Appendix A: Curriculum Vitae

APPENDIX A: CURRICULUM VITAE Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Curriculum Vitae: Minnelise Levendal – Environmental Assessment Practitioner

Name of firm: CSIR Name of staff Minnelise Rouchelle-Ann Levendal Profession: Environmental Assessment Practitioner/Project Manager Position in firm: Senior Environmental Assessment Practitioner Years’ experience: 18 years Nationality: South African Languages: Afrikaans and English Affiliation: SACNASP Registered Professional Natural Scientist (Registration Number: 117078)

1. BIO-SKETCH:

Minnelise has more than 15 years of experience in environmental assessment and management, and is a Senior Environmental Assessment Practitioner (EAP) in the Environmental Management Services (EMS) group of the CSIR in Stellenbosch. She is a Registered Professional Natural Scientist (Registration Number: 117078) with the South African Council for Natural Scientific Professions (SACNASP). Minnelise has experience in the management and integration of various types of environmental assessments in South Africa for various sectors, including renewable energy and industry. Minnelise has undertaken several Environmental Assessments for wind farms and solar PV farms (i.e. EIAs, BAs, and Amendment and Appeal Processes) in the Northern Cape, Western Cape and Eastern Cape. Minnelise is currently the project leader for the Amendment processes for the adjacent Sutherland, Sutherland 2, and Rietrug WEFs, which received positive Environmental Assessments.

A list of projects she had undertaken is provided below.

2. EDUCATION . M.Sc. (Botany) Stellenbosch University 1998 . B.Sc. (Hons.) (Botany) University of the Western Cape 1994 . B.Sc. (Education) University of the Western Cape 1993

3. PROFESSIONAL REGISTRATIONS / MEMBERSHIPS . International Association for Impact Assessment (IAIA), Western Cape (member of their steering committee from 2001-2002). . Professional Natural Scientist (Pr.Sci.Nat) – 117078)

4. EMPLOYMENT RECORD

Name of current employer Position From To CSIR Senior Environmental Assessment 2006 Present (Environmental Management Services- Practitioner EMS)

Appendix A – EAP CVs and Declaration of Independence Page 1 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

CSIR Environmental Researcher 2004 2006 (Natural Resources and the Environment)

Western Cape Department of Assistant Director 2003 2004 Environmental Affairs and Development Principal Environmental Officer 2002 2003 Planning (DEA&DP) Principal Environmental Officer 2002 2003

Senior Environmental Officer 2001 2002

Environmental Officer 1999 2000 University of the Western Cape Junior Lecturer 1996 1996 Cape Peninsula University of Technology Junior Lecturer 1995 1995

5. KEY COURSES

 Public Participation in Environmental Authorisation in South Africa: IAIA workshop presented by Tisha Greyling and Erika Du Plessis (2016).  Environmental Law: Shepstone Wylie Attorneys; Presented by Janice Tooley (2015).  Sharpening the Tool: New techniques and methods in Environmental Impact Assessment: Sustainable Environmental Solutions (Pty) Ltd (2015).  Effective Skills for Challenging Meetings & Engagements: Conflict Dynamics (2015).  Science Communication and Working with the Media: Proof Communications/Jive Media Africa (2014).  Leadership, Innovation and Change Management: University of Stellenbosch (Business School) (2013).  MS Project: CILLA (2011).  Project Management I and II: CILLA (2005)  Social Impact Assessment: IAIA workshop (2002)  Environmental Law (“The New Environmental Law Course for Environmental Managers): University of Potchefstroom: Center for Environmental Management) (2002).  Implementing Environmental Management Systems (SABS/ISO 14001:1996): University of Potchefstroom: Center for Environmental Management (2002).  Conflict Management in Environmental Issues: University of Potchefstroom: Center for Environmental Management) (2001).

6. PROJECT EXPERIENCE RECORD The following table presents a list of key projects undertaken by Minnelise Levendal at the CSIR to date, as well as the role played in each project:

Environmental Impact Assessment (EIAs) and Basic Assessments (BAs)-including their respective Environmental Management Programmes (EMPRs):

Completion Project description Role Client Date 2019 Substantive Amendment Project juwi Renewable Energies (Pty) Ltd

Appendix A – EAP CVs and Declaration of Independence Page 2 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Completion Project description Role Client Date Application for the proposed Leader and Kap Vley Wind Energy Facility EAP near Kleinzee in the Northern Cape 2019 Amendment Application for the Project Mulilo Renewable Project Developments proposed Kuruman Phase 1 Leader and (Pty) Ltd Wind Energy Facility near EAP Kuruman in the Northern Cape 2019 Amendment Application for the Project Mulilo Renewable Project Developments proposed Kuruman Phase 2 Leader and (Pty Ltd Wind Energy Facility near EAP Kuruman in the Northern Cape 2019 Substantive Amendment Project juwi Renewable Energies (Pty) Ltd Application for the proposed Leader and Kap Vley Wind Energy Facility EAP near Kleinzee in the Northern Cape 2019 Substantive Amendment Project South Africa Mainstream Renewable Power Application for the proposed Leader and Developments (Pty) Ltd Rietrug Wind Energy Facility EAP near Sutherland in the Northern Cape 2019 Substantive Amendment Project South Africa Mainstream Renewable Power Application for the proposed Leader and Developments (Pty) Ltd Sutherland Wind Energy EAP Facility near Sutherland in the Northern and Western Cape 2019 Substantive Amendment Project South Africa Mainstream Renewable Power Application for the proposed Leader and Developments (Pty) Ltd Sutherland 2 Wind Energy EAP Facility near Sutherland in the Northern Cape 2019 BA for the proposed Gromis Project ENERTRAG South Africa (Pty) Ltd wind farm near Kleinzee in the Leader and Northern Cape EAP 2019 BA for the proposed Komas Project ENERTRAG South Africa (Pty) Ltd wind farm near Kleinzee in the Leader and Northern Cape EAP 2019 BA for the proposed electrical Project ENERTRAG South Africa (Pty) Ltd infrastructure for the Gromis Leader and wind farm near Kleinzee in the EAP Northern Cape 2019 BA for the proposed electrical Project ENERTRAG South Africa (Pty) Ltd infrastructure for the Komas Leader and wind farm near Kleinzee in the EAP Northern Cape 2018-2019 BA for the proposed Kudusberg Project G7 Renewable Energies (Pty) Ltd WEF near Sutherland in the Leader and Northern and Western Cape EAP 2017-2018 EIA for the proposed Kap Vley Project juwi Renewable Energies (Pty) Ltd

Appendix A – EAP CVs and Declaration of Independence Page 3 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Completion Project description Role Client Date Wind Energy Facility near Leader and Kleinzee in the Northern Cape EAP 2018 BA for the proposed electrical Project juwi Renewable Energies (Pty) Ltd infrastructure to support he Leader and proposed Kap Vley Wind Energy EAP Facility near Kleinzee in the Northern Cape 2015-2016 EIA for the Gemsbok Solar Project Mulilo Renewable Project Developments Photovoltaic (PV) 3 near Manager and Kenhardt in the Northern Cape EAP

2015-2016 EIA for the Gemsbok Solar PV 4 Project Mulilo Renewable Project Developments near Kenhardt in the Northern Manager and Cape EAP

2015-2016 EIA for the Gemsbok Solar PV 5 Project Mulilo Renewable Project Developments near Kenhardt in the Northern Manager and Cape EAP

2015-2016 EIA for the Gemsbok Solar PV 6 Project Mulilo Renewable Project Developments near Kenhardt in the Northern Manager and Cape EAP

2015-2016 EIA for the Boven Solar PV 2 Project Mulilo Renewable Project Developments near Kenhardt in the Northern Manager and Cape EAP

2015-2016 EIA for the Boven Solar PV 3 Project Mulilo Renewable Project Developments near Kenhardt in the Northern Manager and Cape EAP

2015-2016 EIA for the Boven Solar PV 4 Project Mulilo Renewable Project Developments near Kenhardt in the Northern Manager and Cape EAP

2010-2011 EIA for the proposed Ubuntu Project WKN Windkraft SA wind energy project, Eastern Manager Cape 2010-2011 EIA for the proposed Banna Ba Project WKN Windkraft SA Pifhu wind energy project, Manager Eastern Cape 2010-2011 BA for a powerline for a WEF Project BioTherm Energy (Pty Ltd near Swellendam in the Manager Western Cape 2010-2011 EIA for a proposed wind farm Project BioTherm Energy (Pty Ltd near Swellendam in the Manager Western Cape 2010 Basic Assessment for the Project BioTherm Energy (Pty Ltd erection of two wind Manager monitoring masts near Swellendam and Bredasdorp in the Western Cape 2010 Basic Assessment for the Project Windcurrent (Pty Ltd

