trays must be placed under construction machinery to avoid soil contamination. • An oil absorbent materials/spill kit must be kept at the site camp in case of a spill. • Should a spill occur, the individual responsible for (or the individual who discovers the petrochemical spill) must report the incident to the Project Coordinator, ECO and/or Contractor as soon as reasonably possible. The immediate response must be to contain the spill. • The ECO must determine the precise method of treatment of polluted soil. This could involve the application of oil absorbent materials or oil-digestive Sanitation and During the construction phase, failure to provide adequate Direct Localised Short Term Possible Severe MODERATE • Adequate sanitary and ablutions facilities must be provided for construction LOW NEGATIVE Water onsite sanitation and clean drinking water during the NEGATIVE workers. construction phase may result in runoff transferring • No ablutions facilities are to be placed within 50m of a contaminants into the surrounding environment. watercourse/tributary. • The facilities must be serviced regularly to reduce the risk of surface or groundwater pollution. • All wastewater from general activities in the camp must be collected and removed from the site for appropriate disposal at a licensed facility.

www.dedea.gov.za Table 3.4: Operational Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE NATURE SIGNIFICANCE POST- ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES OF IMPACT MITIGATION (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION OPERATIONAL PHASE: BIO-PHYSICAL Changes to fluvial During the operation phase, uncontrolled extraction from the Direct Project Long Term Probable Severe HIGH • The extraction volume from the natural drainage water LOW NEGATIVE geomorphology and natural drainage channels to supply the proposed dams may Level NEGATIVE course to supply the dams must not exceed 10% of the hydrology impact the flow into the Great Kei River, affecting the levels of average annual minimum rainfall for the catchment area. sedimentation within the estuary. • The extraction of water from the natural drainage course for storage in the two proposed dams must be monitored during times of low rainfall to ensure that the flow into the Great Kei River is not affected. Stormwater and During the operation phase, inappropriate maintenance of Direct Project Long Term Probable Severe HIGH • The conditions of the Storm Water Management Plan LOW NEGATIVE Erosion Management stormwater infrastructure will lead to stream sedimentation Level NEGATIVE must be implemented and adhered to throughout the and/or erosion. operational phase of the development. • Stormwater infrastructure must be monitored and maintained post construction to ensure that the receiving environment, particularly sensitive riparian areas are not negatively affected. Waste Management During the operation phase, inappropriate handling and Direct Localised Long Term Probable Severe HIGH • The conditions of the Waste Management Plan must be LOW NEGATIVE disposal of solid waste generated during the operation of the NEGATIVE implemented and adhered to throughout the operation proposed Kei Mouth Eco Estate may have detrimental impacts of the development. on the surrounding environment. • The Home Owners Association must ensure that waste is handled and disposed of in environmentally acceptable manners. • No waste must be disposed of on site. • Waste must be removed from site regularly and disposed of at the nearest licensed waste facility. • Where possible, provisions for waste recycling must be made available. Sewage Package During the operation phase, inadequate management and Direct Localised Long Term Possible Severe HIGH • The Waste Management Plan must include: MODERATE NEGATIVE Plant Design & maintenance of the sewage package plant system can result in Cumulative NEGATIVE o A maintenance plan, undertaken by a suitably Operation ineffective sewage treatment thus contaminating ground, qualified individual, to ensure the treatment facility is groundwater and surface water (rivers and streams). System running well. failure can result from infrequent cleaning frequency, high o An appropriate water quality monitoring programme toilet usage and poor water conservation can result in poor for the sewage package plant in accordance with the retention times and overflows, oil and grease contained in conditions of the water use license. kitchen water can clog up systems, and use of household o Include regular monitoring and inspection of cleaners and chemicals can kill bacteria resulting in ineffective sanitation systems including: biological treatment. ▪ Fat traps ▪ Evidence of system over flows ▪ Inappropriate odours ▪ Leaching around dispersal fields o Educational materials should be disseminated to households on how to properly maintain sanitation systems. Rehabilitation & During the operational phase, inappropriate operational Direct Localised Long Term Possible Severe MODERATE • The conditions of the Rehabilitation and Maintenance LOW NEGATIVE Maintenance activities and inadequate provision for the on-going NEGATIVE Plan must be implemented and adhered to throughout management and maintenance of service infrastructure could the operational phase of the project. lead to degradation of the receiving environment. • In particular, the sewage reticulation and associated infrastructure must undergo regular monitoring and serviced when required to minimize the risk of site contamination.

www.dedea.gov.za Table 3.4: Operational Phase Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / SIGNIFICANCE NATURE SIGNIFICANCE POST- ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL PRE- MITIGATION MEASURES OF IMPACT MITIGATION (EXTENT) (DURATION) (LIKELIHOOD) SCALE MITIGATION OPERATIONAL PHASE: BIOLOGICAL Inadequate During the operational phase, the management of the property Direct Localised Long-Term Probable Moderately LOW POSITIVE • The land-use guidelines and principles of the ECBCP and MODERATE POSITIVE protection of high in accordance with the land-use guidelines and principles of the Beneficial GKLM SDF must be included in the Home Owners conservation areas ECBCP and GKLM SDF will contribute to biodiversity Agreement. conservation within the local area. • All applicable management plans must be implemented and included in Home Owners Agreement, ie.: o Operational Environmental Management Programme (EMPr) o Stormwater Management Plan; o Erosion Management Plan; o Waste management Plan; o Traffic Management Plan; o Conservation Management Plan; o Environmental Monitoring Programme (water quality); o Alien Species Management Plan; and o Rehabilitation and Maintenance Plan Control of alien During the operational phase, the lack of an effective Alien Direct Localised Long Term Possible Moderately MODERATE • The Alien Vegetation Management Plan must be included LOW NEGATIVE invasive plant Vegetation Management Plan post-construction could lead to Cumulative severe NEGATIVE as part of the developments on-going maintenance plan species large scale alien plant invasion during the operational phase. to reduce the establishment and spread of undesirable alien plant species throughout the operational phase. • Indigenous species must be prioritized for use within the estate SOCIO-ECONOMIC During the operational phase, the proposed development will Direct Localised Long Term Probable Moderately LOW POSITIVE • Where possible, individuals from the nearest local MODERATE POSITIVE Job creation create permanent employment opportunities during the Beneficial communities must be contracted for unskilled and semi- operation of the development. skilled employment. During the operational phase, normal vehicle traffic may lead Direct Localised Long Term Probable Moderately MODERATE • Hazardous Chemical Substances Regulations promulgated LOW NEGATIVE to the spillage of toxic substances (such as heavy metals, Indirect severe NEGATIVE in terms of the Occupational Health and Safety Act 85 of hydrocarbons, surfactants and oils) which may negatively 1993 and the SABS Code of Practice must be adhered to. impact the surrounding environment and biodiversity. This applies to solvents and other chemicals possibly used Management of during the operation of the development. hazardous • All hazardous chemicals must be stored properly in a substances secure, bunded and contained area. • The Home Owners Association must have appropriate emergency response procedures in place to deal with possible spills. • The Home Owners Agreement must clearly detail all activities/hazardous substances which area prohibited. During the operational phase, the development will increase Direct Localised Long Term Definite Moderate LOW • The Home Owners Association must ensure all occupants LOW NEGATIVE the volume of traffic through the neighbouring area to the site. NEGATIVE are considerate of neighbouring properties when using Traffic the local access roads. • Provisions for a grievance procedure must be incorporated into the Home Owners Agreement. • Road infrastructure must be maintained, when required. During the operational phase, the Kei Mouth Eco Estate will Direct Localised Long Term Probable Moderately LOW POSITIVE • No mitigation proposed MODERATE POSIITVE Tourism contribute to the local tourism industry by attracting visitors to Indirect Regional Beneficial the area.