Appendix A – EAP CVs and Declaration of Independence Page 4 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Completion Project description Role Client Date erection of two wind Manager monitoring masts near Jeffrey’s Bay in the Eastern Cape 2009-2010 Basic Assessment Process for Project Department of Energy through SANERI; GEF the proposed erection of 10 Manager wind monitoring masts in SA as part of the national wind atlas project 2009 Basic Assessment Report for a Project Transnet Ltd proposed boundary wall at the Manager Port of Port Elizabeth, Eastern Cape

Other Environmental Assessments, Strategies, Biodiversity Management Plans, Frameworks and Reporting tools: 2014-2018 Special Needs and Skills Project DEA Development Programme Leader 2013-2014 Development of a National Project DEA Management Plan and Strategy Manager for Invasive Alien species 2012-2014 Development of a Biodiversity Project DEA Management Plan for the Manager African Lion (Panthera leo) 2010 South Africa’s Second National Project SANBI Communication under the Manager United Nations Framework Convention on Climate Change 2008 The development of protocols Project DEA for the monitoring and manager evaluation of benefits arising from the Working for Water Programme (2008). 2006-2008 Monitoring and Evaluation of Project Internal project awarded through the Young aspects of Biodiversity Leader Researchers Fund 2006 Integrated veldfire Co- author Working on Fire management in South Africa. An assessment of current conditions and future approaches. 2004-2005 Biodiversity Strategy and Action Co-author Wilderness Foundation Plan Wild Coast, Eastern Cape, SA 2005 Western Cape State of the Co- author Department of Environmental Affairs and Environment Report: and Project Development Planning Biodiversity section. (Year One). Manager

7. AWARDS

 2008: Best presentation Award at Arid Zone Conference (Northern Cape)  2015: CSIR award for Human Capital Development: Special Needs and Skills Development Programme

Appendix A – EAP CVs and Declaration of Independence Page 5 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

8. CONFERENCE PRESENTATIONS & PAPERS

 Levendal, M. (2012). “Challenges in the Environmental Assessment of Renewable Energy Projects in South Africa” In IAIA (Portugal) Conference Proceedings.  Bowie, M. (néé Levendal) (1998). “Ecophysiological responses of four succulent Karoo species under different temperature and water regimes.” In Arid Zone Conference (Northern Cape) Conference Proceedings.

9. PUBLICATIONS

 Bowie, M. (néé Levendal) and Ward, D. (2004). Water status of the mistletoe Plicosepalus acaciae parasitic on isolated Negev Desert populations of Acacia raddiana differing in level of mortality. Journal of Arid Environments 56: 487-508.  Wand, S.J.E., Esler, K.J. and Bowie, M.R (2001). Seasonal photosynthetic temperature responses and changes in 13C under varying temperature regimes in leaf-succulent and drought-deciduous shrubs from the Succulent Karoo, South Africa. South African Journal of Botany 67:235-243.  Bowie, M.R., Wand, S.J.E. and Esler, K.J. (2000). Seasonal gas exchange responses under three different temperature treatments in a leaf-succulent and a drought-deciduous shrub from the Succulent Karoo. South African Journal of Botany 66:118-123.

10. LANGUAGE CAPABILITY

Language Speaking Reading Writing English Excellent Excellent Excellent Afrikaans Excellent Excellent Excellent

Minnelise Levendal

October 2019

Appendix A – EAP CVs and Declaration of Independence Page 6

APPENDIX B: PUBLIC PARTICIPATION PROCESS Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Appendix B.1: Newspaper Advertisements ______2 Appendix B.2 Site Notice Boards ______5 Appendix B.3 Letter from the national Department of Environment, Forestry and Fisheries (DEFF) ______8

Appendix B, Page 1 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Appendix B.1: Newspaper Advertisements

Text included in the Newspaper Advertisements – “Die Plattelander” (English and Afrikaans)

Note: The actual advertisements will be included in the Final Amendment Report that will be submitted to the national Department of Environment, Forestry and Fisheries (DEFF) for decision-making.

Advertisements: English and Afrikaans

Appendix B, Page 2 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

NOTIFICATION OF APPLICATION FOR SUBSTANTIVE AMENDMENT TO THE ENVIRONMENTAL AUTHORISATION ISSUED FOR THE PROPOSED KAP VLEY WIND ENERGY FACILITY, NEAR KLEINZEE IN THE NORTHERN CAPE PROVINCE AND THE RELEASE OF THE DRAFT AMENDMENT REPORT FOR COMMENT.

DEA REFERENCE NUMBER: 14/12/16/3/3/2/1046/AM1

Juwi Renewable Energies (Pty) Ltd (herein-after referred to as “juwi”), through its project company Kap Vley Wind Farm (Pty) Ltd, received Environmental Authorisation (EA) dated 25 October 2018 to construct and operate the proposed Kap Vley Wind Energy Facility (WEF) approximately 30 km south-east of Kleinzee in the Northern Cape. The EA was received from the National Department of Environmental Affairs (DEA) (now operating as the Department of Environment, Forestry and Fisheries (DEFF).

The proposed Kap Vley WEF falls within the Renewable Energy Development Zone (REDZ) 8: Springbok and is therefore aligned with national planning initiatives. It will be developed on the following land portions:

• Remainder (RE) Kamaggas Farm 200 Portion 5; • RE Kap Vley Farm 315; • Portion 1 of Kap Vley Farm 315; • Portion 2 of Kap Vley Farm 315, • Portion 3 of Kap Vley Farm 315; • Portion 3 of Platvley Farm 314; • RE Kourootjie Farm 316; and • RE Gra’water Farm 331.

Notice is hereby given in terms of Regulation 41 of the 2014 Environmental Impact Assessment (EIA) Regulations, as amended of the National Environmental Management Act (Act 107 of 1998), as amended, (NEMA) that an application for an amendment to the EA of the proposed Kap Vley WEF was submitted to the DEFF. The proposed amendment constitutes a substantive Amendment in terms of Regulation 31 of the 2014 NEMA EIA Regulations, as amended, and the required process in terms of Regulations 32-33 of the said Regulations will be followed.

The applicant is applying for the following amendments to the EA:

1. An increase from the authorised rotor diameter range from 100 m to 160 m to 100 m to 200 m. 2. To amend the name and contact details of the holder of the EA.

Notice is further given that a Draft Amendment Report has been prepared and is currently being released for a 30-day commenting period extending to 19 November 2019. You are kindly requested to submit any comments you may have on the Draft Amendment Report to the CSIR on or before this date using the contact details provided below. A hard copy of the report is available at the Kleinzee Public Library. The report can also be downloaded from the following website (https://www.csir.co.za/environmental-impact-assessment). Comments received during the commenting period will be recorded and addressed (as applicable) in the Final Amendment Report that will be submitted to DEFF for decision-making.

Should you be interested in registering as an Interested and/or Affected Party (I&AP) and to provide comments on the Draft Amendment Report, you are kindly requested to e-mail, fax or mail your name contact details, and comments to the Environmental Assessment Practitioner (EAP) at CSIR: Minnelise Levendal; Postal address: PO Box 320, Stellenbosch, 7599; Fax: 021 888 2693 or e-mail: [email protected]

Appendix B, Page 3 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

KENNISGEWING VAN AANSOEK OM WYSIGINGS AAN DIE OMGEWINGSMAGTIGING UITGEREIK VIR DIE VOORGESTELDE KAP VLEY WINDKRAGAANLEG, NABY KLEINZEE IN DIE NOORD- KAAP PROVINSIE EN DIE VRYSTELLING VAN DIE KONSEP WYSIGINGSVERSLAG VIR KOMMENTAAR.

DOS VERWYSINGSNOMMER: 14/12/16/3/3/2/1046/AM1

“Juwi Renewable Energies (Pty) Ltd” (hierna verwys na as “juwi),” deur hul projekonderneming Kap Vley (Pty) Ltd, het Omgewingsmagtiging gedateer 25 Oktober 2018 ontvang vir die ontwikkeling en bestuur van die voorgestelde Kap Vley windkragaanleg ongeveer 30 km suid- oos vanaf Kleinzee in die Noord Kaap provinsie. Hierdie Omgewingsmagtiging was ontvang vanaf die Nasionale Departement van Omgewingsake (DOS), wat nou bedryf word as die Nasionale Departement van Omgewingsake, Bosbou en Visserye [“National Department of Environment, Forestry and Fisheries (DEFF)”].