www.dedea.gov.za Table 3.5: NO GO Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / NATURE SIGNIFICANCE SIGNIFICANCE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL MITIGATION MEASURES OF IMPACT PRE-MITIGATION POST-MITIGATION (EXTENT) (DURATION) (LIKELIHOOD) SCALE Proposed Kei Mouth The No-Go Alternative will result in the status-quo being maintained. Direct Localised Long Term Definite No effect NO SIGNIFICANCE No mitigation proposed NO SIGNIFICANCE Eco Estate Job creation The No-Go Option would not create any job opportunities Direct Localised Long Term Definite Moderately MODERATE NEGATIVE No mitigation proposed MODERATE severe NEGATIVE Protection of high The No-Go Option would not result in the promotion of conservation Direct Localised Long Term Definite Moderately MODERATE NEGATIVE No mitigation proposed MODERATE conservation areas within the local area. Indirect severe NEGATIVE

Table 3.6: Cumulative Impact Assessment SPATIAL TEMPORAL CERTAINTY SEVERITY / NATURE SIGNIFICANCE SIGNIFICANCE ISSUE DESCRIPTION OF IMPACT SCALE SCALE SCALE BENEFICIAL MITIGATION MEASURES OF IMPACT PRE-MITIGATION POST-MITIGATION (EXTENT) (DURATION) (LIKELIHOOD) SCALE Biodiversity The clearing of natural vegetation results in land transformation, alien Cumulative Localised Medium Probable Moderately MODERATE NEGATIVE • The Conservation Management Plan must be developed and LOW plant invasion and habitat loss term severe implemented. NEGATIVE Hydrology & Surface water impacts, such as water surface and/or groundwater Cumulative Localised Medium Probable Moderately MODERATE NEGATIVE • An Erosion Management Plan must be developed and implemented. LOW Geohydrology contamination and sedimentation (increased dust and sediment term severe NEGATIVE generation) may extend beyond the immediate project site

• A Waste Management Plan must be developed and implemented.

• Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to.

Changes to surface flow dynamics may have negative effects on the • Storm Water Management Plan must be developed and implemented. aquatic environment beyond the immediate project site Local land capability may be reduced due to loss of topsoil, erosion and Cumulative Localised Medium Probable Moderately MODERATE NEGATIVE • An Erosion Management Plan must be developed and implemented. LOW Soils soil contamination term severe NEGATIVE Traffic Increased flow of traffic to the project site may deteriorate the surface Cumulative Localised Medium Probable Moderate MODERATE NEGATIVE • A Traffic Management Plan must be developed and implemented. LOW condition of the surrounding roads, and increase the risk to public safety term • Rehabilitation and Maintenance Plan must be developed and NEGATIVE within the project area implemented. Tourism The No-Go Option would not result in the promotion of tourism within Direct Localised Long Term Definite Moderately MODERATE NEGATIVE No mitigation proposed MODERATE the local area. Indirect severe NEGATIVE

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4. ENVIRONMENTAL IMPACT STATEMENT

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 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.

Summary of proposed development

The proposed Kei Mouth Eco Estate development relates to the establishment of a low density 50 high- income residential erven, two lodge sites each with a capacity of 100 beds and a recreational facility. This is considerably fewer than the 100+ units approved in the previous EA.

The proposed development will have the following activities:

• The consolidation, subdivision and rezoning of the 3 farms totalling about 599.2 Ha; • The subdivision of portions of the consolidated area into approximately 68 erven (based on 1 unit per 10 Ha as recommended by the Great Kei Spatial Development Framework) and the rezoning of the 68 erven to Resort and Special Zone: Rural Residential; • Holiday housing (development footprint of 4.6 Ha); • Lodge and chalets (development footprint of 0.52 Ha); • Service area (development footprint of 0.1 Ha); and • Remaining area (approximately 577.1 Ha) to remain as agriculture but managed as a game farm.

The associated proposed activities include:

• The construction of distributed on-site sewage package plant (development footprint of 0.09 Ha) and underground sewage reticulation; • The construction of a network of internal roads (development footprint of 1.7 Ha); and • The installation of underground water and electricity reticulation infrastructure.

Internal strip roadways will be constructed between all residential erven, lodges and the recreational facility. Two suitable dam sites have been identified which will be developed concurrently with the installation of the bulk water infrastructure. Water Use Licensing applications will be submitted to the Department of Water and Sanitation (DWS) for all activities associated with the proposed installation of service infrastructure (roads, pipelines, and sewage package plant) and dams requiring authorisation in terms of Section 21 of the National Water Act (1998).