Die voorgestelde Kap Vley windkragaanleg is geleë binne die Hernubare Ontwikkelingsone (“REDZ”) 8: Springbok en is daarom in oorstemming met nasionale beplanningsbeleid. Dit gaan opgerig word op die volgende plase:

• Restant (RES) Kamaggas Plaas 200 Gedeelte 5; • RES Kap Vley Plaas 315; • Gedeelte 1 of Kap Vley Plaas 315; • Gedeelte 2 of Kap Vley Plaas 315, • Gedeelte 3 of Kap Vley Plaas 315; • Gedeelte 3 of Platvley Plaas 314; • RES Kourootjie Plaas 316; en • RES Gra’water Plaas 331.

Kennis word hiermee gegee ingevolge Regulasie 41 van die Nasionale Omgewingsbestuurswet (Wet 107 van 1998, soos gewysig) (NEMA) en die 2014 NEMA Omgewingsimpakstudie Regulasies, soos gewysig, van ‘n aansoek om wysiging aan die Omgewingsmagtiging vir die voorgestelde Kap Vley windkragaanleg wat ingedien was aan DEFF. Die wysiging behels ‘n Materiële Wysiging in terme van Regulasie 31 van die 2014 NEMA Omgewingsimpakstudie Regulasies, soos gewysig, en die vereiste proses in terme van Regulasies 32-33 van die genoemde Regulasies sal gevolg word. Juwi doen aansoek om die volgende wysigings aan die Omgewingsmagtiging:

1. ‘n Toename in die goedgekeurde rotor deursneë vanaf 100 m tot 160 m na ‘n maksimum van 100 m tot 200 m. 2. Om die kontak persoon en kontakbesonderhede van die houer van die Omgewingsmagtiging te verander.

Kennis word verder gegee dat ‘n konsep Wysigingsverslag opgestel en tans vrygestel word vir ‘n 30-dae kommentaar periode wat strek tot en met 19 November 2019. U word vriendelik versoek om enige kommentaar wat u mag hê op die konsep Wysigingsverslag in te dien aan die Wetenskaplike Nywerheid en Navorsingsraad (WNNR) ook bekend as die “CSIR” voor of op hierdie datum. ‘n Afskrif van die konsep Wysigingverslag is beskikbaar vir besigtiging by die Kleinzee Openbare Biblioteek. Die verslag kan ook afgelaai word vanaf die volgende webtuiste (https://www.csir.co.za/environmental-impact-assessment). Kommentaar wat ontvang gaan word gedurende hierdie kommentaar periode gaan ingesluit en geadresseer word (waar van toepassing) in die finale Wysigingverslag wat ingedien gaan word by DEFF vir besluitneming.

Sou u belangstel om te registreer as ‘n Geïnteresseerde en/of Belanghebbende Party (G&BP), en om kommentaar op die konsep Wysigingsverslag in te dien word u vriendelik versoek om u naam, kontakbesonderhede en kommentaar te stuur aan die Omgewingsimpakpraktisyn by die WNNR: Minnelise Levendal; Posadres: Posbus 320, Stellenbosch, 7599; Tel: 021 888 2495; Faks: 021 888 2693 of e-pos: [email protected]

Appendix B, Page 4 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Appendix B.2 Site Notice Boards

Text included in the Site Notice Boards: English and Afrikaans

Note: Photos of the site notice boards will be included in the Final Amendment Report that will be submitted to DEFF for decision-making.

Appendix B, Page 5 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Appendix B, Page 6 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Appendix B, Page 7 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Appendix B.3 Letter from the national Department of Environment, Forestry and Fisheries (DEFF)

Appendix B, Page 8 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

Appendix B, Page 9 APPENDIX C: ASSESSMENT METHODOLGY Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

APPROACH TO THE IMPACT ASSESSMENT AND SPECIALIST STUDIES

This section outlines the assessment methodology for specialist studies that was used by the specialists in the original EIA (CSIR, 2018) as well as in the current Amendment Report, as recommended by the DEA 2006 Guideline on Assessment of Impacts. The impact assessment tables are included in section D of the Draft Amendment Report.

. Generic Terms of Reference for the Assessment of Potential Impacts

The identification of potential impacts should include impacts that may occur during the construction, operational and decommissioning phases of the development. The assessment of impacts is to include direct, indirect as well as cumulative impacts. In order to identify potential impacts (both positive and negative) it is important that the nature of the proposed projects is well understood so that the impacts associated with the projects can be assessed. The process of identification and assessment of impacts will include:

 Determining the current environmental conditions in sufficient detail so that there is a baseline against which impacts can be identified and measured;  Determining future changes to the environment that will occur if the activity does not proceed;  Develop an understanding of the activity in sufficient detail to understand its consequences; and  The identification of significant impacts which are likely to occur if the activity is undertaken.

The impact assessment methodology has been aligned with the requirements for EIA Report as stipulated in Appendix 3 (3) (j) of the 2014 EIA Regulations, as amended, which state the following:

. An EIA Report must contain the information that is necessary for the CA to consider and come to a decision on the application, and must include an assessment of each identified potentially significant impact and risk, including - o (i) cumulative impacts; o (ii) the nature, significance and consequences of the impact and risk; o (iii) the extent and duration of the impact and risk; o (iv) the probability of the impact and risk occurring; o (v) the degree to which the impact and risk can be reversed; o (vi) the degree to which the impact and risk may cause irreplaceable loss of resources; and o (vii) the degree to which the impact and risk can be mitigated. As per the DEAT Guideline 5: Assessment of Alternatives and Impacts the following methodology is to be applied to the predication and assessment of impacts. Potential impacts should be rated in terms of the direct, indirect and cumulative:

. Direct impacts are impacts that are caused directly by the activity and generally occur at the same time and at the place of the activity. These impacts are usually associated with the construction, operation or maintenance of an activity and are generally obvious and quantifiable.

. Indirect impacts of an activity are indirect or induced changes that may occur as a result of the activity. These types of impacts include all the potential impacts that do not manifest immediately when the activity is undertaken or which occur at a different place as a result of the activity.

Appendix A – Methodology for the impact assessment as well as the impact assessment for the original EA Page 1 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

. Cumulative impacts are impacts that result from the incremental impact of the proposed activity on a common resource when added to the impacts of other past, present or reasonably foreseeable future activities. The cumulative impacts were assessed by identifying other wind and solar energy project proposals and other applicable projects, such as construction and upgrade of electricity generation, and transmission or distribution facilities in the local area (i.e. within 50 km of the proposed Kap Vley WEF) that have been approved (i.e. positive EA has been issued) or is currently underway. The proposed and existing relevant projects that were considered as part of the cumulative impacts in the EIA Phase are provided in Chapter 6 of this Updated Draft EIA Report.

In addition to the above, the impact assessment methodology includes the following aspects:

. Spatial extent – The size of the area that will be affected by the impact/risk:  Site specific;  Local (<10 km from site);  Regional (<100 km of site);  National; or  International (e.g. Greenhouse Gas emissions or migrant birds).

. Consequence – The anticipated consequence of the risk/impact:  Extreme (extreme alteration of natural systems, patterns or processes, i.e. where environmental functions and processes are altered such that they permanently cease);  Severe (severe alteration of natural systems, patterns or processes, i.e. where environmental functions and processes are altered such that they temporarily or permanently cease);  Substantial (substantial alteration of natural systems, patterns or processes, i.e. where environmental functions and processes are altered such that they temporarily or permanently cease);  Moderate (notable alteration of natural systems, patterns or processes, i.e. where the environment continues to function but in a modified manner); or  Slight (negligible alteration of natural systems, patterns or processes, i.e. where no natural systems/environmental functions, patterns, or processes are affected).

. Duration – The timeframe during which the impact/risk will be experienced:  Very short term (instantaneous);  Short term (less than 1 year);  Medium term (1 to 10 years);  Long term (the impact will cease after the operational life of the activity (i.e. the impact or risk will occur for the project duration)); or  Permanent (mitigation will not occur in such a way or in such a time span that the impact can be considered transient (i.e. the impact will occur beyond the project decommissioning)). . Reversibility of the Impacts - the extent to which the impacts/risks are reversible assuming that the project has reached the end of its life cycle (decommissioning phase) will be:  Yes: High reversibility of impacts (impact is highly reversible at end of project life);  Partially: Moderate reversibility of impacts; or  No: Impacts are non-reversible (impact is permanent).

. Irreplaceability of Receiving Environment/Resource Loss caused by impacts/risks – the degree to which the impact causes irreplaceable loss of resources assuming that the project has reached the end of its life cycle (decommissioning phase) will be:  High irreplaceability of resources (project will destroy unique resources that cannot be replaced);  Moderate irreplaceability of resources;  Low irreplaceability of resources; or

Appendix A – Methodology for the impact assessment as well as the impact assessment for the original EA Page 2 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

 Resources are replaceable (the affected resource is easy to replace/rehabilitate).