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The proposed development will take place in a phased manner, as indicated in Figure 1.2 above. All service infrastructure will be constructed within Phase 1 of the proposed development.

Ultimately 3.7% of the consolidated area will be occupied by residential erven, lodges and chalets, and associated infrastructure, while 96.3% of the area will be set aside for conservation purposes.

Consideration of alternatives

Table 2.1 provided a comparative assessment of identified alternatives for the proposed Kei Mouth Eco Estate including advantages and disadvantages. In summary, the following conclusions were made:

Incremental alternatives – the following design/technological design alternative will be assessed during the EIA process:

• Sewage technology alternative – As there is no waste water treatment works in the vicinity of the proposed development, a packaged plant system is the preferred sewage treatment alternative for the proposed development. Due to poor percolation results in the area, the installation of a septic tank system is not recommended.

Summary of significant impacts:

A detailed impact assessment (including the types, duration, likelihood, and the significance of impacts) can be found in Tables 3.2 to 3.6 above.

All impacts identified as HIGH negative significance rating pre-mitigation can be reduced to either LOW or MODERATE negative significance rating post-mitigation. Table 4 below provides a summary of the significance ratings for all impacts identified for the proposed development.

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Table 4: Summary of impacts for all project phases PLANNING & DESIGN PHASE Significance Significance Theme Impacts pre-mitigation post-mitigation

Relevant National During the planning and design phase, failure HIGH NEGATIVE LOW NEGATIVE Legislation and to comply with existing policies and legal Policy obligations can lead to the project conflicting with local, provincial and national policies, legislation, etc. This can result in legal non- compliances, fines, delays in construction activity, overall project failure and undue disturbance to the natural environment. During the planning and design phase, MODERATE LOW NEGATIVE inappropriate construction scheduling that does NEGATIVE not take into account the seasonal Scheduling of requirements of the aquatic environment, e.g. construction allowing for unimpeded flood events, could lead to short-term (and potentially long-term) impacts on the aquatic environment such as excessive sediment mobilization, etc. During the planning and design phase, the HIGH NEGATIVE MODERATE Stormwater and inappropriate design of storm water NEGATIVE Erosion infrastructure will lead to stream sedimentation Management and erosion of the surrounding area. Waste During the planning and design phase, MODERATE LOW NEGATIVE Management inadequate planning for the management of NEGATIVE construction rubble and litter, and identification of licensed waste facilities, could lead to pollution in the study area and surrounding areas. During the planning and design phase, poor HIGH NEGATIVE MODERATE package plant system design can result in NEGATIVE Sewage Package ineffective sewage treatment thus Plant Design & contaminating ground, groundwater and Operation surface water (rivers and streams).

During the planning and design phase, MODERATE LOW NEGATIVE inadequate planning for rehabilitation during NEGATIVE Rehabilitation & construction and operation could lead to Maintenance degradation of the study area and surrounding areas.

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Loss of Riparian During the planning and design phase, the HIGH MODERATE Vegetation inappropriate design of the development and NEGATIVE NEGATIVE associated infrastructure will lead to the unnecessary loss of riparian vegetation. Loss of natural During the planning and design phase, the HIGH MODERATE and riparian inappropriate design of the development and NEGATIVE NEGATIVE vegetation associated infrastructure will lead to the unnecessary loss of natural and riparian vegetation. Loss of Species of During the planning and design phase, the MODERATE LOW NEGATIVE Conservation inappropriate design of the proposed NEGATIVE Concern (SCC) development will lead to the loss of identified and unidentified plant and animal SCC. During the planning and design phase, the LOW POSITIVE MODERATE planning and of the Kei Mouth Eco Estate in a POSITIVE Inadequate manner which promotes conservation and protection of high adheres to the land-use guidelines of the conservation ECBCP and local SDF, will positively contribute areas to biodiversity conservation goals within the local area. Control of alien During the planning and design phase, HIGH NEGATIVE MODERATE invasive plant inadequate planning for the removal and NEGATIVE species management of alien vegetation could result in the invasion of alien vegetation in both terrestrial and riparian areas during the construction and operation phase. Visual During the planning and design phase, MODERATE LOW NEGATIVE inadequate consideration giving towards NEGATIVE potential neighbouring visual receptors will lead to visual impacts as a result of poor building placement on the property. Traffic During the planning and design phase, MODERATE LOW NEGATIVE inadequate planning for the management of NEGATIVE traffic through the project area may result in a magnitude of impacts, such as increased dust generation, noise pollution, and increased public safety risks. Heritage & During the planning and design phase, HIGH NEGATIVE LOW NEGATIVE Palaeontological inadequate planning and consideration of Environment cultural, heritage and paleontological artefacts of significance may lead to their damage/destruction CONSTRUCTION PHASE

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Significance Significance Theme Impacts pre-mitigation post-mitigation Relevant National During the construction phase, the failure of the MODERATE LOW NEGATIVE Legislation and contractor to implement mitigation measures NEGATIVE Policy specified in the EMPr and EA could result in fines, overall project failure or delays in construction and undue disturbance to the natural environment. During the construction phase, inappropriate MODERATE LOW NEGATIVE construction scheduling that does not take into NEGATIVE account the seasonal requirements of the Scheduling of aquatic environment, e.g. allowing for construction unimpeded flood events, could lead to short- term (and potentially long-term) impacts on the aquatic environment such as excessive sediment mobilization, etc. During the construction phase, construction HIGH NEGATIVE MODERATE Changes to fluvial activities within watercourses/drainage NEGATIVE geomorphology channels may impede the flow of watercourses, and hydrology affecting the local hydrology, should it not be undertaken in the correct manner. During the construction phase, stockpiling of MODERATE LOW NEGATIVE construction materials close to watercourses NEGATIVE could result in erosion and mobilisation of the Material materials into the nearby Stockpiling watercourses/wetlands, resulting in sedimentation and a decrease in water quality and aquatic habitat. During the construction phase, the MODERATE LOW NEGATIVE Stormwater and inappropriate routing of stormwater will lead to NEGATIVE Erosion stream sedimentation, adversely affecting the Management aquatic environment. Waste During the construction phase, litter on site may MODERATE LOW NEGATIVE Management attract vermin, detract from the visual appeal of NEGATIVE the area, and pollute the surrounding areas. Construction rubble left onsite could pollute the area and encourage the growth of opportunistic alien vegetation. Loss of Natural During the construction phase, indiscriminate HIGH NEGATIVE LOW NEGATIVE and Riparian removal of natural and riparian vegetation at Vegetation rivers and water crossing sites, or encroachment into surrounding areas could lead to destabilisation of bank structures and an increase in erosion rates.

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Loss of Species of During the construction phase, the clearing of MODERATE LOW NEGATIVE Conservation natural vegetation may lead to the destruction NEGATIVE Concern (SCC) of habitats and the loss of identified and unidentified plant SCC. Inadequate During the construction phase, construction not MODERATE LOW NEGATIVE protection of high undertaken in accordance with the land-use NEGATIVE conservation management guidelines of the ECBCP and areas GKLM SDF may lead to the loss of local biodiversity. Control alien During the construction phase, vegetation MODERATE LOW NEGATIVE invasive plant clearing, and poor rehabilitation of disturbed NEGATIVE species areas may lead to the permanent degradation of ecosystems and promote the establishment and spread of alien vegetation species. During the construction phase, the proposed LOW POSITIVE MODERATE development will create temporary employment POSITIVE Job creation opportunities which will benefit the local community. During the construction phase, dust (air) MODERATE LOW NEGATIVE pollution caused by grading and levelling NEGATIVE Air pollution exposed land can cause a nuisance to nearby traffic and neighbouring residential areas. During the construction phase, noise pollution MODERATE LOW NEGATIVE caused by construction activities could NEGATIVE Noise pollution potentially be a nuisance to neighbouring residential areas and local BnBs. During the construction phase, the construction MODERATE LOW NEGATIVE of the proposed Kei Mouth Eco Estate, as well NEGATIVE Visual as temporary construction related structures and activities may impact on the aesthetic appearance of the project area. During the construction phase, inadequate HIGH NEGATIVE LOW NEGATIVE attention to fire safety awareness and fire safety equipment could result in runaway fires, an unsafe working environment and the loss of property. During the construction phase, the HIGH NEGATIVE LOW NEGATIVE Health and Safety inappropriate use of equipment and machinery on site may result in worker injuries or loss of life. During the construction phase, the construction MEDIUM LOW NEGATIVE site and associated activities may present NEGATIVE safety risks to the local community should

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access control and appropriate signage/demarcation not be in place. During the construction phase, improper HIGH NEGATIVE MODERATE Management of management (usage and storage) of hazardous NEGATIVE hazardous substances such as cement, tar bitumen, fuel substances and oil may result in spillages occurring leading to site contamination. Sanitation and During the construction phase, failure to provide MODERATE LOW NEGATIVE Water adequate onsite sanitation and clean drinking NEGATIVE water during the construction phase may result in runoff transferring contaminants into the surrounding environment. Traffic During the construction phase, increased flow MODERATE LOW NEGATIVE of traffic to the project site may negatively NEGATIVE impact the neighbouring areas. Heritage & During the construction phase, the sensitive HIGH NEGATIVE LOW NEGATIVE Palaeontological heritage sites and paleontological findings Environment could be damaged or destroyed by construction activities during the construction phase. OPERATIONAL PHASE Significance Significance Theme Impacts pre-mitigation post-mitigation Changes to fluvial During the operation phase, uncontrolled HIGH NEGATIVE LOW NEGATIVE geomorphology extraction from the natural drainage channels to and hydrology supply the proposed dams may impact the flow into the Great Kei River, affecting the levels of sedimentation within the estuary.

Stormwater and During the operation phase, inappropriate HIGH NEGATIVE LOW NEGATIVE Erosion maintenance of stormwater infrastructure will Management lead to stream sedimentation and/or erosion.

Waste During the operation phase, inappropriate HIGH NEGATIVE LOW NEGATIVE Management handling and disposal of solid waste generated during the operation of the proposed Kei Mouth Eco Estate may have detrimental impacts on the surrounding environment.

Sewage Package During the operation phase, inadequate HIGH NEGATIVE MODERATE Plant Design & management and maintenance of the sewage NEGATIVE Operation package plant system can result in ineffective sewage treatment thus contaminating ground, groundwater and surface water (rivers and

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streams). System failure can result from infrequent cleaning frequency, high toilet usage and poor water conservation can result in poor retention times and overflows, oil and grease contained in kitchen water can clog up systems, and use of household cleaners and chemicals can kill bacteria resulting in ineffective biological treatment.

Rehabilitation & During the operational phase, inappropriate MODERATE LOW NEGATIVE Maintenance operational activities and inadequate provision NEGATIVE for the on-going management and maintenance of service infrastructure could lead to degradation of the receiving environment.

Inadequate During the operational phase, the management LOW POSITIVE MODERATE protection of high of the property in accordance with the land-use POSITIVE conservation guidelines and principles of the ECBCP and areas GKLM SDF will contribute to biodiversity conservation within the local area.

Control of alien During the operational phase, the lack of an MODERATE LOW NEGATIVE invasive plant effective Alien Vegetation Management Plan NEGATIVE species post-construction could lead to large scale alien plant invasion during the operational phase.

During the operational phase, normal vehicle MODERATE LOW NEGATIVE traffic may lead to the spillage of toxic NEGATIVE Management of substances (such as heavy metals, hazardous hydrocarbons, surfactants and oils) which may substances negatively impact the surrounding environment and biodiversity.

During the operational phase, the proposed LOW POSITIVE MODERATE development will create permanent POSITIVE Job creation employment opportunities during the operation of the development.

During the operational phase, the development LOW NEGATIVE LOW NEGATIVE Traffic will increase the volume of traffic through the neighbouring area to the site.

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During the operational phase, the Kei Mouth LOW POSITIVE MODERATE Tourism Eco Estate will contribute to the local tourism POSITIVE industry by attracting visitors to the area.