Using the criteria above, the impacts will further be assessed in terms of the following:

. Probability – The probability of the impact/risk occurring:  Very likely;  Likely;  Unlikely;  Very unlikely; and  Extremely unlikely.

To determine the significance of the identified impact/risk, the consequence is multiplied by probability (as shown in Figure 1). This approach incorporates internationally recognised methods from the IPCC (2014) assessment of the effects of climate change and is based on an interpretation of existing information in relation to the proposed activity. The significance is then rated qualitatively as follows against a predefined set of criteria (i.e. probability and consequence) as indicated in Figure 1:

Figure 1: Guide to assessing risk/impact significance as a result of consequence and probability.

. Significance – Will the impact cause a notable alteration of the environment?  Very low (the risk/impact may result in very minor alterations of the environment and can be easily avoided by implementing appropriate mitigation measures, and will not have an influence on decision-making);  Low (the risk/impact may result in minor alterations of the environment and can be easily avoided by implementing appropriate mitigation measures, and will not have an influence on decision-making);  Moderate (the risk/impact will result in moderate alteration of the environment and can be reduced or avoided by implementing the appropriate mitigation measures, and will only have an influence on the decision-making if not mitigated);

Appendix A – Methodology for the impact assessment as well as the impact assessment for the original EA Page 3 Amendment Report for the Application of a Substantive Amendment to the Environmental Authorisation issued for the development of the Kap Vley Wind Energy Facility, Kleinzee, Northern Cape Province

 High (the risk/impact will result in major alteration to the environment even with the implementation on the appropriate mitigation measures and will have an influence on decision- making); and  Very high (the risk/impact will result in very major alteration to the environment even with the implementation on the appropriate mitigation measures and will have an influence on decision- making (i.e. the project cannot be authorised unless major changes to the engineering design are carried out to reduce the significance rating)).

With the implementation of mitigation measures, the residual impacts/risks will be ranked as follows in terms of significance (based on Figure 1):  Very low = 5;  Low = 4;  Moderate = 3;  High = 2; and  Very high = 1.

. Status - Whether the impact/risk on the overall environment will be:  Positive - environment overall will benefit from the impact/risk;  Negative - environment overall will be adversely affected by the impact/risk; or  Neutral - environment overall not be affected.

. Confidence – The degree of confidence in predictions based on available information and specialist knowledge:  Low;  Medium; or  High.

Impacts will then be collated into the EMPr and these will include the following: . Quantifiable standards for measuring and monitoring mitigatory measures and enhancements will be set. This will include a programme for monitoring and reviewing the recommendations to ensure their ongoing effectiveness. . Identifying negative impacts and prescribing mitigation measures to avoid or reduce negative impacts. Where no mitigatory measures are possible this will be stated. . Positive impacts will be identified and augmentation measures will be identified to potentially enhance positive impacts where possible.

Other aspects to be taken into consideration in the assessment of impact significance are: . Impacts will be evaluated for the construction and operation phases of the development. The assessment of impacts for the decommissioning phase will be brief, as there is limited understanding at this stage of what this might entail. The relevant rehabilitation guidelines and legal requirements applicable at the time will need to be applied; . Impacts will be evaluated with and without mitigation in order to determine the effectiveness of mitigation measures on reducing the significance of a particular impact; . The impact evaluation will, where possible, take into consideration the cumulative effects associated with this and other facilities/projects which are either developed or in the process of being developed in the local area; and . The impact assessment will attempt to quantify the magnitude of potential impacts (direct and cumulative effects) and outline the rationale used. Where appropriate, national standards are to be used as a measure of the level of impact.

Appendix A – Methodology for the impact assessment as well as the impact assessment for the original EA Page 4 APPENDIX D : SPECIALIST INPUTS AND DECLARATIONS OF INDEPENDENCE

APPENDIX D. 1: AVIFAUNA

Steyn Devos juwi Renewable Energies (Pty) Ltd By email: [email protected] 13 August 2019 Dear Steyn,

RE: Avifaunal specialist comment with regards to proposed turbine dimension changes for the authorised Kap Vley Wind Energy Facility (WEF). juwi Renewable Energies (Pty) Ltd (‘juwi’) are proposing to develop the Kap Vley Wind Energy Facility (WEF) on a site approximately 35 km south east of Kleinzee, in the Northern Cape Province (‘the WEF site’). Arcus Consultancy Services South Africa (Pty) Limited (‘Arcus’) conducted the avifaunal specialist studies for the Final Environmental Impact Assessment Report (FEIAR), and the project obtained Environmental Authorisation (EA) in 2018. The applicant is submitting an amendment application to change the rotor diameter from the authorised maximum 160 m to maximum 200 m. The specialist letter will aim to clarify whether the proposed change will:  Increase the significance of impacts originally identified in the EIA report or lead to any additional impacts; or  Have a zero or negligible effect on the significance of impacts identified in the EIA report; or  Lead to a reduction in any of the identified impacts in the EIA report. This letter does not address the grid connection line connecting Kap Vley WEF to the Eskom Gromis Substation. The assessment and mitigation as proposed in Avifaunal Specialist Report (Arcus 2018), still apply.

Literature Review It is widely accepted that WEFs can have a negative impact on avifauna, including fatalities caused by turbine collision. The magnitude of impacts has varied considerably between different wind farms and across different countries. Studies in America (NWCC, 2010) have indicated that relatively low raptor (e.g., hawks, eagles) fatality rates exist at most wind energy developments with the exception of some facilities in parts of California. All developments studied have reported fewer than 14 bird (all species combined) fatalities per MW per year, and most have reported less than 4 fatalities per MW per year (NWCC, 2010). Drewitt & Langston (2006) conducted a literature review and found that where bird collisions have been recorded, the rates per turbine are highly variable with averages ranging from 0.01 to 23 bird collisions annually. The wind energy industry in South Africa is relatively new, however a recent review of the impacts from the first few years of operational monitoring at eight wind farms (Ralston-Paton et al., 2017) found that the average estimated fatality rate at the wind farms ranged from 2.06 to 8.95 birds per turbine per year. The mean fatality rate was 4.1 birds per turbine per year. Unfortunately, the review did not investigate the possible influence of different WTG specifications and dimensions across the WEFs. Large turbines are more efficient, therefore most modern wind developments have fewer turbines with wider spacing for a given number of megawatts. However, wider and longer blades produce greater vortices and turbulence in their wake as they rotate, posing a potential problem for bats (and some birds). NWCC, 2010 explains that larger turbines have fewer rotations per minute but have similar blade tip speeds compared to the smaller turbines commonly used in older wind facilities. It is believed this difference may be partly responsible for the lower raptor collision rates observed at most wind facilities where larger turbines have been installed, but that the main reason

Arcus Consultancy Services South Africa (Pty) Limited Office 220 Cube Workspace, Cnr Long Street and Hans Strijdom Road, Cape Town, 8001 T: +27 21 412 1529 E: [email protected] W: www.arcusconsulting.co.za Registered in South Africa No. 2015/416206/07