NO-GO ALTERNATIVE Significance Significance Theme Impacts pre-mitigation post-mitigation Proposed Kei The No-Go Alternative will result in the status- NO NO Mouth Eco Estate quo being maintained. SIGNIFICANCE SIGNIFICANCE Job creation The No-Go Option would not create any job MODERATE MODERATE opportunities NEGATIVE NEGATIVE

Protection of high The No-Go Option would not result in the MODERATE MODERATE conservation promotion of conservation within the local area. NEGATIVE NEGATIVE areas Tourism The No-Go Option would not result in the MODERATE MODERATE promotion of tourism within the local area. NEGATIVE NEGATIVE

CUMULATIVE IMPACTS Significance Significance Theme Impacts pre-mitigation post-mitigation Biodiversity The clearing of natural vegetation results in land MODERATE LOW transformation, alien plant invasion and habitat NEGATIVE NEGATIVE loss Surface water impacts, such as water surface MODERATE LOW and/or groundwater contamination and NEGATIVE NEGATIVE sedimentation (increased dust and sediment Hydrology & generation) may extend beyond the immediate Geohydrology project site Changes to surface flow dynamics may have negative effects on the aquatic environment beyond the immediate project site Local land capability may be reduced due to MODERATE LOW Soils loss of topsoil, erosion and soil contamination NEGATIVE NEGATIVE Traffic Increased flow of traffic to the project site may MODERATE LOW deteriorate the surface condition of the NEGATIVE NEGATIVE surrounding roads, and increase the risk to public safety within the project area

In summary, Table 5 below provides a breakdown of the total significance ratings for all impacts, pre- and post-mitigation.

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Table 5: Summary of Impact assessment significance, pre- and post-mitigation PRE-MITIGATION POST-MITIGATION

LOW MODERATE HIGH LOW MODERATE HIGH

Planning and 1+ 6 7 8 5 (1+) 0 Design

Construction 1+ 14 6 18 2 (1+) 0

Operation 1 (2+) 3 4 7 1 (2+) 0

TOTAL 1 (4+) 23 17 33 8 (4+) 0

Opinion of the EAP

It is the opinion of CES that NO FATAL FLAWS are associated with the proposed Kei Mouth Eco Estate, and that all impacts can be adequately mitigated to reduce the risk or significance of impacts to an acceptable level (all impacts identified as HIGH negative significance rating pre-mitigation can be reduced to either LOW or MODERATE negative significance rating post-mitigation).

It is also the opinion of CES that this Basic Assessment Report contains sufficient information to allow DEDEAT to make an informed decision. CES therefore recommends that the application for Authorisation should be approved on condition that the recommended mitigation measures stated herein are effectively implemented.

Detailed mitigation measures for all possible impacts identified above are provided in section E below.

www.dedea.gov.za 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:

It is recommended that all mitigation measures provided in this report should be a condition of any approval from DEDEAT. In addition, an EMPr needs to be approved.

PROPOSED MITIGATION MEASURES:

PLANNING AND DESIGN PHASE

• The development must adhere to the relevant legislation and/or policy, e.g. ECBCP, Municipal By-laws, GKLM SEA & SDFs, etc. • All legal matters pertaining to permitting must be completed prior to any construction activity. • All necessary Water Use Licenses must be in order for any construction activities within close proximity to a watercourse, as well as any additional water uses as per Section 21 of the National Water Act. • All relevant permits must be obtained from the competent authority in order to remove/relocate any protected plant species. • All necessary permits must be in place prior to the removal/destruction of any potential heritage or paleontological resources found on site, should it be required. • Sensitive riparian areas must be designated as No-Go areas. • Wherever possible, construction activities must be undertaken during the driest part of the year to minimize downstream sedimentation due to excavation, etc. • A Stormwater Management Plan must be developed by a qualified engineer and implemented during the construction and operation phase of the estate.

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• Al necessary Water Use Licenses must be obtained prior to construction. The conditions contained within the Water Use license/s must be adhered to. • An Erosion Management Plan must be compiled during the planning and design phase, to be implemented during construction and operation of the proposed development • A Waste Management Plan must be compiled during the planning and design phase, to be implemented during construction and operation of the proposed development. • The sewage package system must be designed and implemented by a qualified engineer with input from geo- hydrologist, where required. • Sanitation systems must be located above 1:100-year flood line. • A water quality monitoring programme must be established to be implemented during the operation phase of the estate to ensure that the discharge treated effluent meets the required standards. • A Rehabilitation & Maintenance Plan must be compiled during the planning and design phase, to be implemented during the operational phase of the development. • The plan must detail measures that ensure the day-to-day operations of the development do not cause unnecessary degradation to the surrounding environment and to ensure on-going maintenance of all service infrastructure is undertaken a regular intervals to minimize risks to the surrounding environment. • The development footprint must be surveyed and demarcated prior to construction commencing to ensure that there is no unnecessary loss of natural vegetation outside the approved footprint. • The design and layout of the development and associated infrastructure must have as minimal impact on the natural vegetation as possible. • The placement of the estate buildings must be planned in such a way as to avoid intact thicket/bushland, as much as possible. • Service infrastructure must follow the road reserve, as much as practically possible. • A Rehabilitation Plan must be developed during the pre-construction to include details on rehabilitating disturbed natural areas once construction has been completed. • An ECO must be appointed pre-construction to ensure that the pre-construction requirements area adhered to, i.e. walkthroughs conducted, and management plans are developed. • A search and rescue walkthrough must be undertaken by a suitably qualified individual, pre-construction, to identify any potential plant SCC’s located within the surveyed construction footprint. This should ideally be undertaken with the ECO and Contractor/Developer present. • All relevant permits must be obtained from the competent authority prior to construction in order to remove/relocate any plant SCC’s. • A Conservation Management Plan must be developed for the Eco Estate by a suitably qualified individual, which must include addressing issues such as: • Identification of No-Go and sensitive areas, including the regulation of specific activities within such areas • Hunting • Inappropriate use of vehicles • Inappropriate stocking of game (e.g. overstocking and inappropriate species) • Introduction of dangerous animals • Types of vehicles that will be permitted in the conservation areas (i.e. of access roads) • Domestic pets • Alien species control and management • Fire control and veld burning

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• Fencing • Access control • Others • Having the remaining application area (particularly the portions towards the Great Kei River) proclaimed as a private nature reserve should be considered. • During the planning and design phase, an Alien Vegetation Management Plan must be complied to be implemented during construction and operation of the estate to reduce the establishment and spread of undesirable alien plant species. • The development will largely be visible to rural developments on the Transkei side of the Great Kei River and hidden from neighbouring farms. The design and construction of the development must therefore take into account the following: • Sighting and scale of structures: • Adopt appropriate environmentally and visually sensitive architectural and aesthetics code to limit visual intrusion of the built form. • Building heights for all clusters and lodges should preferably be restricted to single storey, and tucked into the landscape, to reduce the effect of ostentatious facades, given the visual exposure of the area. Exceptions may be necessary for focal buildings, or where space needs dictate. • The height of structures must be limited to a maximum of two stories where development will not intrude on the skyline. • Try and locate as many structures below the skyline. • Architectural guidelines must be formulated as to blend buildings into the landscape through selection of specific materials and colours. Natural materials should be adopted if possible (e.g. stone, wood, etc.) and roof and wall colours must be natural (greens, browns and greys) • Screening measures. Appropriate indigenous tree species must be planted to create visual screen for dwellings and other structures. • Articulated buildings should preferably be used to create smaller scale structures, rather than large rectangular volumes, to accommodate the sloping terrain, and minimise visual impact. • Building platforms should avoid excessive cut and fill, or stilts on steep slopes, as they create visual eyesores. Narrow structures can more easily step down the slope. No structures should be permitted on slopes steeper than 1:4 gradient. • Overhangs and verandahs could be used to visually scale down the height of buildings. Large windows in particular should be shaded by roof overhangs or pergolas. • Roof slopes should follow the slope of the natural terrain, and have consistent angles within each group of dwellings, to avoid visually discordant roof forms. • Sheltered internal courts could be used for outdoor living. Meadows and forest should ideally come right up to the buildings. • Fencing and walls between houses or properties must be avoided as this will result in a suburban effect with major visual consequences. Planted hedges and tree clumps using indigenous species could be used instead to provide privacy and wind shelter. • Clearing of indigenous vegetation must be limited (or prohibited altogether) to the building footprint. • Access roads must be kept as narrow as feasible, in order to minimize visual impact, and to minimise grading and cut slopes on the hillsides. Adopt concretised tracks rather than complete road excavation. • Road verges could have grassed swales for stormwater runoff in order to retain the rural character of the area. Urban engineering details, such a concrete barrier kerbs and stormwater channels should be avoided.

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• Roadway surfaces for minor access roads and parking areas could include alternative materials, such as brick, gravel and reinforced grass. • Hedgerows should be planted along both sides of access roads to screen the residential developments, and to minimise the effect of headlights from cars at night. • Large parking areas must be avoided because of their visual impact. • Lighting: All exterior lighting must be shaded and directed downwards. • Street lighting should be avoided to retain the natural / rural character of the area. Low-level bollard lights could be used close to buildings, in parking areas and along paths. All lighting should be fitted with reflectors to avoid light spillage and minimise visual impact of lights at night. • Signage should generally be avoided on access routes and on buildings, to minimise visual clutter. No commercial signage should be permitted. Information signs should have a distinctive colour and standard symbols, similar to those used by SANParks. Signs should be located against a backdrop to avoid silhouette effects on the skyline. Low signs tend to be less obtrusive in the landscape. • Utility lines should be located underground to minimise visual intrusion in the exposed landscape. Utility structures, including power lines, pylons and masts should be carefully sited to avoid intrusion on the skyline. • Satellite dishes and aerials must not protrude above the ridgeline of building roofs to minimise visual clutter in the landscape. • Informal landscape design should be used in preference to formal or geometric layouts. • Formal gardens or lawns should be avoided, and only locally occurring species should be used, given the context of the site adjacent to a national park. • Landscaping guidelines should be included in the Development Plan and Architectural Design Manual. A list of approved species should be included. Landscape plans are to be submitted with all building plans. • Homeowners Association (HOA) Agreement The above mitigation measures must be included in the Homeowners Agreement and the controls provided must be complied with. • A Traffic Management Plan must be compiled during the planning and design phase detailing appropriate mitigation measures for construction related traffic impacts. • Appropriate signage and traffic calming measures must be implemented, to ensure road users are aware of the possibility of construction vehicles turning off/onto the Kei Mouth road. • Any comments and/or instructions received from the Eastern Cape Provincial Heritage Resources Authority (ECPHRA) and the South African Heritage Resource Agency (SAHRA) must be taken into consideration prior and during construction. • All necessary permits must be in place prior to the removal/destruction of any potential heritage or paleontological resources, if found on site during the site walkthrough by the ECO. • Prior to construction, the ECO and contractor must be made aware of potential new fossil findings. They must familiarise themselves with the sort of fossils they may be found in this area. • Should any graves be located prior to construction, the area must be demarcated and considered a No-Go area. The local heritage authority must be notified. • A full grave relocation process must be followed in accordance with the applicable regulations, should this be required.