is because fewer larger turbines are needed to produce the same energy as smaller turbines. NWCC (2010) does note though that because the transition to larger turbines has largely coincided with a number of other transitions in turbine technology and siting practice, it is difficult to separate the individual effects and thereby determine the degree to which turbine size affects raptor collision rates. It is likely that the level of bird use at the site and the behaviour of the birds at the site are more important factors to consider (than turbine size) when assessing potential risk. For example, raptor fatalities appear to increase as raptor abundance increases (NWCC, 2010) and certain species (e.g., Red-tailed Hawks and Golden Eagles) that forage for prey in close proximity to turbines appear to have increased fatalities, while others like Common Ravens appear to avoid collisions with turbines (NWCC, 2010). Other studies (Barrios & Rodriguez, 2004; Stewart et al. 2007) also found that the size and alignment of turbines and rotor speed are likely to influence collision risk; however, physical structure is probably only significant in combination with other factors, especially wind speed, with moderate winds resulting in the highest risk. In fact, Barrios & Rodriguez (2004) found tower structure to have no effect on mortality, and that mortality may be directly related to abundance for certain species (e.g. Common Kestrel). They concluded that physical structures had little effect on bird mortality unless in combination with other factors. Somewhat conversely, De Lucas et al. (2008) found that turbine height and higher elevations may heighten the risk (taller/higher = higher risk), but that abundance was not directly related to collision risk, at least for Eurasian Griffon Vulture. De Lucas et al. (2008) stated “All else being equal, more lift is required by a griffon vulture over a taller turbine at a higher elevation and we found that such turbines killed more vultures compared to shorter turbines at lower elevations”. Howell et al. (1997) found that the evidence to date from the Altamont Pass did not support the hypothesis that the larger rotor swept area (RSA) (due to increased blade lengths) results in more mortalities. On the contrary it was found that the ratio of smaller to larger turbines rather than RSA was consistent with the mortality ratio, and that it appeared that the mortality occurred on a per-turbine basis, i.e. that each turbine simply presented an obstacle. Barclay et al. (2007) found that diameter of the turbine rotor did not influence the rate of bird or bat fatality, and that the height of the turbine had no effect on bird fatalities per turbine. They stated “Our analysis of the data available from North America indicates that this has had different consequences for the fatality rates of birds and bats at wind energy facilities. It might be expected that as rotor swept area increased, more animals would be killed per turbine, but our analyses indicates that this is not the case. Rotor-swept area was not a significant factor in our analyses. In addition, there is no evidence that taller turbines are associated with increased bird fatalities. The per turbine fatality rate for birds was constant with tower height.” Krijgsveld et al. (2009) found that collision risk of birds with larger multi-MW wind turbines is similar to that with smaller earlier-generation turbines, and much lower than expected based on the large rotor surface and high altitude-range of modern turbines. Smallwood et al. (2013) found that Red-tailed hawk and all raptor fatality rates correlated inversely with increasing wind-turbine size. Everaert (2014) states “Combined with the mortality rates of several wind farms in the Netherlands (in similar European lowland conditions near wetlands or other areas with water), no significant relationship could be found between the number of collision fatalities and the rotor swept area of the turbines. In contrast to more common landscapes, Hötker (2006) also found no significant relationship between mortality rate and the size of wind turbines near wetlands and mountain ridges.” An increase in rotor diameter (i.e. an increase in blade length) will result in a larger Rotor Swept Area (RSA), which can be calculated as the area of the circle, swept by a given rotor diameter. One would initially assume that a larger RSA would mean an increase in the risk of collision. The RSA per WTG for the authorised WTGs at the Kap Vley WEF is 20107 m2, while the proposed new WTG specifications will result in an RSA for each WTG of up to 31416 m2.

However, as can be seen from the above literature survey, most published findings indicate that rotor swept area is not a key factor in the collision risk. Turbine dimensions seem to play an insignificant role in the magnitude of the collision risk in general, relative to other factors (e.g. topography, turbine location, turbine numbers, species abundance and passage rates, morphology and a species’ inherent ability to avoid the turbines), and may only be relevant in combination with other factors. The potential reduction in turbine numbers is likely to be an equally important factor in the overall significance of the collision risk of a project (even if it results in the same or higher combined RSA), potentially offsetting any additional negative risk cause by the change in WTG dimensions.

Kap Vley Pre-Construction Monitoring Activity and abundance of priority species and red data species were generally found to be low on the Kap Vley WEF site after one year of pre-construction monitoring, and overall species diversity was also relatively low. Thorough fieldwork and monitoring did not reveal any key or important avifaunal landscape features or sensitivities (e.g. nest sites) on or within 5 km of the WEF site. Furthermore, the available bird micro-habitats on the WEF site are limited, and there are no important wetlands or rivers on the WEF site. Abundances of small passerines were also found to be low. While the drought conditions experienced during the first two surveys (summer and autumn 2017), may have influenced the results, the third and fourth surveys (winter and spring) were conducted after rainfall in the area. It is unlikely that inter annual variation in bird occurrence would be so substantial so as to significantly alter the findings of this study. This can be said, as historical data sets from the area (as well as other studies done on surrounding proposed projects), did not reveal substantially different findings/conclusions. The Kap Vley WEF site has some of the lowest activity and occurrence of priority species experienced by the specialists, relative to other project sites worked on in South Africa. Passage rates were low (i.e. 0.49 target species per hour) and the level of Verreaux’s’ Eagle activity (0.067 bird per hour) was regarded as very low, and it is unlikely that the development would pose a highly significant risk of turbine collision to this or any other species. During the EIA process for the Kap Vley WEF and as part of the avifaunal impact assessment, a sensitivity mapping exercise found that one turbine (WEA 14) is currently within a high sensitivity area and should be relocated approximately 120 m to the south or 125 m to the south east while turbine WEA 25 may protrude into a high sensitivity area and should be set back approximately 65 m north or 75 m north east to avoid this. These requirements have been added as a condition to the EA and the applicant is committed to moving this turbine out of the high sensitivity area during the micro siting of the final facility layout, based on the amended dimensions of the turbines.

Conclusion The impact assessment as presented in the Avifaunal Specialist Report (Arcus 2018) will not change based on the proposed amendment to increase the rotor diameter, and no additional/new impacts due to the proposed change have been identified. All mitigation measures contained in the report must be included in the Environmental Management Programme and implemented accordingly by the applicant.

Yours sincerely,

Andrew Pearson Avifaunal Specialist

APPENDIX D. 2: BATS

KAP VLEY WIND ENERGY FACILITY EA AMENDMENT REPORT

BAT ASSESSMENT

On behalf of juwi Renewable Energies (Pty) Ltd

August 2019

Prepared By:

Arcus Consultancy Services South Africa (Pty) Limited

Office 220 Cube Workspace Icon Building Cnr Long Street and Hans Strijdom Avenue Cape Town 8001

T +27 (0) 21 412 1529 l E [email protected] W www.arcusconsulting.co.za

Registered in South Africa No. 2015/416206/07

Amendment Application Kap Vley WEF

TABLE OF CONTENTS

1 INTRODUCTION ...... 1

2 METHODOLOGY ...... 1

3 REVIEW ...... 1

4 IMPACT ASSESSMENT ...... 3 4.1 Effect of the Amendment on Current Impacts ...... 3 4.2 Effect of the Amendment on Mitigation Measures ...... 3

5 CONCLUSION ...... 4

6 REFERENCES...... 5

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1 INTRODUCTION juwi Renewable Energies (Pty) Ltd (“juwi”) received environmental authorisation for the Kap Vley Wind Energy Facility (WEF) on 25 October 2018. The applicant is proposing to amend the turbine specifications for the facility, specifically to increase the rotor diameter. The aim of this report is to assess the impact of this change on bats. The rotor diameter will be amended as follows:  Increase the rotor diameter from between 100 m and 160 m, to between 100 m and 200 m (i.e. increase blade length from between 50 m and 80 m to between 50 m and 100 m).

The hub height is currently approved for 80 m to 150 m, and this will not be amended.

2 METHODOLOGY In carrying out this assessment, Arcus conducted a literature review on bats and wind energy impacts with a focus on the relationship between turbine size and bat fatality. The literature review was carried out using the Web of Science® and Google Scholar using the following search terms: bat* OR fatality OR wind energy OR turbine OR wind turbine OR fatalities OR mortality OR mortalities OR kill* OR tower height OR height OR rotor swept zone OR rotor zone OR rotor swept area OR blades OR turbine blades OR influence OR increas* OR trend OR positive OR decreas* OR relation* OR wind farm OR wind energy facility OR carcass* OR chiroptera OR rotor diameter OR correlat* OR size Arcus conducted pre-construction monitoring for the project between March 2017 and February 2018, and used our knowledge of the project and its associated impacts to complete this assessment.

3 REVIEW The issue relevant to this assessment is the impact to bats of amending the size of the turbines at the Kap Vley WEF. Currently, the rotor swept area for each turbine will be 20,107 m2 assuming turbines with blade lengths of 80 m. The amendment would result in an increase of the rotor swept area to 31,416 m2 assuming turbines with blade lengths of 100 m. The minimum and maximum tip heights currently approved will be 70 m and 230 m, using a turbine with a 150 m hub height. These dimensions would change to a minimum and maximum of 50 m and 250 m respectively when using a hub height of 150 m. With an 80 m hub height and blade length of 50 m, the minimum blade tip could extend to 30 m above ground level, and extend to 130 m in the air based on the amendments being applied for. Numerous studies support the hypothesis that taller wind turbines are associated with higher numbers of bat fatalities. Rydell et al. (2010) found a significant positive correlation between bat mortality with both turbine tower height and rotor diameter in Germany. However, there was no significant relationship between bat mortality and the minimum distance between the rotor and the ground. The maximum tower height in their study was 98 m and data on rotor diameter were not given. In addition, there was no relationship between bat fatality and the number of turbines at a wind energy facility. In Greece, Georgiakakis et al. (2012) found that bat fatalities were significantly positively correlated with tower height but not with rotor diameter. In their study, maximum tower height and rotor diameter were 60 m and 90 m respectively. In Minnesota and Tennessee, USA, both Johnson et al. (2003) and Fiedler et al. (2007) showed that taller turbines with a greater rotor swept area killed more bats. The maximum heights of turbines in these two studies were 50 m and 78 m respectively. In Alberta, Canada, bat fatality rates differed

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partly due to differences in tower height but the relationship was also influenced by bat activity (Baerwald and Barclay 2009). For example, sites with high activity but relatively short towers had low bat fatality and sites with low activity and tall towers also had low bat fatality. At sites with high bat activity, an increase in tower height increased the probability of fatality. Maximum turbine height and rotor diameter in this study was 84 m and 80 m respectively. Despite the above support for the hypothesis that taller wind turbines kill more bats, in a review of 40 published and unpublished studies in North America, Thompson et al. (2017) found no evidence that turbine height or the number of turbines influences bat mortality. Berthinussen et al. (2014) also found no evidence of modifying turbine design to reduce bat fatalities. The relationship between bat mortality and turbine size, or number of turbines at a wind energy facility, is therefore equivocal. Turbine size has increased since the above studies were published and no recent data of the relationship between bat fatality and turbine size are available. The maximum size of the turbines in the literature reviewed (where indicated in each study) for this assessment had towers of 98 m and rotor diameters of 90 m. Some towers were as short as 44 m and had blade tips extending down to only 15 m above ground level. It is possible that some bats species, particularly those not adapted to use open air spaces, are being killed at the lower sweep of the turbine blades so having a shorter distance between the ground and the lowest rotor tip point may have a negative impact and potentially place a greater diversity of species at risk. Higher hub heights and longer blades can intrude more into the higher air spaces and possibly have a negative impact on high flying bats such as free-tailed bats. In South Africa, evidence of fatality for species which typically do not forage in open spaces high above the ground, is available from several wind energy facilities (Aronson et al. 2013; Doty and Martin 2012; MacEwan 2016). Although Rydell et al. (2010) did not find a significant relationship between bat mortality and the minimum distance between the rotor and the ground, data from Georgiakakis et al. (2012) suggest that as the distance between the blade tips and the ground increases, bat fatality decreases. It is not known what the impact of the size of turbines proposed for the Kap Vley WEF would be to bats because of a lack of published data from wind energy facilities with turbines of a comparative size. Hein and Schirmacher (2016) suggest that bat fatality should continue to increase as turbines intrude into higher airspaces because bats are known to fly at high altitudes (McCracken et al. 2008; Peurach et al. 2009; Roeleke et al. 2018). Based on unpublished data from 18 such sites Arcus has conducted pre-construction monitoring at, bat activity and species diversity is greater nearer ground level than at height. Therefore, even though bats are recorded at heights that would put them at risk from taller turbines, the proportion of bats that would be at risk might be less. Further, the number of species that might be impacted would decrease because not all bat species use the airspace congruent with the rotor swept area of modern turbines owing to morphological adaptations related to flight and echolocation. Bats that are adapted to use open air space, such as free-tailed and sheath-tailed bats, would be more at risk. In the United Kingdom, both Collins and Jones (2009) and Mathews et al. (2016) showed that fewer species, and less activity, were recorded at heights between 30 m and 80 m compared to ground level. In two regions in France, Sattler and Bontadina (2005) recorded bat activity at ground level, 30 m, 50 m, 90 m and 150 m and found more species and higher activity at lower altitudes. Roemer et al. (2017) found that at 23 met masts distributed across France and Belgium, 87 % of bat activity recorded was near ground level. However, the authors also showed a significant positive correlation between a species preference for flying at height and their collision susceptibility, and between the number of bat passes recorded at height and raw (i.e. unadjusted) fatality counts. In a similar study

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in Switzerland, most bat activity was recorded at lower heights for most species but the European free-tailed bat had greater activity with increasing height (Wellig et al. 2018).

4 IMPACT ASSESSMENT

4.1 Effect of the Amendment on Current Impacts Of the impacts identified in the EIA (July 2018) only mortality of species due to collision with turbine blades or due to barotrauma are relevant to this amendment. The significance of all other identified impacts on bats associated with the development will remain the same as per the EIA. Field data were collected between March 2017 and February 2018 during the pre- construction monitoring. The key finding was that the vast majority of the bat activity, approximately 90%, was recorded in low lying areas of the site, away from proposed turbine positions. Further, at the meteorological mast bat activity was higher at the lower monitoring height. These findings suggest lower risk to bats in the potential rotor swept zone. Therefore, the potential significance of bat mortality was rated as low after mitigation. The proposed amendment would result in an increase in impacts to bats (after mitigation) during the operational phase because of the larger rotor swept area and potential for greater residual impacts.

4.2 Effect of the Amendment on Mitigation Measures There are several mitigation options available to avoid and reduce the potential for bat mortality to occur or to reduce bat mortality. Designing the layout of the project to avoid areas that are more frequently used by bats may reduce the likelihood of mortality and should be the primary mitigation measure. For the Kap Vley WEF, low lying areas should be avoided. This has already been adhered to as all turbines are situated on the low ridges at the site, away from areas of higher bat activity and outside of no-go areas. However, these buffer areas need to be adjusted to account for the new turbine size. Features that were buffered included roosts (either 200 m or 1 km), trees (200 m), NFEPA Rivers (200 m) and drainage lines (50 m). All buffers must be to blade tip and to determine the buffer distances required to ensure that no turbine blades enter the bat buffers, the following formula was used (Mitchell-Jones and Carlin 2014): 푏 = √(푏푑 + 푏푙)2 − (ℎℎ − 푓ℎ)2 Where: bd = buffer distance, bl = blade length, hh = hub height and fh = feature height (zero in this instance) Thus, based on the above, using a turbine with a hub height of 150 m and a blade length of 100 m, the turbine base must be 260 m and 1,090 m away from bat roosts respectively, 260 m away from woodland/trees and 260 m from NFEPA Rivers. The turbine base should also be a minimum of 50 m away from drainage lines regardless of the formula. No turbines fall within these new, updated sensitivity buffers. One turbine is situated approximately 12 m from a drainage line buffer, while this turbine does not need to be relocated, appropriate micro-siting in consultation with the bat specialist is recommended. Even though no turbines fall within bat sensitive areas, increasing evidence suggests that bats actively forage around wind turbines (Cryan et al. 2014; Foo et al. 2017). The installation of turbines in the landscape may alter bat activity patterns, either by increasing activity at height and/or increasing the diversity of species making use of higher airspaces. The greater rotor swept area being proposed as part of this amendment may increase the potential for these interactions. Therefore, there may still be residual impacts after these avoidance measures, and additional mitigation measures may be needed to minimise residual impacts. Turbine design can help to avoid, and hence, reduce residual impacts.

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Since bat activity and species composition tends to be greater and more diverse respectively at lower altitudes, maximising the lower blade tip height is preferable. This could be achieved by having either shorter blades, a higher hub height, or both. However, adjusting the hub height alone would not limit impacts to higher flying species, and a higher hub height would be detrimental to high risk species despite possibly being beneficial to lower flying species. A lower hub height would decrease blade intrusion into higher airspaces and reduce the potential impact to high flying species such as free-tailed bats, but depending on blade length, might increase impacts to lower flying species. It would therefore be preferential, for both high flying and lower flying species, to reduce rotor swept area by having shorter blades. Bats are active at 80 m at the site but there is no information on activity above 80 m. Bats are known to forage much higher than this, with evidence of bat activity at 200 m (Nguyen et al. 2019), 600 m (Fenton and Griffin 1997), and even up to 1000 m above ground level (McCracken et al. 2008). Nguyen et al. (2019) showed that bat activity at 100 m and 200 m was higher than at ground level for the Wrinkle-lipped free-tailed bat, while both Fenton and Griffin (1997) and McCracken et al. (2008) showed that the vertical profile of bat activity can have two peaks; one between the ground and 100 m, and the second between 200 m and 500 m. This could suggest that there may be an ideal height band in which to place wind turbine rotor blades that would limit impacts to bats. However, our current knowledge of bat activity in the aerosphere is too limited to determine this. Notably, this amendment may result in the blade tips reaching 250 m or 230 m above ground level which may coincide with the heights at which free- tailed bats are most active. It is difficult to determine an appropriate turbine size that would reduce impacts to both high and low flying species and as such it is likely that additional residual impacts would occur. Beyond turbine design, more active mitigation to reduce these residual impacts will be needed and ultrasound deterrents and curtailment are two options available. The amendment will result in the likelihood of residual impacts being greater and hence a greater likelihood that deterrents or curtailment will be needed. Curtailment is the most effective way to reduce residual impacts to bats (Arnett and May 2016; Hayes 2019) whereas deterrent technology is still in testing stages and its effect on reducing bat fatality less known (Arnett 2013). The amendment to the turbine specifications may increase the likelihood that curtailment or deterrents will need to be used, especially if a larger rotor swept area is used. To reduce the residual impacts during the operational phase, a smart curtailment approach (e.g. Hayes 2019) should be used which curtails turbines when bats are present by using acoustic monitors installed on wind turbines. In addition, the use of such a system should be based on bat fatality data, collected during the operational phase, using an adaptive management approach. The benefit of this approach as opposed to basing curtailment solely on predicting when bats will be active based on meteorological conditions is that curtailment time could be reduced by approximately 48 % (Hayes 2019). Using smart curtailment does not imply that curtailment will be applied but the technology must be installed to monitor real-time bat activity and be triggered when bats are active around turbines.