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CONSTRUCTION PHASE

• The developer must employ an independent Environmental Control Officer (ECO) for the construction phase to ensure that construction is implemented according to specifications in the EA and EMPr. Bi-weekly audits must be undertaken. • Copies of all applicable licenses, permits and managements plans (EA, EMPr, Water Use Licenses, Permits, etc.) must be available on-site at all times, and adhered to. • Environmental Awareness Training must be included in site meetings/talks with all workers, and all No-Go areas must be clearly communicated and demarcated. • No construction must occur within 100m from the 1:100-year floodline of the Great Kei River. • Wherever possible, construction activities must be undertaken during the driest part of the year to minimize downstream sedimentation due to excavation, etc. • When not possible, sediment traps must be used to ensure the watercourses are not negatively impacted by construction activity. • The construction within licensed watercourses must be done in a manner that is minimally invasive. • Construction activities must adhere to the conditions of the Water Use License • Roads which transverse watercourses must be installed with appropriately designed culvert structures. • Sediment traps must be used to ensure the watercourses are not negatively impacted by construction activity. • Topsoil which is excavated/removed during earthwork activities must be stockpiled on site for use during rehabilitation. • No construction material is to be stored within 50 m of a watercourse or wetland system. • Stockpiles must be monitored for erosion and mobilisation of materials towards watercourses. If this is noted by an ECO, suitable cut-off drains/berms/sediment traps must be placed between the stockpile area and the nearest watercourse. • The conditions set out in the Storm Water Management Plan and Erosion Management Plan must be implemented and adhered to. • The ECO must monitor for erosion and mobilization of sediment and recommend appropriate remedial action if required. • The conditions set out in the Waste Management Plan must be implemented and adhered to. • Construction rubble must be disposed of in predetermined, demarcated spoil dumps. • The ECO must monitor the Contractor campsite for litter and waste. • All waste must be stored on site in closed bins and removed from the site and transported to the closest licensed landfill site. • All No-Go areas, such as riparian areas, 100m inland from the 1:100-year floodline of the Great Kei River and 50 m buffers applied to the iCwili River and smaller tributaries within the study area, must be avoided during construction. • No development (other than authorised service infrastructure and the proposed dams) must occur within these no-go areas. • Where unavoidable (i.e. service infrastructure, water-crossings), construction must be done in a manner that is minimally invasive, i.e. labour intensive rather than heavy machinery. • The ECO must monitor construction activities undertaken within and near licensed water-crossings and ensure that no unnecessary vegetation clearing takes place. • Removal of the alien invasive vegetation must be prioritised.

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• Vehicles and machinery must not encroach into areas outside the surveyed/demarcated development footprint. • Areas within the construction footprint that have been cleared must be rehabilitated in terms of soil stabilisation and revegetation as soon as possible. • Should the ECO identify any SCC’s within the development footprint, these must be demarcated and avoided until the necessary permits are in place and relocated outside of the footprint area by a suitably qualified individual/botanist. • The contractor’s staff must not poach or trap wild animals or harvest any natural vegetation. • The land-use management recommendations of the ECBCP and GKLM SDF must be applied as much as possible. • No-Go areas, such as riparian zones, 100 m from the 1:100-year floodline of the Great Kei River and 50m from the smaller tributaries and intact thicket vegetation, must be kept free of direct and indirect impacts potentially resulting from the development. • The conditions set out in the Alien Vegetation and Rehabilitation Plan must be implemented and adhered to. • All temporarily cleared areas must be rehabilitated back to their original condition. • Only topsoil from the immediate area must be used for rehabilitation. • Where possible, individuals from the nearest local communities must be contracted for unskilled and semi-skilled employment. • Cleared surfaces must be dampened whenever possible, especially during dry and windy conditions, to avoid excessive dust generation. • Any complaints or claims emanating from dust issues must be attended to immediately and noted in the complaints register. • Construction activity close to residential settlements/BnBs, which includes the movement of construction vehicles, must be restricted to normal working hours (7:00am – 17:00pm). • There must be a complaints register on site for nearby residents to make complaints, if required. These must be addressed and recorded. • Construction of the development must be done in accordance with the approved architectural design and aesthetics code. • The site camp must be placed in an area that is not visually obtrusive to the neighbouring properties or local communities. • The site camp and temporary structures must be decommissioned, and the area rehabilitated once construction has been completed. • All waste, materials and equipment must be removed from site. • The project area is to be kept tidy and free of litter, where possible. • The contractor must ensure that operational firefighting equipment is present on site at all times as per Occupational Health and Safety Act. • All construction foremen 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. • No smoking near flammable substances. • All cooking must be done in demarcated areas considered safe in terms of runaway or uncontrolled fires. • The contractor must ensure that workers adhere to all safety regulations as per Occupational Health and Safety Act. • Appropriate PPE must be worn by workers at all time.

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• Regular training/talks must be given to all workers on site regarding safe working procedures. • Appropriate warning signs must be in place to notify the public regarding construction activities and any areas of high risk, i.e. open excavations. • The construction site and camp must have access control and be demarcated, where possible. • Open excavations must be appropriately demarcated, where possible. • Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used during the construction process. • The individual(s) that will be handling hazardous materials must be trained to do so. • All hazardous chemicals must be stored properly in a secure, bunded and contained area. • Concrete must not be mixed directly on the ground, or during rainfall events when the potential for transport to the stormwater system is the greatest. • Concrete must only be mixed in the area demarcated for this purpose and on an impermeable surface. • Oil trays must be placed under construction machinery to avoid soil contamination. • An oil absorbent materials/spill kit must be kept at the site camp in case of a spill. • Should a spill occur, the individual responsible for (or the individual who discovers the petrochemical spill) must report the incident to the Project Coordinator, ECO and/or Contractor as soon as reasonably possible. • The immediate response must be to contain the spill. • The ECO must determine the precise method of treatment of polluted soil. This could involve the application of oil absorbent materials or oil-digestive. • Adequate sanitary and ablutions facilities must be provided for construction workers. • No ablutions facilities are to be placed within 50m of a watercourse/tributary. • The facilities must be serviced regularly to reduce the risk of surface or groundwater pollution. • All wastewater from general activities in the camp must be collected and removed from the site for appropriate disposal at a licensed facility. • Where possible, individuals from the nearest local communities must be contracted for unskilled and semi-skilled employment. • Cleared surfaces must be dampened whenever possible, especially during dry and windy conditions, to avoid excessive dust generation. • Any soil excavated, and not utilised for rehabilitation, must be removed from site or covered and no large mounds of soil may be left behind after construction. • Construction activity close to residential settlements, which includes the movement of construction vehicles, must be restricted to normal working hours (7:00am – 17:00pm). • Construction of the development must be done in accordance with the approved architectural design and aesthetics code. • The site camp must be placed in an area that is not visually obtrusive to the neighbouring properties or local communities. • The site camp and temporary structures must be decommissioned and the area rehabilitated once construction has been completed. • All waste, materials and equipment must be removed from site. • The project area is to be kept tidy and free of litter, where possible. • The contractor must ensure that operational firefighting equipment is present on site at all times as per Occupational Health and Safety Act.