5 CONCLUSION Compared to the previous impact assessment undertaken in 2018 it is likely that the amendments to the turbine dimensions proposed for the Kap Vley WEF will increase the current rated impacts to bats, including cumulative impacts. Although the potential significance on bats remains low after mitigation, there is a higher likelihood that additional mitigation during peak activity periods would be required because of the larger blades. The likelihood that the cumulative impacts increase would also be higher.

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The primary mitigation is to avoid impacts which can be achieved through appropriate turbine siting. The buffers have been increased in response to the change in the rotor diameter and no turbines are located within bat sensitive areas. Following this, choosing an appropriate sized turbine can also help to avoid impacts. During the operational phase a smart curtailment approach must be used to reduce any residual impacts.

6 REFERENCES Arnett, E. B., C. D. Hein, M. R. Schirmacher, M. M. P. Huso, and J. M. Szewczak. 2013. Evaluating the Effectiveness of an Ultrasonic Acoustic Deterrent for Reducing Bat Fatalities at Wind Turbines. PloS one 8(6). Arnett, E.B., May, R.F., 2016. Mitigating Wind Energy Impacts on Wildlife: Approaches for Multiple Taxa. Human–Wildlife Interactions: Vol. 10 : Iss. 1 , Article 5. Aronson, J.B., Thomas, A.J., Jordaan, S.L., 2013. Bat fatality at a wind energy facility in the Western Cape, South Africa. African Bat Conservation News 31, 9-12. Baerwald, E.F., Barclay, R.M.R., 2009. Geographic variation in activity and fatality of migratory bats at wind energy facilities. Journal of Mammalogy 90, 1341-1349. Berthinussen, A., Richardson, O.C., Altringham, J.D., 2014. Bat Conservation - Global evidence for the effects of interventions. Pelagic Publishing. Collins, J., Jones, G., 2009. Differences in bat activity in relation to bat detector height: implications for bat surveys at proposed windfarm sites. Acta Chiropterologica 11, 343-350. Cryan, P.M., Gorresen, P.M., Hein, C.D., Schirmacher, M.R., Diehl, R.H., Huso, M.M., Hayman, D.T.S., Fricker, P.D., Bonaccorso, F.J., Johnson, D.H., Heist, K., Dalton, D.C., 2014. Behavior of bats at wind turbines. Proceedings of the National Academy of Sciences 111, 15126-15131. Doty, A.C., Martin, A.P., 2012. Assessment of bat and avian mortality at a pilot wind turbine at Coega, Port Elizabeth, Eastern Cape, South Africa. New Zealand Journal of Zoology, 1- 6. Fiedler, J.K., Henry, T.H., Tankersley, R.D., Nicholson., C.P., 2007. Results of bat and bird mortality monitoring at the expanded Buffalo Mountain Windfarm, 2005, Tennessee Valley Authority, Knoxville, Tennessee. Foo, C.F., Bennett, V.J., Hale, A.M., Korstian, J.M., Schildt, A.J., Williams, D.A., 2017. Increasing evidence that bats actively forage at wind turbines. PeerJ 5, e3985-e3985. Georgiakakis, P., Kret, E., Carcamo, B., Doutau, B., Kafkaletou-Diez, A., Vasilakis, D., Papadatou, E., 2012. Bat fatalities at wind farms in north-eastern Greece. Acta Chiropterologica 14(2), 459-468. Hayes, M., L. Hooton, K. Gilland, C. Grandgent, R. Smith, S. Lindsay, J. Collins, S. Schumacher, P. Rabie, J. Gruver, and J. Goodrich-Mahoney. 2019. A smart curtailment approach for reducing bat fatalities and curtailment time at wind energy facilities. Ecological Applications. Hein, C.D., Schirmacher, M.R., 2016. Impact of wind energy on bats: a summary of our current knowledge. Human–Wildlife Interactions 10(1):19–27. Johnson, G.D., Erickson, W.P., Strickland, M.D., Shepherd, M.F., Shepherd, D.A., Sarappo, S.A., 2003. Mortality of bats at a large-scale wind power development at Buffalo Ridge, Minnesota. The American Midland Naturalist 150, 332-342. MacEwan, K., 2016. Fruit bats and wind turbine fatalities in South Africa. African Bat Conservation News 42.

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Mathews, F., Richardson, S., Lintott, P., Hosken, D., 2016. Understanding the Risk of European Protected Species (Bats) at Onshore Wind Turbine Sites to Inform Risk Management. Report by University of Exeter. pp 127. McCracken, G.F., Gillam, E.H., Westbrook, J.K., Lee, Y.-F., Jensen, M.L., Balsley, B.B., 2008. Brazilian free-tailed bats (Tadarida brasiliensis: Molossidae, Chiroptera) at high altitude: links to migratory insect populations. Integrative and Comparative Biology 48, 107-118. Mitchell-Jones, T., Carlin, C., 2014. Bats and Onshore Wind Turbines Interim Guidance, In Natural England Technical Information Note TIN051. Natural England. Peurach, S.C., Dove, C.J., Stepko, L., 2009. A decade of U.S. Air Force bat strikes. Wildlife Conflicts 3:199–207. Roeleke, M., Bumrungsri, S., Voigt, C.C., 2018. Bats probe the aerosphere during landscape-guided altitudinal flights. Mammal Review 48, 7-11. Roemer, C., Disca, T., Coulon, A., Bas, Y., 2017. Bat flight height monitored from wind masts predicts mortality risk at wind farms. Biological Conservation 215, 116-122. Rydell, J., Bach, L., Dubourg-Savage, M.-J., Green, M., Rodrigues, L., Hedenström, A., 2010. Bat mortality at wind turbines in northwestern Europe. Acta Chiropterologica 12, 261-274. Sattler, T., Bontadina, F., 2005. Grundlagen zur ökologischen Bewertung von zwei Windkraftgebieten in Frankreich aufgrund der Diversität und Aktivität von Fledermäusen. Unveröffentlichter Kurzbericht. SWILD, Zürich im Auftrag von Megawatt Eole, Stuttgart, 23 Seiten. Thompson, M., Beston, J.A., Etterson, M., Diffendorfer, J.E., Loss, S.R., 2017. Factors associated with bat mortality at wind energy facilities in the United States. Biological Conservation 215, 241-245. Wellig, S.D., Nusslé, S., Miltner, D., Kohle, O., Glaizot, O., Braunisch, V., Obrist, M.K., Arlettaz, R., 2018. Mitigating the negative impacts of tall wind turbines on bats: Vertical activity profiles and relationships to wind speed. PloS one 13, e0192493.

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APPENDIX D. 3: VISUAL

Quinton Lawson Bernard Oberholzer Architect Landscape Architect 8 Blackwood Drive, Hout Bay 7806 PO Box 471 Stanford 7210 [email protected] [email protected] Tel. 083 309 3338 Tel. 028 341 0264

01 August 2019 Juwi Renewable Energies (Pty) Ltd 24th Floor Metropolitan Centre 7 Walter Sisulu Avenue, Foreshore Cape Town 8001

Attention: Steyn de Vos Project Development Manager

Visual Assessment Amendment: Revised rotor diameter for proposed Kap Vley Wind Energy Facility (WEF), near Kleinzee, Northern Cape

Juwi Renewable Energy is planning on changing the rotor diameter of the wind turbines that will be installed at their Kap Vley WEF in the Northern Cape from the previous 100-160m diameter to a proposed 100-200m diameter. An Environmental Authorisation (EA) has already been issued to Juwi and the Visual Specialists have therefore been asked to comment on the visual implications of the technical change. The information provided indicates that all other technical parameters of the wind turbines and of the site layout remain unchanged. As the visual specialists of the original Visual Impact Assessment (VIA) for the Kap Vley WEF in 2018, we have referred to our previous VIA Report, where a viewshed of the proposed turbines was prepared based on a hub height of 150m. From our experience we have found that minor changes to the hub height and rotor diameter have little effect on visibility of the turbines and on the extent of the viewshed, particularly at distances beyond 5 km. In addition, any changes to the visual photomontages would be so marginal as to be imperceptible. It is therefore the view of the visual specialists that the proposed change in the rotor diameter will not have a bearing on the overall visual impact significance ratings, nor the cumulative visual impacts assessed in the previous VIA of 2018. Provided that the visual mitigations listed in the original visual impact study, and inputs to the EMPr, including post-construction rehabilitation of the site, are adhered to, the previous Environmental Authorisation for the Kap Vley project should still be valid, and no further visual mitigation is considered necessary.