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• All construction foremen 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. • No smoking near flammable substances. • All cooking shall be done in demarcated areas considered safe in terms of runaway or uncontrolled fires. • The level of firefighting equipment must be assessed and evaluated thorough a typical risk assessment process. • The contractor must ensure that workers adhere to all safety regulations as per Occupational Health and Safety Act. • Appropriate PPE must be worn by workers at all time. • Regular training/talks must be given to all workers on site regarding safe working procedures. • Appropriate warning signs must be in place to notify the public regarding construction activities and any areas of high risk, i.e. open excavations. • The construction site and camp must have access control and be demarcated, where possible. • Open excavations must be appropriately demarcated, where possible. • Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used during the construction process. • The individual(s) that will be handling hazardous materials must be trained to do so. • All hazardous chemicals must be stored properly in a secure, bunded and contained area. • Concrete must not be mixed directly on the ground, or during rainfall events when the potential for transport to the stormwater system is the greatest. • Concrete must only be mixed in the area demarcated for this purpose and on an impermeable surface. • Oil trays must be placed under construction machinery to avoid soil contamination. • An oil absorbent materials/spill kit must be kept at the site camp in case of a spill. • Should a spill occur, the individual responsible for (or the individual who discovers the petrochemical spill) must report the incident to the Project Coordinator, ECO and/or Contractor as soon as reasonably possible. • The immediate response must be to contain the spill. • The ECO must determine the precise method of treatment of polluted soil. This could involve the application of oil absorbent materials or oil-digestive. • Adequate sanitary and ablutions facilities must be provided for construction workers. • No ablutions facilities are to be placed within 50m of a watercourse/tributary. • The facilities must be serviced regularly to reduce the risk of surface or groundwater pollution. • All wastewater from general activities in the camp must be collected and removed from the site for appropriate disposal at a licensed facility. • The conditions of the Traffic Management Plan must be implemented and adhered to. • Appropriate warning signs must be in place to notify the public regarding construction activities. • Construction vehicles are to adhere to traffic regulations. • Appropriate traffic safety measures, such as flagmen and speedbumps, must be used where deemed necessary. • Should any human graves be discovered during construction, these areas must be demarcated and considered no-go areas. • Should the graves have been discovered during excavation works, the relevant heritage authority and specialist must be notified, and their recommendations adhered to.

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• Provisions must be made for a Fossil Chance Find Protocol to be implemented during the construction phase should fossils be encountered.

OPERATIONAL PHASE

• The extraction volume from the natural drainage water course to supply the dams must not exceed 10% of the average annual minimum rainfall for the catchment area. • The extraction of water from the natural drainage course for storage in the two proposed dams must be monitored during times of low rainfall to ensure that the flow into the Great Kei River is not affected. • The conditions of the Storm Water Management Plan must be implemented and adhered to throughout the operational phase of the development. • Stormwater infrastructure must be monitored and maintained post construction to ensure that the receiving environment, particularly sensitive riparian areas are not negatively affected. • The conditions of the Waste Management Plan must be implemented and adhered to throughout the operation of the development. • The Home Owners Association must ensure that waste is handled and disposed of in environmentally acceptable manners. • No waste must be disposed of on site. Waste must be removed from site regularly and disposed of at the nearest licensed waste facility. Where possible, provisions for waste recycling must be made available. • The Waste Management Plan must include: • A maintenance plan, undertaken by a suitably qualified individual, to ensure the sewage treatment facility is running well. Regular monitoring and inspection of sanitation systems must include: Fat traps, Evidence of system over flows, Inappropriate odours, and Leaching around dispersal fields. • An appropriate water quality monitoring programme for the sewage package plant in accordance with the conditions of the water use license. • Include regular monitoring and inspection of sanitation systems including: o Fat traps o Evidence of system over flows o Inappropriate odours o Leaching around dispersal fields • Educational materials must be disseminated to households on how to properly maintain sanitation systems. • The conditions of the Rehabilitation and Maintenance Plan must be implemented and adhered to throughout the operational phase of the project. • In particular, the sewage reticulation and associated infrastructure must undergo regular monitoring and serviced when required to minimize the risk of site contamination. • The land-use guidelines and principles of the ECBCP and GKLM SDF must be included in the Home Owners Agreement. All applicable management plans must be implemented and included in Home Owners Agreement, ie.: • Operational Environmental Management Programme (EMPr) • Stormwater Management Plan; • Erosion Management Plan; • Waste management Plan;

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• Traffic Management Plan; • Conservation Management Plan; • Environmental Monitoring Programme (water quality); • Alien Species Management Plan; and • Rehabilitation and Maintenance Plan • The Alien Vegetation Management Plan must be included as part of the developments on-going maintenance plan to reduce the establishment and spread of undesirable alien plant species throughout the operational phase. Indigenous species must be prioritized for use within the estate. • Where possible, individuals from the nearest local communities must be contracted for unskilled and semi-skilled employment. • Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used during the operation of the development. • All hazardous chemicals must be stored properly in a secure, bunded and contained area. • The Home Owners Association must have appropriate emergency response procedures in place to deal with possible spills. • The Home Owners Agreement must clearly detail all activities/hazardous substances which area prohibited. • The Home Owners Association must ensure all occupants are considerate of neighbouring properties when using local access roads. Provisions for a grievance procedure must be ncorporated into the Home Owners Agreement. • Road infrastructure must be maintained, when required.

www.dedea.gov.za SECTION F: APPENDICES

The following appendixes must be attached as appropriate:

Appendix A: Site plan(s)

Appendix B: Photographs

Appendix C: Facility illustration(s)

Appendix D: Specialist reports

• Ecological Impact Assessment

Appendix E: Public Participation proof:

• E1: Proof of WULA pre-consultation with DWS • E2: Initial notifications • E3: Comments and Response Report • E4: Stakeholder database

Appendix F: Draft Environmental Management Programme (EMPr)

Appendix G: Impact Assessment Methodology

Appendix H: Other Information:

• H1 Summary of Great Kei Local Municipality’s SDF Environmental Guidelines for spatial planning • H2: Mango Grove Eco-Estate and Conservancy Environmental Authorisation • H3: Preliminary Bulk Services Engineering Report : Preliminary Potable Water Supply Technical Report : Preliminary Effluent Treatment Plant Technical Report • H4: Rezoning Application Approval