Prepared by Bernard Oberholzer, Pr.L.Arch. SACLAP Quinton Lawson, Pr.Arch. SACAP

Quinton Lawson Pr.Arch. B.Arch. SACAP • Bernard Oberholzer Pr.L.Arch. B.Arch. MLA. SACLAP

APPENDIX D. 4: NOISE

Name: Morné de Ja ger Cell: 082 565 405 9 EͲmail: morne@me nco.co.za Date: 1August 20 19 Ref: Kap Vley WE F juwi Renewable Energies (Pt y)Ltd 24t hFloor Met ropolitan Ce ntre 7Walter Sisulu Avenue, Fore shore, Cape Town ͼ 800 1 Sou thAfrica Att ention to :Pr oject Develo pment Man ager Mr.Stey nde Vos Dea rSir SPE CIALIST STU DY: NOISE IMPACT ASS ESSMENT: PROPOSED KAP VLEY WIND ENERG Y FACILITY NEA ROF KOMA GGAS: CHA NGE OF WIN DTURBINE SPECIFICATI ONS The above Ͳmen tioned issu e as well as report CSIR ͲJKVWE F/ENIA/2017 09 ͲRev 4/S hort is of rele vance. Ico nducted an Environmen tal Noise Im pact Assess ment (ENIA) during 201 7for the pr oposed Kap Vley Wind Ener gyFacility (WEF), with on elayout ev aluated for thefinal rep ort. With the input data as used, this as sessment in dicated tha t the propo sed project will have a noise impacct of a low sign ificance on the identi fied Noise Sensitive Development s (NSDs) in the area during the con struction ph ase and, a noise impact of low sig nificance fo r the operat ional phase s using the Acci ona AW125 wind turbin e(for all wi ndspeeds). This wind tu rbine has amaximum so und power gen eration level of 108.4 dB Aand the pr ojected max imum noise levels would be less tha n45 dBA at the closest NSD. The wind energ ymarket is fast changin gand adaptiing to new technologies as well as site specific con straints. Opt imizing the technical sp ecifications can add valu ethrough, forexample, minimizing envi ronmental impact and maximizing energy yiel d. As such the develop er has been evaluating sev eral turbine models, ho wever the sel ection will only be finali zed at alat erstage onc ethe most opti mal wind tu rbine are ide ntified (fact ors such as meteorologic aldata, pric eand financi ngoptions, gua rantees and maintenanc ecosts, etc. must be con sidered). Bec ause of the availability ofmore opti mal or efficie ntwind turb ines, the de veloper of theKap Vley WE F is conside ring changi ng the wind turbine sp ecifications. As the spe cifications of the final sele ction are no tyet defined ,this revie wwill evaluat eapotentia lworst Ͳcase scenario, co nsidering a win d turbine wi th a sound power emi ssion level of 108.5 dB A. The main change wo uld be the pot ential rotor diameter of 200m as defi ned in the ta ble below. Rotor Hub Height Overall Per Tur bine Nu mber of Diamete r Capacity Capacit y Tur bines Curr ent approved 100 –16 0m 80 – 150 m 300 MW Not spe cified 20 Ͳ45 New ly Proposed 100 –20 0m 80 – 150 m 300 MW Not spe cified 20 Ͳ45

Envir oAcoustic Rese arch cc ൟ Reg. No: B2011/045 642/23 Tel: 012 004 0362 ൟ Fax: 086 621 0292 ൟ Email: info@ear es.co.za PO Box 2047, Garsf ontein East, 00 60ൟ www.ear es.co.za Me mbers: Mde Ja ger, JMare, PErasmus Your Env ironmental Ac oustic Connecti on

The layout will notchange. It sh ould be not edthat win dturbine sp ecifications such as hub height and rotor diamet ergenerally do not impact onthe sound power emis sion levels ofaspecific wind turbine model, with the sound pow er emission levels bein g within 1 dB for diffe rent hub heights (for the same wi nnd turbine mo del). Therefo re, consideri ng the locat ion of the wind turbine sand the potential pred iicted noise leve ls, it is my opinion that the change will not in crease or ch ange the si gnificance of the noise imp act. Afull no ise impact assessment with new mo deling will notbe requir edand the fi ndings and reco mmendatio ns as contai ned in the previous do cument (rep ort CSIR ͲJKV WEF/ENIA/ 201709 ͲRev 4/S hort) will still be valid. Sho uld you req uire any furt her details, orhave any additional quuestions, pl ease do not hesitate to call meon the above numbe rs. You rsFaithfully, Mor né de Jager Envi ro ͲAcoustic Research cc

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APPENDIX D. 5: HERITAGE

ASHA Consulting (Pty) Ltd 40 Brassie Street Lakeside 7945

28 August 2019

Minnelise Levendal CSIR P.O. Box 320 Stellenbosch 7599 By email: [email protected]

Dear Minnelise

RE: AMENDMENT OF THE AUTHORISATION FOR THE PROPOSED KAP VLEY WIND ENERGY FACILITY NEAR KOMAGGAS, NORTHERN CAPE DEA REF. NO.: 14/12/16/3/3/2/1046 SAHRIS CaseID.: 11654

Thank you for notifying me of the proposed amendment to the authorisation for the Kap Vley Wind Energy Facility. I note that there is no change to the layout or hub height but that larger rotors are being applied for. The original authorisation allowed for a rotor diameter of 100 to 160 m, but the amendment seeks to increase this to a range of 100 – 200 m.

Given that it is only an increase in rotor diameter there will be no associated changes in the impacts to either archaeological or palaeontological resources. The only potential impact change would be to visual impacts to the cultural landscape. In this regard, reference is made to the comment of Bernie Oberholzer and Quinton Lawson (the visual impact assessors) who note that increases in turbine height have minimal effect on the visibility of the turbines. This means that once turbines are present in a landscape their size is only a minor consideration. Given that Oberholzer and Lawson are of the opinion that the proposed increased rotor diameter will have a negligible effect on the visual impact assessment, the present writer finds that there must similarly be a negligible effect on the impacts to the cultural landscape.

It is thus concluded that:  No meaningful changes to the assessed impacts will occur;  No changes to the ratings made in the original EIA are required; and  The proposed increased rotor diameter can be supported from a heritage point of view.

It is recommended that SAHRA support the proposed amendment application.

Yours sincerely

Jayson Orton

APPENDIX D. 6: SPECIALIST DECLARATIONS OF INDEPENDENCE

I. SPECIALIST INFORMATION 2. Specialist C,ompany Name: ASHA Consultinq Pty) Ltd B-BBEE Contribution level (indicate 1 4 Percentage 0 to B or non-compliant) Procuremenl recoqnition Specialist name: Dr Jayson Orton Specialist Qualilications: D.Phil (Archaeoloqy, Oxford, UK); MA (Archaeology, UCT) Professional ASAPA CRM Section Member No 233 aff iliation/registration: APHP member No 043 Physical address: 40 Brassie Street, Lakeside, 7945 Postal address: 40 Brassie Street, Lakeside Postal code: 7945 Cell: 0832723225 Telephone: 0217881125 Fax: nla E-mail: [email protected] 3.

DECLAR,ATION BY THE SPECIALIST 'tr#iiOni r, 0F7ed ,decrarethar-

I act as the independent specialist in this application;

I will perform the work relating to ihe application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

I declare that therc are no circumstances that may compromise my objectivity in performing such work;

I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity;

I will comply witfr the Act, Regulations and all other applicable legislation;

a I have no, and will not engage in, conflicting interesb in the undertaking of the activity; I undertake to disclose to the applicant and the competent authority all material informalion in my possession that reasonably has or may have the ptential of influencing - any decision to be taken with rcspect to ttte application by the competent authorig; and - the objectivity of any report, plan or document to be prepared by myself for submission to the mmpetent authority; all the pariiculars fumished by me in this form are true and conect; and

a I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.

CoNi ttr7

,l * t"'-]:'''''i Date

Details of Specialist, Declaration and UndertakinE Under Oath page 2 ot 3l

t44 b 5. UNDERTAKINGUNDEROATH/AFFIRMATION

, swear under oath / affirm that all the infonnation submitted or to be submitted for the puposes of this is true and coffect.

Signature of

,L_to_Lot4 .

Signature of the Commlssioner of Oaths // A",44- '1a:? KIFSTENHOF SAPS

20t9 -t0- I 6

oetails ofSpecialist, Declaration and Undertaking Under Oath Page 3 of 3